Wodgina Lithium Project Pipeline Licence PL116
CONSTRUCTION ENVIRONMENT PLAN – PUBLIC DISCLOSURE DOCUMENT
Proponent: Wodgina Lithium Pty Ltd Address: 1 Sleat Road, Applecross, WA 6153 Postal Address: Locked Bag 3, Canning Bridge LPO APPLECROSS WA 6153 Corporate contact: David Temple-Smith Phone: +61 8 9329 3729 Email: [email protected] 21 FEBUARY 2019
Revision History
Revision Issued Date Authorised By Purpose / Changes Number A 25 May 2018 G Barrett First draft for internal review. Release to regulator; various minor changes / corrections 0 12 June 2018 T Berryman from internal review. Various changes throughout to address responses to Rev 1 3 September 2018 D Temple-Smith 0 from DMIRS (email from Amanda Cortez dated 6 July 2017). Addresses DMIRS Notice of Decision (EARS-EP-74597) and 2 19 October 2018 David Swain accompanying email from Amanda Cortez dated 27 September 2018. 3 14 December 2018 David Swain Amend pipeline trench egress ramp conditions Update CEP to include Appendix 14 – Wodgina 2 Pipeline 4 21 February 2019 David Swain – modification to approved activity Rev 0
TABLE OF CONTENTS
1. DESCRIPTION OF THE ACTIVITY ...... 1 Background, Scope, and Purpose ...... 1 Location ...... 2 Built Asset Description ...... 2 Construction Infrastructure and Resources ...... 3 1.4.1. Mobilisation ...... 3 1.4.2. Construction Right-of-Way ...... 3 1.4.3. Ancillary Access and Work Areas ...... 4 1.4.4. Fuel Supply, Hazardous Storage, and Servicing ...... 6 1.4.5. Personnel and Accommodation ...... 6 1.4.6. Water Supply and Storage ...... 7 1.4.7. Borrow and Surplus Earth Material ...... 7 1.4.8. Waste Disposal ...... 8 1.4.9. Other Infrastructure ...... 8 Area of Disturbance ...... 9 Plant and Equipment ...... 9 Contractors ...... 11 Schedules and Hours of Operation ...... 11 Construction Works ...... 12 1.9.1. Overview ...... 12 1.9.2. Mobilisation and Site Establishment ...... 13 1.9.3. Survey and Set-Out ...... 13 1.9.4. Clear and Grade ...... 13 1.9.5. Pipe Stringing and Bending ...... 13 1.9.6. Joint Welding, Testing, and Coating ...... 13 1.9.7. Trenching and Excavation ...... 14 1.9.8. Lowering-in and Backfill...... 14 1.9.9. Special Crossings – Roads ...... 15 1.9.10. Special Crossings – Watercourses ...... 16 1.9.11. Inlet and Delivery Stations ...... 16 1.9.12. Tie-ins ...... 17 1.9.13. Hydrostatic Pipeline Testing ...... 17 1.9.14. Clean-up and Reinstatement of Work Areas ...... 17 1.9.15. Cathodic Protection, Station and Signs ...... 18 Pipeline Signage ...... 18 Commissioning ...... 19 Operations and Maintenance ...... 19 Final Decommissioning and Rehabilitation ...... 19 2. DESCRIPTION OF THE ENVIRONMENT ...... 21 Social, Economic, and Tenure ...... 21 Aboriginal Heritage ...... 22 Climate ...... 22 Biogeographic Region ...... 23 Land Systems and Soils ...... 24 Surface Water ...... 24 Groundwater ...... 25 Vegetation and Flora ...... 25 2.8.1. W2P northern envelope ...... 26 2.8.2. W2P Southern envelope ...... 27 2.8.3. Introduced Flora ...... 28 Habitat and Fauna ...... 28 2.9.1. Fauna Species of Conservation Significance ...... 29 3. ENVIRONMENTAL RISK ASSESSMENT AND MANAGEMENT ...... 30 Risk Assessment Methodology ...... 30 Identification of Sources of Risks and Their Impacts...... 30 Risk Classification and Reporting Requirements ...... 31 Environmental Management Strategies ...... 31 3.4.1. Overview ...... 31 3.4.2. Heritage ...... 31 3.4.3. Vegetation, Flora, and Habitat ...... 33 3.4.4. Fauna ...... 35 3.4.5. Soils and Land Use ...... 39 3.4.6. Water ...... 42 3.4.7. Hydrocarbons and Chemicals ...... 43 3.4.8. Wastes ...... 46 3.4.9. Fire ...... 48 3.4.10. Weeds, Feral Pests, and Diseases ...... 50 3.4.11. Dust and Emissions to Air ...... 52 3.4.12. Noise and Vibration ...... 54 3.4.13. Reinstatement and Maintenance ...... 55 4. OBJECTIVES, STANDARDS, AND MEASUREMENT CRITERIA ...... 58 5. LEGISLATION AND OTHER REQUIREMENTS ...... 65 6. IMPLEMENTATION STRATEGY ...... 69 Systems, Practices, and Procedures ...... 69 Corporate Environmental Policy ...... 69 Roles and Responsibilities of Personnel ...... 70 Training and Competency ...... 72 6.4.1. Inductions ...... 72 6.4.2. Specific Competencies ...... 72 6.4.3. Pre-start Meetings and Toolbox talks ...... 73 Monitoring, Audit, and Review ...... 74 6.5.1. Overview ...... 74 6.5.2. Daily Workplace Inspections ...... 74 6.5.3. Weekly Site Inspections ...... 74 6.5.4. W2P Audits ...... 75 6.5.5. Practical Completion Checks ...... 75 6.5.6. Environmental Monitoring ...... 75 6.5.7. Review ...... 76 Management of Non-Conformance ...... 76 Record-Keeping ...... 77 Oil Spill Contingency Plan ...... 77 7. REPORTING ...... 78 Overview ...... 78 Routine Reporting ...... 78 Contingency Reporting ...... 79 7.3.1. Reportable Events ...... 79 7.3.2. Recordable Events ...... 80 8. STAKEHOLDER ENGAGEMENT ...... 81 9. REFERENCES ...... 83 FIGURES ...... 85
LIST OF FIGURES FIGURE 1: PIPELINE CORRIDOR LOCATION ...... 86 FIGURE 2: PIPELINE LEASE AREA ...... 87 FIGURE 3: IBRA REGION / SUB-REGIONS ...... 88 FIGURE 4: ABORIGINAL HERITAGE ...... 89 FIGURE 5: LAND TENURE ...... 90 FIGURE 6: VEGETATION ASSOCIATIONS (NORTHERN & SOUTHERN ENVELOPE) ...... 91 FIGURE 7: FLORA AND VEGETATION (NORTHERN ENVELOPE – SHEET 1) ...... 92 FIGURE 8: FLORA AND VEGETATION (NORTHERN ENVELOPE – SHEET 2) ...... 93 FIGURE 9: FLORA AND VEGETATION (SOUTHERN ENVELOPE) ...... 94
LIST OF TABLES TABLE 1: KEY POINTS ...... 2 TABLE 2: DESIGN SPECIFICATIONS...... 3 TABLE 3: DEPTHS OF COVER ...... 3 TABLE 4: ANCILLARY AREA DESCRIPTION SUMMARY ...... 4 TABLE 5: ESTIMATED AREAS OF DISTURBANCE ...... 9 TABLE 6: TIMING OF WORKS ...... 12 TABLE 7: W2P CLIMATE DATA ...... 23 TABLE 8: LAND SYSTEMS WITHIN THE W2P AREA ...... 24 TABLE 9: CONSERVATION SIGNIFICANT FAUNA - LIKELIHOOD OF OCCURRENCE ...... 29 TABLE 10: HERITAGE MITIGATION STRATEGIES ...... 32 TABLE 11: VEGETATION, FLORA, AND HABITAT MEASURES ...... 33 TABLE 12: FAUNA MEASURES ...... 35 TABLE 13: SOILS AND LAND USE MEASURES ...... 39 TABLE 14: WATER MEASURES ...... 42 TABLE 15: HYDROCARBON AND CHEMICAL MEASURES ...... 43 TABLE 16: WASTES MEASURES ...... 47 TABLE 17: FIRE MEASURES ...... 49 TABLE 18: WEED AND PEST MEASURES ...... 51 TABLE 19: DUST AND AIR EMISSIONS MEASURES ...... 53 TABLE 20: NOISE AND VIBRATION MEASURES ...... 54 TABLE 21: REINSTATEMENT AND MAINTENANCE MEASURES ...... 56 TABLE 22: OBJECTIVES, STANDARDS, AND MEASUREMENT CRITERIA ...... 59 TABLE 23: REGULATION RELEVANT TO PIPELINE CONSTRUCTION ...... 65 TABLE 24: ROLES AND KEY RESPONSIBILITIES ...... 70
Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
1. DESCRIPTION OF THE ACTIVITY
BACKGROUND, SCOPE, AND PURPOSE The Wodgina mining centre sits about 95 km south of Port Hedland, in the Pilbara region of Western Australia (WA). The site has a long history of mining for a variety of minerals, including iron ore and tantalum. Wodgina Lithium Pty Ltd (WLPL), a subsidiary of Mineral Resources Limited (MRL), presently holds minerals rights to mine spodumene ore (a lithium-bearing mineral). The WLPL operations incorporate an 11 MW gas reciprocating power station, to support production of up to 0.4 million tonnes per annum (Mtpa) of ore for direct shipment. The power station is fed by an existing 80 km DN100 buried gas lateral (here referred to as W1P), connected to the Pilbara Energy Pipeline (PEPL). WLPL intends to expand operations to 0.6 Mtpa, with potential to eventually expand to 12 Mtpa. To support such production rates WLPL proposes to upgrade the power station to 52 MW, fed by an additional DN250 buried gas lateral with new inlet and delivery (outlet) stations (here referred to as W2P), running from the PEPL in parallel with the W1P. WLPL will be the operator of the W2P. The scope of this construction environment plan (CEP) is the construction of the W2P, including above-ground inlet and delivery stations, within pipeline licence (PL) 116, on mining tenements held by WLPL. This CEP briefly address commissioning, operation, and final decommissioning and rehabilitation components of the W2P; however a separate environment plan will be submitted to address commissioning and operation. This CEP excludes PEPL hot tap and piping works, to be completed by others on PL22, to facilitate connection of the W2P inlet station. The purpose of this CEP is to: Document the risks to the environment from the works within its scope, as identified and assessed by WLPL, and the measures proposed to reduce each risk to a level that is considered ‘Acceptable and As Low as Reasonably Practicable (ALARP), in accordance with the Guideline for the Development of Petroleum and Geothermal Environment Plans in Western Australia (November 2016) [1] (EP guidelines). Support environmental approval for the works within its scope, as required under the Petroleum Pipelines Act 1969 (Pipelines Act) and Petroleum Pipelines (Environment) Regulations 2012 (Pipeline Regulations), as administered by the Department of Mines, Industry Regulation, and Safety (DMIRS). WLPL has obtained/applied for separate approvals for the power station upgrades and other aspects of the expansion of the Wodgina mining operations, as required under the Mining Act 1978 (Mining Act), Environmental Protection Act 1978 (EP Act), and other relevant legislation, as addressed in Section 5. Any enquires related to this CEP should be directed to:
Proponent: Wodgina Lithium Pty Ltd Address: 1 Sleat Road, Applecross, WA 6153 Postal Address: Locked Bag 3, Canning Bridge LPO APPLECROSS WA 6153 Contact: David Temple-Smith Phone: +61 8 9329 3729 Email: [email protected]
ENV-TS-RP-0091 Page | 1
LOCATION A “hot tap” will be installed by others about 40 km southwest of Port Hedland (approximate PEPL kilometre point [KP] 182), and piping extended to the PEPL easement boundary, to facilitate connection of the W2P inlet station on PL116. The buried W2P will then run southeast for approximately 80 km (79.95 km) to the delivery station at the Wodgina mine site, about 95 km south of Port Hedland. The W2P on PL116 will run parallel to the W1P on PL55 and PL56. An overview of the location and layout of the W2P is shown in relation to tenure and local features in Figure 1 to Figure 5, with a detailed layout shown in relation to sensitive environmental features provided in Error! Reference source not found.. Table 1 provides the start and end point description for the W2P. As indicated in Figure 1, the W2P route is effectively straight, except for a slight deviation near the Wodgina mine site to avoid steep topography. The location of the W2P in relation to significant or sensitive environmental or social features, and potential for impacts on these features, is addressed in Section 2.
Table 1: Key Points
MGA94 Zone 50 Description Easting Northing Start: PEPL inlet station (W2P KP0.00, PEPL KP182) 633,446 7,725,579 End: Wodgina delivery station (W2P KP79.95) 673,881 7,657,773
BUILT ASSET DESCRIPTION The W2P comprises an 80km DN250 buried gas pipeline, with above-ground inlet and delivery stations and an above-ground Cathodic Protection station. The general arrangement drawings of the inlet and delivery stations are provided in Error! Reference source not found. (drawing nos. 2048-EG-GAR-001 and 2048-EG-GAR-001). The pipeline inlet and outlet facilities are designed for a maximum allowable operating pressure (MAOP) pre- pressure regulation of 10.2 MPa(g) and post-pressure regulation of 6.2 MPa(g) at 60°C (American Society of Mechanical Engineers Class 600). The pipeline is designed for an operating life of at least 40 years, consistent with the expected life of the Wodgina operations. To ensure that the asset achieves its design life, WLPL will implement a comprehensive integrity management program incorporating regular inspections. Towards the end of the pipeline’s design life, WLPL will review the history of integrity inspection reports, repairs, cathodic protection, and coating condition, as part of a comprehensive engineering assessment to determine whether and how far the life of asset can be safely extended. Key design specifications for the W2P are summarised in Table 2. The pipeline will be buried to provide minimum depths of cover consistent with the requirements of AS2885.1, as summarised in Table 3. A safety management study by OSD Limited (OSD) (2048-EG-REP-001) confirms that the appropriate depths of cover have been adopted in the design of the W2P.
Table 2: Design Specifications
Aspect Specification Design life 40 years, with possible extension subject to contracts and engineering study. Maximum design capacity 0.49 million standard m3/ day. Maximum allowable operating pressure 10.2 Mpa Design temperature (maximum) 60 ºC Design temperature (minimum) 0 ºC Pipeline outside diameter 250 mm Pipe wall thickness 6.35 mm (standard), 7.80 (heavy wall) Pipeline material Carbon steel Pipeline depth of cover 750 to 1200 mm depending on location; conformant to AS2885.1 (Table 3).
Table 3: Depths of Cover
Location Type Minimum Depth of Cover (mm) Remote rural (class R1) 750 Remote rural, industrial (class R1-I) 900 Road or river crossings 1,200
CONSTRUCTION INFRASTRUCTURE AND RESOURCES
1.4.1. Mobilisation W2P construction personnel will generally mobilise by air via Port Hedland airport, and then by bus or light vehicle via the Great Northern Highway to the Wodgina mine site. Personnel will travel to and from their worksites each day by crew buses or light vehicles. Equipment and materials will be mobilised by road, and mostly brought to existing parking and laydown areas at the Wodgina mine site via the Great Northern Highway, with some equipment and materials brought to a temporary laydown area the inlet station via the Northwest Coastal Highway.
1.4.2. Construction Right-of-Way A construction right-of-way (CROW) will be cleared and graded to provide construction access along the pipeline corridor. Appendix 2 provides the typical arrangement of the W2P CROW, with specific reference to drawing no. 2048-EP-DTL-001. The CROW will generally be 30 m wide, considered optimum to accommodate construction equipment, stockpiled topsoil, and excavation spoil, with enough room to allow safe movement of vehicles and construction personnel. The CROW can, however, be reduced to 20 - 25 m where appropriate to minimise impacts to third party infrastructure, or places of particular environmental or social significance. Interim gaps may be left in the CROW, to minimise disruption to any third-party routes such as pastoral or mine site tracks that cross the pipeline corridor, or where special crossing techniques (discussed below) are necessary. Third-party crossing requirements will be determined through consultation with land title holders and other relevant stakeholders, as addressed in Section 8. The CROW will be reinstated (ie. rehabilitated) at the completion of pipe-laying, except for a 4 m single-lane track to provide ongoing access to the pipeline corridor for inspections over the life of operations.
1.4.3. Ancillary Access and Work Areas The W2P construction works will, as far as practicable, use existing public and third-party roads and tracks to access the CROW, including the Great Northern Highway, Northwest Coastal Highway, and mine site and pastoral tracks. Agreements for access and use of tracks (including any maintenance or upgrade requirements) will be negotiated with third party title holders. The W2P construction works will make best practicable use of existing laydown, storage, and parking areas at the Wodgina mine site. Additional laydown, storage, and turn-around areas will be cleared and graded adjacent to the CROW as per Table 4, to facilitate efficient movement of equipment and materials. Ancillary turnaround and passing bays will be cleared and graded adjacent to the CROW at intervals along the pipeline corridor to facilitate pipe deliveries and other vehicle movements, and mitigate the need for additional access tracks. Turnaround and passing bays will typically be established at intervals of approximately 2 to 10 km, depending on distances to access points, and will have an approximate footprint of 20 x 20 m (0.04 ha). Ancillary work areas for spoil storage will be established at crossings, with approximate footprint dimensions of 40 - 60 m x 100 – 200 m (0.40 ha to maximum of 1.2 ha). This strategy of establishing designated spoil storage areas eliminates the requirement to stockpile spoil adjacent to the open trench, which if undertaken has the potential to create operational constraints and increased safety hazards in terms of access while the trench is open, due to the spoil being stored on the crossing. The ancillary work areas, as listed in Table 4 are included in the W2P disturbance estimates, as set out in Section 1.5. Indicative locations of these ancillary work areas are provided in Error! Reference source not found. (NOTE: minor adjustments to these locations may be required as part of final set-out due to operational reasons and/ or to minimise impacts). Ancillary work areas will be sited to minimise environmental impact (avoiding native vegetation, drainage lines, key habitats, etc.), in line with the requirements of this CEP and any other relevant regulatory and landholder approvals. Temporary access tracks, turnaround and passing bays, laydown and parking areas, and other temporary construction workspaces will be rehabilitated as construction works are completed, except where required for ongoing pipeline operations.
Table 4: Ancillary Area Description Summary
Description Footprint Dimensions (m) Approximate Location (KP) Turn In/turn out - 2x Right Angles 20m x 20m Triangle 4.85 Turn In/turn out - 1x Obtuse, 1x Acute 20m x 20m Triangle 8.24 Turn In/turn out - 2x Right Angles 20m x 20m Triangle 13.93 Turn In/turn out - 2x Right Angles 20m x 20m Triangle 18.49 Turn In/turn out - 2x Right Angles 20m x 20m Triangle 22.35 Turn In/turn out - 1x Obtuse, 1x Acute 20 m x 20 m Triangle 27.95 Turn In/turn out - 1x Obtuse, 1x Acute 20 m x 20 m Triangle 35.74 Turn In/turn out - 2x Right Angles 20 m x 20 m Triangle 43.44 Turn In/turn out - 1x Obtuse, 1x Acute 20 m x 20 m Triangle 49.13 Turn In/turn out - 1x Obtuse, 1x Acute 20m x 20m Triangle 56.61 Description Footprint Dimensions (m) Approximate Location (KP) Turn In/turn out - 2x Right Angles 20 m x 20 m Triangle 62.61 Turn In/turn out - 1x Obtuse, 1x Acute 20 m x 20 m Triangle 66.61 Turn In/turn out - 2x Right Angles 20 m x 20 m Triangle 76.32 CROW Turn arounds 25 m x 15 m 16.00 CROW Turn arounds 25 m x 15 m 16.30 CROW Turn arounds 25 m x 15 m 20.37 CROW Turn arounds 25 m x 15 m 25.57 CROW Turn arounds 25 m x 15 m 30.86 CROW Turn arounds 25 m x 15 m 32.96 CROW Turn arounds 25 m x 15 m 38.07 CROW Turn arounds 25 m x 15 m 40.44 CROW Turn arounds 25 m x 15 m 45.90 CROW Turn arounds 25 m x 15 m 46.18 CROW Turn arounds 25 m x 15 m 52.11 CROW Turn arounds 25 m x 15 m 54.38 CROW Turn arounds 25 m x 15 m 59.71 CROW Turn arounds 25 m x 15 m 69.59 CROW Turn arounds 25 m x 15 m 72.68 EWS adjacent to CROW (for spoil) 60 m x 160 m 75.65 - 75.75 EWS adjacent to CROW (for spoil) 50 m x 160 m 76.00 - 76.25 EWS adjacent to CROW (for spoil) 40 m x 110 m 77.40 EWS adjacent to CROW (for spoil) 40 m x 80 m 77.80 EWS adjacent to CROW (for spoil) 30 m x 170 m 79.34 - 79.585 Access Road 15 m x 50 m 78.65 EWS adjacent to CROW (for spoil) 40 m x 190 m 79.65 - 79.92 Turkeys Nest 120 m x 60 m 43.25 Radio tower site 25 m x 25 m (within CROW) 16.00 Radio tower site 25 m x 25 m (within CROW) 45.90 Radio tower site 25 m x 25 m (within CROW) 76.00
1.4.4. Fuel Supply, Hazardous Storage, and Servicing The W2P construction works will primarily use either the existing licensed bulk diesel storage facility at the Wodgina mine site or a commercial laydown area in Port Hedland for fuel supply; plant and vehicles. Fuel trucks and/or trailers (carrying up to 12,000 L diesel) will fill up at the bulk diesel facility and travel the CROW daily, to refuel vehicles and plant where return to the mine site or the commercial laydown area is impractical; however vehicles and plant will refuel at the mine site, or commercial laydown area, whenever practical to do so. Jerry cans (up to 20 L) may also be brought into construction areas to supply diesel power generators. Construction vehicles may use commercial fuel stations at or near Port Hedland, particularly for works at the northern end of the CROW and inlet station. Other hydrocarbon and chemical storage for the W2P will incorporate: Engine, gearbox, hydraulic and other oil and greases, in a variety of containers typically including 1,000 L intermediate bulk containers (IBCs), 200 L drums, and 20 L containers. Various other chemicals for construction use, including brake and radiator fluids, paints, concrete retarders, formwork release agents, paints, solvents, thinners, acetone, antiseize, cleaning agents, and others, in containers of less than 50 L. Hydrocarbon and chemical storage will make use of existing bunded storage at the Wodgina mine site or the commercial laydown area, as far as practicable, with additional transportable temporary self-bunded hazardous storage established where necessary. Disposal of waste oil and contaminated materials will make use of existing and temporary facilities at the Wodgina mine site, as addressed in Section 1.4.8. Storage of hydrocarbons and hazardous chemicals along the CROW will generally be avoided where practicable. Portable minor temporary self-bunded hazardous storage (such as spill pallets) will be established along the CROW and at the inlet station site where necessary. Service trucks, carrying intermediate-bulk quantities of oil, grease, and coolant, will travel the CROW daily, to service vehicles and plant where return to the mine site is impractical; vehicles and plant will however return to the existing approved workshops at the Wodgina mine site or commercial laydown area for servicing whenever practical to do so, and particularly for major servicing. Risks to the environment associated with storage, handling, and use of fuels and other hydrocarbons and hazardous chemicals, and measures proposed to reduce those risks, are addressed in Section 3. A specific oil spill contingency plan (OSCP; which also deals with other hydrocarbons and hazardous chemicals) for the W2P construction works is addressed in Section 6.8.
1.4.5. Personnel and Accommodation WLPL expects that an average workforce of about 100 persons will be employed on site for the W2P construction works, with a peak workforce of about 150 persons. Crews and personnel will be progressively mobilised as work ramps up, and progressively demobilised as work winds down. WLPL intends that the workforce will comprise local and WA residents as far as practicable. No new temporary accommodation will be required for the W2P construction works; W2P personnel will mostly be accommodated at the established Wodgina mine workers’ village, with some use of commercial accommodation at or near Port Hedland for personnel working on the inlet station and the northern end of the pipeline corridor.
1.4.6. Water Supply and Storage Water required by the W2P construction works, for dust suppression and other minor related purposes (e.g. rinse water and hydrostatic testing (Section 1.9.13)) will be supplied from licensed bores. WLPL does not expect that any new abstraction bores or increase in allocations will be required to meet W2P water demands, but will if necessary seek appropriate approvals (Section 5). No surface water will be taken. Expected project water demand will be approximately 20,000 kL, and mainly comprise: up to about 17,400 kL (150-220 kL/day) for dust suppression and other minor related purposes including rinse water over the course of construction works. about 2,600 kL (one off volume) for hydrostatic testing. Water for dust suppression will be taken to construction areas by water carts. Water from WLPL bores is fresh to brackish, and considered suitable for dust suppression. To minimise water haulage WLPL is investigating other licensed third-party sources of water along the pipeline route and, subject to the water being of suitable availability and quality, will negotiate agreements for supply with licence holders. WLPL or the construction contractor will if necessary help the relevant licence holders to obtain permits to construct new bores and/or amend their water licences to permit such supply and use (Section 5). A temporary “turkey’s nest” dam will be constructed to hold water part-way along the pipeline route. Design specifications for the dam are provided in Appendix 2 and include: a footprint of 60 m long x 50 m wide, with construction/maintenance access surrounding the dam and connecting it to the CROW a maximum depth of 1.5 m total storage volume of 2,615 kL freeboard minimum of 500 mm from crest of dam dam to be lined with 0.5 mm HDPE or similar impermeable material to prevent seepage facility to be fully fenced and fitted with fauna egress matting. The indicative location of the turkey nest dam is at KP43, as shown in Appendix 1. As with other ancillary work areas, minor adjustments to this location may be required for operational reasons, or to minimise impacts in line with the requirements of this CEP, other regulatory approvals, or landholder agreements. The dam will not be located within sensitive environmental and cultural areas, inclusive of heritage areas, drainage lines, significant habitat for threatened and priority listed fauna and Public Drinking Water Source Areas (PDWSA). The quality of the water to be stored within the dam is expected to be similar to Wodgina North Borefield, which is fresh and slightly alkaline (pH 7.5-9). Water salinity is expected to be around 600 mg/L Total Dissolved Solids (TDS). Cations are dominated by sodium with lesser magnesium and calcium. Drinking and ablution water for construction personnel will be supplied at the Wodgina mine workers’ village under its existing licensed allocation, or at other accommodation used by the W2P.
1.4.7. Borrow and Surplus Earth Material WLPL expects that “borrow” materials such as sand for trench padding (Section 1.9.8) or gravel for road base will generally not be required for W2P construction works, and no new borrow pits or quarries are proposed. Some borrowed fill material may be required to build up a pad for the delivery station as part of the power station expansion however this will be addressed under a separate Mining Proposal application, if required (Section 5). Minor volumes of aggregate may be imported, to be laid down around the inlet and delivery stations, to prevent vegetation regrowth and maintain a firebreak. Any imported material will be from a local source, certified as clean and free of weeds. WLPL also expects that no substantial quantities of surplus material, such as excess trench spoil, will be left from construction works and require disposal. Moved earth will generally be returned to its original location, and natural ground contours largely reinstated at completion of construction. Note: Excavated spoil material that is not suitable for placement within the pipeline trench (ie. large fractured rock fragments) will be relocated to areas within the construction right-of-way (CROW), with this material to be utilised appropriately as part of reinstatement activities. No spoil material will be removed from the Pipeline Licence (PL) 116 boundary.
1.4.8. Waste Disposal Solid wastes from pipeline construction are expected to comprise: inert waste, including packaging, wooden pallets, steel (e.g., pipe off-cuts), used formwork, welding rods, rubble, and minor quantities of waste concrete putrescible waste, predominantly food scraps small quantities of contaminated waste, including fuel, oil, and chemical containers with residual material, and coating / sand blasting wastes (including used garnet, plastic, and coating residues). The W2P construction works will use existing waste management and disposal facilities at the Wodgina mine site as far as practicable, including waste oil and contaminated waste facilities at the mine site workshops. Additional temporary waste collection and containment facilities, including storage areas, bins and skips will be established as necessary for pipeline construction wastes. Inert and putrescible wastes will be taken to the existing landfill facility at the Wodgina mine site, which is licensed for disposal of general inert and putrescible wastes. Scrap and other clean recyclable materials will be segregated for collection and disposal off-site, as will contaminated or potentially contaminated wastes. W2P construction personnel will largely use the existing ablutions at the Wodgina mine site, with wastewater treated by the existing licensed treatment plant. Transportable toilets will be made available on the CROW (moved along with the work front), and at the inlet station. These toilets will be emptied by a contractor for treatment and disposal at a licensed facility. Minor quantities of concrete will be prepared on site for formwork at the inlet and delivery stations; consequently, there will be little waste water from rinsing concrete mixers. Minor volumes of rinse water will be captured within a lined waste water sump, with contaminated water to be collected via a vacuum tanker and disposed of at a licensed waste facility. Waste management arrangements for the W2P, and measures proposed to reduce risks to the environment from pipeline construction wastes, are discussed in greater detail in Section 3.4.8.
1.4.9. Other Infrastructure The W2P construction works will make best practicable use of other existing facilities at the Wodgina mine site, including vehicle wash down, power supply, medical clinic, and communications. Some additional temporary facilities will be established at the mine site or commercial laydown area in Port Hedland, including: shipping containers for storage of tools, equipment, and materials, and demountable offices and crib rooms. Some minor temporary facilities will be established within the W2P corridor and at the inlet station, including transportable diesel power generators and communications towers. AREA OF DISTURBANCE The estimated total area of disturbance for the construction and operational phases of the W2P are 247.55 ha and 32.30 ha respectively, with a breakdown of the key disturbance elements provided in Table 5. At this time, WLPL assumes that all W2P disturbance shown will be new disturbance, but will use previously disturbed areas where practicable. The exact locations of access tracks, turnaround and passing bays, laydowns and other ancillary disturbance remains to be confirmed with the construction contractor (once selected), but will satisfy the requirements of this CEP, including avoidance of environmentally or socially significant or sensitive features. The CROW comprises the majority (97%) of the disturbance area required for pipeline construction. Approximately 88 % of the disturbance area will be reinstated and rehabilitated at the completion of construction, with approximately 32 ha to remain open for the life of pipeline operations. These open areas will include above-ground stations and a 4 m wide access track for maintenance along the pipeline corridor. On decommissioning of the W2P, all remaining open areas including the operational access track will be decommissioned and rehabilitated as per the management actions stated in the Wodgina Mine Closure Plan. WLPL was granted Clearing Permit CPS 8068/1 on 11 October 2018 to allow for clearing of native vegetation for construction of the W2P, as addressed in Section 5. Measures proposed to control clearing and minimise associated risks and impacts to the environment are addressed in Section 3.4.3.
Table 5: Estimated Areas of Disturbance
Disturbance Area (ha) Disturbance Description Construction Operations CROW 240.7 32.301 Inlet Station 0.13 0.10 Delivery station 0.69 0.202 Access roads (turn in / turn out) 1.10 0.00 Turkey nest dam 0.75 0.00 CROW turn-around/ passing bays 0.48 0.00 Extra spoil stockpile areas 3.70 0.00 Communication towers 0.373 0.00 Total 247.55 32.30
PLANT AND EQUIPMENT WLPL is not able at time of this submission to provide a complete, detailed list of construction plant and equipment, as the construction contractor will require a degree of flexibility to select and change equipment as required, and dependent on practical considerations such as availability. WLPL will regardless require all plant and equipment to meet the requirements of this CEP.
1 Operations access track 4 m wide x 80 km long 2 Facility footprint of 27 m x 60 m, with 5 m firebreak 3 Communication towers to be installed within CROW – no additional ground disturbance required WLPL expects vehicles, plant, and equipment for the W2P construction works to include: Clearing and earthmoving equipment, including bulldozers, graders, excavators, backhoes, trench diggers, front-end loaders and bobcats. Side-booms, for lifting and lowering-in pipe strings, and other lifting equipment, including pipe lifters, cranes, and forklifts. Welding and pipe joint coating rigs. Screening plant (padding machines) and rollers/ compactors for trench backfilling. Various heavy rigid vehicles including water trucks, service trucks, and crew buses, and four-wheel drive light vehicles, including wagons and utilities. Fixed plant and equipment, including generators and electrical equipment, sea containers and other storage facilities, storage tanks (water, fuel, oil, etc.), and air compressors. In the event underlying rock material is located during trenching operations, a percussion air track drill rig will be utilised to assist in the fracturing of this material, with conventional excavation equipment to be utilised to remove this material from the trench. General specifications of the percussion air track drill rig are as follows: Drill is a fully self-contained drill carrier D-4 type track assembles with 15-inch triple-bar grousers Prime mover - Electronic diesel engine Hydraulic system: consists of 3 hydraulic pumps driven by the prime mover thru an elastic coupling to the pump drive gear box Compressor - driven by a piston hydraulic motor Extendable telescopic boom and 12-inch feed system, with large wear plates and all externally mounted cylinders Heavy duty construction and low centre of gravity – highly stable drilling platform Overlapping track pads and track frame with a =/- 8% oscillation provide positive ground contact when tramming over rough terrain. The use of a percussion drill rig will not require the use of drill fluids to facilitate the drilling of these holes. In the event of a hydraulic and/or fuel spill during trenching activities: • Drilling will be suspended immediately • Location of spill will be secured and fluid cleaned up • Spill kits to remain onsite to facilitate an immediate response to any incident.
For additional information on the use of a percussion drill rig for fracturing rock located within the pipeline trench, refer to Appendix 14. WLPL will notify DMIRS if it intends to use any vehicles, plant, or equipment that are not substantially described by this CEP, and that materially alters any environmental risks. Prior to this change, the CEP may require amendment and re-submission to DMIRS (Petroleum Branch) for review and approval. As noted in Section 0, vehicles, plant, and equipment along the CROW will be refuelled and serviced by mobile fuel trucks/trailers and service trucks, but will be returned to the Wodgina mine site or commercial Laydown area for refuelling and servicing where practical to do so. CONTRACTORS WLPL has selected Nacap Australia Pty Ltd (NACAP) as the construction contractor for the works within the scope of this CEP. As addressed in Section 6, NACAP has substantial experience in similar projects, a history of satisfactory environmental outcomes, and appropriate management systems. Sub-contractors will be subject to similar screening. Pipeline services provider OSD Limited (OSD) has assisted WLPL with the concept development, feasibility studies, and detailed design for the W2P, and will continue to assist with project execution and management. OSD has extensive experience with substantial pipeline projects in Western Australia, and in Australia generally.
SCHEDULES AND HOURS OF OPERATION WLPL intends that, subject to final design, approvals, and commercial, access, and other agreements, construction works will begin in November 2018, and be practically complete, ready for commissioning and operations in March 2018. The W2P traverses generally open country with little variation of consequence to construction methods; therefore WLPL expects that the pipeline will be largely constructed with a single “mainline” construction “spread” of crews (from survey and clear and grade, to backfill and reinstatement), working from the inlet station at the PEPL connection towards Wodgina. Separate specialist crews will work concurrently on construction of the inlet and delivery stations (Section 1.9.11), and special crossings (Section 0). The W2P disturbance area will be progressively reinstated (except for operations access) as pipe laying is completed; special crossings will be reinstated as they are completed, or as part of mainline reinstatement. Other work areas will be progressively reinstated as they are no longer needed, or as part of a final campaign of works at practical completion of construction (Section 1.9.14). Construction works will generally be limited to daylight hours (nominally 6 am to 6 pm). Some limited late or night works will be necessary, particularly where works cannot practicably be suspended such as hydrotesting (Section 1.9.13), special crossings (Section 0), or line pipe completion works. Some equipment may be moved, refuelled, or serviced outside of normal working hours, for which special measures, such as reduced speed limits (20 km/h at night) and lighting will be put in place. WLPL expects that the construction workforce will work a typical industry roster of 28 days on, 9 days off; rosters and breaks may overlap to some extent between crews. If necessary, a skeleton staff may be retained on site for construction breaks, to attend to routine inspections and other tasks. The timing of works under this CEP, and environmental or social considerations, are summarised in Table 6. Risks related to the timing of works, and measures to reduce such risks, are addressed in Section 3.
Table 6: Timing of Works
Aspect Timing Construction Construction November 2018 to Location near Pilbara coast with higher threat of cyclones bringing intense period February 2019 rains (Section 2.3) that may flood excavations and drown trapped fauna, cause erosion and sediment transport on cleared areas, or flood containment bunds and carry contaminants. The works will be conducted in 2 distinct phases, which are (1) before December 2018 and (2) works commencing in mid-January 2019. All trench works undertaken prior to December 2018 will backed filled and left in suitable condition prior to the Christmas break so as to eliminate any danger to fauna and potential water ingress from flooding. The balance of trenching will recommence in early January 2019 and is expected to be fully completed in February 2019. Fauna activity in Pilbara tends to increase over summer months, with increased risk of entrapment in excavations or collision with vehicles; works will however be complete or largely complete by early summer. High temperatures and arid conditions in Pilbara in spring / early summer (Section 2.3) may present high risk of fires from hot works, such as welding or cutting pipe. Construction 3 months4 Vegetation and habitats will be progressively restored as construction is duration completed; temporary nature of disturbance will reduce impacts on vegetation, habitats, soils, and seed bank, and support good rehabilitation outcomes. Hours of Daylight, with Little requirement for artificial lighting with potential to disturb or confuse work limited exceptions fauna; lower risk of vehicle collisions with fauna that tend to be more active at night. Low risk of disturbing neighbouring residences regardless, due to remote location of the W2P area. Rosters 28 days on, 9 days Adequate skeleton crew to be left on site during construction breaks to fulfil off environmental management obligations (e.g. trench fauna inspections) and/or site left safe (e.g. no trench left open over break).
CONSTRUCTION WORKS
1.9.1. Overview The W2P will be constructed by a dedicated pipeline crew using recognised industry construction methods and equipment, as set out in the W2P scopes of work, specifications, drawings and approved procedures, in accordance with AS 2885.1 Design and Construction of Petroleum Pipelines Section 10, and any conditions of W2P approval, including the conditions of the pipeline licence (PL116), and commitments made under this CEP. Construction will generally be sequential, commencing with mobilisation and establishment, and progressing to survey, clear and grade, stringing, bending, welding, trenching, non-destructive testing (NDT), field joint coating, padding, lower-in, backfill, restoration and hydrostatic testing, as set out in the following sections.
4 Although, as the workfront is moving, duration of works and disturbance in any one location on the pipeline corridor will generally be substantially less. 1.9.2. Mobilisation and Site Establishment Personnel and equipment will be progressively mobilised to the W2P, and temporary infrastructure including laydown and parking areas, storage facilities, and offices established at the Wodgina mine site or a commercial laydown area, as described in Section 1.4, using existing infrastructure and disturbed areas to the extent practicable. Laydown areas will also be established at the inlet and delivery stations, following survey, set-out, clearing, and grading, as described below.
1.9.3. Survey and Set-Out The pipeline centreline will be surveyed well ahead of ground-disturbing construction works. The limits of the CROW, any ancillary workspaces (such as passing bays or laydown areas), and any exclusion (“no-go”) areas (Section 3.4) will be surveyed and marked out just ahead of ground-disturbing works. Boundaries will be marked using markers (pegs) that will be retained until reinstatement is complete. The surveyors will also identify and mark out any special features, such as foreign service crossings and gaps to be left in the CROW.
1.9.4. Clear and Grade Pre-clearance fauna surveys for Bilby and Mulgara will be undertaken, focussing on the identification of burrows. Where individual animals cannot be displaced (i.e. encouraged to move on their own, with the burrow destroyed once confirmed as no longer active), they will be captured and relocated. Following survey and set-out, vegetation will be cleared from and pushed to the side of the CROW and other construction areas using bulldozers. Topsoil will be stripped to a minimum depth of 150 mm and then pushed into windrows at the side of the cleared areas. Topsoil windrows will be adjacent to, but separate from, the stockpiled vegetation, where it will not be disturbed by construction works and vehicle movements. The cleared CROW will be graded to achieve a suitable grade for pipe laying, while minimising disruption to natural drainage. The pipe centreline will be marked out to guide pipe assembly and trench excavation. Signs such as speed limits, traffic directions, and other safety or environmental instructions will be installed as clear and grade progresses along the CROW. Risks to the environment from clear and grade works, in particular to vegetation and habitat, and measures proposed to control disturbance and minimise such risks, are addressed in Section 3.
1.9.5. Pipe Stringing and Bending Pipe will be delivered to the CROW in segments of 18 m, to be laid out end-to-end alongside the trench line, in “strings” typically of about 1 km or less; short gaps will be left between pipe strings to allow construction access, as well as movement of livestock or larger native fauna. Additional gaps will be left at access points or crossings as appropriate. Pipe segments will be placed on timber skids or sandbags to protect them from damage, and to facilitate welding. Some pipe segments will need to be bent, to allow the pipeline to follow its corridor, and/or conform to the terrain. Pipe segments may be supplied bent, or may be ‘cold bent’ on the CROW using hydraulic bending equipment.
1.9.6. Joint Welding, Testing, and Coating Pipe segments will be welded into their strings; welded joints will be examined visually and using non- destructive, automated ultrasonic testing, to confirm conformance to AS2885.2 Pipelines - Gas and Liquid Petroleum - Welding. Joints passing inspection will be blasted with garnet to remove surface scale and rust, then coated with primer, taped over, and wrapped, to prevent joint corrosion. 1.9.7. Trenching and Excavation A trench (approximately 0.6 m wide) will be excavated for the pipeline using a combination of special trenching machines and excavators as appropriate, to a depth ranging from 1,110 mm to 1,660 mm, to provide the minimum required depth of cover at each location as per AS2885. Gaps (“trench plugs”) will be left in the trench at appropriate locations so to align with gaps left between pipe strings; the ends of each trench segment will be left ramped (300) to allow livestock and larger native fauna to escape. Spoil from the trench will be placed on the CROW to the “nonworking” side of the trench (Error! Reference source not found. 2, drawing no. 2048-EP-DTL-001), out of the way of construction equipment and traffic on the “working” side, and separate from stockpiled vegetation and topsoil. In additon, ancillary spoil areas will be constructed at crossings (Section 1.4.3). WLPL does not expect any blasting or dewatering of open trench or other excavations to be necessary. Excavators with rock-breaking tools may be used in harder ground. As indicated in Section 1.6, WLPL may utilise a self-contained hydraulic track drill to assist in fracturing of harder ground encountered during the excavation process, with this equipment not requiring the use of drill fluids to facilitate the drilling of these fracture holes. The drill rig will be positioned over the pipeline trench, with one track located on each side of the trench. The drill rig will straddle the trench and position itself across the trench via established plugs within the identified section of pipeline. Appropriate measures will be implemented to ensure these activities are safely undertaken. Fractured granite material on completion of drilling activities will be removed using standard excavation equipment. Excavated spoil material that is not suitable for placement within the pipeline trench (ie. fractured rock) will be relocated to areas within the construction right-of-way (CROW), with this material to be utilised as part of reinstatement activities. No fractured rock material will be relocated outside of the PL116 boundary. Risks to the environment from open trench and other excavations, in particular to fauna, and measures proposed to minimise such risks, are addressed in Section 3.
1.9.8. Lowering-in and Backfill Assembled pipe strings will be lowered into the trench by special “side-boom” pipe-laying vehicles. The pipe string will be “holiday” (electrically) tested during lowering-in, to detect any coating defects that may occur; any defects will be repaired before lowering-in is completed. Fine bedding and padding material will be placed around the pipe, to prevent any hard or sharp objects (such as rocks or debris) in backfill causing damage to the pipe coating. WLPL expects that stockpiled trench spoil screened in place will supply adequate fine bedding and padding material for the W2P, therefore negating the requirement to bring in material from another source. Once the pipe is adequately padded, the remainder of the trench spoil will be returned to the open trench, to reinstate the natural ground level. WLPL expects that all spoil will be returned to the trench, with minimal surplus material. Temporary ramped “bell-holes” may be left open at the end of pipe strings to allow access to the pipeline for completion of tie-ins (Section 1.9.11).
1.9.9. Special Crossings – Roads The W2P intersects several minor third-party (pastoral or mine site) access tracks that WLPL intends to cross with conventional mainline open trench; works will be arranged (such as providing gaps in pipe strings, open trench, and spoil stockpiles) and scheduled in consultation with relevant landholders to minimise disruption to traffic. The W2P will cross infrastructure including: Northwest Coastal Highway (at KP13.8). Mt Dove mine access road (at KP43.5). Third party asbestos concrete lined (ACL) concrete pipelines. PDWSA (Yule River) borefield pipeline (KP4.8). To prevent disruption to traffic, WLPL expects to use trenchless horizontal directional drilling (HDD) methods at these crossings. Entry and exit pits (typically 3 x 3 x 3 m) will be excavated at either side of the bored crossings within the CROW (no separate drill pad will be required). A specialised HDD rig will drill a borehole under the crossing, from entry pit to exit pit. A prefabricated pipe string will then be pulled through the hole to span the crossing. The entry and exit pits will be left open for up to 7 days until the tie-ins with the mainline pipe strings are complete (Section 1.9.12 for details of tie-ins). To facilitate closure of the entry and exit pits within this timeframe, the tie-ins may be moved away from the road or asset and the pits backfilled. The entry and exit pits will be fenced and ramped (30⁰) for access/egress, and inspected for fauna. The typical arrangement of an HDD crossing is provided in Appendix 2 (drawing no. 2048-EP-DTL-005). Bentonite non-hazardous clay) is used as a drilling fluid, recirculated through transportable tanks and/or captured in the entry and exit pits, for appropriate disposal at completion of the crossing works. Drilling fluid will be captured at the entry and exit pits using either of the following methods: Pumped from the entry/exit pits to an adjacent sump then removed using a vacuum excavation truck and disposed at licensed waste facility. Pumped directly from the entry/exit pits to a vacuum excavation truck for disposal at a licensed waste facility. In the event that sumps are required, these sumps will be constructed within the CROW having approximate dimensions of 2 m x 2 m x 2 m. The sumps will be fenced, ramped for access/egress and inspected for fauna. The estimated volume of drilling fluid required for the two road crossings is 8,000 L and 10,000 L respectively, and 10,000 L for the pipeline crossing. Drilling fluid levels and pressure will be monitored during the drilling process to ensure that losses to ground are minimised. A spotter will be in place throughout the drilling program to identify anomalies. In the event of substantial loss of drilling fluid: Drilling will be suspended immediately and the cause investigated. Location of spill will be secured and fluid cleaned up using vacuum excavation, if required. Spill kits to remain onsite to facilitate an immediate response to any incident.
Environmental risks associated with HDD works and measures to reduce such risks, including management of drilling fluids and reinstatement, are addressed in Section 3. Each HDD crossing will be subject to a specific HDD procedure, prepared by the HDD contractor for approval by WLPL, and incorporating the environmental management requirements of this CEP.
1.9.10. Special Crossings – Watercourses The W2P intersects several minor, weakly defined, ephemeral drainage lines near the Wodgina mine site, but no substantial watercourses. Stream flows in the region are rare, except after high rainfall events, which the construction schedule intends to avoid. The local climate and hydrological setting, and potential for stream flows, are discussed in Section 2. Minor drainage lines will be crossed by conventional mainline open trench methods, with no requirement for specific crossing procedures, special construction methods (e.g. trench dewatering or stream diversions), or special reinstatement methods (egg. stabilisation with imported rock). Particular attention will be given at drainage line crossings to erosion and sediment control, and restoration of natural contours and surface water flows. As noted in Section 1.3, additional minimum depth of cover will be applied over the pipeline at drainage lines, in accordance with AS 2885.1. The typical arrangement of a watercourse crossing is provided in Error! Reference source not found. 2 (drawing no. 2048-EP-DTL-004). Environmental risks associated with surface water flows, such as erosion of disturbed surfaces, and transport of sediments, and measures proposed to reduce such risks, are addressed in Section 3.
1.9.11. Inlet and Delivery Stations The inlet and delivery stations, as described in Section 1.3, will remain as above-ground facilities for the life of the asset. At the inlet station, works will include: building up and compacting a pad, minor excavations, installing underground conduits, placing concrete slabs, and installing skids installing a pig launcher and vent stack completing connections to the PEPL tie-in flange, and tie-in to the W2P pipeline installing a solar array and communications cabinet, other free-standing equipment and structural steel work, and cable trays installing electrical power distribution and control components, cables connecting equipment to power and control systems placing aggregate over the ground around the station, to prevent vegetation regrowth and maintain a firebreak, and installing gated security fencing. At the delivery station, works will include: building up and compacting a pad, minor excavations, piling works, installing underground conduits, placing concrete slabs, and installing skids installing a pig receiver, heaters, filtration, and pressure regulation units completing connections to the Wodgina power station inlet flange, and tie-ins to the W2P pipeline installing an equipment hut, other free-standing equipment and structural steel work, and cable trays installing electrical power distribution and control components, cables connecting equipment to power and control systems placing aggregate over the ground around the station, to prevent vegetation regrowth and maintain a firebreak, and installing gated security fencing.
1.9.12. Tie-ins A dedicated tie-in crew with its own welders, operators, side boom(s), and welding and coating rigs will complete the connections between pipe strings, at special crossings, and to inlet and delivery stations, and will backfill any remaining bell-holes. The tie-in crew will generally work closely with mainline lowering-in, in order that most tie-ins can be completed shortly after the pipe is laid, and the tie-in site backfilled promptly.
1.9.13. Hydrostatic Pipeline Testing The integrity of the buried pipeline will then be tested with water under pressure (hydrostatic testing, or “hydrotesting”), in accordance with AS 2885.5 Pipelines - Gas and Liquid Petroleum Field Pressure Testing, by a NATA-certified contractor. A preliminary gauge plate will be run through the buried pipeline to ensure that it conforms to its nominal diameter, then “pigs” (cylindrical plugs) will be run through the line to clean its interior of construction residue such as weld debris, dust, and surface scale. The pipeline will be hydrotested in 2 x 40 km sections requiring a total volume of approximately 2,600 kL. WLPL expects that no treatment with chemicals, such as biocide or oxygen scavenger will be required. Section 1 (KP 0-40) will be tested first and the required water will be pumped from the turkeys nest into the pipeline, which will then be pressurised for a 4 hour strength test, followed by a 24 hr leak test. Once section 1 has been tested the water will then be pumped back to the turkeys nest, re-decanted and then pumped from the turkeys nest into section 2 (KP40-80) and the same time process for strength testing and leak testing will be followed. On completion of hydrotesting of section 2, the water will be disposed of to Wodgina pit, which is located at the Wodgina mine site in proximity to the southern end of the pipeline. The water will be expelled at a controlled discharge rate of 25 L/s, using lay flat hosing to transfer the water from the pipeline through geotextile or similar material to diffuse the flow. The water will then be reused in the operations mine water circuit. The hydrotested pipeline will then be cleaned using pigs, and dried with desiccated air, to a dew point of about -20ºC, in preparation for commissioning and filling with gas.
1.9.14. Clean-up and Reinstatement of Work Areas The CROW (including adjacent turning and passing bays) will be progressively reinstated, following as closely as practicable behind pipe-laying and trench backfill; other temporary work areas will be reinstated progressively as they are no longer required, or as part of a final campaign of reinstatement works at the completion of construction. Temporary disturbances will be reinstated within one month of practical completion of construction works, although some minor disturbance may remain longer, to facilitate final completion and commissioning. Equipment, stores, buildings, and other temporary infrastructure will be decommissioned and removed from the CROW, Wodgina mine site, and other ancillary areas used to support construction works. Any residual waste will be removed and appropriately disposed of, as addressed in Section 1.4.8 and Section 3. Little or no residual trench spoil will be left after backfill; any residual material will be re-spread evenly on the CROW as part of reinstating the natural contours. The CROW and other disturbed construction areas will be re- profiled as necessary, scarified to reduce compaction and promote infiltration, and re-spread with stockpiled topsoil and vegetation, to promote revegetation and resist erosion. Any mature trees cleared during the W2P construction will be selectively placed to provide habitat, where practicable. A 4 m single-lane track will be left along the CROW, to provide access for inspections and maintenance. Erosion and sediment control structures (such as diversion berms or sediment traps) may be left or put in place to divert rainwater runoff away from potentially unstable areas, or prevent sediment runoff into drainage lines, particularly where higher runoff velocities may occur, such as along slopes or across drainage lines. Inspections over the life of operations will monitor the success of reinstatement, including the stability of reinstated surfaces, vegetation regrowth, and presence of weeds; operations are discussed further in Section 1.12. Measures to promote the success of reinstatement and rehabilitation, and mitigate the risk of failure, are discussed Section 3; objectives, standards, and criteria for reinstatement and rehabilitation success are discussed in Section 4. WLPL will engage with landholders and other relevant stakeholders to ensure that their expectations and concerns for reinstatement are understood and appropriately addressed (Section 8). Final decommissioning and rehabilitation of remaining built infrastructure at the end of the life of operations is briefly addressed in Section 1.13.
1.9.15. Cathodic Protection, Station and Signs Impressed current for cathodic protection will be supplied from either end of the pipeline. Test points will be installed at regular intervals along the pipeline route in conjunction with CROW reinstatement works. Due to telemetry and ground conditions, a small above-ground cathodic protection station will be installed at KP76.3 within the existing CROW; however, a small access track will be constructed and will run 70 m perpendicular to the CROW between the W2P and the cathodic protection station. At the cathodic protection station, works will include: building up and compacting a pad, minor excavations, installing underground conduits, placing concrete slabs, and installing skids. completing connections to the anode ground bed to the CP Station and access track between the two locations. installing a solar array and communications cabinet, other free-standing equipment and structural steel work, and cable trays. installing electrical power distribution and control components, cables connecting equipment to power and control systems. placing aggregate over the ground around the station, to prevent vegetation regrowth and maintain a firebreak, and installing gated security fencing.
PIPELINE SIGNAGE Pipeline marker / warning signs will be installed along the pipeline centreline in accordance with AS2885.1, at regular intervals, bends, and crossings. Signs will also be installed around the above-ground facilities to warn of hazards and deter unauthorised access.
COMMISSIONING The W2P, including pipeline, inlet and delivery stations, and associated systems, will be systematically tested and commissioned according to a W2P-specific commissioning plan in preparation for operations. Commissioning works will broadly incorporate: pre-testing all mechanical and electrical equipment and instrumentation at each facility, proceeding to energisation of all components progressive introduction of gas and commissioning each item of equipment sequentially until the whole system is capable of operating as a unit documentation and handover to the WLPL field services group for operation. Following consultation with DMIRS (Petroleum), WLPL will submit a separate Environmental Plan addressing W2P commissioning and operations phases for review and approval. This Plan will be referred to as the Commissioning and Operations Environmental Plan (COEP), with commissioning works for the W2P scheduled to commence in March 2019.
OPERATIONS AND MAINTENANCE The W2P will be operated and maintained by the WLPL field services group, according to the COEP. Operation and maintenance will include: general easement, facility, and equipment inspection and maintenance, filter changes; cathodic protection surveys; voltage gradient surveys; pipeline excavation; venting; pipeline pigging; pipeline patrols, and; breakdown and emergency response exercises. The pipeline corridor will be inspected regularly over the life of operations; as a minimum once per month, in addition to ad-hoc inspections as part of general operations and maintenance. Inspections will identify potential hazards and risks, such as: erosion, poor revegetation, weeds, encroachment by third parties, exposed pipe, and missing or damaged signs. Maintenance or remedial works will be ordered where required, to ensure both the integrity of the asset, and that reinstatement and rehabilitation obligations and objectives are met. Where required, taller or deeper-rooted vegetation located within the revegetated construction ROW will be removed so to maintain sight of markers as required under AS 2885.1, and protect the pipeline integrity from plant roots. Maintenance works may also include weed control, to the extent required by landholders or rehabilitation objectives. WLPL expects resource requirements for operation and maintenance, such as fuel use, to be minimal. Operations crews will use existing, accommodation, fuel, and other facilities at the Wodgina mine site or at and around Port Hedland.
FINAL DECOMMISSIONING AND REHABILITATION WLPL expects the pipeline to remain buried where it lies at the end of the asset life, with only relatively minor final decommissioning and rehabilitation works for surface facilities (the inlet and delivery stations) and remaining disturbances to be completed. Works are expected to include: Disconnecting and depressurising the below-ground pipeline, and purging it of all residual gas and hydrocarbons. Removing short sections of the pipeline or filling them with grout at third-party crossings, depending on stakeholder requirements. Removing above-ground pipework and installations, including the offtake and delivery stations, and associated control equipment, for salvage, scrap, or disposal. Breaking up above-ground concrete slabs or footings for burial in-situ or other appropriate disposal. Removing marker posts, other signs, and fences. Reinstating any remaining disturbed areas such as inspection tracks and access roads, except where agreements and approvals are established to fully transfer liability to a third party such as a pastoral station. The current expected life of the W2P is 40 years, with potential for extension subject to demand, engineering integrity assessment, and regulatory approval. As the asset approaches the end of its expected life of the asset, a detailed decommissioning plan will be developed in consultation with the relevant stakeholders (including land title holders, and safety, environmental, and lands regulators), and submitted for approval in accordance with the prevailing regulations and standards of the time. Plans of buried assets will be handed over to relevant landholders and regulators. Measures for the final decommissioning and closure of the W2P will be incorporated into the mine closure plan for the Wodgina operations, in accordance with the Mining Act requirements (Section 5). 2. DESCRIPTION OF THE ENVIRONMENT
SOCIAL, ECONOMIC, AND TENURE The W2P will be built in the Pilbara region of Western Australia, within the Town of Port Hedland local government area (LGA), but some distance (40 km at closest point) from any built-up or residential areas. The main land uses of the W2P area and wider region are pastoral grazing, minerals exploration, mining, and regional infrastructure, including roads, railways, power lines, and gas pipelines (Figure 1; Figure 5). The W2P and Wodgina mining operations fall within the Kariyarra People’s native title determination application, (WAD6169/1998), represented by the Yamatji Marlpa Aboriginal Corporation. WLPL is currently negotiating an agreement with the Kariyarra People for the existing Wodgina operations and associated infrastructure, and continues to engage with Traditional Owners on the proposed expansions, including the W2P, as addressed further in Sections 2.2, 5, and 8. The Mugarinya (Yandeyarra) Aboriginal community is located30 km east-south-east of the Wodgina operations and the southern end of the W2P, within the Yandeyarra Aboriginal reserve (reserve nos. 31427 and 31428). TheW2P does not pass through Yandeyarra Aboriginal Reserve or any other Aboriginal reserve; however it does pass through the Kangan pastoral station, which is leased to the Yamatji Marlpa Aboriginal Corporation. The W2P also passes through the Mundabullangana and Indee pastoral stations (Figure 3). WLPL will negotiate arrangements with the pastoral title holders to access and use the land for construction and operation of the W2P, addressed in Section 9. The first 13 km of the W2P from the northern end intersects a public drinking water supply area (PDWSA) WRC 3208-01 (Yule River). This PDWSA is gazetted under the Country Areas Water Supply Act 1947 to protect the quality of groundwater resources supplying Port and South Hedland, and incorporates Water Reserve 33015. Development of the W2P is a compatible land use within the PDWSA as per relevant Department of Water and Environment Regulation (DWER) notices [2]. In the context of the existing infrastructure and activity within and near the reserve, and the management controls proposed, the W2P construction works do not present any material new risk to the water resource. WLPL will consult with DWER ahead of any works in the water reserve, as addressed in Section 8. The W2P will be constructed on several minerals titles previously granted to WLPL under the Mining Act 1978 (WA), including Miscellaneous Licence L45/108, Mining Leases M45/381, M45/50 and M45/949 (Section 5). The W2P also crosses a number of third-party minerals titles (granted or pending); most of these are exploration licences, with the exception of the miscellaneous licence granted to Atlas Iron Limited for the Mt Dove mine access road. WLPL will address access to third party minerals titles under a separate mining proposal for the W2P and other expansions of the Wodgina operations, to be submitted for assessment under the Mining Act (Section 5) as required. The W2P crosses two substantial roads (Northwest Coastal Highway, Mt Dove mine access road) as well as third party pipeline infrastructure in the vicinity of Yule River borefield. WLPL proposes to use bored crossing techniques at these points (Section 1.9.9) to minimise disruption to traffic and disturbance of infrastructure. The W2P also passes under power lines forming part of the regional power network; measures to minimise the risk of disruption to the power network will be addressed as part of the W2P Safety Case in consultation with the asset owner. The W2P crosses a number of other minor pastoral roads, but no railways or other substantial foreign services or infrastructure. The W2P disturbance area will be reinstated (aside from an operations 4 m access track, the small above-ground facilities, and signage), as addressed in Section 3.4. No conservation estate is present within or near the W2P area, with the nearest (Mungaroona Range Wildlife Sanctuary) about 50 km to the southwest. No environmentally sensitive areas (ESAs), as declared under section 51B of the Environmental Protection Act 1986 (WA) (including World Heritage properties or places on the Register of National Estate), are listed within or near the W2P area. WLPL is engaging with community members, traditional owners, pastoral lease and minerals titles holders, infrastructure owners and operators, the LGA, and other relevant local stakeholders, as set out in Section 8, to ensure that impacts from the W2P construction works on their interests, and on local society and economy generally, are minimised.
ABORIGINAL HERITAGE The W2P pipeline corridor crosses the boundary of three Aboriginal heritage sites listed on the Aboriginal Heritage Inquiry System maintained by the Department of Planning, Lands, and Heritage (DPLH) (Figure 4): Site ID 16034 (Karratha-South Hedland 17): The boundaries of this site were re-mapped with representatives of the Kariyarra People and archaeologists from the Yamatji Marlpa Aboriginal Corporation (YMAC). The results of the re-mapping are that the boundaries of Site 16034 do not overlap with WLPL’s pipeline licence. YMAC will provide DPLH with the updated site recording forms. Site ID 37223 Women’s Hill (Coodigulla): The DPLH has undertaken a search of the pipeline in relation to this particular site and advised that the proposed pipeline will not impact this site. YMAC confirmed that no further heritage surveys were required in this area. Site ID 9009 Gulindjina Yambara: WLPL has previously undertaken heritage surveys in this area with the Wamarranya representatives from within the Kariyarra People’s native title determination application. The results of these surveys determined that site 9009 does not fall within the pipeline licence area. WLPL has also undertaken additional Aboriginal ethnographic and archaeological surveys from May 2018 to June 2018. All newly identified Aboriginal heritage sites will not be impacted by this alignment of the proposed pipeline. WLPL continues to engage with the Kariyarra People to ensure that no Aboriginal heritage sites are disturbed by WLPL’s activities.
CLIMATE The Pilbara region has a “arid and tropical’ climate, with high temperatures and low, irregular rainfall. The average annual rainfall for the region is between 200 mm and 350 mm, and almost all falls between December and May, usually in heavy downpours from thunderstorms or tropical cyclones from January to March. The period from June to November is often completely rainless, with warm to very hot and sunny conditions. Construction activities are scheduled to commence in the latter half of October 2018, with commissioning to commence in March 2019. The long-term average rainfall and mean maximum temperatures, as recorded at the Bureau of Meteorology (BoM) weather station (no. 4032) at Port Hedland airport about 40 km from the northern end of the W2P area over the construction and commissioning period (i.e. October 2018 – March 2019) are 227 mm and 36.2 0C respectively. A summary of the monthly long-term average rainfall and mean maximum/ minimum temperatures over the duration of the W2P construction and commission period is provided in Table 7 and Plate 1.
Table 7: W2P Climate Data
Construction Period Commissioning Period Month Oct 2018 Nov 2018 Dec 2018 Jan 2019 Feb 2019 Mar 2019 Apr 2019 Long term Ave Rainfall (mm) 0.9 1.6 19.1 63.9 89.9 51.3 21.8 2017 Rainfall (mm) 0.0 3.4 33.6 90.0 70.2 355.4 37.8 Ave mean Max temp (0C) 35.0 36.3 36.6 36.3 36.2 36.7 35.2 Ave mean Min temp (0C) 18.5 21.4 24.1 25.6 25.4 24.5 21.4
Plate 1: Climate Statistics for Port Hedland Airport
BIOGEOGRAPHIC REGION The W2P falls within the “Pilbara” bioregion, as identified by the Interim Biogeographic Regionalisation of Australia (IBRA; DEE 2016, cited by 360 Environmental (360 Environmental Pty Ltd, 2018)), within the “Roebourne” (PIL04) and Chichester” (PIL01) subregions (Figure 3). The Pilbara bioregion is characterised by vast coastal plains and inland mountain ranges, with cliffs and deep gorges. Vegetation is predominately mulga low woodlands or snappy gum over bunch and hummock grasses (Bastin and ACRIS 2008, cited by 360 Environmental (360 Environmental Pty Ltd, 2018)). The Roebourne subregion is comprised of quaternary alluvial and older colluvial plains with savannah of bunch and hummock grasses, and dwarf shrubs such as Acacia stellaticeps, A. pyrifolia and A. inaequilatera. Triodia hummock grasslands dominate the uplands. Eucalyptus victrix or Corymbia hamersleyana woodlands are supported by drainage lines. River deltas and marine alluvial flats support samphire, mangal and Sporobolus. Resistant ranges of basalt occur along coastal plains with minor outcrops of granite (Kendrick and Stanley 2001, cited by 360 Environmental (360 Environmental Pty Ltd, 2018)). The Chichester subregion comprises the northern section of the Pilbara Craton. Undulating Archaean granite and basalt plains include significant areas of basaltic ranges. Plains support a shrub steppe characterised by Acacia inaquilatera over Triodia wiseana (formerly Triodia pungens) hummock grasslands, while Eucalyptus leucophloia tree steppes occur on ranges (Kendrick and McKenzie 2001, cited by 360 Environmental (360 Environmental Pty Ltd, 2018)). LAND SYSTEMS AND SOILS 360 Environmental (360 Environmental Pty Ltd, 2018); [5] identified four land systems traversed by the W2P area, as summarised in Table 8. These land systems are generally not susceptible to erosion, with the exception of the Mallina system from about KP0 to KP20 of the W2P, which may be moderately to highly susceptible to erosion if vegetation cover is seriously depleted. Given the narrow width and temporary nature of clearing for the CROW, however, the risk of soil erosion from construction works is low.
Table 8: Land Systems within the W2P Area
System Description Uaroo Broad sandy plains, pebbly plains and drainage tracts supporting hard and soft spinifex hummock grasslands with scattered acacia shrubs. Boolgeeda Stony lower slopes and plains below hill systems supporting hard and soft spinifex grasslands or mulga shrublands. Ruth Hills and ridges of volcanic and other rocks supporting shrubby hard spinifex and occasionally soft spinifex grasslands. Mallina Sandy surfaced alluvial plains supporting soft spinifex grasslands and minor hard spinifex and tussock grasslands.
None of the above land systems are typically associated with acid-sulphate soils (ASS), and there is little to no risk of ASS exposure by mainline trenching or other excavation. The Australian Soil Resource Information System (ASRIS) [6] maps the probability of ASS as “very low” to “low” for the entire pipeline route. Soil salinity in the Pilbara region is variable and dependent on land unit location, however many deep clays tend to have weakly saline subsoil. If exposed through erosion, these subsoils may become scalded and sealed, with greatly reduced water infiltration rates and increased surface salinity. None of the land systems within the W2P area are known to demonstrate these properties [5]. Management of construction works to minimise erosion and other impacts on soils in the W2P area is addressed in Section 3.4.
SURFACE WATER No major surface water features intersect the W2P area (360 Environmental Pty Ltd, 2018). The Yule River runs to the west of the W2P, approaching within about 3 km at the northern end of the W2P. The Turner River runs to the east of the corridor, with a tributary approaching within 1 km near the Wodgina mine site (360 Environmental Pty Ltd, 2018) (Figure 1). Surface water flows in the region are typically ephemeral, and generally flow only following heavy rainfall events. The W2P crosses a number of ephemeral, weakly defined drainage lines; crossings in these areas will be completed as part of conventional “mainline” construction works as set out in Section 1.9.10. Construction works will nevertheless be managed to minimise potential impacts to surface water flows or quality, as addressed in Section 3.4.6. The W2P area falls within the “Pilbara” surface water area, defined under the Rights in Water and Irrigation Act 1914, addressed in Section 5.
GROUNDWATER Groundwater in the northern 50 km of the proposed pipeline corridor is characterised as fresh to brackish, with 1,000 to 3,000 mg/L total dissolved solids (TDS); groundwater in the southern 30 km is more fresh, with 500 - 1,000 mg/L TDS (DoW 2010, cited by 360 Environmental [5]). As noted in Section 2.1, the northern section of the corridor from KP0 to KP13 falls within PDSWA WRC 3208-01 (Yule River). The W2P construction works do not present a significant risk of harm to water quality in the PDSWA, or along the construction corridor given: the relatively minor storage and handling of hydrocarbons and hazardous chemicals outside of the Wodgina mine site (Section 0) the controls proposed for hydrocarbons and hazardous chemicals (Section 3.4.7) the context of existing infrastructure and activity in the area (such as the Northwest Coastal Highway). Depths to groundwater in the Yule River well field near the northern end of the W2P are about 4 to 10 metres below ground level (mBGL) [5]; around the Wodgina mine site at the southern end of the corridor, levels range from 10 to 15 mBGL. The W2P trench or other excavations will not require dewatering for pipeline installation given the shallow depth of excavation proposed The W2P area falls within the “Pilbara: groundwater area, defined under the Rights in Water and Irrigation Act 1914, addressed in Section 5.
VEGETATION AND FLORA The W2P envelope lies within the Eremaean Province, as defined and mapped by Beard (1975; 1990), which occupies over 70 % of Western Australia (Beard, 1990). The W2P is located within the Fortescue Botanical District (Pilbara Region) of the Eremaean Province. The Fortescue Botanical District extends northwards from the Acacia-dominated scrub in the south, and is bounded to the west and east by the Carnarvon and Canning Basins. The vegetation of this District was described by Beard (1975) as ‘tree and shrub-steppe communities, with Eucalyptus trees, Acacia shrubs, Triodia pungens and Triodia wiseana, with Triodia hummock grasslands, the characteristic vegetation type of the region’. The W2P lies on the northern section of the Pilbara Craton within the Fortescue Botanical District, on the Abydos Plain. Of the four main associations described on the Abydos Plain, Shrub Steppe is predominant in the study area (Beard 1975). This is the main community of the granite plain and is dominated by Acacia pyrifolia-Triodia pungens associations, with hummock grasses and widely-spaced shrubs. The W2P occurs within the Pilbara IBRA biogeographic region (Interim Biogeographic Regionalisation for Australia) (Environment Australia, 2000), which is equivalent to the Fortescue Botanical District as defined by Beard (1975). More specifically the study area is located within the Pilbara 1 (PIL1) Chichester Subregion of the Pilbara IBRA region (Kendrick & McKenzie 2001). The PIL1 Chichester Subregion is comprised of undulating Archaean granite and basalt plains, with significant areas of basaltic ranges. Plains support a shrub steppe characterised by Acacia inaequilatera over Triodia wiseana hummock grasslands, while Eucalyptus leucophloia tree steppes occur on ranges. Grazing of native pastures by stock and impacts from mining are the main impacts on biodiversity within the region (Kendrick & McKenzie, 2001). Mapping of the pre-European vegetation extents within the Pilbara region of WA was completed on a broad scale (1:1,000,000) by Beard (1975). These vegetation types were later re-assessed by Shepherd et al. (2002) to account for clearing in intensive land use zones, dividing some larger vegetation units into smaller units. Four broad vegetation types have been identified for the W2P (Figure 6): Abydos Plain - Chichester 626: Hummock grasslands, shrub-steppe, kanji over soft spinifex and Triodia brizioides. Abydos Plain 93: Hummock grasslands, shrub steppe; kanji over soft spinifex. Abydos Plain 647: Hummock grasslands, dwarf-shrub steppe; Acacia translucens over soft spinifex. Abydos Plain 589: Mosaic. Short bunch grassland - savanna / grass plain (Pilbara) / Hummock grasslands, grass steppe, soft spinifex (Shepherd, Beeston, & Hopkins, 2002).
2.8.1. W2P northern envelope Two flora and vegetation surveys for the northern envelope were completed by 360 Environmental in 2018. These surveys comprised a Level 1 reconnaissance flora and vegetation survey in January 2018 (Appendix 3) and a detailed flora and vegetation survey in June 2018 (Appendix 12). The following vegetation associations were identified within the northern envelope by 360 Environmental – note that the boundaries of these associations were mapped during the January 2018 survey and confirmed during the detailed survey in June 2018: AaAbTe: A. ancistrocarpa, A. bivenosa mid sparse shrubland over T. epactia tussock grassland. AiGwTe: Acacia inaequilatera, Grevillea wickhamii tall sparse shrubland over A. ancistrocarpa, A. bivenosa mid isolated clumps of shrubs over Triodia epactia tussock grassland. AmTe: A. maitlandii mid isolated clumps of shrubs over T. epactia tussock grassland. AiTe: A. orthocarpa, A. inaequilatera tall isolated clumps of trees over T. epactia, T. brizoides mid tussock grassland. AhAiTe: Atalaya hemiglauca low Isolated clumps of trees over A. inaequilatera tall isolated clumps of shrubs over Carissa lanceolata mid isolated shrubs over Corchorus laniflorus low isolated shrubs over T. epactia, Eragrostis desertorum, *Cenchrus ciliaris. AiGwTe: Acacia inaequilatera, Grevillea wickhamii tall sparse shrubland over A. ancistrocarpa, A. bivenosa mid isolated clumps of shrubs over Triodia epactia tussock grassland. CcAiMlTe: Corymbia candida ?subsp. lautifolia low isolated clumps of trees over A. inaequilatera, Melaleuca lasiandra mid isolated clumps of shrubs over A. stellaticeps low open shrubland over T. epactia mid tussock grassland. CcAiTe: Corymbia candida ?subsp. lautifolia low woodland over Carissa lanceolata, A. inaequilatera mid isolated shrubs overmixed low isolated shrubs over T. epactia, *Cenchrus ciliaris, Eragrostis desertorum mid closed grassland. ChAiTe: Corymbia hamersleyana low isolated trees over A. inaequilatera, A. sericophylla, tall isolated clumps of shrubs over Grevillea wickhamii, Sida arenicola mid isolated shrubs over A. acradenia, A. stellaticeps low isolated shrubs over T. epactia tussock grassland. ChAtTe: Corymbia hamersleyana low isolated trees over A. tumida var. pilbariensis, A. ancistrocarpa, Grevillea wickhamii tall sparse shrubland over A. maitlandii mid isolated shrubs over T. epactia tussock grassland. CzAspp.Te: Corymbia zygophylla low isolated clumps of trees over A. tumida var. pilbariensis, A. acradenia mid sparse shrubland over A. ancistrocarpa, A. stellaticeps low sparse shrubland over T. epactia mid tussock grassland. CzAtTe: Corymbia zygophylla low isolated clumps of trees over A. trachycarpa, Hakea lorea mid sparse shrubland over A. inaequilatera low isolated clumps of shrubs over T. epactia tussock grassland. EvChCc: Eucalyptus victrix mid woodland over Corymbia hamersleyana low isolated trees over A. tumida var. pilbariensis mid isolated shrubs over T. epactia mid tussock grassland. MlAiTe: Melaleuca lasiandra low isolated clumps of trees over Acacia inaequilatera tall isolated shrubs over A. stellaticeps, Corchorus parviflorus low sparse shrubland over Triodia epactia tussock grassland. TsCP: Neptunia dimorphantha, Rhynchosia minima low isolated shrubs over Triodia secunda, Dactyloctenium radulans, Eriachne glauca var. glauca low open grassland.
The distribution of these vegetation associations are shown in (Figure 7; Figure 8). None of the vegetation associations identified in the northern envelope is likely to represent a Threatened Ecological Community (TEC) or a Priority Ecological Community). No threatened species listed under the EPBC Act or Wildlife Conservation Act 1950 (WA) (Declared Rare Flora) were recorded. A single DBCA Priority-listed species, Euphorbia clementii (P3), was recorded at two locations, one of which is outside the northern envelope (Figure 7; Figure 8 ).
2.8.2. W2P Southern envelope There have been numerous flora and vegetation surveys completed over the Wodgina area, including the W2P southern envelope and immediate surrounds. Most recently, a detailed flora and vegetation survey was completed by Woodman Environmental Consulting (WEC) in June 2018 (Error! Reference source not found. 13). The detailed flora and vegetation assessment comprised a field survey to fill gaps in previous survey coverage and the consolidation of previous studies to produce a single flora and vegetation assessment for the Wodgina mine site and surrounds (including the southern envelope). A copy of this assessment is provided in Appendix 13. A single DBCA Priority-listed species, Euphorbia clementii (P3), was recorded at three locations, one of which is outside the southern envelope (Figure 9). The following vegetation units were identified and mapped within the W2P southern envelope. Refer to Figure 9 for the distribution of these units: 2: Low woodland of Corymbia hamersleyana over open shrubland of Acacia ancistrocarpa and A. tumida var. pilbarensis, over hummock grassland of Triodia epactia and T. lanigera with sparse herbs including Bonamia erecta and Ptilotus astrolasius and sparse tussock grasses including Chrysopogon fallax on drainage lines and surrounding flats and plains, occasionally stony, with red to orange sandy to clay loams. 5: Low open woodland to woodland of Corymbia hamersleyana and/or Eucalyptus victrix over tall sparse shrubland to open shrubland dominated by Acacia pyrifolia var. pyrifolia, Acacia tumida var. pilbarensis and/or Melaleuca linophylla over mid sparse tussock grassland to tussock grassland dominated by *Cenchrus ciliaris and/or Cymbopogon ambiguus with mid sparse to open hummock grassland of Triodia epactia and/or Triodia wiseana on stony drainage lines on red or brown clay loam or sandy loam. 6: Tall sparse shrubland of Acacia inaequilatera and Grevillea wickhamii subsp. hispidula over mid sparse to open shrubland dominated by Acacia acradenia or Acacia ancistrocarpa over mid hummock grassland often dominated by Triodia epactia and/or Triodia wiseana and occasionally by Triodia brizoides or Triodia lanigera on rocky lower to midslopes and occasional crests, and outwash plains on red or brown clay loam or sandy loam sometimes with granite outcropping. 7: Tall sparse shrubland Grevillea wickhamii subsp. hispidula over mid sparse shrubland of Acacia acradenia over low to mid hummock grassland dominated by Triodia chichesterensis and Triodia wiseana on stony outwash plains on red or brown clay loam often with calcrete outcropping. 10: Mid sparse shrubland of Acacia acradenia and/or A. inaequilatera over low hummock grassland dominated by Triodia wiseana with Triodia epactia and/or Triodia brizoides occasionally co-dominating and low sparse shrubland of mixed species including Corchorus parviflorus, Gomphrena cunninghamii and Indigofera monophylla on steep midslopes, upperslopes, crests and ridges on brown or red clay loam or sandy loam with dolerite, granite or ironstone outcropping. 11: Tall sparse shrubland of Acacia inaequilatera and/or Acacia orthocarpa over low to mid hummock grassland to closed hummock grassland often dominated by Triodia scintillans, and occasionally also by Triodia epactia or Triodia wiseana on stony low hills and undulating plains on brown or red-brown clay loam or sandy loam often with granite or dolerite outcropping.
None of the vegetation units mapped within the study area (including the southern envelope) represent any listed Threatened or Priority Ecological Communities defined under State or Commonwealth legislation. Further, none of these vegetation units are regionally significant (Error! Reference source not found. 13). Management of construction works to minimise impacts on vegetation and flora in the W2P area is addressed in Section 3.4.3.
2.8.3. Introduced Flora A total of three introduced flora species were recorded in the northern envelope, none of which are listed as a Declared Pest under the Biosecurity and Agriculture Management Act 2007 (WA) or is a Weed of National Significance (Figure 7; Figure 8). Recorded locations will be incorporated into alignment lists issued for construction; other measures to prevent the introduction or spread of weeds in the W2P area from construction works are addressed in Section 3.4.10.
HABITAT AND FAUNA Reconnaissance and targeted fauna surveys of the W2P were completed by 360 Environmental in 2018, comprising a Level 1 fauna and targeted Northern Quoll survey (January 2018) and a targeted fauna survey for conservation significant species (June 2018). More recently, Stantec undertook a Level 1 fauna survey, targeted conservation fauna survey and desktop assessment for Wodgina in July 2018 (Appendix 9): The Level 1 and targeted conservation significant fauna surveys focussed on the eastern range, proposed lithium hydroxide plant, and other areas to the south of Wodgina – these areas are not of relevance to the W2P. The desktop assessment collated and consolidated all previous fauna survey work that has been completed at Wodgina (inclusive of the above surveys, include the 360 Environmental January and June reports). Habitat mapping for the Wodgina Lithium Project, including the W2P, was consolidated and a reassessment of the likelihood of occurrence of conservation significant fauna was completed. A total of seven fauna habitats were identified within the W2P by Stantec. These habitat types and their proportions within the Wodgina study area are provided in Appendix 9 (Table 4-7). The distributions of fauna habitats within the W2P are also shown in Appendix 9 (Figures 4-3 to 4-5).
2.9.1. Fauna Species of Conservation Significance Stantec (Appendix 9) completed a likelihood assessment for conservation significant species, which is summarised in Table 9 below, with respect to species that are likely to occur or have been confirmed as occurring within the W2P area.
Table 9: Conservation Significant Fauna - Likelihood of Occurrence
Common Name Scientific Name Recording Conservation Status W2P northern envelope Recorded Migratory and Marine – Fork-tailed Swift Apus pacificus EPBC Act Recorded Vulnerable – EPBC and WC Bilby Macrotis lagotis Acts Brush-tailed Mulgara Dasycercus blythi Recorded Priority 4 – DBCA W2P southern envelope Two recordings – foraging Vulnerable – EPBC and WC Pilbara Leaf-nosed Bat Rhinonicteris aurantia only Acts Likely to occur Possible likelihood of Vulnerable – EPBC and WC Ghost Bat Macroderma gigas occurrence Acts Western Pebble-mound High likelihood of occurrence Mouse Pseudomys chapmani Priority 4 – DBCA Possible likelihood of Endangered – EPBC and WC Northern Quoll Dasyurus hallucatus occurrence Acts Long-tailed Dunnart Sminthopsis longicaudata) High likelihood of occurrence Priority 4 – DBCA High likelihood of occurrence Vulnerable – EPBC and WC Grey falcon Falco hypoleucos Acts Peregrine falcon Falco peregrinus High likelihood of occurrence Special protection – WC Act
In respect of the likelihood assessment provided in Table 9, the targeted fauna survey undertaken in June 2018 identified: 30 instances of Bilby evidence on the W2P comprised of ten scats, 16 diggings and four track findings. This evidence was primarily recorded at the northern end of the pipeline corridor near the Northwest Coastal Highway (Appendix D-Figure 4-2). 30 instances of Brush-tailed Mulgara on the W2P comprised of four scats, 21 burrows and five tracks. Of the 21 burrow findings, one burrow was high certainty (aged), 11 burrows were medium certainty (two fresh, two recent, seven aged and one old), and nine burrows were low certainty (three aged and six old). No evidence of the Western Pebble-mound Mouse, Ghost Bat or any other fauna species of conservation significance were recorded during the survey. Two records of the Pilbara leaf-nosed Bat were identified in proximity to the rocky ranges near the southern portion of the gas pipeline. Management of construction works to minimise impacts to habit and fauna in the W2P area is addressed in Sections 3.4.3 and 3.4.4. 3. ENVIRONMENTAL RISK ASSESSMENT AND MANAGEMENT
RISK ASSESSMENT METHODOLOGY WLPL adopts a corporate risk identification and assessment methodology as set out in MRL procedures MRL- EN-PRO-0017 Identification of Environmental Aspects and Impacts (Error! Reference source not found. 4) and MRL-OHM-PRO-0014 Hazard and Risk Management. WLPL intends the methodology to be consistent with the relevant requirements of: AS2885.1:2012 Pipelines – Gas and Liquid Petroleum, Part 1: Design and construction. AS2885.3:2012 Pipelines—Gas and Liquid Petroleum, Part 3: Operation and Maintenance. AS/NZS ISO 31000:2009 Risk Management – Principles and Guidelines. Guideline for the Development of Petroleum and Geothermal Environment Plans in Western Australia [1]. The methodology incorporates definitions used to classify different levels of consequence and likelihood for unwanted events, and a matrix used to rate risks as a product of consequence and likelihood; these definitions and risk matrix are set out in Appendix 4.
IDENTIFICATION OF SOURCES OF RISKS AND THEIR IMPACTS Through use of risk assessment methodology, WLPL has sought to identify all aspects of construction work activities for the W2P (e.g., storage and handling of hydrocarbons) that may present sources of risk (hazards) to the environment (e.g., loss of containment) with potential for harm (e.g., contamination to soil, surface water, or groundwater) to the environment. These aspects and hazards have been identified from various sources, including: experience from similar projects, brought to the W2P by WLPL, OSD, and other personnel the APGA Code of Environmental Practice – Onshore Pipelines [13] the DMIRS Guideline for the Development of Petroleum and Geothermal Environment Plans in Western Australia [1] information on the W2P design and construction works, as described in Section 1, including basis of design and scope of work memorandums information on the environmental and social setting of the W2P, as described in Section 2, including ecological and heritage survey reports. On the basis of the aspects and hazards identified from such information, and with regard to controls typically adopted for similar projects, an environmental risk assessment (ERA) table was drafted for the W2P by an environmental consultant (MBS Environmental), based on experience with similar projects, and the W2P activity and environmental descriptions. The draft ERA was circulated to relevant MRL and WLPL personnel for review on 30 May 2018, including the: MRL Senior Environmental Advisor. MRL Senior Environmental Consultant. WLPL General Manager. W2P Consulting Project Manager (OSD Pipelines).
Feedback was incorporated into a final ERA, included in Error! Reference source not found. 5. Environmental management measures to be adopted for the W2P construction works are described in the following sections below. RISK CLASSIFICATION AND REPORTING REQUIREMENTS To ensure consistency between this CEP and the Wodgina 2 Gas Pipeline Construction and Commissioning Fauna Management Plan (W2P FMP), any unplanned event or incident occurring in the course of works where the inherent environmental consequence of the event is classified as “medium” or greater (according to the MRL consequence definition table, Error! Reference source not found. 4), will be deemed a Reportable Incident. This level of consequence is consistent with the definition of “moderate” or greater, as set out in the DMIRS EP guidelines, as the threshold for Reportable Incidents. The reporting protocol for both Reportable and Recordable incidents is provided in Section 787.
ENVIRONMENTAL MANAGEMENT STRATEGIES All environmental management strategies described in the following sections are consistent with management measures and commitments contained in the W2P FMP, which forms part of the W2P Mining Proposal approval document (REGID 74363). The W2P Fauna Management Plan is provided as Error! Reference source not found. 10.
3.4.1. Overview Environmental management strategies developed through the ERA and grouped according to aspect, are summarised in the following sections and tables, addressing: The works with potential to present hazards to the environment, and the nature of those hazards. A summary of the management measures to address the hazards, and reduce the risk of harm to the environment. Monitoring to be carried out and records to be kept, so to demonstrate that mitigation measures are effective. Relevant internal standards, systems, and procedures. WLPL will review its standing procedures for alignment with the scope of works under this CEP, and for conformance to its requirements, once approved by DMIRS. WLPL will ensure contractor procedures (titles and document numbers to be determined) subsequent to contract award and prior to construction, are aligned with this CEP, and MRL standards and procedures. The intended environmental outcomes for the W2P are summarised in Section 4, with the relevant standards and criteria by which completion of the proposed measures and fulfilment of the intended outcomes can be assessed. In addition to the monitoring proposed to address specific aspects, hazards, and risks set out in the sections below, monitoring to assure conformance to, and assess the effectiveness of, proposed management measures across all aspects will incorporate site inspections and audits, as described in Section 6.5, and reporting of hazards, incidents, and non-conformances, as described in Section 7.
3.4.2. Heritage As indicated in Section 2.2, no Aboriginal heritage sites will be disturbed as a consequence of W2P construction works, as the pipeline route has been designed to avoid all sites. For the purpose of due diligence in accordance with the DPLH guidelines, WLPL will implement the management strategies as outlined in Table 10.
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Table 10: Heritage Mitigation Strategies
Activities Clear and grade, trenching, and other ground-disturbing works; general vehicle and plant movements. Hazards Disturbance of ground to Aboriginal heritage sites may be present. Mitigation Measures Disturbance to Aboriginal heritage sites. Heritage surveys completed for all W2P construction areas in conjunction with Traditional Owners. MRL personnel and contractors to be made aware of any Aboriginal heritage sites in close proximity to the pipeline. Construction boundaries will be demarcated to prevent encroachment of works outside of areas clear of Aboriginal heritage sites. Regular Inspection and maintenance of construction boundaries for entire duration of all works in vicinity of heritage sites. Restriction of construction works and movements to CROW, approved access routes, and other approved work areas. Cease work within ~100m and immediately report to the MRL Heritage and Land Access Officer if any Aboriginal cultural material is found during the course of construction. Address cultural heritage in inductions, toolbox talks, training, and site procedures, including requirements to: Remain within approved construction boundaries. Protect sites and exclusion zones. Stop work if suspected artefacts found. Systems and Procedures Heritage Management Procedure MRL-EN-PRO-0015. Standards, Code of Practice, and Guidelines DPLH Aboriginal Heritage Due Diligence Guidelines 2013. APGA Code of Environmental Practice – Onshore Pipelines 2017. Monitoring (in addition to scheduled inspections and audits) Observation for signs of disturbance beyond marked boundaries, or encroachment into heritage site exclusion zones (day-to-day). As-built survey of disturbed areas for conformance to approved areas (at practical completion). Records Heritage survey reports. Alignment lists. Land disturbance permits. As-built surveys. Stakeholder consultation and third-party complaints register. Inspection and audit reports. Hazard, incident, and corrective action registers. Induction, toolbox talk, and pre-start meeting register.
WLPL considers residual risks to heritage after the proposed controls to be ALARP, with reference to the hierarchy of controls in the EP guidelines, including: Elimination: The area of disturbance for the W2P cannot practicably be eliminated or substantially reduced with available construction methods. Proposed CROW widths can be reduced to avoid disturbance to known or suspected Aboriginal heritage sites. Substitution: The pipeline centreline and CROW have been adjusted within the pipeline licence and minerals tenure, to avoid identified sites. Isolation: Aboriginal heritage sites and their exclusion zones have been identified through surveys with relevant Traditional Owners, and where directed by the Traditional Owners, shall be marked for protection on alignment lists and in the field ahead of construction works. Engineering: Engineering controls are not considered applicable. Administration: The Traditional Owners have confirmed there is no requirement for Aboriginal Heritage Monitors to be engaged for these particular works. In the event subsurface material is identified, works will cease in the area and WLPL’s Heritage & Land Access Officer to be contacted immediately to assess the material and will be responsible for notifying the relevant authorities and Traditional Owners. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks to heritage values are considered acceptable, on the basis that WLPL has exercised due diligence in accordance with relevant guidelines, has consulted with Traditional Owners on the proposed works who were subsequently engaged in on-ground surveys to identify the location of any Aboriginal heritage sites.
3.4.3. Vegetation, Flora, and Habitat As noted in Section 2, the vegetation and habitats of the W2P area are considered common and widespread within the region, and construction will disturb only a small fraction of their extent; no listed ecological communities, declared rare flora, or priority flora have been identified within the proposed areas of disturbance. Fauna of conservation significance, in particular Bilbies, and their habitats have been identified in the W2P area. The W2P area will be checked for Bilby burrows as part of the MRL land clearing and site disturbance procedures, and where necessary the area of disturbance will be adjusted to avoid such sites, where practicable, or translocation will be arranged. Trained fauna personnel (Sections 3.4.4 and 6.4.2) will assist with such pre- clearing checks. WLPL nevertheless intends to minimise and control any new disturbance, and reinstate the pipeline corridor and other temporary construction areas as soon possible, to mitigate impacts to regional vegetation, flora, and habitat as summarised in Table 11.
Table 11: Vegetation, Flora, and Habitat Measures
Activities Clear and grade, trenching, backfill, reinstatement, general vehicle and plant movements. Hazards Disturbance to native or pastoral vegetation and habitat. Mitigation Measures Disturbance of vegetation and habitat from construction works Make use of existing disturbance for the W2P layout as far as practicable, including access routes and other ancillary workspaces; negotiate with third parties for use of existing disturbed areas where necessary. Undertake pre-clearance surveys for Bilby and Mulgara prior to commencement of clearing, focusing on identification of burrows; Pre-clearance surveys will be undertaken: A maximum of two weeks (as per Condition 6a of CPS 8068/1) and a minimum of three days prior to commencement of clearing activities in areas of suitable habitat. A maximum of two weeks (as per Condition 6a of CPS 8068/1) and a minimum of two days prior to clearing in areas identified as not suitable habitat. Adjust CROW to avoid burrows or arrange capture and translocation of affected individuals to suitable habitat. Survey and clearly mark out construction boundary to prevent over-clearing or encroachment of works into adjacent areas; mark any mature trees or other significant vegetation for retention where practicable. Limit construction works and movements to CROW, approved access tracks, and other approved construction areas. Clearing is only to occur during daylight hours, minimising light spill and nocturnal animal interactions. Separately stockpile cleared vegetation and topsoil adjacent to construction areas for use in rehabilitation; progressively reinstate disturbed areas as soon as practicable according to measures set out under “reinstatement” (Sections 1.9.14 and 3.4.13) Topsoil stripped (minimum of 0.15m) and pushed into windrows (< 2m height). Address protection of vegetation and flora in inductions, toolbox talks, training, and site procedures, including requirements to remain within approved construction boundaries; and retain marked vegetation. Report any disturbance beyond marked or approved boundaries, or damage to vegetation marked for retention, for investigation and corrective action (Section 7). Systems and Procedures Land Clearing Procedure MRL-EN-PRO-0004. Site Disturbance Permit Procedure MRL-EN-PRO-0005. Environment – Inspections and Audits MRL-EN-PRO-0008. Environment – Legal and Other Obligations MRL-EN-PRO-0006. Standards, Code of Practice and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. AS 4970-2009 – Protection of Trees on Development Sites. Relevant conditions of “Part V” permit to clear native vegetation. Monitoring (in addition to scheduled inspections and audits) Observation for signs of disturbance beyond marked boundaries, or damage to vegetation marked for retention (day-to-day). As-built survey of disturbed areas for conformance to approved areas (at practical completion). Records Vegetation and flora survey reports. Land disturbance permits. As-built surveys. Practical completion checklists. Inspection and audit reports. Hazard, incident, and corrective action registers. Induction, toolbox talk, and pre-start meeting register.
WLPL considers residual risks to vegetation and flora values after controls to be ALARP with reference to the hierarchy of controls, including: Elimination: the disturbance to vegetation for the W2P cannot practicably be eliminated or substantially reduced with available construction methods; CROW width (maximum 30 m) are in line with similar projects, and industry guidelines; the duration of disturbance will however be minimised through progressive reinstatement (final access track width of 4 m). Substitution: no practicable changes to the pipeline route to substantially mitigate risks to vegetation and flora are apparent; the vegetation and flora identified in the W2P area are considered common and widespread in the region. Isolation: vegetation of higher conservation value (such as mature trees) within the CROW will be marked for retention, where practicable. Engineering: no particular engineering controls are considered applicable to this aspect. Administration: systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks to vegetation and flora values are considered acceptable, on the basis that NVCP 8068/1 was granted on 11 October 2018 and that 88 % of the construction disturbance footprint will be reinstated at the completion of construction) (Section 5).
3.4.4. Fauna As noted in Section 2.9, the habitats of the W2P area are common and widespread in the region, and construction will disturb only a small fraction of their regional extent. Species of conservation significance have been recorded in the habitats through which construction will progress. WLPL intends to minimise, control, and reinstate disturbance to habitats as set out in Section 3.4.3 and Section 3.4.13. Adjacent pastoral land use also presents a risk of impacts to stock, although this is primarily considered a community land use or stakeholder issue, rather than environmental. Potential impacts on fauna and management measures are summarised in Table 12. A particular hazard associated with buried pipeline construction is fauna entrapment in open trenches, for which conventional measures, including trench inspection and fauna retrieval by qualified persons are proposed. Trained fauna personnel (Section 6.4) will be engaged to conduct fauna retrieval and relocation from the open trench and from the construction area generally, as well as pre-clearance surveys for conservation significant fauna (Section 3.4.3).
Table 12: Fauna Measures
Activities Clear and grade, trenching, backfill, general vehicle and plant movements, night works/ lighting; water supply Hazards Vehicle and plant collisions with fauna; fauna entrapment in excavations or pipes; light disturbance to fauna. Mitigation Measures Injury or disturbance to native fauna or stock from vehicle and mobile plant movements Restrict construction works and vehicle movements to the CROW, approved access routes, and other approved construction areas. Impose speed limits for W2P vehicles along CROW and access routes - 80 km/h on unsealed roads unless signed otherwise; 40 km/h on the CROW during daylight hours and 20 km/h at night. At all times, all employees are required to drive to conditions. Restrict construction works and vehicle movements to daylight hours as far as practicable - clearing activities are only to be undertaken during daylight hours. Address vehicle and mobile plant hazards to fauna in inductions, toolbox talks, training, and procedures, including: requirements to stay on approved access routes; and observe speed limits; verify that drivers and operators are properly licensed and competent. Conduct night works subject to JHA5 or other risk assessment addressing hazards to nocturnal fauna.
Death of native fauna or stock from entrapment in pipeline trench, other excavations, turkey nests or pipe strings
5 Job hazard analysis, an on-site risk assessment conducted in light of changes to conditions, personnel, equipment, materials, or equipment, or other changes that may affect the nature and level of associated risks. Fence turkey nest dams to prevent access by larger fauna; provide egress ramps / netting to allow smaller fauna to escape. Pipe lengths shall be inspected to ensure no fauna inside prior to welding. Once pipe lengths are welded, end caps shall be placed on ends to prevent fauna entry. Trench gaps to be left in open trench as per requirements for access roads and pastoral movement. For areas where pre-clearance survey outcomes have identified the presence of Conservation Significant Fauna, ramps to be constructed every 100 m and no more than 30O for fauna egress. For areas where pre-clearance survey outcomes have not identified the presence of Conservation Significant Fauna, ramps to be constructed 1 km or less and no more than 45O for fauna egress. Open trench extent where Conservation Significant Fauna and/or habitat is identified is to be limited to what can be safely inspected in two hours by qualified fauna handlers, including construction breaks. Open trench extent for areas not located in areas where Conservation Significant Fauna and/or habitat identified to be limited to what can be safely inspected in three hours by designated fauna handlers, including construction breaks. Close all trenches over construction breaks within 7 days, except for bell-holes and other ramped excavations, unless adequate numbers of designated fauna handlers remain on site. Place fauna shade cover such as sand-filled hessian or calico bags in the trench every 50-100 m to allow fauna to shelter. Weather conditions, particularly high rainfall and/or extreme temperature events need to be monitored regularly via BOM and by observations on site. If significant rainfall events are predicted and the trench cannot be backfilled in time, additional fauna inspections are to be undertaken to minimise the risk of fauna deaths due to drowning. Inspect trenches according to the following schedule: Where conservation significant fauna and/or habit has been identified, open trenches shall be inspected two hours after sunrise and two hours before sunset and immediately before pipe laying and backfilling. Where conservation significant fauna and/or habit has not been identified, open trenches will be inspected three hours after sunrise and three hours before sunset and immediately before pipe laying and backfilling. Where the expected maximum daily temperature is forecast to exceed 35ºC, trench inspections shall be completed two hours after sunrise and two hours before sunset and immediately before pipe laying and backfilling. Inspect pipe lengths for fauna before welding; keep end caps on strings of two or more sections to prevent fauna ingress. Backfill trench, to at least cover laid pipe, as soon as practicable after pipe laying, to prevent entrapped fauna from hiding under pipe. Pre-clearance fauna surveys shall occur prior to any clearing of native vegetation. Pre-clearance fauna surveys, inclusive of identification of Bilby and Mulgara burrows, and relocation of Bilby and Mulgara, shall be conducted by a fauna specialist, as per the requirements of Condition 6 of Clearing Permit 8068/1. For the avoidance of doubt, the fauna specialist must have the following qualifications: A tertiary qualification specializing in environmental science or equivalent A minimum of 2 years work experience in fauna identification and surveys of fauna native to the region being inspected or surveyed; and; A valid fauna licence issued under the Wildlife Conservation Act 1950. Trench inspections shall be conducted by a qualified fauna handler. Fauna handler requires experience in: fauna identification (amphibians, reptiles and mammals) capture and handling of amphibians, reptiles and mammals (importantly venomous snakes and large varanids) assessing injured fauna and their suitability for release (be familiar with fauna vouchering) ecology of species to be potentially encountered in order to relocate them to suitable habitat animal welfare legislation and performing euthanasia venomous snake handling training Recommended relocation process is displacement, rather than capture to minimise stress on animal. Where burrows are identified as ‘active’, individual animals will be, where practicable, displaced. Where displacement is not practicable, animals will be captured and relocated to suitable habitat. The relocation process involves: One burrow entry is to be excavated and the burrow progressively destroyed to encourage Bilby/Mulgara to exit Methods to confirm that the Bilby/Mulgara has successfully been displaced can include the use of motion sensors/cameras and/or secondary activity In areas of suitable habitat for Bilby and Mulgara (currently estimated as the northern 16 km of the CROW), pre- clearance activities will be undertaken a maximum of two weeks (as per Condition 6a of CPS 8068/1) and a minimum of three days prior to commencement of clearing activities and will focus on identifying Bilby and/ or Mulgara burrows. The additional time (3 days) for clearance work and relocation is due to the greater potential for identification of animals within these areas. In areas not of suitable habitat for Bilby and Mulgara (16 km to 80km), pre-clearance activities will be undertaken a maximum of two weeks (as per Condition 6a of CPS 8068/1) and a minimum of two days prior to clearing. In the event the relocation is not successful within a minimum of 3 days, clearing may proceed along the CROW; however a buffer of 10 m shall be maintained around the burrow. The associated noise and vibration may encourage the Bilby/Mulgara to exit the burrow Clearing of burrow shall only occur once successful relocation is confirmed and the burrow has been destroyed to prevent re-entry. If relocation is not confirmed within 3 days, trapping to capture animals is then to be undertaken. Any Bilby/Mulgara captured is to be relocated, where practicable to suitable habitat (and under vegetation cover) at least 500 m away within 1 hour or suitably housed until sunset and then released at least 500 m away. Due to the remote location of W2P, any additional care such as transport to Port Hedland for further medical attention is to be assessed on a case by case basis in consultation with the fauna handler and Project Manager. In the event conservation significant fauna is injured (or is dependent young) and is not able to be re-released (based on veterinarian advice), the DBCA shall be consulted for rehabilitation. Where transportation of fauna to Port Hedland for further medical attention is considered appropriate, the following veterinarian clinics are available: South Hedland Vet, 14 Hedditch St, South Hedland, 08 9172 1608 Port Hedland Vet, 8 Edgar St, Port Hedland, 08 91734254 Prior to the transportation of fauna to Port Hedland, the fauna handler is to seek veterinarian advice to confirm that transportation is an appropriate course of action. Fauna that requires rehabilitation should be taken to Pilbara Wildlife Carers Association based on veterinarian advice. Conservation significant fauna shall be taken to the veterinarian (Port Hedland) and are not to be euthanised by WLPL unless under the instruction of a qualified veterinarian. Euthanisation decision for non-conservation significant fauna shall be made by Fauna Handler / Environment personnel in consultation with the Project Manager and only be performed by experienced personnel. Once successfully euthanised, the specimen shall be disposed of appropriately. If a threatened species, DBCA or WA Museum should be contacted to determine if the carcass is required for scientific purposes. Disturbance to native fauna from light overspill Limit night-time works to hydrotesting and occasional movement of equipment along CROW. Conduct night-time works subject to JHA or other risk assessment addressing hazards to fauna from light spill. Arrange and direct lighting to minimise overspill. General measures Address hazards to fauna in toolbox talks, training, and procedures, including restrictions on open excavations, requirement to minimise interactions, and how to contact designated handlers. Implement pastoral stock management measures, including keeping gates open or closed, or installing fencing or cattle grids along CROW, in accordance with requirements of pastoral leaseholders. Address hazards to fauna in JHAs, including collisions, entrapment, and disturbance. Following details shall be kept in the Fauna Register: Species. Caught location (GPS) and time/date. Number of individuals. Individual condition (health/age/injuries). Outcome (treatment/release/euthanisation). Fauna handler / fauna specialist name. Pipeline Supervisor/ Project Manager name. Veterinarian/ Wildlife Carer contacted. Record all fauna injury and mortality through designated handlers; report injury or mortality of significant fauna to DMIRS/DBCA, as per the required Departmental timeframes (Section 7). Key contact details are: DMIRS Petroleum - [email protected] DBCA - [email protected] DMIRS Minerals/NVCP - [email protected] Implement other measures for protection of native fauna and habitats as set out in management sections for “vegetation and habitat”, “wastes”, “noise and vibration”, ”weeds, pests, and diseases”, and “reinstatement”. Systems and Procedures Fauna Management Procedure MRL-EN-PRO-0001. Site Disturbance Permit Procedure MRL-EN-PRO-005. Land Clearing Procedure MRL-EN-PRO-004. Environment – Inspections and Audits MRL-EN-PRO-0008. Environment – Legal and Other Obligations MRL-EN-PRO-0006. Standards, Code of Practice and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. WLPL and DBCA standards for fauna handler qualifications and experience (Section 6.4). Monitoring (in addition to scheduled inspections and audits) Logging of fauna retrieved from open trench, including species, location and mortality; records submitted to DMIRS and DBCA according to “s15” permit requirements. Records Fauna survey reports. Trench fauna inspection and retrieval records. Land access agreements. Stakeholder consultation and third-party complaints register. Inspection and audit reports. Hazard, incident, and corrective action registers. Induction, toolbox talk, training, and JHA register.
WLPL considers residual risks to vegetation and flora values after controls to be ALARP with reference to the hierarchy of controls, including: Elimination: the disturbance to habitats for the W2P cannot practicably be eliminated or substantially reduced with available construction methods, but the duration of disturbance can be minimised through progressive reinstatement; the extent of trenching cannot be eliminated or practicably substantially reduced, however trenches will be closed as soon as practicable. Substitution: the habitats of the W2P area are extensive, and no practicable changes to the pipeline route to substantially mitigate risks to fauna are apparent. Isolation: features of higher habitat value, such as mature trees, will be identified, and marked for retention where practicable. Engineering: Trench gaps to be left in open trench as per requirements for access roads and pastoral movement; egress ramp locations based on pre-clearance survey outcomes; fauna shelters will be placed in the trench to improve the survival prospects of smaller trapped fauna. Administration: substantial, trained resources will be dedicated to daily open trench inspections and fauna relocation. WLPL has committed to trench inspections occurring as a minimum; on a daily basis (prior to sunrise and prior to sunset) to identify any entrapped animals, in addition to any fauna prior to pipe-laying and backfilling. Other systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks to fauna values are considered acceptable, on the basis that the habitats affected are common and widespread in the region. Some fauna of conservation significance may use the W2P area, however they are not constrained to this area, and any subsequent disturbance will be largely temporary (i.e. 88 % of the W2P disturbance area will be reinstated and rehabilitated at the completion of construction).
3.4.5. Soils and Land Use Potential impacts to soil and land use from pipeline construction typically includes loss or degradation of topsoil resources (from earthworks, vehicle movements, or erosion of disturbed surfaces), salinisation from use of saline water, or acidification or contamination from exposed ASS or contaminated material. Proposed management measures for the W2P to protect soils and land uses are summarised in Table 13. Potential impacts to soils and land use from spills of hydrocarbons and hazardous chemicals in particular are addressed in Section 3.4.7.
Table 13: Soils and Land Use Measures
Activities Clear and grade, trenching or other excavation, reinstatement, water storage, dust suppression, hydrotesting, site access, general vehicle and plant movements. Hazards Water and wind erosion of disturbed surfaces; loss or degradation of topsoil resources; exposure of ASS or contaminated materials; soil and land salinisation; damage to third party land or roads. Potential Impacts and Proposed Mitigation Measures Loss or degradation of topsoil resources from earthworks, vehicle movements, wind or water erosion Clearly mark out boundaries of construction area to prevent unnecessary disturbance. Strip topsoil (minimum of 150 mm) from construction areas and stockpile adjacent, for use in rehabilitation. Stockpile topsoils away from vehicle access points to prevent damage/ loss by vehicle movements; place signs or markings to prevent driving or parking over stockpiles. Stockpile topsoils away watercourses, and areas prone to flooding; leave breaks in stockpiles to allow natural surface water flows, and prevent flooding or water erosion of stockpiles. Keep topsoil stockpiles < 2m high to minimise wind erosion. Progressively re-spread topsoil over disturbed areas as soon as practicable at completion of works; res-spread cleared vegetation over topsoil to promote revegetation and prevent erosion. Address topsoil management and preservation in inductions, toolbox talks, and procedures, including protection of topsoil stockpiles. Report substantial loss of topsoil or damage to stockpiles for investigation and corrective action. Implement other measures to prevent water erosion and promote restoration of a stable land surface, as set out under “water” and “reinstatement and maintenance”. Soil erosion from inadequate drainage control on disturbed surfaces, or uncontrolled release of water from hydrotesting Install appropriate measures (berms, sediment fences, etc.) along CROW and other construction areas, to control surface water flows to prevent erosion of disturbed surfaces. Schedule construct works to be substantially complete before high rainfall season. Remediate any surface erosion on construction areas as part of reinstatement, if necessary. Dispose of used hydro test water to the Wodgina pit for re-use in the operation’s mine water circuit (Section 1.9.13) Report substantial erosion or poorly controlled drainage on construction areas for investigation and corrective action. Saline impacts to soils from storage or use of groundwater water for dust suppression Determine water quality / salinity from proposed sources and assess suitability for use in dust suppression. Strip topsoil (min. 150 mm) and stockpile (< 2m high) adjacent to but separate from construction areas. Spray dust suppression water with care to prevent overspray onto topsoil stockpiles / windrows and/or surrounding vegetation. Remediate any areas demonstrating signs of salinisation caused in course of construction as part of reinstatement works. Scarify construction areas before re-spreading topsoil, to break up any saline crust and promote infiltration and salt flushing, as part of remediation works. Store saline water in lined dam; shape area around standpipe to contain saline water spills. Report soil salinisation or vegetation death from use or storage of saline water, for investigation and corrective action (Section 7). Impacts to soils from ASS or contamination exposed by trenching or other excavation Report signs of unexpected ASS or contamination in spoil for investigation and corrective action. Impacts to soils from release of drilling fluids/ grouting used in bored crossings Engage experienced, reputable specialist HDD contractor. Establish earthen bunds around HDD sites to prevent runoff of spilled drilling fluids. Excavate entry and exit pits sufficient to contain drilling fluids from worst realistic release. Use only benign bentonite/mud mix for drilling fluid; use any additional chemicals only with approval from DMIRS. Continuously monitor for leaks, spills, and breakouts of drilling fluids while boring, stop works immediately and contain if release occurs. Develop site-specific HDD crossing procedure, incorporating requirements of this CEP. Report loss of containment of drilling fluids, for investigation and corrective action. Impacts on land use / third parties from road / land degradation due to site access Keep construction works and movements to CROW, approved access routes, and other approved construction areas Impose speed limits to reduce damage to access roads and tracks - 80 km on unsealed Roads unless signed otherwise; CROW shall be a maximum of 40 km/hr during daylight hours and 20 km/hr during night hours. At all times, all employees are required to drive to conditions. Assess proposed access routes in consultation with relevant landholders to determine need for upgrade / repair works and/or additional controls such as special speed limits, vehicle type restrictions, etc. Inspect access tracks over course of construction works and maintain/ repair where appropriate. Repair and reinstate access tracks in line with landholder expectations and agreements for use. Address protection / maintenance of roads and tracks in inductions, toolbox talks, and site procedures, including use of approved routes, speed limits, restrictions, and driving to conditions; verify drivers and operators licensed and competent. Report damage to roads and tracks from construction use for investigation and corrective action. Systems and Procedures Surface Water Management Procedure MRL-EN-PRO-0003. Site Disturbance Permit Procedure MRL-EN-PRO-005. Land Clearing Procedure MRL-EN-PRO-004. Land Rehabilitation Procedure MRL-EN-PRO-009. Dust Management Procedure MRL-EN-PRO-012. Environment – Inspections and Audits MRL-EN-PRO-0008. Environment – Legal and Other Obligations MRL-EN-PRO-0006. Standards, Code of Practice, and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. IECA Best Practice Erosion and Sediment Control – Land-based Pipeline Construction (2008). Monitoring (in addition to scheduled inspections and audits) Observation for erosion of or damage to soil stockpiles, or signs of salinisation (day-to-day). Observation for damage to or excessive wear on access routes (day-to-day). Monitoring for erosion at point of hydro test water discharge (during disposal). Records Water quality reports. Land disturbance permits. Land access agreements. Stakeholder consultation and third-party complaints register. Inspection and audit reports. Hazard, incident, and corrective action register. Induction, toolbox talk, and pre-start meeting register.
As noted in Section 2, excavation works are expected to present little or no risk of exposing ASS or existing contamination; however measures to address these risks remain in the CEP for contingency. Similarly, as noted in Section 1.4.6, water to be used for dust suppression is expected to be generally fresh to brackish, with little risk of soil salinisation; however measures to address this potential risk have also been addressed in this CEP.
WLPL considers residual risks to soil and land use values after controls to be ALARP with reference to the hierarchy of controls, including: Elimination: the area of disturbance for the W2P cannot practicably be eliminated or substantially reduced with available construction methods, but the duration of disturbance can be minimised through progressive and prompt reinstatement. Substitution: the land systems and drainage patterns of the W2P area are widespread, and no practicable changes to the pipeline route to substantially mitigate risks to soil and land, such as avoiding watercourses, are apparent. Isolation: topsoil resources will be stripped and stockpiled separately from construction areas and spoil stockpiles, to prevent physical damage or salinisation. Engineering: measures to prevent erosion and sediment transport, such as sediment containment fences will be installed on disturbed areas or areas under rehabilitation. Administration: systems and procedures as set out in the table above are intended to support the proposed measures sitting higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks to soils and land use values are considered acceptable, on the basis that habitats are widespread, relevant landholders have been consulted, and have not presented substantial concerns; further, that any impacts are expected to be localised and within the means of the construction contractor to remediate without recourse to third-party resources. 3.4.6. Water Potential impacts to water from pipeline construction typically include transport of sediments from disturbed surfaces into watercourses; groundwater drawdown from abstraction for water supply or trench dewatering; and potential contamination of surface water and groundwater associated with storage and use of chemical and hydrocarbons. As noted in Section 2.6, drainage lines and water bodies of the region are ephemeral and surface water flow or inundation only occurs after particularly heavy rains. Disturbance within the W2P area will be largely temporary and the pipeline corridor, including drainage line crossings, will be reinstated shortly after construction. WLPL expects that water will be supplied from existing licensed sources, within existing assessed and approved infrastructure and allocations (Section 1.4.6).; If any additional abstraction infrastructure or allocation is required, WLPL or the construction contractor will seek assessment and approval, in conjunction with the relevant licence holder. As noted in Section 0, pipeline trench and other excavations will not encounter groundwater to an extent that will require dewatering. Proposed management measures are summarised in Table 14. Potential impacts to water from spills of hydrocarbons and hazardous chemicals are addressed in Section 3.4.7.
Table 14: Water Measures
Activities Clear and grade, trenching and other excavation, drainage line crossings, reinstatement, water supply. Hazards Soil erosion, transport and deposition from disturbed surfaces; redirection / interruption of surface water, land disturbance, impacts on water resources. Potential Impacts and Proposed Mitigation Measures Impacts on surface water quality from release of sediment due to earthworks Align watercourse crossings with access tracks or other existing infrastructure where practical. Clearly delineate boundaries of disturbance through drainage lines. Stockpile vegetation, topsoil, and trench spoil outside of drainage lines, to reduce interruption of natural surface water flows and reduce potential for erosion and transport of sediments. Install erosion and sediment controls (berms, sediment fences, etc.) as directed by approved surface water management procedure. Schedule construction works to avoid high rainfall season. Reinstate CROW and other construction areas as soon as practicable, to stabilise disturbed surfaces and restore resistance to erosion. Reinstate disturbed areas to restore patterns of drainage, infiltration, and evaporation, and resistance to erosion, as set out in “reinstatement and maintenance”; leave long-term erosion and sediment controls where required. Report poorly controlled drainage, erosion or sediment transport on or from construction areas, for investigation and corrective action. Systems and Procedures Surface Water Management Procedure MRL-EN-PRO-0003. Site Disturbance Permit Procedure MRL-EN-PRO-005. Land Clearing Procedure MRL-EN-PRO-004. Land Rehabilitation Procedure MRL-EN-PRO-009. Environment – Inspections and Audits MRL-EN-PRO-0008. Environment – Legal and Other Obligations MRL-EN-PRO-0006. Standards, Codes of Practice, and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. IECA Best Practice Erosion and Sediment Control – Land-based Pipeline Construction (2008). Monitoring (in addition to scheduled inspections and audits) Observation for signs of erosion and maintenance of drainage / sediment controls (day-to-day). Records Land disturbance permits. Water extraction records. Inspection and audit reports. Hazard, incident, and corrective action registers.
WLPL considers residual risks to water values after controls to be ALARP with respect to the hierarchy of controls, including: Elimination: disturbance to drainage lines cannot be eliminated, but the areas and duration of disturbance will be minimised; water use for the W2P cannot be eliminated, but will be minimised. Substitution: given the drainage patterns of the region, no practicable changes to the pipeline route to substantially reduce impacts to drainage lines are apparent; use of alternative dust suppression agents is not considered practicable or necessary. Isolation: no particular isolation controls are identified for this aspect, except to the extent that scheduling construction works to avoid the period of highest rainfall can be regarded as an isolation control. Engineering: construction works will be arranged to minimise interruption to natural surface water flows; measures will be put in place to control surface flows and prevent erosion and sediment transport on and from disturbed areas; rehabilitation works will aim to restore natural flows and resistance to erosion. Administration: construction works will be subject to erosion and sediment control procedures, with particular attention on drainage lines, incorporating the measures higher in the hierarchy of controls as set out above. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks to water values are considered acceptable, on the basis that there is no material risk to high- quality or scarce regional water resources, or water bodies of conservation significance.
3.4.7. Hydrocarbons and Chemicals Potential impacts from the transport, storage, use, handling and transfer of hydrocarbons and other hazardous chemicals used in pipeline construction include contamination of soil, surface water, and groundwater contamination. In the case of the W2P the volumes of hydrocarbons and chemicals proposed for construction (Section 0) present a low risk of contamination to the environment. Potential impacts and proposed management measures for the W2P are summarised in Table 15; management of hazards from wastes contaminated by hydrocarbons or hazardous chemicals is addressed in Section 3.4.7. The CEP also provides an Oil Spill Contingency Plan (OSCP) for the management of major spills of hydrocarbons and other hazardous chemicals in the course of construction works, addressed in Section 6.8. In addition, an emergency response plan (ERP) for the W2P will address major spill response, with reference to the OSCP and CEP.
Table 15: Hydrocarbon and Chemical Measures
Activities Transport, storage, transfers, handling, or use of hydrocarbons or hazardous chemicals / materials; plant and vehicle maintenance. Hazards Spills or leaks of hydrocarbons or hazardous chemicals / materials. Potential Impacts and Proposed Mitigation Measures Contamination of soils; combustible fuel hazard: Use existing approved facilities at Wodgina mine site to store bulk hydrocarbons for construction works; facilities incorporate appropriate secondary containment, transfer interlocks, and lined and bunded transfer pads. Refuel and service vehicles, plant and equipment at Wodgina mine site facilities whenever practicable. Use double-hulled fuel trucks or trailers to refuel to vehicles, plant and equipment along CROW, where return to mine site for refuelling is impractical. Use service trucks service vehicles, plant and equipment along CROW, where return to mine site for servicing is impractical. Use drip trays, where practicable when refuelling or servicing on CROW. Forbid unattended refuelling or other transfers of hydrocarbons or hazardous chemicals; use spotter to assist operator if necessary. Store hydrocarbons and hazardous chemicals in designated areas, away from busy areas or heavy traffic routes. Provide secondary containment for hydrocarbons and hazardous chemicals with capacity >110% of largest container and >25% of total storage (whichever greater); provide portable bunded containers (spill pallets) for minor storage. All bunds shall have grates that prevent access to animals, with bunds inspected on a daily basis; all containers shall remain closed when not in use to ensure no fauna entry. Store substances with potential for adverse interactions in separate bunds at appropriate distance. Return hydrocarbons and hazardous chemicals to designated storage area when not in use. Make spill response, containment, and recovery equipment readily available in construction areas in line with use of hydrocarbons and hazardous chemicals; commandeer earthworks equipment (excavators, loaders, etc.) to assist with spill containment and recovery where appropriate. Carry substantial spill kits on fuel tankers/ trailers and service trucks, capable of dealing with largest credible spill; train operators in spill kit use and large spill response. Incorporate checks for leaks or potential leaks into pre-mobilisation inspections, daily pre-start checks, and periodic maintenance checks, for vehicles, plant and equipment; maintain according to manufacturer’s specifications, to prevent leaks and spills. Control construction traffic, including approved access routes and speed limits, to reduce risk of collisions resulting in spills; verify drivers and operators appropriately trained and licensed; maintain access routes to provide safe driving conditions. Max speed limits along the CROW shall be 40 km/hr during daylight hours and 20 km/hr during night hours. At all times, all employees are required to drive to conditions. Maintain register of all hydrocarbons and hazardous chemicals stored on site; make SDS for all stored substances readily available; review relevant SDS as part of JHAs and attach to JHA document. Address greatest credible spills of hydrocarbons and hazardous chemicals in ERP and OSCP. Address transport, storage, and handling of hydrocarbons and hazardous chemicals in inductions, toolbox talks, and procedures, including transfers, inspections, maintenance, spill response, and waste disposal; provide additional training for higher-risk roles (e.g., fuel and service truck operators). Apply pipeline coatings with reasonable care to minimise overspray/ drips; place plastic sheeting placed to capture overspray/ drips; recover substantial loss to ground recovered with shovels for appropriate disposal; use appropriately rated hoses for coating; keep spill kits with coating rig in case of hose failure. Consider tasks involving hydrocarbon or chemical transport, storage, handling, or transfers in JHAs; identify and address associated hazards, including management of any wastes / contaminated materials. Remediate all residual contamination by completion of reinstatement; confirm as part of practical completion inspections (checks for signs such as staining, etc.). Report improper storage or leaks and spills, including location, size, and nature of spill, and details of clean up/ remediation for investigation and corrective action; report substantial spills to DMIRS (Section 7). Store used containers with residual hydrocarbons or hazardous chemicals as if full until disposed of; treat used containers as contaminated waste. Manage contaminated wastes including used containers or contaminated soils from spill recovery as set out under “wastes”. Contamination of surface waters: measures as above, plus: Store hydrocarbons and hazardous chemicals as far as practicable from drainage lines. Carry out refuelling as far as practicable from drainage lines, and at least 100 m; mark “no-refuelling” zones along the CROW. Complete construction works within and near drainage lines as quickly as is practicable. Park up vehicles and mobile plant away from drainage lines when not in use. Contamination of groundwater; measures as above plus: Identify wellhead locations within PDWSA and ensure no refuelling or chemical or hydrocarbon storage is conducted within a 500 meter radius exclusion zone of these locations (e.g. WPZ 173). No mobile mechanical servicing and/or wash down within the PDWSA area, except in the case of emergency or breakdown. Systems and Procedures Hydrocarbon and Chemical Procedure MRL-EN-PRO-002. Surface Water Management Procedure MRL-EN-PRO-0003. Waste Management Procedure MRL-EN-PRO-011. Environment – Inspections and Audits MRL-EN-PRO-0008. W2P Oil Spill Contingency Plan and Emergency Response Plan (no. TBD). Standards, Codes of Practice, and Guidelines AS1940 – Storage and Handling of Flammable and Combustible Liquids. DMIRS Code of Practice - Storage and Handling of Dangerous Goods 2010. APGA Code of Environmental Practice – Onshore Pipelines 2017. DWER Water Quality Protection Note 25 – Land Use Compatibility for PDWSAs DWER Water Quality Protection Note 60 Tanks for mobile fuel storage in PDWSAs DWER Water Quality Protection Note 65 – Storage and Use of Toxic and Hazardous Substances. DWER Water Quality Protection Note 29 – Mobile Mechanical Servicing and Cleaning NTC Australian Code for the Transport of Dangerous Goods by Road and Rail 2007. DWER Assessment and Management of Contaminated Sites 2014. Monitoring (in addition to scheduled inspections and audits) Observation for improperly stored hydrocarbons or chemicals, signs of spills or leaks (hydrocarbon staining, etc.) (day-to-day). Records Supply logs and invoices for hydrocarbons and hazardous chemicals. Site SDS and hazardous substances register. Pre-mobilisation inspection certificates for vehicles, plant, and equipment. Pre-start and maintenance logbooks for vehicles, plant, and equipment. Practical completion checklists. Inspection and audit reports. Hazard, incident, and corrective action registers. JHA register. Induction and training registers.
WLPL considers residual risks from hydrocarbons and other hazardous chemicals to be ALARP with respect to the hierarchy of controls, including: Elimination: with current technology it is not practicable to eliminate or substantially reduce the use of hydrocarbons or hazardous chemicals, in particular diesel fuel; presently no electric vehicles or heavy plant, or alternative power supply suitable for pipeline construction use are available. Substitution: the fuels and chemicals selected for the W2P are the least hazardous that are suitable for the intended uses, for occupational safety, as well as environmental protection. Isolation: fuels and chemicals will be kept away from high traffic areas at risk of collision, and away from sensitive features such as drainage lines. Engineering: bulk fuel storage and delivery systems will incorporate interlocks to prevent spills and overflows; hydrocarbons and chemicals will be kept within secondary containment such as double- hulled tanks, bunds or spill pallets; measures such as refuelling grids, drip trays will be used to contain spills during transfers; Hydrocarbon spill kits will to be available to manage any reported spill. Administration: fuel and chemical storage, plant, and vehicles will be frequently inspected and maintained to prevent spills and leaks. An OSCP and ERP will be in place to mitigate impacts from loss of containment. Other systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks from hydrocarbons and other hazardous chemicals are considered acceptable, on the basis that the most significant potential impact identified (i.e. localised contamination of soils) will be within the means of the construction contractor to remediate immediately and without the requirement for additional external third-party resources.
3.4.8. Wastes Pipeline construction generates a variety of industrial, domestic, inert, and potentially contaminated wastes, as summarised in Section 1.4.8. Potential impacts, if these waste streams are not adequately managed, include impacts on vegetation, habitats and land uses, contamination, and encouragement of feral species. Proposed management measures are summarised in Table 16, and incorporate proper segregation, containment, and frequent collection of wastes.
Table 16: Wastes Measures
Activities Mobilisation; supply of goods, materials, and equipment; catering; waste disposal. Hazards Litter; windblown or poorly contained wastes; contaminated or hazardous wastes; food wastes. Potential Impacts and Proposed Mitigation Measures Impacts on surrounding land use, vegetation, habitats, and fauna from improper disposal of inert wastes Use bins, skips, and other appropriate containment with lids for holding wastes till collection; provide adequate capacity to prevent containers over-filling between collections. Provide appropriate lids / covers for waste containers to prevent wind-blown wastes; return wind-blown wastes to containment. Remove wastes from CROW daily to collection points at Wodgina mine site. Segregate wastes as required by for landfill disposal or collection by waste contractor; stockpile scrap and other inert industrial wastes in designated areas. Arrange frequent progressive disposal of wastes to landfill or collection as appropriate; prevent large quantities of wastes from accumulating on site. Forbid disposal of wastes in pipe trench or other excavations. Segregate recyclable materials and arrange collection for recycling where practicable. Remove all residual wastes from construction areas at completion of works; confirm as part of practical completion inspections. Report improperly contained or segregated waste for investigation and corrective action. Attraction / encouragement of feral pests or harm to native fauna from improper disposal of food wastes Provide bins/skips with secure lids / covers for food wastes at appropriate locations around construction areas. Return all food wastes/ scraps from construction areas every day, for collection in bins/skips at Wodgina mine site. Arrange frequent disposal of food wastes in landfill; prevent large quantities of food wastes from accumulating on site. Forbid feeding of animals or unauthorised disposal of food waste. Report uncontained or poorly contained food wastes, or scavenging by animals, for investigation and corrective action. All feral animals caught shall be transported immediately for euthanisation. Feral animal control measures include: baiting, trapping and/or culling for the feral cat (Felis catus), feral dog (Canis lupis), the European red fox (Vulpes vulpes) and the European rabbit (Oryctolagus cuniculus). Contamination of soils and/or surface water from improper management of contaminated wastes and residues Keep contaminated wastes including used containers with hydrocarbon or chemical residues, or contaminated materials from spills, in dedicated, bunded containment, segregated from other wastes. Arrange licensed contractor to collect and dispose of contaminated wastes at a facility appropriately licensed for the class(es) of materials. Remove contaminated wastes from site progressively; prevent large quantities of contaminated wastes from accumulating. Remove all remaining contaminated wastes at completion of works; confirm as part of practical completion inspections. Report improperly contained or segregated contaminated waste, for investigation and corrective action. General Address waste management in inductions, toolbox talks, and procedures, including collection points, and proper waste segregation. Systems and Procedures Waste Management Procedure MRL-EN-PRO-011. Hydrocarbon and Chemical Procedure MRL-EN-PRO-002. Environment – Inspections and Audits MRL-EN-PRO-0008. Standards, Codes of Practice, and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. DWER Landfill Waste Classification and Waste Definitions 1997. Monitoring (in addition to scheduled inspections and audits) Site observation for proper segregation and containment of wastes (day-to-day). Site observation for signs of scavenging/ pests (day-to-day). Records Materials supply records and invoices. Waste collection receipts and disposal invoices. Inspection and audit reports. Practical completion checklists. Hazard, incident, and corrective action registers. Project induction and training registers.
WLPL considers residual risks from construction wastes to be ALARP with reference to the hierarchy of controls, including: Elimination: over-runs of materials are avoided as far as practical, for cost as well as environmental reasons, but cannot be avoided entirely; a minimum level of packaging is required for expensive construction materials and equipment to survive the long journey from point of manufacture, including dusty unsealed roads. Substitution: all materials currently specified for the W2P are considered the most appropriate for the intended uses, and no alternatives to mitigate waste are apparent. Isolation: wastes will be returned daily to collection points, and kept in suitable containment for collection; hazardous wastes will be segregated and kept in secondary containment. Engineering: wastes will be kept in containment suitable to prevent over-topping, scavenging, and wind-blown wastes; food wastes in particular will be kept in bins with secure lids. Administration: The construction areas will be inspected frequently for management of waste and housekeeping. Other systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks from wastes are considered acceptable, on the basis that the expected worst realistic impacts will be localised and within the means of the construction contractor to remediate within a reasonable time, without recourse to external third-party resources.
3.4.9. Fire Bushfires resulting from natural causes such as lightning strikes are part of the natural ecological processes in the region; human activity has however changed the pattern of bushfires, and unnatural bushfires can impact the vegetation, habitats, and land uses of the region. Proposed management measures are summarised in Table 17, and incorporate measures such as guarding sources of ignition (welding, grinding, etc.), management of flammable materials, and maintaining a fire response capacity, for both small (spot) and larger fires.
Table 17: Fire Measures
Activities Welding, angle grinding, electrical work, general plant and vehicle operation; smoking. Hazards Uncontained sources of ignition near vegetation susceptible to bushfire. Potential Impacts and Proposed Mitigation Measures Impacts on flora, fauna, land use, and third parties from bushfire started by construction works Maintain fire response equipment on site; locate fire fighting trailers close to fire risk works (hot works such as welding); maintain fire extinguishers in or on all vehicles or mobile plant. Commandeer construction equipment (grader, dozer, water truck) for fire fighting (clearing firebreaks, pushing up bunds, wetting surfaces, etc.) where practicable and safe to do so. Keep construction works and movements (other than survey and set-out) to cleared CROW, access routes, and other approved, cleared construction areas. Park up vehicles in designated cleared areas when not in use, away from vegetation. Store all equipment, materials, and waste in designated cleared areas, away from vegetation; keep hydrocarbons and flammable chemicals in dedicated, marked containers and storage areas. Remove flammable materials from areas around hot work areas or other fire hazards; maintain housekeeping to keep work areas free of flammable materials. Operate permit system for hot works, including welding and grinding; have fire spotter in place for hot works or other works with higher fire risk. Address local fire services in ERP, including services at Wodgina mine site and Hedland; make emergency contact details available to all personnel. Consider fire risk conditions (e.g., hot, dry, and/or windy weather) in pre-starts and JHAs. Monitor weather forecasts and DFES alerts for fire risk conditions; apply to DFES for fire ban exemptions where necessary and appropriate (Error! Reference source not found. 11– Exemption Notice). Permit smoking only at designated places within cleared construction areas; forbid disposal of butts on the ground; provide bins for safe disposal; forbid open / camp fires. Address fire hazards and fire response in inductions, toolbox talks, training, and procedures, including safe storage of equipment and materials, housekeeping, hot work permits, use of fire fighting equipment, and emergency contacts. Report improperly managed sources of ignition or accidental fires for investigation and corrective action. Systems and Procedures Hydrocarbon and Chemical Procedure MRL-EN-PRO-002. Environment – Inspections and Audits MRL-EN-PRO-0008. Wodgina Bush Fire Management Plan D799791-SAF-PLN-0011. W2P Emergency Response Plan (no. TBD). Standards, Code of Practice and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. DFES Guidelines for Operating Private Equipment at Fires 2011. Monitoring (in addition to scheduled inspections and audits) Observation for fire hazards including poorly guarded/ isolated sources of ignition, poor housekeeping, or improper storage of flammable materials (day-to-day). Records Inspection and audit reports. Hazard, incident, and corrective action registers. Pre-start meeting records. Induction, toolbox talk, training, and JHA register. Emergency response drill records. WLPL considers residual risks of fire from construction works to be ALARP with respect to the hierarchy of controls, including: Elimination: hot works such as welding cannot practicably be eliminated with current construction methods. Substitution: all materials currently specified for the W2P are considered the least flammable suitable for the intended use; no alternatives to mitigate fire risk are apparent. Isolation: flammable materials will be kept stored away from hot works or other fire hazards; hot works will be conducted in cleared areas, away from vegetation; hot works will be suspended during fire bans (unless exempted under permit – Error! Reference source not found. 11). Engineering: equipment will be on hand for fire response, with personnel trained in its use. Administration: permits to work, including requirements for fire spotters, will be enforced for hot works. An ERP will be in place to mitigate the impacts of any accidental fire. Other systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry best practices, such as those set out by APGA [13]. Residual risks from fire are considered acceptable, on the basis that while major off-site impacts may result from a fire accidently started by construction works, with the controls proposed the likelihood of such an event is “rare”, and the residual risk rated as “medium”.
3.4.10. Weeds, Feral Pests, and Diseases As noted in Section 2, a number of weeds, feral pest species and introduced flora species common to the region have been identified within the W2P area, or may be expected to occur, although there are no known susceptibilities to particular diseases (such as dieback) in the region. In additional, a number of feral pests common to the region have been identified within the W2P area, or may be expected to occur, including feral cat (Felis catus), feral dog (Canis lupis), the European red fox (Vulpes vulpes) and the European rabbit (Oryctolagus cuniculus). Potential impacts from pipeline construction include the spread of weeds by clear and grade or other construction movements along the CROW or access routes; in addition, new weeds, feral pests, or diseases may be imported with buildings, containers, equipment, or materials. Proposed measures are summarised in Table 18 , and are principally based on ensuring that vehicles, plant, buildings, containers, equipment, or materials are brought to site clean, and that appropriate hygiene (i.e. food/ waste) is maintained for the duration of the W2P. W2P construction works will make use of existing wash down facilities at the Wodgina mine site and commercial facilities at Port Hedland; in addition, a mobile wash down facility including water tank and high-pressure hose may be used to maintain mobile plant hygiene along the CROW. Post-construction inspections will include monitoring, and where the need is indicated, management of weeds and pests.
Table 18: Weed and Pest Measures
Activities Clear and grade, trench padding and backfill, reinstatement, mobilisation of equipment, containers, and buildings, general vehicle and plant movements. Hazards Import, spread, and/or export of weeds, pests, or disease into, within, or out of W2P area. Potential Impacts and Proposed Mitigation Measures Impacts on vegetation, habitats, and land uses from introduction and/or spread of weeds Keep construction footprint as small as practicable, to minimise disturbed area susceptible to colonisation by weeds. Certify vehicles, mobile and fixed plant, equipment, and materials as clean, and free of clumps of soil or vegetation, before entry to the W2P. Mark known weed locations on alignment lists; mark in field as part of survey and set-out. Arrange clear and grade to work into, rather than out of, known weed areas where practicable; clean down clear and grade plant and vehicles often, and particularly after working through known weed locations. Keep construction works and movements to CROW, approved access tracks, and other approved construction areas; minimise construction movements as far as practicable (e.g., use of shared crew bus for transport). Keep vehicles and mobile plant generally clean and free of clumps of soil or vegetation for duration of the W2P (include in pre-start checks). Consult landholders and other relevant stakeholders on weed management requirements / expectations; incorporate into contractor specifications. Address management of weeds in inductions, toolbox talks, and procedures, including hygiene requirements, and information on weeds known to occur in W2P area. Report breaches of hygiene, or new or spreading weed populations, for investigation and corrective action. Impacts on vegetation, habitats, and land uses from introduction and/or spread of pest animals Certify temporary buildings, containers, and other structures as clean and free of pests before entry to the W2P. Report breaches of hygiene, or substantial numbers of pests for investigation and corrective action (Section 7). Manage food wastes to prevent encouragement of feral pests as set out under “wastes”. Reinstate disturbed areas to prevent encouragement of feral pests as set out under “reinstatement and maintenance”. Systems and Procedures Weed Hygiene and Control Procedure MRL-EN-PRO-007. Site Disturbance Permits Procedure MRL-EN-PRO-005. Land Clearing Procedure MRL-EN-PRO-004. Environment – Inspections and Audits MRL-EN-PRO-0008. Standards, Code of Practice and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. Monitoring (in addition to scheduled inspections and audits) Observation for general vehicle and plant hygiene (day-to-day). Observation for weeds and pests around construction areas (day-to-day). Records Pre-mobilisation hygiene inspection certificates for vehicles, plant, equipment, buildings, containers, and materials. Pre-start logbooks for vehicles and mobile plant, including hygiene checks. Inspection and audit reports. Hazard, incident, and corrective action registers. Induction, toolbox talk, and training registers. WLPL considers residual risks from weeds, introduced flora species and feral pests to be ALARP with respect to the hierarchy of controls, including: Elimination: mobilisation of equipment and materials, access to site, vehicle movements, and earthworks cannot be eliminated; however vehicle movements and disturbance will be kept to the minimum practicable. Substitution: No particular substation controls appear relevant to this aspect as weeds and feral pests are common and widespread throughout the W2P area. Isolation: weeds/ introduced flora species/ feral pests identified in surveys will be marked on line alignment lists; clear and grade works will be managed as far as practicable to prevent the spread of weeds from affected to unaffected areas. Engineering: no particular engineering controls appear relevant to this aspect. Administration: vehicles, equipment, buildings, and materials will be certified clean and inspected on entry to the W2P and food wastes will be managed to discourage feral pests. Other systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks from weeds and pests are considered acceptable, on the basis that weeds and introduced flora species have already been spread through the region by past and current land uses, including pastoralism, minerals exploration, and mining. The W2P construction works are short-term and restricted to a discrete area (88 % of the construction disturbance area will be reinstated and rehabilitated at the completion of construction), and unlikely to contribute in any material way to the spread of weeds in the region, based on the implementation of controls as listed above.
3.4.11. Dust and Emissions to Air Dust may be generated from pipeline earthworks (including clear and grade, and trenching), wind erosion of disturbed surfaces, and general vehicle movements; potential impacts include smothering of vegetation or nuisance to third parties although the pipeline is remote from any premises for most of its length. Proposed management measures are summarised in Table 19, and incorporate measures such as dust suppression during construction works. Emissions to air include diesel exhaust from fixed and mobile plant, with attendant risks of local air pollution or contribution to greenhouse effects, although these are considered minor or insignificant in the context of regional or global emissions, given the limited duration of works, and ALARP. No gas will be present in the W2P under the scope of works addressed by this CEP; introduction of gas and management of emissions from planned (venting) or unplanned gas releases will be addressed in the COEP.
Table 19: Dust and Air Emissions Measures
Activities Clear and grade, trenching, reinstatement, general vehicle and plant movements; operation of plant and equipment. Hazards Dust; diesel exhaust. Potential Impacts and Proposed Mitigation Measures Impacts on vegetation and/or third parties from dust Keep water truck on site for dust suppression; site supervisors to direct additional dust suppression as required by conditions. Keep construction works and movements to CROW, approved access routes, and other approved areas where dust can be controlled; minimise movements as far as practicable. Set speed limits for vehicles on unsealed surfaces; reduce speeds in dusty conditions. Max speed limits along the CROW shall be 40 km/hr during daylight hours and 20 km/hr during night hours. At all times, all employees are required to drive to conditions. Limit height of topsoil (<2 m) and spoil stockpiles as far as practicable while remaining within CROW. Consult and engage with any third parties potentially affected by dust; maintain register of any related complaints. Address management of dust in inductions, toolbox talks, and procedures, including speed restrictions, driving to conditions, and dust suppression. Report excessive / poorly controlled dust for investigation and corrective action. Contribution to local air pollution and/or global greenhouse effect from vehicle and plant operation Select W2P vehicles, fixed and mobile plant, and fuels conformant to current Australian standards for emissions. Operate, inspect and maintain vehicles and fixed and mobile plant according to manufacturer’s specification to minimise emissions. Record fuel use quantities; estimate emissions for reporting to DMIRS, NPI, and NGER. Address air emissions in inductions, toolbox talks, and procedures, including vehicle and plant inspections and maintenance. Report unreasonable/ excessive emissions for investigation and corrective action. Systems and Procedures Dust Management Procedure MRL-EN-PRO-0012. Environment – Inspections and Audits MRL-EN-PRO-0008. NGER & NPI Management Procedure MRL-EN-PRO-0014. Standards, Code of Practice, and Guidelines Relevant manufacturer’s specifications and service manuals for vehicles, plant, and equipment. DIRDC Australian Design Rules 2018. Fuel Quality Standards Regulations 2001. APGA Code of Environmental Practice – Onshore Pipelines 2017. Monitoring (in addition to scheduled inspections and audits) Observation for excessive dust (day-to-day, particularly in hot, dry, and/or windy conditions). Records Fuel consumption logs/ meter readings; plant and vehicle log books. Inspection and audit reports. Hazard, incident, and corrective action registers. Third-party complaints register. JHA register. Induction and training registers. WLPL considers residual risks from dust and emissions to air to be ALARP with respect to the hierarchy of controls, including: Elimination: Earthworks and vehicle movements cannot be eliminated, but will be kept to the practicable minimum. Substitution: No practicable alternatives to diesel plant for automotive and electrical power are presently available for construction projects of this type. Isolation: Earthworks will be avoided in conditions (hot, dry, and/or windy) where dust cannot be adequately managed. Engineering: Water sprays will be used to reduce dust emissions from construction areas and spoil piles; plant and vehicles will be maintained to minimise emissions. Administration: The systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices such as those set out by APGA [13]. Residual risks from dust and air emissions are considered acceptable, on the basis that: Dust emissions will be localised and predominantly restricted to the period of construction. As with dust emissions, greenhouse and other emissions to air over the short duration of construction works will be negligible in the context of the region, including emissions from the Wodgina and other mining operations.
3.4.12. Noise and Vibration Earthworks, mobile and fixed plant operation, rock-breaking, and general vehicle movements for pipeline construction will produce noise and vibration, with potential localised impacts on third parties and fauna. WLPL does not however expect to use blasting for any excavation. Most of the pipeline route is remote from community receptors, and given the limited duration of works in any one location as construction progresses along the corridor, the risk of lasting impact to fauna is considered low. Noise from venting will be addressed in the COEP. Proposed management measures are summarised in Table 20.
Table 20: Noise and Vibration Measures
Activities Clear and grade, trenching, rock-breaking, reinstatement; general plant, and vehicle operation. Hazards Noise and vibration. Potential Impacts and Proposed Mitigation Measures Disturbance to native fauna and third parties from noise and vibration due to operation of plant and equipment Equip all vehicles and fixed and mobile plant with noise reduction measures, such as mufflers or enclosures; operate, inspect, and maintain according to manufacturer specifications. Consult and engage with any third parties potentially affected by noise or vibration; maintain register of any related complaints. Report any unreasonable/ excessive noise or vibration for investigation and corrective action.
Systems and Procedures Environment – Inspections and Audits MRL-EN-PRO-0008. Standards, Code of Practice and Guidelines Relevant manufacturer’s specifications and service manuals. DIRDC Australian Design Rules 2018. APGA Code of Environmental Practice – Onshore Pipelines 2017. Monitoring (in addition to scheduled inspections and audits) Observation for excessive noise or vibration, or improperly maintained noise controls (day-to-day). Records Pre-start and service logbooks. Inspection and audit reports. Hazard, incident, and corrective action registers. Third-party complaints register. Induction and training registers.
WLPL considers residual risks from noise and vibration to be ALARP with reference to the hierarchy of controls, including: Elimination: earthworks cannot be eliminated with current construction methods, but will be minimised where practicable. Substitution: the equipment proposed is considered appropriate (i.e. fit for purpose) for the intended uses and will conform to relevant noise standards. Isolation: no particular isolation controls appear applicable to this aspect. Engineering: equipment will incorporate noise reduction measures. Administration: The systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices such as those set out by APGA [3]. Residual risks from noise and vibration are considered acceptable, on the basis that works are short-term, and will progress rapidly along the W2P corridor; no uncommon or restricted habitats are identified, or any residences or other third-party premises likely to be adversely affected.
3.4.13. Reinstatement and Maintenance Inadequate reinstatement activities have the potential to impact on vegetation, habitat, and land uses, including soil erosion, proliferation of weeds on disturbed areas, and encouragement of feral / pest animals from water ponding, where drainage is not properly restored. In addition, the pipeline corridor will create a new access corridor to unauthorised personnel (egg. recreational 4WD), although given the location of the W2P, the risk is considered low. As noted in Section 2.8, weeds and introduced flora species readily occur within the region as a consequence of past and current land uses, including pastoralism, minerals exploration, and mining activities. However, WLPL will take steps to reduce the risk of an increase/ spread of such species in the course of construction works. Proposed mitigation measures are set out in Table 21, and include checks to assure that reinstatement is completed according to specification, and post-construction monitoring to assure that reinstated areas remain stable and free of erosion, with drainage restored to prevent ponding, and vegetation regrowth trending towards its pre-disturbance condition. Table 21: Reinstatement and Maintenance Measures
Activities Reinstatement and maintenance of disturbed areas. Hazards Wind and water erosion, dust and sediment transport; opening up of country to unauthorised users; weed proliferation; attraction/encouragement of feral animals Potential Impacts and Proposed Mitigation Measures Erosion of soils, weed proliferation, and impacts to land uses due to inadequate reinstatement At completion of works, and except where otherwise agreed with landholders, reinstate disturbed areas by: Respreading stockpiled topsoil evenly, to return growth medium and seed bank. Scarifying across contours, to trap seed and water. Respreading stockpiled vegetation, to return vegetative material, and provide resistance to erosion. Set out clear requirements and responsibilities for rehabilitation in access agreements and contract documents. Address conformance to rehabilitation requirements in practical completion acceptance checks; require contractor 12 month warranty for defects arising from inadequate reinstatement. Address inspection and maintenance of reinstated areas in OEP. Continue to liaise with landholders over life of operations to assure satisfaction with reinstatement; maintain register of related complaints. Attraction of feral animals attracted to water ponding due to inadequate reinstatement Measures as above, plus: Backfill and compact trench and reinstate adjacent areas, to ensure that water does not pool and encourage feral species. Develop and implement measures to control feral animals, in conjunction with relevant regulators and landholders, if the need is indicated by monitoring under OEP and risk assessment. Opening up of country to unauthorised 4WD access Measures as above, plus: Install gates, bunds, and signs at pipeline corridor entry to prevent / deter unauthorised access. Develop and implement measures to control feral animals, in conjunction with relevant landholders, if the need is indicated by monitoring under OEP and risk assessment. Systems and Procedures MRL Land Rehabilitation Procedure MRL-EN-PRO-0009. W2P Operations Environment Plan (no. TBD). Standards, Code of Practice, and Guidelines APGA Code of Environmental Practice – Onshore Pipelines 2017. Monitoring (in addition to scheduled inspections and audits) Practical completion checks for acceptance of reinstatement works under contract. Inspections under OEP to address erosion, weeds, feral animals, and unauthorised access/ use. Records Practical completion / acceptance checklists. Stakeholder consultation and third-party complaints register. Hazard, incident, and corrective action register. Operations inspection reports.
WLPL considers residual risks from inadequate reinstatement and maintenance to be ALARP with reference to the hierarchy of controls, including: Elimination: the area of disturbance for the W2P cannot practicably be eliminated or substantially reduced with available construction methods. Substitution: the land systems, drainage patterns, land uses, vegetation, and habitats of the W2P area are extensive, and no practicable changes to the pipeline route to substantially mitigate risks associated with reinstatement and maintenance are apparent. Isolation: no particular isolation controls appear applicable to this aspect. Engineering: the pipeline trench will be backfilled and carefully compacted, and disturbed areas reinstated to restore natural drainage patterns; bunds and gates will be put in place where appropriate to deter unauthorised access. Administration: reinstated areas will be inspected for conformance to specification before acceptance at practical completion, and for stability and revegetation over the life of operations. Other systems and procedures as set out in the table above are intended to support the proposed measures that sit higher in the hierarchy of controls. Overall, WLPL considers the controls for this aspect in line with similar projects approved in the region, and consistent with industry practices, such as those set out by APGA [13]. Residual risks from inadequate reinstatement and maintenance are considered acceptable, on the basis that impacts are expected to be localised within widespread vegetation types, habitats, and land uses, with remediation works anticipated to involve minor earthwork activity. 4. OBJECTIVES, STANDARDS, AND MEASUREMENT CRITERIA Environmental objectives for the W2P construction works, with reference to the sources of risk identified in Section 3, are set out in Table 22 along with standards (key management measures, as identified in Section 3.4) to be met in fulfilling those objectives, and criteria by which the extent to which standards have been met can be measured. In accordance with Regulation 14 (5) (c) of the of the Petroleum Pipeline (Environment) Regulations 2012, all actions listed under “measurement criteria” in Table 22 below are defined so to be auditable and measurable.
Table 22: Objectives, Standards, and Measurement Criteria
Risk Source Objectives Standards Measurement Criteria
Damage to Aboriginal heritage No disturbance to any Risk to heritage areas will be managed in accordance with standards specified in Heritage Records from practical completion surveys and hazard / incident register sites due to ground disturbance Aboriginal Heritage sites. Management Procedure (MRL-EN-PRO-0015), including: confirm no disturbance beyond approved boundaries. from construction works MRL personnel and contractors to be made aware of any Aboriginal heritage sites in close Records from weekly inspections confirm construction boundary and proximity to the pipeline. exclusion zones are clearly marked for duration of works. Information pertaining to cultural heritage matters will be provided to all personnel via SDPs clearly show heritage exclusion areas. inductions, toolbox talks, training, and site procedures, including requirements to: Induction register confirms all personnel have completed inductions. Remain within approved construction boundaries. Incident and consultation registers confirm works were suspended and MRL Protect sites and exclusion zones. Heritage and Land Access Officer notified where any suspected heritage Stop work if suspected artefacts found. material identified. Cease work within ~100m and immediately report to the MRL Heritage and Land Access Officer if any Aboriginal cultural material is found during the course of construction. In accordance with the Site Disturbance Permit Procedure (MRL-EN-PRO-0005): Site Disturbance Permits (SDPs) for clearing will clearly show heritage exclusion areas. In accordance with the Land Clearing Procedure (MRL-EN-PRO-0004): Construction boundaries will be demarcated to prevent encroachment of works outside of areas identified as being clear of Aboriginal heritage sites. Regular Inspection and maintenance of construction boundaries for entire duration of all works in vicinity of heritage sites. Extent of actual disturbance will be surveyed at practical completion to confirm no disturbance of heritage areas. Disturbance to vegetation and Disturbance within approved Disturbance of vegetation will be managed in accordance with standards specified in the Land Induction register confirms all personnel have completed inductions. habitats by construction works areas. Clearing Procedure (MRL-EN-PRO-0004) and will include: Hazard/incident register and records from practical completion surveys Disturbance minimised, where All personnel will complete an induction that includes information on requirements for confirm no disturbance beyond approved boundaries. practicable. protection of vegetation and habitat. Fauna and survey records confirm areas inspected for Bilby burrows ahead of Make use of existing disturbance for W2P layout as far as practicable, including access routes construction; CROW adjusted or relocation arranged where appropriate; and other ancillary workspaces; negotiate with third parties for use of existing disturbed areas, individual animals relocated as required. where necessary. Weekly inspection records confirm construction boundary clearly marked; The construction area will be clearly marked out in the field ahead of clear and grade. markers remain in place for duration of works. Markings will be maintained during construction works. Pre-start checks will be conducted prior to any clearing to ensure all operators are familiar with clearing requirements, including clearing boundaries. All construction works and movements will remain within the construction areas approved in this CEP, including the CROW and access roads. Clearing is only to occur during daylight hours, minimising light spill and nocturnal animal interactions. Extent of actual disturbance surveyed at practical completion to ensure disturbance is within areas approved in this CEP. Undertake pre-clearance surveys for Bilby and Mulgara prior to the commencement of clearing activities, focussing on the identification of burrows; Pre-clearance surveys will be undertaken by a fauna specialist: A maximum of two weeks (as per Condition 6a of CPS 8068/1) and minimum of three days prior to commencement of clearing activities in areas of suitable habitat. A maximum of two weeks (as per Condition 6a of CPS 8068/1) and minimum of two days prior to clearing activities in areas identified as not suitable habitat. Adjust CROW to avoid burrows or arrange capture and translocation of affected individuals to suitable habitat.
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Fauna mortality from Risks to fauna from entrapment will be managed in accordance with the W2 FMP and will Pre-clearance surveys and trench inspection records confirm all inspections entrapment in open trench include: undertaken as per agreed commitments of this CEP. minimised. Trench gaps to be left in open trench as per requirements for access roads and pastoral Trench inspection records confirm gaps and shelters in place for full extent of movement. open trench. For areas where pre-clearance survey outcomes have identified the presence of Conservation Fauna Register records confirm all displacement/ relocation activities were Significant Fauna, ramps to be constructed every 100 m and no more than 30O for fauna egress. undertaken as per agreed commitments of this CEP. For areas where pre-clearance survey outcomes have not identified the presence of Conservation Significant Fauna, ramps to be constructed 1 km or less and no more than 45O Training register confirms that all pre-clearance surveys, trench inspections for fauna egress. and displacement/ relocation activities were undertaken by appropriately All open trenches shall be inspected: trained personnel, as per the requirements as listed in this CEP (Table 12). . o Two hours after sunrise and two hours before sunset and immediately before pipe laying and backfilling where conservation significant fauna habit identified. o Three hours after sunrise and three hours before sunset and immediately before pipe laying and backfilling in areas where conservation significant fauna habit not identified. o Two hours after sunrise and two hours before sunset and immediately before pipe laying and backfilling where the expected maximum daily temperature is forecast to exceed 35ºC. Recommended relocation process is displacement, rather than capture to minimise stress on animal. o Where burrows are identified as ‘active’, individual animals will be, where practicable, displaced. Where displacement is not practicable, animals will be captured and relocated to suitable habitat. Injury or death to fauna from pipeline construction works. Backfill trench, to at least cover laid pipe, as soon as practicable after pipe laying, to prevent entrapped fauna from hiding under pipe. Trench inspections and fauna relocation completed by licensed handlers meeting DBCA training requirements and licensed to take fauna under Regulation 15 of the WC Act. Pre-clearance surveys, inclusive of identification of Bilby and Mulgara burrows, and relocation of Bilby and Mulgara, shall be conducted by a fauna specialist, as per the requirements of Condition 6 of Clearing Permit 8068/1. Fauna mortalities from other Risks to fauna from general construction activities, including vehicle strike, will be managed in Incident register maintained as per the requirement of this CEP, including construction works minimised accordance with the W2 FMP , including: recording of all fauna injury and mortality events. Construction works and movements restricted to areas approved under this CEP, including the All Reportable events, including mortality of significant fauna reported to CROW and access roads. DMIRS/DBCA, as per the required Departmental timeframes (Section 7). Speed limits for W2P vehicles along CROW and access routes - 80 km/h on unsealed roads Fauna Register correctly maintained with appropriate details, as required by unless signed otherwise; 40 km/h on the CROW during daylight hours and 20 km/h at night. At this CEP, including: all times, all employees are required to drive to conditions. Species. Construction works and movements kept to daylight hours unless necessary and exempted Caught location (GPS) and time/date. under approved JHA addressing collision hazards to nocturnal fauna. Number of individuals. Conformance to contractor Safe Driving and Light Vehicle Procedure 2045-HS-011-3. Individual condition (health/age/injuries). Fence turkey nest dams to prevent access by larger fauna; provide egress ramps / netting to allow Outcome (treatment/release/euthanisation). smaller fauna to escape. Fauna handler / fauna specialist name. Prior to the transportation of injured fauna to Port Hedland, the fauna handler is to seek Pipeline Supervisor/ Project Manager name. veterinarian advice to confirm that transportation is an appropriate course of action. Veterinarian/ Wildlife Carer contacted. In the event conservation significant fauna is injured (or is dependent young) and is not able to be JHA register confirm any night works carried out under approved JHA. re-released (based on veterinarian advice), the DBCA shall be consulted for rehabilitation. Loss of topsoil resources due to Minimise loss of topsoil Topsoil resources will be managed in accordance with standards specified in the Land Clearing Weekly inspection records confirm topsoils appropriately placed and construction works. resources. Procedure (MRL-EN-PRO-0004), including: stockpiled; no substantial erosion of or damage to stockpiles; no use of topsoil Sufficient topsoil resources Topsoil stockpiles limited to <2 m height, to prevent loss due to erosion. other than in rehabilitation; and no driving of parking on topsoil stockpiles. available for rehabilitation of No driving or parking over topsoil stockpiles. construction area.
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Topsoil management and preservation information to be provided to all employees via inductions, Practical completion inspection reports confirm disturbed areas (except those toolbox talks, including protection of topsoil stockpiles. associated with long-term infrastructure) are reinstated within three months Erosion by water will be minimised in accordance with Surface Water Management Procedure of works completion, including returning of all topsoil and respread of (MRL-EN-PRO-003). This will include stockpiling topsoil with gaps to allow water flows, and away vegetation to prevent erosion. from drainage lines or other places prone to erosion or flooding. Disturbed areas will be reinstated as soon as practicable following completion of all construction works, according to the Land Rehabilitation Procedure (MRL-EN0PRO-0009). This will include returning topsoil efficiently (e.g. topsoil not used to backfill excavations) and vegetation respread to stabilise potential erosion. Erosion, sediment transport, and Minimise erosion, sediment Erosion and sedimentation will be controlled according to standards in the Land Clearing Procedure Weekly inspection records confirm: loss of topsoil resources from transport and loss of topsoil (MRL-EN-PRO-0004) and Surface Water Management Procedure (MRL-EN-PRO-003), including: Stockpiles have gaps that allow natural surface water flows to be disturbed areas. due to construction. Breaks left in topsoil and spoil piles to retain natural surface water flows during construction, retained. and prevent flooding and erosion. Topsoil stockpiles are placed 50 m from drainage lines or flood-prone Stockpile vegetation, topsoil, and trench spoil outside of drainage lines, to reduce interruption areas. of natural surface water flows and reduce potential for erosion and transport of sediments. Control structures such as berms and sediment fences are used as Where required, control structures such as berms and sediment fences will be used. directed by procedure. Disturbed areas will be reinstated as soon as practicable following completion of all construction Practical completion inspection reports confirm disturbed areas (except those works, according to the Land Rehabilitation Procedure (MRL-EN0PRO-0009). This will include associated with long-term infrastructure) are reinstated within three months restoring natural patterns of drainage and respreading vegetation to stabilise potential erosion. of works completion, including restoration of natural drainage and respread of vegetation to prevent erosion. Exposure of existing contamination No release of existing Potential contamination or ASS (indicated by staining, odour, moisture, colour or colour changes, Weekly inspection records and hazard/ incident register confirm no or ASS by construction works contamination or ASS exposed vegetation stress, etc.) will be reported for investigation. observations of potential contamination / ASS without investigation and (if (expected negligible risk) by construction works. Identification of potential contamination or ASS will be according to methods described in DWER necessary) corrective action. Assessment and Management of Contaminated Sites 2014, Identification and Investigation of Acid Practical completion inspection reports confirm no signs of contamination / Sulfate Soils and Acidic Landscapes 2015 and/or APGA Code of Environmental Practice – Onshore ASS left at surface. Pipelines 2017. Disruption to natural patterns of No long-term disruption to Disruptions to surface water drainage will be managed according to Land Clearing Procedure (MRL- Weekly inspection records confirm stockpiles have gaps that allow natural drainage by construction natural surface water flows. EN-PRO-0004) and Land Rehabilitation Procedure (MRL-EN0PRO-0009). This will include: surface water flows to be retained. earthworks Breaks left in stockpiles to retain natural surface water flows during construction. Practical completion inspections confirm that natural ground contours have Progressively restoring ground contours as soon as practicable following completion of all been restored within three months of works completion. construction works. Operations inspection reports confirm that natural surface flows are Report poorly controlled drainage, erosion or sediment transport on or from construction areas, maintained. for investigation and corrective action. Impacts to groundwater resources Minimise changes to Groundwater will be managed according to the Groundwater Management Procedure (MRL-EN- Water metering records confirm use of water in line with similar projects and and uses from water abstraction groundwater quality and PRO-0013), including: within groundwater licence allocations. for construction use. availability. All abstraction for construction use within approved allocations provided by groundwater W2P approvals register, consultation register, and records of agreements licences and agreements with licence holders. confirm all abstraction for construction use within terms and conditions of Amendments to allocations or conditions of groundwater licences obtained where necessary groundwater licences and agreements with licence holders. for construction use, in conjunction with licence holders. Water metering and abstraction monitoring data confirm abstraction All abstraction for construction use conducted according to requirements of groundwater managed and monitored in accordance with groundwater licence conditions. licence, including metering and monitoring, and agreements with licence holders. Use of water for construction works kept to practicable minimum and in line with similar projects. Spills of hydrocarbons and other No new contamination left in Risk associated with storage and handling of hydrocarbons and other hazardous chemicals, Induction register confirms all personnel have completed inductions. hazardous materials used in construction area. including refuelling and spills, will be managed in accordance with the Hydrocarbon and Chemical Weekly inspection records confirm: Procedure (MRL-EN-PRO-0002) and OSCP, including: construction Hydrocarbons and other hazardous chemicals are stored within All personnel will complete an induction that includes information on requirements for secondary containment with capacity for largest credible spill. storage, handling, transfer, and use of hydrocarbons and hazardous materials. Spill equipment capable of dealing with largest credible spill to ground is kept on site during construction.
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Hydrocarbons and hazardous materials stored within secondary containment with capacity for Daily pre-start and maintenance logs confirm vehicles, plant, and equipment largest credible spill as per OSCP in line with AS1940 and DWER Water Quality Protection Note are inspected and maintained according to manufacturer’s specifications. 65 – Storage and Use of Toxic and Hazardous Substances. Waste collection receipts confirm appropriate disposal of all contaminated Secondary containment will be provided for hydrocarbons and hazardous chemical storage, wastes. with capacity >110% of largest container and >25% of total storage (whichever greater); Incident register confirms no outstanding remediation actions from spills at portable bunded containers (spill pallets) will be utilised for minor storage. completion of works. No refuelling or chemical or hydrocarbon storage within a 500 m radius of wellhead locations within PDWSA (Yule River). Practical completion inspection reports confirm no signs of residual Double-hulled fuel trucks and/or trailers will be utilised to refuel vehicles, plant and equipment contamination at completion of works. along CROW, where return to mine site for refuelling is impractical. Spill response, containment, and recovery equipment will be readily available in construction areas in line with use of hydrocarbons and hazardous chemicals; commandeer earthworks equipment (excavators, loaders, etc.) to assist with spill containment and recovery where appropriate. Fuel tankers/ trailers and service trucks will carry spill kits that are capable of dealing with largest credible spill; operators will be competent in spill kit use and how to respond to a large spill. No mobile mechanical servicing/wash down within the PDWSA (Yule River), except in the case of emergency or breakdown. During construction, vehicles, plant, and equipment will be operated, inspected and maintained to minimise risk of spills, in line with manufacturer’s specifications. During construction, spill response equipment capable of dealing with largest credible spill as per OSCP to ground will be kept on site. All spills will be immediately stopped, contained, recovered and remediated. All residual contamination will be removed/ remediated by completion of reinstatement works, and confirmed as part of practical completion inspections (signs such as staining, etc.). Contaminated wastes from site will be progressively removed so to prevent large quantities of contaminated wastes from accumulating. All remaining contaminated wastes to be removed from the W2P area at completion of works and confirmed as part of practical completion inspections. Report improperly contained or segregated contaminated waste, for investigation and corrective action. Disposal of hazardous wastes and No new contamination in Disposal of hazardous wastes and contaminated material will be completed in accordance with in Induction register confirms all personnel have completed inductions. contaminated materials (including construction area. the Waste Management Procedure (MRL-EN-PRO-0011), including: Weekly inspection records confirm hazardous wastes and contaminated waste hydrocarbons and All personnel will complete an induction that includes information on requirements for materials are: chemicals, contaminated disposal of hazardous wastes and contaminated materials. Segregated from other wastes and appropriately contained until containers and materials) from All hazardous wastes and contaminated materials segregated from other wastes and collection. construction. appropriately contained until collection. Progressively removed from the construction area. All hazardous wastes and contaminated materials will be collected for disposal at facilities Waste collection receipts confirm collection and appropriate disposal of all appropriately licensed for class of waste according to DWER Landfill Waste Classification and hazardous wastes and contaminated materials. Waste Definitions 1997. Practical completion inspection reports confirm all hazardous wastes and All hazardous wastes and contaminated materials will be removed from site progressively; at contaminated materials removed from site at completion of works. completion of works no hazardous wastes or contaminated materials attributable to the construction works will remain in the project area. Confirm as part of practical completion inspections. Disposal of inert and putrescible No impacts to vegetation or Disposal of inert and putrescible wastes will be completed in accordance with in the Waste Induction register confirms all personnel have completed inductions. wastes from construction habitats from wastes. Management Procedure (MRL-EN-PRO-0011), including: Weekly inspection records confirm inert and putrescible wastes are: No harm to native fauna from All personnel will complete an induction that includes information on requirements for Progressively removed from the CROW and other construction areas. wastes (ingestion or disposal of inert and putrescible wastes. Segregated from other wastes and appropriately contained in bins/skips entrapment). Inert and putrescible wastes will be collected daily from the CROW and other construction with heavy/secure lids until disposal. No encouragement of feral / areas for disposal. Disposed of at the Wodgina mine site landfill. pest species from food wastes Inert and putrescible wastes will be progressively disposed of at the DWER licensed Wodgina mine site landfill.
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All inert and putrescible wastes will be segregated from other wastes and appropriately Hazard/incident register confirms there are no incidents of substantial wind- contained in bins/skips with heavy/ secure lids until disposal to prevent littering from wind- blown waste or scavenging by pest fauna. blown waste and attraction of pest fauna. Practical completion inspection reports confirm no inert or putrescible wastes No inert or putrescible wastes from construction will remain in the construction area at attributable to construction works remain in the construction area at completion of works. Confirm as part of practical completion inspections completion of works. Fire hazard to vegetation and No changes to existing regional All personnel will complete an induction that includes information on requirements for fire Induction register confirms all personnel have completed inductions. habitats from construction works fire regime and frequencies. management. Hazard/incident register confirms no accidental fires started. No bush fires started by Potential for ignition of fires during hot works will be managed using a permit to work system Permit to work register confirms all hot works completed under permits to construction works. administered by suitably qualified personnel from WLPL or the contractor. work. Hot works permits will include completion of a JHA. Training records confirm personnel administering hot works permits have No hot works will be undertaken on fire ban days unless a DFES exemption is in place (Appendix been trained in managing fire risk. 11– Exemption Notice). JHA register confirms JHAs completed for all hot works. Fire response equipment to be maintained on site at all times. Fire fighting trailers to be located Weekly inspection records confirm fire response equipment during in close proximity to fire risk work (i.e. hot works such as welding); fire extinguishers to be construction works. maintained in or on all vehicles and associated mobile plant. Review of fire bans and construction records confirms no hot works on fire Prevention of and response to fire for the W2P will be managed according to Wodgina Bush Fire ban days without exemption from DFES. Management Plan D799791-SAF-PLN-0011. Introduction or spread of weeds, or Minimise introduction and Introduction and spread of weeds will be managed using Weed Hygiene Control (MRL-EN-PRO- Induction register confirms all personnel have completed inductions. encouragement of feral animals by spread of weeds and/or feral 0007), including: W2P asset register / equipment lists and hygiene certificates confirm all assets construction works pests. All personnel will complete an induction that includes information weed hygiene requirements certified as clean on arrival to the W2P. for vehicles, plant, and equipment. Daily pre-start logs confirm vehicles and mobile plant kept clean. All vehicles, plant, equipment, containers, and materials certified as clean on arrival to the Weekly inspection records and hazard/incident register confirm that during W2P. construction food wastes are: Vehicles and mobile plant kept generally clean, and free of clumps of soil or vegetation. Contained in securely lidded bins contained. Construction works and movements within construction areas approved under this CEP, Collected for disposed at a licensed landfill. including the CROW and access roads. Known weed locations will be marked on alignment lists. Practical completion checklists confirm no new weeds attributable to construction works identified in construction area. Encouragement of feral animals will be minimised by containing food wastes in securely lidded bins that are frequently collected for disposal at a licensed landfill during construction. Post-construction inspection reports over life of operations indicate there has been no introduction or spread of weeds and no feral fauna attracted to the All food wastes/ scraps from construction areas will be returned every day for disposal to bins/skips construction area as a result of the works. at the Wodgina mine site. Collected putrescible waste will be frequently disposed to landfill so minimise the accumulation of food wastes at the W2P area. Impacts to vegetation, habitat and Minimise dust emissions Dust will be managed in accordance with the Dust Management Procedure MRL-EN-PRO-012), Complaints register confirms no third party complaints related to dust. surrounding land uses from dust generated by construction including: Induction register confirms all personnel have completed inductions. works. due to construction works All personnel will complete an induction that includes information on dust management. Weekly inspection records and hazard/incident register confirm that during No loss of amenity for Consult and engage with any third parties potentially affected by dust; maintain register of any construction: surrounding land users or related complaints. There are no incidents of excessive dust caused by construction works. premises. Active construction areas kept adequately moist with water sprays to prevent excessive dust. Dust suppression is administered using water sprays and where required Water truck maintained on site for dust suppression; site supervisors to direct additional dust a water truck. suppression, as required by conditions. Construction activities remain within construction areas approved in this Keep construction works and movements to CROW, approved access routes, and other CEP. approved areas where dust can be appropriately managed and minimise vehicle movements Topsoil stockpiles remain ≤2 m topsoil, ≤4 m spoil. as far as practicable. Topsoil and spoil stockpiles kept to minimum: ≤2 m and ≤4 m respectively. Impacts to air quality due to Minimise emissions to air and As above and including: Incident register confirms no excessive or unplanned emissions to air. emissions from construction works keep emissions in line with Vehicles, plant, and equipment supplied with emissions reduction measures in line with Asset register confirms all assets conform to Australian Standards for similar projects. Australian Standards. emissions. Vehicles, plant, and equipment operated, inspected and maintained for duration of works to Daily pre-start and maintenance logs confirm all assets inspected and minimise emissions, in line with manufacturer’s specifications. maintained to manufacturer’s specifications to minimise noise.
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Risk Source Objectives Standards Measurement Criteria Minimise impacts on amenity Fuel use quantities recorded; emissions estimated for reporting to DMIRS, NPI, and NGER, Emissions estimates fuel use quantities recorded for reporting to DMIRS, NPI for surrounding land users or including unplanned emissions. and NGER. premises. Impacts to fauna and surrounding No significant impacts to local All personnel will complete an induction that includes information on noise management. Complaints register confirms no third party complaints related to noise. land uses from noise due to fauna from noise. Vehicles, plant, and equipment supplied with noise reduction measures (e.g. Mufflers, enclosures) Induction register confirms all personnel have completed inductions. construction works No loss of amenity for in line with Australian Standards. Asset register confirms all assets conform to relevant Australian Standards for surrounding land users or Vehicles, plant, and equipment operated, inspected and maintained for duration of works to noise. premises. minimise noise, in line with manufacturer’s specifications. Daily pre-start and maintenance logs confirm all assets inspected and Construction works and movements kept to daylight hours unless necessary and exempted under maintained to manufacturer’s specifications to minimise noise. approved JHA addressing noise hazards to nocturnal fauna. JHA register confirms any night works carried out under approved JHA. Consultation register confirms stakeholders are provided appropriate notice prior to works. Erosion of improperly reinstated Reinstated construction areas Reinstatement works will be conducted in accordance with the Land Rehabilitation Procedure Practical completion inspection reports confirm that disturbed areas have construction areas remain stable and resistant to (MRL-EN-PRO-0009), including: been reinstated to restore natural drainage and prevent erosion by erosion over a long term Restoring natural ground contours and patterns of drainage. respreading vegetation. Vegetation will be respread to stabilise potential erosion. Operations inspections reports confirm that all rehabilitated areas show rates Undertake reinstatement of disturbed areas at the completion of works, except where otherwise of erosion and sediment transport similar to surrounding landscape over long agreed with landholders, with works to include: term. Respreading stockpiled topsoil evenly, to return growth medium and seed bank. Scarifying across contours, to trap seed and water. Respreading stockpiled vegetation, to return vegetative material, and provide resistance to erosion Long-term loss of land use, Reinstated construction areas Reinstated works will be conducted in accordance with the Land Rehabilitation Procedure (MRL- Weekly inspection records confirm that topsoil is preserved in stockpiles up vegetation, or habitats, due to support self-sustaining EN-PRO-0009), including: to 2 m. poor revegetation of construction vegetation similar to Preservation of topsoil in stockpiles up to 2m during construction. Practical completion inspection reports confirm that disturbed areas have areas surrounding areas Progressively reinstating topsoil and cleared vegetation over disturbed areas as works are been reinstated to replace topsoil and cleared vegetation. complete, to restore topsoil, seed bank and infiltration to promote revegetation. Completion criteria associated with remaining “active” operational areas of All remaining “active” areas of the W2P will be incorporated into the mine closure plan for the the W2P will be addressed in the Wodgina Mine Closure Plan. Wodgina operations, in accordance with the Mining Act requirements.
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
5. LEGISLATION AND OTHER REQUIREMENTS In addition to requirements under the Petroleum Pipelines Act and Petroleum Pipeline Regulations that are addressed by this CEP, requirements under other environmental, social, or related legislation that are commonly relevant to pipeline construction are summarised in Table 23 along with their particular relevance to construction of the W2P, and status of any approvals required or likely to be required. WLPL will maintain a register and library of all applications and approval instruments relevant to the W2P, in accordance with MRL procedure MRL-EN-PRO-0006 Environment - Legal and Other Obligations. Stakeholder consultation and engagement relevant to legislation and approvals is addressed in Section 8. WLPL was granted Clearing Permit CPS 8068/1 on 11 October 2018 to allow for clearing of native vegetation for construction of the W2P (240 ha), as addressed in Section 5. Measures proposed to control clearing and minimise associated risks and impacts to the environment are addressed in Section 3.4.3. Note: should the maximum approved NVCP Permit footprint of 240 ha be utilised, any remaining disturbance required for the W2P construction will be addressed under the Environmental Protection (Clearing of Native Vegetation) Regulations 2004 Schedule 1 Item 2(2) – Exemption for clearing of 10ha within a financial year for any purpose on land that is not an environmental sensitive area and is administered under the Mining Act 1978.
Table 23: Regulation Relevant to Pipeline Construction
Legislation / Aspect Relevance / Status for W2P Native Title Act 1993 Division 3 (agreements for development of lands under claim) Access to lands subject to Pipeline licence PL116 lies within the Kariyarra People native title claim (1999/03), native title claim or represented by the Yamatji Marlpa Aboriginal Corporation. determination. WLPL has established agreements for the existing Wodgina operations, and continues to liaise with Traditional Owners on the proposed expansions, including the W2P (Section 8). Aboriginal Affairs Planning Act 1972 s31 (permits to enter and remain on Aboriginal reserves) Access to Aboriginal No entry into on any Aboriginal reserve necessary for proposed works; nearest reserves. reserves (31427;31428 “Yandeyarra”) about 20 km southwest of W2P area. Aboriginal Heritage Act 1972 s18 (consent to disturb heritage sites) Ministerial consent to No Aboriginal heritage sites fall within the current alignment of W2P therefore no disturb Aboriginal heritage Ministerial consent is required. sites. Environmental Protection and Biodiversity (EPBC) Act 1999 (Cth) Chapter 4 (impact assessment) Impacts to matters of Proposed Wodgina expansions including W2P referred to Department of national environmental Environment and Energy (DEE) on 24 April 2018 (2018/8194) due to potential for significance6. impacts on EPBC-listed species, including Northern Quoll, Ghost Bat, Pilbara Leaf- nosed Bat and Greater Bilby (Section 2.9). WLPL will comply with any management conditions that may arise subsequent to a Controlled Action Decision being issued under the Act.
6 Including matters pursuant to the JAMBA, CAMBA, and ROKAMBA agreements, and the Bonn Convention.
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Legislation / Aspect Relevance / Status for W2P Environmental Protection Act 1986 Part IV (impact assessment) Impacts to matters of state No matters of state environmental significance identified as likely to be materially environmental impacted by the W2P. significance. All identified potential impacts can be adequately managed under Part V (clearing) of the EP Act and Mining Act provisions.
Environmental Protection Act 1986 Part V Division 2 (permits to clear native vegetation) Clearing of native CPS8068/1 for permit to clear 240 ha of native vegetation submitted to DMIRS on 16 vegetation. April 2018, for various aspects of the proposed Wodgina Lithium Project, including the W2P works; [5]. Following additional consultation with DMIRS (25 September 2018), CPS8068/1 was amended to only address the W2P footprint. Grant of CPS8068/1 occurred on 11 October 2018, with the Permit to become active on 3 November 2018. Some clearing activities may be undertaken under exemption of 10ha within a financial year for any purpose on land that is not an environmental sensitive area and is administered under the Mining Act 1978.
Wildlife Conservation Act 1950 s23 (licences to take protected flora) Clearing of protected flora. No “declared rare” flora listed under this Act identified from surveys (Section 2.8).
Wildlife Conservation Act 1950 s14 / Regulations 1970 s15 (licences to take fauna for relocation) Relocation of fauna. Construction contractor has been granted a Licence to Take Fauna (11-002897-2) for the purpose of relocating fauna found in the pipeline trench and (when necessary) elsewhere in the construction area.
Environmental Protection Act 1986 Part V Division 3 (works approvals and licences) Construction or operation No new prescribed infrastructure of a scale requiring licensing to be installed for of prescribed W2P. infrastructure. W2P construction to use existing licensed infrastructure at Wodgina mine site as far as practicable, including bulk fuel and chemical storage, power supply, sewage treatment, and inert and putrescible landfill.
Mining Act 1978 Part IV (mining tenure and conditions of grant) Access to and Miscellaneous licence L45/108 granted April 2001 for the W1P corridor provides development of land for access to proposed W2P corridor for most of its length from the PEPL. mining or related Mining leases M45/50-I, 381 and 949 provide access to the remainder of the W2P purposes. area as it approaches the Wodgina mine site. Revision 2 of the Wodgina W2P Mining Proposal (MP) was submitted to DMIRS in October 2018, with this amendment including the W2P FMP. The FMP was developed in consultation with DBCA. The W2P MP was submitted in accordance with tenement conditions and MP Guidelines, and aligned with this CEP.
Mining Rehabilitation Fund Act 2012 (contribution to state mining rehabilitation fund) Disturbance on minerals Areas of the W2P required for the operational phase and not reinstated following the tenements. completion of construction activities will be incorporated into the WLPL Mine Closure Plan. The W2P disturbance and rehabilitated areas will be reported on an annual basis via the MRF reporting process.
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Legislation / Aspect Relevance / Status for W2P
Planning and Development Act 2005 (land use planning and sustainable development) General restrictions on W2P area zoned as “Rural” under Port Hedland local planning scheme; no restrictions development and use of on use of land for purpose of gas pipeline identified. land.
Country Areas Water Supply Act 1947 (protection of water resources) Restrictions on First 13 km of W2P falls within PDWSA WRC 3208-01 (Yule River). development and use of Development of W2P is a compatible land use within Yule River PDWSA under land within PDWSAs. relevant DWER notices. WLPL to consult with DWER on management measures, including spill prevention, to mitigate risk of impacts on groundwater quality from construction works (Sections 3.4.6, 3.4.7).
Contaminated Sites Act 2003 (reporting, investigation, and remediation of contaminated sites) Reporting, investigation, Most of pipeline route passes through unallocated Crown land/pastoral country or and remediation of actual largely undisturbed habitat, with little for potential existing contamination or suspected Nearest registered contaminated site (Mt Dove mine site) several km’s from the W2P contaminated sites. corridor. WLPL to investigate any suspected or actual contamination identified or caused in the course of construction, and report and/or remediate where necessary in accordance with the Act and relevant Guidelines.
Biosecurity and Agriculture Management Act 2007 (management of invasive species) Management of declared Three weed species identified from surveys along pipeline route; all are common to weeds. the region, and none are declared under the Act (Section 2.8.3). WLPL to implement management strategies to reduce the risk of the spread of weeds as a result of construction works (Section 3.4.10).
Rights in Water and Irrigation Act 1914 section 5C (licences to take water) Abstraction of All water to be supplied by licensed bores. groundwater. Agreements and licence amendments for supplementary supply from third party licence holders to be sought if necessary. Pipeline trench and other excavations not expected to require dewatering.
Rights in Water and Irrigation Act 1914 section 11/17/21A (permits to disturb bed and banks) Disturbance to Pipeline crosses several ephemeral drainage lines that will be temporarily disturbed, watercourses. corridor falls within proclaimed Pilbara Surface Water Area. WLPL understand additional Permits (reference to DWER guidance [14]) to not be required as surface water will not be taken, stored, or diverted in any material way. Proposed works will be notified to DWER in accordance with tenement conditions.
Rights in Water and Irrigation Act 1914 section 26D (permits to construct or alter wells) Construction of W2P intends to use licensed bores for water supply. groundwater abstraction No requirement for new bores expected; Permit to construct new bores to be sought, bores. if necessary.
Petroleum Pipelines Act 1969 Part IVA (occupational safety and planning) Construction of a gas WLPL to submit separate safety case for W2P to DMIRS petroleum safety branch, in pipeline. accordance with Pipelines (Management of Safety of Pipeline Operations) Regulations 2010 and relevant guidelines.
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Legislation / Aspect Relevance / Status for W2P
Mines Safety and Inspection Regulations 1995 section 3 (W2P management plans for mine safety) Construction and Safety management for W2P including elements within boundary of Wodgina mine operation of infrastructure site to be addressed under pipeline Safety Case. related to mining Wodgina power station and other mine infrastructure to be addressed under PMP operations. for Wodgina operations Bridging statements between documents to be incorporated where appropriate.
Dangerous Goods Safety Act 2004 Section 12 (licences to store dangerous goods) Storage of diesel in bulk Diesel for W2P construction works to be stored in existing licensed bulk storage quantities. facility at Wodgina mine site under current licence.
Health Act 1911 section 107 (permits to construct and operate sewage treatment apparatus) Installation and operation W2P construction personnel to be accommodated in existing camp, with sewage of a waste water treatment operated under current permit. treatment plant.
In addition to legislative requirements, WLPL will adopt relevant standards, consistent with regulatory Guidelines and/or widely accepted industry practices, for construction of the W2P. These standards are discussed in Sections 3 and 4, and include: AS2885.1:2012 Pipelines – Gas and Liquid Petroleum, Part 1: Design and construction. AS2885.3:2012 Pipelines—Gas and Liquid Petroleum, Part 3: Operation and Maintenance. AS/NZS ISO 31000:2009 Risk Management – Principles and Guidelines. APGA Code of Environmental Practice – Onshore Pipelines. ISO 14001 Environmental Management Systems -- Requirements with Guidance for Use7.
7 Noting that while MRL adopts the broad principles of the standard in development and implementation of its EMS, it does not purport or intend to be certified as conformant with all of its requirements.
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6. IMPLEMENTATION STRATEGY
SYSTEMS, PRACTICES, AND PROCEDURES Consistent with its environmental policy (discussed below), and as part of its integrated corporate management systems, MRL has developed an over-arching environmental management system (EMS), described in corporate document MRL-EN-PLN-0001. The general application of the EMS extends to all MRL assets, projects, and subsidiaries, including WLPL and the W2P. The EMS is broadly consistent with ISO 14001 Environmental Management Systems -- Requirements with Guidance for Use, and comprises: a corporate policy (addressed below) stating MRL’s commitment to environmental management, and environmental objectives consistent with this policy requirements to identify and review environmental risks arising from MRL’s activities, and relevant environmental obligations plans and procedures for various aspects associated with MRL’s activities, including controls and resources to mitigate attendant environmental risks, and comply with relevant obligations requirements for induction and training of personnel monitoring and auditing programs to assure compliance with practices and procedures, and to measure success in achieving objectives reporting and records management systems, including hazard and incident reporting requirements for ongoing communication and consultation with relevant stakeholders.
WLPL has a comprehensive library of environmental management documents subsidiary to the EMS, including management plans, procedures, and forms, that will be adopted and/or adapted for the W2P; where necessary, supplementary W2P-specific documents will be developed. WLPL will require the contractor to prepare and submit work procedures relevant to the scope of works under this CEP. WLPL will review contractor procedures for conformance with the CEP before commencement of works. Should inadequate or unclear procedures be identified as a cause or contributing factor in significant or recurring hazards, incidents, or non-conformances, WLPL will direct the contractor to review and re-submit those procedures for approval by MRL. Specific procedures (current and/or proposed) that will be used to direct management of specific aspects and hazards associated with the W2P are listed in the summary tables for environmental risk management set out in Section 3.4.
CORPORATE ENVIRONMENTAL POLICY WLPL, as Operator of the W2P and a subsidiary of MRL, acknowledges that its operations have the potential to impact on environmental, community, and heritage values. WLPL will therefore adopt a systematic approach to understanding and managing potential hazards and risks, and meeting its obligations under relevant legislation. All WLPL projects, including the W2P, will be conducted in accordance with the MRL corporate Environmental Policy (MRL-EN-POL-001), provided in Error! Reference source not found. 6. The W2P Project Manager will be responsible for ensuring the Policy is adhered to for all works associated with the W2P.
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ROLES AND RESPONSIBILITIES OF PERSONNEL The construction of the W2P will be a discrete project under the direction of WLPL, with its own organisational structure. Specific responsibilities for environmental management will be assigned to MRL and WLPL corporate and W2P personnel, and to contractor and sub-contractor personnel, as summarised in Table 24. Ultimate responsibility for ensuring that the W2P conforms to the requirements of the CEP rests with the W2P Project Manager, on advice from the MRL Corporate Team Leader Environment and Heritage. The W2P Project Manager may engage additional resources, such as a W2P environmental advisor (on and/or off site), to help assure and support conformance to the CEP on behalf of WLPL.
Table 24: Roles and Key Responsibilities
Position Key Responsibilities Team Leader - Direct and support development of the CEP in line with MRL Environmental Policy and Environmental and systems, relevant Regulations, and adopted standards. Heritage (MRL) Review requests for tender to assure that CEP requirements are incorporated; assist with review of tenders and contractor work procedures, to ensure that CEP requirements are adequately addressed. Conduct a program of audits as set out in the CEP, to assure W2P conformance. Review investigations of significant incidents and non-conformances, and advise on development of corrective actions. Assist with development of improvement plans where W2P conformance to CEP is inadequate. Review incident and non-conformance reports for completeness prior to submission to Regulatory Authorities. Direct review of the CEP, and where necessary revision, if W2P environmental obligations or objectives are not being met. Generally advise and support the Project Manager in the implementation of the CEP and assurance of W2P conformance.
W2P Project Manager Incorporate CEP requirements into requests for tender; review contractor tenders and (WLPL) work procedures to ensure that CEP requirements are adequately addressed. Review of contractor reports to assure that W2P conformance to CEP is adequate; engage with contractor to develop and implement improvement plan where performance is inadequate. Participate in investigations of significant incidents and non-conformances, and development of corrective actions; assure that corrective actions are closed out within set timeframes. Report incidents and non-conformances to Regulators within required timeframes (Section 7). Ensure all personnel operating on, and accessing the W2P are aware of, and adhere to, the W2P FMP (Error! Reference source not found. 10). Ensure all the W2P FMP management activities are undertaken, as required.
W2P Construction Ensure that CEP requirements are addressed in W2P schedules, budgets, work Manager procedures, training, and selection of personnel and equipment. Engage and schedule on-site environmental personnel including a W2P environmental officer, and adequate numbers of fauna rescue personnel. Review hazard, incident, and non-conformance reports; approve corrective actions, assign appropriate resources to their completion, and confirm that they are completed within set timeframes. Participate in investigations of significant hazards, incidents and non-conformances, and development of corrective actions.
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Position Key Responsibilities Report incidents and non-conformances to the Project Manager within agreed timeframes. Ensure that learnings from hazards, incidents, and non-conformances are disseminated to the W2P workforce. Provide regular reports to the Project Manager, including hazard, incident, and non- conformance statistics, status of corrective actions, and monitoring data required under the CEP and W2P FMP. Ensure all personnel undertaking construction and commissioning activities are also aware of, and adhere to, the W2P FMP.
W2P Environmental Provide day-to-day support to project managers, work area supervisors, and other Officer personnel in implementation of the CEP and W2P FMP. Participate in pre-starts and JHAs to ensure that relevant CEP and W2P FMP requirements are communicated and addressed. Provide pertinent environmental management information, including learnings from hazards, incidents and non-conformances, to the workforce through toolbox talks, notices, and other means. Implement a program of inspections and monitoring, as set out in the CEP and W2P FMP, to assure W2P conformance. Participate in and report on investigations of hazards, incidents and non-conformances, and development of corrective actions. Provide regular reports to the Construction Manager including hazard, incident, and non-conformance statistics, status of corrective actions, and monitoring required under the CEP and W2P FMP. Maintain records of inspections, hazards, incidents, non-conformances, corrective actions, and monitoring data as required by the CEP and W2P FMP. Manage fauna rescue personnel and operations. Ensure fauna management activities (injury, euthanisation and feral animal management) are undertaken in alignment with this CEP and the W2P FMP.
Work area supervisors Ensure that works are carried out according to approved procedures and JHAs incorporating the relevant requirements of the CEP. Verity that persons under their supervision are trained and competent in the work that they are engaged in. Instigate and lead JHAs where appropriate, incorporating the relevant requirements of the CEP. Promptly report environmental hazards, incidents, and non-conformances to the Environmental Officer and/or Construction Manager. Participate in investigations of hazards, incidents and non-conformances, and development of corrective actions for their area of supervision. Ensure all personnel undertaking construction and commissioning activities are also aware of, and adhere to, the W2P FMP.
All personnel Attend and participate in inductions and other training, pre-start meetings, toolbox talks, and JHAs as directed by their supervisor or manager. Follow all environmental management instructions relevant to their area of work as set out in inductions, work procedures, pre-start meetings, JHAs, or as otherwise given by their supervisor. Promptly report environmental hazards, incidents, and non-conformances to the relevant supervisor or manager.
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TRAINING AND COMPETENCY
6.4.1. Inductions All W2P construction personnel (including WLPL, contractor, and sub-contractor staff, regardless of position) will be required to complete a W2P-specific induction before entry to site that will address: The important environmental and social values of the W2P area, including vegetation, habitat, flora, and fauna of conservation concern, places of significance to Aboriginal culture, community expectations, and landholder requirements. The roles and responsibilities of all personnel (Table 24) in environmental management and conformance to the CEP. How to report environmental hazards, incidents, and non-conformances. The main practical environmental management measures relevant to all or most personnel and day- to-day activities, including: . Vehicle and plant hygiene, including clean on entry requirements. . Approved access routes and speed limits. . Boundaries of disturbance and access, and how they are marked, including “no-go” areas and habitat or flora flagged for retention and protection. . Storage and handling of hydrocarbons and other chemicals, including approved storage and transfer locations, transfer procedures, and spill response. . Waste segregation and disposal, including contaminated wastes. . Interaction with fauna, and how to contact fauna rescue officers. . Control of dust. . Prevention of fires.
Inductees will be tested after their induction to ensure that they have understood the material presented. A register of inductees will be maintained for the life for the W2P; the register will be reviewed as part of site audits. Persons requiring limited or occasional access to the W2P area or not directly engaged in construction works, such as delivery drivers or inspectors, will be granted restricted access approval, following successful completion of a visitor’s induction addressing basic safety and environmental requirements. At all times, a person granted a restricted access approval is to be accompanied by and under the direction of a fully inducted person at all times, and subject to site entry requirements of the CEP, such as vehicle hygiene inspections.
6.4.2. Specific Competencies Specific competency and training requirements relevant to implementation of the CEP may be identified for specific W2P positions or tasks, and may include: special fire prevention and response training and/or permit-to-work training for personnel engaged in “hot” works (welding and cutting), through Department of Fire and Emergency Services (DFES) or similar providers special spill response training for fuel and service truck operators, and mechanics WLPL will require the W2P Environmental personnel to demonstrate appropriate qualifications and/ or experience in environmental management for projects of a similar nature, scale, and setting.
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Pre-clearance surveys, inclusive of identification of Bilby and Mulgara burrows, and relocation of Bilby and Mulgara, shall be conducted by a fauna specialist, as per the requirements of Condition 6 of Clearing Permit 8068/1. The fauna specialist must have the following qualifications: a tertiary qualification specializing in environmental science or equivalent a minimum of 2 years work experience in fauna identification and surveys of fauna native to the region being inspected or surveyed; and a valid fauna licence issued under the Wildlife Conservation Act 1950.
As identified in Section 3, fauna handlers will be engaged to safely remove, treat, and relocate fauna from the open trench, CROW, and other construction areas (Section 3.4.4). Fauna handlers will be required to demonstrate competency sufficient to meet DBCA standards for grant of a licence to take fauna for public purposes (relocation), under s15 of the Wildlife Conservation Regulations 1970. Fauna handler requires experience in: fauna identification (amphibians, reptiles and mammals) capture and handling of amphibians, reptiles and mammals (importantly venomous snakes and large varanids) assessing injured fauna and their suitability for release (be familiar with fauna vouchering) ecology of species to be potentially encountered in order to relocate them to suitable habitat animal welfare legislation and performing euthanasia venomous snake handling training.
WLPL will require the contractor to certify and demonstrate that all personnel (including sub-contractors) are currently competent, and where necessary licensed, for the tasks that they will be engaged in, the equipment they will use, and any associated requirements of the CEP, such as spill or fire response. WLPL will require the contractor to maintain a register demonstrating that competencies and licences are current; the register will be reviewed as part of site audits.
6.4.3. Pre-start Meetings and Toolbox talks Pre-start meetings will be held by work crews on site before the start of work each day, led by the crew supervisor, supported by the W2P Environmental Officer, as required. These meetings will address any specific environmental/ safety/ stakeholder issues relevant to the day ahead, including any hazards identified or incidents reported from the previous day, particular environmental hazards associated with the activities planned (such as weather conditions and fire risk), or particular environmental, safety/ stakeholder matters in the area of work (such any no-go areas, features marked for protection on the, watercourse crossings, or weeds). At least once a week, pre-starts will include “toolbox talks” on specific environmental/ stakeholder values, aspects, hazards. Toolbox talks will be targeted to address issues relevant to the area and type of work, recent or recurring incidents or hazards, and any important learnings. Talks may address awareness matters such important flora or fauna, heritage values, or weeds, or practical matters such as proper practices for storing and handling hydrocarbons and chemicals, sediment control, waste management, fire prevention, and plant and vehicle hygiene. Records will be kept of pre-start meetings and toolbox talks, including persons attending, matters discussed, and any actions identified for follow-up.
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MONITORING, AUDIT, AND REVIEW
6.5.1. Overview WLPL will develop and implement a program of environmental inspections and audits for the W2P construction works in accordance with MRL-EN-PRO-0008 Environment - Inspections and Audits, to ensure conformance to the requirements of the CEP, and that management measures are effective in mitigating environmental risks and impacts to ALARP. NOTE: audits and inspections will also include assurance to commitments contained in the W2P FMP.
6.5.2. Daily Workplace Inspections The construction contractor will be required to inspect the workplaces, equipment, materials, and work practices under its control, for day-to-day conformance to the requirements of the CEP and any relevant work procedures or JHAs. WLPL will require the contractor to submit a procedure and checklist for such inspections, to typically be conducted by the W2P Environmental Officer, in conjunction with the relevant workplace supervisors. Where possible, hazards or non-conformances (such as minor housekeeping) will be corrected on the spot; any hazards or non-conformances that cannot be immediately corrected will be recorded in the hazard and incident register (Section 6.5), the risk assessed, and corrective actions developed. Recurring hazards or non- conformances will be escalated, with a risk assessment and corrective actions developed. The construction contractor will be required to keep a record of daily inspections, to be reviewed as part of the audit process.
6.5.3. Weekly Site Inspections The W2P construction areas will be inspected once a week by WLPL; these inspections may be integrated with regular WLPL health and safety inspections. WLPL will invite relevant W2P personnel to participate. WLPL will develop a procedure and checklist for such inspections, which will address matters such as: Conformance to limits of disturbance, including signs of disturbance beyond the marked boundaries, incursion into no-go areas, or damage to features marked for protection. Topsoil management, including signs of damage or erosion to topsoil stockpiles, and appropriate segregation from trench and other spoil. Hydrocarbon and chemical storage, handling, and use, including refuelling and servicing practices, signs of unaddressed spills including staining, and availability of spill kits. Vehicle and plant hygiene, including clean-on-entry certification. Waste management, including segregation, containment, and collection of wastes. Management of drainage, erosion, and sedimentation, including maintenance of sediment fences, bunds, and other controls. Fire prevention, including housekeeping and permits to work. Adequacy of dust suppression. Conformance to approved procedures.
Hazards and non-conformances will be noted and discussed with the relevant work area supervisor. Trivial hazards or non-conformances will generally be corrected on the spot; non-trivial hazards or non-conformances that cannot be immediately corrected will be recorded in the hazard and incident register (Section 6.5), the risk
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assessed, and corrective actions developed. Recurring trivial non-conformances will be treated as non-trivial. WLPL will keep a record of weekly inspections, to be reviewed as part of audits. In addition to weekly inspections, WLPL personnel may raise hazards and non-conformances from day-to-day and ad-hoc site observations with the construction contractor as and when they are identified, rather than being left until the next weekly inspection.
6.5.4. W2P Audits WLPL intends that the W2P will be comprehensively audited for environmental performance at least twice (once part way through mainline construction, and once partway through reinstatement). Audits will incorporate desktop review of W2P environmental records (including inspection reports, hazard and incident reports, and monitoring data), and comprehensive site inspections. WLPL intends that such audits will: assess overall W2P conformance with the requirements of the CEP identify substantial or recurring hazards, incidents, or non-conformances, and their root causes determine whether all material environmental and social risks have been identified and correctly assessed, and whether adequate controls have been developed determine whether all relevant environmental and social obligations have been identified, and the extent to which they have been met assess the extent to which criteria for success as set out in the CEP have been met assess the effectiveness of the CEP in mitigating environmental and social risks, minimising environmental and social impacts, and meeting environmental and social objectives.
Audit reports will identify opportunities for improvement, which may include changes to work procedures, or to the CEP itself. The environmental audits will be directed by the MRL Team Leader Environment and Heritage, and conducted by appropriately qualified persons; third-party auditors may be engaged. Environmental audits may be carried out in conjunction with health and safety audits.
6.5.5. Practical Completion Checks Works under the construction contract will be subject to checks at practical completion before acceptance by WLPL, incorporating checks that reinstatement works have been completed according to specification, including: removal of all residual wastes, remediation of any residual contamination, reinstatement of contours and drainage patterns, adequate respreading of topsoil and vegetation, and (where required) maintenance of erosion and sediment controls.
6.5.6. Environmental Monitoring Environmental monitoring during construction works, as set out under the management measures in section 3.4, will include: records of fauna found in open trench and other construction areas, including taxonomy (to species level where possible), location, and injury/ mortality survey of construction disturbance for conformance to approved areas survey of features marked for protection, to confirm that they remain undisturbed.
Post-construction environmental monitoring will assess the success of reinstatement of disturbed areas including restoration of drainage patterns, vegetation regrowth, stability and resistance to erosion, and the
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presence of weeds and feral animals. Monitoring will address the rehabilitation objectives and criteria set out in Section 4, as well as any specific obligations under Clearing Permit CPS 8068/1 issued for the W2P, or agreements with landholders.
6.5.7. Review The WLPL W2P Project Manager, in consultation with and supported by the MRL Team Leader Environment and Heritage, will periodically review the environmental performance of the W2P, including substantial or recurring hazards, incidents, or non-conformances, and findings from inspections and audits. If necessary, an improvement plan will be developed in conjunction with the construction contractor. Such a plan may incorporate various actions, including changes to inductions, additional training or awareness programs, changes to work procedures, or improvements to resources or facilities. In the event changes to the CEP are considered appropriate, WLPL will engage with DMIRS and where required, submit an amended document for review and approval. Fauna rescue records will be frequently reviewed by the lead fauna handler and W2P Environmental Officer to determine rates of mortality/ injury. A review of W2P mortality/ injury rates will be assessed against similar projects of this nature, where this information is publically available. Where mortality/ injury rates are trending above such levels, the contractor will consider additional measures (such as additional shelters and/or inspections). The W2P Project Manager and MRL Team Leader Environment and Heritage will review fauna rescue data provided as part of weekly reporting, and engage with the contractor to identify causes for mortality/ injury rates and where appropriate, develop appropriate mitigations.
MANAGEMENT OF NON-CONFORMANCE Non-conformances with the requirements of this CEP and/ or the W2P FMP, as identified from inspections, audits, and ad-hoc observations, will be recorded in a register maintained by the construction contractor; the register will be auditable by WLPL and Regulators. A summary report of non-conformances will be included in weekly reporting. The risks arising from each non-conformance will be assessed and immediate and root causes will be identified by W2P personnel. One or more corrective actions will be developed for each cause, and responsibility for each action assigned to a person with the ability (competencies, resources, and authority) to carry them out, subject to approval by the Construction Manager. Appropriate deadlines for completion of corrective actions will be set, commensurate with the associated risk. Corrective actions, responsible persons, and deadlines will be recorded in a register maintained by the construction contractor; the register will be auditable by WLPL. A summary report of current and outstanding corrective actions will be included in weekly reporting. Where required, the W2P Project Manager will liaise with the contractor Construction Manager to ensure that corrective actions are implemented as per the agreed timeframes. Non-conformances entailing a minor to moderate degree of risk will generally be investigated in the workplace, and corrective actions developed, by the relevant workplace supervisor, in consultation with the W2P Environmental Officer. The Construction Manager, W2P Project Manager, and/or MRL Team Leader Environment and Heritage (or their delegates) may participate in the investigation of more serious non- conformances, and the development and assignment of corrective actions. WLPL will also maintain a register of stakeholder engagement, including complaints (Section 8); where appropriate, complaints will be incorporated into the register of hazards, incidents, and non-conformances, for investigation and corrective action.
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RECORD-KEEPING WLPL will maintain records relevant to the implementation of the CEP as set out in Section 6.7 for at least five years, and provide them to DMIRS on request in accordance with the Pipeline Environmental Regulations. Records so maintained will include: Pre-construction studies including ecological and heritage survey reports. Copies of other relevant applications and approvals as set out in Section 5, and agreements with third party landholders. Inspection and audit reports and records of hazards, incidents, non-conformances, and corrective actions. Copies of regular construction reports, including conformance reporting and monitoring data. Copies of correspondence with regulators and other material stakeholders, including routine and contingency (incident or other) reporting, as set out in Section 7 below. Environmental monitoring data as required under this CEP, including fauna rescue data, and fuel use and emissions estimates. As-built surveys and practical completion checklists. Records of stakeholder consultation and any complaints from third parties. This CEP, subsidiary documents such as construction work procedures, and any revisions thereof.
OIL SPILL CONTINGENCY PLAN While the pipeline itself does not carry liquid hydrocarbons, fuels, oils, coolants and other hydrocarbons and hazardous chemicals will be used in the construction, operation, maintenance, decommissioning, and rehabilitation of the W2P. A brief oil spill contingency plan (OSCP) for the W2P construction works, to address the proposed types and quantities of hydrocarbons and hazardous chemicals is incorporated in Appendix 7. Some residual liquid hydrocarbon waste may also be produced by pipeline cleaning during operations and as part of final decommissioning, however this will be addressed under separate EPs or the COEP.
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7. REPORTING
OVERVIEW WLPL will develop and implement a program of environmental reporting for the W2P construction works in line with MRL-EN-PRO-0010 Environmental Reporting and Communication, which is intended to meet relevant regulatory obligations, and ensure a timely flow of information on environmental performance to W2P management, regulators, and other relevant stakeholders. To ensure consistency between this CEP and the W2P FMP (Section 5.3), the reporting process for Contingency Reporting between these documents has been aligned.
ROUTINE REPORTING MRL will submit a pre-start notification to DMIRS before commencement of works as set out in this CEP, in accordance with Section 3.8.1 of the EP guidelines. WLPL proposes to submit a brief monthly W2P progress report to DMIRS, incorporating the status of construction and/or reinstatement works, a summary of any recordable incidents (Section 7.3.2 below), fauna rescue, and other environmental management data. Monthly reports will be submitted by email to DMIRS Petroleum Branch by the 15th of each month, for the preceding month to: [email protected]. A summary of estimated emissions and discharges will be submitted to DMIRS each quarter, within 15 days of the end of the quarter, and using the DMIRS Quarterly Emissions and Discharges Report Form, including: hydro test water disposal, calculated from pipeline volume. diesel exhaust emissions from vehicles and fixed and mobile plant, estimated from fuel use using endorsed National Pollutant Inventory (NPI) and National Greenhouse and Energy Reporting (NGER) methods. construction waste disposal, estimated from log sheets (e.g., waste truck trips to mine site landfill) or collection receipts (e.g., skips or bins collected by contractor).
MRL will submit a cessation notification to DMIRS at completion of works as set out in this CEP, in accordance with Section 3.8.1 of the EP guidelines. WLPL will also submit a close-out report within three months of practical completion, including: summary statistics for environmental hazards, incidents, and non-conformances a summary of emissions for the construction works and commissioning, including planned releases such as venting, and any unplanned releases (addressed under separate documents) details and outcomes of any further stakeholder engagement since submission of the CEP, or any complaints received over the course of construction environmental monitoring data required under this CEP, in spreadsheet or other agreed format the areas of land disturbed for construction works, and areas subsequently reinstated, in both summary table and GIS data form discussion of any significant incidents or non-conformances, status of any corrective actions taken and proposed timeframes for completion of any outstanding actions findings of W2P environmental audits, and any corrective or improvement actions taken outcomes from emergency response drills or testing of the OSCP
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an assessment of the extent to which the objectives, standards, and criteria set out in this CEP have been met.
The close-out report will be submitted by email to DMIRS via [email protected]. In addition, WLPL will submit reports to DMIRS (Minerals Environment Branch) as required under tenement and/or clearing permit conditions; these reports will incorporate the W2P as part of the Wodgina Lithium Project, and will address areas of disturbance and rehabilitation, as well as general compliance with obligations arising from tenement and permit conditions, and mining proposal obligations (Section 5). WLPL will also submit annual reports and levy estimates to the MRF via DMIRS, based on areas of disturbance and rehabilitation, incorporating the W2P construction areas within WLPL tenements. Emissions for the W2P will be estimated and reported to DMIRS, NPI, and NGER, in accordance with MRL-EN- PRO-0014 NGER & NPI Management Procedure.
CONTINGENCY REPORTING
7.3.1. Reportable Events As noted in Section 3.3, WLPL will treat any unplanned event occurring in the course of works under the scope of this CEP as immediately reportable to DMIRS, where the inherent environmental consequence of the event is classed as “medium” or greater, according to the MRL consequence definition table. Other specific types of incidents that WLPL will treat as immediately reportable (in addition to any reporting requirements under other legislation, permits, or agreements) include: disturbance to Aboriginal heritage sites clearing beyond the extent approved under clearing permits large spills of hydrocarbons or hazardous chemicals to ground (>80 L to water or >500 L to any other areas, affecting >100 m2) first aid/ mortality of fauna of conservation significance (Note: requires reporting to DBCA) fires started by construction works that is not immediately contained large unplanned / uncontrolled releases of gas (>500 m3 @STP).
Reportable incidents will be reported to DMIRS petroleum environment branch by email to [email protected]. Initial notification as soon as practicable, but within two hours of the incident first being noticed, and with such information as is available at the time. A follow-up incident report will be subsequently submitted within three days, incorporating: the location, date, and time of the incident, a description of the incident, and relevant surrounding circumstances such as the works in progress and/or prevailing conditions at the time the type, quantity, and fate of any spill or unplanned release, and extent of any impact as a consequence of the incident immediate actions (such as spill response) taken to mitigate impacts, causes identified, actions taken or proposed to prevent recurrence, and any further investigations in progress or proposed names and contact details for witnesses and/ or relevant WLPL and/or contractor representatives.
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Where an incident requires detailed investigation that cannot be completed within three days, a follow-up report will also be submitted once investigations are complete. Incidents will also be reported as soon as practicable to other agencies in accordance with other relevant legislation or approvals (section 5), including: DPLH, for any disturbance to Aboriginal heritage sites DBCA via email ([email protected]) of any conservation significant fauna injury or mortality within 24 hours DMIRS Minerals Environment Branch via email ([email protected]), for disturbance other than that permitted under clearing permits and/or mining proposals, or other incident materially affecting compliance with obligations arising under tenement conditions or mining proposal commitments DWER Industry Regulation Branch via email ([email protected] or [email protected]), for unlicensed release with the potential to cause pollution, or material environmental harm, or other incident materially affecting compliance with obligations arising under part V of the EP Act or prescribed premises licensing (for instance, improper disposal of construction wastes at the Wodgina operations landfill) DWER contaminated sites branch (1300 762 982), for any substantial (actual or suspected) contamination identified in the course of construction (whether caused in the course of construction works, or previously, by a third party) DMIRS resources safety branch, for any reportable releases of dangerous goods, in accordance with Reporting Dangerous Goods Incidents — Guideline.
Landholders will be notified of any incidents on their lands to the extent that their interests are affected (for instance, disturbance other than that under agreement, or contamination identified or caused in the course of works).
7.3.2. Recordable Events WLPL will treat a material breach of environmental performance objectives or environmental performance standards as set out in this CEP (Section 4), that is not otherwise treated as a reportable incident, as a recordable event, in accordance with the pipeline environment regulations, regardless of impact. A summary of recordable incidents will be included in monthly routine reporting to DMIRS (Section 7.1 above), including a summary of corrective actions taken or proposed. Where no recordable incidents have occurred in a given month, it will be explicitly stated in the report. Monthly incident reports will be submitted using DMIRS Recordable Incident Monthly Report form ENV-PEB-190.
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8. STAKEHOLDER ENGAGEMENT WLPL intends to engage with relevant stakeholders for the purpose of maintaining constructive relations for the duration of the W2P. WLPL has identified a number of parties as key stakeholders for the W2P, where they have a substantial influence on major environmental approvals, or whose interests may be materially affected by the W2P. These include: DMIRS, including petroleum environment, minerals environment, and minerals titles divisions, with reference to pipelines act and mining act approvals, and clearing permits delegated to DMIRS for mining projects. DEE, with reference to referrals under the commonwealth EPBC Act. Traditional owners, represented by the Yamatji Marlpa Aboriginal Corporation, with reference to access agreements under the Kariyarra People native title claim and management of heritage sites. The Mundabullanga, Indee, and Kangan pastoral stations, with reference to agreements for access to and use of pastoral lands and (if required) water supply. Main Roads WA, with reference to crossing works and access to the road reserve at the Northwest Coastal Highway crossing. Atlas Iron (operator of the Mount Dove mine site) with reference to crossing works at the Mount Dove access road crossing and access to the associated miscellaneous licence, and other third parties holding minerals titles intersecting the W2P area. DWER and the Water Corporation of WA, with reference to proposed works within PDSWA WRC 3208- 01 and water reserve 33015, and works in the vicinity of the Hedland water supply pipeline. Horizon Power, with reference to proposed works in the vicinity of power lines crossing the pipeline corridor. The Town of Port Hedland, as the relevant LGA, with reference to the W2P generally, use of LGA roads and other infrastructure, and works in the vicinity of LGA infrastructure. Other stakeholders relevant to secondary approvals or with potential interests in the W2P include: DBCA, with reference to licensing of fauna handlers, and W2P fauna management. DWER, with reference to management and restoration of surface water flows during and after construction. Engagement to date with regulators has generally comprised notification of the proposed expansions of the Wodgina operations, including the W2P, and consultation on appropriate approval pathways and expected timeframes. WLPL has commenced and will progress liaison with relevant land title holders and owners / operators of third party infrastructure crossed, used by, or otherwise affected by the W2P. A summary of engagement to date is provided in Error! Reference source not found. 8. WLPL will prepare a comprehensive alignment list marking land title boundaries along the CROW, and incorporating title holder requirements for access, use, and reinstatement, or any other particular concerns. Where applicable property inspections will be completed before and after construction, to assure that landholder requirements have been complied with, and that disturbed land has been reinstated, except where otherwise agreed. WLPL intends to keep affected stakeholders informed of scheduled works and potential impacts on their interests as the W2P progresses. WLPL will maintain a register of stakeholders, and will distribute information and seek stakeholder feedback through correspondence, calls, and/or meetings (on or off site) as appropriate. WLPL will encourage feedback from stakeholders over the duration of the W2P.
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Key milestones for notifications and consultation (in addition to the reporting requirements addressed in Section 7) will incorporate: Grant of pipeline licence; including notice to intersecting land title holders. Confirmation of date for commencement of works, including notice to DMIRS. Mobilisation of personnel and equipment to site, including notice to and liaison with landholders and third party infrastructure owner / operators ahead of access and works. Practical completion and demobilisation, including notice to DMIRS, and liaison with landholders and other affected third parties to confirm that conditions of access and use have been fulfilled.
WLPL will maintain a register of all stakeholder interactions, including any complaints received, documenting issues raised, and their resolution. WLPL intends that any complaints will be addressed promptly and constructively with the aggrieved party. Substantive complaints will be recorded in the W2P incident register (Section 6.6) for further investigation and corrective action, commensurate with the nature and severity of the complaint.
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9. REFERENCES
[1] Western Australia, Department of Mines and Petroleum, “Guideline for the sevelopment of petroleum and geothermal environment plans in Western Australia,” 2016.
[2] Western Australia, Department of Water and Environment Regulation, Land use compatibility tables for public drinking water source areas, 2016.
[3] 360 Environmental Pty Ltd, Wodgina mine and additional gas pipeline - flora, vegetation, and targeted northern quoll report, 2018.
[4] Australia, Bureau of Meterology, Climate statistics for Australian locations - Port Hedland Airport, 2018.
[5] 360 Environmental Pty Ltd, Wodgina Lithium Project - application for a native vegetation clearing permit, 2018.
[6] Australian Collaborative Land Evaluation Progam, “Australian Soil Resource Information System,” 30 June 2014. [Online]. Available: http://www.asris.csiro.au. [Accessed 18 April 2018].
[7] Western Australia, Environmental Protection Authority, Technical guidance - flora and vegetation surveys for environmental impact assessment, 2016.
[8] Western Australia, Department of Agriculture and Food, Western Australian Organism List, 2018.
[9] Western Australia, Environmental Protection Authority, Technical guidance – terrestrial fauna surveys, 2016.
[10] Western Australia, Environmental Protection Authority, Technical guidance- sampling methods for terrestrial vertebrate fauna, 2016.
[11] Australia, Department of Sustainability, Environment, Water, Population and Communities, Survey guidelines for Australia’s threatened mammals - Guidelines for detecting mammals listed as threatened under the Environment Protection and Biodiversity Conservation Act 1999, 2004.
[12] Australia, Department of the Environment, EPBC Act Referral Guidelines for the endangered northern quoll Dasyurus hallucatus, 2016.
[13] Australian Pipelines and Gas Association Ltd, Code of environmental practice - onshore pipelines. Revision 4, 2017.
[14] Western Australia, Department of Water, Do I need a permit?, 2016.
[15] Beard, J.S. Vegetation Survey of Western Australia, Pilbara 1:1 000 000. Map and Explanatory Notes to Sheet 7. 1975
[16] Beard, J.S. Plant Life of Western Australia. 1990.
[17] Kendrick, P. and McKenzie, N. A Biodiversity Audit of Western Australia’s 53 Biogeographic Subregions in 2002 - Pilbara 1 (PIL1 – Chichester Subregion). November 2001.
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[18] Shepherd, D., Beeston, G. and Hopkins, A. (2002). Native Vegetation in Western Australia. Extent, Type and Status. Resource Management Technical Report 249. Department of Agriculture.
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FIGURES
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environmental Plan
Figure 1: Pipeline Corridor Location
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environmental Plan
Figure 2: Pipeline Lease Area
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environmental Plan
Figure 3: IBRA Region / Sub-Regions
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
Figure 4: Aboriginal Heritage
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
Figure 5: Land Tenure
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
Figure 6: Vegetation Associations (northern & southern envelope)
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
Figure 7: Flora and Vegetation (northern envelope – sheet 1)
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
Figure 8: Flora and Vegetation (northern envelope – sheet 2)
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Wodgina Lithium Project | Wodgina 2 Gas Pipeline Construction Environment Plan
Figure 9: Flora and Vegetation (southern envelope)
ENV-TS-RP-0091