Transcript MS PowerPoint format, 2.7MB - RAPS Inc. Multimedia

Why is an air quality improvement plan needed?
• Because of constant complaints about conditions inside
the tunnel and evidence of actual harm to motorists.
• Because of the regular tunnel closures due to degraded air
quality and rising CO levels.
• Because of regular reports of ill effects outside the tunnel
due to stack and portal emissions.
• Because portal emissions have been occurring on a
regular basis, as described in the Holmes report on the
impact of portal emissions.
The RTA $50 million plan has 4 main parts:



?
Video cameras to track and fine smoky
trucks to reduce emissions.
Extra jet fans for better air flow control.
Portal emissions ( blowing unfiltered air
out of the tunnel ends at ground level) to
allow for extra fresh air into the tunnel.
A ‘trial’ of filtration equipment at the west
end of the west-bound tunnel to reduce
‘haze’.
The RTA submission to Planning goes far
beyond the air quality improvement plan:
It proposes to disband the AQCLG and replace it with
an ill defined‘Community engagement strategy’,
without the defined powers and responsibilities of the
current AQCLG.
 It calls for a number of changes to the conditions of
approval, far beyond those needed to account for the
technical changes proposed.
It proposes to remove many of the protections
provided in the existing CoA and to significantly
reduce RTA accountability to the public.
Although RAPS is supportive of some aspects of the RTA
proposal it has made a submission to Planning critical of:
• The proposal for portal emissions
• The use of portal emissions as a tool to improve in-tunnel air quality
• The assumptions about air quality and the continued inappropriate
use of the NEPM goals as a performance goal for tunnel emissions
• The quality, methodology and inadequate nature of the health risk
assessments
• The inappropriate and wasteful technical proposal for filtration in the
westbound tunnel
Will it improve the air in the tunnel?
Filter
• Probably yes. The pollution level inside the tunnel
will be roughly halved.
• The stack emissions should be reduced by 40%
The RTA plan may ‘work’ for those inside the
tunnel, but not for those outside the tunnel:
• Portal emissions will significantly increase the impact of
harmful diesel fumes on people living round the tunnel
portals.
• Around $45 million is spent on fixing 1/3 of 1/4 of the
“haze” problem in the tunnel.
• The remainder of the problem is ‘fixed’ by dumping the
diesel emissions out of the portals at ground level.
• There is no guarantee that the filters will be kept working
after the one year ‘trial’.
The RTA proposal is aimed solely at improving in-tunnel
conditions for motorists.
The stated aim is to remove the ‘perception’ of a
problem with ‘haze’ and to reduce tunnel closures
due to bad air quality.
But ‘Haze’ is not harmless!!!
It is made up largely of diesel particle emissions which
cause asthma and lung irritation and are now known to
trigger heart attacks and cause cancer .
According to the California Office of Environmental Health
Hazard Assessment its cancer risk factor is 3 in 10,000
for every 1µg/m3 increase in exposure.
The RTA EIS document predicts that the
portal emissions will represent an
increase in PM10 at the worst location of
0.6µg/m3 per year.
This is claimed to represent an increased
mortality risk of 1 in 20 million.
The RTA compares this with the lifetime risk of
being killed by lightning, which is 1 in 1.6 million
This claim is insulting, misleading
and, above all, incorrect!
It is contrary to the advice given by NSW Health and the
EPA about the potential dangers of portal emissions.
The risk of 1:20 million claimed by the RTA is a ‘daily’ risk
not a ‘lifetime’ risk as is required by the EPA.
The corrections placed on the RTA web site are still
inadequate and misleading. They still compare daily with
lifetime risks
Diesel exhaust is a specific and separate hazard:
“Significant health risks are associated with carcinogenic toxic
air contaminant emissions in vehicle exhaust. The most
significant carcinogenic toxic air contaminants in vehicle
emissions are 1,3-butadiene and benzene from gasoline
fueled vehicles, and diesel PM from diesel-fueled vehicles.”
Appendix to the Draft Recommended Protocol for Evaluating the Location of Sensitive Land Uses Adjacent to
Major Roadways. Sacramento Metropolitan Air Quality Management District
BUT
The list of toxic air components used currently by the NSW
EPA, although it includes the same risk factors for Benzene
and 1.3 Butadiene as does the OEHHA, DOES NOT
INCLUDE DIESEL EXHAUST AS A TOXIC AIR
COMPONENT.
California Hot Spots regulation:
•California, with its well known pollution problems and its concentration of
active research institutions is acknowledged a leader in air pollution
science.
•California recently introduced the “Hot Spots” Act which is designed to
provide information to state and local agencies and to the general public on
the extent of airborne emissions from stationary sources and the potential
public health impacts of those emissions.
•A diesel 'hot spot' is a facility which uses more than 3000 US gallons
(about 11000 litres) of diesel fuel per YEAR. All types of 'facilities’ including
highways are included. This would clearly cover the M5 tunnel and its
emissions.
•Agencies in Australia , such as the NSW EPA, routinely follow the lead
given in regulation and hazard assessment by the California OEHHA
(Office of Environmental Health Hazard Assessment)
In 2003 the OEHHA listed diesel exhaust as a Toxic Air Contaminant
with a specific ‘unit risk factor’
This is of real significance to the M5 as the NSW EPA Approved
methods document notes "Dose response assessment and risk
characterisation can be undertaken in accordance with the following:
The Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk
Assessments (OEHHA 2003)
Hot Spots Analysis and Reporting Program (HARP) (CARB 2003a)
Hot Spots Analysis and Reporting Program – User Guide Version 1.0 (CARB 2003b).
• NSW EPA requires that carcinogenic risks be assessed on the
basis of 70 year exposure.
• It is clear that diesel exhaust is carcinogenic
• Its carcinogenicity is separate from and greater than the risks for
benzene and 1.3 butadiene, with which it may be associated
• There is no credible argument against the fact of diesel exhaust
carcinogenicity, the only argument being about the size of the risk
• The best available information is that given by the California
OEHHA
• Precautionary principles would DEMAND that this information be
used as the basis of the assessment of risk from the additional
emissions of diesel exhaust from the portals
The cancer risk of the increased emissions is
ignored in the RTA submission --- because the NSW
EPA has not included diesel exhaust in its list of
carcinogenic agents!
33 increase in particle
If
only
half
of
the
of
0.6
µg/m
If only half of the of 0.6 µg/m increase in particle
levels
levels is
is due
due to
to diesel
diesel exhaust,
exhaust, the
the increase
increase in
in lifelife-time
cancer
a million,
according
time cancer
riskrisk
is 90isin90a in
million,
according
to the
to
the California
OEHHA
guidelines.
California
OEHHA
guidelines.
This is 1,800 times greater than the risk claimed in the RTA.
It is 90 times the risk threshold specified by the NSW EPA!
The true risk of the tunnel has not been established
RTA proposals for the M5 AQCLG
• There are about 800
houses, and at least
4 blocks of units
within 500m of the
Bexley North portal!
• All will receive some
increase in pollution
from the portal
emissions.
• The impact at Marsh
St is similar.
• These people were supposed
to be represented by the M5
AQCLG
• For all of its imperfections, this
group has tried to represent all
who are affected by the tunnel
and its operation
• In the course of the 8 years
experience this group has built
up a significant body of
knowledge and expertise
In a move which seems completely unrelated to an ‘air quality
improvement plan’ the RTA proposes to disband the AQCLG in favour
of a vague ‘Community engagement strategy’, without the defined
powers and responsibilities of the current AQCLG.
• The committee’s role under the 1997
conditions ‘includes: input into
defining/formulating air quality
monitoring requirements; accessing and
disseminating monitoring results and
other information on air quality issues;
and associated potential impacts’
As a result of the AQCLG’s defined role, the RTA was compelled to
make available to the members information relating to the monitoring
stations, the operation of the stack and other details of tunnel
operation.
No provision is made in the new proposals for this
information flow, which enabled community members to
identify serious inaccuracies in the stack monitoring and
the occurrence of illicit portal emissions
The RTA claims:
• The AQCLG does not represent or meet the needs
of the broader community, in relation to the operational
aspects relating to the M5 East tunnel
• The AQCLG is considered an inadequate forum to
discuss broader policy issues.
• Issues are not resolved at AQCLG meetings, with a repetitious discussion
on issues of concern for particular AOCLG members.
• The AQCLG is not linked to the broader community or broader
communications process.
None of these claims stand up to serious examination, nor does the
proposed ‘community engagement strategy’ replace the role of
the M5 AQCLG
This is not to say that the AQCLG does not require reform , however
the role of the AQCLG must be maintained and strengthened
Inappropriate use of NEPM goals for regulatory purposes
Both the RTA and the Department of Planning seem determined
to continue to use the NEPM goal for particles for the regulation
of tunnel emissions.
This is in spite of the fact that NEPM goals are not suitable for
such a use.
The NEPM documentation is quite specific:
'‘Conversely, the air quality of some localised areas within major
airsheds are dominated by local activities such as that experienced in
a road tunnel or a heavily trafficked canyon street. Air quality
management in these areas is complex and needs a different approach
to that directed at meeting ambient standards intended to reflect the
general air quality in the airshed’ (p 13 from NEPM 1998)
Some time ago, RAPS approached the Executive Director of the
National Environment Protection Council, Dr. Bruce Kennedy, for an
assessment.
The reply he gave us leaves no room for disagreement:
‘The NEPM PM10 standard….is a legislative entity and applies
only to the ambient background, and a population of 25,000
people. It does not and should not, be applied to a point source
such as a tunnel stack from which an entirely different
composition of pollutant arises.’
The NEPM goals are no more suitable for measuring the impacts of
tunnel emissions than they would be for asbestos exposure - which is
also ‘particulate matter’!
A real plan for improving air quality must be assessed and
regulated using valid and appropriate measures
RTA ‘Filtration’ plan
Some cleaner air in the tunnel,
more dirty air out the portal
Tunnel pollution profiles for ‘RTA plan” showing:
•Unacceptable PM10 level at portal
•Mean trip exposure (not significantly reduced)
•Distance where PM10 exceeds 500µg/m3 (unacceptably high)
The RTA “filtration” plan extracts 200m3/sec air somewhere
along the tunnel, cleans it and returns it to the tunnel.
Unfortunately there is no single location which gives the stated
desired outcomes:
• Reduction of PM10 below 500µg/m3 (no visible pollution) for most
of the tunnel length
• Significant reduction or complete removal of pollutants from
portal emissions
• Preservation of the amenity of residents at the portal
In addition, the cost is inordinately high for the limited benefit gained
RAPS believes that the plan clearly fails to meet its
stated objectives and should be rejected
RAPS’ Plan
• There is an alternative to the RTA’s proposal…
The RAPS plan is based on the following principles:
• It is important to improve air quality both inside and
outside the tunnel.
• Unfiltered portal emissions are dangerous to health and
are unacceptable to local residents. They are inconsistent
with any form of air quality improvement plan as they
inevitably cause a deterioration in local air quality.
• The RAPS proposal does not aim to produce an optimal
ventilation system but is a rescue attempt to provide
acceptable outcomes both inside and outside the tunnel,
which is achievable without taking the tunnel out of use.
The RAPS ventilation plan consists of two
interrelated parts:
• 2 filtration stations, each capable of removing
both particles and nitrogen dioxide from
250m3/sec of tunnel air, located as close as
possible to the Bexley North and Marsh St
portals and ejecting clean air upwards.
• 3 ceiling mounted electrostatic precipitator
cleaning units each capable of cleaning 120 to
140m3/sec air, located 900, 500 and 250 m from
the Bexley North portal.
RAPS M5 filtration concept
Clean air inside and outside!
The RAPS plan is based on the following assumptions:
• Air supply and extraction rates at the stack are operating
at or close to maximum capacity.
• The addition of fresh air at the portals will significantly
improve air quality inside the tunnel - except for the west
end of the westbound tunnel.
• Removal of particles alone (without removal of nitrogen
dioxide) will significantly improve air quality in the
westbound tunnel
• Removal of particles must be done at several locations to
give satisfactory results.
Possible filter station locations
Footprints of possible filter station buildings at Bexley North and
Marsh St., Arncliffe located so as to access the tunnel below.
Both buildings are 35 x 10m .
The Marsh St building is located partially above the tunnel
control centre. The RTA has suggested an alternate, suitable
site.
Cleaning station concept based on filter station design by
CTA for Madrid air cleaning station.
• Cleaning capacity is for 250 m3/sec for both particles
and nitrogen dioxide
Particle level (“haze”) reduction in west bound tunnel.
Using in-tunnel filtration units in existing jet fan locations
• At each of 3 locations, 120-140m3/sec particle
cleaning (16 EP modules) fitted as shown.
• Air flow rates of >8m3/sec per module can be
achieved by using new power supplies with little loss
of efficiency.
• Wash down would require less than 1 hour per station
once a week.
Particle level (“haze”) reduction in west bound tunnel.
• 3 EP filter stations, each cleaning 140m3/sec, give
satisfactory results under the worst conditions.
• Results are significantly better (about 50%) than best ‘RTA’
outcome (however more equipment is involved).
• Installation is by extensive use of prefabrication for the
platform and cleaning units to minimise tunnel closure.
Economic aspects - operational
Additional costs.
Maintenance operations
Fans in cleaning station
Carbon replacement ($A200,000 pa)
•
•
•
Reduced costs.
•
•
Reduced fan usage (cross over fans, jet fans)
Night time operation (all main ventilation fans)
Night time WB
Nightime EB
PM10 µg/m3
250.00
A s is
Filter
300.00
250.00
PM10 µg/m3
300.00
200.00
159.22
150.00
100.00
76.62
200.00
150.00
100.00
101.77
85.85
50.00
50.00
0.00
0.00
0.00
A s is
Filter
0.50
1.00
1.50
2.00
2.50
distance
3.00
3.50
4.00
4.50
0.00
0.50
1.00
1.50
2.00
2.50
3.00
3.50
4.00
distance
Between 9pm and 5am tunnel can be operated in full longitudinal
mode with all main ventilation fans off and no stack emissions.
4.50
Environmental advantages of whole ‘plan’, including new
fans, increased air flows and ‘RAPS’ filtration solutions.
• No portal emissions.
• Reduction of in-tunnel particle (haze) levels by 30 - 50%,
depending on location.
• Reduction of stack emissions by about 40% (day time).
• Total removal of stack emissions between 9pm and 5 am (20%
of total emissions).
• Reduction of energy consumption by night time operational
changes: 10-15% (estimate).
This would represent a clear ‘win’
for the whole community, with everyone
gaining improved outcomes
Madrid worksite - PV2
NO2
carbon
EP
filter
Pre filter
Tunnel
SHAFT
Corona discharge