Newcastle Local Air Quality Monitoring Network · 2017-05-25 · review of meteorology and...

Newcastle Local Air Quality Monitoring Network

NSW ENVIRONMENT PROTECTION AUTHORITY

Review of Cost Effectiveness

EN04425 | Rev 1

5th June, 2014

NLAQMN – Review of Cost Effectiveness

Project Name

Project no: EN04425 Document title: NLAQMN – Review of Cost Effectiveness Revision: Rev 1 Date: 5th June 2014 Client name: NSW EPA Project manager: Matt Davies Author: Matt Davies File name:

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Jacobs derived the data in this report from information sourced from the EPA (if any) and/or available in the public domain at the time or times outlined in this report. The passage of time, manifestation of latent conditions or impacts of future events may require further examination of the project and subsequent data analysis, and re-evaluation of the data, findings, observations and conclusions expressed in this report. This report should be read in full and no excerpts are to be taken as representative of the findings. No responsibility is accepted by Jacobs for use of any part of this report in any other context.

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Document history and status

Revision Date Description By Review Approved

0 07/05/2014 NLAQMN – Review of Cost Effectiveness M. Davies S. Lakmaker M. Davies

1 05/06/2014 NLAQMN – Review of Cost Effectiveness M. Davies J. Moore J. Moore

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Contents

Executive Summary .................................................................................................................................................................................... 1

1. Introduction ................................................................................................................................................................................... 2

1.1 Background ..................................................................................................................................................................................... 2

1.2 Objectives ....................................................................................................................................................................................... 2

1.3 Scope of Work ................................................................................................................................................................................ 3

2. Review of Information .................................................................................................................................................................. 4

2.1 Review of Meteorology in Newcastle Inner City and Port Neighbourhood 2011 ............................................................................ 4

2.2 Lower Hunter Ambient Air Quality Review of Available Data 2012 (OEH2012/0281) .................................................................... 6

2.3 Newcastle Local Ambient Air Quality Monitoring Network Revised Funding Model Draft Discussion Paper Version 2 Sept 2013 ................................................................................................................................................................................................ 8

2.3.1 Overview ......................................................................................................................................................................................... 8

2.3.2 Funding Model Details .................................................................................................................................................................. 10

3. Review of Fit for Purpose and Cost Effective Monitoring....................................................................................................... 12

3.1 Overview ....................................................................................................................................................................................... 12

3.2 Instrument Specifications .............................................................................................................................................................. 12

3.2.1 Particle Monitors ........................................................................................................................................................................... 12

3.2.2 NOX Monitors ................................................................................................................................................................................ 13

3.2.3 SO2 Monitors ................................................................................................................................................................................. 13

3.2.4 Meteorological Sensors and Mast................................................................................................................................................. 13

3.3 EPA Cost Estimates...................................................................................................................................................................... 14

Appendix A. EPA Project Brief

Appendix B. Project Plan – NLAQMN Cost Effectiveness Review

Appendix C. Summary Pollutant Monitoring Data

Appendix D. NLAQMN Cost Information


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Executive Summary The Newcastle Ambient Air Monitoring network (NLAQMN) is proposed as three (3) monitoring stations to be located at Stockton, Warrabrook/Mayfield and Carrington. The pollutants to be monitored include particulate matter (PM10 and PM2.5); nitrogen oxides (NOX); and sulphur dioxide (SO2). Meteorological parameters will also be measured at each site.

The objective of this report is to review documentation provided by the EPA in support of establishing the NLAQMN to ensure it is cost effective in terms providing local air quality data, within a framework whereby industry are funding the network to be procured, constructed and operated by the EPA.

Overall the proposed NLAQMN is considered to be cost effective in terms of providing reliable and accurate air quality monitoring data that can be available in near-real time to the EPA, the community and other stakeholders. The following comments and recommendations are made with respect to ensuring the NLAQMN represents good value for money for industry who will contribute funding for establishing, operating and maintaining the NLAQMN and the EPA and community who will use the data collected:

The initial investigation into proposed NLAQMN monitoring locations undertaken by PAE Holmes, 2011 included the results of PM10 dispersion modelling of emissions from industry located in an around the port. The results of modelling suggest Fern Bay may often experience higher impacts than other localities in particular higher than in nearby Stockton. The report by PAE Holmes, 2011 recommend a monitoring station be located in Fern Bay. No such recommendation was made for Stockton The network as proposed includes a monitoring station in Stockton and not Fern Bay. As such further consideration as to why Fern Bay should be excluded from the NLAQMN is recommended. While Fern Bay has a relatively low population the proposed increase in residential development in and around Fern Bay will see a rise in population in the future.

One point of justification for the NLAQMN is to allow industry to rationalise the cost of monitoring. In this regard it is recommended that the EPA provide a framework for industry outlining how to undertake this rationalisation and remove redundant air quality monitoring from their regulatory requirements. This is needed to demonstrate the NLAQMN being cost effective and value for money.

The NLAQMN funding model requires all licensed industry located within the Newcastle LGA that emit air pollutants which are to be monitored by the NLAQMN to contribute funds to the network in proportion to their emissions. It is noted that the investigations into the location of monitoring stations, namely the review of meteorology and modelling by PAE Holmes (2011), focussed only on industry within the “Newcastle Inner City and Port Neighbourhood”. It is recommended that further investigation is undertaken to assess industry source apportionment to impacts at each of the proposed monitoring stations as a means of allocating funds. This should be undertaken for all industry located within the Newcastle LGA.

With respect to shipping emissions the approach used by the funding model is to allocate these to industry that have a ‘shipping in bulk’ scheduled activity in their EPL. A suggest alternative approach is that costs are attributed to shipping movements (including ship type). This latter approach is recommended, as it will more accurately reflect total emissions from ships serving the individual industries.

It is recommended that the EPA provide a justification for using TEOMs for PM10 and BAMs for PM2.5, considering both cost and consistency of measurement technology, compared with say a combination of either BAMS or TEOMs being used for both particle size ranges.

The independent review of costs revealed that in some cases the EPA itemised cost of equipment was “High” – for example the costs for the portable monitoring enclosures and particle monitors. It is recommended that the EPA provide additional information with respect to the cost of these items so as to resolve the differences in cost estimates.

The EPA operational costs include annualised replacement costs for the various analysers, assuming they are replaced every four years. It is recommended the EPA provide some benchmarking of analyser replacement with consideration of their other existing monitoring stations.

It is recommended that the EPA provide clarification as to if and/or how the monitoring officer costs at $55,222 relate to the $50,000 one off data management costs.


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1. Introduction The Newcastle Local Air Quality Monitoring network (NLAQMN) will consist of three (3) monitoring stations to be located at Stockton, Warrabrook/Mayfield and Carrington. The pollutants to be monitored include particulate matter (PM10 and PM2.5); nitrogen oxides (NOX); and sulphur dioxide (SO2). Meteorological parameters will also be measured at each site.

The EPA decided that a Regulation should be developed to levy funds from industry to construct, maintain and operate the NLAQMN in accordance with section 295Z of the POEO Act. In accordance with Section 295 (6) “the EPA is to obtain, and take into consideration, advice from one or more independent persons or bodies with relevant technical and health expertise as to the cost effectiveness of any environmental monitoring program.”

This report provides the technical review of the cost effectiveness of the NLAQMN required by the Regulation.

1.1 Background

A NSW Office of Environment and Heritage (OEH) Briefing Paper dated 6 November 2012 provides the following background to the NLAQMN:

“In October 2011, the Minister for the Environment directed the EPA to investigate the need for a local air quality monitoring network in Newcastle. Concurrently, the Minister directed the EPA to establish the Newcastle Community Consultative Committee on the Environment (NCCCE). A key function of the NCCCE is to advise the Minister on the implementation of environmental monitoring systems in the Newcastle area.

With assistance from the OEH, the EPA completed a review of air quality monitoring data for the Newcastle local government area. The OEH and EPA presented the findings of the review to the Newcastle Community Air Quality Forum, held on 16 March 2012 and to the NCCCE on 16 April 2012.

In June 2012, the EPA consulted the NSW Ministry for Health’s Air Pollution Expert Advisory Committee (APEAC), seeking advice on the need for an industry-funded air quality monitoring network in the Newcastle area.

The APEAC noted that the Lower Hunter generally has good air quality and that current information suggests that no specific community health issues exist. The APEAC noted that the existing industry-operated air quality monitoring system does not monitor continuously, and therefore does not constitute a strategic local area network. The APEAC recognised the potential benefits in rationalising the current industry monitors into a systematic, well designed network, with continuous monitoring of local air quality at sites in the Newcastle port precinct. The APEAC recommended that air quality data from the network be publically available and easy to understand.

The OEH is assisting EPA to investigate the potential options for a more strategic industry air quality monitoring network in and around residential areas bordering the industrial areas in the port of Newcastle. The objective is to locate air quality monitoring stations in locations to effectively characterise the air quality experienced by those in the communities living closest to the industrial areas and to serve as an indicator of the performance of industry in the port.”

1.2 Objectives The objective of this report is to meet the requirements of the EPA Project Brief (refer to Appendix A) and to ensure the proposed NLAQMN is cost effective in terms providing regional air quality data, and considering a framework whereby industry are funding the network to be procured, constructed and operated by the EPA. Key drivers are whether the NLAQMN is fit for purpose and represents value for money with respect to:

Monitoring site infrastructure;

Monitoring equipment;


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Network maintenance program; and

Telemetry, data processing and graphical user interface.

1.3 Scope of Work

The scope of work for reviewing the cost effectiveness of the NLAQMN involved:

Preparing a project plan to identify key drivers, methodology, team and timing;

Undertaking a review of existing documents on the funding model, data reviews and location reviews to form an independent opinion of the cost effectiveness of the NLAQMN. This included development of criteria relevant to the assessment; and

Undertaking a review of monitoring costs by consultation with equipment suppliers, comparing with EPA estimates and developing cost rankings.


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2. Review of Information This section provides key outcomes from a review of the following EPA documents:

Review of Meteorology in Newcastle Inner City and Port Neighbourhood 2011;

Lower Hunter Ambient Air Quality Review of Available Data 2012 (OEH2012/0281);

Newcastle Local Ambient Air Quality Monitoring Network Revised Funding Model Draft Discussion Paper Version 2 Sept 2013; and

Newcastle Local Ambient Air Quality Monitoring Network Funding Model Part 2 Appendices Version 2 Sept 2013.

2.1 Review of Meteorology in Newcastle Inner City and Port Neighbourhood 2011

Investigation of wind speed and wind direction is a major consideration in the location of air quality monitoring stations. The Review of Meteorology in the Newcastle Inner City & Port Neighbourhood (PAE Holmes, 2011) examined meteorology data from existing industry operated monitoring sites, for a period of five years from 2006 to 2010.

A study boundary and modelling domain of 10 km by 10 km was selected to incorporate the population centres of Fern Bay, Stockton, Carrington, Islington, Wickham, Newcastle (inner city, west and east), Mayfield and Warrabrook.

The major findings of the review were:

Prevailing winds in winter typically occur from the west and west-northwest;

Prevailing summer winds flow onshore, from the east-northeast to east-southeast;

Wind patterns are very similar across all locations around the port;

Modelling of air pollution, as particulate matter (particles with sizes less than 10 micrometres diameter, referred to as PM10), shows the highest predicted impacts across the residential areas of Carrington, Fern Bay, Mayfield and Warrabrook.

With respect to the modelling results PAE Holmes (2011) state that “the spatial distribution of predicted PM10 ground level concentrations clearly indicates that greater impacts are anticipated to occur within the region of the port. Predicted PM10 concentrations generally decrease with distance from this area. This outcome is largely unsurprising, given that potential PM10 emissions from this area largely represent non-buoyant, fugitive, near ground level releases. This is opposed to the industrial and commercial point sources incorporated within the modelling, which are generally buoyant and elevated, thus aiding their dispersion prior to their transport to ground level.”

Most relevant to this review is the rationale for the selection of preferred monitoring locations at Warrabrook, Mayfield, Carrington and Fern Bay. In this regard PAE Holmes (2011) state that the basic principles that need to be considered in the design of air quality monitoring networks are described in the literature (WHO 1976 & Stern et al. 1984). The main principles that need to be considered are:

the needs of the data users including the quantity, quality, location and sampling times;

the available resources (in particular funds and labour availability);

legal requirements;

available technology for monitoring; and

operational criterion including economic, social, legal and cost effectiveness.

PAE Holmes (2011) note that the Peer Review Committee (PRC) for the National Environment Protection Measures (NEPM) has also developed guidelines for various aspects associated with the design and operation


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of monitoring networks in the Australian context. These are set out in the NEPM (Ambient Air) and a series of technical papers which relate specifically to air monitoring networks used for the NEPM, but which provide useful guidance for the design of any air monitoring network. In particular, Technical Paper 3, Monitoring Strategy, discusses the siting requirements for monitors to demonstrate compliance or non-compliance with ambient air quality standards, when there are limited resources.

The basic principle is to identify populated areas where the highest concentrations of pollutants are expected to occur. Monitors sited in such areas can be used to identify the highest levels that the community is expected to be exposed to. If this is done reliably, and if the monitored concentrations are at or below acceptable levels, then it can be inferred that all other populated areas will also experience concentrations at or below acceptable levels. However, if the monitoring does not demonstrate that levels are acceptable then further monitoring is needed to delineate the areas where the levels are acceptable and where they are not acceptable.

The National Environment Protection Measure for Ambient Air Quality (NEPC, 1998) provides guidelines as to the minimum number of monitoring sites required based on population size. The formula for regions with populations greater than 25,000 is 1.5P + 0.5, where P is the population of the region in millions. There is additional guidance as to the number of additional monitoring sites required where the pollutant levels may be influenced by local characteristics such as topography, weather and emissions sources.

While PAE Holmes (2011) make reference to the NEPM and its methods for determining monitoring locations, based on “regions” and “populations” these are not really relevant here, as the Newcastle area already has three (3) NEPM monitoring stations (Newcastle, Wallsend and Beresfield) which are sited to provide regional population centres with ambient air quality monitoring data. Moreover, the purpose of the NLAQMN is to provide additional air quality monitoring to measure the effect of air pollution emissions from the high density of industry in around the port of Newcastle. PAE Holmes (2011) recommend additional monitoring stations be located at:

Warrabrook;

Mayfield;

Carrington; and

Fern Bay.

While Stockton is discussed throughout the report and the results of modelling suggest the area is impacted by industrial emissions, it is not included in the recommended sites, and it is unclear why this is the case.

Briefing Paper: Options Proposed for Newcastle Industry Air Quality Monitoring Sites, OEH (November 2012)

The OEH has considered the PAE Holmes (2011) report, and has determined final monitoring stations at:

Mayfield;

Carrington; and

Stockton.

This represents some departure from the sites identified by PAE Holmes (2011) with Warrabrook and Fern Bay being excluded and Stockton being included.

With respect to Warrabrook the briefing paper states that Mayfield site options were considered to adequately cover impacts at Warrabrook. Giving the proximity of Warrabrook to Mayfield, having one site at Mayfield to represent both localities is considered reasonable.

In terms of Fern Bay the briefing note states “Accessible land suitable for monitoring stations in Fern Bay was very limited. The two initial Fern Bay sites assessed were some distance from residences and only exposed to industrial emissions under winds from the southwest quarter (autumn and winter). A third site off Vardon Road is better exposed to industries on Kooragang Island and is in the Fern bay community.” Additional advice provided by email from the EPA on 16 April 2014 further states with respect to excluding Fern Bay that in


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addition to the difficulty in finding a suitable site that “the relatively low population in Fern Bay assisted in making the final decision.” The initial difficulty in finding a monitoring site at Fern Bay appears to have been overcome by the site off Vardon Road. With respect to the low population in Fern Bay, this is an important consideration when assessing the cost effectiveness of the NLAQMN. However, the results of modelling presented in the PAE Holmes, 2011 report suggest Fern Bay may often experience higher impacts than other localities in particular higher than in nearby Stockton, as such further consideration as to why Fern Bay should be discounted is recommended. Further consideration should include the proposed increase in residential development in and around Fern Bay.

2.2 Lower Hunter Ambient Air Quality Review of Available Data 2012 (OEH2012/0281)

This report was prepared by the OEH in response to the August 2011 Orica incident in Newcastle. Specifically the NSW Government announced a series of legislative reforms and other initiatives to improve the environmental performance of industry in NSW, and community access to information about industrial activities and any incidents that occur at industrial sites. One of these initiatives was the proposal for the establishment of an industry-funded environmental monitoring network in the Lower Hunter, with the initial focus on the Newcastle Local Government Area (LGA).

To give effect to this initiative, on 9 October 2011 the Minister for the Environment, Robyn Parker MP, directed the EPA under s295Y of the Protection of the Environment Operations Act 1997, to immediately commence an investigation into the need for an environmental monitoring program in the vicinity of the heavy industrial precincts within the Lower Hunter area, including but not limited to the suburbs of Stockton and Mayfield, where a cluster of industries may be having significant cumulative impact or impacts on populations centres and the environment more generally.

Specifically the EPA was to investigate:

Whether pollution impacts are occurring or have the potential to develop in the area;

The nature of those impacts (such as cumulative, hot spot or site-specific);

The type of pollutant(s) that appear to be causing the impacts and in general where they are occurring;

The need for a program to monitor the identified pollutants; and

Whether the program should be funded by licence holders or particular classes of licence holders.

In conducting the investigation the EPA was to consult with industry and relevant communities and report its findings to the Minister by March 2012. The Lower Hunter area includes the Local Government Areas of Lake Macquarie, Newcastle, Cessnock, Maitland and Port Stephens.

The initial focus of the investigation will be for an air quality monitoring network (expanding on the existing regional network) in the Newcastle Local Government Area.

The OEH report relates to the investigation of an air monitoring network, and includes:

Air quality standards and goals;

A summary of monitoring stations operated by the EPA, ANSTO and industry monitors, and pollutant data recoded at these stations;

An air emissions inventory review; and

A facility prioritisation analysis.

The report summarises monitoring data using colour coding as indicators for the level of compliance with relevant ambient air quality goals. Colour-coding indicators for each pollutant considered are categorised as follows:


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Green indicates that the all monitoring stations consistently recorded levels less than relevant air quality criteria

Yellow indicates that only one monitoring station infrequently recorded levels above relevant air quality criteria (taking recent years into account)

Orange indicates that either:

more than one monitoring station infrequently recorded levels above relevant air quality criteria (taking recent years into account); or

at least one monitoring station occasionally recorded levels above relevant air quality criteria

Appendix C provides a summary of monitoring data analysis, and for the pollutants proposed for monitoring by the NLAQMN the following is concluded:

NO2 Regional and local nitrogen dioxide levels comply with Ambient Air Quality NEPM goal.

PM10 Regional PM10 concentrations generally comply with the Ambient Air Quality NEPM goal. PM10 concentrations at the OEH Beresfield, Newcastle and Wallsend sites are consistent with other urban areas in NSW.

Local PM10 levels are generally consistent with regional levels. The exception is elevated PM10 at Mayfield 4 berth.

PM2.5 Regional PM2.5 concentrations generally comply with the Ambient Air Quality NEPM advisory reporting standard. PM2.5 concentrations at the OEH Beresfield and Wallsend sites are consistent with other urban areas in NSW.

Local PM2.5 levels at Mayfield ASP are consistent with regional levels.

SO2 SO2 levels exceed the Ambient Air Quality NEPM goals at the School Drive monitoring site in the vicinity of the Tomago Aluminium Smelter. There are occasional exceedances of the SO2 Air NEPM goals at the Farm monitoring location in the vicinity of the Tomago Aluminium Smelter.

Based on this analysis, there is a strong case for the proposed PM10 and PM2.5 monitoring given that these pollutants are, on occasions, measured in concentrations which approach or exceed ambient air quality criteria.

With respect to NO2, existing ambient concentrations comply with relevant criteria, and as such additional explanation is needed in terms of why this pollutant is proposed for monitoring as part of the NLAQMN.

In terms of SO2, with the exception of local impacts from the Tomago aluminium smelter, which are considered to be outside the study area of the NLAQMN (this is discussed further in Section 2.3 to follow), existing SO2 ambient concentrations comply with relevant criteria, and as such additional explanation is needed in terms of why this pollutant is proposed for monitoring as part of the NLAQMN.

In terms of the air emissions inventory (2003 base year) key findings are as follows:

Motor vehicles are the dominant source of CO, NOX and VOC emissions;

Orica is a significant source of PM10 and PM2.5, and of a similar scale to emissions from wood heaters in the Newcastle Local Government Area; and


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Commercial ships are the dominant source of SO2 emissions. It should be noted that as the inventory analysis is for the Newcastle Local Government Area, it does not include emissions from the Tomago Aluminium Smelter.

The results with respect to PM10 and PM2.5 are somewhat surprising, noting that particle emissions from Orica (Agricultural Fertilizer and/or Ammonium Nitrate) are reported at 210,293 kg/year are higher than the reported emissions from the coal loading eg. PWCS at 225 kg/year.

Orica also reported relatively high NOX emissions at 1,056,166 kg/year providing some basis for including NOX/NO2 within the NLAQMN, and the reported dominance of commercial shipping to SO2 emissions in the area provides some support for including SO2 within the NLAQMN.

The report includes a facility prioritisation analysis that provides an analysis of air emissions data based on the 2003 calendar year for industrial facilities in the NSW Greater Metropolitan Region in 2007. The methodology used to prioritise facilities followed the California Air Pollution Control Officer’s Association (CAPCOA) Air Toxics “Hot Spots” Program Facility Prioritisation Guidelines (CAPCOA, 1990; SCAQMD, 2005a; SCAQMD, 2005b; SCAQMD, 2005c; and SCAQMD, 2004). This analysis prioritised industrial facilities according to potential short and long-term health effects. The stated aim of this analysis was to confirm if the EPA was continuing to appropriately target its regulatory activities. The priority pollutants identified are not those being targeted by the NLAQMN and include:

Polycyclic Aromatic Hydrocarbons (PAHs);

Benzene;

Arsenic and compounds;

Acrolein;

Formaldehyde; and

Chromium (VI) compounds.

While the report provides a detailed analysis of air quality monitoring data and air emissions, the results are not used to provide an initial focus or recommendation for an air quality monitoring network (expanding on the existing regional network) in the Newcastle Local Government Area, which is a stated objective of the report.

2.3 Newcastle Local Ambient Air Quality Monitoring Network Revised Funding Model Draft Discussion Paper Version 2 Sept 2013

2.3.1 Overview

The proposed NLAQMN funding model is described in a Draft Discussion Paper - Newcastle Local Ambient Air Quality Monitoring Network Revised Funding Model dated September 2013.

As per the decision from the EPA that a Regulation be made under Section 295Z of the POEO Act, development and operation of the network will be dependent on industry funding. As such, a model is required to enable funding contributions to be equitably allocated across relevant industries.

The discussion paper notes that “the EPA identified sulphur dioxide (SO2), nitrogen oxides (NOx) and fine particulate matter smaller than 10μm (PM10) as the National Environment Protection Measure (NEPM) priority (or target) pollutants to be monitored if a local air quality monitoring network was to be developed. Consideration should also be given to monitoring 2.5 μm (PM2.5) particles”. As per comments made in Section 2.1 and Section 2.2 it is not clear where the EPA identify these pollutants specifically to be the focus of NLAQMN, although it is acknowledged that the review of existing monitoring and emissions inventory data suggest these to be a reasonable choice of pollutants to be monitored.

The EPA has considered the National Pollutant Inventory (NPI) and the Air Pollutant Inventories (API) for the Greater Metropolitan Region in NSW as source data for determining industry contributions to a network funding


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model. API data are available for the broadest range of industry types and has been used in the funding models. This approach is agreed and supported.

Key points justifying the establishment of the NLAQMN identified by the EPA are:

The NSW 2021 Goal 22 to ‘Protect our Natural Environment’ establishes a Target to ‘Provide information to local communities on air quality’.

The Lower Hunter Regional Planning Strategy 2006-31 foreshadows an increase in population growth in population centres in the Newcastle LGA and the projected expansion of industrial and port-related development.

In the Newcastle LGA there are large number of EPA licensed industries, many with air pollution emissions.

Many of the existing industry operated air quality monitoring stations sites are not capable of providing continuous monitoring data and the proposed collaborative approach for a NLAQMN provides a more cost effective model for industry.

The establishment of a local ambient air quality monitoring network with near real time data would support the rationalisation of redundant monitoring sites and reduce the cost to industry to operate and publish data from these sites.

NSW Health (2012) recommended to the EPA “that there are potential benefits in rationalising the current industry monitors in the region into a systematic, well designed network of monitors that are situated on both industrial and residential sites in the Newcastle Port Precinct” and that “ air quality data from the network be publically available.”

In 2012 the Minister for the Environment and the EPA received a number of representations from community interest groups and media interest seeking improvements in air quality monitoring and community access to air quality data in the Newcastle LGA.

The NCCCE supports the concept of a local ambient air quality monitoring network for the Newcastle LGA.

These points of justification are considered to provide a sound basis for establishing the NLAQMN. Given some justification is to rationalise the cost of monitoring for industry it is recommended that the EPA provide a framework for industry as to how to undertake this rationalisation and remove redundant air quality monitoring from their regulatory requirements.

In terms of industry consultation, the EPA held two industry consultation meetings in September 2012 and March 2013 to discuss the funding model options and development of a monitoring levy to fund construction and establishment and maintenance of a local ambient air quality monitoring network (NLAQMN) for Newcastle LGA. The aim of these meetings was to brief industry on the outcomes of the investigation and to seek feedback about development of a strategic AAQMN and discuss how the EPA may levy industry.

The outcomes of these meetings led the EPA to believe that a voluntary Deed of Agreement with 51 premises would not be possible due to the diversity of industries and lack of an industry focus group with which the EPA could engage.

Based on consultation and investigations carried out to date, the EPA has determined that:

two monitoring stations would be constructed; one at Warrabrook / Mayfield (CSIRO Renewable Energy Facility) and one at Carrington (Reserve, Young and Hargrave Streets), with the negotiations with Orica for upgrading and including the current Stockton air quality monitoring station in the network;

the network would be constructed, operated and maintained by OEH;

EPA would progress to development of a Regulation and stakeholder consultation process to levy monitoring funds for construction, establishment, operation and maintenance of the AAQMN; and

that funding model option two would be used as the basis for the levy with a contribution threshold of $100.


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As per comments made in Section 2.1 of this review report, further justification as to why the Fern Bay site has been excluded is recommended, given the initial investigations to find a suitable site and the public consultation that occurred with respect to establishing a site at Fern Bay.

The initial estimated cost to establish three monitoring stations is $912,000 and the estimated annual operating cost for three monitoring stations is $474,000. The funding model identifies at the present time that 44 premises would be required to contribute to the network in the order of between $200 to $294,000 per premises for construction and establishment of the network and between $100 to $164,000 per premises per year to operate and maintain a network.

Section 295Z of the POEO Act makes provision for a Regulation by the EPA to require specified licence holders, or a specified class of licence holder, to pay to the EPA a contribution towards the cost of environmental monitoring programs.

The EPA has drafted the Protection of the Environment Operations (General) Amendment (Upper Hunter Air Quality Monitoring Network) Regulation 2012 to require the mining and power generation industries in the Upper Hunter to fund the Upper Hunter Air Quality Monitoring Network. This draft regulation provides a template for a Regulation to establish a local ambient air quality monitoring network in the Newcastle LGA.

The discussion paper, developed by the EPA, is a summary of the recommendations and preferred funding model. It is a revision of the previous discussion paper dated January 2013 that was previously sent to premises, and that was the subject of discussions at the March 2013 industry consultation meeting.

2.3.2 Funding Model Details

As outlined above the EPA considered both the NPI and the API for the Greater Metropolitan Region in NSW as source data for determining industry contributions to a network funding model. API data have been chosen for use as it is available for the broadest range of industry types. This approach is agreed and supported.

Two funding models with various options were considered. Costs incurred by the OEH to establish and operate the Upper Hunter Ambient Air Quality Monitoring Network have been considered as a guide to cost the Newcastle network. Funding model option two, which is the preferred funding model, splits and separately apportions the site establishment and building costs, and the cost to install and operate specific pollutant monitoring equipment. The site and operating costs are distributed between industry stakeholders as a percentage of total emissions. The costs to install and operate specific equipment to monitor the target pollutants (PM10, NOx and SO2) are distributed as a percentage of each industry’s contribution to each target pollutant.

A conceptual model for determining individual industry contributions to the capital, operating and maintenance cost of a local area ambient air quality monitoring network for the Newcastle LGA, including assumptions, is as follows:

API (EPA 2012) data are used as the base for determining the percentage establishment, operating and maintenance cost contributions for each remises funding the network;

where State scale API data are not available, NPI data (2010-11) is used for that facility where the premises reports NPI data;

where API and NPI facility data are not available, surrogate premises industry emissions contribution from API data are used, proportionate to the activity scale;

for premises where no API or NPI data are available, each premises would be invited to provide the EPA with its emission contributions recorded over a 12 month period to refine the model;

industry, rail and shipping emissions data are summed to provide a total Newcastle LGA emission for each pollutant, as the basis for determining percentage contributions;


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other pollutant sources not regulated by the EPA such as transport, domestic and commercial data cannot be taken into consideration in the funding model as the EPA cannot levy non-scheduled activities or motor vehicle owners to fund the network;

locomotive contributions are attributed to the rail network owned / operated by Australian Rail and Track Corporation (ARTC); and

shipping contributions derived from the ‘off-road mobile’ sector category within the emissions inventory are attributed to industries in accordance with the activity scale for the scheduled activity ‘shipping in bulk’ (there may be options to base the contribution on shipping movements per year, as an alternative) and the shipping proportion per pollutant is added to the industry component as a total contribution from that premise.

Jacobs SKM has not been provided with an electronic version of the funding model. As such our review, and the following comments, exclude any detailed calculation checks of emission and funding contributions attributed to specific industry.

In general:

the proposed model concept of allocating NLAQMN costs proportionally to industries emitting each of the pollutants to be monitored, as function of the their percentage contribution to total emissions is considered reasonable;

the inclusion of all industries in the LGA within the funding model is questionable, noting that the investigations into the location of monitoring stations, namely the review of meteorology and modelling by PAE Holmes (2011), focussed on the “Newcastle Inner City and Port Neighbourhood”. It is recommended that further investigation is undertaken; for example, to assess industry source apportionment to impacts at each of the proposed monitoring stations as a means of allocating costs;

in terms of shipping emissions the approach used by the model is to allocate these to industry that have a ‘shipping in bulk’ scheduled activity. This is further explained in Part 2 appendices to the discussion paper, where in Appendix 6.1 Table A17 costs are apportioned as follows:

0 – 100,000 T/yr - 1 x costs

100,000 – 500,000 T/yr - 2 x costs

> 500,000 T/yr - 3 x costs

> 5M T/yr - 4 x costs

The suggested alternative approach, whereby costs are attributed to shipping movements (including ship type) is preferred, as this will more accurately reflect total emissions from ships serving the individual industries.


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3. Review of Fit for Purpose and Cost Effective Monitoring 3.1 Overview

The EPA has provided equipment specification and cost details for the NLAQMN. The specification and costings are included in Appendix D.

With respect to the costs data, this review is to focus on whether the NLAQMN is fit for purpose and represents value for money with respect to:

Monitoring site infrastructure;

Monitoring equipment;

Network maintenance program; and

Telemetry, data processing and graphical user interface.

3.2 Instrument Specifications

In terms of assessing if the monitoring specification is fit for purpose, a key requirement is that the proposed monitoring instrumentation meets relevant standards.

3.2.1 Particle Monitors

To meet relevant standards particulate monitors would need to either be:

PM10 and PM2.5 Tapered Element Oscillating Microbalances (TEOMs); or

PM10 and PM2.5 Beta Attenuation Mass monitors (BAMs).

The following minimum standards are needed for the instruments:

Instrument Type Minimum Compliance Standard

PM10 TEOM AS3580.9.8 (2008): Determination of suspended particulate matter – PM10 continuous direct mass measurement using a tapered element oscillating microbalance analyser.

PM10 BAM AS/NZS3580.9.11 (2008): Determination of suspended particulate matter – PM10 beta attenuation monitors.

PM2.5 TEOM AS3580.9.13 (2013): Determination of suspended particulate matter – PM2.5 continuous direct mass measurement using a tapered element oscillating microbalance analyser.

PM2.5 BAM AS/NZS3580.9.12 (2013): Determination of suspended particulate matter – PM2.5 beta attenuation monitors.

The EPA costings for the NLAQMN indicate the following instruments have been selected:

PM10 - TEOM Thermo1405 – which is compliant with AS3580.9.8 (2008); and

PM2.5 - BAM Thermo 5014i – which is compliant with AS3580.9.2.12 (2013).

It is recommended that the EPA provide a justification for using TEOMs for PM10 and BAMs for PM2.5, considering both cost and consistency of measurement technology, compared with say a combination of either BAMS or TEOMs being used for both particle size ranges.


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3.2.2 NOX Monitors



NO2 Ambient AS 3580.5.1 (2011) Determination of oxides of nitrogen— Direct reading instrumental method

The EPA costings for the NLAQMN indicate the following instrument has been selected:

Teledyne API Model T200 Chemiluminescence NO/NO2/NOX Analyzer

The proposed instrument meets the requirements of AS 3580.5.1 (2008).

3.2.3 SO2 Monitors



SO2 Ambient AS 3580.4.1 (2008) Determination of sulphur dioxide— Direct reading instrumental method

The EPA costings for the NLAQMN indicate the following instrument has been selected:

Teledyne Model API T100 UV Fluorescence SO2 Analyzer

The proposed instrument meets the requirements of AS 3580.4.1 (2008).

3.2.4 Meteorological Sensors and Mast

The wind instruments must comply with the minimum standards listed in:

AS3580.14.1- 2011 Methods for sampling and analysis of ambient air Part 14: Meteorological monitoring for ambient air quality monitoring applications.

Wind speed and direction is to be measured at a height of 10 m, at the top of a mast.

The proposed installation includes:

Taperline mast;

MetOne 50.5 solid state wind sensor (+calibration cert); and

Vaisala HMP155E x 2 temperature and humidity probe plus radiation shield.

The proposed instruments meet the requirements of AS3580.14.1 (2011).


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3.3 EPA Cost Estimates

A summary of the EPA costing for establishing and operating 1 x NLAQMN monitoring station are outlined below. Also outlined are the Jacobs SKM estimate of costs and a ranking of EPA costs as either “High”, “Reasonable” or “Low”.

Equipment and establishment costs:

In terms of the Jacobs SKM cost estimates we have sourced estimate costs from equipment suppliers for the higher costs items eg. portable building, and pollutant analysers. In cases of other lower cost items we have reviewed the EPA costs and applied our professional judgement as to whether the EPA costs are reasonable or not. The “Jacobs Est. 1” provided costs estimates for identical items to those offered by the EPA. In “Jacobs Est. 2” we have assessed cost based on PM10 and PM2.5 being measured by the one instrument – a Dichotomous TEOM, which is Australian Standards approved.

The EPA “Actual” costs (assumed to be GST exclusive) total $292,550 per site. In general equipment costs are considered reasonable for establishing new monitoring stations. The main exceptions where costs are considered high are:

Portable building;

PM10 / PM2.5 analysers; and

SO2 analyser.

It is recommended that the EPA provide additional information with respect to the cost of these items in particular so as to resolve the differences in cost estimates.

Further information is also requested with respect to the one-off data management (software) cost and what this relates to, acknowledging that operation costs per annum for data management are also included in the model.

A contingency of $25,000 per site is allowed for. This is approximately 9% of the total equipment and establishment costs, and is considered a moderate to high estimate, given, the majority of items will be fixed price items and suppliers and installers would be expected to manage costs within agreed budgets.


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It is understood that the EPA will inherit the existing Stockton monitoring station from Orica, and re-establish the station. The EPA’s preferred approach is to replace the entire station so it meets the same standard and specification of the other proposed NLAQMN stations. Consideration has been given to re-using some components and two options are presented as follows:

Option 1 Do not upgrade particle samplers. Note that this is a short-term option as both samplers will need to be replaced sometime in the next 2-3 years in any case

Estimated cost = $65,300

Option 2 Upgrade all PM samplers and replace existing shed Estimated cost = $157,300

A full breakdown of the Stockton monitoring station costs is included in Appendix D. We agree with the EPA that the particle samplers should be upgraded. The existing shed could continue to be used. In this case the estimated cost would be $126,800.

Operation and maintenance costs per annum:


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The following comments are made on the operation and maintenance costs:

Table C – costs are considered reasonable;

Table D – these are annualised replacement costs for the various analysers, assuming they are replaced every four years. It is recommended the EPA provide some benchmarking of analyser replacement with consideration of their other existing monitoring stations; and

Table E – as per comments with respect to equipment and establishment costs it is recommended that the EPA provide clarification as to if or how the monitoring officer costs at $55,222 relate to the $50,000 one off data management costs.


Appendix A. EPA Project Brief


Appendix B. Project Plan – NLAQMN Cost Effectiveness Review

Jacobs SKM L2/710 Hunter Street NEWCASTLE WEST NSW 2302

T +61 2 4979 2600 F +61 2 4979 2666 www.jacobsskm.com

Jacobs SKM Sinclair Knight Merz Pty Limited ABN 37 001 024 095 Jacobs® is a trademark of Jacobs Engineering Group Inc.

Filename: Project Plan - Newcastle Local Ambient Air Quality Monitoring Network_v1 1 Document no.: 1

Natasha Ryan Environment Protection Authority 117 Bull Street NEWCASTLE WEST NSW 2302

9 April 2014 EN04425

Dear Natasha,

Re: Project Plan and Information Request - Independent Review of Cost Effectiveness of Newcastle Ambient Air Quality Monitoring Network

This document sets out the Project Plan and a Request for Information (RFI) consistent with our proposal dated 24 March 2014.

Yours sincerely

Matt Davies Senior Executive +61 2 4979 2616 | [email protected]

mailto:[email protected]

Environment Protection Authority Re: Project Plan and Information Request - Independent Review of Cost Effectiveness of Newcastle Ambient Air Quality Monitoring Network 9 April 2014


Project Plan

To provide a project plan that is an active document to be used as a management tool to drive the successful delivery of the project. The project plan will be agreed at an inception meeting.

Introduction to the project The NAAQMN will consist of three (3) monitoring stations to be located at Stockton, Warrabrook/Mayfield and Carrington. The pollutants to be monitored include particulate matter (PM10 and PM2.5); nitrogen oxides (NOX); and sulphur dioxide (SO2). Additionally we understand meteorological parameters will also be measured at each site.

The EPA decided that a Regulation should be developed to levy funds from industry to construct, maintain and operate the NAAQMN in accordance with section 295Z of the POEO Act. In accordance with Section 295 (6) “the EPA is to obtain, and take into consideration, advice from one or more independent persons or bodies with relevant technical and health expertise as to the cost effectiveness of any environmental monitoring program.”

Description of the key drivers To ensure the proposed NAAMN is cost effective in terms providing regional air quality data considering a framework whereby industry are funding the network to be procured, constructed and operated by the EPA. Key drivers are whether the NAAMN is fit for purpose and represents value for money with respect to:

Monitoring site infrastructure

Monitoring equipment

Network maintenance program

Telemetry, data processing and graphic user interface

Key deliverables and dates Draft report – 28 April 2014

Final Report – 12 May 2014

Note: dates subject to requested information being received by 14 April 2014

Methodology As per proposal dated 24 March 2014

Project team and governance As per proposal dated 24 March 2014 – PM: M Davies, PD: J Moore, Peer Review: S Lakmaker

Project budget $14,889 ex. GST

Project quality assurance Peer review at Draft Report stage. Project Director review at Final Report stage

Environment Protection Authority Re: Project Plan and Information Request - Independent Review of Cost Effectiveness of Newcastle Ambient Air Quality Monitoring Network 9 April 2014


RFI No. 1

The documents provided to date by the EPA have been reviewed and the following questions are submitted:

Document: Questions:

1. RFQ dated 19 March 2014 a. The RFQ refers to the existing Stockton monitoring station as not complying with the EPA Approved Methods. Can supporting information related to non-compliance be provided.

2. Newcastle Local Ambient Air Quality Monitoring Network Revised Funding Model Draft Discussion Paper Version 2 Sept 2013.

b. Section 2 “Pollutants to Monitor” refers to an EPA commissioned detailed analysis of pollutant inventory data, can this report be provided.

c. Section 3.1 states “industries are invited to review how the contributions are proportionally attributed and suggest alternative methods”. – what is the timeframe for this process.

d. Section 4.3 outlines air quality monitoring station costs and states these are derived from the UHAMN and other monitoring stations. Can actual equipment make and model be provided, and any quotations for equipment sought specifically for the NAAMN.

e. Section 4.4 sets out the formulae for the funding model. Can any spreadsheets containing the formulae and cost data be provided.

f. Section 4.5 “Contingency” – please advise timing for finalising the method for allocating contingency.

g. Section 4.6 Scenario 2, please confirm that the reference to $100 in paragraph 1 should be $1000.

h. Section 7 Site Location Investigation refers to four monitoring stations including Fern Bay, which is not chosen for monitoring. Please provide justification for excluding Fern Bay.

3. Newcastle Local Ambient Air Quality Monitoring Network Funding Model Part 2 Appendices Version 2 Sept 2013.

None at this stage.

4. Lower Hunter Ambient Air Quality Review of Available Data 2012 (OEH2012/0281)

None at this stage.

5. Review of Meteorology in Newcastle Inner City and Port Neighbourhood 2011.

None at this stage.


Appendix C. Summary Pollutant Monitoring Data


Appendix D. NLAQMN Cost Information

Title

Description

Owner Matthew Riley

Created 15-Apr-2014

Contents

Worksheets

Contents

A

B

Version control

Number Date Author

1.0 15-Apr-2014 M. Riley

More information/References

Stockton - Upgrade costs

Comments

This summary is for Jacobs SKM and is to be used solely for the project - Independent Review of Cost Effectiveness of Newcastle Ambient Air Quality

Monitoring Network.

The information is provided in good faith based on actual quotes for goods and services (where available) or estimates of costs based on previous

construction of air quality monitoring stations. Costs are based on constructing or upgrading instrumentation and station design and fit-out to

comply with current specifications of the OEH AQMN.

Cost estimates for the NPAQMN

Description

Cost breakdown for new stations in the NPAQMN

Contents

I:\ENVR\Projects\EN04425\Technical\NPAQMN Costs - For SKM_MD2

Contents

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Title: Cost breakdown for new stations in the NPAQMN

Source: OEH - Climate and Atmospheric ScienceAuthor: Matthew RileyNotes:

Item Details EPA Estimated EPA Actual Jacobs Est. 1 Jacobs Est. 2 EPA Cost RankTable A Portable Building ATCO $19,000 $29,000 $15,000 $15,000 High

Sampling system Custom Blown Glassware $1,070 $450 $1,000 $1,000 Low

Air Conditioning Fujitsu $2,460 $1,650 $1,500 $1,500 Reasonable

Rack Mounting Gilkon $5,350 $1,500 $2,000 $2,000 Reasonable

3G Modem and antennae Digi WR44-R $1,285 $1,400 $1,200 $1,200 Reasonable

Site est slab etc $16,000 $16,000 $16,000 $16,000 Reasonable

Site est electrical $16,000 $16,000 $16,000 $16,000 Reasonable

REF and approvals $7,000 $7,000 $7,000 $7,000 Reasonable

Fencing and landscaping $16,000 $16,000 $16,000 $16,000 Reasonable

Multi component gas cylinder Scott Marrin $1,600 $2,050 $2,000 $2,000 Reasonable

Meterological equipment and mast Taperline, MetOne 50.5 (+calibration cert),

Vaisala HMP155E x2, Radiation Shield

$16,000 $13,250 $12,000 $12,000 Reasonable

Data logger ARK 3360F, Digi CPTS-4MW-R $5,350 $3,750 $5,000 $5,000 Reasonable

Chart recorder Not required $8,560 $0 $0 $0 NA

Diluter Environics EV6100 $7,700 $11,000 $11,000 $11,000 Reasonable

Zero data Generator Environics EV7000 $6,100 $7,000 $7,000 $7,000 Reasonable

Contingency $25,000 $25,000 $25,000 $25,000 Reasonable

Sub total $154,475 $151,050 $137,700 $137,700Table B NOx analyser API T200 $10,700 $14,000 $12,000 $12,000 Reasonable

PM10 analyser (PM10/PM2.5 analyser) Thermo 1405 (1405 D, DF) $39,000 $34,000 $29,000 $45,000 High

PM2.5 analyser Thermo 5014i $39,000 $27,500 $22,000 High

SO2 analyser API T100 $10,700 $16,000 $12,000 $12,000 High

Sub total $99,400 $91,500 $75,000 $69,000Data management (software) One off $50,000 $50,000 $50,000 $50,000 NA

TOTAL $303,875 $292,550 $262,700 $256,700 High

This summary is for Jacobs SKM and is to be used solely for the project - Independent Review of Cost Effectiveness of Newcastle Ambient Air Quality Monitoring Network.

The information is provided in good faith based on actual quotes for goods and services (where available) or estimates of costs based on previous construction of air quality monitoring stations completed recetly by OEH (e.g. Wyong, Camden). The instrumentation and station

design and fit-out complies with current specifications of the OEH AQMN.


A

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Title: Stockton - Upgrade costs

Source: OEH - Climate and Atmospheric ScienceAuthor: Matthew RileyNotes:

OEH data loggerOriginal Estimated

CostOption 1 Option 2

compatible $ $ $

Data logger/telemetry No N/A Replace with OEH inhouse logger/telemetry $6,000 $4,000 $4,000

TOTAL $88,000 $65,300 $157,300

The current shed at Stockton is small compared with OEH standard monitoring stations. This limits the number of samplers that can be installed due to AS requirements for seperation of smplae manifolds.

OEH can work with the existing portable building but will require some work to ensure that roof top access and work platform conforms to OEH WHS requirements.

The orginal cost estimate only included upgrading one particle sampler. Both of the current PM samplers are old units and do not represent state-of-the-art instrumentation. Two options can be explored:

Option 1 - Do not upgrade particle samplers. Note that this is a short-term option as both samplers will need to be replaced sometime in the next 2-3 years in any case.

Option 2 - Upgrade all PM samplers and replace existing shed.

This summary is for Jacobs SKM and is to be used solely for the project - Independent Review of Cost Effectiveness of Newcastle Ambient Air Quality Monitoring Network.

The information is provided in good faith based on actual quotes for goods and services (where available). These estimates reflect likely costs to upgrade the current Stockton site instrumentation and station design and fit-out to comply with current

specifications of the OEH AQMN.

Existing equipment Meets Australian Standards Recommendation

Bam 1020 (PM2.5) No Yes This is an old instrument. Replace with existing monitoring network 5014i $27,000

Ecotech Serinus NOX/NH3 analyser No N/A Replace with NOx analyser $12,000

1400 A TEOM (PM10) Yes Yes This is a very old instrument. It can be used but will need an upgrade in the very near future.

*Ecotech 8301LC zero air supply N/A Yes Replace with Environics to ensure compatibility with OEH network $6,000

*Ecotech Gascal 1100 (calibrations) No Yes Replace with Environics to ensure compatibility with OEH network $8,000

Thermal oxidiser NH3 to NOx N/A N/A These have a slow response and bad efficiency.

*1 Clark mast with sonic anemometer N/A No Replace with Taperline met mast and Meteorology, RH/Temp, anemometer $15,000

SO2 analyser N/A N/A Currently no SO2 installed. $12,000

Portable building 2.3m by 3.3m N/A Yes Useable, however limited in space 2.3m by 3.3 m. Platform and stairs do not comply with OEH WHS standards.

$12,000

$11,000

$7,000

gas bottles Nox, Ammonia NH3) N/A Need multicomponent cylinder for NOx, SO2 $2,000

$27,500

$34,000

$12,000

$11,000

$7,000

$13,250

$16,000

$2,050

$13,250

$30,500

$16,000

$2,050


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