Air Quality Monitoring Plan 1 OBJECTIVE The monitoring and management of air quality within the Port of Townsville is critical to address a potential risk that has generated considerable public interest and complaints and warrants continuing investigation. As a land owner and manager of numerous tenancies, there is a level of expectation and responsibility on Port of Townsville Limited (POTL) to ensure that issues, such as air quality management, are given due consideration and attention. As a land owner of unleased and tenanted areas, POTL has responsibility to ensure appropriate actions are taken to minimise the potential for environmental harm or nuisance to occur. Should an incident of environmental harm or infrastructure damage occur due to poor air quality, POTL will need to be able to demonstrate due diligence for management of the port environment, what actions POTL took to understand air quality from the port in general, and what management actions had been taken to minimise the potential for the incident to have occurred. An air shed model for the port environment has been formulated to address these points. Air quality monitoring at the Port of Townsville is designed to: characterise air quality in the environment within and surrounding the port; assess impacts at the interface to sensitive land uses; identify trends across a range of environmental parameters; identify areas of potential concern across the port (eg a product, parameter, nuisance impact or general location etc); determine whether there is potential for environmental harm or nuisance; and to establish a dataset which may assist in establishing air quality benchmarks to trigger management actions and to assess future performance measures. 2 SCOPE Port operations have the potential to impact on air quality through air emissions from port lands and operations impacting on sensitive land uses, particularly nearby residential areas. Air emissions may arise due to activities conducted by or on behalf of POTL or activities conducted by Port Users which are outside the scope of the EMS. The Air Quality Monitoring Plan has been designed to characterise air quality in the environment within and surrounding the port in order to determine the potential exposure of sensitive receptors to dust and air contaminant emissions that could be attributed to port operations. This information will then be used to assist with improving POTL and Port User control measures where possible. A number of Port Users sample air quality on their sites and POTL will discuss accessing this data with the relevant users. In addition, the Department of Environment and Heritage Protection (DEHP) conducts an air quality monitoring program in Townsville and POTL utilises the data from this program to expand its understanding and analysis of air quality in Townsville. The Air Quality Monitoring Plan will be subject to regular review for adjustment as required. 2.1 Equipment and Sampling Approaches POTL utilises three methods of air quality monitoring: a Tapered Element Oscillating Microbalance (TEOM) at one site; a series of dust deposition gauges located across the port and surrounding areas; and a series of high volume samplers (hi-vols) located across the port and surrounding areas. Page 1 of 7
The TEOM is a continuous monitor which records 30-minute average particulate matter 10µm (PM 10 ) concentrations in addition to wind speeds and wind directions. The TEOM also incorporates an Automatic Collection Cartridge Unit (ACCU) which can continuously collects samples of the dust sampled by the TEOM on filter cartridges over a month long period for laboratory analysis and speciation of various metals. The dust deposition gauges record dustfall, with subsequent laboratory analysis performed to evaluate the composition of deposited dust. The Insoluble solids measured in the dust deposition gauges is the focus for evaluating potential dust nuisance. The hi-vols collect samples of dust on filters over a 24hr period every six days, with subsequent laboratory analysis performed to evaluate the composition of deposited dust and speciation of lead component. The hivols can measure either PM 10 or a total suspended particulate matter (TSP) depending on the type of head unit installed on the body of the sampler. 2.2 Monitoring Locations The air quality monitoring sites have been chosen in order to define the boundary of the port operations and to gauge the potential exposure of the population of nearby residents to nuisance dust and air contaminants that could be attributed to port operations. Monitoring may be conducted at other sites as required in response to complaints or specific activities identified as presenting a high risk of generating elevated emissions. The monitoring sites for the TEOM and the dust deposition gauges are shown on Figure 1. The TEOM is permanently located at the Coast Guard site along with a dust deposition gauge and PM 10 and TSP hi-vols. Meteorological data such as wind speed, wind direction and rainfall is also collected at this site. Hi-vol monitoring is conducted at three sites as indicated on Figure 2. All three sites have both a PM 10 hi-vol and a TSP hi-vol and meteorological equipment. The PM 10 hi-vols at South Townsville and Lennon Drive provide important coverage of the South Townsville/Palmer Street residential exposure to PM 10 to supplement the TEOM PM 10 monitoring at the Coast Guard site to the west. GPS co-ordinates for all monitoring sites are included in Table 2. 2.3 Frequency and Timing of Sampling The TEOM runs continuously, and the TEOM provides real time data. The dust deposition gauges are collected and replaced at the beginning of every month. The hi-vols collect samples of dust on filters over a 24hr period every six days and the filters are collected and replaced every six days. 2.4 Parameters Based on the available information and knowledge of typical contaminants likely to be present on POTL lands, the following parameters will be monitored by one or more of the three methods as stated below: PM 10 TEOM and hi-vol TSP Hi-vol Dust deposition gauge Dust deposition gauge Dust deposition gauge Dust deposition gauge Dust deposition gauge Trace metals (As, Cd, Co, Cu, Fe, Mn, Ni, Pb, Zn) Hi-vol and dust deposition as required Page 2 of 7
Figure 1: TEOM and dust deposition monitoring sites. Note: TEOM located at Coast Guard site only. Figure 2: Hi-vol monitoring sites. Page 3 of 7
3 PERFORMANCE OBJECTIVES AND REPORTING The national guideline for air quality is the National Environment Protection (Ambient Air Quality) Measure 1998 (NEPM) and the state guideline is the Environment Protection (Air) Policy 2008 (). Air quality parameters are assessed by POTL against relevant objectives. In the absence of a relevant objective or trigger value, general comparison and rationale is utilised. POTL analyses data on a monthly, quarterly and annual basis and reports compliance against the performance objectives listed in Table 1. Dust deposition gauges located inside the port are likely subject to near-field dust generating activity that will not extend beyond the port boundaries. Compliance with the adopted air quality guidelines at locations within the port land is not necessary to ensure the environmental amenity of South Townsville and other sensitive locations is preserved. Quarterly and annual reports are presented to the Senior Management Team, the Board and any relevant board committees. The program and trends are also discussed at the Environmental Working Group. Irregular results are raised with individual Port Users as required. Table 1: Air quality performance objectives. Parameter Air Quality Performance Objective Guideline PM 10 50 μg/m 3 (average over 24hrs which may be exceeded a maximum of 5 days per calendar year) TSP 90 μg/m 3 Arsenic and compounds (measured as the total metal content in PM 10) 6 ng/m 3 NEPM and Page 4 of 7
Cadmium and compounds (measured as the total metal content in PM 10) Lead and compounds (measured as the total metal content in TSP) Manganese and compounds (measured as the total metal content in PM 10) Nickel and compounds (measured as the total metal content in PM 10) Dust insoluble solids 5 ng/m 3 0.50 μg/m 3 0.16 μg/m 3 20 ng/m 3 120 mg/m 2 /day (or 3.65 g/m 2 /month) NEPM and No specified guidelines. DERM accepted limit for justifiable complaints about nuisance dustfall 4 INVESTIGATION PROCEDURE In the event that results from POTL s air quality monitoring indicate an exceedance of a relevant air quality performance objective, it is necessary to investigate the cause of the non-compliance and implement corrective actions as appropriate. A short-term (e.g. 24 hour average) monitoring result that exceeds a longterm (e.g. average) air quality objective is not a non-compliance, but should be subject to this Investigation Procedure. This investigation procedure should also be implemented in response to any air quality related complaints or requests from a regulatory authority. 1. Identify the likely cause of the non-compliance by the following assessment procedure: i. Obtain DEHP air quality monitoring data (e.g. Pimlico station) to determine whether the measured non-compliance is likely to be a result of a regional air quality event rather than Port activities. ii. Review and summarise in wind rose format the weather station data (Coast Guard and/or Environmental Park station as appropriate depending upon the location of the non-compliance / complaint) for the period to which the investigation relates. iii. Assess the prevailing wind directions during the investigation period to determine if Port activities are potentially a cause of the non-compliance / complaint. iv. Review available and relevant real-time monitoring data (e.g. Coast Guard TEOM and/or any Environmental Park real-time monitoring data) and correlate short-term pollutant concentrations with the wind direction throughout the investigation period. Summarise in a pollution rose format if appropriate to assist in identifying wind directions from which the highest pollutant concentrations occurred. v. Review Port operational records (i.e. shipping schedules, Port users activities, POTL works) for the investigation period. Correlate the operations with the locations from which pollutants may have emanated based upon the wind analysis conducted in step ii. to iv. above. vi. Prepare a report to the Manager Environment summarising the outcome of the investigation. 2. If the Manager Environment determines that emissions from Port activities are likely to have significantly contributed to the non-compliance / complaint: i. Manager Environment to determine whether administering authority for the activity is required to be informed of the non-compliance / complaint and proposed actions. ii. Manager Environment to determine whether further monitoring is required to assess whether the non-compliance / complaint is an continuing issue or a result of an isolated event. Undertake a targeted short-term monitoring program and/or amend the Air Quality Monitoring Plan as appropriate. iii. If POTL activities are likely to have significantly contributed to the non-compliance / complaint, then POTL to implement emission control measures and/or changes to operational procedures within an appropriate timeframe to avoid further non-compliances / complaints. iv. If a specific Port user is likely to have significantly contributed to the non-compliance / complaint, then advise user of the requirement to implement emission control measures and/or changes to Page 5 of 7
operational procedures within an appropriate timeframe to avoid further non-compliances / complaints. 3. Manager Environment to prepare a report to the Board summarising the outcome of the investigation, proposed additional monitoring and/or corrective actions resulting from the assessment. 4. If investigation has been undertaken in response to a complaint or a request from a regulatory authority, advise the complainant / regulatory authority of the outcome of the investigation as appropriate. 5 SUMMARY OF AIR QUALITY MONITORING PLAN Table 2 provides a summary of the Air Quality Monitoring Plan. Table 2: Summary of the Air Quality Monitoring Plan. Site Name Site Coordinates Easting Northing Sampling approach Frequency Parameters Coast Guard 481841 7871218 TEOM PM 10 hi-vol TSP hi-vol Dust deposition PM 10 and metals speciation (as req) TSP and metals speciation (as req) Metals speciation (as req) Meteorological data South Townsville Environmental Park 482223 7869995 PM 10 hi-vol TSP hi-vol Dust deposition PM 10 and metals speciation (as req) TSP and metals speciation (as req) Metals speciation (as req) Meteorological data Lennon Drive 481779 7870523 PM 10 hi-vol TSP hi-vol PM 10 and metals speciation (as req) TSP and metals speciation (as req) Dust deposition Metals speciation (as req) Meteorological data Tully Street 481928 7870368 Dust deposition Archer Street 482110 7870321 Dust deposition Nexus Business Park 482493 7869750 Dust deposition Page 6 of 7
Site Name Site Coordinates Easting Northing Sampling approach Frequency Parameters Port Entrance 482900 7870553 Dust deposition Metals speciation (if req) Administration Building 482941 7870890 Dust deposition Berth 10 482085 7871284 Dust deposition 6 RELATED DOCUMENTS ENV 126 Rain Gauge Procedure ENV 140 High Volume Sampler Monitoring Procedure PE 102 TEOM and ACCU Operation Procedure PE 104 Dust Deposition Monitoring Procedure Page 7 of 7