Weston Aluminium Pty Ltd 06-Sep-2016
Environmental Assessment: Spent Potlining Processing
Modification to DA 86_04_01 & DA_10397 of 1995
AECOM Environmental Assessment: Spent Potlining Processing – DA 86_04_01 MOD 10 & DA_10397 MOD 8
Environmental Assessment: Spent Potlining Processing DA 86_04_01 MOD 10 & DA_10397 MOD 8
Client: Weston Aluminium Pty Ltd
ABN: 91 075 245 108
Prepared by
AECOM Australia Pty Ltd 17 Warabrook Boulevard, Warabrook NSW 2304, PO Box 73, Hunter Region MC NSW 2310, Australia T +61 2 4911 4900 F +61 2 4911 4999 www.aecom.com ABN 20 093 846 925
06-Sep-2016
Job No.: 60486360
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© AECOM Australia Pty Ltd (AECOM). All rights reserved.
AECOM has prepared this document for the sole use of the Client and for a specific purpose, each as expressly stated in the document. No other party should rely on this document without the prior written consent of AECOM. AECOM undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and AECOM’s experience, having regard to assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. AECOM may also have relied upon information provided by the Client and other third parties to prepare this document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or disseminated only in its entirety.
Revision 0 – 06-Sep-2016 Prepared for – Weston Aluminium Pty Ltd – ABN: 91 075 245 108 AECOM Environmental Assessment: Spent Potlining Processing – DA 86_04_01 MOD 10 & DA_10397 MOD 8
Quality Information
Document Environmental Assessment: Spent Potlining Processing
Ref 60486360
Date 06-Sep-2016
Prepared by Simon Murphy
Reviewed by Catherine Brady
Revision History
Authorised Revision Revision Details Date Name/Position Signature
A 04-Aug-2016 Draft – WA Review Simon Murphy Principal Environmental Planner B 26-Aug-2016 Draft - Consistency Review Simon Murphy Principal Environmental Planner 0 06-Sep-2016 Final Submission Simon Murphy Principal Environmental Planner
Revision 0 – 06-Sep-2016 Prepared for – Weston Aluminium Pty Ltd – ABN: 91 075 245 108 AECOM Environmental Assessment: Spent Potlining Processing – DA 86_04_01 MOD 10 & DA_10397 MOD 8
Table of Contents Executive Summary i 1.0 Introduction 1 1.1 Purpose of this Document 1 1.2 Facility Background 1 1.2.1 Site Location 1 1.2.2 Proponent 1 1.2.3 Facility History 1 1.3 Project Background 2 1.3.1 Background 2 1.3.2 Spent Potlining 2 1.3.3 SPL Processing Trials and Validation 3 1.3.4 Processing of all SPL Material 4 1.3.5 Product Market 4 2.0 Description of the Project 7 2.1 Modification of Conditions 7 2.1.1 Required Modifications to DA 10397 of 1995 7 2.1.2 Required Modifications to DA 84-4-01 7 2.2 Interaction with Existing Operations 7 2.3 Interaction with Proposed Operations 8 2.4 Proposed Project 8 2.4.1 Process Description 8 2.4.2 Raw Materials 9 2.4.3 Operational Facilities 9 2.4.4 Transport Requirements 9 2.4.5 Workforce 9 2.4.6 Hours of Operation 9 2.4.7 Capital Investment Required 9 2.4.8 Construction Details 10 2.4.9 Environmental Controls 10 2.5 Need for the Project 10 2.6 Alternatives Considered 10 3.0 Statutory Planning 13 3.1 Overview 13 3.2 Commonwealth Legislative Requirements 13 3.2.1 Environment Protection and Biodiversity Conservation Act 1999 13 3.3 NSW Legislative Requirements 13 3.3.1 Environmental Planning and Assessment Act 1979 13 3.3.2 Protection of the Environment Operations Act 1997 14 3.3.3 Environmentally Hazardous Chemicals Act (1985) 14 3.4 Environmental Planning Instruments 14 3.4.1 State Environmental Planning Policy No.33 – Hazardous and Offensive Development 14 3.4.2 Cessnock Local Environmental Plan 2011 15 3.5 Basel Convention 15 4.0 Stakeholder Consultation 17 4.1 Consultation Undertaken to Date 17 4.2 Stakeholder Engagement Strategy 17 5.0 Prioritisation of Issues 19 5.1 Risk Matrix 19 5.2 Risk Analysis 19 5.3 Key Issues 20 6.0 Environmental Impact Assessment 21 6.1 Air Quality 21 6.1.1 Existing Environment 21 6.1.2 Potential Impacts 24
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6.1.3 Mitigation Measures 27 6.2 Hazard and Risk 27 6.2.1 Existing Environment 27 6.2.2 Potential Impacts 27 6.2.3 Mitigation Measures 30 6.3 Other Environmental Issues 31 7.0 Summary of Management Measures 35 8.0 Conclusion 37 9.0 References 39 Appendix A Secretary’s Environmental Assessment Requirements A Appendix B Mixed Cut SPL Trial Monitoring Report B Appendix C Existing Consents C Appendix D EPBC Protected Matters Search D Appendix E Air Quality Impact Assessment E Appendix F Preliminary Hazard Screening F
List of Tables Table 1 Existing WA Site Scheduled Activities 14 Table 2 Secretary’s Environmental Assessment Requirements for the Modifications 17 Table 3 Risk Matrix 19 Table 4 Risk Assessment 20 Table 5 Ambient Air Monitoring in Beresfield, NSW for 2015 (OEH website, accessed May 2016) 22 Table 6 Maximum Ambient HF Concentrations; October 2012 – 2014 (Hydro Aluminium) 23 Table 7 Comparison of Pollutant Concentrations for Stack 1 and Stack 5 for WA 25 Table 8 Pollutant Emission Rates for WA 25 Table 9 Predicted Ground Level Concentrations 26 Table 10 Compositions: First Cut SPL and Second Cut SPL 28 Table 11 Preliminary Risk Screening - Gap Analysis 29 Table 12 Other Environmental Issues 32 Table 13 Summary of Management Measures 35
List of Figures Figure 1 Site Location 5 Figure 2 Existing Weston Aluminium Operation 6 Figure 3 SPL Processing Schematic 11
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Executive Summary
Introduction This Environmental Assessment (EA) has been prepared for Weston Aluminium Pty Ltd (WA) to accompany a modification application under Section 75W of the Environmental Planning and Assessment Act 1979 (EP&A Act). WA proposes to modify existing Development Consent DA 86-04-01 and Land and Environment Court (LEC) 10397 of 1995 to allow for the commercial processing of Spent Potlining (SPL) wastes at their Kurri Kurri facility (the Project). SPL is a hazardous by-product of primary aluminium production, generated from the periodic de-lining of electrolytic cells. First Cut SPL (originating from the carbon cathode) and Second Cut SPL (refractory lining) contain varying proportions of aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants, and its management and disposal represents a major issue faced by the industry on a worldwide scale. At present, significant stockpiles of SPL exist within NSW and interstate, with limited technologies and reuse options developed for the sustainable processing of these materials. Domestic smelters continue to stockpile surplus SPL and/or export the waste to Europe for subsequent treatment. Such treatment is performed at significant expense, and relies on the transport of dangerous and hazardous materials over many jurisdictions and the vagaries of third party countries. This strategy is clearly not sustainable for the domestic industry. WA proposes to diversify its service provision to the aluminium smelting industry beyond the reprocessing of aluminium dross, Second Cut SPL and other aluminium-bearing by-products to secure future sustainability and growth. The Project, which is the subject of this application, is to treat and process all SPL waste arising from the primary aluminium manufacturing sector on a commercial scale. This would be undertaken in unison with WA’s existing approvals processing of Second Cut SPL. This would in effect allow WA to process both First and Second Cut SPL either separately or in any mixed ratio known as Mixed SPL. The current development consent authorises WA to process up to a combined 40,000 tonnes of aluminium dross and Second Cut SPL and process up to 35,000 tonnes of scrap aluminium metal per year on site. No change to the existing approved site tonnage limits is proposed as part of this Project. Since 2005, WA representatives have undertaken extensive research, both domestically and overseas, investigating available technologies for the treatment of SPL from primary aluminium smelters. In 2012, WA obtained consent to process Second Cut SPL on a commercial scale. Following WA’s trial series and commercial operation, WA has demonstrated that it can suitably process mixed and First Cut SPL in its existing plant. WA’s objective is to offer a sustainable solution to domestic smelters, enabling the cost-effective treatment of SPL and, in conjunction with other treated industrial by-products, formulate the manufacture of a value added substitute for manufacturing sector raw material inputs. This Project has also been developed in support of the Department of Environment’s (DoE) 2016 initiative program to develop the feasibility of an agreement between government and industry to actively clear stockpiles of SPL within NSW, QLD, VIC and TAS over a 10 year, or where possible, a shorter period.
Description of the Project SPL would be received, handled, stored and processed in the same manner as is currently managed at the WA site. SPL will be received either pre-crushed or uncrushed from various domestic aluminium smelters. The First Cut and Mixed SPL processing chain is identical to that of Second Cut SPL treatment currently undertaken at site and the same facilities, plant and equipment would be used for the recycling of all SPL input materials. The main steps undertaken by WA for the treatment and processing of SPL are: - Primary crushing (where necessary to achieve required particle size); - Controlled blending with other propriety additives, as required; - Fine milling; - Thermal treatment; and - Crushing and mixing (as required) and subsequent distribution to end markets.
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Where storage of untreated SPL is required prior to processing, it would be stored on the premises in accordance with the requirements of the Australian Dangerous Goods Code. The objective of the process is to thermally oxidise the cyanide within the SPL and modify the mineralogical composition so that the material can be transported as a value-added product. Previous trials conducted by WA demonstrated that the proposed process will allow WA to remain within its existing regulatory environmental compliance requirements. Consequently, no change to the existing Environmental Protection Licence (EPL) limits will be required for the Project.
Environmental Impact Assessment Air Quality An Air Quality Impact Assessment was prepared for the Project to determine the potential impacts of processing SPL in addition to the site’s existing operations. The CALPUFF model was used along with stack emissions data for both Dross and SPL processing operations coupled with emissions data from WA’s historical and recent SPL processing trials and commercial operations. Dispersion modelling demonstrated that there was only a minor change to the predicted ground level pollutant concentrations as a result of the proposed SPL processing extension scope. All predicted pollutant concentrations assessed demonstrated compliance with the Environment Protection Authority’s assessment criteria. On the basis of the dispersion modelling undertaken for the Project, the proposed SPL processing is not expected to result in a significant change to the air emissions from the facility and is not expected to result in adverse impacts on the surrounding environment. Hazard and Risk A preliminary risk screening assessment was undertaken to determine the potential need for further hazard assessment to be undertaken. The screening assessment identified that the proposed SPL inputs would have a similar risk profile to that of Second Cut SPL currently processed at WA. The preliminary risk screening also included a review of the Second Cut SPL Processing Preliminary Hazard Assessment (AECOM, 2012) previously prepared for the existing SPL processing operation. This identified that all previously recommended hazard and risk management safeguards are currently in place at WA and would continue to be appropriate for the management of hazards associated with the processing of all SPL waste arisings from the primary aluminium manufacturing sector. Based on the analysis conducted in the preliminary risk screening, the hazards associated with the proposed storage of SPL at the WA facility do not result in a change to the existing risk profile. Hence, the risk criteria published by the NSW DPI in HIPAP No.4 is not exceeded and the facility remains classified as ‘potentially hazardous’ and not ‘hazardous’. Therefore, with the previously recommended safeguards continuing to be in place for the operation of the Project, no further hazard analysis is deemed necessary for the Project to proceed. Other Environmental Factors An assessment was undertaken of the potential impacts of the Project on a range of other environmental factors: - Traffic; - Soil and Water; - Greenhouse Gas Emissions; - Noise; - Waste Management; - Social and Economic; - Visual; - Heritage; - Land use; and - Fauna and Flora.
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The Project is anticipated to have a negligible impact on these environmental issues as there would be no change to the existing tonnage processing limits, vehicle movements, site footprint, construction activities and operation of the facility.
Environmental Management The assessment of potential impacts that may occur as a result of the Project concluded that as the Project would use the same site processes, not increase the site’s existing tonnage limits, not result in an increase in hazards and not result in significant air emissions. Furthermore, existing site management measures are deemed suitable for the ongoing management of potential environmental impacts associated with the Project. WA therefore commits to the ongoing operation of the site’s Environmental Management System including procedures for the handling, storage and processing of SPL, and the operation of the site’s air pollution control systems.
Conclusion The Project offers a solution for the recycling of First Cut and Mixed fraction SPL, in addition to the Second Cut SPL processing, already undertaken by WA. The treatment and processing of all SPL waste arisings on a commercial scale by WA provides a solution to the stockpiled First Cut, Second Cut and Mixed SPL held by Australian aluminium producers and an alternative to the international transport of this hazardous material. In doing so it improves market versatility, product handling and reduces material losses while enabling WA to operate in a more sustainable manner. The potential adverse impacts of the Project have been assessed and shown not to be significant. With the implementation of the mitigation measures (existing and proposed), impacts would be eliminated or minimised. No change to WA’s existing EPL limits will be required for the Project. Additionally, the Project would have a positive impact on the community as it would help secure ongoing employment positions for WA staff and opportunities for local/regional contractors.
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1.0 Introduction
1.1 Purpose of this Document This Environmental Assessment (EA) has been prepared for Weston Aluminium Pty Ltd (WA) to accompany an application under Section 75W of the Environmental Planning and Assessment Act 1979 (EP&A Act) to modify existing Development Consent DA 86-04-01 and Land and Environment Court (LEC) 10397 of 1995. The modification is seeking approval for the commercial processing of Spent Potlining (SPL) wastes at WA’s Kurri Kurri facility (The Project). SPL is a hazardous by-product of primary aluminium production, generated from the periodic de-lining of electrolytic cells. First Cut SPL (originating from the carbon cathode) and Second Cut SPL (refractory lining) contain varying proportions of aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants, and its management and disposal represents a major issue faced by the industry on a worldwide scale. At present, significant stockpiles of SPL exist within NSW and interstate, with limited technologies and reuse options developed for the sustainable processing of these materials. Domestic smelters continue to stockpile surplus SPL and/or export the waste to Europe for subsequent treatment. Such treatment is performed at significant expense, and relies on the transport of dangerous and hazardous materials over many jurisdictions and the vagaries of third party countries. This strategy is clearly not sustainable for the domestic industry. WA proposes to diversify its service provision to aluminium smelters beyond the reprocessing of Second Cut SPL, aluminium dross and other aluminium-bearing by-products, to secure future sustainability and growth. The Project, which is the subject of this application, is to treat and process all SPL waste arisings from the primary aluminium manufacturing sector on a commercial scale. The Project does not seek to increase existing tonnage processing limits but rather seeks to amend the existing approval to also allow the processing of First Cut and Mixed SPL within existing tonnage limits. WA briefed the Department of Planning and Environment (DP&E) and the NSW Environmental Protection Authority (EPA) regarding the Project. Advice received from DP&E on 15 June 2016 confirmed that a modification to WA’s existing consent would be required for the Project and provided the Secretary’s Environmental Assessment Requirements (SEARs) for the modification Environmental Assessment (EA). A copy of these SEARs is attached at Appendix A. This EA provides a detailed assessment of the key environmental issues associated with the Project and has been prepared in accordance with the SEARs.
1.2 Facility Background 1.2.1 Site Location The existing aluminium recycling and refining facility is located on Lot 796 DP 39877 at 129 Mitchell Avenue, Kurri Kurri in the Hunter Valley, NSW. The site is owned by Weston Aluminium Pty Ltd. The location of the site is shown in Figure 1 and the existing site layout is detailed in Figure 2. The site is approximately 40 km northwest of Newcastle and is located within an established industrial area. Residential areas in Kurri Kurri (approximately 600m) and Weston (approximately 800m) are located to the south and west of the site, respectively. The Hydro Aluminium Smelter (now closed) is located approximately 2 km north of the site. 1.2.2 Proponent The plant is owned and operated by WA, which is majority owned by Watou Holdings and the balance by Asahi Seiren, a major secondary aluminium processor in the Japanese Aluminium industry. Both shareholders have an established track record in the operation of aluminium refining and waste recycling facilities through the operation of the existing development in Kurri Kurri and a number of facilities in Japan and Indonesia. 1.2.3 Facility History The facility commenced operations as a pilot plant in 1998 with six employees and one rotary furnace and has progressively grown to support a workforce of over 40 employees. The current WA facility recovers aluminium from dross, a by-product of the aluminium smelting process, sourced from aluminium smelters across Australia and New Zealand, and currently processes Second Cut SPL from the same sources.
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Dross is a dry metallic solid typically composed of aluminium, aluminium oxide, other metal oxides, traces of sodium aluminium fluoride (bath) and alloying metals. Dross can contain 30-75 percent metallic aluminium, which represents a significant loss of metal if not recovered. The plant also remelts and recycles scrap aluminium, producing deoxidant products for steel manufacturing industry. SPL is processed onsite to remove hazardous chemical compounds (e.g. cyanide) and transform its mineralogy. In 2012, WA received development consent for the receipt and processing of Second Cut SPL to complement other treatment technologies being developed domestically for First Cut SPL. Limited domestic treatment and reuse opportunities exist for SPL wastes, and historically, the aluminium industry has either stockpiled significant quantities of these wastes on smelter sites, or transported wastes in campaigns to Europe for treatment and processing. With the appropriate processing however, it can become a value added product which can be used as a substitute for raw materials in a number of manufacturing processes. The facility is currently approved to process up to a combined 40,000 tonnes of aluminium dross and Second Cut SPL, and processing of up to 35,000 tonnes of scrap aluminium metal per annum.
1.3 Project Background 1.3.1 Background Since 2005, WA representatives have undertaken extensive research, both domestically and overseas, investigating available technologies for the treatment of SPL from primary aluminium smelters. WA’s objective is to offer a sustainable solution to domestic smelters, enabling the cost-effective treatment of SPL and, in conjunction with other treated industrial by-products, formulate the manufacture of a value added substitute for manufacturing sector raw material inputs. Initially, the concept for processing of SPL at WA was conceived through WA’s Membership in the NSW Office for Environment Sustainability Advantage Program, and central foundation and ongoing involvement with the NSW Industrial Ecology Network. The Industrial Ecology Network comprises of like-minded industry, academics and Government regulators, eager to encourage the recovery of industrial by-products as valuable resources, and thereby achieve the diversion of large material volumes from landfill. Following initial environmental assessment (AECOM, 2012) and approval for the processing of Second Cut SPL in 2012 (DA 86-04-0-1Mod 7, and DA 10397 Mod 5), WA has gained a greater appreciation of SPL material legacy quantities, generation rates and limited domestic treatment capacity, and has further explored reuse opportunities for treated First Cut and Mixed fraction SPL. Whilst it is now current practice to segregate First and Second Cut SPL into separate stockpiles for storage, legacy management practices at some aluminium smelter have resulted in mixed stockpiles of SPL material being available for processing with varying ratios of First to Second Cut SPL. Stockpiles of First Cut, Second Cut and Mixed SPL material of varying ratios have been identified on both Hydro Aluminium and Tomago Aluminium sites. The quantification of existing SPL stockpiles and forecast SPL generation rates by aluminium smelters within eastern States, and the investigation of an agreement feasibility between government and industry for priority stockpile clearing, is currently the focus of the Department of Environment’s (DoE) 2016 ‘Spent Pot Lining project (feasibility of an agreement for clearing stockpiles)’ Project. WA is participating in this initiative. Given that WA has approval to process Second Cut SPL, this Project is now seeking approval to also process First Cut SPL and Mixed SPL as may be required by customers. 1.3.2 Spent Potlining SPL is a by-product of primary aluminium production (smelting). There are two types of SPL: - First Cut Spent Potlining – originating from the carbon cathode lining of aluminium production pots; and - Second Cut Spent Potlining – which is the refractory lining of aluminium production pots. Both First Cut SPL and Second Cut SPL contain varying proportions of aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants, with its management and disposal representing a major issue faced by the industry. Opportunities to recover mineral resources from SPL and reduce the total volume of waste from the primary aluminium manufacturing sector represent a favourable environmental outcome.
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WA has approval for the processing and treatment of Second Cut SPL. This EA has been prepared in support of an application to also allow the treatment and processing of First Cut and Mixed SPL. Collectively this would give WA the ability to process all SPL wastes. It is noted that drosses are also referred to in this EA in regards to total tonnages of material that can be processed at WA per year. Dross is the mass of impurities which floats on the surfaces of liquid aluminium and is removed during the aluminium smelting, handling and casting processes. For clarity, no changes to the processing of dross as they are currently undertaken at WA, is proposed in this Project. Drosses are stored, handled and processed separately to their SPL due to the different composition. 1.3.3 SPL Processing Trials and Validation WA undertook a number of trial processing events of First and Second Cut SPL in the lead up to seeking approval for the commercial processing of Second Cut SPL. The outcomes of these trials were confirmed during commercial scale processing. WA followed a similar path when proposing to process Mixed SPL. Details of these trials are summarised below. First and Second Cut SPL Processing Trials (2005 – 2012) Prior to seeking approval for the processing of Second Cut SPL at WA, an extensive trial and validation testing series were undertaken to demonstrate WA’s capability to process First and Second Cut SPL whilst achieving the following: - Cyanide destruction; - Low pollutant discharge concentrations, confirmed reliable performance of the existing lime-scrubber and fabric filter baghouse pollutant control systems to manage pollutant load from the SPL processing; - Confirmation through real-time emission monitoring that gaseous fluoride and particulate emission concentrations satisfied the regulatory compliance limits throughout the Trial intervals; and - Confirmation that the particle size distribution, fluoride content and composition profile of products generated are of a commercially viable nature such that it would be of interest to prospective customers. Further details regarding the SPL trials undertaken prior to receiving development consent for the commercial processing of Second Cut SPL are provide in the Second Cut SPL Processing Environmental Assessment (AECOM, 2012). Subsequent Second Cut SPL monitoring and emissions reporting since the start of commercial Second Cut SPL processing since 2012 has validated the trials undertaken. Commercial processing of First Cut SPL was not sought by WA at this time as other parties were focussing on treatment and reuse feasibility for this SPL input fraction. WA’s focus on Second Cut SPL was designed to complement these activities by others. Mixed SPL Processing Trials (2014 - 2016) Pursuant to the conditions of consent under DA 86-04-01 Modification No. 8 and LEC 10397 of 1995 Modification No. 6, and following approval to commercially process Second Cut SPL, WA undertook a trial processing up to 3,000 tonnes of Mixed SPL. A copy of the Monitoring and Verification Report for this trial is attached at Appendix B, and the key findings are summarised below: - All regulatory requirements defined for the Trial, including approvals, material tracking, quantity and duration constraints, notification and reporting commitments, and environmental compliance obligations were adhered to throughout the Trial period; - Batches of Mixed SPL delivered assessed in variable ratios of First Cut SPL to Second Cut SPL. Batch profiles ranged from 5:95 through to 95:5 (First Cut SPL: Second Cut SPL; by visual assessment); - Existing material storage, handling and treatment protocols, conventionally employed for the processing of Second Cut SPL and aluminium dross, were suitable for Mixed SPL storage and handling; - Cyanide was thermally-destroyed at process temperatures achieved. The thermal treatment performance is confirmed by the 98% reduction in cyanide load, and negligible (exceptionally low) cyanide residuals; - For each Trial batch, the furnace was operated at elevated temperatures to investigate the resultant emission control profile (including potential for fluoride evolution), and to monitor physical changes to feedstock blends. These operating conditions facilitated the required mineral transformations in the product (proprietary), and did not result in excessive or uncontrollable air emissions during the processing phase;
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- Independent NATA certified emission testing identified low pollutant discharge concentrations, and confirmed the reliable performance of the existing lime-scrubber and fabric filter baghouse pollutant control systems. Emissions data are of generally of the same order of magnitude, or lower, than that reported for previous Trials and conventional processing of Second Cut SPL and aluminium dross; - Real-time, continuous emission monitoring data confirm that gaseous fluoride and total particulate emission concentrations satisfied the regulatory compliance limits throughout each Trial interval, and similarly, notification to Regulators in the event of elevated emission concentrations was not required. These data further confirm the suitability of existing pollution control systems for future processing of SPL; - As expected, cyanide loads were reduced through treatment. The particle size distribution, fluoride content and composition profile of products (proprietary information withheld) is of great interest to prospective Customers, and enables the substitution of virgin raw materials in various industrial processes (proprietary information withheld); - Product materials were not intended for disposal. Rather, such materials were dispatched for Customer evaluation. WA has received positive feedback from its Customer base regarding the efficacy of treatment and proposed future market opportunities for the product; and - Research and development activities have successfully demonstrated the compatibility of facility infrastructure, processes and control measures available for the effective treatment of Mixed fraction SPL with broad variance in First Cut: Second Cut SPL composition ratios. Trials have confirmed environmental performance, and have verified sustainable market interest. 1.3.4 Processing of all SPL Material As a result of the successful trials, WA is seeking consent for the ongoing processing of all ‘SPL material’ at its Kurri Kurri facility – i.e. with no distinction between First Cut, Second Cut or Mixed fraction SPL. The Project would use existing technologies and processes including: - The transportation of material from primary aluminium smelters to WA’s Kurri Kurri facility by a licensed Dangerous Goods Contractor (segregated First Cut SPL, Second Cut SPL, or unsegregated Mixed SPL); - The storage of material within existing enclosed buildings and dedicated storage bays; - The processing and treatment of material within existing crushing circuits and rotary furnaces, capable of attaining the required temperatures to thermally oxidise contaminants and affect required mineralogical transformations; - The continued use of existing emission controls systems, including extraction hoods, wet-dry lime scrubber, filter baghouse complexes, and real-time continuous fluoride and particulate monitoring systems; and - The storage, handling and dispatch of finished product to customers under existing quality control procedures. Further detail regarding the operation of the Project is provided in Section 2.0. 1.3.5 Product Market WA’s objective is to offer a sustainable solution to domestic smelters, enabling the cost-effective treatment of SPL. Once treated, SPL has the potential to be used as a substitute for raw materials in a number of manufacturing and industrial processes. Such reuse options include: - Slag additives for the steelmaking industry; - Cement manufacture; and - Brick and tile manufacture.
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FIGURE 2 AECOM Environmental Assessment: Spent Potlining Processing – DA 86_04_01 MOD 10 & 7 DA_10397 MOD 8
2.0 Description of the Project
2.1 Modification of Conditions A copy of WA existing development consents are attached at Appendix C. Modification of both consents would be required to enable the commercial scale processing of SPL as described in the following section. Where proposed amendments are shown deletions are indicated by strikethrough and additions in bold. 2.1.1 Required Modifications to DA 10397 of 1995 Condition 2, Schedule 2 This condition needs to be updated to include reference to this EA document. The following should be added to the condition: i) Modification Application Environmental Assessment: Spent Potlining, Modification to DA86_04_01 & DA_10397, AECOM, August 2016. Condition 5, Schedule 2 Reference to Second Cut SPL needs to be removed from this condition so that it does not discriminate between the processing of First and Second Cut SPL. 5. The Applicant shall not process on site more than a combined total of 40,000 tonnes of dross aluminium and Second Cut SPL and 35,000 tonnes of scrap aluminium metal per year. Condition 6A, Schedule 2 Reference to Second Cut SPL needs to be removed from this condition so that it does not discriminate between the storage of First and Second Cut SPL. 6A The Applicant shall ensure that the combined total of Second Cut SPL and aluminium dross stored on site does not exceed 5,000 tonnes at any time. 2.1.2 Required Modifications to DA 84-4-01 Condition 2, Schedule 2 This condition needs to be updated to include reference to this EA document. The following should be added to the condition: i) Modification Application Environmental Assessment: Spent Potlining, Modification to DA86_04_01 & DA_10397, AECOM, August 2016. Condition 5, Schedule 2 Reference to Second Cut SPL needs to be removed from this condition so that it does not discriminate between the processing of First and Second Cut SPL. Proposed amendments to this condition are: 5. The Applicant shall not process on site more than a combined total of 40,000 tonnes of dross aluminium and Second Cut SPL and 35,000 tonnes of scrap aluminium metal per year. Condition 6A, Schedule 2 Reference to Second Cut SPL needs to be removed from this condition so that it does not discriminate between the storage of First and Second Cut SPL. Proposed amendments to this conditions are: 6A The Applicant shall ensure that the combined total of Second Cut SPL and aluminium dross stored on site does not exceed 5,000 tonnes at any time.
2.2 Interaction with Existing Operations The existing WA facility has regulatory approval to undertake the following activities: - Recovers aluminium from dross and scrap aluminium metal products; - Reprocesses the SPL for use in various industries and industrial manufacturing; and - Thermally destroys illicit drug and pharmaceutical wastes under limited trial conditions.
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The current Development consent (DA 86_04_01 MOD 9 & DA_10397 MOD 7) authorises WA to process up to a combined 40,000 tonnes of dross aluminium and Second Cut SPL, process up to 35,000 tonnes of scrap aluminium metal per year, and undertake a limited trial processing of illicit drug (200 tonnes) and pharmaceutical waste (1000 tonnes) over a 24 month interval. The Project does not seek to amend the existing approved combined dross and SPL processing tonnage of 40,000 tonnes per year. The processing of SPL will comply with the existing approval tonnage conditions. The processing of SPL would utilised the same plant, equipment and procedures as currently used for Second Cut SPL, therefore no changes to the existing operation would be required.
2.3 Interaction with Proposed Operations WA is in the process of compiling a detailed environmental assessment for a proposed thermal waste processing project. This project proposes to construct and operate a thermal waste treatment facility for medical and other problem wastes processing up to 8,000 tonnes per year. WA prepared a briefing document for the project that was provided to the DP&E in late 2015. DP&E subsequently issued its SEAR’s (SSD_7369) for the thermal waste processing facility on 16 December 2015. On the behalf of WA, AECOM has subsequently been undertaking detailed environmental investigations for that project, and issued its Draft Environmental Impact Statement to the DP&E in July 2016 for review. The thermal waste processing environmental assessment includes a detailed analysis of the potential cumulative impacts of the project and the existing WA operation. Given the negligible changes to the operation of the WA site expected to result from allowing the processing of SPL, there is limited opportunity for cumulative impacts to occur should the thermal waste treatment project be approved. Regardless, this EA includes consideration of combined air quality impact from the processing of SPL and thermal waste processing. Reference is made to Section 6.1. IN addition to projects proposed by WA, a proponent has also proposed to construction and operate a battery recycling facility (BRF) no a neighbouring site to the east of the WA facility. DP&E has issued SEARs (SSD_16_7520) for the BRF. Whilst the proponents of the BRF are still in the process of undertaking their own environmental assessments for the BRF project WA obtained background information to allow an appropriate level of cumulative assessment to be undertaken for the modification. Reference is made to Section 6.0 which considered potential impacts form the proposed modification along with potential cumulative impacts from the BRF.
2.4 Proposed Project 2.4.1 Process Description WA proposes to diversify its service provision to the aluminium smelting industry beyond the reprocessing of Second Cut SPL, aluminium dross and other aluminium-bearing wastes to now also include the treatment and processing of First Cut SPL and Mixed SPL. SPL is classified as a dangerous good and hazardous material and contains varying proportions of aluminium, carbon, cyanide, fluorides, sodium and other trace contaminants, such that its management and disposal represent a major issue to the aluminium smelting industry. SPL will be received either pre-crushed or uncrushed from various domestic aluminium smelters, and stored on the premises in accordance with the Australian Dangerous Goods Code. WA would process and treat SPL in the same manner that is currently does for Second Cut SPL. In summary the key elements of the process are described as: - Primary crushing (where necessary); - Controlled blending with other propriety additives, as required; - Fine milling; - Thermal treatment; and - Crushing and mixing (as required) and subsequent distribution to end markets. The proposed SPL processing chain is schematically represented in Figure 3. This process is identical to that of Second Cut SPL currently undertaken on site. The processing of SPL would utilise the same facilities, plant and equipment currently used onsite. As no increase in the proposed overall tonnages of materials being process by WA is proposed, no additional storage or processing equipment is required.
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The objective of SPL processing is to thermally oxidise the cyanide within the SPL and modify the mineralogical composition so that the material can be transported as a value-added product. Trials conducted by WA (refer to Section 1.3.3) demonstrate that the thermal treatment reduces cyanide concentrations to negligible concentrations. Additionally, emissions monitoring data obtained during the trials confirmed that all emission concentrations were below the existing regulatory compliance limits throughout the process. Consequently, no change to WA’s existing Environmental Protection Licence (EPL) limits will be required for the Project. Cyanide monitoring is already undertaken by WA in order to manage its potential air emission discharge as a result of Second Cut SPL processing. This monitoring would continue to be in place for the processing of all SPL. All occupational hygiene, safety and monitoring requirements for the treatment of SPL at the facility have already been successfully determined and implemented during both trials operations, and the commercial processing of Second Cut SPL. 2.4.2 Raw Materials Raw material (SPL) will be sourced from various domestic aluminium smelters, as is currently the case with Second Cut SPL and dross. 2.4.3 Operational Facilities The storage and processing of SPL would be undertaken within existing storage buildings and processed through existing rotary furnaces and rotary cooler. Refer to Figure 3. There would be no need for additional pollution control systems, or the construction of any additional infrastructure. In summary, the SPL processing is described as follows: - SPL is delivered to site using the same process and Dangerous Goods licensed contractors as currently service the facility; - The SPL is placed is storage bays where it will be held until processing is performed; - The SPL is then crushed and screened and fed to the main processing building using the existing covered conveyor and/or transferred to the main processing building via bins; - The SPL is heated in dedicated furnaces to thermally oxidise and destroy the cyanide in the material; - Once the cyanide has been destroyed, the processed SPL will be removed from the furnace and cooled in a dedicated rotary cooler (i.e. jacketed cooling). A water spray cooling system will also be installed within the rotary cooler to assist in the final cooling of the product; and - The material will then be milled to specification, bagged and transported to markets. 2.4.4 Transport Requirements Second Cut SPL is currently being delivered to the facility by a Dangerous Goods Licensed contractor. All future SPL to be delivered to site as part of the Project would also be delivered by a Dangerous Goods Licensed contractor. All SPL haulage would be undertaken via the Hunter Expressway with no haulage through the townships of Weston or Kurri Kurri. WA operates a Transport Code of Conduct which was submitted and approved by the DP&E as part of existing approvals. This would be followed for the Project. The existing development consent does not include a limit on the number of truck movements to and from site, however this is limited by approved production limits which this Project does not propose to change. 2.4.5 Workforce The current workforce at the WA plant is composed of approximately 40 personnel. This existing workforce would be used for the processing of the SPL. 2.4.6 Hours of Operation Under the existing development consent, the facility is approved for operations 24 hours per day 7 days a week. Truck movements to and from the premise are limited to between the hours of 7am and 10pm pursuant to the sites Environmental Protection Licence. No change to the existing operating hours or truck movement times is required for the Project. 2.4.7 Capital Investment Required The Project would make use of existing infrastructure that is currently used to treat and process Second Cut SPL, therefore no capital outlay is required to enable the Project.
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2.4.8 Construction Details As the Project would use infrastructure already in place at WA, no installation of construction of any major component or pieces of equipment is required. 2.4.9 Environmental Controls The existing facility is comprised of best available technology, and complies with stringent pollution limits. Emissions of process dust, cyanide and fluoride are controlled by existing plant through: - Temperature control; - Scrubber/baghouse complex; and - By-product residues returned to the raw material feed in a closed-loop cycle. Regular emissions testing and reporting form part of WA’s existing operational procedures to confirm that environmental control systems are maintained and operating as required.
2.5 Need for the Project Untreated surplus SPL continues to be stockpiled in Australia or exported overseas for treatment. This is a significantly expensive and risky process, relying on the transport of hazardous materials over many jurisdictions and through third party countries. This strategy is clearly not sustainable for the domestic industry. Although some treatment and beneficial reuse of both First and Second Cut SPL is occurring domestically there is still a considerable imbalance between the amount of SPL being produced or stored in stockpiles and SPL that is being processed for reuse. With the recent increase in both trials and commercial scale processing of SPL by WA and others, there is a growing understanding in the marketplace regarding potential end uses for processed SPL material. Following receipt of approval to process Second Cut SPL, WA identified that a significant portion of stored SPL is mixed (combined First and Second Cut) and therefore it is not possible to separate for treatment. The Project presents WA with the opportunity to now process and recycle Mixed SPL along within its existing Second Cut SPL processing. Therefore in summary the need for the Project is driven by: - The aluminium producing industry needing to find appropriate disposal and reuse options for its Mixed SPL material; - Aluminium’s smelters having existing stockpiles of First Cut, Second Cut and Mixed SPL that require an appropriate end of life management solution; - Product markets for processed SPL now emerging with increasing demand for greater quantities of processed material with SPL replacing the need for raw material inputs in some instances; and - WA is proposing to process SPL thus making the Project a key link between producers and users of the recycled SPL product in the marketplace. The Project is therefore an important part of increasing the sustainability of the aluminium industry and reducing existing stockpiles waste SPL materials, and meets the objectives of current feasibility investigations being facilitated by the Department of Environment.
2.6 Alternatives Considered The ‘do nothing’ option would involve the continuation of existing stockpiling and/or methods for disposal of SPL waste material by the primary aluminium sector. If the Project does not proceed, SPL material will continue to be stockpiled and/or transported overseas for processing at considerable cost to local aluminium smelters. The Project offers a more cost effective and environmentally sustainable solution to the management of SPL material than is currently available to aluminium smelters, and is the preferred option rather than doing nothing. Alternatives to processing SPL at the WA site or overseas include establishing a new facility for the processing of SPL. As the currently facility is already established and set up for processing SPL with all relevant environmental management processes in place, the additional impacts associated with the establishment of a new facility preclude it from further consideration as an alternative option.
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Figure 3 SPL Processing Schematic
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3.0 Statutory Planning
3.1 Overview This section identifies the legislative requirements and planning controls relevant to the Project and outlines the key policy and statutory considerations that would be addressed in more detail in the Environmental Assessment.
3.2 Commonwealth Legislative Requirements 3.2.1 Environment Protection and Biodiversity Conservation Act 1999 The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) requires the approval of the Commonwealth Department of Environment (DoE) for actions that would have, or are likely to have, a significant impact on matters of National Environmental Significant (NES). The EPBC Act lists nine matters of NES which must be addressed when assessing the impacts of a proposal, which are: - World Heritage properties; - National Heritage places; - Wetlands of International Importance; - Listed threatened species and ecological communities; - Migratory species protected under international agreements; - Commonwealth Marine Areas; - The great Barrier Reef Marine Park; - Nuclear actions; and - A water resource in relation to coal seam gas development and large mining development. If potential significant impacts on a matter of NES are identified, then a referral to the Minister would be made in accordance with the requirements of the EPBC Act for a determination as to whether the Project is a Controlled action. The EPBC Protected Matters Search Tool identified one RAMSAR Wetland, three threatened ecological communities, 26 threatened species and 11 migratory species within 5 km of the WA site. A copy of the Protected Matters Search Results is attached at Appendix D. The Project is not expected to have a significant impact on relevant matters of NES. Accordingly, the Project would not need to be referred to the DoE.
3.3 NSW Legislative Requirements 3.3.1 Environmental Planning and Assessment Act 1979 The Environmental Planning and Assessment Act 1979 (EP&A Act) and the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation) provide the framework for environmental planning in NSW and include provisions to ensure that proposals that have the potential to impact on the environment are subject to detailed assessment and provide opportunity for public involvement. The WA facility at Kurri Kurri currently operates under two separate development consents: - DA No. 86-04-01 (as modified) issued by the then Minister for Urban Affairs and Planning under Part 4 of the EP&A Act; and - Land and Environment Court Consent LEC 10397 of 1995 (as modified). The original development was declared to be State Significant Development (SSD) by the Minister for Planning and Environment pursuant to Schedule 1 of State Environmental Planning Policy No. 34 – Major Employment Generating Industrial Development (SEPP 34) (repealed), as it was a materials processing development with a capital investment in excess of $20 million. Clause 8J(8) of the Environmental Planning and Assessment Regulation 2000 provides the transitional provisions for proposed modifications to Projects declared to be State Significant Development under the now repealed SEPP 34. Clause 8J provides that a modification to a
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development consent issued under SEPP 34 shall be modified in accordance with section 75W of the EP&A Act. Despite Part 3A of the EP&A Act also having been repealed, the transitional provisions continue to apply and the Project can be modified in accordance with section 75W of the EP&A Act. WA had the previous SPL trials (40 tonne and 200 tonne trials) and the commercial processing of Second Cut SPL (up to 40,000 tonnes per annum) approved by the DP&E as section 75W Modifications. Modification is also now being sought to process all SPL inputs at commercial quantities under section 75W. It has been demonstrated through this EA that the commercial scale processing of SPL by the existing facility would not fundamentally alter the scale or nature of the existing development. Importantly, no increase to annual processing tonnage limits is being sought. It is therefore appropriate for DP&E to use its discretionary power to accept the current proposal as a section 75W Modification. 3.3.2 Protection of the Environment Operations Act 1997 The Protection of the Environment Operations Act 1997 (POEO Act) aims to protect, enhance and restore the quality of the environment in NSW, to reduce risk to human health and promote mechanisms that minimise environmental degradation through a strong set of provisions and offences. An EPL is required from Office of Environment and Heritage (OEH) if any of the activities associated with the Project are determined to be a ‘scheduled activity’ under Schedule 1 of the Act. The Kurri Kurri plant currently operates under EPL No. 6423, which allows WA to carry out the following operations on the premises.
Table 1 Existing WA Site Scheduled Activities
Fee Based Activity Scale Aluminium Production (scrap metal) > 10,000 t processed Recovery of hazardous and other waste > 0 t recovered Scrap metal processing 0-100,000 t processed Waste storage – hazardous, restricted solid, liquid, clinical and related waste > 0 t stored and asbestos waste
The approved quantities of materials that can be processes by WA at its plant would not be altered as part of the Project. A variation to EPL 6423 would however be required to ensure there is consistency of wording between the proposed modification and the EPL. 3.3.3 Environmentally Hazardous Chemicals Act (1985) The Environmentally Hazardous Chemicals Act 1985 (EHC Act) is regulated by the NSW EPA and provides a mechanism for the regulation of chemical of environmental concern throughout their entire lifecycle including when they are classed as waste products. Both First and Second Cut SPL, and Mixed SPL, are classed as dangerous good Class 4.3 in accordance with the Australian Dangerous Goods Code. WA currently holds EHC licence No. 119 for the processing, keeping, selling, distributing, conveying or using of aluminium smelter wastes containing fluoride or cyanide. No change is proposed to the amount of SPL, or how it would be processed, kept, stored, distributed or used onsite. Despite this administrative amendments would be required to the EHC Licence No. 119 to make reference to the latest environmental assessment (this document) and approvals.
3.4 Environmental Planning Instruments The following environmental planning instruments have been reviewed for their relevance in relation to the Project. 3.4.1 State Environmental Planning Policy No.33 – Hazardous and Offensive Development State Environmental Planning Policy No. 33 (SEPP 33) aims to ensure that the consent authority has sufficient information regarding a proposal to determine whether the development meets the criteria for hazardous or offensive development. Conditions to minimise or reduce adverse effects can then be imposed with any consent issued. SEPP 33 requires applications for potentially hazardous or offensive industry to be accompanied by a preliminary hazard screening.
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Assessments of the hazards and risks were conducted for the trials (40 tonne and 200 tonne trials) and for the 2012 EA for commercial-scale Second Cut SPL processing. These assessments determined that the operations would not have significant off-site risk implications if the proposed risk mitigation measures were implemented. A Preliminary Risk Screening study prepared for this EA concluded that the hazards associated with the storage of SPL would not result in a change to the existing risk profile. Further details of the hazard assessment are detailed in Section 6.2. 3.4.2 Cessnock Local Environmental Plan 2011 WA’s Kurri Kurri facility is located within the IN3 Heavy Industrial Zone under the Cessnock Local Environmental Plan 2011 (LEP 2011). The objectives of the Zone are: - To provide suitable areas for those industries that need to be separated from other land uses; - To encourage employment opportunities; - To minimise any adverse effect of heavy industry on other land uses; and - To support and protect industrial land for industrial uses. Due to the classification of the Project as a transitional Part 3A Project, the provisions of the LEP 2011 do not apply. Regardless, the proposed Modification is considered consistent with the objectives of the LEP 2011 and is consistent with the existing approved industrial land use.
3.5 Basel Convention The Basel Convention is a United Nations Treaty (to which Australia is a signatory) which aims to control transboundary movements of hazardous wastes and their disposal. The overarching objective of the Convention is to protect human health and the environment against the adverse effects of hazardous wastes. The provisions of the Convention centres around the following principal aims: - The reduction of hazardous waste generation and the promotion of environmentally sound management of hazardous wastes, wherever the place of disposal; - The restriction of transboundary movements of hazardous wastes except where it is perceived to be in accordance with the principles of environmentally sound management; and - A regulatory system applying to cases where transboundary movements are permissible. Historically, SPL was either stockpiled locally or sent overseas for processing due to the lack of treatment facilities in Australia. WA is offering a domestic solution for the processing of SPL, which will eliminate the need for transport of this hazardous waste offshore.
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4.0 Stakeholder Consultation
4.1 Consultation Undertaken to Date WA undertook consultation with relevant agencies and the community are part of its previous trials, per operational and commercial scale Second Cut SPL processing. This included the exhibition of previous Environmental Assessments, the receipt and addressing of submissions and an ongoing dialogue with relevant stakeholders. As part of the proposed modification, WA provided Project details to both DP&E and the EPA. Following this consultation WA lodged a formal submission with DP&E providing details of the Project and requesting confirmation that the Project could be assessed as a modification to WA’s existing site approvals. Prior to confirming the Project could be assessed as a modification, DP&E undertook further consultation with the EPA. DP&E subsequently wrote to WA on 15 June 2016 confirming that the Project could be assessed as a modification and providing both DP&E and EPA requirements for the EA. Specifically the following was identified as needing to be addressed by this EA as a minimum:
Table 2 Secretary’s Environmental Assessment Requirements for the Modifications
SEAR Addressed in this Report Description of the modification – including a clear definition of SPL Section 2.0 and a description of where it will be sourced.
Need and justification for the modification Section 1.3
Other Approvals – Identification of any proposed variations to WA’s Section 3.0 existing EPL and Environmentally Hazardous Chemicals Act (1985) Licence. Identification of environmental impacts of the modification – Including a - more detailed assessment of the following: - Air Quality Section 6.1 - Traffic and Transport – including details of any revised traffic Section 6.3 movements - Hazard and risk – including an updated Preliminary Hazard Section 6.2 Analysis in accordance with the Hazardous Industry Advisory Paper No. 6 – Guidelines for Hazard Analysis and Multi-level Risk Assessment Identification of conditions to be modified Section 2.1
In conjunction with existing stakeholder consultation activities in relation to WA’s proposed Thermal Treatment facility, as attended by local residents, interest groups and representatives of the Cessnock City Council (CCC), WA also outlined the existing Project and sought comment in relation to the proposed Modification.
4.2 Stakeholder Engagement Strategy WA will continue to engage with: - Local environmental interest groups and residents; - Aluminium smelters; and - Regulatory authorities and Local Government (EPA, DP&E, CCC). In particular, WA will continue to meet the relevant reporting conditions of its development consent and EPL to provide agencies with the necessary information regarding the operation of the facility.
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5.0 Prioritisation of Issues An assessment of potential environmental impacts associated with the Project based on existing data and knowledge of the site (including historical performance and compliance during conventional operations and Second Cut SPL processing activities) and preliminary desktop investigations was carried out. A risk analysis was undertaken to rank these issues according to the level of environmental risk.
5.1 Risk Matrix Potential impacts are ranked according to the risk matrix (refer to Table 3) as being a High, Medium, Low or Very Low risk to the environment. Potential Consequences: 1. Broad scale environmental impact. 2. Regional environmental impact. 3. Local environmental impact. 4. Minor environmental impact. 5. Insignificant environmental impact. Likelihood of adverse impact: a. Almost certain. b. Likely. c. Possible. d. Unlikely. e. Rare.
Table 3 Risk Matrix
Likelihood of adverse impact A B C D E 1 High High Medium Low Very Low 2 High High Medium Low Very Low 3 Medium Medium Medium Low Very Low Potential
Consequence Consequence 4 Low Low Low Low Very Low 5 Very Low Very Low Very Low Very Low Very Low
5.2 Risk Analysis The prioritisation of potential environmental issues related to the Project is provided in Table 4. This ranking aims to allow the prioritisation of issues for assessment and does not consider the application of mitigation measures to manage the environmental effects. In all cases, appropriate and proven mitigation measures chosen based on experience with other similar projects would be used to minimise and manage potential impacts identified in this risk analyses. These measures are described throughout Section 6.0 of this EA and summarised in Section 7.0.
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Table 4 Risk Assessment Environmental Potential Environmental Issue Consequence Likelihood Ranking Aspect Air Quality and Generation of fugitive emissions and dust 3 C Med Odour Exceedance of existing regulatory 4 D Low compliance stack air emission limits (including particulates and fluoride) Hazard and Risk Potential contact with water and resultant 3 D Low generation of flammable gases Accident during transport causing release of 3 D Low hazardous substance into environment Transport Traffic movements still within approved limits 5 E Very Low Soil and Water Spills of raw materials to site catchment and 3 E Very Low pollution of local water ways GHG Emissions Excessive generation of GHG, including 4 E Very Low carbon dioxide, methane and oxides of nitrogen Noise Exceedance of regulatory compliance noise 3 E Very Low limits Waste Generation of hazardous waste requiring 3 E Very Low Management disposal Socio-Economic Employment generating opportunity 5 E Very Low Effects Visual No change to current operations 5 E Very Low Heritage No change to current facility footprint 5 E Very Low Land use No change to current facility footprint 5 E Very Low Fauna and Flora No change to current facility footprint 5 E Very Low
5.3 Key Issues Based on the risk analysis presented above and consultation with the DP&E and EPA, the key issues requiring detailed assessment within this EA were identified and include: - Air Quality; and - Hazards and Risk. These key issues are assessed in Sections 6.1 and 6.2 of this EA. Other issues having very low or no anticipated impact are addressed in Section 6.3.
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6.0 Environmental Impact Assessment
6.1 Air Quality An Air Quality Impact Assessment (AQIA) was prepared for the Project. A summary of this assessment is provided below. For further details, refer to the AQIA report included in Appendix E. 6.1.1 Existing Environment The WA plant at Kurri Kurri is located within an established industrial area, with some residential areas to the south and west of the site. The air quality within the area is considered to be typical to that of an industrial area, with existing sources which contribute to air pollution including: - Industrial emissions; - Coal mines; - Emissions from motor vehicles travelling on the local road network; and - Dust and pollens in drier and windier conditions. Emissions from the power stations in the Upper Hunter Valley also affect air quality in the area. It is noted that the Hydro Aluminium Smelter, which was previously a source of local emissions, is now closed. Existing Air Quality The EPA operates a number of air quality monitoring stations in the Lower Hunter. The closest monitoring station sites to the WA site is located at Beresfield (17km east of the site). This station records hourly PM10 and PM2.5 concentrations using a Tapered Element Oscillating Microbalance (TEOM), Nitrogen Dioxide (NO2) and Sulfur Dioxide (SO2). Ambient air quality monitoring data for 2015 at Beresfield is presented in Table 5 as sourced from the OEH website1. All other pollutants assessed in the AQIA and Section 6.1.2 are not measured and as such no background data is available for use in the cumulative assessment. Available background data is described below.
The maximum PM10 24-hour concentration measured at Beresfield in 2015 (the most recent year for which data are available) was 64.9µg/m3 which is above the EPA 24 hour maximum criterion of 50µg/m3 (DEC 2005). There was one additional exceedance of the 24 hour EPA criterion recorded at 57.5µg/m3. The third highest record for the reporting year was below the criterion at 43.3µg/m3. When background levels exceed a criteria, the NSW EPA (DEC 2005) allows for the identification of ‘additional exceedances’, that is, removal of those above the criterion, then add the project contribution and calculate if there are any further exceedances. As stated, the highest background value that meets the criterion is 43.3µg/m3 and as such this value has been applied as the PM10 24-hour background in the assessment in order to identify potentially additional exceedances. 3 The annual average PM10 concentration recorded at 18.7µg/m for 2015 is under the EPA annual average 3 criterion of 30µg/m (DEC 2005).
Similarly to PM10, the maximum PM2.5 24-hour concentration measured at Beresfield in 2015 recorded at 25.9µg/m3 was also found to be above the NEPM standard of 25µg/m3. There were no additional exceedances of the EPA criterion, with the second highest 24 hour concentration recorded for 2015 at 20.2µg/m3. As applied for PM10, the highest value that does not exceed the criterion has been applied as the PM2.5 24-hour background in the assessment in order to identify potentially additional exceedances, being 20.2µg/m3.
The PM2.5 annual average recorded for 2015 was found to be slightly below the NEPM annual average criterion of 8µg/m3 with a concentration of 7.4 µg/m3 recorded for the reporting year.
3 In 2015, the maximum 1 hour NO2 concentration was 100.5µg/m , approximately 40 percent of the EPA criterion. 3 The annual average NO2 concentration was also well below the criterion recorded at 18.5µg/m . Similarly, recorded background concentrations for SO2 for all averaging periods were well below the relevant criteria.
Ground level concentrations for Carbon monoxide (CO) are not recorded at the Beresfield EPA monitoring station, however 8-hour averages for CO are recorded at the EPA monitoring station in the more populated area of Newcastle located approximately 31km southeast of the site. The maximum 8-hour average for CO recorded at Newcastle for 2015 was found to be 1,900µg/m3 which is just under one fifth of the EPA criterion of 10,000µg/m3.
1 http://www.environment.nsw.gov.au/AQMS/search.htm accessed May 2016
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No measurements of local TSP ambient air quality concentrations were available. In the absence of existing annual TSP concentration data, the annual PM10 concentration can be assumed to be 40% of the annual TSP concentration. This is a conservative approach as reported by the NSW Minerals Council (2000) for the measurement of PM10 in TSP in the Hunter Valley and is considered to be applicable in Kurri Kurri. This equates to an annual average TSP concentration of 46.7µg/m3, which is below the NSW EPA criterion of 90 µg/m3. OEH does not currently undertake ambient air quality monitoring for air toxics (such as hydraulic acid (HCl), Sulfuric Acid (H2SO4) and Cyanide (CN)). Previous ambient air quality monitoring for air toxics undertaken between 1996 and 2001 indicated low levels of pollutants within the Greater Metropolitan Region (GMR) and as such background concentrations of air toxics are not considered to be a primary issue of concern.
Table 5 Ambient Air Monitoring in Beresfield, NSW for 2015 (OEH website, accessed May 2016)
Pollutant Averaging Period Concentration (µg/m3) EPA Criteria (µg/m3)
PM10 24 Hour Maximum 64.9 50 Highest 24 hour that meets criterion 43.3** Annual Average 18.7 30
PM2.5 24 Hour Maximum 25.9 25* Highest 24 hour that meets criterion 20.2** Annual Average 7.4 8*
NO2 1 Hour Maximum 100.5 246
Annual Average 18.5 62
SO2 1 Hour Maximum 234.5 570 24 Hour Maximum 22.9 228 Annual Average 2.9 60
* NEPM Standard ** Used in the AQIA as background in order to identify additional exceedances as per DEC 2005.
Table 6 presents ambient hydrogen fluoride (HF) ground level concentrations in the vicinity of the study area recorded between the cessation of smelter operation in October 2012 and 2014. Since the shutdown of Hydro Aluminium, the highest HF concentrations have been recorded at McLeod Road. The McLeod Road station is located in proximity (approximately 1km to the east) to the WA site, and Hydro Aluminium staff have indicated that the concentrations recorded at this station were influenced by WA’s emissions. As such, if ambient data from this station were used in the cumulative HF concentration calculations, the contribution from WA would likely be substantially overestimated. To avoid that overconservative situation, the ambient data used to calculate the total cumulative HF concentrations at receptors were the highest measured HF concentrations at any monitoring station other than McLeod Road, and as such the McLeod Road data was removed from the table.
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Table 6 Maximum Ambient HF Concentrations; October 2012 – 2014 (Hydro Aluminium)
Site 7 days (g/m3) 30 days (g/m3) 90 days (g/m3)
Yawarra 0.20 0.16 0.11 Heddon Greta 0.16 0.12 0.11 Lot 103 0.16 0.11 0.08 Wangara 0.13 0.09 0.07 Bish Bridge 0.13 0.10 0.07 Kurri Kurri 0.13 0.10 0.08 Wandin Valley 0.13 0.09 0.06 Janannie 0.14 0.10 0.08 Allandale 0.14 0.08 0.06 Hope Estate 0.13 0.09 0.07 McWilliams 0.09 0.07 0.05 Wyndham Estate 0.12 0.09 0.07 Maximum 0.20 0.16 0.11 General land use criteria 1.7 0.84 0.5
Terrain Terrain data were captured from NASA’s Shuttle Radar Topography Mission (SRTM), which produces terrain information for the entire globe. For Australia, terrain data are available at approximately 90 m resolution (3-arc seconds). The site lies approximately 17m above Mean Sea Level (MSL) and the immediate terrain surrounding the area is relatively flat. In the wider context, the study area lies approximately 30km to the northwest of the East Australian coastline and terrain height within the study area range from between 0 and 520 metres MSL with higher elevations to the southwest. Land Use and Sensitive Receptors The WA facility is located within the Kurri Kurri industrial area of NSW. Land use surrounding the WA facility is largely comprised of small to medium industrial premises (predominantly to the south of the site) and native vegetation to the north. Residences are located approximately 600 metres to the southeast (Kurri Kurri) and southwest (Weston) of the site. A total of 184 sensitive receptors were included in the dispersion modelling. A description and coordinates for all sensitive receptors are tabulated in Appendix E. Local Climate The Bureau of Meteorology (BoM) meteorological station located at Cessnock Airport (Station Number 061260), approximately 12.5 km west of the site, records climate data for a range of meteorological parameters including temperature, humidity, rainfall, wind speed and wind direction. A summary of the long-term data recorded at this station between 1968 and 2016 is provided in Appendix E and summarised below. The study area experiences a warm to moderate climate. The warmest temperatures occur during the summer months, with the highest average maximum temperature (30.0oC) occurring in January. July is the coldest month, with a recorded average minimum temperature of 4.0oC. The annual average rainfall for the area is 743 millimetres (mm) over 73 days a year. February is the wettest month, with an average rainfall of 100 mm, while August is the driest month with an average rainfall of just 29mm. Humidity follows a diurnal cycle, with higher humidity in the morning compared to the afternoon. Daytime wind speeds were found to be moderate, with higher wind speeds occurring in the afternoon compared to the morning. The annual average 9am wind speed recorded is 11.6 kilometres per hour (km/h) and the annual average 3pm wind speed was 16.9 km/h. Seasonally, wind speeds are higher during the warmer months with the highest average wind speed occurring in September at 19.1 km/h.
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6.1.2 Potential Impacts Modelling Scenarios A modelling scenario was undertaken for this assessment to represent typical WA operations during the processing of SPL. A summary of the emissions from each stack is as follows, with more detail provided in Appendix E: - Stack 1, which would service the plant processing the SPL, has been modelled using the higher of either the proposed SPL emissions or the current Second cut SPL emissions; - Stacks 2, 3, 4, 6 and 7 were modelled using average source emission data from the previous three years stack testing data; and - Stack 5, which is proposed to ventilate either the current reverb furnace or a proposed thermal waste processing facility, has been modelled at the higher emissions of the two stated processes. Emissions Estimation A conservative estimate of emission rates, as presented in Table 8 has been assumed whereby all plant operations, including operation of the SPL processing (Stack 1) and the reverb/thermal processing plant (Stack 5), would be operating continuously 24 hours a day seven days per week. The following methodology was used to estimate emission rates from each stack. Site specific emissions testing data have been used for existing pollutant sources that would remain unchanged, being Stacks 2, 3, 4, 6 and 7. Three years of existing stack data has been used dating from 2013 to 2015, with the average emissions applied (AECOM 2013, AECOM 2014 and AECOM 2015a). Where PM2.5 data was not available, it was conservatively assumed PM2.5 had the same emission rates as PM10. The emission concentrations from Stack 1 during SPL processing have been obtained from two WA reports for trial operations as follows: - WA, 2011, Monitoring and Verification Report – Spent Potlining Material Processing Trial (First and Second Cut); and - WA, 2016, Monitoring and Verification Report – SPL Processing Trial (Mixed SPL). The reports are detailed in Appendix E. The reports summarise the stack emission concentrations for various trials. The 2011 report summarises the results from two trial batches, the first with a First Cut: Second Cut SPL ratio of 0.48:0.52 (together with iron oxide, cullet and lime) and the second 100% Second Cut SPL. The 2016 report reviews four compliance testing events, with an approximate First Cut: Second Cut SPL ratio ranging from 5:95 to 95:5. For the purposes of this AQIA, the range of the two reports is considered appropriate to represent emissions of First Cut SPL as well as the various ratios in-between. In order to estimate the ‘worst case’ emissions over the range of expected SPL mixes, the maximum values of both trial reports (six trial batches in total) were used for each pollutant in the emissions inventory. This is considered highly conservative as it is unlikely that the worst case SPL mix would be processed for the entire year. A comparison of data is provided in Table 7. Further to the above use of the ‘worst case’ emissions inventory, the assessment has compared these values to the currently measured stack testing data for Stack 1 for the previous three years i.e. processing Second Cut SPL. The maximum of either the worst case SPL emission concentration previously discussed or the average current measured Second Cut SPL emission values have been used in the emission inventory to calculate the final emission rate. Again, this is highly conservative as it assumes that the maximum value from either the First Cut SPL or Second Cut SPL or Mixed SPL processing would be processed for the entire year. A comparison of data is provided in Table 7. The methodology for the calculation of emission rates of the thermal treatment facility (Stack 5) and methodology and emission rates for the BRF are provided in Appendix E. The thermal treatment facility is the subject of a separate development application and has been included in this assessment in order to best estimate the cumulative future emissions from the site. With respect to Stack 5, the source discharge can either reflect emissions from the current Reverb Furnace or from the proposed waste thermal treatment process individually i.e. one or the other, never at the same time. To estimate the potential emissions at any point in time from this source, the concentrations from the reverb stack monitoring data were compared against those calculated for the thermal treatment facility and the maximum of the
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two for each pollutant was used in the emissions inventory. This is highly conservative as it assumes that the maximum value from either the reverb stack or the thermal treatment facility would be processed for the entire year.
Table 7 Comparison of Pollutant Concentrations for Stack 1 and Stack 5 for WA
Stack 1 – SPL Stack 5 – Reverb / Thermal Pollutant 2011 SPL 2016 3 Second Assessed Assessed (mg/m ) Trial Mixed SPL Reverb Thermal Cut SPL Value Value Trial TSP 8.90 4.18 0.76 8.90 3.33 0.39 3.33
PM10 0.24 0.55 0.24 0.55 1.08 0.28 1.08
PM2.5 0.24 0.55 0.24 0.55 1.08 0.039 1.08
SO2 3.90 5.48 5.00 5.48 7.33 1.55 7.33
H2SO4 0.80 1.12 1.00 1.12 1.433 15.44 15.44
NOx 4.00 11.33 3.00 11.33 4.67 25.39 25.39 HCl 0.95 1.15 7.50 7.50 1.32 1.85 1.85 HF 0.38 0.058 0.055 0.38 0.35 0.16 0.35
CN 0.031 0.14 0.33 0.33 * Note that after visual inspection of the trial data, a potential outlier was identified in the fluoride data set. A review for statistical outliers using the Interquartile Range analysis method (IQR) was undertaken which confirmed that one of the values was outside the Upper Bound and was a recognised outlier. The value was therefore removed from the assessment calculations. Black cells = no data.
Table 8 Pollutant Emission Rates for WA Pollutant (grams Stack 1 Stack 2 Stack 3 Stack 4 Stack 5 Stack 6 Stack 7 / second) TSP 0.22 0.0054 0.0064 0.033 0.071 0.014 0.10
PM10 0.013 0.0029 0.0037 0.015 0.023 0.0010 0.064
PM2.5 0.013 0.0029 0.0037 0.015 0.023 0.0010 0.064
CO 2.88 0.37 0.0018 0.13 0.16 0.042 0.20 SO2 0.027 0.33 0.0025 0.039 H2SO4 NOx 0.28 0.54 0.10 0.072 HCl 0.18 0.040 HF 0.0093 0.0066 0.0028 0.013 0.0074 0.0083 0.0062 CN 0.0081 Shaded cells = no data. Dispersion Model Potential air quality impacts were assessed using the CALPUFF air quality modelling software. CALPUFF is a non steady-state, threx10-dimensional Gaussian puff model developed for the US Environmental Protection Agency (USEPA) for use in situations where basic Gaussian plume models are not effective. These situations include areas where stagnation conditions occur, which are characterised by calm or very low wind speeds with variable wind direction. The CALPUFF modelling system (and associated CALMET program) has the ability to model spatially varying winds and turbulence fields that are important in complex terrain, long range transport and near calm conditions. As such, CALPUFF was selected as the appropriate dispersion model for this assessment. Full details of the model input parameters used in the Air Quality Impact Assessment are detailed in Appendix E.
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Impact Assessment Results of the dispersion modelling are presented in Table 9 as the maximum ground-level concentrations reported at either “at or beyond the boundary of the facility” (for H2SO4, HCl, CN) or at a sensitive receptor (all other pollutants). Maximum predicted concentrations from the WA facility have been added to the maximum predicted concentrations at each receptor location for the proposed Kurri Kurri BRF to determine the combined impact from all proposals. This has then been added to the existing background concentration to determine the cumulative impacts.
Table 9 Predicted Ground Level Concentrations
Ground Level Concentration (µg/m3) Averaging Criteria Pollutant Percentile Maximum WA Cumulative Assessment Period (µg/m3) Incremental WA + Background Cumulative Contribution BRF2 th TSP Annual 100 0.4 0.5 46.8 47.3 90 th 1 PM10 24 Hour 100 0.7 2.5 43.3 45.8 50 th Annual 100 0.09 0.2 18.7 18.9 30 th 1 PM2.5 24 Hour 100 0.7 2.5 20.2 22.7 25 th Annual 100 0.09 0.2 7.4 7.6 8 th SO2 1 Hour 100 10 94 235 329 570 th 24 Hour 100 3 15 23 38 228 th Annual 100 0.4 1 3 4 60 th H2SO4 1 Hour 99.9 4.3 4.3 - 4.3 18 th 3 NO2 1 Hour 100 15 15 101 116 246 th 3 Annual 100 0.7 0.7 18.5 19.2 62 th HCl 1 Hour 99.9 8 8 - 8 140 HF 90 days 100th 0.12 0.12 0.11 0.23 0.5 30 days 100th 0.21 0.21 0.16 0.37 0.84 7 days 100th 0.30 0.30 0.20 0.50 1.7 24 hours 100th 0.61 0.61 - 0.61 2.9
th CN 1 Hour 99.9 0.36 0.36 - 0.36 0.5 1. The WA and BRF data could not be presented in separate columns as the maximum receptor may be different for each. Presenting the maximum for both in columns may lead to readers inadvertently adding the two and over predicting the actual cumulative value. 2. Applied the highest background value that met the criterion in order to identify any additional exceedances.
3. Conservatively assumed total conversion of NOx to NO2.
A summary of the modelling results and the findings of a comparison with EPA criteria are as follows: - The WA SPL air dispersion modelling predicts that all assessed pollutants would meet their respective EPA criterion for all average periods both incrementally (WA alone) and cumulatively (WA+BRF+background);
- The PM10 and PM2.5 data predicts that there are no additional exceedances of the criteria, beyond those already identified in the background data, once the potential impacts from both the WA and BRF sites are cumulatively assessed with the background;
- The cumulative PM10 and PM2.5 concentrations are primarily due to existing background particulate concentrations, with the WA facility contributing approximately 1% and 3% of the cumulative 24 hour average value respectively; and
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- The presented impact estimates are considered conservative as they assume the WA site is operating continuously for the entire year. The assessment has also applied the calculated emissions from Stack 1 as the higher of either the historical SPL Trial or commercial-scale Second SPL processing emission performance for each pollutant, and for Stack 5 the higher of the proposed thermal facility or current reverb operations for each pollutant, to be emitted at all times. 6.1.3 Mitigation Measures As the Project is not expected to result in an unacceptable change to the expected emissions from the facility and is not expected to result in adverse impacts on the surrounding environment, no additional mitigation measures to those already in place at the WA’s facility are considered necessary. WA commits to the ongoing operation of its existing air quality monitoring and management practices for the existing development and proposed Project.
6.2 Hazard and Risk A Preliminary Risk Screening (PRS) was prepared for the Project. A summary of this assessment is provided below, for further details refer to the PRS report included in Appendix F. 6.2.1 Existing Environment Dross and Second Cut SPL is currently delivered to the WA site by truck from smelters both local and interstate. The dross and SPL is unloaded into a dedicated building and stored in dedicated bays within the building. Dross and SPL is recovered using a front end loader and processed using a crushing and screening plant. The crushed and screened materials are then fed by conveyor to the main building where it is loaded to a furnace and heated. Dross and SPL are handled and processed separately. Dross is heated to extract the aluminium metal and SPL is processed to achieve the required treatment and mineralogical transformations. Following the processing of Second Cut SPL the material is removed from the furnace and allowed to cool in dedicated bunds within the processing building. Products derived from processing are then bagged to specification and dispatched from site by truck. A range of general safeguards are currently installed at the WA site: - Dust control – dust extraction on all equipment and storage bays, baghouse units and dust control curtains in front of the storage bays; - Bag-House Units – fitted with high differential pressure alarms, spare bags sets, pulse jet cleaning of bags, bag breakthrough detection (real-time, continuous particulate monitoring devices) and alarms; - Furnace – real-time, continuous temperature monitoring and high thermal mass in the furnace; and - Spill Retention – fully sealed and bunded buildings for the storage of SPL (no releases outside the buildings in the event of a spill). In addition to these a number of safeguards were identified in the Preliminary Hazard Assessment (PHA) (AECOM, 2012) that accompanied the EA for Second Cut SPL processing. Those safeguards recommended by the PHA (AECOM, 2012) are currently all in place and operational by WA. Further detail in relation to these safeguards is provided in Section 6.2.3. With the operation of theses safeguards, WA has not recorded any incidents or hazardous events during the course of its dross and SPL processing history. 6.2.2 Potential Impacts When examining the potential impacts of the Project, consideration is required of the SPL processing procedures that would be used by the Project. The Project does not propose to amend or alter in any way the established Second Cut SPL processing operation and would use the same process for the Project as described below: Proposed SPL Processing Operation SPL is delivered to site using the same process and Dangerous Goods licensed contractors as currently service the facility. The SPL would be delivered to the storage bays where it would be held until processing is performed. The SPL would be crushed and screened and fed to the main processing building using the existing covered conveyor and/or transferred to the main processing building via bins. The SPL would be heated in dedicated furnaces to thermally treat the material and effect the required mineralogical transformations. Once thermally processed, the charge would be removed from the furnace and cooled in a dedicated rotary cooler (i.e. jacketed cooling). The material would then be bagged to specification and transported to markets.
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Properties of SPL As detailed in Section 1.3, SPL is predominantly carbon and refractory materials, which are formed to line the base and walls of the aluminium smelting pot at the primary smelter. As detailed in the PHA (AECOM, 2012), SPL may produce hydrogen, acetylene, methane and ammonia upon contact with water. Precursors of gas generation are eliminated during WA’s processing phase. Furthermore, hydrogen sulphides or hydrogen cyanides may be formed upon contact with acid. However, there are no acids stored at the WA site and no potential for this incident to occur. In order to further determine potential hazards and risks the addition of First Cut SPL and Mixed SPL may introduce to the site, the following Safety Data Sheets (SDSs) were reviewed: - Second Cut SPL: Refractory Byproduct (product use: Raw material feed to produce refractory feedstock) (Ref. 9); and - First Cut SPL: Carbon Byproduct (product use: Raw material feed to produce kiln fuel) (Ref. 10). Table 10 lists the key composition differences between First Cut SPL and Second Cut SPL. Note that these compositions are general and representative of the type of First and Second Cut SPL that may be processed at the facility. In addition, the processing the First and Second Cut SPL as Mixed SPL would result in compositions generally between that of First and Second Cut SPL.
Table 10 Compositions: First Cut SPL and Second Cut SPL Refractory Byproduct – Second Carbon Byproduct - First Cut Composition Cut SPL SPL Carbon, non-activated 2-5% 50-75% Silica crystalline – quartz 40-70% 0-6% Sodium hydroxide 1-2% 2-4% Sodium fluoride 5-11% 9-11% Sodium aluminium fluoride 3-8% 0% Aluminium 0-1% 0% Iron 0-1% 0% Ferric oxide 2-4% 0% Sulphur 0-1% 0% Fluorspar 0-1% 0-1% Calcium oxide 1-5% 1-2% Fresh alumina (aluminium oxide 12-30% 2-10% Al2O3) Free cyanide 0-0.04% 0-0.1%
A preliminary assessment shows the key difference between First Cut SPL and Second Cut SPL is the significantly higher carbon content and marginally higher cyanide content. The higher carbon content classifies the First Cut SPL as a combustible material whereas the Second Cut SPL is considered a non-combustible material. Other composition differences between First and Second Cut SPL are not considered to result in additional hazards not already identified for Second Cut SPL. Hazard Analysis – Preliminary Risk Screening In order to determine potential hazards associated with the processing of First Cut and Mixed SPL over only Second Cut SPL, a Preliminary Risk Screening was undertaken. This screening took the form of a gap analysis of the hazardous properties of materials, hazardous incidents, and consequence analysis completed in the previous PHA (AECOM, 2012). The intent of this gap analysis is to determine if changes to the composition of SPL would
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result in a change to the risk profile of the facility and therefore whether further hazard analysis is required. The results of the gap analysis are presented in Table 11.
Table 11 Preliminary Risk Screening - Gap Analysis Does the change Element / Gap Analysis impact on the risk Consideration profile? (Y/N) Hazardous Properties of Materials Spent Potline Materials A preliminary assessment shows that First Cut SPL has a No significantly higher carbon content and slightly higher cyanide content than Second Cut SPL. The higher carbon content classifies the First Cut SPL as a combustible material (Ref. 9) whereas the Second Cut SPL is considered a non- combustible material (Ref. 10). Although First Cut SPL is considered a combustible material, it is not classified as Dangerous Goods and no significant risks are identified as a result of this change. Other composition differences between First and Second Cut SPL are not considered to result in additional hazards not already identified for Second Cut SPL. Treated Product Material The treated product materials of First Cut and Mixed SPL are No similar to the treated product material derived from the processing of Second Cut SPL. Therefore, no significant change to the risk profile is expected to arise from the treated product material of First Cut and Mixed SPL. Hazardous Incident Water contamination with Water contamination with cyanide is covered under [Refer Cyanide ‘Consequence Analysis’ below. Consequence Analysis below] Formation of Toxic Contact of SPL with acids may result in the formation of No Gases due to contact of hydrogen sulphide or hydrogen cyanide. However, acids are SPL with acids. not expected to be stored as part of the proposed changes*. Dust Generated during The effectiveness of the existing dust control systems have No Delivery been demonstrated during current plant operations. There is no change in the risk profile of dust generation during delivery. Hole in the Equipment or As there will be no dust release from the building in the event No Dust Extraction Ductwork of an equipment failure, there is no increase in the risk profile. Bag-house Failure There are no proposed changes to how bag-house failure is No monitored and controlled with the introduction of First Cut SPL and Mixed SPL to the site. Minor Holes in the Aldex The current controls remain adequate for the new material. No Building Roof There is no increase in the risk profile. Major Storm Damage to The mixing of water with SPL could result in the formation of [Refer the Aldex Building hydrogen gas and minor quantities of Consequence ammonia/methane/acetylene due to trace concentrations of Analysis below] carbides and nitrides being present within the material. This incident is covered under ‘Consequence Analysis’ below. Furnace Firing Failure In the event of a firing failure, there is a risk of cyanide No remaining within the furnace charge mass during the treatment process. Despite the concentration of cyanide being slightly higher in First Cut SPL, the quantities are still considered minor and
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Does the change Element / Gap Analysis impact on the risk Consideration profile? (Y/N) no change to the risk profile is expected in this scenario. Furthermore in the event of a firing failure, the burners would be restarted and the process restarted and continued through to completion of the processing sequence. Consequence Analysis Water Ingress to the Due to the storage arrangements being the same as No Building, Water/SPL Mix currently applied to Second Cut SPL, no change to the risk and Hydrogen profile is expected in this scenario. Generation Water Ingress to the The mixing of water with SPL could result in the formation of No Building, Water/SPL Mix hydrogen gas and minor quantities of and ammonia/methane/acetylene due to trace concentrations of Ammonia/Methane/Acetyl carbides and nitrides being present within the material. ene Generation Although there may be minor differences in the carbide and nitride concentrations of First Cut SPL compared with Second Cut SPL, the limiting factor in this scenario is the amount of water that may enter the storage building. This building is fully sealed to prevent water ingress. As the storage arrangements for First Cut SPL and Mixed SPL are the same as Second Cut SPL, no change to the risk profile is expected in this scenario. Water Ingress to the The previous PHA (Ref. 1) assessed the potential for No Building, Water/SPL Mix leaching of cyanide due to water ingress. & Dissolving of Cyanide Although First Cut SPL has a slightly higher concentration of cyanide to Second Cut SPL (0.1% compared with 0.04%), it is not expected that the slightly higher concentration would result in a significant risk of cyanide leaching to the environment. Furthermore WA store and handle SPL materials within bunded and enclosed buildings eliminating potential contact with water. Therefore, no change to the risk profile is expected in this scenario.
Based on the analysis conducted in this study, the hazards associated with the proposed storage and handling of First Cut and Mixed SPL (in conjunction with existing Second Cut SPL processing operations) at the WA facility does not result in a change to the existing risk profile, therefore, the risk criteria published by the NSW DPI in HIPAP No.4 are not exceeded. The facility would remain classified as ‘potentially hazardous’ and not ‘hazardous’, and would therefore be permitted to continue processing dross and SPL in a manner consistent with existing operational procedures. 6.2.3 Mitigation Measures Based on the analysis conducted in the PHA (AECOM, 2012) and the Preliminary Screening Analysis prepared for this Project (refer to Appendix F), the hazards associated with the proposed storage, handling and processing of SPL at the WA facility does not result in a change to the existing risk profile as a result of the Project. Therefore, the risk criteria published by the NSW DPI in HIPAP No.4 is not exceeded and the facility remains classified as ‘potentially hazardous’ and not ‘hazardous’ and would therefore be permitted to continue operations processing dross and Mixed SPL. Despite the existing safeguards being deemed suitable for the management of hazards and risk at the WA site, WA commits to the ongoing operation of these existing site safeguards for the duration of the Project: - Dust Control – storage and handling areas within the Aldex and Process buildings are fitted with dust extraction units that deliver extracted dust to bag-house units;
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- Dust Control - curtains are installed across the front of the storage bays to improve ventilation and thereby minimise dust escape into the buildings; - Dust Control - Truck access doors across the entrance to the building can be closed to prevent dust escape whilst handling SPL; - Building Pressure Control – all buildings are maintained at slightly negative pressure to prevent dust escape from the buildings; - Building Dust Control – all buildings are fitted with dust extraction systems that report to bag-house units to extract any dust collected within the building internal atmosphere; - Equipment Dust Control – all equipment (e.g. crushers and material transfer stations on conveyors) are fitted with dust extraction that reports to bag-house units; - Bag-houses – all bag-houses are fitted with real-time, continuous particulate monitoring systems (indicative of filter performance and incidence of failed bags); - Bag-houses – all bag-houses are fitted with high differential pressure detection to activate bag switch-over and clogged bag cleaning processes; - Furnace Operations – furnaces are monitored for real-time, continuous temperature monitoring and control; - Furnace Thermal Load – the furnace contains a high thermal load (also aided by the refractory nature of feedstock materials) and loss of furnace heating which would not result in an immediate drop in furnace temperature. The furnace would remain at elevated temperatures for an extended period (many hours) without further heating; - Treated SPL Cooler – cooler casing is steel, which eliminates the potential for failure of the casing from overheating (note that steel will not fail at 600oC); and - Water Ingress Control – buildings are fully sealed and bunded to prevent water ingress and impact of water on SPL.
6.3 Other Environmental Issues Other environmental aspects that were identified in Section 5.0 as having a ‘very low’ or ‘no anticipated impact’ level of potential impacts include: - Traffic; - Soil and Water; - Greenhouse Gas Emissions; - Noise; - Waste Management; - Social and Economic; - Visual; - Heritage; - Land use; and - Fauna and Flora. Consideration of these matters is provided in Table 12.
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Table 12 Other Environmental Issues
Issue Consideration Traffic Access to site is currently undertaken via Mitchell Avenue. WA ensures that haulage is via the Hunter Expressway, then Hart Rd, Government Rd and Mitchell Avenue. No truck movements would occur through the Kurri Kurri town centre. Access to the site via Mitchell Avenue would remain unchanged for the Project. As the Project is not proposing to increase or change its processing tonnage limits, no additional truck movements beyond those associated with the development would be generated. Therefore it is considered that the Project would have a negligible impact on traffic and transport. The existing management measures currently in place at WA are considered appropriate for the ongoing management of traffic associated with the Project.
Soil and Water The Project would be undertaken within existing facilities on site. There is no proposed change to the existing site footprint, and no excavations will occur. There would be no construction activities associated with the Project and as such there would be no immediate impact on soils and local water quality. SPL will be stored on site as part of the Project within the existing sealed and enclosed site buildings in accordance with current practices. It is therefore unlikely that contamination of stormwater would occur through runoff encountering SPL and potentially leading to downstream contamination of soils and surface water resources. There is also potential for accidental fuel and oil spills to occur on site during operation of plant and equipment, which is managed through training, spill response and capture and containment measures that can be implemented should a spill occur. WA already has in place a first flush stormwater control system on site which consists of a drainage network, pond storage and constructed wetland system. The Stormwater control system segregates off-site stormwater entering the site, uncontaminated on-site stormwater and potentially contaminated on-site stormwater as follows: - Off-site stormwater entering the site is directed to a grass swale catch drain and directly discharged into Swamp Creek; - Uncontaminated on-site stormwater is directed to a swale pond, allowed to settle, and then discharged directly to the wetland; and - Potentially contaminated first flush water is fed through a constructed wetland to remove contaminants, and the resulting clean water is irrigated on site from the main pond storage, which holds the water from the wetland system and acts as a first flush containment facility for the development. Annual water quality monitoring of the Main Pond is undertaken in accordance with EPL 6423. Samples are taken to monitor the concentrations of aluminium, fluoride, total suspended solids, cyanide, conductivity and pH and the results are reported to EPA annually. WA’s existing stormwater management measures would be implemented for the Project. The existing management measures in place at WA to manage potential impacts to soil and water are considered adequate for the Project. Potential impacts to soil and water quality as a result of the Project would therefore be minimal.
Greenhouse A Greenhouse Gas Emissions assessment for the processing of up 40,000 tonnes of Gas Emissions combined dross and SPL per year was undertaken as part of the original project approval. As the Project does not proposed to amend this tonnage limits, GHG production from input energy required to process this quantity of resource would be similar to that reported in the previous SPL EA (AECOM, 2012), therefore there is not expected to be a significant change in GHG generation as a result of the Project.
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Issue Consideration Noise As no construction activities are required to support the Project, there would be no construction noise generated. No new plant, machinery or equipment is proposed as part of the Project. The Project would utilise existing equipment that is currently used for the processing of aluminium dross and Second Cut SPL at WA. Therefore, there would be a negligible change to the previously assessed and approved noise limits for the site. As the Project would continue to process within the approved tonnage limits, there would be a negligible change in the previously assessed number of truck movements; therefore changes to traffic noise would be negligible. Waste SPL material is a hazardous waste product generated as a result of primary aluminium Management production. Currently, limited treatment options and capacity exists domestically, and the only alternative disposal options available to primary aluminium smelters are to stockpile the waste SPL material or transport it overseas for treatment. SPL material has the same dangerous goods classification as aluminium dross, which is Class 4.3 Package Group III material. WA has existing material handling and storage strategies to ensure appropriate handling of the material throughout all production steps. These would continue to be implemented for the Project. The dominant wastes generated within the existing WA facility during dross processing are dust fines collected from each of the baghouse dust collectors. Dust fines are collected into bulka bags and stored on site prior to beneficial reuse in the steel making and foundry industries, and are thereby diverted from landfill disposal. Minor quantities of dust fines for which a beneficial reuse has not yet been realised are currently disposed of, and samples of these wastes are routinely collected and analysed to demonstrate conformance with requirements of the Specific Immobilisation Approval (Issued by the EPA in accordance with the requirements of the POEO (Waste) Regulation 2014, and in conjunction with routine site disposal protocols. Other wastes produced on site include trade wastewater (from excess cooling water, toilet and showering amenities and crib facilities), wastes from general maintenance activities (waste oil (recycled), scrap steel (recycled) and other general waste) and general office waste. The Project would have a negligible impact on the amount of these wastes generated from the site. Potential Impacts The Project would create additional opportunity for domestic treatment of a hazardous waste product, thereby processing it into an alternative raw material that has value. The Project would reduce the need to ship hazardous wastes internationally, which benefits the environment and the waste producer. The Project could generate hazardous waste should processing of the SPL material fail to result in destruction of cyanide. Should this occur, the material would be captured by Quality Assurance and Control processes and returned for reprocessing. Previous trials (refer to Section 6.1 and Appendix D ) have demonstrated that the proposed SPL treatment process is successful in reducing cyanide content to negligible levels, and it is anticipated that cyanide contamination will not represent an issue. There would be no other additional wastes generated by the Project. Mitigation Measures The following mitigation measures (existing and proposed) would be implemented to minimise the potential waste management issues resulting from the Project: - SPL material would be delivered to the facility by a Dangerous Goods Licensed Contractor; - All raw material truck delivery loads would be covered by tarpaulin (similar to existing dross and Second Cut SPL deliveries) to prevent spillages; - All raw materials would be delivered in a dry state, - The unloading and storage of untreated and processed material would be within existing enclosed buildings;
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Issue Consideration - Existing fabric filter baghouses would be utilised for the control and removal or particulate that may arise during the unloading and loading processes; - All operations would be performed within enclosed buildings to mitigate against external spills; - Should a spill occur, site personnel would recover materials in accordance with established spill response procedures. Spilt material would be returned to storage for processing (i.e. not disposed of); and - Existing pollution control systems would be utilised for the Project. Social and The Project would have the positive economic impact of using spare capability within the Economic existing approved development which would provide greater employment security for the existing workforce and associated Contractors. The processing of SPL would also see greater resource recovery and economic benefit from what would otherwise be a waste material. The reuse options for processed SPL would also reduce the need for end users to source raw material from extractive industries therefore reducing pressure on these resource sources of materials and potential demand based price pressures. Visual No new plant or equipment is proposed as part of the Project therefore there would be a negligible impact on visual impacts. Heritage No new construction works or ground disturbance would be required by the Project. All proposed activities would be undertaken within the existing WA site and building footprints. No items of heritage significance have been identified. Impact to heritage would therefore be negligible. Land use As the Project proposed to use an existing process within the confines of an existing facility and within the existing tonnages limits, impacts to land use would be negligible. Fauna and The Project would be undertaken within the existing WA facility. Impact to flora and fauna Flora would be negligible.
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7.0 Summary of Management Measures Weston WA commits to the update of its Environmental Management System to incorporate the management measures listed in Table 13.
Table 13 Summary of Management Measures Issue Mitigation Measures
Air Quality All existing air quality monitoring and management systems will continue to be operated for the duration of the Project. Monitoring of air emission parameters currently assessed for dross and Second Cut SPL processing operations will continue to be undertaken in accordance with the existing emissions monitoring regimes.
Hazards and Risk - Existing operational procedures for the management of hazards and risks would continue to be in place for the duration for the Project. This includes: Dust Control – Storage and handling areas within the Aldex and Process buildings fitted with dust extraction units that deliver extracted dust to bag- house units; Dust Control - Curtains installed across the front of the storage bays to minimise dust escape into the building; Dust Control - Truck access doors across the entrance to the building closed to prevent dust escape whilst tipping SPL; Building Pressure Control – Negative pressure maintained in all buildings to prevent dust escape from the buildings; Building Dust Control – All buildings fitted with dust extraction systems that report to bag-house units to extract any dust collected within the building internal atmosphere; Equipment Dust Control – All equipment (e.g. crushers and material transfer stations on conveyors) fitted with dust extraction that reports to bag-house units; Bag-houses – All bag-houses fitted with real-time, continuous particulate monitoring systems; Bag-houses – All bag-houses fitted with high differential pressure detection to activate bag switch-over and clogged bag cleaning processes; Furnace Operations – furnaces are monitored for real-time, continuous temperature monitoring and control; Furnace Thermal Load – Loss of furnace heating will not result in an immediate drop in furnace temperature. The furnace will remain at elevated temperatures for an extended period (many hours) without further heating; Treated SPL Cooler – Cooler casing is steel, which eliminates the potential for failure of the casing from overheating (note that steel will not fail at 600°C); and Water Ingress Control - Fully sealed and bunded buildings to prevent water ingress and impact of water on SPL. Waste Management - SPL material will be delivered to the facility by a Dangerous Goods Licensed Contractor. - All raw material truck delivery loads will be covered by tarpaulin (similar to existing dross and Second Cut SPL deliveries) or via tautliner (covered flatbed truck) to prevent spillages. - All raw materials will be delivered in a dry state. - The unloading and storage of untreated and processed material will be within existing enclosed buildings. - Existing fabric filter baghouses will be utilised for the control and removal or particulate that may arise during the unloading and loading processes. - All operations will be performed within enclosed buildings to mitigate against external spills. - Should a spill occur, site personnel will recover materials in accordance with established spill response procedures. Spilt material will be returned to storage for
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Issue Mitigation Measures
processing (i.e. not disposed of). Traffic - All haulage will be via the Hunter Expressway with no truck movement to occur through the townships of Kurri Kurri or Weston. - All trucks delivering and removing material will be filled to capacity and covered to minimise required truck movements. Soil and Water - SPL material will be managed under the same operating system as for aluminium dross and Second Cut SPL. - All raw material truck delivery loads will be covered by tarpaulin to prevent spillages and water ingress. - All operations will be performed within enclosed buildings to mitigate against external spills. - Should a spill occur, site personnel will recover materials in accordance with established spill response procedures. Spilt material will be returned to storage for processing (i.e. not disposed of). - Ongoing implementation of the water quality monitoring program. Greenhouse Gas Practices currently in place at the plant to reduce GHG emissions including the routine tuning of furnace burners, to increases burner efficiency and reduces GHG emissions, will continue to be undertaken.
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8.0 Conclusion This Environmental Assessment presents details of the Project, assesses the existing natural and social environments, describes the potential impacts on the environment and described management measures to minimise or avoid the identified impacts. The Project seeks to expand WA’s ability to process and recycle all SPL materials (First Cut, Second Cut and Mixed fraction SPL). The Project would utilise the existing processes in place at WA to process Second Cut SPL, however would improve WA’s position by offering a solution for the recycling of the SPL balance generated by aluminium smelters. Traditionally, SPL has been stockpiled and/or exported overseas for treatment. Some domestic treatment has occurred, yet this has, to date, been limited and capacity is constrained. The treatment and processing of SPL on a commercial scale by WA, provides an alternative to the international transport of this hazardous material, in doing so securing the sustainability and growth of the domestic aluminium industry. The Project would result in improved market versatility would also assist in securing the ongoing operation of the WA site and employment for its workers and associated contractors. The commercial scale treatment and processing of SPL is proposed to be conducted at WA’s existing Plant located at Kurri Kurri. The storage and processing of SPL will be undertaken within existing storage buildings and processed through existing rotary furnaces that are currently used to process Second Cut SPL. The footprint of the development would remain unchanged as a result of the Project. The current development consent authorises WA to process up to 40,000 tonnes of dross aluminium and Second Cut SPL combined per year. The Project does not seek to increase these combined throughput tonnages. Rather, WA would work within this tonnage limit to process up to 40,000 tonnes per year of dross, First and Second Cut SPL and Mixed SPL collectively. Air quality and hazard screening investigations, along with the assessment of other environmental factors undertaken as part of this EA revealed that the potential impacts of the Project would not be significant. With the implementation of the mitigation measures proposed, it is expected that impacts would be eliminated or minimised and the Project can proceed accordingly.
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9.0 References AECOM (2012) 60250493-RPTFinal(Rev0)-20Apr12, Processing of Spent Potlining – Weston Aluminium Pty Limited, Preliminary Hazard Analysis, 20 April 2012. AECOM Report No: 60250487-Environmental Assessment Spent Potlining Processing, Revision D – Final Revised, 10 May 2012. Cessnock City Council (2003) City Wide Settlement Strategy, Cessnock City Council, NSW. DECCW (2009) Waste Classification Guidelines – Part 1 – Classifying Waste, NSW Department of Environment, Climate Change and Water, Sydney, December 2009. DP&E (2011), Applying SEPP 33”, Hazardous and Offensive Industry Development Application Guidelines NSW DPI Hazardous Industry Planning Advisory Paper No.6, “Guidelines for Hazard Analysis. DP&E (1992), Hazardous Industry Planning Advisory Paper No.4, Risk Criteria for Land Use Safety Planning. DP&E (1997) Multi-Level Risk Assessment. Department of Infrastructure and Regional Development (Cwth) The Australian Code for the Transport of Dangerous Goods by Road and Rail (Known as the Australian Dangerous Goods Code or ADG), 7th ed., National Transport Commission, 628 Bourke Street, Melbourne, VIC. United Nations (1989) Basel Convention on the Control of Transboundary Movement of Hazardous Wastes and Their Disposal, 22 March 1989. Weston Aluminium (2011) Monitoring and Verification Report – Spent Potlining Material Processing Trial, Rev 0, 04 March 2011. Weston Aluminium (2016) Monitoring and Verification Report, Mixed Spent Potlining Processing Trial, Rev 0, 20 May 2016.
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Appendix A
Secretary’s Environmental Assessment Requirements
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Appendix A Secretary’s Environmental Assessment Requirements
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Appendix B
Mixed Cut SPL Trial Monitoring Report
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Appendix B Mixed Cut SPL Trial Monitoring Report
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Appendix C
Existing Consents
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Appendix C Existing Consents
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Appendix D
EPBC Protected Matters Search
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Appendix D EPBC Protected Matters Search
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Appendix E
Air Quality Impact Assessment
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Appendix E Air Quality Impact Assessment
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Appendix F
Preliminary Hazard Screening
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Appendix F Preliminary Hazard Screening
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