Sandy Ridge Facility
Works Approval Applica�on No.3 Waste Storage, Processing and Permanent Isola�on Categories 61A, 61, 65 and 66 2019
03 October 2019 HS00-1760150200-22627
Prepared for: Department of Water and Environmental Regula�on
Prepared by Tellus Holdings Ltd
SANDY RIDGE FACILITY WORKS APPROVAL APPLICATION CLASS IV AND CLASS V PRESCRIBED PREMISES CATEGORIES 61, 61A, 65 AND 66
Final | October 2019
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Table of Contents
Abbreviations ...... vii Definitions of terms and acronyms ...... ix 1 Purpose and scope of Application ...... 1 2 Background ...... 3 3 Overview of Premises ...... 6 3.1 Introduction ...... 6 3.2 Waste inspection and surface storage ...... 8 3.3 Liquid waste immobilisation ...... 16 3.4 Permanent isolation of waste ...... 18 3.5 Storm water catchment and retention ...... 21 3.6 Raw water supply and treatment ...... 23 3.7 Exclusions to the Premises ...... 24 4 Legislative Context ...... 26 4.1 Summary of approvals and tenure ...... 26 4.2 Part IV of the EP Act ...... 26 4.3 Contaminated sites ...... 26 4.4 Part V of the EP Act ...... 27 4.5 Radiation Safety Act 1975 ...... 29 5 Location and Siting ...... 30 5.1 Siting and context ...... 30 5.2 Sensitive premises...... 30 5.3 Sensitive receptors and specified ecosystems ...... 31 5.4 Groundwater and water sources ...... 31 5.5 Conceptual site model ...... 32 6 Modelling and Monitoring Data ...... 35 7 Risk Assessment ...... 45 7.1 Determination of emission, pathway and receptor ...... 45 7.1 Consequence likelihood and treatment of risk events ...... 47 7.2 Acceptability and treatment of Risk Event ...... 50 7.3 Potential discharges – storage of waste ...... 50 7.4 Risk assessment - Above-ground storage of Class IV and Class V wastes impacting on soil and vegetation ...... 59 7.5 Risk assessment – Contaminated stormwater impacting on soil and vegetation ...... 61 7.6 Risk assessment – WIP waste impacting on soil and vegetation ...... 63 7.7 Summary of acceptability and treatment of Risk Events ...... 64 8 Controls ...... 67 8.1 General controls ...... 67
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 ii
8.2 Storage, handling and permeant isolation of LLW ...... 69 8.3 Waste isolation in near-surface geological repository ...... 69 8.4 EP Act regulatory controls...... 71 9 Conclusion ...... 72 10 References ...... 73 Appendix A: Construction Quality Assurance Plan ...... Appendix B: Supporting Figures ...... Appendix C: Supporting Drawings ...... Appendix D: Sandy Ridge Dangerous Goods License DGS022452 ...... Appendix E: Radiation Management Plan ...... Appendix F: Sandy Ridge Soil Sampling Analysis & Radionuclide Analysis ...... Appendix G: Waste Acceptance Criteria ...... Appendix H: Waste Acceptance Procedure ...... Appendix I: Waste Zoning Guide ......
List of Figures
Figure 1-1 Site Layout and phasing of Sandy Ridge Facility works approvals...... 2 Figure 2-1 Regional location of the Sandy Ridge Facility ...... 5 Figure 3-1 Sandy Ridge Facility Infrastructure Area layout...... 7 Figure 5-1 Distance to sensitive receptors ...... 33 Figure 5-2 Sandy Ridge Facility Conceptual Site Model during operations...... 34 Figure 6-1 Drill holes and survey locations and where groundwater has been encountered ...... 39 Figure 6-2 Soil sampling locations ...... 40 Figure 6-3 Location of electroseismic and electrotulleric survey lines at Sandy Ridge ...... 41 Figure 6-4 Data trace points for survey line 3 showing relative values of potential hydraulic conductivity ...... 42 Figure 6-5 3D model showing ESKT vales across the Sandy Ridge site looking north ...... 42 Figure 6-6 ESKT result for survey line 1 at Sandy Ridge and interpreted basement level indicated in dark blue ...... 43 Figure 6-7 ESKT result for survey line 3 at Sandy Ridge ...... 43 Figure 6-8 ESKT result for survey line 3 at Sandy Ridge ...... 44 Figure 8-1 Proposed environmental monitoring stations during operations...... 70
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 iii
List of Tables
Table 1-1 EP Act Part V approvals phasing...... 1 Table 4-1 Relevant approvals and tenure achieved for the Facility to date ...... 27 Table 5-1 Off-site premises receptors and distance from site activity boundary ...... 30 Table 5-2 On-site premises receptors and distance from site activity boundary ...... 30 Table 5-3 Distance to sensitive receptors and specified ecosystems from the site activity boundary...... 31 Table 5-4 Distances to regional groundwater and other water sources from the site activity boundary ...... 32 Table 6-1 Summary of soil and ground conditions ...... 35 Table 7-1 Risk rating matrix ...... 47 Table 7-2 Risk criteria table...... 48 Table 7-3 Risk treatment table...... 50 Table 7-4 Environmental Risk Events – construction emissions, pathways and receptors ...... 51 Table 7-5 Environmental Risk Events – operations emissions, pathways and receptors ...... 54 Table 7-6 Risk Assessment Summary - Operations...... 65 Table 8-1 Proposed environmental monitoring...... 68
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 iv
Document control
The signatures below certify that this Works Approval Application has been reviewed, accepted and demonstrates that the signatories are aware of all the requirements contained herein and are committed to ensuring their provision.
Name Signature Position Date Prepared by Richard Phillips General Manager HSECQ 27/09/2019
Reviewed by Julie Mahony Manager –Environment & 03/10/2019 Compliance
Stephen Hosking General Manager – Project 02/10/2019 Development
Approved by Richard Phillips General Manager HSECQ 03/10/2019
Amendment record
This Works Approval Application is reviewed, audited and updated to ensure its continuing relevance to the systems and process that it describes. A record of contextual additions or omissions is given below:
Page No. Context Version Date
Company proprietary information
The electronic version of this Works Approval Application is the latest version. It is the responsibility of the individual to ensure that any paper material is the current version. The printed version of this procedure is uncontrolled, except when provided with a document reference number and version in the field below:
Document Ref. HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 Ver 0
Uncontrolled Copy Controlled Copy Date 03/10/2019
Tellus Holdings Ltd owns and is responsible for the copyright in this document. All rights reserved. Neither the whole nor any part of this document may be reproduced, stored in or transmitted in any form by any means (electronic, mechanical, reprographic, recording or otherwise) without the prior written consent of Tellus Holdings Ltd.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 v
Works Approval details
Applicant Tellus Holdings Ltd ABN 97 138 119 829 ACN 138 119 829 Registered business address Level 10, Suite 2 151 Castlereagh Street Sydney, NSW 2000 Prescribed premises • Category 61 • Category 61A • Category 65 • Category 66 Premises Sandy Ridge Facility Various Lots, Shire of Coolgardie
Interpretation
In this Works Approval: • any reference to an Australian or other standard, guideline or code of means the version of the standard, guideline or code of practice in force at the time of submitting this Works Approval Application and includes any amendments to the standard, guideline or code of practice which may occur from time to time during the assessment of the Works Approval Application; and • unless specified otherwise, any reference to a section of an Act refers to that section of the Environmental Protection Act 1986 Western Australia (WA).
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 vi
ABBREVIATIONS
ABN Australian Business Number
ACN Australian Company Number
ADT Articulated Dump Truck
ARI Annual Recurrence Interval
CBR California Bearing Ratio
CSM Conceptual Site Model
DWER Department of Water and Environmental Regulation
EP Act Environmental Protection Act 1986 (WA)
ESKT electroseismic hydraulic conductivity tomography
FIBC Flexible Intermediate Bulk Container
HIL Health Indicator Level hr hour
HV Heavy vehicle
IBC Intermediate Bulk Container
ISO International Standards Organisation
IWDF Intractable Waste Disposal Facility
ID Identification
Km kilometres kW kilowatts
LV Light vehicle m metres mm millimetres
MS Ministerial Statement
Regulations EP Regulations 1987 (WA)
RS Act Radiation Safety Act 1975 (WA)
SPR Source Pathway Receptor
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 vii
tpa tonnes per annum
WAC Waste Acceptance Criteria
WAP Waste Acceptance Procedure
WIP Waste Immobilisation Plant
WSC Waste Supply Contract
WZG Waste Zoning Guide
% percent
‘ foot
“ inches
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 viii
DEFINITIONS OF TERMS AND ACRONYMS
Terms, acronyms and Definitions abbreviations Application means this Works Approval Application Contaminant means a substance or object in contact or mixed with a material that presents, or has the potential to present, a risk of harm to human health, the environment or any environmental value. Contaminated soil means soil that has a substance in it at above background concentrations that presents, or has the potential to present, a risk of harm to human health, the environment or any environmental value. Class IV refer to the definition of near-surface geological repository. Class V refer to the definition of near-surface geological repository. Discharge has the same meaning given to that term under the EP Act. Emission has the same meaning given to that term under the EP Act. Environmental harm has the same meaning given to that term under the EP Act. Facility means the Sandy Ridge Facility. Hazardous waste means the component of the waste stream which by its characteristics poses a threat or risk to public health, safety or the environment (includes substances which are toxic, carcinogenic, and radioactive). Intractable waste means waste whose toxicity or chemical or physical characteristics make it difficult to dispose of or treat safely, and is not suitable for disposal in Class I, II, III and IV landfill facilities. Material environmental harm has the same meaning given to that term under the EP Act. Minister the Minister responsible for the EP Act and associated regulations. Near surface geological means the Sandy Ridge Facility capable of accepting and permanently repository isolating contaminated soils and intractable wastes. On-site means within the prescribed premises boundary. Pollution has the same meaning given to that term under the EP Act. Prescribed premises has the same meaning given to that term under the EP Act. Proponent refers to Tellus Holdings Ltd. Reportable event means an exceedance above the target limit. Risk Event where an emission is expected, a receptor which may be exposed to that emission through an identified actual or likely pathway, and a potential adverse effect to the receptor from exposure to that emission. Serious environmental harm has the same meaning given to that term under the EP Act. Sensitive receptors and areas of high conservation value and special significance that may be ecosystems impacted as a result of prescribed activities resulting in emissions and discharges from the Facility. Treatment means physical, chemical or biological processing of a waste for disposal or reuse. Unreasonable emission has the same meaning given to that term under the EP Act. Works refers to the Works described in Chapter 3, at the locations shown in Chapter 6 of this Works Approval Application to be carried out at the Premises. Works Approval refers to this document, which evidences the grant of the works approval by the CEO under s.54 of the EP Act, subject to the Conditions. Waste has the same meaning given to that term under the EP Act. Waste Acceptance Criteria means Tellus Waste Acceptance Criteria.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 ix
1 PURPOSE AND SCOPE OF APPLICATION
This Works Approval Application (Application) seeks approval under Part V of the Environmental Protection Act 1986 (EP Act) to construct, commission and operate the Sandy Ridge Facility (Facility) under Categories 61, 61A, 65 and 66 listed in Schedule 1 of the Environmental Protection Regulations 1987 (Regulations).
The extent of physical and operational limits of the Facility are described in Table 2 of Attachment 1 to Ministerial Statement No. 1078 (MS 1078). Approvals under Part V of the EP Act are to be conducted in phases as shown in Table 1-1 and diagrammatically shown in Figure 1-1.
This Application provides high level information about the management, handling and treatment of low level radioactive waste (LLW) for context only, as these activities are regulated under the Radiation Safety Act 1975 (RS Act). See Section 4.5 for more detail.
Table 1-1 EP Act Part V approvals phasing.
Phase Application Timing Description Status WAA0 August 2017 Works approval application for mining, W6089/2017/1 withdrawn chemical, radioactive waste facility. April 2019. WAA1 April 2019 Works approval application for mining-related W6243/2019/1 granted infrastructure, Cat 12, 64 and 89. May 2019. WAA2 September 2019 Category 61 and 61A for short-term and Submitted 26 September temporary1 above-ground waste storage, but no 2019 (Tellus 2019). waste processing, in the East Yard during construction of the main Facility. This may include NORM waste storage which is subject to separate approval by the WA Radiological Council under the WA Radiation Safety Act 1975 (RS Act). WAA3 September 2019 Additional aboveground infrastructure related This application. to Category 61 and 61A plus Category 65 and 66 for Class IV and Class V waste handling, processing and in- cell permanent isolation of chemical and Low Level Radioactive waste. REG1 November 2019 Registration application for Category 64 and Pending Category 89 to be submitted with compliance construction/installation. report for Class II landfill and waste water treatment plan installation. LIC1 December 2019 Licence application for Category 61 and 61A to Pending construction of be submitted with compliance report for East temporary waste area in Yard above-ground waste storage. East Yard. LIC1 February 2020 Licence amendment to add category 12 for Pending mining of the first Amend mobile screening plant during construction. Cell. LIC1 August 2020 Licence amendment to add category 65 and 66. Pending construction. Amend
1 Temporary is defined as the period of construction for the Sandy Ridge Facility.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1 219000 220000 221000 222000
465 0 0 0 0 0 0
0 Category 0
4 Category Description 4 No. 6 Legend 470 6 6 Screening etc. of material: premises (other than premises within 6 Prescribed Premises Boundary 12 category 5 or 8) on which material ex tracted from the ground is screened, washed, crushed, ground, milled, sized or separated. Sewage facility: premises —(a) on which sewage is treated (ex cluding 85 septic tanks); or(b) from which treated sewage is discharged onto land 0 125 250 375 500 or into waters. m Class II or III putrescible landfill site: premises on which waste (as 470 determined by reference to the waste type set out in the document ± 89 entitled “Landfill Waste Classification and Waste Definitions 1996” published by the Chief Ex ecutiv e Officer and as amended from time to time) is accepted for burial. 475 Liquid waste facility: premises on which liquid waste produced on other 61 premises (other than sewerage waste) is stored, reprocessed, treated or 480 irrigated. Solid waste facility: premises (other than premises within category 67A)
4 61A on which solid waste produced on other premises is stored, 4 7 reprocessed, treate8d, or discharged onto land 0 0
0 Liquid waste facility: premises on which liquid waste produced on other 0 0 61 premises (other than sewerage waste) is stored, reprocessed, treated or 0 0 4 0 9 75 irrigated. 9 3 3
6 Solid waste facility: premises (other than premises within category 67A) 6 6 61A on which solid waste produced on other premises is stored, 6 reprocessed, treated, or discharged onto land 470 5 47 Class IV secure landfill site: premises on which waste (as determined by reference to the waste type set out in the document entitled “Landfill 65 Waste Classification and Waste Definitions 1996” published by the Chief Ex ecutiv e Officer and as amended from time to time) is accepted for burial. 465 C4lass V intractable landfill site: premises on which waste (as determined by8 re0ference to the waste type set out in the document entitled “Landfill 66 Waste Classification and Waste Definitions 1996” published by the Chief Ex ecutiv e Officer and as amended from time to time) is accepted for burial. Mining Area 460 Topsoil stockpile
4 8
0 0 0 0 0 0 0 8 8 3 3
6 Overburden stockpiles (1-4) 6 6 6 0 6 3 2 1 4 4 Brine pond Settlement sump
0 Infrastructure area 48 Mine Pit 4 Mine Pit 2 Putrescible Landfill Mine Pit 3 Mine Pit 1 Septic System (discharge point) 460
Solar panel farm 475
0 4 0 6 0 0 0 0 0
7 465 Flood levee 7 3 3
6 465 470 6 6 6 470 0 6 4
460
Landfill access road
465 Prescribed Treated wastewater Premises Boundary irrigation area (discharge point) 0 0 0 0 0 0
6 455 Accommodation access road (with water pipeline) 6 3 465 3 6 6 6 Accommodation 6 village
460 Water pipeline route Site access road 460 460 465
219000 220000 221000 222000 Figure 1-1 Legend Site Layout 5m Contours Works Approval Application 1 (W6234-2019-1) 0 100 200 300 400 m Proposed infrastructure design Works Approval Application 2 Coordinate System: Proposed Mining Area Works Approval Application 3 SANDY RIDGE FACILITY ± GDA 1994 MGA Zone 51 Cat 65 & 66 WORKS APPROVAL Drawn by: RM SP-ID:GL00-2017072102-712 TSR0387_WWAv3_SiteLayout.mxd Data in this map is sourced from © State of Western Australia (Department of Mines, Industry, Regulation and Safety) 2018.
Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Version: B Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 3/10/2019
2 BACKGROUND
Tellus is developing an open-cut kaolin mine and complementary near-surface geological waste repository accepting Class IV and Class V waste (referred to as the Facility). The Facility is located approximately 75 kilometres (km) north-east of Koolyanobbing in the Shire of Coolgardie in the Goldfields Region of WA (Figure 2-1).
MS 1078 for the Facility was published on 26 June 2018. Australian Government Approval (EPBC2015/7478) was published in January 2019. A minor amendment to the size of the development envelope in MS 1078 was made in February 2019.
The assessment of the proposal under Part IV of the EP Act by the Environmental Protection Authority considered the sites suitability for an intractable waste facility and potential adverse impacts on terrestrial environmental quality. Subsequently, MS 1078 included conditions for factors that are often regulated under Part V of the EP Act:
• Condition 9 requires Tellus to develop and implement a Leachate Monitoring and Management Plan to control impacts to soil. • Condition 12 requires Tellus to develop and implement a Waste Facility Decommissioning and Closure Plan to demonstrate how the site will be closed so that it will be safe in the long-term. This Application does not duplicate the risk assessment and management of the above issues. It summarises the key issues for context where the activities may result in emissions or discharges.
Due to the dual nature of the Facility, Mining Act 1978 tenure and Crown Lease/Easements are required under the Land Administration Act 1997. This Application is being submitted for assessment by Department of Water and Environmental Regulation (DWER) in parallel to the final stages of the development of the Crown Lease by Department of Planning, Lands and Heritage.
In accordance with Tellus’ strict Waste Acceptance Criteria (WAC), presented in Appendix G, liquid or sludge waste must be immobilised before being placed inside the waste cell. To achieve this, kaolinised granite mined from the cells and (in some cases cement or other binders) will be blended with the liquid/sludge to immobilise the contaminants so that they become an either spade-able solid or concrete monolith. The added materials will increase the total mass of the waste. Depending on the required waste treatment formulation, the mass of permanently isolated waste may be up to 220,000 tonnes per annum (tpa). Added to the 60,000 tpa of solids accepted at the front gate, the total mass placed in the waste cells may be up to 280,000 tpa as listed in Table 2 of Attachment 1 to MS 1078.
Construction for mining related infrastructure in line with W6243/2019/1 commenced in September 2019 and is scheduled for a period of approximately 10 months. This Application seeks approval for
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 3
above ground waste acceptance and storage, waste processing and permanent isolation of Class IV and Class V intractable waste materials.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 4 160000 200000 240000 280000 320000 360000
Mount Manning Range Nature Reserve
Lake Giles (northern Yerilgee Hills) BIF Western Australia Mount Manning- Helena and Aurora Ranges Conservation Park Sandy Ridge Facility Clear and Muddy Lakes Nature Reserve Sandy Ridge Facility Hunt Range BIF Rowles Lagoon Conservation Park " !( Kalgoorlie
6640000 IWDF Mt Walton East 6640000 !(
Finnerty Range / Mt Dimer / Yendilberin Hills BIF !( Carina Mine Pit
IWDF Access Road
Kalgoorlie !( 6600000 6600000
Carina Mine Camp !( Koolyanobbing Ex-Jaurdi Pastoral Station Homestead !( Wallaroo Rock !( Conservation Park
PERTH-KALGOORLIE RAILWAY Ex-Jaurdi Pastoral Lease
!( Coolgardie Karamindle Forest
Kangaroo Hills Timber Reserve 6560000 6560000 Yallari Timber Reserve
Scahill Timber Reserve
Shire Yilgarnof Kambalda Shire of Coolgardie Dulagdin Nature Reserve Nature Reserve Southern CrossYellowdine Nature Reserve Goldfields Woodlands National Park Goldfields Woodlands National Park Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community !( Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, Boorabbin National Park NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Victoria Rock Nature Reserve Kong), (c) OpenStreetMap contributors, and the GIS User Community GREAT EASTERN HIGHWAY 160000 200000 240000 280000 320000 360000 Figure -1 Legend 2 Regional Location Specified Ecosystems: Potentially 10 5 0 10 Km IWDF Access Road Development Envelope DBCA Lands Occuring Priority Ecological Principal Road Local Government Authority Communities SANDY RIDGE FACILITY ± Coordinate System: Boundaries Cat 65 & 66 WORKS APPROVAL GDA 94 MGA Zone 51 Railway Drawn by: RM SP-ID:GL00-2017072102-709 TSR0383_WWAv3_RegionalLocation.mxd Data in this map is sourced from: © Commonwealth of Australia (Geoscience Australia) 2018 and © State of Western Australia (Department of Mines, Industry Regulation and Safety) 2018.
Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Version: A Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 27/09/2019
3 OVERVIEW OF PREMISES
3.1 Introduction This section describes key waste infrastructure to be constructed, commissioned and operated at the Facility associated with waste acceptance, storage (Category 61 and 61A), processing and permanently isolating Class IV (Category 65) and Class V (Category 66) intractable wastes within a near-surface geological repository. The premises map is presented in Figure 1-1 and detailed layout of the Infrastructure Area is presented in Figure 3-1.
The elements described in Section 3 are the subject of this Application. An accompanying Construction Quality Assurance Plan (Appendix A) has been developed to ensure compliance with the relevant Works Specification detailed.
The information described is supported by a waste management lifecycle process flow chart and Waste Zoning Guide (WZG) contained in Appendix I.
Section 3 does not describe mining activities, as mining is regulated by Department of Mines, Industry Regulation and Safety and has been approved under Mining Proposal Reg ID 75521.
As outlined in Section 1, this Application does not detail the aspects of radiation management in regard to waste, as this is regulated under the RS Act. Section 3 provides high level information about the management, handling and treatment of LLW for context only.
This Application has grouped Categories 61, 61A, 65 and 66 infrastructure as follows:
• Waste inspection and operational surface storage. • Liquid waste immobilisation. • Permanent isolation of waste within waste Cells. • Storm water catchment and retention.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 6 220750 221000 ID Infrastructure 1Flood levee Sandy Ridge Facility 2Fire Risk Store Area Prescribed Premises Boundary 3W h eel w ash facility 4Site entry car/bus p arking 5Site entry gates 6Veh icle insp ection area 33 7Radiation scanner 470 4 7
8Main office 0 5 0 0 0 5 5
9Go line 7 Infrastructure 7 3 3 6 6
10Emergency veh icle station 6 Area 6 11East yard (solids) 12RO Plant 13W ater h andling facility 14Container staging unloading 2 11 15Container staging storage area 16W aste Insp ection Facility 30 17Fire w ater facility 23 18Storm w ater retention p ond 19Service w ater p ond 20Laboratory and office 9 479 21W aste Immobilisation Plant "W IP" 4 22W aste Insp ection & W IP Disp ensing Facility 78 1 23W orksh op and Laydow n yard 26 20 47 24W aste immobilisation p lant loading 19 7 21 25100† cement storage silo 25 476 26Graded kaolin bulk h op p ers 22 27HV and LV w ash dow n facility 16 28Pow er facility 47 18 5 29HV and LV refueling facility 24 30HV and LV mobile p lant w orksh op 14 31Solar p anel farm 32 10 32Stormw ater sump w est
33Stormw ater sump north 0 8 0 5 5 2 2 7 7
3 15 3 1 Works Approval 1 (W6234-2019-1) 6 6 6 7 6 Works Approval 2 1 27 5 4 (Cat 61 & 61A Temporary Storage) 28 6 29 1 Works Approval 3 (Cat 65 & 66)
4 6 12 9 4 17 6 13 8 473
4 3 474 6 7 4 7 0 4 4 7 7 1 2 31
220750 221000 Figure B-X Legend Infrastructure Area 50 25 0 50 m Proposed Infrastructure Footprint Elevation 1m contours Proposed Mining SANDY RIDGE FACILITY ± Projection: GDA94 MGA Zone 51 Prescribed Premises Boundary 5m contours CAT 65 & 66 WORKS APPROVAL Drawn by: DS SP-ID: GL00-2017072102-714 TSR0388_WWAv3_InfrastructureArea.mxd Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Version: A Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 27/09/2019
3.2 Waste inspection and surface storage The Facility will be operated in accordance with the Dangerous Goods Safety (Storage and Handling of Non-Explosives) Regulations 2007 and in accordance with Dangerous Goods Licence DGS022452 (see Appendix D).
Solid wastes may be stored in either the East Yard (see Section 3.2.3) or the Mixed Store (see Section 3.2.2). Liquid/sludge wastes may be stored in either the Mixed Store or the Radioactive Waste Warehouse and Yard (see Section 3.2.5.
During operations, above-ground storage time for wastes at Sandy Ridge is expected to be about 14 days for onsite verification testing in accordance with the Tellus’ WAP. Some waste may occasionally be longer due to operational constraints.
MS 1078 limits the duration of above-ground waste storage to 12 months. Tellus will store materials ‘like with like’ wherever possible and in accordance with its DG licence (Appendix D).
3.2.1 Waste inspection bays
The information explained below is supported by Figure B1 in Appendix B.
On entering the site, the consignment’s waste documentation would be reviewed and inspected at the front gate and waste inspection bays (respectively). The exterior of the truck and containers and non-containerised bulk items would also be inspected at this point.
Immediately after the gate is the drive through radiation detector. The detector will be calibrated to measure radiation levels and indicate go/no-go according to a pre-set threshold. If the truck is flagged as not containing radioactive waste, the truck is to proceed as directed. If the truck is flagged as carrying radioactive material, it is to be halted and escorted to the quarantine area for further investigation and action in accordance with Tellus’ Radiation Safety Management Plan and Standard Operating Procedures2.
The waste inspection bays are intended to allow for the opening, evaluation and inspection of the waste receptacles that are transported to the Facility in a sealed container. The inside of the shipping container (or other transport container e.g. drums) would be inspected to check for damaged/leaking waste packages (this may require removal of some packages). If they are found to be in accordance with the WAP, a selection of waste packages can be removed for Level 3 verification testing.
Containers will be partially unloaded from the incoming road train vehicles. Typically trucks of varying trailer configuration but maximum shall be a B-Triple (36.5 m) onto the bays, or from Container storage as applicable. A minimum of two bays are required. The waste package would be
2 Tellus’ Radiation Safety Management Plan and Standard Operating Procedures for low level radioactive waste for the premises are being assessed and approved separately by the WA Radiological Council under the Radiation Safety Act 1975.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 8
audited against the customer’s pro forma to confirm the volume and type of waste delivered is as described in the customer’s documentation.
If the documentation is not present or is incomplete, Tellus would be unable to confirm that the packaging and transport standards have been met, the truck would be quarantined within a hardstand (temporary yard) area. Tellus would not turn around a truck until a full investigation was carried out and advice sought from DWER while any uncertainties or discrepancies are resolved between Tellus and the waste customer.
If documentation is complete, the waste packages would be inspected for damage and leaks. If the packaging is damaged significantly the pallet would be held whilst a solution is agreed between Tellus and the waste customer. Any damaged or leaking waste package would be made safe as soon as possible to minimise worker or environment exposure to the waste. The waste package would be contained and managed in accordance with the methodology outlined in the Facility’s Operating Strategy. Contaminated shipping containers will be cleaned in a bunded area.
If the waste manifest meets packaging and transport standards as per the Waste Supply Contract (WSC) and the WAC, trucks with containers would proceed through the gate to the waste storage areas (refer to Sections 3.2.2 and 3.2.3).
Consignments would be weighed using a reach stacker fitted with a weightometer. At this point the waste would be considered delivered, but not accepted. The shipping container remains in the Mixed Store or East Yard until it is scheduled to be moved into the waste cell. Waste storage will be in accordance with Dangerous Goods Storage Licence DGS022452.
When scheduled, sludge wastes are transferred directly to the Waste Immobilisation Plant (WIP) (refer to Section 3.3 for more information on the WIP).
Each container would be tracked and logged in an electronic record system which forms part of Tellus’ Enterprise Resource Planning system3. This will track waste through each handling stage so that its location is known and can be communicated to the regulator or customer, if requested.
For bulk solid items (such as sleepers, and piping) the load would be inspected and sampled in the truck before being unloaded into a bulk storage building, vessel, tank, hopper, covered bunker or hardstand area. The frequency of inspection and sampling of waste packages would be adjusted over time as confidence increases in the consistency and reliability of deliveries from any customer.
The construction and operational requirements of the waste inspection bays are:
• Covered area providing protection from rain ingress. • Spatial area for the unloading and storage of 24 standard pallets (unstacked).
3 Tellus’ proposed internal business system
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 9
• Minimum covered spatial area shall allow for ease of access by associated mobile plant, namely a laden container lifter, forklift traffic, LV and pedestrian allowances.
• Traversable blind catchment sumps.
• Structure to be rated for area. • Appropriate flooring (i.e. concrete) to associated work areas.
• Potable water for safety showers and eye wash stations.
Drawings
Refer to drawing number: A3-4 General Arrangement Plan and Elevations in Appendix C
3.2.2 Mixed Store
Mixed Store will be operated in accordance with Dangerous Goods Storage Licence DGS022452 (Appendix D) and can be used to store solid and/or liquid wastes.
The Mixed Store is to be used to store containers within their nominated waste groups, pending either delivery to the waste disposal cell, laboratory sampling, laboratory sampling test results or storage of empty containers awaiting removal from site.
A digital waste management system will assist waste storage planning and will record waste movements. Accordingly, the location and nature of all wastes will be known at any time. Each container will be logged and tracked using the electronic records system.
Containers may also be quarantined if their contents do not meet the WAC and require investigation/further action. These details will be logged in the electronic records system.
Empty containers may be stored anywhere in the Mixed Store or East Yard as they have no consequence from an environmental or human safety perspective.
A section of the Mixed Store or East Yard (see Section 3.2.3) may be set aside on a campaign-basis for consignments of bulk waste items (e.g. contaminated sleepers or pipes) that do not require transport or storage in sea containers and, can be safely stored with minimal containment due to the insolubility of their contamination.
Upon return from the waste Cell, the containers are cleaned (if required) at the bunded area in the Radioactive Waste Area.
Liquid wastes
The Mixed Store will store sludges, liquid wastes in containers within their nominated waste zoning groups as per Dangerous Goods Licence DGS022452. Liquid/sludge wastes may also be stored in the Radioactive Waste Area (see Section 3.2.5.
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As defined in supporting detailed design engineered drawings, an appropriate paving type will be used in areas where liquid/sludge wastes are to be stored. The layout i.e. waste storage zones, will need to be flexible to cater for the changing amounts and types of wastes at the Facility, which will vary over time.
The design criteria for the Mixed Store will be as follows:
• Vehicles – laden container lifter, light vehicles and road train vehicles. • Minimum slope – 0.5 %
• Minimum of 1.5m between ends of the containers and a minimum of 0.5 m between container lengths. • Rainwater containment 100yr ARI for 72 hours.
• Container storage area shall be block paved with an appropriate base course capable of supporting all associated works and equipment. • Suitable yard lighting to provide safe working environment. • Rainwater collected and drained to the yard containment pond. • Pavement Type A as follows: o 80mm block paving and base course as nominated below: . 25 mm bedding sand. . 200 mm thick cement modified silcrete/laterite (with a minimum soaked CBR of 80 %) and approximately 1 % cement by mass. . 200mm thick cement stabilised in situ material and approximately 2 % cement by mass. . Compacted subgrade CBR 15 % minimum. o Block paved areas to be dry swept with Bentonite clay.
Drawings
• Refer to drawing numbers: A3-5 Facility Processing Facility Plant Arrangement and A3-6 Bulk Earthworks Layout in Appendix C for location and layout.
• Refer to drawing number: A3-7 Pavement Type Details in Appendix C for pavement specification
3.2.3 East yard
East yard will be used for the storage of dry and bulk solid waste materials and will be operated in accordance with Dangerous Goods Storage Licence DGS022452.
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The requirements for the East Yard area are:
• Pavement Type C as follows: o Area to be cleared, shaped and proof rolled and compacted. o 250mm select fill compacted to 95 % MMDD. o Compacted subgrade CBR 15 % minimum. • Needs to be free drain away from the facility into a run off pond.
• Be suitable for the container handler.
Drawings
• Refer to drawing numbers: A3-5 Facility Processing Facility Plant Arrangement and A3-6 Bulk Earthworks Layout in Appendix C for location and layout.
• Refer to drawing number: A3-7 Pavement Type Details in Appendix C for pavement specification.
3.2.4 Flammable risk store
The flammable risk store will be used to store containers within their nominated waste groups pending laboratory sampling or consolidation prior to off-site disposal to appropriately licenced third-party waste facilities capable of handling flammable waste, and storage of empty containers awaiting removal from site. Flammable materials are not permitted in the waste Cell (as defined in the Sandy Ridge WAC).
The flammable risk store will be operated in accordance with Dangerous Goods Storage Licence DGS022452.
The requirements for the flammable risk store are:
• Pavement Type A as follows: o 80mm block paving and a base course as nominated below: . 250mm thick cement modified silcrete/laterite compacted to 95 % Maximum Modified Dry Density (MMDD). . Compacted subgrade with a CBR of 15 %. . All block paved areas to be dry swept with bentonite clay. o Rainwater containment to a 100 ARI annual recurrence interval (ARI) for 72 hours with drainage to a sump that can be manually pumped out.
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Drawings
• Refer to drawing numbers: A3-8 Flammable Goods Mechanical Arrangement and A3-9 Flammable Goods Civil Arrangement in Appendix C for location and layout.
• Refer to drawing number: A3-7 Pavement Type Details in Appendix C for pavement specification.
3.2.5 Low level Radioactive Waste warehouse and yard
Overview of LLW approval process for Sandy Ridge
In September 2019, Tellus submitted the WA Radiation Health Unit (RHU) a Site Registration Application under the RS Act. If granted, the Registration will permit Tellus to accept LLW for storage at the Facility. The Site Registration Application was supported by a Radiation Management Plan (RMP) and Standard Operating Procedures for managing hazards associated with storing and handling LLW at the premises. The RMP is attached in Appendix E.
In October 2017, Tellus submitted a pre-operational Safety Case to the RHU covering hazards associated with permanently isolating LLW inside a Cell. The same document covered long term exposure hazards to humans and the receiving environment (also known as post-closure risk assessment).
Both documents are currently under assessment by the RHU and Radiological Council. A copy of the Safety Case can be made available upon request.
Details of the radioactive waste warehouse and yard
The radioactive waste warehouse and yard are used to receive and store low level radioactive materials, NORM solids/liquids and pastes (both radioactive and non-radioactive), and Disused Sealed Radioactive Sources, which are delivered in packaging or as required by the Facility’s Radiation Management Plan and/or Dangerous Goods Licence.
The radioactive waste warehouse will:
• Enable the unloading and inspection of containers laden with radioactive material. • Enable the repacking/filling of containers with radioactive waste that has been consolidated in the radioactive warehouse. • Enable the transfer of liquid waste to the WIP.
• Provide a means of baling empty Intermediate Bulk Containers (IBC) and Flexible Intermediate Bulk Containers (FIBC) and heavy steel drums. • Provide dedicated, access controlled, temporary storage areas for radioactive wastes. The radioactive waste yard will:
• Enclose the radioactive waste warehouse.
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• Be utilised to store both non-radioactive and radioactive sludges and liquids. • Enclose the liquid waste unloading component of the WIP.
• Be utilised to store both empty and loaded half height 20’ containers used for WIP-treated waste material. Access to both the radioactive waste warehouse and yard shall be controlled. For example, vehicle access will be via controlled access gates into the yard. Personnel access shall be via the controlled laboratory access and scanning room.
The requirements of the radioactive waste container yard include:
• Storage for approximately 40 containers or International Standards Organisation (ISO) liquid containers double stacked
• Storage for approximately 12 containers (half height) servicing the WIP facility • Include covered area for container unloading, inspection and/or packing – area shall allow for at least 20 standard pallets to be unloaded and prevent any water ingress in the front of the container. • Suitable for laden container lifter (yard) and forklift for inspection, shedding and liquid waste unloading areas. • Shall allow for secure controlled handover of container from Road Train Vehicle delivery, to the Heavy Vehicle for transport to the waste cell. • Sumps must be suitable for a: o 1 in 100 ARI for 72 hours (open yard area). o 110 % pf a 20’ ISO liquid container. o 110 % of IBC. • Pavement Type A (in the yard): o 80 mm block paving and base course (as nominated below). o 25 mm bedding sand.
o 200 mm thick cement modified silcrete/laterite (with a minimum soaked California Bearing Ratio [CBR] of 80 %) and approximately 1 % cement by mass. o 200 mm thick cement stabilised in situ material and approximately 2% cement by mass. o Compacted subgrade CBR 15 % minimum. o All block paved areas to be dry swept with bentonite clay. • Closed circuit television. • Access card entry or similar access restricting measure.
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• Electric gates (pedestrian and container lifter) – two sides of the yard. • Suitable yard lighting to provide safe working environment.
• Fire detection system. • Potable water for safety showers, washdown, flushing.
Details of LLW isolation in waste Cell
Refer to Section 3.4.2.
Drawings
• Refer to drawing number: A3-10 General Arrangement Plan and Elevations in Appendix C for location and layout.
• Refer to drawing number A3-7 in Appendix C for pavement specification.
3.2.6 Liquid waste unloading area
The waste liquid unloading area is to be a bunded slab capable of handling drums, IBC’s and ISO liquid containers. It shall be utilised for both non-radioactive and radioactive liquids and sludges. Following the relevant inspection and waste acceptance procedure (WAP) (Appendix H), the liquid waste container will be placed in the liquid waste unloading slab. The container will be connected to the dispensing pump system to transfer the contents to the WIP.
The requirements for the waste liquid unloading slab include:
• Close in location to the WIP mixer. • Suit unloading from 20’ ISO liquid containers, IBC’s and drums. • Nominal flow = 15 m3/hr. • Maximum flow = 24 m3/hr. • Fluid is waste sludge at ambient temperature. • Pump discharge head for selection purposes = 400 kPa. • Preferred pump = Verderflex VF80.
• Pump motor = minimum 12 kW (vendor to confirm requirements). • Pump to be powered by a Variable Speed Drive, speed to be manually set by operator.
• Pump suction piping to be manifolded to allow suction from; o 10 off IBCs (each individually valved). o 5 off 20’ ISO liquid containers (each individually valved). o The floor sump.
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o Raw water flushing points(s) at the outer end of suction manifolds(s) • Construction o Bunded slab within radiation store / warehouse building. o Bund should be able to store at least 110 % of the total 20’ ISO liquid container. Sizing or screen to ensure that any possible spray is directed to the bunded or drain area. o Slab should drain to blind floor sump. Emptied by the Waste Pump. o Pump suction and discharge piping to be HDPE, PE100, PN8, DN110. o Piping between suction manifolds(s) valves and IBC’s / 20’ liquid containers to be wire wound suction hose. o Remote head type magnetic flowmeter to be in a vertical rise section of pipe between waste pump and WIP. Flowmeter head unit and display to be located close to waste pump. o Digital pressure transmitter to be located immediately downstream of waste pump. o PLC control – fully integrated as single system with WIP PLC. • Services o Washdown water (raw water) for manual washdown and flushing of waste vessels and floors areas. o Raw water flush (clean in place) form outer end of waste pump suction manifold(s), through the pump, to a point immediately upstream of the WIP suction manifold(s), through the pump, to a point immediately upstream of the WIP mixer and returning back to 20’ ISO liquid container in sump area required. o Safety shower and eye wash station (potable water). o Compressed air main (minimum 25 mm ID pipe) from workshop compressor to be available close to waste pump, terminated in a ball valve.
Drawings
Refer to drawing number: A3-11 Radioactive Inspection Facilities Warehouse – Concrete Arrangement in Appendix C for Concrete Arrangement.
3.3 Liquid waste immobilisation
3.3.1 Waste Immobilisation Plant
The WAC allows for liquids and sludges to be accepted at the Facility and stored on the surface in appropriately bunded areas. The wastes will be fully characterised during the Level 1 Basic
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Characterisation to ensure that they can be safely treated in the WIP prior to issuing the Waste Services Contract.
The WIP is to be used to prepare/stabilise received waste sludge/liquid for disposal within the waste cell by mixing the supplied waste with a combination of mined kaolin and/or cement. The treated solidified waste can then be deposited into a cell where it will no longer pose a risk of subsidence or free liquid discharge.
The likely processes for waste treatment or conditioning that may be implemented at the Facility are described below. Tellus would safeguard that the pre-treatment processes do not result in unacceptable emissions or discharges to the environment.
• Oily sludge - Hydrocarbon sludge containing NORM and/or heavy metals cannot always be recovered or safely disposed of using existing treatment processes such as biodegradation, oxidisation, stabilisation or incineration. Oily sludges would be delivered in either intermediate bulk containers inside shipping containers, or as bulk liquids in a tanker truck, with the former being more likely. Oily sludges would be stored until such time as they are ready to be immobilised and placed in the cell. The oily sludge would then be mixed with controlled measures of binding and immobilising materials such as kaolinised granite or cement, to produce a cement-like slurry.
• Non–oily liquid and sludge - Other wastes in either liquid or sludge form would be reduced in volume, filtered or dried before delivery to the Sandy Ridge Facility, preferably by an existing waste management contractor. In the event of some liquid wastes not being able to be treated or only being partially treated (to a sludge), immobilisation treatment would be provided for these wastes using kaolinised granite and or cement. Immobilisation would typically take place with both materials being added to a mixing device. In the event of drums of waste being delivered where a liquid has separated in transport from a paste, absorbent material would need to be added into the drum or container to absorb the released liquid before the waste can be placed in a Cell.
The mix created by the WIP is discharged into a half height 20’ container that is located on a rail mounted trolley under a mixer. Small batches may alternatively be discharged into disposal packages.
The half-height 20’ container will be located on a purpose-built trolley so that the container can be moved on the rail support system to allow the reach stacker to pick up the container and load on an Articulated Dump Truck (ADT) for disposal in the waste cell.
Containers of immobilised waste will be transported to the current waste cell or stored within the Radioactive Yard awaiting disposal. The immobilised waste would either be transferred from the sea container into the waste cell or placed in the cell in disposal packages. The direct placement slurry would be allowed to set in-place in the cell and later covered with kaolinised granite.
The key requirements for the WIP are as follows:
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• 30 tonnes per hour throughput. • Constituent dosing and measurement will be carried out automatically.
• Cement will be directed from a bulk 100 tonne storage silo. The silo shall be allowed to be pneumatically loaded from a B-triple powder tank.
• Suitable lighting to provide safe working environment.
• Liquid waste pumped from 20’ ISO liquid containers, IBC’s or drums via bunded pipelines. • Kaolin manually machine loaded into feed bin then conveyed to planetary mixer.
• Operator will have the ability to choose what mix design to use through a touch panel programmable logic controller interface.
• The WIP control system shall record and output (to file type suitable for importation into Microsoft Excel software) all batches run, including constituent weights for all materials by batch.
Drawings
Refer to drawing number: A3-12 General Arrangement Plan and Elevations in Appendix C for General Arrangement.
3.4 Permanent isolation of waste
3.4.1 Cell planning
Sea containers would be stored in a storage yard until that waste type is ready to be placed in the Cell in accordance with the cell scheduler. Bulk materials would also be stored until required in the Cell. The Cell scheduler is an electronic planning and inventory assessment tool to effectively manage space within the Cell and to ensure the entire batch of a certain type of waste (e.g. arsenic), can be placed in a designated location within the cell that is ready to receive the waste. Placement of wastes in the Cell will be in accordance with the Waste Zoning Guide (Appendix I). The Cell scheduler would be integrated with the electronic records system so that each waste package is tracked and its location and depth within the Cell logged with a survey co-ordinate. The electronic records system would track each waste package from the point where it is accepted on-site until it is placed in the Cell.
3.4.2 Waste Cell and mining area
The mining area is to operate in a manner where one Cell is in operation (for permanent isolation of Class IV and Class V waste) at a time. The Cell is to be excavated (including access ramp) and on completion the mining void will become a Cell that is backfilled with waste and then “capped” with previously excavated clay and overburden material.
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Cell excavation and waste backfilling operations are to be undertaken under a pre-inflated air dome cover. The Cell dome cover will have an airlock door for entry and egress and span the width and length of each Cell. Prior to placing waste into the cell, the air dome would be in place covering the entire cell. The purpose of the air dome is to exclude water from the cell until it is capped, to avoid the generation of leachate within the cell and avoid any potential structural impacts that may affect the integrity of the cell walls.
Localised drainage around the Cell is also required to prevent ingress of water into the void during waste operations. The water will be directed to a settlement sump. If required, water within the settlement sump will be pumped out and can be re-used within the WIP process. In addition, an clay cored earth bund / levee will be constructed on the perimeter of the Facility to prevent any surface water ingress into the waste infrastructure area and Cells (refer to Figure 3-1).
Survey coordinates of each placed waste package or area of bulk waste placement would be recorded. Each section of the cell would be surveyed, and depths of stored waste updated in the electronic records system. Once the waste customer’s shipping container or bulk materials have been placed in the Cell, a Placement Certificate would be issued to the waste customer.
The waste Cells would be filled in layers with multiple sections in each layer containing wastes of similar characteristics to segregate the different waste types. Chemical waste types would be placed ‘like-with-like’ for safety reasons and for potential future recovery (if identified as potentially valuable). LLW waste materials would be permanently isolated within a concrete cylindrical shaft as depicted in Figure B3 in Appendix B.
Appendix B illustrates how different waste types (chemical and LLW) are intended to be physically separated within the waste Cell i.e. in a ‘like for like manner’.
Spaces between waste packages would be backfilled with kaolinised granite and compacted to minimise air or void space. Small amounts of liquid will be added to aid compaction. If this approach is not taken it may result in settlement which could impair the performance of the Cell cap. Each layer would be compacted, until approximately 7 m below the ground surface, where a thick capping layer of low permeability clay (referred to as a ‘seal’) would be installed to prevent water ingress into the Cell.
Localised Cell excavated material is expected to be graded, stockpiled and available (for operational optimisation) close to the Cell to aid with backfilling and capping operations. Some excavated material of a grade suitable for stabilisation and solidification of waste may be stored at the WIP (in suitable quantities). Additionally, a stockpile of kaolin will be developed and held at the kaolin stockpile for potential future export and processing requirements.
It is important to note that Cell excavation and waste backfilling operations are not to impact the geological isolation integrity of existing and future Cells. This means there will be no blasting operations for future Cell development.
The requirements of the waste Cell and mining area are as follows:
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• Open cut pit. • Minimum Cell size of 80 m x 160 m x 30 m.
• The first pit shall be fully excavated before waste emplacement commences. • Subsequent pits shall be excavated while placement of Class IV and Class V waste materials continue in the adjacent Cell.
• No blasting operations shall be used or considered, silcrete (rock) layers shall be mechanically mined only.
• Equipment - HV, LV, fuel tanker and lighting plant but primarily articulated dump trucks (ADT’s) and wheel loaders
• Vehicle loads – Fully laden ADT (i.e. with fully packaged 20’ container) down ramp; loaded ADT going up ramp. • Speed – Maximum of 15 km/hr • Surface – Unsealed. • Average HV’s per day – 30. Surface drainage around the waste Cells will be typically graded away from the waste Cells to the catchment / settlement ponds in the south west corner of the mining area. If required, water within the settlement pond will be pumped out and can be re-used within the WIP process.
Drawings
Refer to drawing numbers: A3-13 GA Plan & Elevations showing air dome, A3-14 GA Earth works Plan & Elevations, A3-15 GA Concrete Blocks Plan & Elevations and A3-16 Settlement pond GA Plan & Elevations in Appendix C for General Arrangement and Elevations.
3.4.3 Capping Cells
After a low permeability seal is installed, more compacted backfill and a clay domed cap would be situated on the top of the Cell, to shed rainfall. Figure B3 in Appendix B illustrates how wastes would be contained within the Cells.
Waste cells will be closed progressively, with one cell being capped and closed while the next cell is being developed. This process, along with the closure and decommissioning of the waste infrastructure, is detailed in the Waste Facility Decommissioning and Closure Plan required by MS 1078.
The encapsulation of wastes within each cell would be subject to rigorous engineering design and compaction testing to ensure the properties of the constructed Cell is a close analogue of the existing geological and hydrogeological conditions at the site, which naturally excludes water from the kaolinitic soils located beneath the silcrete layer. A feature survey of the Cell would be conducted to confirm the Cell is constructed in accordance with the engineering design.
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3.5 Storm water catchment and retention
3.5.1 General
Water from external catchments (i.e. from rain events) is to be diverted around the facility in order to prevent ingress through the facility and possible contamination. Surface water drainage requirements are as follows:
• 1:100 ARI over 72 hours.
• Construction and operation: o Earthen drains / rock stabilisation / culverts as required. o Cut off drains as required preventing flooding of the site. o Drainage isolation points as required.
3.5.2 Yard capture pond
The yard capture pond will be constructed to collect treated water from the washing facilities and stormwater from the container storage area. The yard capture pond will allow for the retaining, monitoring and handling of any contaminated water and will be joined with the service water pond.
The water will be used to condition backfill material in Class IV and Class V waste placement operations.
The requirements of the yard capture pond are as follows:
• High level overflow or balance level to the service water / retention pond. • Capacity to handle 100 year ARI for 72 hours from allocated capture area. • Excavated/formed HDPE lined pond. • Stock fence perimeter. • Life buoys and egress ropes/mats inside pond. • Equipment: o Electric pump and standpipe shared with the service water pond. o Minimum 100 l/s. o Suitable height for 30,000 litre tank mounted on a 6x6 ADT. o Air key/remote operated. • Feeds: o Treated washdown water and HV/LV mobile plant workshop sump water. o Rain infiltration/storm water from container yard.
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Drawings
Refer to drawing numbers: A3-17 Service Water and Yard Capture Ponds Plan and A3-18 Service Water and Yard Capture Ponds Sections in Appendix C for General Arrangement and Sections.
3.5.3 Service water pond
The service pond is to be sized to suit both mining operations and processing/potable water production operations, excluding storage of any brine water.
The requirements of the service water pond are as follows:
• Excavated / formed HDPE lined pond. • Stock fence for perimeter.
• Life buoys and egress ropes/mats inside pond.
• Equipment: o Electric pump and standpipe shared with the yard capture pond. o Minimum 100 l/s. o Suitable height for 30,000 litre tank mounted on a 6x6 ADT. o Air key / remote operated. o Level control for automatic raw water supplement. • Feed - Raw water from bore transfer tank. • Consumption requirements – Waste backfill and dust suppression in mining operations.
Drawings
Refer to drawing numbers: A3-19 General Arrangement South Catchment Pond, A3-20 General Arrangement West Catchment Pond and A3-17 Service Water and Yard Capture Ponds in Appendix C for General Arrangement.
3.5.4 Brine pond
The construction turkeys’ nest shall be utilised in the future as a brine pond. The pond shall be lined and fenced to prevent livestock entering. The water will be consumed in the backfilling and mining operations within the waste Cell.
During construction, the pond shall be manually filled by the contractor from the raw water pipeline. Once the works are complete, the pond shall have water supplied via the brine output from the water treatment facility while retaining the original raw water supply infrastructure.
The requirements of the brine pond are as follows:
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• Excavated / formed HDPE lined pond. • Stock fence for perimeter.
• Life buoys and egress ropes/mats inside the pond. • Equipment: o Electric pump and standpipe. o Minimum 100 l/s. o Suitable height for a 30,000 litre tank mounted on a 6x6 ADT. o Air key/remote operated. o Level control for automatic raw water supplement. • Feeds: o Waste water from the RO plant
Drawings
Refer to drawing number A3-21 Earthworks Arrangement – Brine in Appendix C for Earthwork Arrangement. 3.6 Raw water supply and treatment
3.6.1 Raw water supply
Raw water is to be supplied from a bore to be installed northwest of Carina Mine Pit. The raw water will be required to be drawn from a new bore to be constructed North West of the disused Carina Mine Pit.
The project requires a robust method of transferring the raw water from the Carina Mine Pit to support the site. The minimum requirements for the water transfer system include:
• Power supply: o Diesel power o Bulk diesel storage to be supplied to support consumption; fuel supply should last a minimum of one week
• Equipment: o Duty / standby transfer pumps with two interchangeable different flow setpoints: o Telemetry for remote control and monitoring. o Staging tank shall provide at least one hour of storage capacity. o The pipeline from the bore to the site shall be buried below any potential radiant heat zone caused by a bush fire and include all required air valves and scour points.
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o The pipe shall be a minimum of 160 mm OD.
Drawings
Refer to drawing number A3-22 General Arrangement 12388-L-029, A3-23 Brine pond 12388-L-030, A3-24 Mine NPI water facilities 12388-L-031, A3-25 Spray filed arrangement 12388-L-032, and A3-26 Bore filed headworks arrangement 12388-L-033 in Appendix C for Arrangements.
3.6.2 Water treatment facility
The potable water facility shall treat the incoming raw water from the bore and allow for the water to be reticulated to the points of use at the facility and the village.
The requirements of the water treatment facility:
• Potable water drinking guidelines and applicable Australian and New Zealand Environment Conservation Council and Australian standards. • Single system for potable water production to cater for the Facility and Village usage. • Waste to discharge to the brine pond. • Potable, fresh water and raw water storage shall cater for fire reserve and residence time. Fresh water to be used for fire water and supply for washdown. • Combined potable and raw water storage shall provide at least three days of uninterruptible potable supply. • Potable water facility shall control the operation of the raw water supply to the Facility. • Construction: o Turnkey modular package. o Pre-filtration unit shall be employed to minimise the requirement for the fouling and consequential replacement of any pre-filters / treatment filters. • Equipment: o Electric pump (10 l/s capacity) connected directly to fresh water storage tank. o 100 mm lay flat lose connection.
Drawings
Refer to drawing number A3-24 in Appendix C. 3.7 Exclusions to the Premises • The Access Road and ground water supply from Carina Iron Ore Mine are not prescribed activities/infrastructure and are therefore not subject to Part V approvals. • A Critical Containment Infrastructure Report, as described in DWER’s Guideline: Industry Regulation Guide to Licensing, does not apply to this Application because the Facility is not
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an engineered landfill. As described in MS 1078, the Facility is a near-surface geological repository and does not rely on engineered barriers.
• Instead, the Facility can rely on the passive safety of the geology (in the form of weathered kaolinised granite). The environmental hazards and risks of the near-surface geological waste repository at Sandy Ridge has been considered and approved by MS 1078 and EPBC2015/7478.
• Raw water supply was described in the Sandy Ridge Mining Works Approval No.1 W6243 and therefore, does not form part of this Application.
• Waste water treatment plant and spray field was described in the Sandy Ridge Mining Works Approval No.1 W6243 and therefore, does not form part of this Application.
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4 LEGISLATIVE CONTEXT
4.1 Summary of approvals and tenure The Australian Government granted approval for the Facility in January 2019 (EPBC2015/7478) under Section 133 of the Environmental Protection Biodiversity Conservation Act 1999.
Table 4-1 summarises approvals that have been achieved and are relevant to the Facility.
4.2 Part IV of the EP Act
4.2.1 Ministerial Statement 1078
MS 1078 applies to the Premises. Several environmental and compliance Conditions apply to the Facility and are summarised below:
• Condition 4-1 requires Tellus to maintain a Compliance Assessment Plan. • Condition 4-6 requires Tellus to submit a Compliance Assessment Report. • Condition 8-2 requires Tellus to engage and independent waste expert to undertake an annual audit of the waste disposal operations. • Condition 9-2 requires Tellus to prepare a Leachate Monitoring and Management Plan prior to the commencement of waste receival. • Condition 10-5 requires Tellus to prepare a construction Flora and Vegetation Management Plan. • Condition 11-2 requires Tellus to prepare a construction Environmental Management Plan to ensure impacts to terrestrial fauna are minimised. • Condition 12-1 requires Tellus to prepare a Waste Facility Decommissioning and Closure Plan.
4.3 Contaminated sites The Premises is not reported as a Contaminated Site. Once Class IV and/or Class V has been emplaced in the waste cell, it is expected the site will be registered on DWER’s contaminated sites register. DWER will decide on the level of remediation required (if any) at the appropriate time.
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Table 4-1 Relevant approvals and tenure achieved for the Facility to date
Legislation Approval reference Subsidiary Approval Part 9 of the 2015/7478 Tellus Holdings Ltd Approval to construct and operate an Environmental Protection open-cut kaolin clay mine, arid near- Biodiversity Conservation surface geological waste repository within Act 1999 the mine voids, and associated infrastructure for the storage, treatment, recovery and permanent isolation (disposal) of hazardous and intractable wastes (including low level radioactive waste Part IV of the EP Act MS 1078 Tellus Holdings Ltd Approval to implement proposal to construct and operate a dual open cut kaolin clay mine and a near-surface geological waste repository accepting Class IV and Class V waste. Section 45C under Part IV MS 1078 Tellus Holdings Ltd Approval to increase development of the EP Act envelope and relocate groundwater bore location. Mining Act 197E Registration ID Tellus Holdings Ltd Approval for Mining Proposal with a Mine 75521 Closure Plan on G 16/21, L 15/361, L 15/362, L 16/119, L 16/121 and M 16/54. Planning and DAP/17/01318 Tellus Holdings Ltd Accept DAP/17/01318 is appropriate for Development Act 2005 consideration as a “Waste Disposal Facility” land use and compatible with the objectives of the zoning table in accordance with Local Planning Scheme No 5 of the Shire of Coolgardie. Approve DAP Application reference DAP/17/01318 and accompanying plans in accordance with Clause 68 of the Planning and Development (Local Planning Schemes) Regulations 2015 and the provisions of the Shire of Coolgardie Local Planning Scheme No.5 Dangerous Goods Safety DGSO22452 Tellus Holdings Ltd A licence authorising the holder to store Act 2004 dangerous goods within WA in accordance with the application and any conditions. Land Administration Act Under assessment Tellus Holdings Ltd Grant of Crown Lease is anticipated in 1997 November 2019. Radiation Safety Act 1975 Under assessment Tellus Holdings Ltd Site Registration and licence to accept and dispose low level radioactive waste. 4.4 Part V of the EP Act To implement the authority granted under MS 1078, this Application is seeking a Works Approval for the construction of the Facility under prescribed premises Categories 65 and 66 being for Class IV and Class V waste disposal. The phasing of approvals under Part V is summarised in Table 1-1.
A separate application for works approval Categories 61 and 61A (Solid and Liquid and Solid waste facility, Tellus 2019) was submitted to DWER on 26 September 2019 (WAA2). That application
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 27
sought approval to construct a small secure facility in which to store low-risk wastes during the construction of the full Sandy Ridge Facility.
The current Application (WAA3) seeks to broaden the scope of infrastructure associated with Categories 61 and 61A to store, treat and manage Class IV and Class V wastes at the Facility.
4.4.1 Application regulations, standards and guidelines
In preparing this Application, Tellus has considered the following guidance statements within the WA legislative framework under the EP Act and EP Regulations. They are:
• Guidance Statement: Regulatory Principles (July 2015)
• Guidance Statement: Setting Conditions (October 2015)
• Guidance Statement: Risk Assessments (February 2017) • Guidance Statement: Environmental Siting (November 2016)
4.4.2 Reporting of incidents
Under Section 72 of the EP Act, Tellus will report all discharges of waste that have caused or are likely to cause pollution, material harm or serious environmental harm.
4.4.3 Offences and defences
The EP Act and its regulations set out several offences including:
• Offence of emitting an Unreasonable Emission from any Premises under s.49. • Offence of causing Pollution under s.49. • Offence of dumping Waste under s.49A. • Offence of discharging Waste in circumstances likely to cause Pollution under s.50. • Offence of causing Serious Environmental Harm (s.50A) or Material Environmental Harm (s.50B). • Offence of causing Emissions which do not comply with prescribed standards (s.51). • Offences relating to Emissions or Discharges under regulations prescribed under the EP Act, including materials discharged under the Environmental Protection (Unauthorised Discharges) Regulations 2004 (WA).
• Offences relating to noise under the Environmental Protection (Noise) Regulations 1997 (WA). Under Section 53 of the EP Act it is an offence for a holder of a Works Approval if emissions are caused, or altered, from a Prescribed Premises unless done in accordance with a Works Approval, Licence or the requirements of a closure notice or an environmental protection notice. Therefore,
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 28
this Application seeks the approval to lawfully emit and discharge contaminants within the Facility within limits and conditions set by DWER.
4.5 Radiation Safety Act 1975 This Application (see Section 3) provides high level information about the management, handling and treatment of low level radioactive waste (LLW) for context only. The management and disposal of NORM / LLW is regulated under the RS Act by way of a site Registration. The Registration application to accept, store, handle and permanently isolate LLW is supported by a Radiation Management Plan (RMP) and a Facility Operational Safety Case.
Both documents detail the potential environmental and human health hazards associated with that prescribed activity and, describe control measures to avoid and reduce radiation exposure. The WA Radiological Council, supported by the Radiation Health Unit, is the responsible decision-making authority for the RMP and Operational Safety Case and Site Registration to accept, manage and permanently isolate LLW at Sandy Ridge Facility.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 29
5 LOCATION AND SITING
5.1 Siting and context The Facility is located approximately 75 kilometres (km) north east of Koolyanobbing (Figure 2-1).
5.2 Sensitive premises Based on the current use and zoning of the site, and publicly available information for off-site areas, the potential sensitive premises include:
• Off-site premises; and • On-site premises.
5.2.1 Off-site premises
Sensitive off-site premises include hospitals, schools, day-care facilities and, elderly housing. The nearest sensitive premises matching this criterion are a minimum of 75 km from the Facility (Koolyanobbing shown in Figure 2-1). Due to the remoteness of the Facility, Tellus has identified other off-site premises which have been adopted for hazard assessment applicable to this Application. The distances to these premises are detailed in Table 5-1.
Table 5-1 Off-site premises receptors and distance from site activity boundary
Sensitive off-site premises Distance from prescribed activity Mount Walton Intractable Waste Approximately 7 km to the east of the Facility (Figure 5-1). Disposal Facility (IWDF) Carina Mine Camp Approximately 50 km to the south (Figure 5-1). Ex-Jaurdi pastoral station homestead Approximately 50 km to the south (Figure 5-1).
5.2.2 On-site premises
Sensitive on-site premises adopted for this Application are set within a 5 km radius of the site activity boundary. The nearest sensitive on-site premises matching this criterion are in Figure 5-1 and listed in Table 5-2.
Table 5-2 On-site premises receptors and distance from site activity boundary
Sensitive on-site premises Distance from prescribed activity Mine Infrastructure Area including Between 0 and 100 m administration and warehouse buildings Waste Cell 0 m Facility accommodation village Approximately 2 km to the south west of the Facility (Figure 5-1).
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 30
5.3 Sensitive receptors and specified ecosystems Sensitive receptors and specified ecosystems4 are areas of high conservation value and special significance that may be impacted as a result of prescribed activities resulting in emissions and discharges from the Facility. Sensitive receptors and specified ecosystems pertinent to this Application are listed in Table 5-3. The distances to sensitive receptors and specified ecosystems are shown in Figure 5-1.
Table 5-3 Distance to sensitive receptors and specified ecosystems from the site activity boundary.
Sensitive receptors or ecosystems Distance from prescribed activity Human health On-site workers On-site visitors to the Facility Environmental Mount Manning Range Nature Reserve Approximately 50 km to the north west of the Facility (Figure 5-1). Mount Manning-Helena and Aurora Approximately 60 km to the north west of the Facility (Figure 5-1). Ranges Conservation Park Clear and Muddy Lakes Nature Approximately 60 km to the east of the Facility (Figure 5-1). Reserve Rowles Lagoon Conservation Park Approximately 60 km to the east of the Facility (Figure 5-1). Wallaroo Rock Conservation Park Approximately 60 km to the south-east of the Facility Figure 5-1). Deborah Lake Approximately 75 km to the west of the Facility (Figure 5-1). Biological component - priority flora Several Priority species of Lepidosperma spp Calytrix sp within the Facility Development Envelope. 5.4 Groundwater and water sources There is no developed aquifer within the Facility’s development envelope. Where groundwater has been encountered, it occurs in natural traps in the deepest parts of the basement surface at great distances from the proposed site activity boundary.
Extensive desktop and field research undertaken between 2014 and 2019 indicates there is not any surface recharge of groundwater in the survey area combined with a significant horizon of low permeability in the kaolinite and saprock horizons (Geo9, 2019). The nearest distance to other groundwater and/or water sources is listed in Table 5-4.
There are no natural surface water features within 50 to 75 km of the site activity boundary (refer to Figure 5-1). Once constructed, the Facility will create artificial stormwater retention ponds to drain the mine infrastructure and administration buildings (Figure 5-2).
4 Specified ecosystems are identified in Appendix 1 of DWER’s Environmental Siting guidance note. The only specified ecosystem that applies to the Facility is ecological communities Priority species 1-5.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 31
Table 5-4 Distances to regional groundwater and other water sources from the site activity boundary
Groundwater and water sources Distance from prescribed activity Environmental value Carina borefield Approximately 15 km to the south west of the Hypersaline Facility. groundwater supply Boorabbin paleochannel Approximately 30 km to the east of the Hypersaline Facility. groundwater supply Walleroo paleochannel Approximately 30 km to the east of the Hypersaline Facility. groundwater supply Lake Deborah Approximately 75 km to the south-east of the Salt Lake Facility. Perth to Kalgoorlie water pipeline Approximately 110 km to the south of the Potable water supply Facility. 5.5 Conceptual site model An Operational Site Conceptual Model (CSM) shown in Figure 5-2 was prepared for this Application to illustrate how the natural and built environments at the Facility interact.
More specifically, it was developed as a visual representation of the biological, physical and chemical processes that explain how contaminants move from sources (i.e. the WIP or waste Cell) through local environmental media (i.e. soil, water or air) to environmental receptors or, to off-site or on-site premises such as humans, plants or animals.
Tellus propose to use the CSM an iterative process of characterising and / or recording site contamination at the Facility based on available information and data.
The CSM must be viewed in conjunction with Figure 5-1 to appreciate the scale of the Facility, particularly with respect to distances of off-site premises from the site activity boundary. Figure 5-2 shows:
• Local topography, geology, hydrogeology (or lack thereof), surface drainage and the potential for underground contaminant pathways. • Current land use for the site (unallocated Crown Land). • The location, extent and nature of proposed infrastructure. • Source contaminant areas.
Please note – a Waste Facility Decommissioning Closure Plan is under preparation for the Facility. It will be lodged to the CEO of DWER for Approval in October 2019.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 32 160000 200000 240000 280000 320000
Mount Manning Range Nature Reserve
Mount Manning- Helena and Aurora Sandy Ridge Ranges Conservation Park Facility
6680000 Lake Giles 6680000 (northern Yerilgee Hills) BIF (!(!(! Carina Iron (! Ore Mine Pit
Carina Koolynanobbing Mine Camp Kalgoorlie (! (! (! (! Mount Manning Range Nature Reserve Ex-Jaurdi Shire of Menzies (! Coolgardie Hunt Range BIF Southern Cross (! (!Koora Retreat
Mount Manning- Helena and Aurora Ranges Conservation Park Sandy Ridge Facility Finnerty Range / Mt Dimer /
6640000 Yendilberin Hills BIF (! Facility Mine Infrastructure Area Clear and Muddy Lakes Nature Reserve 6640000 (! Rowles Lagoon Conservation Park Facility Accommodation Camp (! Mt Walton Intractable Waste Disposal Facility
Ex-Jaurdi Pastoral Lease (! Carina Iron Ore Mine Pit Sandy Ridge Access Road Finnerty Range / Mt Dimer / Yendilberin Hills BIF
25 km
IWDF Access Road Lake Deborah
Ex-Jaurdi Pastoral Lease 6600000 6600000
Carina Iron Ore Mine Camp Ex-Jaurdi Pastoral 50 km (! Station Homestead Wallaroo Rock Conservation Park Koolyanobbing (! (! Service Layer Credits: Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, PERTH-KALGOORLIE RAILWAY Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS User Community Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Shireof Yilgarn Shireof Coolgardie
160000 200000 240000 280000 320000 Figure 5-1 Legend Sensitive Premises and Receptors (! Locality Specified ecosystems: Potentially Radius Boundary IWDF access road 10 5 0 10 Km Occuring Priority Ecological in the vicinity of Sandy Ridge (! Sensitive premises Communities 25 km Principal road SANDY RIDGE FACILITY ± Coordinate System: Prescribed Premises Local Government Authority Boundaries 50 km Railways GDA 94 MGA Zone 51 Cat 65 & 66 WORKS APPROVAL Development Envelope DBCA lands Drawn by: RM SP-ID:GL00-2017072102-722 TSR0391_WWAv3_SensitivePremises.mxd Data in this map is sourced from: © Commonwealth of Australia (Geoscience Australia) 2018 and © State of Western Australia (Department of Mines, Industry Regulation and Safety) 2018.
Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either patially or temporally accurate or fit for a particular use. Version: A Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 3/10/2019 SANDY RIDGE FACILITY North-West OPERATIONAL CONCEPTUAL SITE MODEL South-East
Low rainfall High evaporation
250 m Warehouses & Administration Container Yard Security Human Security Receptor Class IV / Class V Fence WIP Water Fence Arid zone Treatment Air Dome sparsely vegetated Stormwater Facility Ponds
10 m Monitoring 20 m 30 m Monitoring Monitoring Bore 40 m Waste Cell Bore Bore SRMB159 50 m Class IV/ Class V SRMB161 SRMB162
No local or regional aquifer system
Yellow clayey sands and laterite gravel (2m thick) Class IV / Class V Waste Drawn: RM Silcrete (3 - 7m thick) Permanent Isolation Approved: RP Figure 5-2 Kaolin (weathered Granite) (15 - 45m thick) Granite (3500m thick) Date: 02.10.2019 NOT TO SCALE
6 MODELLING AND MONITORING DATA
6.1.1 Modelling
Extensive modelling for the Facility was undertaken during the Part IV assessment. This included landform evolution modelling, permeability, hydrology, hydrogeology, infiltration and seepage modelling. Further information can be found in the Sandy Ridge Public Environmental Review (PER) (Tellus, 2016). In April, May and September 2019, further field research and desktop modelling was completed for soils, groundwater and background radiation (respectively). The results of that work are summarised in Section 6.1.2.
6.1.2 Monitoring and environmental baseline data
The information presented in this section compliments and further supports baseline environmental data prepared for the PER.
Geology
Detailed descriptions of site geology are contained within the Facility’s PER (2016) and in Sandy Ridge WAA 2. A summary of ground conditions is provided in Table 6-1.
Table 6-1 Summary of soil and ground conditions
Lithology Description Topsoil (sand) Yellow-brown, sandy topsoil, with some silt and roots, encountered at all test locations, with the exception of IA-TP74, IA-TP77 and IA-TP79, varying between 0.1 m and 0.2 m in thickness Slightly silty sand Medium dense becoming dense with depth, yellow-brown slightly silty sand, underlying the topsoil and from surface at IA-TP74, IA-TP77 and IA-TP79, to depths of between 0.3 m (IA-TP74) and at least 2.0 m (IA-TP77 termination depth). Loose sand was recorded at IA-TP78, between 0.15 m and 0.45 m. Roots varying between 5 mm and 40 mm in diameter were also recorded at IA-TP76, IA-TP78 and IA-TP79, to depths of between 0.3 m and 1.0 m. Slightly silty sand Medium dense becoming dense with depth, yellow-brown slightly silty sand, underlying the topsoil and from surface at IA-TP74, IA-TP77 and IA-TP79, to depths of between 0.3 m (IA-TP74) and at least 2.0 m (IA-TP77 termination depth). Loose sand was recorded at IA-TP78, between 0.15 m and 0.45 m. Roots varying between 5 mm and 40 mm in diameter were also recorded at IA-TP76, IA-TP78 and IA-TP79, to depths of between 0.3 m and 1.0 m Slightly clayey Dense and hard, light brown and light grey-white, slightly clayey sand, clayey sand and sand, clayey sand sandy clay, with some gravel, below the above slightly silty sand at IA-TP72 and the and sandy clay sandy gravel at IA-TP74 and IA-TP77, to a maximum test pit termination depth of 2.0 m Silcrete High strength, yellow brown and brown silcrete, below the above clayey sand at IA- TP74, to a test pit termination depth of 1.3 m. Test pit refusal was experienced into this material when using a 14 tonne excavator, equipped with a 350 mm wide toothed bucket. (Figure 1-5).
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 35
Groundwater The Facility does not occur within a groundwater area proclaimed under the Rights in Water and Irrigation Act 1914. Monitoring for groundwater within the development envelope has been undertaken since 2015. Where groundwater has been encountered it occurs in natural traps in the deepest parts of the basement surface of the weathered granite (kaolin) and unweathered granite.
Figure 6-1 shows historic drill holes and where water was encountered are marked in blue. It also shows previously interpreted basement contours indicating the strong correlation between depth to basement and groundwater occurrence. It confirms the interception of groundwater occurs outside of the proposed mine infrastructure area and proposed Class IV and Class V waste cells.
Geo9 have prepared a draft electroseismic and electrotelluric survey and mapping report for the Facility. The aim of the project is to incorporate the seismoelectric and electrotelluric survey results into the existing geological models from prior drilling programs and the geophysical and geological information.
A survey strategy of three traverses across the Sandy Ridge site was designed to investigate the potential location of any groundwater on the site and identify any potential movement pathways away to the surrounding area. In total, 171 survey points were recorded. Point spacing was 50 m along each of the survey traverses. Survey data has been processed to a depth of 100m.
• Survey line 1 extends for 1500 m and consists of 31 points. • Survey line 2 extends for 2800 m and consists of 57 points, parallel to line 1, located 850m to the south. • Survey line 3 extends for 4 km, perpendicular to the first 2 survey lines. Line 3 was located to pass through the centre of the area where water has been encountered at depth during the prior drilling programs. Survey data was then built into a 3D model alongside the previous drilling data to correlate between the two data sets. Drilling and survey data was initially used to interpret the likely basement depth across the survey lines which was then incorporated into the hydrogeological interpretation. Data traces for Points 117-136 along Line 3 are shown in Figure 6-4. The seismoelectric data shows the relative values of potential hydraulic conductivity. The thickness of the drill tube modulates to give an indication of relative values of permeability (i.e. potential hydraulic conductivity). The wider the data trace the more permeable the subsurface at the point indicated. The data traces are coloured to display the same electroseismic hydraulic conductivity tomography (ESKT) data to aid in distinguishing the data. The ESKT colours are on a pseudocolour spectrum with the lowest values in blue ranging through to the highest values in red. The same logic applies to Figures Figure 6-6 to Figure 6-8. ESKT is an indicative measure of hydraulic conductivity (K in Darcy’s Law), or the ease at which a fluid, water in this case, can flow through a porous medium. The ESKT data measures potential
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 36
hydraulic conductivity as a normalised percentage relative to the highest value found across the site, the maximum being 100%. Figure 6-5 shows a 3D view of the entire model presenting only the ESKT data. Data tubes modulate and are pseudo-coloured to represent the modelled ESKT values. Areas of highest relative ESKT are easily identifiable as wider red/orange tube sections. There are very few areas of high ESKT observed across the site and where they are, they appear isolated with no real horizontal connectivity to suggest any likelihood of potential aquifer development. A summary of results for the three survey lines is provided below. Survey line 1: ESKT values are low across this northern survey line and there is little evidence of any groundwater potential in this part of the site. ESKT results are presented in Figure 6-6. Survey line 2: Is the southernmost of the two northeast-southwest and runs from Point 32 to Point 88 cutting across the middle of the main drilling program for the Facility. ESKT results are presented in Figure 6-7. The area between Points 39 and 44 has the highest ESKT response in the survey area and is potentially a wet area along this survey line. The ESKT response again is seen at, and below the bottom of a basin-like structure in the basement topography and extends to approximately 90m depth, again suggestive of a vertical fracture system. This is the most significant area of elevated ESKT seen on the site but occurs well outside the limits of the mine footprint. Survey line 3: Survey Line 3 confirms what the 2 southwest – northeast survey lines indicated. On the higher ground north of Survey Line 1 (which crosses Line 3 at Point 138) the modelled relative hydraulic conductivity is very low with little evidence of any groundwater potential in this area (refer to Figure 6-8). The electrotelluric interface results show very good correlation with previous site drilling results and provide a valuable insight into the subsurface geology and hydrogeology of the site. There does not appear to be any surface recharge of groundwater in the survey area with a significant horizon of low permeability indicated in the kaolinite and saprock horizons. High ESKT response in the surface overburden is not seen extending through the kaolinite horizon at any point. The granite basement across the site is irregular in nature with several subsurface ridges and basins evident. Where groundwater has been encountered in historical drilling campaigns, it occurs in natural traps in the deepest parts of the basement surface. There does not appear to be any significant ESKT response developed horizontally in the survey orientations, other than within the confines of the basement lows which appear to act as groundwater traps. The areas of elevated ESKT and potential groundwater occur along each survey line in and beneath these modelled basement lows. In most of these basement lows, the ESKT response is seen extending to depth directly beneath the areas of elevated ESKT and may be indicative of near- vertical faulting and/or fracturing. The areas of highest potential permeability appear well below the kaolinite horizons in the solid granite basement. Relative permeability appears in mostly vertical structures, possibly where fracturing has been preserved in the hard rock.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 37
Surface water
The Facility does not occur within a surface water area and irrigation districts proclaimed under the Rights in Water and Irrigation Act 1914.
A desktop review of GEODATA waterbodies (Geoscience Australia, 2019) and multiple field inspections confirmed there are no natural or artificial surface water bodies within the approved Facility development envelope.
Soil and permeability
A search of DWER’s contaminated sites database (2015 and 2019) confirmed the site holds no records of contaminated soils.
Baseline soil sampling over the mining lease area (Figure 6-2) occurred in 2015 and more recently in April and September 2019. Soils were sampled for metals, asbestos and radionuclides. Appendix F includes a summary report on field activities and sampling undertaken in (SoilWater Group, 2019), a spreadsheet with the metals results compared to WA Health Indicator Level (HIL) guidelines. The results indicate that baseline / background levels are below HIL guideline values for metals5. Radon 226 and Caesium 137 recorded elevated background levels against detection limits.
Permeability modelling and testing was undertaken during the PER. The results are explained in Sandy Ridge Works Approval Application Number 2. In summary, plausible permeability values of between 1 x 10-6 m/s (0.08 m/day) and 1 x 10-5 m/s (0.8 m/day), are suggested for the slightly silty sand, sandy gravel and weakly cemented sand. The underlying clayey sand, sandy clay and silcrete should be assumed as impervious for drainage purposes, with presumptive permeability values of less than 1 x 10-7 m/s (0.008 m/day).
Permeability testing was conducted on drill hole samples collected at Sandy Ridge and tested in a NATA approved laboratory. An extract of the permeability results for silcrete taken from bore holes onsite indicated a silcrete permeability of 4.944 x10-8m/s and 5.012 x 10-8 m/s
5 Please note, conservative levels were included in the HIL for methyl mercury rather than total mercury, and chromium VI rather than total chromium.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 38 220000 221000 !! !! ! ! ! ! ! ! Sandy Ridge Facility Prescribed Premises Boundary
! ! ! ! ! ! ! !
! ! !
! ! ! ! ! ! ! ! ! !
! ! ! ! ! ! ! SRMB149 DTW: 22.82 0 0 0 0
0 EOH (m): 22.90 0
(!!!!!8 ! ! ! ! ! ! ! ! 8 3 Water Column (m): 0.08 3 6 6 6 6
! ! ! ! ! ! ! ! (!!
! !! ! ! ! ! ! !! ! ! (!!! !! !! ! !! ! ! SRMB159 DTW: Dry ! ! ! ! EOH (m!): 28.00 !
! ! ! ! ! ! ! ! ! ! !(! ! ! ! ! ! ! SRMB160! ! ! ! ! ! ! ! ! ! ! ! !(!! DTW: Dry EOH (m): 35.50 ! ! ! ! ! ! ! ! ! (!! ! ! ! ! ! ! ! ! ! ! ! !
SRMB161 ! ! ! ! !DTW! : D!ry! ! ! EOH (m): 22.00
Legend ! 0 (! 0 0 0
0 Depth to Granite/Water 0 7 ! ! 7 3 3
6 Contour (m) 6 6 SRMB162 6 <15 DTW: 42.10 15-20 EOH (m): 43.00 20-25 Water Column (m): 0.90 25-30 30-35 35-40 >40
220000 221000 Figure 6-1 Legend Groundwater Bores and 5m Contours ! Drillhole location 0 25 50 75 100 Groundwater Levels Proposed Footprint m (! Monitoring Bore location Coordinate System: Prescribed Premises Boundary SANDY RIDGE FACILITY ± GDA 1994 MGA Zone 51 CAT 65 & 66 WORKS APPROVAL Drawn by: RM SP-ID:GL00-2017072102-719 TSR0389_WWAv3_Gwater_Cells.mxd Data in this map is sourced from © State of Western Australia (Department of Mines, Industry, Regulation and Safety) 2018.
Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Version: C Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 2/10/2019 219000 220000 221000
465 210 ! 201 ! 202 !!!!!!203 204 205 206 207 208 ! 209 !!!
200 ! ! ! ! ! ! ! !!! ! !!!!! 191 192 193 194 195 196 197 198 199 470
6640000 190 6640000 !!! 181 ! 182 !!!!! 183 !!!!!184 185 186 187 188 ! 189 !!!
470 180 ! ! ! ! ! !!! ! ! !!! 171 172 173 174 175 176 ! 177 178 179 475 480 170 ! 161 ! 162 ! 163 !!164 165 !!!166 167 168 ! 169 !!!
470 480
475 160 ! 151 ! 152 ! 153 !!154 155 ! 156 ! 157 ! 158 !!! 159 !!!
470
6639000 475 150 6639000 ! !!! ! ! !!!!! ! ! ! !!! 141 142 143 144 145 146 ! 147 148 149
465 480 140 ! ! ! !! ! !!! ! ! !!! 131 132 133 134 135 136 137 138 139 Mining Area 130 ! 121 460 ! 122 !!!!!!123 124 125 126 127 128 ! 129 !!! 480
120 ! 111 ! 112 ! 113 !!!!! 114 !!!!115 116 117 118 ! 119 !!!
6638000 110 6638000 !!!!!!! !!!!! 100 ! 101 !!! 102 !!103 104 ! 105 106 ! 107 !!108 109 !!!
99 !!!86 87 88 ! 89 !!!!!!!!!90 ! 91 ! 92 ! 93 !!!!!!!!!!!!!!! 94 !!!!95 96 97 98 !
85 !!!!!72 73 74 75 76 ! 77 ! 78 !!! 79 !!! 80 !81 !!!!!82 !83 ! 84 !
71 ! 58 !59 !!!!! 60 ! 61 !!62 63 ! 64 ! 65 ! 66 ! 67 ! 68 ! 69 !!! 70 ! 6637000 6637000 ! 46 !!47 48 ! 49 !!! 50 ! 51 ! 52 !53 !54 !!!55 !56 !!! 57
! 34 !!35 36 !!! 37 ! 38 ! 39 !!! 40 ! 41 ! 42 !43 !44 !!! 45
! 23 ! 24 ! 25 !!26 27 ! 28 ! 29 !!! 30 ! 31 !!32 33
22 !!!!! 12 ! 13 ! 14 ! 15 !!!16 17 18 ! 19 !!!20 ! 21 !
6636000 11 6636000 !!!!! ! ! ! !!!!! !!! ! 1 2 3460 4 5 6 7 8 9 10
219000 220000 221000
Legend Figure 6-2 ! Soil Sampling Location 5m Contours Soil Sampling Locations 0 100 200 300 400 Proposed infrastructure design m Proposed infrastructure footprint Coordinate System: SANDY RIDGE FACILITY ± GDA 1994 MGA Zone 51 Proposed Mining Area Cat 65 & 66 WORKS APPROVAL Drawn by: DS Prescribed Premises Boundary SP-ID:GL00-2017072102-712 TSR0386_WWAv3_SoilSampling.mxd Data in this map is sourced from © State of Western Australia (Department of Mines, Industry, Regulation and Safety) 2018.
Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Version: A Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 3/10/2019 219000 220000 221000
6640000 Line 3 6640000 6639000 6639000
Line 1 Mining Area 6638000 6638000
Line 2 6637000 6637000 6636000 6636000
219000 220000 221000 Figure 6-3 Legend Electroseismic/Electrotelluric 5m Contours Electroseismic and Electrotelluric 0 100 200 300 400 survey line Aquifer Mapping Survey m Prescribed Premises Boundary Proposed infrastructure design Coordinate System: SANDY RIDGE FACILITY ± GDA 1994 MGA Zone 51 Proposed infrastructure footprint Cat 65 & 66 WORKS APPROVAL Drawn by: RM Proposed Mining Area SP-ID:GL00-2017072102-723 TSR0392_WWAv3_ElectroseismicSurvey.mxd Data in this map is sourced from © State of Western Australia (Department of Mines, Industry, Regulation and Safety) 2018.
Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Version: A Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 3/10/2019
Figure 6-4 Data trace points for survey line 3 showing relative values of potential hydraulic conductivity
Figure 6-5 3D model showing ESKT vales across the Sandy Ridge site looking north
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 42
Figure 6-6 ESKT result for survey line 1 at Sandy Ridge and interpreted basement level indicated in dark blue
Figure 6-7 ESKT result for survey line 3 at Sandy Ridge
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 43
Figure 6-8 ESKT result for survey line 3 at Sandy Ridge
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 44
7 RISK ASSESSMENT
This section identifies the hazards and risk associated with potential emissions and discharges and the proposed environmental monitoring at the Facility to verify the robustness of infrastructure design and operational controls.
A detailed risk assessment for determining the likelihood and consequence of the prescribed activities associated with storing solid, liquid and LLW waste was included in Appendix 3 of Sandy Ridge Works Approval Application No.2 (document reference SR00-299429885-22573). As the management of LLW is regulated under the RS Act, the risk assessment is not addressed here.
7.1 Determination of emission, pathway and receptor
7.1.1 Overview
In undertaking its risk assessment for this application, Tellus has given consideration to DWER’s guidance statement Environmental Siting (November, 2016) and Risk Assessments – Part V, Division 3, Environmental Protection Act 1986 (February 2017).
Tellus has identified potential emissions pathways and potential receptors to establish whether there is a hazard or Risk Event which requires detailed risk assessment. To establish a Risk Event there must be an emission or a receptor which may be exposed to that emission through an identified actual or likely pathway, and a potential adverse effect to the receptor from exposure to that emission.
Where there is no actual or likely pathway and/or no receptor, the emission will be screened out and will not be considered as a Risk Event.
In addition, where an emission has an actual or likely pathway and a receptor which may be adversely impacted, but that emission is regulated through other mechanisms such as Part IV of the EP Act, that emission will not be risk assessed further and will be screened out through the risk assessment process. Table 7-4 presents risk events associated with construction activities.
7.1.2 Emissions and pollutant sources
The Public Environmental Review (Tellus 2016) for the Facility identified several potential emissions and sources across the site. The following have been included in this Application as they are considered the most likely sources of emissions and pollutants:
• Potential leakage from stored wastes.
• Potential leakage from the WIP.
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7.1.3 Pathways
The potential pathways for the migration of the impacts in both soil and groundwater detected at the site include:
• Vertical seepage originating from surface spills and leaks, and from primary sources such as tanks, lines and pumps, through the surface material into the underlying natural material (red and yellow sands).
• Vertical leaching of stored liquid wastes. • Horizontal leaching of isolated wastes.
• Dermal contact and incidental ingestion with hydrocarbons or NORM in shallow soil. • Lateral migration of surface discharge to offsite native vegetation.
• Migration of vapours from hazardous wastes stored on site.
• Migration of vapours by volatilisation from contaminated surface water contained within the stormwater retention ponds.
7.1.4 Receptors
Refer to Section 5.2 and 5.3.
7.1.5 Exposure pathway assessment
For potential exposure to be present, a source-pathway-receptor (SPR) linkage must be identified. Once identified, the likelihood of this SPR linkage causing an unacceptable risk to human health or the environment has been quantified through a risk assessment (i.e. the PER). A qualitative assessment of SPR linkages is presented in the following tables and a visual representation of the preliminary CSM is shown in Figure 5-2.
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7.1 Consequence likelihood and treatment of risk events Risk ratings were determined for risk events in accordance with Risk Assessments – Part V, Division 3, Environmental Protection Act 1986 (February 2017) as shown in the risk rating matrix in Table 7-1
Table 7-1 Risk rating matrix
Consequence
Slight Minor Moderate Major Severe
Almost Certain Medium High High Extreme Extreme
Likely Medium Medium High High Extreme
Possible Low Medium Medium High High Likelihood
Unlikely Low Low Medium Medium High
Rare Low Low Low Medium High
Tellus undertook an assessment of the consequence and likelihood of the Risk Events in accordance with Table 7-2.
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Table 7-2 Risk criteria table
Likelihood Consequence The following criteria has been used to The following criteria has been used to determine the consequences of a Risk Event occurring determine the likelihood of the Risk Environment Public health 6 and amenity (such as air and Event occurring water quality, noise and odour). Almost The risk event is expected Severe • onsite impacts: catastrophic. • Loss of life. certain to occur in most circumstances. • offsite impacts local scale: high level or above. • Adverse health effects: high level or ongoing medical treatment. • offsite impacts wider scale: mid-level or above. • Specific Consequence Criteria (for public • Mid to long-term or permanent impact to an area health) are significantly exceeded. of high conservation value or special significance 7. • Local scale impacts: permanent loss of amenity. • Specific Consequence Criteria (for environment) are significantly exceeded.
Likely The risk event will probably Major • onsite impacts: high level. • Adverse health effects: mid-level or occur in most frequent medical treatment.
circumstances. • offsite impacts local scale: mid-level. • Specific Consequence Criteria (for public • offsite impacts wider scale: low level. health) are exceeded. • Short-term impact to an area of high conservation • Local scale impacts: high level impact to value or special significance. amenity. • Specific Consequence Criteria (for environment) are exceeded.
Possible The risk event could occur Moderate • onsite impacts: mid-level. • Adverse health effects: low level or at some time. occasional medical treatment. • offsite impacts local scale: low level.
6 In applying public health criteria, DWER may have regard to the Department of Health’s Health Risk Assessment (Scoping) Guidelines. 7 Determination of areas of high conservation value or special significance should be informed by the Guidance Statement: Environmental Siting.
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• offsite impacts wider scale: minimal. • Specific Consequence Criteria (for public health) are at risk of not being met. • Specific Consequence Criteria (for environment) are at risk of not being met. • Local scale impacts: mid-level impact to amenity.
No risk events during the construction phase were deemed to warrant detailed risk assessment under the EP Act (see Table 7-4).
Three risk events during operation phase were deemed to warrant detailed risk assessment under Part V of the EP Act (see Table 7-5. These are presented in Section 7.4, Section 7.5 and Section 7.6.
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7.2 Acceptability and treatment of Risk Event DWER will determine the acceptability and treatment of Risk Events in accordance with the Risk treatment listed in Table 7-3.
Table 7-3 Risk treatment table.
Rating of Risk Event Acceptability Treatment Extreme Unacceptable Risk Event will not be tolerated. DWER may refuse application. High May be acceptable. Subject to Risk Event may be tolerated and may be subject to multiple regulatory controls. multiple regulatory controls. This may include both outcome-based and management conditions. Medium Acceptable, generally subject to Risk Event is tolerable and is likely to be subject to regulatory controls. some regulatory controls. A preference for outcome- based conditions where practical and appropriate will be applied. Low Acceptable, generally not Risk Event is acceptable and will generally not be controlled. subject to regulatory controls.
7.3 Potential discharges – storage of waste The Facility is in a remote area within the Goldfields region (Figure 2-1). The Facility is not accessible by public roads and is not open to public access.
No local or regional groundwater aquifer has been identified, removing the possibility of groundwater contamination and ingesting contaminated groundwater.
The nearest surface waterway is greater than 50 km from the Facility (Figure 5-1) and, Tellus considers that there is no off-site premises risk to public health caused by the proposed activities
Potential environmental discharges and their subsequent risk to the environment have been identified in this Section. Proposed controls for identified hazards and risks are described in Section 8.
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Table 7-4 Environmental Risk Events – construction emissions, pathways and receptors
Risk Events Proceed to Justification detailed risk assessment? Source / activities Potential Potential Potential Potential emissions receptors pathway adverse impact Mining/Cells Area Clearing of native Unauthorised Native vegetation Clearing Reduced N/A Assessed and approved under Part IV of vegetation to develop clearing vegetation biodiversity the EP Act (refer MS 1078). Cells. Earthworks to develop Noise • IWDF. Air/wind Reduced No No sensitive receptors likely to be Cells. • Carina Mine dispersion amenity impacted. Local scale impacts: low level impact to amenity. Dust Camp. No • Carina Mine Camp is in care and maintenance, with a part-time care- taker in attendance. • The IWDF is operated on a campaign-basis, last campaign was in 2008. Mining is regulated by Department of Mines, Industry Regulation and Safety under the Mining Act 1978. Infrastructure Area Clearing of native Unauthorised Native vegetation Clearing Reduced N/A Assessed and approved under Part IV of vegetation to develop clearing vegetation biodiversity the EP Act (refer MS 1078). infrastructure area. Earthworks to develop Noise • IWDF. Air/wind Reduced No No sensitive receptors likely to be infrastructure area. • Carina Mine dispersion amenity impacted. Local scale impacts: low level Camp. impact to amenity. Dust No
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Risk Events Proceed to Justification detailed risk assessment? • Carina Mine Camp is in care and maintenance, with a part-time care- taker in attendance. • The IWDF is operated on a campaign-basis, last campaign was in 2008.
Fuel for construction Hydrocarbon Soils and Direct Soil No • Extensive groundwater contained with an above spills vegetation discharge Contamination investigations have been carried out by Tellus, and no aquifer has been ground self-bunded fuel Waste (treated Seepage and vegetation identified. A layer of 2-3m of low- tank and untreated) health impacts. permeability clayey sand overlies a 3m thick layer of a extremely low permeability silcrete material. Contamination of soil 2-3m below ground level is unlikely. In the event of a spill the affected area would be excavated to recover contaminated material for disposal. • Storage in accordance with the Dangerous Goods Safety Act 2004: Dangerous Goods Licence, DGSO22452.
Groundwater n/a n/a No There is not considered to be a pathway to groundwater.
Surface Water n/a n/a No There is not considered to be a pathway for overland flow of surface water.
Installation and Odour IWDF Air/wind Health and No • The IWDF is operated on a campaign-basis, last campaign was commissioning of waste Carina Mine dispersion amenity in 2008. immobilisation plant. Camp
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Risk Events Proceed to Justification detailed risk assessment? • Carina Mine Camp is in care and maintenance, with a part-time care- taker in attendance. • Risk Event is acceptable and will generally not be subject to regulatory controls.
Waste (treated Groundwater n/a n/a No There is not considered to be a pathway and untreated) to groundwater. Surface Water n/a n/a No There is not considered to be a pathway for overland flow of surface water.
Stormwater drainage Contaminated Soils and Overland Soil No • W6243 considered the controls management stormwater vegetation flow. Contamination proposed for stormwater management and ponds at the Seepage and vegetation Premises. from health impacts. retention • There are limited opportunities for ponds. stormwater contamination during Overtopping construction. of ponds • There is not considered to be a pathway for overland flow of surface water. • Management of "Early Wastes" accepted for storage in East Yard during construction are the subject of Sandy Ridge Works Approval Application No.2 (our document reference SR00-299429885-22573).
Groundwater n/a n/a No There is not considered to be a pathway to groundwater.
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Risk Events Proceed to Justification detailed risk assessment? Surface n/a n/a No There is not considered to be a pathway Water for overland flow of surface water.
Table 7-5 Environmental Risk Events – operations emissions, pathways and receptors
Risk Events Proceed to Justification detailed risk assessment? Source / activities Potential emissions Potential receptors Potential Potential pathway adverse impact Mining/Cells Area Clearing of native Unauthorised clearing Native vegetation Clearing Reduced N/A • Assessed and approved under Part vegetation to develop vegetation biodiversity IV of the EP Act 1986 (refer MS Cells. 1078). • Maximum of 202.3 ha approved for clearing of mine pits/waste cells. • Implementation of approved Flora and Vegetation Management Plan as required by Condition 10-6 of MS 1078. Earthworks to Noise • IWDF. Air/wind Reduced No • No sensitive receptors likely to be impacted. Local scale impacts: low develop Cells. • Carina Mine dispersion amenity level impact to amenity. Dust Camp. No • Carina Mine Camp is in care and maintenance, with a part-time care- taker in attendance.
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Risk Events Proceed to Justification detailed risk assessment? • The IWDF is operated on a campaign-basis, last campaign was in 2008. • Mining is regulated by Department of Mines, Industry Regulation and Safety under the Mining Act 1978.
Isolation of Class IV Leachate generation Soils Water ingress Contamination No • Assessed and approved under Part and Class V waste from within cell to cell of soil. IV of the Environmental Protection materials including generating Act 1986 (refer MS 1078) and will be LLW in cells leachate. managed via implementation of the Leachate Monitoring and Groundwater n/a n/a No Management Plan required by condition 9 of MS 1078. • Also managed via a Deep Groundwater Monitoring and Management Plan required by condition 2 of EPBC Act approval 2015/7478. • There is not considered to be a pathway to groundwater or a pathway for overland flow.
External Gamma Humans and Air Radiation Yes • Potential adverse impacts on human radiation exposure biodiversity exposure / health and biodiversity associated sickness. with radiation exposure for the Facility are being assessed by the Reduced WA Radiation Health Unit and biodiversity. Radiological Council under the RS Act and therefore not presented here.
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Risk Events Proceed to Justification detailed risk assessment? Infrastructure Area Unloading, loading Noise IWDF and Carina Air/wind Reduced No No sensitive receptors likely to be and storage of wastes Mine Camp dispersion amenity impacted. Local scale impacts: low level Dust above-ground. impact to amenity. Operating above- • The IWDF is operated on a ground equipment campaign-basis, last campaign was Vehicle movements in 2008. • Carina Mine Camp is 50 km south of the Facility. Furthermore, it is under care and maintenance, with a part- time care-taker in attendance.
No • Refuelling facilities are designed in accordance with AS 1940 and will be managed as per standard industry Direct Contamination practices. discharge, of soil. Fuel storage and Subsurface soils. Hydrocarbon spills contaminated Impacts to • Storage is managed under the refuelling Native vegetation. stormwater native Dangerous Goods Safety Act 2004. discharge. vegetation. The Facility has an approved Dangerous Goods Licence, DGSO22452.
Above-ground Waste (untreated and Soil underlying Infiltration Soil Yes In the event of failure of controls, there storage of Class IV treated) storage areas contamination may be impacts to soils and vegetation and Class V wastes through adjacent to the infrastructure area. release of chemicals. Vegetation to Direct Impact to perimeter of discharge due vegetation infrastructure area to extreme health if rainfall event inundated with
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Risk Events Proceed to Justification detailed risk assessment? contaminated water. Groundwater n/a n/a No There is not considered to be a pathway to groundwater.
Surface Water n/a n/a No There is not considered to be a pathway for overland flow of surface water.
Contaminated Soils. Seepage from Soil Yes In the event of failure of controls, there may be impacts to onsite soils and stormwater Native vegetation. ponds or from contamination, LLW reduced vegetation. Radioactive vegetation Note flora and vegetation is to be (and sludge) health managed in accordance with the Waste Area. approved Flora and Vegetation Overtopping Management Plan required by condition of ponds or 10 of MS 1078. overflow from LLW Radioactive (and sludge) Waste Area. Operating waste Odour IWDF 5 km to east Air/wind Human health No • The IWDF is operated on a campaign-basis, last campaign was immobilisation plant Caretaker at Carina dispersion. and amenity in 2008. Mine Camp 50 km to south. • Carina Mine Camp is in care and maintenance, with a part-time care- taker in attendance. • Risk Event is acceptable and will generally not be subject to regulatory controls.
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Risk Events Proceed to Justification detailed risk assessment?
Waste (untreated and Soils. Direct Contamination Yes In the event of failure of controls, there may be impacts to onsite soils and treated) Native vegetation. discharge. of soil. vegetation. Contaminated Impacts to stormwater native flow. vegetation. Groundwater n/a n/a No As shown in Figure 5-2, the Facility lacks a credible pathway to groundwater.
Surface Water n/a n/a No As shown in Figure 5-2, the Facility lacks a credible pathway for overland flow of surface water.
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7.4 Risk assessment - Above-ground storage of Class IV and Class V wastes impacting on soil and vegetation
7.4.1 Description of above-ground storage of Class IV and Class V wastes impacting on soil and biodiversity.
Class IV and Class V wastes proposed to be accepted are deemed intractable due to their chemical and/or physical characteristics. A waste spill or leak may adversely impact local soils and biodiversity if there were no controls in place.
7.4.2 Identification and general characterisation of emission
The WAC presented in Appendix G, is used to determine the acceptability of waste at the Facility. If an emission were to occur, it would likely have characteristics of one or more of these Class V wastes.
7.4.3 Description of potential adverse impact of emission
Chemical discharges may result in localised impacts to soil contamination and indirectly lead to impacts on vegetation health. A release of contaminated soils, including NORM contaminated soils, may result in localised soil contamination only.
7.4.4 Applicant controls
The location of the Facility was selected based on the climatic and geological characteristics that make the site suitable for containing intractable wastes, consistent with the Basel Convention concerning chemical waste disposal and the requirements of the Code of Practice for the near- surface disposal of radioactive waste in Australia (NHMRC, 1992). Those same site characteristics that make the site suitable for a near surface geological repository also make the site suitable for above-ground storage of wastes awaiting disposal.
Waste acceptance is governed by a strict WAC, with only solid wastes (once treated/immobilised) to be disposed in Cells.
Wastes will be stored in their primary waste packages in appropriate freight containers within dedicated waste zoning groups as per the Dangerous Goods Safety (Storage and Handling of Non- Explosives) Regulations 2007 in accordance with Dangerous Goods Licence DGS022452, where applicable.
Pavement types and civil earthworks have been designed to provide appropriate drainage management for the different storage areas within the infrastructure area (i.e. Radioactive (and sludge/liquid) Waste Facility, Mixed Store and East Yard). See also Section 7.5.
Wastes stored in containers will only be removed and managed in concrete bunded, covered facilities.
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Vehicular traffic will be excluded from waste storage areas by bunding, fencing and/or signage, procedures and training. The only vehicle authorised in waste storage areas will be the reach stacker.
• The Mixed Store will be constructed with Pavement Type A.
• Stormwater from the Mixed Store will drain to the HDPE-lined Stormwater Retention Pond in the west of the Infrastructure Area. The sump has been designed to contain a 100 ARI 72- hour storm event.
• All solid chemical waste will be stored in a primary storage package (e.g. steel drum, bulka- bag) within a sea container.
• All storage packages will have clear readable chemical labels. • Sea containers will be stacked and segregated as per storage requirements (below) for the East Yard area of the Sandy Ridge Goods license DGS022452 (Appendix H).
• Sea containers will remain closed unless they need to be opened to prevent or mitigate a discharge of waste to the environment. • Stormwater from the East Yard will be drained to a sump north-west of the infrastructure area. The sump has been designed to contain a 100 ARI 72-hour storm event and will be lined with clay during operations. • All solid chemical waste will be stored in a primary storage package (e.g. steel drum, bulka- bag) within a sea container. • All storage packages will have clear readable chemical labels. • Sea containers will be stacked and segregated as per storage requirements (below) for the East Yard area of the Sandy Ridge Goods license DGS022452 (Appendix D). • Sea containers will remain closed while in storage areas, unless they need to be opened to prevent or mitigate a discharge of waste to the environment.
7.4.5 Consequence
If a waste spill or leak occurred and seeped or flowed to soil and vegetation, the potential impact to the receiving environment is considered by Tellus to be slight: restricted to minimal impacts on a local scale. Contaminated material would be recovered and disposed in a waste cell.
7.4.6 Likelihood
The likelihood of an uncontrolled discharge from waste storage areas would be dependent on a civil engineering design failure, transport packaging failure and procedural controls failing at the same time coinciding with a storm event.
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Based on the above reasoning Tellus considers that the likelihood of an uncontrolled discharge of waste to soil or vegetation from the above-ground waste storage areas is unlikely (soil) or rare (vegetation).
7.4.7 Overall rating of above-ground storage of Class IV and Class V wastes
The overall risk rating is low.
7.5 Risk assessment – Contaminated stormwater impacting on soil and vegetation
7.5.1 Description of contaminated stormwater impacting soil and vegetation
If a waste spill or leak occurred in waste handling areas (refer to Section ) and the material was washed by stormwater into the on-site Stormwater Retention Pond or was discharged from the sludge/liquid waste handling area, it may either seep into the underlying soil or overtop to soil and vegetation.
7.5.2 Identification and general characterisation of emission
The Waste Acceptance Criteria (WAC, presented in Appendix G) is used to determine the acceptability of wastes at the Facility.
7.5.3 Description of potential adverse impact of emission
Uncontrolled chemical discharges may result in localised impacts to soil and indirectly to impacts on vegetation health in the surrounding area. A release of NORM sludge or soils may result in adverse soil impacts at a local scale.
7.5.4 Applicant controls
The Facility site selection criteria included compliance with hydrogeological site characteristics of Basel Convention Technical Guidelines on Specially Engineered Landfill, namely avoiding sites with drinking water sources, flood-prone regions and separation distance above water table. Sandy Ridge is in an arid region with approximately 250 mm rainfall per year, lacks the presence of a local or regional groundwater aquifer and, is in an arid zone with no history of flooding.
The on-site Stormwater Retention Pond has been designed to contain a 100-year ARI, 72 hour storm event. It is lined with a High Density Polyethylene (HDPE) liner. If the pond reaches capacity and overtops, it has been designed to overflow into the Raw Water Pond located immediately adjacent, which is also HDPE-lined.
“Clean” stormwater upslope of the Infrastructure Area will be diverted away from the Infrastructure Area by a flood levee to the east. In addition, storage yards have been graded to ensure that runoff from clean areas does not enter the catchment and unnecessarily increase the amount of water captured in the ponds.
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Stormwater collected in the Stormwater Retention Pond (and Raw Water Pond if there has been overflow into it) will be sampled for contaminants prior to use on-site (see Section 8). If results indicate concentrations of contaminates greater than site trigger levels, water will be used in waste cells (e.g. for compaction).
Waste inspection areas have been designed with roofs to exclude rainwater and sealed concrete floors i.e. areas where wastes are opened, inspected and handled.
Stormwater management is self-contained within the Radioactive Waste Area (i.e. it does not flow to the Stormwater Retention Pond), draining to blind concrete sumps or a sump in the Liquid Waste Unloading area. Drainage catchment in this area is designed to contain the largest volume waste container expected (e.g. an ISO container).
The Radioactive Waste Area’s storage yard is a block-paved yard that also drains to concrete, blind sumps from which spills can be recovered.
Spills will be recovered and treated in the WIP for disposal in a Cell.
7.5.5 Consequence
If contaminated stormwater was discharged to soil and vegetation, the impact is considered slight: restricted to minimal impacts on a local scale. Contaminated material can be recovered and disposed in a waste cell.
7.5.6 Likelihood
A discharge of contaminated stormwater from the LLW Radioactive Waste Area, Stormwater Retention Pond or Raw Water Pond would rely firstly on contamination through transport packaging failure and procedural controls failing coinciding with a storm event. Secondly, the stormwater containment would need to fail through:
1. Under estimate the capacity of the LLW Radioactive Waste Area’s WIP Waste Bund. 2. Under estimate the storm event, i.e. a larger than 1 in 100-year, 72 hour event. 3. Failure of the HDPE liner in the Stormwater Retention Pond or Raw Water Pond causing seepage to ground; or 4. Failure of the pond wall(s) releasing water to soil and vegetation.
Based on the above reasoning Tellus considers that the likelihood of an uncontrolled discharge of contaminated stormwater to soil or vegetation from the Stormwater Retention Pond is unlikely.
7.5.7 Overall rating for stormwater management
The overall risk rating is low.
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7.6 Risk assessment – WIP waste impacting on soil and vegetation
7.6.1 Description of WIP seepage or loss of containment on land or soils
An uncontrolled release of waste from the WIP, either untreated liquid/sludge or treated spade-able product, may result in impacts to soil and vegetation health.
7.6.2 Identification and general characterisation of emission
The WAC, presented in Appendix G, is used to determine the acceptability of wastes at the Facility. If an emission were to occur, it would likely have the characteristics of a Class IV or Class V waste.
7.6.3 Description of potential adverse impact of emission
Waste (either treated or untreated) discharges may result in localised impacts to soil and indirectly impacts on vegetation health. A release of NORM may result in localised soil impacts.
7.6.4 Applicant controls
Above ground piping that dispenses liquid/sludge waste from the WIP Waste Bund is under low pressure and located within a concrete bund. Concrete bunding has blind concrete sumps to contain spills. The dispensing pump(s) are to be fitted with emergency stop buttons which, in the event of a spill or leak, will avoid/minimise the volume of material spilt.
The planetary mixer is an enclosed machine, limiting the opportunity for spills. It will be installed within a concrete bund with capacity for a 1:100 ARI 72-hour event, with a blind sump to contain spills. The planetary mixer is designed with an underside discharge point which will direct the spade- able mix directly into a sealed, half-height container. The half-height container will have a closable lid to further reduce the chance of emissions.
The WIP will be manned at all times when in operation.
The technical specifications of the WIP are listed in Section 3.3.1.
7.6.5 Consequence
If material was discharged to soil and vegetation from the WIP, the impact to the receiving environment is considered slight: restricted to minimal impacts on a local scale. Contaminated material can be recovered and disposed in a waste cell.
7.6.6 Likelihood
The likelihood of an uncontrolled discharge from the WIP impacting the environment would be dependent on a failure in the design and/or construction of the bunding, piping or the planetary mixer itself. In addition, the spilt material would then have to seep or flow overland to discharge to soil or vegetation.
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Based on the above reasoning Tellus considers that the likelihood of an uncontrolled discharge of waste to soil or vegetation from the WIP is unlikely (soil) or rare (vegetation).
7.6.7 Overall rating of WIP seepage and loss of containment on land and soils
The overall risk rating is low.
7.7 Summary of acceptability and treatment of Risk Events A summary of the risk assessment and the acceptability of the risk events presented in Section 7 are presented in Table 7-6 below. Additional general site controls are listed in Section 8. Due to the designed, engineered controls, the natural geology and hydrogeology of the site and proposed procedural controls, no risk events are considered unacceptable.
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Table 7-6 Risk Assessment Summary - Operations.
Risk Events Controls Consequence* Likelihood* Risk Reasoning Sources/Activities Potential Potential receptors Potential Potential adverse impacts emissions pathway Mixed store Storage of Class waste Soil adjacent to and Infiltration soil contamination Site selection - arid, dry Slight Unlikely Low Vegetation adjacent to the operation IV and Class V (untreated and beneath the Mixed through release of climate. Mixed Store is well wastes treated) Store chemicals. Wastes will be stored in represented locally and Impact to vegetation locked sea-containers. regionally. The closest health if inundated with Stormwater management conservation-significant contaminated water. with capacity for a 100 flora species is year ARI, 72-hour storm approximately 700m to event. the south of the Mixed Engineered paving. Store. The potential Vehicular traffic excluded consequence is therefore Vegetation contaminated Impact to vegetation from waste storage areas. Slight Rare Low slight, and localised. stormwater health if inundated with discharge contaminated water.
Stormwater Contaminated Soils. Seepage from Soil contamination, Flood levee to divert Slight Unlikely Low No sensitive receptors drainage stormwater Native vegetation. ponds reduced vegetation health "clean" stormwater away likely to be impacted. management from the Infrastructure Area. Stormwater management with capacity to contain 1- in-100 ARI 72-hour storm Overtopping of Slight Unlikely Low event. ponds Stormwater retention pond, raw water pond and brine pond will be HDPE- lined. Maintain freeboard on ponds at all times.
Stormwater sampled for contaminants prior to use for dust supression. If contaminated, water will be used in waste cells. Inspection and treatement of waste conducted in concrete bunded areas. Liquid Waste and Stormwater Contaminated Soils. Seepage from Soil contamination, Roof and concrete floors Slight Unlikely Low No sensitive receptors Radioactive Waste drainage stormwater Native vegetation. active waste reduced vegetation health in waste inspection bays likely to be impacted. Area management areas where wastes are opened, inspected and handled. Drainage is self-contained within the Area. Spills will be recovered an
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Risk Events Controls Consequence* Likelihood* Risk Reasoning Overland flow treated in the WIP for Slight Unlikely Low disposal in a Cell. Wastes stored inside transport packaging on engineered-paving yard, drain to concrete, blind sumps.
Operating waste Operating waste (treated native vegetation and direct discharge soil contamination, WIP is an enclosed Slight Unlikely Low No sensitive receptors immobilisation waste and untreated) soils reduced vegetation health machine, in concrete bund likely to be impacted. plant immobilisation designed for 100 year ARI plant 72-hour event, with trafficable kerb and blind sumps to capture spills. Dispensing pump is low- pressure/low flow rate. Piping from WIP waste bund to WIP is bunded and will be manned at all times during operation. Piping and WIP will be fitted with emergency off function to cease operation in the event of a spill. Discharge from the WIP is to sealed shipping containers with lids, for direct placement in waste cell.
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8 CONTROLS
8.1 General controls The following general controls will be implemented to control the event risks identified in Section 7:
• Elimination o The nearest surface water course is located greater than 50 km from the Facility. o No ground water aquifer beneath Sandy Ridge site. o Silcrete layer two metres below ground level has very low permeability. o Waste accepted will not be flammable or combustible. o No underground storage tanks on-site for liquid waste.
• Engineering Controls o Flood levee to divert clean stormwater away from Infrastructure Area. o Stormwater management with capacity for a 1 in 100 ARI 72-hour event. o Waste will be contained in appropriate primary packaging that meets Tellus’ WAC and Chain of Custody requirements. o Storage containers/tanks, piping, handling areas, delivery areas and process tanks located within secondary containment areas. o Storage containers and secondary containment materials will be impermeable to the substance being stored and will not react with the substance being stored. o Primary packages loaded into a sea container and sea containers onsite is kept locked and closed. o Firebreak will be installed on site perimeter of Sandy Ridge. o Fire truck and site Emergency Service Officer onsite to provide asset protection during fire event. o Water cart available to provide extra water for fire fighting efforts.
• Administrative Controls o Inspection of waste packages upon arrival at the Facility. o Sea containers inspected for structural integrity prior to acceptance onsite. o Separation distances will facilitate incompatible chemicals not coming into contact during spills, leaks or fires. o Testing of containment ponds before use of water on-site. o Spill kits containing absorbent material appropriate to the type of substance being used on-site.
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o Recovery drums/containers compatible with the substances which may be put in them. o Implementation of Emergency Response Management Plans and Procedures. o Documented daily inspection of waste storage areas. o Monitoring of environmental parameters as shown in Figure 8-1. Proposed monitoring schedule is presented in Table 8-1.
Table 8-1 Proposed environmental monitoring.
Monitoring Parameter Target Proposed Duration Location(s) Monitoring Frequency Village. WWTP effluent (refer Quarterly spot samples in accordance with W6243/2019/1. to W6243/2019/1) WWTP Irrigation Vegetation health, Quarterly in accordance with W6243/2019/1 and approved Area. ponding, weeds. Flora and Vegetation Management Plan. Putrescible landfill. Waste disposed. < 500 tonnes Monthly To year 26 per year Annually
Litter Weekly Retention Pond. Stormwater prior to Grab sample after rainfall event To year 26 discharge anywhere resulting in water in Retention Pond other than Cells Area. (refer to W6243/2019/1). Raw Water Pond. Raw water if Grab sample (refer to To year 26 Retention Pond W6243/2019/1). overflows and prior to discharge anywhere other than Cells Area Future (subject to Phase 2 and Phase 3 works approvals) Infrastructure Area Tonnes of waste 100,000 tpa Upon To year 26 accepted acceptance, reported annually Front gate Radioactivity of Background Every delivery Active project life deliveries unless vehicle (to year 26) authorised Cell caps Subsidence <1.2 m Annual To year 10* (surveyed) subsidence at highest point of the arc of cell cap Cell caps Subsidence No differential Monthly To year 26 (visual assessment) settlement. Cell caps Cap integrity No vegetation Monthly To year 10* each (visual assessment) >0.5m high, no cell erosion (gullying) >0.20m deep, no fauna burrows >0.20m deep
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Monitoring Parameter Target Proposed Duration Location(s) Monitoring Frequency Cell caps Cap integrity No vegetation Annual After cell (visual assessment) >3.0m high, no rehabilitation* to erosion year 46 (gullying) >0.40m Cell caps (Cells 1 to Moisture at base of <= Cymod8 continuous TBA – probe life 3, 2 per cell) upper clay cap estimate monitoring, dependent monthly data (estimate up to 10 Moisture at base of <= Cymod continuous years) silcrete/laterite estimate monitoring, monthly data Moisture at base of <= Cymod continuous lower clay layer estimate monitoring, monthly data Cell monitoring Moisture Zero free-water quarterly To year 26 bores Full suite of within 5m of the annually Years 26 to 46 contaminants (if deepest waste water present) (baseline) Village Air Quality – dust <=10% above Continuous To year 26 WIP deposition and control monitoring, Control contaminants monthly samples 8.2 Storage, handling and permeant isolation of LLW Controls for the storage, handling and permanent isolation of LLW will be assessed and regulated under the RS Act (refer to Section 1 and Section 4.5).
8.3 Waste isolation in near-surface geological repository As outlined in Section 2 the assessment of the proposal to develop the Sandy Ridge Facility under Part IV of the EP Act considered the sites suitability for an intractable waste disposal facility and potential adverse impacts on inland waters and terrestrial environmental quality. This Application does not seek to duplicate that assessment and respectfully directs the reader to Section 10.5 of the Public Environmental Review (Tellus 2016) which contains a comprehensive environmental impact risk assessment of the natural geological barrier provided by the site.
Further, Condition 9 of MS 1078 require Tellus to ensure the impacts to soil quality are minimised through the implementation of a Leachate Monitoring and Management Plan approved by the Chief Executive Officer of DWER. The management and disposal of NORM / LLW is regulated under the Radiation Safety Act 1975 by way of a site Registration assessed and granted by the Radiological Council (see Section 4.5).
8 CyMod Systems Pty Ltd (2016). The Assessment and Long-Term Recharge to Encapsulated Waste Isolation Cells – Sandy Ridge Project.
Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 69 218000 220000 222000
(! Sandy Ridge Facility Development Envelope (! (! (! (! IWDF (! (! (! (! (! (! (! (! Extra bore E/W (! on end cells (! Material stockpiles Waste Cell Detailed Monitoring (! (! Water pipeline ! 6638000 ( 6638000 (! (! (! (! Carina mine (! (! (! (! (! (! (!(!(! (!(!(! (!(!(! (!(!(! (! (! (! (! (! Putrescible Landfill Mine pits/waste cells WIP: Air quality Waste disposal monitoring )" (! )"kj Infrastructure area
(! Monitoring Station Type kj Air quality kj Air quality control point (! Baseline radiation (! Baseline radiation control point (! Monitoring bore - existing (! ?! (! Monitoring bore - proposed Treated wastewater (! Deep Monitoring bore - proposed kj irrigation area (discharge point) (! Subsidence (! % Control points: % WWTP: effulent Accommodation village
6636000 Air quality & radiation at surface 6636000 )" Water quality kj(! ?! Weather Station
218000 220000 222000 Figure 8-1 Legend Proposed Environmental Monitoring IWDF access road Proposed Mining Area Stations during Operations 0 125 250 500 m Proposed infrastructure Proposed Infrastructure Footprint ± Coordinate System: SANDY RIDGE FACILITY Development Envelope GDA94 MGA Zone 51 Cat 65 & 66 WORKS APPROVAL Drawn by: RM Prescribed Premises Boundary SPID: GL00-2017072102-690 TSR0354_WWAv0_MonitoringBores.mxd Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Version: A Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied. Date: 3/10/2019
Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID,
8.4 EP Act regulatory controls Tellus will submit a compliance construction report to DWER and a licence application for assessment prior to commencing operation of the activities described in this application.
Environmental monitoring will be conducted in accordance with:
• Proposed monitoring of emissions and discharges as per the schedule in Table 8-1 • Sandy Ridge Leachate Monitoring and Management Plan (in preparation) to be approved by DWER CEO in accordance with Condition 9 of MS 1078. • Sandy Ridge Flora and Vegetation Management Plan approved by DWER CEO in accordance with Condition 10 of MS 1078.
• Sandy Ridge Construction Fauna Management Plan approved by DWER CEO in accordance with Condition 11 of MS 1078.
• Sandy Ridge Waste Facility Decommissioning and Closure Plan (in preparation) to be approved by DWER CEO in accordance with Condition 12 of MS 1078.
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9 CONCLUSION
This application has assessed the risks of activities prescribed in Schedule 1 of the EP Regulations on the Sandy Ridge Facility during construction, commissioning and operation. It has been undertaken with due consideration of potential environmental hazards and risks against baseline data gathered between 2015 and 2019.
Based on the potential for environmental and human health hazards and risks presented in Section 7 and the proposed controls described in Section 8, it is recommended the Works Approval for Categories 61, 61A, 65 and 66 be granted subject to conditions proportionate to the determined controls and necessary administration and reporting requirements under Part V of the EP Act.
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10 REFERENCES
Geo9 (2019). Sandy Ridge Project Seismoelectric and Electrotelluric Survey Report. Unpublished report (DRAFT) for Tellus Holdings Ltd. May 2019.
Tellus Holding Ltd. (2016). The Proposed Sandy Ridge Facility Public Environmental Review. Final Report. December 2016. Available at: http://www.epa.wa.gov.au/proposals/sandy-ridge-project#
Tellus Holding Ltd. (2019). Sandy Ridge Facility Temporary Waste Storage – Works Approval Application 2 Supporting Document – Categories 61 and 61A. Unpublished application for works approval under Part V of the Environmental Protection Act 1986. 26 September 2019.
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