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Information on Nippon Paper

July 2014: Victorian Koala Issues, Plantations and Forest Stewardship Council Certification

September 12 2011: Just 1% of Central Highlands Old Growth Survives

August 23 2011: Reflex Paper Loses Green Tick of Approval After Native Timber Stoush

July - August 2011: Sylvia Creek Blockade

Feb 27 2010: Action At Maryvale Pulp Mill (Boycott Reflex Copy Paper).

New Information on Logging of Melbourne's Water Supply

June 16 2009: Australia Home to World Forest Carbon Winner

Feb 17 2009: Nippon Paper Buys Maryvale Mill

June 2008: Wilderness Society and Victorian National Parks Association Used as Corporate Patsies in $5.5 million Strzelecki Rainforest Destruction Deal

Two images of the Strzelecki Ranges Cores and Links Rainforest Reserve. The second image shows what will happen to the Reserve after being logged by Hancock Victorian Plantations largely to supply Maryvale Pulp Mill. 70%+ of the logs coming from the Reserve will end up being pulped for products such as Reflex Copy Paper.

May 31 2008: Strzelecki Rainforest Reserve to be gutted to supply Maryvale Pulp Mill with pulpwood for only two years

May 08: International based website highlights Strzelecki Rainforest Sham

Mar 07: F.S.C. Watch article

Reflex Copy Paper gains Forest Stewardship Council Mixed Sources Certification in July 06, but the certification totally ignores the native forest sources that are currently feeding the Maryale Pulp Mill.

Oct 06: 4 Corners exposes The A-Team and shafts Friends of Gippsland Bush


About us ##About Paperlinx??Paperlinx Forest Issues??Wood pulp agreement act?

?Map of logging areas??Eight point agreement??Mill Expansion Plans

Dioxins and Chlorine in the Paper Making Process??

Pulp and paper manufacturing process? 1996 EPA licence details

Discharge to Latrobe River Summary

Trade Waste Agreement

Mercury History Lesson

APM's Toxic Pesticide Legacy 2,4,5-T Here

Maryvale Mill in Gippsland (The heart and soul of PaperlinX) - Morwell in the background

About us:

The aim of this site is to provide information to the public about current mismanagement of forests by both the makers of Nippon Paper, and the Department of Natural Resources and Environment (Victorian Government). We are extremely concerned that our dwindling native forests - especially in the Gippsland and Central Highlands regions of Victoria - are being destroyed for the production of Reflex copy paper and other AP products. We are also alarmed at current plantation management by Paperlinx and have been forced to create this website to inform the general public about environmental issues involved with the manufacture of Australian Paper.

This website has been made by concerned citizens who four years ago embarked on a project to determine the source of Australian Paper products. Through the course of this project we have come across many many people concerned with similar issues. It is hoped that this website can be used by everyone to make informed decisions about their paper source and to educate themselves on the current situation of Victorian forest management. We are more than happy to add new information to this site as it comes to hand. We are also happy to provide examples of good forest management by Paperlinx and the DNRE.

This site is in no way connected with Nippon Paper or any companies associated with the production of paper in Australia. We like to see ourselves as corporate watchdogs providing up to date information about forests and paper production. Feel free to contact us at

A version of The Hi-Ball which was used extensively by APM in the 1950's to clear native forests to establish plantations. This particular version of the Hi-Ball is located at Simpson in Victoria's south west, where it was used to clear native forest for the Heytesbury settlement in the 1950's. The ball was connected by massive chains which were hooked up to two bulldozers. Any forest caught between the chain and the Hi Ball was torn down. Thousands of hectares of forests were cleared this way by APM for plantations. For more information see Hancock Watch.

Who are Nippon Paper (were Australian Paper/Paperlinx)?

For detailed corporate historical information about Amcor - prior to the corporate separation of Amcor and Paperlinx - click here.

Maryvale's location (yellow dot) in relation to the south east of Victoria.

Nippon Paper is Australasia's leading maker and seller of office papers such as Reflex Copy Paper. Amcor and APM (Australian Paper Manufacturers) were historically Australian Paper's parent companies. Australian Paper is the sole producer of fine printing and writing papers and sack and bag grade paper in Australia. Australian Paper mainly focus on office paper, converting paper and specialty and printing papers. Australian Paper have two mills located at Maryvale (Victoria), Shoalhaven (NSW). Capacity and types of paper made at each mill is shown on table below.

Nippon Paper Manufacturers (Australia)

Key Product
Capacity tonnes/year
Maryvale, Vic
Sack Kraft (1)
Bag Papers (2)
Uncoated Woodfree Papers
Linerboard (3)
Office Papers (incl Reflex)
Shoalhaven, NSW
S2 (closed March 2006)
Specialty Papers
Specialty Papers
Burnie, Tas (not purchased from PaperlinX by Nippon)
B4 (to close July 2009)
Woodfree Base for Coating
B10 (to close July 2009)
Uncoated Woodfree Paper and base for Coating
Wesley Vale, Tas (not purchased from PaperlinX by Nippon)
WV 11 (closed April 1 2010)
Film Coated Offset
WV12 (closed April 1 2010)
Woodfree Coating
Internal Use

857,000 (2006)

535,000 (July 2010)

Maryvale Mill sources fibre from plantation pine and eucalypt, native forests, sawmill residues and recycled paper. Shoalhaven sources its' fibre from recycled waste paper, milk cartons, cotton linters and imported pulp. Burnie sourced its fibre from imported pulp whilst Wesley Vale sources its fibre needs from plantation pulp, native forests and sawmill residues. Each year Maryvale mill produces 483,000 tonnes of pulp and 560,000 tonnes of paper and paperboard.

(1): Sack Kraft includes; multiwall paper sacks and bags for cement, minerals, flour, milk powder, potatoes etc

(2): Bag papers include fast food, lunch and retail bags, confectionary and icecream wrappers).

(3): Lined fruit and vegetable boxes etc.

Burnie Paper Mill with a capacity of 170,000 tonnes paper per year.


With the closure of the Burnie Pulp mill in June 1998 and the subsequent decision by Amcor to no longer source pulp from Tasmania's native forests (Amcor was supplied approximately 300 000 tonnes of woodchips by North Forest Products until late 1998), Amcor was faced with the issue of importing pulp to satisfy its pulp requirements. As reported in the Age 4/6/98 "Amcor intends importing 75 000 tonnes a year of pulp feedstock for its two Burnie paper machines and will spend about $5.5 million adapting the existing plant to accept the imported pulp. The company will also have to import about 50 000 tonnes of pulp a year to supply its new $350 million M5 copypaper machine at Maryvale". "Paper and paperboard production at the Maryvale's four machines will expand from 425 000 tonnes to 575 000 tonnes. . . Maryvale also produces 425 000 tonnes of pulp a year . . . Fibre, the raw material for the new paper machine, includes some softwood but is mainly hardwood from plantations, local sawmill residues and low-quality wood from state forests" (Age 1/3/99 pB1).

Analysts expected that the hardwood pulp would be supplied from Indonesia. After a discussion with Amcor representatives in early March 1999 it is apparent that there were 3 sources of overseas pulp making their way into Amcor's operations in Tasmania. These sources are; eucalypt plantation pulp from Aracruz in Brazil, pulp from Advance Agro in Thailand and mixed tropical hardwood pulp from the Indonesian company Riau Andalan. These imports are used for a variety of papers including offset printing grade, centrefold gloss etc and we argue that all are from unsustainable sources and all imports of pulp come with a whole host of ecological and human rights concerns. In regards to Maryvale, prior to July 1998 Amcor imported bleached long fibre mainly from New Zealand (radiata pine probably supplied by Fletcher Challenge) and the west coast of North America. Since July Amcor has to import bleached short fibre from South America (most likely Brazil), Thailand and Indonesia although noone from the company would elaborate on the companies supplying the fibre, although they are more than likely to be the same companies supplying Amcor/Paperlinx's Tasmanian mills.

Sumatra circa 2001: Tropical rainforest ecocide and below

Paperlinx has an agreement with the Victorian State Government to gain access to native forest fibre until the year 2030. Most of this is supplied from the Central Highlands region of Victoria and the southern Gippsland region of Victoria. Paperlinx also source woodchips from forests held by Hancock Victorian Plantations, who have long raised the ire of Strzelecki conservationists because of the appalling logging practices of Victorian Plantation Corporation (Hancock, a subsidiary of an American insurance company, took over VPC in November 1998.) For more information on Hancock's activities go to:

Map showing Australian Paper's logging concession area:

APM Concession Zone 1970's (below)

Approximate location of the 1996 Amcor (Paperlinx) Forest Agreement Area (marked in red). The agreement runs out in 2030.

South Gippsland and the Strzelecki Ranges.

"Friends of the Gippsland Bush Inc (FOGB) was formed during 1996 as a community response to Amcor's application to clear 1995 hectares of native vegetation of which a large percentage was located in the Strezlecki Ranges. What began as a campaign to demonstrate the folly of this attempted enterprise soon highlighted the need for a set of conditions that would improve the standard of present harvesting practices. Non-compliance with the Code of Forest Practices * is rife. This was demonstrated by the report of Panel Hearings on Application by Amcor Plantations Pty Ltd in 1996. The Panel, personally selected by the Planning Minister, reported that Amcor was unable to demonstrate compliance to the Code. The Panel, after one week of field observations around the various shires, was critical of the roles played by the Shire and the Department of Natural Resources who presented cases supporting Amcor's application. It should not be assumed that the Panel's findings were obtained from observing practices used for harvesting of native vegetation as, at that time, only areas of plantation harvesting were visited. Plantation harvesting practices clearly demonstrate the poor standards of the industry.

Present clearfelling techniques highlight the need for enforcement of protection laws pertaining to retention of native vegetation and soil and the right to maintain access to quality water for all those who access it. Problems in the industry will not disappear by asserting that accredited foresters have attained standards that will achieve the requirements as prescribed in the Code of Practice . . . Members of FOGB have monitored the outcomes of industry operations from 1996 to present date. . . Our consensus is that standards of operations over this time have declined rather than improved. A demonstrated brazenness in the industry openly defies stipulated requirements of The Code and State and Local Planning Ordinances relating to timber harvesting procedures . . .

FOGB and APP achieved local accord through the implementation of an 8-point agreement addressing the application to clear 1995 ha of native vegetation. The agreeement provides for careful compilation of coupe plans developed by the use of ENVIRONMENTAL CARE PRINCIPLES and APPLICATION OF CODE - private native forests and all plantations of the Code of Practice. It is achieving outcomes that will protect identified biodiversity values, and provide sustainable industry practices. Many observers such as local Shires, DNRE and the timber industry have failed to recognise that the agreement between APP and FOGB demonstrates Code of Practice in action and is not limited to the clearing of native vegetation . . . "


Forests (Wood Pulp Agreement) Act 1996

- A Brief Overview

This agreement assented to on July 2 1996, granted Amcor (now calledPaperlinx) supply of pulp wood, sourced from native forests from theCentral Highlands, Gippsland and South Gippsland/Strzelecki regions for the purposes of manufacturing wood pulp. (See Map). Originally the precursor to this agreement was signed between theVictorian State Government and Australian Paper Manufacturers in 1961. Amendments to the act were successfully granted in 1966, 1974 and 1984. The act grants the company numerous conditions (including the Waivering of licence fees) for a period of time ending in 2030.

For the period 1996-1997 to 2003-2004, 500,000 cubic metres of native forest from the Forest Agreement Area has been granted to the company. The amount of timber is gradually reduced by the following amounts;

2004 - 2005 to 2006 - 2007: 450,000 cubic metres.

2007 - 2008 to 2009 - 2010: 400,000 cubic metres

2010 - 2011 to 2029 - 2030: 350,000 cubic metres.

of which at least 300,000 cubic metres available from the mountain forests inside the Forest Area. (See map). The act also grants the company access to timber within 200km radius ofthe Maryvale Mill if the company needs it. Two additional amounts are specified in the act;

I) 150,000 cubic metres

ii) the volume in excess of 300,000 cubic metres of the minimum annual supply of pulpwood. Paperlinx are supposed to pay the government a licence fee of 50 cents per cubic metre, however payment of licence fee is waived by the secretary of DNRE until 1 July 2004.

Royalties from logging operations include (Rate in $ Per Cubic Metre);

ash species* from within the forest area $11.05

mixed species* from within the forest area $ 8.46

pulpwood of whatever class from outside the Forest Area $8.46.

*Ash species are mainly required for fine paper manufacter.

*Mixed species - are mainly required for cardboard and packaging papermanufacter.



(**It must be noted that although this agreement ended up protecting about 1700HA of priceless remnant forest areas, the company have failed to meet the other 7 points outlined in the agreement. This indicates that Australian Paper have failed to meet the intent of this agreement - as at June 2001.)

An historic agreement was reached today which has resolved the disputeover Amcor's clearing of 1950 hectares of native vegetation forplantation development in Gippsland. The agreement was negotiated by Friends of Gippsland Bush (FOGB) withassistance from the Lake Wellington Rivers Authority. FOGB represent those Gippsland residents who objected to Amcor'sproposal. Mr. Bill Briggs, Manager, Australian Paper Plantations, said the Company had considered the views presented to an independent panel, and hadsince met with representatives of FOGB to discuss their concerns further. Mr. Briggs said that part of the State Government's decision to grant its permits to clear the land included a land swap of more sensitive environmental land in the Company's estate for Government land, already cleared. In addition to this swap arrangement Mr. Briggs said the Company will now apply a far stricter set of conditions than those set down in the Code of Forest Practice and those attached with the permit.

The main points of the agreement include:

1. Excluding from clearing those slopes in excess of 25 degrees.

2. Increasing the buffer zones around the Traralgon and Rintoul Creeksfrom 30 metres to 50 metres and;

3. Regenerating pine plantation buffer strips with indigenous species.

4. Exclusion of certain blocks from clearing due to the increased protection through points 1 and 2 above and the effect of the browsing potential of native species.

5. Implementation of a joint project with the EPA and LaTrobe Shire to manage turbidity of streams in plantation areas and to advise best practice in order to address management of streamside reserves.

6. Application for federal funding for the training of young unemployed people in revegetation practices to assist with the regeneration of buffers and the rehabilitation of sensitive land.

7. The engagement of an independent expert to advise on Myrtle Wilt and koalas.

8. Commissioning of an independent, mutually accepted environmental consultant by the Company to advise the company and the shire, on all works associated with the development, with particular attention to permit condition 4(d) "habitat protection" and 4(f) "arrangements for the protection of common, rare and endangered fauna during all operations".


(Gippsland Pilot Study - Timber harvesting (coupe) plan certification - FRIENDS OF THE GIPPSLAND BUSH INC. RESPONSE TO FINAL REPORT - August 1998 (October 1998).

* (the legal document governing timber harvesting in Victoria)

Logging breaches conducted by Australian Paper Plantations (APP) and VPC (Victorian Plantation Corporation who supply Amcor/Paperlinx with woodchips) in the Strzelecki Ranges and documented by Friends of the Gippsland Bush include;

* Gullies bulldozed and backfilled. Adult tree ferns totally buried and chainsawed. Riparian vegetation destroyed. Removal of buffer and filter strips leading to the continual encroachment into native vegetation. Felling of trees into gullies. Destruction of flora, fauna and water quality values. Destruction of wildlife corridors.

* Pollution caused by diesel/hyraulic fluid. (Diesel and hydraulic fluids mix with rotting vegetation and tannin, leading to major spillages after rainfall into catchment).

* Lack of roadside batters and bulldozing of gullies eroding into river systems. Unnecessary soil disturbance caused by logging tracks. Inadequate buffers constructed adjacent to roadsides. Slumping road batters leading to severe roadside erosion. Loose roadside earthworks (A factor often encountered in Strezlecki roadwork construction is the addition of erodible effects caused by land mobilisation of soils deposited during construction of roadside shoulders leading to formation of roadside fissures). Erosion caused through innappropriate culvert locations. Concentrated waterflows channelled into unprotected highly erodable soils, that in many cases have recently been subjected to considerable disturbance, causing devastating effects on the environment. Lack of culverts at some locations.

* Thousands of tons of earth being disturbed, displaced, loosened and left on hillsides ready to slip down slopes after rain. Earthworks resembling quarries. Erosion of overburden. Unstable soil sited above gully slopes in at over 60 degrees. Formation of silt plateaus. (Strezlecki soils keep leaching away well after human operations have concluded. When operations locate to other areas these events are repeated. This leaves high turbidity and nutrient levels in watercourses (including town water catchments)).

* Burnt off areas eroding into gullies, thus increasing phosphate loads into water courses. The combination of excessive slopes and lack of soil stability leading to bad erosion and large landslips (slopes often range from 25 - 45 degrees). Landslips occurring after rainfall on recently cleared plantation sites.

* Log landings and dumps usually perched precariously on steep jutting out projections of spur lines (Because of this, watercourses are never far away. The usual way of disposing these dumps in "The Hills" regions of LaTrobe shire is to incinerate them at extremely high temperatures. These extremely hot fires burn deep into the soils seeking out any combustible materials. This leads to tons of unstable soils and ash left on banks awaiting transportation by rainfall. Ash has been known to form a coral like appearance which is super brittle and decomposes on animal and human contact or by the action of raindrops. The habit of denuding gullies from their riparian vegetation complicates the environmental hazard created by these log dumps when burnt. The ashes move unimpeded down the hillsides into water courses increasing phosphorous loads.

* Porous, sandy soil unable to retain nutrients supplied at planting leading to poor vegetation growth after replanting. Plateaus of fine sand deposits at the base of some slopes. These sands are deposited where mainstream gully flows occurs during heavy rains. The material is then transported to the main gully leading into Traralgon Creek. Up to 80cm of sand at some sites after erosion.

* The most definitive document on Myrtle Wilt - "Survey and Monitoring of Myrtle Wilt within Victoria's Cool Temperate Rainforest in Victoria, D.G Cameron, L.A. Turner DNRE 1996", categorically states that: A direct relationship between road construction or maintenance and the wounding of Myrtle Beech was established. Trees subsequently developed symptoms of Myrtle Wilt and, in some instances, were considered to have become the focus for the spread of infection into undisturbed forest (Kile pers. obs.). Myrtle Wilt has been found near adjacent to both APP and Hancock roading in the Strezleckis.

* Destruction of Cool Temperate Rainforest. March 97 and November 97 barring of logging track into canopy of Cool Temperate Rainforest. APP had been alerted to the sensitivity of the area from 1996 until this present time. Roading activities introduced Myrtle Wilt a disease fatal to Myrtle Beech in 1996, into an area which had previously shown no signs of this disease.

* Logging of old growth trees under the guise of plantation management.


The forests of the Central Highlands are being converted from a 1939 hardwood sawmill resource to a high frequency pulp resource. Many locals have noticed since the signing of the Central Highlands Regional Forest Agreement in early 1998 a massive increase in logging activity (and since Kimberley-Clark were given access to the area) - up to 7 days a week in some cases. The Woodpulp Agreement rushed through Victorian Parliament in March 1996 guarantees Amcor/Paperlinx more than 500 000 cubic metres of timber from their concession zone. Over 80% of the timber resource coming out of the Central Highlands is pulped and increasingly mixed species such as Messmate and Mountain Grey Gum are being logged as the Mountain Ash resource has been cut unsustainably. For instance the Management Plan for the Dandenong region in 1990 stated that there was supposed to be a Mountain Ash resource which would last for 30 years. By 1996 the timber industry was already half way through that.

The Central Highlands includes the Forest Management Areas of Central Gippsland, Central and Dandenong. There were some small green gains from the Central Highlands RFA including the creation of Special Protection Zones which supposedly mean that there is a prohibition on logging of leadbeaters possum habitat and of any ash species established prior to 1900 (This includes Mountain Ash, Shining Gum and potentially Messmate). However the continous impact of logging is causing serious ecological decline, with Cool Temperate Rainforest still be knocked down in areas of mixed species forest. This has contributed to the spread of Myrtle Wilt in many areas of Cool Temperate Rainforest. Logging has seriously impacted upon the ecological health of a number of areas containing old growth forest, including the Starling Hill area, the top end of Starvation Creek (which incidently feeds into Melbourne's water catchment at the Upper Yarra Dam) and Mississippi Creek which was cleared of regrowth forest, and then the area was set fire to, killing many old growth senescent trees. The Central Highlands are home to the nationally endangered Leadbeaters Possum, Spotted Tree Frog, Sooty Owl, Tiger Quoll, Powerful Owl as well as rare vegetation types. - Source: Upper Yarra Conservation Society.

Dioxins and Chlorine in the Paper Making Process
1. Pollution in the Manufacturing Process
2. What Australian Paper Says
3. What is Dioxin?
4. Dioxin at Pulp and Paper Mills
5. Chlorine in the Paper Process

2.4 Pollution in the Manufacturing Process

Source: The Environmental Impacts of Paper-Consuming Office Technologies in Australia. Final Report. Joseph Gyanesh Pickin - Australian Conservation Foundation 1996.

"The environmental impact of pulp and paper mill effluents and emissions has been the subject of intense international scrutiny during the past decade. While much progress has been achieved in mitigating the more serious problems within the principal producing regions, complete resolution has not been reached with respect to known impacts, and new effluent-related issues may be emerging. . .

2.4.1 Organochlorines

The most environmentally significant class of chemicals in chemical pulp mill effluents are the ‘organochlorines’ (or chlorinated organics’), which form from interactions between the pulp and the chlorine (or chloride) bleaching agent. Many of these chemicals are toxic, and some persist in the environment and accumulate in sediments and animal tissues. Over 300 different organochlorines may be present in kraft pulp mill effluents (IIED, 1995), but two families of compounds known as the dioxins and furans are of particular interest. These include some of the most toxic synthetic chemicals known. In 1985 dioxins were discovered in discharges from some US kraft mills, and later in the paper products themselves. Government and industry were forced to quickly respond to the intense public concern which followed, and in the space of a few years production processes were modified so as to greatly reduce formation of dioxins, furans, and organochlorines.

The standard measure of levels of organochlorines is the generic Adsorbable Organic Halides (AOX). Levels of up to 10kg per air-dried tonne (Adt) were common in old mills, but in modern mills levels of less than 1kg/Adt can be expected. Not all organochlorines are toxic and many occur naturally (Fleming, 1995) so that AOX is considered by many to be a poor indicator of organochlorine toxicity. Below 1.5kg/ADt, a level readily achievable by modern pulp mills, "there is no consistent relationship between AOX and effluent toxicity" (NPMRP, 1995). There is now more focus on directly measuring levels of those organochlorines known to be toxic, especially dioxin. In modern mills, however, "the most toxic dioxin forms are not detectable in effluents" and "whatever toxicity there is may be caused by other factors,such as organic compounds in the wood" (ibid). While these researchers and many in the industry consider the organochlorine problem solved, other groups believe the potential for environmental damage remains even at these low levels. A section of the environment movement, led by Greenpeace International and the US Chlorine Free Products Association, is running an ongoing campaign to entirely eliminate industrial chlorine use because of the organochlorine issue.

2.4.2 Conventional Pollutants

Chemical pulping is generally much more polluting than papermaking. Conventional pollutant measures include biochemical and chemical oxygen demand (BOD and COD) and total suspended solids (TSS). Discharges containing high BOD consume dissloved oxygen in the receiving waters and, if the concentration is high enough, can deplete the oxygen supply and severely affect resident organisms. BOD reductions of 70-95% are achievable through secondary treatment systems (Mjoberg et al., cited in IIED, 1995) though this requires energy and generates solid waste. BOD discharge generally ranges from 10-40 kg per tonne of pulp, but state-of-the-art kraft mills have reached as low as 2kg/t. TSS consists mainly of bark and wood fibres which normally degrade within about a month. They can affect aquatic organisms, particularly by forming mats on the bottom of the receiving water body. A typical value for TSS in a pulp mill discharge is 20kg/t, and for effluent volume is 40kL/t.

2.4.3 Other Effluent Compounds

Recent work by Canadian and Swedish researchers has revealed that a previously undetected set of impacts may exist in the sub-lethal physiological responses of fish to effluent exposure, including disturbance of the reproductive hormones balance. In Canada these effects were found to occur whether the mills used chlorine bleaching or not, and it is throught they are related to a range of compounds including natural wood extracts (IIED, 1995).

2.4.4 Air Emissions

Chemical pulping is the industry’s primary source of gaseous emissions of concern, these being mainly hydrogen sulphide, oxides of sulphur, oxides of nitrogen and ‘dust’. Many older mills caused severe air pollution which manifested most obviously in the ‘rotten egg’ smell of hyrdogen sulphide. This problem, and that of particulate emissions, has been largely eliminated from newer plants. Attention has now shifted to volatile organic compounds which can act as precursors in the formation of low altitude ozone, a component of smog which can have a serious effect on human health. In the US the pulp and paper industry is included in a category of ‘major sources of hazardous air pollutants’ because of the known presence of volatile organic compounds, chlorine, chloroform and hazardous metallic air pollutants in pulp mill emissions (ibid). Following its increased profile in the US, the issue of pulp mill air toxins is likely to become prominent in other regions.

2.4.5 Solid Wastes

Quantities of generated solid waste vary widely. In the past, up to 250kg of dry material was produced per tonne of pulp, but today some mills generate as little as 10kg/t. Solid wastes are generally benign biomass comprising bark, rejected fibre and bio-solids, combined with small amounts of lime, clay, wood ash, coal ash and woodyard rejects. The principal issue to date has been the increasing costs of disposal to land, compared to the cost of on-site incineration in an acceptable manner. Trends in solid waste management include cleaner incineration,use of sludge as a soil conditioner, and a better process control for minimal waste generation.

2.4.6 Technical Developments in Limiting Effluent Toxicity

Over the last 10 years the pulp and paper industry worldwide has invested hugely to offset environmental damage, focusing mainly on treatment and management of wastes and modification of bleaching systems. While this expenditure has too often been undertaken reluctantly, it has not damaged profitability. A study of 50 manufacturers of white pulp and paper in six countries found that the longer a firm has invested in pollution-prevention technologies in its bleaching process, the better its economic performance (Nehrt, 1995). Modified Chlorine Bleaching

The main driver of the changes has been concern over organochlorines, and consequently the most significant modifications have been aimed at reducing the use of chlorine gas, the traditional bleaching agent. Measures include extended delignification, which works by cooking the pulp for longer during pulping and so reducing the amount of lignin residues and the degree of bleaching required on the resultant pulp. Other commonly used processes involve pre-treatment of pulps with chlorine dioxide, oxygen, ozone or hydrogen peroxide before chlorine bleaching. Elemental and Totally Chlorine Free (ECF and TCF) Bleaching

Technologies are now widespread which enable complete elimination of chlorine gas from chemical pulp bleaching processes, and it is unlikely that any new mill would be built to use elemental chlorine, at least in the developed world. The best established of the new technologies, with some 40% of the world bleached chemical pulp market, is Elemental Chlorine Free (ECF) bleaching. ECF bleaching avoids use of chlorine gas by substituting chlorine dioxide as the main bleaching agent, often preceded by oxygen delignification. Effluents contain less total organochlorines and are less toxic than those produced by chlorine gas.
Totally Chlorine Free (TCF) bleaching is technically more difficult and, until recently at least, more expensive to retrofit on existing mills. The process uses neither chlorine nor chlorine compounds and relies solely on peroxide, ozone and oxygen to achieve satisfactory whiteness. TCF processes have been pioneered in Europe, particularly Scandanavia, and produce effluents virtually free from organochlorines. The world market share is around 7%.

A fierce propaganda war is currently being waged between the proponents of ECF and TCF pulps. ECF lobbying is led by the Alliance for Environmental Technology, a group of US and Canadian pulp mills which are locked into ECF production. This groups claims that whereas chlorine elimination is driven by legitimate environmental concerns, there is no justification on economic or environmental grounds for TCF. According to them, ECF is ‘the answer’ to the industry’s organochlorine problem and TCF pulps are inferior and more expensive to produce. They dispute the environmental claims of TCF proponents, maintaining they are unproven and are merely bids to win market share and government support at the expense of the ECF pulps.
TCF manufacturers, on the other hand, contend that the environmental benefits of their technology are significant and that conversion to ECF is only halfway to solving the organochlorine problem. Apart from the dioxins and other organochorines still produced by ECF pulping, they also point out that chlorine dioxide is explosive, releases poisonous chlorine gas and leaves chlorinated organic residues in the mill sludge. TCF producing companies such as Louisiana Pacific of the US and Sodra Cell of Sweden report dramatic improvements in the quality of their effluent.

The scientific community is uncertain about the relative environmental merits of the two technologies, but most researchers do not believe that organochlorine emissions from ECF pulping will cause a problem. According to Abel (1995) "there is currently no scientific evidence to suggest that TCF effluents have any less environmental impact than the low organochlorine ECF effluents". A recent Finnish study found "no significant difference in toxicity" and concluded that "the natural constituents of wood are probably responsible for the toxicity observed in the ECF and TCF effluents" (IIED, 1995). Nelson (1995), on the other hand, reports that laboratory testing of TCF techniques results in "cleaner effluents" than ECF. The International Joint Commission of the Great Lakes Water Quality Agreement concluded that "when chlorine is used ... in a manufacturing process, one cannot necessarily predict or control which chlorinated organics will result, and in what quantity. Accordingly ... the use of chlorine and its compounds should be avoided in the manufacturing process" (Greenpeace, 1995).
Environmental groups, including the ACF, generally see TCF pulping as preferable. While accepting that less organochlorines are released than previously, Greenpeace points out that 90% of organochlorines in pulp mill effluent and atmospheric discharges have not yet been specifically identified or assessed, and cites the ‘precautionary principle’ for why these should not be discharged into the environment. Even low levels of dioxins, they maintain, can accumulate to dangerous levels. Further, recent work by the US EPA (1994) suggests that dioxin poses a significantly greater threat to public health than was previously thought, so that the ‘safe’ exposure levels may themselves by questionable. ..."


What Australian Paper says

According to PaperlinX websites;
"Maryvale mill uses a small amount of chlorine in its bleaching processes, but no elemental chlorine is used at our other mills - Burnie, Wesley Vale, and Shoalhaven. There are no detectable dioxins in the wastewater discharges at any of the four mills . . ."
"Water and Air
Papermaking requires large volumes of water. . . All four mills have effluent treatment processes appropriate to the receiving waters. Chemicals used in the pulping processes are reclaimed and the waste lignin burned in recovery furnaces to provide energy. Discharges to both water and air are controlled and monitored . . ."
From REFLEX Environmental Fact Sheet

" . . . Maryvale mill was originally established in 1937, and has five paper machines with a total annual capacity of 550,000 tonnes of paper. The mill is an intergrated operation, with three pulp mills supplying unbleached softwood pulp, NSSC hardwood pulp, and bleached hardwood kraft pulp to five paper machines.

REFLEX is made from bleached hardwood fibre, but also contains some bleached softwood fibre and calcium carbonate filler. . . , the total Maryvale mill fresh water usage is only 47 cubic metres per tonne of paper produced (or 27 cubic per tonne based on the combined pulp and paper production). . .

The energy sources used at the mill are natural gas, electricity from the Victorian grid, and wood wastes from pulping operations. Approximately 47% of the site’s steam and 33% of its electrical requirements are derived from burning of pulping residues, and the chemicals used for pulping are recovered and recycled as well.

. . . Bleaching effulent is first treated with lime, clarified in combination with other mill wastewater, and then discharged to the local water authority treatment system. In this system it undergoes 70 days of alternating aerobic and anaerobic treatment before discharge via an ocean outfall . . . No impact of the effluent has been able to be measured. Some of these studies have been published.

Dilute effluent from the papermaking operations receives 28 days of treatment, comprising clarification, biological oxidisation, secondary clarification and biological polishing before discharge to the Latrobe River. Monitoring of any impacts on the river is conducted annually in accordance with the EPA licence.

Thus, despite the use of a small quantity of chlorine in its unique bleaching sequence . . ."

Environmental Bleaching Maryvale

" . . . In the late 1980s, Australian Paper undertook a research and development program to address the issue of organochlorines in bleaching effluents. In 1990 the bleach sequence was modified to include pretreatment with oxygen and hydrogen peroxide, followed by the combined addition of chlorine and chlorine dioxide under a modified pH regime. This unique sequence has resulted in the elimination of dioxin generation, and a substantial reduction in organochlorine emissions . . .

Effluent from the bleach plant also undergoes extensive treatment before discharge. The effluent is first treated with lime, clarified in combination with other mill wastewater, and then discharged to the local water authority treatment system. In this system it undergoes 70 days of alternating aerobic and anaerobic treatment before discharge via an ocean outfall which is designed to achieve high levels of dilution. . .

Levels of AOX discharge after treatment measured per kg/air dried tonne bleach pulp
1989 - < 1.1
1990 - < 0.6
1991 - about 0.4
1992 - < 0.5
1993 - about 0.3
1994 - above 0.2
1995 - above 0.2
1996 - above 0.2
1997 - about 0.2
1998 - about 0.2
1999 - about 0.2"

The Table below shows a comparison with the 1995 Australian ‘Environmental Guidelines for New Bleached Eucalypt Kraft Pulp Mills’.
Total Suspended Solids kg/ADt 8 < 2.7
BOD kg/Adt 6 < 0.001
COD (monthly average) kg/Adt 25.4 <16.8
AOX (annual average) kg/Adt 0.3 0.22
Dioxin (2378 TCDD) picogram/L 15 <detection (2ppq)"


What is dioxin?

By the Clark Fork Coalition

"To characterize, it's four chlorines, a couple of oxygens and two benzene rings.
Dioxin is often used as a catch-all term for three acutely toxic chemical groups: true dioxins, furans and polychlorinated biphenyls (PCBs). What all of these groups have in common are two benzene rings and chlorine molecules. The most toxic form of dioxin is 2,3,7,8-tetrachlorodibenzo-p-dioxin, or TCDD for short. The toxicity of other dioxins, furans and PCBs are all considered in comparison to TCDD.

Dioxin is an industrial poison, an unwanted byproduct of various industrial operations. In the paper industry, for example, dioxin is formed when chlorine combines with organic compounds in wood pulp.
To date, the U.S. Environmental Protection Agency has identified 75 dioxins, 135 furans and 209 PCBs.

Where is it?

Everywhere, and they're deadly. And once they're in the environment, it takes generations for them to go away. They accumulate in the tissues of living organisms, getting more and more concentrated as they move up the food chain, becoming concentrated in fats. Humans are at the top of the food chain, and over 90 percent of our dioxin exposure comes from eating animal foods. Once these chemicals are in us, they stay and cause long-term damage.

Dioxin is found in all of our food, but mostly in animal fats, especially in animals higher up the food chain. The reason dioxin is so high in meat, fish and dairy products, but not in grains and vegetables is that it attaches strongly to fats. Because of this, it concentrates in the bodies of animals. For example, butter has a high concentration, because it's a high fat food. But lowfat fish is also high because fish eat invertebrates and other fish that also have dioxin in their bodies. They build up a higher dose over their lifetimes than animals like dairy cows that just eat plants.

What does it do?

Dioxin causes a whole host of health problems in humans and animals, including: cancer; behavioral effects and learning disorder; decreased immune responses; decreased male sex hormone; diabetes; chloracne; sperm loss; and endometriosis.

We all carry enough dioxin in our bodies to be "at or near" the level where serious health effects may occur. A research paper published in Environmental Health Perspectives (by some of the major authors of EPA's Dioxin Reassessment) compared the minimum dioxin levels shown to cause health problems with the dioxin level the general population now carries in their bodies. (And remember, this is an average--some folks are higher.) The results are not good:

* Cancer occurs in humans at only 10 times the dioxin level now in our bodies, on average.

* Behavioral effects and learning disorders occur in monkeys at only 10 times the dioxin level now in our bodies.

* Decreased immune responses occurs in monkeys and mice at 25% BELOW the dioxin level now in our bodies.

* Decreased male sex hormone occurs in humans at only 1.3 times the dioxin level now in our bodies.

* Diabetes occurs in humans at only 10 times the dioxin level now in our bodies.

* Sperm loss occurs in humans at only 10 times the dioxin level now in our bodies.

* Endometriosis occurs in humans at only 10 times the dioxin level now in our bodies.

How does dioxin do so much damage once it gets into the body?

It attaches to cell receptors that are designed for regulatory hormones and enzymes. The result--normal cell function--including that of DNA--can run amok.

Dangerous dioxin contamination has been part of our world only since the turn of the century--tests for dioxin in lake sediments and tissues of ancient humans show much lower levels of dioxin than seen in current generations. It entered our environment in significant amounts with industrial expansion and the post-World War II explosion of the chlorine and petrochemical industries.

It took a long time to figure out that dioxin is bad stuff, because the concentration of dioxin in our bodies is minute: measured in parts per trillion, (equal to a billionth of a gram of dioxin per kilogram of body fat). This level is hundreds or even thousands of times lower than most other synthetic chemicals of environmental concern. But even at these low levels, scientists are seeing evidence of serious health effects. (For more information, read Theo Colborn's excellent book, Our Stolen Future.)

What can we do?

All this about dioxin is frightening. It seems clear that we've seriously soiled our nests, eroded our own future viability, and jeopardized the health of living systems. But things can be done. Virtually all dioxin releases are preventable. We need to make a decision as a society that dioxin emissions are unacceptable and that there are products and production processes that we can do without; that we must do without. It's not too late to undertake these changes. Buying unbleached and chlorine-free bleached paper is a good start.

Dioxin is not easily broken down, and as a result--it ends up in soil, water, and on plant surfaces. From there it enters the food chain and the fats of fish, meat and into dairy products. In fact, over 90% of our dioxin exposure comes from these foods.
So, what's the best way to protect yourself from dioxin? Eat low on the food chain, and cut down on your fat intake. For years doctors have been telling us to cut down on fats to help prevent heart-disease. Here's another reason to follow that good advice. Animals don't have a choice to change their diets to avoid dioxin. Many animals, like fish, eagles, wolves, cougars, dogs and cats, are naturally carnivores. When they eat the food they've always eaten, dioxins build up in their . They don't have a choice to eat a lower fat diet like we do. That's why we're working to ensure that the EPA adopts more stringent rules regarding dioxin emissions at pulp and paper mills.The best paper buys for the environment:

Unbleached: recycled paper that's not re-bleached.

Processed Chlorine-Free: recycled paper bleached with oxygen-based chemicals

Totally Chlorine-Free: non-recycled paper bleached with oxygen-based chemicals


Dioxin at pulp & paper mills

Many pulp and paper mills use chlorine-based chemicals to bleach pulp white. These chemicals react with organic molecules in the wood and other fibers to create many toxic by-products, including dioxin. Dioxin is found throughout the pulp and paper manufacturing process, its wastes and even in the paper products themselves.

In the water

Dioxin is in the wastewater from all mills using chlorine bleaching.
Pulp mills use large quantities of water to wash process chemicals off the paper fibers. This water contains many pollutants, including dioxin in mills using chlorine-based bleaching. Dioxin concentrations are very, very low, (often parts per quadrillion in mill wastewater, and sometimes below the detection limit of 10 parts per quadrillion that most labs use). But remember that mills release huge volumes of water--28,000 gallons per ton of paper produced at a typical bleached kraft pulp mill--so this adds up over time. Also, since dioxin doesn't easily break down in the environment, the dioxin released builds up in the river, lake or ocean sediments near the pulp mills, and concentrates in the food chain. Because dioxin persists and magnifies in the foodchain, it can be hundreds of times more concentrated in fish than in the water they live in.

A US EPA study, the National Study of Chemical Residues in Fish, found that fish near chlorine-bleaching pulp and paper mills have significantly higher dioxin concentrations than anywhere else that's been tested.
Many mills are now switching to chlorine dioxide bleaching (called "elemental chlorine-free"), but this method still produces some dioxin. Although we can expect lower dioxin levels in waters and fish after these changes, some will still be there. And remember: there's no "safe" level of dioxin exposure.

In the solid waste

Pulp mills treat their wastewater by settling the particles in it and by a settling process which includes the particulate matter and pollution-eating bacteria. This settling produces a solid waste called "sludge." EPA reports bleached kraft pulp mill sludge contamination with the worst dioxin, (2,3,7,8-TCDD), at a median concentration of 51 parts per trillion and a maximum concentration of 3800 parts per trillion. Where this ends up in the environment depends on how the sludge is disposed of. Most sludge is landfilled or applied to land. 12% is burned, and 8% is marketed as useful product.

In the air

This hasn't been studied as much as water releases, but EPA's Dioxin Reassessment did report that pulp mills emit airborne dioxin by burning used industrial chemicals (called black liquor) in recovery boilers. And any mill that burns sludge from a chlorinated bleach plant is likely to emit airborne dioxins as well.

The EPA didn't evaluate airborne emissions from sludge burning in the Dioxin Reassessment even though their data shows sludges are contaminated with the worst dioxin, 2,3,7,8-TCDD at up to 3800 parts per trillion, and that 20% of the sludge produced by bleaching mills is burned. Every other incineration process tested releases dioxin in significant amounts, so we can expect sludge burning is a problem too.

In the paper

EPA estimates that about a third of the dioxin at pulp mills goes into the paper products themselves. Dioxin TEQ values in a Canadian study found dioxin ranging from 0.1-22.7 parts per trillion in these paper products:

coffee filters
paper cups
facial tissues
paper plates
disposable diapers

Other products are likely to have dioxin as well, including napkins, paper towels, milk cartons, printing and office paper and feminine sanitary products."


Chlorine in the Paper Process

Source: Greenpeace
Chlorine chemistry starts with ordinary salt - sodium chloride, a stable natural substance that flows constantly through the ecosystem and our bodies. Each molecule of sodium chloride contains one atom of sodium bound to one atom of chlorine. The chemical industry creates chlorine gas by passing huge quantities of electricity through salt water, splitting the salt molecule and fundamentally changing the character of the chlorine in it. The sodium reacts with water to form sodium hydroxide, sold commercially as caustic soda. Chlorine was originally considered a waste by-product from caustic soda production, and is a highly reactive chemical that is often combined with other materials.

Chlorine gas is a human invention. It is extremely unstable and reactive. When it comes into contact with organic (carbon containing) molecules, the chlorine binds tightly to the carbon atoms, creating new substances called organochlorines. Most chlorine is combined with petrochemicals to produce organochlorine products, including plastics (especially PVC), pesticides, solvents and other chemicals. About 15% of chlorine gas is sold for use outside the chemical industry, primarily as a bleach in the production of paper.

Because chlorine is so reactive, it combines quickly with organic matter to form a variety of very toxic by-products and wastes. hundreds of these accidental organochlorines are released when chlorine is used to bleach pulp, disinfect water, manufacture other organochlorines and whenever chlorine-containing chemicals and wastes are burned.

Paper in Australia and around the world is made by toxic chlorine bleaching that has a negative impact on rivers, lakes, oceans and our health. Chlorine is used in a number of different forms: as elemental chlorine gas, chlorine dioxide or sodium hypochlorite. All result in the discharge of toxic organochlorine by-products. Organochlorines from pulp mills have been found in water, sediment and food chain as far as 1400 kilometres from their source.

Pulp and paper mills are major sources of dioxins and related compounds - the most toxic, persistent and bioaccumulative compounds known to science. Over 300 organochlorines have been identified in the discharges of bleached pulp mills,including dioxins, furans, chlorinated phenols, acids, benzines etc. Predator fish and other species near pulp mills have been found to accumulate dioxins and other organochlorines at concentrations thousands or even millions of times greater than the levels in the water itself. Organochlorines are found in paper products themselves. Environment Canada has estimated that 2% of the organochlorines formed in the bleaching process remain in the pulp. Dioxins and furans have been identified in cigarette papers, tampons, disposable nappies, tissues, coffee filters and bleached milk cartons.

Unbleached off-white paper is suitable for most used, from office paper to toilet tissue. When white paper is necessary, pulp can now be bleached using totally chlorine free (TCF) methods. Since the 1970’s many of the world’s major paper companies have developed chlorine-free bleaching processes that use oxygen-based bleaches, including ozone, hydrogen peroxide and oxygen gas.

Known Dioxin Sources from Greenpeace website:

Maryvale Pulp and Paper Mill
Sampling carried out between November 1995 and October 1997 found that effluent from the Maryvale paper mill to be between 0.307n 2.8187 pg/l l-TEQ (parts per quadrillion) which is below the 15 ppq required by the National Environmental Guidelines for Bleached Eucalyptus (BEK) Pulp Mills. With the exception of one sample in 1995 (1.6 pg/g l -TEQ, sediment samples from ninety Mile Beach, adjacent to the outfall, were below 0.5 pg/g l-TEQ.


Pulp and Paper Manufacturing Processes

Ref: The Environmental Impacts of Paper-Consuming Office Technologies in Australia
Final Report - Joseph Gyanesh Pickin - Australian Conservation Foundation. May 1996.
Appendix 2

Pulp and Paper Manufacturing Processes

To understand the environmental issues associated with plain office paper it is necessary to have some knowledge of the various processes involved in paper manufacturing generally and the status of the industry in Australia. These topics are introduced in this section.

A2.1 Fibre Sources

The information in this section is derived mostly from BCG (1995a) and Appita (1995).
Commercially-produced paper consists of a mat of binded organic fibres mixed with various additives. In Australia, the primary source is nearly always trees which can be divided into:
*softwood species (generally radiata pine); and
*hardwood species (generally eucalypts).
Pine fibres are long (about 3mm) and coarse, providing high strength and tear resistance which is good for wrapping papers. Eucalypt fibres, on the other hand, are short (about 1mm), finer and more flexible and produce smoother papers with high opacity. These are characteristics suitable for printing and writing papers. Australian softwood is sourced from extensive radiata pine plantations while hardwood is derived from other eucalypt plantations or native forests. Waste material from the cotton industry is also used as a high quality input to fine printing and writing papers.
On average, only about half of Australian paper and board products are made up of virgin fibre. The other half is recycled fibre sourced from cut-offs and wastes from the production of paper products or from the collection of post-consumer wastes.

A2.2 Pulping

Three main groups of processes are used for turning the solid material into a useable pulp:
* Chemical pulping
* Mechanical pulping
* Semichemical and chemimechanical pulping
In chemical pulping, the first step is to convert the logs and logging debris into woodchips by feeding the material into a rotary chipper. The chips are then ‘cooked’ in chemicals which dissolve the lignin that bonds the fibres together, leaving primarily the fibres. The pulp is washed with water to remove pulping chemicals and dissolved wood components. Modern pulp mills have a chemical recovery system in which these washings are concentrated and then burnt to recover the chemicals for reuse and to generate energy. Pulp is obtained at a typical yield of 45-55% of the dry woodchip weight and is a brown colour due to residual lignin. The most common chemical pulping method is the kraft process which uses a mixture of sodium hydroxide and sodium sulphide as pulping chemicals and produces pulps noted for high strength.

Papermaking pulps can also be manufactured by mechanically seperating wood into its constituent fibres, either by pressing whole logs against a cylindrical grindstone, or by passing woodchips between rotating metal discs equipped with radial bars. This type of process involves the application of large amounts of energy and produces pulps with lower strength properties than chemical pulps. Mechanical pulps are suitable for low-cost limited-life papers such as newsprint and box board. Yield is high (90-98%) as only water-soluble material in the wood is removed.

In the middle of the continuum is a range of processes known as semichemical and chemimechanical pulping, which use varying proportions of chemical, mechanical and heat energy. These processes remove about half of the lignin in the wood and yield 60-90% of the original dry mass as pulp. The resultant pulps are usually weaker than chemical pulps and are more difficult to bleach.

A2.3 Bleaching

The main objective of bleaching is to increase and stabilise the brightness of the pulp by removing the lignin from the fibre. For chemical pulps bleaching is a two step process, the first removing the bulk of the lignin and the second furnishing most of the brightening. The conventional way of removing the residue lignin involves treatment with chlorine or chlorine dioxide, or a combination of both, followed by extraction with alkali. . . Brightening involves the use of bleaching agents over a number of stages; chlorine dioxide, hypochlorite, oxygen and hydrogen peroxide are used.

In Australia, when production of printing and writing paper is based on eucalypt fibre, the term BEK is often used as an acronym for pulps manufactured from the conventional Bleached Eucalypt Kraft process. Bleached chemical pulps in general are commonly, if misleadingly, designated ‘woodfree’ because of the minimal lignin content in the product.

Mechanical and chemimechanical pulps contain large amounts of lignin which has not been appreciably altered during the pulping process. The aim in bleaching these pulps is to decolourise the lignin without removing it, and the chemicals hydrogen peroxode and sodium hydrosulphite are commonly used. Papers made from bleached mechanical pulps tend to yellow over time because of oxidation of lignin.

A2.4 Matching Pulps to Product Needs

It will be apparent that there are significant differences between wood pulp fibres, depending both on the properties of the raw material and on the process used to produce the pulp. Many paper products are made from blends of long and short fibres so that the appropriate range of properties will be imparted to the product. Similarly, mixes of mechanical and chemical pulps are common. It is not normally possible to entirely replace a chemical pulp with a mechanical pulp due to marked differences in their properties.

Choice of appropriate pulp or blend of pulps is a complex process which requires considerable expertise. The combination of pulps selected for a particular grade may vary over time according to market availability and conditions. Some substitution of long for short fibres in printing and writing paper is possible (Higgins, 1991).

A2.5 Papermaking

The fibres separated by the pulping process are diluted to about 99.5% water and cleaned by means of centrifuges and screens. A range of fillers and additives are added to assist behaviour during the production process or enhance qualities such as smoothness, bulk, water resistance, bonding, strength and colour. Fillers are usually calcium carbonate or kaolinite, and these may form up to 20% of the mass of the final paper. The ‘stock’ mixture is squirted onto a moving wire mesh to form the sheet. Most of the paper machine is simply devoted to getting the moisture content down to around 10% by a series of presses, absorbent felts and heated drums. Various types of coatings may be added to the surface where a glossy finish is required. The sheet is then fed through a stack of polished smoothing rolls and finally wound onto a jumbo roll for later slitting and winding into customer reels.

A2.6 Recycling

Paper for recycling can be divided into pre-consumer and post-consumer waste. The former is obtained from printers offcuts and run errors, and has long been utilised as a resource by the industry. Pre-consumer waste is clean, uniform and obtained in bulk, and so is relatively cheap to collect and re-process. Post-consumer waste is material that has been through its end use and is the main target in the drive to increase recycling rates.

Post-consumer waste accumulates in households, offices, shops and factories (used packaging) and is collected by either a private operator, a municipal authority or a paper manufacturer. The paper may be sorted by hand at a depot or mill into grades suited to various uses, and is then agitated in a large vessel of water to break it into its constituent fibres. The resultant stock must be cleaned of impurites such as wire, string, adhesive, plastic, paper clips, grit and dirt. Cleaning processes include collecting from the bottom, skimming, centrifugation and passing a revolving wire continuously through the stock on which stringy materials become wound.

The ink in printed wastepaper gives the washed fibres a grey colour, and where this is unsuited to the final product the stock is deinked by adding alkalis, detergents, water softening agents, frothing agents, bleaches and other chemicals. Some fibres are degraded into ‘fines’ in the reprocessing and are removed with the waste effluent. A fractionator may be used to divide fibres into grades of certain lengths, and a proportion of virgin fibre may be added according to the type of paper to be produced. The stock is then ready to be made into paper.

1996 EPA Licence Details:

Discharge Licences for Australian Paper included;

-of effluent to the Latrobe River (EX000114/8)

- to atmosphere (EA005427/6)

-of materials to the on-site waste dump (LS000020/4); and

- of saltcake to a disposal site (LS000232/5)

Waste Licence (EX000114/8)

...Licence Coverage:

This licence relates to the discharge of treated wastewater from the APM/Maryvale Mill to the Latrobe River. This licence allows the discharge of process wastes from the mill to the treatment lagoons, and from the treatment lagoons to the Latrobe River. It also allows the discharge of excess stormwater from the mill area to the Latrobe River from an overflow point at the east basin.

Other Wastewater Discharges:

The licence does not cover the discharge of high strength wastewaters, which are directed to the Latrobe Valley Outfall Sewer under a trade waste agreement with the Latrobe Region Water Authority. This includes the majority of the wastewater generated within the bleaching process.

Organochlorine Limits:

The discharge of organochlorine compounds (measured as AOX) to the environment from Maryvale operations is limited by the Ministerial assessment of the Latrobe Valley Wastewater Review to 1.0 kg AOX/ADt, with an operating target of 0.75 kg AOX/ADt, an an annual average. These limits include the discharge to the Latrobe River (the subject of this licence) as well as the APM component of the discharge from Dutson Downs (which is subject to EPA licence EW000005/5 held by the Latrobe Regional Water Authority). The concentration limit for AOX in this licence has been calculated to be consistent with the achievement of the overall limit given above, given a normal split in flows from the bleach plant to the two discharge systems. Monitoring of AOX from both discharges during the year will ensure that the overall limit is met.

... Waste Discharge Rate: A3. The rate of discharge must not be greater than: (a) to Number 2 aeration lagoon from the East Basin - unspecified; (b) to the Latrobe River from the East Basin - unspecified; (c) to the Latrobe River from Number 2 Aeration Lagoon - 55 megalitres per day, dry weather flow...


... Water Quality Requirements: ... B1. The concentrations of the components and/or characteristics in the waste discharge must not exceed the following values:

(a) total dissolved solids (1000 milligrams per litre)

(b) suspended solids (60 milligrams per litre)

(c) colour (450 Pt-Co units)

(d) bio-chemical oxygen demand (5 day) (40 milligrams per litre)

(e) anionic surfactants (0.5 milligrams per litre)

(f) total phosphate as phosphorus (0.5 milligrams per litre)

(g) nitrate as nitrogen (1.5 millgram per litre)

(h) ammonia as nitrogen (2.5 milligrams per litre)

(i) chloride (320 milligrams per litre)

(j) mercury (total) (0.002 milligrams per litre)

(k) adsorbable organic halogen (2.5 milligrams per litre)

(l) TCDD* (20 picograms per litre) *2,3,7,8-tetrachlorodibenzo-p-dioxin.

Map of planned ocean outfall which was completed in 1990. Dioxins from Maryvale are released into Bass Strait via the outfall. (Dioxins are also released into the Latrobe River via EPA licence EX000114/8). The proposed pipeline on this map was marked in green. Most of the area shown in this map was known as the Latrobe Valley Water and Sewerage Board - Dutson Downs Disposal Area Boundary. Note that the storage area included a portion of Lake Coleman. Also note No 2 Storage in centre of map. What has been the impact of Dioxins on surface and groundwater? What is the ongoing impact of pumping dioxins and mill waste into Bass Strait?

The above EPA waste water licences refer to the Latrobe River. A seperate EPA licence was required for Dutson Downs and the ocean outfall completed at 90 Mile Beach in 1990. Prior to the outfall being built about 900 hectares of the total Dutson Downs farm area of 9000 hectares had been developed for irrigation. Common practice up until the late 1980's was to treat wastewaters by detention in stabilisation lagoons and discharge the effluent direct to Lake Coleman.

Waste Licence (EA005427/6)

... Excess Emissions - Bleach Plant

7. (a) Emissions from discharge points number 24 and 26 may exceed the discharge limits given in Schedule C, Table 1, for the periods stated under the following cicumstances:

(i) for a period not exceeding 40 minutes per discharge point during any one close down-start up cycle of the equipment served by the discharge points;

(ii) for a period not exceeding 10 minutes per discharge point during a change in bleach pulp grade in the equipment served by the discharge points. ...

8. Emissions from discharge points numbers 25, 27 and 28 may exceed the discharge limits given in Schedule C, Table 1, for periods not exceeding a total of 17 hours in any one calender week for each discharge point. The emissions muct not exceed the limits given in the table below:

Discharge Point Number 25 27 28
Rate: kg/hr 0.324 0.300 5.328
Concentration: g/m3 0.200 0.200 0.200

Schedule C Page 4

Chlorine is discharged from (Discharge Point 22) at the rate of 0.045 kg/hr with a concentration of 0.20 g/m3.

Chlorine is discharged from (Discharge Point 24) at the rate of 0.054 kg/hr with a concentration of 0.20 g/m3.

Chlorine is discharged from (Discharge Point 25) at the rate of 0.16 kg/hr with a concentration of 0.10 g/m3

Chlorine is discharged from (Discharge Point 26) at the rate of 0.30 kg/hr with a concentration of 0.20 g/m3

Chlorine is discharged from (Discharge Point 27) at the rate of 0.15 kg/hr with a concentration of 0.10 g/m3

Chlorine is discharged from (Discharge Point 28) at the rate of 2.7kg/hr with a concentration of 0.10 g/m3

Chlorine is discharged from (Discharge Point 34) at the rate of 0.096kg/hr with a concentration of 0.20 g/m3

Other discharges include: Sulphur, Mercury, Nitrogen Oxides, Carbon Monoxide, Sulphur Dioxide, Sulphur Trioxide, Methane.

Please note that Discharge Point 22 is the Chlorine Plant Absorption Tower.

Discharge Point 24 is the Chlorine Dioxide Tower Stack.

Discharge Point 25 is the Bleach Plant - Hypo Tower Vent

Discharge Point 26 is the Bleach Plant - Chlorination Tower Vent.

Discharge Point 27 is the Bleach Plant - Caustic Extraction Vent.

Discharge Point 28 is the Bleach Plant - Main Exhaust Washers/Seals Tanks.

Discharge Point 34 is the Chlorine Dioxide Generator Vent.

No. 2 storage at Dutson Downs - photographed in the mid 1980's. The farm at Dutson Downs was used to dispose of wastewater from the Latrobe Valley starting in 1957. At that stage about 85% of the discharge came from the APM plant at Maryvale. High levels of dissolved salts, colour and alkalinity were found in the waste water.

2005 EPBC Submission

Attachment A3 Summary of discharge limits

A3.1 Maryvale Mill Discharge Licence

The Maryvale mill operates under an EPA Waste Discharge Licence (EM30021) issued under Section 20 of the Environment Protection Act 1970. The licence was originally issued on 16 September 1996 and has been periodically reviewed and revised by the EPA since then, most recently on 28 May 2004.

A summary of licence discharge limits relevant to this referral and proposed performance following implementation of the devlopment is set out in the table below. These limits cover discharge to the Latrobe River. Discharges to the Gippsland Water sewer are covered by a trade waste agreement detailed in Attachment A3.2.

Discharge to the Latrobe River Summary

EPA Licence Specifications

Total Dissolved Solids
Suspended Solids
Colour (Pt-Co Units)
Anionic Surfactants
Total Phosphate (as P)
Nitrate (as N)
Ammonia (as N)
Mercury (total)
2,3,7,8, TCDD (dioxin)
6.0 - 8.5

Mass Loads

Total Dissolved Solids
Suspended Solids
Colour (Pt-Co Units)
Anionic Surfactants
Total Phosphate (as P)
Nitrate (as N)
Ammonia (as N)
Mercury (total)
2,3,7,8 TCDD (dioxin)


Air Emission* Licence Limits (kg/hr)
Typical Air Emission Following Upgrade (kg/hr)
Chlorine dioxide
Total Reduced Sulphur (TRS) compounds
Nitrogen Oxides
Carbon Monoxide
Sulphur Dioxide
Sulphur Trioxide

A3.2 Gippsland Water Trade Waste Agreement

At present, wastes with higher concentrations of dissolved salts and colour are discharged to the Gippsland Water sewer and treatment facility under a trade waste agreement. The wastes from the proposed facility would be within the current trade waste agreement parameters.

Trade Waste Agreement

Quality Criteria

Agreement Specifications

Estimated Future
Sewer Flow
Lab Electrical Conductivity
Suspended Solids
Colour (annual average)
PtCo units
Oil & Grease (5 days ave.)
Dissolved Oxygen
Total Nitrogen
Sulphur (Total)
Dimethyl sulphide
Dimethyly disulphide
Dioxin (2,3,7,8 TCDD)
AOX (after treatment)

Note: <DL(1) = less than detection limit of 1 ppq (part per quadrillion)

Mercury History Lesson

June 5 2008: Mercury Poisoning Linked to Dolphin Deaths

Subverting the System (The Politics of Pollution) Peter Russ & Lindsay Tanner 1978

p67 " In Victoria it is possible for large companies to circumvent the operation of the EPA's licensing system by exerting political and economic pressure on the state government and the EPA. The weaknesses of the EPA's systems of delegation, licensing, enforcement and appeals, and the way politico-corporate pressure influences their effectiveness, are illustrated emphatically by the recent APM case.

The Australian Paper Manufacturers (APM) Ltd's paper pulp mill at Maryvale in the Latrobe Valley has discharged mercury-contaminated wastes into the valley airshed, the Latrobe River, and the Latrobe Valley sewerage system for many years. APM's chlor-alkali plant, which manufactures chlorine and caustic soda for use in the paper manufacturing process, uses mercury electrodes in the electrolytic process which produces these chemicals. Electrolysis converts the mercury into an inorganic state, and it is later discharged as a waste product. Inorganic mercury is not highly toxic, but when discharged to water it is gradually converted into methyl mercury, which accumulates in plants, animals and humans, and in high concentrations is extremely toxic.

APM's mercury discharge was one of the most pressing problems facing the EPA upon its creation: the discharge had continued virtually unchecked for almost 40 years, the pollutant involved was highly dangerous, the ecosystem needing protection was an important one, and the company involved could marshal unrivalled economic and political muscle. What ensured bordered on a conspiracy to effect harm to the public interest for reasons of private gain: APM leant on the government and the EPA, and consequently the company was virtually able to write its own licence to pollute.

When the problem of licensing this discharge first arose, the then Chief Water Quality Officer, David Smith, recommended that the EPA itself should license APM, as APM has a representative on the Latrobe Valley Water and Sewerage Board. However, the EPA rejected Smith's recommendation and left the licensing of APM up to the Latrobe Valley Board.

On 29 May 1973 APM applied for a license to discharge waste to the Latrobe River, requesting a permissible maximum mercury concentration of 60 parts per million, and a maximum total load of one kilogram of mercury per day. Later the company wrote to the EPA, which responded on 16 October 1973:

'Our agents the Latrobe Valley Water and Sewerage Board have previously told you of the proposed limits for your effluent. These were arrived at after careful consideration of environmental requirements and we cannot make any major alteration without considerable detriment to Latrobe River quality.'

This letter, probably drafted by David Smith, stated that the proposed limit of one part per billion mercury would probably apply for at least ten years, subject to 'no major environmental hazards' developing and the use of 'best practicable technology' by APM. The licence as proposed differed materially from APM's application only with respect to four parametres: mercury, lead, colour, and biochemical oxygen demand (BOD). The EPA letter concluded:

'We cannot fulfil our statuatory obligation to maintain water quality in the Latrobe River and accede to your requested limits for colour, BOD5 and mercury. The maximum mercury composition in the effluent must not be greater than 0.001 parts per million. We would make provision for leaching of mercury from your premises for a suitable period after the discharge of mercury from your production processes has ceased.'

This was nothing less than an emphatic statement that any increase in the mercury limit beyond one part per billion would be detrimental to the Latrobe River ecosystem.

Six days later, Smith wrote in a memo to the authority:

'We are firmly convinced that the mercury concentration in the effluent must not be more than 0.001 parts per million and the Health Commission will require strict limits. We prefer that the use of mercury electrodes for chlorine generation be discontinued and no mercury discharged to the river. This has been our position throughout discussions.'

The EPA pressured APM to replace its mercury electrodes with diaphragm electrodes, now commonly used throughout the world and in other chlor-alkali plants in Victoria. Smith further outlined the long-term implications of pollution of the Latrobe River:

'In a letter of 5 October, APM demanded an immediate statement from the EPA of what we would guarantee as acceptable for ten years. There is need to improve Latrobe River water quality by limiting waste discharges. In ten years there will be possibly lower flow due to increased abstraction, there will be more industry including power stations, and a massive increase in population if Traralgon goes ahead as a decentralisation centre. Increase in population, even in fully sewered developments, results in a large increase in waste load on the streams in the catchment. If APM load the Latrobe River to capacity it will limit other development.'

APM's licence as issued by the Latrobe Valley Board on 10 April 1974 set a maximum mercury concentration of one part per billion, to be effective from 1 April 1977. In the interim period the level was set at the limit applied for, namely 60 parts per billion. However, section 6 of the 'A' schedule in the licence stated: 'The mercury content of the waste discharge shall be reduced to a maximum of 0.001 grams per cubic metre prior to the 1st October 1974, and provision for the leaching of mercury from the system shall be made for a suitable period thereafter'. These provisions effectively allowed APM some leeway to remove mercury already accumulated in the waste discharge system before the absolute limit came into force in April 1977.

On 14 May 1974 the secretary of the Commission of Public Health wrote to the Latrobe Valley Board, as provided by the act, expressing the Commission's comments on APM's licence:

'Although there is at present no evidence to indicate immediate danger to health by the incorporation of methyl mercury in food chains from this discharge, the accumulation of mercury in bottom sediments poses the risk to future health hazard. Mercury discharges of up to one kilogram per day are excessive and should be substantially reduced without delay by the employment of modern techniques using settling basins and a recycling system to recover the mercury.'

At this stage, odd things began to happen. Quite legitimately, APM lodged an appeal against the provisions of the licence. However, not content with following the due processes, they simultaneously pressured the Latrobe Valley Water and Sewerage Board to agree to their demands. The main thrust of this pressure was contained in a letter to the board entitled 'Without Prejudice', dated 16 May 1974. In this 13-page document, APM listed all the alterations to the licence which they were seeking and suggested specific rewording of the conditions appealed against to make them 'acceptable'. The letter began: 'Our mutual aim is to ensure the health and beneficial use of the Latrobe River. APM much prefers to continue discussion on the licence conditions at issue with the object of reaching agreement with the board on these conditions'. APM's appeal had been lodged to 'protect its interests', and it is obvious that by 'agreement with the board' it really meant 'licence conditions acceptable to APM'.

The letter claimed that the one part per billion mercury limit was near the threshold of reliable measurement, and equivalent to pre-exisiting mercury conditions in the Latrobe River upstream of APM's discharge. It was pointed out that much of APM's raw materials contained high concentrations of mercury, and that improved control techniques instituted between 1971 and 1974 had drastically reduced mercury discharges.

As it happened, the first two claims were invalidated by data on mercury concentrations in the Latrobe River prepared for the EPA soon after, which established a range of 'natural' mercury concentrations in the river waters between 0.1 and 0.3 parts per billion. The claim that mercury concentrations in the river were as high as one part per billion even without APM's discharge was meaningless in any case, because APM's discharge is added to, rather than absorbed by, existing concentrations. The fact that APM's raw materials contain high mercury concentrations is irrelevant both to the environmental effects of the discharge and to the socio-economic justifications for it. In any case, approximately two-thirds of APM's discharged waste mercury goes to the atmosphere. The fact that APM had reduced their mercury discharges to the river substantially since 1971 merely indicates the likelihood of severe contamination having already accumulated over many years.

APM suggested that the exisiting mercury conditions be replaced with the following:

Mercury-contaminated effluents from the APM chlorine/caustic soda plant and from purchased caustic soda will be diverted to the sewer prior to 1st October 1974 to September 1976 to determine the consequences of diversion of mercury contaminated effluents to the industrial sewer. Following this, the board will set mercury concentrations and APM will be permitted a period of eighteen months to instal equipment which may be necessary. Use of the industrial sewer shall continue for the disposal of mercury-contaminated effluents, provided the Department of Health agrees.

As indicated by the minutes of a meeting between EPA and Latrobe Valley Board representatives on 30 May 1974, both bodies agreed to virtually all APM's demands, inserting a few words here and there for clarification. The suggested rewording of the mercury conditions was accepted without alteration. APM also suggested that the licence be amended so that concentrations of contaminants in their discharge were to be measured by the addition of exisiting concentrations in the influent, rather than on an overall basis. This was agreed to. Effectively the mercury limit in APM's licence was now to be sixty parts per billion, because in the absence of licence specification, the limit applied for will take effect.

For purposes of legitimising this consent agreement, APM's appeal went ahead, and a determination by the Appeals Board was handed down on 16 July 1974. In the Age a few days later statements attributed to Appeal Board Chairman Philip Opas indicated that the board had hardly even looked at the details of the agreed amendments, and suggested that Opas did not understand the provisions of the amended licence. The article, entitled 'QC Explains Mercury in Latrobe Decision', stated:

'Mr Opas said mercury would be leached from the system before the discharge reached the river, and mercury reaching the river would be monitored continuously. Mercury-contaminated effluents are not to go directly to the river, but are to be diverted to the sewer, Mr Opas said. Mr Opas said the minute amounts of mercury that might get into the Latrobe River did not enter a static body of water and it was nonsense to speak of a tonne a year entering the river as if this could be found in one time at one place.'

Even when considered in isolation, let alone when correlated with the licence actual provisions, the first two statements attributed to Opas bear no relation to the actual provisions. On the one hand, leaching of mercury from the system was specifically intended to reach the river - because provision was made for the relaxation of limits for mercury discharges to the river to enable such leaching. On the other hand, Opas had a very generous definition of the term 'continuous' monitoring. The original licence provided for mercury samples to be taken every day of discharge: this was amended under the agreement on appeal to only once a week. Opas' final statement about the mobile tonne of mercury revealed a disturbing lack of knowledge of heavy metals, their effects on the ecosystem, and the way they accumulate in living organisms over time.

Was the Licence Illegal?

We strongly contend that the issue of APM's licence as amended was illegal under section 29(5)(b) of the Environment Protection Act. This section states: 'In the event of the Commission of Public Health lodging an objection with the Authority or protection agency on the ground that in the opinion of the Commission, the public health is likely to be endangered if a licence is granted, the Authority or protection agency shall not issue the licence'.

In a letter sent to both the EPA and the Latrobe Valley Board dated 2 October 1974, the Secretary of the Commission of Public Health conveyed the commission's strong objections to the licence as issued:

'The commission has noted that the initial licence issued by your board as the delegated agency of the Environment Protection Authority provided safeguards in connection with the mercury contained in the discharge.

However, the commission notes with concern that following an appeal to the Environment Protection Appeals Board by the Australian Paper Manufacturers Ltd pursuant to s. 32(3) of the Environment Protection Act 1970, the schedule to the decision of the appeals board provides for a variation in relation to the mercury content of the waste, which in the view of the Commission of Public Health presents a potential hazard to health.

The revised wording of clause 6 in the schedule to the appeals board determination represents a maximum allowable rate of mercury in excess of three kilograms/Hg per day which is to be reduced to 0.5 kilograms/Hg per day by the 1st of April 1977.

If, as stated in the schedule to the determination of the appeals board that all mercury waste is to be discharged to the sewers of Latrobe Valley Water and Sewerage Board as from October 1st 1974, the commission considers that this will also present a potential health hazard unless all of the mercury can be retained at the sewer outfall.

The commission considers that the revised conditions contained in the schedule determination by the appeals board provide for an excessive discharge of mercury in view of the potential for mercury wastes to be converted to methyl mercury in bottom suds and subsequent incorporation in the food chains leading eventually to dangerous levels of this highly toxic metal in fish and birds which may be consumed by man.'

There is no requirement under the act for the Health Commission to either cite section 20(5)(b) of formally state that it is lodging an objection when actually doing so. The act states that the EPA or delegated agancy shall not issue the licence in the event of an objection being made by the Health Commission. Thus they are obliged to bow to the dictates of the commission. This they did not do.

Legally, the Health Commission was undoubtedly making an 'objection' under the act. Only specious and legally perverse interpretations of the act and the situation could possibly avail the EPA and the Latrobe Valley Board, and if accepted would make nonsense of the entire provision.

The question of legality of the APM licence raises broader issues, such as the faults in the Environment Protection Act. No provision is made for appeals against a decision by a protection agency to ignore a Commission of Public Health objection: yet, in such a situation, the normal thirty-day limitation is obviously unworkable. Even the fact than an objection was actually lodged may not come to light until months after the issue or amendment of the disputed licence. It would appear that the only recourse available to the ordinary citizen and, incidently to the Public Health Commission, is to take out a writ of mandamus to compel the protection agency to perform its public duty.

The EPA's reply to the Commission of Public Health, dated 23 October 1974, simply restated the conditions on the amended licence. No explantation for ignoring the commission's objection was given. Thus the EPA and the Latrobe Valley Board acted prima facie illegally in not summarily revoking APM's amended licence and issuing another licence considered by the Health Commission to be satisfactory.

There can be no doubt that the commission was right in objecting to the new licence. Its attitude is corroborated by David Smith's earlier statements to the effect that anything higher than a limit of one part per billion inclusive of the exisiting concentration in APM's influent from the Latrobe River would not be acceptable. The implications of these events are very serious: a large and politically powerful corporate polluter was able to secure the unwarranted privilege of polluting the environment to an extent considered completely unacceptable by the responsible public authorities. Even more serious is the fact that this situation has been concealed from the people of Victoria.


A further instance of the incompetence of the EPA and the appeals board was later discovered in the provisions of the licence as reissued. The appeals board altered the maximum concentration of mercury in APM's discharge after 1 April 1977 from a limit of one part per billion, to one of ten parts per billion. Yet clause 6 of the new schedule 'A' stated that monitoring programme would be conducted by APM and the Latrobe Valley Board to determine mercury concentrations in APM's effluent between 1 October 1974 and 30 September 1976, and that the permanent mercury limit would be based on the results of this monitoring. This of course made the setting of a post April limit by the board completely meaningless. Fortunately this galring contradiction was later discovered, and on 22 November 1974 the 10 parts per billion limit was deleted and replaced by a phrase making the permanent limit dependent upon the results of the monitoring programme.

However, another glaring fault in the licence was completely overlooked by the EPA, the appeals board, and the Latrobe Valley Board. The concentration of contaminants including mercury was now to be calculated on the basis of subtracting the previous existing level in the river water used by APM - but no requirement for the monitoring of this influent as a basis for such a calculation was set. This fault was pointed out by Latrobe University zoology lecturer Peter Rawlinson in a letter to Conservation Minister Bill Borthwick of 1 November 1974 - a full 21 days before the licence was amended. When Rawlinson reiterated this point in a subsequent appeal against the 22 November amendment, EPA Chairman Don Little stated: 'It did seem that there was some ambiguity in the conditions as stated, and my understanding is that the reason for this November amendment was to clarify this so that this ambiguity was removed'. Unfortunately Little was thinking of the wrong ambiguity. The fact that such problems arose at all indicates indecent haste and lack of proper concern with which the protection agencies sought to placate APM. Needless to say, the appeals against the amended licence were disallowed by the appeals tribunal.

Interestingly, at no stage throughout this period did the mercury concentration in APM's discharge approach 60 parts per billion, the limit which applied because of the deliberate omission of any mercury limit from the licence as amended. This is illustrated in a letter from Don Little to Borthwick on 15 April 1975.

'The licence issues to APM Ltd required that mercury-contaminated wastes were diverted to the sewer by the 1st of October 1974. This has been done. Prior to this diversion to sewer, mercury levels in waters discharged to the Latrobe River from APM Ltd were within the range of 0.001 to 0.0036g/m3 and since diversion this level has decreased and is currently in the range of 0.0003 to 0.0009g/m3. This means that currently under maximum flow conditions 48 grams of mercury are being discharged to the Latrobe River per day. This mercury is leached from the pipes and exisiting water treatment ponds and is anticipated will fall off to a very low level. Analytical work has established background levels of mercury in the Latrobe River within range 0.0001 to 0.0003g/m3. Taking the figure of 0.0001 and the average daily flow of the Latrobe River at Rosedale this means that 260 grams of mercury are discharged by the Latrobe River into the Lakes system each day from natural sources. As similar background levels it may be calculated that the Thompson River and its daily flow at Cowwarr would discharge 108 grams of mercury per day into the Gippsland Lakes system.'

The attitude of APM may seem mystifying, given that its discharge was within the conditions of its original licence. However, the reason for APM's wish for a limit in the 50 to 60 parts per billion range becomes quite obvious when a memo from former Chief Water Quality Officer Dr Manir Hussain to the Principal Water Quality Officer (Policy and Research) is examined. In this memo of 26 June 1975, characteristically entitled 'Mercury in Latrobe River - Justifcation', Hussain stated: "Mr Fred Westbrook from the Latrobe Valley Board indicated that the board will not be accepting any mercury containing wastes from Australian Paper Manufacturers into Dutson Downs treatment farm after 1976, when the current trade waste agreement expires'. The subsequent enforcement of this decision was later dictated by an appeals tribunal decision in early 1976, whereby the Latrobe Valley Board is no longer permitted to discharge sewage effluent in to Lake Coleman from Dutson Downs. Obviously in seeking a loose licence limitation APM was looking to the future when it would have to discharge its mercury contaminated wastes, which had previously gone to the sewer, into the Latrobe River. Hussain continued:

'The representatives of APM at this meeting indicated that there is no practical alternative but to continue the manufacture of chlorine at Maryvale if paper production is to continue. They also indicated that APM may be able to obtain a level of 0.005mg/l of mercury in their effluent. At present the EPA and the Latrobe Valley Board have very little information concerning mercury levels in the Latrobe system and the Gippsland Lakes in general, and it is considered essential that more comprehensive data be obtained in order to be able to justify whether APM should be permitted to discharge their waste to the Latrobe River'.

Hussain asked that a monitoring programme for mercury in the sediments and biota of the Latrobe River be prepared as soon as possible.

The implications of this document are serious. Hussain admits that when the EPA, appeals board, and Latrobe Valley Board relaxted APM's licence they were completely in ignorance ofthe current mercury contamination situation of the biota and sediments of the Latrobe River system and the Gippsland Lakes system, and that this ignorance extended for at least a year afterwards. They allowed APM the privilege of discharging large quantities of mercury into the Latrobe River without knowing whethere this would lead to a dangerously high mercury accumulation in sediments, and more particularly in the food chain - the final and most accumulative links of which are consumed by humans.

Hussain's memo also indicates that the EPA has accepted almost without question APM's claim that there is no alternative to the use of mercury electrodes in its chlor-alkali plant. This is despite the fact that APM is unlikely to abandon its enourmous capital investment at Maryvale because it is required to spend a little more; and that recent APM profits have been rather substantial. Interestingly enough, Hussain refers both in the title and the text of his memo to 'justifying' APM's discharge. This is yet another indication of the role the EPA fulfils: the legitimisation of pollution.

It is intersting to compare APM's 'Without Prejudice' letter of 16 May 1974, the 'Summary of Discussions' of 30 May 1974, and the subsequent amendments to the AMP licence. Of nine other 'suggestions' made by APM, the EPA and Latrobe Valley Board agreed to five, provisionally supported two, and rejected two. The licence was even further amended at the request of APM on 27 June 1975, relaxing the maximum permissible sulphate concentrations from 136 parts per million to 400 parts per million.

It is worth recalling David Smith's comments quoted above, both in memos and through EPA Secretary Durnan in the letter of 16 October 1973. These show consistently that the Water Quality Branch at that time was strogly opposed to any relaxation of the limits set in APM's original licence: 'We cannot fulfil our statuatory obligation to maintain water quality in the Latrobe River, and accede to your requested limits for Colour, BoD5, and Mercury (Durnam to APM, 16 October 1973). None of the documents studied nor the evidence available gives any indication that the environmental and public health risks have become any less serious. There can be no doubt that there is a pressing need for an open public inquiry into the whole APM affair: the Victorian system of environment protection has been contemptuously circumvented and subverted, and the people of Victoria are entitled to know exactly how, why and by whom - and then to have the appropriate corrective and preventative action taken.




Source Woodchipping in Victoria by P.A. Rawlinson - Native Forest Action Council 1977

Pulpmills and Pollution

In Industrialized countries pulp and paper mills are generally recognized to be amongst the most polluting industries. The Australian situation bears this out, for example, in 1972 the Director of Environmental Control for Tasmania prepared a report in which he named the paper making industry as the states major polluter. In South Australia Lake Bonney is now grossly polluted with pulp mill effluents and in Victoria three paper pulpmills, (A.P.M. Maryvale; Bowater-Scott, Myrtleford; and Smorgons General Paper Mill, West Footscray) are all causing pollution problems for the E.P.A.

A.P.M. representatives on the Senate Committee Gippsland tour claimed that pollution from the Maryvale pulpmill was controlled by rigid conditions set by the E.P.A. which A.P.M. conformed to. This is false, A.P.M. have strongly opposed the conditions of all E.P.A. licences which are relevant to the mill.

A.P.M. has three methods for disposing effluents.

1. By discharging mildly contaminated water to the Latrobe River.

2. By discharging gaseous effluents to the air via chimneys, vents etc.

3. By discharging grossly contaminated water to the Dutson Downs sewerage farm via the Latrobe Valley sewer.

Under the E.P.A. license system the company only needs licences for discharge to the air and the Latrobe River. The discharge to the sewer is covered by a "Trade Waste" agreement, ultimately the Latrobe Valley Water and Sewerage Board need an E.P.A. licence to cover discharge of the treated effluents from its sewerage farm to Lake Coleman.

A.P.M. applied for a licence to discharge wastes to the Latrobe River on 29th May 1973. The licence was granted on 10th April 1974 and A.P.M. immediately appealed against the conditions and pressured the E.P.A. and its delegated agency to amend the licence. This was successful and A.P.M. was able to present a consent agreement to amend the licence to the E.P.A. Appeals Board on 16th July 1974. Of the eleven "limitations, restrictions and conditions" in the orginal licence, six were amended in a major way - all amendments were to the detriment of the environment and the advantage of A.P.M. There was gross erosion of the original licence. Particularly serious was amendment of condition 6 which controlled mercury emission. Originally condition 6 stated that the mercury content of the waste discharge be reduced to a maximum of 0.001 grams per cubic metre prior to the 1st of October 1974. The E.P.A. had wanted A.P.M. to close down its chlor-alkali plant which was the source of the mercury. A.P.M. refused and had the licence amended so the mercury contaminated effluents were diverted to the Latrobe Valley sewer and Dutston Downs. The licence was reissued on 20th September and reamended in a minor way again on the 22nd November. The licence application and the various amendments are public documents and can be obtained by the E.P.A. (No LW 000031/4).

The company also applied for its licence to discharge to the air on 29th May 1973, but it was not issued until 21st May 1976. As soon as the licence was issued A.P.M. appealed against the conditions. As with the water licence, the application and licence are public documents and can be obtained from the E.P.A. (No. LA000045/3).

A.P.M.'s difficult effluents are discharged to the Latrobe Valley sewer under a trade waste agreement. The agreement is not a public document so the conditions are unknown. Most of the effluent carried by the sewer (65% to 75%) comes from A.P.M. From the conditions imposed by the water licence this is known to include mercury and it also carried large quantities of cellulose fibre and lignin. The cellulose fibre settles out in the primary treatment but the mercury passes through on to the lagoon and irrigation systems. The lignin wastes give the effluent an intense black colour, and are not treated by farm processes. In fact the farm intensifies the colour. On entry to the farm, the effluents have an average colour value of 8,505 units, after primary treatment this has risen to 11,655 units and on discharge to Lake Coleman it is 14,900 units. Lake Coleman is proclaimed a State Game Reserve.

The Latrobe Valley Water and Sewerage Board applied for an E.P.A. licence to discharge treated effluents to Lake Coleman on 17th May 1973. Three licences (EW 000005/5, EW 000383/2 and EW 000384/5) were issued on 16th January 1976. As they specified an average colour value of 18,000 units and a maximum of 35,000 units which would have allowed the gross contamination of Lake Coleman with lignin to contnue over 20 third party appeals were lodged against the conditions of the licence. A.P.M. contested these appeals as an interested party and they were legally represented.

The E.P.A. tribunal announced its determination on the appeals on 15th April 1976. They found in favour of the third party appeallants and stated:

"The Authority believes that Lake Coleman and associated wetlands, and Lake Wellington - as parts of the Gippsland Lakes system - need more protection, because of their present and potential beneficial uses for the community, than is given by the licences in their present form. The Authority believes that the discharge of waste water from the Dutson Downs site to Lake Coleman should cease as soon as possible. Accordingly the Authority allows the appeal..."

A.P.M. have lodged an appeal against the determination.


Strzelecki Ranges - College Creek rainforest area threatened by plantation harvesting in surrounding catchment. This rainforest is now under the control of US based John Hancock Financial Services.