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Sulfur dioxide in the Wollongong/Port Kembla area: a historical review of ambient atmospheric levels, major emission sources and their regulation

Peter Bloem University of Wollongong

Bloem, Peter, Sulfur dioxide in the Wollongong/Port Kembla area: a historical review of ambient atmospheric levels, major emission sources and their regulation, Master of Environmental Science (Research) thesis, School of Earth and Environmental Sciences, University of Wollongong, 2007. http://ro.uow.edu.au/theses/2561

This paper is posted at Research Online.

SULFUR DIOXIDE IN THE WOLLONGONG/PORT KEMBLA AREA: A HISTORICAL REVIEW OF AMBIENT ATMOSPHERIC LEVELS, MAJOR EMISSION SOURCES AND THEIR REGULATION

A thesis submitted in (partial) fulfilment of the requirements for the award of the degree

Master of Environmental Science (Research)

from

UNIVERSITY OF WOLLONGONG

by

PETER BLOEM, BSc (Hons)

School of Earth and Environmental Sciences 2007 Certification

I, Peter Bloem, declare that this thesis, submitted in partial fulfilment of the requirements for the award of Masters of Environmental Science (Research), in the School of Earth and Environmental Sciences, University of Wollongong, is wholly my own work unless otherwise referenced or acknowledged. The document has not been submitted for qualifications at any other academic institution.

Peter Bloem 23 November 2007

2 Table of Contents

Certification……...... 2 Table of Contents...... 3 Table of Figures ...... 4 Table of Tables …………………………………………………………………………………………9 List of Abbreviations ...... 10 Abstract …………… ...... 11 Acknowledgments ...... 12 1. Introduction...... 13 1.1 General...... 13 1.2 Key Questions ...... 15 1.3 Thesis outline ...... 15 1.4 Study area and monitoring locations ...... 16 1.5 Methods for Data Collection, Analysis & Quality Control...... 23 2. Background ...... 25 2.1 Sulfur dioxide - its effects and environmental fate...... 25 2.2 Sources of Sulfur Dioxide...... 30 2.3 Monitoring sulfur dioxide concentrations in the atmosphere...... 36 2.4 Ambient Air Quality Goals for Sulfur Dioxide...... 39 2.5 Primary Production of Copper ...... 43 2.6 Sulfur dioxide emissions and controls from the primary production of copper...... 52 2.7 Effects of Meteorology on Ambient Atmospheric Sulfur Dioxide Concentrations...... 57 2.8 Pollution Dispersion from Tall Stacks ...... 67 2.9 Summary of Background...... 73 3. Results and Discussion...... 75 3.1 Overview ...... 75 3.2 Limitations and assumptions in data analysis ...... 77 3.3 Emission History 1907 to 1965...... 95 3.3.1 Smelter Operations - Sulfur Dioxide Emissions & Controls...... 95 3.3.2 Environmental Regulation...... 109 3.3.3 Ambient Atmospheric Sulfur Dioxide Concentrations...... 116 3.3.4 Summary of information 1907 to 1965 ...... 134 3.4 Emission History 1966 to 1988...... 136 3.4.1 Smelter Operations - Sulfur Dioxide Emissions & Controls...... 136 3.4.2 Environmental Regulation...... 139 3.4.3 Ambient Atmospheric Sulfur Dioxide Concentrations...... 147 3.4.4 Summary of Information from 1966 to 1988 ...... 158 3.5 Emission History 1989 to 1995...... 160 3.5.1 Smelter Operations - Sulfur Dioxide Emissions & Controls...... 160 3.5.2 Environmental Regulation...... 169 3.5.3 Ambient Atmospheric Sulfur Dioxide Concentrations...... 175 3.5.4 Summary of information 1989 to 1996 ...... 197 3.6 Emission History 1996 to 2006...... 198 3.6.1 Smelter Operations - Sulfur Dioxide Emissions & Controls...... 198 3.6.2 Environmental Regulation...... 207 3.6.3 Ambient Atmospheric Sulfur Dioxide Concentrations...... 216 3.6.4 Summary of information 1996 to 2006 ...... 233 3.7 General Discussion...... 234 4. Conclusions and Recommendations ...... 241 4.1 Conclusions ...... 241 4.2 Recommendations ...... 246 References …………...... 249 Appendix 1 Copy of Database of Ambient Sulfur Dioxide Monitoring Data and EPA Environment Protection Licence (dated 2002) for Port Kembla Copper Pty, Bluescope Steel (Port Kembla Steelworks) and Orica...... 261

3 Table of Figures

Figure 1 Map showing study area location. The extent of the Wollongong Local Government Area is shown (pink)...... 17 Figure 2 Map showing locations of Sulfur Dioxide Monitors, Major Points of Interest and Geographical Zones in the Wollongong area (see Tables 1 and 2 for details)...... 21 Figure 3 Map showing locations of Sulfur Dioxide Monitors, Major Points of Interest and Geographical Zones in the Port Kembla area (see Tables 1 and 2 for details)...... 22 Figure 4 Summary of National Sulfur Dioxide Emissions 2005/2006 (from NPI, 2007) ...... 31 Figure 5 Summary of NSW Sulfur Dioxide Emissions 2005/2006 (from NPI, 2007)...... 33 Figure 6 Summary of Wollongong Local Government Area Sulfur Dioxide Emissions 2005/2006 (from NPI, 2007)...... 34 Figure 7 Typical Reverberatory Furnace (from Biswas and Davenport, 1980)...... 46 Figure 8 Typical Blast Furnace Operation (from Biswas and Davenport, 1976)...... 47 Figure 9 Noranda Reactor (from Biswas and Davenport, 1994) ...... 48 Figure 10 Pierce-Smith Converter for producing blister copper from copper matte (from Biswas and Davenport, 1994)...... 49 Figure 11 Mitsubishi Process for continuous converting (From Biswas & Davenport, 1976) ...... 51 Figure 12 Relative Positions of the Pierce Smith Converter for Charging, Blowing and Skimming. Note the gap between the collection hood and converter during charging and skimming operations (from Biswas and Davenport, 1994)...... 56 Figure 13 Port Kembla Climate Data (From BoM, 2007)...... 59 Figure 14 Formation of a sea breeze (from Sturman et al, 2006)...... 60 Figure 15 Annual Windroses for Port Kembla based on data from the Port Kembla Signal Station for 1957 to 1976 (from BoM, 2007)...... 64 Figure 16 Idealised patterns of stack plume behaviour. The lines on the left figures represents the dry adiabatic lapse rate (dotted) and environmental lapse rate (solid). (From Zanetti et al, 2003)...... 69 Figure 17 Port Kembla Smelter stack plume under fanning conditions in the early morning. Looking north from Shellharbour. Photodate 2000. Photo courtesy of DECC...... 70 Figure 18 Port Kembla Smelter stack plume under looping conditions, looking north from Primbee. Photodate circa 1980. Photo courtesy of DECC...... 70 Figure 19 Sea breeze fumigation. The lines on the left figures represent the dry adiabatic lapse rate (dotted) and environmental lapse rate (solid). (From CASANZ, 1999)...... 72 Figure 20 View of Steel works looking northeast from Cringila. Circa 1961 (Photo courtesy of DECC) ...... 79 Figure 21 View of Steelworks looking west along Christy Drive, Inner Harbour. A = Sinter Plant. B = SMERP. C = Ironmaking area. Photodate November 2007 (Photo by author)...... 80 Figure 22 Tallawarra Power Station. Photodate circa 1962. From the collections of the Wollongong City Library and Illawarra Historical Society...... 82 Figure 23 View of Orica acid works from Foreshore Road, Port Kembla. Photodate November 2007 (Photo by author)...... 84 Figure 24 Terrain effects on wind flow (from Sturman et al, 2006) ...... 93 Figure 25 Distribution of hourly average sulfur dioxide levels versus wind direction at EPA MAQS at Warrawong (2000 to 2003)...... 94 Figure 26 Incomplete Stack and water tank of the Australian Smelting Corporation. Photodate 1910. From the collections of the Wollongong City Library and Illawarra Historical Society...... 99 Figure 27 Township of Port Kembla shortly after the smelter commenced operation. Looking east along Wentworth Street towards Hill 60. Photodate 1910. Note the main smelter stack in far left of photograph. From the collections of the Wollongong City Library and Illawarra Historical Society...... 100 Figure 28 Early converters used by the ERS. Photodate early 1900s. From the collections of the Wollongong City Library and Illawarra Historical Society...... 101

4 Figure 29 Aerial view of Port Kembla industrial complex (looking southeast). Photodate circa 1920s. A= ERS works, B = Australian Fertlisers Ltd, C= Metal Manufacturers, D= Incomplete stack and reservoir of the Australian Smelting Corporation. E= Ulladulla Silica Brick Company (Later Newbolds General Refractories Ltd). From the collections of the Wollongong City Library and Illawarra Historical Society...... 102 Figure 30 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Port Kembla Fire Station, Military Road, Port Kembla, 1957 to 1961 (values in pphm)...... 118 Figure 31 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Terescoa Lane, Port Kembla, 1959 to 1960 (values in pphm)...... 118 Figure 32 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Third Avenue, Port Kembla, 1957 to 1961 (values in pphm)...... 119 Figure 33 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Corner of Parkes & Cowper Streets, Port Kembla, 1957 to 1961 (values in pphm).....119 Figure 34 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Somme Street, Port Kembla, 1959 to 1961 (values in pphm)...... 120 Figure 35 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Jubilee Street, Port Kembla, 1958 to 1961 (values in pphm)...... 120 Figure 36 Monthly Average and Highest Daily Average sulfur dioxide concentrations for James Avenue, Primbee, 1959 to 1961 (values in pphm)...... 121 Figure 37 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Lake Heights Road, Lake Heights, 1959 to 1961 (values in pphm)...... 121 Figure 38 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Flagstaff and Lake Heights Rd, Warrawong, 1958 to 1960 (values in pphm)...... 122 Figure 39 Looking east along Military Rd , Port Kembla. Note the low level (fugitive) emissions from the smelting buildings. Photodate circa 1916. From the collections of the Wollongong City Library and Illawarra Historical Society...... 124 Figure 40 Looking east along Wentworth Street Port Kembla. Note smelter stack emissions. Photodate circa 1920s. From the collections of the Wollongong City Library and Illawarra Historical Society...... 124 Figure 41 Aerial view of Port Kembla. Looking north towards Port Kembla Harbour. Note the plume extending from the main stack at ERS under a prevailing north easterly wind. Photodate circa 1927. From the collections of the Wollongong City Library and Illawarra Historical Society...... 125 Figure 42 Map of Port Kembla downwind of ERS showing Areas A, B and C used in Bell(1963) health study (from Bell & Sullivan, 1963)...... 129 Figure 43 Aerial photograph of Port Kembla 1937. From the collection of the University of Wollongong, School of Earth and Environmental Sciences...... 132 Figure 44 Aerial photograph of Port Kembla 1938. From the collection of the University of Wollongong, School of Earth and Environmental Sciences...... 133 Figure 45 Aerial photograph of Port Kembla 1948. From the collection of the University of Wollongong, School of Earth and Environmental Sciences...... 133 Figure 46 Low level (fugitive) emissions from the ERS smelter buildings. Photodate Circa 1977. Photograph courtesy of DECC...... 137 Figure 47 Fugitive emissions during matte charging operations at the Pierce Smith converters. Photodate 1981. Photograph courtesy of DECC...... 137 Figure 48 Sulfur dioxide traverse in vicinity of Tallawarra Power Station during 1984 with elevated readings attributed to the copper smelter at Port Kembla (From CSIRO (1984))...... 150 Figure 49 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Port Kembla Fire Station, Military Road, Port Kembla, 1970 to 1978 (values in pphm)...... 151 Figure 50 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Warrawong Baby Health Centre, Warrawong, 1980 to 1982 (values in pphm)...... 152 Figure 51 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Blaxland & Flagstaff Rd, Warrawong, 1972 to 1988 (values in pphm)...... 152 Figure 52 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Wollongong Council Chambers, Wollongong, 1973 to 1988 (values in pphm) ...... 153 Figure 53 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Wollongong Technical College, Wollongong, 1973 to 1979 (values in pphm)...... 153 Figure 54 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Flagstaff Road Warrawong, 1976 to 1979 (values in pphm)...... 154

5 Figure 55 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Tongarra Road, Albion Park, 1983 to 1998 (values in pphm) ...... 154 Figure 56 Maximum 1 hour sulfur dioxide concentrations for Port Kembla Fire Station, Military Road, Port Kembla, 1972 to 1978 (values in pphm)...... 156 Figure 57 Maximum 1 hour sulfur dioxide concentrations for Warrawong Baby Health Centre, Warrawong, 1980 to 1982 (values in pphm) ...... 157 Figure 58 Maximum 1 hour sulfur dioxide concentrations for Tongarra Road. Albion Park, 1983 to 1988 (values in pphm) ...... 157 Figure 59 View looking north along smelter aisle at PKC. Photodate 1994. Note the fumes from the open air ladle used to transport molten matte from the Noranda Reactor to the Pierce Smith Converters. Photograph courtesy of DECC...... 167 Figure 60 Fugitive emissions from the operation of the Pierce Smith converters. Note the gas hoods installed in an attempt to control converter emissions during blowing. Photodate 1994. Photograph courtesy of DECC...... 167 Figure 61 Brownspot fallout on concrete driveway at Port Kembla. Photodate 1993. Photograph courtesy of DECC ...... 168 Figure 62 Close up of same fallout. Photodate 1993. Photograph courtesy of DECC...... 168 Figure 63 Monthly Average sulfur dioxide concentrations for Port Kembla Fire Station, 1994 to 1995 (values in pphm)...... 177 Figure 64 Maximum 1 hour sulfur dioxide concentrations for Port Kembla Fire Station, 1994 to 1995 (values in pphm)...... 178 Figure 65 Maximum 10 minute sulfur dioxide concentrations for Port Kembla Fire Station, 1994 to 1995 (values in pphm) ...... 178 Figure 66 Monthly Average sulfur dioxide concentrations for Saint Patrick’s School Port Kembla, 1992 to 1995 (values in pphm) ...... 179 Figure 67 Maximum 1 hour sulfur dioxide concentrations for Saint Patricks School Port Kembla, 1992 to 1995 (values in pphm) ...... 179 Figure 68 Maximum 10 minute sulfur dioxide concentrations for Saint Patricks School Port Kembla, 1992 to 1995 (values in pphm) ...... 180 Figure 69 Monthly Average sulfur dioxide concentrations for Primbee Public School, 1989 to 1995 (values in pphm)...... 180 Figure 70 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Primbee Public School, 1989 to 1995 (values in pphm) ...... 181 Figure 71 Monthly Average sulfur dioxide concentrations for Port Kembla Hospital, Port Kembla, 1989 to 1995 (values in pphm) ...... 181 Figure 72 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Port Kembla Hospital, 1989 to 1995 (values in pphm)...... 182 Figure 73 Monthly Average sulfur dioxide concentrations for Warrawong Baby Health Centre, 1989 to 1995 (values in pphm)...... 182 Figure 74 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Warrawong Baby Health Centre, 1989 to 1995 (values in pphm) ...... 183 Figure 75 Monthly Average and Highest Daily concentrations for King and Wattle St, Warrawong, 1989 to 1990 (values in pphm) ...... 183 Figure 76 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for King and Wattle St, Warrawong, 1989 to 1990 (values in pphm)...... 184 Figure 77 Monthly Average and Highest Daily concentrations for Blaxland and Flagstaff St, Warrawong, 1989 to 1991 (values in pphm) ...... 184 Figure 78 Monthly Average and Highest Daily concentrations for Kemblawarra Public School, 1989 to 1990 (values in pphm)...... 185 Figure 79 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Kemblawarra Public School , 1989 to 1990 (values in pphm)...... 185 Figure 80 Monthly Average sulfur dioxide concentrations for Steelhaven, 1989 to 1995 (values in pphm) ...... 186 Figure 81 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Steelhaven, 1989 to 1995 (values in pphm)...... 186 Figure 82 Monthly Average sulfur dioxide concentrations for Coniston, 1992 to 1995 (values in pphm)...... 187 Figure 83 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Coniston, 1992 to 1995 (values in pphm)...... 187

6 Figure 84 Monthly Average sulfur dioxide concentrations for Wollongong Showground, 1992 to 1995 (values in pphm)...... 188 Figure 85 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Wollongong Showground, 1992 to 1995 (values in pphm) ...... 188 Figure 86 Monthly average and highest daily sulfur dioxide concentrations for Auburn St, Wollongong, 1989 to 1991 (values in pphm)...... 189 Figure 87 Monthly Average sulfur dioxide concentrations for Windang, 1992 to 1995 (values in pphm)...... 189 Figure 88 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Windang, 1992 to 1995 (values in pphm)...... 190 Figure 89 Monthly Average sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1989 to 1996 (values in pphm)...... 190 Figure 90 Highest Daily sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1989 to 1996 (values in pphm)...... 191 Figure 91 Maximum 1 hour sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1989 to 1996 (values in pphm)...... 191 Figure 92 Emissions from PKC Acid Plant Stack. Photodate 2000. Photograph courtesy of DECC ...... 204 Figure 93 Port Kembla Copper Smelter (looking east from Police Station). A = Acid Plant stack, B = Smelter building roof vents, C = Smelter building roof ventilators, D = MIC Cooling Water Tower and E = Main Stack. Photodate 2002. (Photo courtesy of DECC) ...... 205 Figure 94 Port Kembla Copper Smelter (looking north west from main stack). A = Main stack, B = Acid Plant stack, C = acid plants, D = copper billet casting area. Photodate 2008. (Photograph by author)...... 206 Figure 95 Monthly Average sulfur dioxide concentrations for Port Kembla Fire Station, 2000 to 2003 (values in pphm)...... 218 Figure 96 Maximum 1 hour sulfur dioxide concentrations for Port Kembla Fire Station, 2000 to 2003 (values in pphm)...... 219 Figure 97 Maximum 10 minute sulfur dioxide concentrations for Port Kembla Fire Station, 2000 to 2003 (values in pphm) ...... 219 Figure 98 Monthly Average sulfur dioxide concentrations for Saint Patrick’s School Port Kembla, 1989 to 2003 (values in pphm) ...... 220 Figure 99 Maximum 1 hour sulfur dioxide concentrations for Saint Patricks School Port Kembla, 1989 to 2003 (values in pphm) ...... 220 Figure 100 Maximum 10 minute sulfur dioxide concentrations for Saint Patricks School Port Kembla, 1989 to 2003 (values in pphm) ...... 221 Figure 101 Monthly Average sulfur dioxide concentrations for Old Port Kembla Primary School, 2000 to 2003 (values in pphm)...... 221 Figure 102 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Old Port Kembla Primary School, 2000 to 2003 (values in pphm)...... 222 Figure 103 Monthly Average sulfur dioxide concentrations for Primbee Public School, 2000 to 2003 (values in pphm)...... 222 Figure 104 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Primbee Public School, 2000 to 2003 (values in pphm) ...... 223 Figure 105 Monthly Average sulfur dioxide concentrations for Port Kembla Hospital, Port Kembla, 2000 to 2003 (values in pphm) ...... 223 Figure 106 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Port Kembla Hospital, 2000 to 2003 (values in pphm)...... 224 Figure 107 Monthly Average sulfur dioxide concentrations for Warrawong Baby Health Centre, 2000 to 2003 (values in pphm)...... 224 Figure 108 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Warrawong Baby Health Centre, 2000 to 2003 (values in pphm) ...... 225 Figure 109 Monthly Average sulfur dioxide concentrations for Steelhaven, 2000 to 2003 (values in pphm) ...... 225 Figure 110 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Steelhaven, 2000 to 2003 (values in pphm)...... 226 Figure 111 Monthly Average sulfur dioxide concentrations for Coniston, 2000 to 2003 (values in pphm)...... 226

7 Figure 112 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Coniston, 2000 to 2003 (values in pphm)...... 227 Figure 113 Monthly Average sulfur dioxide concentrations for Wollongong Showground, 2000 to 2003 (values in pphm)...... 227 Figure 114 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Wollongong Showground, 2000 to 2003 (values in pphm) ...... 228 Figure 115 Monthly Average sulfur dioxide concentrations for Windang, 2000 to 2003 (values in pphm)...... 228 Figure 116 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Windang, 2000 to 2003 (values in pphm)...... 229 Figure 117 Monthly Average sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1996 to 2006 (values in pphm)...... 229 Figure 118 Highest Daily sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1996 to 2006 (values in pphm)...... 230 Figure 119 Maximum 1 hour sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1996 to 2006 (values in pphm)...... 230 Figure 120 Annual average sulfur dioxide concentrations for Port Kembla Fire Station from 1957 to 2003 (values in pphm) ...... 237 Figure 121 Monthly average sulfur dioxide concentrations for Port Kembla Fire Station from 1957 to 2003 (values in pphm) ...... 239

8 Table of Tables

Table 1 Table of sulfur dioxide monitor locations used in the Wollongong/Port Kembla area between 1957 and 2006...... 18 Table 2 Major points of interest used in this study...... 20 Table 3 Sulfur Dioxide Conversion Factor ( µg/m 3 (0 o C) to pphm) ...... 23 Table 4 Top 12 industry sources in Australia which emit sulfur dioxide in 2005/2006 (from NPI, 2007) ...... 32 Table 5 Summary of Annual Loads of Sulfur Dioxide from Bluescope Steel, Port Kembla Copper and Orica Pty Ltd for the period 1999 to 2006 (from NPI, 2007)...... 35 Table 6 Ambient air quality standards/guidelines for sulfur dioxide (from NEPC, 2004)...... 41 Table 7 Adopted air quality standards/guidelines for sulfur dioxide for the purposes of this study...... 43 Table 8 Typical Comparative Sulfur Dioxide Gas Strengths (from George and Taylor, 1981) ...... 53 Table 9 Percentage Frequency of Calms at Bellambi AWS (Source BoM, 2007) ...... 63 Table 10 Percentage Frequency of Calms at Albion Park AWS (Source BoM, 2007)...... 63 Table 11 Inventory of annual sulfur dioxide emissions (tonnes/year) from the Wollongong – Port Kembla Pollution Control Study (SPCC, 1986b)...... 78 Table 12 Summary of copper production data (blister (from concentrates), anode, refined) for the Port Kembla smelter for various years 1911 to 1990 (Compiled from various sources) and estimated sulfur dioxide load...... 86 Table 13 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1958 to 1960. All values in pphm...... 117 Table 14 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1970 to 1988. All values in pphm...... 148 Table 15 Plume travel times (minutes) to SCL monitoring stations from the main smelter stack (from Hyde, 1992)...... 165 Table 16 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1989 to 1996. All values in pphm...... 176 Table 17 Copper production from raw feed (copper concentrates and scrap) for various periods 1981 to 1993...... 193 Table 18 ERS Stack Sulfur Emissions Data (From Kaybond, 1988)...... 195 Table 19 PKC Anode Production data 2000 to 2003 (pers comm Ian Wilson- PKC)...... 201 Table 20 PKC Sulfur Dioxide Load Emission Data 1999 to 2004 (NPI, 2007) ...... 202 Table 21 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1996 to 2006. All values in pphm...... 217 Table 22 Changes in Annual Average Sulfur dioxide in the four geographical zones between 1958 and 2006...... 236

9 List of Abbreviations

BoM Bureau of Meteorology (Commonwealth) CASANZ Clean Air Society of Australia and New Zealand DEC Department of Environment and Conservation (NSW) DECC Department of Environment and Climate Change (NSW) EC European Commission EPA Environment Protection Authority (NSW) EPHC Environment Protection and Heritage Council (Australia) ERS The Electrolytic Refining and Smelting Company of Australia Pty Ltd glc ground level concentration MAQS Metropolitan Air Quality Station MIC Mitsubishi Continuous Converter NEPC National Environment Protection Council NEPM National Environment Protection Measure NPI National Pollutant Inventory (Commonwealth) PKC Port Kembla Copper Ltd ppm parts per million pphm parts per hundred million PRP Pollution Reduction Program SCL Southern Copper Ltd SPCC State Pollution Control Commission (NSW) SO 2 Sulfur dioxide USEPA United States of America Environment Protection Agency WHO World Health Organisation

10 Abstract

Air pollution from sulfur dioxide (SO 2) in the Wollongong/Port Kembla region, New South Wales, Australia, has been of major concern for nearly 100 years. This long- term situation is due to the presence of local major industries which emit the gas, in particular, a copper smelter at Port Kembla, established in 1907. Extensive information on the emission and control of sulfur dioxide from this smelter has been reported over the years by the community, government and industry. Systematic monitoring of ambient atmospheric levels of sulfur dioxide was first undertaken in the region between 1957 and 1961. It recommenced in 1970 and has continued to the present day. This study is the first comprehensive, spatio-temporal analysis of all available ambient atmospheric sulfur dioxide monitoring data for the region. Previous reviews have tended to average data for the whole region, without considering the trends in specific locations and did not explore in any detail the relative contributions of major emission sources, such as the smelter. Two key factors were suspected to influence atmospheric sulfur dioxide levels in the region. The first was the nature of primary metallurgical operations undertaken at the smelter known to generate sulfur dioxide and any associated pollution abatement measures. The second was NSW government regulation regarding pollution control at the smelter. The interplay of these factors and their effect on ambient sulfur dioxide levels was explored over four distinct time periods namely; 1908 to 1965, 1966 to 1988, 1989 to 1995 and 1996 to 2006. The study found the copper smelter at Port Kembla has been a dominant source of elevated sulfur dioxide concentrations recorded in the area. There has been an overall decline in the atmospheric levels of sulfur dioxide from 1957 to the present day. The most significant downward trends in these sulfur dioxide concentrations were strongly associated with reductions in the load of sulfur dioxide emitted from the smelter. These were closely linked to changes in smelting technology (progression from batch – type to more continuous operation) and increasing pollution abatement (increasing sulfur capture) at the facility. The most significant of these reductions have tended to coincide with government intervention and regulation. This study provides a valuable retrospective on trends in air quality in the region and the environmental history of technology and regulation at the smelter in addressing ambient sulfur dioxide levels which, to date, have been poorly recorded.

11 Acknowledgments

This thesis would not have been possible without the cooperation and help of many people.

I would like to express my appreciation to my supervisor, Professor John Morrison (University of Wollongong) and Joe Woodward (DECC) for their guidance and encouragement during its progress.

Gratitude must also be extended to several other individuals who have assisted me greatly in its preparation. These include Craig Patterson (DECC) for software advice, Sheree Woodroofe and Ian Wilson (Port Kembla Copper) for information on smelting operations at Port Kembla, and the wonderful librarians at the DECC Library (Sydney), Wollongong City Library (Local Studies Section) and NSW State Library for locating many older (and often obscure) documents.

Lastly, I would like to thank my family and friends, in particular my partner Paul Black, who have supported me in this endeavour over the years.

I would like to dedicate this thesis to attendees, both past and present, of the Port Kembla Pollution Meeting, on its 21 st anniversary. This meeting continues to provide an open forum for local community, industry and relevant government agencies to work cooperatively in reducing the levels of pollution that impact on the health and comfort of the community.

12 1. Introduction

1.1 General

Sulfur dioxide (SO 2) is widely recognised as a significant air pollutant and its effects on the environment and human health are well known (National Pollutant Inventory, 2007). There is a long association between sulfur dioxide and the Wollongong/Port Kembla area due to the presence of several major industries which emit the gas, in particular, a copper smelter, steelworks and chemical (sulfuric acid) manufacturing plant. Whilst all major local sulfur dioxide emission sources are outlined, this study has placed an emphasis on the copper smelter at Port Kembla. This is because, historically, it has been the most dominant source of elevated levels of sulfur dioxide measured in the ambient air, in the Wollongong/Port Kembla area. This assumption is supported by several previous air quality studies (Bell and Sullivan, 1963 ; SPCC, 1986b) and is investigated in more detail in the following chapters. At times controversial, the emission and control of sulfur dioxide from this smelter has been of interest to the community, government and industry for nearly 100 years (Eklund & Murray, 2000; McPhillips, 2002). For these reasons, extensive and publicly accessible monitoring information is available on the concentrations of ambient atmospheric sulfur dioxide in the Wollongong/Port Kembla area. This information underpins a major literature review which forms the basis for this study.

This study involved collating, presenting and reviewing publicly available ambient sulfur dioxide monitoring data for the Wollongong/Port Kembla region. Systematic monitoring of ambient atmospheric levels of sulfur dioxide in the region was first undertaken by the NSW government between 1957 and 1961 (Sullivan, 1961). It recommenced in 1970 and whilst the number and locations of monitors has varied, this monitoring has continued to the present day. Monitoring of ambient levels of sulfur dioxide has also been undertaken by industry, although publicly reported data appears only to be available from 1988 onwards (EPA, 1988). This data review draws on all publicly available government and industry data from 1957 to the 2006. Several previous reviews of ambient sulfur dioxide data in the Wollongong/Port Kembla area are known to exist, including from 1972 to 1982 (SPCC, 1983a), 1976 to 1985 (McGinness, 1985) and 1980 to 1990 (Young and Laird, 1992). These reviews,

13 however, have tended to average data for the whole region without considering the trends in specific locations. They have also not examined in any detail the identity or relative contribution of some of the human sources of the pollutant. This is the first known comprehensive spatio-temporal analysis all the available data from 1957 to 2006.

Two key factors that can affect the observed ambient atmospheric sulfur dioxide levels have also been investigated in this study. The first is smelting operations and associated sulfur dioxide emissions and controls at the Port Kembla copper smelter. The second is NSW state government environment protection legislation relating to the regulation of air pollution from the smelter.

This study includes a literature review outlining the major operations at the smelter known to generate sulfur dioxide and associated pollution abatement measures, from commencement of operations in 1907 to the present day. Whilst this period includes several decades prior to monitoring data being available, the early information provides an important foundation to the evolution of smelting technology and associated environmental controls at the site.

Government regulation, in particular NSW State Government, and its effect on sulfur dioxide emissions and control at the smelter have also been investigated. A literature review is presented outlining the key legislation which regulated sulfur dioxide emissions from the smelter from the early 1900s to the present day and its influence on atmospheric sulfur dioxide levels. Again this literature review period extends beyond the timeframe where monitoring data is available, but the early information provides a useful context to future reforms.

The evolution of these factors over time and the interplay between them are explored in this thesis, together with the monitoring data to understand their influences on ambient atmospheric sulfur dioxide concentrations recorded in the region. The study also draws on the author’s personal observations as an environment protection officer with the DECC (and its predecessors the DEC and EPA) from 1992 to the present day.

14 The study provides a valuable retrospective on trends in air quality in the region and the environmental history of technology and regulation at the smelter in addressing ambient sulfur dioxide levels which, to date, have been poorly recorded.

1.2 Key Questions

Several key questions have been addressed in this study, including but not necessarily limited to the following:

1. What have been the concentrations of ambient atmospheric sulfur dioxide in the Wollongong/Port Kembla region and how have they varied from 1957 to the present day?

2. How have the following factors evolved over time and influenced the concentrations of ambient sulfur dioxide measured: • Evolving smelting technologies and pollution abatement measures at the Port Kembla copper smelter? • State government environment protection legislation relating to the regulation of air pollution from the smelter?

3. In relation to the smelter, has government regulation driven technology/pollution abatement or vice versa?

1.3 Thesis outline

In order to explore and answer the above key questions, this study has been structured in the following manner.

Chapter 1 provides an introduction to the study topic and the key questions to be answered. It also includes the methods used in collecting, interpreting, collating and presenting the ambient atmospheric sulfur dioxide monitoring information.

Chapter 2 is a literature review providing an overview of sulfur dioxide, the primary production of copper (via matte smelting) and associated sulfur dioxide emissions and

15 their control. It also explores the effects of meteorology and how they can influence ambient sulfur dioxide concentrations.

Chapter 3 presents the results and discussion following a literature review of ambient atmospheric sulfur dioxide monitoring data for the period 1957 to 2006. It examines how smelter operations (in particular sulfur dioxide emissions and controls) and environmental regulation have influenced ambient levels of sulfur dioxide in the air. This section has been divided into four distinct time periods. The study demonstrates that these time periods coincide with key step changes in the design, operation and/or regulation of the smelter that influenced atmospheric ambient sulfur dioxide levels. These time periods were: • 1907 to 1965 – Commencement of smelter operations leading up to the commissioning of the landmark 198 metre main stack. • 1966 to 1988 – Post commissioning of 198 metre main stack leading up to first major smelter upgrade. • 1989 to 1995 – First major redevelopment of the smelter with provision of sulfur capture using an acid plant. This was followed by smelter closure in 1995. • 1996 to 2006 – Second major redevelopment of the smelter with increasing sulfur capture in acid plants. Smelter recommenced operation in 2000 and closed in 2003.

Chapter 4 provides a set of conclusions from the study and makes recommendations for future research. This is followed by a list of the references used in the study.

1.4 Study area and monitoring locations

Wollongong is the primary city of the Illawarra region of New South Wales. It is the ninth largest city in Australia and the third largest in New South Wales, with a population approaching 200,000 people (Wollongong City Council, 2007). It is located about 80 kilometres south of Sydney on the south east coast of Australia (Figure 1). The Illawarra Region is situated on a narrow coastal plain bordered by the Royal National Park to the north, Lake Illawarra to the south, the South Pacific Ocean to the east and the Illawarra Escarpment to the west. The plain has a maximum width of 15 kilometres but tapers to less than 2 km wide both north and south. The

16 plain lies within 50 metres of sea level for the greater part of its area, with occasional hills rising to approximately 100 metres, except for the Illawarra escarpment which rises steeply in the west to more than 500 metres.

Port Kembla is a southern suburb of Wollongong and the associated port and environs represent one of the largest industrial centres in the southern hemisphere. This industry includes a steelworks, a copper smelter, a coal and grain export facility, metal manufacturing and other chemical manufacturing facilities.

Figure 1 Map showing study area location. The extent of the Wollongong Local Government Area is shown (pink).

Systematic measurements of sulfur dioxide in the air first occurred in the Wollongong/Port Kembla area between 1957 and 1961 (Sullivan, 1961). These measurements were undertaken by the NSW Department of Public Health. A review of the annual air quality monitoring data collected by the NSW government indicates that sulfur dioxide monitoring did not recommence in the region until 1970 (Reports to the Director General of the Department of Health, 1971). Whilst the number and

17 locations of monitors has varied, this monitoring has continued to the present day (2007) under the auspices of the SPCC, EPA, DEC and now DECC. It is understood that some sulfur dioxide monitoring was also conducted by industry, in particular ERS (Eklund and Murray, 2000). A review of the literature indicates that this publicly reported industry data appears only to be available from 1988 onwards (EPA, 1988b). Some sulfur dioxide monitoring appears to have been undertaken by BHP in locations in the Wollongong area (Wollongong Hospital and Mt St Thomas (near WIN TV) between 1995 to 1998 as part of the Sinter Plant upgrade. Only brief summaries of the findings of this monitoring campaign appear to be publicly available (Sinclair Knight Merz, 2001).

As stated above, the number and location of monitors used to measure sulfur dioxide in the Wollongong/Port Kembla area, at any one time, has varied enormously between 1957 and 2006. Only monitoring locations with at least one year worth of data were reviewed in this study. Taking this into account, about 29 monitors provided useful data during the study period for varying lengths of time. Table 1 provides a summary of these monitors and the approximate range of available sulfur dioxide data. In addition to ambient sulfur dioxide monitors, other important points of interest are also referred to in this study. This includes major industrial emission sources (such as the copper smelter and steelworks), historical emission sources (such as Tallawarra Power station) and BoM weather monitoring sites. These points are summarised in Table 2. The locations of these monitoring stations and points of interest are shown in Figures 2 and 3, using the keys provided in Table 1 and 2 respectively.

Table 1 Table of sulfur dioxide monitor locations used in the Wollongong/Port Kembla area between 1957 and 2006.

KEY Suburb Address Approximate range of available data (years) 1 Port Kembla Port Kembla Fire Station, 1957 to 1961, 1970 to Military Road (former) 1978, 1994 to 1995, 2000 to 2003 2 Port Kembla Saint Patrick’s Catholic 1992 to 1995, 1999 to School/Church, O’Donnell Street 2003

18 3 Port Kembla Port Kembla Primary School, 2000 to 2003 Military Road (former) 4 Port Kembla Terascoa Lane (former) 1959 to 1961 5 Port Kembla Corner of Cowper and Parkes 1957 to 1961 Street 6 Port Kembla Third Avenue 1957 to 1961 7 Port Kembla Jubilee Street 1958 to 1961 8 Port Kembla Somme Street 1959 to 1961 9 Lake Heights Lake Heights Road 1959 to 1961 10 Warrawong Flagstaff & Lake Heights Road 1958 to 1961 11 Warrawong Blaxland & Flagstaff Road 1972 to 1991 12 Warrawong Flagstaff Road 1976 to 1979 13 Warrawong King & Wattle Street 1989 to 1990 14 Warrawong Port Kembla District Hospital, 1989 to 1990, 1992 to Cowper Street 1995, 2000 to 2003 15 Warrawong Baby Health Centre, Green 1981 to 1982, 1989 to Street 1990, 1992 to 1995, 2000 to 2003 16 Warrawong Carlotta Crescent (EPA MAQS) 1993, 1998 to 2006 17 Kemblawarra Kemblawarra Public School 1989 to 1990 18 Primbee James Ave 1959 to 1961 19 Primbee Primbee Public School, Illowra 1989 to 1990, 1992 to Crescent 1995, 2000 to 2003 20 Windang Catholic Church, Windang Road 1992 to 1995, 2000 to 2003 21 Steelhaven BHP Instrument shop, 1989 to 1990, 1992 to Steelhaven area 1995, 2000 to 2003 22 Coniston Water Board Property, Old 1992 to 1995, 2000 to Springhill Road 2003 23 Kembla Kembla Grange Racecourse, 1994 to 1997 Grange Princes Highway (EPA MAQS) 24 Wollongong Wollongong Technical College, 1973 to 1979 Lysaght Street

19 25 Wollongong Auburn St 1989 to 1991 26 Wollongong Former Wollongong Council 1973 to 1988 Chambers, Burelli Street 27 Wollongong Wollongong Showground, 1992 to 1995 Harbour Street 28 Wollongong Gipps Street, Gwynneville (EPA 1993 to 2006 MAQS) 29 Albion Park Albion Park Airport, Tongarra 1984, 1986 to 2004, 2006 Road (EPA MAQS)

Table 2 Major points of interest used in this study.

KEY Point of interest A Port Kembla Copper Pty Ltd. Main Stack and Smelter building B Bluescope Steel. Sinter Plant and iron making. C Bluescope Steel. Coke making. D Orica Acid Plant. E Metal Manufacturers. F Former Tallawarra Power Station. G Former Port Kembla Power Station. H Former Australian Fertlisers Ltd Acid Plant. I Former Dapto Smelter. J Proposed site of Australian Smelting Corporation. K BoM station Port Kembla Signal Station. L BoM station. Bellambi Point. M BoM station. Albion Park.

To further investigate spatial trends in air quality over time, the sulfur dioxide monitors were grouped into four geographical zones; Port Kembla Township, Central, Wollongong City and Outer. These geographical zones are shown in Figure 2 and 3. The Port Kembla Township zone was chosen because studies have shown this area can be affected by both stack and fugitive emissions from the smelter (Sullivan, 1963). The Central zone was selected because it is known to be affected by stack emissions from the smelter (Kaybond, 1988; Dames & Moore, 1994). The

20 Wollongong City and Outer zones provide useful comparisons and allow the relative contribution of other potential sulfur dioxide sources to be investigated.

WOLLONGONG CITY

SEE FIGURE 3 FOR INSET OUTER

Figure 2 Map showing locations of Sulfur Dioxide Monitors, Major Points of Interest and Geographical Zones in the Wollongong area (see Tables 1 and 2 for details).

21 OUTER CENTRAL PORT KEMBLA TOWNSHIP

Figure 3 Map showing locations of Sulfur Dioxide Monitors, Major Points of Interest and Geographical Zones in the Port Kembla area (see Tables 1 and 2 for details).

22 1.5 Methods for Data Collection, Analysis & Quality Control

This study involved collating, presenting and reviewing ambient atmospheric sulfur dioxide monitoring data for the Wollongong/Port Kembla region. It includes routine monitoring data (both government and industry) from 1957 to 2006. This data was obtained from publicly available air quality monitoring reports published by the Environment Protection Authority (EPA, 1991b to 1998b), State Pollution Control Commission (SPCC, 1974b to 1990b) and Department of Public Health (Division of Occupational Health and Pollution Control, 1972 to 1973; Reports to the Director General of Public Health, 1970 & 1971; Bell & Sullivan, 1963).

The monitoring data from the 29 sulfur dioxide monitors stated in Section 1.4, was entered manually into a Microsoft Excel database (about 5000 data points). Some data was obtained electronically from the DECC from its Metropolitan Air Quality Stations (MAQS) at Albion Park, Wollongong, Kembla Grange and Wollongong from 1998 to 2006. A copy of this database is provided on CD in Appendix 1 of this thesis.

The monitoring data was grouped chronologically according to the specific location of the monitor. The units for the measurement of sulfur dioxide have varied over the years between parts per million (ppm), micrograms per cubic metre ( µg/m 3) and parts per hundred million (pphm). In this study, all data was converted to parts per million (pphm) to provide a consistent basis for data presentation and assessment using a conversion factor (Table 3).

Pollutant Unit Convert to Divide by Sulfur dioxide µg/m 3 (0 o C) pphm 28.6

Table 3 Sulfur Dioxide Conversion Factor ( µg/m 3 (0 o C) to pphm)

The averaging periods adopted for ambient sulfur dioxide monitoring data have varied considerably over the years as more routine and direct methods became available. They include daily, hourly and 10 minute readings. These readings have been used to determine monthly averages as well as the highest daily, maximum 1 hour and maximum 10 minute readings for a particular month. Other information, such as the

23 number of occasions recognised air quality goals (national / international) were exceeded are also available in these reports. This study has focussed on monthly average, maximum daily, maximum hourly and maximum 10 minute readings as these provide the most comprehensive data set and give representative indications of air quality that enable trends to be identified.

Unless available in the above reports, annual averages were calculated from monthly averages for the purposes of this study. Where less than 9 months data was available in any year, the respective annual average was not calculated for that year.

The monthly average, highest daily, maximum hourly and maximum 10 minute data (where available) was graphed to assess trends in ambient atmospheric levels of sulfur dioxide in the four identified time periods, namely; 1907 to 1965, 1966 to 1988, 1989 to 1995 and 1996 to 2006. For each time period, trends in sulfur dioxide levels were also examined in each the following geographical zones: Port Kembla Township, Central, Wollongong City and Outer.

The above air quality trends and literature reviews on smelting technology, emissions and controls and government regulation were used to address the key research questions stated in Section 1.2. The influence of local meteorology, for example, prevailing winds, on the transport of sulfur dioxide from major industrial sources in the study area and its impact on ambient sulfur dioxide levels, was also examined.

At many monitoring locations there are gaps in the monitoring record that are not explained in the respective published air quality monitoring reports. Monitors with less than 25% availability were often shown as “no data” or “data not available”. These gaps could be due to problems with the operation and maintenance of the instruments. Data that did not meet the strict quality assurance/quality control standards required under the relevant Australian Standard was not reported. There were also a limited number of monitors available at any one time. As a result, monitors were often relocated from the Wollongong/Port Kembla region to other sites, for example, Sydney or Newcastle, as part of State-wide air quality monitoring surveys.

24 2. Background

2.1 Sulfur dioxide - its effects and environmental fate

Sulfur dioxide (SO 2) is a colourless, irritating and reactive gas with a strong odour (Hazardous Substances Data Bank, 2005). It has a range of effects on human health which can vary depending on the concentration, frequency and duration of exposure and the health of the individual (WHO, 2006). There is considerable variation between individuals and the exposure-response relationship appears continuous without any clearly defined threshold (Ferrari and Salisbury, 1999). These responses are also further complicated by other pollutant components which also affect lung function, such as, fine particles, ozone or sulfuric acid mist which may have a synergistic effect (WHO, 2006; Ferrari and Salisbury, 1999).

Evidence from human and animal studies shows that inhalation of sulfur dioxide can cause a reduction in lung function (forced expiratory volumes) and increased airways resistance (bronchoconstriction) (WHO, 2006). Because of its solubility in water, it can dissolve in the mucous membranes of the nasal area and upper respiratory tract. Oxidation to sulfuric acid is followed by neutralization and excretion as ammonium and other salts (Ferrari and Salisbury, 1999). Ammonia in the mouth (a product of bacterial metabolism) is thought to play a key role in this neutralization process (WHO, 2006). Sulfuric acid aerosols can be deposited in the nose, throat, tracheal and bronchial regions or lung alveoli, according to their size (Ferrari and Salisbury, 1999). Factors such as humidity and atmospheric loading can influence this deposition pattern in the lungs. Conditions that generate highly acidic droplets which can exceed the neutralizing capacity of ammonia in the upper respiratory tract, lead to a greater deposition of acidic aerosols in the lungs (Ferrari and Salisbury, 1999). The irritant effect of sulfur dioxide occurs when nerves in the lining of the nose, throat and the airways of the lungs are stimulated by sulfuric acid. This causes a reflex cough, irritation and a feeling of chest tightness and may lead to narrowing of the airways (Ferrari and Salisbury, 1999). This latter effect is particularly evident in people suffering from asthma and chronic lung disease, whose airways are already inflamed and easily irritated (WHO, 2006; Ferrari and Salisbury, 1999).

25 Studies have shown that short term exposures (10 minutes) of sulfur dioxide of greater than 1 ppm (100 pphm) are associated with bronchoconstriction in non-asthmatic individuals, 0.2 to 0.3 ppm (20 to 30 pphm) bronchoconstriction in exercising asthmatics and less than 0.2 ppm (20 pphm) possibly associated with bronchoconstriction in exercising asthmatics (WHO, 2006 ; NEPC, 2004).

Sulfur dioxide can also harm plants and trees and reduce crop productivity (Ferrari and Salisbury, 1999). Responses of individual plant species vary enormously and ambient conditions may strongly influence the level at which damage can occur. For example, adaptations that prevent water loss in some native Australian plants in arid regions appear to protect them from injury at levels that would devastate them in more humid areas. Low levels of sulfur dioxide can enhance the growth of some plants, especially in soils low in sulfur (Ferrari and Salisbury, 1999). The transition between enhancement and reduction in yield is often quite abrupt. Some susceptible plant species may be damaged by 0.05 to 0.5 ppm (5 to 50 pphm) for 8 hours and 1 to 4 ppm (100 to 400 pphm) for 30 minutes (Liu and Lipt āk, 2000; Brian Mudd and Kozlowski, 1975). Resistant species require 2 ppm (200 pphm) for 8 hours or 10 ppm (1,000 pphm) for 30 minutes. These effects may be greater if other pollutants are present. For example, at concentrations of about 0.05 to 0.25 ppm (5 to 25 pphm), sulfur dioxide can react synergistically with either ozone or nitrogen dioxide in short term exposures (less than 4 hours) to produce moderate to severe injury to sensitive plants (Liu and Lipt āk, 2000).

Once in the atmosphere, sulfur dioxide is almost always oxidized to sulfuric acid

(H 2SO 4) in the form of acid sulfate aerosol. This oxidation reaction can occur via gas phase or non-gas phase (heterogeneous) chemistry (Potter and Coleman, 2003). It appears that, overall, heterogeneous reactions are the dominant pathway and account for about 80 to 90% of the total sulfur dioxide oxidized. In contrast, gas phase reactions account for about 10 to 20% of the sulfur dioxide oxidized (Potter and Coleman, 2003).

In gas phase reactions, the oxidation of sulfur dioxide to sulfur trioxide (SO 3) is most likely dominated by oxidants such as the hydroxyl (OH•) radical (Sienfield J.H and Pandis S.N, 2006). The photo-oxidation of sulfur dioxide to sulfur trioxide is not

26 common because under normal conditions it is very slow (Wayne, 2002). The sulfur trioxide, once formed, is rapidly converted to sulfuric acid in the presence of water vapour. The conversion rates of sulfur dioxide to sulfuric acid are influenced in a complex and non-linear manner by concentrations of oxides of nitrogen, hydrocarbons and sunlight intensity, through their effect on the hydroxyl radical concentration (Australian Environment Council, 1985). Typically, rates of formation for sulfuric acid via OH-SO 2 reactions are low. They have been estimated to vary from about 0.7% per hour in cloudless summertime conditions to 0.1% per hour in winter (Australian Environment Council, 1985). On a time scale of 1 to 2 days, however, sulfuric acid formation can be substantial.

The oxidation of sulfur dioxide via non-gas pathways involves heterogeneous reactions with a number of species. These can include cloud droplets and sea salt aerosols (in coastal/marine areas), as well as trace metals and soot particles (in urban air) (Potter and Coleman, 2003). Critical oxidizing agents are typically ozone (O 3) and hydrogen peroxide (H 2O2). The concentration of these oxidizing agents is much greater in urban air undergoing photochemical smog, than in clean air.

The degree of sulfate formation from sulfur dioxide is influenced by several competing factors including sulfur dioxide removal processes (for example, wet or dry deposition discussed below) and sulfur dioxide oxidation in the atmosphere. It can be seen from the above that both sulfur dioxide oxidation by the hydroxyl radical and heterogeneous pathways are significantly influenced by local photochemistry. Mueller (2005) has stated that some locales may on an annual basis be more oxidant limited for sulfate formation than sulfur dioxide limited. As a consequence, the atmospheric productivity of sulfate may be influenced by changes in not only the levels of sulfur dioxide, but also oxidant concentrations.

Sulfur dioxide can be removed from the atmosphere through either dry or wet deposition processes (Sienfeld and Pandis, 2006). Dry deposition processes involve the transport of sulfur dioxide (or sulfates) from the atmosphere onto surfaces in the absence of precipitation. Wet deposition processes involve sulfur dioxide (or sulfates) being scavenged by rain, snow or fog.

27 The most important dry deposition processes involve the ocean (pH 8), other non- acidic moist surfaces and some crops and forest species at certain growth stages (Hazardous Substances Data Bank, 2005).

Deposition by precipitation (wet deposition) is the result of both in-cloud and below- cloud capture of sulfur dioxide and particulate sulfate. Acid sulfate aerosol particles are readily incorporated into cloud water. Sulfur dioxide is not substantially removed from the atmosphere by rain unless it is oxidized to sulfate, since it does not dissolve to any great extent in clouds. In-cloud processes include the coagulation and diffusion uptake of sulfur dioxide in water droplets and sulfate particles serving as condensation nuclei. These processes are most important in clean air, that is, where sulfur dioxide concentrations below the clouds are low (Hazardous Substances Data Bank, 2005). Below cloud processes include interception of particles by falling rain drops and diffusion uptake of sulfur dioxide. The overall efficiency of wet deposition depends on many factors: precipitation type, intensity, duration, frequency, the relative amounts of sulfur dioxide and sulfate present and the size and distribution of particulate sulfate (Hazardous Substances Data Bank, 2005). In general, the removal rate for sulfates is about 40% per hour and for sulfur dioxide, an order of magnitude less (Hazardous Substances Data Bank, 2005).

Wet and dry deposition appears to be of comparable importance, on an annual basis, over those areas where measurements have been made. Dry deposition is more important closer to source regions where concentrations are higher, and in principle, it goes on all the time. Estimates of regional sulfur budgets in North America indicate that about half of the total deposition is dry deposited (Australian Environment Council, 1985). Conversely, wet deposition occurs only periodically (Hazardous Substances Data Bank, 2005).

Taking into account the above atmospheric processes, the average residence time of pollution sulfur, including sulfur dioxide in the air, is usually between one and five days, depending on the climate of a region (Hazardous Substances Data Bank, 2005). For this reason, sulfur dioxide pollution tends to congregate mainly around major industrial areas.

28 Conversion of sulfur dioxide to acidic sulfate and its incorporation into clouds or rain can cause the resultant rainwater to become acidic. The natural acidity of unpolluted rainwater is often taken to be pH 5.6 due to the presence of dissolved carbon dioxide. Certain natural organic acids (namely formic and acetic) can, however, play a significant role in lowering pH even further in some areas (Sienfield and Pandis, 2006). Given this, it is reasonable to consider precipitation with a pH less than 5.0 as anthropogenic “acid rain” (Baird & Cann, 2008). Acid rain has been associated with a number of environmental problems including acidification of lakes and loss of aquatic life, leaching of trace minerals from forest soils, contamination of drinking water, metal corrosion and damage to certain stone buildings, monuments and automobile paintwork. Sulfur dioxide is the main pollutant responsible, but nitric oxide and to a lesser extent hydrogen chloride, can also contribute (Wayne, 2002). Acid rain is a serious concern in parts of Europe and North America/Canada, but has not been documented to any great extent in Australia (National Pollutant Inventory, 2007; Australian Environment Council, 1985). This is thought to be due to our geographical isolation from other industrialised countries and our emission of acid rain precursors is relatively small compared to Northern Hemisphere countries.

Fine particle aerosols, of which particulate sulfate compounds contribute substantially, have been of increasing concern over the past few years (Cohen et al, 1993). These aerosol particles can be very fine (less than 2.5 micrometres) and accordingly can travel large distances because they do not readily settle out of the air. They are also sufficiently small to have human health consequences because they can penetrate deep into the lungs when inhaled. These fine particles also have significant effects on visibility because of their excellent ability to scatter light. This is further compounded by the fact that sulfate aerosol compounds of sulfuric acid and ammonium sulfate are highly hygroscopic, particularly in humid coastal climate. This makes them even more efficient optical scatters. They have also been implicated in their ability to exert an influence on global climate that is comparable, but opposite, to the Greenhouse Effect (Cohen et al, 1993).

Whilst moving beyond the scope of this study, the concentrations of sulfate in the ambient air in the Wollongong/Port Kembla area have been investigated. In 1981, the SPCC selectively tested routine total suspended particulate samples collected on high

29 volume filters for sulfate concentrations (SPCC, 1981). They found Port Kembla and Newcastle had significantly higher sulfate concentrations (24 hr average) than Sydney, with Port Kembla registering the highest readings. Cohen et al (1993) undertook extensive investigations of fine particulate sulfate (<2.5 microns) in the Sydney, Newcastle and Wollongong during 1992. It was found that Wollongong (comprising monitoring sites at Albion Park, Warrawong and Bellambi) had the highest levels (24 hour average) of sulfate, compared to Sydney and Newcastle cities. The study corrected these sulfate values to take into account sulfur associated with sea spray. Further fine particle (<2.5 microns) work by Huo et al (1999) during 1992/1993 found there were distinct seasonal variations in airborne sulfur at Warrawong and Albion Park with the highest readings occurring during the summer months. There was evidence to suggest the majority of these fine particles originated from industrial emissions. This effect was not as pronounced at Bellambi, due to the prevailing north easterlies and greater influence of pyrometallurgical industries at Port Kembla. At Bellambi, however, there was greater evidence that the region was affected by the interregional transport of fine particulates, including anthropogenic sulfur, from the Sydney area, under prevailing north-easterlies. These fine particle studies serve as an important historical record against which future air quality changes can be judged.

2.2 Sources of Sulfur Dioxide

Sulfur dioxide is released into the atmosphere in large quantities by natural processes (Ferrari and Salisbury, 1999). An important source is the action of anaerobic bacteria in peat bogs and tidal marshes, forming hydrogen sulfide (H 2S), which can be oxidised to sulfur dioxide in the atmosphere. Phytoplankton in the oceans can also produce other reduced sulfur compounds, such as, dimethyl sulfide (CH 3SCH 3), which are subsequently oxidised in the atmosphere to form sulfur dioxide. Sulfur dioxide is also released in large quantities as a result of volcanic activity.

Most of the sulfur dioxide that is of concern to public health and the environment is, however, associated with human activities. On a global basis, about 172 tera tonnes (172 x 10 12 or 172 million million tonnes) per year can be assigned to anthropogenic activities (Potter and Coleman, 2003). Of this, fossil fuel combustion accounts for 75

30 to 85% of the emissions generated and industrial processes such metal sulfide ore refining/smelting and sulfuric acid manufacture account for the remainder (Hazardous Substances Data Bank, 2005). Combustion of fossil fuels is the dominant source worldwide, because coal or oil burnt in power stations or boilers can contain between 0.1% to 3% sulfur. It is estimated that 94% of the global sulfur dioxide pollution is produced in the Northern Hemisphere, and the remaining 6% in the Southern Hemisphere (Hazardous Substances Data Bank, 2005). It has also been stated that these anthropogenic sulfur dioxide emissions now substantially exceed, on a global basis, natural emissions into the atmosphere (Cohen et al, 1993).

According to the Australian National Pollutant Inventory (2007) about 1.4 million tonnes of sulfur dioxide were estimated to be released to air in Australia from human activities in 2005/2006. These major sources of sulfur dioxide emissions (source type, tonnes per year and overall percentage) are summarised in Figure 4 (from NPI, 2007).

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Figure 4 Summary of National Sulfur Dioxide Emissions 2005/2006 (from NPI, 2007)

The main sources of sulfur dioxide emissions nationally are associated with electricity generation and basic non-ferrous metal manufacturing (smelting). Elevated concentrations of sulfur dioxide in the ambient air detected around Australia are

31 generally associated with these industry sources. There are a number of monitoring sites in the vicinity of such facilities, where local SO 2 concentrations have been routinely measured by government and industry, and can exceed recognised health goals (NEPC, 2004).

By international standards, Australian fuels tend to be low in sulfur. For example, typical coal, oil or gas all contain less that 1% sulfur and imported fuels are rarely used. Despite this low sulfur content, the large quantities of coal burnt in power stations can still mean high loads of sulfur dioxide are emitted to air annually. Most of this sulfur in coal is in pyritic or mineral sulfate form (for example, iron sulfate) and can sometimes be reduced by “clean coal technologies” such as beneficiation, which can remove this sulfur (Cheremisinoff, 2001). The smelting and refining of metal ores rich in sulfur (up to 30%), associated with basic non-ferrous metal manufacturing, is also a significant source. Table 4 lists the national top twelve industry sources which emitted sulfur dioxide in 2005/2006 (from NPI, 2007).

Table 4 Top 12 industry sources in Australia which emit sulfur dioxide in 2005/2006 (from NPI, 2007) Facility Emission Industry type (tonnes/year) Mount Isa Mines Ltd (Mount Isa, 240,000 Smelting and refining of sulfide Queensland) ores (copper, silver, lead and zinc) Kalgoorlie Consolidated Gold Mines 180,000 Smelting and refining of sulfide (Kalgoorlie, Western Australia) ores (gold) Bayswater Power Station 90, 000 Electricity generation (coal) (Muswellbrook, NSW) Zinifex Aust Ltd (Port Pirie, South 55,000 Smelting and refining of sulfide Australia) ores (silver, lead and zinc) Loy Yang Power Station (Traralgon, 54,000 Electricity generation (coal) Victoria) Liddell Power Station (Muswellbrook, 46,000 Electricity generation (coal) NSW) Muja Power Station (Collie, WA) 42,000 Electricity generation (coal) Alcoa World Alumina Australia 40,000 Electricity generation (coal) (Anglesea, Victoria)

32 Mount Piper Power Station (Portland, 38,000 Electricity generation (coal) NSW) Stanwell Power Station (Gracemere, 36,000 Electricity generation (coal) Qld) Eraring Power Station (Eraring, NSW) 33,000 Electricity generation (coal) Kalgoorlie Nickel Smelter (Kalgoorlie, 30,000 Smelting and refining of sulfide WA) ores (silver, lead and zinc)

Table 4 shows the biggest point sources of sulfur dioxide in Australia are associated with metal sulfide ore smelting and refining facilities. The largest is Mount Isa Mine Ltd at Mount Isa, Queensland (copper, silver, lead, zinc). The second largest is the Kalgoorlie Consolidated Gold Mines at Kalgoorlie, Western Australia (gold). It can be seen from Table 4 that the Mt Isa plus Kalgoorlie facilities alone account for about one third of Australia’s sulfur dioxide emissions. The twelve premises listed in Table 4 account for about two thirds of Australia’s sulfur dioxide emissions.

In NSW, the primary sources of sulfur dioxide (source type, tonnes per year and overall percentage) in 2005/2006 are summarised in Figure 5 (from NPI, 2007).

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Figure 5 Summary of NSW Sulfur Dioxide Emissions 2005/2006 (from NPI, 2007)

33 The most important sources of sulfur dioxide in NSW are associated with electricity generation (coal fired power stations). These are principally located in the Hunter Valley, near Newcastle. Since Australian coals are relatively low in sulfur, high ambient concentrations are not common in most NSW cities from these sources. As a result, sulfur dioxide pollution is not normally an issue on a regional scale in NSW. It can, however, be a concern in very localised areas around major emitters where short- term peaks in ambient atmospheric concentrations are known to occur, for example, basic metal and chemical manufacturing and oil refineries.

The primary sources of sulfur dioxide emissions in the Wollongong local government area (source type, tonnes per year and overall percentage) in 2005/2006 are summarised in Figure 6 (from NPI, 2007).

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Figure 6 Summary of Wollongong Local Government Area Sulfur Dioxide Emissions 2005/2006 (from NPI, 2007)

The largest source of sulfur dioxide emissions currently in Wollongong (tonnes/year) results from iron and steel manufacturing associated with Bluescope Steel Ltd (formerly Broken Hill Proprietary Ltd and Australian Iron and Steel Ltd). This is a large integrated steelworks producing around 5 million tonnes of iron per year. It includes two blast furnaces and associated coke making, sintering (making a raw feed for the blast furnace) and steelmaking activities. The sintering process is the main

34 point source of sulfur dioxide from the steelworks and is discussed further in Section 3.2. Since at least the mid 1970s (with the installation of the No 3 Sinter Plant), sulfur dioxide output from the steelworks has been relatively constant at around 10,000 tonnes per annum, of which about half is related to the Sinter Plant (NPI, 2007, SPCC 1986b).

Whilst Bluescope Steel is currently the largest load emitter of sulfur dioxide in the Wollongong Local Government area, other important point sources of sulfur dioxide have occurred in the Wollongong/Port Kembla area in recent years. This includes the copper smelter (currently owned by Port Kembla Copper) and a sulfuric acid plant (currently operated by Orica). Table 5 compares the annual loads of sulfur dioxide emitted from the steelworks, copper smelter and Orica acid plant for the period 2000 to 2006 (from NPI, 2007).

Reporting Period Bluescope Steel Port Kembla Orica Pty Ltd Copper Emission Emission Emission (Tonnes/year) (Tonnes/year) (Tonnes/year) 2005 - 2006 9,600 0 21 2004 - 2005 9,400 0 23 2003 - 2004 10,000 1,300 21 2002 - 2003 13,000 2,700 72 2001 – 2002 14,000 2,700 140 2000 - 2001 12,000 1,800 43 1999 - 2000 6,400 <10 No data

Table 5 Summary of Annual Loads of Sulfur Dioxide from Bluescope Steel, Port Kembla Copper and Orica Pty Ltd for the period 1999 to 2006 (from NPI, 2007)

Whilst currently closed and under “care and maintenance”, the copper smelter at Port Kembla was, whilst operational from 2000 to 2003, the second largest point source of sulfur dioxide in the region. This smelter has operated at this site for almost 100

35 years. Previous operations of the smelter emitted much higher annual loads of sulfur dioxide than those shown in Table 5 and it was the largest point source of sulfur dioxide in the region. For example, the smelter was emitting around 33,000 tonnes per year of sulfur dioxide in 1969 and up to 52,000 tonnes per year in 1993. These emissions are discussed in considerable detail in Chapter 3.

At Orica, sulfuric acid and other sulfur-based chemicals are produced from the thermal oxidation of spent alkylation acid (from oil refineries) or molten sulfur. Whilst the load of sulfur dioxide from Orica is much lower in comparison to the steelworks and copper smelter, it is known, on rare occasions, to generate localised, elevated levels of ambient sulfur dioxide. These emissions can, under certain conditions, impact on nearby residential areas. This can include, for example, acid plant start up and upsets (Personal observations by this author as an environment protection officer).

In addition to exploring the annual loads themselves, there is a distinct difference in the nature of the resulting sulfur dioxide emissions generated between the steelworks and copper smelter. The emission of sulfur dioxide from the steelworks is characterised by a number of separate sources (coke ovens, sinter plant, blast furnaces) and high gas volumes/low sulfur dioxide concentrations. Conversely, those of the smelter are typified by a centralised source (smelter building and associated stack) and low gas volumes/high sulfur dioxide concentrations. This higher intensity of emissions from the smelter, together with its greater proximity to residential areas, tends to result more in elevated concentrations of sulfur dioxide impacting on human health and the environment. For this reason, the emission and control of sulfur dioxide from the copper smelter has been of considerable interest to the community, industry and government, and forms the focus of this study.

2.3 Monitoring sulfur dioxide concentrations in the atmosphere

During the period during which sulfur dioxide monitoring has been undertaken in the Wollongong/Port Kembla area (namely 1957 to present day), there have been many different methods for the quantitative measurement of sulfur dioxide in the

36 atmosphere. Early techniques relied on wet chemical, titrimetric methods. The simplest and most common was the use of hydrogen peroxide (Palmer, 1974). As discussed latter in this section, this test is not, however, specific for sulfur dioxide. This method is usually carried out on a daily basis (but can be hourly in more polluted areas) to give a 24 hour average figure of the ambient sulfur dioxide concentration, expressed as “acid gases”.

The hydrogen peroxide method involves bubbling a filtered air sample through a dilute solution of excess hydrogen peroxide. Any sulfur dioxide present is oxidised to sulfuric acid. In order to prevent carbon dioxide in the air from dissolving in the hydrogen peroxide, a known amount of sulfuric acid is also added to the absorbing solution. A gas meter is used to measure the volume of the air sample that has passed through the solution. At the completion of the sample collection, the hydrogen peroxide solution is titrated with a standard alkali. The titration figure obtained from the unknown sample, minus the titration figure from a blank, is equivalent to the sulfur dioxide present in the atmosphere. A sequential sampler can be employed to automatically switch through a bank of eight bubblers, which need only be attended once per week (the eighth bubbler being a reserve).

There are certain limitations in using the hydrogen peroxide method. If the apparatus was sited near a chemical plant emitting, for example, hydrogen chloride or sulfur trioxide, an acid solution would be obtained. Conversely, if it was near a plant making ammonia, an alkaline solution would result. If equipment is sited correctly, the method is satisfactory for use on a daily basis and the results will show a trend over a period for the concentration of sulfur dioxide present in the atmosphere (Palmer, 1974).

The above titrimetric method for determining acid gases (expressed as sulfur dioxide) forms the basis of Australian Standard (AS) 3580.3.1 – 1990 (previously AS 2509- 1981 and British Standard 1747). The method is applicable to ambient air in which the sulfur dioxide concentration ranges from approximately 0.007 ppm to 3.5 ppm by volume (0.7 to 350 pphm). It has a precision of 0.007 ppm (0.7 pphm), expressed as sulfur dioxide, for a daily sample (CASANZ, 2000)

37 Whilst these methods are acceptable for the routine monitoring of sulfur dioxide in urban air, close to point sources the rapid fluctuations in concentration mean that measurement over shorter time increments is essential.

To overcome this limitation, conductimetric methods were adopted to provide more real time measurements of sulfur dioxide levels. These commenced with the use of the Thomas Autometer in the USA in the 1950s and introduced into Australia in the 1960s (Bell and Sullivan, 1963; CASANZ, 2000). The sulfur dioxide is sampled by passing a measured volume of air through a dilute, acidified solution of hydrogen peroxide. The sulfur dioxide is oxidised to sulfuric acid which yields hydrogen and sulfate ions (in solution). This increased ionic concentration causes a change in the conductivity of the solution. When a voltage is applied across the solution, these changes in conductivity can be measured. The more sulfur dioxide present, the greater the conductivity of the solution, due to the increase in ionic concentrations. The readout of the conductance measurement may range from a single strip chart recorder to an automatic electronic display. The early instruments of the Thomas Autometer used in Australia typically had a range of 0 to 10 ppm sulfur dioxide (0 to 1000 pphm) and a sensitivity of about 0.1 ppm (10 pphm) (CASANZ, 2000).

Like the titrimetric method, conductimetric methods respond to all ionisable substances collected in the measuring solution. This can include hydrogen chloride, chlorine, oxides of nitrogen and ammonia. Carbon dioxide can also contribute to the conductance and this contribution must be subtracted from the total reading. The carbon dioxide contribution is periodically measured by scrubbing sulfur dioxide from the air stream. For this reason the method was not specific for sulfur dioxide but actually measured acid gases. In most polluted air situations, however, sulfur dioxide is assumed to be the principal source of the increased conductivity in the H 2O2 –

H2SO 4 solution.

With advances in technology, spectrometric methods for routine and direct air pollution measurement emerged in the early 1980s. These analytical instrumentation methods require only micro amounts of sample, compared to previous wet chemical techniques. They also provide an instantaneous, continuous measurement by relying on, for example, pulsed fluorescent analysers (Ferrari and Salisbury, 1999). In these

38 analysers, ambient air is drawn into a sample chamber and irradiated with pulses of ultra-violet light. This results in the excitation of sulfur dioxide molecules to a higher energy state. As the molecules relax they subsequently emit light of a particular frequency (termed fluorescence), unique to sulfur dioxide. This fluorescence can be measured by a photomultiplier tube and is proportional to the concentration of sulfur dioxide present.

The spectrometric method forms the basis of AS 3580.4.1 – 1990 (previously AS 2523-1982). It is used to determine sulfur dioxide in ambient air where the concentration lies within the range 0 to 5 ppm by volume (0 to 500 pphm). It has a minimum range of 0 to 0.1 ppm (0 to 10 pphm) and a sensitivity of 0.001 ppm (0.1 pphm) (CASANZ, 2000).

Another technique that has been employed to measure ambient sulfur dioxide levels involves flame photometric detection (FPD). In these often portable devices, for example a Melloy TM sulfur meter, a sample of the air is drawn through a hydrogen rich flame. Any sulfur present is reduced to sulfur atoms. These atoms re-combine to form diatomic sulfur molecules in the excited state which emit ultraviolet light as they relax to the ground state. This light can be detected by a photomultiplier tube, with any increase in light proportional to the amount of total sulfur present. The device will not normally discriminate between sulfur species because all sulfur containing gas will be detected. This includes elemental sulfur, sulfur dioxide, sulfur trioxide and hydrogen sulfide as well as other organosulfur compounds such as carbon disulfide, dimethyl sulfide, mercaptans. Many of these organosulfur compounds are naturally occurring, for example, emitted from lakes and swamps. The detection limit for sulfur dioxide using this method is about 20 ppb (0.2 pphm). Scrubbing of the inlet gases, however, can allow for some sulfur speciation. For example, if a sodium citrate solution is used it will preferentially scrub out sulfur dioxide and the amount present in air could be obtained by difference.

2.4 Ambient Air Quality Goals for Sulfur Dioxide

Concentrations of sulfur dioxide in the atmosphere have historically been of particular concern because the pollutant has a range of adverse effects on human health. As

39 discussed in Section 2.1, these effects can vary depending on the concentration, frequency and duration of exposure and the health of the individual (Ferrari and Salisbury, 1999). A number of overseas and Australian jurisdictions have sought to assess air quality by comparing levels of measured contaminants against recognised standards and goals. For these reasons, several goals have been developed, over averaging periods from 10 min to 1 year, to protect human health.

National standards for ambient air quality are currently set by the National Environment Protection Council (NEPC), a statutory entity within the Environment Protection and Heritage Council of Australia and New Zealand (EPHC) (NEPC, 2007). The NEPC is a body established jointly by each State and Territory and the Commonwealth government, to work cooperatively at a national level to ensure that all Australians enjoy the benefits of equivalent protection wherever they live and that business decisions are not distorted nor markets fragmented by variations in environment protection arrangements between member governments. It was established in 1994 (Ferrari and Salisbury, 1999). The NEPC makes National Environment Protection Measures (NEPMs) which outline agreed national objectives for protecting particular aspects of the environment. An Ambient Air Quality NEPM for ambient air quality was adopted in 1998 which covered six criteria pollutants including carbon monoxide, lead, nitrogen dioxide, photochemical oxidants (ozone), particles (less than 10 microns) and sulfur dioxide (NEPC, 2004). This NEPM is still in use today. Before this, national goals were set by the National Health and Research Council (NHMRC) and in some cases State authorities, to serve as guidelines for those who had responsibility for developing strategies for controlling and reducing emissions (Ferrari and Salisbury, 1999).

The national environment protection goal of the above NEPM is to achieve the standards by 2008 and the desired outcome is ambient air quality that allows for the adequate protection of human health and well being (NEPC, 2004). The current Ambient Air Quality NEPM for sulfur dioxide (1 hour, 1 day and annual) are summarised in Table 6 (from EPHC, 2007).

40 Standard Averaging Period Maximum level Maximum (pphm) allowable exceedances of level NEPM 1 hour 20 1 day a year (Australia) 1 day 8 1 day a year Annual 2 None NHMRC 10 minute 25 None 1 hour 20 None 1 year 2 None WHO 10 minute 17.5 None 24 hours 4 None 1 year 1.8 None

Table 6 Ambient air quality standards/guidelines for sulfur dioxide (from NEPC, 2004)

It is interesting to note that, the NEPC did not set a 10 minute goal for sulfur dioxide, but agreed to review the practicability of one by 2003. An issues paper was released for public comment in 2004. This issues paper examined the sources and levels of sulfur dioxide in Australia, the health impacts arising from short term exposure and the implications of adopting a short term standard (NEPC, 2004). The NEPC subsequently resolved (NEPC, 2005) that such a goal was not required because 10 minute levels were only a concern at a limited number of locations, usually close to point sources. In these locations, a NEPM was not the most effective instrument to deal with these impacts. It was recommended that individual jurisdictions could deal with short term peaks of sulfur dioxide through their legislation and ongoing environmental improvement programs. These included reliance on existing 10 minute goals, such as those set by the NHMRC or WHO.

Prior to the establishment of the NEPC, the NHMRC produced goals for a set of major air pollutants based on their effect on human health, including sulfur dioxide (NEPC, 2004). These were developed in 1988 and reviewed in 1995. The 10 minute, 1 hour and 1 year goals for sulfur dioxide are shown in Table 6. In relation to the 10

41 minute goal the NHMRC noted that “ at these recommended levels, there may still be some people (for example, asthmatics and those suffering from chronic lung disease ) who will still experience respiratory symptoms and may need further medical advice or medication ”. In March 2002, the NHMRC rescinded its 10 minute sulfur dioxide goal, along with a number of other air quality goals, as part of a regular review of publications for currency and relevance (NEPC, 2004).

The World Health Organisation (WHO) has also produced Air Quality Guidelines for Europe, which include sulfur dioxide (NEPC, 2004). These were developed in 1997 and reviewed in 2000. These 10 minute, 24 hour and one year goals are shown in Table 6. No goal was set for 1 hour. The 10 minute goal defines the concentration of sulfur dioxide below which no significant risk is posed to the health of individuals exposed for 10 minutes or less. This includes the most sensitive population groups, in particular exercising asthmatics (NEPC, 2004). It was also recommended by WHO that countries who use these guidelines to set national or regional standards, also take into account existing environmental, social, economic and cultural conditions (NEPC, 2004).

Whilst the above NEPC measures are the current accepted standard for sulfur dioxide, the 10 minute WHO and NHMRC goals are still important (NEPC, 2004). There are some Australian jurisdictions, such as NSW, that still continue to use these short term goals in managing air quality, in particular from major industry.

In this study, air quality will be assessed by comparing the measured levels of sulfur dioxide in the atmosphere against recognised standards and goals. Systematic monitoring of sulfur dioxide in the Wollongong/Port Kembla region first began in 1957 and still occurs today. This monitoring centred on major industrial sulfur dioxide emitters, such as, the copper smelter at Port Kembla. Air quality goals have, however, varied considerably over the decades that monitoring has occurred. There is broad acceptance that Ambient Air Quality NEPM standards deal with general population exposure and do not deal with hot spots or the control of individual point sources (NEPC, 2007; NEPC, 2005). With this in mind, and for the purposes of this study, the goals listed in Table 7, derived from WHO and NHMRC requirements, will be used as the basis for this assessment. These goals are also relevant for comparison

42 because they have in the past underpinned the regulation of the copper smelter at Port Kembla. This is discussed further in Section 3 of this thesis.

Averaging Period Maximum level (pphm) Origin 10 minute 17.5 WHO 1 hour 20 NHMRC 24 hour 4 WHO 1 year 1.8 WHO

Table 7 Adopted air quality standards/guidelines for sulfur dioxide for the purposes of this study

2.5 Primary Production of Copper

Copper is one of the world’s most important metals. Because of its abundance, resistance to corrosion, ability to readily form alloys and high electrical and thermal conductivity, it has been used by humankind for centuries.

Copper can be obtained from a variety of naturally occurring ores, with sulfide ores, such as, chalcopyrite (CuFeS 2) being the major source (Davenport and Biswas, 2002). These ores consist mainly of copper and iron sulfides together with some oxides, gangue (silica) and impurities such as arsenic, antimony, and bismuth. The ores may also contain sulfides of nickel, zinc, molybdenum and lead and small but valuable contents of precious metals such as silver, gold and palladium.

Copper ores can contain less than one percent copper (Davenport and Biswas, 2002). To enable the smelting process to be carried out economically and facilitate transportation to the smelter, ores are concentrated at the mine sites via crushing, grinding and flotation. The resulting copper “concentrate” generally contains around 25 per cent copper, but can be higher depending on the mineralogical composition of the ore.

There is a wide range of commercially proven processes or combinations of processes used to extract copper from its ores. These processes are designed to meet the particular requirements of a given ore and specific site conditions. The extraction of

43 copper is fundamentally based around various modifications of either pyrometallurgical or hydrometallurgical processes (Davenport and Biswas, 2002). The vast majority of copper produced in the world today, including at the copper smelter at Port Kembla, involves the pyrometallurgical processes (Davenport and Biswas, 2002). For this reason, this study will focus on the pyrometallurgical process, and in particular those processes that were used at, or relate to the Port Kembla smelter. Detailed information on other processes is available in the literature (European Commission, 1991; Davenport and Biswas, 2002). It is worthwhile pointing out, however, that hydrometallurgical production of copper has been steadily increasing in recent years because it has the distinct advantage of not producing sulfur dioxide emissions (Davenport and Biswas, 2002).

Pyrometallurgical processes aim to separate the copper from the iron, sulfur and gangue (silicious) materials present. At the copper smelter at Port Kembla, and indeed at most smelters around the world, this was traditionally achieved sequentially in the following two distinct operations: • Smelting; and • Converting.

Smelting is the first step in the pyrometallurgical process. Sulfidic copper ores are smelted entirely by what is known as “matte smelting”. Its main function is to remove gangue materials to a “slag” and the smelting of the copper, iron and sulfur, plus any precious metals present down to a “matte”. In the smelting process, feed material such as copper ores or concentrates and silicious flux (sand) are charged to an externally fired furnace at about 1200° C (Davenport and Biswas, 2002). This furnace can be fuelled by natural gas, oil or pulverised coal. Solid material is melted and subject to certain chemical changes. The copper sulfides are oxidised to form a copper matte. Impurities, chiefly iron, in the charge, react to form a layer of slag. This slag floats to the top of the molten matte. Some of the sulfur in the charge is released as sulfur dioxide. Example reactions are as follows (Davenport and Biswas, 2002).

8CuFeS 2 + 13 O 2 → 4Cu 2S.2FeS + 6FeO + 10SO 2 chalcopyrite molten matte

44

2FeO + SiO 2 → Fe 2SiO 4 silica flux molten slag

The slag is frequently skimmed and the matte periodically tapped. Smelting results in concentrates typically containing around 25% copper being processed to yield a matte of 40 to 65 % copper, depending upon the type of furnace used.

Various types of smelting furnaces are available. These include the Reverbatory Furnace, Blast Furnace, Isasmelt, Noranda, Teniente, Electric Furnace, Vanyukov, Inco, Contop and Flash Smelting Furnaces. A fuller explanation of these various smelting processes is available in the literature (for example, Davenport and Biswas (2002)). This study will focus on the types of smelting furnaces that were employed at the copper smelter at Port Kembla. These were the Reverberatory furnace, Blast furnace and Noranda Reactor.

The reverberatory furnace was once the most extensively used smelting furnace in the world, because of its versatility. It is a fuel fired hearth furnace in which concentrates are melted to produce separate layers of liquid matte and slag (see Figure 7). The heat for smelting was provided by burning fuel, such as oil, natural gas or pulverised coal, in the furnace and passing the hot combustion gases over the charge. All types of material, lumpy or fine, wet or dry, can be readily smelted. The furnace is continuously fired and matte and slag are produced from the solid charge.

45 Please see print copy for image

Figure 7 Typical Reverberatory Furnace (from Biswas and Davenport, 1980)

In the past, Blast Furnaces were used extensively to produce matte from lump sulfide ores (see Figure 8). Depletion of these lump ores and the increasing production of froth flotation concentrates gradually reduced their use worldwide. This is because Blast Furnaces cannot treat fine concentrates as they are quickly blown out of the furnaces by the rising combustion gases. For this reason they were combined with a Sinter Plant to provide a suitable raw feed. This had the disadvantage, however, of introducing another step in copper production (Biswas, 1976). Sintering refers to the physical process of agglomerating fine ores, coke and fluxes into course pieces by heating in a furnace. This produces a porous, lumpy material, suitable for feeding into the blast furnace. Some sulfur is oxidised and removed in the process.

The charge to the blast furnace usually consists of sintered concentrates, lump ore, silica flux and metallurgical coke. Air is injected through tuyeres near the bottom of

46 the furnace. The air burns the coke to provide heat for the smelting process and partially roast the sulfides, thereby producing a matte of improved copper grade when the charge melts near the bottom of the furnace. Tap holes are provided so that matte and slag can be withdrawn separately, as they accumulate in the furnace (Biswas and Davenport, 1976).

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Figure 8 Typical Blast Furnace Operation (from Biswas and Davenport, 1976)

The Noranda reactor uses a cylindrical, refractory lined furnace for smelting (see Figure 9). Pelletised concentrates and additives are charged into the bath of molten slag at the top end of the furnace. Burners fired by natural gas or oil situated at both ends produce the heat necessary for processing. Oxygen enriched air is blown into the molten bath through tuyeres causing sulfur and iron to oxidise. Slag and matte separate out. The matte is tapped periodically and the slag continuously. The process can also be used to produce blister copper, in particular, when using copper concentrates with low impurity levels. It is, however, used normally to produce a copper rich matte to undergo further conversion.

47 Please see print copy for image

Figure 9 Noranda Reactor (from Biswas and Davenport, 1994)

Converting is the second step in the smelting/converting sequence by which copper- iron sulfide ore is made into metallic copper. It consists essentially of blowing air (often enriched with oxygen) through molten copper matte produced from the smelting furnace, thereby eliminating the remaining iron and sulfur present, and producing molten copper. This is known as “blister copper” because of its appearance when cooled. No fuels are necessary as all the heat is provided by the chemical reactions taking place.

Various types of converting furnaces are available. These include Pierce Smith, Hoboken, Flash Converters and Mitsubishi Continuous Converter. Detailed descriptions of these are available in the literature (for example, Davenport and Biswas, 2002). This study will focus, however, on the converting furnaces that were used at the copper smelter at Port Kembla, namely the Pierce Smith Converter and the Mitsubishi Continuous Converter.

48 The Pierce Smith converter was the most common converting furnace used at the copper smelter at Port Kembla, and is also the most popular historically around the world (Newton, 1942; European Community, 2001; Davenport and Biswas, 2002). Pierce Smith Converters are refractory lined cylindrical steel shells mounted on trunnions at either end and rotated around a major axis for charging and pouring (Figure 10). Please see print copy for image

Figure 10 Pierce-Smith Converter for producing blister copper from copper matte (from Biswas and Davenport, 1994).

Liquid matte is transferred from the smelting furnace in large ladles and an opening at the centre of the converter functions as a mouth through which molten matte, siliceous flux and scrap copper are charged and gaseous products are vented. The oxidising “blast” is then started and the converter is rotated, forcing oxygen enriched air or air into the matte through a line of tuyeres.

The converting takes place in two sequential stages, a “slag blow” and a “copper blow” (Davenport and Biswas, 2002).

In the “slag blow”, iron sulfides present in the molten matte (2Cu2S. FeS) are oxidised to form iron oxides which combine with the siliceous flux to form a slag. This slag is periodically tapped and fresh charge and flux added. Sulfur is removed as sulfur dioxide gas according to the following reaction (Davenport and Biswas, 2002):

49 2FeS + 3O 2 + SiO 2 → Fe 2SiO 4 + 2SO 2 in matte in “blast” flux molten slag in off-gas

Charging, blowing and slag skimming of the copper matte continues until an adequate amount of cuprous sulfide (“white metal”, Cu 2S) accumulates at the bottom of the converter.

During the final stages of the blow (the “copper blow”), the sulfur in the cuprous sulfide (Cu 2S) is oxidised to sulfur dioxide and metallic copper (“blister copper”) is formed as follows (Davenport and Biswas, 2002):

Cu 2S + O2 → 2Cu + SO 2 Liquid in blister in matte “blast” copper off gas

Temperature control during converting is effected by charging copper scrap or cold fluxes if the converter is too hot, or charging molten matte if it is too cold. Converting yields blister copper of up to 99% purity. The molten blister copper is tapped from the converting furnace and subsequently treated by fire refining (for example, anode furnaces) and electrolytic refining methods to remove trace impurities. These remaining smelter operations release little or no sulfur dioxide (Davenport and Biswas, 2002).

It can be shown from the above chemical reactions involving matte smelting and converting that for every tonne of blister copper produced directly from copper sulfide concentrates, about two tonnes of sulfur dioxide is generated. In practice, however, the amount of sulfur dioxide actually released depends on several factors. These factors include the amount of sulfur in the copper concentrate feed, the amount of concentrate used, the amount of scrap copper used and whether facilities are in place to capture the sulfur dioxide generated (for example, an acid plant).

In recent years, there have been significant advances in copper production which have resulted in newer processes which more effectively combine the above smelting and converting processes. This enables copper to be produced continuously rather than through a series of batch type furnaces. Examples of these types of furnaces include

50 the Outokumpu Flash Furnace and the Mitsubishi Continuous Converter. A more detailed description of these integrated processes is available in the literature (George and Taylor, 1981; European Community, 2001; Davenport and Biswas, 2002). The Mitsubishi process is discussed further here because it was a system that was used (in part) at the copper smelter at Port Kembla.

The full Mitsubishi process employs three interconnecting furnaces, a bath smelting furnace, an electric slag cleaning furnace and a converting furnace (see Figure 11). Gravity flow is used between furnaces and avoids ladle transfers. All the furnaces are sealed and extracted heat from process gases is recovered and treated to remove dusts and sulfur dioxide. Please see print copy for image

Figure 11 Mitsubishi Process for continuous converting (From Biswas & Davenport, 1976)

51 In the case of the copper smelter at Port Kembla, a Noranda Reactor was used as the smelting furnace that was coupled with the Mitsubishi Converting furnace (also known as “Mitsubishi C” or MIC). Copper matte produced in the existing Noranda furnace was periodically tapped and transferred to a holding furnace. The holding furnace was designed to ensure a constant flow of molten matte using gravity and enclosed launders to the converting furnace. This Noranda/ Mitsubishi Converter hybrid was the only one of its kind in the world (Davenport and Biswas, 2002).

Continuous smelting/converting, even in more than one furnace, has significant energy, sulfur dioxide collection and cost advantages. It has long been the goal of metallurgical engineers and chemical engineers to combine the smelting and converting steps into one continuous direct to copper process. Direct–to-copper smelting is currently achieved in a single furnace by using Outokumpu flash smelting. This has become the accepted best practice for the pyrometallurgical production of copper today (Davenport and Biswas, 2002; Riekkola-Vanhanen, 1999).

2.6 Sulfur dioxide emissions and controls from the primary production of copper

Historically, the major environmental issue associated with the primary production of copper has been the emission of sulfur dioxide to air from the smelting of sulfide concentrates. This is because of the considerable quantities of sulfur in the concentrate from which copper is won, typically 25 to 35%. Unless adequately controlled, these sulfur dioxide emissions can be a significant problem in the surrounding environment. The amount of sulfur dioxide released depends on the amount of sulfur in the copper concentrate feed and whether facilities are in place to capture the gas. Sulfur dioxide emissions may range from less than 4 kg per tonne of copper to 2000 kg per tonne of copper produced (Cheremisinoff, 2001).

As discussed in Section 2.5, sulfur dioxide emissions can be generated during a wide variety of smelting and converting operations. A summary of the typical gas strengths (percent sulfur dioxide) from various types of furnaces used in the industry are summarised in Table 8. Table 8 indicates that sulfur dioxide in the off gases is at the high end where newer continuous smelting/converting processes and/or oxygen

52 enrichment of reaction air are used. Figures at the low end of the range, such as reverberatory furnaces, represent the worst ingress of dilution air, high volume of combustion gases or low rate of sulfur elimination.

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Table 8 Typical Comparative Sulfur Dioxide Gas Strengths (from George and Taylor, 1981)

Historically, tall stacks have been synonymous with copper smelters around the world. Initially these stacks were built to provide natural draft and bring smoke or fumes from a furnace out of a building, instead of having it back up inside, with little concern for safe atmospheric dispersion (Lund, 1971). Later they were seen as the ultimate disposal method for waste gases, such as sulfur dioxide, that were considered difficult to treat. Prior to the late 1900s, most smelters did not include facilities for the capture and fixation of sulfur dioxide. All gases were typically vented to the atmosphere via tall stacks (George and Taylor, 1981). These stacks were designed to meet the emission standards of the time when this was accepted practice. There was little incentive, economically, practically or legislatively, for sulfur containment.

53

During the 1960s and 1970s, it became obvious world wide that smelting operations produced too much sulfur to rely on stacks alone (Lund, 1971). Growing concerns about the effects of sulfur dioxide on the environment and human health, as well as increasing pollution control regulation, lead to copper smelters exploring other options. One method for preventing high ambient concentrations was to simply reduce production when meteorological conditions were such as to make high concentrations likely or when ambient monitors detected pollution above recognised targets. These Air Quality Management Systems do not, however, reduce the overall emissions from the facility.

The technology of actual removal of sulfur dioxide from smelter emissions has developed in different directions, each with its particular advantages and disadvantages. The sulfur dioxide capture products and techniques involved have included the following (Biswas and Davenport, 1994): • Sulfuric acid – by conversion of sulfur dioxide to sulfuric acid in an acid plant. • Liquid sulfur dioxide – by cooling, drying and refrigerating sulfur dioxide gas. • Elemental sulfur – from the reduction of sulfur dioxide gas with hydrocarbons. • Gypsum (wall board grade) – by reacting sulfur dioxide gases with a calcium oxide/calcium carbonate slurry; and • Ammonium sulfate (fertiliser) - by reaction of sulfur dioxide with ammonia or ammoniacal leach solutions.

All of the above processes benefit from high sulfur dioxide concentrations in the gas stream, both economically and in terms of conversion efficiency. The most common method for fixing sulfur from smelter sulfur dioxide gases in the world today is the production of sulfuric acid (Davenport and Biswas, 2002). This is because it is the easiest, least expensive sulfur fixation method and does not require as high a concentration of sulfur dioxide in the off gases as some of the other methods. The market for sulfuric acid is also much larger than for the other products at most locations. This process is described in more detail here because it was the main sulfur dioxide capture method used at the copper smelter at Port Kembla.

54 The acid making process consists of the following basic steps (Biswas and Davenport, 1994): (a) Gas Cooling : Gases are cooled to avoid damage to gas cleaning (using electrostatic precipitators) usually in waste heat boilers, which can also recover the heat in useful form (for example, steam); (b) Cleaning & Drying : Dusts are removed by electrostatic precipitation and moisture is removed by scrubbing with dilute sulfuric acid; (c) Conversion : Sulfur dioxide is oxidised in contact with a catalyst (usually

vanadium pentoxide) to sulfur trioxide (SO 3) by the following exothermic reaction:

2 SO 2 + O 2 → 2 SO 3 The conversion is normally about 97% complete at 450 o C;

(d) Absorption : Sulfur trioxide is absorbed in 98% sulfuric acid (H 2SO 4) (remainder water); (e) Dilution : the strengthened acid is blended with the diluted acid from step ( c ), purged with air to remove sulfur dioxide and sent to market. The typical product grades are 93 to 98% sulfuric acid.

The process described above is for a single contact acid plant (SCAP). Double contact acid plants (DCAP) absorb sulfur trioxide twice; one after partial sulfur dioxide to sulfur trioxide oxidation and again after final oxidation. If properly designed and operated, typical SCAPs are about 96% efficient and DCAPs are up to 99.85% efficient in sulfur dioxide removal (National Pollutant Inventory, 1999). The residual acid plant “tail gas” can contain sulfuric acid mists and residual sulfur dioxide and is discharged to atmosphere via a stack. This tail gas can be cleaned further by scrubbing with basic solutions, such as calcium carbonate or sodium hydroxide (Davenport and Biswas, 2002). It is possible to control these tail gas emissions so that they contain sulfur less than 0.1% of the input of the smelter (Riekkola-Vanhanen, 1999).

Use of sulfuric acid plants to treat copper smelter gases requires that particulate free gas with a steady sulfur dioxide concentration of at least three percent be maintained (George and Taylor, 1981; USEPA, 1992). Early smelters traditionally comprised

55 several unit operations (for example, smelting and converting) in producing blister copper from sulfide concentrates, some of which are batch in nature. The result was discontinuous gas streams and highly variable sulfur dioxide gas concentrations and volumes. This did not lend themselves to sulfur capture using acid plants. For example, as indicated in Table 8, whilst the Pierce Smith converter can generate sulfur dioxide streams of over 3%, because of its two distinct blowing cycles (slag and copper “blows”), the gas flow is discontinuous and varies in strength within the range shown. The intermittent “batch” nature of this operation makes it generally unsuitable for acid plants, unless a bank of converters is used and “cycled” to produce a more stable gas flow.

Fugitive emissions, those that escape from furnaces to the atmosphere and not captured by pollution collection devices, are common during the primary production of copper. For example, emissions from Pierce Smith converters are particularly problematic. They result primarily from charging and pouring procedures, during which the converter mouth is outside the collection hood. Especially severe are emissions when the converter is rotated between its three positions (charging, blowing, skimming) because blowing must be continued during the rotation to prevent molten materials flowing back into the tuyeres and damaging the air delivery system. This is shown in Figure 12.

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Figure 12 Relative Positions of the Pierce Smith Converter for Charging, Blowing and Skimming. Note the gap between the collection hood and converter during charging and skimming operations (from Biswas and Davenport, 1994)

56 To prevent the hood from binding to the converter with splashing molten metal, a gap exists between the hood and vessel, resulting in fugitive gaseous emissions (USEPA, 1992). These fugitive emissions are difficult and expensive to control (Davenport and Biswas, 2002) and frequently result in offsite impacts of sulfur dioxide. Similarly, other rotary furnaces such as the Noranda Furnace can also generate fugitive emissions of sulfur dioxide when they are charged or tapped.

Modern smelting technology, such as flash smelting, maximises the production of a continuous and high strength sulfur dioxide gas. This permits the recovery of sulfur as sulfuric acid, the accepted control technology of the industry today (Davenport and Biswas, 2002). Modern plants using good industrial practices should set as targets sulfur dioxide discharges of at least 25 kg/tonne of copper produced (Cheremisinoff, 2001). The cleanest smelter in the world is reported to be the Kennecott Garfield Smelter in the USA (Riekkola-Vanhanen, 1999). It employs flash smelting and converting methods with a very modern double contact acid plant. The sulfur dioxide emission rate is less than 3.5 kilograms per tonne of copper (or 99.9% sulfur recovery).

2.7 Effects of Meteorology on Ambient Atmospheric Sulfur Dioxide Concentrations

No discussion on air pollution would be complete without reference to meteorology. This is because the transport and dispersion of air pollutants is strongly dependant on meteorology (Zannetti et al, 2003).

It has long been known that air quality in the suburbs surrounding heavy industry in the Wollongong/Port Kembla region undergoes seasonal variations (Sullivan, 1956). Recent studies have shown that concentrations of airborne pollutants generated from industries at Port Kembla and measured in adjacent suburbs are strongly dependant on wind direction and speed.

Crisp et al (1984) examined wind direction data in 1980 to calculate the percentage time during which winds blew from principal industrial sources of pollution, such as the steelworks and copper smelter, towards certain residential areas. It was found that

57 percentage wind frequencies from these emission sources into particular suburbs correlated well with measured concentrations of airborne metals (total suspended particulates, >10 microns) and metal deposition (coarse particles, 100 -500 microns) in those suburbs. Further work by Huo et al (1999) on fine particles (less than 2.5 microns) during January 1992 and June 1993 has shown air pollution in Albion Park (i.e., downwind of the industrial area) was highest during summer when north easterly winds were dominant. Approximately 50% of the fine particles collected at Albion Park were associated with industries in Port Kembla (the remaining principal components, road dust 25%, sea salt 15%). Areas to the north of Port Kembla (for example, Bellambi) were less affected. The copper smelter and steelworks at Port Kembla were the likely source of these fine particulate pollutants. These studies show that pollution dispersion is affected by the variability in wind direction. If wind direction is relatively constant, areas downwind of major emitters will be continually exposed to high pollutant levels.

The most important processes governing meteorology and hence air quality in the Illawarra region include: • Gradient (or synoptic) winds; • Sea breezes; • Drainage flows; and • Atmospheric stability.

Gradient (or synoptic) winds are large scale flows determined by synoptic pressure gradients. Port Kembla is located in a coastal region and on a middle latitude. Generally speaking, gradient winds at this latitude are predominantly from the west (offshore) during April to September and from the east (onshore) from November to March. Winds are also common from the south from November to March, associated with the passage of cold fronts, for example, “southerly bursters” (Crisp, 1984). This is due to the annual variation in the mean latitude of anticyclones (high pressure systems) crossing the east coast of Australia (Colls and Whitaker, 1990). It is this seasonality that exerts the greatest influence on the local climate. A summary of climate data for Port Kembla (Signal Station) is shown in Figure 13 (from BoM (2007), period 1950 to 2004). On occasions, synoptic wind conditions can be calm or

58 very light, for example, when associated with anticyclones. This can inhibit pollution dispersion in the atmosphere. Please see print copy for image

Figure 13 Port Kembla Climate Data (From BoM, 2007)

Given its coastal location, sea breezes provide an important diurnal variation to wind flow in the region. They are caused by the unequal heating and cooling of adjacent land and sea surfaces during the day. This is illustrated in Figure 14. In the morning, the heating of air over the land, relative to the sea, causes it to expand, and a pressure gradient forms at a higher level, from land to sea. Air then starts to move seaward aloft in response to this gradient (termed the “return flow”) and air rises over the land to take its place. An onshore wind (the “sea breeze”) develops as a consequence near the surface and a descending motion forms over the sea to complete the circulation (Sturman et al, 2006). The opposite can occur at night when the land cools more rapidly than the sea, so the pressure gradient is reversed. This is termed a “land breeze” (Sturman et al, 2006).

A sea breeze will typically commence over the coastline after the land temperature begins to exceed the sea temperature (usually late morning/early afternoon). As this difference increases, so does the strength of the sea breeze, attaining a maximum speed a few hours after the maximum temperature has been reached (Bureau of Meteorology, 2007). On the NSW coast, this effect is most pronounced from about

59 August through to December, when cooler sea water temperatures prevail, whilst the warming effect of solar radiation on land is increasing to its maximum (Bureau of Meteorology, 2007).

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Figure 14 Formation of a sea breeze (from Sturman et al, 2006)

The direction and strength of gradient winds, cloud cover and the orientation and complexity of the coastline, can all affect the start up and final sea breeze direction and speed (Bureau of Meteorology, 2007). It is found that a “pure” sea breeze in NSW will generally start up as a light onshore surface wind at roughly right angles to the coast (easterly). Sea breezes that become particularly strong or extensive may be influenced by the Earths rotation due to the Coriolis Effect (Sturman et al, 2006). This causes the sea breeze to deflect to the left or counter-clockwise (north easterly) in the Southern Hemisphere (Sturman et al, 2006). In the Illawarra, however, other factors appear to have a greater influence on the direction of sea breezes than the Coriolis Effect. Investigations by Crisp et al (1984), Prescott (1989) and EPA (1997) have indicated that the predominance of sea breezes from the northeast is most

60 probably caused by the topographic steering of the flow by the Illawarra escarpment. This effect is further accentuated by the prevalence of north westerly gradient winds, especially in summer. The strongest and most persistent sea breezes in the Illawarra occur when reinforced by an offshore gradient north – northwest wind. These are typically caused by an anticyclone located in the Tasman Sea (Dames & Moore 1994; Bureau of Meteorology, 2007). These “re-enforced” sea breezes tend to have a direction more from the north-northeast (Bureau of Meteorology, 2007).

Prescott (1989) found that, in general, the onset time for a sea breeze in the Illawarra coastal plain is usually 2 to 3 hours after sunrise and breakdown usually occurs before sunset. The exception is coastal locations like Port Kembla and Bellambi. Here we see the effect of north westerly gradient winds becoming more north-easterly as they flow over the escarpment (topographic steering), giving the appearance of a sea breeze that persists late into the night (Prescott, 1989). Whilst north to westerly gradient winds will enhance the generation of north easterly sea breezes, west to south gradient winds can sometimes lead to the formation of south easterly sea breezes (Prescott, 1989; Bureau of Meteorology, 2007). South easterly sea breezes, however, tend to be not as developed and are much less frequent than north easterly sea breezes in the Illawarra (Dames & Moore, 1994).

The depth of the atmosphere in which pollution is mixed can be 1 to 2 kilometres (Hyde, 1991). Sea breezes can range in depth from around 200 to 2000 metres (Sturman et al, 2006). In the Illawarra, the sea breeze has been found to range in depth between 300 to 600 metres (measured at Albion Park) with return flows between 300 to 1100 metres, under a prevailing north westerly gradient wind (Hyde and Prescott, 1984; Prescott, 1989). This suggests that under these conditions, the sea breeze and associated return flow can at times be limited by the height of the Escarpment. It was found that lighter gradient winds favoured a deeper sea breeze that could allow it to mount the Escarpment (Hyde and Prescott, 1984; Prescott, 1989).

Drainage flows occur at night as the air close to the cooling land surface cools. The air is colder and denser than the surrounding air and hence will flow downslope, sinking to the lowest topographic points (Sturman et al, 2006). Prescott (1989) has shown that high ground to the west, for example, the top of the Illawarra Escarpment

61 and foothills of the Great Dividing Range, provide a source region for westerly drainage flows into the Illawarra region. Whilst they can vary widely in their structure and frequency, Prescott (1989) identified some common characteristics. The flows typically begun within 2 hours of astronomical sunset and ended within 2 hours of sunrise. The seasonal nature of sunrise and sunset timing affected the timing and duration of the drainage flows. The strength of any gradient winds present may also affect drainage flows. For example, whilst they can occur at any time during the year, drainage flows tend to be favoured in the region during spring, summer and autumn because gradient winds are lighter (Prescott , 1989).

In the Illawarra, drainage flows were found to have a depth of up to 280 metres (Prescott, 1989). At locations closer to the escarpment, such as Albion Park, drainage flows can be very distinctive. Their direction is strongly determined by the orientation of the Escarpment and at this site the drainage flows are westerly (Prescott, 1989). At sites such as Bellambi and Port Kembla, these drainage flows are not as well developed. Given their more exposed coastal location, gradient winds and sea breezes dominate, especially with onshore flows. A drainage flow would need to have high speeds to negate these effects. In addition, strong radiative cooling is less likely to occur at these coastal sites because of the heat buffering effect of the ocean.

Seasonal and diurnal variations in wind speed are important in the study of air quality because they affect the transport and dispersion of air pollution. Seasonally, the passage of anticyclones across the region produces lighter gradient winds in spring, summer and autumn; and stronger gradient winds in winter. Air pollution in the Illawarra tends to be very low in the winter during westerly winds because it is generally carried away from the land and out to sea. The opposite occurs in summer with the prevailing on-shore (north-easterly) winds.

In terms of diurnal variations, wind speeds in the Illawarra are typically greater in the afternoon / evening, than at night or mornings. This is mainly due to the effect of sea breezes. Given its seaside location and greater exposure to gradient winds, the percentage calms for Port Kembla tends to be much lower than other sites located further inland on the coastal plain. This is demonstrated by Tables 9 and 10 which summarise the percentage calms both seasonally and diurnally for the BoM automatic

62 weather stations (AWS) at Bellambi and Albion Park. Bellambi has a seaside location very similar to that of Port Kembla and for this reason we would expect a similar wind pattern to occur. These changes in regional ventilation can also affect the volume of air available to dilute pollutants from industry. Many night time air pollution complaints reported to government regulatory agencies, may be related to reduced ventilation of the area at night rather than changes in industrial emission levels (Crisp et al, 1984). It has been stated that a doubling of wind speed can halve the pollutant concentration in the ambient air (Liu and Liptāk, 2000)

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Table 10 Percentage Frequency of Calms at Albion Park AWS (Source BoM, 2007)

The interplay of these seasonal and diurnal wind patterns for Port Kembla is further illustrated by the wind roses in Figure 15 for the Port Kembla Signal Station based on data for the years 1957 to 1976 (BoM, 2007).

63 Please see print copy for image

Figure 15 Annual Windroses for Port Kembla based on data from the Port Kembla Signal Station for 1957 to 1976 (from BoM, 2007).

64 The wind rose for summer indicates sea breezes from the north-north east as well as winds from the south-south east associated with southerly changes. The wind rose for autumn shows the arrival of the west - southwest winds common during winter and also the south-south east winds which bring rain to the region during late summer and autumn. The wind rose for winter shows that sea breezes tend to be rare and west- south-westerly winds dominate. The wind rose for spring shows the dominance of west to south-west winds as well as the north east sea breezes that return after the winter period. The percentage calms in Figure 15 (Port Kembla Signal Station) tend to be higher than those in Table 9 (for Bellambi AWS). This is because in the past “calms” at Port Kembla Signal Station were estimated on the basis of visual observations, in contrast to the sensitive anemometers used today at modern automatic weather stations (BoM, 2007).

Important to the understanding of air quality in the region is the interplay of the gradient winds, sea breezes and drainage flows. Undercutting can occur when a wedge of air from a developing flow pushes in underneath another flow, forcing the original flow aloft. For example, seabreezes can undercut gradient winds and seabreezes can in turn be undercut by drainage flows. In air sheds such as Sydney, this is a regular sequence (Hyde, 1991; EPA, 1996). Whilst variations can occur from day to day, it is reasonable to expect a similar continual flux of one flow undercutting another in the Illawarra air, resulting in regular and often complex changes to the vertical structure of the atmosphere.

Air pollutants from an emission source, such as a tall stack, can disperse horizontally and vertically. The rate of horizontal dispersion is controlled by wind speed. Vertical dispersion is controlled by the degree of atmospheric stability (or turbulence). Atmospheric stability is influenced by a number of factors, in particular the heating and cooling of the land (by the sun) and wind speed. These affect its thermal and dynamic state, which in turn affect its vertical structure.

Air normally cools with increased elevation at a rate of around 3 degrees Celsius for every 300 metres (the dry adiabatic lapse rate). The observed change in temperature with height is called the environmental lapse rate. Where the environmental lapse rate equals the dry adiabatic lapse rate the air is termed neutral (Sturman et al, 2006). If

65 the environmental lapse rate is greater than the dry adiabatic lapse rate, the air is termed stable (inversion), and the reverse, unstable (Sturman et al, 2006). Stable (inversion), neutral and unstable conditions can help or hinder the dispersion of air pollutants.

On still, clear nights as the land cools, cold air can pool under warmer air forming stable (inversion) conditions. These are sometimes called radiation or nocturnal inversions. In the Illawarra, this could also result from westerly drainage flows that drain from the Escarpment towards the coast. This type of inversion would be expected to be common in the region in autumn, winter and spring, when lighter gradient winds and cooler nights are more conducive to drainage flow formation. Inversion conditions typically break up during the morning as heating of the land forms a mixed layer (neutral or unstable conditions) next to the surface that deepens with time. Inversions can also occur at the interface zone between sea breezes and the prevailing gradient wind. These are called advection inversions. For example, Prescott (1989) has shown through radiosonde measurements in the Illawarra that a strong discontinuity can exist between the cooler, moister north easterly sea breeze and the warmer, dryer north westerly gradient wind – resulting in inversion conditions. It is known that these types of inversions can trap both local and interregional pollution (EPA, 1997).

In addition to surface inversions, persistent high level inversions can also occur during prolonged anticyclonic weather. These are called subsidence inversions. Air settling in high pressure systems is compressed and warmed as it subsides. These inversions occur typically 300 to 3000 metres above the ground (Bureau of Meteorology, 2007). If such inversions lie above radiation inversions, they can act as a lid to convection during the day and prevent pollutants from rising to greater heights. Subsidence inversions during the winter can be particularly serious from an air pollution perspective. This is because they often descend whilst a radiation inversion gradually rises during a prolonged period of calm anticyclonic weather. This can, after two or three days, result in a very intense inversion at a rather high level (compared to a usual radiation inversion). It is only brought to an end by the movement of the anticyclone. These large inversions have been implicated in acute air pollution episodes, such as the London smog disaster of 1952, which resulted in several

66 thousand deaths (Palmer, 1974). Subsidence inversions in Australia are, however, seldom low enough to cause high pollution levels to develop. Nevertheless the meteorological conditions associated with them are conducive to radiation inversions.

Sullivan (1956) states that pollution episodes, such as the London smog disaster, are unlikely to occur in NSW. This is because its major cities, Newcastle, Sydney and Wollongong, are not confined to valleys and rarely subject to extended periods of calm. Normally, the frequent air movement is sufficient to disperse pollutants and the longest period of calm recorded is about 14 hours (Sullivan, 1956).

2.8 Pollution Dispersion from Tall Stacks

Historically, tall stacks have been synonymous with copper smelters around the world, as a principal pollution control measure to dilute and disperse sulfur dioxide pollution. They were designed with the aim of ensuring ground concentrations of sulfur dioxide and other pollutants met recognised air quality goals to reduce impacts on human health and the environment. The maximum ground level concentration of pollutants can be theoretically determined from the following equation (from Godish, 2004).

Cmax = 2Q σy 2 π u e H σz Where: 3 Cmax = maximum ground level concentration of pollutant (g/m ) Q = mass emission rate of pollutant (g/s) u = wind speed at stack height (m/s) H = effective stack height (m) π and e = constants

σy = crosswind diffusion (dispersion) coefficient

σz = downwind diffusion (dispersion) coefficient

It can be shown from this equation that the ground concentration of a pollutant varies inversely as the square of the effective stack height. Significant reductions in the ground level concentration of a pollutant can be achieved by increasing the effective

67 height of the stack. The effective stack height can be increased physically or by increasing the exit velocity or temperature (buoyancy) of the pollutants (or both). The equation also shows that a reduction in ground level concentrations can also be achieved by reducing the mass emission rate of the pollutant.

Several rules of thumb have been suggested for stack design that provide a useful guide to their performance (Lund, 1971). Ground level emissions from a stack typically first rise to a maximum and then decrease as the distance from the stack increases. The average distance at which the maximum ground level concentration occurs is about 10 stack heights from the stack in a horizontal direction. In addition, ground level concentrations on the order of 0.001 to 1% of the stack concentration are possible for a properly designed stack. This is a wide range and reflects the high degree of science involved in the design of stacks.

As indicated in Section 2.7, the dispersion of air pollution from a tall stack is governed by the degree of atmospheric stability and ambient wind conditions. Complex patterns of stack plume behaviour can arise from different atmospheric stabilities. This is because the stability of the atmosphere can affect the rate of vertical mixing and dilution of the plume. These plume behaviours include looping, coning, fanning, lofting, fumigation and trapping. They are shown in Figure 16 (from Zannetti et al, 2003). Of particular interest are plume behaviours such as “looping” and “fumigation” because they can cause sudden increases in ground level concentrations close to a source. Conversely, fanning and lofting plumes are considered more favourable conditions with tall stacks. The circumstances under which these plume behaviours can occur are discussed below.

A fanning plume occurs in stable air, which mostly occurs at night. The plume rises to a height determined by the degree of atmospheric stability and its thermal buoyancy. It cannot spread vertically but can disperse horizontally. This produces a fan which is then carried downwind in a thin band. Looping occurs with an unstable atmosphere. Unstable conditions are most likely on a bright, sunny day with light winds. They are frequently evident by midday when convection as the day warms up generates large eddies which bring the plume to ground and also lift it upward.

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Figure 16 Idealised patterns of stack plume behaviour. The lines on the left figures represents the dry adiabatic lapse rate (dotted) and environmental lapse rate (solid). (From Zanetti et al, 2003)

69 This causes the looping behaviour and intense turbulent mixing. The average ground level concentration increases very rapidly with distance from the stack, attains its peak value and then decreases farther downwind. Because of the vigorous mixing associated with the thermals, conditions rapidly decrease away from the source. Actual photographs taken of fanning and looping stack plumes from the Port Kembla smelter are shown in Figure 17 and 18. Please see print copy for image

Figure 17 Port Kembla Smelter stack plume under fanning conditions in the early morning. Looking north from Shellharbour. Photo date 2000. Photo courtesy of DECC. Please see print copy for image

Figure 18 Port Kembla Smelter stack plume under looping conditions, looking north from Primbee. Photo date circa 1980. Photo courtesy of DECC

70 A neutral atmosphere results in a pattern of dispersion between these two extremes, termed coning. It usually accompanies cloudy conditions with moderate winds and very weak convection. It can occur during the day or night. Lofting is most often observed near sunset, as the nocturnal surface inversion begins to develop just below the top of the stack and reduce diffusion downward. At the same time eddies in the residual mixed layer can still be active and cause intensive diffusion above the surface inversion.

There are two other situations that can result in high ground level concentrations downwind from a tall stack. These are called fumigation and trapping. Fumigation can be further divided into two categories; transient and steady state. Transient fumigation occurs shortly after the sun rises on a clear morning, under stable conditions. If an existing nocturnal inversion layer is present just above the top of the stack it acts as a lid. As the land warms up, the inversion layer begins dissipating and is slowly replaced by the mixed layer that increases with depth during the morning. Once the layer reaches the height of the plume, the newly developed convective eddies rapidly spread the pollutants within the mixed layer, causing a sudden rise in ground-level concentrations. Since the depth of the well mixed layer will continue to increase in depth, high concentrations tend to be a transient phenomenon (persisting typically for periods of less than an hour), hence the name. This phenomena is also sometimes known as radiation fumigation because it is caused by solar heating. Sea breeze fumigation (also called shoreline, steady state or coastal fumigation) occurs when stable marine air flows across a heated land surface. This produces a well mixed layer next to the surface and stable air above it and a Thermally Induced Boundary Layer (TIBL) between them. A fumigation situation arises when plumes emitted into the stable air eventually intercept the TIBL and are carried down to the surface. This is shown in Figure 19. Sea breeze fumigation is a common feature of air pollution meteorology in coastal industrial locations. It is potentially a more serious situation than transient fumigation because a steady state situation can develop where the shape of the boundary layer remains static, causing continuous fumigation. This fumigation can persist at the same location for hours and furthermore, the same area can be affected repeatedly as the sea breeze occurs day after day in coastal environments (CASANZ, 2000).

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Figure 19 Sea breeze fumigation. The lines on the left figures represent the dry adiabatic lapse rate (dotted) and environmental lapse rate (solid). (From CASANZ, 1999)

The other adverse condition that can cause high ground level concentrations downwind from a source is trapping. This occurs when a neutral or unstable layer next to the surface has an inversion or stable layer above it. In this situation, emissions may initially disperse downwind from a source in the normal fashion, but eventually become trapped within the surface layer by the capping inversion above which can act as a lid to the vertical dispersion of pollution. Trapping can occur within shallow sea breezes, shallow drainage flows, or both. It can also be caused by subsidence inversions associated with regions of high pressure (anticyclones).

Studies have shown that the relatively strong winds encountered in the Wollongong/Port Kembla region significantly influence atmospheric stability and result in near neutral stability for a large proportion of the time (Dames & Moore, 1994). Hyde (1992) and EPA (1996) have, however, shown that elevated concentrations of sulfur dioxide around Wollongong/Port Kembla were consistent with poor summertime dispersion conditions. This resulted from emissions from the copper smelter main stack looping down to the ground during the morning as the land warmed up, but before the onset of local sea breezes, or as a result of sea breeze fumigation.

72 2.9 Summary of Background

Sulfur dioxide (SO 2) is a colourless, irritating and reactive gas with a strong odour. Emissions of sulfur dioxide can mix with water vapour to form acids that can damage vegetation, affect soils and corrode materials. Sulfur dioxide has a range of human health effects. On a global basis fossil fuel burning accounts for most of the sulfur dioxide generated by human activities. In both Australia and NSW, this is predominantly associated with electricity supply and our reliance on coal, which contains small amounts of sulfur. In the Wollongong local government area, the primary source of sulfur dioxide is iron and steel manufacturing. Sulfur dioxide is principally generated by the combustion of fuels such as coal and from the small amounts of iron sulfide (pyrites) in the iron oxide ores that are processed. Basic non- ferrous metal manufacturing, such as the copper smelter at Port Kembla is the second major source. Here sulfur dioxide is generated by the smelting of copper sulfide ores to produce copper.

Generally speaking, sulfur dioxide is not an issue on a regional scale in NSW, but it can, however, be a concern in very localised areas around major emitters where short term peaks in ambient atmospheric concentrations are known to occur. Sulfur dioxide is widely recognised as a significant air pollutant in the Wollongong/Port Kembla area due to heavy industry in the area, in particular the copper smelter. For this reason, the emission and control of sulfur dioxide from the smelter has been of considerable interest to the community, industry and government, and forms the basis for this study.

Several techniques are available for the quantitative measurement of sulfur dioxide in air. Early monitoring techniques relied on titrimetric and conductametric (wet chemical) methods. These methods were not specific for sulfur dioxide and measured “acid gases”. With advances in technology, analytical instrumentation methods (spectrometric) for routine and direct air measurement specific for sulfur dioxide emerged in the early 1980s.

Historically the major environmental issue associated with the primary production of copper has been the emission of sulfur dioxide to air from the smelting of copper

73 sulfide ores. The vast majority of copper produced in the world today, including the copper smelter at Port Kembla, is produced by this pyrometallurgical process. This is traditionally achieved in the stepwise and batch type operations of smelting and converting furnaces. These operations produce discontinuous and highly variable sulfur dioxide gas concentrations and volumes, which make their collection and control difficult. In recent years, there have been significant advances in copper production which have resulted in newer processes which combine the above smelting and converting processes, enabling continuous production of copper.

The amount of sulfur dioxide released depends upon the amount of sulfur in the copper feed and whether facilities are in place to capture it. Prior to the mid 1900s, most smelters typically vented all gases to atmosphere via tall stacks. During the 1960s and 1970s, growing concerns about the effects of sulfur dioxide on the environment and human health, as well as increasing pollution control legislation resulted in increasing capture and fixing of sulfur dioxide. The most common method was the production of sulfuric acid. Modern smelting is based on maximising the production of a continuous, constant volume and high strength sulfur dioxide gas stream to permit recovery of sulfur dioxide as sulfuric acid, the accepted control technique of the industry today.

The transport and dispersion of pollutants into ambient air is strongly dependant on meteorological factors such as wind speed and direction. There are distinct seasonal variations to wind direction in the Wollongong/Port Kembla area which can be used to predict and assess the transport of pollution from source to receptors. The most notable of these is the predominant north-easterly breeze in the summer months. Atmospheric stability can also significantly influence dispersion of pollutants from tall stacks. Complex patterns of stack plume behaviour, such as fanning, coning, looping and fumigation, can arise from different atmospheric stabilities. Both looping and fumigation can result in sudden increases in ground level concentrations of pollutants close to the source. Elevated ground level concentrations of sulfur dioxide around Wollongong can be attributed to looping and fumigation of the plume from the tall stack at the copper smelter at Port Kembla.

74 3. Results and Discussion

3.1 Overview

Systematic atmospheric pollution measurements commenced in the Wollongong/Port Kembla towards the end of 1953 (Sullivan, 1961) and have continued in various forms to the present day. Initially the work, undertaken by the NSW Department of Public Health (Division of Occupational Health), was limited to the measurement of smoke and dustfall, as part of the state survey, but it was extended to include sulfur dioxide between 1957 to 1961 (Sullivan, 1961). This was partly due to the widening of the general survey of air quality in NSW. The investigation at Port Kembla was also primarily designed as a means of evaluating two known specific sources of sulfur dioxide emissions, namely the ERS copper smelter and AFL acid plants, which were giving rise to public complaints (Sullivan, 1961). A review of government air quality monitoring reports indicates that sulfur dioxide monitoring did not recommence in the Port Kembla/Wollongong area until 1970 (Reports to the Director General of the Department of Health, 1971). Whilst the exact number and locations of monitors has varied over time, this monitoring has continued to the present day. Monitoring of ambient levels of sulfur dioxide has also been undertaken by industry, although publicly reported data appears only to be available from 1988 onwards (EPA, 1988b). This section draws on all publicly available government and industry data from 1957 to 2006.

Two key factors that can affect the observed ambient atmospheric sulfur dioxide levels are also investigated in this section. The first is smelting operations and associated pollution controls at the Port Kembla copper smelter. The second is NSW state government environment protection legislation relating to the regulation of air pollution from the smelter.

Whilst all major local sulfur dioxide emission sources are outlined, a particular emphasis has been placed on the copper smelter at Port Kembla. This is because it has had the most dominant influence on sulfur dioxide levels measured in the air in the region. An outline of major operations at the smelter known to generate sulfur dioxide and associated pollution abatement measures, from the establishment of operations in 1907 to the present day, is provided.

75 Government regulation, in particular NSW State Government, and its effect on sulfur dioxide emissions and their control at the smelter is also investigated in this section. This includes an outline of key legislation which regulated sulfur dioxide emissions from the smelter from the early 1900s to present day.

The evolution of these factors over time and the interplay between them are explored in this chapter, together with the monitoring data to understand their influences on ambient atmospheric sulfur dioxide concentrations recorded in the region. This monitoring data was examined in four geographical zones - Port Kembla Township, Central, Wollongong City and Outer - to further investigate spatial trends in air quality over time.

The information in this Chapter has been divided into four distinct time periods, namely 1907 to 1965 (Section 3.3); 1966 to 1988 (Section 3.4), 1989 to 1995 (Section 3.5) and 1996 to 2006 (Section 3.6). The study demonstrates that these time periods coincide with paradigm shifts in the design, operation and/or regulation of the smelter that influenced atmospheric ambient sulfur dioxide levels. These time periods relate to: • 1907 to 1965 – Commencement of smelter operations leading up to the commissioning of the landmark 198 metre main stack; • 1966 to 1988 – Post commissioning of 198 metre main stack leading up to first major smelter upgrade; • 1989 to 1995 – First major redevelopment of the smelter with provision of sulfur capture using acid plant. This was followed by smelter closure in 1995; and • 1996 to 2006 – Second major redevelopment of the smelter with increasing sulfur capture in acid plants. Smelter recommenced operation in 2000 and closed in 2003. The first period, 1907 to 1965, includes several decades prior to monitoring data being available. This early information on smelter operations, sulfur dioxide emission and controls and government regulation provides an important context to future reforms.

76 3.2 Limitations and assumptions in data analysis

Major human sources of sulfur dioxide in the Wollongong/Port Kembla region

This study has placed a particular emphasis on the copper smelter at Port Kembla as, historically, the most dominant source of elevated levels of sulfur dioxide measured in the ambient air in the Wollongong/Port Kembla area, between 1957 to 2006. Whilst this assumption is supported in considerable detail further in this chapter, for the moment it is based upon several key studies.

Bell and Sullivan (1963) concluded that, following an intensive campaign of sulfur dioxide monitoring in the area between 1957 and 1961, the copper smelter was the dominant source of high concentrations of sulfur dioxide, that sometimes occurred, especially when compared to the steelworks and acid plants at AFL.

In 1986, the SPCC published the Wollongong – Port Kembla Pollution Control Study (SPCC, 1986b). The study estimated the contributions of sulfur dioxide from various industries. A summary of the key sources is provided in Table 11. Whilst there were some debates about the accuracy of the estimated load from the smelter (see later in this section), it shows that the copper smelter was the dominant industrial point source of sulfur dioxide in the area. This is also confirmed by reports in the press during the period by the State Pollution Control Commission (Illawarra Mercury, 13 May 1986).

There are, however, several other human sources of sulfur dioxide in the region that are important to consider over the period from 1957 to 2006, when sulfur dioxide monitoring has occurred. These include the steelworks, municipal power stations, chemical works and other more diffuse sources such as burning fuel oil in kilns and boilers. These sources could have contributed to atmospheric concentrations of sulfur dioxide measured.

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Table 11 Inventory of annual sulfur dioxide emissions (tonnes/year) from the Wollongong – Port Kembla Pollution Control Study (SPCC, 1986b).

As indicated in Table 11, the steelworks at Port Kembla is, and has been, another key source of sulfur dioxide in the region. Iron production began in 1928 and steel production in 1931 (Ogden, 1969). When sulfur dioxide monitoring began in the Wollongong/Port Kembla area in 1957, the steelworks was already well established. It consisted of three blast furnaces, coke ovens batteries (and by-products plant) and several open hearth furnaces (see Figure 20). Iron and steel production averaged around 1.32 and 1.83 million tons per year respectively (Ogden, 1969). With the commissioning of No 4 Blast Furnace in 1959, No 5 Blast Furnace in 1972 and No 6 Blast Furnace in 1996, iron production has risen to around 5.5 million tonnes per year (Sinclair Knight, 1993). The replacement of open hearth furnaces with Basic Oxygen Steelmaking (BOS) in the early 1970s has also seen steel production grow to around 5 million tonnes per annum (Sinclair Knight Merz, 1993).

78 Please see print copy for image

Figure 20 View of Steel works looking northeast from Cringila. Circa 1961 (Photo courtesy of DECC)

At the steelworks, the Sinter Plant, furnaces (fuel combustion) and coke ovens are all sources of sulfur dioxide. The main point source is the sinter plant and this is typical of most steelworks that rely on sintering (Sinclair Knight Merz, 2001). The Sinter Plant at BHP is used to agglomerate raw materials including fine iron ores, waste dusts, coke and fluxes into course granules by heating on a moving bed (strand). This resultant sinter provides a suitable feed material for the blast furnaces to make iron. The sulfur dioxide arises from the sulfur contained in the iron ores processed (for example, iron pyrites). It can also result from the coke ovens gas which is burnt at the Sinter Plant to produce the heat necessary to make sinter. Coke ovens gas is an indigenous fuel generated in the making of coke at the steelworks. It is used extensively on the site as a fuel in many furnaces and can contain more sulfur than natural gas (mostly present as hydrogen sulfide).

The first (No 1) sinter plant was commissioned in 1957. The current (No. 3) Sinter Plant was commissioned in 1975. In 1997, a major Pollution Reduction Program (PRP) was attached to the environment protection licence issued to the company by the EPA, to improve the environmental performance of the Sinter Plant. This

79 included significant reductions in visible emissions, dust and dioxins in the waste gases from the Sinter Plant stack. These reductions were required to be completed by the end of 2002. A carbon packed bed system was ultimately selected as the waste gas cleaning technology for the new Sinter Machine Emission Reduction Plant (SMERP) (Sinclar Knight Merz, 2001). The Sinter Plant and SMERP is shown in Figure 21.

B A C

Figure 21 View of Steelworks looking west along Christy Drive, Inner Harbour. A = Sinter Plant. B = SMERP. C = Ironmaking area. Photo date November 2007 (Photo by author).

It was also recognised that as a result of the Pollution Reduction Program emission reduction requirements, significant reductions in oxides of sulfur and nitrogen would also result from the chosen technology (Sinclar Knight Merz, 2001). With respect to sulfur dioxide emissions, the existing Sinter plant emitted approximately 4100 tonnes per year and this was to be reduced by around 60% to about 1200 tonnes per year with the SMERP (Sinclar Knight Merz, 2001). A sulfur rich gas by-product (containing about 18% sulfur dioxide) would be generated and this was going to be directed to the existing acid plant at Orica – Port Kembla (see below) for processing into sulfuric

80 acid. Any excess was to be converted to ammonium sulfate fertiliser by reaction with ammonia (Sinclar Knight Merz, 2001).

The SMERP was commissioned in mid 2003 and satisfied the PRP performance requirements for fine particles, plume visibility and dioxins. To date, however, the sulfur dioxide reduction component has not been realised. Problems with the ability of the Orica acid plant to accept the sulfur rich gas lead to a reappraisal of the proposal. Bluescope now intend to install a plant to convert this sulfur dioxide to gypsum (calcium sulfate) by reaction with lime (calcium oxide). This facility is expected to be commissioned by the end of 2007. Bluescope hope to achieve a reduction in sulfur dioxide levels from the Sinter Plant by at least 750 tonnes/year with the new gypsum plant. In the interim, however, the Sinter Plant continues to emit around 4100 tonnes/year of sulfur dioxide and remains the largest current (2007) point source of sulfur dioxide in the Wollongong/Port Kembla area. A copy of the current EPA environment protection licence for Bluescope Steel is included on the CD in Appendix 1 of this thesis.

As stated in Section 2.2, whilst the sulfur content of Australian coal is very low, the large amount of coal burnt in power stations can mean they are major sulfur dioxide emitters. In 1912 a coal fired power station was constructed at Port Kembla North (near the corner of present day Christie Drive and Old Port Rd) (Hoogendoon, 1999). It began supplying electricity in 1915 and underwent several major expansions in capacity, before its operation gradually wound down with the commissioning of Tallawarra Power Station in 1955. The power station finally closed around 1969. This power station was smaller in scale than Tallawarra Power Station (Hoogendoon, 1999). Whilst it could have contributed to sulfur dioxide levels in the locality, its operation was limited or had ceased before ambient sulfur dioxide monitoring commenced in the Wollongong/Port Kembla area in 1959 (Sullivan 1956; Hoogendoon 1999).

The Tallawarra Power Station (Figure 22) was a much larger coal fired power station that operated during the period sulfur dioxide monitoring occurred. It was located near Yallah on the western shore of Lake Illawarrra. Station A, consisting of four, 30 megawatt units, was commissioned between 1954 to 1957 and operated until 1985.

81 Station B, consisting of two, 100 megawatt units, was commissioned between 1960 to 1962 and operated until 1988 (Elcom, 1987; Pacific Power, 1997).

Data on the operation of the Tallawarra Power Station in 1985 (CSIRO, 1985) indicates that the maximum emission rate of sulfur dioxide from Station A was around 0.19 kilograms per second and Station B was around 0.28 kilograms per second. If we assume continuous operation, this translates to an annual load of sulfur dioxide emitted to air of up to 6000 and 9000 tonnes per year from each station respectively. Depending on whether Station A, Station B or both were operating, the maximum emission load of sulfur dioxide could have ranged between 6000 to 15,000 tonnes per year. This represents a significant point source in this area and could account for some elevated sulfur dioxide values seen in Albion Park area, during 1987, when monitoring began in the locality.

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Figure 22 Tallawarra Power Station. Photo date circa 1962. From the collections of the Wollongong City Library and Illawarra Historical Society.

82 The production of sulfuric acid at the Orica Pty Ltd, Port Kembla site has occurred from the 1920s to date (formerly Incitec Pty Ld and, before that, Green Leaf Pty Ltd and Australian Fertilisers Ltd). Australian Fertilisers Ltd originally manufactured sulfuric acid on its premises in an acid plant (No. 1 plant) via the “Chamber” process by “burning” elemental sulfur (ERS, 1938). In 1960, a second plant commenced operation. It relied on the Contact process for making acid but also had provision to accept sulfur dioxide gases from the recently installed sinter plant at the adjacent copper smelter (South Coast Times, 28 Jan 1960). Both of these plants released some sulfur dioxide which was reported at times to impact on nearby residences at Port Kembla (Sullivan, 1961). These acid works were, however, known to be a much less significant source of sulfur dioxide, compared to either the steelworks or copper smelter (Sullivan, 1961). This conclusion was supported by measurements of not only sulfur dioxide but nitrogen dioxide in the ambient air (Bell and Sullivan, 1963). It is known that Chamber plants emit more nitrous oxides (including nitrogen dioxide) than contact plants (Lund, 1971). This allowed the relative contribution of the sulfur dioxide from AFL and ERS to be assessed. The acid plants were located in original (No. 1) works area of AFL which was immediately adjacent to the ERS works (close to the corner of present day Darcy Rd and Gloucester Boulevard, Port Kembla).

In the early 1970s, a new contact acid plant was built, approximately 500 metres west, (near the corner of Foreshore Rd and Old Port Rd, Port Kembla). Some extensive start up problems and numerous complaints about highly visible emissions containing sulfuric acid mist are recorded (SPCC, 1979a). These problems were addressed when the company installed further controls (including mist eliminators). Air quality monitoring by the SPCC indicated that the plant could operate and meet the regulation emission limits for acid plants that existed at the time (SPCC, 1979a). In 1989, the plant was modified to regenerate spent alkylation acid from oil refineries (SPCC, 1989) and this has continued to the present day, supplemented by burning of elemental sulfur. Operations have also been expanded to include the production of other sulfur based chemicals (from sulfur dioxide generated on-site), for example sodium metabisulfite. This is shown in Figure 23. A copy of the current EPA environment protection licence for Orica is included on the CD in Appendix 1 of this thesis.

83

Figure 23 View of Orica acid works from Foreshore Rd, Port Kembla. Photo date November 2007 (Photo by author).

In contrast to major industrial point sources of sulfur dioxide, more diffuse sources have been known to contribute to measured ambient levels of sulfur dioxide at a regional level. There was a peak in acid gases in many NSW cities, including Wollongong, in the late 1960s and early 1970s, due a greater reliance on imported fuel oil (Report of the Director General of Public Health, 1968; SPCC, 1983a). Whilst Australian fuel oil is low in sulfur (<1%), imported fuel oil can contain higher amounts (sometimes up to 2.5% sulfur) (SPCC, 1983a). The problem risked eroding the improvements in air quality achieved when many industrial furnaces in NSW were converted from coal to oil usage. For example, the No 1 Power House at the Port Kembla steelworks had commenced conversion from coal to oil around 1965 (Daily Mercury, 18 June, 1965 ; Report of the Director General of Public Health, 1966). The ambient sulfur dioxide levels gradually decreased with the burning of residual Australian fuel oil and then levelled out during the rest of the decade when industrial furnaces began switching from fuel oil to natural gas (SPCC, 1983a).

84

Whilst this study has focussed on the copper smelter at Port Kembla as the main contributor, where these other sources may have significantly influenced the levels of sulfur dioxide measured in the ambient air, they will be accounted for when interpreting the monitoring data.

Estimating annual sulfur dioxide load generation from copper production

In order to ascertain the effect of changes in the annual load of sulfur dioxide emitted from the smelter on the measured ambient atmospheric levels of sulfur dioxide, it is important that sulfur dioxide load data be located or generated. From the mid 1980s, actual sulfur dioxide load data can be found in Environmental Impact Statements (for example; Kaybond, 1988 and Dames & Moore, 1994) or other studies (for example SPCC, 1986b and National Pollutant Inventory, 2007). Where available, this load data has been used in this study. Prior to the mid 1980s, however, when this data was not directly available, a method of estimating the load of sulfur dioxide generated had to be developed for the purposes of this study.

As indicated in Sections 2.5 and 2.6, there is a relationship between copper production and the load of sulfur dioxide generated. Sulfur dioxide emissions may range from less than 4 kilogram to 2 tonne per tonne of copper produced. The amount (load) of sulfur dioxide actually released can depend on several factors, including the amount of sulfur in the copper concentrate feed, the amount of concentrate used, the amount of scrap copper used and whether facilities are in place to capture the sulfur dioxide generated (for example an acid plant). With this in mind, reported copper production data was investigated to develop a model to estimate the load of sulfur dioxide generated from the Port Kembla copper smelter.

Several sources of copper production data for the Port Kembla copper smelter are available in the publicly accessible literature. This includes blister copper produced solely from copper concentrates, anode copper (also known as blister copper), cathode copper, refined copper and total saleable copper (which can include cathodes and anodes). Table 12 summarises some of this copper production data for blister (mainly from concentrates), anode and refined copper from various published sources. The

85 author found that there can be considerable variation in this reported data between publication sources, even for the same year.

Both blister (from concentrates) and anode copper are closely linked to the pyrometallugical processes which generate sulfur dioxide, namely matte smelting and converting. For this reason, they can be used to estimate sulfur dioxide load. In comparison, refined copper is considered a weaker indicator of sulfur dioxide generation. This is because it is linked less to the smelting of sulfide ores and more heavily influenced by other factors such as scrap recycling, electrorefining and casting. It can be seen from Table 12 that there is no clear relationship between anode copper and refined copper production. Given this, refined copper production data was not used to estimate sulfur dioxide loads.

Table 12 Summary of copper production data (blister (from concentrates), anode, refined) for the Port Kembla smelter for various years 1911 to 1990 (Compiled from various sources) and estimated sulfur dioxide load. Year Tonnes of blister Tonnes of anode Tonnes of refined Estimated copper (produced copper (total) copper A Annual load of mainly from sulfur dioxide copper (tonnes/year) concentrates)

1911 nd nd 14,400 nd 1934 nd nd 13,484 nd 1935 nd nd 14248 nd 1936 nd nd 19387 nd 1937 nd nd 19228 nd 1938 nd nd 19,713 nd 1939 nd nd 21,668 nd 1940 nd nd 21,222 nd 1941 nd nd 26,673 nd 1942 nd nd 23,230 nd 1943 nd nd 20,960 nd 1944 nd nd 23,118 nd 1945 nd nd 28,173 nd 1946 nd nd 17,090 nd 1947 nd nd 24,009 nd 1948 nd nd 22,774 nd 1949 nd nd 22,962 nd 1950 4,000 B 20,000 B 18,553 8,000

86 1951 nd nd 23,105 nd 1952 nd 22,150 C 26,383 8,860 1953 5326 D 22,032 C 26,383 10,692 1954 4073 24,789 C 33,297 8,146 1955 nd nd 37,594 nd 1956 nd nd 41,828 nd 1957 nd nd 41,813 nd 1958 9,174 E 32,872 E 55,543 18,348 1959 9,516 E 39,558 E 50,164 19,032 1960 9,899 E 30,218 E 37,355 19,798 1961 7,188 E 25,095 E 33,264 14,376 1962 nd nd 35,385 nd 1963 nd nd 49,914 nd 1964 nd nd 53,054 nd 1965 nd 23,272 F 52,286 13,963 1966 nd 32,765 F 43,765 19,659 1967 nd 47,799 F 56,829 28,679 1968 nd 50,581 F 57,243 30,349 1969 nd 55,426 G 54,536 33,256 1970 nd 50,662 G nd 30,397 1971 nd 45,872 G 46,370 27,523 1972 nd 42,529 G nd 25,517 1973 nd 44,131 G nd 26,479 1974 nd 42,740 H 50,687 25,644 1975 nd 45,693 H 42,550 27,416 1976 nd 34,104 I 43,716 20,462 1977 nd 43,676 I nd 26,206 1978 nd 36,566 I nd 21,940 1979 nd 45,844 I nd 27,506 1980 12,774 A 47,261 J 22,733 25,548 1981 nd 45,180 J 38,937 27,108 1982 nd 40,745 J nd 24,447 1983 nd 51,991 J 42,414 31,195 1984 nd nd 34,076 nd 1985 nd nd 35,000 nd 1986 nd nd 33,800 nd 1987 nd nd 36,600 nd 1988 12,695 K 39,859 K 33,900 25,390 1989 12,558 K 39,590 K nd 25,116 1990 16,414 K 39,000 K 22,400 32,828

Notes: A=Eklund & Murray (2000), B=ERS(1950), C=ERS(c1955), D=ERS(1954), E=ERS(1961), F=ERS(1969), G=ERS(1971), H=ERS(1978), I=ERS(1979), J=ERS(1984), K=ERS(1990). All figures in tonnes until 1966, then tonnes.

The amount of sulfur dioxide generated at the Port Kembla smelter would tend be at the higher end of the above range (about 2 tonnes of sulfur dioxide per tonne of copper produced), if the only source of copper used during smelting and converting

87 was copper concentrate ore and no sulfur capture was in place (Kaybond, 1988). Where blister copper (from concentrates) data is available it has been used to estimate the load of sulfur dioxide generated. This is based on the assumption of two tonnes of sulfur dioxide being generated for every tonne of blister copper (from concentrates) produced.

Where blister copper (from concentrates) data was not available, anode copper production data was used to calculate sulfur dioxide loads. The above 1:2 ratio cannot apply to anode copper because copper scrap is used at the smelter (in addition to copper concentrates) to produce anode copper.

As stated in Section 2.5, copper scrap is often added during matte converting to regulate temperature control. It is also added to the smelting, converting and/or refining (anode) furnaces as a valuable recycling opportunity. This can increase anode copper production without increasing the amount of copper sulfide concentrate feed and requires much less energy to process than unrefined ores.

Copper scrap was particularly important for ERS because it helped to correct an imbalance between the smelting and refining capacity of the operation (Eklund & Murray, 2000). The greater capacity for refining at ERS was a legacy from the days when the main function of ERS was to refine the blister copper from Mount Morgan (Qld) and Mount Lyell (Tas). This imbalance was gradually reduced over the years as smelting capacity was expanded, particularly with the introduction of blast furnaces in the 1930s and 1950s and Noranda reactor in the late 1980s. In any case, as the amount of copper scrap increased, the amount of sulfur dioxide generated per tonne of anode copper produced would tend to decrease, from the 2 tonnes stated above.

Prior to the redevelopment of the plant in the late 1980s, about 50% of its copper feed came from scrap (Andrews, 1993). Subsequent expanded smelting operations relied on less than 25% copper scrap (Dames & Moore, 1994). Up to one quarter of the blister copper produced from the converters at the Port Kembla smelter was known to be derived from copper scrap (Andrews, 1993). In addition, high grade scrap copper was also routinely added to the anode furnace and could constitute 40 to 70% of the anode copper produced. As a further complication, the scrap used was not only

88 limited to externally sourced material. Waste copper cathodes, anodes and reverts produced by the smelter itself were recycled within any or all of the smelting, converting or anode furnaces.

The actual amount of scrap used at the Port Kembla smelter varied from year to year, depending on availability and quality, as well as the smelting capacity of the furnaces. Because it was a custom smelter, the feed materials used could vary considerably in their source, composition and tonnages. The interplay of these factors can make estimating the amount of sulfur dioxide generated using anode copper production data complex. Comparison of available blister copper (from concentrates) and anode copper data in Table 12, suggests, however, that on average, 20 to 30% of the anode copper produced at the Port Kembla smelter came from copper concentrates.

Given this, where anode copper production data is available the amount of sulfur dioxide generated per tonne of anode copper was estimated as follows: • Prior to the 1960s: 0.4 tonne of sulfur dioxide, assuming 20% of the anode copper produced came from sulfide ores; and • From 1960s to 1980s: 0.6 tonne of sulfur dioxide, assuming 30% of the anode copper produced came from sulfide ores. The step change around 1960 recognises the new sinter plant and blast furnace expansion around 1959, which operated until the late 1980s. This slightly reduced the reliance on copper scrap.

The above assumptions were used to estimate the load of sulfur dioxide emitted by the copper smelter at Port Kembla using available blister copper (from concentrates) and anode copper production data. These estimates are shown in Table 12. This methodology provides a crude but useful indicator of the annual sulfur dioxide loads to air and allows comparisons to be made between years as production activity changed.

There is some limited information on annual loads of sulfur dioxide reported in the literature during the period 1910 to 1989, that allows comparisons to be made with those calculated in Table 12. Sullivan (1957) states that about 30 tonnes per day of sulfur dioxide was emitted by the smelter in the early to mid 1950s. This equates to

89 around 11,000 tonnes per year and compares well to the average value of 9,000 tonnes per year for the first half of the 1950s estimated in Table 12. SPCC (1986b) estimated up to 54,578 tonnes per year of sulfur dioxide could be released from the smelter in 1985. This is nearly double the average figure of 26,000 tonnes per year estimated for the 1980s in Table 12. The SPCC figure appears to be derived from projections of up to 90,000 to 100,000 tonnes per annum of copper concentrates processed at the smelter to make copper (SPCC, 1986b). This projection grossly exceeds the amount of copper concentrate feed actually available and used at the time (see Table 17 later in this thesis). Given this, we would expect the actual load of sulfur dioxide emitted from the smelter at the time to be considerably less than that reported by the SPCC, and more closely aligned with that in Table 12. This view is supported by reports in the newspaper, by ERS, at the time which indicate the SPCC value is an overestimate (Illawarra Mercury, 5 May 1986). Kaybond (1988) states that up to 44,000 tonnes per year of sulfur dioxide could be released from the smelter in 1988, based on the existing design of the plant. The estimated actual load of around 25,000 tonnes per year in Table 12 is just over half this design load. The estimated load is derived from reported amounts of blister copper produced from copper concentrate feed at the time (see Table 17 later in this thesis). It indicates that actual emissions of sulfur dioxide at the time were still well below the design values. This is again linked to limitations in availability of, or use of, copper concentrate feed at the time (Eklund and Murray, 2000).

Measurement of acid gases and sulfur dioxide

Systematic monitoring of atmospheric sulfur dioxide levels commenced in the Wollongong/Port Kembla in 1957. As stated in Section 2.3, this monitoring was initially undertaken using titrimetric or conductimetric (both wet chemical) methods. In the early 1970s, direct reading instrumental (spectrometric) methods, specific for sulfur dioxide emerged. Use of these methods commenced in the region at the Warrawong Baby Health Centre/King St – Warrawong in 1980. This technique is used at the present day.

As outlined in Section 2.3, early wet chemical methods were not specific for sulfur dioxide and the result was expressed as “acid gases”. This is because, in addition to

90 sulfur dioxide, other acidic gases that may be generated by industrial processes, for example, sulfur trioxide, nitrogen oxides or hydrogen chloride, will also acidify the test solution. Conversely, any basic gases from industry, for example, ammonia, would result in an alkaline solution being obtained.

In this study, it has been assumed that sulfur dioxide is the main constituent in all acid gas measurements in the Wollongong/Port Kembla area. Accordingly, all monitoring data expressed as acid gases in air quality monitoring reports has been presented as sulfur dioxide in this study.

A review of the monitoring data collected during this study does not indicate any monitor in the Wollongong/Port Kembla area where acid gases (wet chemical) and sulfur dioxide (spectrometric) measurements were conducted at the same time and in the same location, to enable direct comparisons to be made. There are examples in the government air quality reports of simultaneous measurements being made in other locations, for example, Rozelle Hospital (Sydney) in the early 1980s. It is not considered relevant to use this data for comparison purposes because any relationship between the measurements is highly dependant on the air shed and uniqueness of emission sources in the vicinity of the monitors.

On the basis of the literature review, there does not appear to have been any other major industries generating significant amounts of other acid or basic gases in the Wollongong/Port Kembla area. Operations such as Australian Fertilisers Ltd would have generated some acid gases including sulfur trioxide and nitric oxides (from acid manufacturing) as well as hydrogen fluoride (associated with fertilizer manufacturing) but this is considered to be low given the small scale of the operations. It is likely that the smelter and steelworks would have also generated small amounts of acid gases such as sulfur trioxide and nitric oxides. The coke ovens at the steelworks could have also generated some basic emissions, such as ammonia gas, however, because these ovens are of a recovery type, these emissions would also be expected to be low. Whilst the above acid or basic emissions are all expected to be minor, it is possible, however, that they could result in a slight under-estimate or over-estimate of the actual amount of sulfur dioxide present, from time to time.

91 Taking into account this information, the above assumption is considered reasonable given the major sulfur dioxide emitters (smelter, steelworks, power station) that occurred in the region at the time the acid gas measurements were made. This allows trends in the concentration of sulfur dioxide present in the atmosphere over extensive time periods to be assessed.

Use of wind direction to predict and assess air pollution

As stated in Section 2.7, wind direction is an important meteorological consideration in determining the transport of air pollution. In this study, it has been used as a key factor in determining the source of air quality degradation due to the presence of sulfur dioxide. In doing this the following assumptions have been made: • Wind direction data at Port Kembla is representative of wind direction across the study area; • Any air parcel carrying sulfur dioxide pollution has travelled in a direct path from the source to the receptor; and • There is no recirculation of sulfur dioxide air pollution in the study area.

The Wollongong/Port Kembla area is located on a coastal plain bounded to the west by the Illawarra Escarpment (up to 500 metres above sea level) and to the east by the South Pacific Ocean. This plain, however, is not flat and contains a series of small hills (up to 100 metres above sea level). This undulating terrain can influence the horizontal flow of air in several ways, the most obvious being topographic steering of synoptic winds or sea breezes in different directions as they pass over the area. These terrain effects are shown in Figure 24.

Different microclimates can also be generated on undulating lands which can alter wind flow. For example, hill slopes facing the sun can warm up faster and increase air temperature more rapidly than shaded slopes or flat land. This warm air may rise with sufficient strength to create very localised, anabatic winds. These can aid and abet sea breezes. Conversely, cold air draining from elevated higher lands, such as the Illawarra Escarpment, can flow down valleys and across the coastal plain and result in localised wind flows. This is especially the case in winter time, on cloudless

92 still nights. Because the resulting katabatic winds are induced by gravity, steeper slopes will result in faster winds. As they move down slope they force upward any warmer air and can also create local inversions, which can trap pollution.

Please see print copy for image

Figure 24 Terrain effects on wind flow (from Sturman et al, 2006)

Taking into account the above influences, Prescott (1989) has shown that wind direction in the Illawarra can vary across the coastal plain and no one location can be considered to be truly representative of the area.

It is known that recirculation of air pollution can sometimes occur in the Wollongong/Port Kembla area (Huo et al, 1999). For example, in summer, a northeasterly sea breeze can be quickly replaced by one from a southerly direction with the passage of a cold front (“southerly buster”). It is not common, however, for a wind in one direction to be replaced by one exactly opposite in direction (Crisp et al, 1984).

Whilst these considerations demonstrate that using wind direction to predict and assess the transport of sulfur dioxide pollution, is not always simple, the above assumptions are still considered reasonable for the purposes of this study. The study has relied on annual wind roses to explore dominant trends in wind direction in the study area and any broad variations on a seasonal and annual time scale. The above considerations are likely to be of greater significance if much shorter term time

93 periods are used. The majority of the sulfur dioxide monitors were all located within a 7 kilometres radius of the Port Kembla weather station used to provide wind direction data. This area is also where the coastal plain is at its widest point from the Illawarra Escarpment. Studies have shown that this location is generally representative of wind conditions across the study area (Crisp et al, 1984).

In 2004, the DECC examined hourly average levels of sulfur dioxide in the air versus wind direction as measured at its MAQS monitor located at Warrawong, for the period 2000 to 2003 (personal experience of the author). This is shown in Figure 25.

360 North north westerly source

270

180

(deg) direction wind hourly average 90 North easterly source

0 0.01 0.03 0.05 0.07 0.09 0.11 0.13 0.15 0.17

hourly average SO 2 (ppm)

Prior March 2002 Post March 2002

Figure 25 Distribution of hourly average sulfur dioxide levels versus wind direction at EPA MAQS at Warrawong (2000 to 2003)

The DECC study found that elevated levels of sulfur dioxide occurred at the monitor whenever the wind blew from two main wind directions. These wind directions coincided exactly with known major industrial emitters of sulfur dioxide in the area. A source to the north north west coincided with the steelworks. A source to the north east coincided with emissions from the copper smelter. This supports the view that wind direction is a reliable indicator of the transport of air pollution in the study region.

It is considered that some of the above assumptions would be less correct for more remote monitoring stations, located closer to the Escarpment, such as Albion Park. The above considerations are provided, however, to serve as an important reminder

94 that care must be utilised when using wind data alone to predict or assess air pollution.

3.3 Emission History 1907 to 1965

3.3.1 Smelter Operations - Sulfur Dioxide Emissions & Controls

Spanning a century, Port Kembla has a long history associated with primary copper smelting. In 1907, two companies decided to erect smelting works in Port Kembla; the Australian Smelting Corporation and the Electrolytic Refining and Smelting Company of Australia (ERS).

In early 1907, the Australian Smelting Corporation was established to smelt and refine copper ores. Attracted by a new harbour and extensive coal resources, they began transferring related smelting operations (by the Smelting Company of Australia) from a site near Dapto and started construction of new works at Port Kembla (Illawarra Mercury, 23 March 1907). These works were located on the present day vacant land between Port Kembla Primary School and Metal Manufacturers, at Gloucester Boulevard, Port Kembla.

The Electrolytic Smelting and Refining Company of Australia (ERS) was officially formed and registered in February 1907 (Illawarra Mercury, 19 February 1907). The company had several sites for a copper smelter under consideration in the region, including Port Kembla, Bulli, Austinmer and Waterfall (Illawarra Mercury, 19 March 1907). Port Kembla was again of particular interest because of the prospects of a new harbour. Before coming to a decision on the Port Kembla site, however, ERS wrote to the local Council (at the time known as the Central Illawarra Council) seeking any objections. In the letter the company stated, “there is nothing in the business that can be regarded as injurious to health, but the sulfur fumes can affect vegetation in the vicinity of the works ” (South Coast Times, 16 March 1907). If there was any objection on the part of Council or other authorities, the company indicated they would abandon the idea.

95 Opinions about potential harmful emissions from the proposed smelter quickly emerged, in particular due to the release of sulfur dioxide. Some of these views were recorded in the local papers of the time. The Mayor was reported to have said “The fumes would be carried by the winds which most prevailed away from the direction of Wollongong” (South Coast Times, 23 March 1907). Another Council alderman said “the fumes only affected vegetation within a radius of two miles ” (South Coast Times, 23 March 1907). The Mayor is reported as saying at the time, that the sulfur dioxide from the smelter would act as disinfectant and would increase the milk yield of local cows (Hagan and Wells, 1997). The views of local residents were mixed. The Wentworth Estate, a large and influential landholder downwind of the proposed smelter, lodged a strong objection with the Mayor against the proposed works and threatened injunctions (South Coast Times, 23 March 1907). The O’Donnells also protested on the grounds that the works would cause them serious loss “…both in health and otherwise.” (South Coast Times, 13 April 1907). The O’Donnells owned land in the Port Kembla area (including farms) and later were to become local managers of the Wentworth estate (Eklund, 2002). The O’Donnells had sought advice for themselves and advised Council that “there fears had been fully realised” (South Coast Times, 13 April 1907). But the benefit that new industry would bring to the area was mostly on people’s mind. “ Things are transpiring in the history of Illawarra that in my best moments I have never dreamed of …” said one resident in a letter to the Editor of the Illawarra Mercury, “...Fancy two large smelting works being established at Port Kembla, and others in prospect, to employ thousands of workmen, including our boys. One can hardly conceive what this means for the prosperity of the district ” (Illawarra Mercury, 19 March 1907).

A special meeting of Council was convened on 27 March 1907 to consider the ERS proposal. Representatives from ERS and the Australian Smelting Company were also in attendance. Details of this meeting were recorded in the local papers (Illawarra Mercury 12 April, 1907: South Coast Times, 13 April 1907). ERS stated that the main function of its company was the electrolytic refining of blister copper produced by existing smelters at Mount Morgan (Queensland) and Mount Lyell (Tasmania). Emissions from this refinery would “ in no way do your district any injury, but quite the reverse ”. The electrolytic refining of copper generates little or no sulfur dioxide.

96 When asked about the small amount of matte smelting that would also occur at the works, the company stated the following (Illawarra Mercury, 12 April 1907).

“The fumes emanating from the smelters may possibly be injurious to foliage and pasture in the immediate proximity to the works, but would not affect anything more than 1 ½ miles at the greatest distance. The modern appliances are so perfected that what was allowed to escape some years ago through the chimney stacks in the form of lead etc, are now arrested in the chimney stack. Consequently the possibility of damage by the fumes are now much less than ever before . Around Cockle Creek, Lithgow and Cobar at the present time practically no damage to foliage or vegetation is done”.

Some Alderman were sceptical about the need for the Company to approach Council first, “if no danger was to be apprehended from the works ” (Illawarra Mercury, 12 April 1907). The Australian Smelting Company, for example, had not thought it necessary to ascertain the feeling of the neighbourhood, before construction, because they thought their operations would not do serious damage (South Coast Times, 13 April 1907). There were also concerns that the Council might be held liable if damage to property occurred from emissions, particularly that of objecting landholders (South Coast Times, 13 April 1907). ERS stated permission from Council to construct the works was sought because the Company was concerned about the threat of injunctions by objecting land owners (Illawarra Mercury, 12 April 1907). Whilst the Company did not want any concessions or shirk any responsibilities, they did point out that they had been made offers from Queensland and South Australian governments for the works to be erected in Gladstone or Port Pirie. These offers also included many more inducements (for example, free land and rate exemptions) than ever offered by the New South Wales government (Illawarra Mercury, 12 April 1907).

The views of Council were mostly in support of the proposal on the grounds of the value the industry could bring to the area. The Mayor moved that permission be granted for erection of the works on the Port Kembla site, “ but such consent shall not be construed to make the said Council responsible; nor shall it be regarded as a party to any breach of the law contained in any act of parliament (or otherwise) of which

97 this Council has administration” (Illawarra Mercury, 12 April 1907 ; Borough of Central Illawarra Minutes, 10 April 1907). The view of the Mayor was that the erection of the works would “ confer a benefit upon the district ” and “ it would provide a means of giving the rising generation a chance of becoming expert workers ” (Illawarra Mercury, 12 April 1907). The motion was carried six votes to four. The site for the works was “ between the Australian Smelting Corporation’s land and the Church of England, extent 52 acres ” (South Coast Times, 13 April 1907). This is the site of the current copper smelter at Military Rd, Port Kembla.

It is worthwhile noting that the operation of the previous smelter at Dapto (by the Smelting Company of Australia) was raised at the above Council meeting as a point of reference on the expected environmental performance of the new ERS works. The Dapto smelter was the first commercial attempt at metalliferrous smelting and refining in the Illawarra and principally processed lead sulfide ores and smaller amounts of copper sulfide ores (Reynolds, 1989). The facility operated from about 1895 until around 1905 (O’Malley, 1968). It was located on present day Kanahooka Rd, Dapto. Most Aldermen appeared to have the view that the old Dapto works had done very little damage (Illawarra Mercury, 12 April 1907). One, however, did state that farmers had suffered “ a good deal of injury from the works at Dapto ” (South Coast Times, 13 April 1907). The following account from a teacher at a school at Dapto, gives us one glimpse of what these works might have been like (Port Kembla Public School Centenary, 1990)

The smelting works when here had a very bad effect on the land for some distance (1/8 to ¼ mile) round them. Cattle grazing on the paddocks within the radius were seriously affected by the poisonous fumes and died. Many of the smelters suffered from lead poisoning. Those residences on the track of the prevailing winds had their water supply injuriously affected by the deposits from the fumes. Our school used to experience the fume laden winds only a few times a year, and those winds were so suffocating as to compel us to shut all doors and windows.

It is interesting to note (in contrast to early smelting operations at Port Kembla) that the Dapto smelter was also believed to convert some of its sulfur dioxide to sulfuric acid, in a simple acid plant (Reynolds, 1989) . This is probably due to the higher

98 concentration of sulfur dioxide that could be recovered from the smelting of lead ores (for example, galena (PbS)) in the blast furnaces used, compared to copper ores.

In January 1908 the Australian Smelting Corporation went into liquidation. Only a chimney and reservoir were constructed and no smelting operations ever occurred (O’Malley, 1968). This is shown in Figure 26. The chimney remained on the site until the 1960s (Eklund and Murray, 2000) and the reservoir until the 1990s (personal observations by author).

Please see print copy for image

Figure 26 Incomplete Stack and water tank of the Australian Smelting Corporation. Photo date 1910. From the collections of the Wollongong City Library and Illawarra Historical Society.

Construction work on the new ERS smelter, however, began in early 1908 and production started the following year (Eklund and Murray, 2000). The first batch of refined copper was produced on 11 February 1909 (Catterall et al, 1994). In contrast to some views (Eklund, 2002), the presence of dead trees in the vicinity of the works in early photographs (see Figure 27) more likely reflects Port Kembla’s rural past and the results of extensive clearing, rather than the effects of sulfur dioxide emissions from the smelter.

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Figure 27 Township of Port Kembla shortly after the smelter commenced operation. Looking east along Wentworth St towards Hill 60. Photo date 1910. Note the main smelter stack in far left of photograph. From the collections of the Wollongong City Library and Illawarra Historical Society.

The ERS plant was erected mainly for the refining of blister copper produced at Mt Morgan and Mt Lyell and as a custom smelter for the treatment of various copper, gold and silver ores from various centres throughout Australia (Eklund and Murray, 2000). Early smelting operations consisted of two reverberatory furnaces and two converters (White, 1911; ERS, 1921), the latter resembling the Pierce Smith type. These converters are shown in Figure 28. Copper ore was charged to the reverberatory furnaces. The resulting matte (about 42% copper) was transferred to the converters vessels in open ladles using an overhead crane for conversion to blister copper. Only one converter was operated at any particular time. The blister copper produced was then cast into ingots in the converter shed before loading into trucks for transport to the anode furnaces for fire refining in a separate refinery building (White, 1911).

100 Please see print copy for image

Figure 28 Early converters used by the ERS. Photo date early 1900s. From the collections of the Wollongong City Library and Illawarra Historical Society.

Sulfur dioxide generated by the smelting process was vented to the atmosphere via a 64 metre (210 ft) brick stack. This stack served both the reverberatory furnaces and converters (White, 1911). Dust chambers were installed between the furnaces and the stack to capture coarse particulates, mainly as a result of their metal content and economic value (Eklund and Murray, 2000). The stack dominated the local landscape in early photographs of the period. It was located near the present day corner of Military Rd and Electrolytic Lane, about 100 metres west of the current 198 metre stack.

The success of ERS lead to the establishment of Metal Manufacturers (also known as Kembla Copper) in 1918 and Australian Fertilisers Limited (AFL) (now known as Orica) in 1921. Both of these companies had close links to the smelter (Eklund and Murray, 2000; Hoogendoorn, 1999). This industrial complex is shown in Figure 29. Sulfuric acid is an important ingredient in the production of superphosphate fertiliser. Contrary to some reports (Hoogendoorn, 1999), it is unlikely that ERS produced or supplied the sulfuric acid used by AFL until at least the late 1980s when the first acid plant was built. AFL manufactured sulfuric acid on its premises in its own acid plant and in these early days would have supplied sulfuric acid to ERS (ERS, 1938; ERS,1955). Sulfuric acid is an important reagent in the electrolytic refining of copper and was vital to the production of bluestone (copper sulfate) which occurred at the

101 smelter at least until the 1980s (ERS, 1981). This bluestone is produced from the reaction of white metal (Cu2S) and sulfuric acid.

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Figure 29 Aerial view of Port Kembla industrial complex (looking southeast). Photo date circa 1920s. A= ERS works, B = Australian Fertlisers Ltd, C= Metal Manufacturers, D= Incomplete stack and reservoir of the Australian Smelting Corporation. E= Ulladulla Silica Brick Company (Later Newbolds General Refractories Ltd). From the collections of the Wollongong City Library and Illawarra Historical Society.

In 1938, a blast furnace was installed, replacing the existing reverberatory furnaces for matte smelting (Andrews, 1993). The blast furnace was operated to produce a matte containing 45 to 50% copper (ERS, 1938). Both matte and slag were continuously tapped. The matte from the blast furnace was transferred to the converter vessels using open ladles and an overhead crane. The converter section then consisted of six vessels. Two were used for the production of blister copper, whilst the remainder were employed for making white metal (Cu2S). The blister copper produced was cast into ingots before loading into trucks for transport to the anode furnace. A lead blast furnace was also known to operate (ERS, 1938)

In the 1940s and 1950s, there were improvements and refinements to existing plant rather than wholesale renewal and upgrade (Eklund and Murray, 2000). The smelter

102 consisted of one blast furnace and three converters of the Pierce Smith type (ERS, circa 1950). Again, only one converter was “blown” at any one time and matte/slag was tapped continuously. Molten matte was transferred to the converter by ladles and overhead crane. A large baghouse was installed to treat dust emissions from the main stack in 1951. By 1955, there were four Pierce Smith converters (ERS, circa 1955). Blister copper from the converters was cast into ingots for further processing in the anode furnace.

Whilst there is a history of complaint about sulfur dioxide pollution from the smelter dating back at least until the late 1930s (Eklund and Murray, 2000), during February 1959, sulfur dioxide pollution from smelter, and its effects on Port Kembla residents and their gardens, attracted considerable attention in the local press (Illawarra Mercury, 5, 6, 9, 10, 11 & 18 February 1959). It was on the eve of a State government election and there were claims, driven to a large extent by a Council alderman, that ERS was not doing enough to address the emissions. These allegations were rigorously denied by the company. There were repeated calls by one Alderman for the State Government to enact legislation to bring in the Clean Air Bill during the life of the present Parliament (Illawarra Mercury, 10 February 1959). Some of the observations and recommendations contained in a “Report on Air Pollution in NSW” presented to NSW State Parliament in 1958 were quoted (Parliament of NSW, 1958). This included references to the excessive “30 tons per day” of sulfur dioxide emitted by the smelter when it was working.

One press article (Daily Mercury, 18 February 1959) provides a detailed ERS perspective of sulfur dioxide emissions and their control at the smelter. The smelting company stated that extensive amounts of money were being spent on improving fume collection “to better safeguard the health of its workers”. They also stated that as far as was known, sulfur dioxide was not recovered anywhere in the world from the type of smelting furnaces (namely blast furnace) it used and gases were always allowed to escape to atmosphere. The Company stated that whilst the converter gases contained a higher percentage of sulfur dioxide, it varied between wide limits and could not be made into sulfuric acid using the type of plants available in Port Kembla. The company also indicated that it was looking at the installation of a Sinter Plant to increase production and safeguard the future of the copper industry in the area.

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Of particular interest in the same article (Daily Mercury, 18 February 1959) are statements by ERS that “plans are under consideration for the building of a new and higher stack or other means of rendering the gases comparatively innocuous ”. The company stated it was cooperating with the Department of Public Health, to obtain data on gas concentrations, to enable it to determine whether a higher stack was the answer or some other means be sought. In regard to a new stack, the company stated “this is a costly business; an expenditure of more than ₤750,000 will probably be necessary and it is no good spending all this money if the nuisance is merely to be transferred from Parkes St to Primbee” . As indicated in Section 3.3.3, the area most affected by the impact of fumes from the main stack was the corner of Parkes and Cowper Sts, Port Kembla. In terms of “other means of rendering the gases comparatively innocuous ”, the company indicated it was considering a new gas treatment system to handle an economically treatable portion of the gases from the proposed Sinter Plant gas and send it to AFL for conversion into sulfuric acid. Plans were also underway for a new blast furnace and new converters which had significance both from a production angle and to minimise the fume nuisance. In 1959, ERS installed a new sinter plant and larger blast furnace (Andrews, 1993). This combined with the new baghouse in 1951 represented the largest single capital expenditure at the site for many years (Eklund and Murray, 2000).

As stated in Section 3.2, there were attempts in the late 1950s/early 1960s to collect and clean sulfur dioxide from the sinter plant and transfer it via a pipeline into the existing sulfuric acid plant at Australian Fertilisers Ltd, for conversion to acid (ERS, 1961; ERS, 1969; South Coast Times, Jan 18 1965). These measures were, however, ultimately unsuccessful due to the strength and reliability of the gas stream and its particulate load.

By 1961, the four Pierce Smith converters were replaced with three larger converters of the same type (ERS, 1969). Given the noxious nature of sulfur dioxide and the fact that no relevant regulation discharge limits existed under the Clean Air Act 1961 for sulfur dioxide (except from sulfuric acid plants manufacturing acid from sulfur), licensed premises such as the copper smelter were required to control emissions through best practicable means. Best practice at the time centred on the dispersion

104 and dilution of emissions using tall stacks. Based on the outcomes of a study by the NSW Department of Health on the levels of sulfur dioxide in the Port Kembla area and the health of residents (discussed further in Section 3.3.3), a view emerged that the existing 64 metre (210 ft) stack at the copper smelter should be replaced with a taller one, to control sulfur dioxide.

In 1963, the local Council (then the City of Greater Wollongong) received a development application from ERS for approval to construct a new 650 ft (198 metre) reinforced concrete stack. Attempts to locate this actual building application (Building Application 63/2137) from Wollongong City Council archives to ascertain the exact design basis for the stack have not been successful. Council has advised that these records were destroyed several years ago. Perusal of the annual NSW Government Report of the Director General of Public Health from 1961 to 1972 did not provide any further detail either. The Report of the Director General of Public Health for 1963 states “ During the past year protracted negotiations were carried out between the Department and the Company to decide upon the most effective means of controlling sulfur dioxide pollution. The final decision was that the Company should take steps to treat as much as possible of the sulfur dioxide and use it for the manufacture of sulfuric acid and that the remainder which could not be treated would be dispersed to atmosphere through a stack of 650 feet in height. This is probably the tallest stack on any copper smelter in the world even though there are many larger works than the one at Port Kembla. However, the height was decided upon calculations of the probable ground level concentrations which might be produced. A level was determined which it could be anticipated would not cause any inconvenience to the residents of the south coast and would not have any effects on vegetation ”. The “level” determined was not described and could not be identified in the above Report.

Under the NSW Clean Air Act 1961, occupiers of scheduled premises were required to obtain approval from the NSW Health Department for stack heights before building them. Prior to the release of British Report of the Government Committee on Air Pollution (the “Beaver Report”) in 1954, which drew attention to the knowledge that had accumulated on chimney design to secure adequate dispersion of pollutants, a lot of this design was previously more or less guesswork (Nonhebal, 1964). As a result

105 of this and experience in implementing their own Clean Air legislation, considerable British expertise had developed on stack design that could be drawn on in NSW. It is likely that this expertise was heavily relied upon for the new, taller smelter stack.

The first step in designing the stack would have been to identify the relevant design ground level concentrations or “glc” for sulfur dioxide. Suitable stack heights are then determined to ensure the glc is not exceeded, for example, using the method of Sutton and Bosanquet (Nonhebal, 1964). These glc are set in order to protect the public against adverse health effects, aesthetic or nuisance effects and economic loss, such as might occur if vegetation is affected.

A review of the available literature indicates that in the early 1960s, the NSW Air Pollution Advisory Committee used a sulfur dioxide glc of 50 pphm (1 hour) to set the height for the new stack at the Port Kembla smelter, with no short term peaks above 150 pphm (South Coast Times, 27 Aug 1963). It is stated that this glc was used to protect the community and prevent damage to vegetation in local gardens. It is consistent with acceptable limits for sulfur dioxide published at the time to protect human health and most vegetation (Nonhebal, 1964). There are some reports in the literature (South Coast Times, October 29 1964 and Illawarra Historical Society, 1965) which state that the 198 metre Port Kembla smelter stack was designed to conform to the NSW Clean Air Act 1961 which required that the maximum amount of sulfur dioxide in the air was not more than 12 ppm. The basis of this level (in-stack or ground level) is not clear. In any case it does not appear to be consistent with the above design glc or legislation in place at the time.

Eklund and Murray (2000) state Council delayed construction of the new stack because of zoning regulations and the State government intervened. The Council minutes for 23 September 1963 (Wollongong City Council, 1963) indicate a building application was received from ERS that same month and that “Council has for some time sought relief from air pollution created by the operations of ERS and as the erection of the proposed stack would assist in the alleviation of this problem, it appears that Council should support the application for the erection of a stack in the location indicated”. The Town Planner goes on to state that “ The erection of this 650 ft stack is a prohibited use in this “Residential B” zone. However, in view of the

106 special circumstances in this particular case, it is recommended that the application be approved, provided the decision of Council is made available to the Department of Local Government Town Planning Branch for an expression of opinion on the matter, prior to the developers being informed. At the meeting, Council approved the building application, subject to conditions, including that approval be obtained from the Minister for Local Government in respect of the erection of the stack on “Residential B” land and work not commencing until full engineering details had been submitted to and approved by Council. Council also recommended that certain lands in the ownership of ERS and Metal Manufacturers, zoned as “Residential B” be the subject of an application to the Minister for Local Government for rezoning to “Heavy Industrial”.

In an address to the NSW Parliament in 1964, Mr Porter MP, Member for Wollongong, stated “ The construction at the ERS works of one of the tallest chimneys in the world is one of the first fruits of the Clean Air Act introduced by the State Labour Government after one of the most detailed studies of industrial air pollution ever attempted ” (NSW Legislative Assembly, 1964).

In 1963, in recognition of the concern for the health of residents, the NSW Department of Public Health (acting on the advice of the Air Pollution Advisory Committee) required the Company to purchase and install sulfur dioxide recorders to monitor the ambient atmosphere. The Department also signalled its intention to reintroduce its own monitors in the area “ to ensure that the interests of the community are protected ” (Report of the Director General of Public Health, 1963). Public reporting of this data, however, does not appear to have actually occurred until 1970 (Report of the Director General of Public Health, 1971). As a further safeguard, the Department of Health also required an undertaking from the Company that operations would be curtailed or stopped altogether if the weather conditions were such that concentrations higher than recommended limits were recorded in any area (Report of the Director General of Public Health, 1963; South Coast Times 12 July 1962 and 22 August 1963).

In 1964, the Department of Health introduced a production ban on ERS from January to March each year to reduce ground level impacts of sulfur dioxide, until the new

107 stack was built (Eklund and Murray, 2000; South Coast Times 12 July 1962 and 22 August 1963). This period coincided with the prevailing north westerlies sea breezes carrying emissions from the smelter onto nearby residential areas. This ban was lifted in January 1965 following a national shortage of copper and with the impending completion of the new, taller stack; subject to conditions to ensure sulfur dioxide emissions were kept to a minimum (South Coast Times, 18 January 1965).

Construction on the new 198 metre (650 ft) stack commenced in late 1963 (South Coast Times, 25 Nov 1963). It was built on the site of the smelter Manager’s residence (South Coast Times, 26 August 1963). The new stack was commissioned in early 1965 (Illawarra Mercury, 6 March 1965). The Department of Public Health reported later that year that “ observations and tests made during the summer period have shown it to be completely effective and complaints have ceased altogether ” (Report of the Director General of Public Health, 1965). The original stack was demolished in 1968 (Illawarra Mercury, 17 May 1968).

It can be seen from the above that, from the commencement of smelting activities in 1908 to 1965, the primary method of air pollution control at the copper smelter at Port Kembla was fume collection, particulate removal and discharge through the main stack. The control of sulfur dioxide emissions was based around dispersion and dilution from tall stacks.

As indicated in Section 3.2, we can estimate the load of sulfur dioxide emitted annually around the time ambient sulfur dioxide monitoring first occurred between 1957 and 1961. Table 12 indicates the plant averaged around 18,000 tonnes per year of sulfur dioxide (or 49 tonnes per day) in the late 1950s/early 1960s. An estimate of 30 tonnes per day of sulfur dioxide emitted from the smelter during the mid 1950s was reported by NSW Parliament (Parliament of NSW, 1958) and the local press of the time (Daily Mercury, 10 February 1959).

The new ERS stack cost about ₤400,000 to build (Illawarra Historical Society, 1965). At the time, it was reported to be the tallest stack in Australia (South Coast Times, 29 October 1964) and the Southern Hemisphere (Illawarra Mercury, 6 March 1965). These claims were soon superseded by taller stacks associated with smelters at Mt Isa

108 Mines, Queensland and Port Pirie, South Australia, at heights of 886 ft (270 m) and 673 ft (205 m) respectively (Wikipedia, 2007). The tallest smelter stack in the world is the 1247 ft (380 metre) “superstack” serving the Sudbury nickel works in Ontario, Canada and built in 1972 (Cunningham, 1994). As a point of comparison, the tallest stack in the Southern Hemisphere is currently the 984 ft (300 m) stack in Secunda, South Africa, associated with Sasol Synthetic Fuels Ltd and built in 1979 (Wikipedia, 2007). The tallest stack in the world is currently the 1410 ft (420 m) chimney of the GRES-2 Power Station (coal fired) in Ekibastuz, Kazakhstan, built in 1987 (Wikipedia, 2007).

3.3.2 Environmental Regulation

After settlement, Australia inherited the existing common law and legislation of the United Kingdom (Bates, 2006). The common law is that body of law declared and developed by the courts of law over centuries. Legislation (also known as statute law) is the law embodied in an Act of Parliament. Both forms of law exist side by side, unless and until, an Act of Parliament repeals or changes the common law.

The development of pollution control policy in Australia basically followed the pattern in the United Kingdom. Prior to 1960s, there was limited legislation to regulate air pollution in NSW, beyond the Smoke Nuisance Abatement Act which was passed in 1902. This Act was used for abating the nuisance of smoke from furnaces. Whilst this was probably decades before many developed parts of the world had thought about air pollution legislation (Sullivan, 1965), no record of any proceedings having been taken under this Act can be found and it had little or no effect on controlling air pollution, even by smoke (Sullivan, 1965). Other provisions for air pollution control in NSW were progressively introduced into the legislature by incorporating sections in the Public Health Act 1902 and Local Government Act 1919 (Sullivan, 1965). This latter Act gave local Councils the power to control and regulate furnaces and chimneys and the emissions of smoke. It included a requirement (Ordinance 58) placing a limit of three minutes of thick smoke emission in any one half hour period (Sullivan, 1965). Some successful prosecutions were launched under this ordinance (Sullivan, 1965). Whilst the costs of litigation tended to outweigh any penalty imposed, it did illustrate that even a nebulous emission standard had merit and was to be preferred to legislation based on the common law

109 concepts of proving public nuisance (Sullivan, 1965). This existing patchwork of laws that controlled some forms of pollution was, however, administered by various authorities which regarded air pollution as incidental to public health and local government functions (Butlin, 1976).

If there were no legislative controls over pollution, the only legal controls were those existing under the common law which could be enforced by citizens in the courts. These laws focused on the rights of neighbouring land owners to enjoy their properties without undue interference or “nuisance” from smoke, fumes or dust. It has been described that this “law of nuisance” is the common laws contribution to environmental protection (Bates 1992). These rights were, however, limited, but no discussion about the history of pollution control regulation would be complete without mentioning them.

It was not until the 1950s that public health considerations began to replace nuisance type ones and real attention was given towards air pollution and its control. This was prompted by the occurrence of several serious air pollution episodes which resulted in human (and also animal) morbidity and mortality, as well as causing huge physical damage (Kessell, 2006). The most notable incident occurred in London in 1952, when a “smog” lasting four days descended on the city and caused over 4000 deaths (Palmer, 1974). Whilst this 1952 Great Smog, caused the most deaths, there had been at least four previous notable London smogs that had resulted in increased mortality, dating as far back as 1876 (Kessell, 2006). Other documented smogs also occurred in the previous decades in other British cities or overseas. For example, in 1930, in the Meuse Valley near Liege, Germany, 63 people died as a result of airborne pollution when the valley air became stagnant with a fog persisting 5 days (Meetham, 1952). This valley was occupied by a large number of industries including iron and steel, zinc and chemical (phosphate) works. In 1948, another five day fog at Donora, near Pittsburgh, USA, caused the death of 19 people (Meetham, 1952). Here sulfur dioxide from a zinc smelting works where ores of high sulfur content were roasted, was implicated as a main cause.

Kessell (2006) cautions against the historical tendency to emphasise the 1952 “Great Smog” in London, as the only catalyst for substantial change. This is because some

110 new laws were already underway in the UK to tackle air pollution, albeit slowly and at a local or regional level. In the post war years, however, these acute pollution episodes stimulated real attention towards air pollution in Great Britain and other parts of the world (Sullivan, 1965).

In Great Britain, a Government Committee on Air Pollution was appointed to examine the 1952 London smog disaster under the chairmanship of Sir Hugh Beaver. The end result of the “Beaver” Committee, as it was known, was the replacement of existing weak and ineffectual laws, with more comprehensive air pollution legislation contained in the Clean Air Act of 1956. This Act, together with the existing Alkali and Works, etc. Act 1906 and Public Health Act 1936, gave Great Britain at the time, the most comprehensive national legislation on air pollution in the world (Nonhebel, 1964).

It can be seen from the above that the protection of public health was the main driver for pollution control internationally, as well as in Australia in the early 1950s. In the case of NSW, the Department of Public Health (Division of Occupational Health) began a survey into the problem of air pollution in the State’s major industrial cities (Newcastle, Sydney and Port Kembla) in 1953. It initially focussed on monitoring levels of smoke and dustfall. Prior to this there had been no attempts to measure the extent of air pollution on any substantial scale in NSW. Newcastle City Council did, however, establish some dustfall gauges in 1951 (under guidance from the Department of Public Health) to investigate impacts from heavy industry in the Mayfield area, following numerous complaints from local residents. This was the very first air quality monitoring campaign in NSW and influenced decisions to extend and expand the program to Sydney and Port Kembla in 1953 (Sullivan, 1956).

The NSW Department of Public Health (Division of Occupational Health) was founded as the Division of Industrial Hygiene in 1923, and was originally formed to prevent sickness and death from pollutants generated in the workplace. The publication in 1954 of the “Beaver Report” by the above British Government Committee, further galvanised interest in Australia. Coward (1988) indicates State politicians for electorates in Sydney began to take up the issue further in NSW Parliament in 1954, and there were calls for a technical inquiry into air pollution.

111 These representations grew from concerns about smoke pollution in Sydney by city health (Council) officers. These ideas took shape with the establishment of the Smoke Abatement Committee by NSW State Parliament in 1955 (similar to the “Beaver” committee). Butlin (1976) states the NSW Smoke Abatement Committee was prompted partly through uneasiness about the impact of air pollutants on the health of city dwellers and partly because of increasing nuisance caused by smoke, ash and grit discharged from the smoke stacks of Electricity Commission power houses located in inner Sydney (Pyrmont, Ultimo and Balmain).

The Smoke Abatement Committee was composed of representatives from government, industry and universities. The purpose of the committee (Sullivan, 1965; Palmer 1975) was to: (a) Investigate and report on the causes, extent and effect of air pollution; (b) Consider the existing provisions of the law relating to the prevention of air pollution; and, (c) Recommend what further preventative measures were necessary.

After lengthy examination of the State’s problems and a study of the records of the monitoring programs started in 1953, the committee decided that the State had a significant air pollution problem and that new legislation and the establishment of a central organization to control air pollution was required. The observations and recommendations of the Smoke Abatement Committee were contained in the “Report on Air Pollution in NSW” presented to NSW State Parliament in 1958 (Parliament of NSW, 1958). The recommendations were approved in 1959 and a Clean Air Bill was prepared by the Public Health Department and submitted to Parliament in 1960 (Coward, 1988). Because the government was anxious that the proposals would be generally acceptable, particularly to industry, it was not adopted immediately but was allowed to remain open for public comment until the following year (Sullivan, 1965).

To provide clear legal authority, a single, Clean Air Act became law in 1961 and an Air Pollution Control Branch was formed within the Division of Occupational Health, under the NSW Department of Public Health in 1962. This Act, addressing air pollution and its control, went far beyond the common law nuisance provisions that existed prior to the 1960s (Bates 1992). An Air Pollution Advisory Committee was

112 also set up in 1962 and its main purpose was the drafting of regulations under the Act (Palmer, 1974). Around the same time, pollution control legislation was also passed in Victoria, Queensland, Western Australia and South Australia (Palmer, 1975) as well as other parts of the world, including the United States of America (Lund, 1971).

Although the introduction of the Clean Air Act in Britain in 1956 undoubtedly stimulated the development of air pollution legislation in Australia, it was not used as a model to major extent in the NSW Clean Air Act 1961 (Sullivan, 1965). Instead, the NSW Act was based on the much older British Alkali and Works, etc. Act of 1906 (which despite its name had a broad industrial scope). This system was considered to be more suitable for adoption in NSW where air pollution problems were predominantly industrial in origin (as opposed to domestic in Great Britain). It replaced all previous legislation relating to stationary sources of pollution.

Under the NSW Clean Air Act, industrial premises are divided into two classes, major and minor air polluters. The first were termed “scheduled” premises. Administration of these premises fell under State supervision by the Air Pollution Control Branch. The second category, comprising industry of a smaller nature, was classed “non- scheduled” and was controlled by local government authorities such as Councils. Scheduled premises were required to apply for a licence each year and pay a fee. The amount of the fee varied according to the type and capacity of the industry. Conditions were attached to the licence which defined how the industry should be operated to prevent or minimise pollution. The administration of these licences or establishment of new premises that are scheduled made up much of the work of the Air Pollution Control Branch. The Branch also aided and consulted with industry on the selection of pollution control equipment and the emission control procedures required. Ultimately, decisions were backed by prosecution. For example in 1974, the maximum penalty for an offending corporation was $10,000 with an additional $2,000 for each day that the offence continues (Butlin, 1976).

By the mid 1960s, the routine work of the Air Pollution Control Branch had expanded to concentrate on Sydney, Newcastle and Wollongong (Butlin, 1976). Policies originally introduced by the Air Pollution Advisory Committee were used to regulate scheduled premises. For example, emission standards for scheduled industrial

113 premises came into effect in 1965 through Clean Air Regulations. These regulations set out maximum standards of concentration and rates of emission of air impurities in respect of scheduled premises. There were no regulation limits for sulfur dioxide emissions, except for acid plants manufacturing sulfuric acid (Sullivan, 1965).

From its inception, the concept of “best practicable means” of controlling pollution underpinned the Clean Air Act 1961 (Sullivan, 1965). This concept has its origins in the British legislation on which it is based. What this means is where discharge limits for air pollutants are not set by regulations, occupiers of premises must conduct any trade, industry or process by such practicable means as may be necessary to prevent or minimise air pollution. For example, in determining chimney heights, current practice and experience of what has been found acceptable is considered (CASANZ, 1999). All new installations are then required to at least meet the acceptable standard and so the general standard is improved. To operate effectively it needs competent practitioners (both industry and government).

What is meant by “best practicable means” is negotiated between the government and company concerned. “Practicable” under the Act meant reasonably practicable, having regard amongst other things, to local conditions and circumstances, and to the current state of technical knowledge and “practicable means” included the provision and maintenance of plant and the proper use thereof. Although not stated in the NSW Clean Air Act, this was taken to include economic considerations (Sullivan, 1965).

This best practice philosophy remained a key element of government environment regulation in the following decades and has continued to the present day. “Best practice” allows some flexibility in the measures to be adopted and encourages industry to work out its own solutions for maximising environmental performance, coupled with economic efficiency. It should achieve ongoing minimisation of the impacts through effective means, assessed against measures used nationally or internationally for that activity. Application of the concept requires continual monitoring of performance and implementation of new measures as appropriate, in order to keep pace with technological advances, rather than minimum regulatory requirements.

114 The “best practicable” approach has, however, attracted criticism, especially in the past (Kessell, 2006). What was “practicable” was often open to interpretation and demonstration, on the environmental and economic worth of the investment. As new pollution control measures became available, their early use can be expensive and there is uncertainty sometimes on how well they will work in particular situations. It has been stated (CASANZ, 1999) that it also depended on the ability of control technology and not on the quality of the air we breathe (see discussion on the “air quality management approach” in Section 3.4.2). An operation which is practicable on one process may be deemed to be equally practicable on another process, against which it is yet to be tested. Considerations of air quality did not enter directly into the choice of best technology. If the best technology is not good enough, it will yield air of unsatisfactory quality (CASANZ, 1999). It can also be the case that something less than the best theoretical method might be accepted by industry and government (Sullivan, 1965). These aspects, particularly in the early days of pollution control, could be construed as loophole for routine legal defence because punishable offences for air pollution breaches had such a broad caveat.

It has been suggested that citizen action in Port Kembla, in response to pollution from industry such as the copper smelter, eventually led to the passing of the Clean Air Act in 1961 (Hagan and Wells, 1997). As can be seen from the above history of the formation of the Clean Air Act, this is unlikely to be true. Concerns over air pollution in Port Kembla were raised directly in State Parliament, with the earliest regarding “noxious fumes arising from ERS having a baneful effect on both life and vegetation in that town for over a generation ”, appearing to be around 1950, from the then Member for Wollongong, Rex Conner (NSW Legislative Assembly, 1950) . These representations, however, do not provide any specific reference to the need for a government inquiry into air pollution or a reform in pollution control legislation. They would appear to be relating to the need to control pollution and protect community amenity at a very localised level using existing approaches. It was not until the late 1950s/early 1960s that direct references to the need for new legislation appear in NSW Parliament, within the context and culture of the Wollongong/Port Kembla area. By this time reforms in air pollution control in NSW were well underway with government air quality monitoring programs (commencing 1953), the NSW Smoke Abatement Committee (established 1955) and the Clean Air Bill (1961).

115 It is reasonable to assume, however, that this government attention to air pollution would have galvanised public interest on the issue. Major industries with a history of pollution problems would have attracted particular scrutiny and calls for action.

3.3.3 Ambient Atmospheric Sulfur Dioxide Concentrations

Between 1957 and 1961, sulfur dioxide monitors were operated by the NSW Government at nine locations in the Wollongong/Port Kembla. The vast majority of these monitors were located surrounding and downwind of the copper smelter at Port Kembla. A summary of the annual average sulfur dioxide levels from this monitoring campaign is shown in Table 13. The locations of these monitors and the geographical zones are shown in Figures 2 and 3.

Table 13 shows that the highest annual averages were recorded at the Port Kembla Fire Station (4.4 pphm). The annual averages tend to decrease as the distance from the smelter increases. The WHO goal for sulfur dioxide of 1.8 pphm (1 year) stated in Section 2.4, was exceeded at monitors located at Port Kembla Fire Station, Terascoa Lane, and Cowper & Parkes St. These monitors are all located in the immediate vicinity of the copper smelter at Port Kembla. All other monitors recorded annual averages below this goal.

In the Port Kembla Township zone annual averages ranged from 4.4 to 1.0 pphm (zone mean 2.5 pphm). The highest annual averages tended to occur in two areas. The first was around Cowper and Parkes Sts, Port Kembla, (3.0 to 3.7 pphm). The second was in the vicinity of Military Rd & Terescoa Lane (2.7 to 4.4 pphm). This can be attributed to emissions from the copper smelter at Port Kembla and is discussed in more detail later in this section.

The lowest annual averages were recorded in the Outer Zone. Here averages ranged from 0.27 to 0.19 pphm (zone mean 0.23 pphm). These monitors can be expected to be least affected by the smelter. This is due to its distance from it and the lack of prevailing winds (easterly) that could carry emissions from the smelter towards that direction. This site, however, is probably more reflective of ambient sulfur dioxide

116 levels resulting from emissions from the steelworks and other more diffuse sources in the region.

Geographical Location Year Annual Zone Average in 1958 1959 1960 zone for all years

Port Kembla Port Kembla Fire 2.7 2.8 4.4 2.5 Township Station, Military Road, Port Kembla Terascoa Lane, Port 2.4 4.2 Kembla Cowper & Parkes St, 3.7 3.8 3.0 Port Kembla Third Ave, Port Kembla 1.5 1.2 1.7 Jubilee Street, Port 1.2 1.2 - Kembla Somme Street, Port - 1.0 - Kembla Central James Ave, Primbee - 0.40 - 0.40 Wollongong - - - - - City Outer Lake Heights Rd, Lake - 0.27 - 0.23 Heights Flagstaff & Lake 0.19 0.23 - Heights, Warrawong

Table 13 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1958 to 1960. All values in pphm.

Annual averages in the Central zone were around 0.40 pphm. These are intermediate in value between the Port Kembla Township and Outer Zone. There was no monitoring undertaken in the Wollongong City zone during this period.

Figures 30 to 38 summarise the monthly average and highest daily readings for each monitor listed in Table 13, during the above campaign.

117

45

40

35

30

25

pphm 20

15

10

5

0 Jul-58 Jul-59 Jul-60 Apr-58 Apr-59 Apr-60 Oct-57 Jan-58 Jun-58 Oct-58 Jan-59 Jun-59 Oct-59 Jan-60 Jun-60 Oct-60 Jan-61 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Sep-57 Nov-57 Dec-57 Aug-58 Sep-58 Nov-58 Dec-58 Aug-59 Sep-59 Nov-59 Dec-59 Aug-60 Sep-60 Nov-60 Dec-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 30 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Port Kembla Fire Station, Military Rd, Port Kembla, 1957 to 1961 (values in pphm)

70

60

50

40 pphm 30

20

10

0 Jul-58 Jul-59 Jul-60 Apr-58 Oct-57 Apr-59 Oct-58 Apr-60 Oct-59 Oct-60 Jan-58 Jan-59 Jun-58 Jan-60 Jun-59 Jun-60 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Sep-57 Nov-57 Aug-58 Sep-58 Nov-58 Aug-59 Sep-59 Nov-59 Aug-60 Sep-60 Nov-60 Dec-57 Dec-58 Dec-59 Dec-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 31 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Terescoa Lane, Port Kembla, 1959 to 1960 (values in pphm).

118 20

18

16

14

12

10 pphm

8

6

4

2

0 Jul-58 Jul-59 Jul-60 Oct-57 Apr-58 Oct-58 Apr-59 Oct-59 Apr-60 Oct-60 Jan-58 Jun-58 Jan-59 Jun-59 Jan-60 Jun-60 Jan-61 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Sep-57 Nov-57 Aug-58 Sep-58 Nov-58 Aug-59 Sep-59 Nov-59 Aug-60 Sep-60 Nov-60 Dec-57 Dec-58 Dec-59 Dec-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 32 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Third Avenue, Port Kembla, 1957 to 1961 (values in pphm)

70.0

60.0

50.0

40.0 pphm 30.0

20.0

10.0

0.0 Jul-58 Jul-59 Jul-60 Oct-57 Apr-58 Oct-58 Apr-59 Oct-59 Apr-60 Oct-60 Jan-58 Jan-59 Jun-58 Jan-60 Jun-59 Jan-61 Jun-60 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Sep-57 Nov-57 Dec-57 Aug-58 Sep-58 Nov-58 Dec-58 Aug-59 Sep-59 Nov-59 Dec-59 Aug-60 Sep-60 Nov-60 Dec-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 33 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Corner of Parkes & Cowper Sts, Port Kembla, 1957 to 1961 (values in pphm)

119 18

16

14

12

10 pphm 8

6

4

2

0 Jul-58 Jul-59 Jul-60 Oct-57 Apr-58 Oct-58 Apr-59 Oct-59 Apr-60 Oct-60 Jan-58 Jan-59 Jun-58 Jan-60 Jun-59 Jan-61 Jun-60 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Nov-57 Dec-57 Sep-57 Nov-58 Dec-58 Aug-58 Sep-58 Nov-59 Dec-59 Aug-59 Sep-59 Nov-60 Dec-60 Aug-60 Sep-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 34 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Somme St, Port Kembla, 1959 to 1961 (values in pphm)

30

25

20

15 pphm

10

5

0 Jul-58 Jul-59 Jul-60 Oct-57 Apr-58 Oct-58 Apr-59 Oct-59 Apr-60 Oct-60 Jan-58 Jan-59 Jun-58 Jan-60 Jun-59 Jan-61 Jun-60 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Sep-57 Nov-57 Dec-57 Aug-58 Sep-58 Nov-58 Dec-58 Aug-59 Sep-59 Nov-59 Dec-59 Aug-60 Sep-60 Nov-60 Dec-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 35 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Jubilee St, Port Kembla, 1958 to 1961 (values in pphm)

120 7

6

5

4 pphm 3

2

1

0 Jul-58 Jul-59 Jul-60 Oct-57 Apr-58 Oct-58 Apr-59 Oct-59 Apr-60 Oct-60 Jan-58 Jan-59 Jun-58 Jan-60 Jun-59 Jan-61 Jun-60 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Nov-57 Dec-57 Sep-57 Nov-58 Dec-58 Aug-58 Sep-58 Nov-59 Dec-59 Aug-59 Sep-59 Nov-60 Dec-60 Aug-60 Sep-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 36 Monthly Average and Highest Daily Average sulfur dioxide concentrations for James Avenue, Primbee, 1959 to 1961 (values in pphm).

3.5

3

2.5

2 pphm 1.5

1

0.5

0 Jul-58 Jul-59 Jul-60 Oct-57 Apr-58 Oct-58 Apr-59 Oct-59 Apr-60 Oct-60 Jan-58 Jan-59 Jun-58 Jan-60 Jun-59 Jan-61 Jun-60 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Sep-57 Nov-57 Dec-57 Aug-58 Sep-58 Nov-58 Dec-58 Aug-59 Sep-59 Nov-59 Dec-59 Aug-60 Sep-60 Nov-60 Dec-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 37 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Lake Heights Rd, Lake Heights, 1959 to 1961 (values in pphm)

121 8

7

6

5

4 pphm

3

2

1

0 Jul-58 Jul-59 Jul-60 Oct-57 Apr-58 Oct-58 Apr-59 Oct-59 Apr-60 Oct-60 Jan-58 Jan-59 Jun-58 Jan-60 Jun-59 Jan-61 Jun-60 Feb-58 Mar-58 Feb-59 Mar-59 Feb-60 Mar-60 Nov-57 Dec-57 Sep-57 Nov-58 Dec-58 Aug-58 Sep-58 Nov-59 Dec-59 Aug-59 Sep-59 Nov-60 Dec-60 Aug-60 Sep-60 May-58 May-59 May-60 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 38 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Flagstaff and Lake Heights Rd, Warrawong, 1958 to 1960 (values in pphm)

Figures 30 to 38 show that the highest monthly averages and daily readings occurred in the Port Kembla Township zone in two areas. The first was at the Port Kembla Fire Station monitor (Figure 30). The second was at the monitor located at the Corner of Parkes and Cowper St – Port Kembla (Figure 33). The highest monthly average, of up to 12 pphm, was recorded at the Fire Station monitor. The highest daily reading, of up to 63 pphm, was measured at the Cowper St monitor.

The graphs for the Port Kembla Fire Station and Cowper St – Port Kembla monitor show a distinct seasonal variation in the monthly average and highest daily concentration of sulfur dioxide. This is consistent with the seasonal pattern of winds in the area and the copper smelter at Port Kembla being the dominant source of the sulfur dioxide. These monitors were located to the south/south west of the smelter and the highest readings were recorded during summer months with the prevailing north-easterly winds. In the winter months, the prevailing winds are from the west and south-westerly. These winds tend to carry the emissions away from these monitors, resulting in lower monthly and maximum daily readings.

122 As indicated above, the areas most affected by sulfur dioxide (annual averages, highest monthly averages and maximum daily readings) occurred in two main geographical areas, which can be accounted for in terms of sulfur dioxide generating activities at the smelter.

The first area was at the corner of Cowper and Parkes Sts, Port Kembla (Figure 33). This is downwind of the smelter under a prevailing north easterly summer wind. These high ground level concentrations can be attributed to plumes from the main smelter stack impacting at ground level. Stack sulfur dioxide emissions originated from the roasting/sintering (Sinter Plant), smelting (Blast Furnace) and converting (Pierce Smith) operations. All these operations were ducted to the main stack, with some dust controls provided. Due to the grade of matte produced by the Blast Furnaces (about 40 to 50% copper, 5 to 10% iron), the maximum emission rates for sulfur dioxide from the stack tended to occur during the converting cycle, in particular, the slag blow portion (Kaybond, 1988) where the majority of iron is removed. As indicated in Section 2.8, this zone of impact, a distance of about 10 stack lengths downwind, is also consistent with the general rule of stack dispersion and maximum ground level impacts, for a stack of this height and prevailing summer winds.

The second area was at Military Rd (Figure 30) and Terascoa Lane (Figure 31). This is in the immediate vicinity of the smelter and was due to fugitive emissions from the smelter. Because of limitations in the design and operation of the furnaces and the ventilation systems that served them, it was not possible for all emissions to be collected and dispersed from the main stack. As a result, low level fugitive emissions resulted from operations in the furnace buildings. The Sinter Plant and Blast Furnace were major chronic sources in this regard (Kaybond, 1988). Acute (short duration, high intensity) episodes routinely occurred during ladle operations, when molten matte was transferred from the smelting furnaces to the converters along the smelter aisle, or when scrap charging or slag tapping operations occurred at these furnaces.

The above footprints of impact would have also been typical of smelter stack and fugitive emissions in the first half of the 1900s, prior to the commencement of sulfur dioxide monitoring in 1957. This is suggested by examination of the early

123 photographs of the operation of the smelter held by Wollongong City Library (see Figures 39 to 41). Please see print copy for image

Figure 39 Looking east along Military Rd, Port Kembla. Note the low level (fugitive) emissions from the smelting buildings. Photo date circa 1916. From the collections of the Wollongong City Library and Illawarra Historical Society.

Please see print copy for image

Figure 40 Looking east along Wentworth St Port Kembla. Note smelter stack emissions. Photo date circa 1920s. From the collections of the Wollongong City Library and Illawarra Historical Society.

124 Please see print copy for image

Figure 41 Aerial view of Port Kembla. Looking north towards Port Kembla Harbour. Note the plume extending from the main stack at ERS under a prevailing north easterly wind. Photo date circa 1927. From the collections of the Wollongong City Library and Illawarra Historical Society. The highest monthly average for ambient sulfur dioxide was recorded during the summer months at Port Kembla Fire Station, with readings up to 22 pphm (Figure 30). In contrast, the highest monthly averages in the Central and Outer zones were less than 1.3 pphm.

The above graphs show that highest daily averages regularly exceeded the NHMRC goal for sulfur dioxide of 4 pphm (24 hr) stated in Section 2.4, at all monitoring locations, except Lake Heights Rd, Lake Heights (Figure 37) and Flagstaff & Lake Heights Rd, Warrawong (Figure 38). The highest daily reading was obtained at the corner of Parkes St and Cowper St, Port Kembla, with a value of 62 pphm (Figure 33). In contrast, the highest daily averages in the Central and Outer zones were up to 6.6 pphm and 7.2 pphm, respectively.

There is a noticeable difference between the monthly average and highest daily average at monitoring locations in the Port Kembla Township zone (especially those at Port Kembla Fire Station and Cowper St, Port Kembla). The highest daily averages

125 tend to be greater. This is consistent with the “batch wise” nature of smelting and converting operations at the smelter and the resulting intermittent and highly variable strength of stack or fugitive emissions. The ratios tend to be lower in the other geographical zones. The lowest ratio tends to occur in the Outer zone (Flagstaff & Lake Heights Rd, Warrawong). As stated above, this monitor is probably more reflective of emissions from the steelworks, not the smelter. Here a lower ratio between monthly average: highest daily average would be expected given the more diffuse nature of sulfur dioxide from the steelworks.

Initially, daily measurements of sulfur dioxide concentrations were made (using the hydrogen peroxide method outlined in Section 2.3). It was soon realised, however, that they did not provide an adequate appraisal of the problem because of the rapid fluctuations in sulfur dioxide that were known to occur from the smelter, over shorter time increments. At the time, the Division of Occupational Health had one instrument suitable for more rapid measurement of sulfur dioxide concentrations, a Thomas Automatic Sulfur Dioxide Recorder. This monitor provided an integrated reading of the level of sulfur dioxide present in the air every half hour. It initially had a range of 0 to 5 ppm and was sensitive to changes in sulfur dioxide of 0.05 ppm. Using this monitor, it immediately became apparent that the sulfur dioxide fluctuated through a much wider range of concentrations than was shown by the daily test stations (Bell and Sullivan, 1963).

The Thomas Automatic Sulfur Dioxide Recorder was first employed during the 1958/1959 summer at the Port Kembla Fire Station site for a 4 month period (Bell and Sullivan, 1963). It was found that whilst daily concentrations could at times be low (even zero), episodes of elevated sulfur dioxide occurred, lasting often for a few hours. Recordings of 1 to 3 ppm were not uncommon for “significant” lengths of time. Readings in excess of the maximum range of the instrument (5 ppm) also occurred. This was attributed to fugitive emissions from metal and slag pouring operations at the smelter. The monitor was relocated to the corner of Parkes and Cowper Sts, Port Kembla in February 1959 to ascertain the impact of emissions from the main stack (Bell and Sullivan, 1963). The highest ground level concentrations of sulfur dioxide were again recorded at this site. On numerous occasions during the six week period, sulfur dioxide concentrations of between 1 and 2 parts per million (ppm)

126 occurred, often for several hours, and some peaks in excess of 3 ppm were recorded. For one period on 24 February 1959, the level of sulfur dioxide remained continuously between 3 and 5 ppm for approximately 3 hours. As had occurred at the Fire Station site, readings in excess of the maximum range of the instrument (5 ppm) also occurred.

In an effort to investigate the peak levels of sulfur dioxide, the monitor was modified to enable its original range of 0 to 5 ppm to be extended to 0 to 25 ppm for sulfur dioxide (Bell and Sullivan, 1963). The monitor was redeployed at the corner of Parkes and Cowper Sts, Port Kembla in October 1959 and operated during the 1959/1960 summer. It generally showed a similar pattern of impact as had been recorded the previous summer. A peak concentration of 13.5 ppm was, however, recorded at this location in January 1960, the highest ever recorded in the community in Port Kembla (Bell and Sullivan, 1963). On no other occasion during this survey was a peak of 10 ppm recorded and concentrations of 5 ppm or more were not common.

The location at the corner of Parkes and Cowper Sts, Port Kembla was selected because it was an area of Port Kembla known to be seriously affected by sulfur dioxide. It was clearly defined by the visible path of the smelter stack plume under a prevailing north-easterly wind (see also Figure 41). It was also confirmed by comparison of sulfur dioxide monitor readings with an anemometer which showed a clear correlation with a north-easterly wind. It was also known that this locality was where the majority of air pollution complaints had been received in the past (Bell and Sullivan, 1963). The highest ground level concentrations from stack emissions tended to occur during a north-easterly wind of 15 to 20 ft/sec (about 17 to 22 km/hr). This is typical of a common but strong summertime sea breeze in Port Kembla. During light winds (1 to 6 ft/s or about 1 to 7 km/hr) these incidents were rare. Bell and Sullivan (1963) accounts for this regular grounding of the stack plume at this location by the effects of the local terrain. The stack was located on the crest of a hill about 30 metres in altitude and the plume followed the direction of a shadow valley. This appears to generate a negative pressure in the lee of the hill under strong winds which funnelled gases more rapidly to the ground (see also Figure 24).

127 Consequently, the above measurements of sulfur dioxide at Port Kembla, made over a number of years, were made available in a survey of the respiratory status of residents in and adjacent to areas affected by sulfur dioxide pollution (Bell and Sullivan, 1963). The respiratory study involved 947 residents of East Port Kembla. The area most affected by sulfur dioxide was designated “Area A” ; the control section “Area C” and the intermediate area, subject to moderate levels of sulfur dioxide “Area B”. These areas are shown in Figure 42.

During the medical interviews, it was clear that many residents not only considered the fumes to be a social nuisance, but also believed that they affected their health (Bell, 1961). The survey found that the respiratory health of residents living in the most affected area (Area A), did not appear to be as good as that of those living in the control area (Area C). As a further investigation, residents from each area were asked about the effects of air pollution from the smelter on their home gardens. In Area A, 89% of residents reported adverse effects on their vegetation, compared to 59% in Area B and 36% in Area C.

As to the cause of these differences, the survey stated that “... although it (was) not possible to provide a clear cut answer, there was sufficient evidence incriminating sulfur dioxide, to warrant more effective control in order to reduce, as far as practical, the amount of contamination of the atmosphere by this pollutant .” (Bell, 1961). These studies concluded that “a significant sulfur dioxide problem existed in a limited area of Port Kembla and the copper smelter was the only truly significant source” . It also stated “...the situation calls obviously for measures to control or more effectively disperse the sulfur dioxide emissions” (Sullivan, 1961). As explored in more detail in Section 3.3.1, this was to provide the main impetus for the construction of the new 198 metre main stack in 1965.

128 Please see print copy for image

Figure 42 Map of Port Kembla downwind of ERS showing Areas A, B and C used in Bell(1963) health study (from Bell & Sullivan, 1963). It has been stated that deputations and complaints regarding air pollution from the smelter, in particular sulfur dioxide fumes, emerged as a community issue from the late 1930s onwards (Eklund and Murray, 2000; Daily Mercury 10 February 1959). This is supported by headlines that began appearing in the local paper like “ Fumes at Port Kembla detrimental to health (Illawarra Mercury, 16 November 1945; Shire of Central Illawarra, 1945), “ Port Kembla Folk have had it – Meeting move on smog” (Illawarra Mercury, 11 February 1959) and “ Fumes “health danger, killing gardens – People angry” ” (Illawarra Mercury, 11 February 1955).

It is interesting to speculate why these pollution concerns emerged in Port Kembla in the late 1930s, given the long history of operations at the smelter and general acceptance that industry was a part of life in the town (Eklund and Murray, 2000). These concerns predate the general environmental movement that occurred in NSW in the late 1950s/1960s and follows the Second World War (1939 to 1945). The need for economic prosperity and industrial productivity during the Second World War would have tended to override, in most resident’s minds, any negative impacts such as pollution. Sentiments, such as the following, provide an insight into the hardship that affected residents during the Great Depression in the early 1930s and general improvement in the economy from local industry that followed (Davis, 1984).

“Pollution always has been a problem, especially when the wind was in the wrong direction, from that big stack up the road, and the chimneys from various furnaces around the place. But there’s two ways of looking at it in my opinion. Anyway, in the first instance in those days, when there was smoke coming out of those chimneys there was money going into people’s pockets, and many people looked at it that way too.”

Possible explanations that could trigger a shift in community attitudes in the late 1930s could include increased air pollution from the smelter or land use conflict (arising from changes in urban settlement patterns downwind of the smelter).

Assisted by the need for metals during the war, demand for copper did increase. Following the installation of a new blast furnace in 1938, plant production capacity rose slightly, but actual production was hampered by shortages of copper ore and impure blister copper for refining (Eklund and Murray, 2000). As a consequence, we would expect any resultant increases in the load of sulfur dioxide over this period to be small. They are not considered major enough to shift community attitudes towards the smelter.

A far more likely explanation for the change in community attitude towards emissions from the smelter in the post war years, could be land use conflict. Changes in land use were known to be occurring at the time, as major industries expanded and residential growth was encouraged near them. Sullivan (1956) alludes to this conflict, both existing and emerging, in his pioneering investigation of air pollution in NSW in the mid 1950s. For example, in the Wollongong/Port Kembla area, he states “ It appears likely that industry in Port Kembla, especially that connected with iron and steel, will continue to expand…Further impetus will be given to industrial expansion of the town, when the planned extension, on a very large scale, of the harbour is put into effect. At the same time, large numbers of houses have been and are still being erected mainly in the Warrawong district. Consequently, unless remedial measures, at least keep pace with development, the position in this area may become even more acute than it is now ”. It is considered that this land use conflict explanation is a far more likely one, for the change in community attitude in Port Kembla towards sulfur dioxide pollution from smelter that emerged in the late 1930s.

Robinson (1977) describes that, prior to the late 1930s, a large area of cleared land under single ownership existed down wind of the smelter under the prevailing summer north easterlies. This vacant land can be seen in Figure 41. The land owner (the Wentworth estate), in company with a real estate agent, developed new housing estates on this land with considerable forethought and enterprise. Quite early it was decided that the main road leading south from Wollongong to Shellharbour would eventually be re-routed along a more direct route (present day King St) and bypass the township of Port Kembla. Foreshadowing this, several shops were built in 1936 at Warrawong (present day shopping precinct) and subsequent housing subdivisions were designed to approach it and radiate from it (Robinson, 1977). As the developer had previously been instrumental in founding building societies and obtaining credit facilities, incentives were given to lot purchasers to build quickly. As a result, urban expansion proceeded rapidly along two sectors. The first, south from Cringila through Lake Heights ultimately to Wollamia Point on the lake. The second, west and

131 south-west from Port Kembla (Robinson, 1977). It is this latter, Port Kembla urban expansion, that could account for changing community attitudes to air pollution and the smelter.

Perusal of aerial photographs of Port Kembla taken in 1937, 1938 and 1948 (held in the collection of the University of Wollongong, School of Earth and Environmental Sciences), clearly demonstrate the rapid urban expansion that occurred from the late 1930s, downwind of the smelter at Port Kembla. It is interesting to note that this area of new and rapid urban growth coincides exactly with the area identified by pollution studies in the early 1960s (Sullivan, 1961) as being most impacted by smelter stack emissions (namely corner Parkes and Cowper Sts). This is shown in Figures 43, 44 and 45. These aerial photographs show the smelter (marked “A”) and the area most affected downwind at the corner Parkes and Cowper Sts, Port Kembla (marked “B”) essentially vacant cleared land in 1937 (Figure 43), increasing residential development in 1938 (Figure 44) and then, by 1948, almost completely urbanised (Figure 45).

Please see print copy for image

Figure 43 Aerial photograph of Port Kembla 1937. From the collection of the University of Wollongong, School of Earth and Environmental Sciences.

132 Please see print copy for image

Figure 44 Aerial photograph of Port Kembla 1938. From the collection of the University of Wollongong, School of Earth and Environmental Sciences.

Please see print copy for image

Figure 45 Aerial photograph of Port Kembla 1948. From the collection of the University of Wollongong, School of Earth and Environmental Sciences.

These photographs appear to support the view that the emergence of community representations about emissions from the smelter in the late 1930s and 40s most likely

133 reflects the reactions of new residents being located in a zone heavily impacted by emissions from the main stack at the smelter.

This argument is further supported by comments in press articles of the time that state that “ residential development was building up along the line of smoke and fumes which were bad from the present time (November) to the end of April owing to the north easterly winds ” (Illawarra Mercury, 16 November 1945). These problems were addressed by the installation and commissioning of the much taller smelter stack in 1965.

3.3.4 Summary of information 1907 to 1965

With the establishment of smelting operations in 1907 at Port Kembla, sulfur dioxide quickly emerged as a major air pollution issue in the Wollongong/Port Kembla area, with the smelter establishing itself as the main source. The process initially consisted of copper matte smelting in reverberatory furnaces with its conversion to blister copper in converters of the Pierce Smith type. Blast furnace technology was first introduced in the late 1930s to replace these smelting furnaces. In the late 1950s, a larger blast furnace and associated Sinter Plant was commissioned for the production of copper matte. From this period, on to 1965, there was little change to the fundamental method of copper production at the smelter.

During this period, resulting sulfur dioxide emissions were simply vented to atmosphere via a 64 metre stack, with no attempts to capture sulfur. It has been estimated that the load of sulfur dioxide emitted was around 9,000 tonnes per year (or 25 tonnes per day) in the mid 1950s, increasing to around 18,000 tonnes per year (49 tonnes per day) by the late 1950s/early 1960s.

Prior to the early 1960s, there was limited legislation regulating air pollution in NSW. It was not until the early 1950s that real attention was finally given to air pollution in Australia and other parts of the world. In NSW, the Department of Public Health commenced air pollution monitoring (smoke, dust) in the major industrial cities including Wollongong/Port Kembla in the early 1950s. A Smoke Abatement Committee was set up and determined that the State had a significant air pollution

134 problem and that new legislation and a central organisation was required to control it. In 1961, the Clean Air Act was introduced in NSW and the Air Pollution Control Branch under the NSW Department of Health (Division of Occupational Health) was established. This Act required major industrial premises, such as the copper smelter at Port Kembla, to be licensed. Licence conditions defined how industries should be operated to prevent or minimise air pollution.

Systematic air pollution monitoring of sulfur dioxide was first undertaken by the Department of Public Health in the Wollongong/Port Kembla area between 1957 and 1961. Initially daily readings were made. The highest sulfur dioxide readings occurred in the Port Kembla Township zone. Here values of up to 4.4 pphm (annual average), 12 pphm (monthly average) and 63 pphm (highest daily) were recorded. The worst affected areas were immediately downwind of the smelter during prevailing north easterly breezes, in two distinct impact areas. The first was in the immediate vicinity of the smelter (Port Kembla Fire Station) due to ground level fugitive emissions resulting from operations within the smelter buildings. The second area was where emissions from the main stack impacted at ground level (corner of Cowper and Parkes Sts, Port Kembla).

By comparison, sulfur dioxide levels in the Central and Outer zones were considerably lower. They tended to decrease as the distance from the smelter increased. The lowest values were recorded in the Outer zone. Here values of up to 0.27 pphm (annual average), 1.1 pphm (monthly average) and 3.2 pphm (highest daily) were recorded. This zone was less affected by sulfur dioxide emissions because prevailing winds did not carry emissions from the smelter towards these monitors. In the Central zone values of up to 1.7 pphm (annual average), 1.3 pphm (monthly average) and 6.6 pphm (highest daily readings) were found. These are intermediate in value between the Port Kembla Township and Outer Zone. No monitoring was undertaken during this period in the Wollongong City zone.

With improvements to instrumentation (Thomas Autometer), it became possible to measure sulfur dioxide over much shorter time increments than daily averages. At the Port Kembla Fire station, concentrations of sulfur dioxide ranging from 1 to 3 ppm were detected, often for several hours due to fugitive smelter emissions. The worst

135 affected area was found to be at the corner of Cowper and Parkes Sts, Port Kembla, attributable to stack emissions. This area was also the subject of regular complaints to the Department of Health and Council in regard to sulfur dioxide impacts. These effects were heightened by an expansion of the Port Kembla township into this impact area during the 1930s to the 1950s. Here peaks of concentration greater than 5 ppm were recorded on numerous occasions, one episode of 3 to 5 ppm occurring over 3 hours were detected. The highest reading recorded was 13.5 ppm.

Studies of smelter emissions and their health impacts by the Department of Health at the time concluded that there was a significant sulfur dioxide problem in the Port Kembla area and that the copper smelter was the only truly significant source. This resulted in the government requiring the company to introduce more effective measures to control or disperse sulfur dioxide emissions. The outcome was the replacement of the existing main stack (64 metre) with a much taller one (198 metre) that was completed in 1965.

3.4 Emission History 1966 to 1988

3.4.1 Smelter Operations - Sulfur Dioxide Emissions & Controls

From 1966 to 1988 there was little change to the fundamental design and operation of the smelter. The process consisted of a Sinter Plant and Blast Furnace with three large converters of the Pierce Smith type for the production of blister copper (ERS, 1969; Kaybond, 1988). The primary method of sulfur dioxide control at the premises continued to be fume collection, particulate removal through the main baghouse and discharge through the new 198 metre main stack. Most of the pollution control attention during this period focussed on increasing the ventilation and fume collection capacity at the smelting, converting and refining (anode) sections of the plant. This was to address fugitive emissions of sulfur dioxide and lead (See Figures 46 and 47). These efforts are discussed in more detail in Section 3.4.2.

136 Please see print copy for image

Figure 46 Low level (fugitive) emissions from the ERS smelter buildings. Photodate Circa 1977. Photograph courtesy of DECC.

Please see print copy for image

Figure 47 Fugitive emissions during matte charging operations at the Pierce Smith converters. Photo date 1981. Photograph courtesy of DECC.

As outlined in Section 3.2, we can estimate the load of sulfur dioxide emitted annually from the smelter. Table 12 indicates that sulfur dioxide loads had increased to around 30,000 tonnes per annum (82 tonnes per day) in the late 1960s and then about 25,000 tonnes per annum (68 tonnes per day) during the 1970s and 1980s. This equates to around 630 kilograms per tonne of anode copper produced. The highest load of sulfur dioxide produced by the smelter, during this period, appears to have been around 33,000 tonnes per year (90 tonnes per day) in 1969.

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Despite this slight reduction in the level of copper production (and hence annual sulfur dioxide load) and the installation of the taller stack in 1965, sulfur dioxide emissions still impacted on surrounding areas. Elevated ground level concentrations continued to be caused by stack plume impingement and low level fugitive emissions from the smelter. There was a clear need for new techniques of emission control, rather than relying on stacks alone. Growing concerns about the effects of sulfur dioxide on the environment and human health, as well as increasing pollution control regulation, prompted copper smelters all around the world to explore other control options. Reclamation by formation into sulfuric acid was available, however, as shown in Section 2.6, smelting gases from blast furnaces and Pierce Smith converters used at the Port Kembla smelter are not normally suitable for fixing in sulfuric acid plants. This is due to the low and variable concentration of the sulfur dioxide they produce.

Another method used at smelters to control sulfur dioxide emissions was to reduce production when meteorological conditions were such as to make high ground concentrations likely, or when ambient monitors detected pollution above recognised targets. These Air Quality Management Systems do not, however, reduce the overall emissions from the facility. In 1982, ERS commissioned an Intermittent Production Control System (IPCS) for controlling ground level concentrations of sulfur dioxide emitted from the main stack. Sulfur dioxide monitoring sites were initially established at Primbee and Warrawong with telemetry direct to a central control room at the smelter, where a microcomputer, visual display unit and alarm system were operating. Over time the number of monitors connected to this system expanded. Whenever a predetermined ambient ground level concentration of sulfur dioxide (8 pphm averaged over 5 minutes) occurred at a monitoring station, the converter operations were closed down for a minimum of 30 minutes until atmospheric conditions improved, (SPCC, 1983a; McGinness, 1985). This could cut sulfur dioxide emissions from the smelter stack by 75% (Illawarra Mercury, 17 December 1986). It had the aim of not allowing the ground level concentration of sulfur dioxide to exceed 13 pphm, which was one quarter of, the then, recommended NHMRC maximum goal of 50 pphm (10 minute average).

138 The company and SPCC relied on this reactive strategy to manage sulfur dioxide emissions from converter operations to prevent ground level impacts. This was mainly possible during the copper blow portion of the converter cycle (McGinness, 1985). In its early days, the IPCS suffered due to the unreliability of the system which reduced its availability (SPCC, 1983a). This system also meant a 20 to 25% loss of converter operating time in summer (SPCC, 1986a) which had serious implications for the economic viability of the smelter.

It is interesting to note that during the late 1960s to 1970, ERS was experimenting with its own revolutionary approach to smelting, called WORCRA. WORCRA effectively combined the blast furnace and converting stage of smelting into one furnace (Eklund and Murray, 2000; Biswas and Davenport, 1976). It symbolised the growing environmental pressures to control sulfur dioxide and the need to be competitive and efficient. It was not, however, adopted commercially at the site, with the company choosing to rely on more traditional and proven approaches to smelting, namely the existing Blast Furnace and Pierce Smith converting (Eklund and Murray, 2000). It tended to suffer from low productivity, high energy requirements and other design deficiencies (durability of lances) (Biswas and Davenport, 1976). There were also complaints that its operation lead to the generation of acidic fallout that impacted on nearby residences (Report of the Air Pollution Advisory Committee, 1970 ; NSW Legislative Assembly, 1970). In addition to WORCRA, other more integrated systems, namely Noranda and Mitsubishi Continuous Converting, were also emerging at the time (Biswas and Davenport, 1976). Of the three technologies, only the Noranda and Mitsubishi Continuous Converting eventually operated on an industrial scale and were, ironically, to be used at the Port Kembla smelter several decades later (See Sections 3.5 and 3.6).

3.4.2 Environmental Regulation

The environmental movement of the 1960s must rank as one of the great social revolutions of the 20 th century (Bates, 2006). It seemed to have originated in the United Kingdom and USA at virtually the same time, though there was an immediate worldwide reaction among the developed countries and the movement quickly spread to Australia and New Zealand (Bates, 2006). Whilst trends among industrial nations

139 to enact pollution control legislation in the late 1950s/early 1960s appeared to be a key impetus (for example, the NSW Clean Air Act in 1961), it is interesting to speculate on other factors that may have contributed to these reforms, during or in the lead up to these times.

Bates (2006) has suggested that the Depression, the war years, together with longer working hours and less opportunity to travel, left people with little knowledge or inclination towards aesthetic, conservation or environmental considerations. The prosperity and stability following the war years led to a higher standard of living and general reduction in working hours. The return to a full peace time economy and expansion in commerce due to fresh technological developments, however, also led to increased exploitation of natural resources and increased pollution from new manufacturing processes.

Community perceptions emerged that pollution impacted on that higher quality of life and pressure grew on Governments to tackle it. Scientific investigations also began to produce hard facts about the effects of pollution on the environment. Books, such as Rachel Carson’s “Silent Spring” (1962) are regularly cited as being instrumental in exposing issues and placing them before the general public. Popular music groups and singers also took up and preached this new “environmental religion”. The media began to take interest and suddenly people were confronted with pollution in their own living rooms.

Butlin (1976) states that from a human point of view, amenity began to displace public health as the primary driver for pollution control. People drew on their direct experience of the effects of pollution during the 1950s and 1960s. This included particulate fallout on their property, sewage washed up on beaches, litter on the roadside and smog lingering in urban air. The suddenness of this new, but widely held set of community values, challenged established institutional and legal structures. These in turn led to significant political and social tensions as they struggled for recognition and expression (Bates, 2006). By the mid to late 1960s, pollution was at the forefront of common speech, both socially and politically.

140 In response, two Commonwealth Senate Select Committees were established to investigate pollution of air (1968 to 1969) and water (1968 to 1970), respectively (Butlin, 1976). These pollution investigations were undertaken to explore the growing impact of pollutants upon Australians and provide opportunities for existing public agencies to explain their activities, indicate administrative blocks and suggest ways they could be improved (Butlin, 1976). The role of the Select Committee on Air Pollution was to enquire into and report on air pollution in Australia, in particular causes and effects, and, methods of prevention and control (Parliament of the Commonwealth of Australia, 1969). With respect to sulfur dioxide, typical annual average values for Australian cities in 1966/1967 were reported by the committee as follows: Brisbane 1.2 pphm, Melbourne 2.0 pphm, Sydney 2.0 pphm and Adelaide 2.0 pphm (Parliament of the Commonwealth of Australia, 1969). No monitoring was undertaken in the Wollongong/Port Kembla area at the time of this investigation. The committee reported that these average concentrations had not reached the high levels experienced overseas. For example, many US cities such as New York had annual averages of up to 24 pphm (Parliament of the Commonwealth of Australia, 1969).

During the investigations, concerns emerged from the NSW Air Pollution Control Branch (under the Department of Public Health) regarding limits on its administrative authority and technical solutions for specific emission control problems (Butlin, 1976). For example, the initial application of the Clean Air Act did not address mobile pollution sources such as motor vehicles and shipping, and the Act also did not address the problem of odours from industrial premises.

With general elections imminent, the NSW government acted. In 1970, parliament showed a clear intention to deal with pollution of the environment by means of more comprehensive pollution control legislation (Butlin, 1976). In December 1970, the State Pollution Control Act, Waste Disposal Act and Clean Waters Act were passed. The first two acts led to the establishment of the State Pollution Control Commission (SPCC) and the Metropolitan Waste Disposal Authority in June 1971 (Butlin, 1976). The third act lead to the establishment of the Water Pollution Control Branch which, like the Air Pollution Control Branch, formed part of the Department of Public Health (Butlin, 1976). The coming of these agencies made significant formal changes the regulation of pollution in NSW.

141

Despite its authoritative title, the SPCC initially held no statutory powers and had few staff (Coward, 1988). Its role was to co-ordinate the pollution control activities of other public agencies, make policies, conduct research and raise the priority of newly perceived problems with the State at large (Butlin, 1976).

The Department of Public Health, which at this time administered the Clean Air and Clean Waters Acts, increased in importance and formed within it, the Division of Occupational Health and Pollution Control (Butlin, 1976). Following its establishment in 1961, the ambit of the Clean Air Act was also progressively widened and the work of the Department of Public Health in regulating air pollution increased correspondingly. This included the regulation of emissions from motor vehicles and odours, which commenced in 1972 and 1974 respectively (Butlin, 1976). There continued to be no regulation limits for sulfur dioxide emissions, except for acid plants manufacturing sulfuric acid. In 1973, all new plant and equipment using fuel oil on scheduled premises were obliged, however, to observe limits on the percentage sulfur by weight in their fuel (Butlin, 1976).

The administrative and legislative gaps that had emerged during the 1960s were filled by this reorganisation, but the challenge now was for the interwoven public agencies to achieve integration at both a policy and administrative level (Butlin, 1976). With this in mind, during the early 1970s, pollution control administration underwent further restructuring. In 1974, the NSW Planning and Environment Commission Act was passed. The Act brought the SPCC to the centre of pollution control activity. It shifted the two pollution control branches and the Clean Air and Clean Water Acts from the Department of Public Health into the SPCC. The formation of the SPCC followed the establishment of similar agencies; such as the Environment Protection Authority in Victoria (1971), the Department of the Environment in the United Kingdom (1970), and the Environment Protection Agency in the USA (1970).

By the early 1970s, the copper smelter at Port Kembla was again at the centre of much public complaint regarding sulfur dioxide, dust and smoke emissions (SPCC, 1974a). With a new government agency now clearly responsible for regulation of industrial pollution, a planned program of air pollution control measures was required by the

142 SPCC. This was progressively implemented by the company for the smelting, converting and refining sections of the plant (SPCC, 1974a). These programs included automatic air controls for converter operation; improved hood operations at the converter, blast furnace and sinter plant; enclosure of the ore storage and gantry area; automatic combustion control on copper refining furnace and boilers; as well as the installation of a high energy venturi scrubber and 44 metre stack on the outlet of an anode refining furnace (SPCC, 1974a).

In the mid to late 1970s, low level fumes were reported by the SPCC as still occurring from the sinter plant and blast furnaces at the works and further improvements were being persued (SPCC, 1976a). The Commission stated “Reduced levels of copper production at the time had meant that acid gases in the vicinity of the works were lower than previously. Better controls will be needed before the production picks up again ” (SPCC, 1976a). Concerns were also raised by the SPCC regarding bypassing of control equipment on copper refining furnaces at ERS (SPCC, 1976a). The Commission stated, as a result, “ residents in the vicinity of the works and children at an adjacent school have been subject to significant air pollution which could have been prevented if the high energy work scrubbers, provided in compliance with conditions applied by the Commission in 1974, had been used ” (SPCC, 1976a). The scrubbers served the anode furnaces at the smelter. The SPCC issued a stern warning “Such cases where the environment takes second place to production will not be tolerated ” (SPCC, 1976a).

The SPCC’s air pollution control strategy now combined features from two approaches; “best practicable means” (as discussed in Section 3.3.2) and “air quality management” (SPCC, 1981). The air quality management approach prohibited the levels of pollution in the ambient air from exceeding prescribed standards. This determined the extent of control needed, almost without consideration of the cost. In contrast, the best practicable means approach required pollution to be controlled to the lowest level judged technologically practicable and economically feasible. It may or may not result in a satisfactory air quality (SPCC, 1981). The air quality management approach relied on mathematical models to determine emission standards which can be applied to individual sources, drawing on the health effects of air pollution and air quality standards for them (CASANZ, 1999). There is no assurance, however, that a

143 standard derived from a computational model can be met in practice. Difficulties lie in the adequacy of mathematical models, the often uncertain nature of health effects and the complexities of administration (CASANZ, 1999). Despite this, even if a standard cannot be met in practice, it would still establish a considerable incentive to improve “best technology”.

Compounding existing concerns regarding sulfur dioxide, in 1980 a new pollution issue emerged. The SPCC total particulate sampler at Port Kembla Fire Station (Military Rd), began to measure an increase in the atmospheric level of lead (SPCC, 1980a). The blood lead levels and health of children attending schools in the proximity became a concern (Gan et al, 1982; McGinness, 1985). A major emission source of the lead was believed to be the Pierce Smith converters. The increase in lead approximately coincided with a change in the source of copper ore used at the smelter (SPCC, 1980). Eklund and Murray (2000) state that this new ore (from mines at Woodlawn, NSW) had up to three times the lead content of the ore previously used (from mines at Cobar, NSW).

Whilst the regulatory focus at the time was on fugitive lead, it is likely that improvements in fugitive lead control would have also benefited fugitive sulfur dioxide control. In 1980, the SPCC served a notice requiring the company to install secondary fume collection hoods and associated ductwork to collect and direct the fume to its existing baghouse (SPCC, 1980a). The work was required to be completed that same year. Upon modification of one of the converters, initial performance of the collection system did not live up to expectations (SPCC, 1980a). The Commission asked the company to review all possible sources of lead emissions within the works. They also requested the Company analyse the fume collection system of the whole plant. This was with the aim of increasing volumetric flow through the plant and improving the collection of air impurities from all sections of the smelter (SPCC, 1980a). The SPCC stated “ The situation is regarded as very serious and urgent action is needed to reduce the concentration of atmospheric lead in this area ” (SPCC, 1980a).

In the early 1980s, the SPCC reported that episodes of high ground level concentrations of sulfur dioxide, in the Warrawong, Primbee and other nearby

144 suburbs, continued, in particular during summer and autumn. These episodes resulted in complaints from the public about irritation to their respiratory system (SPCC, 1982a). In 1982, the Commission asked the Company to install an Intermittent Production Control System. As discussed in Section 3.4.1 this system used information on weather conditions and ambient sulfur dioxide levels to determine the rate of emission of sulfur dioxide from the plant during periods when unfavourable weather conditions gave rise to high ground level concentrations (SPCC, 1982a).

In 1984, the Commission completed a survey of heavy metal processing industry in NSW. Ambient lead levels in the vicinity of the Port Kembla smelter continued to exceed acceptable goals. Investigations by the Commission revealed excessive fugitive emissions from the blast furnace top, converter and sinter plant, and the company agreed in principle to install suitable monitors and controls (SPCC, 1984a). The Commission reported that high sulfur dioxide levels at Warrawong and Primbee were lessened by the increased availability of the real-time Intermittent Production Control System at the works. Further reductions in these suburbs were expected following the commissioning of a system that predicts the likelihood of high sulfur dioxide levels at Warrawong or Primbee on the basis of current and expected meteorological conditions (SPCC, 1984a). This is the forerunner of the predictive reactive system discussed in Section 3.5.1.

A joint SPCC – ERS working group was formed in 1985 to establish a cost effective program to reduce lead levels outside the premises (SPCC, 1986a). Fugitive sulfur dioxide emissions were also considered, but due to a lack of hard data, the same scientific approach used in assessing lead emissions was not possible (SPCC, 1986a). In 1986 the SPCC directed that the investigations be completed that same year. The working group concentrated on how to improve the existing processing equipment. New smelting technology or process changes were not within the scope of its investigation because of the marginal economics of the plant (SPCC, 1986a). An emission inventory was completed and identified that the main sources of fugitive lead were: Sinter Plant 10%, Blast Furnace 30% and Converters 60%. The working group also found existing smelter area ventilation rates for the blast furnace and converter area were inadequate. A program of works comprising seven stages had the potential to reduce fugitive lead by approximately 70%, for an estimated capital

145 expenditure of over $5.6 million. It was proposed that the program could be completed by early 1990 with the majority of benefit being experienced by early 1988 (SPCC, 1986a). The Commission stated at the time the following (SPCC, 1986a).

Due to the age, existing technology and layout of the plant, the control options were selected using best practicable technology rather than best available technology. Some compromise is needed if the economic viability of the plant is to be retained.

In 1986, the SPCC published the Wollongong – Port Kembla Pollution Control Study (SPCC, 1986b). The study estimated the contributions of sulfur dioxide from various industries. A summary of the key sources is presented in Table 11. It concluded that ERS was the most dominant sulfur dioxide source locally, emitting up to 54,578 tonnes annually. There was debate in the local media about the accuracy of this figure (Illawarra Mercury, 5 May 1986). This is further discussed in Section 3.2. The study concluded that “ The technology used by ERS was dated and relied on a high degree of operator skill to minimise emissions. Improving the technology would be expensive but the plant’s sensitive location and pollutants emitted call for a higher level of pollution and process contro l” (SPCC, 1986b).

In 1987, the company was reported to be considering its business future and proposed an environmental improvement plan as an alternative to works ordered by the Commission (Illawarra Mercury 17 December 1986; SPCC, 1987a). These measures were essentially completed and achieved some level of control of lead and sulfur dioxide, but not to the degree sought by the Commission or community (SPCC, 1987a). It was stated that the future of the smelter was to be decided by the end of 1987 with either: new technology and redevelopment, or closure; the likely options (SPCC, 1987a). In 1988, the company decided to undergo a major redevelopment to ensure the new plant operated within the Commission’s licence requirements. This is discussed further in Section 3.5.

Whilst the number of prosecutions is not the only measure of the SPCC’s regulatory efforts, the Annual Reports of the SPCC state the Commission successfully prosecuted ERS on at least seven occasions, between 1974 and 1989, for various air pollution offences (SPCC, 1974a to 1989a).

146

3.4.3 Ambient Atmospheric Sulfur Dioxide Concentrations

Following the campaign between 1957 and 1961, monitoring for sulfur dioxide by the NSW Government did not recommence in the Wollongong/Port Kembla area until 1970. It is reported that this monitoring began at the “Wollongong Fire Station” in 1970 and 1971 (Report to the Director General of Public Health, 1971). This location is more likely to be the Port Kembla Fire Station and, as such, data for 1970 and 1971 has been grouped accordingly. It is understood that some sulfur dioxide monitoring was also conducted by ERS (Eklund and Murray, 2000), but no publicly available data has been located during this study.

In the 1970s the locations and descriptions for the sulfur dioxide monitoring sites reported in the government air quality monitoring reports was often poorly described. Upon advice from the EPA Air Science Section, measurements contained in the reports for Blaxland St – Port Kembla, Port Kembla Substation and Port Kembla Monitoring Station have been grouped with Blaxland Rd – Warrawong measurements. Some limited monitoring (less than 1 year) was also conducted at Keira St – Port Kembla in 1979 and this has been excluded. Initially during this period, sulfur dioxide was measured as acid gases using wet samplers. These were based on daily samples, except in the case of Port Kembla Fire Station, where hourly samples were collected from 1972 onwards. In the early 1980s, monitoring specific for sulfur dioxide, utilising spectrophotometry, began to be adopted in the Wollongong/Port Kembla area. This first occurred at “King St – Warrawong” in 1980 and later Warrawong Baby Health Centre/ Warrawong in 1981/1982. This sulfur dioxide data has been grouped under Warrawong Baby Health Centre.

A summary of the annual average sulfur dioxide levels measured by the SPCC at the identified 7 locations, during the years 1970 to 1988, is shown in Table 14. The locations of these monitors and the geographical zones are shown in Figures 2 and 3.

147 Geographical Location YEAR Annual Zone 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 Average in zone for all years Port Kembla Port Kembla 2.7 2.1 2.9 5.2 3.0 2.3 1.6 2.0 1.1 ------2.5 Township Fire Station, Military Rd, Port Kembla Central Warrawong - - 1.3 1.0 0.59 0.40 0.73 0.65 0.35 0.57 0.38 0.60 0.45 0.34 0.28 0.66 0.40 0.48 0.50 0.52 Blaxland / Flagstaff Rd Warrawong ------0.27 0.27 0.22 - - - - - Baby Health Centre Wollongong Wollongong - - - - 0.87 0.49 0.85 0.74 0.84 0.58 0.51 0.65 0.57 0.67 0.67 0.65 0.43 0.38 0.45 0.63 City Council Chambers Wollongong - - - - 0.87 0.63 0.91 0.67 0.41 0.37 ------Technical College Outer Warrawong ------1.3 0.56 0.41 0.37 ------0.72 Flagstaff Rd

Albion Park – ------1.2 0.48 Tongarra Rd

Table 14 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1970 to 1988. All values in pphm. Table 14 shows that the highest annual average of sulfur dioxide continued to be recorded in the immediate vicinity of the smelter (Port Kembla Fire Station). Yearly averages met the WHO goal for sulfur dioxide of 1.8 pphm (1 year) at all locations, except the Port Kembla Fire Station.

The highest annual averages were recorded in the Port Kembla Township zone. Here the yearly averages ranged from 5.2 to 1.1 pphm (zone mean 2.5 pphm). Annual averages in the Central, Wollongong City and Outer zones tended to be similar. They ranged from 1.3 to to 0.22 pphm (zone mean 0.52 pphm); 0.91 to 0.37 pphm (zone mean 0.63 pphm) and 1.3 to 0.37 pphm (zone mean 0.72 pphm) respectively.

There appears to an increase in the yearly averages recorded in the Central zone during the early 1970s, when compared to the last monitoring period (1957 to 1961). This suggests a sulfur dioxide enhancement in these suburbs which could be accounted for by the following: • The increase in main stack height at the smelter from 60 metres to 198 metres in 1965 could enable emissions from the smelter to travel further into these suburbs under certain wind conditions. • BHP commissioned the No 5 Blast Furnace in 1972 and the No 3 Sinter Plant in 1975, both of which are sulfur dioxide sources (Sinclair Knight Merz, 2001). • There was a peak in acid gases in many NSW cities in the late 1960s and early 1970s, due a greater reliance on imported fuel oil which contained higher amounts of sulfur.

Perusal of the estimated sulfur dioxide loads from the copper smelter during the 1970s and 80s in Section 3.2 suggests that output was relatively constant at around 25,000 tonnes per year (see Table 12). Given this, it is likely that reliance on the imported fuel oil was a key factor. This is because sulfur dioxide levels gradually decreased during the decade as the fuel crisis was resolved or industries switched from fuel oil to natural gas.

Whilst data for the Outer Zone is limited, the zone average during this study period (0.60 pphm) appears to be higher than the last monitoring period (0.23 pphm). This could suggest the presence of a large sulfur dioxide source upwind of the Albion Park monitor, but in the local area, for example, Tallawarra Power Station.

As discussed in Section 3.2, Tallawarra Power Station was a coal fired power station located near Yallah on the western shore of Lake Illawarrra. Station A, consisting of four, 30 megawatt units, commenced operation in 1954 and operated until 1985. Station B, consisting of two, 100 megawatt units, commenced operation in 1962 and operated until 1988 (Pacific Power, 1997). The higher annual average value for Albion Park in 1987 (1.2 pphm) could be attributed to sulfur dioxide emissions from the 200 megawatt Station B which operated at this time. The lower annual average for 1988 (0.48 pphm) could reflect this closure of the power station.

Ambient air quality measurements of the impact of power station stack plumes were undertaken in 1984 for the power station by the CSIRO (CSIRO, 1984). Traverses were undertaken downwind of the stack plume at ground level using a Meloy sulfur meter. This is shown in Figure 48.

Please see print copy for image

Figure 48 Sulfur dioxide traverse in vicinity of Tallawarra Power Station during 1984 with elevated readings attributed to the copper smelter at Port Kembla (From CSIRO (1984)).

150 Traverses 1.0 to 5.8 kilometres downwind from the power station in August, October and December 1984 revealed peak (instantaneous) ground level concentrations of sulfur dioxide ranging from 0.9 to 24 pphm. This suggests the power station could at times contribute to elevated ambient sulfur dioxide levels. CSIRO (1984) also states that some of the elevated peak readings of sulfur dioxide (up to 160 ppb or 16 pphm) measured around the power station in 1984 could also be attributed to sulfur dioxide emissions from the Port Kembla copper smelter. In some instances the elevated readings of the sulfur meter were attributed to natural sulfur emissions from Lake Illawarra.

Figures 49 to 55 summarise the monthly average and maximum daily readings for the ambient sulfur dioxide monitors listed in Table 14.

50

45

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35

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25 pphm

20

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0 Jul-70 Jul-71 Jul-72 Jul-73 Jul-74 Jul-75 Jul-76 Jul-77 Jul-78 Apr-70 Oct-70 Apr-71 Oct-71 Apr-72 Oct-72 Apr-73 Oct-73 Apr-74 Oct-74 Apr-75 Oct-75 Apr-76 Oct-76 Apr-77 Oct-77 Apr-78 Oct-78 Jan-70 Jan-71 Jan-72 Jan-73 Jan-74 Jan-75 Jan-76 Jan-77 Jan-78 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 49 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Port Kembla Fire Station, Military Rd, Port Kembla, 1970 to 1978 (values in pphm).

151 3

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0 Jul-80 Jul-81 Jul-82 Apr-80 Apr-81 Apr-82 Oct-80 Oct-81 Oct-82 Jun-80 Jun-81 Jan-80 Jun-82 Jan-81 Jan-82 Feb-80 Mar-80 Feb-81 Mar-81 Feb-82 Mar-82 Aug-80 Sep-80 Nov-80 Dec-80 Aug-81 Sep-81 Nov-81 Dec-81 Aug-82 Sep-82 Nov-82 Dec-82 May-80 May-81 May-82 Month/Year Monthly Average (pphm) Highest Daily (pphm) Figure 50 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Warrawong Baby Health Centre, Warrawong, 1980 to 1982 (values in pphm).

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Figure 52 Monthly Average and Highest Daily Average sulfur dioxide concentrations for Wollongong Council Chambers, Wollongong, 1973 to 1988 (values in pphm)

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154 Daily averages often exceeded the NHMRC goal for sulfur dioxide of 4 pphm (24 hr) during the summer months, at all monitoring locations, except Warrawong Baby Health Centre. The highest daily reading was recorded at the Port Kembla Fire Station (up to 44 pphm).

The area with the highest monthly averages and maximum daily readings continued to be in the immediate vicinity of the smelter, at Port Kembla Fire Station, Military Rd (Figure 49). Here monthly averages of up to 9 pphm and daily readings up to 44 pphm were recorded. This was due to fugitive emissions from the smelter buildings, in particular, the Sinter Plant and Blast Furnace. The graph for this location continues to indicate the “summer high/winter low” variation in the monthly average concentration of sulfur dioxide. This is consistent with the seasonal pattern of winds in the area and the location of monitors downwind from the smelter. There is also a noticeable difference between the ratio of the monthly average: highest daily average at this monitoring station, compared with more remote monitors. This is consistent with the “batch wise” nature of ladle operations, scrap charging or slag tapping occurred at these furnaces and the resultant intermittent emissions.

In the Central and Wollongong City zones the highest monthly average and highest daily readings were similar. Values of up to 2.7 pphm (monthly average) and 7.5 pphm (highest daily) were recorded in the Central zone. Values of up to 3.2 pphm (monthly average) and 7.0 pphm (highest daily) were recorded in the Wollongong City zone.

In the Outer Zone, the monthly average and highest daily readings were up to 3.1 pphm and 10 pphm respectively. The monthly average and highest daily readings at Albion Park (Figure 55) in 1987 are slightly higher than corresponding levels measured at Blaxland & Flagstaff Rd Warrawong (Figure 51) and Wollongong Council Chambers (Figure 52). There then appears to be a decrease in monthly average/highest daily readings measured at Albion Park in 1988. As noted earlier, this could be attributed to the operation of the Tallawarra Power station in 1987 and its decommissioning in 1988.

155 With the emergence of improved monitoring methods, it became possible for highest hourly values to be recorded from 1972 onwards. In the Port Kembla Township zone (Port Kembla Fire Station) this was achieved measuring acid gases. In the Central zone (Warrawong Baby Health Centre) and Outer zone (Albion Park) it was achieved using spectrometric methods (for sulfur dioxide). These are shown in Figures 56 to 58.

Maximum 1 hour averages often exceeded the NHMRC goal for sulfur dioxide of 20 pphm (1 hr) stated in Section 2.4 at Port Kembla Fire Station (Figure 56) due to smelter fugitive emissions and Warrawong Baby Health Centre (Figure 57) due to smelter stack emissions, especially during the summer months. Figure 56 shows that the highest hourly levels of sulfur dioxide were recorded at the Port Kembla Fire Station, often exceeding the limit of detection of the monitor (100 pphm). These give further evidence of the limitations in controlling fugitive emissions from the smelter and the magnitude of their impacts on the surrounding local area. This is notwithstanding construction of the higher stack in 1965.

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Figure 56 Maximum 1 hour sulfur dioxide concentrations for Port Kembla Fire Station, Military Rd, Port Kembla, 1972 to 1978 (values in pphm)

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157 It cannot be fully determined whether there has been any decrease in the sulfur dioxide levels (monthly averages, highest daily and maximum hourly) since 1982, with the implementation of the Intermittent Process Control System at the smelter. This system was used to control stack emissions of sulfur dioxide during converting operations to prevent high ground level concentrations of sulfur dioxide. This is because monitoring by the SPCC ceased shortly afterwards (in the mid 1980s) in key areas in the Central zone. Had they continued it would have enabled the success or otherwise of the system to be evaluated (McGinness, 1985).

3.4.4 Summary of Information from 1966 to 1988

From 1966 to the late 1980s there was little change to the fundamental design and operation of the smelter at Port Kembla. The process continued to consist of several batch type operations for matte smelting (Sinter Plant/ Blast furnace) and converting (Pierce Smith type) for blister copper production. There was no sulfur capture and sulfur dioxide management relied principally on dilution and dispersion from the 198 metre stack. We can estimate that, during this monitoring period, the annual load of sulfur dioxide discharged also decreased; from an average of around 30,000 tonnes per year (82 tonnes per day) in the late 1960s, to around 25,000 tonnes per year (68 tonnes per day) in the 1970s and 1980s. The highest load of sulfur dioxide emitted by the smelter appears to have been around 33,000 tonnes per year (90 tonnes per day) in 1969. Notwithstanding these reductions, stack and fugitive emissions remained a serious problem, in particular for areas downwind of the smelter during prevailing summer winds. In an effort to control sulfur dioxide emissions that impacted at ground level from the stack, air quality management strategies involving the curtailing of converting operations were employed, with limited success environmentally. These strategies also had serious implications for the economic viability of the smelter.

By the late 1960s, pollution was at the forefront of common speech both socially and politically. Administration of the Clean Air Act was transferred to the State Pollution Control Commission in the early 1970s to better co-ordinate pollution control activities. In 1985, the SPCC, extended the system of licences to include air, noise and water pollution. Studies by the SPCC in Wollongong/Port Kembla during the

158 1980s confirmed that the smelter was the dominant sulfur dioxide emitter, followed by the steelworks.

Following the campaign between 1957 and 1961, monitoring for sulfur dioxide by Government did not recommence in the Wollongong/Port Kembla area until 1970. The emergence of spectrometric methods in the early 1980s allowed sulfur dioxide to be measured over smaller averaging periods. Measurements during 1970 to 1989 show that the areas with the highest sulfur dioxide readings continued to be in the Port Kembla Township zone, in the immediate vicinity of the smelter (Port Kembla Fire Station). This was due to the impact of fugitive emissions. Here annual averages of up to 5.2 pphm, monthly averages up to 9 pphm, highest daily readings up to 44 pphm and highest hourly readings over 100 pphm (limit of range of instrument) were measured.

In the Central and Wollongong City zones overall sulfur dioxide levels tended to be comparable, but were much lower than the Port Kembla Township zone. In the Central zone values of up to 1.3 pphm (annual average), 7.5 pphm (highest daily) and 35 pphm (highest hourly) were recorded. In the Wollongong City zone values of up to 0.91 pphm (annual average), 7 pphm (highest daily) were recorded. It appears that monitors in the Central zone tended to record higher annual averages during the 1970s, than between 1958 and 1961. This is most likely attributable to a greater reliance on imported fuel oil (which had a higher sulfur content).

In the Outer zone values of up to 1.3 pphm (annual average), 10 pphm (highest daily) and 14 pphm (maximum hourly) were measured. The annual average levels of sulfur dioxide in 1987, measured at Albion Park appears higher than that measured at other monitors in the Central, Wollongong City and Outer zones, and then decrease to comparable levels in 1988. This may be attributed to the operation of the Tallawarra Power station in 1987 and its decommissioning in 1988.

159 3.5 Emission History 1989 to 1995

3.5.1 Smelter Operations - Sulfur Dioxide Emissions & Controls

During years 1989 to 1995 the first major upgrade and expansion of the copper smelter at Port Kembla occurred. Towards the end of this period the smelter also ceased operation and went into “care and maintenance”.

The first redevelopment commenced construction in 1989 and was commissioned by late 1991 (Eklund and Murray, 2000; SPCC, 1990). ERS had sold their Port Kembla works to a new consortium with the works then being renamed Southern Copper Ltd (Hoogendoorn, 1999). A design parameter for this redevelopment was that the smelter remain in operation during the upgrade to maintain a cash flow (Andrews, 1993). As stated in Section 3.4.2, the refit became necessary after the SPCC required an improved performance from the Company. It was the subject of an Environmental Impact Statement (EIS) (Kaybond,1988). The smelter copper production capacity doubled from around 40,000 tonnes to 80,000 tonnes per year. A key focus of the upgrade was to be a reduction in sulfur dioxide emissions. The EIS stated that fugitive emissions were to be “negligible”. Stack sulfur dioxide emissions would also be reduced significantly to minimise ground level concentrations above the NHMRC goal of 50 pphm (10 minute). The total cost of the redevelopment was around $155 million of which $47 million was considered environmentally related (Kaybond, 1988).

At the heart of the upgrade was a new smelting furnace of the Noranda type to replace the Sinter plant, blast furnace and part of the converting cycle (Kaybond, 1988). There was no change in the technology employed for matte converting. Two new, larger Pierce Smith converters were installed to replace the existing three smaller units. New converter hoods were installed to reduce fugitive emissions. These included a primary hood (when charging & blowing the converters) and a secondary hood to catch fugitives from the matte charging, slag skimming and blister copper pouring operations (Kaybond, 1988).

160 As stated in Section 2.6, the Noranda Reactor produces a constant stream of sulfur dioxide rich gas which is ideally suited for fixation in an acid plant. Although the Noranda Reactor is technically capable of producing impure blister copper rather than matte, this was not proposed for technical and operational reasons. This was despite the environmental benefits that could be achieved by capturing and fixing all sulfur from one continuous operation. These reasons included unacceptable refractory wear, reduced furnace campaign life and poor metal chemistry which can cause problems in later refining operations (Kaybond, 1988). Instead, the Noranda Reactor was run at the highest possible matte grade (within the above furnace constraints) to produce a matte containing about 65% copper. This is the point at which point all the copper in the matte is present as cuprous sulfide (Cu 2S) or “white metal” (Kaybond, 1988). Sulfur dioxide generated by the Noranda Reactor (about 75% of all sulfur dioxide generated) was collected and treated in the new single contact acid plant to produce sulfuric acid, the remainder from the converters being vented via the 198 metre stack. These converter emissions were not amenable to capture in the acid plant. Sulfuric acid was a new product and was to be sold onto Greenleaf Pty Ltd (formerly Australian Fertilisers Ltd) for fertiliser manufacturing (Kaybond, 1988). This was reported to have returned the super phosphate plant back to full time fertiliser production (SPCC, 1990).

The EIS (Kaybond, 1988) for the redeveloped plant provides a sulfur balance for the existing and redeveloped smelter. It states that without any sulfur removal, the estimated annual load of sulfur dioxide potentially generated by the new smelter was to be around 160,000 tonnes per year (or 80,000 tonnes per year sulfur). With the installation of the acid plant, however, about 75% of the sulfur dioxide generated was to be captured. The remaining overall load of sulfur dioxide emitted would be less than 40,000 tonnes per year. The EIS stated it would be around 36,000 tonnes per year, because of the small amount of copper scrap that would still be used (Kaybond 1988).

The EIS (Kaybond, 1988) states that the design load of sulfur dioxide in 1988 was around 44,000 tonnes per year (or 22,000 tonnes per year sulfur). This shows that despite a double in copper production, there was to be a reduction in the overall sulfur dioxide loads emitted between the existing and redeveloped plant. This reduction was

161 in the order of 10 to 20% (Kaybond, 1988). As indicated in Table 12, however, actual sulfur dioxide emissions from the previous smelter averaged only around 25,000 tonnes per year in the late 1980s.

Whilst this was the first significant reduction in overall sulfur dioxide emissions by sulfur capture in the history of the smelter, the operation of the redeveloped plant was not without its problems. It has been stated that copper production for 1992 and 1993 was around 65,000 and 82,000 tonnes respectively (Dames & Moore, 1994). The reported load of sulfur dioxide emitted in 1992 and 1993, was 38,000 and 52,000 tonnes per year respectively (Dames & Moore, 1994). This is considerably higher than the EIS design sulfur dioxide load figure of 36,000 tonnes/year. The amount of sulfur dioxide generated per tonne of copper does not appear to have changed markedly. On average about 600 kg of sulfur dioxide was emitted for every tonne of anode copper produced. This appears no different from the previous smelter figure of around 630 kg of sulfur dioxide per ton of anode copper.

The failure of the new smelter to achieve the above design load of around 36,000 tonnes per year was due to commissioning problems with new plant and equipment. Meeting design production performance was difficult because of the large numbers of items that were interdependent. This included the Noranda Reactor, acid plant and converters as well as cranes and ladles used to carry matte, metals or slags (Andrews, 1993). For example, a problem with the Noranda Reactor smelting furnace resulted in intermittent operation of the acid plant. This in turn reduced sulfur dioxide capture to less than the expected 75% target (Andrews, 1993).

For the Noranda – acid plant system to operate successfully, the acid plant had certain tolerances which had to be met before it could accept sulfur dioxide and convert it to sulfuric acid. The sulfur gases from the Noranda had to be cooled, cleaned, and at an acceptable concentration. The sulfur dioxide gases entering the vanadium catalyst beds, at the heart of the acid plant, also had to be at the correct temperature. Typically, the sulfur dioxide feed gas for an acid plant must be above the ignition temperature of about 400 degrees C for rapid oxidation to sulfur trioxide, but less that around 650 degrees C to avoid degrading the catalyst (Biswas and Davenport, 1994). These operational constraints meant that the operation of the Noranda had to be

162 closely matched with the operation of the acid plant. Where they were not aligned, for example, the acid plant was not at the correct strike temperature or “tripped” due to operational problems, the sulfur dioxide was vented to atmosphere via the main stack.

Other design production performance problems included the small quantity of matte available from the Noranda Reactor at any one time relative to that required to fill the converters (Andrews, 1993). This meant several molten matte transfers had to occur, via ladles and overhead crane, between the Noranda and Converter, before the converter was filled and blowing could commence. Thus small delays in Noranda Reactor operation affected converter operation and vice versa (Andrews, 1993). This is reported to have improved as the furnace moved to more stable and effective operation (Andrews, 1993).

Although improved compared to previous operations, the redeveloped smelter did not meet the expectations of the government, community and company. Sulfur dioxide remained a significant issue both in terms of stack and fugitive emissions. In an attempt to further reduce ground level concentrations of sulfur dioxide the company implemented a “Predictive Reactive Sulfur Dioxide Emissions Monitoring and Control System” to reduce stack sulfur dioxide emissions whilst maximising production. This system was claimed as a world first (Illawarra Mercury, 5 December 1990). It involved curtailing smelting operations that generated stack emissions when: (a) meteorological conditions were predicted by a computer model linked to weather stations to be conducive to excessive ground level impacts. The NHMRC goal of 50 pphm (10 minute average) was used as the target; or (b) elevated ground level concentrations of sulfur dioxide were actually detected by a network of sulfur dioxide monitors placed in the surrounding suburbs and fed information back to the smelter control room. Here a trigger of 8 pphm (10 minutes) was used.

This system can be considered to have evolved from the Intermittent Production Control System (IPCS) referred to in 3.4.1. Its difference lay in the predictive component. The IPCS was a reactive system only. In any case, the most usual

163 response was to roll out the Pierce Smith converter by reducing or stopping the blow of enriched air, until conditions improved, placing significant restrictions on production capacity. While the system aimed to ensure compliance with the NHMRC standard of 50 pphm (10 minute), the Commission also demanded a refining of controls to meet newer, more stringent WHO goals of 17.5 pphm (10 minutes) by 1991. The Company also stated publicly “ Southern Copper’s long term aim is to stop emitting sulfur altogether, a plan known as Total Sulfur Capture ” (Illawarra Mercury, 5 December 1990). This approach was supported by the Commission (SPCC, 1991a).

In 1992, a status report was prepared on behalf of the company on the predictive reactive system under the Air Quality Project Southern Copper (Hyde, 1992). The study was initiated because of continued concerns about high concentrations of sulfur dioxide measured at SCL monitors at Warrawong, Port Kembla Hospital and Primbee. An assessment of meteorological conditions associated with the high sulfur dioxide concentrations concluded that they were most likely caused by sea breeze fumigation. Following installation of additional SCL monitors at Coniston, Windang and Wollongong, it became clear that the NHMRC goal of 50 pphm (10 min) and WHO goal of 17.5 pphm (10 minute) could be exceeded at all monitors in the SCL regional network.

The status report found that it was not possible to predict in real time and with any certainty, the precise locations where ambient air quality goals (NHMRC or WHO) would be exceeded. This meant that the predictive component of the system was not viable as an emission control strategy. This was due to the plume travel time, variable wind speeds in the atmospheric boundary layer (within sea breezes and onshore gradient winds) and the intermittent nature of emissions from the smelter stack. The result was a constantly changing pattern of concentrations as the plume wafted about the coastal plain.

Plume travel time was a critical factor. Table 15 shows there was a considerable time lag between a plume leaving the stack and being detected by a monitor. This lag time was a function of wind speed and the distance between the stack and the monitor. For example, on a summer day with a typical north easterly sea breeze of around 10 km/hr (2.7 m/s) it would take about 30 to 40 minutes for the plume to travel from the stack

164 to monitors at Windang. This meant, conversely, if a converter was rolled out under these emission control strategies, it would still take about 30 to 40 minutes before emissions could dissipate in the community. These issues soon proved that both the IPCS and predictive-reactive systems were not viable long term strategies for pollution control and greater capture of sulfur dioxide at the source was required. The company did, however, continue to operate the IPCS (reactive) system. Roll out of the converter in operation could also be requested by an EPA officer if ground level impacts were known to be occurring (for example, by field inspection or following public complaints) in areas where no monitors were located.

Please see print copy for image

Table 15 Plume travel times (minutes) to SCL monitoring stations from the main smelter stack (from Hyde, 1992)

165 Fugitive emissions occurred regularly from the main smelter building. The vast majority (over 75%) of these were attributed to the Noranda Reactor during slag and copper matte tapping operations (Dames and Moore, 1994). Another key source was the transfer of copper matte along the smelter aisle from the Noranda in open ladles to the Pierce Smith converters. Section 2.6 outlines the inherent problems associated with Pierce Smith converters and fume collection.

Whilst only one converter was blown at any one time, it took several ladles of copper matte to charge a converter, prior to it being “rolled in”. The frequency and duration of this activity along the smelter aisle increased markedly, given the increase in capacity of the new Pierce Smith Converters and the small quantity of matte available from the Noranda Reactor at any one time. Some fugitive emissions also occurred when the converter was tapped for slag after the slag blows. Emissions also resulted when the converter was tapped after the copper blow and molten copper was transferred in open ladles to the anode furnace for fire refining, particularly if the batch was "green”. A green batch occurred when not all the sulfur in the matte had been eliminated in the copper blow. This transfer of molten metal from the converters to the anode furnace appears to be a new operation. Previously blister copper had been cast from the converters into pigs and transferred to anode furnaces located in a separate casting building, where they were remelted and refined. The roll out of the Noranda or Pierce Smith converter when triggered by the “predictive- reactive” system also released sulfur dioxide. These activities along the smelter aisle all contributed the fugitive emissions on a regular basis. This can be seen in Figures 59 and 60.

Compounding these concerns was a new air pollution concern that arose after the redeveloped smelter was hot commissioned in 1991. Residents of Port Kembla noticed at new type of fallout that was acidic and caused rusty brown spots on outside surfaces, such as concrete foot paths and car ducos (Illawarra Mercury, 19 March 1992 & 27 March 1992).

166 Please see print copy for image

Figure 59 View looking north along smelter aisle at PKC. Photo date 1994. Note the fumes from the open air ladle used to transport molten matte from the Noranda Reactor to the Pierce Smith Converters. Photograph courtesy of DECC. Please see print copy for image

Figure 60 Fugitive emissions from the operation of the Pierce Smith converters. Note the gas hoods installed in an attempt to control converter emissions during blowing. Photo date 1994. Photograph courtesy of DECC.

167 Whilst the exact cause of this “brown spotting” was never conclusively proven by the EPA or SCL, monitoring of this fallout by the EPA using small concrete plates indicated it was attributable to the smelter. It was loosely described as “iron sulfate” on the basis of qualitative chemical analysis by the EPA. It was thought the fallout was caused by the surface absorption of sulfuric acid droplets on particles emerging from the main stack or a corrosion product from the mild steel ductwork within the new acid plant system (Planning NSW, 2002). Examples of this fallout are shown in Figures 61 and 62.

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Figure 61 Brownspot fallout on concrete driveway at Port Kembla. Photo date 1993. Photograph courtesy of DECC

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Figure 62 Close up of same fallout. Photo date 1993. Photograph courtesy of DECC

As discussed in Section 3.6, to address all these air emission concerns, a second upgrade and expansion of the smelter was proposed in 1994. In 1995, however, the

168 smelter ceased operation and went into “care and maintenance”, mainly due to economic reasons.

3.5.2 Environmental Regulation

Whilst the central focus of pollution control policy in NSW in the 1960s and 1970s concentrated upon strict regulation to achieve the objectives of the legislation, by the 1980s this “command and control” approach began to attract criticism for concentrating too much on process, rather than on environmental outcomes, and for failing to provide adequate incentives for upgrade and improvement (Bates, 2006). The regime also required the regulator to expend a large proportion of its resources on investigation and policing. Giving incentives to industry to introduce and monitor their own improvements would reduce the administrative burden on regulatory authorities and lead to desired environmental outcomes (Bates, 2006). In response new regulatory systems emerged in Australia based on three broad principles (Bates, 2006). First, that integration of approaches to environmental management (air, water, land, noise) will lead to best practicable environmental outcomes. Second, that pollution control must be integrated with land use planning and other regulatory systems. Third, that economic systems must be employed as a major policy initiative to supplement regulation in achieving improved standards of pollution control.

From 1989 to 1992, the State Pollution Control Commission continued to regulate pollution sources in NSW. In 1992, however, the NSW Environment Protection Authority (EPA) was established under the Protection of the Environment Administration Act 1991 as the primary NSW public sector organisation responsible for protecting the environment. It was formed by amalgamation of the State Pollution Control Commission and the Radiation Control Branch from NSW Health. The smelter continued to hold separate pollution control licences, issued by the EPA, under the Clean Air Act 1961 and Clean Waters Act 1970.

In 1992, the EPA reported the upgrade of the smelter had not met the expectations of a better environmental performance (EPA, 1992a). The $160 million redevelopment (represented by a new Noranda reactor and acid plant) had been plagued by both production and pollution control problems. Whilst the EPA and Company continued

169 to explore control options, growing numbers of complaints regarding air pollution from the smelter were being received by the EPA, especially during the summer months. These pollution problems included the ability of the smelter to manage sulfur dioxide (both stack and fugitive), lead (fugitive) and brown spot fallout.

Whilst not a legal requirement, the existing smelter regularly exceeded the 10 min and 1 hour ambient air quality goals for sulfur dioxide recommended by WHO and the NHMRC in nearby residential areas (Dames and Moore, 1994). Fugitive lead emissions still continued to exceed NHMRC standards downwind of the smelter. Damage to property from brown spot fallout continued to be a major concern.

In late 1993, following extensive negotiations between the EPA and SCL on the range of measures required to address these continuing problems, the Authority served a legal notice on SCL to upgrade pollution controls at the smelter. The notice included 5 major Pollution Reduction Programs (PRPs) aimed at reducing air and water pollution. Underpinning the notice was the EPA requirement for stack and fugitive sulfur dioxide emissions to not exceed the WHO ambient air quality goal for sulfur dioxide of 17.5 pphm (10 min average). The upgrade was now required, under the EPA pollution control licence, to be completed by September 1996 (EPA, 1994a). As a result, SCL began undertaking detailed design work. In order to meet the EPA requirements SCL took the view that a fundamentally different approach to the operation of the smelter was required.

In addition to this major PRP program, the EPA facilitated an independent community mediation process to address public concerns regarding damage to property from brown spot fallout. The outcome of this process was that the company should appropriately compensate residents whose property had been affected (Lake Times, 13 October 1993). Over $7 million was eventually paid by the company to rectify property damage caused by this fallout .

Proposals for the major environmental upgrade and expansion for the copper smelter were publicly announced in late 1994 (Illawarra Mercury, 22 September 1994) and the subject of an EIS (Dames & Moore, 1994). Public information displays on the upgrade and EIS were also held at local community centres or libraries in Cringila,

170 Warrawong and Port Kembla (Illawarra Mercury, 21 September 1994). The redevelopment works were estimated by the company to cost around $118 million. A decision still remained, however, on whether the company would actually proceed with the redevelopment. Speculation began to emerge that the company would wind down its operations. This is because company shareholders refused to commit financially to the required environmental and expansion projects (Illawarra Mercury, 13 September 1994, 7 October 1994 & 2 November 1994).

On 30 November 1994, SCL finally announced that it would close its smelting operations and place the facility under care and maintenance (Illawarra Mercury, 1 & 2 December 1994). Smelting operations ceased in early January 1995. The principal factors which contributed to the decision included the following:
Continued operation of the smelter without firm commitment to early environmental upgrading was not acceptable to the local community, EPA or SCL shareholders;
Further capital expenditure, of the order of $230 million, was necessary for environmental upgrading and expansion of output to improve economic performance. This expenditure was not supported by all shareholders;
Financial performance of SCL was consistently poor since completion of the redevelopment in 1991 and the shorter term outlook was particularly bleak. It can be seen that the ability to comply with EPA requirements, whilst a contributing factor, was not the main reason for the smelter closure. During care and maintenance, efforts to attract a new equity partner continued, as did plans for the upgrade. Much depended on whether SCL could demonstrate by further study that the operation could become internationally competitive and profitable.

Whilst the number of prosecutions is not the only measure of the EPA’s regulatory efforts, the Authority took legal action to enforce licence conditions whilst the smelter operated. This included issuing notices and taking prosecutions in line with its prosecution guidelines (DEC, 2003) where there were breaches of the environmental legislation. The EPA successfully prosecuted SCL five times between 1991 and 1995 (EPA, 1991a to 1995a). This included breaches of the sulfur dioxide concentration limits in the tail gas from the acid plant.

171 Because of the scope of the smelter upgrade works, the development application triggered a public and independent Commission of Inquiry (COI) in late 1994/early 1995 under the requirements of the NSW environmental planning legislation. The EPA provided detailed submissions to the COI. The EPA stressed requirements for sulfur dioxide control, consistent with its PRP requirements. Other issues included brown spotting, waste management, soil and groundwater contamination, noise and water pollution. These submissions are well documented and on the public record (COI, 1995).

At the COI, the Commissioner found that the smelting technology and associated pollution controls proposed by SCL would be able to generally meet most of the EPA requirements, except in relation to stack and fugitive sulfur dioxide. Whilst the proposals by SCL would result in reduced stack emissions, the likelihood of a small number of exceedances of the WHO 10 minute goal still remained. SCL stated that the highest ground level concentrations (short term) were predicted to occur to the west of the stack, along a line from the Primbee, Port Kembla Hospital, Warrawong Baby Health Centre and Steelhaven monitors (Dames and Moore, 1994). This coincides, approximately, with the Central zone identified in Figure 2 of this thesis. The most affected location would be Primbee and it was estimated that the WHO 10 minute goal would be exceeded there less than 8 times per year (Dames and Moore, 1994). It was estimated that the existing smelter exceeded the same goal at Primbee about 50 times per year (Dames and Moore, 1994; COI, 1995). Of far more significance was a question about the control of fugitive emissions of sulfur dioxide from the Pierce Smith converters, and this quickly emerged as a major issue for the Commissioner to resolve (COI, 1995).

Whilst it was accepted that the overall effectiveness of the fugitive emissions control would be improved compared to the existing smelter, the relative extent of the improvement was uncertain until operational information was obtained. There was considerable uncertainty with the estimated figures presented at the COI. SCL argued that about 150 exceedances of the WHO 10 minute goal were likely in the vicinity of the Port Kembla Fire Station and about 5 exceedances at Saint Patrick’s School (Dames and Moore, 1994). These were still a significant improvement on the existing smelter. Estimates presented to the COI indicated up to 250 exceedances occurred at

172 Saint Patrick’s School and up to 4,000 exceedances occurred at the Fire Station each year (Dames and Moore, 1994; COI, 1995).

As the COI concluded, the Commissioner was convinced that the smelter could not meet the WHO 10 minute sulfur dioxide goal one hundred percent of the time at all locations. A view emerged from the Commissioner that the community could be adequately protected by a less stringent goal. This goal, however, included up to 150 exceedances of the WHO 10 minute goal in certain areas with no upper “cap” on the extent of each exceedance.

In its final submission to the Inquiry, the EPA recommended maintaining the WHO 10 minute goal, 99% of the time (that is no more than 12 exceedances per year in residential areas), and 100% compliance with the then contemporary NHMRC goal of 50 pphm (10 minute average). The Authority also proposed up to 36 exceedances of the WHO goal at monitoring stations in an industrial/commercial zone (including Port Kembla Fire Station). The EPA was convinced that the community would be protected by the limits it proposed provided that the NHMRC goal was never exceeded. SCL indicated that whilst the maximum concentration of each exceedance episode would be reduced, this NHMRC 10 minute goal could still be frequently exceeded at key locations such as the Port Kembla Fire Station. The Authority also recommended a second stack be constructed to improve the ventilation capacity of the smelter and allow higher fugitive emission capture efficiencies to be achieved. SCL rejected the concept of a second stack on the grounds that it was not necessary and would not deliver the results expected by the EPA. They also stated it would render the upgrade and expansion non-viable because of the increased capital and operating costs of a new stack.

In the final report (COI, 1995), the Commissioner recommended the development proceed, subject to conditions. In relation to sulfur dioxide these included a requirement to demonstrate that the plant is capable of operating without causing “a significant number of exceedances” of the 10 minute WHO and NHMRC goals. “Significant number of exceedances” were defined as follows: • More than 12 exceedances of 17.5 pphm in any year at any existing monitor in a residential area;

173 • Any exceedances greater than 50 pphm at any existing monitoring station in a residential area; • More than 150 exceedances of 17.5 pphm in any year at the Port Kembla Fire Station; • More than 12 exceedances of 50 pphm at the Port Kembla Fire Station.

These requirements did not meet the EPA stated recommended limits. It is worthwhile noting that these recommendations allowed up to 150 exceedances of the WHO goal at Port Kembla Fire Station and provided no upper “cap” of each exceedance episode. This is because the Fire Station was considered to be in commercial zone, rather than a residential one. There was, however, a requirement to develop a sulfur dioxide management plan which set out the actions to be taken whenever the 10 minute average concentration rose above 50 pphm at the Port Kembla Fire Station or Saint Patrick’s School monitors. These actions could include consideration of upgraded control measures (including a second stack), work practices, modification of production levels and progressive acquisition of buffer zones. There was also a requirement to employ a trained “aisle scheduler” whose responsibility was to control the ventilation system to ensure optimal capture of fugitive emissions at all times.

These and other requirements in relation to discharge limits, monitoring and reporting, were translated into conditions of consent which were granted by the Minister for Planning in February 1996. The modified consent also included: • the establishment of a 24 hour telephone service by the company for the community to report pollution incidents or seek information relating to the environmental performance of the premises; • an independent and comprehensive annual environmental audit of the smelter; and, • the establishment of a monitoring committee to monitor the company’s environmental performance. This committee will include representatives from the local community.

174 The EPA did not issue a licence as there was no licence application at this stage. In November 1995 the NHMRC also revised its 10 minute goal from 50 pphm to 25 pphm. In mid 1996, Japanese principals (Nissho Iwai Corporation & Furukawa Co. Ltd), represented by the Port Kembla Smelter Project (PKSP) applied to modify the development consent to accommodate a fundamental change in the design and operation of the smelter. This is discussed further in Section 3.6.

3.5.3 Ambient Atmospheric Sulfur Dioxide Concentrations

During the period 1989 to 1995 sulfur dioxide was monitored at 16 locations in and around Port Kembla/Wollongong. A summary of the annual average sulfur dioxide levels at all monitoring locations during this period is given in Table 16. The locations of these monitors and the geographical zones are shown in Figures 2 and 3.

Table 16 shows that areas with the highest annual averages of sulfur dioxide continued to be localities that were impacted by stack and fugitive emissions from the smelter. For the first time, however, yearly averages eventually met the WHO goal (1 year) of 1.8 pphm, even with the smelter operating.

In the Port Kembla Township zone annual averages ranged from 2.0 to 0.34 pphm (zone average 0.82 pphm) during this study period. Here monitors in the immediate vicinity of the smelter continue to be affected by fugitive emissions (Port Kembla Fire Station and St Patrick’s School). There appears, however, to be a reduction in annual average levels at key monitors in this zone, during this period. For example, at St Patrick’s School annual averages decrease from 2.0 pphm in 1992 to 0.46 pphm in 1994. This suggests increasing capture and control of fugitives from the smelter.

In the Central zone annual averages ranged from 2.5 to 0.09 pphm (zone average 0.84 pphm). The high annual readings arise from monitors located downwind of the smelter under a prevailing summer northeasterly wind, being impacted by sulfur dioxide emissions from the smelter stack. These monitors include Port Kembla Hospital, Warrawong Baby Health Centre and Steelhaven. As stated in Section 2.8, this is consistent with the expected zone of maximum impact of stack emissions, given the smelter stack height and prevailing north easterly summer winds. Yearly

175 averages recorded in the Central zone during 1989, appear much higher at some monitors than the last study period. They then decrease during this review period, even with the smelter operating. For example, at Warrawong Baby Health Centre, annual averages were 2.5 pphm in 1989 and then decreased to 0.90 in 1990 and 0.47 pphm in 1994. These air quality patterns can be attributed to a major increase and then decrease in smelter stack sulfur dioxide emissions, the exact causes of which, are explained later in this section.

Geographical Location YEAR Annual Average Zone 1989 1990 1991 1992 1993 1994 1995 in zone for all years Port Kembla Port Kembla - - - - - 0.34 - 0.82 Township Fire Station St Patrick’s - - - 2.0 0.66 0.46 0.63 School Central Primbee 0.42 0.48 - 0.50 0.09 0.19 - 0.84 Public School Port Kembla 2.4 0.81 - 0.80 0.39 0.55 - Hospital Warrawong 2.5 0.90 - 0.73 0.81 0.47 - Baby Health Centre Steelhaven 1.3 0.70 - 0.76 0.49 0.80 - Kemblawarra 0.48 ------Public School Warrawong – 1.7 1.4 - - - - - King & Wattle St Warrawong – 0.53 0.74 - - - - - Blaxland & Flagstaff Rd Wollongong Wollongong, 0.54 0.52 - - - - - 0.48 City Auburn St Coniston - - - 0.75 0.48 - - (Water Board Stores) Wollongong - - - 0.73 0.23 0.15 - Showground (Harbour St) EPA - - - - 0.45 0.60 0.31 Wollongong Outer Windang - - - 0.24 0.09 0.42 - 0.27 Catholic Church EPA Kembla - - - - - 0.33 0.21 Grange EPA Albion 0.33 0.35 0.25 0.39 0.26 0.19 0.15 Park

Table 16 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1989 to 1996. All values in pphm.

176 In the Wollongong City and Outer zones, annual averages ranged from 0.75 to 0.15 pphm (zone average 0.48 pphm) and 0.42 to 0.09 pphm (zone average 0.27 pphm) during this study period. Both zones also appear to show a slight reduction in annual average levels at individual monitoring stations over the years, though not as marked as in the Port Kembla Township and Central zones.

A more detailed insight into the above changes in air quality can be found in the monthly average, maximum 10 minute and maximum hourly sulfur dioxide data. Figures 63 to 91 summarise this data at the 16 monitoring locations.

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Max 1hr (pphm) Figure 67 Maximum 1 hour sulfur dioxide concentrations for Saint Patricks School Port Kembla, 1992 to 1995 (values in pphm)

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Monthly Average (pphm) Figure 71 Monthly Average sulfur dioxide concentrations for Port Kembla Hospital, Port Kembla, 1989 to 1995 (values in pphm)

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Figure 77 Monthly Average and Highest Daily concentrations for Blaxland and Flagstaff St, Warrawong, 1989 to 1991 (values in pphm)

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Figure 78 Monthly Average and Highest Daily concentrations for Kemblawarra Public School, 1989 to 1990 (values in pphm)

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Figure 79 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Kemblawarra Public School , 1989 to 1990 (values in pphm)

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Figure 86 Monthly average and highest daily sulfur dioxide concentrations for Auburn St, Wollongong, 1989 to 1991 (values in pphm)

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Figure 90 Highest Daily sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1989 to 1996 (values in pphm)

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9 9 9 0 0 1 1 2 2 2 3 3 3 4 4 5 5 6 8 8 90 9 9 9 9 9 9 9 95 9 96 - r-8 - l- r-9 t- r-9 r-9 -94 r-9 l- r-9 t- ul- n-90 u n-91 p p ul- p ul- ul- n-95 p u p ul-96 c Jan Ap J Oct-89 Ja Apr J Oct- Ja A Jul-91 Oc Jan-9 A J Oct-92 Jan-9 A J Oct-93 Jan Apr-94 J Oct- Ja A J Oct- Jan-96 A J O Month/Year Warrawong (pphm) Wollongong (pphm) Kembla Grange (pphm) Albion Park (pphm) Figure 91 Maximum 1 hour sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1989 to 1996 (values in pphm)

191 Figures 63 to 91 indicate that there tends to be an overall decline in sulfur dioxide levels from 1989 to 1995 across all monitoring stations. The graphs show that hourly and 10 minute averages often exceeded the NHMRC goal for sulfur dioxide of 20 pphm (1 hr) and WHO goal of 17.5 pphm (10 min), at all monitoring locations whilst the smelter operated (especially during summer).

In the Port Kembla Township zone, values of up 36 pphm (monthly average) and 2926 pphm (maximum 10 minute) were recorded. These are considerably higher than the values of up to 9 pphm (monthly average) and 44 pphm (maximum daily) recorded during the 1970s and 80s. Maximum hourly values were up to 744 pphm. This is despite the promise of “negligible” fugitive emissions in the EIS (Kaybond, 1988). There is a also a marked difference between the monthly average, maximum hourly and maximum ten minute values. This is consistent with the intermittent nature of emissions from the smelter and the “batch type” processes that continued to be used, principally for matte converting.

In the Central zone values of up to 8.2 pphm (monthly average), 81 pphm (maximum hourly) and 300 pphm (maximum 10 minute) were recorded. These are much higher than the values of up to 2.8 pphm (monthly average), 7.5 pphm (maximum daily) and 35 pphm (maximum hourly) recorded during the 1970s and 80s. This is despite the provision of sulfur capture at the smelter and an expected decrease in the annual load of sulfur dioxide emitted. In fact, this period in the late 1980s/early 1990s, had the highest monthly average, maximum hourly and maximum 10 minute readings ever recorded at sites in the Central Zone. The highest values for monthly average, maximum hourly and maximum 10 minute measurements tend to be recorded in the summer months as the prevailing north easterlies carry emissions from the smelter stack towards these monitors.

As seen in the annual average data, ambient sulfur dioxide concentrations (monthly average, maximum hourly and maximum 10 minute) measured at monitors in the Port Kembla Township and Central zone, appeared to increase significantly in 1989, immediately following the first redevelopment, especially when compared to the last study period. These increases in ground level concentrations can be linked to failures

192 in the redeveloped smelter to achieve key design targets for the emission and control of sulfur dioxide.

As indicated in Table 12, actual sulfur dioxide emissions from the previous smelter averaged only around 25,000 tonnes per year in the late 1980s. The load of sulfur dioxide emitted rose sharply following the first redevelopment. It was around 33,000 tonnes per year in 1989, 38,000 tonnes per year in 1992 and up to 52,000 tonnes per in 1993. These latter loads are significantly higher than the design sulfur dioxide load figure of 36,000 tonnes/year.

Table 17 shows that whilst the overall production of blister copper during 1988 to 1990 was lower compared to 1981/1982, there was a greater reliance on smelting copper concentrate in 1989/1990 and decreased reliance on copper scrap. Reliance on copper concentrates continued to grow into the early 1990s. This not only increased copper production but also increased the annual load of sulfur dioxide generated and potentially emitted, unless captured in the acid plant.

Source of Copper Production from raw feed (tonnes) raw feed 1981 / 1988 2 1989 2 1990 2 1991 3 1992 4 1993 4 1982 1 Copper 12774 12695 12858 16414 ND 49529 57626 concentrates Scrap & 33618 27164 26732 22586 ND 15560 23141 other recycled copper TOTAL 46392 39859 39590 39000 ND 65089 81667

Notes 1 Financial year from Eklund and Murray (2000) 2 Financial year from ERS (1990) 3. No data available 4. Calendar year from Dames & Moore (1994)

Table 17 Copper production from raw feed (copper concentrates and scrap) for various periods 1981 to 1993.

193 As stated in Section 3.5.1, during the first redevelopment there were commissioning problems with the new smelting furnace (Noranda Reactor). These resulted in intermittent operation of the acid plant and reduced sulfur dioxide capture to less than the expected 75% target. Whenever sulfur dioxide could not be captured, the sulfur dioxide was vented to atmosphere via the main stack. These emissions would account for the observed increases in ambient sulfur dioxide concentrations measured downwind of the smelter, especially in the Central zone.

In addition to these increases in the annual load of sulfur dioxide emitted, there also appears to have been increases in the emission rate of sulfur dioxide from the main stack, even if the smelter functioned as designed. These increased emission rates could also increase ambient sulfur dioxide levels. In Section 2.8, we saw that ambient concentrations of pollutants are directly related to their emission rate (for example, grams/second) from a stack. Evidence for significant increases in stack emission rates of sulfur dioxide following this redevelopment can be found in the EIS (Kaybond, 1988), especially during matte converting operations. This is summarised in Table 18. Please note this emission data refers to sulfur and not sulfur dioxide.

Table 18 shows that there was to be a significant reduction in the stack emission rate of sulfur (and hence sulfur dioxide) during the slag blow following this redevelopment. This can be attributed to the higher matte grade produced by the Noranda Reactor, compared to the previous Blast Furnace. The higher grade matte would contain less iron and sulfur required to be removed in the slag blow. What is apparent is an increase in the stack sulfur (and hence sulfur dioxide) emission rate during the copper blow portion of the converting cycle for the redeveloped smelter. This is important because, as Table 18 indicates, it was the slag blow that previously had the higher emission rates. Because the copper blow portion of the converting cycle is four times longer in duration (minutes) than the slag blow, this would mean that the higher emission rates potentially occurred over a longer time period during each converting cycle in the redeveloped smelter, than previous operations. These changes in converting emissions could account for the observed increases in ambient sulfur dioxide concentrations, measured downwind of the smelter.

194 Please see print copy for image

* Includes (a) or (b) ** Estimated from gas exit flow rate and stack emission concentration.

Table 18 ERS Stack Sulfur Emissions Data (From Kaybond, 1988)

Another compounding factor would have also been the increase in converter operating time. To account for the increased production, the converters were not only increased in size but also operated on a more frequent basis. The number of converter blows increased from around 3 per day to about 5 per day (Kaybond, 1988). As the most significant stack emissions occurred during converting, this increased the percentage of time per day these emissions could occur in the community.

Later on in this study period, there appears to be a decrease in maximum hourly and maximum ten minute levels recorded in the Central zone, even with the smelter operating. This can be seen in the graphs for Primbee Public School (Figure 70) and Port Kembla Hospital (Figure 72). This could be due to increased online availability of the acid plant following initial commissioning problems (Andrews, 1993). It could

195 also be due to the impact of the Intermittent Production Control System in reducing the operation of the converters to prevent high ground level concentrations occurring. The effect of this reactive strategy would have been to increase the ratio between the maximum 10 minute and corresponding 1 hr average concentrations (Dames & Moore, 1994). This is suggested in some of the figures, for example, Port Kembla Hospital (Figure 72).

At other zones, sulfur dioxide levels were considerably lower. In the Wollongong City zone, values of up to 0.75 pphm (annual averages), 70 pphm (highest hourly) and 357 pphm (maximum 10 minute values) occurred. In the Outer zone, values of up to 0.42 pphm (annual average), 38 pphm (highest hourly) and 175 (maximum 10 minute values) were recorded. The higher hourly and 10 minute readings in the Wollongong City zone suggest some intermittent grounding of the smelter stack plume in this zone, in particular at the Coniston and Wollongong Showground monitors.

At monitors in the Outer Zone (for example, Albion Park and Windang), there appears to be some seasonality in the monthly average data during smelter operation between 1989 to 1995. The highest values tend to be recorded in the summer months (Figures 87 and 89). This is consistent with prevailing north easterlies carrying emissions from the smelter towards this monitor.

Whilst the above discussion has focussed on increases in ambient concentrations of sulfur dioxide from the main stack; increases in the frequency and intensity of fugitive sulfur dioxide emissions also occurred. This had major impacts on neighbourhoods immediately downwind of the smelter in the Port Kembla Township zone. These resulted from an increase in activity on the smelter aisle, in particular, ladle transfers of matte from the Noranda reactor to the converters.

Following smelter closure in 1995, there is a reduction in the monthly average, maximum daily and maximum hourly readings at EPA MAQS at Warrawong, Albion Park, Kembla Grange and Wollongong. This is shown in Figures 89 to 91. This is further evidence of the smelter being the dominant source of sulfur dioxide monitored in the study area.

196 3.5.4 Summary of information 1989 to 1996

The period 1989 to 1995 saw the first major redevelopment of the smelter. Copper production capacity increased from 40,000 to 80,000 tonnes per annum and for the first time in the history of the smelter, some sulfur capture was provided. This was achieved by replacing the Sinter Plant/Blast Furnace combination and part of the converting stage with a Noranda smelting furnace. The converting furnaces continued to be of the Pierce Smith type. Up to 75% of the total sulfur dioxide generated, mostly from the Noranda furnace, was to be captured and converted to sulfuric acid in a new acid plant. During this period the smelter continued to be regulated under a pollution control licence administered by the SPCC and later the EPA.

Despite the doubling in production capacity, there was to be a 10 to 20% reduction in overall sulfur dioxide loads emitted between the previous and redeveloped plant. In practice, however, the sulfur dioxide loads increased from about 26,000 tonnes per year in the late 1980s to up to 52,000 tonnes per year in the early 1990s. This was due to commissioning problems with the new Noranda/Acid Plant system. The smelter did not fully meet the expectations of the community and government. Sulfur dioxide emissions continued to be a concern until it ceased operation in 1995 and went into care and maintenance.

Sulfur dioxide monitoring during 1989 to 1995 shows that the area with the highest readings tended to be in two zones. The first was in the Port Kembla Township zone. Here annual averages up to 2.0 pphm, highest hourly values up to 750 pphm and highest 10 minute readings up to 2926 pphm were recorded. These were due to fugitive emissions from the smelter. The second was the Central zone. This was due to smelter stack emissions. In this zone annual averages up to 2.5 pphm, highest hourly values up to 81 pphm and maximum 10 minute readings of up to 300 pphm were measured.

A review of the monitoring data from monitors in the Port Kembla Township and Central zone indicates that sulfur dioxide concentrations (monthly average, maximum hourly and maximum 10 minute) increased significantly in 1989, immediately following the first redevelopment, especially when compared to the last study period.

197 These increases can be linked to failures in the redeveloped smelter achieving key design targets for the emission and control of sulfur dioxide. These levels appear to decrease later on in this study period. This could be due to increased capture of stack and fugitive emissions, in particular due to the greater online availability of the acid plant following initial commissioning problems. It could also be due to the impact of the Intermittent Production Control System that was sometimes used to reduce stack emissions from converter operations whenever high ground level concentrations occurred.

At other zones, annual sulfur dioxide levels were considerably lower. In the Wollongong City zone, values of up to 0.75 pphm (annual averages), 70 pphm (highest hourly) and 357 pphm (maximum 10 minute values) occurred. In the Outer zone, values of up to 0.42 pphm (annual average), 38 pphm (highest hourly) and 175 (maximum 10 minute values) were recorded. The higher hourly and 10 minute readings in the Wollongong City zone suggest some intermittent grounding of the smelter stack plume in this zone, in particular at the Coniston and Wollongong Showground monitors. There is an observable seasonality in the monthly average data reported in the Outer zone (Albion Park). The highest values tended to be recorded in the summer months suggesting emissions from the smelter or Sinter Plant may have been carried towards this monitor under prevailing north easterly winds.

The shutdown of the smelter due to economic reasons, in 1995, allowed ambient levels of sulfur dioxide to be measured in the absence of the smelter. A major decrease was observed in the sulfur dioxide levels. This decrease indicates that, when operational, the smelter was a dominant source of the sulfur dioxide measured.

3.6 Emission History 1996 to 2006

3.6.1 Smelter Operations - Sulfur Dioxide Emissions & Controls

The period 1996 to 2006 saw a second major upgrade and expansion of the copper smelter at Port Kembla. These resulted in unprecedented changes to its fundamental design and operation and had a significant impact on sulfur dioxide emissions and

198 their control. Towards the end of this period, the smelter also ceased operation and went into “care and maintenance”.

As discussed in Section 3.5, following the securing of new investors and the founding of a new smelter operator, Port Kembla Copper (PKC) in 1996, a revised smelter design was finally agreed upon. Before committing to the investment of some $250 million on a major new smelter, the Port Kembla Smelter Project consortium approached the NSW Government seeking specific EPA licence conditions and a commitment that these conditions would remain fixed for a period of up to 10 years. Following extensive negotiations, agreement was reached on the intended licence conditions applying to the new technology. These ensured compliance with the WHO 10 minute goal 99% of the time and 100% compliance with the then contemporary NHMRC 10 minute goal. This meant that during the ongoing operation of the plant, following its initial commissioning, only 12 exceedances of the WHO goal of 17.5 pphm (10 minute average) were permitted in residential areas. At no time could the plant exceed the NHRMC goal of 50 pphm (10 minute average). This was consistent with the EPA final submission to the COI. In November 1996, the Minister for Planning granted a modification to the existing consent consistent with the EPA's intended licence conditions.

The new smelter design was anticipated to result in more effective control of air pollution at the source, resulting in significant environmental benefits. It would also increase production from 80,000 tons per year to 120,000 tons per year. Construction of the redeveloped smelter began in early 1997 and hot commissioning commenced in February 2000.

As stated in Section 3.5, the upgrade was originally to be achieved through extensions to the existing two Pierce Smith converters and installation of a third new Pierce Smith converter. These three converters could be cycled to produce a steady stream of sulfur dioxide that could be accepted by a new acid plant. This approach was not, however, adopted. There was a fundamental change in the design and operation of the smelter. The revised approach included crucial design elements to control stack and fugitive sulfur dioxide emissions and brown spotting.

199 To address stack sulfur dioxide emissions the converting stage was based on the more efficient Mitsubishi Converting (MIC) furnace. Copper matte produced in the existing Noranda furnace (approximately 65% copper) was periodically tapped and transferred to a holding furnace. These transfers occurred via ladles, but in an enclosed “matte tunnel”. The holding furnace was designed to ensure a constant flow of molten matte using gravity and enclosed launders to the MIC. The MIC replaced the previous Pierce Smith Converters for converting of the copper matte to blister copper. Gravity and enclosed launders were used for the transfer of molten blister copper from the MIC to the anode furnace. The Noranda Furnace and MIC were both coupled to a new double contact acid plant (to complement the existing single contact plant). This acid plant system was designed to significantly reduce sulfur dioxide emissions to the air (up to 95%) from both smelting and converting operations.

Crucial to the control of fugitive emissions was the elimination of the Pierce Smith converters and the associated open air ladle transfers of molten matte, slag or blister copper. There was, however, one ladle transfer operation that still remained. Slag tapped from the Noranda furnace was sent to an electric furnace for “cleaning”. Any residual matte in the slag settled out in the electric furnace and was recovered and sent to the MIC for conversion to blister copper. These electric furnace slag transfer operations were less frequent than those associated with the Pierce Smith converters, but could still result in fugitive emissions. As a further safeguard, the smelter building was totally enclosed, with any remaining fugitive emissions ventilated through the main baghouse to the main stack.

To address brown spot fallout, a new 70 metre stack was installed to serve the acid plants. It was thought that this second stack would enable segregation of gas streams in the smelter to minimise the formation of “brown spots”. Wet, acid bearing gases would be restricted to the acid plant circuit and new (second) stack. Dry, particulate bearing gases would be restricted to the smelter main baghouse / main stack system.

The EIS (Dames and Moore, 1994) states that without any sulfur removal, the annual load of sulfur dioxide potentially generated by the redeveloped smelter would have been around 240,000 tonnes per year. With the installation of a second acid plant, over 95 % of the sulfur dioxide generated was to be captured. The remaining overall

200 design load of sulfur dioxide emitted by the smelter would be reduced from the pre- development level of around 36,000 tonnes per year to less than 9,200 tonnes per year. The EPA licence limit for sulfur dioxide was set at 6,300 tonnes per year (from the main and acid plant stack combined). This limit took into account campaign shutdowns of the smelter. These campaigns occurred every few years at the smelter (often for several months) to perform essential maintenance work. This maintenance could include, but not be limited to, replacement of refractory bricks lining critical furnaces.

Anode copper production data provided by PKC (pers comm., Ian Wilson) indicates that whilst the 120,000 tonnes per year design capacity was not fully achieved at the redeveloped smelter, there was a major production increase compared to the previous smelter that operated. There was also a corresponding major decrease in the amount of sulfur dioxide emitted.

Annual copper production and sulfur dioxide emission data during the operation of PKC, between 2000 to 2003, are summarised in Table 19 and Table 20 respectively. Direct comparison for each year is not possible due to differences in the reporting periods. The tables show, however, that during the period PKC operated between 2000 to 2003, on average about 40 kg of sulfur dioxide was emitted for every tonne of anode copper produced. This represents a major decrease compared to the previous smelter figure of around 600 kg of sulfur dioxide per tonne of copper produced during the early 1990s. Please see print copy for image

Table 19 PKC Anode Production data 2000 to 2003 (pers comm Ian Wilson- PKC)

201

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Table 20 PKC Sulfur Dioxide Load Emission Data 1999 to 2004 (NPI, 2007)

Whilst this smelter was clearly a very different smelter from the previous ones that operated on the site, commissioning was not without its issues. Environmental problems quickly began to emerge, two of which related to sulfur dioxide emissions and their control. The first related to heat build-up in the smelting building which raised occupational health and safety questions. The second was related to the new acid plant and associated stack. These problems are discussed in more detail below and resulted in further modifications to plant and equipment and the existing development consent (Planning NSW, 2002).

Several large furnaces existed in the smelter building. These included the Noranda Reactor, Holding Furnace, MIC furnace and Anode Furnaces. Following commissioning, it was soon found that there were inadequate measures to dissipate this heat. The design of the smelter was based on maximising enclosure to prevent fugitive emissions containing sulfur dioxide and/or lead from leaving the smelter building. Any fumes that accumulated in the building were ducted through the main baghouse to the main stack. In 2000, the company installed two roof vents and ten roof ventilators above the furnaces to maintain a cooling air flow through the smelter aisle to meet occupational health and safety requirements for heat stress (Planning NSW, 2002). Sulfur dioxide was continuously monitored in these vents and if a specified concentration was reached, they were automatically closed by a damper system. These emissions were then vented through the main baghouse to the main

202 stack. The system could also be operated manually if required. The roof vents were reopened when the measured sulfur dioxide returned to normal or visible fugitive emissions ceased. There were debates in the community about the effectiveness of this system, particularly following complaints regarding visible emissions from the smelter building that were not captured, because they often contained little or no sulfur dioxide to trigger the dampers. The roof vents were also perceived by some residents to conflict with the commitment by the company for an enclosed smelter building to contain all fugitive emissions.

In the early stages of commissioning it was found that there were occasions when the ground level concentration of sulfur dioxide was above the WHO goal (10 minute) in the vicinity of the smelter (measured at Port Kembla Fire Station and Saint Patrick’s School). Some of these we attributed to fugitive emissions of sulfur dioxide that sometimes occurred from the acid plant system (caused by process leaks) and smelter buildings (caused by the transfer of matte from the electric slag furnace to the Noranda Reactor). These incidents resulted in considerable community concern and media interest (For example, Illawarra Mercury, 7 April 2000). The majority of these events, however, were attributed emissions from the new acid plant stack. Discharges from this new stack began to attract public complaints, both from visible emissions but also ground level sulfur dioxide impacts (Illawarra Mercury, 11 November 2000). Even when the acid plant discharge met licence limits for sulfur dioxide, it was found that under certain meteorological conditions, the plume from the new acid plant stack exhibited unstable characteristics. This resulted in it impinging on ground level causing exceedences of the WHO 10 minute goal (PKC, 2001). The exceedances occurred mainly during clear sunny days with light winds indicative of convective (unstable) conditions. As the land warmed up during the day, thermal eddies caused the plume to loop to ground level (see Figure 92).

203 Please see print copy for image

Figure 92 Emissions from PKC Acid Plant Stack. Photodate 2000. Photograph courtesy of DECC

As an interim measure, the company implemented a protocol to restrict smelter (and acid plant) operations during these atmospheric conditions. This limited the number of incidents but also affected plant utilisation and profitability. Following review of a number of options, the company agreed to a scrubber unit to treat the tail gas from the acid plant (PKC, 2001). This utilised a caustic soda (sodium hydroxide) solution to reduce the level of sulfur dioxide being emitted, according to the following reaction.

2NaOH (aq) + SO2 → Na2SO3 (aq) + H2O

The company operated the scrubber so that the concentration of sulfur dioxide in the acid plant tail gas was reduced from around 1000 ppm to 200 ppm. This was considered low enough to prevent exceedances of the ambient WHO 10 minute goal. Due to the quenching effects of the scrubber and the resulting negative buoyancy effects, it was also necessary to install a natural gas burner to reheat the gas to a temperature that minimised the potential for the plume to come to ground level. Given these constraints and associated operating costs, the scrubber was only operated on an

204 intermittent basis and activated manually. This was when meteorological conditions were conducive to ground level impacts or when acid plant start up was less than optimal.

In September 2003, the smelter ceased operation and currently (2007) remains idle under “care and maintenance”. Photographs of the works are shown in Figures 93 and 94. The company cited a downturn in the copper market as the main reason for the shutdown.

Please see print copy for image

Figure 93 Port Kembla Copper Smelter (looking east from Police Station). A = Acid Plant stack, B = Smelter building roof vents, C = Smelter building roof ventilators, D = MIC Cooling Water Tower and E = Main Stack. Photo date 2002. (Photo courtesy of DECC)

205

B

D

A C

Figure 94 Port Kembla Copper Smelter (looking north west from main stack). A = Main stack, B = Acid Plant stack, C = acid plants, D = copper billet casting area. Photo date 2008. (Photograph by author). It is worthwhile considering the scale of smelting operations at Port Kembla against other copper smelters around the world. Up until the late 1980s the capacity of the smelter at Port Kembla was only 40,000 tonnes per year. The two redevelopments during the 1990s increased capacity up to 120,000 tonnes per year. Despite these expansions, the smelter’s capacity has always been small in comparison to other smelters that existed during its operation. For example, even in the 1970s, smelters such as Mt Isa, Queensland had capacities around 150,000 tonnes per year and others in the USA, Soviet Union, Chile and South Africa had capacities well over 300,000 tonnes per year (Biswas, 1976). The largest copper smelter in the world is currently LS Nikko Copper in Korea with a capacity of around 510,000 tonnes per year of refined copper (LS-Nikko Copper, 2007).

3.6.2 Environmental Regulation

Following its closure in 1995, the commencement of construction of the new smelter in 1997 attracted considerable community and government attention. Whilst the EPA continued to regulate the smelter under a licence, further reforms of the pollution control legislation occurred.

In the late 1990s, the EPA recognised that traditional approaches to pollution regulation could no longer guarantee the best outcomes for the environment (EPA, 2001). T he EPA’s duties and functions were authorised by new legislation, entitled the Protection of the Environment Operations Act 1997 (POEO Act). The Act was passed in December 1997 and commenced in July 1999. It incorporated and consolidated provisions from the existing State Pollution Control Act, Clean Air Act, Clean Waters Act, Noise Control Act and Waste Disposal Act. This Act replaced the above separate Acts controlling and licensing air, water and noise pollution and waste management and resulted in a single licence now controlling all aspects of pollution for each premises. Having a single licence reduced the potential to shift pollution between air, water and land.

The POEO Act also allowed previous works approvals or “Pollution Control Approvals” (PCAs), to become integrated with licensing. These PCAs were issued before new works were constructed to permit the installation (or changes to existing plant/equipment) to proceed at licensed premises. Following completion of the approved works, premises would still have to obtain any necessary licence to operate. The POEO Act allowed a single regulatory instrument to be issued, namely an environment protection licence, which covered both construction and operation. The POEO Act was also closely aligned with the Environmental Planning and Assessment Act. This facilitated closer integration of planning (development consent) and environmental protection (environment protection licences). This allowed better identification and consideration of important environmental values and streamlined the time and resources required to process them.

The new environment protection legislation also reflected a commitment to the effective implementation of the principles of “ecologically sustainable development” (ESD). ESD has been described as a central pivot around which all government legislation is increasingly being required to revolve (Bates, 2006). It requires the effective integration of economic and environmental considerations in decision- making processes. An objective of the POEO Act is “to protect, restore and enhance the quality of the environment in NSW, having regard to the need to maintain ecologically sustainable development”. Further clarification on how ecologically sustainable development can be achieved is contained in the Protection of the Environment Administration Act 1991 and includes the following principles and programs: o the precautionary principle—namely, that if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In the application of the precautionary principle, public and private decisions should be guided by:
careful evaluation to avoid, wherever practicable, serious or irreversible damage to the environment;
an assessment of the risk-weighted consequences of various options;
inter-generational equity—namely, that the present generation should ensure that the health, diversity and productivity of the environment are maintained or enhanced for the benefit of future generations;

208
conservation of biological diversity and ecological integrity—namely, that conservation of biological diversity and ecological integrity should be a fundamental consideration;
improved valuation, pricing and incentive mechanisms—namely, that environmental factors should be included in the valuation of assets and services, such as: o polluter pays—that is, those who generate pollution and waste should bear the cost of containment, avoidance or abatement, the users of goods and services should pay prices based on the full life cycle of costs of providing goods and services, including the use of natural resources and assets and the ultimate disposal of any waste; and o environmental goals, having been established, should be pursued in the most cost effective way, by establishing incentive structures, including market mechanisms, that enable those best placed to maximise benefits or minimise costs to develop their own solutions and responses to environmental problems.

The POEO Act also introduced the Load Based Licensing (LBL) Scheme. This scheme is administered by the EPA and applies the ‘polluter pays’ principle. It introduced a strong mechanism to control, reduce and prevent air and water pollution in NSW. The fundamental shift in this new LBL approach was to use pollutant ‘load’ (the tonnes of pollution emitted each year) as the basic unit of measure, rather than pollution concentration (EPA, 2001). The annual licence fee is calculated on the potential environmental impact of that pollution load. The lower the potential for environmental impact, the lower the fee. This approach offers industry a financial incentive to reduce the pollution they produce, and to keep on reducing it. It also encourages industry to invest in pollution reduction in those areas where it will most reduce fees, and so most improve the environment. It shifts the environmental costs of pollution from the community to those who pollute (EPA, 2001).

The EPA issued an Environment Protection Licence for the redeveloped smelter to operate under the POEO Act in 1999. This involved consolidating existing pollution control licences issued under the Clean Air Act 1961 and Clean Waters Act 1970.

209 Around the same time (29 December 1999), the EPA’s intended licence conditions for the redeveloped smelter were formalised on this licence by way of a legal notice. Smelting operations were required to comply with these licence requirements. A copy of this licence is provided on the CD in Appendix 1 of this thesis. In summary, these licence conditions included: • Air emission limits including;  Point Source limits set for sulfur dioxide, sulfur trioxide, metals and solid particles for the acid plant stack, the main stack, the precious metals plant and the concentrate gantry/conveyor de-dusting unit,  Ambient limits for sulfur dioxide at 10 community monitoring stations, and  Ambient lead limits for the Port Kembla Fire Station monitoring station. • Recognition of the three distinct time periods relating to the commissioning period (0-6 months), the start up period (6-12 months) and the on-going operational period (18 months to the future); • Controls on scrap quality and quantity to prevent the generation of offensive odours or air toxics; and • A comprehensive air quality monitoring and reporting network including:  Quarterly and annual reports of monitoring data to the EPA; and  Incident reporting to the EPA and significant incidents additionally to the Department of Health and to the local community in line with a new PKC Community Notification Protocol.

Following a $350 million upgrade, a six month hot commissioning period commenced in February 2000. Whilst there was a significant improvement in the performance of the smelter, especially compared to the previous smelter that operated on the site until 1995, the PKC still had problems complying with its licence. The Company had difficulties with its sulfur dioxide (fugitive) emissions and water discharges during the commissioning period. The EPA initiated prosecution action for some of these licence breaches (EPA, 2000a). The Authority also conducted investigations, issued Penalty Infringement Notices (“on the spot” fines), and required further pollution reduction programs (some costing more than $5 million) to lower sulfur dioxide and noise emissions (EPA, 2002a).

210 When considering the community, government and industry reactions to the problems PKC experienced in the lead up to and during smelter commissioning, it is worthwhile considering several things. The second redevelopment followed a previous upgrade which had not fully met the expected environmental outcomes (for example, in relation to sulfur dioxide) and had introduced new pollution concerns (for example, brown spotting). This raised doubts, in the public’s mind, about the ability of industry and government to adequately and competently control emissions. Around the same time, other major issues also arose that further galvanised community concern about the possible impacts of air pollution from heavy industry in the Illawarra.

In 1993, a report was released into heavy metal contamination of roof dust in Port Kembla (Illawarra Public Health Unit, 1993). In 1997, a Leukaemia cluster of eleven people in the Warrawong area was investigated by the NSW Health (NSW Health Department et al (1997)). A Health Risk Assessment of the Sinter Plant undertaken by BHP in 2000 (Sinclair Knight Merz, 2001) found emissions (due to dioxins and furans) contributed to an increase in cancer risk. This cancer risk was just above acceptable levels, but below unacceptable levels (Sinclair Knight Merz, 2001). Around the same time, BHP advised the EPA and the community in August 2000 that airborne emissions from the Sinter Plant at Port Kembla were found to contain low levels of naturally occurring radioactive elements (Polonium 210 and Lead 210). A report (Australian Nuclear Science and Technology Organisation, 2003) found that this radiation dose was a fraction of the annual public dose limit, and far less than the natural background dose.

In the late 1990s, two high profile courts cases were brought forward against the State government by a long time resident of Port Kembla, Ms Helen Hamilton. These cases even featured on national TV (See “Every Breath You Take” on Australian Story. ABC Television, 3 June 1999). These cases attracted considerable political and media attention. They are outlined below because they are considered important in understanding the social history of the smelter, pollution control and the local environment.

In May 1997, the NSW Land & Environment Court began hearing a case put forward by Ms Hamilton, challenging the development consent for the new smelter, granted

211 by the Minister for Planning in 1996 (Eklund and Murray, 2000; McPhillips, 2002; and Arcioni & Mitchell, 2005). The basis of this case goes back to when the original development application was lodged by Southern Copper with Department of Planning in 1994 for the upgrade and expansion of the smelter (Dames & Moore, 1994).

Generally speaking, a development consent may be challenged under the environmental planning legislation in one of two ways: by judicial review and merits appeal; by persons to whom the legislation gives rights (Bates, 2006). Judicial review is a challenge to the legality of the decision, a form of civil enforcement. It examines how, as a matter of law, a decision was reached – not, from a policy or judgemental point of view, whether that decision was bad, good or indifferent (Bates, 2006). A merits appeal concentrates on the quality of the decision, not its legality, and the wisdom, propriety or substantial fairness of it (Bates, 2006). The Hamilton case was based on a legal challenge that centred on a claim that the Company had not properly complied with the requirements of the planning legislation in regard to the original 1994 development application. It was a challenge to the legality of the decision to grant development consent (judicial review), not a merit based appeal. Hamilton argued that the level of public consultation on the 1994 development application (and associated EIS and COI) was grossly inadequate and not satisfied statutory planning requirements (Eklund and Murray, 2000; McPhillps, 2002; Arcioni and Mitchell, 2005). The court case, however, ended quickly, when the NSW Government passed the Port Kembla Development (Special Provisions) Act 1997 on 29 May 1997 (Hansard, 1997). The Bill legitimised both the development consent and subsequent modifications (Eklund and Murray, 2000; McPhillps, 2002).

The decision generated public outrage and claims that environmental justice had been denied (McPhillps 2002; Arcioni and Mitchell, 2005). It even prompted the renowned Australian poet Bruce Dawe to write a poem personally for Helen Hamilton entitled “Port Kembla Blues” (Tertangala, 2001). The Government’s decision was firm on the fact that it was a not a merit based appeal but rather a legal challenge that was considered minor and technical in nature. It claimed that nothing would have been gained from going through the court process, even if the court upheld the challenge

212 (Hansard, 1997). Ultimately it was about “Securing jobs, investment and growth, not only for the Illawarra, but also the State and the Nation” (Hansard, 1997).

Following the above unsuccessful legal challenge, a second court case was brought forward by Ms Hamilton against the State, that again had close links to the copper smelter at Port Kembla. This court case was about the information the EPA provides to the public and not about the merits of the environment protection decision.

In the course of the preparation of the above legal challenge, the files of the EPA were subpoenaed by the legal team acting for Ms Hamilton to access documents relating to the smelter. This included EPA documents relating to the development application lodged by SCL, associated Commission of Inquiry and the Departments granting of the Pollution Control Licence. The documents were, however, subject to legal undertakings, that the contents would remain confidential and only be used by Hamilton’s solicitors for the conduct of these proceedings.

In June 1997, Ms Hamilton sought to have the subpoenaed EPA documents released under the Freedom of Information (FOI) Act. Several hundreds of documents were released by the EPA, however, certain documents (about 250) were either wholly or partially exempted under the FOI Act from disclosure by the EPA. The EPA stated disclosure of these internal working documents would impair the integrity of the decision making process within government by inhibiting the frank and open exchange of views prior to final decision making.

In mid 1998, an appeal was lodged by Helen Hamilton in the District Court of NSW under Section 55 of the Freedom of Information Act against the refusal of the EPA to release these withheld documents. In August 1998 the Court determined that of the 250 documents withheld, about 230 should be released. The remaining documents were still exempted from disclosure on the grounds of legal or commercial in confidence privilege and were never released. This case attracted considerable political and media attention (Illawarra Mercury, Oct 3 1998).

Adding to the above already complex situation, in mid 2002, an incident occurred at the anode furnace at the smelter involving a spill of molten copper and several steam

213 explosions. The incident attracted considerable media interest. The Minister for Planning directed that a whole of government Task Force, coordinated by NSW Planning, including the EPA and NSW Workcover be established. This Task Force investigated the environmental and safety performance of the smelter and measures to improve its performance (Planning NSW, 2002).

The Task Force found that the company had not met all of its environmental performance conditions. In relation to sulfur dioxide there had been exceedances of the following EPA licence requirements: • Sulfur dioxide mass discharge limits. • Acid plant stack sulfur dioxide concentration limits. • Main stack sulfur dioxide limits, and • Ambient sulfur dioxide limit (50 pphm (10 minute average)). Whilst exceedances of the WHO (10 minute) goal did occur, the company did not actually breach its licence conditions in terms of the number of permissible exceedances. Other areas where the environmental performance of the smelter did not meet prescribed limits included noise and water treatment discharge quality (for arsenic, selenium and pH). In addition, “brown spotting” fallout continued to occur, though mostly not to the same magnitude as during the last smelter redevelopment. The audit report (Planning NSW, 2002) provides an excellent overview of these compliance issues.

Considerable attention was focussed on the operation of the acid plant. It was found that whilst it had sufficient capacity to treat sulfur dioxide from normal smelter operations, it had limited capacity to treat excessive emissions that could result from smelting operations. It was identified as “the only line of defence” against the release of sulfur dioxide into the atmosphere. For example, if the acid plant ceased operation immediately, the Noranda Reactor could still continue to produce sulfur dioxide bearing gases for about 5 minutes and the MIC for about 20 minutes before these furnaces could be rolled out. During the period the acid plant is offline, the only option was for PKC to vent the process gases via the baghouse and main stack. The audit found that the vast majority of incidents were due to acid plant upsets. They centred around process control problems such as tripping blowers, as well as

214 maintenance. These maintenance issues included ceasing dampers and valves improperly directing gases for treatment, as well as general corrosion and breakdown of hardware, such as piping joints that caused leaks or fugitive emissions. It was these fugitive emissions from the acid plant that tended to result in exceedances of limits specified for ground level concentrations of sulfur dioxide measured at Port Kembla Fire Station and Saint Patrick’s School.

Upon commissioning of the redeveloped smelter in 2000 and the fugitive emission episodes that followed, local residents had lobbied for a “community warning system” to alert them of elevated sulfur dioxide levels. Ideas like green and red lights on the main stack were suggested, but resisted by PKC. This issue was again raised during the audit (Planning NSW, 2002). The audit concluded that provision of a generalised warning system would create problems that outweighed the community benefit. This included the ability of the system to discriminate between various types and levels of emergency and specify the most appropriate response in each case. Instead the company refined its community notification protocol where potentially affected persons would be contacted by PKC. It is worthwhile noting, however, PKC did operate a warning system at Saint Patrick’s School that was based around coloured lights in its last years of operation (2002 to 2003). These alerted the school that elevated levels of sulfur dioxide were being detected by the sulfur dioxide monitor located at the school, and children were ushered into classrooms until conditions improved (Personal observations by author as an EPA officer).

The performance of the sulfur dioxide monitors and their locations were also debated by the community. A concern was that the monitors only recorded up to 100 pphm and that there had been occasions (albeit rare) at the Fire Station and Saint Patrick’s School where this range had been exceeded. Calls for 2 minute readings to be provided instead of 10 minute averages were also being pursued.

Whilst the audit found that the vast majority of non-compliances with stack sulfur dioxide limits (concentration and mass emission rate) resulted from the operation of the acid plant, these exceedances did not tend to result in impacts offsite or in the local community. The emissions did, however, reflect inherent problems in the design and operation of the acid plant.

215

The Department of Planning secured the recommendations (action plans) of the audit by translating them into court enforceable undertakings with agreed timeframes for completion, that the company had to comply with (Planning NSW, 2002). In August 2003, however, all smelting operations ceased at the PKC site. The company cited economic losses in recent years from a weak international copper market as the main cause of the shutdown (Illawarra Mercury 2/8/03). Prior to its closure, the EPA successfully prosecuted PKC on at least three occasions for several air and water pollution incidents (EPA, 2000a to 2004a). This included 5 breaches of sulfur dioxide licence requirements (both ambient and point source limits).

In September 2003, the NSW government formed the Department of Environment and Conservation (DEC) from the consolidation and incorporation of a number of separate agencies including the EPA, National Parks and Wildlife Service, Botanic Gardens Trust and Resource NSW. The DEC also had strong linkages with the Sydney Catchment Authority (Personal observations by author as an EPA officer). In April 2007, the NSW government announced the creation of the Department of Environment and Climate Change (DECC), of which the EPA remains a part. The new department brought together a range of conservation and natural resources science and programs, including native vegetation, biodiversity and environmental water recovery to provide an integrated approach to natural resource management (DECC, 2007). The EPA continues to be responsible for administering the POEO Act and statutory functions and powers in this Act. For example, environment protection licences, continue to be exercised in the name of the EPA.

The smelter site continues to hold and be regulated by an EPA Environment Protection Licence (Number 1753). Despite being placed in care and maintenance, PKC continues to actively seek new investors to enable the recommencement of operations at the site.

3.6.3 Ambient Atmospheric Sulfur Dioxide Concentrations

During the period 1996 to 2006 sulfur dioxide was monitored at 14 locations in the Port Kembla/Wollongong. A summary of the annual average sulfur dioxide levels at

216 these locations is given in Table 21. The locations of these monitors and the geographical zones are shown in Figures 2 and 3.

Geographical Location YEAR Annual Zone 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 Average in zone for all years Port Kembla Port Kembla - - - - 0.34 0.68 0.68 0.50 - - - 0.28 Township Fire Station St Patrick’s - - - 0.06 0.25 0.20 0.24 0.20 - - - School Old Port - - - - 0.10 0.07 0.15 0.20 - - - Kembla Primary School Central Primbee - - - - 0.17 0.05 0.10 0.10 - - - 0.12 Public School Port Kembla - - - - 0.31 0.22 0.28 0.19 - - - Hospital Warrawong - - - - 0.09 0.11 0.15 0.18 - - - BHC EPA - - 0.10 0.10 0.12 0.15 0.14 0.12 0.10 0.10 - Warrawong Steel Haven - - - - 0.22 0.19 0.23 0.30 - - - Wollongong Coniston - - - - 0.11 0.13 0.18 0.19 - - - 0.13 City (Water Board Stores) Wollongong - - - - 0.18 0.05 0.06 0.14 - - - Showground (Harbour St) EPA - 0.14 0.17 0.15 0.16 0.12 0.14 0.11 0.10 0.10 0.10 Wollongong Outer Windang - - - - 0.13 0.04 0.08 0.10 - - - 0.10 Catholic Church EPA Kembla 0.18 0.06 ------Grange EPA Albion 0.12 0.12 0.09 0.09 0.13 0.11 0.13 0.08 0.09 - 0.08 Park

Table 21 Summary of annual average sulfur dioxide levels for Wollongong/Port Kembla area during 1996 to 2006. All values in pphm.

Table 21 shows the annual average levels of sulfur dioxide from 1996 to 2006 across all zones was very low, even with the smelter operating between 2000 to 2003. The smelter shutdowns before and after this operational period allow the relative contribution of the smelter to be assessed. Even with the smelter operating, annual averages are significantly lower than previous study periods and well below the WHO goal (1 year) of 1.8 pphm. This is a direct result of major reductions in stack and fugitive emissions from the smelter, following the second redevelopment.

217

The highest annual averages of sulfur dioxide (up to 0.68 pphm) were recorded in the Port Kembla Township Zone, in the immediate vicinity of the smelter. These annual averages, however, are still considerably lower than previous values recorded in this zone. These can be attributed to fugitive emissions from the smelter. By far the greatest reason for the observed reduction is the replacement of the Pierce Smith converters with the MIC furnace. This eliminated batch wise operations on the smelter aisle and fugitives inherently associated with Pierce Smith converter operation. The annual averages in the Central, Wollongong City and Outer zones are also very low and also less than previous values recorded in this zone. They tend to decrease as the distance from the smelter increase. This indicates, in particular in the Central zone, that there has been a dramatic reduction in stack emissions of sulfur dioxide.

Figures 95 to 119 summarise the monthly average, maximum hourly and maximum 10 minute sulfur dioxide data for each monitor during this study period. As seen in the annual average data, they show very low sulfur dioxide levels during 1996 to 2006 across all monitoring stations, even with the smelter operating between 2000 to 2003.

1.6

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 95 Monthly Average sulfur dioxide concentrations for Port Kembla Fire Station, 2000 to 2003 (values in pphm)

218 35

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Max 1hr (pphm) Figure 96 Maximum 1 hour sulfur dioxide concentrations for Port Kembla Fire Station, 2000 to 2003 (values in pphm)

140

120

100

80 pphm 60

40

20

0 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Sep-97 Sep-98 Sep-99 Sep-00 Sep-01 Sep-02 Sep-03 Sep-04 Sep-05 Sep-06 May-97 May-98 May-99 May-00 May-01 May-02 May-03 May-04 May-05 May-06 Month/Year Max 10min (pphm) Figure 97 Maximum 10 minute sulfur dioxide concentrations for Port Kembla Fire Station, 2000 to 2003 (values in pphm)

219 0.8

0.7

0.6

0.5

0.4 pphm

0.3

0.2

0.1

0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 98 Monthly Average sulfur dioxide concentrations for Saint Patrick’s School Port Kembla, 1989 to 2003 (values in pphm)

25

20

15 pphm 10

5

0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year

Max 1hr (pphm) Figure 99 Maximum 1 hour sulfur dioxide concentrations for Saint Patricks School Port Kembla, 1989 to 2003 (values in pphm)

220 60

50

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30 pphm

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10

0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Max 10min (pphm) Figure 100 Maximum 10 minute sulfur dioxide concentrations for Saint Patricks School Port Kembla, 1989 to 2003 (values in pphm)

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 101 Monthly Average sulfur dioxide concentrations for Old Port Kembla Primary School, 2000 to 2003 (values in pphm)

221 50

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35

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25 pphm

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Max 1hr (pphm) Max 10min (pphm) Figure 102 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Old Port Kembla Primary School, 2000 to 2003 (values in pphm)

0.35

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0.2 pphm 0.15

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 103 Monthly Average sulfur dioxide concentrations for Primbee Public School, 2000 to 2003 (values in pphm)

222 10

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8

7

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5 pphm

4

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Apr-98 Apr-99 Apr-00 Apr-01 Apr-02 Apr-03 Apr-04 Apr-05 Apr-06 Jan-97 Oct-97 Jan-98 Oct-98 Jan-99 Oct-99 Jan-00 Oct-00 Jan-01 Oct-01 Jan-02 Oct-02 Jan-03 Oct-03 Jan-04 Oct-04 Jan-05 Oct-05 Jan-06 Oct-06 Month/Year Max 1hr (pphm) Max 10min (pphm) Figure 104 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Primbee Public School, 2000 to 2003 (values in pphm)

0.7

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Apr-98 Apr-99 Apr-00 Apr-01 Apr-02 Apr-03 Apr-04 Apr-05 Apr-06 Jan-97 Oct-97 Jan-98 Oct-98 Jan-99 Oct-99 Jan-00 Oct-00 Jan-01 Oct-01 Jan-02 Oct-02 Jan-03 Oct-03 Jan-04 Oct-04 Jan-05 Oct-05 Jan-06 Oct-06 Month/Year

Monthly Average (pphm) Figure 105 Monthly Average sulfur dioxide concentrations for Port Kembla Hospital, Port Kembla, 2000 to 2003 (values in pphm)

223 30

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Apr-98 Apr-99 Apr-00 Apr-01 Apr-02 Apr-03 Apr-04 Apr-05 Apr-06 Jan-97 Oct-97 Jan-98 Oct-98 Jan-99 Oct-99 Jan-00 Oct-00 Jan-01 Oct-01 Jan-02 Oct-02 Jan-03 Oct-03 Jan-04 Oct-04 Jan-05 Oct-05 Jan-06 Oct-06 Month/Year Max 10min (pphm) Max 1hr (pphm) Figure 106 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Port Kembla Hospital, 2000 to 2003 (values in pphm)

0.35

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0 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Sep-97 Sep-98 Sep-99 Sep-00 Sep-01 Sep-02 Sep-03 Sep-04 Sep-05 Sep-06 May-97 May-98 May-99 May-00 May-01 May-02 May-03 May-04 May-05 May-06 Month/Year Monthly Average (pphm) Figure 107 Monthly Average sulfur dioxide concentrations for Warrawong Baby Health Centre, 2000 to 2003 (values in pphm)

224 60

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Apr-98 Apr-99 Apr-00 Apr-01 Apr-02 Apr-03 Apr-04 Apr-05 Apr-06 Jan-97 Oct-97 Jan-98 Oct-98 Jan-99 Oct-99 Jan-00 Oct-00 Jan-01 Oct-01 Jan-02 Oct-02 Jan-03 Oct-03 Jan-04 Oct-04 Jan-05 Oct-05 Jan-06 Oct-06 Month/Year

Max 1hr (pphm) Max 10min (pphm) Figure 108 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Warrawong Baby Health Centre, 2000 to 2003 (values in pphm)

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 109 Monthly Average sulfur dioxide concentrations for Steelhaven, 2000 to 2003 (values in pphm)

225 35

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Apr-98 Apr-99 Apr-00 Apr-01 Apr-02 Apr-03 Apr-04 Apr-05 Apr-06 Jan-97 Oct-97 Jan-98 Oct-98 Jan-99 Oct-99 Jan-00 Oct-00 Jan-01 Oct-01 Jan-02 Oct-02 Jan-03 Oct-03 Jan-04 Oct-04 Jan-05 Oct-05 Jan-06 Oct-06 Month/Year Max 1hr (pphm) Max 10min (pphm) Figure 110 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Steelhaven, 2000 to 2003 (values in pphm)

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 111 Monthly Average sulfur dioxide concentrations for Coniston, 2000 to 2003 (values in pphm)

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Max 10min (pphm) Max 1hr (pphm) Figure 112 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Coniston, 2000 to 2003 (values in pphm)

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 113 Monthly Average sulfur dioxide concentrations for Wollongong Showground, 2000 to 2003 (values in pphm)

227 8

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Max 1hr (pphm) Max 10min (pphm) Figure 114 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Wollongong Showground, 2000 to 2003 (values in pphm)

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Monthly Average (pphm) Figure 115 Monthly Average sulfur dioxide concentrations for Windang, 2000 to 2003 (values in pphm)

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0 Jul-97 Jul-98 Jul-99 Jul-00 Jul-01 Jul-02 Jul-03 Jul-04 Jul-05 Jul-06 Apr-97 Oct-97 Apr-98 Oct-98 Apr-99 Oct-99 Apr-00 Oct-00 Apr-01 Oct-01 Apr-02 Oct-02 Apr-03 Oct-03 Apr-04 Oct-04 Apr-05 Oct-05 Apr-06 Oct-06 Jan-97 Jan-98 Jan-99 Jan-00 Jan-01 Jan-02 Jan-03 Jan-04 Jan-05 Jan-06 Month/Year Max 1hr (pphm) Max 10min (pphm) Figure 116 Maximum 1 hour and Maximum 10 minute sulfur dioxide concentrations for Windang, 2000 to 2003 (values in pphm)

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0 Jan-06 Jan-05 Jan-04 Jan-03 Jan-02 Jan-01 Jan-00 Jan-99 Jan-98 Jan-97 Jan-96 Sep-06 Sep-05 Sep-04 Sep-03 Sep-02 Sep-01 Sep-00 Sep-99 Sep-98 Sep-97 Sep-96 May-06 May-05 May-04 May-03 May-02 May-01 May-00 May-99 May-98 May-97 May-96 Month/Year Warrawong (pphm) Wollongong (pphm) Kembla Grange (pphm) Albion Park (pphm) Figure 117 Monthly Average sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1996 to 2006 (values in pphm)

229 1.6

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7 7 8 2 2 3 -96 -96 -9 -9 -01 -01 -0 -06 -06 y-96 y-97 n-99 n-00 p-00 y-01 y-02 y-03 n-04 p-04 n-05 p-05 y-06 an ep an an-9 a a e an an-0 an-0 a a e a e an J Ma S J Ma Sep J May-98Sep-98 J May-99Sep-99 J May-00S J Ma Sep J Ma Sep J M Sep-03 J May-04S J May-05S J Ma Sep Month/Year

Warrawong (pphm) Wollongong (pphm) Kembla Grange (pphm) Albion Park (pphm)

Figure 118 Highest Daily sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1996 to 2006 (values in pphm)

18

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0

7 7 8 2 2 3 -96 -96 -9 -9 -01 -01 -0 -06 -06 y-96 y-97 n-99 n-00 p-00 y-01 y-02 y-03 n-04 p-04 n-05 p-05 y-06 an ep an an-9 a a e an an-0 an-0 a a e a e an J Ma S J Ma Sep J May-98Sep-98 J May-99Sep-99 J May-00S J Ma Sep J Ma Sep J M Sep-03 J May-04S J May-05S J Ma Sep Month/Year Warrawong (pphm) Wollongong (pphm) Kembla Grange (pphm) Albion Park (pphm) Figure 119 Maximum 1 hour sulfur dioxide concentrations for EPA MAQS at Kembla Grange, Albion Park, Warrawong and Wollongong, 1996 to 2006 (values in pphm)

230 Following the second redevelopment, the NHMRC goal of 20 pphm (1hr) and WHO goal of 17.5 pphm (10 min) was complied with in all zones, except at monitors immediately adjacent to the smelter in the Port Kembla Township zone (Port Kembla Fire Station, St Patricks School and Old Port Kembla Primary School). Here the WHO (10 minute) and NHMRC (1hr) goals were at times exceeded. Values of up to 1.4 pphm (monthly average), 31 (highest hourly) and 123 pphm (maximum 10 minute) were recorded in this zone. These are considerably less than the values of up to 36 pphm (monthly average), 750 pphm (maximum hourly) and 3000 (maximum 10 minute) recorded during the first redevelopment. With the closure of the smelter in 2003, the WHO 10 minute goal for sulfur dioxide was finally met at these monitoring sites.

Figures 95 to 119 confirm that even whilst the smelter operated during the second redevelopment (2000 to 2003), there was a marked reduction in monthly average, maximum hourly and maximum 10 minute values in the Central zone, compared to previous study period. For example, values of up 0.6 pphm (monthly average), 16 pphm (maximum hourly) and 48 pphm (maximum 10 minute) were recorded. These are considerably less than the values of up to 8.2 pphm (monthly average), 81 pphm (maximum hourly) and 300 (maximum 10 minute) recorded during the first redevelopment. This is because over 95% of the sulfur dioxide generated at the smelter had been captured in the acid plants resulting in a significant reduction in stack sulfur dioxide emissions.

Examination of the maximum hourly and maximum 10 minutes graphs also indicates that the ratio between the maximum 10 minute and the corresponding 1 hour value also fell considerably, especially in the Port Kembla Township and Central zone. This is because Pierce Smith converters were no longer used at the smelter (following their replacement by the MIC) eliminating batch-type operations and resulting emissions.

In the Wollongong City and Outer zones, ambient sulfur dioxide levels also show a significant reduction. Annual averages ranged from 0.19 to 0.10 pphm (zone average 0.13 pphm) and 0.18 to 0.08 pphm (zone average 0.10 pphm) respectively, even with the smelter operating. They are less than the annual average values of up to 0.75

231 pphm (Wollongong City zone) and 0.42 pphm (Outer Zone) recorded during the last study period.

The highest hourly and maximum 10 minute values recorded in the Wollongong City zone and Outer zone also show a reduction, even with the smelter operating. In the Wollongong City zone, values of up to 15 pphm (highest hourly) and 24 pphm (maximum 10 minute) occurred. In the previous study period, values of up 70 pphm (highest hourly) and 357 pphm (maximum 10 minute values) were recorded. In the Outer zone, values of up to 5.5 pphm (highest hourly) and 6.4 (maximum 10 minute values) occurred. In the previous study period, values of up 38 pphm (highest hourly) and 175 pphm (maximum 10 minute values) were recorded.

The overall result of the major changes to smelting operations during the second redevelopment is a progression from intermittent batch –type to more continuous operation and increasing sulfur capture. The net effect is a major reduction in overall sulfur dioxide emissions to air from the smelter (both stack and fugitive). The annual load of sulfur dioxide emitted by the smelter was reported to range from 1300 to 2700 tonnes per annum whilst it operated between 2000 to 2003. The reduction in the ambient sulfur dioxide levels during this study period clearly reflects this reduction in annual load from the smelter.

Smelter closure in 2003 provided another unique opportunity to further investigate the relative contribution of other potential sulfur dioxide sources in the area, for example the Sinter Plant.

During 2003 to 2006, the levels of sulfur dioxide measured in all zones was very low. Values of up to 0.22 pphm (monthly average), 1.5 pphm (highest daily) and 8.8 pphm (maximum hourly) were recorded. A summer high/winter low seasonality to the maximum daily and hourly readings is apparent at the Albion Park monitor (see Figures 118 and 119). Maximum hourly readings also tended to be slightly higher at the Warrawong monitor, compared to both the Wollongong and Albion Park monitor (Figure 119). These findings continue to support the view that a local source of sulfur dioxide, such as the Sinter Plant at Port Kembla steelworks, was still making a small, but detectable contribution to measured ambient sulfur dioxide concentrations.

232

3.6.4 Summary of information 1996 to 2006

Following the shutdown of the smelter in 1995, a second redevelopment of the smelter was commissioned in 2000. This redevelopment not only increased smelter production but also resulted in fundamental changes to its design and operation, which had direct effects on sulfur dioxide emissions and their control. This upgrade followed a major Commission of Inquiry under the environmental planning legislation. The development consent was also the subject of an unsuccessful legal challenge by a Port Kembla resident.

This second upgrade was prompted by several major Pollution Reduction Programs attached to the environment protection licence for the smelter by the EPA in 1993. These PRPs addressed significant environmental concerns associated with the operation of the previous smelter, including stack and fugitive emissions of sulfur dioxide. Ensuring the smelter operated to comply with the WHO air quality goal (10 minute) for sulfur dioxide was the primary goal. This was achieved by replacing the Noranda/Pierce Smith Converting system with a Noranda/Mitsubishi Continuous Converting furnace combination. This hybrid, allowed even greater sulfur capture, with up to 95% of the sulfur dioxide now generated converted to sulfuric acid. The overall design load of sulfur dioxide emitted by the smelter was now reduced to less than 6,300 per year. In practice, however, the load of sulfur dioxide emitted was only around 3000 tonnes per year, because the full copper production level of 120,000 tonnes per year was never fully realised.

Following this redevelopment there was a major reduction in sulfur dioxide levels in all zones, even with the smelter operating between 2000 and 2003. The highest levels continued to occur in the Port Kembla Township zone. Here values of up to 0.68 pphm (annual average), 27 pphm (highest hourly) and 123 pphm (highest 10 minute) still occurred. This was due to continued fugitive emissions from the smelter. These emissions were, however, significantly lower than previous operations at the smelter. In areas traditionally affected by stack emissions, for example, the Central Zone, major decreases were also observed in ambient sulfur dioxide levels, compared to previous smelter. Here values of up to 0.31 pphm (annual average), 16 pphm (highest hourly) and 48 pphm (maximum 10 minute) were recorded. In the Wollongong City

233 values of up to 0.19 pphm (annual average), 15 pphm (highest hourly) and 24 pphm (maximum 10 minute) were recorded. Values of up to 0.18 pphm (annual average), 5.5 pphm (highest hourly) and 6.4 pphm (maximum 10 minute) were recorded in the Outer zone.

A further shutdown of the smelter from 2003 allowed ambient levels of sulfur dioxide to be measured in the absence of smelter operations. Annual averages in the Central, Wollongong and Outer zones were less than 0.10 pphm and maximum hourly readings less than 9 pphm. Some monitors, for example, Albion Park, suggest that the Sinter Plant at Port Kembla steelworks may still be making a small, but detectable contribution to measured ambient sulfur dioxide concentrations. The smelter continues to remain idle and under “care and maintenance” to the present day (2007).

3.7 General Discussion

Ambient atmospheric levels of sulfur dioxide in the Wollongong/Port Kembla area have been reviewed in this chapter, for four time periods; 1907 to 1965, 1966 to 1988, 1989 to 1995 and 1996 to 2006; together with information on the emission and control of sulfur dioxide and government regulation. The review has shown that these time periods coincide with major step changes in the design, operation and regulation of the smelter that have had major influences on observed sulfur dioxide levels.

Discussion of the first period, between 1907 to 1965, examined the decision to build a copper smelter at Port Kembla, its early days of its operation following its commissioning in 1908, leading up to the installation of the 198 metre stack in 1965. During this period the smelter first relied on Reverberatory Furnaces and later a Sinter Plant/Blast Furnace for smelting. Pierce Smith converters were used to convert the matte produced to blister copper. The resulting sulfur dioxide emissions were simply vented to atmosphere by a tall stack, with no sulfur capture. The period also saw major government reforms in the regulation and control of air pollution. At a local level, intensive studies into ambient atmospheric levels of sulfur dioxide at Port Kembla and their effects on the health of residents were undertaken in the late 1950s/early 1960s. At a state level, the Clean Air Act was introduced in 1961. This Act introduced a licensing system which defined how industry should be operated to

234 minimise pollution. It was first administered by the Department of Health. The above studies and new legislation were major drivers for improvements in the control of sulfur dioxide emissions from the smelter. They prompted the replacement of the original 70 metre high stack with the 198 metre high stack in 1965.

The second period, between 1966 and 1988, covers the operation of the smelter following the commissioning of the new 198 metre stack, until just before the first major redevelopment of the smelter in 1989. During this period the smelter continued to rely on a Sinter Plant/Blast Furnace for smelting and Pierce Smith converters for converting. Sulfur dioxide control principally relied on dilution and dispersion from the 198 metre stack, with no sulfur capture. Some attempts were made to control sulfur dioxide emissions through air quality management systems, which reduced smelter production when weather conditions were conducive to pollution episodes, but these did not solve the problem. The smelter continued to be regulated under a pollution control licence administered at first by the Department of Health and later the SPCC.

The third period, between 1989 and 1995, saw the first major redevelopment of the smelter. This was prompted by growing concerns from the community about air pollution, in particular, sulfur dioxide and lead. It resulted in the installation of a Noranda Furnace which replaced the Sinter Plant/Blast Furnace. Pierce Smith converters continued to be used for converting. For the first time, sulfur capture was provided in a new acid plant, with up to 75% of the sulfur dioxide generated to be converted to sulfuric acid. This environmental upgrade did not, however, fully meet the expectations of the community and government. In response, in 1993 the EPA issued legal directions requiring major pollution reduction programs to address pollution concerns, in particular sulfur dioxide emissions (both stack and fugitive). The smelter, however, closed down in 1995 for economic reasons.

The fourth period, between 1996 to 2006, saw a second major environmental upgrade and expansion of the smelter. This resulted in the installation of a Mitsuibishi Continuous Converter (MIC) to replace the Pierce Smith Converters. It commenced operation in 2000. This Noranda/MIC hybrid was unique and allowed up to 95% of the sulfur dioxide to be captured in a second acid plant. The smelter, however, closed

235 down in 2003 for economic reasons and has remained in “care and maintenance”. During this period the smelter continued to be regulated under a licence administered by the EPA.

Systematic air pollution monitoring of sulfur dioxide was first undertaken in the Wollongong/Port Kembla area between 1957 and 1961. It recommenced in 1970 and whilst the number and locations of monitors has varied, it has continued to the present day. A review of this monitoring data from 1957 to 2006 has shown that there has been an overall reduction in the ambient sulfur dioxide levels in the Wollongong/Port Kembla area.

To investigate these trends in ambient sulfur dioxide levels over time, the annual average sulfur dioxide concentrations for each time period were grouped into four geographical zones; Port Kembla Township, Central, Wollongong City and Outer. These geographical zones are shown in Figure 2 and 3. The annual mean concentrations for sites in each zone were then averaged for the corresponding time period, as shown in Table 22.

Annual Averages (pphm) Years Port Kembla Central Wollongong Outer Township City 1958 to 1960 2.5 (n=6A) 0.40 (n=1) nd 0.23 (n=2) 1970 to 1979 2.5 (n=1) 0.70 (n=1) 0.69 (n=2) 0.66 (n=1) 1980 to 1988 nd 0.40 (n=2) 0.55 (n=1) 0.84 (n=1) 1989 to 1995 0.82 (n=2) 0.84 (n=7) 0.48 (n=4) 0.27 (n=3) 1996 to 1999 B 0.06 (n=1) 0.10 (n=1) 0.15 (n=1) 0.11 (n=2) 2000 to 2003 0.30 (n=3) 0.17 (n=5) 0.13 (n=3) 0.10 (n=2) 2004 to 2006 B nd 0.10 (n=1) 0.10 (n=1) 0.09 (n=1)

Notes: A n = number of sites averaged. B Smelter closed and under care and maintenance during this time period.

Table 22 Changes in Annual Average Sulfur dioxide in the four geographical zones between 1958 and 2006.

236

Whilst the numbers of sites averaged were at times limited, several features of the data in Table 22 should be noted: • Annual average concentrations of sulfur dioxide in all zones show an overall downward trend from 1957 to 2006; • The highest annual average concentrations of sulfur dioxide occurred in the Port Kembla Township in the late 1950s; • The greatest reductions in sulfur dioxide levels occur in the Port Kembla Township zone and they decline rapidly from 1989 onwards, following the second smelter redevelopment; • Concentrations in the Central zone appear to increase in the 1970s, decrease in the 1980s, increase again in the early 1990s and then decrease again; • Concentrations in the Outer zone appear to increase in the 1980s and then decrease again, and • Present day concentrations are similar at all locations and well below the WHO air quality goal of 1.8 pphm (annual mean).

The above overall reduction in annual average sulfur dioxide levels is further demonstrated in Figure 120, for the Port Kembla Fire Station monitor.

6

5

4

3 pphm

2

1

0 Sep-57 Sep-58 Sep-59 Sep-60 Sep-61 Sep-62 Sep-63 Sep-64 Sep-65 Sep-66 Sep-67 Sep-68 Sep-69 Sep-70 Sep-71 Sep-72 Sep-73 Sep-74 Sep-75 Sep-76 Sep-77 Sep-78 Sep-79 Sep-80 Sep-81 Sep-82 Sep-83 Sep-84 Sep-85 Sep-86 Sep-87 Sep-88 Sep-89 Sep-90 Sep-91 Sep-92 Sep-93 Sep-94 Sep-95 Sep-96 Sep-97 Sep-98 Sep-99 Sep-00 Sep-01 Sep-02 Sep-03 Sep-04 Month/Year

yearly average (pphm)

Figure 120 Annual average sulfur dioxide concentrations for Port Kembla Fire Station from 1957 to 2003 (values in pphm)

237 Figure 120 shows the decrease in annual average sulfur dioxide levels for the Port Kembla Fire Station monitor (in the Port Kembla Township zone) between 1957 and 2003. This monitor has the longest record of sulfur dioxide monitoring in the Wollongong/Port Kembla area.

The principal reason for the overall decline in the average annual sulfur dioxide concentrations is a general reduction in the annual load of sulfur dioxide emitted by the copper smelter at Port Kembla. This load has decreased from around 30,000 tonnes per annum in the 1960s, to less than 3,000 in early 2000. This smelter emission signature is further confirmed by the significant reduction in annual average sulfur dioxide levels across all zones between 1989 to 1995 (smelter operating) and 1996 to 1999 (smelter closed). These reductions in the load of sulfur dioxide can be attributed to improvements in smelting technology and pollution abatement at the smelter. This has resulted in a progression from batch – type (Sinter Plant/Blast Furnace/Pierce Smith Converters) to more continuous operation (Noranda Reactor/MIC) and increasing sulfur capture in acid plants. The net effect is a major reduction in overall sulfur dioxide emissions to air from the smelter (both stack and fugitive).

The increase in annual concentrations in the Central zone in the 1970s can be explained by temporary increases in the use of imported fuel oil that contained a higher sulfur content. The increase in the early 1990s is likely to have resulted from increases in the load of sulfur dioxide from the smelter that occurred following the first smelter redevelopment. This redevelopment did not fully meet environmental expectations and resulted in an increase in the load of sulfur dioxide emitted of up to 52,000 tonnes per year in 1993. These issues were subsequently resolved following the second redevelopment of the smelter in 2000.

The increase in annual concentrations in the Outer zone in the 1980s may be due to emissions from the Tallawarra Power station which operated until the late 1980s. It is difficult, however, to draw firm conclusions due to the limited data set available.

Further demonstration of these patterns of reduction from 1957 to 2006 can be found in the shorter term monitoring data in each of the geographical zones studied.

238

In the Port Kembla Township zone, concentrations of 1 to 5 ppm were detected, often for several hours during the late 1950s/early 1960s. The highest reading recorded was 13.5 ppm (30 min averaging period). Annual averages of up to 5.2 pphm were recorded in the early 1970s. Values of up to 36 pphm (monthly average) and 750 (highest hourly) and 2926 pphm (maximum 10 minute) were recorded in the late 1980s/early 1990s. By the period 1996 to 2006, sulfur dioxide levels had fallen to less than 0.68 pphm (annual average), 1.4 pphm (monthly average), 31 pphm (highest hourly) and 123 pphm (maximum 10 minute), even when the smelter operated. These patterns in ambient sulfur dioxide levels are further demonstrated in Figure 121. This figure summarises the monthly average sulfur dioxide levels for the Port Kembla Fire Station monitor between 1957 and 2003.

40

35

30

25

20 pphm

15

10

5

0 Sep-57 Sep-58 Sep-59 Sep-60 Sep-61 Sep-62 Sep-63 Sep-64 Sep-65 Sep-66 Sep-67 Sep-68 Sep-69 Sep-70 Sep-71 Sep-72 Sep-73 Sep-74 Sep-75 Sep-76 Sep-77 Sep-78 Sep-79 Sep-80 Sep-81 Sep-82 Sep-83 Sep-84 Sep-85 Sep-86 Sep-87 Sep-88 Sep-89 Sep-90 Sep-91 Sep-92 Sep-93 Sep-94 Sep-95 Sep-96 Sep-97 Sep-98 Sep-99 Sep-00 Sep-01 Sep-02 Sep-03 Sep-04 Sep-05 Month/Year Monthly Average (pphm) Figure 121 Monthly average sulfur dioxide concentrations for Port Kembla Fire Station from 1957 to 2003 (values in pphm)

In the Central zone, values of up to 2.5 pphm (annual average), 8.2 pphm (monthly average), 81 pphm (highest hourly) and 300 pphm (maximum 10 minute) were recorded in the late 1980s/early 1990s. By the period 1996 to 2006, sulfur dioxide levels had fallen to less than 0.31 pphm (annual average), 0.6 pphm (monthly average), 16 pphm (highest hourly) and 48 pphm (maximum 10 minute), even when the smelter operated.

239

In the Wollongong City zone, when monitoring first began in 1970s, values of up to 0.87 ppm (annual average) and 3.2 pphm (monthly average) were recorded. Values of up to 70 pphm (highest hourly) and 357 pphm (maximum 10 minute) were recorded in the late 1980s/early 1990s. By the period 1996 to 2006, sulfur dioxide levels had fallen to less than 0.19 pphm (annual average), 0.7 pphm (monthly average), 15 pphm (highest hourly) and 24 pphm (maximum 10 minute), even when the smelter operated.

In the Outer zone, values of up to 1.2 ppm (annual average) and 3.1 pphm (monthly average) were recorded in the 1970s/1980s. Values of up to 38 pphm (highest hourly) and 175 pphm (maximum 10 minute) were recorded in the late 1980s/early 1990s. By the period 1996 to 2006, sulfur dioxide levels had fallen to less than 0.18 pphm (annual average), 0.41 pphm (monthly average) and 5.5 pphm (highest hourly), even when the smelter operated.

This study has provided the first comprehensive, spatio-temporal analysis of all available ambient atmospheric sulfur dioxide monitoring data for the region. Previous reviews have tended to average data for the whole region, without considering the trends in specific locations and did not explore in any detail the relative contributions of major emission sources, such as the smelter. This study provides a valuable retrospective on trends in air quality in the region and the environmental history of technology and regulation at the smelter in addressing ambient sulfur dioxide levels which, to date have been poorly recorded.

240 4. Conclusions and Recommendations

4.1 Conclusions

As stated in Section 1.2, several key questions underpinned this study and these can now be directly addressed.

1. What have been the concentrations of ambient atmospheric sulfur dioxide in the Wollongong/Port Kembla region and how have they varied from 1957 to the present day?

This study has shown that sulfur dioxide, has at times, been a major air pollutant in the Wollongong/Port Kembla area. This is due to the presence of several major industrial sources of this pollutant, including a primary copper smelter and a steelworks. Section 3 of this thesis demonstrates there has been an overall decline in ambient sulfur dioxide levels since monitoring for this pollutant commenced in 1957, to the present day. This includes annual average, monthly average, highest daily, maximum hourly and maximum 10 minute values. The highest levels of sulfur dioxide have tended to occur in two geographical zones; Port Kembla Township and Central. This study has found the copper smelter at Port Kembla has been the dominant source of elevated sulfur dioxide levels recorded in these zones.

Port Kembla Township zone is in the immediate vicinity of the smelter. It was typically affected by fugitive emissions from these works. Prior to the construction of the taller smelter stack in 1965, this zone was also affected by smelter stack emissions. The Central zone was typically affected by stack emissions.

The greatest reductions in ambient sulfur dioxide levels have also occurred in the Port Kembla Township and Central zones. This can be directly attributed to reductions in the load of sulfur dioxide emitted from the smelter which have arisen from improvements in smelting technology and pollutant abatement measures.

241 2. How have the following factors evolved over time and influenced the levels of ambient sulfur dioxide measured:

• Evolving smelting technologies and pollution abatement measures at the smelter?

This study has shown that there has been a close link between smelting technologies and pollution abatement measures employed at the smelter. It is evident that as the smelter has relied on more continuous/integrated systems for smelting, it has increased the feasibility of sulfur dioxide abatement measures. These measures have lead to a reduction in the load (tonnes/year) of sulfur dioxide emitted to air, which in turn have reduced the levels of atmospheric sulfur dioxide. The success of these reductions is principally due to an increase in compatibility between smelting technologies that generate sulfur dioxide and pollution abatement measures that capture and treat it.

From the commencement of operations in 1908 up until the late 1980s, smelting technologies centred around the use of reverbatory furnaces or Blast Furnaces for matte smelting coupled with Pierce Smith converters. These resulted in intermittent, “batch type” operation and highly variable sulfur dioxide emissions. These emissions were difficult to collect, control and treat, using accepted pollution abatement measures like acid plants. The main form of pollution control was simply dilution and dispersion from tall stacks, with no sulfur capture. Tall stacks do not, however, reduce at all the load of sulfur dioxide emitted to atmosphere. Some attempts were made to control stack sulfur dioxide emissions through air quality management systems which reduced smelter production when weather conditions were conducive to pollution episodes, but these did not solve the problem. Because of the limitations of these systems, significant stack and fugitive emissions of sulfur dioxide occurred in neighbouring areas.

Fundamental changes to this basic mode of smelter operation did not occur until 1989, with the introduction of the Noranda Reactor for matte smelting, and in 2000, with its coupling to a Mitsubishi Continuous Converter for matte converting. These replaced the intermittent, batch-type furnaces for copper production with one that was much

242 more continuous and integrated. This comparatively smoother and efficient system enabled the greatest improvement in sulfur dioxide abatement because the resulting stack emissions were better suited to capture and control in acid plants. In addition, fugitive emissions of sulfur dioxide from the smelting buildings could now be greatly reduced because open air hot metal/slag transfers along the smelter aisle, using ladles and overhead cranes, were largely eliminated. The end result of these technological and abatement measures was that, despite major increases in copper production, there was a dramatic reduction in the annual load of sulfur dioxide emitted from the smelter over the same period. This is reflected in the reductions in the observed ambient levels of sulfur dioxide.

• State government environment protection legislation relating to the regulation of air pollution from the smelter?

There has been an unprecedented improvement in the regulation of air pollution in NSW during the study period. Prior to 1961, there was little legislation to regulate air pollution from industry. Existing nuisance laws tended to be weak and ineffective. The Clean Air Act 1961, and its successor, the Protection of the Environment Operations Act 1997, has provided and continues to provide, a strong regulatory framework to control and reduce sulfur dioxide emissions from the copper smelter at Port Kembla. This has been achieved through several statutory tools provided by this legislation. The first is a system of licensing which specifies design or operational conditions which must be complied with to prevent or minimise pollution, or economic incentives (for example load based licensing fees) to reduce sulfur dioxide under the “polluter pays” principle. The second is Pollution Reduction Programs requiring environmental improvement works within defined timeframes to address pollution problems. For example, Pollution Reduction Programs attached to the environment licence issued by the EPA in 1993 resulted in major changes in smelting and pollution abatement technologies at the smelter. These in turn lead to significant reductions in ambient sulfur dioxide levels in the surrounding areas. The third is a system of penalties for causing pollution and failing to comply with legislative requirements.

243 The study has shown that implementation of all these legislative tools has been a key factor in reducing the amount of sulfur dioxide emitted by the smelter, which in turn, has reduced ambient levels of this pollutant.

3. In relation to the smelter, has government regulation driven technology/pollution abatement or vice versa?

The copper smelter provides an interesting opportunity to explore this question because, being one of NSW oldest major industries, it provides a unique case study in point.

For almost a century, the emission and control of sulfur dioxide from the smelter has been a major air pollution issue facing government, community and industry in the Wollongong/Port Kembla area. The study has shown there is a complex inter- relationship between government regulation and technology/abatement. Both have undergone major changes over this time in relation to the smelter and sulfur dioxide emissions and their control. The study indicates that the most significant changes in technology/abatement at the Port Kembla smelter have tended to coincide with government intervention and regulation.

Two pivotal examples of government intervention and major step changes (improvements) in technology/pollution abatement support this conclusion. The first, and most graphic, was the installation of the new 198 m stack in 1965. This, together with government production bans at around the same time, were the first major pollutant abatement measures installed to address sulfur dioxide. Whilst the concept of taller stacks as an abatement measure has been around for centuries, it was not until the outcomes of government air pollution and health investigations, as well as the introduction of the Clean Air Act in 1961, that the smelter decided to construct one. There was no economic benefit for the company to install the stack so it is unlikely that this would have been done without being a government requirement. The second example relates to legal directions issued to the company in 1993 requiring an upgrade of the smelter to meet agreed environmental performance measures. These took the form of major Pollution Reduction Programs which centred on the WHO goal of 17.5pphm (10 min) as the agreed performance outcome. This set the legal

244 environmental goal posts and influenced investors in the smelter. In order to achieve this regulatory outcome, the company implemented new smelting technology (MIC furnace) and pollution abatement (second acid plant) measures.

Notwithstanding the above conclusion, it evident from the study that other factors have also significantly influenced government regulation and technology decision making. These factors include economic cost-benefits and the public interest.

As there were no applicable discharge limits for sulfur dioxide set by regulations under the Clean Air Act 1961 or Protection of the Environment Operations Act 1997 (except for acid plants), the smelter was typically required to operate by “best practicable means” necessary to prevent or minimise air pollution. What was “practicable”, whilst negotiated between the government and company, was often open to interpretation and demonstration, of the environmental and economic worth of the investment. In the case of the copper smelter, as new smelting technology/pollution control measures became available, there was uncertainty sometimes on how well they will work in particular situations. The retrofitting of pollution control measures at the smelter was often complex and expensive due to the age, existing technology and layout of the plant. The capital and operating costs associated with these newer abatement measures could, however, often be offset with increases in copper production. This was certainly the case for the two major smelter redevelopments that occurred in 1989 and 2000. Conversely, these expansions provided an opportunity for government to “piggy back” smelter environmental improvements. For these reasons, it cannot be assumed that increases in production will always translate into increased environmental impacts.

Even from its earliest days, the smelter has had a complex and often controversial social history. The emission of sulfur dioxide from this facility has attracted considerable interest and at times protest from the public, over the years. Even before a decision was made to build a smelter at the site, in 1907, community concerns regarding sulfur dioxide emissions are well documented. These concerns continued until the smelter ceased operation in 2003. Initially they focussed on the nuisance effects of sulfur dioxide on vegetation and property, but by the middle of the 20 th century they had shifted to public health issues. Community complaints about

245 emissions from the smelter prompted air quality and public health studies by government in the late 1950s/early 1960s. Public concerns over lead in the air and its potential affects on children attending schools or living in the vicinity emerged in the late 1980s. Several high profile court cases challenging government and the validitity of smelter redevelopments occurred in the 1990s. This public interest has resulted in continued pressure on both the government and industry to act.

4.2 Recommendations

On the basis of the findings of this study, the following recommendations should be considered.

1. Sulfur dioxide is a primary air pollutant and its harmful effects on the environment and human health are well known. All new industrial developments should be required to prevent or minimise, as far as practicable, emissions of sulfur dioxide during the design and development assessment stage.

2. Whilst current sulfur dioxide levels in the Wollongong/Port Kembla area are low and satisfy recognised ambient air quality goals, large point source emissions of sulfur dioxide still exist and should be progressively reduced. The most significant source on an annual load basis (tonnes/year) is iron and steelmaking (NPI, 2007). BlueScope Steel should, as a priority, achieve the sulfur oxide reductions proposed under the Sinter Machine Emission Reduction Project (SMERP). This sulfur rich gas will be collected and converted to gypsum and was expected to be completed by mid 2007. Further sulfur dioxide emission reductions should also be started by better optimisation and integration of iron/steel manufacturing (through energy savings and fuel consumption reductions) or desulfurization of indigenous fuels, such as coke ovens gas.

3. Should smelting operations ever recommence at the Port Kembla site, detailed consideration should be given to the use of alternate processes which prevent the emission of sulfur dioxide. These could include hydrometallurgical

246 processes which generate no sulfur dioxide. Should pyrometallurgical methods be the only feasible option, the use of fully integrated systems (for example flash smelting or Mitsubishi Continuous Converting) should be carefully considered. These methods enhance the generation and collection of sulfur dioxide and its conversion to value added products such as sulfuric acid. The cleanest smelter in the world (Kennecott Garfield Smelter, USA) employs flash smelting and converting methods with a very modern double contact acid plant. It has a sulfur dioxide emission rate less than 3.5 kilograms per tonne of copper. By comparison, in its final years of operation, the Port Kembla Copper smelter (utilising the Noranda/Mitsubishi Converting system and double contact acid plant) had an emission rate of around 40 kilograms of sulfur dioxide per tonne of copper. There are limitations, however, to the best management practices available to prevent pollution from copper smelters. In a sensitive location, such as Port Kembla, where residences are less than 100 metres from major smelting furnaces, these limitations may only be addressed through better land use planning.

4. Retrospectives on air quality provide valuable insights into progress on environmental improvements. For these to be effective, reliance on access to historical monitoring data is crucial. With changing government and industry departments, it is vital that this monitoring data is not lost or destroyed and remains accessible. The responsibility is on government agencies or industries who hold such data to ensure it is properly catalogued and archived to ensure it is preserved and accessible for future researchers. Advice should be sought from the NSW State Library, University of Wollongong Library or Wollongong City Council Library (Local Studies Section) in this regard to ensure this is achieved.

5. There is currently a focus on greenhouse gas (carbon dioxide) emission reductions resulting from electricity generation at coal fired power stations. Initiatives including “clean coal technologies” aim to improve both the efficiency and environmental acceptability of coal for preparation and use in power stations and allow reductions in carbon dioxide emissions. Nationally and state wide, these power stations are also a major source of sulfur dioxide.

247 The effect of these greenhouse gas reduction technologies in not only reducing carbon dioxide but also sulfur dioxide in this industry sector is worthy of further examination.

6. Fine particle sulfate compounds have been of increasing concern over the past few years because of their effects on human health and air quality (visibility). Whilst some studies have been undertaken in the Wollongong/Port Kembla area on sulfate levels in the air, for example, Cohen et al (1993) and Huo et al (1999), they appear to have been only conducted during the early 1990s when the smelter was operational. The smelter ceased operation in 2003 and this now provides an opportunity to investigate the effect of the emission change on the local atmospheric productivity of sulfate as well as any inter-regional transport of sulfate from Sydney to Wollongong.

248

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261