MARDIE PROJECT PILOT EVAPORATION POND TRIAL
APPENDIX 3A (PROPOSED ACTIVITIES)
WORKS APPROVAL APPLICATION: CATEGORY 14:
AUGUST 2018
1 SYNOPSIS This document presents information required for:
An application for a Works Approval for a Category 14: Solar salt manufacturing: premises on which salt is produced by solar evaporation.
This document has been prepared for submission to the Department of Water and Environmental Regulation.
Table of Contents
1 Synopsis ...... 2 1 Premise Details ...... 1 1.1 Applicant / Occupier Details ...... 1 2 Introduction ...... 1 2.1 Project ...... 1 2.2 Purpose ...... 1 3 Premise Details ...... 2 3.1 Legal Land Description ...... 2 3.2 Prescribed Premise Location and Coordinates ...... 3 4 Description of Existing Environment ...... 6 4.1 Flora and Vegetation ...... 6 4.2 Fauna and fauna habitats ...... 7 4.3 Geology ...... 7 4.4 Topography and Soils ...... 8 4.5 Climate ...... 9 4.6 Surface Hydrology ...... 11 4.7 Ground Water ...... 12 5 Stakeholder Engagement ...... 12 6 Prescribed Premise Category ...... 13 6.1 DWER Approvals ...... 13 6.2 Documents associated with this proposal ...... 13 6.3 Other Relevant Licenses / Permits ...... 14 6.3.1 DMIRS ...... 14 6.3.2 Local Government ...... 14 7 Proposal Description ...... 15 7.1 Trial Evaporation Pond Project Objectives ...... 15 7.2 Scope and scale of proposed activities ...... 15 7.2.1 Key Characteristics ...... 15 7.3 Pilot Evaporation Project Location ...... 16 7.4 Pilot Evaporation Ponds ...... 18 7.4.1 Size ...... 18 7.4.2 Construction Method ...... 19 7.4.3 Source of Construction Materials ...... 20 7.4.4 Operational Management Plan ...... 21 7.5 Key Infrastructure & Equipment ...... 22
DWER – Works Approval Appendix 3A
7.6 Unique processes to be tested ...... 22 7.7 Conservation Areas ...... 22 7.8 Sensitive Receptors / Separation Distances ...... 23 7.9 Commissioning ...... 23 8 Environmental management ...... 24 8.1 Process Emissions ...... 24 8.2 Gaseous and Particulate Emissions ...... 24 8.3 Dust Emissions ...... 24 8.4 Odour Emissions ...... 25 8.5 Noise Emissions ...... 25 8.6 Discharges to Water ...... 25 8.6.1 Stormwater Control / Emissions ...... 25 8.6.2 Surface Water Management ...... 25 8.7 Discharges to Land ...... 26 8.8 Solid and Liquid Waste Management ...... 27 8.9 Light Emissions ...... 27 8.10 Hydrocarbon/Chemical Storage ...... 28 8.11 Contaminated Sites ...... 28 8.12 Other Emissions and Discharges ...... 29 9 Incident Response ...... 29 9.1 Seawater Spill Response ...... 29 9.2 Incident Response ...... 29 9.3 Complaints ...... 30 10 Risk Assessment ...... 31 10.1 Risk Assessment Process ...... 31 11 Cost of project ...... 32 12 Appendix ...... 33
Mardie Project – Pilot Evaporation Pond Trial 4
1 PREMISE DETAILS
1.1 Applicant / Occupier Details The occupier (Company) of the land subject to this Works Approval application / Licence to Operate application is:
Mardie Minerals Pty Ltd ACN: 152 574 457 Level 1, 15 Rheola Street West Perth, Western Australia.
Mardie Minerals Pty Ltd is a wholly owned subsidiary of BCI Minerals Limited (ABN 21 120 646 924).
The contact person for this Works Approval application is:
Mr Michael Klvac General Manager Corporate Affairs BCI Minerals Limited Phone: +61 8 63113406
Mobile: 0438 268 877 Fax: +61 8 6311 3449 Email: [email protected]
Mardie Project – Pilot Evaporation Pond Trial 1
2 INTRODUCTION
2.1 Project The Mardie Project aims to produce 3.5 million tonnes per annum (Mtpa) of high purity industrial grade sodium chloride (salt) from seawater via solar evaporation, crystallisation and raw salt purification. Through the crystallisation and processing of remaining bitterns, the Project will also produce 75 thousand tonnes per annum (ktpa) of fertiliser grade SOP.
This trial program of works is to construct a nominal 1:10,000 scale system of ponds and crystallisers to confirm the evaporation rates at each stage of the solar evaporation process on the site at the same time recording atmospheric conditions and to prepare raw salts for pilot scale processing off-site.
2.2 Purpose The purpose of this document to apply for a Works Approval (WA) under Part V of the Environmental Protection Act 1986 as prescribed under Section 54(1)(a) and Section 57(1)(a) respectively of the Environmental Protection Regulations 1987,. This document therefore provides the necessary information to support:
1. An application for a Works Approval; Category 14: Solar salt manufacturing: premises on which salt is produced by solar evaporation under Schedule 1, Part 1 of the Environmental Protection Regulations 1987
The WA Category 14 capacity being applied for is outlined in Table 1 below.
Table 1 WA and LTO Design Capacities
Production or Design Category Number Category Description Capacity
Solar salt manufacturing: 14 premises on which salt is NaCl 350 tpa produced by solar evaporation
Mardie Project – Pilot Evaporation Pond Trial 1 DWER – Works Approval Appendix 3A
3 PREMISE DETAILS
3.1 Legal Land Description
The Project is owned 100% by Mardie Minerals Pty Ltd, a wholly owned subsidiary of BCI Minerals Limited (BCI). The current tenement status is shown on Table 2.
Table 2- List of Mardie Tenements
Area Application Tenement Id Current Holder Grant Date Expiry Date (km2) Date
E08/1849 134.4 Mardie Minerals Pty Ltd 22-Feb-08 21-Nov-08 20-Nov-18
E08/2741 60.8 Mardie Minerals Pty Ltd 24-Jun-15 10-Feb-16 09-Feb-21
The tenements are indicated regionally on Figure 1, which also includes the native title claim areas. The tenement overlies the Mardie Pastoral lease (Crown Lease CL453-1984) owned by Citic Pacific Limited.
Current access to the site is from Northwest Coastal Highway and then the Mardie Station access track.
Mardie Project – Pilot Evaporation Pond Trial 2 DWER – Works Approval Appendix 3A
Figure 1- Mardie Tenements Regional Location
3.2 Prescribed Premise Location and Coordinates
The proposed premise is located in Western Australia’s Pilbara coast, midway between the towns of Dampier and Onslow. Current access to the site is from Northwest Coastal Highway and then the Mardie Station access track. See Figure 2 for details of the actual premise boundary.
Mardie Project – Pilot Evaporation Pond Trial 3
Figure 2 Proposed Prescribed Premise Boundary
Mardie Project – Pilot Evaporation Pond Trial 4 DWER – Works Approval Appendix 3A
Figure 3 – Proposed Pilot Evaporation pond boundary
Mardie Project – Pilot Evaporation Pond Trial 5
4 DESCRIPTION OF EXISTING ENVIRONMENT
4.1 Flora and Vegetation A total of 17 land cover types have been mapped for the Mardie Project, including 14 terrestrial vegetation types. The Mardie Project is dominated by unvegetated algal mat and mudflat/salt flats. The Trial Pond study area is also dominated by unvegetated mudflat/saltflat (Figure 3a) and to a lesser extent Spinifex (Triodia spp.) steppe (Figure 3b), Prosopis (mesquite) shrubland (Figure 3c) and Shrublands over Triodia spp. grasslands (Figure 3d). Mesquite is a Weed of National Significance (WoNS) and the mesquite infestation at Mardie station is recognised as the largest single infestation in Australia (Astron 2014; NHT 2003).
Figure 4 Vegetation types present within the Trial Pond study area More detail on flora and vegetation can be found in the report prepared by Phoenix Environmental Sciences (Attachment 4A)
Mardie Project – Pilot Evaporation Pond Trial 6 DWER – Works Approval Appendix 3A
4.2 Fauna and fauna habitats Fourteen fauna habitats (Table 3) have been recognised for the Mardie Project, including four within the Trial Pond study area. Fauna habitat within the Trial Pond study area is also dominated by mudflat/saltflat, spinifex grassland and Prosopis shrublands (Figure 3). None of these habitats are restricted within the Mardie Project or indeed regionally.
Table 3 Fauna habitat types Mardie Project and Trial Pond study areas
More detail on fauna and fauna habitats can be found in the report prepared by Phoenix Environmental Sciences (Attachment 4A)
4.3 Geology Regional geology is well mapped and as part of the Mardie Project detailed investigations have been undertaken within the project area. The white area is clay to surface with or without a salt crust. The light is unconsolidated alluvium consisting of beach sands and fine gravels. The Orange area is an alluvium of clay, gravels and fine sands interspersed. The materials are loosely agglomerated in some zones.
Mardie Project – Pilot Evaporation Pond Trial 7 DWER – Works Approval Appendix 3A
Figure 5 - Geology Map of Area
4.4 Topography and Soils The area is very flat between 1.25m and 2.0m AHD over the entire mud/salt flats. Within the flats the occasional island rises to a nominal RL of 4.4m AHD, the eastern edge of the mudflats presents as a rise to approximately 4.5m AHD.
Figure 6 is a photo of the Error! Reference source not found. proposed pilot evaporation trial pond area. The photo was captured from the raised island which is nominally 2m above the brown/white clay. The gray scree consists of loose gravel rocks which overlay brown clays. The hypersaline
Mardie Project – Pilot Evaporation Pond Trial 8 DWER – Works Approval Appendix 3A ground water is approximately 500mm below the clay surface. The quad bike tracks indicate the direction of the proposed access track, in the distance on the slightly raised ground is a mixture of spinifex and the declared pest (C2 control classification, DPIRD 2018) Prosopis sp1. (Mesquite).
Figure 6 - Proposed pilot evaporation pond area
4.5 Climate The Mardie regional climate is classed by the Bureau of Meteorology (BoM) as ‘Grassland’ characterised by year-round hot weather. Rains occur predominately in the first half of the year with summer rainfall related to tropical lows including cyclones and ex-tropical cyclones. Winter rains are typically the result of the northern extent of large southern fronts. The Mardie Project has undertaken detailed analysis of the BoM data and installed in wet and dry bulb temperature loggers within the project footprint. Figure 7 indicates the long term mean rainfall and evaporation.
Mardie Project – Pilot Evaporation Pond Trial 9 DWER – Works Approval Appendix 3A
Figure 7 - Monthly Mean Rainfall and Evaporation Figure 8 indicates the long term monthly mean maximum and minimum temperatures and the wind speed at 9.00am and 3 pm.
Figure 8 - Mean Monthly Max, Min temperature and wind speed
Mardie Project – Pilot Evaporation Pond Trial 10 DWER – Works Approval Appendix 3A
Wind roses for 9:00am and 3:00pm at Mardie Station are shown on Figure 9. These indicate morning Southerly to Easterly winds followed by afternoon Westerly to Northerly winds. The winds will on average change the air over the solar ponds every 30 minutes reducing the impact of the ponds on local relative humidity.
Figure 9 - Mardie Station Wind Roses
Figure 10 - Australian pan evaporation data
4.6 Surface Hydrology A surface hydrology study has been completed as part of the Mardie Project Prefeasibility study. The work included:
Mardie Project – Pilot Evaporation Pond Trial 11 DWER – Works Approval Appendix 3A
• a hinterland drainage study based on storm events and the impacts on the project area • coastal inundation study based on tidal inundation of the project footprint.
The results of these studies have been used to:
• set the bund wall height of 4.2m AHD for a ARI of 1:100 year • select the rock armor for bund wall protection, and • design the project to allow east-west movement of flood waters without impacting the Mardie project.
The studies have been used to select the site for the trial ponds ensuring that the ponds area protected from both land and sea inundation and the site infrastructure is installed above the maximum flood level.
The proposed pilot evaporation ponds have been situated on the east side of a mud flat island with a 4.2m AHD high bund wall around the outside perimeter that will protect the ponds from storm surge. Surface water from the east will flow around the pond structure and out onto the mud flats.
4.7 Ground Water Samples of water from the mud flats have been collected and analysed which confirmed the water table is between 0.3m and 0.8m below the surface the with salinity varying between 130,000uS/cm and 210,000uS/cm, or up to 3 times the salinity of Mardie seawater which averaged 69,000 uS/cm.
No impact to the ground water is anticipated from a seawater pipeline leak because the mudflats are regularly inundated by seawater at high tide.
No impact to the ground water salinity is anticipated from the pond area from seepage because:
• Ponds P1 to P7 are unlined and contain concentrated sea water which averaged will not exceed the salinity of the underlying ground water. • Pond P8 and all the crystallisers will be lined with a HDPE membrane preventing leakage.
5 STAKEHOLDER ENGAGEMENT BCI has undertaken the following stakeholder consultation in regards to the Project with the following stakeholders:
Table 4 Stakeholder Engagement
Stakeholder Discussion Outcome / Actions
Completed discussion with YM Yaburara and Mardudunera People CEO (Amanda Wheeler) Completed heritage survey People regarding Project rationale, No Engaged in on-going discussions objections were raised.
Mardie Project – Pilot Evaporation Pond Trial 12 DWER – Works Approval Appendix 3A
General discussion outlining the Shire of Roebourne/City of Project rationale and implementation Initial discussions completed Karratha activities. No objections were raised.
Email discussion held regarding approvals required for the Pilot Evaporation Pond Trial Project. No approvals required under Part IV of BCI to discuss project with DWER DWER – EPA EP Act. Discussion held with Vanessa and DMIRS to gain Part V approval Robinson and Peter Tapsell. and Mining Act Approval Discussion regarding applying for works approval and applying for Licence to Operate (LTO)
Overview of Mardie Project given and overview of trial pond project.
DMIRS Agreed that work could be completed BCP to submit a POW and under a POW-E and Part V EP Act accompanying letter to Matt Approvals. Boardman Discussion held with Danielle Risby and Matt Boardman
Pilot evaporation pond works scheduled to minimise impact on On-site meetings, telephone and Mardie Station station, Access through the station email discussions agreed with map signposting and instructions prepared.
Pilbara Mesquite Management Control of impacted mesquite during Works will use best practice Committee clearing, construction and operation clearing and control methods.
No objections or concerns were raised by any of the above stakeholders, providing the appropriate approvals are granted. Please refer to Section 6.3 Other Relevant Licences/Permits for more information on additional approvals.
6 PRESCRIBED PREMISE CATEGORY
6.1 DWER Approvals No Part IV approvals required. Part V of EP Act approvals outlined in this submission
6.2 Documents associated with this proposal
The following documents related to the Project are outlined in the table below and are available on request.
Table 5 Site Surveys and assessments
Mardie Project – Pilot Evaporation Pond Trial 13 DWER – Works Approval Appendix 3A
Factor Study area Study effort
Vegetation Full Project and trial ponds Two-season, Level 2 survey. Local impact assessment report
Full Project and trial ponds Habitat assessments; targeted surveys Terrestrial Vertebrate Fauna Full Project and trial ponds Habitat assessments; targeted surveys
ASS Full Project and trial ponds Static testing of drill samples, Leachate, waste fines and process liquor
6.3 Other Relevant Licenses / Permits
6.3.1 DMIRS POW No. 75407 and PMP No. PM450-316706 have been submitted.
The quantity of diesel and minor other fuels stored on site will not require a Storage of Dangerous Goods Licence (DGL).
6.3.2 Local Government Any applicable Local Government approvals required will be obtained from the Shire of Roebourne prior to commencement of construction.
The Project and the proposed operations outlined in this application will be constructed and operated in accordance with approvals issued under the Mining Act 1978. As such, this infrastructure will not be subject to the Planning and Development Act 2005 or any other local government planning by-laws.
Mardie Project – Pilot Evaporation Pond Trial 14 DWER – Works Approval Appendix 3A
7 PROPOSAL DESCRIPTION
7.1 Trial Evaporation Pond Project Objectives The purpose of the proposed works is to:
• confirm the evaporation rates at each brine density stage during solar concentration and crystallisation; • calibrate the results using recorded atmospheric conditions to long term BOM records; • provide raw salt product samples for laboratory and pilot processing trials; and, • produce samples of the resultant waste bitterns for characterisation.
7.2 Scope and scale of proposed activities
7.2.1 Key Characteristics
This works approval application relates to a pilot trial for the production of salt (NaCl), mixed potassium salts for further processing into Sulphate of Potash (K2SO4) and waste bitterns for characterisation.
Details of key characteristics relevant to Category 14 prescribed premises activities are summarised in Table 6.
Table 6 - Key Characteristics
Project Element Description
Operational Purpose Pilot seawater solar evaporation trials Location of Nominally 122km southwest of Karratha Operations Annual Production 350t of raw NaCl salt and 7.5t of mixed potassium and magnesium salts Project Duration 24 months
Processing Method Solar evaporation of seawater
Tailings No tailings will be produced Waste 60t of mixed NaCl and Magnesium salts Diesel will be used to fuel the generators for supply of power and mobile equipment. Small amounts of unleaded fuel will be used in quad bikes used to Reagents and Fuels access the seawater pump and periodically check the pipeline. No reagents will be used in the process. Product will be transported to Perth in 1 tonne bulka bags, IBC’s or sealed 20l Product Transport plastic drums 1-2 people, who will be accommodated at the local pastoral station or at Fortescue Workforce roadhouse village
Mardie Project – Pilot Evaporation Pond Trial 15 DWER – Works Approval Appendix 3A
Seawater abstraction Nominally 22,000m3 over 12 months Other water Nil, provided via RO plant attached to pilot program requirements Nominal demand of 7.5 KVA provided by diesel generators for pumps and site Power Requirements laboratory Estimated ground 3.2ha for the pond area. The sea water pipeline will be laid on the surface and disturbance removed on completion
7.3 Pilot Evaporation Project Location The pilot evaporation trial access track will commence on a local station track at the north western corner of E08/2740 and then continue north along the boundary of lease E08/1849 until it reaches the trial site as indicated on Figure 11.
Mardie Project – Pilot Evaporation Pond Trial 16 DWER – Works Approval Appendix 3A
Figure 11 - Pilot Evaporation Project Location
Mardie Project – Pilot Evaporation Pond Trial 17 DWER – Works Approval Appendix 3A
7.4 Pilot Evaporation Ponds
7.4.1 Size The proposed trial evaporation ponds will be contained within a bunded area 180m long by 120m wide as indicated in Figure 12.
Seawater Generator , RO Plant, fuel
natural island bank, 2.5m high Store Gen Lab
C1 C1 P7 P Pan evaporators P1 P8 A B P P6 C2 C2 A B P2 P5 C4
150 m 150 C3 Access track P C6 C5 C11
P3 P4 C7 C8 C9 C10 P
160 m
Figure 12 - Pilot Evaporation Pond Layout
The disturbance area will extend up to 40m outside the bund wall for the purpose of operating a dozer and grader, allowing sufficient room to level the area, remove gravel scree and obtain natural clays for wall and pond floor construction.
Table 7 lists the pond dimensions.
Mardie Project – Pilot Evaporation Pond Trial 18 DWER – Works Approval Appendix 3A
Table 7 - Pilot pond internal dimensions
Length Width Area Fill Volume Pond (m) (m) (m2) (m3)
P1 50 26 1292 650 P2 50 29 1457 730
P3 50 26 1300 650
P4 40 25 1000 500 P5 40 23 924 460
P6 40 12 482 250
P7 20 15 305 150 P8 18 12 209 100
C1 20 19.5 390 195
C2 20 19.5 390 195 C3 10 7.3 73 37
C4 10 6.6 66 33
C5 10 6.1 61 31 C6 10 5.3 53 27
C7 10 4.6 46 23
C8 10 7.2 72 36 C9 10 11.5 115 58
C10 10 11.6 116 58
C11 10 9.6 96 48
The flat top of pond walls will be 2m wide with access ramps formed to allow safe operating access.
7.4.2 Construction Method
The area selected is within the proposed crystalliser area of the Mardie project and the intention is to use and test local materials to validate broad area geotechnical testwork completed during the Prefeasibility study. The bund wall construction consists of:
• Removal of highly permeable gravels from the surface and covering underlying clay nominally 400-700mm below the surface. • Construction of a bund wall clay core from the exposed clay base nominally 2m high
Mardie Project – Pilot Evaporation Pond Trial 19 DWER – Works Approval Appendix 3A
• Cover of the clay core using local gravels and fines materials blended to from a compactable general fill material • Lining of the outside of the bund wall with locally won light weight rock armour.
The internal pond walls for ponds P1 to P7 will be constructed similar to the external wall with the top of wall height nominally 1m lower.
Crystallisers C1 to C11 will be lined with 1mm HDPE to allow the precipitated salts to be collected for analysis.
Figure 13 indicates the proposed bund wall cross section and internal pond walls.
Compacted road base
Clay Core Gravel Layer - removed to underlying clay General fill Internal wall to form core seal Average water level Rock armor layer 1.4m 0.5m
Underlying Clay
Figure 13 - external bund wall and internal pond wall sections
Pumps and weirs are located to control the flow of brine between the ponds. There are placed to represent to proposed full scale operation.
The pan evaporators will be fabricated from stainless steel to BOM specifications and placed on timber pallets.
7.4.3 Source of Construction Materials
Geotechnical work completed during the PFS and subsequent site inspection indicates the selected site will have gravel/sand scree up to 600mm deep overlaying clay. The scree will be graded into a stock pile windrow and blended and used as general fill to construct the bund wall.
Underlying clays will be excavated and used to build the clay core.
Mardie Project – Pilot Evaporation Pond Trial 20 DWER – Works Approval Appendix 3A
Around the raised dune there is loosely agglomerated rock, which is proposed for the bund wall armour rock. The material will be extracted using mechanical equipment without the need for explosives.
7.4.4 Operational Management Plan
The Mardie Project pilot test work program has been developed to validate key PFS assumptions including: • Collection of detailed weather parameters on a 30 minute interval basis • Analysis of site specific evaporation rates for evaporation ponds and crystallisers • Confirm civil construction techniques • Produce crystallised salt samples for salt purification and SOP process plant testwork; and • Produce raw salt product samples.
Once the ponds have been constructed seawater from the ocean will be pumped into ponds P1 to P8 filling them to a depth of 500mm. As evaporation occurs brine densities will increase in each pond. As each pond density reaches its design density it will be maintained by transferring brine from up and down stream ponds which will be representative of the proposed continuous flow design incorporated in the Mardie Project eight pond concentrator system. Pond 8 will have a brine density just lower than when NaCl begins to precipitate. At this point it will be transferred into Crystallisers where in C1 and C2 high purity NaCl is precipitated. The layout indicated two parallel C1 and C2 Crystallisers. This is to allow 50% of the crystalliser to be drained to C3 and allow the NaCl to be dry harvested by hand and using a bobcat. This will be representative of the high purity raw salt from the proposed Mardie Project.
The brine is then transferred to the down stream crystallisers C3 to C11 and will follow the same process. Because the volumes are much reduced a single crystalliser is proposed at the stage.
The precipitated salts at each crystalliser stage will be representative of the proposed Mardie Project solar evaporation stages.
The continuous flow of brine through the ponds and crystallisers will be monitored daily and seawater added into pond P1 to retain pond levels. This will be completed using a small submersible electric pump and nominal 4.8km long 75dia HDPE pipeline.
After 12 months operation the predicted tonnes of salts listed in the key characteristics will be produced.
Mardie Project – Pilot Evaporation Pond Trial 21 DWER – Works Approval Appendix 3A
The control pan evaporators will be filled with brine artificially concentrated (using heat lamps in a laboratory) to the design density of each pond and crystalliser. Daily the net evaporation will be recorded in each pan and the pan will be filled to the original starting level.
7.5 Key Infrastructure & Equipment The key infrastructure associated with and supporting the proposed pilot trial ponds includes:
• Laboratory sea container and test equipment – used to complete daily site tests for each pond brine to ensure that the system is operating within proposed design tolerances. • Storage sea container – used to store tools and maintenance equipment. • Diesel powered generator and bunded fuel tank – used to provide power to the laboratory equipment and room and brine pumps. • Seawater pump, local diesel generator and 4.8km 75mm dia HDPE pipeline. • Water tanks – for storage of seawater ready for decant into pond 1 and to supply the RO plant. • Nominal 20 l/hr self-contained reverse osmosis for provision of fresh water to fill pan evaporators, operate the laboratory and general washdown. • Fresh water storage tank and dispensing pump. • Mobile equipment – bobcat for minor pond maintenance, quad bike for seawater pump and pipeline operation, 4WD vehicle for general use and out-loading of raw salts. • Portable pump used as standby for pond to pond transfers and storm water management.
7.6 Unique processes to be tested
The pilot trials will test the solar evaporation of seawater to a brine density of 1.328, well past the density of bitterns discharged from solar pond operations along the Western Australian coast, which are typically around 1.25. Between the density of 1.25 and 1.328 little work has been completed for coastal salt operations and this will be a unique process. This kind of evaporation work has never been completed for the Mardie area and even fresh water pan evaporation records are not included at the Mardie BOM site.
7.7 Conservation Areas The Project area is not located within:
• an Environmentally Sensitive Area (ESA) as listed under the Environmental Protection (EP) Act 1986.
Mardie Project – Pilot Evaporation Pond Trial 22 DWER – Works Approval Appendix 3A
• a ‘specified ecosystem’ as described in the Department of Environment Regulation (DER), Environmental Siting Guidelines (2016) • Conservation Reserve/ DBCA managed land (including Threatened or Priority Ecological Community), Ramsar Site, Significant/ Nationally Important Wetland or a Bush Forever Site. The nearest known specified ecosystem is Fortescue River delta. This specified ecosystem is not proposed to be impacted by pilot trial ponds development or disturbance foot print.
7.8 Sensitive Receptors / Separation Distances
No Threatened Ecological Communities (TECs) or Priority Ecological Communities (PECs) occur within, or adjacent to the trial pond survey area. The only potential sensitive receptor within the vicinity of the Project is the Mardie Pastoral station accommodation facilities for the Project construction and operational employees and contractors.
During construction and initial operations of the trial pond, employees and contractors will be accommodated at the Fortescue Roadhouse, approximately 35km from the proposed premises.
The EPA Guidance Statement 3. Separation Distances between Industrial and Sensitive Land Uses (EPA 2005) doesn’t delineate a separation distance for salt evaporation activities. However, Appendix 1, Table 1 did determine that there is a ‘Specified Ecosystem’ across the project area; namely # 31. Acid Sulfate Soils (ASS) Risk Area (map, Pilbara Coastline Department of Environment Regulation). An assessment for ASS was undertaken by Stantec (Stantec, 2017), conducted in accordance with the Department of Environment Regulation (DER) 2015 Guidelines for Identification and Investigation of Acid Sulfate Soils and Acidic Landscapes (DER, 2015). The outcome of the assessment determined that due to the low ASS risk of surface soils within the Project area, further investigations into the presence of ASS is not considered necessary, unless disturbance is planned at greater depths (>1 mbgl). Therefore, no risk from ASS is expected due to construction or operational activities of the proposed test ponds.
Furthermore, BCI will ensure that the proposed premise location will not impact sensitive receptors within the Project locality, i.e. Mardie Station.
During operations, all employees and contractors for the Project will be accommodated at the abovementioned Fortescue Roadhouse.
7.9 Commissioning
It is requested that commissioning of the trial ponds be undertaken under the Works Approval and prior to submission of the required Compliance Document and granting of a Licence to enable
Mardie Project – Pilot Evaporation Pond Trial 23 DWER – Works Approval Appendix 3A various components to be trialed and tested. This will enable testing of equipment whilst the licence is being assessed.
Commissioning will consist of two stages, pre-commissioning and load commissioning and is expected to take a maximum of three months. Pre-commissioning will consist of the electrical and mechanical testing of the equipment. This will involve running or live testing all items of equipment to confirm that they operate as per their intended function.
The system will then go through the load commissioning stage; namely the test ponds will be operated to test and confirm all control functions including pumps and generators are working correctly.
8 ENVIRONMENTAL MANAGEMENT Emissions, Discharges and Waste will be responsibly managed as described in the following sections.
8.1 Process Emissions
There are no planned process emissions from the pilot evaporation pond trials.
The pilot evaporation pond trials will use solar evaporation to reduce seawater to solids and a small residue brine. The solid salts will remain in each pond forming part of the seepage and bearing capacity testwork. Solids for off-site testwork will be dry harvested and placed in drums for transport to laboratories. The residue liquor will be transferred to containers and be analyzed off site for potential byproducts.
8.2 Gaseous and Particulate Emissions
Diesel generators will be used at the seawater pump and pilot evaporation ponds to generate electrical power. The estimated operating demand at the seawater pump is 1.8kW and at the Pilot evaporation ponds is 4.2 kW. Based on the manufacturers energy consumption and emissions data the resultant emission of CO2 will be 3.4kg/hr, estimated to be 34kg of CO2 per day.
8.3 Dust Emissions
The Project will be situated a minimum of 9km away from Mardie Station. Based on the configuration of the operations, there are no significant environmental receptors that are likely to be affected by any dust that is generated through the Project activities.
Water trucks will be used on roads to suppress dust, if required. Visual dust monitoring will be used to confirm that controls are effective or as a basis for implementing corrective action.
Mardie Project – Pilot Evaporation Pond Trial 24 DWER – Works Approval Appendix 3A
8.4 Odour Emissions
The Project will not emit any odour.
8.5 Noise Emissions
Water pumping activities, and power generation, will produce additional noise levels. However, given that there are no sensitive receptors in proximity to the Project noise is not expected to be an issue.
BCI understands that the Environmental Protection (Noise) Regulations 1997 apply. BCI will:
• Use equipment, machines and vehicles that would be the quietest, reasonably available, consistent with operational requirements that would be routinely maintained to ensure the effectiveness of noise suppression systems and equipment. • Inform all personnel (including contractors) through site inductions of their responsibilities and the importance of managing noise levels during the construction phase and ongoing operations.
All construction and operations will be expected to comply with the Environmental Protection (Noise) Regulations 1997 (noting that Clause 13 of the Regulations covers construction noise and how it is managed through the Regulations).
8.6 Discharges to Water
There will be no discharges to water from the Project. The Project is regularly inundated with seawater, so any potential discharges will be diluted.
8.6.1 Stormwater Control / Emissions
Rain falling directly into ponds will naturally evaporate. Rain falling inside the perimeter bund but outside the ponds will evaporate or seep into the ground, identical to the current natural situation. Should an unusual or extreme rain event occur water collected in the pond area will gravitate to a sump where it will be tested before it is pumped over the bund wall into the environment, in this type of extreme event the entire Mardie region is likely to be flooded and the mudflats under water.
8.6.2 Surface Water Management
Mardie Project – Pilot Evaporation Pond Trial 25 DWER – Works Approval Appendix 3A
The Pilot Evaporation ponds have been located against an existing naturally formed raised island on the mud flats. The mud flat component is periodically inundated via two mechanisms:
• Tidal cycles, and • Extreme rainfall events (cyclones).
Under normal tide cycles the area will be inundated for short periods on the highest tides several times per month. The depth of seawater at hightide will not exceed 100mm unless there is an extreme storm surge associated with the high tide. Measures to protect against an extreme event include:
• construction of a perimeter bund wall with a top level set at the calculated 1:100 ARI. • positioning of the ponds to the east side of the naturally occurring island away from direct impact of ocean storm events, • protection of the outside of the perimeter bund wall with rock material, to protect against erosion • installation of supporting infrastructure on the top of the island above the inundation level of an extreme event • installation of the seawater pump generator on raised ground above the calculated storm inundation water level.
An extreme rainfall event can be associated with a cyclone. In these events surface water can flow from the higher land to the east down onto the mudflats. The pilot evaporation ponds have been positioned to allow any surface flow to pass along the natural creek lines either side of the perimeter wall. Rock protection has been included to eliminate wall erosion.
Management measures will include:
• Any evidence of erosion, disturbance to natural drainage flow or impact on vegetation must be reported to the Project Manager and be remediated as required; • Site surfaces will be shaped to allow for natural drainage and to avoid pooling or ponding on site; • Disturbance will be minimized.
8.7 Discharges to Land
There will be no discharges to land from the Project.
Mardie Project – Pilot Evaporation Pond Trial 26 DWER – Works Approval Appendix 3A
8.8 Solid and Liquid Waste Management
Solid and liquid wastes generated from construction and ongoing operations may include:
• Inert wastes such as glass, paper, cardboard, wood, bricks, concrete, plastics, scrap metal, obsolete or expired equipment (e.g. transformers, pumps and pipes); • Domestic waste including the generation of putrescibles (e.g. kitchen scraps), non- recyclable packaging and non-hazardous liquids; • Sewage and wastewater from toilets and onsite ablutions; and • Hydrocarbon waste generated from fuel spills.
BCI has an obligation to manage waste disposal in accordance with the Environmental Protection Regulations 1987 and the Environmental Protection (Controlled Waste) Regulations 2004. These regulations govern the general control of pollution and outline obligations regarding the transportation and disposal of ‘controlled’ wastes.
BCI will implement the following management measures in regards to waste storage and disposal:
• Disposing of putrescible and inert waste to an appropriately licensed facility (off site), • Collecting and treating ablution effluent prior to removal from site by approved controlled waste carrier; and • Maintaining and servicing equipment regularly.
8.9 Light Emissions
Additional lighting will be required to service the Project. Given the distance to the nearest sensitive receptor, nuisance light is not expected to be an issue. There is potentially some impact to local fauna from additional light emissions.
Managing impacts of light overspill on fauna during construction and operations will be conducted through the implementation of the following management strategies:
• All external lighting will be targeted where possible, using shields and directional lighting to minimise light spill beyond the required work area; and • External lighting will use, where possible, red or low pressure sodium lights. Bright white lights such as mercury vapour, metal halide or florescent will be avoided where possible.
The design of these systems will be such that light spill to the surrounding environment will be minimised as far as practicable.
Mardie Project – Pilot Evaporation Pond Trial 27 DWER – Works Approval Appendix 3A
8.10 Hydrocarbon/Chemical Storage
The design and construction of tanks, pipes and bunding will comply with all relevant regulations under the Dangerous Goods Act 2004 (WA) to prevent and/or manage spills. Hydrocarbons and chemicals will be stored in bunded areas. The bund will be constructed in an impervious material to comply with Australian Standard (AS) 1940 – 2004 ‘The Storage and Handling of Flammable and Combustible Liquids’ with a minimum retention capacity of 110%. Bunded areas will be regularly maintained by inspecting the integrity of the bund, regularly cleaning out of the bund and checking that any valves are sealed and kept in the closed position;
The following measures are proposed to be implemented to manage and mitigate potential issues associated with hydrocarbon and chemicals handling during construction and operations at the Project:
• Separation of hydrocarbon materials from other facilities and people, segregation from stored dangerous goods, placarding, providing firefighting equipment at hydrocarbon and chemicals storage and handling areas. • Vehicles will be refuelled by a mobile fuel truck utilising drip trays; • The diesel fuel will be pumped and not gravity fed into vehicles/generators and the pump will be installed with a shut off device, so that the pump can be shut off in case of an emergency. The shut off device will be easily accessible and clearly identified; • The Project area will be equipped with spill kits and equipment that will be regularly monitored and maintained. The kit will include sufficient quantities absorbent materials, equipment for recovering spilled materials, containers for recovered materials and personal protective equipment; • In the case that a spill occurs, it will be reported immediately to the Site Manager and the area around the spill will be isolated and mopped up using the spill response kit and equipment; • The waste from the spill will be stored separately and isolated, until the spill waste is collected and disposed by a licensed contractor; and • All site personnel will be made aware of the hydrocarbon management strategies through training at inductions and ‘tool-box’ meetings.
8.11 Contaminated Sites
No known contaminated sites exist within the proposed premise boundary. The works proposed are also unlikely to give rise to any contamination given the safeguards proposed in this document.
Mardie Project – Pilot Evaporation Pond Trial 28 DWER – Works Approval Appendix 3A
8.12 Other Emissions and Discharges
There are no further anticipated impacts to groundwater, soil hygiene, visual impact, flora and fauna as the result of the implementation of this proposed works approval and ongoing operations. No increase in the risk of incidents which may cause harm to the environment (or personnel) is anticipated to occur because of the installation and operation of the trial ponds that have not been considered in the risk assessment (See Section 11 for more details).
All management of emissions and discharges will be considered in line with the surrounding receiving environment and implemented in line with approval guidelines and associated industry best practice.
9 INCIDENT RESPONSE
9.1 Seawater Spill Response Seawater could spill due to a leak in the seawater pipeline or a breach of the perimeter bund wall and the internal pond walls. A leak from the seawater pipeline is considered the most likely of the two events. Operational protocols include a daily inspection. In additional the system has high and low pressure safety switches and flow meter to confirm that the pump only operates when required and when the pump is operating that water is flowing into the storage tank. The method of control will limit the volume of a spill and corrective action would be undertaken to fix a leak if one occurs. The pipeline route is across the mudflats which are inundated by seawater several times per month at high tide and wherefore a small leak is unlikely to have any impact.
A breach of the perimeter bund wall has been considered by the project risk committee as the major cause of a potential breach is a result of a severe cyclone where the damage is cause by excessive wind and a storm surge at high tide. The bund wall design has been designed to protect against a 1:100 ARI event. The response to the cyclone is to evacuate area project until it is safe to return. I full evaluation of the project would be undertaken on return to the site and corrective measures instigated.
9.2 Incident Response
If a potential pollution incident occurs (e.g. hydrocarbons spill), the Site Manager will be notified, the activity causing the problem will cease and an investigation will be initiated immediately. The following corrective action will be taken as soon as practicable:
Mardie Project – Pilot Evaporation Pond Trial 29 DWER – Works Approval Appendix 3A
• Recording of the date, time and reason for the incident; • Estimation of the period over which the incident occurred; • Determination of the extent of the emissions or discharges over that period and potential or known environmental consequences; • Establishment and implementation of corrective action taken or planned to mitigate adverse environmental consequences; and • Establishment of a corrective action to prevent a recurrence of the incident.
The Site Manager will advise DWER within 24 hours of becoming aware of an incident which may have resulted in emissions which exceeded works approval limits.
The Project will be equipped with spill kits and spill response equipment that will be regularly maintained. The kits include absorbent materials, equipment for recovering spilled materials, containers for recovered materials and personal protective equipment. In the event of a fuel or chemical spill, the spill will be contained and the source will be isolated and recovered immediately using absorbent materials, which will then be placed in disposable drums or containers onsite.
Any contaminated soil or absorbent material resulting from a fuel or chemical spill will be removed by a licensed contractor to an authorised waste disposal site. Where necessary, validation sampling will be undertaken to verify that all contaminated soil has been removed. All spills that may cause a significant environmental impact will be reported to the DWER as soon as practicable.
All site personnel will be trained in the site’s procedure to follow in the event of a hydrocarbon spill
Once the incident has been investigated, the Site Manager will advise DWER in writing of the status of corrective actions implemented to address the problem.
9.3 Complaints
The Project will record any complaints in the BCI Complaints Register. If a complaint is received, it is most likely to be from an adjoining landholder, either the pastoralist from Mardie Station or another lease holder. Records of any correspondence and dealing with the complainant will be maintained.
Should a complaint be received, the Project Manager will contact any complainants that have concerns related to the environmental issues and determine the nature of the issue. The Project Manager will take steps to ensure that any identified impacts are addressed. If the issue relates to matters covered by the licence issued under Part V of the EP Act, the Project Manager will advise
Mardie Project – Pilot Evaporation Pond Trial 30 DWER – Works Approval Appendix 3A
DWER of a valid complaint and advise in writing the corrective actions implemented to address the problem.
10 RISK ASSESSMENT
BCI has completed a risk assessment of the pilot test pond activities proposed under this works approval application and is offered to assist DWER with its own assessment.
Information on the biophysical setting within which the trial would take place is provided in Section 7.
Selected technical studies used to prepare the “Existing Conditions” summary are appended to the works approval as Attachments 3C1 and 3C2.
10.1 Risk Assessment Process
The risk process was sourced from DER Guidance Risk Assessments - Part V, Division 3, Environmental Protection Act 1986 (February 2017).
A risk register with further details on inherent and residual risk assessments for construction and operations of the Mardie trial ponds is presented in Attachment 8A of the works approval application.
Mardie Project – Pilot Evaporation Pond Trial 31 DWER – Works Approval Appendix 3A
11 COST OF PROJECT
The estimated capital cost of the project is highlighted in Table XX
Cost of Facilities
Prescribed Premise Capital Cost Mobilisation costs $30,000 Construction costs of ponds $325,000 Laboratory costs $125,000 Total costs $480,000
Mardie Project – Pilot Evaporation Pond Trial 32
12 APPENDIX Appendix A - Mardie Trial Pond PoW Memo PhoenixEnvSci
Appendix B - Stantec ASS Investigation
Mardie Project – Pilot Evaporation Pond Trial 33