Weston Aluminium Pty Ltd 10 May 2012
Environmental Assessment Spent Potlining Processing
AECOM Environmental Assessment Spent Potlining Processing
Environmental Assessment Spent Potlining Processing
Prepared for Weston Aluminium Pty Ltd
Prepared by
AECOM Australia Pty Ltd 17 Warabrook Boulevarde, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T +61 2 4911 4900 F +61 2 4911 4999 www.aecom.com ABN 20 093 846 925
10 May 2012
60250487
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10 May 2012
AECOM Environmental Assessment Spent Potlining Processing
Table of Contents Executive Summary i 1.0 Introduction 1 1.1 Purpose of this Document 1 1.2 Facility Background 1 1.2.1 Site Location 1 1.2.2 Proponent 1 1.2.3 Facility History 1 1.3 Project Background 1 1.3.1 Background 1 1.3.2 Spent Potlining 2 1.3.3 SPL Trials and Validation 2 1.3.4 Product Market 3 1.3.5 Staged Approval 3 2.0 Description of the Project 5 2.1 Project Location 5 2.2 Interaction with Existing Operations 5 2.3 Proposed Project 5 2.3.1 Process Description 5 2.3.2 Raw Materials 6 2.3.3 Operational Facilities 6 2.3.4 Transport Requirements 6 2.3.5 Workforce 6 2.3.6 Hours of Operation 6 2.3.7 Capital Investment Required 6 2.3.8 Construction Details 6 2.3.9 Environmental Controls 6 2.4 Need for the Project 7 2.5 Alternatives Considered 7 3.0 Statutory Planning 11 3.1 Overview 11 3.2 Commonwealth Legislative Requirements 11 3.2.1 Environment Protection and Biodiversity Conservation Act 1999 11 3.2.2 National Greenhouse and Energy Reporting Act 2007 11 3.3 NSW Legislative Requirements 11 3.3.1 Environmental Planning and Assessment Act 1979 11 3.3.2 Protection of the Environment Operations Act 1997 12 3.4 Environmental Planning Instruments 12 3.4.1 State Environmental Planning Policy No.33 – Hazardous and Offensive Development 12 3.4.2 Cessnock Local Environmental Plan 2011 13 3.5 Basel Convention 13 3.6 NSW 2021: A Plan to Make NSW Number One 13 4.0 Stakeholder Consultation 15 4.1 Consultation Undertaken to Date 15 4.2 Stakeholder Engagement Strategy 15 5.0 Prioritisation of Issues 17 5.1 Risk Matrix 17 5.2 Risk Analysis 17 5.3 Key Issues 18 6.0 Environmental Impact Assessment 19 6.1 Air Quality 19 6.1.1 Existing Environment 19 6.1.2 Potential Impacts 19 6.1.3 Mitigation Measures 20 6.2 Greenhouse Gas Emissions 20
10 May 2012 AECOM Environmental Assessment Spent Potlining Processing
6.2.1 Existing Environment 20 6.2.2 Potential Impacts 21 6.2.3 Mitigation Measures 21 6.3 Waste Management 21 6.3.1 Existing Environment 21 6.3.2 Potential Impacts 22 6.3.3 Mitigation Measures 22 6.4 Hazard and Risk 22 6.4.1 Existing Environment 22 6.4.2 Potential Impacts 23 6.4.3 Mitigation Measures 24 6.5 Soil and Water 24 6.5.1 Existing Environment 24 6.5.2 Potential Impacts 25 6.5.3 Mitigation Measures 25 6.6 Transport 26 6.6.1 Existing Environment 26 6.6.2 Potential Impacts 26 6.6.3 Mitigation Measures 26 6.7 Other Environmental Issues 26 7.0 Statement of Commitments 27 8.0 Conclusion 29 9.0 References 31 Appendix A Director-General's Requirements A Appendix B Stakeholder Information Session: Documentation B Appendix C Air Quality Impact Assessment C Appendix D Preliminary Hazard Analysis D
List of Tables Table 1 Fee based activity under EPL 6423 12 Table 2 Risk Matrix 17 Table 3 Risk Assessment 18 Table 4 Greenhouse Gas Emissions and Energy Use, 2009 - 2011 20 Table 5 NSW Greenhouse Gas Emissions by Economic Sector, 2009 21 Table 6 Statement of Commitments 27
List of Figures Figure 1 Site Location 4 Figure 2 Proposed SPL Processing Schematic 8 Figure 3 Plant Layout 9
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Executive Summary Introduction This Environmental Assessment (EA) has been prepared for Weston Aluminium Pty Ltd (Weston Aluminium) to accompany an application under Section 75W of the Environmental Planning and Assessment Act 1979 (EP&A Act) to modify existing Development Consent DA 86-04-01 and LEC 10397 of 1995 (as modified) to allow for the commercial processing of Spent Potlining (SPL) at the Kurri Kurri facility. Weston Aluminium proposes to diversify its service provision to the aluminium smelting industry beyond the reprocessing of aluminium drosses and other aluminium-bearing by-products to secure future sustainability and growth. The proposed project, which is the subject of this application, is to treat and process Second Cut SPL on a commercial scale. The current development consent authorises Weston Aluminium to process up to 40,000 tonnes of aluminium dross and process up to 35,000 tonnes of scrap aluminium metal per year on site. Dross inputs are currently in the order of 10,000-15,000 tonnes per annum, which is well below the approved capacity. Under the proposed project, it is envisaged that (ultimately) 15,000-25,000 tonnes per annum of SPL processing will be undertaken on the premises. As such, the combined dross and SPL processing tonnage will comply with the existing approval conditions. Since 2005, Weston Aluminium representatives have undertaken extensive research, both domestically and overseas, investigating available technologies for the treatment of SPL from primary aluminium smelters. Weston Aluminium’s objective is to offer a sustainable solution to domestic smelters, enabling the cost-effective treatment of SPL and, in conjunction with other treated industrial by-products, formulate the manufacture of a value added substitute for manufacturing sector raw material inputs. Description of the Project SPL will be received either pre-crushed or uncrushed from various domestic aluminium smelters, and stored on the premises in accordance with the Australian Dangerous Goods Code. The proposed SPL processing chain is identical to that of dross treatment and the same facilities, plant and equipment will be used for the recycling of both materials. However, as the recycling of dross and SPL produce different end products, the treatment of both materials will be conducted independently as dedicated campaigns. Weston Aluminium proposes a treatment process of SPL based on the following elements: - Primary crushing (where necessary); - Controlled blending with other propriety additives, as required; - Fine milling; - Thermal treatment; and - Crushing and mixing (as required) and subsequent distribution to end markets. The objective of the process is to thermally oxidise the cyanide within the SPL and modify the mineralogical composition so that the material is declassified and able to be transported as a non-hazardous goods product. Previous trials conducted by Weston Aluminium demonstrated that the proposed process will allow Weston Aluminium to remain within its existing regulatory compliance limits in terms of both cyanide concentrations and atmospheric emissions. Consequently, no change to Weston Aluminium’s existing Environmental Protection Licence (EPL) limits will be required for the project. Environmental Impact Assessment Air Quality An air quality impact assessment was prepared for the proposed processing of SPL at the Weston Aluminium facility. The objective of the investigation was to assess the potential change in pollutant concentrations experienced at sensitive receptors as a result of the modification to the facility’s operations. The Ausplume model was run using representative stack emissions data from both dross and SPL processing operations. Dispersion modelling predicted only minor changes to ground level pollutant concentrations as a result of the change to the processing activities at the Weston facility. With the exception of fluoride and cumulative
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PM10, all predicted pollutant concentrations complied with the relevant impact assessment criteria. Further analysis (through receptor-specific modelling) demonstrated that the exceedances of the fluoride criteria were confined to the site, and that acceptable levels were predicted at sensitive receptor locations. The exceedances of the 24 hour PM10 criterion were demonstrated to be solely attributable to elevated background concentrations; no additional exceedances were predicted to result from the operation of the facility processing either dross or SPL. On the basis of the dispersion modelling undertaken for this project, processing of SPL processing at the facility is not expected to result in an unacceptable change to the expected emissions from the facility, and ground level pollutant concentrations at all sensitive receptors should be within acceptable levels. Greenhouse Gas Emissions The proposed processing of SPL would bring the facility back up to its typical rotary furnace inputs of 40,000 tonnes per annum (current approved limit). The estimated Scope 2 emissions (indirect GHG emissions generated from electricity consumption) associated with full-scale operation of the facility would be approximately 19 % higher than those reported in 2010-11, or equivalent to approximately 5,874 t CO2-e per year. Scope 1 emissions (direct GHG emissions) would similarly be expected to increase over existing levels, but be in the same order as those associated with typically full-scale operation. Assuming a similar 19% increase in emissions, the Scope 1 emissions associated with full-scale operation would be in the order of 8,886.9 t CO2-e per year, resulting in total greenhouse gas emissions in the order of 14,760.9 t CO2-e per year (0.0148 Mt CO2-e per year) for the facility. Weston Aluminium’s predicted emissions represent approximately 0.078% of the total NSW manufacturing emissions. As such, the proposed modification is not expected to significantly change NSW or Australian emissions levels. Waste Management The proposed project would create an opportunity for domestic treatment of a hazardous waste product, thereby processing it into an alternative raw material that has value. The project would reduce the current need to ship hazardous wastes internationally, which benefits the environment and the waste producer. The proposed project could generate hazardous waste should processing of the SPL material fail to result in destruction of cyanide. Should this occur, the material would be captured by Quality Assurance and Control processes and returned for reprocessing. Previous trials have demonstrated that the proposed SPL treatment process is successful in reducing cyanide content to negligible levels, and it is anticipated that cyanide contamination will not represent an issue. There would be no other additional wastes generated by the proposed project. Hazard and Risk A Preliminary Hazard Analysis (PHA) of the proposed project was undertaken as part of this EA in accordance with Hazardous Industry Planning Advisory Paper (HIPAP) No.6 in support of the Development Application.
Based on the analysis conducted in the PHA, the hazards associated with the proposed storage of SPL at the Weston aluminium facility do not result in a change to the existing risk profile. Hence, the risk criteria published by the NSW DPI in HIPAP No.4 is not exceeded and the facility remains classified as potentially hazardous and not hazardous and would therefore be permitted to continue operations processing dross and SPL in the existing land zoning. Soil and Water The proposed project would be undertaken within existing facilities on site. There is no proposed change to the existing site footprint, and no excavations will occur. There would be no construction activities associated with the proposed project and as such there would be no immediate impact on soils and local water quality. SPL material has the same dangerous goods classification as aluminium dross. SPL contains contaminants such as aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants. Quantities of SPL will be stored on site as part of the project, and there is a risk of stormwater contamination through runoff and rainfall events, potentially leading to downstream contamination of soils and surface water resources. There is also potential for accidental fuel and oil spills to occur on site during operation of plant and equipment. However, Weston’s existing stormwater management measures, combined with the additional controls identified, would be implemented for the proposed project. Potential impacts to soil and water quality as a result of the proposed project would therefore be minimal.
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Transport The proposed project would result in an additional four trucks entering and exiting the site (eight heavy vehicle movements) per day for the delivery of the SPL raw materials to the site and dispatch of product from the site. This increase is minimal, given that existing truck movements are currently well below previously approved estimates of truck movements. There would also be an increase of approximately 10-15 light vehicles accessing the site per day due to the expected increase in staff numbers required for the project operations. All parking generated by the development would be accommodated on site and no staff vehicles or vehicles associated with the operation would park on the public road system. The effects of the project on transport and road traffic are therefore expected to be minimal. Other Environmental Issues Operational noise at the facility will be generated as a result a truck movements to and from the site, and from the operation of existing onsite plant and equipment. Noise monitoring indicates that the facility is currently operating within the licence limits. Given that existing plant and equipment will be used for the project and that overall truck movements will remain within the existing approval limits, it is expected that noise levels will be equivalent to existing levels and therefore within EPL limits. Weston Aluminium is not seeking a change to existing Environment Protection Licence noise limits. Further assessment of noise impacts is therefore not required. Weston Aluminium is a strong employment generator and procurer of local contractor services in the local community. The proposed project would utilise local contractors where possible for required modifications to the plant. It is also anticipated that an additional 15 staff would be required during operation of the proposed project. With the recent retrenchments from Weston Aluminium and local aluminium smelters, the project is timely to recover these skilled resources and provide ongoing employment to the local community in a period of downturn. The proposed project would therefore have a positive impact on the community through employment generation, and a detailed socio-economic assessment is not required. Other environmental issues considered include impacts to visual amenity, heritage values, landuse, and flora and fauna. No impact on these environmental issues is anticipated as there is no change to the existing site footprint, no construction outside of buildings and no change in operation of the facility. Conclusion The proposed project offers a solution for the recycling of SPL generated by aluminium smelters. The treatment and processing of SPL on a commercial scale by Weston Aluminium provides an alternative to the international transport of this hazardous material, in doing so securing the sustainability of the domestic aluminium industry. The proposed project would result in improved market versatility, product handling and a reduction of material losses. It is anticipated that the potential adverse impacts of the proposed project will not be significant. With the implementation of the mitigation measures (existing and proposed), impacts would be eliminated or minimised. No change to Weston Aluminium’s existing EPL limits will be required for the project. Additionally, the proposed project would have a positive impact on the community through employment generation.
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1.0 Introduction
1.1 Purpose of this Document This Environmental Assessment (EA) has been prepared for Weston Aluminium Pty Ltd (Weston Aluminium) to accompany an application under Section 75W of the Environmental Planning and Assessment Act 1979 (EP&A Act) to modify existing Development Consent DA 86-04-01 and LEC 10397 of 1995 (as modified) to allow for the commercial processing of Spent Potlining (SPL) at the Kurri Kurri facility. Weston Aluminium proposes to diversify its service provision to the aluminium smelters beyond the reprocessing of aluminium drosses and other aluminium-bearing by-products to secure future sustainability and growth. The proposed project, which is the subject of this application, is to treat and process SPL on a commercial scale. A Preliminary Environmental Assessment (PEA) was prepared and provided to the NSW Department of Planning and Infrastructure (DP&I) in February 2012, to characterise the proposed project and provide an overview of its potential effects on the environment and the community. Director-General’s Requirements (Appendix A) were subsequently issued by the DP&I in March 2012 to identify the key issues required to be addressed in the EA. This EA provides a detailed assessment of the key environmental issues associated with the proposed project and has been prepared in accordance with the Director-General’s Requirements.
1.2 Facility Background 1.2.1 Site Location The existing aluminium recycling and refining facility is located on Lot 796 DP 39877 at 129 Mitchell Avenue, Kurri Kurri in the Hunter Valley, NSW. The site is located within the Parish of Heddon, County of Northumberland, and City of Cessnock. The deed of sale is in the name of Weston Aluminium Pty Ltd. The location of the site is shown in Figure 1. The site is approximately 40 km northwest of Newcastle and is located within a heavy industrial area. Residential areas in Kurri Kurri and Weston are located to the south and west of the site, respectively. The Hydro Aluminium Smelter is located approximately 2 km north of the site; its buffer zone extends to Weston Aluminium’s northern boundary. 1.2.2 Proponent The plant is owned and operated by Weston Aluminium, which is majority owned by Watou Holdings and the balance by Asahi Seiren, a major secondary aluminium processor in the Japanese Aluminium industry. Both shareholders have an established track record in the operation of aluminium refining and recycling facilities through the operation of the existing development in Kurri Kurri and a number of facilities in Japan and Indonesia. 1.2.3 Facility History The facility commenced operations as a pilot plant in 1998 with six employees and one rotary furnace and has progressively grown. The current Weston Aluminium facility recovers aluminium from dross, a by-product of the aluminium smelting process, sourced from aluminium smelters across Australia and New Zealand. Dross is a dry metallic solid typically composed of aluminium, aluminium oxide, other metal oxides, traces of sodium aluminium fluoride (bath) and alloying metals. Dross can contain 30-75 percent metallic aluminium, which represents a significant loss of metal if not recovered. The plant also recycles scrap aluminium metal products and reprocesses the aluminium for use in various industries. The facility is approved to process up to 40,000 tonnes of dross aluminium and process up to 35,000 tonnes of scrap aluminium metal per year on site.
1.3 Project Background 1.3.1 Background Since 2005, Weston Aluminium representatives have undertaken extensive research, both domestically and overseas, investigating available technologies for the treatment of SPL from primary aluminium smelters. Weston Aluminium’s objective is to offer a sustainable solution to domestic smelters, enabling the cost-effective treatment of SPL and, in conjunction with other treated industrial by-products, formulate the manufacture of a value added
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substitute for manufacturing sector raw material inputs. This particular project was conceived through Weston Aluminium’s Membership in the NSW Office for Environment Sustainability Advantage Program, and central foundation and ongoing involvement with the NSW Industrial Ecology Network. The Industrial Ecology Network is represented by like-minded industry, academics and Government regulators, eager to encourage the recovery of industrial by-products as valuable resources, and thereby achieve the diversion of large material volumes from landfill. 1.3.2 Spent Potlining SPL is a by-product of primary aluminium production, generated from the periodic de-lining of electrolytic cells. First Cut SPL (originating from the carbon cathode) and Second Cut SPL (refractory lining) contain varying proportions of aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants, with its management and disposal representing a major issue faced by the industry. In this EA we are only concerned with the Second Cut SPL. 1.3.3 SPL Trials and Validation Laboratory Scale Trial, New-Zealand (Feb-Apr 2010) Initially, Weston Aluminium undertook a laboratory-scale trial in New Zealand (NZ) that demonstrated the treatment concept and the emission control performance of a small-scale plant. This involved the processing of Second Cut SPL in a 2.7 m length diesel-fired kiln at elevated temperatures in a batch-style process, and the recovery of the residue. The emission control system comprised a wet lime scrubber and fabric filter baghouse constructed for the removal of fluoride and particulate emissions. This pollution control system was designed and operated to emulate that operating at the Kurri Kurri facility, and from which the full-scaled operation was modelled. Analyses were performed to profile the input raw materials and to characterize the treated products. The data and laboratory analyses demonstrated the complete destruction of cyanide. Small Scale Trial – Weston Aluminium Facility, Kurri Kurri (Aug 2010) As an extension of the NZ-based trials, Weston Aluminium conducted a larger-scale trial exercise at their Kurri Kurri premises. The objectives of the trial were to verify operations and to demonstrate emission control performance and compliance on the larger-scale. Weston Aluminium’s Kurri Kurri processing facility was considered ideal for the validation trial due to the compatibility of existing unit processes and practices including: - Rotary furnaces, capable of attaining elevated temperatures required to thermally oxidise cyanide; - Facilities for the recovery of treated SPL; and - Best-practice emission controls systems, including extraction hoods, wet-dry lime scrubber, baghouse complex, and real-time continuous fluoride and particulate monitoring system controlled by a Citect-based PLC. On 14 August 2010, approximately 8 tonnes (t) of Second Cut SPL was sourced from Tomago Aluminium and processed in one of the existing rotary furnaces. SPL was processed independently to normal aluminium dross processing activities to allow the assessment of emissions performance directly attributed to SPL processing. Rotary furnace off-gasses were directed through the existing wet-dry fluoride scrubber and baghouse pollution control systems. Emission control performance was monitored continuously throughout the trial by real-time stack emissions monitoring and independent NATA accredited stack emission testing. Samples from both feed and processed SPL were submitted to a NATA accredited laboratory to profile and determine residual contaminants present within the material. Cyanide concentrations contained within the process SPL material were dramatically reduced. Real-time, continuous emission monitoring data confirmed that gaseous fluoride and particulate emission concentrations were below existing regulatory compliance limits throughout the entire trial interval. Treatment temperatures during the trial were increased to over 1000°C to demonstrate worst-case fluoride dissociation, with the pollution control system demonstrating appropriate fluoride scrubbing capability. NATA-accredited emission testing was undertaken in conjunction with trial activities, revealing negligible discharge concentrations, thus confirming the suitability of the existing lime-scrubber and fabric filter baghouse pollutant control systems. All air emission concentrations were below regulatory compliance limits demonstrating the suitability of the existing pollution control system for future processing of SPL.
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Rotary Furnace Optimisation Laboratory Trials, Newcastle (Feb 2011) A process optimisation study was conducted during February 2011 using a laboratory scale infra-red rotary furnace located at the University of Newcastle Newbolds laboratories. One kilogram samples of Second Cut SPL were heated to different treatment temperatures ranging between 450°C – 750°C for a period of 45 minutes. Treated SPL samples were collected for each temperature point and submitted to a NATA accredited laboratory for testing to determine remaining cyanide contamination contained within the treated sample. Data obtained from this study was used to refine future process conditions required to meet SPL processing objectives in future trials. A treatment temperature of greater than 450°C was determined to be sufficient for the destruction of cyanide contained within Second Cut SPL material, which is consistent with previously published literature for SPL treatment. Large Scale Trial – Weston Aluminium Facility, Kurri Kurri (from Nov 2011) Following the successful completion of previous laboratory and small-scale trials to establish the suitability of existing rotary furnaces and associated environmental controls, Weston Aluminium obtained approvals and has recently completed a larger-scale SPL validation trial before the development of commercial operations. Over a 3-month period, Weston Aluminium processed up to 200 tonnes of Second Cut SPL within the existing rotary furnaces located at its Kurri Kurri premises. This large-scale trial was approved in November 2011 and commenced in December 2011. The objective of this trial was to confirm processing requirements and explore potential beneficial end use opportunities for the treated material within different industrial processes. SPL material was sourced and transported to the Kurri Kurri plant from Tomago Aluminium. It was then processed through a series of 2.5-3.5 tonne batches, identical to the process employed for the small-scale trial conducted on 14 August 2010. Trial outcomes were as follows: - Cyanide was confirmed to be thermally-destroyed at process temperatures achieved; - Independent NATA certified emission testing undertaken in conjunction with Trial activities revealed exceptionally low pollutant discharge concentrations, and confirmed reliable performance of the existing lime-scrubber and fabric filter baghouse pollutant control systems. Emissions data are of generally of the same order of magnitude, or lower, than that reported for previous Trials; - Real-time, continuous emission monitoring data confirm that gaseous fluoride and particulate emission concentrations satisfied the regulatory compliance limits throughout the Trial interval; and - The particle size distribution, fluoride content and composition profile of treated residues is of great interest to prospective Customers, and will enable the substitution of virgin raw materials in various industrial processes. Research and development activities have successfully demonstrated the compatibility of facility infrastructure, processes and control measures available for the effective treatment of SPL, confirmed environmental and safety performance and compliance of such processes, and have verified sustainable market interest. 1.3.4 Product Market Weston Aluminium’s objective is to offer a sustainable solution to domestic smelters, enabling the cost-effective treatment of SPL and, in conjunction with other treated industrial by-products, formulate the manufacture of a value added substitute for manufacturing sector raw material inputs. 1.3.5 Staged Approval Weston Aluminium proposes a two stage program to reach their goal of full scale commercial treatment and processing of SPL: - Stage 1 – Commercial scale treatment and processing of Second Cut SPL, which is the subject of this application; and - Stage 2 – A future application will be lodged for a Preliminary Monitoring and Verification Trial of First Cut SPL, and subsequently approval will be sought for commercial scale processing of First Cut SPL.
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Figure 1 Site Location
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2.0 Description of the Project
2.1 Project Location The commercial scale treatment and processing of Second Cut SPL will be conducted at Weston Aluminium’s existing Plant located at Kurri Kurri (refer to Figure 1). The storage and processing of SPL will be undertaken within existing storage buildings and processing through existing rotary furnaces.
2.2 Interaction with Existing Operations The current Weston Aluminium facility recovers aluminium from dross and scrap aluminium metal products and reprocesses the aluminium for use in various industries. The current development consent authorises Weston Aluminium to process up to 40,000 tonnes of dross aluminium and process up to 35,000 tonnes of scrap aluminium metal per year on site. Dross inputs at the Kurri Kurri facility are currently in the order of 10,000-15,000 tonnes per annum, which is well below the approved capacity. Under the proposed project, it is envisaged that (ultimately) 15,000-25,000 tonnes per annum of SPL processing will be undertaken on the premises. As such, the combined dross and SPL processing tonnage will comply with the existing approval conditions.
2.3 Proposed Project 2.3.1 Process Description Weston Aluminium proposes to diversify its service provision to the aluminium smelting industry beyond the reprocessing of aluminium dross and other aluminium-bearing wastes, to include the treatment and processing of Second Cut SPL. SPL is classified as a dangerous good and hazardous material and contains varying proportions of aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants, such that its management and disposal represent a major issue to the aluminium smelting industry. SPL will be received either pre-crushed or uncrushed from various domestic aluminium smelters, and stored on the premises in accordance with the Australian Dangerous Goods Code. As discussed with the DP&I in March 2010, Weston Aluminium proposes a treatment process of SPL based on the following elements: - Primary crushing (where necessary); - Controlled blending with other propriety additives, as required; - Fine milling; - Thermal treatment; and - Crushing and mixing (as required) and subsequent distribution to end markets. The proposed SPL processing chain is schematically represented in Figure 2. This process is identical to that of dross treatment and the same facilities, plant and equipment will be used for the recycling of both materials. However, as the recycling of dross and SPL produce different end products, the treatment of both materials will be conducted independently as dedicated campaigns. The objective of the process is to thermally oxidise the cyanide within the SPL and modify the mineralogical composition so that the material is declassified and able to be transported as a non-hazardous goods product. Previous trials conducted by Weston Aluminium (refer to Section 1.3.3) demonstrated that the proposed process dramatically reduces cyanide concentrations in treated SPL to a level at or below the analytical limit of reporting (1 mg/kg). Additionally, emissions monitoring data obtained during the trials confirmed that all emission concentrations were below the existing regulatory compliance limits throughout the process. Consequently, no change to Weston Aluminium’s existing Environmental Protection Licence (EPL) limits will be required for the project. However, cyanide monitoring may be added to the air quality monitoring and water sampling regimes for completeness. All occupational hygiene, safety and monitoring requirements for the treatment of SPL at the facility have already been successfully determined during the successive trials, and will be implemented for the proposed project.
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2.3.2 Raw Materials Raw material (SPL) will be sourced from various domestic aluminium smelters, as is currently the case with dross. 2.3.3 Operational Facilities The storage and processing of SPL will be undertaken within existing storage buildings and processed through existing rotary furnaces. The only additional plant equipment required for the proposed project will consist of a new rotary cooler, which will be installed within the existing processing chain (refer to Figure 2). There would be no need for additional pollution control systems, or the construction of any additional infrastructure. The plant layout for the Weston Aluminium facility is presented in Figure 3 with the proposed modifications marked. 2.3.4 Transport Requirements SPL will be delivered to the Kurri Kurri facility by a Dangerous Goods Licensed contractor. The current development consent requires Weston Aluminium to ensure that the haulage is via Main Road 588 when travelling towards the F3 motorway, that all parking generated by the development is accommodated on site and that the development does not result in vehicles queuing on the public road network. Weston Aluminium also implements a Transport Code of Conduct which was submitted and approved by the Director-General. The existing development consent does not include a limit on the number of truck movements to and from site, however this is limited by approved production limits. All transports requirements will continue to be met during the proposed project. Further, it is anticipated that truck movements will occur via the Hunter Expressway (following completion of its construction), thereby alleviating traffic movements within the Kurri Kurri township. 2.3.5 Workforce The current workforce at the Kurri Kurri Weston aluminium plant is composed of 33 staff. It is anticipated that an additional 15 staff will be required during the operation of the project, bringing the total workforce to 48 personnel. 2.3.6 Hours of Operation Under the existing development consent, the facility is approved for operations 24 hours per day 7 days a week. Truck movements to and from the premise are limited to between the hours of 7 am and 10 pm. No change to the existing operating hours is anticipated for the project. 2.3.7 Capital Investment Required It is anticipated that a capital investment of approximately AU $100,000 will be required for the project. 2.3.8 Construction Details The only new plant to be installed at the facility is the Rotary Cooler. During the construction period, the crushing plant will also be upgraded (for crushing of both SPL and dross) and Baghouse 3 re-ducted to service the proposed Rotary Cooler. Construction is expected to be over a period of 1–2 months and be carried out by both Weston Aluminium employees and external contractors. Construction works would occur weekdays between 8 am and 6 pm. 2.3.9 Environmental Controls The existing facility is comprised of best available technology, and complies with stringent pollution limits. This plant will be utilised for the processing of SPL. Risk assessments were undertaken for the SPL trials, and safe operating procedures developed. These will be further developed for commercial production. The trials characterised ongoing SPL processing performance requirements and demonstrated the facilities’ ability to satisfy emissions criteria. Emissions of process dust, cyanide and fluoride are controlled by existing plant through: - Temperature control; - Scrubber/baghouse complex; and - By-product residues returned to the raw material feed in a closed-loop cycle.
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2.4 Need for the Project At present, no primary smelter, internationally or domestically, has yet developed an effective and sustainable solution for their generated SPL. Untreated surplus SPL continues to be stockpiled and/or exported overseas for treatment. This is a significantly expensive process, relying on the transport of hazardous materials over many jurisdictions and the vagaries of third party countries. This strategy is clearly not sustainable for the domestic industry. Although some treatment and beneficial reuse of First Cut SPL is occurring domestically there has been limited success in developing end use market opportunities for the Second Cut refractory brick component of SPL. Processed SPL material generated from Weston Aluminium’s previous trials was aimed at developing end use market opportunities for the Second Cut treated material. Product markets are now emerging with increasing demand for greater quantities of processed material.
2.5 Alternatives Considered The ‘do nothing’ option would involve the continuation of existing methods for disposal of SPL waste material. If the proposed project does not proceed, SPL material will continue to be stockpiled and/or transported overseas for processing at considerable cost to local aluminium smelters. The proposed project offers a more cost effective and environmentally sustainable solution to the management of SPL material than is currently available to aluminium smelters, and is the preferred option rather than doing nothing. Trials conducted in New Zealand and at the current facility (refer to Section 1.3.3) have been undertaken to refine the optimum process conditions required for the effective treatment of SPL material and to explore the potential end use opportunities. The large scale 200 tonne trial recently completed at the existing facility has allowed prospective end-use customers to determine the suitability of the material within different industrial processes. Feedback from these customers has allowed Weston to develop treated material specifically to these customer’s specifications.
10 May 2012 Preliminary (Pre-crushed 2nd Cut + 1st Cut 2nd Cut + 1st Cut Monitoring and 2nd Cut +1st Cut Offsite) Rotary Cooler Bagging Station Product Onsite Dispatch to Verification Trial Rotary Furnace SPL Onsite (New) (Existing) Storage (Existing) Customers (1st Cut Road Deliveries Treatment Storage (Existing) Processing) (Existing)
2nd Cut + 1st Cut
Crushing Circuit (Existing)
Key
Stage 1 – Proposed SPL (2nd Cut) Processing Schematic
Stage 2 – Proposed SPL (1st and 2nd Cut) Processing Schematic
07/02/12 Proposed SPL Processing Reference No. WA-FLW-052 Date Issued: Revision No. 0 Schematic Prepared By: Graham Snedden Authorised By: Chris McClung
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3.0 Statutory Planning
3.1 Overview This section identifies the legislative requirements and planning controls relevant to the project and outlines the key policy and statutory considerations that would be addressed in more detail in the Environmental Assessment.
3.2 Commonwealth Legislative Requirements 3.2.1 Environment Protection and Biodiversity Conservation Act 1999 The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) requires the approval of the Commonwealth Minister for Sustainability, Environment, Water, Population and Communities (SEWPaC) for actions that would have, or are likely to have, a significant impact on matters of National Environmental Significance (NES). The EPBC Act lists seven matters of NES which must be addressed when assessing the impacts of a proposal, which are: - World Heritage properties; - National Heritage places; - Wetlands of International Importance; - Listed threatened species and ecological communities; - Migratory species protected under international agreements; - Commonwealth Marine Areas; and - Nuclear actions. If potential significant impacts on a matter of NES are identified, then a referral to the Minister would be made in accordance with the requirements of the EPBC Act for a determination as to whether the Project is a Controlled action. The EPBC Protected Matters Search Tool identified one RAMSAR Wetland, one threatened ecological community, 21 threatened species and 14 migratory species within 5 km of the Weston Aluminium Plant. The proposed project is not expected to have a significant impact on relevant matters of NES. Accordingly, the Project would not need to be referred to the SEWPaC. 3.2.2 National Greenhouse and Energy Reporting Act 2007 The National Greenhouse and Energy Reporting Act 2007 (NGER Act) came into effect in September 2007 and introduced a single national reporting framework for the reporting and dissemination of information about greenhouse gas emissions, greenhouse gas projects and energy use and production by corporations. The NGER Act makes registration and reporting mandatory for corporations whose energy production, energy use or greenhouse gas emissions meet specified thresholds. Weston Aluminium reports emissions including those from its Kurri Kurri plant operations.
3.3 NSW Legislative Requirements 3.3.1 Environmental Planning and Assessment Act 1979 The Environmental Planning and Assessment Act 1979 (EP&A Act) and the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation) provide the framework for environmental planning in NSW and include provisions to ensure that proposals that have the potential to impact on the environment are subject to detailed assessment and provide opportunity for public involvement. The Weston Aluminium facility at Kurri Kurri currently operates under two separate development consents: - DA No. 86-04-01 (as modified) issued by the then Minister for Urban Affairs and Planning under Part 4 of the EP&A Act; and - Land and Environment Court Consent LEC 10397 of 1995 (as modified).
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The development was declared to be State Significant Development under State Environmental Planning Policy No. 34 – Major Employment Generating Industrial Development (SEPP 34). Clause 8J(8) of the Environmental Planning and Assessment Regulation 2000 requires that development consents for State Significant Development under SEPP 34 are subject to modification under section 75W, despite the repeal of that section with the recent repeal of Part 3A of the EP&A Act. Weston Aluminium has had the two previous SPL trials (40 tonne and 200 tonne trials) approved by the Department of Planning and Infrastructure (DP&I) as section 75W Modifications. It is expected that the transition to full scale commercial production would be a further section 75W Modification. It has been demonstrated through this EA that transition to full scale commercial production would not fundamentally alter the scale or nature of the existing development, and it is therefore appropriate for the Department to use its discretionary power to accept the current proposal as a section 75W Modification. 3.3.2 Protection of the Environment Operations Act 1997 The Protection of the Environment Operations Act 1997 (POEO Act) aims to protect, enhance and restore the quality of the environment in NSW, to reduce risk to human health and promote mechanisms that minimise environmental degradation through a strong set of provisions and offences. An Environmental Protection Licence (EPL) is required from OEH if any of the activities associated with the proposed works are determined to be a ‘scheduled activity’ under Schedule 1 of the Act. The Weston Aluminium’s Kurri Kurri plant currently operates under existing EPL No. 6423, which allows Weston Aluminium to carry out the following operations on the premises:
Table 1 Fee based activity under EPL 6423
Fee Based Activity Scale Aluminium Production (scrap metal) > 10,000 t processed Recovery of hazardous and other waste > 0 t recovered Scrap metal processing 0-100,000 t processed Waste storage – hazardous, restricted solid, liquid, clinical and related waste > 0 t stored and asbestos waste
No change to the current EPL conditions would be required for the construction and operation of the proposed project. However, an application would be made to add cyanide to the air quality monitoring and water sampling regimes.
3.4 Environmental Planning Instruments There are two key environmental planning instruments relevant to the existing facility and the proposed modification: 1) State Environmental Planning Policy No. 33 – Hazardous and Offensive Development (SEPP 33); and 2) Cessnock Local Environmental Plan 2011. The Environmental Planning and Assessment Act 1979 (EP&A Act) and the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation) provide the framework for environmental planning in NSW and include provisions to ensure that proposals that have the potential to impact on the environment are subject to detailed assessment and provide opportunity for public involvement. 3.4.1 State Environmental Planning Policy No.33 – Hazardous and Offensive Development State Environmental Planning Policy No. 33 (SEPP 33) aims to ensure that the consent authority has sufficient information regarding a proposal to determine whether the development meets the criteria for hazardous or offensive development. Conditions to minimise or reduce adverse effects can then be imposed with any consent issued. SEPP 33 requires applications for potentially hazardous or offensive industry to be accompanied by a Preliminary Hazard Analysis (PHA). Applications to carry out hazardous or offensive development, or potentially hazardous or offensive development, are to be advertised for public comment.
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Assessments of the hazards and risks were conducted for the trials (40 tonne and 200 tonne trials). These assessments determined that the operations would not have significant off-site risk implications if the proposed risk mitigation measures were implemented. A PHA study was prepared for this EA (Section 6.4) and concluded that the hazards associated with the proposed storage of SPL would not result in a change to the existing risk profile. 3.4.2 Cessnock Local Environmental Plan 2011 Weston Aluminium’s Kurri Kurri facility is located within the IN3 Heavy Industrial Zone under the Cessnock Local Environmental Plan 2011 (LEP 2011). The objectives of the Zone are: - To provide suitable areas for those industries that need to be separated from other land uses; - To encourage employment opportunities; - To minimise any adverse effect of heavy industry on other land uses; and - To support and protect industrial land for industrial uses. The proposed modification is consistent with the objectives of the LEP 2011 and is consistent with the existing approved industrial land use. The LEP 2011 provides that the existing facility with proposed modifications is permissible with consent.
3.5 Basel Convention The Basel Convention aims to control transboundary movements of hazardous wastes and their disposal. The overarching objective of the Convention is to protect human health and the environment against the adverse effects of hazardous wastes. The provisions of the Convention centre around the following principal aims: - The reduction of hazardous waste generation and the promotion of environmentally sound management of hazardous wastes, wherever the place of disposal; - The restriction of transboundary movements of hazardous wastes except where it is perceived to be in accordance with the principles of environmentally sound management; and - A regulatory system applying to cases where transboundary movements are permissible. Historically, SPL has been sent overseas for processing due to the lack of treatment facilities in Australia. Weston Aluminium is offering a domestic solution for the processing of SPL, which will eliminate the need for transport of this hazardous waste offshore.
3.6 NSW 2021: A Plan to Make NSW Number One In 2011 the NSW Government released NSW 2021: A Plan to Make NSW Number One, which is ‘a 10 year plan to rebuild the economy, provide quality services, renovate infrastructure, restore government accountability, and strengthen our local environment and communities. It replaces the State Plan as NSW Government’s strategic business plan, setting priorities for action and guiding resource allocation’ (Department of Premier and Cabinet, September 2011). The NSW 2021 plan was developed to achieve promised results over the medium to long term across five strategy areas: - Rebuilding NSW’s economy; - Returning quality services; - Renovating infrastructure; - Strengthening our local environment and communities; and - Restoring accountability to Government. The strategy to rebuild the NSW economy is most relevant to Weston Aluminium’s project to process SPL. The proposed project will contribute to achieving growth in the NSW economy by utilising local contractors where
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possible for required construction and modifications to the plant. It is also anticipated that an additional 15 staff will be required to those currently employed during the operation of the proposed project. With the recent retrenchments from Weston Aluminium and the local aluminium smelters (both Tomago Aluminium and Hydro Aluminium) the project is timely to recover these skilled resources and provide ongoing employment to the local community in a period of downturn in the aluminium smelting industry.
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4.0 Stakeholder Consultation
4.1 Consultation Undertaken to Date Weston Aluminium consulted with OEH on 21 February 2011, and with DP&I on 28 February and 30 March 2011 in regards to the SPL trials being conducted. During DP&I’s assessment process for the 40 tonne trial, the Department consulted with OEH and Cessnock City Council (CCC) on the proposed trial modification. Neither agency raised any concerns with the proposal. For the 200 tonne trial the Department exhibited the application and received eight submissions on the proposal, six from the public and two from public authorities as follows: - OEH had no objection to the proposal and provided recommended conditions of approval; - CCC had no objection to the proposal provided that the modification complied with predictions and mitigation measures provided in the 200 tonne trial EA; - Tomago Aluminium supported the proposed modification; and - Five submissions were received in objection to the proposal raising concerns for air quality impacts including odour, health impacts, and hazard and risk. Weston Aluminium also consulted with community representatives, industry and regulatory authorities via: - The distribution of a 2-page information letter outlining details of the SPL trials. The letter was sent to local environmental interest groups, Regulatory Authorities and local aluminium smelter representatives on the 26 May 2011; - Two formal information sessions conducted on 8 June and 6 July 2011. These information sessions were held at Weston Aluminium’s Kurri Kurri premises and at the Kurri Kurri Station Hotel, respectively, to ensure that community concerns and questions were adequately addressed within the EA for the 200 tonne trial; and - Formal written response to the Department in response to the submissions received. As part of preparation of this EA, a Stakeholder Information Session was held on 3 April 2012 at the Weston Aluminium’s Kurri Kurri premises. The intent of this session was to provide relevant stakeholders with relevant background information, feedback on the success of the recent 200 tonne processing trial, an overview of the proposed project, and to answer or address any questions or comments arising from the proposed project. The presentation provided at the Stakeholder Information Session, along with the meeting minutes and attendance record, is included in Appendix B.
4.2 Stakeholder Engagement Strategy Weston Aluminium will continue to engage with: - Local environmental interest groups and residents; - Aluminium smelters; and - Regulatory authorities (OEH, DP&I, CCC).
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5.0 Prioritisation of Issues The Preliminary Environmental Assessment (PEA) (AECOM, 2012) provided an initial assessment of potential environmental impacts associated with the project based on existing data and knowledge of the site (including historical performance and compliance during conventional operations and SPL trial activities) and preliminary desktop investigations. A risk analysis was undertaken to rank these issues according to the level of environmental risk.
5.1 Risk Matrix Potential impacts are ranked according to the risk matrix (refer to Table 2) as being High, Medium, Low or Very Low risk to the environment. Potential Consequences: 1) Broad scale environmental impact. 2) Regional environmental impact. 3) Local environmental impact. 4) Minor environmental impact. 5) Insignificant environmental impact. Likelihood of adverse impact: a) Almost certain. b) Likely. c) Possible. d) Unlikely. e) Rare.
Table 2 Risk Matrix
Likelihood of adverse impact A B C D E 1 High High Medium Low Very Low 2 High High Medium Low Very Low 3 Medium Medium Medium Low Very Low Potential Potential
Consequence 4 Low Low Low Low Very Low 5 Very Low Very Low Very Low Very Low Very Low
5.2 Risk Analysis The prioritisation of potential environmental issues related to the proposed project is provided in Table 3. This ranking aims to allow the prioritisation of issues for assessment and does not consider the application of mitigation measures to manage the environmental effects. In all cases, appropriate and proven mitigation measures chosen based on experience with other similar projects would be used to minimise and manage potential impacts identified in this risk analyses. These measures are described throughout Section 6 of this EA and summarised in Section 7.
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Table 3 Risk Assessment Environmental Potential Environmental Issue Consequence Likelihood Ranking Aspect Air Quality and Generation of fugitive emissions and dust 4 D Low Odour Exceedance of existing regulatory 4 D Low compliance stack air emission limits (including particulates and fluoride) GHG Emissions Excessive generation of GHG, including 4 E Very Low carbon dioxide, methane and oxides of nitrogen Soil and Water Spills of raw materials to site catchment and 3 E Very Low pollution of local water ways Noise Exceedance of regulatory compliance noise 3 E Very Low limits Hazard and Risk Potential contact with water and resultant 3 D Low generation of flammable gases Furnace explosion and expulsion of 3 E Very Low raw/product materials Accident during transport causing release of 3 D Low hazardous substance into environment Waste Generation of hazardous waste requiring 3 E Very Low Management disposal Socio-Economic Employment generating opportunity 5 E Very Low Effects Transport Traffic movements still within approved limits 5 E Very Low Visual No change to current operations 5 E Very Low Heritage No change to current facility footprint 5 E Very Low Landuse No change to current facility footprint 5 E Very Low Fauna and Flora No change to current facility footprint 5 E Very Low
5.3 Key Issues Based on the risk analysis presented above and consultation with the DP&I and EPA, the key issues requiring detailed assessment within this EA were identified and include: - Air Quality; - Greenhouse Gas Emissions; - Waste Management; - Hazards and Risk; - Soil and Water; and - Traffic. These key issues are assessed in Sections 6.1 - 6.6 of this EA. Other issues considered to have little or no anticipated impact, include noise, visual amenity, heritage, landuse, flora and fauna, and socio-economic effects. These issues are discussed briefly in Section 6.7.
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6.0 Environmental Impact Assessment
6.1 Air Quality An Air Quality Impact Assessment (AQIA) was prepared for the proposed project. A summary of this assessment is provided below, for further details refer to the AQIA report included in Appendix C. 6.1.1 Existing Environment Ambient Air Quality The Weston Aluminium plant at Kurri Kurri is located within a heavy industrial area, with some residential areas to the south and west of the site. The Hydro Aluminium Smelter is located approximately 2 km north of the site; its buffer zone extends to Weston Aluminium’s northern boundary. The air quality within the area is considered to be typical to that of an industrial area, with existing sources which contribute to air pollution including: - Hydro Aluminium Smelter; - Industrial emissions; - Coal mines; - Emissions from motor vehicles travelling on the local road network; and - Dust and pollens in drier and windier conditions. Emissions from the power stations in the Upper Hunter Valley also affect air quality in the area. It should be noted that Hydro Aluminium closed its Potline No. 1 in February 2012, and hence fluoride loads within the local (and regional) area have dramatically reduced. Representative monitoring data covering a period of time since the closure is yet to confirm this expectation and as such historical monitoring data including all potlines has been used. The EPA operates an ambient monitoring station at Beresfield, which is approximately 16 km east of the Weston Aluminium facility. The Beresfield station monitors levels of sulfur dioxide, nitrogen dioxide and particulate matter (PM10 and PM2.5). Recent EPA monitoring results (refer to Appendix C) show that concentrations of sulfur dioxide and nitrogen dioxide are all well below the EPA ambient criteria. Particulate concentrations, however, have exceeded the 24 hour criteria on a number of occasions, primarily as a result of a major dust storm event in 2009, and other natural events, such as bushfires. The background Fluoride concentration is based on historical measurements made by Hydro Aluminium as reported in previous AQIA’s prepared for Weston (ENSR Australia Pty Ltd (AECOM) report 'Air Quality Impact Assessment, Weston Aluminium Facility Gaseous Fluoride Emissions, Weston NSW' 31 July 2008). Based on these measured values, the 7 day average background HF concentrations were estimated at 0.6µg/m3. All other air pollutants emitted from the operations at Weston Aluminium (refer to Appendix C) are assumed to have low or negligible concentrations in the environment surrounding the Weston facility. Climate The closest meteorological station (Nulkaba) is located approximately 10 km to the west of the Weston Aluminium site. Data from 1966 to March 2012 indicate that average monthly maximum temperatures range from 30.4°C in January (summer) to 17.8°C in July (winter). Annual average relative humidity levels are 72% and 50% at 9:00 am and 3:00 pm respectively. Rain generally falls on 80 days per year with an average recorded rainfall of 765.7 mm. 6.1.2 Potential Impacts Dispersion modelling was undertaken to predict maximum ground level concentrations of pollutants within the modelling domain (I.e. including locations within the site boundary). Results from the dross and SPL processing were quite similar, with the main differences noted in the predicted carbon monoxide concentrations (which were higher for SPL processing but still well below the assessment criteria). Additionally, the SPL will generate cyanide emissions not present during dross processing; however these emissions are well below the assessment criterion.
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Predicted ground level pollutant concentrations were well below the impact assessment criteria for most pollutants. Exceedances were, however, predicted for 24 hour PM10 and fluoride. For these pollutants, further analysis of the concentrations at the surrounding sensitive receptors was undertaken. Concentrations of fluoride predicted at the closest sensitive receptor (situated at the RSPCA dog shelter, approximately 200 m to the east of the Weston Aluminium eastern boundary) are provided at Appendix C. The predicted fluoride concentrations fell below the assessment criteria at this location.
For the short term PM10 predictions, a contemporaneous assessment was undertaken to further assess PM10 dust concentrations at the closest sensitive receptor, and determine whether the processing of SPL at the Weston facility would result in additional exceedances of the 24 hour criterion above those attributable to the elevated ambient concentrations.
The contemporaneous assessment was undertaken by summing the predicted 24 hour average PM10 concentration for each day in the modelled year of 2005 with the corresponding measured 24 hour average PM10 concentrations at the Beresfield OEH monitoring station. No additional exceedances of the PM10 criterion were predicted. On the basis of the contemporaneous assessment, no adverse impacts are expected to result from the processing of the SPL.
In order to compare the 1 hour metals results against the EPA assessment criteria, the contribution of each individual species was calculated based on the proportion of each species in the emissions. No exceedances of the metals criteria were predicted for either dross or SPL processing.
6.1.3 Mitigation Measures As the proposed project is not expected to result in an unacceptable change to the expected emissions from the facility and is not expected to result in adverse impacts on the surrounding environment, no additional mitigation measures to those already in place at the Weston Aluminium’s facility are necessary.
6.2 Greenhouse Gas Emissions The AQIA (Appendix C) includes an assessment of the greenhouse gas emissions anticipated as a result of the proposed project. A summary of this assessment is provided below (refer to Appendix C for further details). 6.2.1 Existing Environment The Weston Aluminium facility is subject to the reporting requirements of the National Greenhouse and Energy Reporting (NGER) Act 2007. Reported greenhouse gas emissions for the 2009 -10 and 2010 -11 periods are provided in Table 4.
Table 4 Greenhouse Gas Emissions and Energy Use, 2009 - 2011 Scope 1 Emissions Scope 2 Emissions Total Emissions (Scope 1 + 2) Year (t CO2-e) (t CO2-e) (t CO2-e) 2009 -10 7,819 4,789 12,608 2010 -11 7,468 4,785 12,252
Greenhouse gas emissions data for NSW for 2009 (the most recent available data) are summarised in Table 5. As shown, total NSW greenhouse gas (GHG) emissions were 160.5 Mt CO2-e, which represented 28% of Australia's total emissions (564.5 Mt CO2-e). The principal source of GHG emission is from the electricity/gas/water sector, which accounts for 40 % of total NSW GHG emissions (64.3 Mt CO2-e). Other major sources are agriculture (15%) and mining (13%). Emissions from manufacturing, including metal production, accounted for 12% of NSW total emissions in 2009 (approximately 19 Mt CO2-e).
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Table 5 NSW Greenhouse Gas Emissions by Economic Sector, 2009
Sector Gg (1,000 Tonnes) Percentage of Total NSW Emissions (%) Div A Agriculture, forestry, fishing 24,169.72 15 Div B Mining 21,432.14 13 Div C Manufacturing 19,028.25 12 Div D Electricity, gas, water 64,287.69 40 Div E Construction 326.47 0 Div F-H, J-Q Commercial Services 5,427.99 3 Div I Transport & storage 10,473.90 7 Residential 15,418.98 10 Total of all Economic (ANZSIC) Sectors 160,565.13 100
Source: Australian Greenhouse Emissions Information System, Department of Climate Change and Energy Efficiency. (Tue Apr 03 16:53:07 2012); http://ageis.climatechange.gov.au/ANZSIC.aspx; accessed 3 April 2012 © 2010 Department of Climate Change and Energy Efficiency.
6.2.2 Potential Impacts The facility has been operating at a reduced rate of input to the rotary furnace for the past few years. As electricity use is associated with furnace inputs, the electricity consumption at the facility has, therefore, also been lower than usual. The proposed processing of SPL would bring the facility back up to its typical rotary furnace inputs of 40,000 tonnes per annum (current approved limit). The estimated Scope 2 emissions (electricity consumption) associated with full-scale operation of the facility (of either SPL or dross) would be approximately 19% higher than 1 those reported in 2010-11, or equivalent to approximately 5,874 t CO2-e per year . Scope 1 emissions would similarly be expected to increase over existing levels, but be in the same order as those associated with typically full-scale operation. Assuming a similar 19% increase in emissions, the Scope 1 emissions associated with full- 2 scale operation would be in the order of 8,886.9 t CO2-e per year , resulting in total greenhouse gas emissions in the order of 14,760.9 t CO2-e per year (0.0148 Mt CO2-e per year) for the facility. Weston Aluminium’s predicted emissions represent approximately 0.078% of the total NSW manufacturing emissions. As such, the proposed modification is not expected to significantly change NSW or Australian emissions levels. 6.2.3 Mitigation Measures Practices currently in place at the refinery to reduce GHG emissions include the routine tuning of furnace burners, which increases burner efficiency and reduces GHG emissions. Additionally, emissions of unburned methane and other natural gas constituents are unlikely to occur due to burner tuner and set-up, and the furnace temperature proposed for the project. No further mitigation measures are necessary for the proposed project.
6.3 Waste Management 6.3.1 Existing Environment SPL material is a hazardous waste product generated as a result of primary aluminium production. Currently the only disposal options available to primary aluminium smelters are to stockpile the waste SPL material or transport it overseas for treatment. SPL material has the same dangerous goods classification as aluminium dross, which is Class 4.3 Package Group III material. Weston has implemented material handling and storage strategies to ensure appropriate handling of the material throughout all production steps. These would be implemented for the proposed project, as outlined in Section 6.3.3.
1 Based on the July 2011 National Greenhouse Accounts Factors emission factor of 0.89 kg CO2-e/kWh. 2 Assuming a 19% linear increase in emissions from 2010-11, as data on projected fuel use were not available at the time of preparation of this report.
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The dominant wastes generated within the existing Weston facility during dross processing are dust fines collected from each of the baghouse dust collectors. Dust fines are collected into bulka bags and stored on site prior to beneficial reuse in the steel making and foundry industries, and are thereby diverted from landfill disposal. Dust fines for which a beneficial reuse has not yet been realised are currently disposed of, and samples of these wastes are routinely collected and analysed to demonstrate conformance with requirements of the Specific Immobilisation Approval and in conjunction with routine site disposal protocols. Other wastes produced on site include sewage, vehicle wash-down waters and general office waste. 6.3.2 Potential Impacts The proposed project would create an opportunity for domestic treatment of a hazardous waste product, thereby processing it into an alternative raw material that has value. The project would reduce the need to ship hazardous wastes internationally, which benefits the environment and the waste producer. The proposed project could generate hazardous waste should processing of the SPL material fail to result in destruction of cyanide. Should this occur, the material would be captured by Quality Assurance and Control processes and returned for reprocessing. Previous trials (refer to Section 1.3.3 of this EA) have demonstrated that the proposed SPL treatment process is successful in reducing cyanide content to negligible levels, and it is anticipated that cyanide contamination will not represent an issue. There would be no other additional wastes generated by the proposed project. 6.3.3 Mitigation Measures The following mitigation measures (existing and proposed) would be implemented to minimise the potential waste management issues resulting from the proposed project: - SPL material would be delivered to the facility by a Dangerous Goods Licensed Contractor; - All raw material truck delivery loads would be covered by tarpaulin (similar to dross deliveries) or via tautliner to prevent spillages; - All raw materials would be delivered in a dry state, and hence residues of SPL within storage bags would be negligible; - No deliveries would occur during wet weather; - The unloading and storage of untreated and processed material would be within existing enclosed buildings; - Existing fabric filter baghouses would be utilised for the control and removal or particulate that may arise during the unloading and loading processes; - All operations would be performed within enclosed buildings to mitigate against external spills; - Should a spill occur, site personnel would recover materials in accordance with established spill response procedures. Spilt material would be returned to storage for processing (i.e. not disposed of); and - Existing pollution control systems would be utilised for the proposed project.
6.4 Hazard and Risk A Preliminary Hazard Analysis was prepared for the proposed project. A summary of this assessment is provided below, for further details refer to the PHA report included in Appendix D. 6.4.1 Existing Environment Dross is currently delivered to site by truck from smelters both local and interstate. The dross is unloading into a dedicated building (Aldex Building) and stored in eight dedicated bays within the building. Dross is recovered using a front end loader and processing using a crushing and screening plant. The crushed and screened dross is then fed by conveyor to the main building where it is loaded to a furnace and heated to extract the aluminium metal. Metal is tapped from the furnace and cast, while ash residues generated in the furnace are processed within a cooling circuit. The cast material is then sold to markets. The remaining non-metallic ash material, known as Aldex, is bagged or briquetted and sold to the steel and building materials industry.
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The following safeguards are installed at the Weston Aluminium site: - Dust control – dust extraction on all equipment and storage bays, baghouse units and dust control curtains in front of the storage bays; - Bag-House Units – fitted with high differential pressure alarms, spare bags sets, pulse jet cleaning of bags, bag breakthrough detection (real-time, continuous particulate monitoring devices) and alarms; - Furnace – real-time, continuous temperature monitoring and high thermal mass in the furnace; and - Spill Retention – fully sealed and bunded buildings for the storage of SPL (no releases outside the buildings in the event of a spill). 6.4.2 Potential Impacts Proposed SPL Processing Operation It is proposed to deliver SPL to site using the same process and Dangerous Goods licensed contractors as for the dross deliveries. The SPL will be delivered to the storage bays where it will be held until processing is performed. The SPL will be crushed and screened and fed to the main processing building using the existing covered conveyor and/or transferred to the main processing building via bins. The SPL will be heated in dedicated furnaces to thermally oxidise and destroy the cyanide in the material. Once the cyanide has been destroyed, the processed SPL will be removed from the furnace and cooled in a dedicated rotary cooler (i.e. jacketed cooling). A water spray cooling system will also be installed within the rotary cooler to assist in the final cooling of the product. The material will then be bagged and transported to markets. Properties of SPL SPL is predominantly carbon and refractory materials which are formed to line the base of the aluminium smelting pot at the smelter. In contact with water SPL may produce hydrogen, acetylene, methane and ammonia, and in contact with acid, hydrogen sulphides or hydrogen cyanides may be formed. However, there are no acids stored at the Weston site and no potential for this incident to occur. The dust generated as part of handling SPL could result in irritation to eyes and mucous membranes, mainly through mechanical impacts on these areas rather than chemical. The fluorides in the SPL result in chronic rather than acute impacts and the relatively small quantity of cyanide (<0.7%) may result in environmental impacts if release beyond the immediate containment area. Properties of Product The treated product is not classified as a Dangerous Good (DG), as the majority of constituent components in the material are not listed as a DG and the single component classified as a DG, sodium fluoride, is in low quantity (<8% on average). However, the product dust may cause irritation to eyes and mucous membranes, mainly by mechanical action rather than the chemical properties of the constituent materials. Hazard Analysis The hazard analysis identified three scenarios that had the potential to develop incident consequences that could adversely impact offsite. These incidents were: - Storm damage to the storage and process buildings resulting in roof damage, water ingress and hydrogen generation. Ignition of hydrogen accumulation could result in explosion, however, the analysis showed that there is insufficient hydrogen generated and as the scenario included the building roofs being blown off, there is no entrapment of hydrogen in the buildings. - Storm damage to the Aldex building resulting in roof damage, water ingress and ammonia/acetylene/ methane development. The analysis showed that the quantity of water ingress over 1 hour did not result in sufficient ammonia generation to reach LC50 concentration levels and that the weather conditions would result in rapid dispersion of the gas failing to reach harmful levels. The quantities of water required to generate sufficient acetylene/methane, so that the concentration exceeded LEL, were considerably higher than would enter the building during the postulated storm event. It is noted that the MSDS for SPL does not list aluminium nitride or aluminium carbide as a constituent of SPL, however, some contamination of the SPL may occur during the aluminium smelting operation. The selection of 1% contamination (the level used in this study) is considered very conservative as in reality only trace elements would be present in the total SPL material.
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- Storm damage to the process and storage buildings resulting in roof damage, water ingress and dissolving of cyanide into the storm-water, resulting in the potential for contaminated water to escape offsite. The analysis identified that the buildings are bunded with spill containment capacity sufficient to hold the estimated storm-water ingress without release off-site. As the assessed hazard and risk impacts are anticipated to be negligible, the cumulative impact as a result of existing risks does not change the existing risk profile. Hence, the risk criteria published by the NSW DPI in HIPAP No.4 is not exceeded and the facility remains classified as potentially hazardous and not hazardous and would therefore be permitted to continue operations processing dross and SPL in the existing land zoning. 6.4.3 Mitigation Measures Based on the analysis conducted in the PHA study (refer to Appendix D), the hazards associated with the proposed storage, handling and processing of SPL at the Weston aluminium facility does not result in a change to the existing risk profile, hence, the risk criteria published by the NSW DPI in HIPAP No.4 (Ref.4) is not exceeded and the facility remains classified as potentially hazardous and not hazardous and would therefore be permitted to continue operations processing dross and SPL in the existing land zoning. The following process safeguards exist and/or are proposed: - Dust Control – storage and handling areas within the Aldex and Process buildings are fitted with dust extraction units that deliver extracted dust to bag-house units (existing); - Dust Control – curtains installed across the front of the dross storage bays to minimise dust escape into the buildings (existing); - Dust Control – Truck access doors across the entrance to the building can be closed to prevent dust escape whilst tipping SPL (existing); - Building Pressure Control – all buildings are maintained at slightly negative pressure to prevent dust escape from the buildings (existing); - Building Dust Control – all buildings are fitted with dust extraction systems that report to bag-house units to extract any dust collected within the building internal atmosphere (existing); - Equipment Dust Control – all equipment (e.g. crushers and material transfer stations on conveyors) are fitted with dust extraction that reports to bag-house units (existing); - Bag-houses – all bag-houses are fitted with real-time, continuous particulate monitoring systems (indicative of failed bags) (existing); - Bag-houses – all bag-houses are fitted with high differential pressure detection to activate bag switch-over and clogged bag cleaning processes (existing); - Furnace Operations – furnaces are monitored for real-time, continuous temperature monitoring and control (existing); - Furnace Thermal Load – the furnace contains a high thermal load (also aided by the refractory nature of feedstock materials) and loss of furnace heating would not result in an immediate drop in furnace temperature. The furnace would remain at elevated temperatures for an extended period (many hours) without further heating (existing); - Treated SPL Cooler – cooler casing is steel, which eliminates the potential for failure of the casing from overheating (note that steel will not fail at 600°C) (proposed); and - Water Ingress Control – fully sealed and bunded buildings to prevent water ingress and impact of water on SPL (existing).
6.5 Soil and Water 6.5.1 Existing Environment The plant is located within the Hunter River catchment. Several creeks and drainage lines occur in the close vicinity of the plant with Swamp Creek located 200 m north of the premises. Swamp Creek flows generally in a north-easterly direction and drains directly into Wentworth Swamps approximately 5 km north east of the plant. Wentworth Swamps were identified as significant wetlands in the Cessnock Wide Settlement Strategy (2003).
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Swamp Creek catchment is considered degraded due to relatively high levels of development. Swamp Creek usually has elevated pH, turbidity, conductivity, nitrate and phosphate levels, and contains low level faecal contamination. As such, water quality is generally unsuitable for potable supply, yet suitable for agriculture uses and the maintenance of aquatic ecosystems (Shearer, 1997). The soils on the site are classified as belonging to the Neath Soil Landscape. The main soil types are grey solodic soils and yellow solodic soils, which are classified as being moderately to highly erodible (URS, 2001). 6.5.2 Potential Impacts The proposed project would be undertaken within existing facilities on site. There is no proposed change to the existing site footprint, and no excavations will occur. There would be no construction activities associated with the proposed project and as such there would be no immediate impact on soils and local water quality. SPL material has the same dangerous goods classification as aluminium dross. SPL contains contaminants such as aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants. Large quantities of SPL will be stored on site as part of the project, and there is a risk of stormwater contamination through runoff and rainfall events, potentially leading to downstream contamination of soils and surface water resources. There is also potential for accidental fuel and oil spills to occur on site during operation of plant and equipment. However, Weston Aluminium already has in place a first flush stormwater control system on site which consists of a drainage network, pond storage and constructed wetland system. The Stormwater control system segregates off-site stormwater entering the site, uncontaminated on-site stormwater and potentially contaminated on-site stormwater as follows: - Off-site stormwater entering the site is directed to a grass swale catch drain and directly discharged into Swamp Creek. - Uncontaminated on-site stormwater is directed to a swale pond, allowed to settle, and then discharged directly to the wetland. - Potentially contaminated first flush water is fed through a constructed wetland to remove contaminants, and the resulting clean water is irrigated on site from the main pond storage, which holds the water from the wetland system and acts as a first flush containment facility for the development. Annual water quality monitoring of the Main Pond is undertaken in accordance with EPL 6423. Samples are taken to monitor the concentrations of aluminium, fluoride, total suspended solids, conductivity and pH and the results are reported to OEH annually. Weston’s existing stormwater management measures, combined with the additional controls identified below, would be implemented for the proposed project. Potential impacts to soil and water quality as a result of the proposed project would therefore be minimal. 6.5.3 Mitigation Measures The following mitigation measures would be implemented to minimise the potential impacts to soil and water quality resulting from the proposed project: - SPL material would be managed under the same operating system as for aluminium dross; - All raw material truck delivery loads would be covered by tarpaulin (similar to dross deliveries) or via tautliner to prevent spillages; - No deliveries would occur during wet weather; - All operations would be performed within enclosed buildings to mitigate against external spills; - Should a spill occur, site personnel would recover materials in accordance with established spill response procedures. Spilt material would be returned to storage for processing (i.e. not disposed of); and - The water quality and air quality monitoring programs would be modified to incorporate cyanide monitoring.
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6.6 Transport 6.6.1 Existing Environment Access to site is currently undertaken via Mitchell Avenue. The 2001 EIS estimated that there would be approximately 23 heavy vehicles (46 movements) and approximately 18 light vehicles (36 movements) per day. However, recent observations at the facility indicate that there are approximately 10 trucks entering and exiting the site each day (20 truck movements). As required under the existing development consent, Weston Aluminium ensures that haulage is via Main Road 588 (Renshaw Drive) when travelling towards the Sydney- Newcastle Freeway (F3), rather than via Main Road 195 (Kurri Kurri-Mulbring Road) and Main Road 220 (Lake Road). 6.6.2 Potential Impacts Access to the site via Mitchell Avenue would remain unchanged for the proposed project. The proposed project would result in an additional four trucks entering and exiting the site (eight heavy vehicle movements) per day for the delivery of the SPL raw materials to the site and dispatch of product from the site. This increase is minimal, given that existing truck movements are currently well below previously approved estimates of truck movements. There would also be an increase of approximately 10-15 light vehicles accessing the site per day due to the expected increase in staff numbers required for the project operations. All parking generated by the development would be accommodated on site and no staff vehicles or vehicles associated with the operation would park on the public road system. The effects of the project on transport and road traffic are therefore expected to be minimal. 6.6.3 Mitigation Measures The following mitigation measures would be implemented to minimise potential traffic impacts resulting from the proposed project: - All haulage would be via Main Road 588 (Renshaw Drive) when travelling towards the Sydney – Newcastle Freeway (F3); and - All trucks delivering and removing material would be filled to capacity to minimise required truck movements. Further, it is anticipated that truck movements will occur via the Hunter Expressway (following completion of its construction), thereby alleviating traffic movements within the Kurri Kurri township.
6.7 Other Environmental Issues Operational noise at the facility will be generated as a result a truck movements to and from the site, and from operation of existing onsite plant and equipment. The facility is located within a heavily trafficked industrial area, which is subject to a variety of noise sources. Noise monitoring indicates that the facility is currently operating within the licence limits. Given that existing plant and equipment will be used for the project (with the exception of one new rotary cooler to be installed within the Plant building), and that overall truck movements will remain within the existing approval limits, it is expected that noise levels will be equivalent to existing levels and therefore within EPL limits. Weston Aluminium is not seeking a change to existing Environment Protection Licence noise limits. Further assessment of noise impacts is therefore not required. Weston Aluminium is a strong employment generator and procurer of local contractor services in the local community since 1998. Expansion of the facility has utilised local contractors where possible and local employment has translated to funds being spent in the community. The proposed project would utilise local contractors where possible for required modifications to the plant. It is also anticipated that an additional 15 staff would be required during operation of the proposed project. With the recent retrenchments from Weston Aluminium and local aluminium smelters, the project is timely to recover these skilled resources and provide ongoing employment to the local community in a period of downturn in the aluminium smelting industry. The proposed project would therefore have a positive impact on the community through employment generation, and a detailed socio-economic assessment is not required. Other environmental issues considered include impacts to visual amenity, heritage values, landuse, and flora and fauna. No impact on these environmental issues is anticipated as there is no change to the existing site footprint, no construction outside of buildings and no change in operation of the facility.
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7.0 Statement of Commitments In accordance with the Director-General’s Requirements (Appendix A), the following draft Statement of Commitments (Table 6) states Weston Aluminium’s environmental commitments and provides a summary of the environmental management measures to be undertaken for the project. Weston Aluminium commits to the preparation and implementation of the environmental management and mitigation measures detailed in the Statement of Commitments for the proposed project.
Table 6 Statement of Commitments Issue Mitigation Measures
Air Quality As the proposed project is not expected to result in an unacceptable change to the expected emissions from the facility and is not expected to result in adverse impacts on the surrounding environment, no additional mitigation measures are proposed. Monitoring of cyanide will be included in existing emissions monitoring regimes for Stack 1.
Greenhouse Gas Practices currently in place at the plant to reduce GHG emissions include the routine tuning of furnace burners, which increases burner efficiency and reduces GHG emissions. No further mitigation measures are necessary for the proposed project.
Waste Management - SPL material would be delivered to the facility by a Dangerous Goods Licensed Contractor. - All raw material truck delivery loads would be covered by tarpaulin (similar to dross deliveries) or via tautliner to prevent spillages. - All raw materials would be delivered in a dry state, and hence residues of SPL within storage bags would be negligible. - No deliveries would occur during wet weather. - The unloading and storage of untreated and processed material would be within existing enclosed buildings. - Existing fabric filter baghouses would be utilised for the control and removal or particulate that may arise during the unloading and loading processes. - All operations would be performed within enclosed buildings to mitigate against external spills. - Should a spill occur, site personnel would recover materials in accordance with established spill response procedures. Spilt material would be returned to storage for processing (i.e. not disposed of). - Existing pollution control systems would be utilised for the proposed project. Hazards and Risk - Dust Control – storage and handling areas within the Aldex and Process buildings are fitted with dust extraction units that deliver extracted dust to bag-house units. - Dust Control - curtains installed across the front of the dross storage bays to minimise dust escape into the building. - Dust Control - Truck access doors across the entrance to the building can be closed to prevent dust escape whilst tipping SPL. - Building Pressure Control – all buildings are maintained at slightly negative pressure to prevent dust escape from the buildings. - Building Dust Control – all buildings are fitted with dust extraction systems that report to bag-house units to extract any dust collected within the building internal atmosphere. - Equipment Dust Control – all equipment (e.g. crushers and material transfer stations on conveyors) are fitted with dust extraction that reports to bag-house units. - Bag-houses – all bag-houses are fitted with real-time, continuous particulate monitoring systems. - Bag-houses – all bag-houses are fitted with high differential pressure detection to activate bag switch-over and clogged bag cleaning processes. - Furnace Operations – furnaces are monitored for real-time, continuous temperature monitoring and control. - Furnace Thermal Load – the furnace contains a high thermal load and loss of furnace heating would not result in an immediate drop in furnace temperature. The
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Issue Mitigation Measures
furnace would remain at elevated temperatures for an extended period (many hours) without further heating. - Treated SPL Cooler – cooler casing is steel, which eliminates the potential for failure of the casing from overheating (note that steel will not fail at 600°C). - Water Ingress Control - Fully sealed and bunded buildings to prevent water ingress and impact of water on SPL. Soil and Water - SPL material would be managed under the same operating system as for aluminium dross. - All raw material truck delivery loads would be covered by tarpaulin (similar to dross deliveries) or via tautliner to prevent spillages. - No deliveries would occur during wet weather. - All operations would be performed within enclosed buildings to mitigate against external spills. - Should a spill occur, site personnel would recover materials in accordance with established spill response procedures. Spilt material would be returned to storage for processing (i.e. not disposed of). - The water quality monitoring program would be modified to incorporate cyanide monitoring. Traffic - All haulage would be via Main Road 588 (Renshaw Drive) when travelling towards the Sydney – Newcastle Freeway (F3). - All trucks delivering and removing material would be filled to capacity to minimise required truck movements. - Truck movements could occur via the Hunter Expressway (following completion of its construction), thereby alleviating traffic movements within the Kurri Kurri township.
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8.0 Conclusion This environmental assessment presents details of the Proposal, assesses the existing natural and social environments, describes the potential impacts on the environment and presents safeguards to minimise and/or avoid these identified impacts. The proposed project offers a solution for the recycling of SPL generated by aluminium smelters, which has traditionally been stockpiled and/or exported overseas for treatment. The treatment and processing of SPL on a commercial scale by Weston Aluminium provides an alternative to the international transport of this hazardous material, in doing so securing the sustainability and growth of the domestic aluminium industry. The proposed project would result in improved market versatility, product handling and a reduction of material losses from the productive economy. The commercial scale treatment and processing of Second Cut SPL is proposed to be conducted at Weston Aluminium’s existing Plant located at Kurri Kurri. The storage and processing of SPL will be undertaken within existing storage buildings and processing through existing rotary furnaces. The footprint of the development would not be changed as a result of the proposed project. The current development consent authorises Weston Aluminium to process up to 40,000 tonnes of dross aluminium and process up to 35,000 tonnes of scrap aluminium metal per year on site. Dross inputs are currently in the order of 10,000-15,000 tonnes per annum, which is well below the approved capacity. Under the proposed project, it is envisaged that (ultimately) 15,000-25,000 tonnes per annum of SPL processing will be undertaken on the premises. As such, the combined dross and SPL processing tonnage will comply with the existing approval conditions. Air quality and PHA investigations, along with the assessment of potential waste, soil and water, and traffic impacts that were undertaken as part of this EA revealed that the potential impacts of the proposed project would not be significant. With the implementation of the mitigation measures proposed, it is expected that impacts would be eliminated or minimised. No change to Weston Aluminium’s existing EPL limits will be required for the project. Additionally, the proposed project would have a positive impact on the community through employment generation.
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9.0 References Cessnock City Council (2003) City Wide Settlement Strategy, Cessnock City Council, NSW. DCC (2009) State and Territory Greenhouse Gas Inventories 2007: Australia's National Greenhouse Accounts, Department of Climate Change, Canberra, www.climatechange.gov.au/inventory/2007/stateinv.html DECCW (2009) Waste Classification Guidelines – Part 1 – Classifying Waste, NSW Department of Environment, Climate Change and Water, Sydney, December 2009. Department of Premier and Cabinet (September 2011) NSW 2021: A Plan to Make NSW Number One. Shearer, N. (1997) The Cessnock City Council Local Government Area Catchment Study, prepared for Cessnock City Council (unpublished). URS (2001) Additions to the Kurri Kurri Aluminium Refining and Recycling Facility – Environmental Impact Statement, prepared for Weston Aluminium, 23 April 2001.
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Appendix A
Director-General's Requirements
10 May 2012 AECOM Environmental Assessment Spent Potlining Processing A-1
Appendix A Director-General's Requirements
10 May 2012
AECOM Environmental Assessment Spent Potlining Processing
Appendix B
Stakeholder Information Session: Documentation
10 May 2012 AECOM Environmental Assessment Spent Potlining Processing B-1
Appendix B Stakeholder Information Session: Documentation
10 May 2012 SPL Processing Trial & Forward Strategy
Stakeholder Information Session
3 April 2012
Agenda
1. Welcome & Apologies
2. Weston Aluminium Overview
3. Environmental Controls
4. What is SPL?
5. Brief History of Trial Activities
6. 200Mt Trial Performance
7. Forward Strategy
8. Questions and Comments?
3 April 2012
1 Weston Aluminium Company Overview
Kurri Kurri, NSW operations • Aluminium refining and recycling facility • Dross, scrap metal and other aluminium-bearing wastes • Purpose-built control features • Proven environmental compliance track record • Non-salt technology • Focus on quality, efficiencies, innovation, safety and environment Solid, alloyed aluminium products •Sows • Deoxidant puck • Specialist alloyed ingot Company Diversification • Alternative Materials Division established 2007 • Founder of Australasian Industrial Ecology Network • Exploring other business opportunities (e.g. SPL)
3 April 2012
Company Vision
To Be The Most Innovative Industrial Ecology-Focused Product & Services Company In The World
3 April 2012
2 Company Mission
To provide innovative customer solutions via effective resource recovery, delivering results in a sustainable and profitable manner
3 April 2012
Environmental Controls
• Specially designed gaseous HF & Pt controls, and continuous monitoring systems • Regime of regular independent NATA stack emission testing for particulates, heavy metals, pops, acid gases and fluoride • Wash-down pad for mobile equipment, with oil separator • First Flush System, onsite reticulation & water monitoring • Independent External Environmental Audits • Independent External Hazard Audits • Environmental Management System
3 April 2012
3 What is Spent Potlining?
What is Spent Potlining? • By-product of the primary aluminium smelting process, generated locally by Tomago Aluminium and Hydro Aluminium •1st Cut (carbon cathode) & 2nd Cut (refractory brick lining) • Constituents • Inherent mineralogical value • Significant issue to worldwide Al industry viability • Treatment required prior to beneficial reuse/disposal
What is currently being done? • Warehouse stockpiling • Limited domestic treatment & reuse • Overseas treatment
3 April 2012
Research & Development?
R&D since 2005 • Appreciation of local smelter activities and issues • Technology appraisal NZ Trials Laboratory-scale Treatment Trials (Feb 2010) • Demonstration of treatment success • Demonstration of air emissions controls 8Mt rotary furnace Trial (Aug 2010) • DC Modification and EPL Variation approval • Verification of ‘fit for purpose’ infrastructure • Demonstration of environmental control performance • Air emissions all compliant with existing regulatory limits Laboratory furnace optimisation Trials (Mar 2011) • Optimisation of treatment temperature and residence time 200Mt rotary furnace Trial (Jan – Mar 2012) • DC Modification and EPL Variation approval • Verification of ‘fit for purpose’ infrastructure • Large-scale demonstration of environmental control performance • Air emissions all compliant with existing regulatory limits • End-use Customer evaluation – emerging markets and demand
3 April 2012
4 Current 200Mt Trial Monitoring Outcomes
• ~180Mt of 2nd Cut SPL sourced from Tomago Aluminium
• Trial processing over 3-months
• Verification of technology & infrastructure compatibility on large-scale
• Safety performance confirmed - HSP implementation, hygiene monitoring performed
• Compliant hygiene and environmental performance for all parameters
• Independent NATA-certified emission testing
• Real-time continuous Fluoride and Particulate monitoring
• Generation of treatment product quantities for reuse assessment & evaluation
3 April 2012
Current 200Mt Trial Monitoring Outcomes
Trial Trial Trial Emission Regulatory Emission Monitoring Emission Emission Monitoring Compliance Parameter Monitoring Monitoring (NZ Trial; Limits (2010) (2012) 2010) Total Particulate Matter <0.12 8.9 0.23 25 Fine Particulate Matter ND 0.24 0.76 NL Hydrogen Chloride ND 0.95 1.1 400 Chlorine ND 0.42 1 NL Particulate Fluoride 0.070 0.027 0.013 NL Gaseous Fluoride 0.072 0.38 0.16 2 Oxides of Sulfur ND <9.4 0.9 100 Total Hazardous Substances (metals) ND 0.017 0.025 10 Total Polycyclic Aromatic Hydrocarbons ND 0.74 0.005 NL Volatile Organic Compounds ND <0.17 <0.00019 NL
Total Oxides of Nitrogen (as equiv. NO2) ND 4 0.7 2500 Carbon Monoxide ND 5 19 100 Cyanide 0.068 <0.061 <0.0082 NL Oxygen (%) 3.1 20.7 20.09 NL Temperature (oC) 53 52.4 92.0 NL Velocity (m/s) 5.6 14 14 NL Flowrate (m3/s) 0.36 30 30 NL Dry Gas Density (kg/m3) 1.31 1.29 1.29 NL
Notes: All values are expressed in mg/m3 (0oC, 1 atm, dry gas) unless otherwise defined NL – Not Listed ND – Not Determined
3 April 2012
5 Current 200Mt Trial Monitoring Outcomes
3 April 2012
Forward Strategy
• Stage 1: Seeking approval for commercial-scale 2nd Cut SPL processing operations
• Preliminary Environmental Assessment
• Maintaining existing (approved) scale of activity, including:
• Input tonnage
• Hours of operation
• Air emission compliance limits (addition of cyanide monitoring)
• Transport movements and routes
• Minor plant and infrastructure additions (cooler)
• Additional staff recruitment (15 personnel)
• Maintaining best-practice environmental controls & compliance
• Stage 2: Potential future application for processing all SPL inputs (mixed SPL)
3 April 2012
6 Outline of Proposed Processing
ENVIRONMENTAL CONTROLS & PERFORMANCE
Transportation by DG-licenced Contractor
Storage in purpose-built storage bays (under cover, bunded & ventilated)
Thermal treatment and processing in existing rotary furnaces
Best-practice emission controls
Real-time, continuous particulate and fluoride monitoring systems
NATA-certified laboratory testing
Beneficial Reuse
3 April 2012
QUESTIONS / COMMENTS?
QUESTIONS / COMMENTS?
3 April 2012
7 Afternoon Presentation to Rod Doherty 2:30pm 3rd April 2012
Attendees: Rod Doherty (Kurri Kurri District Business Chamber Inc), Chris McClung (Weston Aluminium), Ian Burns (Weston Aluminium), Graham Snedden (Weston Aluminium), Ben McDonough (Weston Aluminium)
RD
• Attending a meeting this afternoon at Cessnock City Council to discuss the LEP – requested earlier session • 17th April will attend the major projects committee meeting & could facilitate a meeting with business leaders regarding SPL • Is surprised that the other dross processors still use salt or ‘reduced salt’ process rather than non-salt (Weston Aluminium) or plasma arc processes • Sought clarification on what happens to the cyanide on treatment of SPL o WA: The cyanide is effectively oxidised in the rotary kiln, this is the least of the concerns for the project as the process and technology is sound and well- understood, the real challenge lies in developing end use markets for the treated material • Question: Will Weston Aluminium operate on a ‘just in time’ storage regime? o WA: Yes, storage times should be ~1 week on average to allow for minimum accumulation of material on site • Question: Where does Weston Aluminium fit with Regain? o WA: Weston Aluminium is complementary to Regain’s process. Regain treats first cut SPL predominantly as there is a market for the processed carbon. The second cut SPL consisting of refractory brick requires some further market development and this is where Weston Aluminium believes it has opportunities. Traditionally, cement makers have accepted small quantities of treated SPL although Weston Aluminium believes this market is decreasing o Question: Will SPL supplement blue metal quarries and virgin materials? WA: Potentially so, depending on the chemical/physical characteristics of SPL compared to the virgin material and whether it is fit for purpose • Question: Is Tomago Aluminium the easiest Primary Smelter to deal with and is there any difference to Hydro? o WA: No difference, aside from quantity of SPL material • Is aware of the local market size for treatment of SPL with Hydro and Tomago primary aluminium smelters. Also aware of possibility for installing purpose built facilities for SPL treatment on-site at these locations • Question: What total tonnage/truck movements per day will result from the SPL project o WA: Weston Aluminium will effectively return to full operations after reductions due to the GFC and recent contractual changes, this will mean approximately 24,000 tonnes per year or 3 trucks per day • Question: Can the trucks coming from Tomago Aluminium or going to Port utilise the Hunter Expressway once this is built? o WA: Certainly, this will mean no truck movements to/from Weston Aluminium will need to go through the Kurri Kurri town centre once the Expressway is built
Scheduled Stakeholder Information Session – 4:00pm 3rd April 2012
Attendees: Barry Arens (Hydro Aluminium), Alex Fry (Hydro Aluminium), Richard Forbes (Cessnock Council), Chris McClung (Weston Aluminium), Ian Burns (Weston Aluminium), Graham Snedden (Weston Aluminium), Ben McDonough (Weston Aluminium)
Apologies: NSW Department of Planning & Infrastructure, NSW Office of Environment & Heritage, Friends of Tumblebee, Rod Doherty (Kurri Kurri District Business Chamber Inc), Kurri Kurri Landcare Group, Kurri Kurri Tidy Town, Tomago Aluminium, Weston Heritage & Tidy Town
RF
• Question: What are the reuse opportunities? o WA: Most of 1st cut SPL is reused currently as fuel, 2nd cut SPL is not as widely reused. Cement industry in Australia is contracting and cement makers charge high fees for accepting this material, the market in Australia through the cement makers is unsustainable. We are looking at other markets in refractory substitution • Acknowledges Weston Aluminium’s efforts to promote industrial ecology and beneficial reuse of 2nd cut SPL • Question: What tonnages of dross/SPL will Weston Aluminium be processing under full scale operations? o WA: Weston Aluminium has a license to accept 40,000 tonnes per annum of aluminium industry wastes. Under full scale treatment operations approximately 24,000 tonnes of this will be SPL, with the remaining 16,000 tonnes as dross • Acknowledges WA’s considerable investment in trials, R&D to get SPL up and running • Queried whether DGR’s had been given o WA: Yes. Currently responding • Noted that Council is aware of the impact of the high Australian dollar on the manufacturing sector • Question: Apart from the installation of an additional cooler, are there any other significant changes to the site/operation? o WA: No, the cooler is the only modification to site. Same footprint • Is excited about the construction of the Hunter Expressway and what this means for the Region
AF
• Question: Is Weston Aluminium going to store a lot of SPL on site? o WA: Only 200-300 MT at any time, 1200 MT/month treatment possible in order to meet the 24,000 MT per year estimate for full production. The intention is to maintain a low stock level and accept material as needed
• Question: Was the 40MT trial from Tomago crushed? o WA: Yes, although Weston Aluminium has a crushing and grinding circuit on site and can accept SPL material whether it is first crushed or not • Noted that the Weston Aluminium site is in good position, of good size and well equipped to deal with the proposed SPL treatment tonnages • Acknowledges the emotion in the community surrounding ‘cyanide’ and has faith in the facts shown by Weston Aluminium regarding non-detectible emissions seen throughout the Trials
RF
• Cessnock Council is asked to comment by DoP on DA’s often but cannot see any problems from CCC’s point of view • Question: Do you expect any material handling problems with the treated material? o WA: No, this material is easy to handle, is not a Dangerous Good and is Non- hazardous and will be stored in bulk bags for transport • Noted that some councillors may have some additional questions regarding the more technical issues of treatment and reuse o WA: WA has been in contact with Council, and will keep updated
BA
• Hydro are interested in any sustainability projects, particularly for SPL and removing existing legacy issues regarding this material
AF
• Noted that Weston Aluminium would not have even gone through the NZ 8MT trial if the project was not feasible
WA
• Would like to thank Tomago and Hydro for working well with Weston Aluminium on this project
AECOM Environmental Assessment Spent Potlining Processing
Appendix C
Air Quality Impact Assessment
10 May 2012 AECOM Environmental Assessment Spent Potlining Processing C-1
Appendix C Air Quality Impact Assessment
10 May 2012 Environmental Assessment Weston Aluminium 8 May 2012
Air Quality Impact Assessment
Spent Pot Lining Processing
AECOM Environmental Assessment Air Quality Impact Assessment
Air Quality Impact Assessment Spent Pot Lining Processing
Prepared for Weston Aluminium
Prepared by
AECOM Australia Pty Ltd 17 Warabrook Boulevarde, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T +61 2 4911 4900 F +61 2 4911 4999 www.aecom.com ABN 20 093 846 925
8 May 2012
60250487
AECOM in Australia and New Zealand is certified to the latest version of ISO9001 and ISO14001.
© AECOM Australia Pty Ltd (AECOM). All rights reserved.
AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and AECOM’s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety.
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AECOM Environmental Assessment i Air Quality Impact Assessment
Table of Contents 1.0 Introduction 1 1.1 Location 1 1.2 Scope of Works 1 2.0 Project Description 3 2.1 Project Location 3 2.2 Interaction with Existing Operations 3 2.3 Proposed Project 3 2.3.1 Spent Pot Lining 3 2.3.2 Process Description 4 2.3.3 Operational Facilities 7 2.3.4 Transport Requirements 7 2.3.5 Hours of Operation 7 2.3.6 Construction Details 7 2.3.7 Environmental Controls 7 2.4 Emission Sources 7 3.0 Pollutants of Potential Concern 9 3.1 Carbon Monoxide 9 3.2 Chlorine 9 3.3 Cyanide 9 3.4 Fluoride and Hydrogen Fluoride 9 3.5 Heavy Metals 9 3.6 Hydrogen Chloride 10 3.7 Nitrogen Dioxide 10 3.8 Particulate Matter 10 3.9 Sulfur Dioxide 10 3.10 Volatile Organic Compounds (VOCs) 10 4.0 Assessment Criteria 12 5.0 Existing Air Quality 13 5.1 Ambient Air Quality 13 5.2 Climate 15 6.0 Methodology 17 6.1 Dispersion Model 17 6.2 Modelling Scenarios 17 6.3 Model Inputs 17 6.3.1 Meteorology 17 6.3.2 Source Characteristics 18 6.3.3 Emissions Inventory 18 6.3.4 Terrain Effects 20 6.3.5 Building Wake Effects 20 7.0 Dispersion Modelling Results 21 8.0 Greenhouse Gas Emissions 26 9.0 Conclusion 28 Appendix A MSDS Excerpts A Appendix B Example Modelling Input File B Appendix C Excerpts from Weston Stack Emissions Testing Reports 2011/12 C Appendix D Concentration Contours D Appendix E Change Log E
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List of Tables Table 1 SPL and Dross Characteristics 3 Table 2 Impact Assessment Criteria 12 Table 3 Ambient Air Quality Data, 2008 – 2012 14 Table 4 Climate Averages – BOM Station 061242, Nulkaba, 1966 - 2012 16 Table 5 Source Characteristics 18 Table 6 Data Sources 19 Table 7 Emissions Inventory 19 Table 8 Maximum Predicted Ground Level Pollutant Concentrations 21 Table 9 Metals Assessment – Dross 22 Table 10 Metals Assessment - SPL 23 Table 11 Predicted Ground Level Fluoride Concentrations at Closest Sensitive Receptor 23 Table 12 Greenhouse Gas Emissions and Energy Use, 2009 - 2011 26 Table 13 NSW Greenhouse Gas Emissions by Economic Sector, 2009 26
L:\60250487_Weston\Report\EPA Review\60250487_Revised_FINAL_Rpt_AQIA_8May12.docx Revision D - 8 May 2012 AECOM Environmental Assessment 1 Air Quality Impact Assessment
1.0 Introduction Weston Aluminium Pty Ltd (Weston Aluminium) operates a secondary aluminium processing facility at Kurri Kurri in NSW (refer to Figure 1). The facility recovers aluminium from dross, a by-product of the aluminium smelting process, sourced from aluminium smelters across Australia and New Zealand. The plant also recycles scrap aluminium metal products and reprocesses the aluminium for use in various industries. The facility is approved to produce up to 40,000 tonnes of dross aluminium and process 35,000 tonnes of scrap aluminium metal per year on site. Weston Aluminium proposes to diversify its service provision to the aluminium smelters beyond the reprocessing of aluminium dross and other aluminium-bearing wastes. The proposed project is to treat and process Second Cut Spent Pot Lining (SPL) on a commercial scale. Weston Aluminium proposes to modify its existing Development Consent DA 86-04-01 and 10397 of 1995 (as modified) to allow for the commercial processing of SPL at the Kurri Kurri facility. This Air Quality Impact Assessment (AQIA) was prepared by AECOM to accompany the Environmental Assessment for the proposed project. This AQIA was prepared in accordance with Director General’s Requirements, and assesses the potential changes in local air quality associated with the proposed project. Existing and proposed emissions from the facility were assessed using the AUSPLUME Gaussian dispersion model.
1.1 Location The Weston Aluminium facility is located on Lot 796, Mitchell Avenue, a nine hectare site in the Kurri Kurri industrial area of NSW. Residences are located approximately 600 m to the south (Kurri Kurri) and west (Weston) of the site. The Hydro Aluminium Smelter, whose buffer zone extends to the northern boundary of the WA site, is located approximately 2 km to the north.
1.2 Scope of Works This AQIA compared the existing emissions against the expected emission levels associated with the proposed modification. Emission rates and stack parameters were obtained from results obtained from stack emission testing conducted by AECOM, and were used in the AUSPLUME dispersion model to estimate maximum ground level concentrations of pollutants. The following pollutants were assessed: - Carbon monoxide; - Chlorine; - Cyanide; - Fluoride/hydrogen fluoride; - Heavy metals; - Hydrogen chloride; - Nitrogen dioxide;
- Particulate matter (PM10 and total suspended particulate); - Oxides of sulfur; and - Volatile organic compounds.
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Figure 1 Site Location
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2.0 Project Description
2.1 Project Location The commercial scale treatment and processing of Second Cut SPL will be conducted at Weston Aluminium’s Kurri Kurri facility (refer to Figure 1). The storage and processing of SPL will be undertaken within existing storage buildings and processing through existing rotary furnaces.
2.2 Interaction with Existing Operations The current Weston Aluminium facility recovers aluminium from dross and scrap aluminium metal products, and reprocesses the aluminium for use in various industries. The current development approval authorises Weston Aluminium to process 35,000 tonnes of scrap aluminium metal per year on site and to produce up to 40,000 tonnes of dross aluminium. Dross inputs at the Kurri Kurri facility are currently in the order of 10,000 -15,000 tonnes per annum, which is well below the approved capacity. Under the proposed project, it is envisaged that (ultimately) 15,000 - 20,000 tonnes per annum of SPL processing will be undertaken on the premises. As such, the combined dross and SPL processing tonnage will comply with the existing approval conditions.
2.3 Proposed Project 2.3.1 Spent Pot Lining SPL is a by-product of primary aluminium production, generated from the periodic de-lining of electrolytic cells. First Cut SPL (originating from the carbon cathode) and Second Cut SPL (refractory lining) contain varying proportions of aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants, with their management and disposal representing a major issue faced by the industry. SPL is classified as a hazardous material, and as for aluminium dross, is classified as a 4.3 Dangerous Good. The purpose of the processing to be undertaken by Weston Aluminium is to thermally oxidise the cyanide from the material while retaining its intrinsic mineralogical value, so that the SPL can be transported as a non-hazardous material. The composition of the Dross and SPL is summarised in Table 1 with the corresponding MSDS included as Appendix A.
Table 1 SPL and Dross Characteristics
Dross Composition (%) SPL Composition (%) Chemical Characteristics Tomago Hydro Tomago Hydro Carbon Refractory
Aluminium 10 - 90 20 - 70 5 - 20 0 - 3 0 - 1 Magnesium oxide < 10 - - - Cryolite < 5 1 - 2 - - Aluminium oxide 10 - 90 28 - 78 11 - 22 2 - 10 12 - 30 Aluminium nitride 2 - 10 < 0.1 - - Aluminium carbide < 5 - - - Oxides < 5 - - - Potassium chloride < 1 < 0.1 - - Sodium chloride < 1 - - - Calcium oxide - - < 3 1 - 2 1 - 5 Carbon - - 26 - 72 50 - 75 2 - 5
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Dross Composition (%) SPL Composition (%) Chemical Characteristics Hydro Tomago Hydro Tomago Fluoride - - 7 - 22 - Sodium compounds - - 13 - 17 - Aluminium sodium oxide - - 5 - 10 - Silicon - - < 10 - Sodium aluminosilicate - - 3 - 7 - Cyanide - - < 0.7 0 - 0.1 0 - 0.04 Silica crystalline - quartz - - - 0 - 6 40 - 70 Sodium hydroxide - - - 2 - 4 1 - 2 Sodium fluoride - - - 9 - 11 5 - 11 Sodium aluminium fluoride - 1 - 2 - 3 - 8 3 - 8 Calcium fluoride - - - 0 - 1 0 - 1 Iron - - - 0 - 1 0 - 1 Ferric oxide - - - 0 - 2 2 - 4 Sulfur - - - 0 - 2 0 - 1 Magnesium aluminate - < 0.1 - - -
“-“ denotes no entry provided in the MSDS.
2.3.2 Process Description SPL will be received either pre-crushed or uncrushed from various domestic aluminium smelters, and stored on the premises in accordance with the Australian Dangerous Goods Code. Weston Aluminium proposes a treatment process of SPL based on the following elements: - Primary crushing (where necessary); - Controlled blending with cullet and other propriety additives, as required; - Fine milling; - Thermal treatment; - Crushing and mixing; and - Processing and utilisation in the manufacturing process of various products. The proposed SPL processing chain is schematically represented in Figure 2. This process is identical to that of dross treatment, and the same facilities, plant and equipment (with the addition of a new cooler) will be used for the recycling of both materials (refer to Figure 3). As the recycling of dross and SPL produce different end products, the treatment of both materials will be conducted independently as dedicated campaigns, with all plant and equipment cleaned in between switching between dross and SPL processing.
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Figure 2 SPL Processing Schematic
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Figure 3 Plant Layout
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The objective of the process is to thermally oxidise the cyanide within the SPL and modify the mineralogical composition so that the material is declassified and able to be transported as a non-hazardous goods product. Previous trials conducted by Weston Aluminium demonstrated that the proposed process effectively reduces cyanide concentrations in treated SPL to a level considered negligible. 2.3.3 Operational Facilities The storage and processing of SPL will be undertaken within existing storage buildings and processed through existing rotary furnaces. The only additional plant equipment required for the proposed project is a new rotary cooler, which will be installed within the existing processing chain, and serviced by an existing baghouse (refer to Figure 2). There would be no need for additional pollution control systems, or the construction of any additional infrastructure. The proposed modifications to the plant layout are marked on Figure 3. 2.3.4 Transport Requirements SPL will be delivered to the Kurri Kurri facility in a truck-and-trailer arrangement by a licensed Dangerous Goods contractor. 2.3.5 Hours of Operation The facility has approval to operate 24 hours per day, 7 days a week. No change to the existing operating hours is anticipated for the project. 2.3.6 Construction Details The only new plant to be installed at the facility is the Rotary Cooler. During the construction period, Baghouse 3 will be re-ducted to service the proposed cooler. Construction is expected to take a period of one month and will be carried out by both Weston Aluminium employees and local contractors. Construction works would occur weekdays between 8 am and 6 pm. No substantial air emissions are expected to be generated by the construction works. 2.3.7 Environmental Controls The existing facility is comprised of best available technology, and complies with stringent pollution limits. This plant will be utilised for the processing of SPL. Emissions of process dust, cyanide and fluoride are controlled by existing plant through: - Temperature control; - A scrubber/baghouse complex; and - Baghouse residues are returned to the raw material feed in a closed-loop cycle. Processing trials conducted for the SPL material on site have demonstrated that the existing facilities are able to meet the emissions criteria for the facility. Additionally, emissions monitoring during the SPL trials confirmed that gaseous fluoride and particulate emission concentrations were below the regulatory compliance limits throughout the process. Consequently, it is anticipated that no change to Weston Aluminium’s existing Environmental Protection Licence (EPL) limits will be required for the project, but that cyanide monitoring may be added to the air quality monitoring and water sampling regimes.
2.4 Emission Sources The two sources of combustion emissions at the facility are the reverbatory and rotary furnaces, which are both currently serviced by lime-fed scrubbers that remove gaseous fluorides and other acid gases liberated from the materials during the heating process. Fugitive emissions are generated from materials processing and handling. These fugitive emissions are captured by baghouses. The facility is serviced by seven stacks: - Stack 1: Rotary furnace. - Stack 2 - 4: Baghouse stacks servicing fugitive dust within the processing plant. Weston Aluminium proposed to use Stack 3 (Baghouse 3) to service the new Rotary Cooler. - Stack 5: Reverbatory furnace.
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- Stack 6: Gas combustion side of the reverbatory furnace. - Stack 7: Pre-processing plant and briquetting plant. Other emission sources associated with plant operations are combustion emissions from vehicles. Due to the intermittent nature and small scale of these emissions, they were not quantified in this assessment.
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3.0 Pollutants of Potential Concern A number of pollutants are emitted under licence from the operations at Weston Aluminium, including particulate matter, combustion products, and metals. The proposed modification would involve processing SPL, which contains a number of compounds, including cyanide. A summary of the pollutants of concern is provided in the following sections. It should be noted that processing trials of the SPL material have demonstrated that nuisance odour is not generated by the activities. Furthermore, fugitive emissions and dust are not considered to be an issue for the existing plant, and are not expected to change as a result of the proposed modification.
3.1 Carbon Monoxide Carbon monoxide is an odourless, tasteless gas released during the combustion of fossil fuels, as well as through natural processes such as volcanic eruptions and bush fires. As the gas can cause significant harmful health effects, it is considered to be a criteria pollutant by Australian federal and state governments. While normal levels of carbon dioxide in the lungs and arterial blood are essential for normal health, exposure to higher concentrations can result in headaches, fatigue, nausea and dizziness. Inhibition of the oxygen-carrying capacity of blood can occur following exposure to high concentrations.
3.2 Chlorine Chlorine is a diatomic green gas that has strong oxidising, bleaching and disinfecting properties in liquid and solid form. The substance is extremely irritating to the eyes and mucous membranes, with low exposures leading to stinging and coughing, while higher exposure can result in breathing difficulties, headaches, and severe respiratory tract damage and pulmonary oedema (accumulation of fluid in the lungs). Chlorine reacts with water to form hydrochloric acid.
3.3 Cyanide Cyanide is a naturally occurring compound that is essential for a healthy diet (as cyanocobalmin, or vitamin B12). Compounds are released into the atmosphere (from both natural and human processes) as gaseous or particulate matter, which settles into the soil or water, with most compounds being water soluble. Cyanides break down in a matter of days in water but are persistent in air. Exposure can occur from ingestion of food or water or smoking, or air pollution from chemical processing facilities, steel and iron industries and high motor vehicle traffic areas. Pesticides and rodenticides can also contain cyanide. Cyanide is very toxic to humans, and brief exposures to lower concentrations may result in symptoms such as shortness of breath, convulsions and unconsciousness, while long-term exposure to low concentrations can result in deafness, vision and coordination problems. Exposure to high levels for short periods can result in damage to the respiratory, cardiovascular and central nervous systems and quickly cause death. Cyanides are also highly toxic to aquatic life, birds and animals over short periods. While cyanides have high chronic toxicity to aquatic life, insufficient data exist to determine chronic toxicity to land organisms. Cyanides are not expected to bioaccumulate. Cyanide within the SPL feedstock has been demonstrated to be readily oxidised (to carbon monoxide and oxides of nitrogen).
3.4 Fluoride and Hydrogen Fluoride Fluorides are naturally occurring elements. Hydrogen fluoride is used to make aluminium and other fluoride salts, as well as for cleaning, etching, and galvanising metal. Exposure to high levels of hydrogen chloride gas can result in muscle spasms and damage to the heart and lungs, while low levels can cause irritation to the skin and mucous membranes.
3.5 Heavy Metals Trace levels of a number of heavy metals are contained within the materials processed at the Weston Aluminium plant, including beryllium, cadmium, chromium, copper, lead, manganese, mercury, nickel and tin. Small amounts
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of these substances are necessary for good health, while high levels are toxic, leading to damages to mental and nervous system function as well as organ damage and, in some cases, death. Some heavy metals are also carcinogenic.
3.6 Hydrogen Chloride Hydrogen chloride (hydrochloric acid) is a colourless, non-flammable, corrosive solution or gas used for many applications, including refining ores, cleaning metal, fertiliser and dye production, and in industries such as textile and rubber production. The compound is corrosive to the eyes, skin and mucous membranes, resulting in a number of adverse health effects. It is not known to be a human carcinogen.
3.7 Nitrogen Dioxide
Nitrogen dioxide (NO2) is a brownish gas with a pungent odour. It exists in the atmosphere in equilibrium with nitric oxide. The mixture of these two gases is commonly referred to as oxides of nitrogen (NOx). NOx is a product of combustion processes. In urban areas, motor vehicles and industrial combustion processes are the major sources of ambient NOx. NO2 can cause damage to the human respiratory tract, increasing a person’s susceptibility to respiratory infections and asthma. NO2 can also cause damage to plants, especially in the presence of other pollutants such as O3 and SO2. NOx are also primary ingredients in the reactions that lead to photochemical smog formation.
3.8 Particulate Matter Particulate matter can be emitted from natural sources (bushfires, dust storms, pollens and sea spray) or as a result of human activities such as combustion activities (motor vehicle emissions, power generation and incineration), excavation works, bulk material handling, crushing operations, unpaved roads and wood heaters. Airborne particles are commonly differentiated according to size based on their equivalent aerodynamic diameter. Particles with a diameter of less than or equal to 50 micrometres (Pm) are collectively referred to as total suspended particulates (TSP). TSP primarily causes aesthetic impacts associated with coarse particles settling on surfaces, which also causes soiling and discolouration. These large particles, however, can cause some irritation of mucosal membranes and can increase health risks from ingestion if contaminated. Particles with diameters less than or equal to 10 Pm (known as PM10 or fine particles) tend to remain suspended in the air for longer periods than larger particles, and can penetrate into human lungs. Exposure to particulate matter has been linked to a variety of health effects, such as respiratory problems (such as coughing, aggravated asthma, chronic bronchitis) and non-fatal heart attacks. Furthermore, if the particles contain toxic materials (such as lead, cadmium, zinc) or live organisms (such as bacteria or fungi), toxic effects or infection can occur from the inhalation of the dust.
3.9 Sulfur Dioxide
Sulfur dioxide (SO2) is an invisible gas that has a sharp, offensive odour. The gas reacts with other substances to form a number of harmful compounds, including sulfuric acid. The burning of fossil fuels is a primary source of SO2 in the air. Sulfur dioxide irritates the respiratory system, and inhalation can cause breathing difficulties, particularly for asthmatics.
3.10 Volatile Organic Compounds (VOCs) Organic compounds with a vapour pressure at 20 °C exceeding 0.13 kPa are referred to as VOCs. VOCs have been implicated as a major precursor in the production of photochemical smog, which causes atmospheric haze, eye irritation and respiratory problems. VOCs are emitted by the combustion process. Benzene is often used as an indicator species of VOCs. It is an airborne substance that is a precursor to photochemical smog. It can be washed out of the air by rain, but then evaporated back into the air. It will decompose in soil or water when oxygen is present. Benzene exposure commonly occurs through inhalation of air containing the substance. It can also enter the body through the skin, although it is poorly absorbed this way. Low levels of benzene exposure result from tobacco smoke and car exhaust. Benzene is considered to be a toxic health hazard and a carcinogen. It has high acute toxic effects on aquatic life and long-term effects on marine life and agricultural crops. Human exposure to very high levels for even brief
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periods of time can potentially result in death, while lower level exposure can cause skin and eye irritation, drowsiness, dizziness, headaches and vomiting, damage to the immune system, leukaemia and birth defects.
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4.0 Assessment Criteria The impact assessment criteria for the pollutants of concern in this assessment are provided in Table 2. These criteria were sourced from the NSW EPA Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales, 2005.
Table 2 Impact Assessment Criteria
Pollutant Averaging period Criteria (Pg/m3)
Carbon monoxide 15 minutes 100,000 1 hour 30,000 8 hours 10,000 Chlorine 1 hour 50 Cyanide (CN) 1 hour 90 Fluoride (hydrogen fluoride)* 24 hours 2.9 7 days 1.7 30 days 0.84 90 days 0.5 Lead Annual 0.5 Antimony 1 hour 9 Arsenic 1 hour 0.09 Beryllium 1 hour 0.004 Cadmium 1 hour 0.018 Heavy Chromium* 1 hour 0.09 Metals Copper 1 hour 18 Magnesium 1 hour 1810 Manganese 1 hour 18 Mercury 1 hour 0.18 Nickel 1 hour 0.18 Hydrogen chloride 1 hour 140
Nitrogen dioxide 1 hour 246 Annual 62
Particulate matter - PM10 24 hours 50 Annual 30 Particulate matter - total particulates Annual 90 Sulfur dioxide 10 minutes 712 1 hour 570 24 hours 228 Annual 60 VOCs (as benzene)** 1 hour 29
* Impact assessment criteria for general land use adopted as there are no known land uses surrounding the Weston facility that may be sensitive to fluoride ** Benzene was chosen as the most conservative VOC criterion relevant to the assessment; refer to Section 6.3.3
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5.0 Existing Air Quality The Weston Aluminium plant at Kurri Kurri is located within a heavy industrial area, with some residential areas to the south and west of the site. The Hydro Aluminium Smelter is located approximately 2 km north of the site; its buffer zone extends to Weston Aluminium’s northern boundary. The air quality within the area is considered to be typical to that of an industrial area, with existing sources which contribute to air pollution including: - Hydro Aluminium Smelter; - Industrial emissions; - Coal mines; - Emissions from motor vehicles travelling on the local road network; and - Dust and pollens in drier and windier conditions. Emissions from the power stations in the Upper Hunter Valley also affect air quality in the area. It should be noted that Hydro Aluminium closed its Potline No. 1 during February 2012, and hence fluoride loads within the local (and regional) area have dramatically reduced. Representative monitoring data covering a period of time since the closure is yet to confirm this expectation and as such historical monitoring data including all potlines has been used.
5.1 Ambient Air Quality
The EPA operates an ambient monitoring station at Beresfield, which is approximately 16 km east of the Weston Aluminium facility. The Beresfield station monitors levels of sulfur dioxide, nitrogen dioxide and particulate matter (PM10 and PM2.5). A summary of the recent EPA monitoring results is shown in Table 3. As shown, concentrations of sulfur dioxide and nitrogen dioxide are all well below the EPA ambient criteria. Particulate concentrations, however, have exceeded the 24 hour criteria on a number of occasions, primarily as a result of a major dust storm event in 2009, and other natural events, such as bushfires.
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Table 3 Ambient Air Quality Data, 2008 – 2012
Beresfield Statistic Year 3 3 3 SO2 (Pg/m ) NO2 (Pg/m ) PM10 (Pg/m )
2008 133.62 58.28 - 2009 128.38 67.68 - 2010 123.14 60.16 - 1 Hour Maxima 2011 157.2 78.96 - 2012 (YTD) 157.2 78.96 - Criteria 570 246 - 2008 26.2 - 59.9 2009 26.2 - 1999 2010 20.96 - 50 Maximum 24 Hour Average 2011 31.44 - 42.8 2012 (YTD) 10.48 - 40.6 Criteria 228 - 50 2008 4.5 15.1 18.3 2009 3.9 11.5 28.9 2010 3.5 13.3 16.6 Annual Average 2011 4.4 16.9 17.2 2012 (YTD) 2.7 11.3 18.1 Criteria 60 62 30
To ensure the assessment is conservative, maximum background concentrations for the monitored years were adopted for the assessment. Adopted background concentrations are as follows: x SO2 o 1 hour maximum concentration = 157.2 Pg/m3 o Maximum 24 hour concentration = 31.4Pg/m3 o Annual average concentration = 4.5Pg/m3 x NO2 o 1 hour maximum concentration = 78.96 Pg/m3 o Maximum 24 hour concentration = 16.9Pg/m3 x PM10 o Maximum 24 hour concentration = 59.9Pg/m3 (the maximum concentration from 2009 was considered an outlier, due to severe dust storms)
o Annual average concentration = 18.3Pg/m3 The background fluoride concentration is based on historical measurements made by Hydro Aluminium as reported in previous AQIAs prepared for Weston Aluminium [ENSR Australia Pty Ltd (AECOM) report 'Air Quality Impact Assessment, Weston Aluminium Facility Gaseous Fluoride Emissions, Weston NSW' 31 July 2008]. Based on these measured values, the 7 day average background HF concentrations were estimated at 0.6Pg/m3. To try and obtain background concentration for different averaging times, the percentage of the 7 day average criterion
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already taken up by fluoride (35%) was applied to the different averaging periods, resulting in the following adopted background concentration: x Fluoride
o 24 hour concentration = 1.02 Pg/m3 o 7 day average concentration = 0.6Pg/m3 o 90 day average concentration = 0.18Pg/m3 All pollutants outlined in Section 3.0 not listed above were assumed to have low or negligible concentrations in the environment surrounding the Weston facility.
5.2 Climate
Climatological data from the Bureau of Meteorology’s Cessnock (Nulkaba) monitoring station for 1966 to 29 March 2012 are presented in Table 4. The Nulkaba station is located approximately 10 km to the west of the Weston Aluminium site. These data indicate that average monthly maximum temperatures range from 30.4qC in January (summer) to 17.8 qC in July (winter). Annual average relative humidity levels are 72 % and 50 % at 9:00 am and 3:00 pm respectively. Rain generally falls on 80 days per year with an average recorded rainfall of 765.7 mm.
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Table 4 Climate Averages – BOM Station 061242, Nulkaba, 1966 - 2012
Statistics Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual Temperature
Mean maximum temperature (°C) 30 29.6 28 25 21 18 18 20 23 25 27 29 24.5
Mean minimum temperature (°C) 18 17.7 16 12 8.5 6 4.6 4.9 7.8 11 14 16 11.3 Rainfall
Mean rainfall (mm) 88 105 85 58 54 60 33 37 44 59 73 71 765.7
Decile 5 (median) rainfall (mm) 71 73.8 68 40 45 35 26 26 34 45 67 67 756.2
Mean no. of days of rain 1 mm 7.8 8 8.3 6.4 6.2 6 4.8 5.1 5.2 7 8 7.2 80 Other daily elements
Mean number of clear days 4.7 3.6 5 5.5 6 6.4 7.7 9.6 7.5 5.9 4.3 4.2 70.4
Mean number of cloudy days 12 12.3 12 9.4 10 9.6 8.1 6.8 7.8 10 12 11 121.8 9 am conditions
Mean 9am temperature (°C) 23 22.2 21 18 14 11 9.8 12 16 19 20 23 17.4
Mean 9am relative humidity (%) 70 76 76 75 80 81 79 71 63 60 65 65 72
Mean 9am wind speed (km/h) 11 9.8 9.7 9.6 9.7 10 11 13 14 13 12 12 11.2 3 pm conditions
Mean 3pm temperature (°C) 29 28.1 26 23 20 17 17 19 21 24 26 28 23.1
Mean 3pm relative humidity (%) 49 53 54 52 55 57 52 44 44 46 48 46 50
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6.0 Methodology
6.1 Dispersion Model
AUSPLUME is an advanced Gaussian plume dispersion model with algorithms based on the Industrial Source Complex – Short Term (ISCST3) model approved by the US EPA for use in regulatory assessments undertaken within the United States. AUSPLUME was developed by the EPA Vic to enhance the ISCST3 model and make it applicable to Australian conditions. AUSPLUME is approved by the NSW EPA for use in regulatory assessments undertaken in NSW. The model uses the Gaussian dispersion model equation to simulate the dispersion of plumes from point, area, or volume sources. Dry and wet deposition can be taken into account, and algorithms are included to account for retention of dust within open pits. Mechanisms for determining the effect of terrain on plume dispersion are also provided. AUSPLUME operates on an hourly time step, and requires hourly wind speed, wind direction and other dispersion parameter data. The dispersion of each pollutant plume is determined for each hour using conventional Gaussian model assumptions. Atmospheric dispersion modelling was conducted using AUSPLUME in accordance with the EPA’s approved methods (DEC, 2005). This document prescribes calculation modes for accounting for terrain effects, building wake effects, horizontal and vertical dispersion curves, buoyancy effects, surface roughness, plume rise, wind speed categories and wind profile exponents.
6.2 Modelling Scenarios
Two scenarios were utilised in this assessment: - Scenario 1, which represented the existing operating conditions of the plant; and - Scenario 2, which represented proposed operating conditions of the plant, where emissions from Stack 1 represent the SPL process rather than the dross. The assessment assumed operations occur 24 hours per day, 7 days a week over 365 days a year. This was a conservative assumption that did not account for plant shut downs and normal operating variations.
6.3 Model Inputs
AUSPLUME requires five main categories of data to determine the dispersion of pollutants: - Meteorology. - Source characteristics. - Emissions inventory. - Terrain effects. - Building wake effects. The above inputs are addressed separately in the following sections. An example modelling input file is provided in Appendix B. 6.3.1 Meteorology To ensure consistency with previous reports, the meteorological data used in this assessment were the same as that used for the previous assessments undertaken for the Weston Aluminium facility (ENSR Australia Pty Ltd (AECOM) report 'Air Quality Impact Assessment, Weston Aluminium Facility Gaseous Fluoride Emissions, Weston NSW' 31 July 2008). Hourly wind speed, wind direction, atmospheric stability class and mixed layer height data for 2005 were collected from a meteorological station located at the Hydro Aluminium Smelter. Meteorological data are used by dispersion models in different ways to estimate the dispersion of air pollutants: - Ambient temperature is used to incorporate thermal buoyancy effects when calculating the rise and dispersion of pollutant plumes.
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- Wind direction determines the direction in which pollutants will be carried. - Wind speed influences the dilution and entrainment of the plume into the air continuum. - Atmospheric stability class is a measure of atmospheric turbulence and the dispersive properties of the atmosphere. Most dispersion models utilise six stability classes, ranging from A (very unstable) to F (stable/very stable). - Vertical mixing height is the height at which vertical mixing occurs in the atmosphere.
6.3.2 Source Characteristics
Details of the characteristics of each of the stacks on site are provided in Table 5. Data were taken from the most recent stack emission testing results available at the time of preparation; copies of the emissions testing reports are provided in Appendix C, which were conducted while the plant was operating under full load, worst-case conditions. Both furnaces were operating at normal, full-capacity at the time of emissions testing, together with other auxiliary plant and equipment (e.g. cooling circuit) servicing furnace operations. Charge temperatures associated with SPL processing batches were also elevated to confirm fluoride liberation and emission control performance under worst case conditions. It should be noted that Stack 1 is the only source that will be affected by the proposed changes for the purpose of this assessment; as such, characteristics of the other stacks were assumed to be the same for Scenarios 1 and 2.
Table 5 Source Characteristics
Stack 1 Stack Stack Stack Stack Stack Stack Parameter Existing Proposed^ 2 3 4 5 6 7
Velocity (m/s)* 13.0 14.0 14.0 8.7 14.0 18.0 16.0 16.0 Height (m) 15.0 15.0 15.0 15.0 15.0 20.0 18.0 15.0 Internal diameter (m) 1.65 1.65 1.3 1.0 1.4 1.5 0.6 1.5 Temperature (oC)* 56.2 87.8 41.8 34.8 41.2 60.0 377.8 23.1 Area (m2) 2.14 2.14 1.3 0.8 1.5 1.7 0.3 1.8 Flow (Am3/s)* 27.8 30.0 17.5 6.9 21.3 31.3 4.2 28.3 Flow (Nm3/s) 22.5 22.2 14.8 6.0 18.3 25.2 1.6 25.4
* Represent averages from testing undertaken between 2011 and 2012 with the exception of the Proposed Stack 1 parameters ^ Parameters taken from AECOM. (2012). Emissions Testing Report - Stack 1 Jan 2012, Weston Aluminium
6.3.3 Emissions Inventory
Details of the sources of the emissions data and the data used in the modelling are shown in Table 6 and Table 7 respectively. The most recent available stack emission results from annual testing undertaken during 2011 and 2012 (refer to Appendix C) and the SPL processing trial conducted by Weston Aluminium were utilised in the dispersion modelling. It should be noted that the completed stack emissions results for 2012 were not available at the time of modelling; as such, data from 2011 were used wherever required. Emission rates were entered into the dispersion model based on their measured concentrations and calculated stack parameters (as shown in Table 5). Table 7 outlines the data sources used in the assessment. Note that the processing of SPL is only expected to affect emissions from Stack 1; data from Stacks 2 - 7 were assumed to be the same as the emissions measured when processing dross. In cases where pollutants were not detected, the limit of detection was adopted as the emission rate as indicated in Table 7. It should be noted that slight variations may be present in the emission rates used in the modelling compared to the stack emission measurement results; these variations are not considered likely to have significantly affected the results.
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Table 6 Data Sources
Stack Pollutant Data Source Material
S1 PM10; TP; particulate and gaseous fluoride; AECOM. (2012). Emissions Testing Report SPL hydrogen chloride; chlorine; hazardous - Stack 1 Jan 2012, Weston Aluminium substances (metals); cyanide; VOCs; CO; NOX; SO2
S1 PM10; TP; particulate and gaseous fluoride; AECOM. (2012). Annual Emissions Testing Dross hydrogen chloride; chlorine; hazardous Report 2012 – Weston Aluminium; Table 7 substances (metals); cyanide; VOCs
CO; NOX; SO2 AECOM. (2011). Emissions Testing Report Dross – 2011 Annual Testing, Weston Aluminium; Table 11
S2,3,4 PM10; TP; particulate and gaseous fluoride AECOM. (2012). Annual Emissions Testing Dross & 7 Report 2012 – Weston Aluminium; Table 7
S5 PM10; TP; particulate and gaseous fluoride; AECOM. (2011). Emissions Testing Report Dross hydrogen chloride; chlorine; metals; VOCs; – 2011 Annual Testing, Weston Aluminium; CO; NOX; SO2 Table 12
S6 PM10; TP; particulate and gaseous fluoride; AECOM. (2011). Emissions Testing Report Dross CO; NOX; VOCs; SO2 – 2011 Annual Testing – Stack 6, Weston Aluminium
Table 7 Emissions Inventory
Emission Rates (g/s) Pollutant S1 S2 S3 S4 S5 S6 S7 Dross SPL
PM10 0.009 0.0168 0.0490 0.0310 0.0622 0.0174 0.0074*** 0.0837 TP 0.011 0.0051 0.1291 0.0131 0.1025 0.0192 0.0094 0.0608 Particulate fluoride 0.00031 0.0003 0.0004 0.0002 0.0018 0.0002 0.0016 0.0020 Gaseous fluoride 0.002** 0.0035 0.0144 0.0011 2.2E-5 0.0078 0.0033 0.0165 Hydrogen chloride 0.020** 0.0244 - - - 0.0045** - - Chlorine 0.004** 0.0222 - - - 0.0045** - - Hazardous 0.0004 0.0006 - - - 0.0020 - - substances (metals) Cyanide - 0.0002** ------VOCs^ 0.004 4.2E-6 - - - 0.04 0.0015 - CO 0.054 0.5540 - - - 0.13 0.000016 -
NOX* 0.020 0.0111 - - - 0.07 0.0703 -
SO2 0.1438** 0.0160 - - - 0.30** 0.01440 -
** Not detected during testing; limit of detection used for conservative assessment ^ All VOCs were assumed to be benzene for the purpose of this assessment * As a conservative approach, all oxides of nitrogen were assumed to be nitrogen dioxide. *** Measured by laser sizing analysis S1 - S7 denote stacks 1 to 7
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Metals were modelled as a single pollutant, with the predicted ground level concentrations speciated according to the proportion of each type of metal measured during the emissions testing. Further details are provided in Section 7. For the purpose of this assessment, VOCs were all assumed to be benzene. This provides a worst-case assessment, as benzene has the lowest criterion for VOCs typically found in the stack emissions from the Weston facility (i.e. acetone, benzene, and toluene as demonstrated in Appendix C).
6.3.4 Terrain Effects
The ortho-topographical maps for Cessnock (9132-2N) and Beresfield (9232-2N) were used to determine the terrain in the area surrounding the Weston Aluminium facility. A terrain file was prepared and entered into AUSPLUME. A 5 km x 4 km grid with a spacing of 200 m was used.
6.3.5 Building Wake Effects
The dispersion of pollutants around the Weston Aluminium facility is likely to be affected by aerodynamic wakes generated by winds having to flow around buildings. Building wakes generally decrease the distance downwind at which the plume comes into contact with the ground. This may result in higher ground level pollutant concentrations closer to the emission source. The Building Profile Input Program (BPIP) utility option in the AUSPLUME program was used to enter building dimension (details are shown as part of the AUSPLUME input file in Appendix B). These dimensions were subsequently incorporated into the pollutant dispersion calculations to allow concessions for wake effects in the determination of ground level pollutant concentrations.
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7.0 Dispersion Modelling Results Table 8 provides the maximum ground level concentrations of pollutants predicted by this study. Results are presented as predicted concentrations from the Weston operations alone and as cumulative concentrations, where the predicted contributions from the Weston facility were added to the adopted background concentrations where background data were available. The maximum predicted ground level concentrations predicted at any location within the modelling domain (i.e. including locations within the site boundary) were compared to the EPA assessment criteria; results are provided in Table 8. As shown, results from the dross and SPL processing are quite similar, with the main differences noted in the predicted carbon monoxide concentrations. Additionally, the SPL will generate cyanide emissions not present during dross processing; these emissions are, however, well below the assessment criterion.
Table 8 Maximum Predicted Ground Level Pollutant Concentrations
Predicted GLCs (Pg/m3) Pollutant Averaging Period Criteria (Pg/m3) Dross SPL
10 minutes 13.2 9.37 712 1 hour 13.3 (170.5) 6.89 (164.1) 570 Sulfur dioxide 24 hours 5.81 (37.2) 1.74 (33.1) 228 Annual 0.61 (5.1) 0.27 (4.8) 60 1 hour 8.3 (87.3) 8.0 (87.0) 246 Nitrogen dioxide* Annual 0.42 (17.3) 0.41 (17.3) 62
Particulate matter (PM10) Annual 2.4 (20.7) 2.4 (20.7) 30 15 minutes 5.32 44.4 100 000 Carbon monoxide 1 hour 4.96 40.5 30 000 8 hours 2.46 23 10 000 Total particulates Annual 2.97 (48.7) 2.95 (48.7) 90 Hydrogen chloride 1 hour 1.61 1.93 140 Chlorine 1 hour 0.3 1.62 50 Refer to Table 9 and 1 hour 0.05 0.06 Total metals Table 10 below. Annual^ 0.002 0.0026 0.5 VOCs (as benzene) 1 hour 1.16 1.05 29 Cyanide 1 hour - 0.02 90
* Modelling results represent oxides of nitrogen, which were assumed to represent nitrogen dioxide for this assessment. Numbers in parentheses denote cumulative pollutant concentrations. Note that where no cumulative data exist, or where levels are expected to be negligible, no cumulative values are presented. ^ Lead is the only metal with an annual criterion; as such, total metals were compared against the annual lead criterion. Bold text denotes exceedence of a criterion.
Predicted ground level pollutant concentrations were well below the impact assessment criteria for most pollutants. Exceedences were, however, predicted for 24 hour PM10 and fluoride, which are discussed below. It should be noted that these data are omitted from Table 8. In order to compare the 1 hour metals results against the EPA assessment criteria, the contribution of each individual species was calculated based on the proportion of each species in the emissions as described in Table 9 (dross) and Table 10 (SPL). The predicted maximum concentrations for each processing scenario were used (i.e. 0.05 Pg/m3 for dross and 0.06 Pg/m3 for SPL). As shown, no exceedences of the metals criteria were predicted for either dross or SPL processing.
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Table 9 Metals Assessment – Dross Calculated Dross Proportion Stack 1 Stack 5 1 Hour Ground Combined of total Criteria Metals Emissions Emissions Level Emissions emissions (Pg/m3) (mg/s)^ (mg/s) # Concentrations (mg/s) (%) (Pg/m3) Lead 0.046 1 1.046 45.76 0.02 N/A** Antimony 0.006 0 0.006 0.26 0.0001 9 Arsenic 0 0.034 0.034 1.49 0.001 0.09 Cadmium 0.01 0.0044 0.0144 0.63 0.0003 0.018 Chromium* 0.043 0.0032 0.0462 2.02 0.001 0.09 Copper 0.12 0.12 0.24 10.50 0.01 18 Magnesium 0.13 N/A 0.13 5.69 0.003 180 Manganese 0 0.63 0.63 27.56 0.01 18 Mercury 0 0.032 0.032 1.40 0.0007 0.18 Nickel 0.012 0.011 0.023 1.01 0.0005 0.18 Tin 0.0031 0.019 0.0221 0.97 0.0005 N/A Zinc 0.062 N/A 0.062 2.71 0.001 N/A Total 0.4321 1.8536 2.2857 100.00 0.05 -
^ From AECOM. (2012). Emissions Testing Report Stack 1 Jan 2012, Table 10 # 2011 Annual Testing – Emissions Testing Report Stack 14 Mar 2011, Table 26 * All chromium was assumed to be chromium VI for the purpose of this assessment as the criterion is more conservative than that for chromium III ** Lead does not have a 1 hour criterion
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Table 10 Metals Assessment - SPL Calculated SPL Proportion Stack 1 Stack 5 1 Hour Ground Combined of total Criteria Metals Emissions Emissions Level Emissions emissions (Pg/m3) (mg/s)^ (mg/s) # Concentrations (mg/s) (%) (Pg/m3)
Lead 0.046 1 1.046 43.24 0.03 N/A** Antimony 0.057 0 0.057 2.36 0.001 9 Arsenic 0.019 0.034 0.053 2.19 0.001 0.09 Beryllium 0.00057 0 0.00057 0.02 0.00001 0.004 Cadmium 0.16 0.0044 0.1644 6.80 0.004 0.018 Chromium* 0.044 0.0032 0.0472 1.95 0.001 0.09 Copper 0.019 0.12 0.139 5.75 0.003 18 Manganese 0.15 0.63 0.78 32.24 0.02 18 Mercury 0 0.032 0.032 1.32 0.0008 0.18 Nickel 0.033 0.011 0.044 1.82 0.001 0.18 Tin 0.037 0.019 0.056 2.31 0.001 N/A Total 0.57 1.85 2.42 100 0.06 -
^ From AECOM. (2012). Emissions Testing Report Stack 1 Jan 2012, Table 11 # 2011 Annual Testing – Emissions Testing Report Stack 14 Mar 2011, Table 26 * All chromium was assumed to be chromium VI for the purpose of this assessment as the criterion is more conservative than that for chromium III ** Lead does not have a 1 hour criterion
For the pollutants that exceeded the assessment criteria via the screening assessment approach (24 hour cumulative PM10 and fluoride), further analysis of the concentrations at the surrounding sensitive receptors was undertaken. Concentrations of fluoride predicted at the closest sensitive receptor (situated at the RSPCA dog shelter, approximately 100 m to the east of the Weston Aluminium eastern boundary) are shown in Table 11. Predicted fluoride concentrations fell below the assessment criteria at this location. Isopleths of predicted fluoride concentrations are provided in Appendix D.
Table 11 Predicted Ground Level Fluoride Concentrations at Closest Sensitive Receptor
3 Averaging Predicted GLCs (Pg/m ) Pollutant Criteria (Pg/m3) Period Dross SPL
24 hours 1.32 (2.34) 1.35 (2.37) 2.9 Hydrogen fluoride 7 days 0.31 (0.91) 0.32 (0.92) 1.7 90 days 0.30 (0.48) 0.31 (0.49) 0.5
Numbers in parentheses denote cumulative pollutant concentrations.
For the short term PM10 predictions, a contemporaneous assessment was undertaken to further assess PM10 dust concentrations at the closest sensitive receptor, and determine whether the processing of SPL at the Weston facility would result in additional exceedences of the 24 hour criterion above those attributable to the elevated ambient concentrations.
The contemporaneous assessment was undertaken by summing the predicted 24 hour average PM10 concentration for each day in the modelled year of 2005 with the corresponding measured 24 hour average PM10
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concentrations at the Beresfield OEH monitoring station1. As shown in Figure 4, no additional exceedences of the
PM10 criterion were predicted. On the basis of the contemporaneous assessment, no adverse impacts are expected to result from the processing of the SPL.
1 Beresfield is the closest available station with suitable for contemporaneous assessment; sourced from the NSW OEH online pollutant database for Beresfield, calendar year of 24 hour average PM10 concentrations.
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Figure 4 Contemporaneous Assessment, 24 hour PM10
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8.0 Greenhouse Gas Emissions The Weston Aluminium facility is subject to the reporting requirements of the National Greenhouse and Energy Reporting (NGER) Act 2007. Reported greenhouse gas emissions for the 2009 -10 and 2010 -11 periods are provided in Table 12.
Table 12 Greenhouse Gas Emissions and Energy Use, 2009 - 2011 Scope 1 Emissions Scope 2 Emissions Total Emissions (Scope 1 + 2) Year (t CO2-e) (t CO2-e) (t CO2-e) 2009 -10 7,819 4,789 12,608 2010 -11 7,468 4,785 12,252
The facility has been operating at a reduced rate of input to the rotary furnace for the past few years. As electricity use is associated with furnace inputs, the electricity consumption at the facility has, therefore, also been lower than usual. The proposed processing of SPL would bring the facility back up to its typical rotary furnace inputs of 40,000 tonnes per annum (current approved limit). The estimated Scope 2 emissions (electricity consumption) associated with full-scale operation of the facility (of either SPL or dross) would be approximately 19 % higher 2 than those reported in 2010-11, or equivalent to approximately 5,874 t CO2-e per year . Scope 1 emissions would similarly be expected to increase over existing levels, but be in the same order as those associated with typically full-scale operation. Assuming a similar 19 % increase in emissions, the Scope 1 emissions associated with full- 3 scale operation would be in the order of 8,886.9 t CO2-e per year , resulting in total greenhouse gas emissions in the order of 14,760.9 t CO2-e per year (0.0148 Mt CO2-e per year) for the facility. Greenhouse gas emissions data for NSW for 2009 (the most recent available data) are summarised in Table 13. As shown, total NSW greenhouse gas (GHG) emissions were 160.5 Mt CO2-e, which represented 28 % of Australia's total emissions (564.5 Mt CO2-e). The principal source of GHG emission is from the electricity/gas/water sector, which accounts for 40 % of total NSW GHG emissions (64.3 Mt CO2-e). Other major sources are agriculture (15 %) and mining (13 %). Emissions from manufacturing, including metal production, accounted for 12 % of NSW total emissions in 2009 (approximately 19 Mt CO2-e).
Table 13 NSW Greenhouse Gas Emissions by Economic Sector, 2009
Sector Gg (1,000 Tonnes) Percentage of Total NSW Emissions (%) Div A Agriculture, forestry, fishing 24,169.72 15 Div B Mining 21,432.14 13 Div C Manufacturing 19,028.25 12 Div D Electricity, gas, water 64,287.69 40 Div E Construction 326.47 0 Div F-H, J-Q Commercial Services 5,427.99 3 Div I Transport & storage 10,473.90 7 Residential 15,418.98 10 Total of all Economic (ANZSIC) Sectors 160,565.13 100
Source: Australian Greenhouse Emissions Information System, Department of Climate Change and Energy Efficiency. (Tue Apr 03 16:53:07 2012); http://ageis.climatechange.gov.au/ANZSIC.aspx; accessed 3 April 2012 © 2010 Department of Climate Change and Energy Efficiency.
2 Based on the July 2011 National Greenhouse Accounts Factors emission factor of 0.89 kg CO2-e/kWh. 3 Assuming a19 % linear increase in emissions from 2010-11, as data on projected fuel use were not available at the time of preparation of this report
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Practices currently in place at the refinery to reduce GHG emissions include the regular tuning of furnace burners, which increases burner efficiency and reduces GHG emissions. Additionally, emissions of unburned methane and other natural gas constituents are unlikely to occur due to burner tuner and set-up, and the furnace temperature proposed for the project. Furthermore, Weston Aluminium’s predicted emissions represent approximately 0.078 % of the total NSW manufacturing emissions. As such, the proposed modification is not expected to significantly change with NSW or Australian emissions levels.
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9.0 Conclusion An air quality impact assessment was prepared for the proposed processing of SPL at the Weston Aluminium facility in Weston NSW. The objective of the investigation was to assess the potential change in pollutant concentrations experienced at sensitive receptors as a result of the modification to the facility’s operations. The AUSPLUME model was run using representative stack emissions data from both dross and SPL processing operations. Dispersion modelling predicted only minor changes to ground level pollutant concentrations as a result of the change to the processing activities at the Weston facility. With the exception of fluoride and cumulative PM10, all predicted pollutant concentrations complied with the relevant impact assessment criteria. Further analysis (through receptor-specific modelling) demonstrated that the exceedences of the fluoride criteria were confined to the site, and that acceptable levels were predicted at sensitive receptor locations. The exceedences of the 24 hour PM10 criterion were demonstrated to be solely attributable to elevated background concentrations; no additional exceedences were predicted to result from the operation of the facility processing either dross or SPL. On the basis of the dispersion modelling undertaken for this project, the processing of SPL at the facility is not expected to result in an unacceptable change to the expected emissions from the facility, and ground level pollutant concentrations at all sensitive receptors should be within acceptable levels.
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Appendix A
MSDS Excerpts
L:\60250487_Weston\Report\EPA Review\60250487_Revised_FINAL_Rpt_AQIA_8May12.docx Revision D - 8 May 2012 TOMAGO SPENT POTLINING CARBON BYPRODUCT Chemwatch Material Safety Data Sheet Issue Date: 7-Apr-2008 CHEMWATCH 4686-68 NC317ECP Version No:6 CD 2008/1 Page 2 of 20
Section 3 - COMPOSITION / INFORMATION ON INGREDIENTS
NAME CAS RN % carbon, non- activated 7440-44-0 50-75 silica crystalline - quartz 14808-60-7 0-6 sodium hydroxide 1310-73-2 2-4 sodium fluoride 7681-49-4 9-11 sodium aluminium fluoride 15096-52-3 3-8 calcium fluoride 7789-75-5 0-1 calcium oxide 1305-78-8 1-2 aluminium oxide 1344-28-1. 2-10 aluminium 7429-90-5 0-3^ iron 7439-89-6 0-1^ ferric oxide 1309-37-1 0-2^ sulfur 7704-34-9. 0-2^ free cyanide 0-0.1
Section 4 - FIRST AID MEASURES
SWALLOWED · If swallowed do NOT induce vomiting. · If vomiting occurs, lean patient forward or place on left side (head-down position, if possible) to maintain open airway and prevent aspiration. · Observe the patient carefully. · Never give liquid to a person showing signs of being sleepy or with reduced awareness; i.e. becoming unconscious. · Give water to rinse out mouth, then provide liquid slowly and as much as casualty can comfortably drink. · Seek medical advice.
EYE If this product comes in contact with the eyes: · Immediately hold eyelids apart and flush the eye continuously with running water. · Ensure complete irrigation of the eye by keeping eyelids apart and away from eye and moving the eyelids by occasionally lifting the upper and lower lids. · Continue flushing until advised to stop by the Poisons Information Centre or a doctor, or for at least 15 minutes. · Transport to hospital or doctor without delay. · Removal of contact lenses after an eye injury should only be undertaken by skilled personnel.
SKIN If skin contact occurs: · Immediately remove all contaminated clothing, including footwear. · Flush skin and hair with running water (and soap if available). · Seek medical attention in event of irritation.
INHALED · If dust is inhaled, remove from contaminated area. · Encourage patient to blow nose to ensure clear breathing passages. · Ask patient to rinse mouth with water but to not drink water. · Seek immediate medical attention. · If fumes or combustion products are inhaled remove from contaminated area. · Lay patient down. Keep warm and rested. · Prostheses such as false teeth, which may block airway, should be removed, where possible, prior to initiating first aid procedures.
continued... TOMAGO SPENT POTLINING REFRACTORY BYPRODUCT Chemwatch Material Safety Data Sheet Issue Date: 7-Apr-2008 CHEMWATCH 4686-69 NC317ECP Version No:6 CD 2008/1 Page 2 of 20
Section 3 - COMPOSITION / INFORMATION ON INGREDIENTS
NAME CAS RN % silica crystalline - quartz 14808-60-7 40-70 aluminium oxide 1344-28-1. 12-30 carbon, non- activated 7440-44-0 2-5 sodium hydroxide 1310-73-2 1-2 sodium fluoride 7681-49-4 5-11 sodium aluminium fluoride 15096-52-3 3-8 calcium fluoride 7789-75-5 0-1 calcium oxide 1305-78-8 1-5 aluminium 7429-90-5 0-1^ iron 7439-89-6 0-1^ ferric oxide 1309-37-1 2-4^ sulfur 7704-34-9. 0-1^ free cyanide 0-0.04
Section 4 - FIRST AID MEASURES
SWALLOWED · If swallowed do NOT induce vomiting. · If vomiting occurs, lean patient forward or place on left side (head-down position, if possible) to maintain open airway and prevent aspiration. · Observe the patient carefully. · Never give liquid to a person showing signs of being sleepy or with reduced awareness; i.e. becoming unconscious. · Give water to rinse out mouth, then provide liquid slowly and as much as casualty can comfortably drink. · Seek medical advice.
EYE If this product comes in contact with the eyes: · Immediately hold eyelids apart and flush the eye continuously with running water. · Ensure complete irrigation of the eye by keeping eyelids apart and away from eye and moving the eyelids by occasionally lifting the upper and lower lids. · Continue flushing until advised to stop by the Poisons Information Centre or a doctor, or for at least 15 minutes. · Transport to hospital or doctor without delay. · Removal of contact lenses after an eye injury should only be undertaken by skilled personnel.
SKIN If skin contact occurs: · Immediately remove all contaminated clothing, including footwear. · Flush skin and hair with running water (and soap if available). · Seek medical attention in event of irritation.
INHALED · If dust is inhaled, remove from contaminated area. · Encourage patient to blow nose to ensure clear breathing passages. · Ask patient to rinse mouth with water but to not drink water. · Seek immediate medical attention. · If fumes or combustion products are inhaled remove from contaminated area. · Lay patient down. Keep warm and rested. · Prostheses such as false teeth, which may block airway, should be removed, where possible, prior to initiating first aid procedures.
continued...
CHEM ALERT REPORT Extended Summary Report PRODUCT NAME SPENT POTLINING (HYDRO ALUMINIUM) IDENTIFICATION SUPPLIER HYDRO ALUMINIUM KURRI KURRI PTY LTD Ph:(02) 4937 1555 Emerg. Ph:(02) 4937 1555 STOCK NUMBER 522 CLASSIFIED AS HAZARDOUS ACCORDING TO NOHSC CRITERIA CLASSIFIED AS A DANGEROUS GOOD BY THE CRITERIA OF THE ADG CODE
Ingredient CAS No. Content ALUMINIUM 7429-90-5 5-20% CALCIUM OXIDE 1305-78-8 <3% CARBON 7440-44-0 26-72% ALUMINIUM OXIDE 1344-28-1 11-22% FLUORIDE 16984-48-8 7-22% SODIUM COMPOUND(S) Not Available 13-17% ALUMINIUM SODIUM OXIDE 11138-49-1 5-10% SILICON 7440-21-3 <10% SODIUM ALUMINOSILICATE 1344-00-9 3-7% CYANIDE 57-12-5 <0.7% Synonym(s) SPENT CATHODES • POTROOM CATHODE WASTES • SPL
Use(s) BRICK MANUFACTURE • BY-PRODUCT • PROCESS REAGENT BY-PRODUCT
UN No. 3170 Hazchem Code 4W Pkg Group III DG Class 4.3 Subsidiary Risk(s) None Allocated EPG 4A3 Poison Schedule 6 HEALTH HAZARDS Health Hazard Toxic - corrosive. This product has the potential to cause adverse health effects. Over exposure to fluorides may Summary result in mottling of dental enamel, and lung, bone (osteosclerosis, skeletal fluorosis) and kidney/ligament damage. CAUTION: Dangerous when wet - may evolve toxic and/or flammable gases upon contact with water.
Eye Corrosive - irritant. Contact may result in pain, redness and irritation with possible corneal burns and permanent damage. Inhalation Irritant. Over exposure may result in mucous membrane irritation. May cause respiratory sensitisation. Some studies report that chronic exposure to fine aluminium dust may cause asthma-like symptoms, lung fibrosis (restricting lung function) and a link with Alzheimers disease. Skin Corrosive. Contact may result in irritation, redness, itching, pain, rash and dermatitis.
Ingestion Toxic - corrosive. Ingestion may result in burns to the mouth and throat, nausea, vomiting, abdominal pain and diarrhoea. Due to product form, ingestion is considered unlikely. PRECAUTIONS Flammability Non flammable. May evolve flammable & toxic gases (hydrogen, phosphine, methane, ammonia) upon contact with water. May evolve fluorides, cyanides & metal oxides when heated to decomposition. Potentially explosive dust. Reactivity Incompatible with water (evolving flammable hydrogen gas), oxidising agents, acids (evolving hydrogen sulphide, hydrogen cyanide) alkalis, heat and ignition sources. Ventilation Do not inhale dust/vapours. Use in well ventilated areas. In poorly ventilated areas, mechanical explosion proof extraction ventilation is recommended.
Page 1 of 3 HYDRO ALUMINIUM KURRI KURRI Printed: 05 Mar 2009 Reviewed: 29 Oct 2003 Hazard Alert Code: TOMAGO DROSS EX CASTHOUSE TO REFINER MODERATE Chemwatch Material Safety Data Sheet Revision No: 2.0 Chemwatch 7502-26 Issue Date: 28-Jun-2004 CD 2008/2
Section 1 - CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: TOMAGO DROSS EX CASTHOUSE TO REFINER SYNONYMS "Casthouse dross", "aluminum alloy smelting dross residue", "dross fines", "aluminium skimmings", "pot skimmings" PROPER SHIPPING NAME ALUMINIUM SMELTING OR REMELTING BY- PRODUCTS PRODUCT USE Exported from the casthouse to Refiner. SUPPLIER Company: Tomago Aluminium Co Address: Tomago Road Tomago NSW, 2322 AUS Telephone: +61 2 4966 9669 Fax: +61 2 4966 9711 HAZARD RATINGS Min Max Flammability: 1
Toxicity: 1
Body Contact: 2 Min/Nil=0 Low=1 Reactivity: 1 Moderate=2 High=3 Chronic: 2 Extreme=4
Section 2 - HAZARDS IDENTIFICATION STATEMENT OF HAZARDOUS NATURE
HAZARDOUS SUBSTANCE. DANGEROUS GOODS. According to the Criteria of NOHSC, and the ADG Code.
POISONS SCHEDULE None RISK SAFETY Contact with water liberates extremely flammable gases. Never add water to this product. Harmful: danger of serious damage to health by prolonged exposure through Do not breathe dust. inhalation and if swallowed. Cumulative effects may result following exposure*. Wear suitable protective clothing. May produce discomfort of the respiratory system*. Keep container dry.
* (limited evidence). Use only in well ventilated areas. Keep container in a well ventilated place. Keep away from food drink and animal feeding stuffs. If swallowed IMMEDIATELY contact Doctor or Poisons Information Centre (show this container or label). This material and its container must be disposed of as hazardous waste.
Section 3 - COMPOSITION / INFORMATION ON INGREDIENTS NAME CAS RN % mixture of variable composition aluminium 7429-90-5 20-70 aluminium oxide 1344-28-1. 28-78 aluminium nitride 24304-00-5 <0.1 total fluorides as sodium aluminium fluoride 15096-52-3 1-2 potassium chloride 7447-40-7 <0.1 magnesium aluminate <0.1 Reacts with water or moisture to produce hydrogen 1333-74-0
Section 4 - FIRST AID MEASURES SWALLOWED Rinse mouth out with plenty of water. For advice, contact a Poisons Information Centre or a doctor. If swallowed do NOT induce vomiting. If vomiting occurs, lean patient forward or place on left side (head-down position, if possible) to maintain open airway and prevent aspiration. Observe the patient carefully. Never give liquid to a person showing signs of being sleepy or with reduced awareness; i.e. becoming unconscious Give water to rinse out mouth, then provide liquid slowly and as much as casualty can comfortably drink. Seek medical advice. Page 1 of 9
CHEM ALERT REPORT 16 Header Report
PRODUCT NAME PRIMARY ALUMINIUM DROSS
1. IDENTIFICATION OF THE MATERIAL AND SUPPLIER Stock Number 677 Supplier Name HYDRO ALUMINIUM KURRI KURRI PTY LTD Address P.O. Box 1 , Kurri Kurri, NSW, AUSTRALIA, 2327 Telephone (02) 4937 1555 Fax (02) 4937 3452 Emergency (02) 4937 1555
Synonym(s) ALUMINIUM SKIMMINGS • SKIM • CAST HOUSE DROSS • ELECTROLYSIS PROCESS DROSS
Use(s) ALUMINIUM PRODUCTION • BY-PRODUCT • PROCESS REAGENT BY-PRODUCT
2. HAZARDS IDENTIFICATION CLASSIFIED AS HAZARDOUS ACCORDING TO NOHSC CRITERIA
RISK PHRASES R15/29 Contact with water liberates toxic, highly flammable gas. R18 In use, may form flammable/explosive vapour-air mixture. R23 Toxic by inhalation. R36/38 Irritating to eyes and skin. SAFETY PHRASES S24/25 Avoid contact with skin and eyes. S3 Keep in a cool place. S56 Dispose of this material and its container at hazardous or special waste collection point. S9 Keep container in a well ventilated place. CLASSIFIED AS A DANGEROUS GOOD BY THE CRITERIA OF THE ADG CODE UN No. 3170 DG Class 4.3 Subsidiary Risk(s) None Allocated Pkg Group II Hazchem Code 4W EPG 4A3 3. COMPOSITION / INFORMATION ON INGREDIENTS
Ingredient Formula CAS No. Content ALUMINIUM Al 7429-90-5 10-90% MAGNESIUM OXIDE Mg-O 1309-48-4 <10% CRYOLITE Na3-Al-F6 15096-52-3 <5% ALUMINIUM OXIDE Al2-O3 1344-28-1 10-90% ALUMINIUM NITRIDE Al-N 24304-00-5 2-10% ALUMINIUM CARBIDE Not Available 1299-86-1 <5% OXIDES Not Available Not Available <5% POTASSIUM CHLORIDE KCl 7447-40-7 <1% SODIUM CHLORIDE Na-Cl 7647-14-5 <1% METAL ALLOYS Not Available Not Available Not Available
Page 1 of 5 HYDRO ALUMINIUM KURRI KURRI Reviewed: 01 Jan 2004 Printed: 15 Sep 2008 AECOM Environmental Assessment Air Quality Impact Assessment
Appendix B
Example Modelling Input File
L:\60250487_Weston\Report\EPA Review\60250487_Revised_FINAL_Rpt_AQIA_8May12.docx Revision D - 8 May 2012 Appendix A.txt 1 ______
Weston SPL AQIA - HF
______Concentration or deposition Concentration Emission rate units grams/second Concentration units microgram/m3 Units conversion factor 1.00E+06 Constant background concentration 0.00E+00 Terrain effects Egan method Smooth stability class changes? No Other stability class adjustments ("urban modes") None Ignore building wake effects? No Decay coefficient (unless overridden by met. file) 0.000 Anemometer height 10 m Roughness height at the wind vane site 0.300 m DISPERSION CURVES Horizontal dispersion curves for sources <100m high Pasquill-Gifford Vertical dispersion curves for sources <100m high Pasquill-Gifford Horizontal dispersion curves for sources >100m high Briggs Rural Vertical dispersion curves for sources >100m high Briggs Rural Enhance horizontal plume spreads for buoyancy? Yes Enhance vertical plume spreads for buoyancy? Yes Adjust horizontal P-G formulae for roughness height? Yes Adjust vertical P-G formulae for roughness height? Yes Roughness height 0.400m Adjustment for wind directional shear None
PLUME RISE OPTIONS Gradual plume rise? Yes Stack-tip downwash included? Yes Building downwash algorithm: PRIME method. Entrainment coeff. for neutral & stable lapse rates 0.60,0.60 Partial penetration of elevated inversions? No Disregard temp. gradients in the hourly met. file? No
and in the absence of boundary-layer potential temperature gradients given by the hourly met. file, a value from the following table (in K/m) is used:
Wind Speed Stability Class Category A B C D E F ______1 0.000 0.000 0.000 0.000 0.020 0.035 2 0.000 0.000 0.000 0.000 0.020 0.035 3 0.000 0.000 0.000 0.000 0.020 0.035 4 0.000 0.000 0.000 0.000 0.020 0.035 5 0.000 0.000 0.000 0.000 0.020 0.035 6 0.000 0.000 0.000 0.000 0.020 0.035 WIND SPEED CATEGORIES Boundaries between categories (in m/s) are: 1.54, 3.09, 5.14, 8.23, 10.80 WIND PROFILE EXPONENTS: "Irwin Urban" values (unless overridden by met. file) AVERAGING TIMES 24 hours 7 days 90 days ______1 ______
Weston SPL AQIA - HF Page 1 Appendix A.txt
SOURCE CHARACTERISTICS
______
STACK SOURCE: S1 X(m) Y(m) Ground Elev. Stack Height Diameter Temperature Speed 57265 69322 12m 15m 1.65m 88C 14.0m/s ______Effective building dimensions (in metres) ______Flow direction 10° 20° 30° 40° 50° 60° 70° 80° 90° 100° 110° 120° Effective building width 0 0 70 81 90 96 99 99 96 95 100 102 Effective building height 0 0 12 12 12 12 12 12 12 12 12 12 Along-flow building length 0 0 102 101 97 89 80 67 53 41 56 70 Along-flow distance from stack 0 0 -71 -64 -54 -43 -31 -18 -4 9 7 4 Across-flow distance from stack 0 0 -39 -42 -43 -44 -43 -41 -37 -32 -27 -20 Flow direction 130° 140° 150° 160° 170° 180° 190° 200° 210° 220° 230° 240° Effective building width 101 97 89 80 67 53 0 0 70 81 90 96 Effective building height 12 12 12 12 12 12 0 0 12 12 12 12 Along-flow building length 81 90 96 99 99 96 0 0 102 101 97 89 Along-flow distance from stack 1 -1 -4 -7 -9 -11 0 0 -31 -37 -42 -46 Across-flow distance from stack -14 -6 1 9 16 23 0 0 39 42 43 44
Flow direction 250° 260° 270° 280° 290° 300° 310° 320° 330° 340° 350° 360° Effective building width 99 99 96 95 100 102 101 97 89 80 67 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 80 67 53 41 56 70 81 90 96 99 99 96 Along-flow distance from stack -48 -49 -49 -50 -63 -74 -82 -88 -92 -92 -90 -85 Across-flow distance from stack 43 41 37 32 27 20 14 6 -1 -9 -16 -23 (Constant) emission rate = 3.50E-03 grams/second No gravitational settling or scavenging.
STACK SOURCE: S5 X(m) Y(m) Ground Elev. Stack Height Diameter Temperature Speed 57347 69347 12m 20m 1.49m 60C 18.0m/s ______Effective building dimensions (in metres) ______Flow direction 10° 20° 30° 40° 50° 60° 70° 80° 90° 100° 110° 120° Effective building width 0 56 70 81 90 96 99 99 0 0 0 0 Effective building height 0 12 12 12 12 12 12 12 0 0 0 0 Along-flow building length 0 100 102 101 97 89 80 67 0 Page 2 Appendix A.txt 0 0 0 Along-flow distance from stack 0 -128 -134 -136 -133 -127 -117 -103 0 0 0 0 Across-flow distance from stack 0 34 20 5 -10 -24 -38 -51 0 0 0 0 Flow direction 130° 140° 150° 160° 170° 180° 190° 200° 210° 220° 230° 240° Effective building width 0 0 0 0 0 0 0 0 0 0 0 0 Effective building height 0 0 0 0 0 0 0 0 0 0 0 0 Along-flow building length 0 0 0 0 0 0 0 0 0 0 0 0 Along-flow distance from stack 0 0 0 0 0 0 0 0 0 0 0 0 Across-flow distance from stack 0 0 0 0 0 0 0 0 0 0 0 0 Flow direction 250° 260° 270° 280° 290° 300° 310° 320° 330° 340° 350° 360° Effective building width 0 0 0 0 0 0 0 0 0 0 0 0 Effective building height 0 0 0 0 0 0 0 0 0 0 0 0 Along-flow building length 0 0 0 0 0 0 0 0 0 0 0 0 Along-flow distance from stack 0 0 0 0 0 0 0 0 0 0 0 0 Across-flow distance from stack 0 0 0 0 0 0 0 0 0 0 0 0
(Constant) emission rate = 8.00E-03 grams/second No gravitational settling or scavenging.
STACK SOURCE: S6
X(m) Y(m) Ground Elev. Stack Height Diameter Temperature Speed 57302 69325 12m 18m 0.58m 378C 16.0m/s
______Effective building dimensions (in metres) ______Flow direction 10° 20° 30° 40° 50° 60° 70° 80° 90° 100° 110° 120° Effective building width 41 56 70 81 90 96 99 99 96 95 100 102 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 95 100 102 101 97 89 80 67 53 41 56 70 Along-flow distance from stack -89 -92 -92 -90 -85 -77 -67 -55 -41 -27 -27 -27 Across-flow distance from stack 6 -1 -8 -15 -22 -28 -33 -37 -40 -41 -42 -41 Flow direction 130° 140° 150° 160° 170° 180° 190° 200° 210° 220° 230° 240° Effective building width 101 97 89 80 67 53 41 56 70 81 90 96 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 81 90 96 99 99 96 95 100 102 101 97 89 Along-flow distance from stack -25 -23 -20 -16 -12 -8 -6 -8 -9 -11 -12 -12 Across-flow distance from stack -40 -36 -32 -27 -21 -15 -6 1 8 15 22 28
Page 3 Appendix A.txt Flow direction 250° 260° 270° 280° 290° 300° 310° 320° 330° 340° 350° 360° Effective building width 99 99 96 95 100 102 101 97 89 80 67 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 80 67 53 41 56 70 81 90 96 99 99 96 Along-flow distance from stack -13 -13 -12 -14 -29 -43 -56 -67 -76 -82 -86 -88 Across-flow distance from stack 33 37 40 41 42 41 40 36 32 27 21 15 (Constant) emission rate = 3.30E-03 grams/second No gravitational settling or scavenging.
STACK SOURCE: S2 X(m) Y(m) Ground Elev. Stack Height Diameter Temperature Speed 57310 69262 12m 15m 1.26m 42C 14.0m/s ______Effective building dimensions (in metres) ______Flow direction 10° 20° 30° 40° 50° 60° 70° 80° 90° 100° 110° 120° Effective building width 41 56 70 81 90 96 99 50 40 32 43 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 95 100 102 101 97 89 80 88 87 85 88 88 Along-flow distance from stack -28 -36 -42 -47 -50 -52 -53 -1 4 9 9 9 Across-flow distance from stack 25 28 30 31 31 31 29 -30 -24 -17 -6 4
Flow direction 130° 140° 150° 160° 170° 180° 190° 200° 210° 220° 230° 240° Effective building width 64 74 81 80 67 53 41 56 70 81 90 96 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 85 80 72 99 99 96 95 100 102 101 97 89 Along-flow distance from stack 9 8 7 -78 -76 -71 -67 -64 -60 -54 -46 -37 Across-flow distance from stack 13 22 30 -13 -18 -23 -25 -28 -30 -31 -31 -31
Flow direction 250° 260° 270° 280° 290° 300° 310° 320° 330° 340° 350° 360° Effective building width 99 50 40 32 43 53 64 74 81 80 67 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 80 88 87 85 88 88 85 80 72 99 99 96 Along-flow distance from stack -27 -87 -91 -94 -97 -97 -94 -88 -80 -20 -23 -25 Across-flow distance from stack -29 30 24 17 6 -4 -13 -22 -30 13 18 23 (Constant) emission rate = 1.40E-02 grams/second No gravitational settling or scavenging.
STACK SOURCE: S3
Page 4 Appendix A.txt X(m) Y(m) Ground Elev. Stack Height Diameter Temperature Speed 57310 69272 12m 15m 1.00m 35C 8.7m/s ______Effective building dimensions (in metres) ______Flow direction 10° 20° 30° 40° 50° 60° 70° 80° 90° 100° 110° 120° Effective building width 41 56 70 81 90 96 99 99 96 95 43 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 95 100 102 101 97 89 80 67 53 41 88 88 Along-flow distance from stack -38 -45 -50 -54 -57 -57 -56 -53 -49 -44 12 14 Across-flow distance from stack 23 25 25 25 24 22 20 17 13 9 -16 -4 Flow direction 130° 140° 150° 160° 170° 180° 190° 200° 210° 220° 230° 240° Effective building width 64 74 81 80 67 53 41 56 70 81 90 96 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 85 80 72 99 99 96 95 100 102 101 97 89 Along-flow distance from stack 15 16 16 -69 -66 -61 -57 -55 -51 -46 -40 -32 Across-flow distance from stack 6 15 25 -17 -20 -23 -23 -25 -25 -25 -24 -22
Flow direction 250° 260° 270° 280° 290° 300° 310° 320° 330° 340° 350° 360° Effective building width 99 99 96 95 43 53 64 74 81 80 67 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 80 67 53 41 88 88 85 80 72 99 99 96 Along-flow distance from stack -23 -14 -4 3 -100 -102 -100 -96 -88 -30 -33 -35 Across-flow distance from stack -20 -17 -13 -9 16 4 -6 -15 -25 17 20 23
(Constant) emission rate = 1.00E-03 grams/second No gravitational settling or scavenging.
STACK SOURCE: S4
X(m) Y(m) Ground Elev. Stack Height Diameter Temperature Speed 57314 69296 12m 15m 1.39m 41C 14.0m/s ______Effective building dimensions (in metres) ______Flow direction 10° 20° 30° 40° 50° 60° 70° 80° 90° 100° 110° 120° Effective building width 41 56 70 81 90 96 99 99 96 95 100 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 95 100 102 101 97 89 80 67 53 41 56 88 Along-flow distance from stack -62 -69 -73 -75 -75 -73 -68 -62 -53 -44 -48 22 Across-flow distance from stack 23 20 17 12 8 3 -2 -6 -11 -15 -19 -27
Flow direction 130° 140° 150° 160° 170° 180° 190° 200° 210° 220° 230° 240° Page 5 Appendix A.txt Effective building width 101 97 89 80 67 53 41 56 70 81 90 96 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 81 90 96 99 99 96 95 100 102 101 97 89 Along-flow distance from stack -53 -53 -51 -48 -43 -37 -33 -31 -29 -25 -21 -17 Across-flow distance from stack -25 -27 -28 -28 -28 -27 -23 -20 -17 -12 -8 -3 Flow direction 250° 260° 270° 280° 290° 300° 310° 320° 330° 340° 350° 360° Effective building width 99 99 96 95 100 53 64 74 81 80 67 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 80 67 53 41 56 88 85 80 72 99 99 96 Along-flow distance from stack -11 -6 0 3 -8 -110 -113 -111 -107 -51 -56 -59 Across-flow distance from stack 2 6 11 15 19 27 15 3 -9 28 28 27 (Constant) emission rate = 2.20E-05 grams/second No gravitational settling or scavenging.
STACK SOURCE: S7
X(m) Y(m) Ground Elev. Stack Height Diameter Temperature Speed 57325 69226 12m 15m 1.50m 23C 16.0m/s
______Effective building dimensions (in metres) ______Flow direction 10° 20° 30° 40° 50° 60° 70° 80° 90° 100° 110° 120° Effective building width 85 88 88 85 80 72 62 50 40 32 43 53 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 32 43 53 64 74 81 86 88 87 85 88 88 Along-flow distance from stack 0 1 1 -1 -3 -6 -8 -9 -11 -12 -18 -22 Across-flow distance from stack -30 -26 -22 -17 -11 -5 1 8 12 16 23 28
Flow direction 130° 140° 150° 160° 170° 180° 190° 200° 210° 220° 230° 240° Effective building width 64 74 81 80 67 87 85 88 88 85 80 72 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 85 80 72 99 99 40 32 43 53 64 74 81 Along-flow distance from stack -26 -29 -31 -117 -114 -32 -32 -44 -54 -63 -70 -75 Across-flow distance from stack 31 34 35 -15 -27 33 30 26 22 17 11 5 Flow direction 250° 260° 270° 280° 290° 300° 310° 320° 330° 340° 350° 360° Effective building width 62 50 40 32 43 53 64 74 81 80 67 87 Effective building height 12 12 12 12 12 12 12 12 12 12 12 12 Along-flow building length 86 88 87 85 88 88 85 80 72 99 99 40 Page 6 Appendix A.txt Along-flow distance from stack -78 -78 -76 -73 -70 -66 -59 -51 -41 19 15 -8 Across-flow distance from stack -1 -8 -12 -16 -23 -28 -31 -34 -35 15 27 -33 (Constant) emission rate = 1.60E-02 grams/second No gravitational settling or scavenging. ______1 ______
Weston SPL AQIA - HF
RECEPTOR LOCATIONS
______The Cartesian receptor grid has the following x-values (or eastings): 55200.m 55400.m 55600.m 55800.m 56000.m 56200.m 56400.m 56600.m 56800.m 57000.m 57200.m 57400.m 57600.m 57800.m 58000.m 58200.m 58400.m 58600.m 58800.m 59000.m 59200.m and these y-values (or northings): 67600.m 67800.m 68000.m 68200.m 68400.m 68600.m 68800.m 69000.m 69200.m 69400.m 69600.m 69800.m 70000.m 70200.m 70400.m 70600.m 70800.m
______
METEOROLOGICAL DATA : Weston SEE Wind Roses
______
Page 7
AECOM Environmental Assessment Air Quality Impact Assessment
CAppendix C
Excerpts from Weston Stack Emissions Testing Reports 2011/12
L:\60250487_Weston\Report\EPA Review\60250487_Revised_FINAL_Rpt_AQIA_8May12.docx Revision D - 8 May 2012 Weston Aluminium Pty Ltd Commercial-in-Confidence 14 March 2011
Emissions Testing Report 2011 Annual Testing
Weston Aluminium
NATA ACCREDITATION No. 2778 (14391) Accredited for compliance with ISO/IEC 17025 This document is issued in accordance with NATA’s accreditation requirements. This document may not be reproduced except in full.
AECOM Emissions Testing Report 2011 Annual Testing
Emissions Testing Report 2011 Annual Testing Weston Aluminium
Prepared for Weston Aluminium Pty Ltd PO Box 295 Kurri Kurri NSW 2327 Attn: Mr Christopher McClung Plant Manager
Prepared by
AECOM Australia Pty Ltd 17 Warabrook Boulevarde, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T +61 2 4911 4900 F +61 2 4911 4999 www.aecom.com ABN 20 093 846 925
14 March 2011
60195964
AECOM in Australia and New Zealand is certified to the latest version of ISO9001 and ISO14001.
© AECOM Australia Pty Ltd (AECOM). All rights reserved.
AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and AECOM’s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety.
60195964 14 March 2011 Commercial-in-Confidence AECOM Emissions Testing Report 2011 Annual Testing
Quality Information
Document Emissions Testing Report 2011 Annual Testing
60195964 Ref k:\60162060_weston 1&7\stack 1 additional and stack 7\weston 2011\60195964_rpt_feb11.docx
Date 14 March 2011
Prepared by Cye Buckland NATA Signatory
Reviewed by Chad Whitburn NATA Signatory
Revision History
Authorised Revision Revision Details Date Name/Position Signature
1.0 14-Mar-2011 Chad WhitburnSenior Professional/ Workgroup Leader
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Table of Contents 1.0 Introduction 1 2.0 Sampling Plane Requirements 3 3.0 Methodology 5 3.1 NATA Accredited Methods 5 4.0 Sampling Location 7 4.1 Sampling Location Summary 7 5.0 Equipment Calibration 9 6.0 Results 11 7.0 References 32
List of Tables Table 1: Criteria for Selection of Sampling Planes (AS 4323. 1- 1995) 3 Table 2: AECOM NATA Endorsed Methods 5 Table 3: Sampling Location Summary 7 Table 4: Air Emission Results Summary, Stack 1 – 2011 11 Table 5: Air Emission Results Summary, Stacks 2, 3 and 4 – 2011 11 Table 6: Air Emission Results Summary – Stack 5 – 2011 12 Table 7: Calculated PM10 Cut Sizes 12 Table 8: Stack 1 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 13 January 2011 13 Table 9: Stack 1 Sulfuric Acid Mist (H2SO4 as SO3) and Sulfur Dioxide (SO2 as SO3) Results, 13 January 2011 14 Table 10: Stack 1 Hazardous substances (Metals), Hydrogen Chloride and Chlorine Results, 13 January 2011 15 Table 11: Stack 1 Polycyclic Aromatic Hydrocarbons (PAH) Results, 14 January 2011 16 Table 12: Stack 2 Fine Particulate (PM10), Total Particulate and Particulate/Gaseous Fluoride Results, 12 January 2011 17 Table 13: Stack 3 Fine Particulate (PM10), Total Particulate and Particulate/Gaseous Fluoride Results, 12 January 2011 18 Table 14: Stack 4 Fine Particulate (PM10), Total Particulate and Particulate/Gaseous Fluoride Results, 11 January 2011 19 Table 15: Stack 5 Fine Particulate (PM10) and Total Particulate Results, 24 January 2011 20 Table 16: Stack 5 Hydrogen Chloride and Chlorine Results, 24 January 2011 21 Table 17: Stack 5 Hazardous Substances (Metals), Particulate Fluoride and Gaseous Fluoride Results, 25 January 2011 22 Table 18: Stack 5 Sulfuric Acid Mist (H2SO4 as SO3) and Sulfur Dioxide (SO2 as SO3) Results, 25 January 2011 23 Table 19: Stack 5 Dioxins and Furans and Polycyclic Aromatic Hydrocarbons (PAH) Results 24 January 2011 24 Table 20: Stack 5 Dioxins and Furans and Polycyclic Aromatic Hydrocarbon Results, 24 January 2011 25 Table 21: Stack 5 Speciated Polycyclic Aromatic Hydrocarbons (PAH) Results, 24 January 2011 26 Table 22: Stack 1 Speciated Volatile Organic Compounds (VOC) Results, 13 January 2011 27 Table 23: Stack 5 Speciated Volatile Organic Compounds (VOC) Results, 25 January 2011 28 Table 24: Stack 1 Speciated Polycyclic Aromatic Hydrocarbons (PAH) Results, 14 January 2011 29 Table 25: Stack 1 Speciated Hazardous Substances (Metals) Results, 13 January 2011 30 Table 26: Stack 5 Speciated Hazardous Substances (Metals) Results, 25 January 2011 31
List of Appendices Appendix A Field Sheets 159 pages Appendix B Raw and Calculated Gas 19 pages Appendix C Laboratory Analysis Reports 35 pages
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1.0 Introduction AECOM was appointed by Weston Aluminium Pty Ltd to conduct a series of measurements to determine air emissions from five stacks located at their Weston plant in Kurri Kurri, NSW. Emission testing was a compliance requirement of Environmental Protection Licence (EPL) number 6423. Testing was conducted over the period 11 January to 25 January 2011 to determine emission concentrations for EPL Points 1, 2, 3, 4 and 13 for the following parameters: Total Particulate (TP);
Fine Particulate (PM10); Particulate Fluoride; and Gaseous Fluoride. Additional testing was undertaken on EPL Points 1 and 13 for: Sulfuric Acid Mist; Sulfur Dioxide; Hazardous Substances (Metals); Polycyclic Aromatic Hydrocarbons (PAH); Volatile Organic Compounds (VOCs);
Oxides of Nitrogen (NOx as Equivalent NO2); Carbon Monoxide (CO); and
Oxygen (O2). Sampling was also undertaken for the following parameters on EPL Point 1: Hydrogen Chloride (HCl); Chlorine (Cl); and Volatile Organic Compounds (VOCs). Laboratory analysis was conducted by the following laboratories, which hold NATA accreditation for the specified tests: Australian Laboratory Services, NATA Accreditation No. 825, laboratory report number EN1100231 for analysis of: - Sulfuric Acid Mist; - Sulfur Dioxide; - Hydrogen Chloride; - Chlorine; - Total Particulate; - Fine Particulate; - Particulate and Gaseous Fluoride; and - Volatile Organic Compounds (VOCs). National Measurement Institute (NMI), NATA Accreditation No. 198, laboratory report number DAU11_027, ORG11_001 and ORG11_005 for analysis of: - Polycyclic Aromatic Hydrocarbons; and - Dioxins and Furans.
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SGS Environmental, NATA Accreditation No. 2562, performed the following analysis detailed in report number SE85169: - Hazardous Substances (Metals).
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2.0 Sampling Plane Requirements The criteria for sampling planes are specified in AS 4323.1-1995.
Table 1: Criteria for Selection of Sampling Planes (AS 4323. 1- 1995)
Minimum distance Minimum distance upstream Type of flow disturbance downstream from from disturbance, diameters (D) disturbance, diameters (D) Bend, connection, junction, >2D >6D direction change Louvre, butterfly damper >3D >6D (partially closed or closed) Axial fan >3D >8D (see Note) Centrifugal fan >3D >6D NOTE: The plane should be selected as far as practicable from a fan. Flow straighteners may be required to ensure the position chosen meets the check criteria listed in Items (a) to (f) below. a. The gas flow is basically in the same direction at all points along each sampling traverse. b. The gas velocity at all sampling points is greater than 3 m/s. c. The gas flow profile at the sampling plane shall be steady, evenly distributed and not have a cyclonic component which exceeds an angle of 15o to the duct axis, when measured near the periphery of a circular sampling plane. d. The temperature difference between adjacent points of the survey along each sampling traverse is less than 10% of the absolute temperature, and the temperature at any point differs by less than 10% from the mean. e. The ratio of the highest to lowest pitot pressure difference shall not exceed 9:1 and the ratio of highest to lowest gas velocities shall not exceed 3:1. For isokinetic testing with the use of impingers, the gas velocity ratio across the sampling plane should not exceed 1.6:1. f. The gas temperature at the sampling plane should preferably be above the dewpoint. The sampling planes for Stacks 2, 3, 4 and 5 (EPA Identification No. 2, 3, 4 and 13 respectively) were in accordance with AS 4323.1 Section 4.1. Stack 1 (EPA Identification No. 1) did not satisfy the requirements of AS 4323.1 Section 4.1 – 1995 with regard to the upstream and downstream distances from disturbances. To compensate for this, additional sampling points were added in accordance with AS 4323.1 Section 4.2 – 1995.
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3.0 Methodology
3.1 NATA Accredited Methods The following methods are accredited with the National Association of Testing Authorities (NATA), Accreditation No. 2778 (14391), and are approved for the sampling and analysis of gases and aerosols. Specific details of the methods are available on request. All sampling and analysis is conducted according to the methods in Table 2.
Table 2: AECOM NATA Endorsed Methods
NSW DECC Approved USEPA Methods Parameter measured Methods NSW DECC TM-1 USEPA (2000) Method 1 under approved Selection of sampling positions (AS 4323.1-1995) circumstances USEPA (2000) Method 2 or 2C or USEPA Velocity or volumetric flow rate or NSW DECC TM-2 (1999) Method 2F or 2G or 2H (as appropriate) temperature or pressure of stack gases USEPA (2000) Method 8 (for sampling and analysis) or APHA (1998) Method 4110B (for Sulfuric acid mist (H2SO4) or sulphur analysis only if interference from fluorides, free NSW DECC TM-3 trioxide (SO3) ammonia and/or dimethyl aniline has been
demonstrated to the satisfaction of the Chief Scientist) (as appropriate) USEPA (2000) Method 6 or 6A or 6B or USEPA (1996) Method 6C or ISO (1989) Method 7934 Sulfur dioxide (SO2) NSW DECC TM-4 or ISO (1992) Method 7935 or ISO (1993)
Method 10396 or ISO (1998) Method 11632 (as appropriate) Chlorine (Cl2) NSW DECC TM-7 USEPA (2000) 26A
Hydrogen chloride (HCl) NSW DECC TM-8 USEPA (2000) 26A
Fluorine (F2) or any compound USEPA (2000) Method 13A or 13B (as containing fluorine, except where NSW DECC TM-9 appropriate) emitted by a primary aluminium smelter while manufacturing aluminium from alumina Type 1 substances (elements antimony USEPA (2000) Method 29 or USEPA (2000) (Sb), arsenic (As), cadmium (Cd), lead Method 102 (for mercury only in hydrogen rich NSW DECC TM-12 (Pb) or mercury (Hg) or any compound streams) (as appropriate) containing one or more of those
elements) USEPA (2000) Method 29 (Analysis for tin and Type 2 substances (elements beryllium vanadium to be done by Inductively Coupled (Be), chromium (Cr), cobalt (Co), NSW DECC TM-13 Argon Plasma Emission Spectroscopy (ICAP) manganese (Mn), nickel (Ni), selenium as defined in USEPA Method 29) or USEPA (Se), tin (Sn) or vanadium (V) or any (1986) Method 7910 (for vanadium only) or compound containing one or more of USEPA (1986) Method 7911 (for vanadium those elements) only) (as appropriate)
NSW DECC TM-14 Cadmium (Cd) or mercury (Hg) or any USEPA (2000) Method 29 or USEPA compound containing one or more of those (2000) Method 102 (for mercury only in elements hydrogen rich streams) (as appropriate)
NSW DECC TM-15 USEPA (2000) Method 5 under approved Solid particles (Total) (AS 4323.2-1995) circumstances
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NSW DECC Approved USEPA Methods Parameter measured Methods NSW DECC TM-22 USEPA (2000) Method 4 Moisture content in stack gases
Dry gas density or molecular weight of NSW DECC TM-23 USEPA (2000) Method 3 stack gases USEPA (2000) Method 18 or USEPA NSW DECC TM-34 (2000) Method 25 or 25A or 25B or 25C or Volatile organic compounds 25D or 25E (as appropriate) USEPA (1997) Method 201 or 201A (as NSW DECC OM-5 ‘Fine’ particulates (PM ) appropriate) 10 California EPA Air Resources Board (1997) Polycyclic aromatic hydrocarbons NSW DECC OM-6 Method 429 (PAHs) NSW DECC TM-18 USEPA (1995) Method 23 Dioxins and furans NSW DECC TM-32 USEPA Method 10 Determination of Carbon Monoxide emissions from stationary sources
NSW DECC TM-25 USEPA Method 3A Determination of Oxygen concentrations from stationary sources
NSW DECC TM-11 USEPA(2000) Method 7C Determination of Nitrogen dioxide or nitric oxide emissions from stationary sources All parameters are reported adjusted to 0oC at 1 atmosphere and dry gas
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4.0 Sampling Location
4.1 Sampling Location Summary Table 3 provides a summary of the location sampled by AECOM during January 2011 at the Weston Aluminium plant in Kurri Kurri, NSW.
Table 3: Sampling Location Summary
Stack 1 Stack 2 Stack 3 Stack 4 Stack 5 Discharge (EPA (EPA (EPA (EPA (EPA Description Identifica- Identifica- Identifica- Identifica- Identifica- tion No. 1) tion No. 2) tion No. 3) tion No. 4) tion No. 13) Duct Shape Circular Circular Circular Circular Circular Construction Metal Metal Metal Metal Metal Material Duct Diameter 1650 1265 1000 1395 1490 (mm) Minimum No. 16 12 12 12 12 Sampling Points Sampling Ports 2 2 2 2 2 Min. 8 6 6 6 6 Points/Traverse Disturbance Yes No No No No Distance from Upstream 2D 6D 6D 6D 7D Disturbance Type of Fan entry Fan entry Fan entry Fan entry Fan entry Disturbance Distance from Downstream 4D 6D 7D 4D 7D Disturbance Type of Stack exit Stack exit Stack exit Stack exit Stack exit Disturbance Ideal Sampling No Yes Yes Yes Yes Location Correction Yes No No No No Factors Applied Total No. Points 20 12 12 12 12 Sampled Points/Traverse 10 6 6 6 6 Sampling Performed to Yes2 Yes1 Yes1 Yes1 Yes1 Standard* *AS 4323.1 Stationary source emissions Method 1 – Selection of sampling positions 1 AS 4323.1 Section 4.1 2 AS 4323.1 Section 4.2
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5.0 Equipment Calibration AECOM has a calibration schedule to ensure the emission testing equipment is maintained in good order and with known calibration. Equipment used in this project was calibrated according to the procedures and frequency identified in the AECOM calibration schedule. Details of the schedule and the calibration calculations are available on request.
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6.0 Results A summary of test results for the 2011 annual testing is presented in Tables 4 to 6. Calculated Fine Particulate (PM10) cut sizes for all stacks tested are displayed in Table 7. Detailed results along with gas stream properties during the testing periods can be found in Tables 8 to 18. Tables 19 to 23 provide speciated results for Polycyclic Aromatic Hydrocarbons, Volatile Organic Compounds and Hazardous Substances (Metals). All emission concentrations are converted to standard conditions of 0oC, dry gas and 1 atm pressure for comparison with regulatory limits outlined in the revised Weston Aluminium licence (variation dated 10 August 2010). Field notes recorded during the project are attached as Appendix A. Raw and calculated gas data can be viewed in Appendix B, with Laboratory Analysis Reports attached as Appendix C.
Table 4: Air Emission Results Summary, Stack 1 – 2011
Stack 1 Regulatory Limit Parameter (EPA point 1) (mg/m3) Total Particulate (mg/m3) 6.9 25 3 Fine Particulate (PM10) (mg/m ) 0.73 Not Listed Hydrogen Chloride (mg/m3) 0.15 400 Chlorine (mg/m3) 0.11 Not Listed Particulate Fluoride (mg/m3) 0.27 Not Listed Gaseous Fluoride (mg/m3) <0.076 2 3 Sulfuric Acid Mist (H2SO4 as SO3) (mg/m ) <1.6 100 3 Sulfur Dioxide (SO2 as SO3) (mg/m ) <8 Not Listed Total Hazardous Substances (Metals) (mg/m3) 0.035 10 Total Polycyclic Aromatic Hydrocarbons (mg/m3) 0.15 Not Listed Volatile Organic Compounds (VOC) (mg/m3) 2.9 Not Listed Total Oxides of Nitrogen 3 1.4 2500 (as Equivalent NO2) (mg/m ) Carbon Monoxide (CO) (mg/m3) 2.4 100
Table 5: Air Emission Results Summary, Stacks 2, 3 and 4 – 2011
Stack 2 Stack 3 Stack 4 Parameter Regulatory Limit (mg/m3) (EPA point 2) (EPA point 3) (EPA point 4) Stack 2 (EPA point 2) – 35.0 Total Particulate 0.47 0.43 0.59 Stack 3 (EPA point 3) – 50.0 (mg/m3) Stack 4 (EPA point 4) – 24.0 Fine Particulate 3 <0.14 <0.15 0.13 Not Listed (PM10) (mg/m ) Particulate 0.0042 0.0022 0.0062 Not Listed Fluoride (mg/m3) Gaseous Fluoride <0.14 <0.11 <0.12 Not Listed (mg/m3)
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Table 6: Air Emission Results Summary – Stack 5 – 2011
Emission Parameter Regulatory Limit Concentration Total Particulate (mg/m3) 0.76 10 3 Fine Particulate (PM10) (mg/m ) 0.69 Not Listed Particulate Fluoride (mg/m3) 0.0071 Not Listed Gaseous Fluoride (mg/m3) 0.31 Not Listed Hydrogen Chloride (HCl) (mg/m3) <0.18 10 Chlorine (mg/m3) <0.18 Not Listed 3 Sulfuric Acid Mist (H2SO4 as SO3) (mg/m ) <3 100 3 Sulfur Dioxide (SO2 as SO3) (mg/m ) <15 Not Listed Hazardous Substances (Metals) (mg/m3) 0.078 5 Dioxins and Furans (Lower Bound) (ng/m3) 0.034 0.1 Dioxins and Furans (Middle Bound) (ng/m3) 0.035 0.1 Volatile Organic Compounds (VOC) (mg/m3) 1.5 Not Listed Total Polycyclic Aromatic Hydrocarbons (g/m3) 0.024 Not Listed 3 Total Oxides of Nitrogen (as Equivalent NO2) (mg/m ) 3.4 100 Carbon Monoxide (CO) (mg/m3) 5.3 125
Oxygen (O2) (%) 20.0 Not Listed
USEPA Method 201A, Section 6.3.5, specifies that fine particulate (PM10) results are acceptable provided the calculated cut size (D50) for the testing lies between 9.0 and 11.0 µm. Post sampling calculations for the PM10 sampling performed at Weston Aluminium during January 2011 resulted in calculated cut sizes displayed in Table 7.
Table 7: Calculated PM10 Cut Sizes
Sampling Location PM10 Cut Size (D50) Stack 1 10.0 Stack 2 10.1 Stack 3 10.6 Stack 4 9.8 Stack 5 10.2 All of the calculated cut sizes meet the criteria for cut size conditions stated above.
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Table 8: Stack 1 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 13 January 2011
Sampling Conditions: Stack internal diameter at test location 1650 mm Stack gas temperature (average) 58.9 oC 332.1 K Stack pressure (average) 1016 hPa Stack gas velocity (average, stack conditions) 16 m/s Stack gas flowrate (stack conditions) 35 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 28 m3/s
Fine Particulate (PM10) Testing Test Period 10:38 - 12:20
Fine Particulate (PM10) Mass 0.9 mg Gas Volume Sampled 1.24 m3 1 3 Fine Particulate (PM10) Emission* 0.73 mg/m 2 Fine Particulate (PM10) Mass Emission Rate* 21 mg/s Regulatory Limit NA Total Particulate Testing Test Period 10:38 - 12:20 Total Particulate Mass 7.5 mg Gas Volume Sampled 1.09 m3 Total Particulate Emission*1 6.9 mg/m3 Total Particulate Mass Emission Rate*2 200 mg/s Regulatory Limit 25 mg/m3 Particulate Fluoride Testing Test Period 10:38 - 12:20 Particulate Fluoride Mass 0.358 mg Gas Volume Sampled 1.31 m3 Particulate Fluoride Emission*1 0.27 mg/m3 Particulate Fluoride Mass Emission Rate*2 7.6 mg/s Regulatory Limit NA Gaseous Fluoride Testing Test Period 10:38 - 12:20 Gaseous Fluoride Mass <0.1 mg Gas Volume Sampled 1.31 m3 Gaseous Fluoride Emission*1 <0.076 mg/m3 Gaseous Fluoride Mass Emission Rate*2 <2.1 mg/s Regulatory Limit 2 mg/m3 Moisture Content (%) 2.3 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations for each test.
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Table 9: Stack 1 Sulfuric Acid Mist (H2SO4 as SO3) and Sulfur Dioxide (SO2 as SO3) Results, 13 January 2011
Sampling Conditions: Stack internal diameter at test location 1650 mm Stack gas temperature (average) 57.7 oC 330.9 K Stack pressure (average) 1016 hPa Stack gas velocity (average, stack conditions) 16 m/s Stack gas flowrate (stack conditions) 34 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 27 m3/s
Sulfuric Acid Mist (H2SO4 as SO3) Testing Test Period 13:39 - 15:23
Sulfuric Acid Mist (H2SO4 as SO3) Mass <2 mg Gas Volume Sampled 1.24 m3
1 3 Sulfuric Acid Mist (H2SO4 as SO3) Emission* <1.6 mg/m 2 Sulfuric Acid Mist (H2SO4 as SO3) Mass Emission Rate* <44 mg/s Regulatory Limit 100 mg/m3
Sulfur Dioxide (SO2 as SO3) Testing Test Period 13:39 - 15:23
Sulfur Dioxide (SO2 as SO3) Mass <10 mg Gas Volume Sampled 1.24 m3
1 3 Sulfur Dioxide (SO2 as SO3) Emission* <8 mg/m 2 Sulfur Dioxide (SO2 as SO3) Mass Emission Rate* <220 mg/s Regulatory Limit NA Moisture Content (%) 2.5 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 10: Stack 1 Hazardous substances (Metals), Hydrogen Chloride and Chlorine Results, 13 January 2011
Sampling Conditions: Stack internal diameter at test location 1650 mm Stack gas temperature (average) 57.7 oC 330.9 K Stack pressure (average) 1016 hPa Stack gas velocity (average, stack conditions) 16 m/s Stack gas flowrate (stack conditions) 34 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 27 m3/s Hazardous Substances (Metals) Testing Test Period 13:39 - 15:23 Hazardous Substances (Metals) Mass 0.059 mg Gas Volume Sampled 1.67 m3 Hazardous Substances (Metals) Emission*1 0.035 mg/m3 Hazardous Substances (Metals) Mass Emission Rate*2 0.96 mg/s Regulatory Limit 10 mg/m3 Hydrogen Chloride Testing Test Period 13:39 - 15:23 Hydrogen Chloride Mass 0.14 mg Gas Volume Sampled 0.95 m3 Hydrogen Chloride Emission*1 0.15 mg/m3 Hydrogen Chloride Mass Emission Rate*2 4.1 mg/s Regulatory Limit 400 mg/m3 Chlorine Testing Test Period 13:39 - 15:23 Chlorine Mass 0.103 mg Gas Volume Sampled 0.95 m3 Chlorine Emission*1 0.11 mg/m3 Chlorine Mass Emission Rate*2 3 mg/s Regulatory Limit NA Moisture Content (%) 3.0 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 11: Stack 1 Polycyclic Aromatic Hydrocarbons (PAH) Results, 14 January 2011
Sampling Conditions: Stack internal diameter at test location 1650 mm Stack gas temperature (average) 61.4 oC 334.6 K Stack pressure (average) 1017 hPa Stack gas velocity (average, stack conditions) 16 m/s Stack gas flowrate (stack conditions) 35 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 28 m3/s Polycyclic Aromatic Hydrocarbons Testing Test Period 10:21 - 12:12 Polycyclic Aromatic Hydrocarbons Mass 0.15 mg Gas Volume Sampled 1.02 m3 Polycyclic Aromatic Hydrocarbons Emission*1 0.15 mg/m3 Polycyclic Aromatic Hydrocarbons Mass Emission Rate*2 4.3 mg/s Regulatory Limit NA Moisture Content (%) 1.2 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.9 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 12: Stack 2 Fine Particulate (PM10), Total Particulate and Particulate/Gaseous Fluoride Results, 12 January 2011
Sampling Conditions: Stack internal diameter at test location 1265 mm Stack gas temperature (average) 44.2 oC 317.4 K Stack pressure (average) 1014 hPa Stack gas velocity (average, stack conditions) 15 m/s Stack gas flowrate (stack conditions) 18 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 15 m3/s
Fine Particulate (PM10) Testing Test Period 12:46 - 13:47
Fine Particulate (PM10) Mass <0.1 mg Gas Volume Sampled 0.717 m3 1 3 Fine Particulate (PM10) Emission* <0.14 mg/m 2 Fine Particulate (PM10) Mass Emission Rate* <2.1 mg/s Regulatory Limit NA Total Particulate Testing Test Period 12:46 - 13:47 Total Particulate Mass 0.3 mg Gas Volume Sampled 0.642 m3 Total Particulate Emission*1 0.47 mg/m3 Total Particulate Mass Emission Rate*2 7.3 mg/s Regulatory Limit 35 mg/m3 Particulate Fluoride Testing Test Period 12:46 - 13:47 Particulate Fluoride Mass 0.003 mg Gas Volume Sampled 0.719 m3 Particulate Fluoride Emission*1 0.0042 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.064 mg/s Regulatory Limit NA Gaseous Fluoride Testing Test Period 12:46 - 13:47 Gaseous Fluoride Mass <0.1 mg Gas Volume Sampled 0.719 m3 Gaseous Fluoride Emission*1 <0.14 mg/m3 Gaseous Fluoride Mass Emission Rate*2 <2.1 mg/s Regulatory Limit NA Moisture Content (%) 2.8 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of (00C, 1 atm, dry gas) *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 13: Stack 3 Fine Particulate (PM10), Total Particulate and Particulate/Gaseous Fluoride Results, 12 January 2011
Sampling Conditions: Stack internal diameter at test location 1000 mm Stack gas temperature (average) 34.9 oC 308.1 K Stack pressure (average) 1015 hPa Stack gas velocity (average, stack conditions) 6.3 m/s Stack gas flowrate (stack conditions) 5 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 4.3 m3/s
Fine Particulate (PM10) Testing Test Period 9:09 - 10:11
Fine Particulate (PM10) Mass <0.1 mg Gas Volume Sampled 0.688 m3 1 3 Fine Particulate (PM10) Emission* <0.15 mg/m 2 Fine Particulate (PM10) Mass Emission Rate* <0.65 mg/s Regulatory Limit NA Total Particulate Testing Test Period 9:09 - 10:11 Total Particulate Mass 0.4 mg Gas Volume Sampled 0.931 m3 Total Particulate Emission*1 0.43 mg/m3 Total Particulate Mass Emission Rate*2 1.9 mg/s Regulatory Limit 50 mg/m3 Particulate Fluoride Testing Test Period 9:09 - 10:11 Particulate Fluoride Mass 0.002 mg Gas Volume Sampled 0.894 m3 Particulate Fluoride Emission*1 0.0022 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.0094 mg/s Regulatory Limit NA Gaseous Fluoride Testing Test Period 9:09 - 10:11 Gaseous Fluoride Mass <0.1 mg Gas Volume Sampled 0.894 m3 Gaseous Fluoride Emission*1 <0.11 mg/m3 Gaseous Fluoride Mass Emission Rate*2 <0.47 mg/s Regulatory Limit NA Moisture Content (%) 2.1 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of (00C, 1 atm, dry gas) *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 14: Stack 4 Fine Particulate (PM10), Total Particulate and Particulate/Gaseous Fluoride Results, 11 January 2011
Sampling Conditions: Stack internal diameter at test location 1395 mm Stack gas temperature (average) 40.2 oC 313.4 K Stack pressure (average) 1009 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 22 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 18 m3/s
Fine Particulate (PM10) Testing Test Period 12:35 - 13:36
Fine Particulate (PM10) Mass 0.1 mg Gas Volume Sampled 0.754 m3 1 3 Fine Particulate (PM10) Emission* 0.13 mg/m 2 Fine Particulate (PM10) Mass Emission Rate* 2.4 mg/s Regulatory Limit NA Total Particulate Testing Test Period 12:35 - 13:36 Total Particulate Mass 0.4 mg Gas Volume Sampled 0.674 m3 Total Particulate Emission*1 0.59 mg/m3 Total Particulate Mass Emission Rate*2 11 mg/s Regulatory Limit 24 mg/m3 Particulate Fluoride Testing Test Period 12:35 - 13:36 Particulate Fluoride Mass 0.005 mg Gas Volume Sampled 0.809 m3 Particulate Fluoride Emission*1 0.0062 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.11 mg/s Regulatory Limit NA Gaseous Fluoride Testing Test Period 12:35 - 13:36 Gaseous Fluoride Mass <0.1 mg Gas Volume Sampled 0.809 m3 Gaseous Fluoride Emission*1 <0.12 mg/m3 Gaseous Fluoride Mass Emission Rate*2 <2.2 mg/s Regulatory Limit NA Moisture Content (%) 3.1 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of (00C, 1 atm, dry gas) *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 15: Stack 5 Fine Particulate (PM10) and Total Particulate Results, 24 January 2011
Sampling Conditions: Stack internal diameter at test location 1490 mm Stack gas temperature (average) 60.0 oC 333.2 K Stack pressure (average) 1015 hPa Stack gas velocity (average, stack conditions) 18 m/s Stack gas flowrate (stack conditions) 31 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 25 m3/s
Fine Particulate (PM10) Testing Test Period 12:57 - 15:00
Fine Particulate (PM10) Mass 0.1 mg Gas Volume Sampled 1.46 m3
1 3 Fine Particulate (PM10) Emission* 0.069 mg/m 2 Fine Particulate (PM10) Mass Emission Rate* 1.7 mg/s Regulatory Limit NA Total Particulate Testing Test Period 12:57 - 15:00 Total Particulate Mass 0.1 mg Gas Volume Sampled 1.31 m3 Total Particulate Emission*1 0.076 mg/m3 Total Particulate Mass Emission Rate*2 1.9 mg/s Regulatory Limit 10 mg/m3 Moisture Content (%) 1.7 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 16: Stack 5 Hydrogen Chloride and Chlorine Results, 24 January 2011
Sampling Conditions: Stack internal diameter at test location 1490 mm Stack gas temperature (average) 70.8 oC 344.0 K Stack pressure (average) 1015 hPa Stack gas velocity (average, stack conditions) 18 m/s Stack gas flowrate (stack conditions) 31 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 24 m3/s Hydrogen Chloride Testing Test Period 10:42 - 11:48 Hydrogen Chloride Mass <0.2 mg Gas Volume Sampled 1.1 m3 Hydrogen Chloride Emission*1 <0.18 mg/m3 Hydrogen Chloride Mass Emission Rate*2 <4.4 mg/s Regulatory Limit 10 mg/m3 Chlorine Testing Test Period 10:42 - 11:48 Chlorine Mass <0.2 mg Gas Volume Sampled 1.1 m3 Chlorine Emission*1 <0.18 mg/m3 Chlorine Mass Emission Rate*2 <4.4 mg/s Regulatory Limit NA Moisture Content (%) 1.9 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 17: Stack 5 Hazardous Substances (Metals), Particulate Fluoride and Gaseous Fluoride Results, 25 January 2011
Sampling Conditions: Stack internal diameter at test location 1490 mm Stack gas temperature (average) 78.7 oC 351.9 K Stack pressure (average) 1015 hPa Stack gas velocity (average, stack conditions) 18 m/s Stack gas flowrate (stack conditions) 32 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 24 m3/s Hazardous Substances (Metals) Testing Test Period 10:34 - 12:26 Hazardous Substances (Metals) Mass 0.087 mg Gas Volume Sampled 1.12 m3 Hazardous Substances (Metals) Emission*1 0.078 mg/m3 Hazardous Substances (Metals) Mass Emission Rate*2 1.9 mg/s Regulatory Limit 5 mg/m3 Gaseous Fluoride Testing Test Period 10:34 - 12:26 Gaseous Fluoride Mass 0.4 mg Gas Volume Sampled 1.27 m3 Gaseous Fluoride Emission*1 0.31 mg/m3
Gaseous Fluoride Mass Emission Rate*2 7.6 mg/s Regulatory Limit NA Particulate Fluoride Testing Test Period 10:34 - 12:26 Particulate Fluoride Mass 0.009 mg Gas Volume Sampled 1.27 m3 Particulate Fluoride Emission*1 0.0071 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.17 mg/s Regulatory Limit NA Moisture Content (%) 2.1 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each.
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Table 18: Stack 5 Sulfuric Acid Mist (H2SO4 as SO3) and Sulfur Dioxide (SO2 as SO3) Results, 25 January 2011
Sampling Conditions: Stack internal diameter at test location 1490 mm Stack gas temperature (average) 78.7 oC 351.9 K Stack pressure (average) 1015 hPa Stack gas velocity (average, stack conditions) 18 m/s Stack gas flowrate (stack conditions) 32 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 25 m3/s
Sulfuric Acid Mist (H2SO4 as SO3) Testing Test Period 10:34 - 12:26
Sulfuric Acid Mist (H2SO4 as SO3) Mass <2 mg Gas Volume Sampled 0.657 m3
1 3 Sulfuric Acid Mist (H2SO4 as SO3) Emission* <3 mg/m 2 Sulfuric Acid Mist (H2SO4 as SO3) Mass Emission Rate* <73 mg/s Regulatory Limit 100 mg/m3
Sulfur Dioxide (SO2 as SO3) Testing Test Period 10:34 - 12:26
Sulfur Dioxide (SO2 as SO3) Mass <10 mg
Gas Volume Sampled 0.674 m3
1 3 Sulfur Dioxide (SO2 as SO3) Emission* <15 mg/m 2 Sulfur Dioxide (SO2 as SO3) Mass Emission Rate* <370 mg/s Regulatory Limit NA Moisture Content (%) 2.0 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 19: Stack 5 Dioxins and Furans and Polycyclic Aromatic Hydrocarbons (PAH) Results 24 January 2011
Sampling Conditions: Stack internal diameter at test location 1490 mm Stack gas temperature (average) 67.1 oC 340.3 K Stack pressure (average) 1015 hPa Stack gas velocity (average, stack conditions) 19 m/s Stack gas flowrate (stack conditions) 33 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 27 m3/s Dioxins and Furans Lower Bound Testing Test Period 9:42 - 15:48 Dioxins and Furans Lower Bound Mass 0.133325 ng Gas Volume Sampled 3.93 m3 Dioxins and Furans Lower Bound Emission*1 0.034 ng/m3 Dioxins and Furans Lower Bound Mass Emission Rate*2 0.9 ng/s Regulatory Limit 0.1 ng/m3 Dioxins and Furans Middle Bound Testing Test Period 9:42 - 15:48 Dioxins and Furans Middle Bound Mass 0.137481 ng Gas Volume Sampled 3.93 m3 Dioxins and Furans Middle Bound Emission*1 0.035 ng/m3 Dioxins and Furans Middle Bound Mass Emission Rate*2 0.93 ng/s Regulatory Limit 0.1 ng/m3 Polycyclic Aromatic Hydrocarbons Testing Test Period 9:42 - 15:48 Polycyclic Aromatic Hydrocarbons Mass 0.094 mg Gas Volume Sampled 3.93 m3 Polycyclic Aromatic Hydrocarbons Emission*1 0.024 mg/m3 Polycyclic Aromatic Hydrocarbons Mass Emission Rate*2 0.64 mg/s Regulatory Limit NA Moisture Content (%) 0.7 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 20: Stack 5 Dioxins and Furans and Polycyclic Aromatic Hydrocarbon Results, 24 January 2011
Toxic Equiva- Total Toxic Total Toxic Mass Concentration Analyte lency Factor Equivalence Equivalence (ng) (ng/m3) (1 - TEFs) (1 - TEQs) (ng) (1-TEQs) (ng/m3)
2,3,7,8-TCDF 0.43 0.1 0.043 0.11 0.011 Total TCDF isomers 8.69 2,3,7,8-TCDD <0.004 1 0.002 <0.001 0.00051 Total TCDD isomers 0.43
1,2,3,7,8-PeCDF 0.12 0.05 0.006 0.031 0.0015 2,3,4,7,8-PeCDF 0.15 0.5 0.075 0.038 0.019 Total PeCDF isomers 2.01 1,2,3,7,8-PeCDD <0.008 0.5 0.002 <0.002 0.00051 Total PeCDD isomers 0.18
1,2,3,4,7,8-HxCDF 0.034 0.1 0.0034 0.0087 0.00087 1,2,3,6,7,8-HxCDF 0.033 0.1 0.0033 0.0084 0.00084 2,3,4,6,7,8-HxCDF 0.015 0.1 0.0015 0.0038 0.00038 1,2,3,7,8,9-HxCDF <0.001 0.1 0.00005 <0.00025 0.000013 Total HxCDF isomers 0.29 1,2,3,4,7,8-HxCDD 0.0034 0.1 0.00034 0.00087 0.000087 1,2,3,6,7,8-HxCDD 0.0039 0.1 0.00039 0.00099 0.000099 1,2,3,7,8,9-HxCDD <0.002 0.1 0.0001 <0.00051 0.000025 Total HxCDD isomers 0.073
1,2,3,4,6,7,8-HpCDF 0.025 0.01 0.00025 0.0064 0.000064 1,2,3,4,7,8,9-Hp CDF <0.001 0.01 0.000005 <0.00025 0.0000013 Total HpCDF isomers 0.033 1,2,3,4,6,7,8-HpCDD 0.011 0.01 0.00011 0.0028 0.000028 Total HpCDD isomers 0.035
OCDF <0.002 0.001 0.000001 <0.00051 0.00000025 OCDD 0.035 0.001 0.000035 0.0089 0.0000089
I-TEQDF Lower Bound (excluding LOD Values) 0.13 ng Middle Bound (including half LOD Values) 0.14 ng
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Table 21: Stack 5 Speciated Polycyclic Aromatic Hydrocarbons (PAH) Results, 24 January 2011
Emission Mass Emission Sample Result Concentration Rate (ng) (g) (mg) (g/m3) (mg/m3) (g/s) (mg/s) Naphthalene 16000 16 0.016 4.1 0.0041 110 0.11 2 - Methylnapthalene 9700 9.7 0.0097 2.5 0.0025 66 0.066 Acenaphthylene 1800 1.8 0.0018 0.46 0.00046 12 0.012 Acenaphthene 530 0.53 0.00053 0.13 0.00013 3.6 0.0036 Fluorene 1800 1.8 0.0018 0.46 0.00046 12 0.012 Phenanthrene 24000 24 0.024 6.1 0.0061 160 0.16 Anthracene 2800 2.8 0.0028 0.71 0.00071 19 0.019 Fluoranthene 21000 21 0.021 5.3 0.0053 140 0.14 Pyrene 13000 13 0.013 3.3 0.0033 88 0.088 Benz(a)anthracene 470 0.47 0.00047 0.12 0.00012 3.2 0.0032 Chrysene 1900 1.9 0.0019 0.48 0.00048 13 0.013 Benzo(b)fluoranthene 240 0.24 0.00024 0.061 0.000061 1.6 0.0016 Benzo(k)fluoranthene 190 0.19 0.00019 0.048 0.000048 1.3 0.0013 Benzo(e)pyrene 120 0.12 0.00012 0.031 0.000031 0.81 0.00081 Benzo(a)pyrene <30 <0.03 <0.00003 0.0076 <0.0000076 <0.2 <0.0002 Perylene <85 <0.085 <0.000085 0.022 <0.000022 <0.57 <0.00057 Indeno(123:cd)pyrene <35 <0.035 <0.000035 0.0089 <0.0000089 <0.24 <0.00024 Dibenzo(ah)anthracene <40 <0.04 <0.00004 0.01 <0.00001 <0.27 <0.00027 Benzo(ghi)perylene <45 <0.045 <0.000045 0.011 <0.000011 <0.3 <0.0003 Sum of reported 94000 94 0.094 24 0.024 630 0.63 PAH's
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Table 22: Stack 1 Speciated Volatile Organic Compounds (VOC) Results, 13 January 2011
Sample Blank Concen- Sample Blank Result Mass Emission Analyte Corrected tration Resultg) g) Rate (mg/s) (g) (mg/m3)
Acetone <0.5 <0.5 <0.5 <0.088 <2.4 1,1-dichloroethane <0.5 <0.5 <0.5 <0.088 <2.4 2-Butanone <0.5 <0.5 <0.5 <0.088 <2.4 Chloroform <0.5 <0.5 <0.5 <0.088 <2.4 Benzene <0.5 <0.5 <0.5 <0.088 <2.4 1-heptene <0.5 <0.5 <0.5 <0.088 <2.4 n-heptane <0.5 <0.5 <0.5 <0.088 <2.4 Trichloroethene <0.5 <0.5 <0.5 <0.088 <2.4 MIBK <0.5 <0.5 <0.5 <0.088 <2.4 Toluene 16.7 <0.5 16.5 2.9 78 2-hexanone <0.5 <0.5 <0.5 <0.088 <2.4 Chlorobenzene <0.5 <0.5 <0.5 <0.088 <2.4 Ethyl Benzene <0.5 <0.5 <0.5 <0.088 <2.4 m- & p-xylene <1 <1 <1 <0.18 <4.9 o-xylene <0.5 <0.5 <0.5 <0.088 <2.4 Styrene <0.5 <0.5 <0.5 <0.088 <2.4 Cyclohexanone <0.5 <0.5 <0.5 <0.088 <2.4 Isopropylbenzene <0.5 <0.5 <0.5 <0.088 <2.4 2-chlorotoluene <0.5 <0.5 <0.5 <0.088 <2.4 4-chlorotoluene <0.5 <0.5 <0.5 <0.088 <2.4 1,3,5- trimethylbenzene <0.5 <0.5 <0.5 <0.088 <2.4 n-decane <0.5 <0.5 <0.5 <0.088 <2.4 1,2,4- trimethylbenzene <0.5 <0.5 <0.5 <0.088 <2.4
1,3-dichlorobenzene <0.5 <0.5 <0.5 <0.088 <2.4 1,4-dichlorobenzene <0.5 <0.5 <0.5 <0.088 <2.4 1,2-dichlorobenzne <0.5 <0.5 <0.5 <0.088 <2.4 n-butylbenzene <0.5 <0.5 <0.5 <0.088 <2.4 Hexachlorobutadiene <0.5 <0.5 <0.5 <0.088 <2.4 Total 16.7 16.5 2.9 78 Note: Where the blank has returned a less than value, the analysed value has been corrected for half of that blank value. ie a blank value of <0.5 has had 0.25 subtracted from the analysed value.
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Table 23: Stack 5 Speciated Volatile Organic Compounds (VOC) Results, 25 January 2011
Sample Concen- Mass Sample Blank Result Blank Analyte tration Emission Resultg) g) Corrected (mg/m3) Rate (mg/s) (g) Acetone 1.1 <0.5 0.9 0.16 4 1,1-dichloroethane <0.5 <0.5 <0.5 <0.087 <2.2 2-Butanone <0.5 <0.5 <0.5 <0.087 <2.2 Chloroform <0.5 <0.5 <0.5 <0.087 <2.2 Benzene <0.5 <0.5 <0.5 <0.087 <2.2 1-heptene <0.5 <0.5 <0.5 <0.087 <2.2 n-heptane <0.5 <0.5 <0.5 <0.087 <2.2 Trichloroethene <0.5 <0.5 <0.5 <0.087 <2.2 MIBK <0.5 <0.5 <0.5 <0.087 <2.2 Toluene 7.4 <0.5 7.2 1.3 33 2-hexanone <0.5 <0.5 <0.5 <0.087 <2.2 Chlorobenzene <0.5 <0.5 <0.5 <0.087 <2.2 Ethyl Benzene <0.5 <0.5 <0.5 <0.087 <2.2 m- & p-xylene <1 <1 <1 <0.17 <4.3 o-xylene <0.5 <0.5 <0.5 <0.087 <2.2 Styrene <0.5 <0.5 <0.5 <0.087 <2.2 Cyclohexanone <0.5 <0.5 <0.5 <0.087 <2.2 Isopropylbenzene <0.5 <0.5 <0.5 <0.087 <2.2 2-chlorotoluene <0.5 <0.5 <0.5 <0.087 <2.2 4-chlorotoluene <0.5 <0.5 <0.5 <0.087 <2.2 1,3,5- trimethylbenzene <0.5 <0.5 <0.5 <0.087 <2.2 n-decane <0.5 <0.5 <0.5 <0.087 <2.2 1,2,4- trimethylbenzene <0.5 <0.5 <0.5 <0.087 <2.2
1,3-dichlorobenzene <0.5 <0.5 <0.5 <0.087 <2.2 1,4-dichlorobenzene <0.5 <0.5 <0.5 <0.087 <2.2 1,2-dichlorobenzne <0.5 <0.5 <0.5 <0.087 <2.2 n-butylbenzene <0.5 <0.5 <0.5 <0.087 <2.2 Hexachlorobutadiene <0.5 <0.5 <0.5 <0.087 <2.2 Total 8.5 8.1 1.5 37 Note: Where the blank has returned a less than value, the analysed value has been corrected for half of that blank value. ie a blank value of <0.5 has had 0.25 subtracted from the analysed value.
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Table 24: Stack 1 Speciated Polycyclic Aromatic Hydrocarbons (PAH) Results, 14 January 2011
Sample Result Emission Mass Emission Rate (ng) (g) (mg) (g/m3) (mg/m3) (g/s) (mg/s) Naphthalene 64000 64 0.064 63 0.063 1800 1.8 2 - Methylnapthalene 87000 87 0.087 86 0.086 2400 2.4 Acenaphthylene 100 0.1 0.0001 0.098 0.000098 2.8 0.0028 Acenaphthene 280 0.28 0.00028 0.28 0.00028 7.8 0.0078 Fluorene 540 0.54 0.00054 0.53 0.00053 15 0.015 Phenanthrene 1700 1.7 0.0017 1.7 0.0017 47 0.047 Anthracene 81 0.081 0.000081 0.08 0.00008 2.3 0.0023 Fluoranthene 460 0.46 0.00046 0.45 0.00045 13 0.013 Pyrene 290 0.29 0.00029 0.29 0.00029 8.1 0.0081 Benz(a)anthracene <30 <0.03 <0.00003 0.03 <0.00003 <0.84 <0.00084 Chrysene 180 0.18 0.00018 0.18 0.00018 5 0.005 Benzo(b)fluoranthene 38 0.038 0.000038 0.037 0.000037 1.1 0.0011 Benzo(k)fluoranthene 26 0.026 0.000026 0.026 0.000026 0.72 0.00072 Benzo(e)pyrene <20 <0.02 <0.00002 0.02 <0.00002 <0.56 <0.00056 Benzo(a)pyrene <30 <0.03 <0.00003 0.03 <0.00003 <0.84 <0.00084 Perylene <45 <0.045 <0.000045 0.044 <0.000044 <1.3 <0.0013
Indeno(123:cd)pyrene <45 <0.045 <0.000045 0.044 <0.000044 <1.3 <0.0013 Dibenzo(ah)anthracene <30 <0.03 <0.00003 0.03 <0.00003 <0.84 <0.00084 Benzo(ghi)perylene <45 <0.045 <0.000045 0.044 <0.000044 <1.3 <0.0013 Sum of reported PAH's 150000 150 0.15 150 0.15 4300 4.3
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Table 25: Stack 1 Speciated Hazardous Substances (Metals) Results, 13 January 2011
Total Total Total Total Total Total Mass Particulate Gaseous Gaseous Oxidisable Sample Particulate Oxidisable Total (mg) Total (mg/m3) Emission Metals Metals Metals Mercury Metals (mg) Mercury (mg) Rate (mg/s) (mg/m3) (mg) (mg/m3) (mg/m3)
Antimony <0.004 <0.0024 <0.004 <0.0024 <0.02 <0.0024 <0.066
Arsenic <0.0047 <0.0028 <0.003 <0.0018 <0.015 <0.0028 <0.077
Beryllium 0.00003 0.000018 <0.00003 <0.000018 0.00003 0.000018 0.00049
Cadmium 0.0015 0.0009 0.0016 0.00096 0.003 0.0019 0.052
Chromium 0.0008 0.00048 0.00035 0.00021 0.001 0.00069 0.019
Cobalt <0.0028 <0.0017 <0.0007 <0.00042 <0.0015 <0.0017 <0.047
Copper 0.0041 0.0025 0.0004 0.00024 0.005 0.0027 0.074
Lead 0.037 0.022 <0.003 <0.0018 0.037 0.022 0.6
Magnesium NA NA NA NA NA NA NA
Manganese 0.0087 0.0052 0.000085 0.000051 0.009 0.0053 0.15
Mercury 0.000075 0.000045 <0.00025 <0.00015 0.0011 0.00066 0.001 0.00071 0.019
Nickel 0.0021 0.0013 0.0004 0.00024 0.003 0.0015 0.041
Selenium <0.004 <0.0024 <0.0004 <0.00024 <0.02 <0.0024 <0.066
Thallium <0.008 <0.0048 <0.008 <0.0048 <0.04 <0.0048 <0.13
Tin <0.0078 <0.0047 0.00023 0.00014 0.00023 0.00014 0.0038
Vanadium <0.0004 <0.00024 <0.0004 <0.00024 <0.02 <0.00024 <0.0066
Zinc NA NA NA NA NA NA NA Total Hazardous 0.054 0.032 0.0031 0.0018 0.0011 0.00066 0.059 0.035 0.97 Metals*
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Table 26: Stack 5 Speciated Hazardous Substances (Metals) Results, 25 January 2011
Total Total Total Total Total Total Mass Particulate Gaseous Oxidisable Total Sample Particulate Gaseous Oxidisable Total (mg) Emission Metals Metals Mercury (mg/m3) Metals (mg) Metals (mg) Mercury (mg) Rate (mg/s) (mg/m3) (mg/m3) (mg/m3)
Antimony <0.004 <0.0036 <0.004 <0.0036 <0.02 <0.0036 <0.088 Arsenic 0.0016 0.0014 <0.003 <0.0027 0.0016 0.0014 0.034 Beryllium <0.00005 <0.000045 <0.00003 <0.000027 <0.00012 <0.000045 <0.0011 Cadmium 0.0002 0.00018 <0.0002 <0.00018 0.0002 0.00018 0.0044 Chromium <0.0072 <0.0064 0.00015 0.00013 0.00015 0.00013 0.0032 Cobalt <0.0028 <0.0025 <0.0007 <0.00063 <0.0015 <0.0025 <0.061 Copper 0.0051 0.0046 0.0003 0.00027 0.005 0.0049 0.12 Lead 0.048 0.043 <0.003 <0.0027 0.048 0.043 1 Magnesium NA NA NA NA NA NA NA Manganese 0.0025 0.0022 0.027 0.024 0.03 0.026 0.63 Mercury 0.000035 0.000031 <0.00025 <0.00022 0.0014 0.0013 0.001 0.0013 0.032 Nickel 0.0002 0.00018 0.0003 0.00027 0.0005 0.00045 0.011 Selenium <0.004 <0.0036 <0.0004 <0.00036 <0.02 <0.0036 <0.088 Thallium <0.008 <0.0072 <0.008 <0.0072 <0.04 <0.0072 <0.18 Tin <0.0078 <0.007 0.00087 0.00078 0.00087 0.00078 0.019 Vanadium <0.0004 <0.00036 <0.0004 <0.00036 <0.02 <0.00036 <0.0088 Zinc NA NA NA NA NA NA NA Total Hazardous 0.058 0.052 0.029 0.025 0.0014 0.0013 0.087 0.078 1.9 Metals* Total 0.058 0.052 0.029 0.025 0.087 0.078 1.9 Metals * Total does not include Magnesium and Zinc as they are classed non-hazardous
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7.0 References NSW DECC “Section 55 protection of the Environment Operations Act 1997, Environmental Protection Licence 6423”. NSW State Government “Protection of the Environment Operations (Clean Air) Regulation 2002, Schedule 3 Standards of concentration for scheduled premises: general activities and plant”. NSW DECC, 2007, Approved methods for the sampling and analysis of air pollutants in New South Wales, January 2007
60195964 14 March 2011 Commercial-in-Confidence Weston Aluminium Pty Ltd Commercial-in-Confidence 8 April 2011
Emissions Testing Report 2011 Annual Testing - Stack 6
Weston Aluminium
NATA ACCREDITATION No. 2778 (14391) Accredited for compliance with ISO/IEC 17025 This document is issued in accordance with NATA’s accreditation requirements. This document may not be reproduced except in full.
AECOM Emissions Testing Report 2011 Annual Testing - Stack 6
Emissions Testing Report 2011 Annual Testing - Stack 6 Weston Aluminium
Prepared for Weston Aluminium Pty Ltd PO Box 295 Kurri Kurri NSW 2327 Attn: Mr Christopher McClung Plant Manager
Prepared by
AECOM Australia Pty Ltd 17 Warabrook Boulevarde, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T +61 2 4911 4900 F +61 2 4911 4999 www.aecom.com ABN 20 093 846 925
8 April 2011
60195964
AECOM in Australia and New Zealand is certified to the latest version of ISO9001 and ISO14001.
© AECOM Australia Pty Ltd (AECOM). All rights reserved.
AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and AECOM’s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety.
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Table of Contents 1.0 Introduction 1 2.0 Sampling Plane Requirements 3 3.0 Methodology 5 3.1 NATA Accredited Methods 5 3.2 Deviations from NATA Accredited Test Procedures 5 4.0 Sampling Location 7 4.1 Sampling Location Summary 7 5.0 Equipment Calibration 9 6.0 Results 11 7.0 References 19
List of Tables Table 1: Criteria for Selection of Sampling Planes (AS 4323. 1- 1995) 3 Table 2: AECOM NATA Endorsed Methods 5 Table 3: Sampling Location Summary 7 Table 4: Air Emission Results Summary, Stack 6 – 2011 11 Table 5: Stack 6 Total Particulate Results, 1 March 2011 12 Table 6: Stack 6 Gaseous and Particulate Fluoride, Sulfuric Acid Mist (H2SO4 as SO3) and Sulfur Dioxide (SO2 as SO3) Results, 1 March 2011 13 Table 7: Stack 6 Dioxins and Furans and Polycyclic Aromatic Hydrocarbon (PAH) Results, 1 March 2011 14 Table 8: Speciated Polycyclic Aromatic Hydrocarbon (PAH) Results, 1 March 2011 15 Table 9: Stack 6 Speciated Volatile Organic Compounds (VOC), 1 March 2011 16 Table 10: Speciated Dioxins and Furans Results, 1 march 2011 17 Table 11: Summary of Gaseous Data, 1 March 2011 18
List of Appendices Appendix A Field Sheets 37 pages Appendix B Raw and Calculated Gas 8 pages Appendix C Laboratory Analysis Reports 14 pages
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1.0 Introduction AECOM was appointed by Weston Aluminium Pty Ltd to conduct a series of measurements to determine air emissions from Stack 6 (EPL point 14) located at their Weston plant in Kurri Kurri, NSW. Emission testing was a compliance requirement of Environmental Protection Licence (EPL) number 6423. Testing was conducted on 1 March 2011 to determine emission concentrations for EPL Point 14 for the following parameters: - Total Particulate (TP);
- Fine Particulate* (PM10); - Particulate Fluoride; - Gaseous Fluoride; - Sulfuric Acid Mist; - Sulfur Dioxide; - Dioxins and Furans; - Polycyclic Aromatic Hydrocarbons (PAH); - Volatile Organic Compounds (VOCs);
- Oxides of Nitrogen (NOx as Equivalent NO2); - Carbon Monoxide (CO); and
- Oxygen (O2). Laboratory analysis was conducted by the following laboratories, which hold NATA accreditation for the specified tests: - Australian Laboratory Services, NATA Accreditation No. 825, laboratory report number EN1100504 for analysis of: Sulfuric Acid Mist; Sulfur Dioxide; Total Particulate; Particulate and Gaseous Fluoride; and Volatile Organic Compounds (VOCs). - National Measurement Institute (NMI), NATA Accreditation No. 198, laboratory report number DAU11_042, and ORG11_013 for analysis of: Polycyclic Aromatic Hydrocarbons; and Dioxins and Furans. - Macquarie Testing Services report numbers 3109 and 3111 for the analysis of the following:
PM10 by laser particle sizing analysis.
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2.0 Sampling Plane Requirements The criteria for sampling planes are specified in AS 4323.1-1995.
Table 1: Criteria for Selection of Sampling Planes (AS 4323. 1- 1995)
Minimum distance upstream from Minimum distance downstream Type of flow disturbance disturbance, diameters (D) from disturbance, diameters (D) Bend, connection, junction, >2D >6D direction change Louvre, butterfly damper >3D >6D (partially closed or closed) Axial fan >3D >8D (see Note) Centrifugal fan >3D >6D NOTE: The plane should be selected as far as practicable from a fan. Flow straighteners may be required to ensure the position chosen meets the check criteria listed in Items (a) to (f) below. a. The gas flow is basically in the same direction at all points along each sampling traverse. b. The gas velocity at all sampling points is greater than 3 m/s. c. The gas flow profile at the sampling plane shall be steady, evenly distributed and not have a cyclonic component which exceeds an angle of 15o to the duct axis, when measured near the periphery of a circular sampling plane. d. The temperature difference between adjacent points of the survey along each sampling traverse is less than 10% of the absolute temperature, and the temperature at any point differs by less than 10% from the mean. e. The ratio of the highest to lowest pitot pressure difference shall not exceed 9:1 and the ratio of highest to lowest gas velocities shall not exceed 3:1. For isokinetic testing with the use of impingers, the gas velocity ratio across the sampling plane should not exceed 1.6:1. f. The gas temperature at the sampling plane should preferably be above the dewpoint. The sampling plane for Stack 6 was in accordance with AS 4323.1 Section 4.1.
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3.0 Methodology
3.1 NATA Accredited Methods The following methods are accredited with the National Association of Testing Authorities (NATA), Accreditation No. 2778 (14391), and are approved for the sampling and analysis of gases and aerosols. Specific details of the methods are available on request. All sampling and analysis is conducted according to the methods in Table 2.
Table 2: AECOM NATA Endorsed Methods
NSW DECC Approved USEPA Methods Parameter measured Methods NSW DECC TM-1 USEPA (2000) Method 1 under approved Selection of sampling positions (AS 4323.1-1995) circumstances Velocity or volumetric flow rate or USEPA (2000) Method 2 or 2C or USEPA (1999) NSW DECC TM-2 temperature or pressure of stack Method 2F or 2G or 2H (as appropriate) gases USEPA (2000) Method 8 (for sampling and analysis) or APHA (1998) Method 4110B (for analysis only if Sulfuric acid mist (H2SO4) or NSW DECC TM-3 interference from fluorides, free ammonia and/or sulphur trioxide (SO3) dimethyl aniline has been demonstrated to the satisfaction of the Chief Scientist) (as appropriate) USEPA (2000) Method 6 or 6A or 6B or USEPA (1996) Method 6C or ISO (1989) Method 7934 or Sulfur dioxide (SO2) NSW DECC TM-4 ISO (1992) Method 7935 or ISO (1993) Method 10396 or ISO (1998) Method 11632 (as appropriate) Fluorine (F2) or any compound USEPA (2000) Method 13A or 13B (as containing fluorine, except where NSW DECC TM-9 appropriate) emitted by a primary aluminium smelter while manufacturing aluminium from alumina NSW DECC TM-15 USEPA (2000) Method 5 under approved Solid particles (Total) (AS 4323.2-1995) circumstances NSW DECC TM-22 USEPA (2000) Method 4 Moisture content in stack gases Dry gas density or molecular weight NSW DECC TM-23 USEPA (2000) Method 3 of stack gases USEPA (2000) Method 18 or USEPA NSW DECC TM-34 (2000) Method 25 or 25A or 25B or 25C or Volatile organic compounds 25D or 25E (as appropriate) California EPA Air Resources Board (1997) Polycyclic aromatic hydrocarbons NSW DECC OM-6 Method 429 (PAHs) NSW DECC TM-18 USEPA (1995) Method 23 Dioxins and furans NSW DECC TM-32 USEPA Method 10 Determination of Carbon Monoxide emissions from stationary sources NSW DECC TM-25 USEPA Method 3A Determination of Oxygen concentrations from stationary sources NSW DECC TM-11 USEPA(2000) Method 7C Determination of Nitrogen dioxide or nitric oxide emissions from stationary sources All parameters are reported adjusted to 0°C at 1 atmosphere and dry gas
3.2 Deviations from NATA Accredited Test Procedures The following test was conducted which is not covered under the terms of our NATA accreditation:
- Fine Particulate (PM10) was conducted by laser particle sizing analysis of Total particulate sample.
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4.0 Sampling Location
4.1 Sampling Location Summary Table 3 provides a summary of the location sampled by AECOM during March 2011 at the Weston Aluminium plant in Kurri Kurri, NSW.
Table 3: Sampling Location Summary
Discharge Description Stack 6 (EPA Identification No. 14) Duct Shape Circular Construction Material Metal Duct Diameter (mm) 580 Minimum No. Sampling Points 8 Sampling Ports 2 Min. Points/Traverse 4 Disturbance No Distance from Upstream Disturbance 9D Type of Disturbance Bend Distance from Downstream Disturbance 5D Type of Disturbance Stack exit Ideal Sampling Location Yes Correction Factors Applied No Total No. Points Sampled 8 Points/Traverse 4 Sampling Performed to Standard* Yes1 *AS 4323.1 Stationary source emissions Method 1 – Selection of sampling positions 1 AS 4323.1 Section 4.1
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5.0 Equipment Calibration AECOM has a calibration schedule to ensure the emission testing equipment is maintained in good order and with known calibration. Equipment used in this project was calibrated according to the procedures and frequency identified in the AECOM calibration schedule. Details of the schedule and the calibration calculations are available on request.
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6.0 Results A summary of test results for the 2011 Stack 6 annual testing is presented in Table 4. Detailed results along with gas stream properties during the testing periods can be found in Tables 5 - 7. Tables 8 to 10 provide speciated results for Polycyclic Aromatic Hydrocarbons, Volatile Organic Compounds and Dioxins and Furans respectively. Table 11 provides a summary of gaseous data. All emission concentrations are converted to standard conditions of 0oC, dry gas and 1 atm pressure for comparison with regulatory limits outlined in the revised Weston Aluminium licence (variation dated 10 August 2010). Field notes recorded during the project are attached as Appendix A. Raw and calculated gas data can be viewed in Appendix B, with Laboratory Analysis Reports attached as Appendix C.
Table 4: Air Emission Results Summary, Stack 6 – 2011
Stack 6 Regulatory Limit Parameter (EPA point 14) (mg/m3) 3 Total Particulate at 3% O2 (mg/m ) 5.8 10 3 Fine Particulate (PM10) at 3% O2 (mg/m ) 0.3* Not Listed Particulate Fluoride (mg/m3) 0.99 50 Gaseous Fluoride (mg/m3) 2.0 50 3 Sulfuric Acid Mist (H2SO4 as SO3) (mg/m ) <2.1 100 3 Sulfur Dioxide (SO2 as SO3) (mg/m ) <11 Not Listed Total Polycyclic Aromatic Hydrocarbons (mg/m3) 0.047 Not Listed 3 Dioxins and Furans (Middle Bound) at 3% O2 (ng/m ) 0.065 0.1 3 Dioxins and Furans (Lower Bound) at 3% O2 (ng/m ) 0.065 0.1 Volatile Organic Compounds (VOC) (mg/m3) 0.9 Not Listed Total Oxides of Nitrogen 3 195 2500 (as Equivalent NO2) at 3% O2 (mg/m ) 3 Carbon Monoxide (CO) at 3% O2 (mg/m ) 0.02 Not Listed Oxygen (%) 15.2 Not Listed *Due to high temperatures, in-stack PM10 sampling was not possible so laser particle sizing analysis was performed on the Total Particulate sample to achieve a result. Analysis was performed in duplicate with the average of the two results used to calculate the PM10 concentration.
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Table 5: Stack 6 Total Particulate Results, 1 March 2011
Sampling Conditions: Stack internal diameter at test location 580 mm Stack gas temperature (average) 441.4 oC 714.6 K Stack pressure (average) 1018 hPa Stack gas velocity (average, stack conditions) 17 m/s Stack gas flowrate (stack conditions) 4.6 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 1.6 m3/s Total Particulate Testing Test Period 12:17 - 13:45 Total Particulate Mass 1.8 mg Gas Volume Sampled 0.88 m3 1 3 Total Particulate Emission* (Corrected to 3% O2) 5.8 mg/m 2 Total Particulate Mass Emission Rate* (Corrected to 3% O2) 9.4 mg/s Regulatory Limit 10 mg/m3 Moisture Content (%) 7.0 Gas Density (dry at 1 atmosphere) 1.30 kg/m3 Dry Molecular Weight 29.1 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas
*2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 6: Stack 6 Gaseous and Particulate Fluoride, Sulfuric Acid Mist (H2SO4 as SO3) and Sulfur Dioxide (SO2 as SO3) Results, 1 March 2011
Sampling Conditions: Stack internal diameter at test location 580 mm Stack gas temperature (average) 395.8 oC 669.0 K Stack pressure (average) 1017 hPa Stack gas velocity (average, stack conditions) 17 m/s Stack gas flowrate (stack conditions) 4.4 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 1.7 m3/s Gaseous Fluoride Testing Test Period 14:50 - 16:15 Gaseous Fluoride Mass 1.3 mg Gas Volume Sampled 0.663 m3 Gaseous Fluoride Emission*1 2.0 mg/m3 Gaseous Fluoride Mass Emission Rate*2 3.3 mg/s Regulatory Limit 50 mg/m3 Particulate Fluoride Testing Test Period 14:50 - 16:15 Particulate Fluoride Mass 0.66 mg Gas Volume Sampled 0.663 m3 Particulate Fluoride Emission*1 0.99 mg/m3 Particulate Fluoride Mass Emission Rate*2 1.7 mg/s Regulatory Limit 50 mg/m3
Sulfuric Acid Mist (H2SO4 as SO3) Testing Test Period 14:50 - 16:15
Sulfuric Acid Mist (H2SO4 as SO3) Mass <2 mg Gas Volume Sampled 0.947 m3 1 3 Sulfuric Acid Mist (H2SO4 as SO3) Emission* <2.1 mg/m 2 Sulfuric Acid Mist (H2SO4 as SO3) Mass Emission Rate* <3.6 mg/s Regulatory Limit 100 mg/m3
Sulfur Dioxide (SO2 as SO3) Testing Test Period 14:50 - 16:15
Sulfur Dioxide (SO2 as SO3) Mass <10 mg Gas Volume Sampled 0.947 m3 1 3 Sulfur Dioxide (SO2 as SO3) Emission* <11 mg/m 2 Sulfur Dioxide (SO2 as SO3) Mass Emission Rate* <19 mg/s Regulatory Limit NA Moisture Content (%) 7.1 Gas Density (dry at 1 atmosphere) 1.30 kg/m3 Dry Molecular Weight 29.1 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas.
*2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 7: Stack 6 Dioxins and Furans and Polycyclic Aromatic Hydrocarbon (PAH) Results, 1 March 2011
Sampling Conditions: Stack internal diameter at test location 580 mm Stack gas temperature (average) 377.8 oC 651.0 K Stack pressure (average) 1017 hPa Stack gas velocity (average, stack conditions) 16 m/s Stack gas flowrate (stack conditions) 4.3 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 1.7 m3/s Dioxins and Furans Lower Bound Testing Test Period 11:20 - 17:25 Dioxins and Furans Lower Bound Mass 0.079 ng Gas Volume Sampled 3.8 m3 1 3 Dioxins and Furans Lower Bound Emission* at 3% O2 0.065 ng/m 2 Dioxins and Furans Lower Bound Mass Emission Rate* at 3% O2 0.11 ng/s Regulatory Limit 0.1 ng/m3 Dioxins and Furans Middle Bound Testing Test Period 11:20 - 17:25 Dioxins and Furans Middle Bound Mass 0.08 ng Gas Volume Sampled 3.8 m3 1 3 Dioxins and Furans Middle Bound Emission* at 3% O2 0.065 ng/m 2 Dioxins and Furans Middle Bound Mass Emission Rate* at 3% O2 0.11 ng/s Regulatory Limit 0.1 ng/m3 Polycyclic Aromatic Hydrocarbons Testing Test Period 11:20 - 17:25 Polycyclic Aromatic Hydrocarbons Mass 0.18 mg Gas Volume Sampled 3.8 m3 Polycyclic Aromatic Hydrocarbons Emission*1 0.047 mg/m3 Polycyclic Aromatic Hydrocarbons Mass Emission Rate*2 0.081 mg/s Regulatory Limit NA Moisture Content (%) 4.7 Gas Density (dry at 1 atmosphere) 1.30 kg/m3 Dry Molecular Weight 29.1 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas
*2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 8: Speciated Polycyclic Aromatic Hydrocarbon (PAH) Results, 1 March 2011
Sample Result Emission Mass Emission Rate
(ng) (g) (mg) (g/m3) (mg/m3) (g/s) (mg/s) Naphthalene 80000 80 0.08 21 0.021 36 0.036 2 - Methylnapthalene 90000 90 0.09 24 0.024 41 0.041 Acenaphthylene 210 0.21 0.00021 0.055 0.000055 0.095 0.000095 Acenaphthene 120 0.12 0.00012 0.032 0.000032 0.054 0.000054 Fluorene 560 0.56 0.00056 0.15 0.00015 0.25 0.00025 Phenanthrene 2900 2.9 0.0029 0.76 0.00076 1.3 0.0013 Anthracene 200 0.2 0.0002 0.053 0.000053 0.09 0.00009 Fluoranthene 1700 1.7 0.0017 0.45 0.00045 0.77 0.00077 Pyrene 880 0.88 0.00088 0.23 0.00023 0.4 0.0004 Benz(a)anthracene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Chrysene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Benzo(b)fluoranthene 110 0.11 0.00011 0.029 0.000029 0.05 0.00005 Benzo(k)fluoranthene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Benzo(e)pyrene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Benzo(a)pyrene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Perylene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Indeno(123:cd)pyrene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Dibenzo(ah)anthracene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Benzo(ghi)perylene <20 <0.02 <0.00002 0.0053 <0.0000053 <0.009 <0.000009 Sum of reported PAH's 180000 180 0.18 47 0.047 80 0.08
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Table 9: Stack 6 Speciated Volatile Organic Compounds (VOC), 1 March 2011
Sample Result Blank Result Sample Blank Concentration Mass Emission Analyte g) g) Corrected (g) (mg/m3) Rate (mg/s)
Acetone <0.5 <0.5 <0.5 <0.094 <0.16 1,1-dichloroethane <0.5 <0.5 <0.5 <0.094 <0.16 2-Butanone <0.5 <0.5 <0.5 <0.094 <0.16 Chloroform <0.5 <0.5 <0.5 <0.094 <0.16 Benzene <0.5 <0.5 <0.5 <0.094 <0.16 1-heptene <0.5 <0.5 <0.5 <0.094 <0.16 n-heptane <0.5 <0.5 <0.5 <0.094 <0.16 Trichloroethene <0.5 <0.5 <0.5 <0.094 <0.16 MIBK <0.5 <0.5 <0.5 <0.094 <0.16 Toluene 4.8 <0.5 4.6 0.86 1.5 2-hexanone <0.5 <0.5 <0.5 <0.094 <0.16 Chlorobenzene <0.5 <0.5 <0.5 <0.094 <0.16 Ethyl Benzene <0.5 <0.5 <0.5 <0.094 <0.16 m- & p-xylene <1 <1 <1 <0.19 <0.32 o-xylene <0.5 <0.5 <0.5 <0.094 <0.16 Styrene <0.5 <0.5 <0.5 <0.094 <0.16 Cyclohexanone <0.5 <0.5 <0.5 <0.094 <0.16 Isopropylbenzene <0.5 <0.5 <0.5 <0.094 <0.16 2-chlorotoluene <0.5 <0.5 <0.5 <0.094 <0.16 4-chlorotoluene <0.5 <0.5 <0.5 <0.094 <0.16 1,3,5-trimethylbenzene <0.5 <0.5 <0.5 <0.094 <0.16 n-decane <0.5 <0.5 <0.5 <0.094 <0.16 1,2,4-trimethylbenzene <0.5 <0.5 <0.5 <0.094 <0.16 1,3-dichlorobenzene <0.5 <0.5 <0.5 <0.094 <0.16 1,4-dichlorobenzene <0.5 <0.5 <0.5 <0.094 <0.16 1,2-dichlorobenzne <0.5 <0.5 <0.5 <0.094 <0.16 n-butylbenzene <0.5 <0.5 <0.5 <0.094 <0.16 Hexachlorobutadiene <0.5 <0.5 <0.5 <0.094 <0.16 Total 4.8 4.6 0.9 1.5 Note: Where the blank has returned a less than value, the analysed value has been corrected for half of that blank value. ie a blank value of <0.5 has had 0.25 subtracted from the analysed value.
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Table 10: Speciated Dioxins and Furans Results, 1 march 2011
Toxic Total Toxic Total Toxic Equivalency Concentration Equivalence Analyte Mass (ng) Equivalence Factor (ng/m3) (1-TEQs) (1 - TEQs) (ng) (1 - TEFs) (ng/m3) 2,3,7,8-TCDF 0.21 0.1 0.021 0.055 0.0055 Total TCDF isomers 6.23 2,3,7,8-TCDD 0.0047 1 0.0047 0.0012 0.0012 Total TCDD isomers 0.57
1,2,3,7,8-PeCDF 0.08 0.05 0.004 0.021 0.0011 2,3,4,7,8-PeCDF 0.079 0.5 0.0395 0.021 0.01 Total PeCDF isomers 1.75 1,2,3,7,8-PeCDD 0.0071 0.5 0.00355 0.0019 0.00094 Total PeCDD isomers 0.23
1,2,3,4,7,8-HxCDF 0.024 0.1 0.0024 0.0063 0.00063 1,2,3,6,7,8-HxCDF 0.023 0.1 0.0023 0.0061 0.00061 2,3,4,6,7,8-HxCDF <0.01 0.1 0.0005 <0.0026 0.00013 1,2,3,7,8,9-HxCDF <0.003 0.1 0.00015 <0.00079 0.00004 Total HxCDF isomers 0.27 1,2,3,4,7,8-HxCDD <0.004 0.1 0.0002 <0.0011 0.000053 1,2,3,6,7,8-HxCDD 0.0026 0.1 0.00026 0.00068 0.000068 1,2,3,7,8,9-HxCDD 0.0039 0.1 0.00039 0.001 0.0001 Total HxCDD isomers 0.072
1,2,3,4,6,7,8-HpCDF 0.018 0.01 0.00018 0.0047 0.000047 1,2,3,4,7,8,9-Hp CDF 0.0038 0.01 0.000038 0.001 0.00001 Total HpCDF isomers 0.037 1,2,3,4,6,7,8-HpCDD 0.018 0.01 0.00018 0.0047 0.000047 Total HpCDD isomers 0.045
OCDF 0.016 0.001 0.000016 0.0042 0.0000042 OCDD 0.15 0.001 0.00015 0.04 0.00004
I-TEQDF Lower Bound (excluding LOD Values) 0.079 ng Middle Bound (including half LOD Values) 0.08 ng
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Table 11: Summary of Gaseous Data, 1 March 2011 Parameter Result Nitrogen Oxide (NO) (mg/m3) 35 3 Nitrogen Dioxide (NO2) (mg/m ) 8.4 Oxides of Nitrogen (NOx) (mg/m3) 43 3 Total Oxides of Nitrogen (as Equivalent NO2) (mg/m ) 62 3 Total Oxides of Nitrogen (as Equivalent NO2) at 3% O2 (mg/m ) 195 Carbon Monoxide (CO) (mg/m3) 0.01 3 Carbon Monoxide (CO) at 3% O2 (mg/m ) 0.02 Oxygen (O2) (%) 15.2
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7.0 References NSW DECC “Section 55 protection of the Environment Operations Act 1997, Environmental Protection Licence 6423”. NSW State Government “Protection of the Environment Operations (Clean Air) Regulation 2002, Schedule 3 Standards of concentration for scheduled premises: general activities and plant”. NSW DECC, 2007, Approved methods for the sampling and analysis of air pollutants in New South Wales, January 2007
8 April 2011 Commercial-in-Confidence 60195964 Weston Aluminium 8 May 2012
Annual Emissions Testing Report 2012
Weston Aluminium
NATA ACCREDITATION No. 2778 (14391) Accredited for compliance with ISO/IEC 17025 This document is issued in accordance with NATA’s accreditation requirements. This document may not be reproduced except in full.
AECOM Annual Emissions Testing Report 2012
Annual Emissions Testing Report 2012 Weston Aluminium
Prepared for Weston Aluminium
Prepared by
AECOM Australia Pty Ltd 17 Warabrook Boulevarde, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T +61 2 4911 4900 F +61 2 4911 4999 www.aecom.com ABN 20 093 846 925
8 May 2012
60246634
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Quality Information
Document Annual Emissions Testing Report 2012
Ref 60246634
Date 8 May 2012
Prepared by Peter Waddingham
Reviewed by Chad Whitburn NATA Signatory ______
Revision History
Revision Authorised Revision Details Date Name/Position Signature 1.0 08-May- Weston Aluminiuim Annual Chad Whitburn 2012 Emissions Testing Report Principal/Professional 2012 Workgroup Leader
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Table of Contents 1.0 Introduction 1 2.0 Sampling Plane Requirements 3 3.0 Methodology 4 3.1 NATA Accredited Methods 4 4.0 Sampling Location 6 4.1 Sampling Location Summary 6 5.0 Equipment Calibration 7 6.0 Results 8 Appendix A A Field Sheets A Appendix B Laboratory Analytical Reports B Appendix C Raw & Calculated Gas Data C
List of Tables Table 1 Criteria for Selection of Sampling Planes (AS 4323. 1- 1995) 3 Table 2 AECOM NATA Endorsed Methods 4 Table 3 Sampling Location Summary 6 Table 4 Stack 1, Air Emissions Results Summary – 2012 8 Table 5 Air Emission Results Summary, Stacks 2, 3, 4 & 7 – 2012 8 Table 6 Stack 5, Air Emissions Results Summary – 2012 9 Table 7 Stack 6, Air Emissions Results Summary – 2012 9 Table 8 Calculated PM10 Cut Sizes 10 Table 9 Stack 1 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 23 February 2012 11 Table 10 Stack 1 Hazardous Substances, Sulfuric Acid Mist as SO3 and Sulfur Dioxide as SO3 Results, 23 February 2012 12 Table 11 Stack 1 Polycyclic Aromatic Hydrocarbon, Hydrochloric Acid and Chlorine Results, 24 February 2012 13 Table 12 Stack 2 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 17 January 2012 14 Table 13 Stack 3 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 10 February 2012 15 Table 14 Stack 4 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 17 January 2012 16 Table 15 Stack 5 Fine Particulates (PM10), Total Particulates and Polycyclic Aromatic Hydrocarbons Results, 20 March 2012 17 Table 16 Stack 5 Hazardous Materials (Metals), Hydrogen Chloride & Chlorine Results, 20 March 2012 18 Table 17 Stack 5 Gaseous and Particulate Fluoride, H2SO4 as SO3 & SO2 as SO3 Results, 20 March 2012 19 Table 18 Stack 5 Dioxins & Furans Results, 12 January 2012 20 Table 19 Stack 6 Total Particulates & Polycyclic Aromatic Hydrocarbon Results, 20 March 2012 21 Table 20 Stack 6 Gaseous and Particulate Fluoride, H2SO4 as SO3 & SO2 as SO3 Results, 20 March 2012 22 Table 21 Stack 6 Dioxins & Furans Results, 12 January 2012 23 Table 22 Stack 7 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 25 January 2012 24 Table 23 Stack 1 Speciated Volatile Organic Compounds Results, 24 February 2012 25 Table 24 Stack 5 Speciated Volatile Organic Compounds Results, 20 March 2012 26 Table 25 Stack 6 Speciated Volatile Organic Compounds Results, 20 March 2012 27 Table 26 Stack 5 Speciated Dioxins & Furans Results, 12 January 2012 28 http://vpo.au.aecomnet.com/projects/WestonEmissionsTesti/4TechWorkArea/Weston Annual 2012/Annual Emissions Testing Report 2012.docx Revision 1.0 - 8 May 2012 AECOM Annual Emissions Testing Report 2012
Table 27 Stack 6 Speciated Dioxins & Furans Results, 12 January 2012 29 Table 28 Stack 1 Elemental Metals 30 Table 29 Stack 5 Elemental Metals 31 Table 30 Stack 1 Speciated Polycyclic Aromatic Hydrocarbons Results 32 Table 31 Stack 5 Speciated PAH 33 Table 32 Stack 6 Speciated PAH 34
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1.0 Introduction AECOM was appointed by Weston Aluminium Pty Ltd to conduct a series of measurements to determine air emissions from five stacks located at their Weston plant in Kurri Kurri, NSW. Emission testing was a compliance requirement of Environmental Protection Licence (EPL) number 6423. Testing was conducted over the period of January to March 2012 to determine emission concentrations for EPL Points 1, 2, 3, 4, 13, 14 and 15 for the following parameters: - Total Particulate (TP);
- Fine Particulate (PM10); - Particulate Fluoride; and - Gaseous Fluoride. Additional testing was undertaken on EPL Points 1 and 13 for: - Sulfuric Acid Mist; - Sulfur Dioxide; - Hazardous Substances (Metals); - Polycyclic Aromatic Hydrocarbons (PAH); - Volatile Organic Compounds (VOCs);
- Oxides of Nitrogen (NOx as Equivalent NO2); - Carbon Monoxide (CO); and
- Oxygen (O2). Sampling was also undertaken for the following parameters on EPL Point 1: - Hydrogen Chloride (HCl); - Chlorine (Cl); and - Volatile Organic Compounds (VOCs). Laboratory analysis was conducted by the following laboratories, which hold NATA accreditation for the specified tests: - Steel River Testing Pty. Ltd., NATA accreditation number 18079, performed the following analysis detailed in report number 2755-P, 2596-P, 2424-P, 2403-P, 2543-P, 2424-M, 2524-M, 2755-M, 2403-M, and 2596-M.
x Fine Particulate (PM10); and x Total Particulate. - Australian Laboratory Services, NATA accreditation number 18079, performed the following analysis detailed in report number EN1200313, EN1200792, EN1201127, EN1201180, EN1200375, EN1200583. x Fluoride; x Sulfuric Acid Mist; x Sulfur Dioxide; x Hydrogen Chloride; x Chlorine; and x Volatile Organic Compounds.
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- National Measurements Institute, NATA accreditation number 198, performed the following analysis detailed in report number ORG12_010, DAU12_024, ORG12_019. x Dioxins and Furans; and x Polycyclic Aromatic Hydrocarbons. - Leeder Consulting, NATA accreditation number 14429, performed the following analysis detailed in report number M120421R1, M120617. x Hazardous Substances (Metals) Some of these analytical reports have different job numbers. This has occurred as a result of some testing being done earlier in the year, when the project was using an older job number. The more recent reports were submitted under the new job number, once it was created. The two job numbers that appear are both representative of the Weston Aluminium Annual Emissions Testing 2012 work.
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2.0 Sampling Plane Requirements The criteria for sampling planes are specified in AS 4323.1-1995.
Table 1 Criteria for Selection of Sampling Planes (AS 4323. 1- 1995) Minimum distance upstream from Minimum distance downstream Type of flow disturbance disturbance, diameters (D) from disturbance, diameters (D) Bend, connection, junction, >2D >6D direction change Louvre, butterfly damper >3D >6D (partially closed or closed) Axial fan >3D >8D (see Note) Centrifugal fan >3D >6D NOTE: The plane should be selected as far as practicable from a fan. Flow straighteners may be required to ensure the position chosen meets the check criteria listed in Items (a) to (f) below. a. The gas flow is basically in the same direction at all points along each sampling traverse. b. The gas velocity at all sampling points is greater than 3 m/s. c. The gas flow profile at the sampling plane shall be steady, evenly distributed and not have a cyclonic component which exceeds an angle of 15o to the duct axis, when measured near the periphery of a circular sampling plane. d. The temperature difference between adjacent points of the survey along each sampling traverse is less than 10% of the absolute temperature, and the temperature at any point differs by less than 10% from the mean. e. The ratio of the highest to lowest pitot pressure difference shall not exceed 9:1 and the ratio of highest to lowest gas velocities shall not exceed 3:1. For isokinetic testing with the use of impingers, the gas velocity ratio across the sampling plane should not exceed 1.6:1. f. The gas temperature at the sampling plane should preferably be above the dewpoint. The sampling planes for Stacks 2, 3, 4 and 7(EPA Identification No. 2, 3, 4 and 15 respectively) were in accordance with AS 4323.1 Section 4.1. Stack 1 (EPA Identification No. 1) did not satisfy the requirements of AS 4323.1 Section 4.1 – 1995 with regard to the upstream and downstream distances from disturbances. To compensate for this, additional sampling points were added in accordance with AS 4323.1 Section 4.2 – 1995.
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3.0 Methodology
3.1 NATA Accredited Methods The following methods are accredited with the National Association of Testing Authorities (NATA), Accreditation No. 2778 (14391), and are approved for the sampling and analysis of gases and aerosols. Specific details of the methods are available on request. All sampling and analysis is conducted according to the methods in Table 2.
Table 2 AECOM NATA Endorsed Methods NSW OEH USEPA Methods Parameter measured Approved Methods NSW DECC TM-1 USEPA (2000) Method 1 under approved Selection of sampling positions (AS 4323.1-1995) circumstances USEPA (2000) Method 2 or 2C or USEPA Velocity or volumetric flow rate or NSW DECC TM-2 (1999) Method 2F or 2G or 2H (as appropriate) temperature or pressure of stack gases USEPA (2000) Method 8 (for sampling and analysis) or APHA (1998) Method 4110B (for Sulfuric acid mist (H2SO4) or sulphur analysis only if interference from fluorides, free NSW DECC TM-3 trioxide (SO3) ammonia and/or dimethyl aniline has been
demonstrated to the satisfaction of the Chief Scientist) (as appropriate) USEPA (2000) Method 6 or 6A or 6B or USEPA (1996) Method 6C or ISO (1989) Method 7934 Sulfur dioxide (SO2) NSW DECC TM-4 or ISO (1992) Method 7935 or ISO (1993)
Method 10396 or ISO (1998) Method 11632 (as appropriate)
Chlorine (Cl2) NSW DECC TM-7 USEPA (2000) 26A
Hydrogen chloride (HCl) NSW DECC TM-8 USEPA (2000) 26A
Fluorine (F2) or any compound USEPA (2000) Method 13A or 13B (as containing fluorine, except where NSW DECC TM-9 appropriate) emitted by a primary aluminium smelter while manufacturing aluminium from alumina Type 1 substances (elements antimony USEPA (2000) Method 29 or USEPA (2000) (Sb), arsenic (As), cadmium (Cd), lead Method 102 (for mercury only in hydrogen rich NSW DECC TM-12 (Pb) or mercury (Hg) or any compound streams) (as appropriate) containing one or more of those
elements) USEPA (2000) Method 29 (Analysis for tin and Type 2 substances (elements beryllium vanadium to be done by Inductively Coupled (Be), chromium (Cr), cobalt (Co), NSW DECC TM-13 Argon Plasma Emission Spectroscopy (ICAP) manganese (Mn), nickel (Ni), selenium as defined in USEPA Method 29) or USEPA (Se), tin (Sn) or vanadium (V) or any (1986) Method 7910 (for vanadium only) or compound containing one or more of USEPA (1986) Method 7911 (for vanadium those elements) only) (as appropriate)
NSW DECC TM-14 Cadmium (Cd) or mercury (Hg) or any USEPA (2000) Method 29 or USEPA compound containing one or more of those (2000) Method 102 (for mercury only in elements hydrogen rich streams) (as appropriate)
NSW DECC TM-15 USEPA (2000) Method 5 under approved Solid particles (Total) (AS 4323.2-1995) circumstances http://vpo.au.aecomnet.com/projects/WestonEmissionsTesti/4TechWorkArea/Weston Annual 2012/Annual Emissions Testing Report 2012.docx Revision 1.0 - 8 May 2012 AECOM Annual Emissions Testing Report 2012 5
NSW OEH USEPA Methods Parameter measured Approved Methods NSW DECC TM-22 USEPA (2000) Method 4 Moisture content in stack gases
Dry gas density or molecular weight of NSW DECC TM-23 USEPA (2000) Method 3 stack gases USEPA (2000) Method 18 or USEPA NSW DECC TM-34 (2000) Method 25 or 25A or 25B or 25C or Volatile organic compounds 25D or 25E (as appropriate) USEPA (1997) Method 201 or 201A (as NSW DECC OM-5 ‘Fine’ particulates (PM ) appropriate) 10 California EPA Air Resources Board (1997) Polycyclic aromatic hydrocarbons NSW DECC OM-6 Method 429 (PAHs) NSW DECC TM-18 USEPA (1995) Method 23 Dioxins and furans
NSW DECC TM-32 USEPA Method 10 Determination of Carbon Monoxide emissions from stationary sources
NSW DECC TM-25 USEPA Method 3A Determination of Oxygen concentrations from stationary sources
NSW DECC TM-11 USEPA(2000) Method 7C Determination of Nitrogen dioxide or nitric oxide emissions from stationary sources
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4.0 Sampling Location
4.1 Sampling Location Summary Table 3 provides a summary of the location sampled by AECOM during January – March 2012 at the Weston Aluminium plant in Kurri Kurri, NSW.
Table 3 Sampling Location Summary Stack 1 (EPA Stack 2 (EPA Stack 3 (EPA Stack 4 (EPA Stack 5 (EPA Stack 6 (EPA Stack 7 (EPA Discharge Description Identification Identification Identification Identification Identification Identification Identification No. 1) No. 2) No. 3) No. 4) No. 13) No. 14) No. 15) Duct Shape Circular Circular Circular Circular Circular Circular Circular Construction Material Metal Metal Metal Metal Metal Metal Metal Duct Diameter (mm) 1650 1265 1000 1395 1490 580 1500 Minimum No. Sampling Points 16 12 12 12 12 8 12 Sampling Ports 2 2 2 2 2 2 2 Min. Points/Traverse 8 6 6 6 6 4 6 Disturbance Yes No No No No No No Distance from Upstream Disturbance 2D 6D 6D 6D 7D 9D 7D Type of Disturbance Fan entry Fan entry Fan entry Fan entry Fan entry Bend Fans Distance from Downstream Disturbance 4D 6D 7D 4D 7D 5D 2D Type of Disturbance Stack Exit Stack exit Stack exit Stack exit Stack exit Stack exit Stack exit Ideal Sampling Location No Yes Yes Yes Yes Yes Yes Correction Factors Applied Yes No No No No No No Total No. Points Sampled 20 12 12 12 12 8 12 Points/Traverse 10 6 6 6 6 4 6 Sampling Performed to Standard* Yes2 Yes1 Yes1 Yes1 Yes1 Yes1 Yes1 *AS 4323.1 Stationary source emissions Method 1 – Selection of sampling positions 1 AS 4323.1 Section 4.1 2 AS 4323.1 Section 4.2
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5.0 Equipment Calibration AECOM has a calibration schedule to ensure the emission testing equipment is maintained in good order and with known calibration. Equipment used in this project was calibrated according to the procedures and frequency identified in the AECOM calibration schedule. Details of the schedule and the calibration calculations are available on request.
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6.0 Results
A summary of test results for the 2012 annual testing is presented in Table 4. Calculated Fine Particulate (PM10) cut sizes for all stacks tested are displayed in Table 5. Detailed results along with gas stream properties during the testing periods can be found in Tables 9 to 22. Speciated Volatile Organic Carbons results can be found in Tables 23 to 25, Dioxins & Furans results in Tables 26 to 27, Hazardous Substances (Metals) results in Tables 28 to 29, and Polycyclic Aromatic Hydrocarbons results in Tables 30 to 32.
All emission concentrations are converted to standard conditions of 0oC, dry gas and 1 atm pressure for comparison with regulatory limits outlined in the revised Weston Aluminium licence (variation dated 10 August 2010). Field notes recorded during the project are attached as Appendix A. with Laboratory Analysis Reports attached as Appendix B, and Raw & Calculated Gas Data as Appendix C.
Table 4 Stack 1, Air Emissions Results Summary – 2012 Stack 1 Regulatory Limit Parameter (EPA point 1) (mg/m3) Total Particulate (mg/m3) 0.51 25 3 Fine Particulate (PM10) (mg/m ) 0.4 Not Listed Hydrogen Chloride (mg/m3) <0.91 400 Chlorine (mg/m3) <0.18 Not Listed Particulate Fluoride (mg/m3) 0.014 Not Listed Gaseous Fluoride (mg/m3) <0.082 2 3 Sulfuric Acid Mist (H2SO4 as SO3) (mg/m ) <1.7 100 3 Sulfur Dioxide (SO2 as SO3) (mg/m ) <8.6 Not Listed Total Hazardous Substances (Metals) (mg/m3) 0.018 10 Total Polycyclic Aromatic Hydrocarbons (mg/m3) 0.018 Not Listed Volatile Organic Compounds (VOC) (mg/m3) <0.19 Not Listed 3 Total Oxides of Nitrogen (as Equivalent NO2) (mg/m ) 9 2500 Carbon Monoxide (CO) (mg/m3) 28 100
Table 5 Air Emission Results Summary, Stacks 2, 3, 4 & 7 – 2012 Stack 2 Stack 3 Stack 7 Stack 4 Regulatory Limit Parameter (EPA point (EPA point (EPA point (EPA point 4) (mg/m3) 2) 3) 15) Stack 2 – 35.0 Total Particulate Stack 3 – 50.0 8.7 2.2 5.6 2.4 (mg/m3) Stack 4 – 24.0 Stack 7 – 15.0 Fine Particulate 3 3.3 0.87 3.4 3.3 Not Listed (PM10) (mg/m ) Particulate 0.026 0.039 0.096 0.078 Not Listed Fluoride (mg/m3) Gaseous 0.97 0.18 0.0012 0.65 Not Listed Fluoride (mg/m3)
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Table 6 Stack 5, Air Emissions Results Summary – 2012 Emission Parameter Regulatory Limit Concentration Total Particulate (mg/m3) 1.1 10 3 Fine Particulate (PM10) (mg/m ) 2.6 Not Listed Particulate Fluoride (mg/m3) 0.0045 Not Listed Gaseous Fluoride (mg/m3) <0.15 Not Listed Hydrogen Chloride (HCl) (mg/m3) <1.8 10 Chlorine (mg/m3) <3.7 Not Listed 3 Sulfuric Acid Mist (H2SO4 as SO3) (mg/m ) <3.1 100 3 Sulfur Dioxide (SO2 as SO3) (mg/m ) <16 Not Listed Hazardous Substances (Metals) (mg/m3) 0.17 5 Dioxins and Furans (Lower Bound) (ng/m3) 0.039 0.1 Dioxins and Furans (Middle Bound) (ng/m3) 0.039 0.1 Volatile Organic Compounds (VOC) (mg/m3) 6.3 Not Listed Total Polycyclic Aromatic Hydrocarbons (Pg/m3) 0.19 Not Listed 3 Total Oxides of Nitrogen (as Equivalent NO2) (mg/m ) 3 100 Carbon Monoxide (CO) (mg/m3) 24 125
Oxygen (O2) (%) 20.7 Not Listed
Table 7 Stack 6, Air Emissions Results Summary – 2012 Stack 6 Regulatory Limit Parameter (EPA point 14) (mg/m3) 3 Total Particulate at 3% O2 (mg/m ) 6.2 10 Particulate Fluoride (mg/m3) 2.3 50 Gaseous Fluoride (mg/m3) 8.9 50 3 Sulfuric Acid Mist (H2SO4 as SO3) (mg/m ) <3.2 100 3 Sulfur Dioxide (SO2 as SO3) (mg/m ) <16 Not Listed Total Polycyclic Aromatic Hydrocarbons (mg/m3) 0.0085 Not Listed 3 Dioxins and Furans (Middle Bound) at 3% O2 (ng/m ) 0.008 0.1 3 Dioxins and Furans (Lower Bound) at 3% O2 (ng/m ) 0.0057 0.1 Volatile Organic Compounds (VOC) (mg/m3) 3.5 Not Listed 3 Total Oxides of Nitrogen (as Equivalent NO2) (mg/m ) 50 2500 3 (as Equivalent NO ) at 3% O (mg/m ) 3 Carbon Monoxide (CO) at 3% O2 (mg/m ) 36 Not Listed Oxygen (%) 17.1 Not Listed
USEPA method 201A, section 6.3.5 (Determination of PM10 Emissions) and USEPA Conditional Test Method 040, Section 17, Table 2 (Determination of PM2.5 Emissions) specifies that results are acceptable provided the calculated aerodynamic cut size (D50) for the test lies between 9.0Pm and 11.0Pm and 2.25Pm and 2.75Pm respectively. Post sampling cut size calculations performed for the sampling conducted during March 2012 are displayed in Table 8. The calculated cut size (D50) value meets the above stated criteria.
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Table 8 Calculated PM10 Cut Sizes
Sampling Location PM10 Cut Size (D50) Stack 1 10.3 Stack 2 8.4 Stack 3 10.5 Stack 4 10.2 Stack 5 10.4 Stack 7 9.9
All of the calculated cut sizes meet the criteria for cut size conditions stated above, with exception to Stack 2.
Cut size, or D50, refers to the aerodynamic diameter of the particles contained in the gas stream which can be captured with a 50% efficiency and is a calculated value. For a Fine Particulate (PM10) test particle sizes of 10µm and less and for a Fine Particulate (PM2.5) test particle sizes of 2.5µm or less.
The cut size (D50) is calculated prior to testing and is based on the pre-test measurements such as stack gas velocity, stack gas temperature, moisture content of the gas stream and stack gas density. This pre-test calculation of cut size (D50) is used in conjunction with the pre-test measurements, some of which are stated above, to establish the sampling conditions or parameters.
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Table 9 Stack 1 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 23 February 2012
Sampling Conditions: Stack internal diameter at test location 1650 mm Stack gas temperature (average) 76.3 oC 349.5 K Stack pressure (average) 1023 hPa Stack gas velocity (average, stack conditions) 13 m/s Stack gas flowrate (stack conditions) 28 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 21 m3/s Fine Particulate (PM10) Testing Test Period 13:29 - 15:12 Fine Particulate (PM10) Mass 0.5 mg Gas Volume Sampled 1.24 m3 Fine Particulate (PM10) Emission*1 0.4 mg/m3 Fine Particulate (PM10) Mass Emission Rate*2 8.6 mg/s Regulatory Limit N/A mg/m3 Total Particulate Testing Test Period 13:29 - 15:12 Total Particulate Mass 0.7 mg Gas Volume Sampled 1.38 m3 Total Particulate Emission*1 0.51 mg/m3 Total Particulate Mass Emission Rate*2 11 mg/s Regulatory Limit 25 mg/m3 Gaseous Fluoride Testing Test Period 13:29 - 15:12 Gaseous Fluoride Mass <0.1 mg Gas Volume Sampled 1.22 m3 Gaseous Fluoride Emission*1 <0.082 mg/m3 Gaseous Fluoride Mass Emission Rate*2 <1.7 mg/s Regulatory Limit 2 mg/m3 Particulate Fluoride Testing Test Period 13:29 - 15:12 Particulate Fluoride Mass 0.017 mg Gas Volume Sampled 1.22 m3 Particulate Fluoride Emission*1 0.014 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.3 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 3.3 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 10 Stack 1 Hazardous Substances, Sulfuric Acid Mist as SO3 and Sulfur Dioxide as SO3 Results, 23 February 2012
Sampling Conditions:
Stack internal diameter at test location 1650 mm Stack gas temperature (average) 56.2 oC 329.4 K Stack pressure (average) 1023 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 29 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 24 m3/s Hazardous Substances (Metals) Testing
Test Period 10:14 - 11:54 Hazardous Substances (Metals) Mass 0.025 mg Gas Volume Sampled 1.39 m3 Hazardous Substances (Metals) Emission*1 0.018 mg/m3 Hazardous Substances (Metals) Mass Emission Rate*2 0.43 mg/s Regulatory Limit 10 mg/m3 Sulfuric Acid Mist (H2SO4 as SO3) Testing
Test Period 10:14 - 11:54 Sulfuric Acid Mist (H2SO4 as SO3) Mass <2 mg Gas Volume Sampled 1.17 m3 Sulfuric Acid Mist (H2SO4 as SO3) Emission*1 <1.7 mg/m3 Sulfuric Acid Mist (H2SO4 as SO3) Mass Emission Rate*2 <40 mg/s Regulatory Limit 100 mg/m3 Sulfur Dioxide (SO2 as SO3) Testing
Test Period 10:14 - 11:54 Sulfur Dioxide (SO2 as SO3) Mass <10 mg Gas Volume Sampled 1.17 m3 Sulfur Dioxide (SO2 as SO3) Emission*1 <8.6 mg/m3 Sulfur Dioxide (SO2 as SO3) Mass Emission Rate*2 <200 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 2.2 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.8 g/g-mole
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Table 11 Stack 1 Polycyclic Aromatic Hydrocarbon, Hydrochloric Acid and Chlorine Results, 24 February 2012
Sampling Conditions:
Stack internal diameter at test location 1650 mm Stack gas temperature (average) 77.1 oC 350.3 K Stack pressure (average) 1023 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 30 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 23 m3/s Polycyclic Aromatic Hydrocarbons Testing
Test Period 10:32 - 12:15 Polycyclic Aromatic Hydrocarbons Mass 0.025 mg Gas Volume Sampled 1.4 m3 Polycyclic Aromatic Hydrocarbons Emission*1 0.018 mg/m3 Polycyclic Aromatic Hydrocarbons Mass Emission Rate*2 0.42 mg/s Regulatory Limit N/A mg/m3 Hydrogen Chloride Testing
Test Period 10:32 - 12:15 Hydrogen Chloride Mass <1 mg Gas Volume Sampled 1.1 m3 Hydrogen Chloride Emission*1 <0.91 mg/m3 Hydrogen Chloride Mass Emission Rate*2 <21 mg/s Regulatory Limit 400 mg/m3 Chlorine Testing
Test Period 10:32 - 12:15 Chlorine Mass <0.2 mg Gas Volume Sampled 1.1 m3 Chlorine Emission*1 <0.18 mg/m3 Chlorine Mass Emission Rate*2 <4.1 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 3.0 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.9 g/g-mole
Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 12 Stack 2 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 17 January 2012
Sampling Conditions: Stack internal diameter at test location 1265 mm
Stack gas temperature (average) 41.8 oC 315.0 K Stack pressure (average) 1022 hPa
Stack gas velocity (average, stack conditions) 14 m/s
Stack gas flowrate (stack conditions) 17 m3/s
Stack gas flowrate (00C, dry gas, 1 atm pressure) 15 m3/s
Fine Particulate (PM10) Testing Test Period 12:31 - 1:35 Fine Particulate (PM10) Mass 3.2 mg
Gas Volume Sampled 0.955 m3
Fine Particulate (PM10) Emission*1 3.3 mg/m3
Fine Particulate (PM10) Mass Emission Rate*2 49 mg/s
Regulatory Limit N/A
Total Particulate Testing Test Period 12:31 - 1:35 Total Particulate Mass 5 mg
Gas Volume Sampled 0.575 m3
Total Particulate Emission*1 8.7 mg/m3
Total Particulate Mass Emission Rate*2 130 mg/s
Regulatory Limit 35 mg/m3 Particulate Fluoride Testing Test Period 12:31 - 1:35 Particulate Fluoride Mass 0.016 mg
Gas Volume Sampled 0.618 m3
Particulate Fluoride Emission*1 0.026 mg/m3
Particulate Fluoride Mass Emission Rate*2 0.38 mg/s
Regulatory Limit N/A
Gaseous Fluoride Testing Test Period 12:31 - 1:35 Gaseous Fluoride Mass 0.6 mg
Gas Volume Sampled 0.618 m3
Gaseous Fluoride Emission*1 0.97 mg/m3
Gaseous Fluoride Mass Emission Rate*2 14 mg/s
Regulatory Limit N/A
Moisture Content (%) 2.2 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 13 Stack 3 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 10 February 2012
Sampling Conditions: Stack internal diameter at test location 1000 mm Stack gas temperature (average) 34.8 oC 308.0 K Stack pressure (average) 1009 hPa Stack gas velocity (average, stack conditions) 8.7 m/s Stack gas flowrate (stack conditions) 6.8 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 5.9 m3/s Fine Particulate (PM10) Testing Test Period 11:16 - 12:19 Fine Particulate (PM10) Mass 0.6 mg Gas Volume Sampled 0.693 m3 Fine Particulate (PM10) Emission*1 0.87 mg/m3 Fine Particulate (PM10) Mass Emission Rate*2 5.2 mg/s Regulatory Limit N/A mg/m3 Total Particulate Testing Test Period 11:16 - 12:19 Total Particulate Mass 1.7 mg Gas Volume Sampled 0.783 m3 Total Particulate Emission*1 2.2 mg/m3 Total Particulate Mass Emission Rate*2 13 mg/s Regulatory Limit 50 mg/m3 Particulate Fluoride Testing Test Period 11:16 - 12:19 Particulate Fluoride Mass 0.022 mg Gas Volume Sampled 0.571 m3 Particulate Fluoride Emission*1 0.039 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.23 mg/s Regulatory Limit N/A mg/m3 Gaseous Fluoride Testing Test Period 11:16 - 12:19 Gaseous Fluoride Mass 0.1 mg Gas Volume Sampled 0.571 m3 Gaseous Fluoride Emission*1 0.18 mg/m3 Gaseous Fluoride Mass Emission Rate*2 1 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 2.2 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 14 Stack 4 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 17 January 2012
Sampling Conditions: Stack internal diameter at test location 1395 mm Stack gas temperature (average) 41.2 oC 314.4 K Stack pressure (average) 1023 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 21 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 18 m3/s Fine Particulate (PM10) Testing Test Period 9:58 - 11:00 Fine Particulate (PM10) Mass 2.5 mg Gas Volume Sampled 0.739 m3 Fine Particulate (PM10) Emission*1 3.4 mg/m3 Fine Particulate (PM10) Mass Emission Rate*2 62 mg/s Regulatory Limit N/A Total Particulate Testing Test Period 9:58 - 11:00 Total Particulate Mass 3.5 mg Gas Volume Sampled 0.629 m3 Total Particulate Emission*1 5.6 mg/m3 Total Particulate Mass Emission Rate*2 100 mg/s Regulatory Limit 24 mg/m3 Particulate Fluoride Testing Test Period 9:58 - 11:00 Particulate Fluoride Mass 0.062 mg Gas Volume Sampled 0.649 m3 Particulate Fluoride Emission*1 0.096 mg/m3 Particulate Fluoride Mass Emission Rate*2 1.7 mg/s Regulatory Limit N/A Gaseous Fluoride Testing Test Period 9:58 - 11:00 Gaseous Fluoride Mass 0.0008 mg Gas Volume Sampled 0.649 m3 Gaseous Fluoride Emission*1 0.0012 mg/m3 Gaseous Fluoride Mass Emission Rate*2 0.022 mg/s Regulatory Limit N/A Moisture Content (%) 1.0 Gas Density (dry at 1 atmosphere) 1.29 kg/m3 Dry Molecular Weight 28.9 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 15 Stack 5 Fine Particulates (PM10), Total Particulates and Polycyclic Aromatic Hydrocarbons Results, 20 March 2012
Sampling Conditions:
Stack internal diameter at test location 1490 mm Stack gas temperature (average) 95.8 oC 369.0 K Stack pressure (average) 1022 hPa Stack gas velocity (average, stack conditions) 15 m/s Stack gas flowrate (stack conditions) 27 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 19 m3/s Fine Particulate (PM10) Testing
Test Period 10:01 - 11:03 Fine Particulate (PM10) Mass 1.8 mg Gas Volume Sampled 0.696 m3 Fine Particulate (PM10) Emission*1 2.6 mg/m3 Fine Particulate (PM10) Mass Emission Rate*2 50 mg/s Regulatory Limit NA Total Particulate Testing
Test Period 10:01 - 11:03 Total Particulate Mass 1.4 mg Gas Volume Sampled 1.29 m3 Total Particulate Emission*1 1.1 mg/m3 Total Particulate Mass Emission Rate*2 21 mg/s Regulatory Limit 10 mg/m3 Polycyclic Aromatic Hydrocarbons Testing
Test Period 10:01 - 11:03 Polycyclic Aromatic Hydrocarbons Mass 0.21 mg Gas Volume Sampled 1.13 m3 Polycyclic Aromatic Hydrocarbons Emission*1 0.19 mg/m3 Polycyclic Aromatic Hydrocarbons Mass Emission Rate*2 3.7 mg/s Regulatory Limit NA Moisture Content (%) 1.9 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.9 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas
*2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations"
for each test.
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Table 16 Stack 5 Hazardous Materials (Metals), Hydrogen Chloride & Chlorine Results, 20 March 2012
Sampling Conditions:
Stack internal diameter at test location 1490 mm Stack gas temperature (average) 87.5 oC 360.7 K Stack pressure (average) 1022 hPa Stack gas velocity (average, stack conditions) 15 m/s Stack gas flowrate (stack conditions) 26m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 19m3/s Hazardous Substances (Metals) Testing
Test Period 12:02 - 13:04 Hazardous Substances (Metals) Mass 0.2 mg Gas Volume Sampled 1.14 m3 Hazardous Substances (Metals) Emission*1 0.17 mg/m3 Hazardous Substances (Metals) Mass Emission Rate*2 3.3 mg/s Regulatory Limit 5 mg/m3 Hydrogen Chloride Testing
Test Period 12:02 - 13:04 Hydrogen Chloride Mass <1 mg Gas Volume Sampled 0.545 m3 Hydrogen Chloride Emission*1 <1.8 mg/m3 Hydrogen Chloride Mass Emission Rate*2 <35 mg/s Regulatory Limit 10 mg/m3 Chlorine Testing
Test Period 12:02 - 13:04 Chlorine Mass <2 mg Gas Volume Sampled 0.545 m3 Chlorine Emission*1 <3.7 mg/m3 Chlorine Mass Emission Rate*2 <71 mg/s Regulatory Limit N/A Moisture Content (%) 2.8
Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.9 g/g-mole
Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas
*2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations"
for each test.
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Table 17 Stack 5 Gaseous and Particulate Fluoride, H2SO4 as SO3 & SO2 as SO3 Results, 20 March 2012
Sampling Conditions: Stack internal diameter at test location 1490 mm Stack gas temperature (average) 88.5 oC 361.7 K Stack pressure (average) 1022 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 25 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 18 m3/s Gaseous Fluoride Testing Test Period 14:11 - 15:13 Gaseous Fluoride Mass <0.1 mg Gas Volume Sampled 0.661 m3 Gaseous Fluoride Emission*1 <0.15 mg/m3 Gaseous Fluoride Mass Emission Rate*2 <2.7 mg/s Regulatory Limit N/A mg/m3 Particulate Fluoride Testing Test Period 14:11 - 15:13 Particulate Fluoride Mass 0.003 mg Gas Volume Sampled 0.661 m3 Particulate Fluoride Emission*1 0.0045 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.08 mg/s Regulatory Limit N/A mg/m3 Sulfuric Acid Mist (H2SO4 as SO3) Testing Test Period 14:11 - 15:13 Sulfuric Acid Mist (H2SO4 as SO3) Mass <2 mg Gas Volume Sampled 0.639 m3 Sulfuric Acid Mist (H2SO4 as SO3) Emission*1 <3.1 mg/m3 Sulfuric Acid Mist (H2SO4 as SO3) Mass Emission Rate*2 <56 mg/s Regulatory Limit 100 mg/m3 Sulfur Dioxide (SO2 as SO3) Testing Test Period 14:11 - 15:13 Sulfur Dioxide (SO2 as SO3) Mass <10 mg Gas Volume Sampled 0.639 m3 Sulfur Dioxide (SO2 as SO3) Emission*1 <16 mg/m3 Sulfur Dioxide (SO2 as SO3) Mass Emission Rate*2 <290 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 4.4 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.9 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 18 Stack 5 Dioxins & Furans Results, 12 January 2012
Sampling Conditions:
Stack internal diameter at test location 1490 mm Stack gas temperature (average) 78.5 oC 351.7 K Stack pressure (average) 1017 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 25 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 19 m3/s Dioxins and Furans Lower Bound Testing
Test Period 10:23 - 16:23 Dioxins and Furans Lower Bound Mass 0.19 ng Gas Volume Sampled 4.85 m3 Dioxins and Furans Lower Bound Emission*1 0.039 ng/m3 Dioxins and Furans Lower Bound Mass Emission Rate*2 0.76 ng/s Regulatory Limit 0.1 ng/m3 Dioxins and Furans Middle Bound Testing
Test Period 10:23 - 16:23 Dioxins and Furans Middle Bound Mass 0.19 ng Gas Volume Sampled 4.85 m3 Dioxins and Furans Middle Bound Emission*1 0.039 ng/m3 Dioxins and Furans Middle Bound Mass Emission Rate*2 0.76 ng/s Regulatory Limit 0.1 ng/m3 Moisture Content (%) 0.5 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 19 Stack 6 Total Particulates & Polycyclic Aromatic Hydrocarbon Results, 20 March 2012
Sampling Conditions:
Stack internal diameter at test location 580 mm Stack gas temperature (average) 412.4 oC 685.6 K Stack pressure (average) 1009 hPa Stack gas velocity (average, stack conditions) 18 m/s Stack gas flowrate (stack conditions) 4.9m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 1.8m3/s Total Particulate Testing
Test Period 10:10 - 11:17 Total Particulate Mass 2 mg Gas Volume Sampled 1.19 m3 Total Particulate Emission*1 at 3% O2 6.2 mg/m3 Total Particulate Mass Emission Rate*2 at 3% O2 11 mg/s Regulatory Limit at 3% O2 10 mg/m3 Polycyclic Aromatic Hydrocarbons Testing
Test Period 10:10 - 11:17 Polycyclic Aromatic Hydrocarbons Mass 0.0079 mg Gas Volume Sampled 0.927 m3 Polycyclic Aromatic Hydrocarbons Emission*1 0.0085 mg/m3 Polycyclic Aromatic Hydrocarbons Mass Emission Rate*2 0.016 mg/s Regulatory Limit N/A Moisture Content (%) 5.3
Gas Density (dry at 1 atmosphere) 1.30 kg/m3
Dry Molecular Weight 29.1 g/g-mole
Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas
*2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations"
for each test.
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Table 20 Stack 6 Gaseous and Particulate Fluoride, H2SO4 as SO3 & SO2 as SO3 Results, 20 March 2012
Sampling Conditions: Stack internal diameter at test location 580 mm Stack gas temperature (average) 402.9 oC 676.1 K Stack pressure (average) 1009 hPa Stack gas velocity (average, stack conditions) 18 m/s Stack gas flowrate (stack conditions) 4.8 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 1.9 m3/s Gaseous Fluoride Testing Test Period 12:03 - 12:50 Gaseous Fluoride Mass 7.2 mg Gas Volume Sampled 0.813 m3 Gaseous Fluoride Emission*1 8.9 mg/m3 Gaseous Fluoride Mass Emission Rate*2 17 mg/s Regulatory Limit 50 mg/m3 Particulate Fluoride Testing Test Period 12:03 - 12:50 Particulate Fluoride Mass 1.85 mg Gas Volume Sampled 0.813 m3 Particulate Fluoride Emission*1 2.3 mg/m3 Particulate Fluoride Mass Emission Rate*2 4.3 mg/s Regulatory Limit 50 mg/m3 Sulfuric Acid Mist (H2SO4 as SO3) Testing Test Period 12:03 - 12:50 Sulfuric Acid Mist (H2SO4 as SO3) Mass <2 mg Gas Volume Sampled 0.63 m3 Sulfuric Acid Mist (H2SO4 as SO3) Emission*1 <3.2 mg/m3 Sulfuric Acid Mist (H2SO4 as SO3) Mass Emission Rate*2 <5.8 mg/s Regulatory Limit 100 mg/m3 Sulfur Dioxide (SO2 as SO3) Testing Test Period 12:03 - 12:50 Sulfur Dioxide (SO2 as SO3) Mass <10 mg Gas Volume Sampled 0.63 m3 Sulfur Dioxide (SO2 as SO3) Emission*1 <16 mg/m3 Sulfur Dioxide (SO2 as SO3) Mass Emission Rate*2 <29 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 4.5 Gas Density (dry at 1 atmosphere) 1.30 kg/m3
Dry Molecular Weight 29.1 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 21 Stack 6 Dioxins & Furans Results, 12 January 2012
Sampling Conditions: Stack internal diameter at test location 580 mm Stack gas temperature (average) 427.4 oC 700.6 K Stack pressure (average) 1017 hPa Stack gas velocity (average, stack conditions) 17 m/s Stack gas flowrate (stack conditions) 4.6 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 1.7 m3/s Dioxins and Furans Lower Bound Testing Test Period 10:55 - 15:59 Dioxins and Furans Lower Bound Mass 0.006 ng Gas Volume Sampled 3.33 m3 Dioxins and Furans Lower Bound Emission*1 at 3% O2 0.0057 ng/m3 Dioxins and Furans Lower Bound Mass Emission Rate*2 at 3% O2 0.0097 ng/s Regulatory Limit at 3% O2 0.1 ng/m3 Dioxins and Furans Middle Bound Testing Test Period 10:15 - 15:59 Dioxins and Furans Middle Bound Mass 0.0083 ng Gas Volume Sampled 3.33 m3 Dioxins and Furans Middle Bound Emission*1 at 3% O2 0.008 ng/m3 Dioxins and Furans Middle Bound Mass Emission Rate*2 at 3% O2 0.014 ng/s Regulatory Limit at 3% O2 0.1 ng/m3 Moisture Content (%) 5.0 Gas Density (dry at 1 atmosphere) 1.30 kg/m3
Dry Molecular Weight 29.1 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 22 Stack 7 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 25 January 2012
Sampling Conditions: Stack internal diameter at test location 1500 mm Stack gas temperature (average) 23.1 oC 296.3 K Stack pressure (average) 1014 hPa Stack gas velocity (average, stack conditions) 16 m/s Stack gas flowrate (stack conditions) 28 m3/s Stack gas flowrate (00C, dry gas, 1 atm pressure) 25 m3/s Fine Particulate (PM10) Testing Test Period 10:06 - 11:06 Fine Particulate (PM10) Mass 2.5 mg Gas Volume Sampled 0.75 m3 Fine Particulate (PM10) Emission*1 3.3 mg/m3 Fine Particulate (PM10) Mass Emission Rate*2 84 mg/s Regulatory Limit N/A Total Particulate Testing Test Period 10:06 - 11:06 Total Particulate Mass 1.7 mg Gas Volume Sampled 0.698 m3 Total Particulate Emission*1 2.4 mg/m3 Total Particulate Mass Emission Rate*2 60 mg/s Regulatory Limit 15 mg/m3 Particulate Fluoride Testing Test Period 10:06 - 11:06 Particulate Fluoride Mass 0.06 mg Gas Volume Sampled 0.774 m3 Particulate Fluoride Emission*1 0.078 mg/m3 Particulate Fluoride Mass Emission Rate*2 2 mg/s Regulatory Limit N/A Gaseous Fluoride Testing Test Period 10:06 - 11:06 Gaseous Fluoride Mass 0.5 mg Gas Volume Sampled 0.774 m3 Gaseous Fluoride Emission*1 0.65 mg/m3 Gaseous Fluoride Mass Emission Rate*2 16 mg/s Regulatory Limit N/A Moisture Content (%) 2.9 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.8 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective
test moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 23 Stack 1 Speciated Volatile Organic Compounds Results, 24 February 2012 Sample Blank Analyte SamplePg BlankPg (mg/m3) mg/s Corrected Pg Acetone <0.5 <0.5 <0.5 <0.096 <2.2 1,1-dichloroethane <0.5 <0.5 <0.5 <0.096 <2.2 2-Butanone <0.5 <0.5 <0.5 <0.096 <2.2 Chloroform <0.5 <0.5 <0.5 <0.096 <2.2 Benzene <0.5 <0.5 <0.5 <0.096 <2.2 1-heptene <0.5 <0.5 <0.5 <0.096 <2.2 n-heptane <0.5 <0.5 <0.5 <0.096 <2.2 Trichloroethene <0.5 <0.5 <0.5 <0.096 <2.2 MIBK <0.5 <0.5 <0.5 <0.096 <2.2 Toluene <0.5 <0.5 <0.5 <0.096 <2.2 2-hexanone <0.5 <0.5 <0.5 <0.096 <2.2 Chlorobenzene <0.5 <0.5 <0.5 <0.096 <2.2 Ethyl Benzene <0.5 <0.5 <0.5 <0.096 <2.2 m- & p-xylene <1 <1 <1 <0.19 <4.4 o-xylene <0.5 <0.5 <0.5 <0.096 <2.2 Styrene <0.5 <0.5 <0.5 <0.096 <2.2 Cyclohexanone <0.5 <0.5 <0.5 <0.096 <2.2 Isopropylbenzene <0.5 <0.5 <0.5 <0.096 <2.2 2-chlorotoluene <0.5 <0.5 <0.5 <0.096 <2.2 4-chlorotoluene <0.5 <0.5 <0.5 <0.096 <2.2 1,3,5-trimethylbenzene <0.5 <0.5 <0.5 <0.096 <2.2 n-decane <0.5 <0.5 <0.5 <0.096 <2.2 1,2,4-trimethylbenzene <0.5 <0.5 <0.5 <0.096 <2.2 1,3-dichlorobenzene <0.5 <0.5 <0.5 <0.096 <2.2 1,4-dichlorobenzene <0.5 <0.5 <0.5 <0.096 <2.2 1,2-dichlorobenzne <0.5 <0.5 <0.5 <0.096 <2.2 n-butylbenzene <0.5 <0.5 <0.5 <0.096 <2.2 Hexachlorobutadiene <0.5 <0.5 <0.5 <0.096 <2.2 Total <1 <1 <0.19 <4.4
Note: Where the blank has returned a less than value, the analysed value has been corrected for half of that blank value. ie a blank value of <0.5 has had 0.25 subtracted from the analysed value.
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Table 24 Stack 5 Speciated Volatile Organic Compounds Results, 20 March 2012 Sample Blank Analyte SamplePg BlankPg (mg/m3) mg/s Corrected Pg Acetone 10.3 <0.5 10.1 1.9 36 1,1-dichloroethane <0.5 <0.5 <0.5 <0.095 <1.8 2-Butanone <0.5 <0.5 <0.5 <0.095 <1.8 Chloroform <0.5 <0.5 <0.5 <0.095 <1.8 Benzene 21.7 <0.5 21.5 4.1 78 1-heptene 0.8 <0.5 0.6 0.11 2.1 n-heptane <0.5 <0.5 <0.5 <0.095 <1.8 Trichloroethene <0.5 <0.5 <0.5 <0.095 <1.8 MIBK <0.5 <0.5 <0.5 <0.095 <1.8 Toluene 1.1 <0.5 0.9 0.17 3.2 2-hexanone <0.5 <0.5 <0.5 <0.095 <1.8 Chlorobenzene <0.5 <0.5 <0.5 <0.095 <1.8 Ethyl Benzene <0.5 <0.5 <0.5 <0.095 <1.8 m- & p-xylene <1 <1 <1 <0.19 <3.6 o-xylene <0.5 <0.5 <0.5 <0.095 <1.8 Styrene <0.5 <0.5 <0.5 <0.095 <1.8 Cyclohexanone <0.5 <0.5 <0.5 <0.095 <1.8 Isopropylbenzene <0.5 <0.5 <0.5 <0.095 <1.8 2-chlorotoluene <0.5 <0.5 <0.5 <0.095 <1.8 4-chlorotoluene <0.5 <0.5 <0.5 <0.095 <1.8 1,3,5-trimethylbenzene <0.5 <0.5 <0.5 <0.095 <1.8 n-decane <0.5 <0.5 <0.5 <0.095 <1.8 1,2,4-trimethylbenzene <0.5 <0.5 <0.5 <0.095 <1.8 1,3-dichlorobenzene <0.5 <0.5 <0.5 <0.095 <1.8 1,4-dichlorobenzene <0.5 <0.5 <0.5 <0.095 <1.8 1,2-dichlorobenzne <0.5 <0.5 <0.5 <0.095 <1.8 n-butylbenzene <0.5 <0.5 <0.5 <0.095 <1.8 Hexachlorobutadiene <0.5 <0.5 <0.5 <0.095 <1.8 Total 33.9 33.1 6.3 119.3 Note: Where the blank has returned a less than value, the analysed value has been corrected for half of that blank value. ie a blank value of <0.5 has had 0.25 subtracted from the analysed value.
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Table 25 Stack 6 Speciated Volatile Organic Compounds Results, 20 March 2012 Sample Blank Analyte SamplePg BlankPg (mg/m3) mg/s Corrected Pg Acetone 6.8 <0.5 6.6 1.3 520 1,1-dichloroethane <0.5 <0.5 <0.5 <0.097 <39 2-Butanone <0.5 <0.5 <0.5 <0.097 <39 Chloroform <0.5 <0.5 <0.5 <0.097 <39 Benzene 10.4 <0.5 10.2 2 810 1-heptene 0.6 <0.5 0.4 0.078 31 n-heptane <0.5 <0.5 <0.5 <0.097 <39 Trichloroethene <0.5 <0.5 <0.5 <0.097 <39 MIBK <0.5 <0.5 <0.5 <0.097 <39 Toluene 1.1 <0.5 0.9 0.17 68 2-hexanone <0.5 <0.5 <0.5 <0.097 <39 Chlorobenzene <0.5 <0.5 <0.5 <0.097 <39 Ethyl Benzene <0.5 <0.5 <0.5 <0.097 <39 m- & p-xylene <1 <1 <1 <0.19 <77 o-xylene <0.5 <0.5 <0.5 <0.097 <39 Styrene <0.5 <0.5 <0.5 <0.097 <39 Cyclohexanone <0.5 <0.5 <0.5 <0.097 <39 Isopropylbenzene <0.5 <0.5 <0.5 <0.097 <39 2-chlorotoluene <0.5 <0.5 <0.5 <0.097 <39 4-chlorotoluene <0.5 <0.5 <0.5 <0.097 <39 1,3,5-trimethylbenzene <0.5 <0.5 <0.5 <0.097 <39 n-decane <0.5 <0.5 <0.5 <0.097 <39 1,2,4-trimethylbenzene <0.5 <0.5 <0.5 <0.097 <39 1,3-dichlorobenzene <0.5 <0.5 <0.5 <0.097 <39 1,4-dichlorobenzene <0.5 <0.5 <0.5 <0.097 <39 1,2-dichlorobenzne <0.5 <0.5 <0.5 <0.097 <39 n-butylbenzene <0.5 <0.5 <0.5 <0.097 <39 Hexachlorobutadiene <0.5 <0.5 <0.5 <0.097 <39 Total 18.9 18.1 3.5 1429 Note: Where the blank has returned a less than value, the analysed value has been corrected for half of that blank value. ie a blank value of <0.5 has had 0.25 subtracted from the analysed value.
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Table 26 Stack 5 Speciated Dioxins & Furans Results, 12 January 2012 Toxic Total Toxic Total Toxic Equivalency Concentration Equivalence Analyte Mass ng Equivalence (1 - Factor (1 - ng/m3 (1-TEQs) TEQs) ng TEFs) ng/m3 2,3,7,8-TCDF 0.36 0.1 0.036 0.074 0.0074 Total TCDF isomers 6.61 2,3,7,8-TCDD 0.0089 1 0.0089 0.0018 0.0018 Total TCDD isomers 0.7
1,2,3,7,8-PeCDF 0.15 0.05 0.0075 0.031 0.0015 2,3,4,7,8-PeCDF 0.2 0.5 0.1 0.041 0.021 Total PeCDF isomers 2.42 1,2,3,7,8-PeCDD 0.026 0.5 0.013 0.0054 0.0027 Total PeCDD isomers 0.44
1,2,3,4,7,8-HxCDF 0.089 0.1 0.0089 0.018 0.0018 1,2,3,6,7,8-HxCDF 0.08 0.1 0.008 0.016 0.0016 2,3,4,6,7,8-HxCDF 0.046 0.1 0.0046 0.0095 0.00095 1,2,3,7,8,9-HxCDF 0.0033 0.1 0.00033 0.00068 0.000068 Total HxCDF isomers 0.77 1,2,3,4,7,8-HxCDD 0.0093 0.1 0.00093 0.0019 0.00019 1,2,3,6,7,8-HxCDD 0.012 0.1 0.0012 0.0025 0.00025 1,2,3,7,8,9-HxCDD 0.0082 0.1 0.00082 0.0017 0.00017 Total HxCDD isomers 0.31
1,2,3,4,6,7,8-HpCDF 0.08 0.01 0.0008 0.016 0.00016 1,2,3,4,7,8,9-Hp CDF 0.006 0.01 0.00006 0.0012 0.000012 Total HpCDF isomers 0.12 1,2,3,4,6,7,8-HpCDD 0.023 0.01 0.00023 0.0047 0.000047 Total HpCDD isomers 0.059
OCDF 0.0048 0.001 0.0000048 0.00099 0.00000099 OCDD 0.043 0.001 0.000043 0.0089 0.0000089
I-TEQDF Lower Bound (excluding LOD Values) 0.19 ng Middle Bound (including half LOD Values) 0.19 ng
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Table 27 Stack 6 Speciated Dioxins & Furans Results, 12 January 2012 Toxic Total Toxic Total Toxic Equivalency Concentration Equivalence Analyte Mass ng Equivalence (1 - Factor (1 - ng/m3 (1-TEQs) TEQs) ng TEFs) ng/m3 2,3,7,8-TCDF 0.0067 0.1 0.00067 0.002 0.0002 Total TCDF isomers 0.15 2,3,7,8-TCDD <0.002 1 0.001 <0.0006 0.0003 Total TCDD isomers 0.019
1,2,3,7,8-PeCDF 0.004 0.05 0.0002 0.0012 0.00006 2,3,4,7,8-PeCDF 0.0099 0.5 0.00495 0.003 0.0015 Total PeCDF isomers 0.1 1,2,3,7,8-PeCDD <0.002 0.5 0.0005 <0.0006 0.00015 Total PeCDD isomers <0.03
1,2,3,4,7,8-HxCDF <0.002 0.1 0.0001 <0.0006 0.00003 1,2,3,6,7,8-HxCDF <0.004 0.1 0.0002 <0.0012 0.00006 2,3,4,6,7,8-HxCDF <0.005 0.1 0.00025 <0.0015 0.000075 1,2,3,7,8,9-HxCDF <0.002 0.1 0.0001 <0.0006 0.00003 Total HxCDF isomers 0.039 1,2,3,4,7,8-HxCDD <0.002 0.1 0.0001 <0.0006 0.00003 1,2,3,6,7,8-HxCDD <0.001 0.1 0.00005 <0.0003 0.000015 1,2,3,7,8,9-HxCDD <0.001 0.1 0.00005 <0.0003 0.000015 Total HxCDD isomers 0.011
1,2,3,4,6,7,8-HpCDF 0.0067 0.01 0.000067 0.002 0.00002 1,2,3,4,7,8,9-Hp CDF 0.0017 0.01 0.000017 0.00051 0.0000051 Total HpCDF isomers 0.015 1,2,3,4,6,7,8-HpCDD 0.0051 0.01 0.000051 0.0015 0.000015 Total HpCDD isomers 0.01
OCDF <0.002 0.001 0.000001 <0.0006 0.0000003 OCDD <0.01 0.001 0.000005 <0.003 0.0000015
I-TEQDF Lower Bound (excluding LOD Values) 0.006 ng Middle Bound (including half LOD Values) 0.0083 ng
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Table 28 Stack 1 Elemental Metals Total Total Total Total Total Total Mass Particulate Particulate Gaseous Gaseous Oxidisable Oxidisable Sample Total (mg) Total (mg/m3) Emission Metals Metals Metals Metals Mercury Mercury Rate (mg/s) (mg) (mg/m3) (mg) (mg/m3) (mg) (mg/m3) Antimony 0.00035 0.00025 <0.00029 <0.00021 0.00035 0.00025 0.006 Arsenic <0.00091 <0.00065 <0.00029 <0.00021 <0.0015 <0.00065 <0.016 Beryllium <0.00029 <0.00021 <0.00029 <0.00021 <0.000015 <0.00021 <0.005 Cadmium 0.00028 0.0002 0.00031 0.00022 0.0006 0.00042 0.01 Chromium 0.00051 0.00037 0.0019 0.0014 0.002 0.0018 0.043 Cobalt <0.00029 <0.00021 <0.00029 <0.00021 <0.00015 <0.00021 <0.005 Copper 0.0063 0.0045 0.00039 0.00028 0.007 0.0048 0.12 Lead 0.0023 0.0017 0.00028 0.0002 0.003 0.0019 0.046 Magnesium <0.3428 <0.25 0.0078 0.0056 0.0078 0.0056 0.13 Manganese <0.0307 <0.022 <0.0303 <0.022 <0.00004 <0.022 <0.53 Mercury <0.00029 <0.00021 <0.00029 <0.00021 <0.00025 <0.00018 <0.000025 <0.00021 <0.005 Nickel 0.00072 0.00052 <0.00061 <0.00044 0.00072 0.00052 0.012 Selenium <0.00029 <0.00021 <0.00029 <0.00021 <0.002 <0.00021 <0.005 Thallium <0.00029 <0.00021 <0.00029 <0.00021 <0.004 <0.00021 <0.005 Tin 0.00018 0.00013 <0.00029 <0.00021 0.00018 0.00013 0.0031 Vanadium <0.00029 <0.00021 <0.00029 <0.00021 <0.0002 <0.00021 <0.005 Zinc 0.0036 0.0026 <0.00565 <0.0041 0.0036 0.0026 0.062 Total Hazardous 0.0042 0.003 0.0025 0.0018 <0.00025 <0.00018 0.0069 0.0049 0.12 Metals* Total Metals 0.014 0.01 0.011 0.0077 0.025 0.018 0.44 * Total does not include Copper, Magnesium and Zinc as they are classed non-hazardous
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Table 29 Stack 5 Elemental Metals Total Total Total Total Oxidisable Total Gaseous Total Oxidisable Mass Emission Sample Particulate Particulate Gaseous Mercury Total (mg) Total (mg/m3) Metals (mg/m3) Mercury (mg) Rate (mg/s) Metals (mg) Metals (mg/m3) Metals (mg) (mg/m3) Antimony 0.00083 0.00073 0.00016 0.00014 0.001 0.00087 0.017
Arsenic <0.0011 <0.00096 <0.00005 <0.000044 <0.0015 <0.0013 <0.025
Beryllium <0.00006 <0.000052 <0.00005 <0.000044 <0.000015 <0.000013 <0.00025
Cadmium 0.0002 0.00017 0.0024 0.0021 0.003 0.0026 0.05
Chromium <0.00468 <0.0041 0.0021 0.0018 0.0021 0.0018 0.035
Cobalt <0.00005 <0.000044 0.00005 0.000044 0.00005 0.000044 0.00085
Copper <0.0023 <0.002 0.004 0.0035 0.004 0.0035 0.068
Lead 0.00074 0.00065 0.034 0.03 0.03 0.026 0.5
Magnesium 0.05 0.044 0.18 0.16 0.2 0.17 3.3
Manganese 0.00076 0.00066 <0.00093 <0.00081 0.00076 0.00066 0.013
Mercury <0.00005 <0.000044 0.00006 0.000052 <0.00025 <0.00022 0.00006 0.000052 0.001 Nickel 0.00066 0.00058 0.0036 0.0031 0.004 0.0035 0.068
Selenium <0.00017 <0.00015 0.16 0.14 0.16 0.14 2.7
Thallium <0.00005 <0.000044 <0.00005 <0.000044 <0.004 <0.0035 <0.068
Tin <0.00032 <0.00028 0.0017 0.0015 0.0017 0.0015 0.029
Vanadium <0.00005 <0.000044 0.00011 0.000096 0.00011 0.000096 0.0019
Zinc <6.50094 <5.7 0.037 0.032 0.037 0.032 0.62
Total Hazardous 0.0032 0.0028 0.2 0.18 <0.00025 <0.00022 0.2 0.18 3.4 Metals* Total Metals 0.053 0.047 0.43 0.37 0.44 0.39 7.5
* Total does not include Copper, Magnesium and Zinc as they are classed non-hazardous
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Table 30 Stack 1 Speciated Polycyclic Aromatic Hydrocarbons Results
Sample Result Emission Mass Emission Rate (ng) (Pg) (mg) (Pg/m3) (mg/m3) (Pg/s) (mg/s)
Naphthalene 12000 12 0.012 8.6 0.0086 200 0.2 2 - Methylnapthalene 4700 4.7 0.0047 3.4 0.0034 79 0.079 Acenaphthylene 770 0.77 0.00077 0.55 0.00055 13 0.013 Acenaphthene 320 0.32 0.00032 0.23 0.00023 5.3 0.0053 Fluorene 770 0.77 0.00077 0.55 0.00055 13 0.013 Phenanthrene 4400 4.4 0.0044 3.1 0.0031 74 0.074 Anthracene 220 0.22 0.00022 0.16 0.00016 3.7 0.0037 Fluoranthene 860 0.86 0.00086 0.61 0.00061 14 0.014 Pyrene 630 0.63 0.00063 0.45 0.00045 11 0.011 Benz(a)anthracene <85 <0.085 <0.000085 0.061 <0.000061 <1.4 <0.0014 Chrysene 110 0.11 0.00011 0.078 0.000078 1.8 0.0018 Benzo(b)fluoranthene 100 0.1 0.0001 0.071 0.000071 1.7 0.0017 Benzo(k)fluoranthene <90 <0.09 <0.00009 0.064 <0.000064 <1.5 <0.0015 Benzo(e)pyrene 180 0.18 0.00018 0.13 0.00013 3 0.003 Benzo(a)pyrene <100 <0.1 <0.0001 0.071 <0.000071 <1.7 <0.0017 Perylene <100 <0.1 <0.0001 0.071 <0.000071 <1.7 <0.0017 Indeno(123:cd)pyrene <85 <0.085 <0.000085 0.061 <0.000061 <1.4 <0.0014 Dibenzo(ah)anthracene <85 <0.085 <0.000085 0.061 <0.000061 <1.4 <0.0014 Benzo(ghi)perylene <95 <0.095 <0.000095 0.068 <0.000068 <1.6 <0.0016 Sum of reported PAH's 25000 25 0.025 18 0.018 420 0.42
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Table 31 Stack 5 Speciated PAH
Sample Result Emission Mass Emission Rate (ng) (Pg) (mg) (Pg/m3) (mg/m3) (Pg/s) (mg/s)
Naphthalene 100000 100 0.1 89 0.089 1700 1.7 2 - Methylnapthalene 46000 46 0.046 41 0.041 800 0.8 Acenaphthylene 9100 9.1 0.0091 8.1 0.0081 160 0.16 Acenaphthene 2400 2.4 0.0024 2.1 0.0021 42 0.042 Fluorene 25000 25 0.025 22 0.022 440 0.44 Phenanthrene 15000 15 0.015 13 0.013 260 0.26 Anthracene 2400 2.4 0.0024 2.1 0.0021 42 0.042 Fluoranthene 3100 3.1 0.0031 2.8 0.0028 54 0.054 Pyrene 2400 2.4 0.0024 2.1 0.0021 42 0.042 Benz(a)anthracene 620 0.62 0.00062 0.55 0.00055 11 0.011 Chrysene 2200 2.2 0.0022 2 0.002 38 0.038 Benzo(b)fluoranthene 650 0.65 0.00065 0.58 0.00058 11 0.011 Benzo(k)fluoranthene 370 0.37 0.00037 0.33 0.00033 6.4 0.0064 Benzo(e)pyrene <200 <0.2 <0.0002 0.18 <0.00018 <3.5 <0.0035 Benzo(a)pyrene <200 <0.2 <0.0002 0.18 <0.00018 <3.5 <0.0035 Perylene <200 <0.2 <0.0002 0.18 <0.00018 <3.5 <0.0035 Indeno(123:cd)pyrene <200 <0.2 <0.0002 0.18 <0.00018 <3.5 <0.0035 Dibenzo(ah)anthracene <200 <0.2 <0.0002 0.18 <0.00018 <3.5 <0.0035 Benzo(ghi)perylene <200 <0.2 <0.0002 0.18 <0.00018 <3.5 <0.0035 Sum of reported PAH's 210000 210 0.21 190 0.19 3600 3.6
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Table 32 Stack 6 Speciated PAH
Sample Result Emission Mass Emission Rate (ng) (Pg) (mg) (Pg/m3) (mg/m3) (Pg/s) (mg/s)
Naphthalene 4700 4.7 0.0047 5.1 0.0051 9.4 0.0094 2 - Methylnapthalene 1200 1.2 0.0012 1.3 0.0013 2.4 0.0024 Acenaphthylene 260 0.26 0.00026 0.28 0.00028 0.52 0.00052 Acenaphthene 83 0.083 0.000083 0.09 0.00009 0.17 0.00017 Fluorene 570 0.57 0.00057 0.62 0.00062 1.1 0.0011 Phenanthrene 680 0.68 0.00068 0.73 0.00073 1.4 0.0014 Anthracene 59 0.059 0.000059 0.064 0.000064 0.12 0.00012 Fluoranthene <280 <0.28 <0.00028 0.3 <0.0003 <0.56 <0.00056 Pyrene 160 0.16 0.00016 0.17 0.00017 0.32 0.00032 Benz(a)anthracene <25 <0.025 <0.000025 0.027 <0.000027 <0.05 <0.00005 Chrysene 60 0.06 0.00006 0.065 0.000065 0.12 0.00012 Benzo(b)fluoranthene 29 0.029 0.000029 0.031 0.000031 0.058 0.000058 Benzo(k)fluoranthene 23 0.023 0.000023 0.025 0.000025 0.046 0.000046 Benzo(e)pyrene 22 0.022 0.000022 0.024 0.000024 0.044 0.000044 Benzo(a)pyrene 61 0.061 0.000061 0.066 0.000066 0.12 0.00012 Perylene <20 <0.02 <0.00002 0.022 <0.000022 <0.04 <0.00004 Indeno(123:cd)pyrene <20 <0.02 <0.00002 0.022 <0.000022 <0.04 <0.00004 Dibenzo(ah)anthracene <20 <0.02 <0.00002 0.022 <0.000022 <0.04 <0.00004 Benzo(ghi)perylene <20 <0.02 <0.00002 0.022 <0.000022 <0.04 <0.00004 Sum of reported PAH's 7900 7.9 0.0079 9 0.0086 16 0.016
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Emissions Testing Report Stack 1 Jan 2012
Weston Aluminium
NATA ACCREDITATION No. 2778 (14391) Accredited for compliance with ISO/IEC 17025 This document is issued in accordance with NATA’s accreditation requirements. This document may not be reproduced except in full.
AECOM Emissions Testing Report Stack 1 Jan 2012
Emissions Testing Report Stack 1 Jan 2012 Weston Aluminium
Prepared for Weston Aluminium Pty Ltd
Prepared by
AECOM Australia Pty Ltd 17 Warabrook Boulevarde, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T +61 2 4911 4900 F +61 2 4911 4999 www.aecom.com ABN 20 093 846 925
23 February 2012
60195964
AECOM in Australia and New Zealand is certified to the latest version of ISO9001 and ISO14001.
© AECOM Australia Pty Ltd (AECOM). All rights reserved.
AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and AECOM’s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety.
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Quality Information
Document Emissions Testing Report Stack 1 Jan 2012
Ref 60195964
Date 23 February 2012
Prepared by Colin Clarke
Reviewed by Chad Whitburn NATA Signatory
Revision History
Authorised Revision Revision Details Date Name/Position Signature
1.0 23 Feb 2012 Chad Whitburn Senior Professional/ Workgroup Leader
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Table of Contents 1.0 Introduction 1 2.0 Sampling Plane Requirements 3 3.0 Methodology 5 3.1 NATA Accredited Methods 5 3.2 Deviations From NATA Approved Methods 6 4.0 Sampling Location 7 4.1 Sampling Location Summary 7 5.0 Equipment Calibration 9 6.0 Results 11 7.0 References 19 Appendix A Field Sheets A Appendix B Raw and Calculated Gas B Appendix C Laboratory Analysis Reports C
List of Tables Table 1 Criteria for Selection of Sampling Planes (AS 4323. 1- 1995) 3 Table 2 AECOM NATA Endorsed Methods 5 Table 3 Sampling Location Summary 7 Table 4 Air Emission Results Summary, Stack 1 – 2012 11 Table 5 Calculated PM10 Cut Size 11 Table 6 Stack 1 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 10 January 2012 12 Table 7 Stack 1 Hazardous substances (Metals), Hydrogen Chloride and Chlorine Results, 11 January 2012 13 Table 8 Stack 1 Polycyclic Aromatic Hydrocarbons (PAH), and Cyanide Results, 11 January 2012 14 Table 9 Stack 1 Speciated Volatile Organic Compounds (VOC) Results, 10 January 2012 15 Table 10 Stack 1 Speciated Polyaromatic Hydrocarbons (PAH) Results, 11 January 2012 16 Table 11 Stack 1 Speciated Hazardous Substances (Metals) Results, 11 January 2012 17
List of Appendices Appendix A Field Sheets 54 pages Appendix B Raw and Calculated Gas 9 pages Appendix C Laboratory Analysis Reports 24 pages
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1.0 Introduction AECOM was appointed by Weston Aluminium Pty Ltd to conduct a series of measurements to determine air emissions from one stack located at their Weston plant in Kurri Kurri, NSW. Emission testing was a compliance requirement of Environmental Protection Licence (EPL) number 6423. Testing was conducted on 10-11 January 2012 to determine emission concentrations for EPL Point 1 for the following parameters: - Total Particulate (TP);
- Fine Particulate (PM10); - Particulate Fluoride; - Gaseous Fluoride; - Hazardous Substances (Metals); - Polycyclic Aromatic Hydrocarbons (PAH); - Volatile Organic Compounds (VOCs);
- Oxides of Nitrogen (NOx as Equivalent NO2); - Carbon Monoxide (CO);
- Oxygen (O2); - Hydrogen Chloride (HCl); - Chlorine (Cl); and - Cyanide. Laboratory analysis was conducted by the following laboratories, which hold NATA accreditation for the specified tests: - Australian Laboratory Services, NATA Accreditation No. 825, laboratory report number EN1200170 for analysis of: x Hydrogen Chloride; x Chlorine; x Total Particulate; x Fine Particulate; x Particulate and Gaseous Fluoride; x Volatile Organic Compounds (VOCs); and x Cyanide. - National Measurement Institute (NMI), NATA Accreditation No. 198, laboratory report number DAU141211C for analysis of: x Polycyclic Aromatic Hydrocarbons; and - SGS Environmental, NATA Accreditation No. 2562, performed the following analysis detailed in report number SE104686: x Hazardous Substances (Metals).
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2.0 Sampling Plane Requirements The criteria for sampling planes are specified in AS 4323.1-1995.
Table 1 Criteria for Selection of Sampling Planes (AS 4323. 1- 1995) Minimum distance upstream from Minimum distance downstream Type of flow disturbance disturbance, diameters (D) from disturbance, diameters (D) Bend, connection, junction, >2D >6D direction change Louvre, butterfly damper >3D >6D (partially closed or closed) Axial fan >3D >8D (see Note) Centrifugal fan >3D >6D NOTE: The plane should be selected as far as practicable from a fan. Flow straighteners may be required to ensure the position chosen meets the check criteria listed in Items (a) to (f) below. a. The gas flow is basically in the same direction at all points along each sampling traverse. b. The gas velocity at all sampling points is greater than 3 m/s. c. The gas flow profile at the sampling plane shall be steady, evenly distributed and not have a cyclonic component which exceeds an angle of 15o to the duct axis, when measured near the periphery of a circular sampling plane. d. The temperature difference between adjacent points of the survey along each sampling traverse is less than 10% of the absolute temperature, and the temperature at any point differs by less than 10% from the mean. e. The ratio of the highest to lowest pitot pressure difference shall not exceed 9:1 and the ratio of highest to lowest gas velocities shall not exceed 3:1. For isokinetic testing with the use of impingers, the gas velocity ratio across the sampling plane should not exceed 1.6:1. f. The gas temperature at the sampling plane should preferably be above the dewpoint. Stack 1 (EPA Identification No. 1) did not satisfy the requirements of AS 4323.1 Section 4.1 – 1995 with regard to the upstream and downstream distances from disturbances. To compensate for this, additional sampling points were added in accordance with AS 4323.1 Section 4.2 – 1995.
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3.0 Methodology
3.1 NATA Accredited Methods The following methods are accredited with the National Association of Testing Authorities (NATA), Accreditation No. 2778 (14391), and are approved for the sampling and analysis of gases and aerosols. Specific details of the methods are available on request. All sampling and analysis is conducted according to the methods in Table 2.
Table 2 AECOM NATA Endorsed Methods NSW DECC USEPA Methods Parameter measured Approved Methods NSW DECC TM-1 USEPA (2000) Method 1 under approved Selection of sampling positions (AS 4323.1-1995) circumstances NSW DECC TM-2 USEPA (2000) Method 2 or 2C or USEPA Velocity or volumetric flow rate or (1999) Method 2F or 2G or 2H (as appropriate) temperature or pressure of stack gases
NSW DECC TM-7 USEPA (2000) 26A Chlorine (Cl2)
NSW DECC TM-8 USEPA (2000) 26A Hydrogen chloride (HCl)
NSW DECC TM-9 USEPA (2000) Method 13A or 13B (as Fluorine (F2) or any compound appropriate) containing fluorine, except where emitted by a primary aluminium smelter while manufacturing aluminium from alumina NSW DECC TM-12 USEPA (2000) Method 29 or USEPA (2000) Type 1 substances (elements antimony Method 102 (for mercury only in hydrogen rich (Sb), arsenic (As), cadmium (Cd), lead streams) (as appropriate) (Pb) or mercury (Hg) or any compound containing one or more of those elements) NSW DECC TM-13 USEPA (2000) Method 29 (Analysis for tin and Type 2 substances (elements beryllium vanadium to be done by Inductively Coupled (Be), chromium (Cr), cobalt (Co), Argon Plasma Emission Spectroscopy (ICAP) manganese (Mn), nickel (Ni), selenium as defined in USEPA Method 29) or USEPA (Se), tin (Sn) or vanadium (V) or any (1986) Method 7910 (for vanadium only) or compound containing one or more of USEPA (1986) Method 7911 (for vanadium those elements) only) (as appropriate) NSW DECC TM-14 Cadmium (Cd) or mercury (Hg) or any USEPA (2000) Method 29 or USEPA compound containing one or more of those (2000) Method 102 (for mercury only in elements hydrogen rich streams) (as appropriate) NSW DECC TM-15 USEPA (2000) Method 5 under approved Solid particles (Total) (AS 4323.2-1995) circumstances NSW DECC TM-22 USEPA (2000) Method 4 Moisture content in stack gases NSW DECC TM-23 USEPA (2000) Method 3 Dry gas density or molecular weight of stack gases NSW DECC TM-34 USEPA (2000) Method 18 or USEPA Volatile organic compounds (2000) Method 25 or 25A or 25B or 25C or 25D or 25E (as appropriate)
NSW DECC OM-5 USEPA (1997) Method 201 or 201A (as ‘Fine’ particulates (PM10) appropriate) NSW DECC OM-6 California EPA Air Resources Board (1997) Polycyclic aromatic hydrocarbons Method 429 (PAHs) NSW DECC TM-32 USEPA Method 10 Determination of Carbon Monoxide emissions from stationary sources
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NSW DECC USEPA Methods Parameter measured Approved Methods NSW DECC TM-25 USEPA Method 3A Determination of Oxygen concentrations from stationary sources NSW DECC TM-11 USEPA(2000) Method 7C Determination of Nitrogen dioxide or nitric oxide emissions from stationary sources All parameters are reported adjusted to 0oC at 1 atmosphere and dry gas
3.2 Deviations From NATA Approved Methods The following method is not accredited with the National Association of Testing Authorities (NATA), Accreditation No. 2778 (14391), for the sampling and analysis of gases and aerosols: - USEPA OTM-29 Sampling and Analysis of Hydrogen Cyanide Emissions from Stationary Sources.
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4.0 Sampling Location
4.1 Sampling Location Summary Table 3 provides a summary of the location sampled by AECOM during January 2011 at the Weston Aluminium plant in Kurri Kurri, NSW.
Table 3 Sampling Location Summary
Discharge Description Stack 1 (EPA Identification No. 1) Duct Shape Circular Construction Material Metal Duct Diameter (mm) 1650 Minimum No. Sampling Points 16 Sampling Ports 2 Min. Points/Traverse 8 Disturbance Yes Distance from Upstream Disturbance 2D Type of Disturbance Fan entry Distance from Downstream Disturbance 4D Type of Disturbance Stack exit Ideal Sampling Location No Correction Factors Applied Yes Total No. Points Sampled 20 Points/Traverse 10 Sampling Performed to Standard* Yes1 *AS 4323.1 Stationary source emissions Method 1 – Selection of sampling positions 1 AS 4323.1 Section 4.2
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5.0 Equipment Calibration AECOM has a calibration schedule to ensure the emission testing equipment is maintained in good order and with known calibration. Equipment used in this project was calibrated according to the procedures and frequency identified in the AECOM calibration schedule. Details of the schedule and the calibration calculations are available on request.
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6.0 Results A summary of test results for the Stack 1 January 2012 testing is presented in Table 4. Calculated Fine Particulate (PM10) cut sizes for Stack 1 are displayed in Table 5. Detailed results along with gas stream properties during the testing periods can be found in Tables 6 to 8. Tables 9 to 11 provide speciated results for Polycyclic Aromatic Hydrocarbons, Volatile Organic Compounds and Hazardous Substances (Metals). All emission concentrations are converted to standard conditions of 0oC, dry gas and 1 atm pressure for comparison with regulatory limits outlined in the revised Weston Aluminium licence (variation dated 10 August 2010). Field notes recorded during the project are attached as Appendix A. Raw and calculated gas data can be viewed in Appendix B, with Laboratory Analysis Reports attached as Appendix C.
Table 4 Air Emission Results Summary, Stack 1 – 2012 Stack 1 Regulatory Limit Parameter (EPA point 1) (mg/m3) Total Particulate (mg/m3) 0.23 25
3 Fine Particulate (PM10) (mg/m ) 0.76 Not Listed Hydrogen Chloride (mg/m3) 1.1 400 Chlorine (mg/m3) 1 Not Listed Particulate Fluoride (mg/m3) 0.013 Not Listed Gaseous Fluoride (mg/m3) 0.16 2 Cyanide <0.0082 Not Listed Total Hazardous Substances (Metals) (mg/m3) 0.025 10 Total Polycyclic Aromatic Hydrocarbons (mg/m3) 0.005 Not Listed Volatile Organic Compounds (VOC) (mg/m3) <0.00019 Not Listed Oxygen (%) 20.09 Not Listed
USEPA Method 201A, Section 6.3.5, specifies that fine particulate (PM10) results are acceptable provided the calculated cut size (D50) for the testing lies between 9.0 and 11.0 µm. Post sampling calculations for the PM10 sampling performed at Weston Aluminium during January 2012 resulted in calculated cut size displayed in Table 7.
Table 5 Calculated PM10 Cut Size
Sampling Location PM10 Cut Size (D50) Stack 1 10.4 The calculated cut sizes meet the criteria for cut size conditions stated above.
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Table 6 Stack 1 Fine Particulate (PM10), Total Particulate, Gaseous and Particulate Fluoride Results, 10 January 2012
Sampling Conditions Stack internal diameter at test location 1650 mm Stack gas temperature (average) 97.0 oC 370.2 K Stack pressure (average) 1011 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 30 m3/s Stack gas flowrate (0oC, dry gas, 1 atm pressure) 22 m3/s Fine Particulate (PM10) Testing Test Period 11:06 - 12:50
Fine Particulate (PM10) Mass 0.9 mg Gas Volume Sampled 1.19 m3 3 Fine Particulate (PM10) Emission*1 0.76 mg/m
Fine Particulate (PM10) Mass Emission Rate*2 16 mg/s Regulatory Limit N/A mg/m3 Total Particulate Testing Test Period 11:06 - 12:50 Total Particulate Mass 0.4 mg Gas Volume Sampled 1.74 m3 Total Particulate Emission*1 0.23 mg/m3 Total Particulate Mass Emission Rate*2 4.9 mg/s Regulatory Limit 25 mg/m3 Particulate Fluoride Testing Test Period 11:06 - 12:50 Particulate Fluoride Mass 0.024 mg Gas Volume Sampled 1.88 m3 Particulate Fluoride Emission*1 0.013 mg/m3 Particulate Fluoride Mass Emission Rate*2 0.28 mg/s Regulatory Limit N/A mg/m3 Gaseous Fluoride Testing Test Period 11:06 - 12:50 Gaseous Fluoride Mass 0.3 mg Gas Volume Sampled 1.88 m3 Gaseous Fluoride Emission*1 0.16 mg/m3 Gaseous Fluoride Mass Emission Rate*2 3.5 mg/s Regulatory Limit 2 mg/m3 Moisture Content (%) 2.2 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.9 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations for each test.
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Table 7 Stack 1 Hazardous substances (Metals), Hydrogen Chloride and Chlorine Results, 11 January 2012
Sampling Conditions:
Stack internal diameter at test location 1650 mm Stack gas temperature (average) 87.8 oC 361.0 K Stack pressure (average) 1006 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 30 m3/s Stack gas flowrate (0oC, dry gas, 1 atm pressure) 22 m3/s Hazardous Substances (Metals) Testing
Test Period 12:20 - 14:05 Hazardous Substances (Metals) Mass 0.03 mg Gas Volume Sampled 1.17 m3 Hazardous Substances (Metals) Emission*1 0.026 mg/m3 Hazardous Substances (Metals) Mass Emission Rate*2 0.57 mg/s Regulatory Limit 10 mg/m3 Hydrogen Chloride Testing
Test Period 12:20 - 14:05 Hydrogen Chloride Mass 1.57 mg Gas Volume Sampled 1.46 m3 Hydrogen Chloride Emission*1 1.1 mg/m3 Hydrogen Chloride Mass Emission Rate*2 24 mg/s Regulatory Limit 400 mg/m3 Chlorine Testing
Test Period 12:20 - 14:05 Chlorine Mass 1.45 mg Gas Volume Sampled 1.46 m3 Chlorine Emission*1 1 mg/m3 Chlorine Mass Emission Rate*2 22 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 3.1 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.9 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 8 Stack 1 Polycyclic Aromatic Hydrocarbons (PAH), and Cyanide Results, 11 January 2012
Sampling Conditions:
Stack internal diameter at test location 1650 mm Stack gas temperature (average) 91.3 oC 364.5 K Stack pressure (average) 1007 hPa Stack gas velocity (average, stack conditions) 14 m/s Stack gas flowrate (stack conditions) 31 m3/s Stack gas flowrate (0oC, dry gas, 1 atm pressure) 23 m3/s Cyanide Testing
Test Period 14:25 - 16:07 Cyanide Mass <0.01 mg Gas Volume Sampled 1.22 m3 Cyanide Emission*1 <0.0082 mg/m3 Cyanide Mass Emission Rate*2 <0.19 mg/s Regulatory Limit N/A mg/m3 Polycyclic Aromatic Hydrocarbons Testing
Test Period 14:25 - 16:07 Polycyclic Aromatic Hydrocarbons Mass 0.0052 mg Gas Volume Sampled 1.05 m3 Polycyclic Aromatic Hydrocarbons Emission*1 0.005 mg/m3 Polycyclic Aromatic Hydrocarbons Mass Emission Rate*2 0.11 mg/s Regulatory Limit N/A mg/m3 Moisture Content (%) 1.1 Gas Density (dry at 1 atmosphere) 1.29 kg/m3
Dry Molecular Weight 28.9 g/g-mole Notes *1 Emission concentration at Standard conditions of 00C, 1 atm, dry gas *2 Mass emission rate determined from pre and post test sampling flow measurements and the respective test
moisture content. See Qstd in field sheets and final calculations "Stack Analysis - Final Calculations" for each test.
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Table 9 Stack 1 Speciated Volatile Organic Compounds (VOC) Results, 10 January 2012 Sample Blank Concen- Sample Blank Result Mass Emission Analyte Corrected tration Result Pg) Pg) Rate (mg/s) (Pg) (mg/m3) Acetone <0.5 <0.5 <0.5 <0.000096 <0.0021 1,1-dichloroethane <0.5 <0.5 <0.5 <0.000096 <0.0021 2-Butanone <0.5 <0.5 <0.5 <0.000096 <0.0021 Chloroform <0.5 <0.5 <0.5 <0.000096 <0.0021 Benzene <0.5 <0.5 <0.5 <0.000096 <0.0021 1-heptene <0.5 <0.5 <0.5 <0.000096 <0.0021 n-heptane <0.5 <0.5 <0.5 <0.000096 <0.0021 Trichloroethene <0.5 <0.5 <0.5 <0.000096 <0.0021 MIBK <0.5 <0.5 <0.5 <0.000096 <0.0021 Toluene <0.5 <0.5 <0.5 <0.000096 <0.0021 2-hexanone <0.5 <0.5 <0.5 <0.000096 <0.0021 Chlorobenzene <0.5 <0.5 <0.5 <0.000096 <0.0021 Ethyl Benzene <0.5 <0.5 <0.5 <0.000096 <0.0021 m- & p-xylene <1 <1 <1 <0.00019 <0.0042 o-xylene <0.5 <0.5 <0.5 <0.000096 <0.0021 Styrene <0.5 <0.5 <0.5 <0.000096 <0.0021 Cyclohexanone <0.5 <0.5 <0.5 <0.000096 <0.0021 Isopropylbenzene <0.5 <0.5 <0.5 <0.000096 <0.0021 2-chlorotoluene <0.5 <0.5 <0.5 <0.000096 <0.0021 4-chlorotoluene <0.5 <0.5 <0.5 <0.000096 <0.0021 1,3,5- <0.5 <0.5 <0.5 <0.000096 <0.0021 trimethylbenzene n-decane <0.5 <0.5 <0.5 <0.000096 <0.0021 1,2,4- <0.5 <0.5 <0.5 <0.000096 <0.0021 trimethylbenzene 1,3-dichlorobenzene <0.5 <0.5 <0.5 <0.000096 <0.0021 1,4-dichlorobenzene <0.5 <0.5 <0.5 <0.000096 <0.0021 1,2-dichlorobenzne <0.5 <0.5 <0.5 <0.000096 <0.0021 n-butylbenzene <0.5 <0.5 <0.5 <0.000096 <0.0021 Hexachlorobutadiene <0.5 <0.5 <0.5 <0.000096 <0.0021 Total <1 <1 <0.00019 <0.0042
Note: Where the blank has returned a less than value, the analysed value has been corrected for half of that blank value. ie a blank value of <0.5 has had 0.25 subtracted from the analysed value.
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Table 10 Stack 1 Speciated Polyaromatic Hydrocarbons (PAH) Results, 11 January 2012 Emission Sample Result Mass Emission Rate Concentration (ng) (Pg) (mg) (Pg/m3) (mg/m3) (Pg/s) (mg/s) Naphthalene 3700 3.7 0.0037 3.5 0.0035 80 0.08 2 - Methylnapthalene 470 0.47 0.00047 0.45 0.00045 10 0.01 Acenaphthylene 64 0.064 0.000064 0.061 0.000061 1.4 0.0014 Acenaphthene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Fluorene 44 0.044 0.000044 0.042 0.000042 0.95 0.00095 Phenanthrene 520 0.52 0.00052 0.5 0.0005 11 0.011 Anthracene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Fluoranthene 170 0.17 0.00017 0.16 0.00016 3.7 0.0037 Pyrene 160 0.16 0.00016 0.15 0.00015 3.4 0.0034 Benz(a)anthracene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Chrysene 28 0.028 0.000028 0.027 0.000027 0.6 0.0006 Benzo(b)fluoranthene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Benzo(k)fluoranthene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Benzo(e)pyrene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Benzo(a)pyrene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Perylene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Indeno(123:cd)pyrene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Dibenzo(ah)anthracene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Benzo(ghi)perylene <20 <0.02 <0.00002 0.019 <0.000019 <0.43 <0.00043 Sum of reported PAH's 5200 5.2 0.0052 5.1 0.0049 110 0.11
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Table 11 Stack 1 Speciated Hazardous Substances (Metals) Results, 11 January 2012
Total Total Total Total Total Total Mass Particulate Gaseous Gaseous Oxidisable Sample Particulate Oxidisable Total (mg) Total (mg/m3) Emission Metals Metals Metals Mercury Metals (mg) Mercury (mg) Rate (mg/s) (mg/m3) (mg) (mg/m3) (mg/m3) Antimony 0.003 0.0026 <0.004 <0.0034 - - 0.003 0.0026 0.057
Arsenic 0.001 0.00085 <0.003 <0.0026 - - 0.001 0.00085 0.019
Beryllium 0.00003 0.000026 <0.00004 <0.000034 - - 0.00003 0.000026 0.00057
Cadmium 0.00082 0.0007 0.0079 0.0067 - - 0.009 0.0074 0.16
Chromium 0.0023 0.002 <0.0063 <0.0054 - - 0.0023 0.002 0.044
Cobalt <0.0003 <0.00026 <0.0003 <0.00026 - - <0.0015 <0.00026 <0.0057
Copper 0.001 0.00085 <0.0012 <0.001 - - 0.001 0.00085 0.019
Lead 0.0025 0.0021 <0.003 <0.0026 - - 0.0025 0.0021 0.046
Magnesium NA NA NA NA - - NA NA NA
Manganese 0.008 0.0068 <0.004 <0.0034 - - 0.008 0.0068 0.15
Mercury <0.00005 <0.000043 <0.00005 <0.000043 <0.00025 <0.00021 <0.00005 <0.000043 <0.00094
Nickel 0.0017 0.0015 <0.0008 <0.00068 - - 0.0017 0.0015 0.033
Selenium <0.004 <0.0034 <0.004 <0.0034 - - <0.02 <0.0034 <0.075
Thallium <0.008 <0.0068 <0.008 <0.0068 - - <0.04 <0.0068 <0.15
Tin 0.002 0.0017 <0.002 <0.0017 - - 0.002 0.0017 0.037
Vanadium <0.0004 <0.00034 <0.0004 <0.00034 - - <0.02 <0.00034 <0.0075
Zinc NA NA NA NA - - NA NA NA Total Hazardous 0.019 0.017 0.0079 0.0067 <0.00025 <0.00021 0.03 0.025 0.55 Metals* * Total does not include Magnesium and Zinc as they are classed non-hazardous
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7.0 References NSW DECC “Section 55 protection of the Environment Operations Act 1997, Environmental Protection Licence 6423”. NSW State Government “Protection of the Environment Operations (Clean Air) Regulation 2002, Schedule 3 Standards of concentration for scheduled premises: general activities and plant”. NSW DECC, 2007, Approved methods for the sampling and analysis of air pollutants in New South Wales, January 2007
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Appendix D
Concentration Contours
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Dross Emissions Applied Criteria: Isolated (cumulative criterion - background) = 1.88 Figure F1 Isolated Hydrogen Fluoride 24 hour Average SPL Emissions Applied Cumulative = 2.90 Site Boundary Weston Aluminium Pty Ltd 0 200m Units: ug/m3 10 April 2012 AP www.aecom.com
Dross Emissions Applied Criteria: Isolated (cumulative criterion - background) = 0.32 Figure F2 Isolated Hydrogen Fluoride 90 Day Average SPL Emissions Applied Cumulative = 0.50 Site Boundary Weston Aluminium Pty Ltd 0 200m Units: ug/m3 10 April 2012 AP www.aecom.com
Dross Emissions Applied Criteria: Cumulative = 50 Figure F3 Isolated PM 10 24 Hour Average SPL Emissions Applied Site Boundary Weston Aluminium Pty Ltd 0 200m Units: ug/m3 AECOM Environmental Assessment Air Quality Impact Assessment
Appendix E
Change Log
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Appendix E Change Log
Issue AQIA Section
Include composition data for SPL Provided in Table 1
Include emissions test data from both dross Provided in Appendix C processing and SPL trials
Revise report and correct inconsistencies Throughout report, as described below.
Assess ‘worst case’ emissions Further justification provided; refer to Section 6.3.2
Emissions data is inconsistent with stack Refer to Table 6, which outlines data sources, and testing data Appendix C
Identify process conditions at the time of Provided in Section 6.3.2 emissions testing
Inconsistencies – higher results with lower Transcription error of results; please refer to emissions and stack parameters corrected Table 8
Inconsistent assessment criteria Corrected in Table 2; Table 8; Table 9; Table 10
VOC assessment methodology unclear Additional details added to Section 6.3.3.
Methodology revised; refer to Section 6.3.3 and Metal assessment methodology unclear Section 7.0.
Metals exceedence not explained or No longer relevant; no exceedences of metal criteria discussed predicted
Interpretation of results inconsistent Results section revised (Section 7.0)
Discussion of additional exceedences for Further assessment provided in Section 7.0; no PM10 required additional exceedences predicted
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Appendix D
Preliminary Hazard Analysis
10 May 2012 AECOM Environmental Assessment Spent Potlining Processing D-1
Appendix D Preliminary Hazard Analysis
10 May 2012
Weston Alumninium Spent Pot Lining Weston Aluminium Pty Limited 20 April 2012
Processing of Spent Potlining - Weston Aluminium Pty Limited
Preliminary Hazard Analysis
AECOM Weston Alumninium Spent Pot Lining Processing of Spent Potlining - Weston Aluminium Pty Limited
Processing of Spent Potlining - Weston Aluminium Pty Limited Preliminary Hazard Analysis
Prepared for Weston Aluminium Pty Limited
Prepared by
AECOM Australia Pty Ltd Level 21, 420 George Street, Sydney NSW 2000, PO Box Q410, QVB Post Office NSW 1230, Australia T +61 2 8934 0000 F +61 2 8934 0001 www.aecom.com ABN 20 093 846 925
20 April 2012
60250493
AECOM in Australia and New Zealand is certified to the latest version of ISO9001 and ISO14001.
© AECOM Australia Pty Ltd (AECOM). All rights reserved.
AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and AECOM’s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety.
20 April 2012
AECOM Weston Alumninium Spent Pot Lining i Processing of Spent Potlining - Weston Aluminium Pty Limited
Table of Contents Abbreviations ii Executive Summary iii 1.0 Introduction 1 1.1 Background 1 1.2 Objectives 1 1.3 Scope of Work 1 2.0 Methodology 2 2.1 General Approach 2 2.2 Detailed Approach 3 2.2.1 Hazard Analysis 3 2.2.2 Consequence Analysis 3 2.2.3 Frequency Analysis 3 2.2.4 Risk Assessment 3 3.0 Brief Description Of The Proposed Project 4 3.1 Surrounding Land Uses 4 3.2 General Site Operations Description 5 3.3 Proposed SPL Processing Description 8 3.4 Proposed and Existing Safeguards Associated with the Process 8 4.0 Hazard Analysis 10 4.1 Hazardous Properties of Materials 10 4.1.1 Spent Potline Materials 10 4.1.2 Treated Product Material 11 4.2 Hazardous Incident 11 4.2.1 Dust Generated During Delivery 11 4.2.2 Hole in the Equipment or Dust Extraction Ductwork 11 4.2.3 Bag-house Failure 11 4.2.4 Minor Holes in the Aldex Building Roof 12 4.2.5 Major Storm Damage to the Aldex Building 12 4.2.6 Furnace Firing Failure 12 5.0 Consequence Analysis 13 5.1 Incidents Carried Forward for Further Analysis 13 5.2 Water Ingress to the Building, Water/SPL Mix & Hydrogen Generation 13 5.3 Water Ingress to the Building, Water/SPL Mix & Ammonia/Methane/ Acetylene Generation 14 5.4 Water Ingress to the Building, Water/SPL Mix & Dissolving of Cyanide 15 5.5 Summary of Incident Consequence Impacts 16 6.0 References 17 Appendix A Hazard Identification Table A Appendix B SPL – Water Mix Analysis B List of Tables Table 4.1 Summary of Gas Release Quantities from 1kgt of Water Mixing with SPL Table 4.2 Summary of Gas release Quantities from 1kg of Water Mixing with SPL Incorporating Heat Loss and Fractions of Water Component Mix Table 4.3 Summary of Levels of Water Requirements to Generate Hazardous Quantities of Flammable & Toxic Gases List of Figures
Figure 2.1 The Multi Level Risk Assessment Approach Figure 3.1 Weston Aluminium Dross & SPL Processing Facility – Regional Location Figure 3.2 Weston Aluminium Dross & SPL Processing Facility – Local Location Figure 3.3 Weston Aluminium Site Layout Figure 3.4 Aldex Building Layout Showing the SPL Storage Bays
20 April 2012 AECOM Weston Alumninium Spent Pot Lining ii Processing of Spent Potlining - Weston Aluminium Pty Limited
Abbreviations
Abbreviation Description
ADG Australian Dangerous Goods Code DG Dan gerous Goods DPI Department of Planning and Infrastructure EA Environmental Assessment g/m3 Grams per cubic metre g/s Grams per second HIPAP Hazardous Industry Planning Advisory Paper kg/hr kilogr ams per hour kg/m3 kilograms per cubic metre L Litres L/hr Litres per hour PHA Preliminary Hazard Analysis QRA Quantitative Risk Analysis SEPP State Environmental Planning Policy SPL Spent Potlining
20 April 2012 AECOM Weston Alumninium Spent Pot Lining iii Processing of Spent Potlining - Weston Aluminium Pty Limited
Executive Summary
Introduction, Objectives & Scope
In 1998, Weston Aluminium Pty. Limited (Weston) commenced operations at its Dross Processing Plant at Weston, Kurri Kurri, NSW. Dross, which is a by-product of aluminium smelting, contains a significant amount of aluminium that can be recovered in a re-heat and extraction process. Since the initial approval, a number of expansion projects have also been approved and Weston is now seeking approval for the processing of Spent Potlining another waste product formed as a result of the manufacture of aluminium. As part of the approval process, Weston is required to submit an Environmental Assessment (EA), incorporating a Preliminary Hazard Analysis (PHA). Weston has engaged AECOM to conduct the PHA study with the objective of preparing the study in accordance with Hazardous Industry Planning Advisory Paper No.6 (Ref.3) in support of the Development Application (DA). The scope of the study is for a PHA of the proposed SPL processing only and does not include the existing dross and scrap and processing operations, which have been assessed as part of previous PHSA studies. However, the study does include cumulative impacts of hazards and risks.
Methodology
The methodology selected for the study was a Level 2 assessment using the approach recommended in the Multi Level Risk Assessment document, published by the DPI.
Brief Description of the Proposed Project
The Weston facility is located on about 22 hectares of land on the northern side of Mitchell Avenue, Kurri Kurri, NSW. The site is located in an area zoned 4(a) industrial. There are currently only three major industrial facilities in the vicinity of the site, two are steel fabrication industries and are over 200m from the plant, and Hydro Aluminium, which is located over 2km to the north of the site. The closest residential land to the site is located about 600m to the south east. The closest residence is located on land zoned rural, about 270m to the north (in the Hydro Aluminium Smelter buffer zone). The closest public place (the footpath passing the property) is at Mitchell Avenue, about 150m from the plant building. Existing Dross Processing Operation – dross is currently delivered to site by truck from smelters both local and interstate. The dross is unloaded into a dedicated building (Aldex Building) and stored in 8 dedicated bays within the building. Dross is recovered using a front end loader and processed using a crushing and screening plant. The crushed and screened dross is then fed by conveyor to the main building where it is loaded to a furnace and heated to extract the aluminium metal. Metal is tapped from the furnace and cast, whilst ash residues generated in the furnace are processed within a cooling circuit. The cast material is then sold to markets. The remaining ash material, known as Aldex, is bagged or briquetted and sold to the steel and building materials industry. Proposed SPL Processing Operation – it is proposed to deliver SPL to site using the same process and licensed Dangerous Goods transport contractors as for the dross deliveries. The SPL will be delivered to the storage bays where it will be held until processing is performed. The SPL will be crushed and screened and fed to the main processing building using the existing covered conveyor and/or transferred to the main processing building via bins. The SPL will be heated in dedicated furnaces to thermally oxidise and destroy the cyanide in the material. Once the cyanide has been destroyed, the processed SPL will be removed from the furnace and cooled in a dedicated rotary cooler (i.e. jacketed cooling). A water spray cooling system will also be installed within the rotary cooler to assist in the final cooling the product. The material will then be bagged and transported to markets.
20 April 2012 AECOM Weston Alumninium Spent Pot Lining iv Processing of Spent Potlining - Weston Aluminium Pty Limited
Safeguards – the following safeguards are installed at the Weston Aluminium site:
- Dust control – dust extraction on all equipment and storage bays, baghouse units and dust control curtains in front of the storage bays; - Bag-House Units – fitted with high differential pressure alarms, spare bags sets, pulse jet cleaning of bags, bag breakthrough detection (real-time, continuous particulate monitoring devices) and alarms; - Furnace – real-time, continuous temperature monitoring and high thermal mass in the furnace; and - Spill Retention – fully sealed and bunded buildings for the storage of SPL (no releases outside the building in the event of a spill).
Hazard Analysis Properties of SPL
SPL is predominantly carbon and refractory materials which are formed to line the base of the aluminium manufacturing pot at the smelter. In contact with water SPL may produce hydrogen and in contact with acid, hydrogen sulphides or hydrogen cyanides may be formed. However, there are no acids stored at the Weston site and no potential for this incident to occur. The dust generated as part of handling SPL could result in irritation to eyes and mucous membranes, mainly through mechanical impacts on these areas rather than chemical. The fluorides in the SPL result in chronic rather than acute impacts and the relatively small quantity of cyanide (<0.7%) may result in environmental impacts if released beyond the immediate containment area. Properties of Product
The treated product is not classified as Dangerous Goods (DGs), as the majority of constituent components in the material are non-DG and the single component classified as a DG (Sodium Fluoride) is in low quantity (<8% on average; below DG Classification threshold). However, the product dust may cause irritation to eyes and mucous membranes, mainly by mechanical action rather than the chemical properties of the constituent materials. Hazardous Incidents
The following hazardous incidents were identified as part of the hazard analysis study: - Dust Generated During Delivery – dumping of SPL generates dust, dust extraction equipment in the storage bays maintains dust control. No further analysis considered necessary. - Hole in the Equipment or Dust Extraction Ducts – m inor dust release into the building, building dust control systems prevent release outside the building. No further analysis considered necessary. - Bag-House F ailure – potential b ag fa ilure & rele ase thro ugh th e b aghouse e xhaust. B ag fa ilure d etection and alarm, spare on-line bag sets available. No further analysis considered necessary. - Minor Ho les i n Buildi ng R oof – minor ingr ess of water, in significant h ydrogen ge neration, no spil l/release beyond the stockpile. No further analysis considered necessary. - Major Storm Damage to the Aldex/Main Pr ocessing Bu ilding – potential large i ngress of water, pote ntial significant h ydrogen ge neration, ign ition a nd fire/e xplosion. T his incid ent is carrie d for ward for further analysis. - Major Storm Damage to the Aldex/Main Pr ocessing Bu ilding – potential large i ngress of water, pote ntial generation of ammonia/acetylene/methane, toxic gas impacts or ign ition and fire/explosion. This incident is carried forward for further analysis. - Major Storm Damage to the Aldex Building – water ru n-off from the st ockpile c ontaminated with c yanide, release beyond the s ite building and impact to the environment. This incident is carried forward for fur ther analysis. - Furnace Firing Failure – failure to destroy the cyanide in the SPL, cyanide release via the furnace stack resulting in impact to environment. However, it is noted that dust generation in the furnace is low and exhausted gases from the furnace must pass through the lime scrubber and baghouse, further reducing the potential for release. Further, processing procedures and quality control systems are in place to ensure temperature and residence times required for cyanide destruction. In addition, the furnace has real-time temperature monitoring and firing failure detection systems. High thermal load in the furnace prevents low temperature until days after the firing failure. Sufficient response time. No further analysis considered necessary.
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Hazard and Consequence Analysis
The hazard analysis identified three scenarios that had the potential to develop incident consequences that could adversely impact offsite. These incidents were: - storm damage to the storage and processing buildings resulting in roof damage, water ingress and hydrogen generation. Ignition of hydrogen accumulation could result in explosion, however, the analysis showed that there is insufficient hydrogen generated and as the scenario included the building roof being blown off, there is no entrapment of hydrogen in the building. - Storm damage to the Aldex building resulting in roof damage, water ingress and ammonia/acetylene/ methane development. The analysis showed that the quantity of water ingress over 1 hour did not result in sufficient ammonia generation to reach LC50 concentration levels and that the weather conditions would result in rapid dispersion of the gas failing to reach harmful levels. The quantities of water required to generate sufficient acetylene/methane, so that the concentration exceeded LEL, were considerably higher than would enter the building during the postulated storm event. It is noted that the MSDS for SPL does not list aluminium nitride or aluminium carbide as a constituent of SPL, however, some contamination of the SPL may occur during the aluminium smelting operation. The selection of 1% contamination (the level used in this study) is considered very conservative as in reality only trace elements would be present in the total SPL material. - storm damage to the process and storage buildings resulting in roof damage, water ingress and dissolving of cyanide into the storm-water, resulting in the potential for contaminated water to escape offsite. The analysis identified that the Aldex building is bunded with spill containment capacity sufficient to hold the estimated storm-water ingress without release off-site. As the assessed hazard and risk impacts are considered to be negligible, the cumulative impact as a result of existing risks does not change the existing risk profile. Based on the analysis conducted in this study, the hazards associated with the proposed storage, handling and processing of SPL at the Weston aluminium facility does not result in a change to the existing risk profile, hence, the risk criteria published by the NSW DPI in HIPAP No.4 (Ref.4) is not exceeded and the facility remains classified as potentially hazardous and not hazardous and would therefore be permitted to continue operations processing dross and SPL in the existing land zoning.
20 April 2012 AECOM Weston Alumninium Spent Pot Lining 1 Processing of Spent Potlining - Weston Aluminium Pty Limited
1.0 Introduction
1.1 Background
In 1998, Weston Aluminium Pty Limited. (Weston) commenced operations at its Dross Processing Plant at, Kurri Kurri, NSW. Dross is a by-product of aluminium smelting which contains a significant amount of aluminium that can be recovered in a re-heat and extraction process. In 2000, permission was granted for Weston to expand the processing facility to include a larger dross storage and the storage of Aldex, a by-product of the dross process. In 2007 additional processing equipment and storage facilities were approved for the site as part of a dross processing expansion project. Since the expansion of the dross processing facilities, Weston has been researching the potential to process Spent Pot Lining (SPL) materials at its Kurri Kurri site. A number of SPL trials were conducted both overseas (New Zealand) and domestically at the University of Newcastle and at the Kurri Kurri site, all showing positive results. Based on the successful trial results, Weston proposes to process SPL at the Kurri Kurri facility on a commercial scale. As part of the Development Application for the process, Weston is required to conduct an Environmental Assessment (EA). AECOM has been commissioned by Weston to assist with the preparation of a Preliminary Hazard Analysis (PHA) report, required as part of the EA process. This document reports on the results of the PHA study for the proposed SPL storage and processing facilities at the Weston Aluminium site, Kurri Kurri, NSW.
1.2 Objectives
The objectives of the study have been based on the Department of Planning and Infrastructure (DPI) requirements (Ref.1). These requirements state that the proposed facility must be assessed against the requirements of State Environmental Planning Policy No.33 – Hazardous and Offensive Development (SEPP 33). A review of the application guidelines associated with this SEPP (Ref.2) indicates that the site may be hazardous and/or offensive, hence, it is necessary to prepare a Preliminary Hazard Analysis (PHA) for the proposed project. The objectives are, therefore: - to conduct a preliminary hazard analysis of the proposed SPL storage and processing facilities, at the Weston site, in accordance with the NSW DPI Hazardous Industry Planning Advisory Paper (HIPAP) No.6, “Guidelines for Hazard Analysis” (Ref.3); and - prepare a study report on the findings and recommendations for submission in support of the development application.
1.3 Scope of Work
The scope of work is for a PHA study of the proposed SPL storage and processing facilities. The scope does not include the assessment of any existing facilities that have already been reviewed as part of previous PHA studies, however, the assessment of cumulative risks at the site is included within the scope.
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2.0 Methodology
2.1 General Approach
The NSW DPI Multi Level Risk Assessment (Ref.4) approach was used for this study. The approach considered the development in context of its location and its technical and safety management control. The Multi Level Risk Assessment Guidelines are intended to assist industry, consultants and the consent authorities to carry out and evaluate risk assessments at an appropriate level for the facility being studied. The Multi Level Risk Assessment approach is summarised in Figure 2.1. There are three levels of assessment, depending on the outcome of preliminary screening. These are: - Level 1 – Qualitative Analysis, primarily based on the hazard identification techniques and qualitative risk assessment of consequences, frequency and risk; - Level 2 – Partially Quantitative Analysis, using hazard identification and the focused quantification of key potential offsite risks; and - Level 3 – Quantitative Risk Analysis (QRA), based on the full detailed quantification of risks, consistent with HIPAP No.6 – Guidelines for Hazard Analysis (Ref.3). Figure 2.1: The Multi-Level Risk Assessment Approach
Preliminary Screening (Qualitative Assessment)
Risk Classification and Prioritisation
Not potentially Hazardous – No Further Analysis Qualitative Analysis Partial Quantitative Quantitative Risk (Level 1) Analysis (Level 2) Analysis (Level 3)
The document “Applying SEPP 33” (Ref.2) guideline may also be used to assist in the selection of the appropriate level of assessment. This guideline states the following: “It is considered that a qualitative PHA may be sufficient in the following circumstances: - where materials are relatively non-hazardous (for example corrosive substances and some classes of flammables); - where the quantity of materials used are relatively small; - where the technical and management safeguards are self-evident and readily implemented; and - where the surrounding land uses are relatively non-sensitive. In these cases, it may be appropriate for a PHA to be relatively simple. Such a PHA should: - identify the types and quantities of all dangerous goods to be stored and used; - describe the storage/processing activities that will involve these materials; - identify accident scenarios and hazardous incidents that could occur (in some cases, it would also be appropriate to include consequence distances for hazardous events); - consider surrounding land uses (identify any nearby uses of particular sensitivity); and - identify safeguards that can be adopted (including technical, operational and organisational), and assess their adequacy (having regards to the above matters).
20 April 2012 AECOM Weston Alumninium Spent Pot Lining 3 Processing of Spent Potlining - Weston Aluminium Pty Limited
A sound qualitative PHA which addresses the above matters could, for some proposals, provide the consent authority with sufficient information to form a judgement about the level of risk involved in a particular proposal”. The proposed SPL storage and handling facilities will be identical to the existing dross storage and handling facilities assessed for previous studies. The hazard and risk assessments previously conducted for the site did not identify any incidents that could result in an offsite impact above the published risk criteria (Ref.4). In addition, the Weston Aluminium site is located in an industrial area with sensitive land users well clear of the site, the closest residential area being over 600m to the south east. Detailed technical and management safeguards are proven at the Weston Aluminium site and, hence, under these circumstances, a qualitative assessment may be considered for the project. However, the properties of SPL require review to determine hazards associated with ingress of water to the storage area. In addition, failure to control the furnace process (i.e. temperature) could result in the release of cyanide in flue gas from the furnace. Hence, methods of furnace control also require review. Based on the previous assessments, and the storage and handling conditions proposed at the site, the low potential for hazardous gas generation and the separation from sensitive receptors, a level 2 analysis has been selected as the most appropriate level of assessment for the site. 2.2 Detailed Approach
The detailed study approach follows that recommended in HIPAP No.6, “Hazard Analysis Guidelines”(Ref.3). The approach is summarised below. 2.2.1 Hazard Analysis
A detailed hazard identification was conducted for the SPL storage and processing facilities described in Section 3. Where an incident was identified to have potential off site impact, it was included in the recorded hazard identification table (Appendix A). The hazard identification table lists incident type, causes, consequences and safeguards. This was performed using the format suggested in HIPAP No.6 (Ref.3). Each postulated hazardous incident was assessed qualitatively in light of proposed safeguards (technical and management controls). Where a potential offsite impact was identified, the incident was carried into the main report for further analysis. Where the qualitative review in the main report determined that the safeguards were adequate to control the hazard, or that the consequence would obviously have no offsite impact, no further analysis was performed. The hazard analysis and safety systems review was conducted in consultation with the Weston operations and management team. 2.2.2 Consequence Analysis
For those incidents qualitatively identified in the hazard analysis to have a potential offsite impact, a detailed consequence analysis was conducted. The analysis modelled the various postulated hazardous incidents and determined impact distances from the incident source. The results were compared to the consequence criteria listed in HIPAP No.4 (Ref.5). Where an incident was identified to result in offsite effect, it was carried forward for frequency analysis. Where an incident was identified to have an offsite effect, and a simple solution was evident (i.e. move the proposed equipment further away from the site boundary), the solution was recommended and no further analysis was performed. 2.2.3 Frequency Analysis
In the event a simple solution for managing consequence impacts was not evident, each incident identified to have potential offsite impact would be subjected to a frequency analysis. The analysis would consider the initiating event and probability of failure of the safeguards (both hardware and software). The results of the frequency analysis, would be carried forward to the risk assessment for combining with the consequence analysis results. 2.2.4 Risk Assessment
As the selected approach for this analysis was a Level 2 assessment (Ref.2), where incidents were identified to impact offsite and where a consequence and frequency analysis was conducted, the consequence and frequency analysis for each incident would be combined and compared to the risk criteria published in HIPAP No.4 (Ref.4). Where the criteria were exceeded, a review of the major risk contributors would be performed. Recommendations would then be made regarding risk reduction measures.
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3.0 Brief Description Of The Proposed Project
3.1 Surrounding Land Uses
The Weston facility is located on about 22 hectares of land on the northern side of Mitchell Avenue, Kurri Kurri, NSW. The regional and site locations are shown at Figure 3.1 and 3.2. The current site layout is shown in Figure 3.3. The site is located in an area zoned 4(a) industrial. There are currently only three major industrial facilities in the vicinity of the dross processing plant site, two are steel fabrication industries and are over 200m from the plant, and Hydro Aluminium, which is located over 2km to the north of the site. The closest residential land to the site is located about 600m to the south east. The closest residence is located on land zoned rural, about 270m to the north (in the Hydro Aluminium Smelter buffer zone). The closest public place (the footpath passing the property) is at Mitchell Avenue, about 150m from the plant building. Figure 3.1: Weston Aluminium Dross & SPL Processing Facility – Regional Location
Weston Aluminium
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Figure 3.2: Weston Aluminium Dross/SPL Processing Facility – Local Location
Weston Aluminium
3.2 General Site Operations Description
The existing site layout is shown in Figure 3.3, along with the approved developments (not yet constructed) and the proposed development. Bulk dross is currently delivered by road to the Kurri Kurri site and is stored in the southern portion of the existing main building or in the Aldex building (dross storage). Trucks enter the site from Mitchell Avenue, via a driveway and onsite road. The trucks position adjacent to the dross storage area (main building), reverse into the building and dump the dross into one of six storage bays. Trucks delivering dross to the Aldex building drive around the rear of the main building and access the Aldex building from the north. Trucks reverse into the Aldex building and dump the dross into one of eight dedicated storage bays within the building. Dross from the storage bays in the main building is recovered by front end loader, and scoop-mounted forklift, for delivery directly to the rotary furnace. The agitation in the rotary furnace coupled with the high temperatures liberates aluminium metal, which forms in a pool within the furnace, which is tipped into sows for solidification. Dross recovered from the Aldex building storage bays is pre-processed in the crushing plant and delivered to the main building via conveyor or bin. This material is stored in the dross storage in the main building prior to feed to the furnaces for processing. The low metal ash produced from the rotary furnace is transferred to the dross cooling circuit. During this process fines are extracted for collection in a baghouse. The existing storage area, in the main storage building, is ventilated via Baghouse No. 2. Baghouse No. 3 may service the proposed additional cooler. The existing cooler is serviced by Baghouse No. 4. Emissions from the rotary furnaces are vented to Baghouse No. 1, which is serviced by a slurried lime injection wet/dry scrubbing system. This lime fed baghouse is used to remove gaseous fluorides liberated during the heating process in the Rotary Furnaces. Weston has approval to extend its existing main building to the south to increase storage area and to facilitate processing of the contained dross (see Figure 3.3).
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Figure 3.3: Weston Aluminium – Site Layout
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Figure 3.4: Aldex Building Layout Showing the SPL Storage Bays
Curtain across the front of the storage bays
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3.3 Proposed SPL Processing Description
SPL is similar in physical nature to dross, in that it is a “lump” material transported by truck to the Weston site. It is proposed to utilise the existing dross storage areas in the Aldex building at the Weston facility. SPL will be sourced from aluminium smelters and transported to the site by truck. Trucks will enter the site from Mitchell Avenue and drive around the rear of the main processing building to the Aldex building, via the internal sealed road. The trucks will then reverse through open sliding doors in the existing Aldex buildings and deliver the dross into one of the existing eight bays. Figure 3.4 shows the Aldex building layout. Each of the existing storage bays is fitted with an extraction fan duct that collects any dust generated during the delivery process and delivers the extracted dust stream to a baghouse (Bag-House 7), whereby the dust is extracted and “clean”, treated air is discharged from the baghouse. The existing baghouse is fitted with a real- time, continuous particulate monitoring system, which detects potential bag failure through tears or holes. The baghouse is also fitted with high differential pressure detection which activates a bag change-over and cleaning process. In the event a high pressure is detected, the clogged bags are cleaned by pulse jet to shake off the accumulated dust. Once the cleaning cycle is complete, the bags are placed on stand-by until required. The treatment of the SPL commences with recovery from one of the eight existing storage bays and delivery to the pre-processing facility by front end loader. The SPL will be crushed to a size fraction suitable for furnace processing. Crushed material will be transferred by covered conveyor or bins to storage bays within the main plant building. Effective air pollution control is fundamental to the operation of this SPL pre-processing facility. An existing bag- house (Bag-house 7) dust collector is used to collect emissions from the pre-processing plant. Baghouse collection off-takes are located at the process transfer points and crushers. Once the SPL material has been pre-processed and transferred to the main building, using the existing covered conveyor, it is stored in the existing storage bays within the main building. Baghouse 2 services any residual dust generated in the main plant building storage bays. Each of the bays are also isolated by curtains, which enhances the collection efficiency of dust from the localised area. The current operation achieves up to 20 air changes per hour within the storage bays. Experience within the existing dross receival areas has shown that dust emissions from dross receival are minimal. It is expected that similar dust control will be achieved with the SPL, as this material is almost identical in nature to the dross. The SPL material would then be collected from the storage area using an existing dedicated furnace loading machine. This machine is, in effect, a forklift truck with a dedicated furnace loading bucket. The SPL material will be collected in the bucket and loaded to the existing rotary furnace along with other feed-stocks such as lime, cullet (crushed glass) or iron oxide, as required. The existing furnaces will attain temperatures of between 600oC and 750oC to ensure any cyanide within the SPL is effectively destroyed during the heating operation. On completion of the heating process, the treated SPL will be tapped from the furnace and cooled in a new rotary cooler. A single pass of the SPL is proposed, with external water sprays applied within the cooler to provide final evaporative cooling of the material. Once cooled, the product, manufactured as a result of the treatment, will be loaded to 1 tonne bulk bags and transported to customers.
3.4 Proposed and Existing Safeguards Associated with the Process
The following process safeguards exist and/or are proposed: - Dust Control – storage and handling areas within the Aldex and Process buildings are fitted with dust extraction units that deliver extracted dust to bag-house units (existing). - Dust Control - curtains installed across the front of the dross storage bays to minimise dust escape into the buildings (existing). - Dust Control - Truck access doors across the entrance to the building can be closed to prevent dust escape whilst tipping SPL (existing). - Building Pressure Control – all buildings are maintained at slightly negative pressure to prevent dust escape from the buildings (existing).
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- Building Dust Control – all buildings are fitted with dust extraction systems that report to bag-house units to extract any dust collected within the building internal atmosphere (existing). - Equipment Dust Control – all equipment (e.g. crushers and material transfer stations on conveyors) are fitted with dust extraction that reports to bag-house units (existing). - Bag-houses – all bag-houses are fitted with real-time, continuous particulate monitoring systems (existing). - Bag-houses – all bag-houses are fitted with high differential pressure detection to activate bag switch-over and clogged bag cleaning processes (existing). - Furnace Operations – furnaces are monitored for real-time, continuous temperature monitoring and control (existing). - Furnace Thermal Load – the furnace contains a high thermal load (also aided by the refractory nature of the feedstock material) and loss of furnace heating would not result in an immediate drop in furnace temperature. The furnace would remain at elevated temperatures for an extended period (many hours) without further heating (existing). - Treated SPL Cooler – cooler casing is steel, which eliminates the potential for failure of the casing from overheating (note that steel will not fail at 600oC) (proposed). - Water Ingress Control - Fully sealed and bunded buildings to prevent water ingress and impact of water on SPL (existing). It is noted that the dust and furnace control systems are currently operating at the plant and are used for dross storage and handling dust control. These systems have proven successful in preventing the release of dust and untreated gases from the operational areas of the plant.
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4.0 Hazard Analysis A hazard identification table was developed as part of the study, this is included at Appendix A. The analysis in this section is centred on the storage, handling and processing of SPL and the potential hazards posed by this material. Where a hazard is identified to have a potential offsite impact, in excess of the published risk criteria in HIPAP No.4 (Ref.4), the incident is carried forward for consequence analysis. Where no offsite impact is identified (i.e. the safeguards and controls are considered effective), no further analysis is conducted.
4.1 Hazardous Properties of Materials 4.1.1 Spent Potline Materials
Aluminium metal is formed by the electrolytic reduction of alumina (aluminium oxide, Al2O3). The process involves passing an electric current through molten alumina. The reduction (loss of oxygen) occurs at the cathode or negative electrode, which is located in the base of the reaction container or “pot”. This loss of oxygen converts the molten alumina into aluminium, which forms a pool in the bottom of the reaction container. Anodes, or positive electrodes, create oxidation, which occurs at the top of the reaction container. Cathodes and anodes are usually made from carbon, which is consumed during the aluminium production process. Fluxes are added to the process to reduce melting temperatures and to increase electrolytic properties. The main process flux is cryolite, which comprises sodium fluoride and aluminium fluoride. The electrolytic process forms many by-products that are removed from the process as waste. During the production of aluminium within the “pot”, the cathode, which is predominantly carbon and refractory material, becomes impregnated with other materials including aluminium, fluorides, sodium compounds and minor quantity of cyanide (<0.7%). The SPL MSDS does not list carbides and nitrides as being present within the material, however, trace concentrations of carbides and nitrides may be present within the SPL. Hence, the potential for the formation of ammonia and methane/acetylene when mixing with water is limited. Notwithstanding this, the mixing of water with SPL could result in the formation of hydrogen gas and minor quantities of ammonia/methane. SPL contact with large quantities of water could result in the dissolving of cyanide into the water. The water could then contain harmful quantities of cyanide, however, it is noted that the SPL contains a maximum of 0.7% cyanide, hence, the water contamination with cyanide would be minor. Should a potential release occur beyond the confines of the storage, the potentially contaminated stormwater would be captured by the existing first flush stormwater management system, and hence, the potential for impact to the environment mitigated. Contact of SPL with acids may result in the formation of hydrogen sulphide or hydrogen cyanide. These are dense toxic gases which would accumulate within the area where the acid contact occurs and could result in injury and fatality to people who come into contact with the gases. However, there are no acids stored at the Weston site and therefore there is no potential for this hazard to occur. SPL contains fluorides at concentrations levels that could have adverse chronic effects if exposure to people occurs over an extended period. Fluorides may result in mottling of dental enamel, lung and bone osteo-sclerosis and potential kidney ligament damage. However, as noted, these impacts are chronic and would occur only after extended exposure at the concentration levels within the SPL. Weston has existing dust extraction systems and PPE regimes implemented as part of normal operations, and hence, exposure would be minimal. An occupational hygiene assessment was conducted during the SPL trial at the Weston facility (Ref.8) to determine whether there were any occupational hazards associated with the storage and handling of SPL. The study results concluded that the control of hazardous dusts within the SPL storage and handling areas were well within the Safe Work Australia time weighted average (TWA) exposure levels for fluoride and cyanide. SPL dust particles are irregular in nature with sharp corners that can cause irritation to eyes and mucous membranes, mainly through mechanical action. Whilst personnel on site are protected from dust impact to eyes by the compulsory wearing of safety glasses, offsite impact may occur if dust escapes beyond the site boundary. Dust escaping offsite could result in impacts to people close to the site boundaries and there could be some corneal burning from the materials within the SPL itself.
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4.1.2 Treated Product Material
Material produced after the SPL has been processed and treated in the rotary furnace is not classified as a Dangerous Good (DG) as gas evolution is negligible, and the constituents, with the exception of sodium fluoride are not listed in the Australian Dangerous Goods Code or ADG (Ref.6). The quantity of sodium fluoride in the product is minor and varies based on the batch of SPL received from the smelter. The average amount of sodium fluoride in the product would be less than 8% (below DG Threshold), hence, the material would not be classified as a DG as there is insufficient sodium fluoride within the material to result in impacts to people or the environment. The product dust may cause irritation to eyes and mucous membranes, mainly by mechanical action rather than the chemical properties of the constituent materials within the product.
4.2 Hazardous Incident 4.2.1 Dust Generated During Delivery
SPL is delivered to site in trucks and tipped into the storage bays for processing in the plant. A hazard may occur if the delivered SPL generates significant quantities of dust. The dust may escape the building through doors and opening, being released to the environment. This dust may then escape offsite and impact areas adjacent to the site. However, buildings are fitted with large sliding doors that open to allow trucks within the buildings and then may be closed to contain any dust generation. Further, each bay is fitted with curtains that contain any generated dust within the bays and the dust exhaust system then extracts the dust, which is removed within baghouses. Hence, during delivery, as the building doors may be closed, the curtains contain the dust in the bay and the dust extraction system removes the dust and extracts it (baghouse), there is no potential for dust release from the building. The effectiveness of the dust control systems have been demonstrated during current plant operations with dross. There is no dross dust release from the Aldex building during dross delivery. Hence, there would be no SPL dust discharge during SPL delivery. This incident has therefore not been carried forward for further analysis. 4.2.2 Hole in the Equipment or Dust Extraction Ductwork
The pre-processing of SPL in the Aldex building will be performed using screens, conveyors and crushers. The potential for dust generation occurs where the SPL is agitated as part of the process (e.g. screens and crushers). This equipment is covered and any dust generated is contained within the equipment itself. However, in the event of casing wear there is a potential for release of SPL dust from the equipment into the Aldex building. SPL released into the Aldex building will be contained within the building confines as the structure is fitted with doors that may be closed during plant operation and/or SPL deliveries and there will be no release beyond the Aldex building. In the unlikely event of a dust release within the building, the released dust will be managed by the dust extraction system, which comprises dust extraction ducts and intake registers within the building roof area. This will collect the dust and deliver it to the baghouse, where the dust will be extracted prior to the exhaust stream, discharge to the atmosphere. As there will be no dust release from the building in the event of an equipment failure (hole), this incident has not been carried forward for further analysis. 4.2.3 Bag-house Failure
The incidents assessed in Sections 4.2.1 & 4.2.2 assumes that the bag-houses work effectively and the dust is extracted by the bag sets. However, in the event of a failure of a bag (i.e. bag split or hole), the dust would be passed through the failed bag and escape via the stack to the atmosphere. The quantity released through a single bag would be small and there would be minimal impact beyond the immediate release zone. Notwithstanding this, bag-houses are fitted with real-time, continuous particulate monitoring systems so that in the event of a bag failure (split or hole), the elevated particulate is immediately detected. The bag-house contains a number of cells and the cell, containing the failed bag, can be isolated and the bag changed. Based on the low quantity of dust released in the event of a single bag failure, the bag alarm system and the low acute impact of the dust, there is a negligible risk that this incident would impact beyond the site. Hence, this incident has not been carried forward for further analysis.
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4.2.4 Minor Holes in the Aldex Building Roof
Over time, there is a potential that minor holes may occur in the roof of the building. This could lead to water ingress via the holes during rain. As noted in Section 4.1.1, water and SPL contact could result in the development of flammable gas (hydrogen). However, the quantity of gas generated is directly proportional to the quantity of water contacting the SPL. The quantity of water entering the building via small holes would be negligible and water entering via this route would be insufficient to generate significant quantities of gas as a result of water/SPL contact. Further, the building is sealed and the dust extraction system would extract any vapours generated by the small quantity of water/SPL contact, discharging this via the dust removal system stack. The large volumes of air drawn into this system would significantly dilute the gas and the discharged air stream would be well below impact levels. There would be no potential for the lower flammable limit (LEL) to be reached, for hydrogen, from small water ingress incidents. Based on the above analysis, this incident has not been carried forward for further analysis. 4.2.5 Major Storm Damage to the Aldex Building
In the event of a major storm, there is a potential for the Aldex and Process building to be damaged, resulting in roof panels being blown-off, exposing the SPL storage to rain. Water (rain) could then enter the buildings via the damaged roof panel, impacting the SPL, evolving flammable gas (hydrogen). A major storm could deposit a significant quantity of water on the building in an hour, which spread over an open panel area could be a significant water volume. This could result in the release of toxic & flammable gas, which could escape the building via the damaged roof, impacting areas offsite. Hence, this incident has been carried forward for further analysis. In addition, large volumes of water mixing with SPL could result in to formation of a water cyanide mixture, which if released off site could impact the environment surrounding the building and adjacent properties. This incident has therefore been carried forward for further analysis. 4.2.6 Furnace Firing Failure
The SPL is processed within an existing rotary furnace at the site. The SPL contains minor quantities of cyanide (<0.7%), which must be destroyed prior to completion of the treatment process. Weston has conducted a number of trials both in Australia and New Zealand to identify the optimum temperatures for operation of the furnace to ensure all cyanide is destroyed in the heating process. The SPL trials indicated that cyanide was destroyed at temperatures above 450oC and that operation of the furnace above this temperature would ensure no cyanide remained in the product after treatment. To ensure a safety factor is applied to the process, Weston plans to attain temperatures within the furnaces above 600oC, which provides considerably higher operating temperatures, ensuring that all cyanide is destroyed. The furnace contains a high thermal mass and in the event of firing failure (i.e. loss of gas, burner failure, etc.), the furnace will remain above 450oC for more than 2 days, hence, there is a considerable time for response to failure of the firing. It is considered that gas or burner system failure can be rectified well within 2 days by burner repair or temporary burner installation and completion of the SPL heating cycle and emptying of the furnace. The high thermal mass in the furnace, and the furnace firing loss alarms, results in a low to negligible risk of low furnace temperature and therefore a low to negligible risk of cyanide development within the furnace. Based on the results of this assessment, this incident has not been carried forward for further analysis.
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5.0 Consequence Analysis
5.1 Incidents Carried Forward for Further Analysis
Only two incidents were identified to have a potential to impact offsite, these are: - water ingress to the building, water mixing with SPL and the generation of hydrogen gas; and - water ingress to the building, water mixing with SPL and the generation of ammonia/methane/acetylene gas; and - water ingress to the building, water mixing with SPL resulting in the cyanide within the SPL being dissolved into solution. These incidents have been assessed in detail below.
5.2 Water Ingress to the Building, Water/SPL Mix & Hydrogen Generation
The existing dross storage in the Aldex building, where the SPL will be stored, is shown in Figure 3.4. The SPL will be stored in eight (8) storage bays, with a total storage dimension of 42m x 13.5m, which gives a total storage area of 567m2. SPL will also be stored in six (6) storage bays in the main processing building ready for loading to the furnace. The storage area of the loading bays in the main processing building is 330m2, which is considerably smaller than the storage area in the Aldex building (<60%), hence, the Aldex storage area has the potential to generate a higher quantity of gas as there is a greater surface area over which the water could fall. Therefore the Aldex building has been used in this analysis, noting that the generated gas volumes (from SPL/water mix) in the main processing building storage would be less than that in the Aldex building. In the event a storm occurs, there is a potential for the roof to be completely blown off the building, exposing the dross storage to rain. The average rainfall in the wettest month of the year in the Kurri Kurri district is 108.9mm for the full month of February (Ref.7). Assuming, conservatively, that 25% falls within a 12 hour period, the average hourly rainfall entering the building and falling on the SPL pile is: Mass of water = rainfall depth over 1 hour x dross surface area x density of water = (0.25 x 0.1089/12) m x 567m2 x 1000kg/m3 = 1,286 kg or 1.286 tonnes/hour With a significant amount of water falling on the stockpile in a short period, much of the water will run off into the base of the storage bays, with some of the water reacting with the SPL to form hydrogen. Assuming conservatively that 50% of the water reacts and 50% runs away from the storage bays, the mass of water reacting with the SPL is 643kg/hr. As this reaction is exothermic, some of the water will be consumed by heat in the form of steam, with other reactions forming hydrogen and oxygen compounds. Whilst this is difficult to estimate, a conservative assumption would be to assume 50% of the water form hydrogen, with the oxygen atoms forming oxygen compounds. One (1) mole of water (18kg), releases 2 kg of hydrogen, Hence, for a total quantity of water of 322kg, available for hydrogen (H2) generation, the total quantity of hydrogen is:
H2 Generated = 2 x 322/18 = 36kg/hr or 0.01 kg/s (10 g/s) This is an insignificant amount, considering hydrogen is an extremely light gas and would rise rapidly on release. Noting that the roof to the storage would have been blown off in the storm, the rising hydrogen would escape via the open roof, preventing accumulation of gas within the building. In summary, there is an insignificant quantity of gas developed as a result of water ingress to the building and any gas developed would escape via the open roof, eliminating the potential for gas accumulation, ignition and explosion. Hence, the risk of gas release and explosion as a result of water ingress from storm damage is negligible. This incident has therefore not been carried forward for further analysis.
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5.3 Water Ingress to the Building, Water/SPL Mix & Ammonia/Methane/ Acetylene Generation
As noted in Section 4.1.1, mixing of water and SPL could result in the generation of flammable and toxic gases. Appendix B details the calculations for water SPL mix and the generation of toxic and flammable gases. Table 4.1 summarises the calculation for a mix of 1kg of water with SPL. However, it is noted that mixing of water and SPL will never be homogenous and various factors, such as exothermic reactions, will reduce the available water and limit the quantity of gas release, hence, the results shown in Table 4.1 are conservative. Table 4.1: Summary of Gas Release Quantities from 1 kg of Water Mixing with SPL
Material Release Quantity
Ammonia 0.315k g Acetylene 1.4kg Methane 0.44kg
Acetylene and methane are produced from aluminium carbide that may be present within the SPL. It has been assumed (conservatively) that the SPL used in the Weston facility has, on average about 1% aluminium nitride and 0.1% aluminium carbide content (as a result of contaminants impregnating the SPL). When mixed with water, there is a potential for the generation of ammonia (from the nitrides in the SPL) and acetylene/methane (from the carbides in the SPL). Aluminium carbide comes in two forms, Al2C6 and Al4C3 (Ref.6). When mixed with water, the former produces acetylene, the latter methane. Assuming that these two forms of carbide are available in equal quantities, then each of these materials would form about 0.05% of the SPL. The apportioning of water available for mixing with the various components of the SPL is assumed to be (based on the assumption of 1% nitride and 0.1% carbide in SPL): Total: 0.1% carbide + 1% nitride = 1.1% nitride carbide mix. Fraction of water available to mix with nitride = 1/1.1 = 0.91 Fraction of water available to mix with Carbide = 0.1/1.1 x 1 = 0.09 (= 0.045 for each carbide type) Water lost to heat and exothermic reaction = 0.25 (estimate) Table 4.2 presents the modified quantities based on the available water:
Table 4.2: Summary of Gas release Quantities from 1kg of Water Mixing with SPL Incorporating Heat Loss and Fractions of Water Component Mix Proportion Proportion for Initial Release Final Release Material Remaining after each material Quantity Quantity loss to Heat Ammonia 0.75 0.91 0.315k g 0.215kg Acetylene 0.75 0.045 1.4kg 0.047kg Methane 0.75 0.045 0.44kg 0.015kg
Notwithstanding the analysis above, all SPL processing will be performed within the SPL handling area (inside the building) preventing contact between rainwater and SPL. However, building damage could lead to the ingress of water up to a quantity of 1.268 tonnes per hour, with 50% of this being available for mixing with nitrides and carbides (see Section 5.4). Hence, a total of 643 kg/hour of water would be available for mixing with the carbides and nitrides. Vehicles that may enter the building may carry minor amounts of water into the storage area as a result of dripping water from trucks and equipment entering the building. This will not result in sufficient toxic or flammable gas release to be a hazard. This is demonstrated in the analysis conducted in Appendix B, a summary of which is presented at Table 4.3. This table shows that to reach flammable gas lower explosive limits # (LEL)*or LC50 significant quantities of water will be required (e.g. 800kg for ammonia and a minimum of 10 tonnes for acetylene). Quantities of the magnitude required to generate flammable gas will not enter the building during storm damage.
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The analysis conducted in Section 5.2 indicates that around 643kg/hr of water would be available for mixing with SPL to form ammonia, acetylene and methane. The analysis conducted in Appendix B indicates that over 800 kg is required to generate hazardous gas levels (ammonia). Hence, for harmful levels of ammonia to be reached (i.e. LC50) it would be necessary for all the ammonia generated to accumulate within the building and remain in the building for well in excess of 1 hour and for the continued water/SPL reaction to generate ammonia without any escape from the building. It is noted that the hazardous incident described in this scenario is storm damage and, hence, there is significant rainfall and wind and, as such, dispersion of ammonia and absorption by rainwater will further reduce the harmful concentration accumulation. The potential for the ammonia to accumulate within the building (considering the roof has been damaged and is no longer present to retain the ammonia) is considered low if not negligible. In summary, it is considered that the risk to personnel onsite and people offsite is low and will not exceed the criteria published in Hazardous Industry Planning Advisory Paper No.4 (Ref.9). Hence, no further analysis has been conducted in this study. Table 4.3: Summary of Levels of Water Requirements to Generate Hazardous Quantities of Flammable & Toxic Gases
Flammable/Toxic Gas LEL or LC50 Quantity of gas Quantity of Water Generated (in the bld) Generated Required
Ammonia (NH3) 11,500ppm 213 kg 814 kg
Acetylene (C2H2) 2.3% 734 10,200 kg
Methane (CH4) 5% 966 kg 43,900 kg
It is further reiterated that the assessments conducted in this analysis have been conservative, as much of the water will run off the stockpile into the bunded area of the building, minimising the quantity of water available for reaction. Further, any absorption of ammonia into the rainwater as the rainwater falls into the building has not been accounted for, further reducing the quantity of ammonia released. In summary, the quantity of gases released are considered to be less than the estimates in this study and therefore impact on and offsite would be below acceptable consequence criteria. In addition to the assessment conducted above, no account has been taken of emergency response, whereby personnel on site (noting the plant is staffed 24 hours per day) could cover stockpiles with tarpaulins, preventing water dross contact and reducing the likelihood of water SPL mix.
5.4 Water Ingress to the Building, Water/SPL Mix & Dissolving of Cyanide
In the event of storm damage to the roof, as assessed in Section 5.2, the quantity of water assessed to run off the stockpile and accumulate in the base of the storage bays was estimated to be 643 kg (or 643 L). The hazard analysis identified that water in the base of the storage bay could contain dissolved cyanide from the stockpile, which could have severe impacts on the environment if it escaped beyond the SPL stockpile area and into adjacent sites. The quantity of water was assessed to accumulate over a 1 hour period. The storm was estimated to occur over a 12 hour period, hence the total quantity of water estimated to accumulate in the storage bays is 12 hrs x 643 L/hr= 7,716 L. The storage bays and Aldex building are bunded to prevent any escape of solids or liquids from the building. The building has a minimum bund height of 50mm all round. Based on the area of the storage bays alone (567 m2), the volume of water that can be retained within the storage bays is 28m3. This exceeds the quantity of water that would run off the stored SPL in a rain storm (7,716 m3). Further, the site has been constructed with a first flush management system that contains any potentially contaminated stormwater that may escape the bunding within the buildings. Based on this analysis, there would be no release offsite and no potential for environmental impact. Based on the assessment above, this incident has not been carried forward for further analysis.
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5.5 Summary of Incident Consequence Impacts
The hazard analysis identified three scenarios that had the potential to develop incident consequences that could adversely impact offsite. These incidents were: - storm damage to the Aldex building resulting in roof damage, water ingress and hydrogen development. Ignition of hydrogen accumulation could result in explosion, however, the analysis showed that there is insufficient hydrogen generated and as the scenario included the building roof being blown off, there is no entrapment of hydrogen in the building. - Storm damage to the Aldex building resulting in roof damage, water ingress and ammonia/acetylene/ methane development. The analysis showed that the quantity of water ingress over 1 hour did not result in sufficient ammonia generation to reach LC50 concentration levels and that the weather conditions would result in rapid dispersion of the gas failing to reach harmful levels. The quantities of water required to generate sufficient acetylene/methane, so that the concentration exceeded LEL, were considerably higher than would enter the building during the postulated storm event. It is noted that the MSDS for SPL does not list aluminium nitride or aluminium carbide as a constituent of SPL, however, some contamination of the SPL may occur from contact with dross during the aluminium smelting operation. The selection of 1% contamination (the level used in this study) is considered very conservative. - storm damage to the Aldex building resulting in roof damage, water ingress and dissolving of cyanide into the storm-water, resulting in the potential for contaminated water to escape offsite. The analysis identified that the Aldex building is bunded with spill containment capacity sufficient to hold the estimated storm-water ingress without release off-site. As the assessed hazard and risk impacts are considered to be negligible, the cumulative impact as a result of existing risks does not change the existing risk profile. Based on the analysis conducted in this study, the hazards associated with the proposed storage of SPL at the Weston aluminium facility does not result in a change to the existing risk profile, hence, the risk criteria published by the NSW DPI in HIPAP No.4 (Ref.9) is not exceeded and the facility remains classified as potentially hazardous and not hazardous and would therefore be permitted to continue operations processing dross and SPL in the existing land zoning.
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6.0 References 1. NSW Department of Planning and Infrastructure, Weston Aluminium Spent Potlining Processing – Director General’s Requirements (DA-86-04-01 Mod 7 and 10397 Mod 5). 2. DPI (2011), “Applying SEPP 33”, Hazardous and Offensive Industry Development Application Guidelines 3. NSW DPI Hazardous Industry Planning Advisory Paper No.6, “Guidelines for Hazard Analysis”; 4. Multi-Level Risk Assessment, Department of Infrastructure, Planning and Natural Resources – 1997 5. NSW DPI Hazardous Industry Planning Advisory Paper No.4, “Risk Criteria for Land Use Safety Planning”; 6. The Australian Code for the Transport of Dangerous Goods by Road and Rail (Known as the Australian Dangerous Goods Code or ADG), 7th ed., National Transport Commission, 628 Bourke Street, Melbourne, Vic. 7. http://weather.yahoo.com.au/local-climate-history/nsw/kurri-kurri, Data Supplied by the Australian Bureau of Meteorology. 8. AECOM Report No: 60239605-SPLTrialFinal-21122012, Occupational Hygiene Monitoring – Spent Potlining (SPL) Trial, Revision 2 26 March 2012 9. NSW Department of Planning, Hazardous Industry Planning Advisory Paper No.4, Risk Criteria for Land Use Safety Planning (1992). 10. Withers, J. et.al. (1988), Ammonia Toxicity Monograph, United Kingdom Institution of Chemical Engineers, Rugby 11. West, R.C. (1951) “Handbook of Chemistry and Physics”, CRC Press, Ohio, USA
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Appendix A
Hazard Identification Table
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Appendix A Hazard Identification Table
Operation or Area Hazard Cause Hazard Consequence Safeguards
Delivery of SPL to the Aldex SPL tipped into storage bays Potential for dust generation and SPL storage bays are fitted with curtains to minimise dust building release from the storage area escape from bay area impacting adjacent sites Bays are fitted with dust extraction ducts Dust extraction is passed through a baghouse Buildings are fitted with doors that can be closed, when required, during tipping of high dust SPL SPL Processing Equipment Hole in SPL processing-equipment Potential dust release via the All equipment and ductwork is installed within the Aldex (screen, trommel, crusher, etc.) damaged component, release outside building the Aldex building impacting adjacent Aldex Building is fitted with dust extraction equipment sites Baghouse is fitted to extraction system Real-time, continuous particulate monitoring devices and bag failure alarms are fitted to baghouse Aldex building is fitted with doors to confine any dust releases where required Baghouse SPL baghouse bag failure SPL dust discharged directly to SPL is not acutely hazardous - Class 4.3 hazardous when atmosphere via the baghouse stack, wet (noting cyanide content in SPL is minor <0.7%) impacting adjacent sites Single bag failure would not cause significant impact (negligible release) Real-time, continuous particulate monitoring devices and bag failure alarms are be fitted Regular bag inspection and replacement regime is established as part of preventative maintenance programs. Aldex/Main Processing Building Leaks in roof (minor holes) Minor water ingress, potential for Minor water ingress only Roof water/SPL mixing and minor Small water quantity-small gas generation hydrogen gas development, Release contained within the building accumulation of gas, ignition and Large air flow and extraction via baghouse (dilution) explosion Steel sheet roofing (minimal holes) Regular building inspection, maintenance & repair
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Operation or Area Hazard Cause Hazard Consequence Safeguards
Aldex/Main Processing Building Storm damage to building – roof Large water ingress into building – Steel sheeting screwed to roof Roof sheet blown off water SPL mix and hydrogen gas Building designed for 100 year storm generation Storm resulting in damage would also result in dispersion of gas (wind) Water/SPL mix and ammonia/ Hydrogen is an extremely light gas and would escape via acetylene/methane generation. the damaged roof panel (no gas accumulation) Large building volume Methane is a light gas (rises and disperses) Acetylene is slightly lighter than air (rises slowly and disperses) Rotary Furnace Gas firing of rotary furnace fails, Cyanide is not destroyed in the Scrubber-baghouse complex operation at all times during temperature of furnace falls below furnace, potential for furnace fumes processing cyanide destruction level to contain cyanide particles. Release Temperature controls on the furnace from the main processing building Gas failure alarms (loss of gas firing activates an alarm) and impact offsite. High thermal mass in the furnace (furnace temperature does not reduce immediately firing stops) Furnace operation are attended at all times by a furnace operator (furnaces do not operate unattended)
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Appendix B
SPL – Water Mix Analysis
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Appendix B SPL – Water Mix Analysis
B1 AMMONIA RELEASE FROM SPL AND WATER MIX B1.1 Introduction
The SPL proposed for processing at the Weston facility contains a variety of materials including aluminium, sodium fluorides, carbon (majority constituent), silicon, aluminium sodium oxide, sodium alumina silicate and cyanide (<0.7%). Although not listed, aluminium carbides and nitrides may impregnate the SPL as a result of operations in the pot. A typical level of carbide/nitride in dross would be about 10% aluminium nitride with smaller quantities of aluminium carbide. The MSDS for the SPL does not list aluminium nitride and carbide in the constituents, however, it is likely that the MSDS provided for SPL is for new material and trace level contaminants contained in the SPL would not be shown in new SPL. Where carbides and nitrides are present in materials, when water mixes with SPL ammonia would be released as the predominant gas with smaller amounts of acetylene and methane. The analysis in this section is performed to determine the release quantities of the various gases from an SPL- water mix, based on 1kg of water. The above description of SPL indicates that there could be contamination from the aluminium nitrides and carbides, the description section of the study estimates that this contamination could be about 1% (very conservative). B1.2 Ammonia Release B1.2.1 Chemical Reactions
The mixing of water and SPL results in a reaction that takes place according to the equation: AlN + 3(H O) NH + Al(OH) 2 3 3.
This calculation assumes that all water mixing with SPL is available for reaction. However, this is not usually the case in water SPL mixes. In reality, other reactions take place in conjunction with the aluminium nitride/water reaction above. One important reaction is: 2 AlN + 3 (H O) 2NH + Al O 2 3 2 3 This reaction creates significant heat, liberating water in the form of vapour and steam. Hence, not all the water is available for reaction. The MSDS for the SPL indicates that hydrogen may also be generated as a result of the mixing of SPL with Water. A 50% estimate of water mix with SPL was used to determine the potential for hydrogen generation. Hence, conservatively, the remaining 50% has been estimated to be available for generation of ammonia/methane/acetylene. This is conservative as some of the water will run off into the bunded area and will not react with the SPL. B1.2.2 Release Rate Calculations For this an alysis a b ase v alue of 1 litre (or 1kg) of water has b een us ed to determi ne t he u nit q uantity of ga s released per litre/kg of water.
Mass of water = 1kg
A stoichiometric mixture of 1 mole of AlN (0.41kg) and 3 moles of H 2O (0.54kg) gives 1 mole of NH3 (0.17kg). Therefore the mass of ammonia released per kg of water is given by:
Mass of ammonia produced/kg of water = 1kg H2O x 0.17 kg NH3
0.54kg H2O
= 315g ammonia/kg of water
Noting that this analysis is conservative as all water will not be available for generation of ammonia due to heat and side reactions (hydrogen generation, see main report) and those demonstrated below in Sections B2 & B3.
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B1.3 Nature and Properties of the Evolved Ammonia Releases It is important at this stage to discuss the nature and properties of ammonia that are critical in understanding the behaviour of the gas after it has been released. Anhydrous ammonia (or liquid ammonia) is stored at 840kPa(abs.) at ambient temperature (20oC). Hence, when anhydrous ammonia is released it immediately commences to vaporise, absorbing heat from the surroundings. This causes a reduction in temperature of the released gas/liquid which increases the gas density, making heavier than air in the immediate area of the release point. Further, as the gas in this form is highly saturated, it is highly hygroscopic, and is therefore absorbed by the water vapour in the air resulting in an ammonia water molecule that is also heavier than air. In general, a release of anhydrous ammonia acts as a dense gas, although the gas molecule itself is lighter than air. The gas release due to water/ SPL mix is not anhydrous. The gas is formed as a result of a chemical reaction between the water and aluminium nitrides in the SPL. This reaction is exothermic, hence the gas is released at above ambient temperature and does not cool during the release period. The gas in this form is less hygroscopic and tends to remain as a gas (i.e. does not mix with water vapour) during and after the release. Under these circumstances, the gas is buoyant, as the molecular weight of ammonia (17) is much lighter than air (28). B2 OTHER GASES RELEASED FROM SPL AND WATER MIX B2.1 Introduction
The evolution of other gases, such as acetylene and methane would be limited due to the alkaline nature of the SPL water mix (i.e. aluminium hydroxide formation). Acetylene and methane are produced from minor quantities of aluminium carbide in the SPL. The SPL at proposed for use at Weston is not listed as having significant quantities of nitrides or carbides as the new SPL does not contain these materials, however, these contaminants may be present in quantities up to 1%, with a predominance of nitride (see Section B1.1). On average about 0.1% aluminium carbide content may be found in the SPL. Hence, based on 1% Nitrides and 0.1% carbides (i.e. 10:1 ratio of nitrides to carbides), the water available to nitride/carbide would be 10:1 (or 90% to 10% respectively). This ratio has been used in the analyses conducted later in this section.
Aluminium carbide comes in two forms, Al2C6 and Al4C3 (Ref.11-main report). When mixed with water, the former produces acetylene, the latter methane. The SPL contains, relatively, only trace amounts of cyanide bearing compounds (<0.7%), hence, releases of cyanide would not be sufficient to generate a toxic cloud resulting in offsite effects. At the levels of gas evolution expected from the SPL water mix postulated in this analysis, hydrogen fluoride (HF) would not be an acute toxic gas. Further, as the mixture would be alkaline, there is little potential for HF production as the chemical reaction forming HF is suppressed by alkaline conditions. Based on this analysis, there is no further consideration of hydrogen cyanide or hydrogen fluoride release. In some cases high humidity can affect SPL and release toxic and flammable gases. The high humidity can cause a slow reaction at the surface of the SPL releasing ammonia, acetylene and methane. The reaction would occur at the surface only, releasing insignificant quantities of gas. Nevertheless over a period of time, these gases can build up in confined spaces leading to dangerous and flammable atmospheres. The proposed SPL storage area is fully vented with exhaust fans drawing air from the storage space through dust collection units thus preventing build up of gas in the storage area. Fresh air is currently drawn into the storage area as air is removed from the space by the fans. The fans operate on a 24 hour basis, reducing the likelihood of gas build up in the building. The slow release rate of gas and the vent fans result in a low risk of toxic or flammable gas build up at this facility. B2.2 Chemical Reactions
The mixing of water and SPL results in a reaction that takes place according to the equation: Al2C6 + 3(H2O) C2H2 + Al2O3 and
Al4C3 + 6 H2O 3 CH4 + 2 Al2O3
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Assuming each of the carbides mix stoichiometrically with water, the following amounts of acetylene and methane are produced:
Al2C6 = 1kg of water mixed with 2.33kg of carbide leads to 1.44kg of acetylene
Al4C3 = 1kg of water mixed with 1.33kg carbide leads to 0.44kg of methane.
B3 Mass of Water Required to Generate Hazardous Levels of Ammonia, Acetylene & Methane B3.1 General Theory
The density of a gas in a specified volume can be determined from the relationship: Density [] = molecular weight/22.412 grams/litre. Each material has a sp ecific hazard level at which ignition will occur (lower explosive limit or LEL for flammable gases – acetylene and methane) or toxic impact will occur (ammonia). These levels are:
- Ammonia (LC50)– 11,500ppm (Ref.10 – main report) - Acetylene (LEL) – 2.3% or 23,000ppm (Ref.11 – main report) - Methane (LEL) – 5% or 50,000ppm (Ref.11 - main report)
The volume of w ater required to gener ate the specific l evels of hazardo us gas can therefore be ca lculated using the density relationship and the hazard levels above. This analysis is conducted in detail below. B3.2 Water Required to Generate Hazardous Levels of Ammonia
An elevation and end elevation of the building in which the SPL will be stored (Aldex and main processing buildings) is shown at Figure B1. The volume of the buildings is: - Main Processing Building – 33,230 m3 - Aldex Building – 27,216m3
Hence the smallest building is the Aldex building, hence, this building has been used for the assessment
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Figure B1: Aldex and Main Processing Building Dimensions
38m 66m 33m 19m
3 Total Vol.= 33,230m 11m 9m
Elevation End Elevation MAIN PROCESSING BUILDING
84m 23.5m 42m 7m
Total Vol.= 27,216m3 12m
Elevation End Elevation
ALDEX Building
Whilst it is recognised that localised water mixing and higher concentrations of the gas may be present at specific locations, personnel impacted by the gas at these locations may leave the area and move to an uncontaminated area, which will facilitate recovery from any symptoms of impact. It has been assumed that only a building full of gas at a hazardous level will result in impact to personnel as they will not be able to escape to a clear area in sufficient time. Further, where a hazardous gas concentration occurs within the building (i.e. at the minimum concentration as assessed in this study), once the gas escapes from the building, it is diluted below impact levels and, hence, impacts beyond the site will be below hazardous concentrations. Hence, if ammonia gas filled the full volume of the Aldex building (noting the characteristics of the gas listed in Section B1.3), the density of gas would be: Density [] = molecular weight/22.412 grams/litre
Where molecular weight of ammonia is 17 (based on the chemical formula of NH3) Density = 17/22.412 = 0.76grams/litre or kg/m3 The selected hazardous impact level for ammonia is 11,500ppm or 0.0115 of the normal density of the gas in a given space. Hence, the density of ammonia in air at 11500ppm = 0.0115 x 0.76 = 0.0085 kg/m3. The volume of the Aldex building is 27,216m3, therefore the mass of ammonia released, in order to reach 11,500ppm, would need to be 0.0085 x 27,216 = 231 kg (or in excess of two tonnes). From Section B1.1.2, the quantity of ammonia produced per kg water is 0.315kg and it was stated above (Section B2.1) that only 50% of the water is available for ammonia/acetylene/methane production (40% ammonia and the remaining 10% goes to acetylene/methane production). Therefore the amount of water required to produce 231 kg of ammonia in the Aldex building is: Quantity of water = 231/(0.315 x 0.9) = 814 kg. This analysis assumes complete mixing and all available water (40%) for ammonia production (i.e. no account of side or exothermic reactions).
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B3.3 Water Required to Generate Hazardous Levels of Acetylene
By similar analysis to that conducted above for ammonia: Density [] = molecular weight/22.412 grams/litre
Where molecular weight of acetylene is 26, based on a chemical formula of C2H2. Density = 26/22.412 = 1.16grams/litre or kg/m3 The selected hazardous impact level for acetylene (LEL) is 23,000ppm or 0.023 of the normal density of the gas in a given space. Hence, the density of acetylene in air at 23,000ppm = 0.023 x 1.16 = 0.027 kg/m3. The volume of the Aldex building (the smaller building) is 27,216 m3, therefore the mass of acetylene released, in order to reach 23,000ppm, would need to be 0.027 x 27,216 = 734 kg. From Section B1.1.2, the quantity of acetylene produced per kg water is 1.44kg and it was stated above (Section B2.1) that only 10% of the water is available for acetylene/methane production, which has been apportioned to half of this amount (5%) for each gas. Therefore the amount of water required to produce 614 kg of acetylene is: Quantity of water = 734/(1.44 x 0.05) = 10,200 kg or 10.2 tonnes. This analysis is very conservative and assumes complete mixing and all water assumed available for acetylene production will produce the gas (i.e. no account of side or exothermic reactions). Hence, in reality, more water would be required to produce an acetylene LEL in the building. B3.4 Water Required to Generate Hazardous Levels of Methane
By similar analysis to that conducted above for ammonia and acetylene: Density [] = molecular weight/22.412 grams/litre = 16/22.412 = 0.71grams/litre or kg/m3 The selected hazardous impact level for methane (LEL) is 50,000ppm or 0.05 of the normal density of the gas in a given space. Hence, the density of methane in air at 50,000ppm = 0.05 x 0.71 = 0.0355kg/m3. The volume of the building is 27,216m3, therefore the mass of methane released, in order to reach 50,000ppm, would need to be 0.0355 x 27,216 = 966 kg. From Section B1.1.2, the quantity of methane produced per kg water is 0.44kg and it was stated above (Section 2.1) that only 10% of the water is available for acetylene/methane production, which has been apportioned to half of this amount (5%) for each gas. Therefore the amount of water required to produce 340 kg of methane is: Quantity of water = 966/(0.44 x 0.05) = 43,900 kg or 43.9 tonnes. This analysis assumes complete mixing and all water assumed available for methane production will produce the gas (i.e. no account of side or exothermic reactions). B3.5 Summary of Water Requirements to Generate Hazardous Quantities of Toxic & Flammable Gases
The quantities of water required to generate hazardous levels of toxic and flammable gases are presented in Table B1. Table B1: Summary of Levels of Water Requirements to Generate Hazardous Quantities of Flammable & Toxic Gases
Flammable/Toxic Gas LEL or LC50 Quantity of gas Quantity of Water Generated (in the bld) Generated Required
Ammonia (NH3) 11,500ppm 213 kg 814 kg
Acetylene (C2H2) 2.3% 734 10,200 kg
Methane (CH4) 5% 966 kg 43,900 kg
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