Sulphuric Acid from Port Kembla, to the Project

Cowal Gold Project – Addendum to the Transport of Hazardous Materials Study

On 7 February 2017 the Cowal Gold Project’s (the Project) Development Consent (DA 14/98) was modified to reflect approval of the Mine Life Modification. The Mine Life Modification involves an extension of the Project’s operational mine life for an additional eight years (i.e. to end 2032) and an increase to the depth of the existing open pit (among other things).

During the preparation of the Mine Life Modification, Evolution identified an alternative transport route that involves direct road transport of sulphuric acid from Port Kembla, to the Project. Accordingly, this Addendum to the Transport of Hazardous Materials Study (THMS) has been prepared to reflect the alternate transport route for sulphuric acid.

This Addendum includes an updated assessment of the likelihood of a hazardous incident along the revised transport route for the delivery of sulphuric acid to the Project, and an update to the risk analysis results.

COWAL GOLD PROJECT

ADDENDUM TO THE TRANSPORT OF HAZARDOUS MATERIALS STUDY

JULY 2018 Project No. HAL-02-07 Document No. 922533

Sulphuric Acid Road Transport Route Evaluation – Overview

ADDENDUM Transport of Hazardous Materials Study

1. Given the proposed route change, hydrochloric acid and sulphuric acid are no longer following the same route and cannot be assessed together. As such, consider the attachments in this Addendum as an additional attachment (i.e. Attachment 8) to the original THMS.

2. Include the new Attachment 8A provided in this document.

3. Include the new Attachment 8B provided in this document.

4. Include the new Attachment 8C provided in this document.

5. Include the new Attachment 8D provided in this document.

6. Split Section 4.2 of the THMS into 4.2(a) and 4.2(b) and insert the text below as Section 4.2(b):

Road transport of sulphuric acid within NSW begins at Port Kembla and terminates at the Project.

The road transport route for sulphuric acid to the Project has been divided into four segments (Segments 1 to 4) for the purpose of route evaluation. Route evaluations for Segments 1 to 4 are attached to the THMS as Attachments 8A, 8B, 8C and 8D respectively. An overview of Segments 1 to 4 is provided below.

Segment 1 Attachment 8A Transport of sulphuric acid from Port Kembla to the Hume Highway (Sydney)

Segment 2 Attachment 8B Transport of sulphuric acid from the Hume Highway (Sydney) to Temora

Segment 3 Attachment 8C Transport of sulphuric acid from Temora to West Wyalong

Segment 4 Attachment 8D Transport of sulphuric acid from Newell Highway/Mid Western Highway (West Wyalong) to the Cowal Gold Project

A summary of the outcomes of the route evaluations for Segments 1 to 4, including the identification of suitable transport routes, is provided below. The overall sulphuric acid transport route to the Project and suitable transport routes for Segments 1 to 4 are shown on Figures 9a, 9b and 9c.

00927525 1 Evolution Mining (Cowal) Pty Limited QUEENSLAND

MOREE

WALGETT BOURKE

NARRABRI COFFS HARBOUR ARMIDALE NEW SOUTH WALES

NYNGAN

DUNEDOO DUBBO MUSWELLBROOK

SINGLETON South

For SEGMENT 4 NEWCASTLE MOLONG detail see Figure 9c PARKES COWAL BATHURST GOLD

535 PROJECT ML1 Pacific GRENFELL COWRA SYDNEY WEST WYALONG For SEGMENT 1 SEGMENT 3 detail see Figure 9b (Route 3B) MIRROOL YOUNG TEMORA WOLLONGONG Port Kembla Ocean GOULBURN SEGMENT 3 YASS NARRANDERA (Route 3A) WAGGA WAGGA SEGMENT 2 (Route(Route 2A) A.C.T.

TOCUMWAL ALBURY

LEGEND

Route 2(Segment As 2) and 3A (Segment 3) VICTORIA Route B3(Segment 3)

0 50 100 15 0 Kilometres Transport of Hazardous Materials Study FIGURE 9a Overall Sulphuric Acid Transport Route and Segments 2 and 3 Suitable Transport Routes HAL-02-07-THMS MR 2018_003A !

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LEGEND Route 1A Route 2A (Segment 2) Lake Illawarra 0 5 Transport of Hazardous Materials Study Kilometres FIGURE 9b Sulphuric Acid - Segment 1 Suitable Transport Routes HAL-02-07-THMSHAL-02-07-THMS MRMR 2018_201A2018_201A

! !

! Burcher Nerang

540 000 E

530 000 E 520 000 E Cowal

6 290 000 N 6 290 000 N

Bogeys Island

Wamboyne Mountain

6 280 000 N Road 6 280 000 N ML1535 Wamboyne Dip COWAL Gazetted GOLD Lake Rail Crossing PROJECT Cowal

Bonehams Wamboyne Road

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6 250 000 N 6 260 000 N LEGEND Lake Cargelligo Route A4 Mid Western 0 2.5 5.0 Highway West Wyalong Kilometres Cootamundra Transport of Hazardous Materials Study oTemoraTo FIGURE 9c Sulphuric Acid - Highway Railway Segment 4 Suitable Transport Route

520 000 E

Newell 530 000 E HAL-02-07-THMS SA_002A Sulphuric Acid Road Transport Route Evaluation – Overview

Segment 1

Route 1A (Table 9a) has been identified as potential available routes for heavy vehicles for Segment 1 and is suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). The route is assessed as posing a minimal to acceptable level of risk to surrounding people, property and the natural environment. Therefore, Route 1A is suitable for the transport of sulphuric acid for Segment 1.

Risk management measures required to be implemented by the material supplier and transport provider for the transport of sulphuric acid to the Project are set out in Attachment 8A.

Table 9a Sulphuric Acid – Segment 1 – Suitable Transport Routes

Route Directions 1A On exiting Foreshore Road, Port Kembla, turn right onto Old Port Road which becomes Flinders Street, turn right onto Five Islands Road then right onto M1 Princes Motorway then left onto Picton Road on left onto the Hume Highway.

Route 1A is shown on Figure 9b.

Segment 2

Route 2A (Table 9b) has been identified as the only potential available route for heavy vehicles for Segment 2 and is suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). Route 2A is assessed as posing a minimal level of risk to surrounding people, property and the natural environment. This route has also been recommended by the RMS and transport provider for the transport of hazardous materials. Consultation with Councils regarding Route 2A will also be undertaken and Council comments will be taken into consideration by the THMS.

Risk management measures required to be implemented by the material supplier and transport provider for the transport of sulphuric acid to the Project are set out in Attachment 8B.

Table 9b Sulphuric Acid – Segment 2 – Suitable Transport Route

Route Directions 2A From the Hume Highway (Glenfield), continue on the Highway until Bowning (west of Yass). Turn off the Hume Highway into State Route 94 (Burley Griffin Way) and continue to Temora.

Route 2A is shown on Figure 9a.

00927525 5 Evolution Mining (Cowal) Pty Limited Sulphuric Acid Road Transport Route Evaluation – Overview

Segment 3

Routes 3A and 3B (Table 9c) have been identified as potential available routes for heavy vehicles for Segment 3 and are suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). Both routes are assessed as posing a minimal to acceptable level of risk to surrounding people, property and the natural environment. Therefore, Routes 3A and 3B are both suitable for the transport of sulphuric acid for Segment 3.

Risk management measures required to be implemented by the material supplier and transport provider for the transport of sulphuric acid to the Project are set out in Attachment 8C.

Table 9c Sulphuric Acid – Segment 3 – Suitable Transport Routes

Route Directions 3A On entering Temora, continue along Burley Griffin Way (State Route 94) to the Newell Highway south of Mirrool. Turn right onto the Newell Highway and continue to the Newell Highway/Mid Western Highway (West Wyalong). 3B On entering Temora, turn right into Barmedman Road (State Route 85) and continue to Wyalong. At Wyalong turn left onto the Newell Highway and continue to West Wyalong. On entering West Wyalong, take the town heavy vehicle bypass route (Turn left into Copeland Street which becomes Railway Road. Take the first left off Railway Road and cross over the Temora-Lake Cargelligo Railway line. After crossing the railway line, turn immediately right and follow the railway line to the Newell Highway). Turn right onto the Newell Highway and continue to West Wyalong. Turn left into the Mid Western Highway until the junction with Ungarie Road.

Routes 3A and 3B are shown on Figure 9a.

Segment 4

Route 4A (Table 9d) has been identified as the only potential available route for heavy vehicles for Segment 4 and is suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). Route 4A is assessed as posing a minimal level of risk to surrounding people, property and the natural environment. This route is also the approved Project Access Road. Therefore, Route 4A is suitable for the transport of hazardous materials and is the preferred route for the transport of sulphuric acid from the Newell Highway/Mid Western Highway (West Wyalong) to the Cowal Gold Project.

Risk management measures required to be implemented by the material supplier and transport provider for the transport of sulphuric acid to the Project are set out in Attachment 8D.

Table 9d Sulphuric Acid – Segment 4 – Suitable Transport Route

Route 4A is shown on Figure 9c.

7. Insert Attachment 8:

00927525 6 Evolution Mining (Cowal) Pty Limited Sulphuric Acid Road Transport Route Evaluation – Overview

SULPHURIC ACID ROAD TRANSPORT ROUTE EVALUATION

OVERVIEW

Road transport of sulphuric acid within NSW begins at Port Kembla and terminates at the Project.

Segment 1 Attachment 8A Transport of sulphuric acid from Port Kembla to the Hume Highway (Sydney)

Segment 2 Attachment 8B Transport of sulphuric acid from the Hume Highway (Sydney) to Temora

Segment 3 Attachment 8C Transport of sulphuric acid from Temora to West Wyalong

Segment 4 Attachment 8D Transport of sulphuric acid from Newell Highway/Mid Western Highway (West Wyalong) to the Cowal Gold Project

The following figures are referred to in Attachments 8A to 8D and are appended to this overview:

Figure 8-1 Project Location, Overall Sulphuric Acid Transport Route and Segments 2 and 3 Suitable Transport Routes Figure 8-2 Route Selection Assessment Process Figure 8-3 Sulphuric Acid – Segment 1 Suitable Transport Routes Figure 8-4 Sulphuric Acid – Segment 4 Suitable Transport Route

00927525 7 Evolution Mining (Cowal) Pty Limited QUEENSLAND

MOREE

WALGETT BOURKE

NARRABRI COFFS HARBOUR ARMIDALE NEW SOUTH WALES

NYNGAN

DUNEDOO DUBBO MUSWELLBROOK

SINGLETON South

For SEGMENT 4 NEWCASTLE MOLONG detail see Figure 8-4 PARKES COWAL BATHURST GOLD

535 PROJECT ML1 Pacific GRENFELL COWRA SYDNEY WEST WYALONG For SEGMENT 1 SEGMENT 3 detail see Figure 8-3 (Route 3B) MIRROOL YOUNG TEMORA WOLLONGONG Port Kembla Ocean GOULBURN SEGMENT 3 YASS NARRANDERA (Route 3A) WAGGA WAGGA SEGMENT 2 (Route(Route 2A) A.C.T.

TOCUMWAL ALBURY

LEGEND

Route 2(Segment As 2) and 3A (Segment 3) VICTORIA Route B3(Segment 3)

0 50 100 15 0 Kilometres Transport of Hazardous Materials Study FIGURE 8-1 Overall Sulphuric Acid Transport Route and Segments 2 and 3 Suitable Transport Routes HAL-02-07-THMS Add SA 2018_003A Define Transport Area

Identify Hazardous Material, Source and Destination

Identify Available Roads for Heavy Vehicles

Mandatory Considerations Subjective Factors

Preliminary List of Routes

Emergency Response Risk Assessment Road and Traffic Factors Capability Operational Factors

Select Routes

Identify Risk Management Measures

Preliminary Screening Secondary Screening

Source: Adapted from DoP, 2011a

Transport of Hazardous Materials Study FIGURE 8-2 Route Selection Assessment Process

HAL-02-07-THMS Add SA 2018_001A !

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LEGEND Route 1A Route 2A (Segment 2) Lake Illawarra 0 5 Transport of Hazardous Materials Study Kilometres FIGURE 8-3 Sulphuric Acid - Segment 1 Suitable Transport Routes HALL--02--07--TTHMS Add SA 2018_201A

! !

! Burcher Nerang

540 000 E

530 000 E 520 000 E Cowal

6 290 000 N 6 290 000 N

Bogeys Island

Wamboyne Mountain

6 280 000 N Road 6 280 000 N ML1535 Wamboyne Dip COWAL Gazetted GOLD Lake Rail Crossing PROJECT Cowal

Bonehams Wamboyne Road

Wests Lane Lane

Blow Clear Road Road Lake Cowal Blow Clear Bland 6 270 000 N Lonergans Lane 6 270 000 N Billys Creek Lookout

Sandy Ridge Road

Wilsons Lane Creek

Clear

Bodels

Lane

Road To Forbes 6 260 000 N 6 260 000 N

Wamboyne

Railway

Road

Burcher

Ridge Highway

Newell West Wyalong Clear

6 250 000 N 6 260 000 N LEGEND Lake Cargelligo Route 4 A Mid Western 0 2.5 5.0 Highway West Wyalong Kilometres Cootamundra Transport of Hazardous Materials Study oTemoraTo FIGURE 8-4 Sulphuric Acid - Highway Railway Segment 4 Suitable Transport Route

520 000 E

Newell 530 000 E HAL-02-07-THMS Add SA 2018_002A Sulphuric Acid Road Transport Route Evaluation – Overview

ATTACHMENT 8A

00927525 1 Evolution Mining (Cowal) Pty Limited

Sulphuric Acid Road Transport Route Evaluation – Segment 1

COWAL GOLD PROJECT TRANSPORT OF HAZARDOUS MATERIALS STUDY

ATTACHMENT 8A

SULPHURIC ACID ROAD TRANSPORT ROUTE EVALUATION

SEGMENT 1 PORT KEMBLA TO HUME HIGHWAY

JULY 2018 Project No. HAL-02-07 ID: 922539 Sulphuric Acid Road Transport Route Evaluation – Segment 1

TABLE OF CONTENTS

Section Page

8A1 INTRODUCTION 8A-1

8A2 DEFINITION OF THE TRANSPORT AREA 8A-1

8A3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION 8A-1 8A3.1 IDENTIFICATION OF HAZARDOUS MATERIAL 8A-1 8A3.2 SOURCE AND DESTINATION 8A-2 8A4 PRELIMINARY SCREENING 8A-2 8A4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES 8A-2 8A4.1.1 Road Hierarchy 8A-2 8A4.1.2 Identification of Truck Routes 8A-3 8A4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes 8A-4 8A4.2 MANDATORY CONSIDERATIONS 8A-4 8A4.2.1 Physical Considerations 8A-4 8A4.2.2 Laws and Regulations 8A-5 8A4.3 SUBJECTIVE FACTORS 8A-6 8A4.3.1 Landuse 8A-6 8A4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes 8A-7 8A4.3.3 Emergency and Evacuation Planning and Infrastructure 8A-7 8A4.3.4 RMS and Transporter Preferred Transport Routes 8A-8 8A4.4 PRELIMINARY SCREENING FINDINGS 8A-8 8A5 PRELIMINARY LIST OF ROUTES 8A-9

8A6 SECONDARY SCREENING 8A-9 8A6.1 ROAD AND TRAFFIC FACTORS 8A-9 8A6.1.1 Accident Statistics 8A-10 8A6.1.2 Availability of Alternative Emergency Routes 8A-10 8A6.2 EMERGENCY RESPONSE CAPABILITY 8A-10 8A6.3 OPERATIONAL FACTORS 8A-11 8A6.4 RISK ASSESSMENT 8A-11 8A6.4.1 Hazard Identification 8A-11 8A6.4.2 Consequence Analysis 8A-13 8A6.4.3 Estimation of the Likelihood of a Hazardous Incident 8A-13 8A6.4.4 Risk Analysis and Assessment of Risk Results 8A-15 8A7 SELECTION OF ROUTES 8A-17

8A8 RISK MANAGEMENT MEASURES 8A-18

8A9 REFERENCES 8A-20

922539 8A-i Sulphuric Acid Road Transport Route Evaluation – Segment 1

TABLE OF CONTENTS (continued)

LIST OF TABLES

Table 1 Hazardous Material Source and Destination Table 2 Transport Details Table 3 Truck Routes Table 4 Sensitive Landuses Table 5 Sensitive Ecosystems and Natural Landscapes Table 6 Summary of Subjective Factors Table 7 Preliminary List of Routes Table 8 Summary of Accident Statistics Table 9 Heavy Vehicle Incidents – Initiating and Contributing Causes Table 10 Risk Matrix Table 11 Consequence Ratings Table 12 Summary of Risk Analysis Assessment Factors Table 13 Risk Analysis Findings

922539 8A-ii Sulphuric Acid Road Transport Route Evaluation – Segment 1

8A1 INTRODUCTION

The Cowal Gold Project (the Project) is located approximately 38 kilometres (km) north-east of West Wyalong, New South Wales (NSW) (Figure 8-1). The Project is owned by Evolution Mining (Cowal) Pty Limited (Evolution).

As described in Section 1.2 of the Transport of Hazardous Materials Study (THMS), route evaluation is required for the road transport of sulphuric acid to the Project. Road transport of this material within NSW begins at Port Kembla and terminates at the Project. The road transport route for sulphuric acid to the Project has been divided into four segments (Segments 1, 2, 3 and 4) for the purpose of route evaluation.

This attachment sets out the route evaluation for the road transport of sulphuric acid from Port Kembla to the Hume Highway. This part of the overall road transport route is referred to as Segment 1. The route evaluation for Segment 2, 3 and 4 are attached to the THMS as Attachments 8B, 8C and 8D.

This route evaluation has been carried out in accordance with the Department of Planning’s (DoP’s)_Hazardous Industry Planning Advisory Paper No. 11 Route Selection guidelines (DoP, 2011a) (the Guidelines), as required by Development Consent Condition 5.4(b)(i). The Guidelines state that in considering the relative risks of transport incidents involving hazardous materials, simplifying assumptions can be made such as the use of representative loads.

Figure 8-2 shows the assessment process flowsheet for this route evaluation.

8A2 DEFINITION OF THE TRANSPORT AREA

The transport area is defined by the Guidelines as follows:

Definition of the transport area is carried out from a traffic perspective. It should include the area over which traffic to or from the development is likely to have a significant effect.

The transport area for Segment 1 is defined as the area between the Port Kembla and the Hume Highway (Figure 8-3).

The transport area is situated within the Wollongong and Wollondilly Local Government Areas (LGAs).

8A3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION

8A3.1 IDENTIFICATION OF HAZARDOUS MATERIAL

As described in Section 1.2 of the THMS, identification of hazardous materials for which a route evaluation is required was undertaken prior to the preparation of this route evaluation. This included an assessment of the class of material being transported (i.e. the classification of dangerous goods under the Australian Code for the Transport of Dangerous Goods by Road and Rail 1998 [ADG Code]), the type of container and the movement quantity and frequency. The assessment identified sulphuric acid as hazardous materials for which a route evaluation is required. The DoP concurred with this assessment (as outlined in DoP correspondence dated 14 October 2005).

Sulphuric acid is classified as Class 8 under the ADG Code. Details of the type of container (i.e. packaging) and the movement quantity and frequency are provided in the following section.

922539 8A-1 Sulphuric Acid Road Transport Route Evaluation – Segment 1

8A3.2 SOURCE AND DESTINATION

The source and destination of sulphuric acid for Segment 1 are outlined in Table 1 and shown on Figure 8-1.

Table 1 Hazardous Material Source and Destination

Source: Destination: Port Kembla Hume Highway Location Town/City LGA Location Town/City LGA Hume Highway Port Kembla Wollongong Wollongong Sydney Campbelltown (Glenfield)

Details of the transport of sulphuric acid from Port Kembla to the Hume Highway are provided in Table 2.

Table 2 Transport Details

Hazardous Delivery Maximum Volume per Maximum Frequency Transported Packaging Material Vehicle Delivery of Deliveries State Sulphuric Acid B-Double 40 t 2 per day Liquid Bulk tanker

8A4 PRELIMINARY SCREENING

The following subsections identify available roads for heavy vehicles within the transport area and examine mandatory and subjective factors for potential transport routes. Section 8A5 provides the results of this analysis as a preliminary list of routes. Further screening of this preliminary list is provided in Section 8A6.

8A4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES

The Guidelines require the identification of potential available roads for heavy vehicles to be based on:

 a review of the road hierarchy (Section 8A4.1.1); and  the identification of routes suitable in general for the movement of trucks (Section 8A4.1.2). Results of the review of the road hierarchy and the identification of routes suitable in general for the movement of trucks are provided in Section 8A4.1.3.

8A4.1.1 Road Hierarchy

The RMS has developed a road hierarchy for NSW that classifies roads as national highways, state roads, regional roads or local roads. The NSW road hierarchy is described below.

National Highways

National highways are classified as arterial roads and comprise the principal connections between Sydney, Canberra, Melbourne, Adelaide and Brisbane (RTA, pers. comm., 4 May 2005; RTA, 2004).

922539 8A-2 Sulphuric Acid Road Transport Route Evaluation – Segment 1

The Hume Highway is the only national highways within the transport area. The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005). These highways would be used by heavy vehicles within the transport area where possible.

State Roads

State roads are classified as arterial roads and are the principal traffic carrying and linking routes for the movement of people and goods within the urban centres of Sydney, Newcastle, Wollongong and the Central Coast, and throughout NSW (RTA, 2004). State roads are characterised by high flows of general traffic over long distances and have a higher capacity relative to surrounding roads (ibid.).

There are several state roads in the transport area including Old Port Road, Flinders Street, Five Islands Road and M1 Princes Motorway. The RMS prefers heavy vehicles to utilise national highways and state roads (over regional and local roads) wherever possible (RTA, pers. comm., 4 May 2005). Accordingly, these roads would also be used by heavy vehicles within the transport area where possible.

Regional Roads

Regional roads comprise the secondary road network which, in combination with state roads, provide for travel between smaller towns and districts and perform a sub-arterial function within major urban centres (RTA, 2004). The RMS considers regional roads to be suitable for heavy vehicles (RTA, pers. comm., 4 May 2005).

Local Roads

Local roads are generally all other roads other than national highways, state roads and regional roads. The RMS prefers heavy vehicles to avoid local roads where possible (RTA, pers. comm., 4 May 2005).

8A4.1.2 Identification of Truck Routes

In accordance with the Guidelines, truck routes within the transport area were identified following a review of: the NSW road hierarchy; the NSW truck route network; routes used by heavy vehicles within and through the transport area; heavy vehicle bypasses; and travel time.

The NSW road hierarchy is described in Section 8A4.1.1. Arterial and sub-arterial roads (i.e. national highways, state roads and regional roads) should be evaluated for their appropriateness to cater for heavy vehicles (DoP, 2011a). The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005), therefore these roads were used wherever possible when identifying truck routes within the transport area.

The RMS was consulted to determine the NSW truck route network and identify routes used by heavy vehicles within and through the transport area. The use of 14.6 m semi-trailers (prime mover and trailer combined length of 19 m) is legal on all roads in NSW (except where a sign shows a load limit for a particular road, bridge, causeway or ferry) (RTA, 2003). Therefore, for heavy vehicles less than 19 m in length, all roads within NSW (except those signed otherwise) form part of the NSW truck route network.

The RMS has published a map showing B-Double and road train routes (which includes B-doubles) throughout NSW (RMS, 2018). These roads are approved restricted access vehicle routes and are specifically designed to accommodate these heavy vehicles and would therefore accommodate the B-Doubles used to transport sulphuric acid. Designated B-Double and road train routes were used wherever possible when identifying truck routes within the transport area.

922539 8A-3 Sulphuric Acid Road Transport Route Evaluation – Segment 1

In accordance with the Guidelines, travel time was also taken into consideration when identifying truck routes. Generally, an increase in travel distance increases the travel time. This subsequently increases the cost of transport. Therefore, the shortest and most direct route is the most preferable in terms of cost.

8A4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes

Following a review of the road hierarchy and the identification of truck routes within the transport area, Route 1A has been identified as the only potential available route for heavy vehicles for Segment 1. Route 1A is set out in Table 3 and shown on Figure 8-3.

Table 3 Truck Routes

Route 1A only utilises roads that are designated B-Double or road train routes (RMS, 2018). Route 1A is also the shortest and most direct route from Port Kembla to the Hume Highway. Other routes from Port Kembla to the Hume Highway utilising designated B-Double and road train routes could have been identified as truck routes but are significantly longer and were discounted from the route evaluation on the basis of increased travel time.

Route 1A was tested against mandatory and subjective factors. The assessment is set out below in Sections 8A4.2 and 8A4.3.

8A4.2 MANDATORY CONSIDERATIONS

8A4.2.1 Physical Considerations

Physical considerations may preclude a potential transport route from consideration because of weight limitations on bridges, height restrictions on underpasses, inadequate shoulders for breakdowns, extensive construction activities or inadequate parking and turning spaces (DoP, 2011a). Roads designated by the RMS as B-Double or road train routes are considered to be physically capable of accommodating these heavy vehicles. No further assessment of physical capability has been undertaken for these roads.

Route 1A only utilises roads designated as B-Double or road train routes. Therefore, physical considerations do not preclude this transport route from the route evaluation.

In NSW the legislation relevant to the transport of dangerous goods is the NSW Dangerous Goods (Road and Rail) Transport Act, 2008 (the DGT Act), and the NSW Dangerous Goods (Road and Rail) Transport Regulation, 2014 (DGT Regulation). The DGT Act appoints the NSW Environment Protection Authority (EPA) and SafeWork NSW as Competent Authorities to administer the legislation. The EPA regulates the on-road transport of dangerous goods while SafeWork NSW regulates activities prior to transport, including correct classification, packaging and labelling.

922539 8A-4 Sulphuric Acid Road Transport Route Evaluation – Segment 1

Although the above legislation does not include provisions which prohibit the transport of hazardous materials or dangerous goods on certain roads or structures, Part 3, Division 1, Clause 18 of the NSW Road Transport (General) Regulation, 2013 and Rule 300-2 of the NSW Road Rules, 2014 legislation provide dangerous goods must not be transported on or in certain prohibited areas. The potential transport route for Segment 1 proposed to be used to transport sulphuric acid does not involve transport through any of the prohibited areas listed in Rule 300-2 of the NSW Road Rules, 2014.

8A4.2.2 Laws and Regulations

Laws and regulations may prohibit the transport of hazardous materials on certain roads or structures (DoP, 2011a). The Guidelines state that local, state and national transport authorities should be consulted and prohibited roadways eliminated from consideration unless there are no suitable alternative routes (DoP, 2011a).

National Transport Authority

The Australian Government Department of Infrastructure, Regional Development and Cities (DIRDC) website (DIRDC, 2018) advises that:

The Australian states and territories have responsibility for the road and rail transport of dangerous goods in Australia. For technical information on the transport of dangerous goods by road and rail in Australia, please contact the Competent Authority in your state or territory.

The DIRDC lists the EPA as the NSW Competent Authority for Road and Rail Transport (refer sub-section below).

State Transport Authority

NSW EPA

As described above, the EPA regulates the transport of dangerous goods in NSW. The EPA carries out regular audits of dangerous goods transport providers to ensure compliance with legislative requirements.

NSW RMS

As described in Section 8A4.1.2, the RMS has published a RAV map showing B-Double routes throughout NSW (RMS, 2018). These roads are approved RAV routes and are specifically designed to accommodate these heavy vehicles and would therefore accommodate the B-Double’s proposed to be used to transport sulphuric acid. Route 1A is restricted to approved RAV routes. The RMS will be consulted regarding the proposed transport route to confirm the RMS has no objections to the proposed route.

Local Transport Authority

For the purposes of this study, the local transport authority has been defined as the authority accountable for a specified road according to its classification. In NSW, the State Government, through the RMS, manages national highways and state roads and is accountable for the outcomes on these roads (RTA, 2004). Therefore, the RMS is the local transport authority for national highways and state roads. Councils are accountable for regional and local roads (RTA, 2004) and are therefore the local transport authorities for these roads.

Route 1A utilises local roads and state roads, therefore the local transport authorities are the relevant local Councils and the RMS.

922539 8A-5 Sulphuric Acid Road Transport Route Evaluation – Segment 1

The local Councils relevant to Route 1A are the Wollongong and Wollondilly Shire Councils. Outcomes of consultation with Wollongong and Wollondilly Shire Councils will be taken into consideration in this THMS.

Consultation with the Wollongong and Wollondilly Shire Councils and RMS is currently being undertaken to determine if there are any factors which may preclude Route 1A from the route evaluation. This THMS Addenda will be revised if necessary once the consultation is complete.

8A4.3 SUBJECTIVE FACTORS

Subjective factors usually include the proximity of the potential transport route to sensitive landuses (such as hospitals, schools, aged care facilities, churches and items of heritage or cultural significance) (Section 8A4.3.1) and sensitive ecosystems and natural landscapes (such as park reservations and wetlands) (Section 8A4.3.2) (DoP, 2011a). Emergency and evacuation planning and infrastructure are also usually included in the assessment of subjective factors (Section 8A4.3.3) (DoP, 2011a).

8A4.3.1 Landuse

Sensitive Landuses

Sensitive landuses include schools (pre-schools and primary and secondary schools), hospitals, aged care facilities, churches and items of heritage or cultural significance.

Table 4 and the following sections detail sensitive landuses along Route 1A.

Table 4 Sensitive Landuses

Schools Hospitals Items of Aged Care Heritage or Route Churches Number of Number of Number of Number of Facilities Cultural Schools Students Hospitals Beds Significance 1A 5 2,419 0 0 1 0 0

Schools

Vehicles travelling along Route 1A would pass five schools including Mount St Thomas Public School, The Illawarra Grammar School, West Wollongong Pre-School, Gwynneville Public School and St Brigid’s Catholic Parish Primary School.

Hospitals/Aged Care Facilities

There are no hospitals located along Route 1A and the route only passes one aged care facilities.

Churches

No churches are located along Route 1A.

Items of Heritage or Cultural Significance

The NSW State Heritage Inventory was searched for items of heritage or cultural significance located along potential transport routes. No items of heritage or cultural significance are located along Route 1A (NSW Office of Environment and Heritage, 2018).

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8A4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes

Sensitive ecosystems and natural landscapes include park reservations (i.e. national parks, state forests, recreational parks and conservation areas) and waterways (i.e. wetlands, lakes, dams, rivers, creeks and other drainage lines). Sensitive ecosystems and natural landscapes traversed by or occurring along or within approximately 100 m of Route 1A are identified in Table 5 and described in the following sections.

Table 5 Sensitive Ecosystems and Natural Landscapes

Park Reservations Route Approximate Total Road Waterways Number Frontage (m) 1A 2 28,200 31

Park Reservations

Vehicles travelling on Route 1A would pass through the Upper Nepean State Conservation Area and the Illawarra Escarpment State Conservation Area.

To determine if Route 1A is suitable for the transport of hazardous materials, a measure of the quality and size of potentially affected park reservations is required. It was conservatively assumed that all park reservations are of a similar, high quality. The road frontage of park reservations was measured to compare the size of the parks traversed by or occurring along or within approximately 100 m of Route 1A. The approximate total length of road frontage of park reservations for Route 1A is 28,200 m.

Waterways

Vehicles travelling on Route 1A would traverse or come within approximately 100 m of 31 waterways, including Allans Creek, Byarong Creek, American Creek, Rocky Creek, Cataract River, Angel’s Creek and a number of unnamed tributaries.

8A4.3.3 Emergency and Evacuation Planning and Infrastructure

Emergency and evacuation planning and infrastructure includes: the availability of formalised emergency and evacuation procedures and plans; the location of emergency response teams and their ability to respond to hazardous material release; access; and ease of emergency evacuation (DoP, 2011a).

In NSW the management of state emergencies and rescues is controlled under the State Emergency and Rescue Management Act, 1989. The Act sets out strategies for the integration of emergency management at local, district and state levels. The NSW State Emergency Management Committee (SEMC) was established by the State Emergency and Rescue Management Act, 1989 and is responsible for emergency planning at the state level. The SEMC has prepared a NSW State Emergency Management Plan (EMPLAN) that provides a strategic overview to emergency management in NSW (SEMC, 2012).

A Hazardous Materials/Chemicals, Biological, Radiological and Nuclear Emergency Sub Plan (HAZMAT/CBRN PLAN) has been prepared as a sub-plan to the EMPLAN. The HAZMAT/CBRN PLAN details the arrangements relating to an imminent or actual, accidental or deliberate release of a hazardous material in NSW.

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Route 1A falls within the Illawarra South Coast and South West Metro Emergency Management Regions. Each Emergency Management Region is responsible for preparing District or Regional Emergency Management Plans which describe the arrangements at the Regional level to effectively and efficiently prevent, prepare for, respond to and recover from emergencies.

The above approach to emergency management in NSW ensures: the availability of formalised emergency and evacuation procedures and plans (i.e. EMPLAN, HAZMAT/CBRN PLAN, District or Regional Emergency Management Plans); the location of emergency response teams throughout NSW; and the ability of emergency response teams to respond to hazardous material release.

Access and ease of emergency evacuation would be affected by several factors including proximity to emergency services, nature of the hazardous material, availability of alternative routes and road surface (i.e. sealed or unsealed) (RTA, pers. comm., 18 August, 2005). As detailed above, the approach to emergency management in NSW is comprehensive and would ensure that emergency services could access and respond promptly to an incident involving a hazardous material.

In addition, the NSW state and regional road network is extensive and the availability of alternative routes is considered to be adequate. All roads used for the transport of hazardous materials to the Project are sealed, ensuring accessibility and ease of emergency evacuation in the event of an incident.

Following a review of emergency management in NSW, emergency and evacuation planning and infrastructure are considered to be adequate for Route 1A. This route is therefore suitable for the transport of hazardous materials with respect to emergency and evacuation planning and infrastructure.

8A4.3.4 RMS and Transporter Preferred Transport Routes

8A4.4 PRELIMINARY SCREENING FINDINGS

Preliminary screening took into account available roads for heavy vehicles and mandatory and subjective factors (Sections 8A4.1, 8A4.2 and 8A4.3). Following a review of the road hierarchy and the identification of truck routes within the transport area, Route 1A has been identified as the only potential available route for heavy vehicles for Segment 1. Mandatory factors did not preclude this route from the route evaluation.

Table 6 provides a summary of subjective factors outlined in Section 8A4.3 for Route 1A.

Table 6 Summary of Subjective Factors

Assessment Factor Route 1A Schools 5 Number of School Students 2,419 Hospitals # Number of Hospital Beds # Aged Care Facilities 1 Churches #

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Table 6 (Continued) Summary of Subjective Factors

Items of Heritage or Cultural Significance # Other Landuse State Conservation Areas Number of Park Reservations 2 Park Reservations – Approximate Total Road Frontage (m) 28,200 Waterways 31 Emergency Infrastructure Adequate RMS and Transporter Preferred Route Transporter preferred route RMS and local Council preference being confirmed # Sensitive landuses along Route 1A are relatively uncommon and do not preclude this route from the route evaluation. Further information is provided in Section 8A4.3.1. RMS Roads and Maritime Services

Table 6 indicates that Route 1A would have minimal impact on subjective factors and is suitable for the transport of hazardous materials.

8A5 PRELIMINARY LIST OF ROUTES

On the basis of the preliminary screening in Section 8A4, the following preliminary list of routes from Port Kembla to the Hume Highway has been determined (Table 7).

Table 7 Preliminary List of Routes

8A6 SECONDARY SCREENING

Secondary screening involves the assessment of the preliminary list of routes (Section 8A5) against road and traffic factors (Section 8A6.1), emergency response capability (Section 8A6.2), operational factors (Section 8A6.3) and risk (including environmental and landuse factors) (Section 8A6.4) (Figure 8-2). The potential route has been assessed against each secondary screening factor to confirm that the route is suitable for the transport of hazardous materials. The final selection of routes for Segment 1 is detailed in Section 8A7.

8A6.1 ROAD AND TRAFFIC FACTORS

The Guidelines state that the assessment of a potential transport route for suitability on road and traffic grounds will require the collection of particular information (for example road structural condition) to establish the capability and level of service of the road system (DoP, 2011a). The Guidelines offer the following road and traffic factors that consider the ability of a route to effectively and safely handle traffic using it: structural and geometric adequacy; level of service of carriageway and critical intersections; travel speed; accident rates; and the availability of alternative emergency routes.

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The capability of a route to safely and effectively handle the traffic using it is reflected in the accident statistics for that route (Pinnacle Risk Management, pers. comm., 20 July 2005). Accident statistics are influenced by the route’s structural and geometric adequacy, level of service (of carriageway and intersections), and travel speed. It follows then that the structural and geometric adequacy, level of service (of carriageway and intersections), and travel speed are effectively embodied within the accident statistics of the transport route (Pinnacle Risk Management, pers. comm., 20 July 2005). Therefore, it is appropriate to assess accident statistics for potential transport routes and infer from them the capability and level of service of the road system.

Accident statistics for Route 1A are provided in Section 8A6.1.1. An assessment of remaining road and traffic factors (i.e. the availability of alternative emergency routes) is provided in Section 8A6.1.2.

8A6.1.1 Accident Statistics

Available accident statistics for Route 1A were obtained from the RMS and are summarised in Table 8.

Table 8 Summary of Accident Statistics

Heavy Vehicle No. of Heavy % Increase of Heavy Vehicle Annual Million Length Accidents/Annual Route Vehicles Heavy Vehicles Accidents km of Heavy (km) Million km of Heavy (per day)1 due to Project3 (per year)4 Vehicle Travel Vehicle Travel 1A 46.5 2,0162 – 9,4252 0.04% – 0.2% 17.2 34.21 – 159.97 0.11 – 0.50 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 2018 values extrapolated from previous years assuming 1% annual growth rate. 3 Assumes 28 truck movements per week. 4 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016).

Accident statistics for Route 1A are considered to be within normal operating levels for the road type and use. The increase of heavy vehicles due to the Project would be very small (up to approximately 0.2%) and would be unlikely to affect traffic flows or accident statistics. Route 1A is therefore suitable for the transport of hazardous materials with respect to accident statistics.

8A6.1.2 Availability of Alternative Emergency Routes

The NSW state and regional road network is extensive. As a result, there are alternative emergency transport routes that could be used in the event of a temporary closure of Route 1A.

8A6.2 EMERGENCY RESPONSE CAPABILITY

The emergency response capability available for potential routes may include considerations such as the speed of response of emergency services, ease of access to the potential accident site and the availability of emergency combat equipment (DoP, 2011a).

The formalised approach to emergency management in NSW ensures: the availability of emergency combat equipment at a local, district and state level; the location of emergency response teams throughout NSW; and the ability of emergency response teams to respond to hazardous material release (Section 8A4.3.3). Further information on the management of emergencies in NSW and an evaluation of the ease of access to a potential accident for Segment 1 are provided in Section 8A4.3.3.

Following a review of emergency management in NSW, emergency response capability is considered to be adequate for Route 1A. This route is therefore suitable for the transport of hazardous materials with respect to emergency response capability.

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8A6.3 OPERATIONAL FACTORS

Operating costs and distribution logistics have been considered for Segment 1. Route 1A is suitable on the basis of logistical considerations.

The Guidelines (DoP, 2011a) state that the main cost criterion when comparing alternative routes is the expected increase or decrease in distance and travel time if another route is used. Generally, an increase in travel distance increases the travel time and subsequently the cost of transport. Therefore, the shortest route is the most preferable in respect of operating costs. Route 1A is the shortest available route for Segment 1 and is therefore cost effective and suitable on the basis of operating costs.

8A6.4 RISK ASSESSMENT

The Guidelines outline an intermediate risk assessment method that should be undertaken for each potential transport route found to be satisfactory on road and traffic grounds. If the intermediate method does not enable the analyst to identify a clear-cut low risk alternative and differences between potential routes are small then a detailed risk assessment may need to be carried out in accordance with Hazardous Industry Planning and Advisory Paper No. 6, Hazard Analysis (HIPAP No. 6) guidelines (DoP, 2011b).

The risk assessment for Segment 1 has been undertaken in accordance with HIPAP No. 6. HIPAP No. 6 sets out methodology for risk assessment as follows:

1. Hazard identification: the identification of all possible conditions that could lead to a hazardous incident is achieved by evaluating the hazards of the material of interest, the land use adjacent to each potential transport route, the type of transport vehicle to be used, the conditions of the material when being transported and the causes of potential incidents involving heavy vehicles. 2. Consequence Analysis: determined on either a qualitative or quantitative basis depending on the potential hazardous incident outcomes. 3. Estimation of likelihood of a hazardous incident: estimated using available historical traffic data or generic traffic data. 4. Risk analysis. 5. Assessment of risk results.

8A6.4.1 Hazard Identification

8A6.4.1.1 Type of Hazardous Material

Sulphuric acid is classified under the ADG Code as Class 8 (corrosive substance) and Packing Group II. It is a colourless, oily, viscous liquid with a strong pungent odour. It is non flammable but is highly corrosive, toxic and poisonous.

Sulphuric acid is a very powerful oxidiser that is incompatible with materials such as oxidising agents, organics, nitric acid, chlorates, carbides, metals (e.g. sodium, aluminium, potassium) and zinc oxide.

In the presence of water, sulphuric acid is highly corrosive to most metals. Flammable hydrogen gas may evolve upon contact with metals. Toxic sulphur oxides will evolve when the acid is heated to decomposition.

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Although non flammable, sulphuric acid may produce toxic gases when heated by fire (e.g. sulphuric acid mist and sulphur dioxide). If fumes are inhaled, severe irritation to the throat will occur. Over exposure may result in mucous membrane irritation, coughing, bronchitis, ulceration, bloody nose, lung tissue damage, chemical pneumonitis, pulmonary oedema and death. Contact with skin may result in rash, dermatitis, blistering, severe burns and discolouration. In splash accidents involving sulphuric acid, the heat liberated by dilution with water (i.e. from the body) can add thermal burn to the chemical injury caused by the acid itself.

When spilt, sulphuric acid is very slippery.

8A6.4.1.2 Adjacent Landuse

Refer to Section 8A4.3.1 for a description of adjacent landuse for Route 1A.

8A6.4.1.3 Transport Vehicle and Conditions of Transport

Sulphuric acid will be transported to the Project by B-double road tankers. It will be transported as a liquid by bulk tanker. Regulation of temperature and pressure are not required during the transport of this material.

8A6.4.1.4 Causes of Hazardous Incidents

Initiating and contributory causes for incidents involving heavy vehicles has been detailed in Guidelines for Chemical Transportation Risk Analysis (CCPS, 1995). The identified causes, with additional causes included, are reproduced in Table 9.

Table 9 Heavy Vehicle Incidents – Initiating and Contributing Causes

System or Procedural Human Error Equipment Failures External Events Failures  driver impairment,  non-dedicated trailer  driver incentives to  vandalism/sabotage e.g. alcohol or drugs  rail road crossing guard work longer hours  rain  speeding failure  driver training  fog/visibility  driver overtired  leaking valve  carrier selection  wind  driver exceeding safe  leaking fitting  container specification  flood/washout working hours  brake failure  route selection  fire at rest area/parking  en-route inspection  relief device failure  emergency response areas  contamination  tyre failure training  earthquake  overfilling  soft shoulder  speed enforcement  existing accident  other vehicle’s driver  overpressure  driver rest periods  animals on road  taking tight turns/ramps  material defect  maintenance too quickly (overturns)  steering failure  inspection  unsecured loads  sloshing  time of the day restrictions  high centre of gravity  corrosion  bad weld  excessive grade  poor intersection design  road chamber/width  suspension system  tyre fire caused by friction, brakes overheating or exploding tyres give sparks due to metal in the rubber)  fuel tank fire (diesel)

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8A6.4.2 Consequence Analysis

An accident involving a heavy vehicle transporting sulphuric acid resulting in a release of the material is the hazardous incident relevant to the transport of sulphuric acid. The following consequences of an accident involving a heavy vehicle transporting sulphuric acid resulting in a release of the material are relevant:

 direct exposure to acid liquid or mist for people or animals at or near to an accident scene;  contamination of waterways (from a large liquid release) causing acidification of the water resulting in fatality for fish and other aquatic life including aquatic plants;  burning of vegetation upon contact with acid liquid or mist; and  corrosion of metallic structures from acid mist.

Sulphuric acid will remain indefinitely in waterways as a sulphate.

8A6.4.3 Estimation of the Likelihood of a Hazardous Incident

Accident data for heavy vehicles utilising Route 1A are detailed in Section 8A6.1.1 and Table 8. Approximately 17 accidents per year involving heavy vehicles occur for Route 1A.

In the event of an accident involving a heavy vehicle, the carried goods may or may not be released. The probability of release is dependent on factors such as speed, shipping conditions (i.e. pressurised compared to non-pressurised), inadequate load securing, and strength and integrity of the container.

Various studies of release probabilities from heavy vehicles involved in an accident have been undertaken. The Guidelines for Chemical Transportation Risk Analysis (CCPS, 1995) indicates that the release probability for various road types is between 5 and 10% (i.e. approximately one heavy vehicle accident in every 10 to 20 will result in a release of the material).

An estimation of the likelihood of an accident involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material must take into account the following:

 the number of vehicles transporting sulphuric acid to the Project relative to the total number of heavy vehicles already using the same transport route;  the number of accidents that have involved heavy vehicles; and  the probability of a release of the material (which is assumed to be 10% of all accidents involving heavy vehicles results in a release of material) (CCPS, 1995).

The likelihood of an accident involving a vehicle transporting sulphuric acid to the Project resulting in a release of material for Route 1A is estimated to be 5x10-3/year (i.e. such an incident is estimated to occur on Route 1A once every 1,600 years) (Pinnacle Risk Management Pty Ltd, 2018).

The risk of the event is determined using the risk matrix in Table 10 and the consequence ratings in Table 11 (Pinnacle Risk Management Pty Ltd, 2018).

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Table 10 Risk Matrix

Likelihood Frequent II II I I I I >1/yr Probable III II II I I I >10-1 to 1/yr Possible III III II II I I >10-2 to 10-1/yr Unlikely III III III III II I >10-4 to >10-2/yr Very Unlikely III III III III III II >10-6 to 10-4/yr Extremely Unlikely III III III III III III <=10-6/yr Extremely Consequence Minor Significant Severe Serious Catastrophic Serious Source: Pinnacle Risk Management Pty Ltd (2011; 2018) Class I: Indicates a high level of risk which is intolerable and where risk reduction is required. This requires the reduction of frequency and/or consequence. Class II: Indicates a moderate level of risk. Whilst the risk is not unacceptable, there should be practical measures taken to lower the risk if economically viable. For risks where further mitigation is not economically viable, judgement needs to be exercised as to whether the level of risk is acceptable or not. This area is the beginning of the ALARP region (i.e. as low as reasonably practicable). Class III: Indicates a low level of risk and is broadly considered to be acceptable. Further risk mitigation may not be required / appropriate. However, low and accepted risks should be monitored and routinely reviewed to ensure that they remain acceptable. Few risks remain static. This area includes ALARP as well as what are known as trivial or negligible risks.

Table 11 Consequence Ratings

Extremely Minor Significant Severe Serious Catastrophic Serious Safety and One minor Recordable or Multiple Permanent Multiple Multiple Health injury, First Aid single Medical Medical disability permanent fatalities Treatment Treatment casualty or disabilities or Injury Injuries or one multiple Lost one fatality Lost Time Time Injuries Injury Environment Very minor Minor local Evident Significant Major local Extremely pollution. No pollution. pollution, local local pollution. pollution. severe offsite escape Nuisance concern. For example, Observable pollution. of material offsite effect, Minimal waterways offsite effect Ecosystems at (contained typically of duration offsite discoloured (e.g. waterways high risk of within the short duration, effects 10s of metres, discoloured 10s destruction. operational (e.g. noise, (e.g. waterway fire or smoke to 100s of Only resolved areas). Onsite odours, dust slightly affecting metres for a via long term nuisance value and/or visible discoloured, people near to few weeks with solutions only plumes for less turbid etc the site a significant (potentially than one hour) around the number of taking years) point of release aquatic life with no or very adversely few fish killed) affected) Public Minor issue, Local issue, Local media, Regional or Wide media Headlines, Relations one complaint 10 complaints 100 complaints state media national corporate coverage damage Financial < $25,000 $25,000 to > $100,000 to > $1 million to > $20 million to > $100 million Impact $100,000 $1 million $20 million $100 million Source: Pinnacle Risk Management Pty Ltd (2011; 2018)

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For releases of sulphuric acid from a road traffic accident, the consequence rating is determined to be “Serious” (Pinnacle Risk Management Pty Ltd, 2018). The volume is limited to the size of the tanker, i.e. 40 tonnes, and it is possible that only one of the two barrels is breached (Pinnacle Risk Management Pty Ltd, 2018).

Given a likelihood of 5x10-3/year and a consequence rating of “Serious”, the corresponding risk level is Class III (Pinnacle Risk Management Pty Ltd, 2018). These values indicate a low level of risk associated with the transport of hazardous materials (Pinnacle Risk Management Pty Ltd, 2018).

8A6.4.4 Risk Analysis and Assessment of Risk Results

Risk analysis took into account the preliminary screening findings as well as road and traffic factors (Section 8A6.1), emergency response capability (Section 8A6.2) and operational factors (Section 8A6.3). Table 12 provides a summary of all assessment factors utilised in the risk analysis for Route 1A. Table 12 Summary of Risk Analysis Assessment Factors

Assessment Factor Route 1A Schools 5 Number of School Students 2,419 Hospitals # Number of Hospital Beds # Aged Care Facilities 1 Churches # Items of Heritage or Cultural Significance # Other Landuse State Conservation Areas Number of Park Reservations 2 Park Reservations – Approximate Total Road Frontage (m) 28,200 Waterways 31 Emergency Infrastructure Adequate RMS and Transporter Preferred Route Transporter preferred route RMS and local Council preference being confirmed Length (km) 46.5 No. of Heavy Vehicles (per day)1 2,0162 – 9,4252 % Increase of Heavy Vehicles due to Project3 0.04% – 0.2% Heavy Vehicle Accidents (per year)4 17.2 Annual Million km of Heavy Vehicle Travel 34.21 – 159.97 Heavy Vehicle Accidents/Annual Million km of Heavy Vehicle Travel 0.11 – 0.50 Availability of Alternative Emergency Routes Available Emergency Response Capability Adequate Operational Factors Cost effective 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 2018 values extrapolated from previous years assuming 1% annual growth rate. 3 Assumes 28 truck movements per week. 4 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016). # Sensitive landuses along Route 1A are relatively uncommon and do not preclude this route from the route evaluation. Further information is provided in Section 8A4.3.1. RMS Roads and Traffic Authority

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Table 13 presents the results of the risk analysis for Route 1A, in which the consequences and likelihood of potential hazardous events were considered. This risk assessment approach effectively combines the estimated accident frequency with the potential for harm (i.e. risk), making it consistent with the principles and methodologies embodied within Australian Standard (AS) 4360 Risk Management and HIPAP No. 6.

Table 13 presents the results of the risk analysis in terms of minimal, acceptable, significant and unacceptable risk. For the purposes of this risk assessment the following definitions apply:

 minimal risk: the transport of sulphuric acid along Route 1A is assessed as posing a minimal risk to the factor of interest;  acceptable risk: the transport of sulphuric acid along Route 1A is assessed as posing an acceptable amount of risk to the factor of interest;  significant risk: the transport of sulphuric acid along Route 1A is assessed as posing a significant increase of risk to the factor of interest; and  unacceptable risk: the transport of sulphuric acid along Route 1A is assessed as posing an unacceptable level of risk to the factor of interest.

Table 13 Risk Analysis Findings

Assessment Factor Minimal Risk Acceptable Significant Unacceptable Risk Risk Risk Schools  Hospitals  Aged Care Facilities  Churches  Items of Heritage or Cultural Significance  Other Landuse  Park Reservations  Waterways  Emergency Infrastructure  RMS and Transporter Preferred Route  Heavy Vehicle Accidents (per year)  Heavy Vehicle Accidents/Annual Million km of  Heavy Vehicle Travel Availability of Alternative Emergency Routes  Emergency Response Capability  Operational Factors  Comparative Assessment of all Factors  RMS Roads and Maritime Services

There are no defined absolute risk criteria for the transport of hazardous materials throughout NSW, therefore the assessment of risk results is a balanced judgement based on experience in accordance with HIPAP No. 6. Overall, the net increase in the number of heavy vehicles due to the transport of this material would be up to approximately 0.2% (i.e. a minor impact on existing traffic volume). Therefore, there would be only a minor increase in transport risk when compared to existing risk levels. From a risk perspective, the results detailed in Tables 12 and 13 deem Route 1A to pose a minimal level of risk to surrounding people, property and the natural environment. This route is therefore suitable for the transport of hazardous materials to the Project.

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8A7 SELECTION OF ROUTES

The purpose of the Guidelines is to provide guidance on the identification and assessment of transport routes suitable for hazardous materials, based on an integrated approach that accounts for traffic, environmental and landuse safety and economic and other operational factors (DoP, 2011a).

The Guidelines state that the results of the study are generally best presented on a comparative basis. Following the identification of available roads for heavy vehicles in the transport area, there is only one potential available route for heavy vehicles for Segment 1 (Section 8A4.1). Therefore, there is no basis for a comparative assessment. As an alternative to comparative assessment, the potential available route for Segment 1 was assessed against all remaining preliminary and secondary screening factors to confirm that the route is suitable for the transport of hazardous materials to the Project.

Selecting a route that is suitable for the transport of hazardous materials must be a balanced judgement considering each of the factors, since it is not possible to integrate them into a single indicator of acceptability because of their diversity (DoP, 2011a). To make a balanced judgement, preliminary and secondary screening factors have been assessed with respect to the consequences and likelihood of a potential hazardous event occurring (e.g. a heavy vehicle carrying the material of interest being involved in an accident resulting in a release of material).

In accordance with Development Consent Condition 5.4(b)(i), suitable routes identified in this route evaluation for the transport of hazardous materials shall be used except where departures are necessary for local deliveries or emergencies.

Following preliminary and secondary screening, Route 1A has been identified as the only potential available route for heavy vehicles for Segment 1 and is suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). Route 1A is assessed as posing a minimal level of risk to surrounding people, property and the natural environment. Consultation with the RMS and the Wollongong and Wollondilly Shire Councils regarding Route 1A is also being undertaken and their comments will be taken into consideration by this THMS.

Route 1A is the preferred route for the transport of sulphuric acid from Port Kembla to the Hume Highway. Once consultation with the RMS and the Wollongong and Wollondilly Shire Councils is complete, their comments will be taken into consideration to confirm that Route 1A is suitable for the transport of hazardous materials.

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8A8 RISK MANAGEMENT MEASURES

The identification of risk management measures is the final step in the route evaluation process (Figure 8-2). The Guidelines state that the identification of risk management measures should include opportunities for risk reduction where the evaluation shows undesirable levels of risk along the preferred routes, together with consideration of an appropriate safety management system (DoP, 2011a).

The level of risk associated with the transport of sulphuric acid to the Project has been minimised by the selection of suitable transport routes based on an assessment of mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk. Suitable routes identified in this route evaluation for the transport of hazardous materials shall be used in accordance with Consent Condition 5.4(b)(i).

This route evaluation did not identify undesirable levels of risk for the suitable transport route as risk management measures required to be implemented by the material supplier and transport provider are suitable for the hazardous material being transported. Therefore, no additional opportunities for risk the risk reduction are recommended. The risk management measures required to be implemented by the material supplier and transport provider for the transport of sulphuric acid to the Project include:

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- Table 12.1 sets out guidance on the minimum requirements for: the types of personal protective equipment (including self-contained breathing apparatus, SCBA) with which a driver of a road vehicle transporting a placard load of dangerous goods should be provided; and the safety equipment with which a road vehicle used in the transport of a placard load of dangerous goods should be equipped (Clause 12.1.1); - a road vehicle transporting a placard load of dangerous goods must be equipped with a fire extinguisher or fire extinguishers in accordance with Table 12.2; - if a road vehicle transporting dangerous goods is involved in an incident that results in a dangerous situation, the driver of the vehicle must notify the police or fire brigade and prime contractor as soon as possible in accordance with Clause 14.1.1; and - the driver of a vehicle transporting dangerous goods involved in an incident that results in a dangerous situation should also take all safe and practicable steps to carry out any emergency procedures recommended in the emergency information in accordance with Clause 14.1.1.  Drivers transporting dangerous goods by road in bulk are required to be appropriately licensed to drive the vehicle under Part 18 of the DGT Regulation.  Vehicles transporting dangerous goods by road in bulk are required to be licensed to transport the goods under Part 18 of the DGT Regulation.  Those undertaking any task involved in the transport of dangerous goods by road (e.g. driving a vehicle transporting dangerous goods; loading dangerous goods into or onto a vehicle, or into a container to be put in or on a vehicle; unloading dangerous goods) are required to be appropriately instructed and trained under Part 20 of the DGT Regulation.  The prime contractor and driver of a vehicle transporting dangerous goods by road that is involved in an incident resulting in a dangerous situation are required to tell the Competent Authority about the incident and give the Competent Authority a written report about the incident in accordance with Part 14 of the DGT Regulation.  Vehicles transporting hazardous materials to the Project are required to carry appropriate communication devices (such as a radio or telephone).

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8A9 REFERENCES

Centre for Chemical Process Safety (CCPS) (1995) Guidelines for Chemical Transportation Risk Analysis.

Department of Planning (2011a) Hazardous Industry Planning and Advisory Paper No. 11, Route Selection.

Department of Planning (2011b) Hazardous Industry Planning and Advisory Paper No. 6, Hazard Analysis.

NSW Office of Environment and Heritage (2018)

Pinnacle Risk Management Pty Ltd (2011) Matrix Based Risk Assessment.

Pinnacle Risk Management Pty Ltd (2018) Review comments on draft THMS Addenda for Sulphuric Acid provided by Dean Shewring in emails dated 14 June 2018 and 16 July 2018.

Roads and Maritime Services (2018) Restricted Access Vehicle (RAV) map and website link.

Roads and Traffic Authority (RTA) (2003) 14.6 Metre Semi-Trailers. June 2003. Cat No. 45070811B.

Roads and Traffic Authority (RTA) (2004) Information Paper and Invitation for Submissions – NSW Road Classification Review. May 2004.

State Emergency Management Committee (2012) NSW State Emergency Management Plan.

922539 8A-20 Sulphuric Acid Road Transport Route Evaluation – Overview

ATTACHMENT 8B

00927525 2 Evolution Mining (Cowal) Pty Limited

Sulphuric Acid Road Transport Route Evaluation – Segment 2

COWAL GOLD PROJECT TRANSPORT OF HAZARDOUS MATERIALS STUDY

ATTACHMENT 8B

SULPHURIC ACID ROAD TRANSPORT ROUTE EVALUATION

SEGMENT 2 HUME HIGHWAY (SYDNEY) TO TEMORA

JULY 2018 Project No. HAL-02-07 Document No. 922537 Sulphuric Acid Road Transport Route Evaluation – Segment 2

TABLE OF CONTENTS

Section Page

8B1 INTRODUCTION 8B-1 8B2 DEFINITION OF THE TRANSPORT AREA 8B-1 8B3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION 8B-1 8B3.1 IDENTIFICATION OF HAZARDOUS MATERIAL 8B-1 8B3.2 SOURCE AND DESTINATION 8B-2 8B4 PRELIMINARY SCREENING 8B-2 8B4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES 8B-2 8B4.1.1 Road Hierarchy 8B-2 8B4.1.2 Identification of Truck Routes 8B-3 8B4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes 8B-4 8B4.2 MANDATORY CONSIDERATIONS 8B-5 8B4.2.1 Physical Considerations 8B-5 8B4.2.2 Laws and Regulations 8B-5 8B4.3 SUBJECTIVE FACTORS 8B-6 8B4.3.1 Landuse 8B-6 8B4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes 8B-7 8B4.3.3 Emergency and Evacuation Planning and Infrastructure 8B-7 8B4.3.4 RMS and Transporter Preferred Transport Routes 8B-8 8B4.4 PRELIMINARY SCREENING FINDINGS 8B-8 8B5 PRELIMINARY LIST OF ROUTES 8B-9 8B6 SECONDARY SCREENING 8B-9 8B6.1 ROAD AND TRAFFIC FACTORS 8B-10 8B6.1.1 Accident Statistics 8B-10 8B6.1.2 Availability of Alternative Emergency Routes 8B-10 8B6.2 EMERGENCY RESPONSE CAPABILITY 8B-11 8B6.3 OPERATIONAL FACTORS 8B-11 8B6.4 RISK ASSESSMENT 8B-11 8B6.4.1 Hazard Identification 8B-12 8B6.4.2 Consequence Analysis 8B-13 8B6.4.3 Estimation of the Likelihood of a Hazardous Incident 8B-13 8B6.4.4 Risk Analysis and Assessment of Risk Results 8B-15 8B7 SELECTION OF ROUTES 8B-17 8B8 RISK MANAGEMENT MEASURES 8B-18 8B9 REFERENCES 8B-21

922537 8B-i Sulphuric Acid Road Transport Route Evaluation – Segment 2

TABLE OF CONTENTS (continued) LIST OF TABLES

Table 1 Hazardous Material Source and Destination Table 2 Transport Details Table 3 Truck Routes Table 4 Sensitive Ecosystems and Natural Landscapes Table 5 Summary of Subjective Factors Table 6 Preliminary List of Routes Table 7 Summary of Accident Statistics Table 8 Heavy Vehicle Incidents – Initiating and Contributing Causes Table 9 Risk Matrix Table 10 Consequence Ratings Table 11 Summary of Risk Analysis Assessment Factors Table 12 Risk Analysis Findings

922537 8B-ii Sulphuric Acid Road Transport Route Evaluation – Segment 2

8B1 INTRODUCTION

As described in Section 1.2 of the Transport of Hazardous Materials Study (THMS), route evaluation is required for the road transport of sulphuric acid to the Project. Road transport of sulphuric acid within NSW begins at Port Kembla and terminates at the Project. The road transport route for sulphuric acid to the Project has been divided into four segments (Segments 1 to 4) for the purpose of route evaluation.

This attachment sets out the route evaluation for the road transport of sulphuric acid from the Hume Highway (Sydney) to Temora. This part of the overall sulphuric acid road transport route is referred to as Segment 2. Route evaluations for Segments 1, 3, and 4 are attached to the THMS as Attachments 8A, 8C, and 8D, respectively.

Figure 8-2 shows the assessment process flowsheet for this route evaluation.

8B2 DEFINITION OF THE TRANSPORT AREA

The transport area is defined by the Guidelines as follows:

Definition of the transport area is carried out from a traffic perspective. It should include the area over which traffic to or from the development is likely to have a significant effect.

The transport area for Segment 2 is defined as the area between the Hume Highway (Sydney) (within the suburb of Glenfield) and Temora (Figure 8-1).

The transport area is situated within the Local Government Areas (LGAs) of Campbelltown, Wollondilly, Wingecarribee, Greater Argyle (Goulburn Mulwaree), Upper Lachlan, Yass Valley, Harden, Cootamundra and Temora.

8B3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION

8B3.1 IDENTIFICATION OF HAZARDOUS MATERIAL

As described in Section 1.2 of the THMS, identification of hazardous materials for which a route evaluation is required was undertaken prior to the preparation of this route evaluation. This included an assessment of the class of material being transported (i.e. the classification of dangerous goods under the Australian Code for the Transport of Dangerous Goods by Road and Rail 1998 [ADG Code] [National Road Transport Commission, 1998]), the type of container and the movement quantity and frequency. The assessment identified sulphuric acid as a hazardous material for which a route evaluation is required. The DoP concurred with this assessment (as outlined in DoP correspondence dated 14 October 2005).

922537 8B-1 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Sulphuric acid is classified as Class 8 under the ADG Code. Details of the type of container (i.e. packaging) and the movement quantity and frequency are provided in the following section.

8B3.2 SOURCE AND DESTINATION

The source and destination of sulphuric acid for Segment 2 are outlined in Table 1 and shown on Figure 8-1.

Table 1 Hazardous Material Source and Destination

Source: Destination: Hume Highway (Sydney) Temora Location Town/City LGA Location Town/City LGA Hume Highway Burley Griffin Way Sydney Campbelltown Temora Temora (Glenfield) (State Route 94)

Details of the transport of sulphuric acid from the Hume Highway (Sydney) to Temora are provided in Table 2.

Table 2 Transport Details

Hazardous Delivery Maximum Volume per Maximum Frequency Transported Packaging Material Vehicle Delivery of Deliveries State Sulphuric Acid B-Double 40 t 2 per day Liquid Bulk tanker

8B4 PRELIMINARY SCREENING

The following subsections identify available roads for heavy vehicles within the transport area and examine mandatory and subjective factors for potential transport routes. Section 8B5 provides the results of this analysis as a preliminary list of routes. Further screening of this preliminary list is provided in Section 8B6.

8B4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES

The Guidelines require the identification of potential available roads for heavy vehicles to be based on:

 a review of the road hierarchy (Section 8B4.1.1); and  the identification of routes suitable in general for the movement of trucks (Section 8B4.1.2).

Results of the review of the road hierarchy and the identification of routes suitable in general for the movement of trucks are provided in Section 8B4.1.3.

8B4.1.1 Road Hierarchy

The RMS has developed a road hierarchy for NSW that classifies roads as national highways, state roads, regional roads or local roads. The NSW road hierarchy is described below.

922537 8B-2 Sulphuric Acid Road Transport Route Evaluation – Segment 2

National Highways

National highways are classified as arterial roads and comprise the principal connections between Sydney, Canberra, Melbourne, Adelaide and Brisbane (RTA, pers. comm., 4 May 2005; RTA, 2004a).

National highways within the transport area include the Hume Highway. The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005). Therefore, the Hume Highway would be used by heavy vehicles within the transport area where possible.

State Roads

State roads are classified as arterial roads and are the principal traffic carrying and linking routes for the movement of people and goods within the urban centres of Sydney, Newcastle, Wollongong and the Central Coast, and throughout NSW (RTA, 2004a). State roads are characterised by high flows of general traffic over long distances and have a higher capacity relative to surrounding roads (ibid.).

State roads within the transport area include Burley Griffin Way. The RMS prefers heavy vehicles to utilise national highways and state roads (over regional and local roads) wherever possible (RTA, pers. comm., 4 May 2005). Accordingly, Burley Griffin Way would also be used by heavy vehicles within the transport area where possible.

Regional Roads

Regional roads comprise the secondary road network which, in combination with state roads, provide for travel between smaller towns and districts and perform a sub-arterial function within major urban centres (RTA, 2004a). The RMS considers regional roads to be suitable for heavy vehicles (RTA, pers. comm., 4 May 2005).

Local Roads

8B4.1.2 Identification of Truck Routes

The NSW road hierarchy is described in Section 8B4.1.1. Arterial and sub-arterial roads (i.e. national highways, state roads and regional roads) should be evaluated for their appropriateness to cater for heavy vehicles (DoP,2011a). The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005), therefore these roads were used wherever possible when identifying truck routes within the transport area.

The RMS was consulted to determine the NSW truck route network and identify routes used by heavy vehicles within and through the transport area. The use of 14.6 m semi-trailers (prime mover and trailer combined length of 19 m) is legal on all roads in NSW (except where a sign shows a load limit for a particular road, bridge, causeway or ferry) (RTA, 2003a). Therefore, for heavy vehicles less than 19 m in length, all roads within NSW (except those signed otherwise) form part of the NSW truck route network.

922537 8B-3 Sulphuric Acid Road Transport Route Evaluation – Segment 2

The RMS has published a map showing B-Double and road train routes throughout NSW (RMS, 2018). These roads are approved restricted access vehicle routes and are specifically designed to accommodate these heavy vehicles. Designated B-Double and road train routes were used wherever possible when identifying truck routes within the transport area.

The RMS prefers heavy vehicles carrying hazardous materials to avoid travelling over the Blue Mountains and in the vicinity of the World Heritage listed Greater Blue Mountains Area given the sensitive nature of the area (RTA, pers. comm., 2 September 2005). This was taken into consideration when identifying truck routes within the transport area.

Designated heavy vehicle bypasses within the transport area were taken into consideration when identifying truck routes. There were no heavy vehicle bypasses identified within the transport area (RTA, pers. comm., 31 August 2005).

8B4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes

Following a review of the road hierarchy and the identification of truck routes within the transport area, Route 2A has been identified as the only potential available route for heavy vehicles for Segment 2. Route 2A is set out in Table 3 and shown on Figure 8-1.

Table 3 Truck Routes

Route Directions 2A From the Hume Highway (Glenfield), continue on the Highway until Bowning (west of Yass). Turn off the Hume Highway into State Route 94 (Burley Griffin Way) and continue to Temora.

Route 2A only utilises roads that are national highways or state roads (RTA, 2004b) and designated B-Double routes (RTA, 2001). Route 2A is also the shortest and most direct route from Sydney to Temora whilst avoiding travelling over the Blue Mountains and in the vicinity of the World Heritage listed Greater Blue Mountains Area. Other routes from Sydney to West Wyalong utilising national highways and state roads and designated B-Double routes could have been identified as truck routes but are significantly longer and were discounted from the route evaluation on the basis of increased travel time.

Route 2A was tested against mandatory and subjective factors. The assessment is set out below in Sections 8B4.2 and 8B4.3.

922537 8B-4 Sulphuric Acid Road Transport Route Evaluation – Segment 2

8B4.2 MANDATORY CONSIDERATIONS

8B4.2.1 Physical Considerations

Physical considerations may preclude a potential transport route from consideration because of weight limitations on bridges, height restrictions on underpasses, inadequate shoulders for breakdowns, extensive construction activities or inadequate parking and turning spaces (DoP,2011a). Roads designated by the RMS as B-Double or road train routes are considered to be physically capable of accommodating the vehicles that are proposed to be used to transport sulphuric acid. No further assessment of physical capability has been undertaken for these roads.

Although the above legislation does not include provisions which prohibit the transport of hazardous materials or dangerous goods on certain roads or structures, Part 3, Division 1, Clause 18 of the NSW Road Transport (General) Regulation, 2013 and Rule 300-2 of the NSW Road Rules, 2014 legislation provide dangerous goods must not be transported on or in certain prohibited areas. The potential transport route for Segment 2 proposed to be used to transport sulphuric acid does not involve transport through any of the prohibited areas listed in Rule 300-2 of the NSW Road Rules, 2014.

8B4.2.2 Laws and Regulations

Laws and regulations may prohibit the transport of hazardous materials on certain roads or structures (DoP,2011a). The Guidelines state that local, state and national transport authorities should be consulted and prohibited roadways eliminated from consideration unless there are no suitable alternative routes (DoP, 2011a).

National Transport Authority

The Australian Government Department of Infrastructure, Regional Development and Cities (DIRDC) website (DIRDC, 2018) advises that:

The DIRDC lists the EPA as the NSW Competent Authority for Road and Rail Transport (refer sub-section below).

State Transport Authority

NSW EPA

922537 8B-5 Sulphuric Acid Road Transport Route Evaluation – Segment 2

NSW RMS

As described in Section 8A4.1.2, the RMS has published a RAV map showing B-Double routes throughout NSW (RMS, 2018). These roads are approved RAV routes and are specifically designed to accommodate these heavy vehicles and would therefore accommodate the B-Double’s proposed to be used to transport sulphuric acid. Route 2A is restricted to approved RAV routes. The RMS will be consulted regarding the proposed transport route to confirm the RMS has no objections to the proposed route.

Local Transport Authority

For the purposes of this study, the local transport authority has been defined as the authority accountable for a specified road according to its classification. In NSW, the State Government, through the RMS, manages national highways and state roads and is accountable for the outcomes on these roads (RTA, 2004a). Therefore, the RMS is the local transport authority for national highways and state roads. Councils are accountable for regional and local roads (RTA, 2004a) and are therefore the local transport authorities for these roads.

Route 2A only utilises the Hume Highway (a national highway) and Burley Griffin Way (a state road), therefore the local transport authority is the RMS. As stated above, the RMS has prohibited the carriage of hazardous materials on a number of routes under the Road Transport (Safety and Traffic Management) (Road Rules) Regulation 1999.

Laws and regulations do not preclude Route 2A from the route evaluation.

8B4.3 SUBJECTIVE FACTORS

Subjective factors usually include the proximity of the potential transport route to sensitive landuses (such as hospitals, schools, aged care facilities, churches and items of heritage or cultural significance) (Section 8B4.3.1) and sensitive ecosystems and natural landscapes (such as park reservations and wetlands) (Section 8B4.3.2) (DoP,2011a). Emergency and evacuation planning and infrastructure are also usually included in the assessment of subjective factors (Section 8B4.3.3) (DoP,2011a).

8B4.3.1 Landuse

Sensitive Landuses

Sensitive landuses include schools (pre-schools and primary and secondary schools), hospitals, aged care facilities, churches and items of heritage or cultural significance.

Route 2A predominantly passes through rural areas comprising of areas of open space. Sensitive landuses (e.g. the primary school and early childhood day care centre located in the Harden LGA) are relatively uncommon along Route 2A and do not preclude it from the route evaluation. Therefore, further detailed consideration of sensitive landuses was not undertaken for this route evaluation.

Other Landuses

Other landuses may include residential, commercial or industrial areas and areas of open space. Route 2A predominantly passes through rural areas comprising areas of open space.

922537 8B-6 Sulphuric Acid Road Transport Route Evaluation – Segment 2

8B4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes

Sensitive ecosystems and natural landscapes include park reservations (i.e. national parks, state forests, recreational parks and conservation areas) and waterways (i.e. wetlands, lakes, dams, rivers, creeks and other drainage lines). Sensitive ecosystems and natural landscapes traversed by or occurring along or within approximately 100 m of Route 2A are identified in Table 4 and described in the following sections.

Table 4 Sensitive Ecosystems and Natural Landscapes

Park Reservations Route Approximate Total Road Waterways Number Frontage (m) 2A 4 8,125 9

Park Reservations

Vehicles travelling on Route 2A would pass within approximately 100 m of four park reservations, including Penrose State Forest, Mundoonen State Forest and Jindalee State Forest.

To determine if Route 2A is suitable for the transport of hazardous materials, a measure of the quality and size of potentially affected park reservations is required. It was conservatively assumed that all park reservations are of a similar, high quality. The road frontage of park reservations was measured to compare the size of the parks traversed by or occurring along or within approximately 100 m of Route 2A. The approximate total length of road frontage of park reservations for Route 2A is 8,125 m.

Waterways

Vehicles travelling on Route 2A would traverse or come within approximately 100 m of nine waterways, including the Lachlan River, Muttama Creek and Bland Creek.

8B4.3.3 Emergency and Evacuation Planning and Infrastructure

922537 8B-7 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Route 2A falls within the Riverina, South Eastern and South West Metro Emergency Management Regions. Each Emergency Management Region is responsible for preparing District or Regional Emergency Management Plans which describe the arrangements at the Regional level to effectively and efficiently prevent, prepare for, respond to and recover from emergencies.

Following a review of emergency management in NSW, emergency and evacuation planning and infrastructure are considered to be adequate for Route 2A. This route is therefore suitable for the transport of hazardous materials with respect to emergency and evacuation planning and infrastructure.

8B4.3.4 RMS and Transporter Preferred Transport Routes

The RMS, an authority which maintains the majority of the road system (i.e. national highways and state roads) and which acts as an advisory body to Councils, is being consulted to determine the RMS’s preferred route for the transport of hazardous materials from the Hume Highway (Sydney) to Temora. Route 2A is the route preferred by the RMS and for the transport of hazardous materials from the Hume Highway (Sydney) to Temora (RTA, pers. comm., 20 July 2005, 26 July 2005 and 2 September 2005).

8B4.4 PRELIMINARY SCREENING FINDINGS

Preliminary screening took into account available roads for heavy vehicles and mandatory and subjective factors (Sections 8B4.1, 8B4.2 and 8B4.3). Following a review of the road hierarchy and the identification of truck routes within the transport area, Route 2A has been identified as the only potential available route for heavy vehicles for Segment 2. Mandatory factors did not preclude this route from the route evaluation.

Table 5 provides a summary of subjective factors outlined in Section 8B4.3 for Route 2A.

922537 8B-8 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Table 5 Summary of Subjective Factors

Table 5 indicates that Route 2A would have minimal impact on subjective factors and is suitable for the transport of hazardous materials.

8B5 PRELIMINARY LIST OF ROUTES

On the basis of the preliminary screening in Section 8B4, the following preliminary list of routes from the Hume Highway (Sydney) to Temora has been determined (Table 6).

Table 6 Preliminary List of Routes

Route Directions 2A From the Hume Highway (Glenfield), continue on the Highway until Bowning (west of Yass). Turn off the Hume Highway into State Route 94 (Burley Griffin Way) and continue to Temora.

8B6 SECONDARY SCREENING

Secondary screening involves the assessment of the preliminary list of routes (Section 8B5) against road and traffic factors (Section 8B6.1), emergency response capability (Section 8B6.2), operational factors (Section 8B6.3) and risk (including environmental and landuse factors) (Section 8B6.4) (Figure 8-2). The potential route has been assessed against each secondary screening factor to confirm that the route is suitable for the transport of hazardous materials. The final selection of routes for Segment 2 is detailed in Section 8B7.

922537 8B-9 Sulphuric Acid Road Transport Route Evaluation – Segment 2

8B6.1 ROAD AND TRAFFIC FACTORS

It follows then that the structural and geometric adequacy, level of service (of carriageway and intersections), and travel speed are effectively embodied within the accident statistics of the transport route (Pinnacle Risk Management, pers. comm., 20 July 2005). Therefore, it is appropriate to assess accident statistics for potential transport routes and infer from them the capability and level of service of the road system.

Accident statistics for Route 2A are provided in Section 8B6.1.1. An assessment of remaining road and traffic factors (i.e. the availability of alternative emergency routes) is provided in Section 8B6.1.2.

8B6.1.1 Accident Statistics

Available accident statistics for Route 2A were obtained from the RMS and are summarised in Table 7.

Table 7 Summary of Accident Statistics

Heavy Vehicle No. of Heavy % Increase of Heavy Vehicle Annual Million Length Accidents/Annual Route Vehicles Heavy Vehicles Accidents km of Heavy (km) 1 4 5 Million km of Heavy (per day) due to Project (per year) Vehicle Travel Vehicle Travel 2A 381.5 1662 – 7,0282,3 0.05% – 2.5% 61.8 23.07 – 978.57 0.06 – 2.68 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 2018 values extrapolated from previous years assuming 1% annual growth rate. 3 Only one-way traffic count available. Assumed equal HV counts for both traffic direction. 4 Assumes 28 truck movement per week. 5 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016).

Accident statistics for Route 2A are considered to be within normal operating levels for the road type and use. The increase of heavy vehicles due to the Project would be very small (up to approximately 2.5%) and would be unlikely to affect traffic flows or accident statistics. Route 2A is therefore suitable for the transport of hazardous materials with respect to accident statistics.

8B6.1.2 Availability of Alternative Emergency Routes

The NSW state and regional road network is extensive. As a result, there are alternative emergency transport routes that could be used in the event of a temporary closure of Route 2A.

922537 8B-10 Sulphuric Acid Road Transport Route Evaluation – Segment 2

8B6.2 EMERGENCY RESPONSE CAPABILITY

The formalised approach to emergency management in NSW ensures: the availability of emergency combat equipment at a local, district and state level; the location of emergency response teams throughout NSW; and the ability of emergency response teams to respond to hazardous material release (Section 8B4.3.3). Further information on the management of emergencies in NSW and an evaluation of the ease of access to a potential accident for Segment 2 are provided in Section 8B4.3.3.

Following a review of emergency management in NSW, emergency response capability is considered to be adequate for Route 2A. This route is therefore suitable for the transport of hazardous materials with respect to emergency response capability.

8B6.3 OPERATIONAL FACTORS

Operating costs and distribution logistics have been considered for Segment 2. Route 2A is suitable on the basis of logistical considerations.

The Guidelines (DoP, 2011a) state that the main cost criterion when comparing alternative routes is the expected increase or decrease in distance and travel time if another route is used. Generally, an increase in travel distance increases the travel time and subsequently the cost of transport. Therefore, the shortest route is the most preferable, in respect of operating costs. Route 2A is the shortest available route for Segment 2 and is therefore cost effective and suitable on the basis of operating costs.

8B6.4 RISK ASSESSMENT

The risk assessment for Segment 2 has been undertaken in accordance with HIPAP No. 6. HIPAP No. 6 sets out methodology for risk assessment as follows:

922537 8B-11 Sulphuric Acid Road Transport Route Evaluation – Segment 2

8B6.4.1 Hazard Identification

8B6.4.1.1 Type of Hazardous Material

8B6.4.1.2 Adjacent Landuse

Refer to Section 8B4.3.1 for a description of adjacent landuse for Route 2A.

8B6.4.1.3 Transport Vehicle and Conditions of Transport

8B6.4.1.4 Causes of Hazardous Incidents

922537 8B-12 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Table 8 Heavy Vehicle Incidents – Initiating and Contributing Causes

Human Error Equipment Failures System or Procedural External Events Failures  driver impairment,  non-dedicated trailer  driver incentives to  vandalism/sabotage e.g. alcohol or drugs  rail road crossing guard work longer hours  rain  speeding failure  driver training  fog/visibility  driver overtired  leaking valve  carrier selection  wind  driver exceeding safe  leaking fitting  container specification  flood/washout working hours  brake failure  route selection  fire at rest area/parking  en-route inspection  relief device failure  emergency response areas  contamination  tyre failure training  earthquake  overfilling  soft shoulder  speed enforcement  existing accident  other vehicle’s driver  overpressure  driver rest periods  animals on road  taking tight turns/ramps  material defect  maintenance too quickly (overturns)  vacuum  inspection  unsecured loads  steering failure  time of the day restrictions  sloshing  high centre of gravity  corrosion  bad weld  excessive grade  poor intersection design  road chamber/width  suspension system  tyre fire caused by friction, brakes overheating or exploding tyres give sparks due to metal in the rubber)  fuel tank fire (diesel)

8B6.4.2 Consequence Analysis

Sulphuric acid will remain indefinitely in waterways as a sulphate.

8B6.4.3 Estimation of the Likelihood of a Hazardous Incident

Accident data for heavy vehicles utilising Route 2A are detailed in Section 8B6.1.1 and Table 7. Approximately 62 accidents per year involving heavy vehicles occur on Route 2A.

922537 8B-13 Sulphuric Acid Road Transport Route Evaluation – Segment 2

An estimation of the likelihood of an accident involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material must take into account the following:

The likelihood of an accident (based on averaged accident data) involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material for Route 2A is estimated to be 3x10-3/year (i.e. such an incident is estimated to occur on Route 2A once every 290 years) (Pinnacle Risk Management Pty Ltd, 2018).

The risk of the event is determined using the risk matrix in Table 9 and the consequence ratings in Table 10 (Pinnacle Risk Management Pty Ltd, 2018).

Table 9 Risk Matrix

Likelihood Frequent II II I I I I >1/yr Probable III II II I I I >10-1 to 1/yr Possible -2 -1 III III II II I I >10 to 10 /yr Unlikely -4 -2 III III III III II I >10 to >10 /yr Very Unlikely III III III III III II >10-6 to 10-4/yr Extremely Unlikely III III III III III III <=10-6/yr Extremely Consequence Minor Significant Severe Serious Catastrophic Serious Source: Pinnacle Risk Management Pty Ltd (2011; 2018) Class I: Indicates a high level of risk which is intolerable and where risk reduction is required. This requires the reduction of frequency and/or consequence. Class II: Indicates a moderate level of risk. Whilst the risk is not unacceptable, there should be practical measures taken to lower the risk if economically viable. For risks where further mitigation is not economically viable, judgement needs to be exercised as to whether the level of risk is acceptable or not. This area is the beginning of the ALARP region (i.e. as low as reasonably practicable). Class III: Indicates a low level of risk and is broadly considered to be acceptable. Further risk mitigation may not be required / appropriate. However, low and accepted risks should be monitored and routinely reviewed to ensure that they remain acceptable. Few risks remain static. This area includes ALARP as well as what are known as trivial or negligible risks.

922537 8B-14 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Table 10 Consequence Ratings

Extremely Minor Significant Severe Serious Catastrophic Serious Safety and One minor Recordable or Multiple Permanent Multiple Multiple Health injury, First Aid single Medical Medical disability permanent fatalities Treatment Treatment casualty or disabilities or Injury Injuries or one multiple Lost one fatality Lost Time Time Injuries Injury Environment Very minor Minor local Evident Significant local Major local Extremely pollution. No pollution. pollution, local pollution. For pollution. severe offsite escape Nuisance concern. example, Observable pollution. of material offsite effect, Minimal waterways offsite effect Ecosystems at (contained typically of duration offsite discoloured (e.g. waterways high risk of within the short duration, effects 10s of metres, discoloured 10s destruction. operational e.g. noise, (e.g. waterway fire or smoke to 100s of Only resolved areas). Onsite odours, dust slightly affecting metres for a via long term nuisance value and/or visible discoloured, people near to few weeks with solutions only plumes for less turbid etc the site a significant (potentially than one hour around the number of taking years) point of release aquatic life with no or very adversely few fish killed) affected) Public Minor issue, Local issue, 10 Local media, Regional or Wide media Headlines, Relations one complaint complaints 100 complaints state media national corporate coverage damage Financial < $25,000 $25,000 to > $100,000 to > $1 million to > $20 million to > $100 million Impact $100,000 $1 million $20 million $100 million Source: Pinnacle Risk Management Pty Ltd (2011; 2018)

Given a likelihood of 3x10-3/year and a consequence rating of “Serious”, the corresponding risk level is Class III (Pinnacle Risk Management Pty Ltd, 2018). These values indicate a low level of risk associated with the transport of hazardous materials (Pinnacle Risk Management Pty Ltd, 2018).

8B6.4.4 Risk Analysis and Assessment of Risk Results

Risk analysis took into account the preliminary screening findings as well as road and traffic factors (Section 8B6.1), emergency response capability (Section 8B6.2) and operational factors (Section 8B6.3). Table 11 provides a summary of all assessment factors utilised in the risk analysis for Route 2A.

922537 8B-15 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Table 11 Summary of Risk Analysis Assessment Factors

Assessment Factor Route 2A Schools # Number of School Students # Hospitals # Number of Hospital Beds # Aged Care Facilities # Churches # Items of Heritage or Cultural Significance # Other Landuse # Number of Park Reservations 4 Park Reservations – Approximate Total Road Frontage (m) 8,125 Waterways 9 Emergency Infrastructure Adequate RMS and Transporter Preferred Route RTA and Transporter preferred route Length (km) 381.5 No. of Heavy Vehicles (per day)1 1662 – 7,0282,3 % Increase of Heavy Vehicles due to Project4 0.05% – 2.5% Heavy Vehicle Accidents (per year)5 61.8 Annual Million km of Heavy Vehicle Travel 23.07 – 978.57 Heavy Vehicle Accidents/Annual Million km of Heavy Vehicle Travel 0.06 – 2.68 Availability of Alternative Emergency Routes Available Emergency Response Capability Adequate Operational Factors Cost effective 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 2018 values extrapolated from previous years assuming 1% annual growth rate. 3 Only one-way traffic count available. Assumed equal HV counts for both traffic direction. 4 Assumes 28 truck movement per week. 5 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016). # Sensitive landuses along Route 2A are relatively uncommon and do not preclude this route from the route evaluation. Further information is provided in Section 8B4.3.1. RMS Roads and Traffic Authority ).

Table 12 presents the results of the risk analysis for Route 2A in which the consequences and likelihood of potential hazardous events were considered. This risk assessment approach effectively combines the estimated accident frequency with the potential for harm (i.e. risk), making it consistent with the principles and methodologies embodied within Australian Standard (AS) 4360 Risk Management and HIPAP No. 6.

Table 12 presents the results of the risk analysis in terms of minimal, acceptable, significant and unacceptable risk. For the purposes of this risk assessment the following definitions apply:

 minimal risk: the transport of sulphuric acid along Route 2A is assessed as posing a minimal risk to the factor of interest;  acceptable risk: the transport of sulphuric acid along Route 2A is assessed as posing an acceptable amount of risk to the factor of interest;  significant risk: the transport of sulphuric acid along Route 2A is assessed as posing a significant increase of risk to the factor of interest; and  unacceptable risk: the transport of sulphuric acid along Route 2A is assessed as posing an unacceptable level of risk to the factor of interest.

922537 8B-16 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Table 12 Risk Analysis Findings

Acceptable Unacceptable Assessment Factor Minimal Risk Significant Risk Risk Risk Schools  Hospitals  Aged Care Facilities  Churches  Items of Heritage or Cultural Significance  Other Landuse  Park Reservations  Waterways  Emergency Infrastructure  RTA and Transporter Preferred Route  Heavy Vehicle Accidents (per year)  Heavy Vehicle Accidents/Annual Million km of  Heavy Vehicle Travel Availability of Alternative Emergency Routes  Emergency Response Capability  Operational Factors  Comparative Assessment of all Factors  RMS Roads and Traffic Authority .

There are no defined absolute risk criteria for the transport of hazardous materials throughout NSW, therefore the assessment of risk results is a balanced judgement based on experience in accordance with HIPAP No. 6. Overall, the net increase in the number of heavy vehicles due to the transport of this material would be up to approximately 2.5% (i.e. a minor impact on existing traffic volume). Therefore, there would be only a minor increase in transport risk when compared to existing risk levels. From a risk perspective, the results detailed in Tables 11 and 12 deem Route 2A to pose a minimal level of risk to surrounding people, property and the natural environment. This route is therefore suitable for the transport of hazardous materials to the Project.

8B7 SELECTION OF ROUTES

The Guidelines state that the results of the study are generally best presented on a comparative basis. Following the identification of available roads for heavy vehicles in the transport area, there is only one potential available route for heavy vehicles for Segment 2 (Section 8B4.1). Therefore, there is no basis for a comparative assessment. As an alternative to comparative assessment, the potential available route for Segment 2 was assessed against all remaining preliminary and secondary screening factors to confirm that the route is suitable for the transport of hazardous materials to the Project.

922537 8B-17 Sulphuric Acid Road Transport Route Evaluation – Segment 2

In order to make a balanced judgement, consultation with Councils was also undertaken. The transport area for Segment 2 is situated within the Campbelltown, Wollondilly, Wingecarribee, Greater Argyle (Goulburn Mulwaree), Upper Lachlan, Yass Valley, Harden, Cootamundra and Temora LGAs. These Councils were consulted during the preparation of the THMS.

Following preliminary and secondary screening, Route 2A has been identified as the only potential available route for heavy vehicles for Segment 2 and is suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). Route 2A is assessed as posing a minimal level of risk to surrounding people, property and the natural environment. Consultation with the RMS and relevant Councils regarding Route 2A is also being undertaken and their comments will be taken into consideration by the THMS.

Route 2A is the preferred route for the transport of sulphuric acid from the Hume Highway (Sydney) to Temora. Once consultation with the RMS and the relevant Shire Councils is complete, their comments will be taken into consideration to confirm that Route 2A is suitable for the transport of hazardous materials.

8B8 RISK MANAGEMENT MEASURES

The identification of risk management measures is the final step in the route evaluation process (Figure 8-1). The Guidelines state that the identification of risk management measures should include opportunities for risk reduction where the evaluation shows undesirable levels of risk along the preferred routes, together with consideration of an appropriate safety management system (DoP, 2011a).

922537 8B-18 Sulphuric Acid Road Transport Route Evaluation – Segment 2

- a bulk container (other than a pressure vessel that is referred to in Clause 4.8.1) that forms part of, or is attached to, a road vehicle must be hydraulically tested and visually inspected in accordance with Clause 4.8.2; - a bulk container which is transported on a vehicle must be: securely fastened to the vehicle or contained within the periphery of the vehicle so as to prevent movement during transport, and so as to provide adequate external support (Clause 4.9.1); - a bulk container, other than multi-compartment tank, that contains dangerous goods in bulk must be placarded with Emergency Information Panels (Clause 7.5.1); - a road vehicle transporting dangerous goods in bulk having the same UN Number but no packaged dangerous goods must be placarded with: a class label for the goods; and any subsidiary risk label that is applicable to the goods; and Emergency Information Panels (Clause 7.6.2); - a vehicle used to transport dangerous goods: must be suitable for transporting the goods; and must be free of any defect that is likely to create a risk in transporting the goods (Clause 8.1.1); - a road vehicle that is transporting a placard load of dangerous goods must be covered by a policy of insurance or other form of indemnity in accordance with Clause 8.1.2; - dangerous goods must not be transported on the same vehicle with incompatible goods unless the dangerous goods and the incompatible goods: are segregated in accordance with the ADG Code; or are otherwise allowed under the ADG Code to be transported together, in accordance with Clause 9.1.1; - an emergency information holder must be securely placed on a road vehicle in accordance with Clause 11.2.4; - Table 12.1 sets out guidance on the minimum requirements for: the types of personal protective equipment (including self-contained breathing apparatus, SCBA) with which a driver of a road vehicle transporting a placard load of dangerous goods should be provided; and the safety equipment with which a road vehicle used in the transport of a placard load of dangerous goods should be equipped (Clause 12.1.1); - a road vehicle transporting a placard load of dangerous goods must be equipped with a fire extinguisher or fire extinguishers in accordance with Table 12.2; - if a road vehicle transporting dangerous goods is involved in an incident that results in a dangerous situation, the driver of the vehicle must notify the police or fire brigade and prime contractor as soon as possible in accordance with Clause 14.1.1; and - the driver of a vehicle transporting dangerous goods involved in an incident that results in a dangerous situation should also take all safe and practicable steps to carry out any emergency procedures recommended in the emergency information in accordance with Clause 14.1.1.  Drivers transporting dangerous goods by road in bulk are required to be appropriately licensed to drive the vehicle under Part 18 of the DGT Regulation  Vehicles transporting dangerous goods by road in bulk are required to be licensed to transport the goods under Part 18 of the DGT Regulation.  Those undertaking any task involved in the transport of dangerous goods by road (e.g. driving a vehicle transporting dangerous goods; loading dangerous goods into or onto a vehicle, or into a container to be put in or on a vehicle; unloading dangerous goods) are required to be appropriately instructed and trained under Part 20 of the DGT Regulation.  The prime contractor and driver of a vehicle transporting dangerous goods by road that is involved in an incident resulting in a dangerous situation are required to tell the Competent

922537 8B-19 Sulphuric Acid Road Transport Route Evaluation – Segment 2

Authority about the incident and give the Competent Authority a written report about the incident in accordance with Part 14 of the DGT Regulation.  Vehicles transporting hazardous materials to the Project are required to carry appropriate communication devices (such as a radio or telephone).

922537 8B-20 Sulphuric Acid Road Transport Route Evaluation – Segment 2

8B9 REFERENCES

Centre for Chemical Process Safety (CCPS) (1995) Guidelines for Chemical Transportation Risk Analysis.

Department of Planning (2011a) Hazardous Industry Planning and Advisory Paper No. 11, Route Selection.

Department of Planning (2011b) Hazardous Industry Planning and Advisory Paper No. 6, Hazard Analysis.

National Road Transport Commission (1998) Australian Code for the Transport of Dangerous Goods by Road and Rail (ADG Code), Sixth Edition. Prepared by the National Road Transport Commission in conjunction with the Advisory Committee on the Transport of Dangerous Goods and the Federal Office of Road Safety.

Pinnacle Risk Management Pty Ltd (2011) Matrix Based Risk Assessment.

Pinnacle Risk Management Pty Ltd (2018) Review comments on draft THMS Addenda for Sulphuric Acid provided by Dean Shewring in emails dated 14 June 2018 and 16 July 2018.

Roads and Maritime Services (2018) Restricted Access Vehicle (RAV) map and website link.

Roads and Traffic Authority (RTA) (2003a) 14.6 Metre Semi-Trailers. June 2003. Cat No. 45070811B.

Roads and Traffic Authority (RTA) (2004a) Information Paper and Invitation for Submissions – NSW Road Classification Review. May 2004.

Roads and Traffic Authority (RTA) (2004b) NSW State and Regional Road Network. Map prepared by P Gibbons RNIM.

State Emergency Management Committee (2012) NSW State Emergency Management Plan.

922537 8B-21 Sulphuric Acid Road Transport Route Evaluation – Overview

ATTACHMENT 8C

00927525 3 Evolution Mining (Cowal) Pty Limited

Sulphuric Acid Road Transport Route Evaluation – Segment 3

COWAL GOLD PROJECT TRANSPORT OF HAZARDOUS MATERIALS STUDY

ATTACHMENT 8C

SULPHURIC ACID ROAD TRANSPORT ROUTE EVALUATION

SEGMENT 3 TEMORA TO WEST WYALONG

JULY 2018 Project No. HAL-02-07 ID: 922538 Sulphuric Acid Road Transport Route Evaluation – Segment 3

TABLE OF CONTENTS

Section Page

8C1 INTRODUCTION 8C-1

8C2 DEFINITION OF THE TRANSPORT AREA 8C-1

8C3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION 8C-1 8C3.1 IDENTIFICATION OF HAZARDOUS MATERIAL 8C-1 8C3.2 SOURCE AND DESTINATION 8C-2 8C4 PRELIMINARY SCREENING 8C-2 8C4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES 8C-2 8C4.1.1 Road Hierarchy 8C-2 8C4.1.2 Identification of Truck Routes 8C-3 8C4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes 8C-4 8C4.2 MANDATORY CONSIDERATIONS 8C-4 8C4.2.1 Physical Considerations 8C-4 8C4.2.2 Laws and Regulations 8C-5 8C4.3 SUBJECTIVE FACTORS 8C-6 8C4.3.1 Landuse 8C-6 8C4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes 8C-6 8C4.3.3 Emergency and Evacuation Planning and Infrastructure 8C-7 8C4.3.4 RMS and Transporter Preferred Transport Routes 8C-8 8C4.4 PRELIMINARY SCREENING FINDINGS 8C-8 8C5 PRELIMINARY LIST OF ROUTES 8C-10

8C6 SECONDARY SCREENING 8C-10 8C6.1 ROAD AND TRAFFIC FACTORS 8C-10 8C6.1.1 Accident Statistics 8C-11 8C6.1.2 Availability of Alternative Emergency Routes 8C-11 8C6.2 EMERGENCY RESPONSE CAPABILITY 8C-11 8C6.3 OPERATIONAL FACTORS 8C-12 8C6.4 RISK ASSESSMENT 8C-12 8C6.4.1 Hazard Identification 8C-12 8C6.4.2 Consequence Analysis 8C-14 8C6.4.3 Estimation of the Likelihood of a Hazardous Incident 8C-14 8C6.4.4 Risk Analysis and Assessment of Risk Results 8C-16 8C7 SELECTION OF ROUTES 8C-18

8C8 RISK MANAGEMENT MEASURES 8C-19

8C9 REFERENCES 8C-22

920768 8C-i Sulphuric Acid Road Transport Route Evaluation – Segment 3

TABLE OF CONTENTS (continued)

LIST OF TABLES

Table 1 Hazardous Material Source and Destination Table 2 Transport Details Table 3 Truck Routes Table 4 Sensitive Ecosystems and Natural Landscapes Table 5 Summary of Subjective Factors Table 6 Preliminary Screening Findings Table 7 Preliminary List of Routes Table 8 Summary of Accident Statistics Table 9 Heavy Vehicle Incidents – Initiating and Contributing Causes Table 10 Risk Matrix Table 11 Consequence Ratings Table 12 Summary of Risk Analysis Assessment Factors Table 13 Risk Analysis Findings

922538 8C-ii Sulphuric Acid Road Transport Route Evaluation – Segment 3

8C1 INTRODUCTION

As described in Section 1.2 of the Transport of Hazardous Materials Study (THMS), route evaluation is required for the road transport of sulphuric acid to the Project. Road transport of sulphuric acid within NSW begins at Port Kembla and terminates at the Project. The road transport route for sulphuric acid to the Project has been divided into four segments (Segments 1 to 4) for the purpose of route evaluation.

This attachment sets out the route evaluation for the road transport of sulphuric acid from Temora to West Wyalong. This part of the overall sulphuric acid road transport route is referred to as Segment 3. Route evaluations for Segments 1, 2 and 4 are attached to the THMS as Attachments 8A, 8B and 8D, respectively.

Figure 8-2 shows the assessment process flowsheet for this route evaluation.

8C2 DEFINITION OF THE TRANSPORT AREA

The transport area is defined by the Guidelines as follows:

Definition of the transport area is carried out from a traffic perspective. It should include the area over which traffic to or from the development is likely to have a significant effect.

The transport area for Segment 3 is defined as the area between the Burley Griffin Way (State Route 94) (Temora) and the Newell Highway/Mid Western Highway (West Wyalong) (Figure 8-1). The transport area is situated within the Temora, Coolamon and Bland Local Government Areas (LGAs) which are located in the Central West Statistical Division.

8C3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION

8C3.1 IDENTIFICATION OF HAZARDOUS MATERIAL

As described in Section 1.2 of the THMS, identification of hazardous materials for which a route evaluation is required was undertaken prior to the preparation of this route evaluation. This included an assessment of the class of material being transported (i.e. the classification of dangerous goods under the Australian Code for the Transport of Dangerous Goods by Road and Rail 1998 [ADG Code] [National Road Transport Commission, 1998]), the type of container and the movement quantity and frequency. The assessment identified sulphuric acid as a hazardous material for which a route evaluation is required. The DoP concurred with this assessment (as outlined in DoP correspondence dated 14 October 2005).

Sulphuric acid is classified as Class 8 under the ADG Code. Details of the type of container (i.e. packaging) and the movement quantity and frequency are provided in the following section.

922538 8C-1 Sulphuric Acid Road Transport Route Evaluation – Segment 3

8C3.2 SOURCE AND DESTINATION

The source and destination of sulphuric acid for Segment 3 are outlined in Table 1 and shown on Figure 8-1.

Table 1 Hazardous Material Source and Destination

Source: Destination: Temora West Wyalong Location Town/City LGA Location Town/City LGA Burley Griffin Newell Highway/ Way (State Temora Temora Mid Western West Wyalong Bland Route 94) Highway

Details of the transport of sulphuric acid from Temora to West Wyalong are provided in Table 2.

Table 2 Transport Details

Hazardous Delivery Maximum Volume per Maximum Frequency Transported Packaging Material Vehicle Delivery of Deliveries State Sulphuric Acid B-Double 40 t 2 per day Liquid Bulk tanker

8C4 PRELIMINARY SCREENING

The following subsections identify available roads for heavy vehicles within the transport area and examine mandatory and subjective factors for potential transport routes. Section 8C5 provides the results of this analysis as a preliminary list of routes. Further screening of this preliminary list is provided in Section 8C6.

8C4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES

The Guidelines require the identification of potential available roads for heavy vehicles to be based on:

 a review of the road hierarchy (Section 8C4.1.1); and  the identification of routes suitable in general for the movement of trucks (Section 8C4.1.2).

Results of the review of the road hierarchy and the identification of routes suitable in general for the movement of trucks are provided in Section 8C4.1.3.

8C4.1.1 Road Hierarchy

The RMS has developed a road hierarchy for NSW that classifies roads as national highways, state roads, regional roads or local roads. The NSW road hierarchy is described below.

National Highways

National highways are classified as arterial roads and comprise the principal connections between Sydney, Canberra, Melbourne, Adelaide and Brisbane (RTA, pers. comm., 4 May 2005; RTA, 2004a).

922538 8C-2 Sulphuric Acid Road Transport Route Evaluation – Segment 3

The Newell Highway is the only national highway within the transport area. The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005). Therefore, the Newell Highway would be used by heavy vehicles within the transport area where possible.

State Roads

State roads are classified as arterial roads and are the principal traffic carrying and linking routes for the movement of people and goods within the urban centres of Sydney, Newcastle, Wollongong and the Central Coast, and throughout NSW (RTA, 2004a). State roads are characterised by high flows of general traffic over long distances and have a higher capacity relative to surrounding roads (ibid.).

State Roads within the transport area include Burley Griffin Way (State Route 94), Barmedman Road (State Route 85) and the Mid Western Highway. The RMS prefers heavy vehicles to utilise national highways and state roads (over regional and local roads) wherever possible (RTA, pers. comm., 4 May 2005). Accordingly, these roads would also be used by heavy vehicles within the transport area where possible.

Regional Roads

Regional roads comprise the secondary road network which, in combination with state roads, provide for travel between smaller towns and districts and perform a sub-arterial function within major urban centres (RTA, 2004a). The RMS considers regional roads to be suitable for heavy vehicles (RTA, pers. comm., 4 May 2005).

Local Roads

8C4.1.2 Identification of Truck Routes

The NSW road hierarchy is described in Section 8C4.1.1. Arterial and sub-arterial roads (i.e. national highways, state roads and regional roads) should be evaluated for their appropriateness to cater for heavy vehicles (DoP, 2011a). The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005), therefore these roads were used wherever possible when identifying truck routes within the transport area.

The RMS has published a map showing B-Double and road train routes (which includes B-doubles) throughout NSW (RMS, 2018). These roads are approved restricted access vehicle routes and are specifically designed to accommodate these heavy vehicles and would therefore accommodate the vehicles proposed to be used to transport sulphuric acid. Designated B-Double and road train routes were used wherever possible when identifying truck routes within the transport area.

922538 8C-3 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Designated heavy vehicle bypasses within the transport area were taken into consideration when identifying truck routes. There is one heavy vehicle bypass within the transport area at West Wyalong (RTA, pers. comm., 1 August 2005; Bland Shire Council, pers. comm., 4 July 2005). This bypass is applicable to Route 3B, however is not applicable to Route 3A (refer Table 3).

8C4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes

Following a review of the road hierarchy and the identification of truck routes in the transport area, Routes 3A and 3B have been identified as potential available routes for heavy vehicles for Segment 3. Routes 3A and 3B are set out in Table 3 and shown on Figure 8-1. Routes 3A and 3B were tested against mandatory and subjective factors. The assessment is set out below in Sections 8C4.2 and 8C4.3. Table 3 Truck Routes

8C4.2 MANDATORY CONSIDERATIONS

8C4.2.1 Physical Considerations

Physical considerations may preclude a potential transport route from consideration because of weight limitations on bridges, height restrictions on underpasses, inadequate shoulders for breakdowns, extensive construction activities or inadequate parking and turning spaces (DoP, 2011a). Roads designated by the RMS as B-Double or road train routes are considered to be physically capable of accommodating the vehicles that are proposed to be used to transport sulphuric acid. No further assessment of physical capability has been undertaken for these roads.

Routes 3A and 3B only utilise roads that are designated as B-Double or road train routes (RTA, 2001). Therefore, physical considerations do not preclude either of the potential transport routes.

922538 8C-4 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Although the above legislation does not include provisions which prohibit the transport of hazardous materials or dangerous goods on certain roads or structures, Part 3, Division 1, Clause 18 of the NSW Road Transport (General) Regulation, 2013 and Rule 300-2 of the NSW Road Rules, 2014 legislation provide dangerous goods must not be transported on or in certain prohibited areas. The potential transport route for Segment 3 proposed to be used to transport sulphuric acid does not involve transport through any of the prohibited areas listed in Rule 300-2 of the NSW Road Rules, 2014.

8C4.2.2 Laws and Regulations

National Transport Authority

The Australian Government Department of Infrastructure, Regional Development and Cities (DIRDC) website (DIRDC, 2018) advises that:

The DIRDC lists the EPA as the NSW Competent Authority for Road and Rail Transport (refer sub-section below).

State Transport Authority

NSW EPA

NSW RMS

As described in Section 8A4.1.2, the RMS has published a RAV map showing B-Double routes throughout NSW (RMS, 2018). These roads are approved RAV routes and are specifically designed to accommodate these heavy vehicles and would therefore accommodate the B-Double’s proposed to be used to transport sulphuric acid. The RMS will be consulted regarding the proposed transport route to confirm the RMS has no objections to the proposed route.

Local Transport Authority

For the purposes of this study, the local transport authority has been defined as the authority accountable for a specified road according to its classification. In NSW, the State Government, through the RMS, manages national highways and state roads and is accountable for the outcomes on these roads (RTA, 2004a). Therefore, the RMS is the local transport authority for national highways and state roads. Councils are accountable for regional and local roads (RTA, 2004a) and are therefore the local transport authorities for these roads.

922538 8C-5 Sulphuric Acid Road Transport Route Evaluation – Segment 3

The heavy vehicle bypass at West Wyalong (applicable to Route 3B) is comprised of regional or local roads and therefore the local transport authority is the Bland Shire Council. The RMS is the transport authority for the Newell Highway, Burley Griffin Way (State Route 94), Barmedman Road (State Route 85) and the Mid Western Highway. As stated above, the RMS has prohibited the carriage of hazardous materials on a number of routes under the Road Transport (Safety and Traffic Management) (Road Rules) Regulation 1999.

Laws and regulations do not preclude either of the potential transport routes.

The local Councils relevant to Routes 3A and 3B are the Bland, Coolamon and Temora Shire Councils. Outcomes of consultation with the Bland, Coolamon and Temora Shire Councils will be taken into consideration in this THMS.

Consultation with the Bland, Coolamon and Temora Shire Councils and RMS is currently being undertaken to determine if there are any factors which may preclude Routes 3A or 3B from the route evaluation. This THMS Addenda will be revised if necessary once the consultation is complete.

8C4.3 SUBJECTIVE FACTORS

Subjective factors usually include the proximity of the potential transport route to sensitive landuses (such as hospitals, schools, aged care facilities, churches and items of heritage or cultural significance) (Section 8C4.3.1) and sensitive ecosystems and natural landscapes (such as park reservations and wetlands) (Section 8C4.3.2) (DoP,2011a). Emergency and evacuation planning and infrastructure are also usually included in the assessment of subjective factors (Section 8C4.3.3) (DoP,2011a).

8C4.3.1 Landuse

Sensitive Landuses

Sensitive landuses include schools (pre-schools and primary and secondary schools), hospitals, aged care facilities, churches and items of heritage or cultural significance.

Routes 3A and 3B predominantly pass through rural areas comprising of areas of open space. Sensitive landuses are equally uncommon along both potential routes and do not provide a strong basis for comparison. Therefore, further detailed consideration of sensitive landuses was not undertaken for this route evaluation.

Other Landuses

Other landuses may include residential, commercial or industrial areas and areas of open space. Routes 3A and 3B predominantly pass through rural areas comprising areas of open space.

Adjacent landuses are similar along both potential routes and do not provide a strong basis for comparison. Therefore, further detailed consideration of other adjacent landuses was not undertaken for this route evaluation.

8C4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes

Sensitive ecosystems and natural landscapes include park reservations (i.e. national parks, state forests, recreational parks and conservation areas) and waterways (i.e. wetlands, lakes, dams, rivers, creeks and other drainage lines). Sensitive ecosystems and natural landscapes traversed by or occurring along or within approximately 100 m of Routes 3A and 3B are identified in Table 4 and described in the following sections.

922538 8C-6 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Table 4 Sensitive Ecosystems and Natural Landscapes

Park Reservations Route Approximate Total Road Waterways Number Frontage (m) 3A 1 500 42 3B 1 3,100 20

Park Reservations

Vehicles travelling on Routes 3A and 3B would pass within approximately 100 m of The Charcoal Tank Nature Reserve and Reefton State Forest, respectively.

To determine the preferred transport route, a measure of the quality and size of potentially affected park reservations is required. It was conservatively assumed that all park reservations are of a similar high quality. The road frontage of park reservations was measured to compare the size of the parks traversed by or occurring along or within approximately 100 m of potential routes. The approximate total length of road frontage of park reservations for Routes 3A and 3B are 500 m and 3,100 m respectively.

Waterways

Vehicles travelling on Route 3A would cross or come within approximately 100 m of 42 waterways including Trigalong Creek, Mirrool Creek, Scotts Creek, Mandamah Creek and branches of Yiddah Creek. Vehicles travelling on Route 3B would cross or come within approximately 100 m of 20 waterways including Trigalong Creek, Sproules Creek, Greens Creek, Barmedman Creek and Yiddah Creek.

8C4.3.3 Emergency and Evacuation Planning and Infrastructure

Route 3A and 3B falls within the Riverina Murray Emergency Management Regions. Each Emergency Management Region is responsible for preparing District or Regional Emergency Management Plans which describe the arrangements at the Regional level to effectively and efficiently prevent, prepare for, respond to and recover from emergencies.

922538 8C-7 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Following a review of emergency management in NSW, emergency and evacuation planning and infrastructure are considered to be adequate for both potential routes. These routes are therefore equally suitable for the transport of hazardous materials with respect to emergency and evacuation planning and infrastructure.

8C4.3.4 RMS and Transporter Preferred Transport Routes

The RMS, an authority which maintains the majority of the road system (i.e. national highways and state roads) and which acts as an advisory body to Councils, is being consulted to determine the RMS’s preferred route for the transport of hazardous materials from Temora to West Wyalong. Route 3A is the route preferred by the RMS for the transport of hazardous materials from Temora to West Wyalong (RTA, pers. comm., 26 July 2005).

The transport provider was contacted to determine their preferred route for the transport of hazardous materials from Temora to West Wyalong. Route 3B is the route preferred by the transporter for the transport of hazardous materials for Segment 3.

8C4.4 PRELIMINARY SCREENING FINDINGS

Preliminary screening took into account available roads for heavy vehicles and mandatory and subjective factors (Sections 8C4.1, 8C4.2 and 8C4.3). Following a review of the road hierarchy and the identification of truck routes within the transport area, Routes 3A and 3B have been identified as potential available routes for heavy vehicles for Segment 3. Mandatory factors did not preclude these routes from the route evaluation.

Table 5 provides a summary of subjective factors outlined in Section 8C4.3 for Routes 3A and 3B.

Table 5 Summary of Subjective Factors

Assessment Factor Route 3A Route 3B Schools # # Number of School Students # # Hospitals # # Number of Hospital Beds # # Aged Care Facilities # # Churches # # Items of Heritage or Cultural Significance # #

922538 8C-8 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Table 5 (Continued) Summary of Subjective Factors

Assessment Factor Route 3A Route 3B Other Landuse # # Number of Park Reservations 1 1 Park Reservations – Approximate Total Road Frontage (m) 500 3,100 Waterways 42 20 Emergency Infrastructure Adequate Adequate RMS and Transporter Preferred Route RMS and local Council Transporter preferred preference being route confirmed RMS and local Council preference being confirmed # There is little difference in the type of landuse along each potential route, therefore these factors were not used to compare Routes 3A and 3B. Further information is provided in Sections 8C4.3.1. RMS Roads and Traffic Authority

Table 5 indicates that Routes 3A and 3B would have minimal impact on subjective factors and are suitable for the transport of hazardous materials.

In accordance with the Guidelines, Table 6 presents the results of the preliminary screening on a comparative basis. Table 6 details the most preferred, acceptable, least preferred and excluded routes for each of the subjective factors detailed in Section 8C4.3. For the purposes of this study:

 a preferred route is one which is deemed to have a minimal amount, if any, of the factor of interest;  an acceptable route has a typical amount of the factor of interest;  a least preferred route has a significant increase in the amount of the factor of interest when compared to alternative routes; and  an excluded route is deemed to have an unacceptable amount of the factor of interest.

Table 6 Preliminary Screening Findings

922538 8C-9 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Tables 5 and 6 indicate there is a minor preference for Route 3A following preliminary screening. This route is the preferred route for three of the subjective factors presented in Table 6 and therefore would have the least potential adverse effect in the unlikely event of a release of sulphuric acid. The preliminary screening has identified Route 3B as an acceptable route and worthy of further assessment.

8C5 PRELIMINARY LIST OF ROUTES

On the basis of the preliminary screening in Section 8C4, the following preliminary list of routes from Temora to West Wyalong has been determined (Table 7).

Table 7 Preliminary List of Routes

8C6 SECONDARY SCREENING

Secondary screening involves the assessment of the preliminary list of routes (Section 8C5) against road and traffic factors (Section 8C6.1), emergency response capability (Section 8C6.2), operational factors (Section 8C6.3) and risk (including environmental and landuse factors) (Section 8C6.4) (Figure 8-2). The potential routes have been assessed against each secondary screening factor to confirm that the routes are suitable for the transport of hazardous materials and to determine the preferred route. The final selection of routes is detailed in Section 8C7.

8C6.1 ROAD AND TRAFFIC FACTORS

The Guidelines state that the assessment of potential transport routes for suitability on road and traffic grounds will require the collection of particular information (for example road structural condition) to establish the capability and level of service of the road system (DoP,2011a).

The Guidelines offer the following road and traffic factors that consider the ability of a route to effectively and safely handle traffic using it: structural and geometric adequacy; level of service of carriageway and critical intersections; travel speed; accident rates; and the availability of alternative emergency routes.

The capability of a route to safely and effectively handle the traffic using it is reflected in the accident statistics for that route (Pinnacle Risk Management, pers. comm., 20 July 2005). Accident statistics are influenced by the route’s structural and geometric adequacy, level of service (of carriageway and intersections), and travel speed. It follows then that the structural and geometric adequacy, level of service (of carriageway and intersections), and travel speed are effectively embodied within the accident statistics of the transport route (Pinnacle Risk Management, pers. comm., 20 July 2005). Therefore, it is appropriate to compare accident statistics for potential transport routes and infer from them the capability and level of service of the road system.

922538 8C-10 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Accident statistics for potential routes are provided in Section 8C6.1.1. An assessment of remaining road and traffic factors (i.e. the availability of alternative emergency routes) is provided in Section 8C6.1.2.

8C6.1.1 Accident Statistics

Available accident statistics for Routes 3A and 3B were obtained from the RMS and are summarised in Table 8.

Table 8 Summary of Accident Statistics

Heavy Vehicle No. of Heavy % Increase of Heavy Vehicle Annual Million Length Accidents/Annual Route Vehicles Heavy Vehicles Accidents km of Heavy (km) Million km of Heavy (per day)1 due to Project4 (per year)5 Vehicle Travel Vehicle Travel 3A 97 1702,3 – 5053 0.8% – 2.4% 2.25 6.02 – 17.87 0.13 – 0.37 3B 77 1592,3 – 9032,3 0.4% – 2.5% 3.25 4.47 – 25.37 0.13 – 0.73 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 Assumes 10% of all vehicles are heavy vehicles. 3 2018 values extrapolated from previous years assuming 1% annual growth rate. 4 Assumes 28 truck movement per week. 5 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016).

Accident statistics for Routes 3A and 3B are considered to be within normal operating levels for the road types and use. The increase of heavy vehicles due to the Project would be very small (up to approximately 2.5%) and would be unlikely to affect traffic flows or accident statistics. Routes 3A and 3B are therefore suitable for the transport of hazardous materials with respect to accident statistics. Accident statistics for Routes 3A and 3B are compared in Table 11, Section 8C6.4.4.

8C6.1.2 Availability of Alternative Emergency Routes

The NSW state and regional road network is extensive. As a result, there are alternative emergency transport routes that could be used in the event of a temporary closure of Routes 3A and 3B.

8C6.2 EMERGENCY RESPONSE CAPABILITY

The formalised approach to emergency management in NSW ensures: the availability of emergency combat equipment at a local, district and state level; the location of emergency response teams throughout NSW; and the ability of emergency response teams to respond to hazardous material release (Section 8C4.3.3). Further information on the management of emergencies in NSW and an evaluation of the ease of access to a potential accident for Segment 3 are provided in Section 8C4.3.3.

Following a review of emergency management in NSW, emergency response capability is considered to be adequate for Routes 3A and 3B. These routes are therefore equally suitable for the transport of hazardous materials with respect to emergency response capability.

922538 8C-11 Sulphuric Acid Road Transport Route Evaluation – Segment 3

8C6.3 OPERATIONAL FACTORS

Operating costs and distribution logistics have been considered in the selection of the preferred transport route for Segment 3. Routes 3A and 3B are both suitable on the basis of logistical considerations.

The Guidelines (DoP, 2011a) state that the main cost criterion when comparing alternative routes is the expected increase or decrease in distance and travel time if another route is used. Generally, an increase in travel distance increases the travel time and subsequently the cost of transport. Therefore, the shortest route is the most preferable, in respect of operating costs. Route 3B is the shortest available route for Segment 3 and is therefore cost effective and preferred on operating cost grounds. However, Route 3A is not unacceptably longer than Route 3B and, although less cost effective, is also suitable on the basis of operating costs.

8C6.4 RISK ASSESSMENT

The risk assessment for Segment 3 has been undertaken in accordance with HIPAP No. 6. HIPAP No. 6 sets out methodology for risk assessment as follows:

8C6.4.1 Hazard Identification

86.4.1.1 Type of Hazardous Material

922538 8C-12 Sulphuric Acid Road Transport Route Evaluation – Segment 3

When spilt, sulphuric acid is very slippery.

86.4.1.2 Adjacent Landuse

Refer to Section 8C4.3.1 for a description of adjacent landuse for potential transport routes.

86.4.1.3 Transport Vehicle and Conditions of Transport

86.4.1.4 Causes of Hazardous Incidents

Table 9 Heavy Vehicle Incidents – Initiating and Contributing Causes

System or Procedural Human Error Equipment Failures External Events Failures  driver impairment,  non-dedicated trailer  driver incentives to  vandalism/sabotage e.g. alcohol or drugs  rail road crossing guard work longer hours  rain  speeding failure  driver training  fog/visibility  driver overtired  leaking valve  carrier selection  wind  driver exceeding safe  leaking fitting  container specification  flood/washout working hours  brake failure  route selection  fire at rest area/parking  en-route inspection  relief device failure  emergency response areas  contamination  tyre failure training  earthquake  overfilling  soft shoulder  speed enforcement  existing accident  other vehicle’s driver  overpressure  driver rest periods  animals on road  taking tight turns/ramps  material defect  maintenance too quickly (overturns)  vacuum  inspection  unsecured loads  steering failure  time of the day restrictions

922538 8C-13 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Table 9 (Continued) Heavy Vehicle Incidents – Initiating and Contributing Causes

System or Procedural Human Error Equipment Failures External Events Failures  sloshing  high centre of gravity  corrosion  bad weld  excessive grade  poor intersection design  road chamber/width  suspension system  tyre fire caused by friction, brakes overheating or exploding tyres give sparks due to metal in the rubber)  fuel tank fire (diesel)

8C6.4.2 Consequence Analysis

Sulphuric acid will remain indefinitely in waterways as a sulphate.

8C6.4.3 Estimation of the Likelihood of a Hazardous Incident

Accident data for heavy vehicles utilising Routes 3A and 3B are detailed in Section 8C6.1.1 and Table 8. Approximately 2 accidents per year involving heavy vehicles occur for Route 3A and 3 accidents per year involving heavy vehicles occur for Route 3B.

922538 8C-14 Sulphuric Acid Road Transport Route Evaluation – Segment 3

An estimation of the likelihood of an accident involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material must take into account the following:

The likelihood of an accident (based on averaged accident data) involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material for Routes 3A and 3B is estimated to be approximately 1x10-3/year (i.e. such an incident is estimated to occur on Routes 3A and 3B once every 900 years) (Pinnacle Risk Management Pty Ltd, 2018).

The risk of the event is determined using the risk matrix in Table 10 and the consequence ratings in Table 11 (Pinnacle Risk Management Pty Ltd, 2018).

Table 10 Risk Matrix

922538 8C-15 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Table 11 Consequence Ratings

Extremely Minor Significant Severe Serious Catastrophic Serious Safety and One minor Recordable or Multiple Permanent Multiple Multiple Health injury, First Aid single Medical Medical disability permanent fatalities Treatment Treatment casualty or disabilities or Injury Injuries or one multiple Lost one fatality Lost Time Time Injuries Injury Environment Very minor Minor local Evident Significant Major local Extremely pollution. No pollution. pollution, local local pollution. pollution. severe offsite escape Nuisance concern. For example, Observable pollution. of material offsite effect, Minimal waterways offsite effect Ecosystems at (contained typically of duration offsite discoloured (e.g. waterways high risk of within the short duration, effects 10s of metres, discoloured 10s destruction. operational (e.g. noise, (e.g. waterway fire or smoke to 100s of Only resolved areas). Onsite odours, dust slightly affecting metres for a via long term nuisance value and/or visible discoloured, people near to few weeks with solutions only plumes for less turbid etc the site a significant (potentially than one hour around the number of taking years) point of release aquatic life with no or very adversely few fish killed) affected) Public Minor issue, Local issue, 10 Local media, Regional or Wide media Headlines, Relations one complaint complaints 100 complaints state media national corporate coverage damage Financial < $25,000 $25,000 to > $100,000 to > $1 million to > $20 million to > $100 million Impact $100,000 $1 million $20 million $100 million Source: Pinnacle Risk Management Pty Ltd (2011; 2018)

Given a likelihood of 1x10-3/year and a consequence rating of “Serious”, the corresponding risk level is Class III (Pinnacle Risk Management Pty Ltd, 2018). These values indicate a low level of risk associated with the transport of hazardous materials (Pinnacle Risk Management Pty Ltd, 2018).

8C6.4.4 Risk Analysis and Assessment of Risk Results

Risk analysis took into account the preliminary screening findings as well as road and traffic factors (Section 8C6.1), emergency response capability (Section 8C6.2) and operational factors (Section 8C6.3). Table 12 provides a summary of all assessment factors utilised in the risk analysis for Routes 3A and 3B.

Table 12 Summary of Risk Analysis Assessment Factors

Assessment Factor Route 3A Route 3B Schools # # Number of School Students # # Hospitals # # Number of Hospital Beds # # Aged Care Facilities # #

922538 8C-16 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Table 12 (Continued) Summary of Risk Analysis Assessment Factors

Assessment Factor Route 3A Route 3B Churches # # Items of Heritage or Cultural Significance # # Other Landuse # # Number of Park Reservations 1 1 Park Reservations – Approximate Total Road Frontage (m) 500 3,100 Waterways 42 20 Emergency Infrastructure Adequate Adequate RMS and Transporter Preferred Route Transporter preferred RMS and local Council route preference being RMS and local Council confirmed preference being confirmed Length (km) 97 77 No. of Heavy Vehicles (per day)1 1702,3 – 5053 1592,3 – 9032,3 % Increase of Heavy Vehicles due to Project2 0.8% – 2.4% 0.4% – 2.5% Heavy Vehicle Accidents (per year)3 2.25 3.25 Annual Million km of Heavy Vehicle Travel 6.02 – 17.87 4.47 – 25.37 Heavy Vehicle Accidents/Annual Million km of Heavy Vehicle Travel 0.13 – 0.37 0.13 – 0.73 Availability of Alternative Emergency Routes Available Available Emergency Response Capability Adequate Adequate Operational Factors Less cost effective More cost effective 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 Assumes 10% of all vehicles are heavy vehicles. 3 2018 values extrapolated from previous years assuming 1% annual growth rate. 4 Assumes 28 truck movement per week. 5 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016). # There is little difference in the type of landuse along each potential route, therefore these factors were not used to compare Routes 3A and 3B. Further information is provided in Section 3C4.3.1. RMS Roads and Traffic Authority

In accordance with the Guidelines, Table 13 presents the results of the risk analysis on a comparative basis. In each case the consequences and likelihood of potential hazardous events were considered. This risk assessment approach effectively combines the estimated accident frequency with the potential for harm (i.e. risk), making it consistent with the principles and methodologies embodied within Australian Standard (AS) 4360 Risk Management and HIPAP No. 6.

Table 13 details the most preferred, acceptable, least preferred and excluded routes for the risk analysis assessment factors. For the purposes of this risk assessment:

 a preferred route is one which is deemed to have a minimal amount, if any, of the factor of interest and poses a minimal amount of risk to the factor of interest;  an acceptable route has a typical amount of the factor of interest and poses an acceptable amount of risk to the factor of interest;  a least preferred route has a significant increase in the amount of the factor of interest and poses a significant increase of risk to the factor of interest; and  an excluded route is deemed to have an unacceptable amount of the factor of interest and poses an unacceptable level of risk to the factor of interest.

922538 8C-17 Sulphuric Acid Road Transport Route Evaluation – Segment 3

Table 13 Risk Analysis Findings

Assessment Factor Most Preferred Acceptable Least Preferred Excluded Route Route Route Route Schools # # # # Hospitals # # # # Aged Care Facilities # # # # Churches # # # # Items of Heritage or Cultural Significance # # # # Other Landuse # # # # Park Reservations 3A 3B - - Waterways - 3B 3A - Emergency Infrastructure 3A, 3B - - - RMS and Transporter Preferred Route 3A 3B - - Heavy Vehicle Accidents (per year)1 3A 3B - - Heavy Vehicle Accidents/Annual Million km of 3A 3B - - Heavy Vehicle Travel Availability of Alternative Emergency Routes 3A, 3B - - - Emergency Response Capability 3A, 3B - - - Operational Factors 3B 3A - - Comparative Assessment of all Factors 3A 3B - - 1 RTA (2005) Excel database of traffic crash data for the South Western Region 2000-2004. Provided by David Amery on 5 August 2005. # There is little difference in the type of landuse along each potential route, therefore these factors were not used to compare Routes 3A and 3B. Further information is provided in Section 8C4.3.1. RMS Roads and Traffic Authority

From a risk perspective, the results detailed in Tables 12 and 13 show little difference in the level of risk associated with Routes 3A and 3B. In addition, these results deem both potential routes to pose a minimal to acceptable level of risk to surrounding people, property and the natural environment. Therefore, there is insufficient difference in the results of the risk analysis to recommend a preferred route. Routes 3A and 3B are therefore equally suitable for the transport of hazardous materials from a comparative risk perspective.

8C7 SELECTION OF ROUTES

In accordance with the Guidelines, the selection of preferred routes1 is a balanced judgement considering each of the factors, since it is not possible to integrate them into a single indicator of acceptability because of their diversity (DoP, 2011a). To make a balanced judgement, preliminary and secondary screening factors have been assessed with respect to the consequences and likelihood of a potential hazardous event occurring (e.g. a heavy vehicle carrying the material of interest being involved in an accident resulting in a release of material).

1 In all cases, preferred routes have been assessed as being suitable for the transport of hazardous materials.

922538 8C-18 Sulphuric Acid Road Transport Route Evaluation – Segment 3

In order to make a balanced judgement, consultation with Councils was also undertaken. The transport area for Segment 3 is situated within the Temora, Coolamon and Bland LGAs. These Councils were consulted during the preparation of the THMS.

To identify a route which presents the lowest overall risk to surrounding people, property and the natural environment, a holistic review of the preliminary and secondary screening factors and consultation undertaken with the RMS, Councils and transport provider has been performed.

There are a number of possible outcomes of any route evaluation, including:

1. One route is preferable because the potential for harmful effects resulting from the accidental loss of containment are significantly lower than the alternative routes considered. 2. Two or more routes are considered preferable because there is little difference in the overall potential impact resulting from the accidental loss of containment. 3. Two or more routes are considered suitable because there is little difference in the overall potential impact resulting from the accidental loss of containment. Consideration of operational factors (e.g. cost) or consultation with the RMS or Councils may, however, determine the preferred route.

Whilst a preferred route may be determined, the alternative routes may not pose unacceptable risk to surrounding people, property and the natural environment. Therefore, this route evaluation presents all routes that are suitable for the transport of the hazardous material in question. In accordance with Development Consent Condition 5.4(b)(i), suitable routes identified in this route evaluation for the transport of hazardous materials shall be used except where departures are necessary for local deliveries or emergencies.

Following preliminary and secondary assessment, Routes 3A and 3B have been identified as potential available routes for heavy vehicles for Segment 3 and are suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). Both routes are assessed as posing a minimal to acceptable level of risk to surrounding people, property and the natural environment. Consultation with the RMS and the relevant Shire Councils regarding Routes 3A and 3B is also being undertaken and their comments will be taken into consideration by this THMS.

Routes 3A and 3B are both suitable for the transport of sulphuric acid for Segment 3. Once consultation with the RMS and the relevant Shire Councils is complete, their comments will be taken into consideration to decide upon the suitability of the routes.

8C8 RISK MANAGEMENT MEASURES

922538 8C-19 Sulphuric Acid Road Transport Route Evaluation – Segment 3

This route evaluation did not identify undesirable levels of risk for any suitable transport routes as risk management measures required to be implemented by the material supplier and transport provider are suitable for the hazardous material being transported. Therefore, no additional opportunities for risk reduction are recommended. The risk management measures required to be implemented by the material supplier and transport provider for the transport of sulphuric acid to the Project include:

 As sulphuric acid is classified as a dangerous good under the ADG Code, it must be transported in accordance with the requirements set out in the DGT Regulation and the ADG Code. Examples of the requirements set out in the ADG Code include: - dangerous goods must not be transported in a bulk container if the container is: constructed of material which is incompatible with the goods; or leaking, defective or damaged so that it is not safe to transport the goods (Clause 4.2.1); - a bulk container (other than a pressure vessel that is referred to in Clause 4.8.1) that forms part of, or is attached to, a road vehicle must be hydraulically tested and visually inspected in accordance with Clause 4.8.2; - a bulk container which is transported on a vehicle must be: securely fastened to the vehicle or contained within the periphery of the vehicle so as to prevent movement during transport, and so as to provide adequate external support (Clause 4.9.1); - a bulk container, other than multi-compartment tank, that contains dangerous goods in bulk must be placarded with Emergency Information Panels (Clause 7.5.1); - a road vehicle transporting dangerous goods in bulk having the same UN Number but no packaged dangerous goods must be placarded with: a class label for the goods; and any subsidiary risk label that is applicable to the goods; and Emergency Information Panels (Clause 7.6.2); - a vehicle used to transport dangerous goods: must be suitable for transporting the goods; and must be free of any defect that is likely to create a risk in transporting the goods (Clause 8.1.1); - a road vehicle that is transporting a placard load of dangerous goods must be covered by a policy of insurance or other form of indemnity in accordance with Clause 8.1.2; - dangerous goods must not be transported on the same vehicle with incompatible goods unless the dangerous goods and the incompatible goods: are segregated in accordance with the ADG Code; or are otherwise allowed under the ADG Code to be transported together, in accordance with Clause 9.1.1; - an emergency information holder must be securely placed on a road vehicle in accordance with Clause 11.2.4; - Table 12.1 sets out guidance on the minimum requirements for: the types of personal protective equipment (including self-contained breathing apparatus, SCBA) with which a driver of a road vehicle transporting a placard load of dangerous goods should be provided; and the safety equipment with which a road vehicle used in the transport of a placard load of dangerous goods should be equipped (Clause 12.1.1); - a road vehicle transporting a placard load of dangerous goods must be equipped with a fire extinguisher or fire extinguishers in accordance with Table 12.2; - if a road vehicle transporting dangerous goods is involved in an incident that results in a dangerous situation, the driver of the vehicle must notify the police or fire brigade and prime contractor as soon as possible in accordance with Clause 14.1.1; and - the driver of a vehicle transporting dangerous goods involved in an incident that results in a dangerous situation should also take all safe and practicable steps to carry out any emergency procedures recommended in the emergency information in accordance with Clause 14.1.1.

922538 8C-20 Sulphuric Acid Road Transport Route Evaluation – Segment 3

 Drivers transporting dangerous goods by road in bulk are required to be appropriately licensed to drive the vehicle under Part 18 of the DGT Regulation.  Vehicles transporting dangerous goods by road in bulk are required to be licensed to transport the goods under Part 18 of the DGT Regulation.  Those undertaking any task involved in the transport of dangerous goods by road (e.g. driving a vehicle transporting dangerous goods; loading dangerous goods into or onto a vehicle, or into a container to be put in or on a vehicle; unloading dangerous goods) are required to be appropriately instructed and trained under Part 20 of the DGT Regulation.  The prime contractor and driver of a vehicle transporting dangerous goods by road that is involved in an incident resulting in a dangerous situation are required to tell the Competent Authority about the incident and give the Competent Authority a written report about the incident in accordance with Part 14 of the DGT Regulation.  Vehicles transporting hazardous materials to the Project are required to carry appropriate communication devices (such as a radio or telephone).

922538 8C-21 Sulphuric Acid Road Transport Route Evaluation – Segment 3

8C9 REFERENCES

Centre for Chemical Process Safety (CCPS) (1995) Guidelines for Chemical Transportation Risk Analysis.

Department of Planning (2011a) Hazardous Industry Planning and Advisory Paper No. 11, Route Selection.

Department of Planning (2011b) Hazardous Industry Planning and Advisory Paper No. 6, Hazard Analysis.

NSW Office of Environment and Heritage (2018)

Pinnacle Risk Management Pty Ltd (2011) Matrix Based Risk Assessment.

Pinnacle Risk Management Pty Ltd (2018) Review comments on draft THMS Addenda for Sulphuric Acid provided by Dean Shewring in emails dated 14 June 2018 and 16 July 2018.

Roads and Maritime Services (2018) Restricted Access Vehicle (RAV) map and website link.

Roads and Traffic Authority (RTA) (2003) 14.6 Metre Semi-Trailers. June 2003. Cat. No. 45070811B.

Roads and Traffic Authority (RTA) (2004a) Information Paper and Invitation for Submissions – NSW Road Classification Review. May 2004.

State Emergency Management Committee (2012) NSW State Emergency Management Plan.

922538 8C-22 Sulphuric Acid Road Transport Route Evaluation – Overview

ATTACHMENT 8D

00927525 1 Evolution Mining (Cowal) Pty Limited

Sulphuric Acid Road Transport Route Evaluation – Segment 4

COWAL GOLD PROJECT TRANSPORT OF HAZARDOUS MATERIALS STUDY

ATTACHMENT 8D

SULPHURIC ACID ROAD TRANSPORT ROUTE EVALUATION

SEGMENT 4 NEWELL HIGHWAY/MID WESTERN HIGHWAY (WEST WYALONG) TO THE COWAL GOLD PROJECT

JULY 2018 Project No. HAL-02-07 Document No. 922540

Sulphuric Acid Road Transport Route Evaluation – Segment 4

TABLE OF CONTENTS

Section Page

8D1 INTRODUCTION 8D-1

8D2 DEFINITION OF THE TRANSPORT AREA 8D-1

8D3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION 8D-1 8D3.1 IDENTIFICATION OF HAZARDOUS MATERIAL 8D-1 8D3.2 SOURCE AND DESTINATION 8D-2 8D4 PRELIMINARY SCREENING 8D-2 8D4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES 8D-2 8D4.1.1 Road Hierarchy 8D-2 8D4.1.2 Identification of Truck Routes 8D-3 8D4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes 8D-5 8D4.2 MANDATORY CONSIDERATIONS 8D-5 8D4.2.1 Physical Considerations 8D-5 8D4.2.2 Laws and Regulations 8D-6 8D4.3 SUBJECTIVE FACTORS 8D-6 8D4.3.1 Landuse 8D-6 8D4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes 8D-6 8D4.3.3 Emergency and Evacuation Planning and Infrastructure 8D-7 8D4.4 PRELIMINARY SCREENING FINDINGS 8D-8 8D5 PRELIMINARY LIST OF ROUTES 8D-8

8D6 SECONDARY SCREENING 8D-9 8D6.1 ROAD AND TRAFFIC FACTORS 8D-9 8D6.1.1 Accident Statistics 8D-9 8D6.1.2 Availability of Alternative Emergency Routes 8D-10 8D6.2 EMERGENCY RESPONSE CAPABILITY 8D-10 8D6.3 OPERATIONAL FACTORS 8D-10 8D6.4 RISK ASSESSMENT 8D-10 8D6.4.1 Hazard Identification 8D-11 8D6.4.2 Consequence Analysis 8D-12 8D6.4.3 Estimation of the Likelihood of a Hazardous Incident 8D-12 8D6.4.4 Risk Analysis and Assessment of Risk Results 8D-14 8D7 SELECTION OF ROUTES 8D-16

8D8 RISK MANAGEMENT MEASURES 8D-17

8D9 REFERENCES 8D-19

922540 8D-i Sulphuric Acid Road Transport Route Evaluation – Segment 4

TABLE OF CONTENTS (continued)

LIST OF TABLES

922540 8D-ii Sulphuric Acid Road Transport Route Evaluation – Segment 4

8D1 INTRODUCTION

As described in Section 1.2 of the Transport of Hazardous Materials Study (THMS), route evaluation is required for the road transport of sulphuric acid to the Project. Road transport of these materials within NSW begins at Port Kembla and terminates at the Project. The road transport route for sulphuric acid to the Project has been divided into four segments (Segments 1, 2, 3 and 4) for the purpose of route evaluation.

This attachment sets out the route evaluation for the road transport of sulphuric acid from the Newell Highway/Mid Western Highway (West Wyalong) to the Cowal Gold Project. This part of the overall road transport route is referred to as Segment 4. The route evaluation for Segment 1, 2 and 3 is attached to the THMS as Attachment 8A, 8B and 8C.

This route evaluation has been carried out in accordance with the Department of Planning’s (DoP’s) Hazardous Industry Planning Advisory Paper No. 11 Route Selection guidelines (DoP,2011a) (the Guidelines), as required by Development Consent Condition 5.4(b)(i). The Guidelines state that in considering the relative risks of transport incidents involving hazardous materials, simplifying assumptions can be made such as the use of representative loads.

Figure 8-2 shows the assessment process flowsheet for this route evaluation.

8D2 DEFINITION OF THE TRANSPORT AREA

The transport area is defined by the Guidelines as follows:

Definition of the transport area is carried out from a traffic perspective. It should include the area over which traffic to or from the development is likely to have a significant effect.

The transport area for Segment 4 is defined as the area between the Newell Highway/Mid Western Highway (West Wyalong) and the Cowal Gold Project (Figure 8-4). The transport area is wholly situated within the Bland Local Government Area (LGA). Bland LGA is part of the Central West Statistical Division.

8D3 IDENTIFICATION OF HAZARDOUS MATERIAL, SOURCE AND DESTINATION

8D3.1 IDENTIFICATION OF HAZARDOUS MATERIAL

Sulphuric acid is classified as Class 8 under the ADG Code. Details of the type of container (i.e. packaging) and the movement quantity and frequency are provided in the following section.

922540 8D-1 Sulphuric Acid Road Transport Route Evaluation – Segment 4

8D3.2 SOURCE AND DESTINATION

The source and destination of sulphuric acid for Segment 4 are outlined in Table 1 and shown on Figure 8-4.

Table 1 Hazardous Material Source and Destination

Source: Destination: West Wyalong Cowal Gold Project Location Town/City LGA Location Town/City LGA Newell Highway/ Bonehams Road, Mid Western West Wyalong Bland 38 km north-east - Bland Highway of West Wyalong

Details of the transport of sulphuric acid from the Newell Highway/Mid Western Highway (West Wyalong) to the Cowal Gold Project are provided in Table 2.

Table 2 Transport Details

Hazardous Delivery Maximum Volume per Maximum Frequency Transported Packaging Material Vehicle Delivery of Deliveries State Sulphuric Acid B-Double 40 t 2 per day Liquid Bulk tanker

8D4 PRELIMINARY SCREENING

The following subsections identify available roads for heavy vehicles in the transport area and examine mandatory and subjective factors for potential transport routes. Section 8D5 provides the results of this analysis as a preliminary list of routes. Further screening of this preliminary list is provided in Section 8D6.

8D4.1 IDENTIFICATION OF AVAILABLE ROADS FOR HEAVY VEHICLES

The Guidelines require the identification of potential available roads for heavy vehicles to be based on:

 a review of the road hierarchy (Section 8D4.1.1); and  the identification of routes suitable in general for the movement of trucks (Section 8D4.1.2).

Results of the review of the road hierarchy and the identification of routes suitable in general for the movement of trucks are provided in Section 8D4.1.3.

8D4.1.1 Road Hierarchy

The RMS has developed a road hierarchy for NSW that classifies roads as national highways, state roads, regional roads or local roads. The NSW road hierarchy is described below.

National Highways

National highways are classified as arterial roads and comprise the principal connections between Sydney, Canberra, Melbourne, Adelaide and Brisbane (RTA, pers. comm., 4 May 2005; RTA, 2004).

922540 8D-2 Sulphuric Acid Road Transport Route Evaluation – Segment 4

The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005). National highways within the transport area include the Newell Highway.

State Roads

State roads in the transport area include the Mid Western Highway.

Regional Roads

Local Roads

8D4.1.2 Identification of Truck Routes

The NSW road hierarchy is described in Section 8D4.1.1. Arterial and sub-arterial roads (i.e. national highways, state roads and regional roads) should be evaluated for their appropriateness to cater for heavy vehicles (DoP,2011a). The RMS prefers heavy vehicles to utilise national highways and state roads wherever possible (RTA, pers. comm., 4 May 2005), therefore these roads were used wherever possible when identifying truck routes within the transport area.

The RMS has published a map showing B-Double and road train routes (which include B-doubles) throughout NSW (RMS, 2018). Road train routes within the transport area include Ungarie Road and the Mid Western Highway (RMS, 2018). The Newell Highway is a B-double route. These roads are approved restricted access vehicle routes and are specifically designed to accommodate these heavy vehicles and would therefore accommodate the B-Doubles used to transport sulphuric acid. These routes were used wherever possible when identifying truck routes within the transport area.

Designated heavy vehicle bypasses within the transport area were taken into consideration when identifying truck routes. One heavy vehicle bypass is located at West Wyalong.

922540 8D-3 Sulphuric Acid Road Transport Route Evaluation – Segment 4

The Project Environmental Impact Statement (EIS) (North Limited, 1998a) assessed potential access routes to the Project. The EIS identified three potential transport routes which were taken into consideration when identifying truck routes.

Potential truck routes to the Project identified for Segment 4 include:

Route Directions 4A Turn off the Mid Western Highway into Ungarie Road, turn right into Wamboyne Road and right into Blow Clear Road which becomes Lake Cowal Road. Turn left into Bonehams Lane and continue to the Cowal Gold Project. 4B From the Newell Highway, take the town heavy vehicle bypass route (turn right into the heavy vehicle bypass, left into Compton Street and cross over the Temora-Lake Cargelligo Railway Line. After crossing the railway line, turn immediately right into Railway Road which becomes Copeland Street), turn right onto the Newell Highway, turn left into Slee Street, right into Clear Ridge Road, right into Blow Clear Road, left into Bonehams Lane and continue to the Cowal Gold Project.

The Traffic Impact Assessment of the Proposed Cowal Gold Project West Wyalong (Traffix, 1997) carried out for the EIS identified Route 4A as the preferred access road to the Project. Following submission and approval of the EIS, Route 4A is the approved Project Access Road and has been upgraded in accordance with Project Development Approval Conditions. The road works along the Access Road have been undertaken by Bland Shire Council to relevant AUSTROAD design standards.

Condition (i) of the Part 5 Approval for the Access Road requires that the Project Access Road development be carried out generally in accordance with the Cowal Gold Project Mine Access Road Upgrade Review of Environmental Factors (Resource Strategies, 1997), and all other relevant documentation including Cowal Gold Project Commission of Inquiry Primary Submission (North Limited, 1998b) and Cowal Gold Project Commission of Inquiry Submission in Reply (North Limited, 1998c) to the Commission of Inquiry, as may be modified by the conditions in the Part 5 Approval. Other relevant documentation includes Traffic Impact Assessment of the Proposed Cowal Gold Project West Wyalong (Traffix, 1997) and Section 94 Study and Plan (Bland Shire Council, 1999).

The Project Access Road has been upgraded to provide a sealed carriageway over its entire length, with appropriate geometric and structural improvements (Traffix, 1997). The Project Access Road upgrade programme included the following (North Limited, 1998b):

 widening and sealing of the existing dirt road within the existing road reserve from the Project site entrance to the Lake Cowal station silo across a gazetted rail crossing;  sealing the existing gravel road and adjustment of the alignment on some bends within the existing road reserve west along Blow Clear Road for a distance of approximately 10.5 km to its intersection with Wamboyne Road at Blow Clear; and  intersection improvements and some widening on curves within the existing road reserve (over a distance of 0.5 km to improve bends [Traffix, 1997]) south along Wamboyne Road for a distance of approximately 18.7 km to its intersection with Ungarie Road.

Other improvements that have been undertaken include the provision of passing lanes and road shoulders and the upgrade of several major intersections where increased traffic numbers were identified as having the potential to compromise safety and/or operational efficiency.

922540 8D-4 Sulphuric Acid Road Transport Route Evaluation – Segment 4

The Project Access Road has been specifically designed to provide access to the Project. Other potential transport routes to the Project comprise segments of unsealed local roads of varying condition which, in their present state, would not provide suitable, all-weather access to the Project for heavy vehicles, particularly those carrying hazardous materials. These roads are therefore, not considered to be suitable for heavy vehicles.

8D4.1.3 Potential Available Routes for Heavy Vehicles and Selection of Potential Routes

Following a review of the road hierarchy and the identification of truck routes within the transport area, Route 4A has been identified as the only potential available route for heavy vehicles for Segment 4. Route 4A is also the approved Project Access Road. Route 4A is set out in Table 3 and shown on Figure 8-4.

Table 3 Truck Routes

Route 4A was tested against mandatory and subjective factors. The assessment is set out below in Sections 8D4.2 and 8D4.3.

8D4.2 MANDATORY CONSIDERATIONS

8D4.2.1 Physical Considerations

The Project Access Road (Route 4A) has been specifically designed to provide access to the Project and is currently being upgraded in accordance with Project Development Approval Conditions. When complete, the Access Road will provide a sealed carriageway over its entire length, with appropriate geometric and structural improvements. Therefore, Route 4A is considered to be physically capable of accommodating heavy vehicles and physical considerations do not preclude this transport route from the route evaluation.

Although the above legislation does not include provisions which prohibit the transport of hazardous materials or dangerous goods on certain roads or structures, Part 3, Division 1, Clause 18 of the NSW Road Transport (General) Regulation, 2013 and Rule 300-2 of the NSW Road Rules, 2014 legislation provide dangerous goods must not be transported on or in certain prohibited areas. The potential transport route for Segment 4 proposed to be used to transport sulphuric acid does not involve transport through any of the prohibited areas listed in Rule 300-2 of the NSW Road Rules, 2014.

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8D4.2.2 Laws and Regulations

Road works proposed for the Project Access Road (Route 4A) were described and assessed in the Access Road Upgrade Review of Environmental Factors (REF) (Resource Strategies, 1997). In 1999, approval under Part 5 of the Environmental Planning and Assessment Act 1979 was obtained which approves the Access Road for all Project traffic. Laws and regulations do not preclude Route 4A from the route evaluation.

8D4.3 SUBJECTIVE FACTORS

Subjective factors usually include the proximity of the potential transport route to sensitive landuses (such as hospitals, schools, aged care facilities, churches and items of heritage or cultural significance) (Section 8D4.3.1) and sensitive ecosystems and natural landscapes (such as park reservations and wetlands) (Section 8D4.3.2) (DoP,2011a). Emergency and evacuation planning and infrastructure are also usually included in the assessment of subjective factors (Section 8D4.3.3) (DoP, 2011a).

8D4.3.1 Landuse

Sensitive Landuses

Sensitive landuses include schools (pre-schools and primary and secondary schools), hospitals, aged care facilities, churches and items of heritage or cultural significance.

Route 4A predominantly passes through rural areas comprising of areas of open space. Sensitive landuses such as those listed above are relatively uncommon along Route 4A and do not preclude it from the route evaluation. Therefore, further detailed consideration of sensitive landuses was not undertaken for this route evaluation.

Other Landuses

Other landuses may include residential, commercial or industrial areas and areas of open space. Route 4A predominantly passes through rural areas comprising areas of open space.

8D4.3.2 Proximity of Sensitive Ecosystems and Natural Landscapes

Sensitive ecosystems and natural landscapes include park reservations (i.e. national parks, state forests, recreational parks and conservation areas) and waterways (i.e. wetlands, lakes, dams, rivers, creeks and other drainage lines). Sensitive ecosystems and natural landscapes traversed by or occurring along or within approximately 100 m of Route 4A are identified in Table 4 and described in the following sections.

Table 4 Sensitive Ecosystems and Natural Landscapes

Park Reservations Route Approximate Total Road Waterways Number Frontage (m) 4A 1 5,100 22

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Park Reservations

Vehicles travelling on Route 4A would pass within approximately 100 m of Hiawatha State Forest.

To determine if Route 4A is suitable for the transport of hazardous materials, a measure of the quality and size of the potentially affected park reservation is required. It was conservatively assumed that the park reservation is of a high quality. The road frontage of park reservations was measured to compare the size of the parks traversed by or occurring along or within approximately 100 m of Route 4A. The approximate total length of road frontage of park reservations for Route 4A is 5,100 m.

Waterways

Vehicles travelling on Route 4A would traverse or come within approximately 100 m of 22 waterways.

8D4.3.3 Emergency and Evacuation Planning and Infrastructure

Route 4A falls within the Riverina Murray Emergency Management Regions. Each Emergency Management Region is responsible for preparing District or Regional Emergency Management Plans which describe the arrangements at the Regional level to effectively and efficiently prevent, prepare for, respond to and recover from emergencies.

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Following a review of emergency management in NSW, emergency and evacuation planning and infrastructure are considered to be adequate for Route 4A. This route is therefore suitable for the transport of hazardous materials with respect to emergency and evacuation planning and infrastructure.

8D4.4 PRELIMINARY SCREENING FINDINGS

Preliminary screening took into account available roads for heavy vehicles and mandatory and subjective factors (Sections 8D4.1, 8D4.2 and 8D4.3). Following a review of the road hierarchy and the identification of truck routes within the transport area, Route 4A has been identified as the only potential available route for heavy vehicles for Segment 4. Mandatory factors did not preclude this route from the route evaluation.

Table 5 provides a summary of subjective factors outlined in Section 8D4.3 for Route 4A.

Table 5 Summary of Subjective Factors

Assessment Factor Route 4A Schools # Number of School Students # Hospitals # Number of Hospital Beds # Aged Care Facilities # Churches # Items of Heritage or Cultural Significance # Other Landuse Predominantly open space Number of Park Reservations 1 Park Reservations – Approximate Total Road Frontage (m) 5,100 Waterways 22 Emergency Infrastructure Adequate # Sensitive landuses along Route 4A are relatively uncommon and do not preclude this route from the route evaluation. Further information is provided in Section 8D4.3.1.

Table 5 indicates that Route 4A would have minimal impact on subjective factors and is suitable for the transport of hazardous materials.

8D5 PRELIMINARY LIST OF ROUTES

On the basis of the preliminary screening in Section 8D4, the following preliminary list of routes from the Newell Highway/Mid Western Highway (West Wyalong) to the Cowal Gold Project has been determined (Table 6).

Table 6 Preliminary List of Routes

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8D6 SECONDARY SCREENING

Secondary screening involves the assessment of the preliminary list of routes (Section 8D5) against road and traffic factors (Section 8D6.1), emergency response capability (Section 8D6.2), operational factors (Section 8D6.3) and risk (including environmental and landuse factors) (Section 8D6.4) (Figure 8-2). The potential route has been assessed against each secondary screening factor to confirm that the route is suitable for the transport of hazardous materials. The final selection of routes for Segment 4 is detailed in Section 8D7.

8D6.1 ROAD AND TRAFFIC FACTORS

Accident statistics for Route 4A are provided in Section 8D6.1.1. An assessment of remaining road and traffic factors (i.e. the availability of alternative emergency routes) is provided in Section 8D6.1.2.

8D6.1.1 Accident Statistics

Available accident statistics for Route 4A were obtained from the RMS and are summarised in Table 7.

Table 7 Summary of Accident Statistics

% Increase of Heavy Vehicle No. of Heavy Heavy Vehicle Annual Million Length Heavy Accidents/Annual Route Vehicles Accidents km of Heavy (km) Vehicles due Million km of Heavy (per day)1 (per year)4 Vehicle Travel to Project3 Vehicle Travel 4A 41 2172 1.8% 1 3.24 0.31 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 2018 values extrapolated from previous years assuming 1% annual growth rate. 3 Assumes 28 truck movements per week. 4 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016).

Accident statistics for Route 4A are considered to be within normal operating levels for the road types and use. The data shown in Table 7 relates to the current road design for Route 4A (i.e. partially unsealed). Improved driving conditions will be achieved due to the upgrading of the Project Access Road (Route 4A) including sealing of the road to the Project (Section 8D4.1.2). The increase of heavy vehicles due to the Project would be small (approximately 1.8%) and would be unlikely to affect traffic flows or accident statistics. Route 4A is therefore suitable for the transport of hazardous materials with respect to accident statistics.

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8D6.1.2 Availability of Alternative Emergency Routes

The NSW state and regional road network is extensive. As a result, there are alternative emergency transport routes that could be used in the event of a temporary closure of Route 4A.

8D6.2 EMERGENCY RESPONSE CAPABILITY

The formalised approach to emergency management in NSW ensures: the availability of emergency combat equipment at a local, district and state level; the location of emergency response teams throughout NSW; and the ability of emergency response teams to respond to hazardous material release (Section 8D4.3.3). Further information on the management of emergencies in NSW and an evaluation of the ease of access to a potential accident for Segment 4 are provided in Section 8D4.3.3.

Following a review of emergency management in NSW, emergency response capability is considered to be adequate for Route 4A. This route is therefore suitable for the transport of hazardous materials with respect to emergency response capability.

8D6.3 OPERATIONAL FACTORS

Operating costs and distribution logistics have been considered for Segment 4. Route 4A is suitable on the basis of logistical considerations.

The Guidelines (DoP, 2011a) state that the main cost criterion when comparing alternative routes is the expected increase or decrease in distance and travel time if another route is used. Generally, an increase in travel distance increases the travel time and subsequently the cost of transport. Therefore, the shortest route is the most preferable in respect of operating costs. Route 4A is not the shortest available route for Segment 4. However, this route is only marginally longer than alternative routes and the increase in operating costs would be minimal. Route 4A is cost effective and is therefore suitable on the basis of operating costs.

8D6.4 RISK ASSESSMENT

The risk assessment for Segment 4 has been undertaken in accordance with HIPAP No. 6. HIPAP No. 6 sets out methodology for risk assessment as follows:

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3. Estimation of likelihood of a hazardous incident: estimated using available historical traffic data or generic traffic data. 4. Risk analysis. 5. Assessment of risk results.

8D6.4.1 Hazard Identification

8D6.4.1.1 Type of Hazardous Material

When spilt, sulphuric acid is very slippery.

8D6.4.1.2 Adjacent Landuse

Refer to Section 8D4.3.1 for a description of adjacent landuse for Route 4A.

8D6.4.1.3 Transport Vehicle and Conditions of Transport

8D6.4.1.4 Causes of Hazardous Incidents

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Table 8 Heavy Vehicle Incidents – Initiating and Contributing Causes

Human Error Equipment Failures System or Procedural External Events Failures  driver impairment,  non-dedicated trailer  driver incentives to  vandalism/sabotage e.g. alcohol or drugs  rail road crossing guard work longer hours  rain  speeding failure  driver training  fog/visibility  driver overtired  leaking valve  carrier selection  wind  driver exceeding safe  leaking fitting  container specification  flood/washout working hours  brake failure  route selection  fire at rest area/parking  en-route inspection  relief device failure  emergency response areas  contamination  tyre failure training  earthquake  overfilling  soft shoulder  speed enforcement  existing accident  other vehicle’s driver  overpressure  driver rest periods  animals on road  taking tight turns/ramps  material defect  maintenance too quickly (overturns)  steering failure  inspection  unsecured loads  sloshing  time of the day restrictions  high centre of gravity  corrosion  bad weld  excessive grade  poor intersection design  road chamber/width  suspension system  tyre fire caused by friction, brakes overheating or exploding tyres give sparks due to metal in the rubber)  fuel tank fire (diesel)

8D6.4.2 Consequence Analysis

Sulphuric acid will remain indefinitely in waterways as a sulphate.

8D6.4.3 Estimation of the Likelihood of a Hazardous Incident

Accident data for heavy vehicles utilising Route 4A are detailed in Section 8D6.1.1 and Table 7. As detailed in Table 7, approximately 1 accident per year involving heavy vehicles occur for Routes 4A.

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An estimation of the likelihood of an accident involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material must take into account the following:

The likelihood of an accident (based on averaged accident data) involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material for Route 4A is estimated to be approximately 9x10-4/year. Alternatively, an accident involving a vehicle transporting sulphuric acid to the Project resulting in a release of the material would occur once every 1,000 years for Route 4A (Pinnacle Risk Management Pty Ltd, 2018).

The risk of the event is determined using the risk matrix in Table 9 and the consequence ratings in Table 10 (Pinnacle Risk Management Pty Ltd, 2018).

Table 9 Risk Matrix

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Table 10 Consequence Ratings

Extremely Minor Significant Severe Serious Catastrophic Serious Safety and One minor Recordable or Multiple Permanent Multiple Multiple Health injury, First Aid single Medical Medical disability permanent fatalities Treatment Treatment casualty or disabilities or Injury Injuries or one multiple Lost one fatality Lost Time Time Injuries Injury Environment Very minor Minor local Evident Significant Major local Extremely pollution. No pollution. pollution, local local pollution. pollution. severe offsite escape Nuisance concern. For example, Observable pollution. of material offsite effect, Minimal waterways offsite effect Ecosystems at (contained typically of duration offsite discoloured (e.g. waterways high risk of within the short duration, effects 10s of metres, discoloured 10s destruction. operational (e.g. noise, (e.g. waterway fire or smoke to 100s of Only resolved areas). Onsite odours, dust slightly affecting metres for a via long term nuisance value and/or visible discoloured, people near to few weeks with solutions only plumes for less turbid etc the site a significant (potentially than one hour) around the number of taking years) point of release aquatic life with no or very adversely few fish killed) affected) Public Minor issue, Local issue, 10 Local media, Regional or Wide media Headlines, Relations one complaint complaints 100 complaints state media national corporate coverage damage Financial < $25,000 $25,000 to > $100,000 to > $1 million to > $20 million to > $100 million Impact $100,000 $1 million $20 million $100 million Source: Pinnacle Risk Management Pty Ltd (2011; 2018)

Given a likelihood of 9x10-4/year and a consequence rating of “Serious”, the corresponding risk level is Class III (Pinnacle Risk Management Pty Ltd, 2018).This value indicates a low level of risk associated with the transport of hazardous materials. (Pinnacle Risk Management Pty Ltd, 2018)

8D6.4.4 Risk Analysis and Assessment of Risk Results

Risk analysis took into account the preliminary screening findings as well as road and traffic factors (Section 8D6.1), emergency response capability (Section 8D6.2) and operational factors (Section 8D6.3). Table 11 provides a summary of all assessment factors utilised in the risk analysis for Route 4A.

Table 11 Summary of Risk Analysis Assessment Factors

Assessment Factor Route 4A Schools # Number of School Students # Hospitals # Number of Hospital Beds # Aged Care Facilities # Churches # Items of Heritage or Cultural Significance #

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Table 11 (Continued) Summary of Risk Analysis Assessment Factors

Assessment Factor Route 4A Other Landuse # Number of Park Reservations 1 Park Reservations – Approximate Total Road Frontage (m) 5,100 Waterways 22 Emergency Infrastructure Adequate Length (km) 41 No. of Heavy Vehicles (per day)1 2172 % Increase of Heavy Vehicles due to Project3 1.8% Heavy Vehicle Accidents (per year)4 1 Annual Million km of Heavy Vehicle Travel 3.24 Heavy Vehicle Accidents/Annual Million km of Heavy Vehicle Travel 0.31 Availability of Alternative Emergency Routes Available Emergency Response Capability Adequate Operational Factors Cost effective 1 Roads and Maritime Services Traffic Volume Viewer (retrieved 23 May 2018). 2 2018 values extrapolated from previous years assuming 1% annual growth rate. 3 Assumes 28 truck movements per week. 4 Roads and Maritime Services Crash Report Data (1 Jan 2012 to 21 Dec 2016). # Sensitive landuses along Route 4A are relatively uncommon and do not preclude this route from the route evaluation. Further information is provided in Section 8D4.3.1.

Table 12 presents the results of the risk analysis for Route 4A. In each case the consequences and likelihood of potential hazardous events were considered. This risk assessment approach effectively combines the estimated accident frequency with the potential for harm (i.e. risk), making it consistent with the principles and methodologies embodied within Australian Standard (AS) 4360 Risk Management and HIPAP No. 6.

Table 12 presents the results of the risk analysis in terms of minimal, acceptable, significant and unacceptable risk. For the purposes of this risk assessment the following definitions apply:

 minimal risk: the transport of sulphuric acid along Route 4A is assessed as posing a minimal risk to the factor of interest;  acceptable risk: the transport of sulphuric acid along Route 4A is assessed as posing an acceptable amount of risk to the factor of interest;  significant risk: the transport of sulphuric acid along Route 4A is assessed as posing a significant increase of risk to the factor of interest; and  unacceptable risk: the transport of sulphuric acid along Route 4A is assessed as posing an unacceptable level of risk to the factor of interest.

Table 12 Risk Analysis Findings

Acceptable Significant Unacceptable Assessment Factor Minimal Risk Risk Risk Risk Schools  Hospitals  Aged Care Facilities  Churches  Items of Heritage or Cultural Significance 

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Table 12 (Continued) Risk Analysis Findings

Acceptable Significant Unacceptable Assessment Factor Minimal Risk Risk Risk Risk Other Landuse  Park Reservations  Waterways  Emergency Infrastructure  Heavy Vehicle Accidents (per year)  Heavy Vehicle Accidents/Annual Million km of  Heavy Vehicle Travel Availability of Alternative Emergency Routes  Emergency Response Capability  Operational Factors  Comparative Assessment of all Factors 

There are no defined absolute risk criteria for the transport of hazardous materials throughout NSW, therefore the assessment of risk results is a balanced judgement based on experience in accordance with HIPAP No.6. Overall, the net increase in the number of heavy vehicles due to the transport of this material would be approximately 1.8% (i.e. a minor impact on existing traffic volume). Therefore, there would be only a minor increase in transport risk when compared to existing risk levels. From a risk perspective, the results detailed in Tables 11 and 12 deem Route 4A to pose a minimal level of risk to surrounding people, property and the natural environment. This route is therefore suitable for the transport of hazardous materials to the Project.

8D7 SELECTION OF ROUTES

The Guidelines state that the results of the study are generally best presented on a comparative basis. Following the identification of available roads for heavy vehicles in the transport area, there is only one potential available route for heavy vehicles for Segment 4 (Section 8D4.1). Therefore, there is no basis for a comparative assessment. As an alternative to comparative assessment, the potential available route for Segment 4 was assessed against all remaining preliminary and secondary screening factors to confirm that the route is suitable for the transport of hazardous materials to the Project.

Selecting a route that is suitable for the transport of hazardous materials must be a balanced judgement considering each of the factors, since it is not possible to integrate them into a single indicator of acceptability because of their diversity (DoP,2011a). To make a balanced judgement, preliminary and secondary screening factors have been assessed with respect to the consequences and likelihood of a potential hazardous event occurring (e.g. a heavy vehicle carrying the material of interest being involved in an accident resulting in a release of material).

In order to make a balanced judgement, consultation with Councils was also undertaken. The transport area for Segment 4 is wholly situated within the Bland LGA and the Bland City Council was consulted during the preparation of the THMS.

922540 8D-16 Sulphuric Acid Road Transport Route Evaluation – Segment 4

Following preliminary and secondary screening, Route 4A has been identified as the only potential available route for heavy vehicles for Segment 4 and is suitable for the transport of hazardous materials when tested against mandatory considerations, subjective factors, road and traffic factors, emergency response capability, operational factors and risk (including environmental and landuse factors). Route 4A is assessed as posing a minimal level of risk to surrounding people, property and the natural environment. This route is also the approved Project Access Road.

Route 4A is the preferred route for the transport of sulphuric acid from the Newell Highway/Mid Western Highway (West Wyalong) to the Cowal Gold Project. Once consultation with the RMS and the Bland Shire Council is complete, their comments will be taken into consideration to confirm that Route 4A is suitable for the transport of hazardous materials.

8D8 RISK MANAGEMENT MEASURES

This route evaluation did not identify undesirable levels of risk for the suitable transport route as risk management measures required to be implemented by the material supplier and transport provider are suitable for the hazardous material being transported. Therefore, no additional opportunities for risk reduction are recommended. The risk management measures required to be implemented by the material supplier and transport provider for the transport of sulphuric acid to the Project include:

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- a vehicle used to transport dangerous goods: must be suitable for transporting the goods; and must be free of any defect that is likely to create a risk in transporting the goods (Clause 8.1.1); - a road vehicle that is transporting a placard load of dangerous goods must be covered by a policy of insurance or other form of indemnity in accordance with Clause 8.1.2; - dangerous goods must not be transported on the same vehicle with incompatible goods unless the dangerous goods and the incompatible goods: are segregated in accordance with the ADG Code; or are otherwise allowed under the ADG Code to be transported together, in accordance with Clause 9.1.1; - an emergency information holder must be securely placed on a road vehicle in accordance with Clause 11.2.4; - Table 12.1 sets out guidance on the minimum requirements for: the types of personal protective equipment (including self-contained breathing apparatus, SCBA) with which a driver of a road vehicle transporting a placard load of dangerous goods should be provided; and the safety equipment with which a road vehicle used in the transport of a placard load of dangerous goods should be equipped (Clause 12.1.1); - a road vehicle transporting a placard load of dangerous goods must be equipped with a fire extinguisher or fire extinguishers in accordance with Table 12.2; - if a road vehicle transporting dangerous goods is involved in an incident that results in a dangerous situation, the driver of the vehicle must notify the police or fire brigade and prime contractor as soon as possible in accordance with Clause 14.1.1; and - the driver of a vehicle transporting dangerous goods involved in an incident that results in a dangerous situation should also take all safe and practicable steps to carry out any emergency procedures recommended in the emergency information in accordance with Clause 14.1.1.  Drivers transporting dangerous goods by road in bulk are required to be appropriately licensed to drive the vehicle under Part 18 of the Road DGT Regulation.  Vehicles transporting dangerous goods by road in bulk are required to be licensed to transport the goods under Part 18 of the DGT Regulation.  Those undertaking any task involved in the transport of dangerous goods by road (e.g. driving a vehicle transporting dangerous goods; loading dangerous goods into or onto a vehicle, or into a container to be put in or on a vehicle; unloading dangerous goods) are required to be appropriately instructed and trained under Part 20 of the DGT Regulation.  The prime contractor and driver of a vehicle transporting dangerous goods by road that is involved in an incident resulting in a dangerous situation are required to tell the Competent Authority about the incident and give the Competent Authority a written report about the incident in accordance with Part 14 of the DGT Regulation.  Vehicles transporting hazardous materials to the Project are required to carry appropriate communication devices (such as a radio or telephone).

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8D9 REFERENCES

Bland Shire Council (1999) Section 94 Study and Plan. Prepared by Don Fox Planning Pty Ltd in conjunction with Bland Shire Council.

Centre for Chemical Process Safety (CCPS) (1995) Guidelines for Chemical Transportation Risk Analysis.

Department of Planning (2011a) Hazardous Industry Planning and Advisory Paper No. 11, Route Selection.

Department of Planning (2011b) Hazardous Industry Planning and Advisory Paper No. 6, Hazard Analysis.

North Limited (1998a) Cowal Gold Project Environmental Impact Statement (EIS) – Appendix J Traffic Impact Assessment.

North Limited (1998b) Cowal Gold Project Commission of Inquiry Primary Submission.

North Limited (1998c) Cowal Gold Project Commission of Inquiry Submission in Reply.

Pinnacle Risk Management Pty Ltd (2011) Matrix Based Risk Assessment.

Pinnacle Risk Management Pty Ltd (2018) Review comments on draft THMS Addenda for Sulphuric Acid provided by Dean Shewring in emails dated 14 June 2018 and 16 July 2018.

Roads and Maritime Services (2018) Restricted Access Vehicle (RAV) map and website link.

Resource Strategies Pty Ltd (1997) Cowal Gold Project Mine Access Road Upgrade Review of Environmental Factors. Appendix O in North Limited (1998a) Cowal Gold Project Environmental Impact Statement.

Roads and Traffic Authority (RTA) (2003) 14.6 Metre Semi-Trailers. June 2003. Cat No. 45070811B.

Roads and Traffic Authority (RTA) (2004) Information Paper and Invitation for Submissions – NSW Road Classification Review. May 2004.

State Emergency Management Committee (2012) NSW State Emergency Management Plan.

Traffix – Traffic and Transport Planners (1997) Traffic Impact Assessment of the Proposed Cowal Gold Project West Wyalong Appendix J in North Limited (1998a) Cowal Gold Project Environmental Impact Statement.

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