Licence Amendment – BHP Port Operation 330Mtpa
Environmental Protection Act 1986 Licence (L4513/1969/18) Amendment – BHP Port Operations 330Mtpa
Supporting Documentation
June 2020
`Jimblebar L5415/1988/9 Licence Amendment Supporting Documentation (Including Information relating to Attachments 1 to 10)
October 2017 Licence Amendment – BHP Port Operation 330Mtpa
Contents 1. Introduction ...... 7 Background ...... 7 Purpose of this Document...... 7 Applicant details ...... 7 2. Premises ...... 8 Location ...... 8 2.1.1. Tenement Details ...... 8 2.1.2. Local Government ...... 8 3. Other Approvals and Regulatory Context ...... 8 State Agreement ...... 8 Part IV EP Act – Ministerial Statement 1070 ...... 9 Part V of the EP Act ...... 11 3.3.1. Licence L4513/1969/18 ...... 11 3.3.2. Noise Regulation ...... 11 3.3.3. Native Vegetation Clearing Permit ...... 12 Other Regulatory Context ...... 12 3.4.1. Port Hedland Dust Management Taskforce ...... 12 3.4.2. Taskforce Recommendation Endorsement ...... 12 3.4.3. Whole of Government Approach...... 13 3.4.4. DWER/DOH Industry Regulation Fact Sheet - Managing Dust in Port Hedland ...... 13 3.4.5. Planning and Development Act ...... 13 3.4.6. Port Hedland Voluntary Buy Back Scheme ...... 15 4. Overview of Proposed Infrastructure Changes ...... 15 Route Upgrades & Productivity Initiatives...... 19 South Yard Expansion 1 (SYE1) ...... 19 South Yard Expansion 2 (SYE2) ...... 19 Car Dumper 6 (CD6) ...... 20 Proposed Implementation Approach ...... 20 5. Emissions and Discharges ...... 24 Air Emissions ...... 24 5.1.1. Our Focus on Air Quality ...... 24 Dust Management ...... 25 5.2.1. Dust Monitoring ...... 25 5.2.2. Ambient Air Monitoring ...... 26 5.2.3. Dust Management Leading Practice ...... 28 5.2.4. Existing Dust Controls ...... 28 5.2.5. Ore Moisture ...... 32 5.2.6. Continual Dust Improvement Works ...... 32 5.2.7. Amenity Based Improvements ...... 33 5.2.8. Proposed Additional Dust Controls ...... 33 5.2.9. Wind Fences ...... 34
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5.2.10. Air Quality Assessment ...... 36 5.2.11. Overview of Dust Model ...... 36 5.2.12. LiDAR ...... 37 5.2.13. Potential Emission Sources ...... 38 5.2.14. Updates to the Dust Model for 330Mtpa ...... 38 5.2.15. Air Quality Assessment Criteria ...... 39 5.2.16. Summary of Dust Assessment Results ...... 39 Noise Emissions ...... 40 5.3.1. Noise Model ...... 40 5.3.2. Monitoring and Model Validation...... 41 5.3.3. Equipment Noise Specifications ...... 41 5.3.4. Operations and Maintenance...... 41 5.3.5. Upgrades and Major Works ...... 42 5.3.6. Summary of Additional Noise Controls ...... 42 5.3.7. Summary of Noise Assessment Results ...... 43 5.3.8. Construction Noise ...... 46 Discharge to Land and Water ...... 46 5.4.1. Relocation of Freshwater Recovery Pond ...... 46 5.4.2. Potential Acid Sulfate Soils ...... 46 5.4.3. Contaminated Sites ...... 46 6. Environmental Management ...... 46 7. Conclusion...... 46 8. Other Relevant Information ...... 47 Community Complaints...... 47 Stakeholder Consultation ...... 47 9. Fee Calculation ...... 49 10. References ...... 50 11. IR-F09 Application Form Attachments ...... 51 Appendix 1: Comparison of BHP controls against PPA Leading Practice Guidelines ...... 52 Appendix 2: Dust Assessment Report (GHD, 2020) ...... 55 Appendix 3: Noise Assessment Report (Talis, 2020) ...... 55 Appendix 4: Proposed Noise Control Packages ...... 56 Appendix 5: Stakeholder Consultation Presentation ...... 58
List of Tables Table 1: Prescribed Premises Categories for L4513/1969/18 ...... 11 Table 2: Summary of Proposed Infrastructure Changes...... 16 Table 3: Proposed Dust & Noise Control Packages ...... 20 Table 4: Proposed Dust Control Packages ...... 34 Table 5: Modelled Dust Concentrations at Taplin St (BHP only)...... 40 Table 6: Stakeholder Engagement ...... 48 Table 7: Calculation of Application Fee ...... 49 Table 8: Summary Attachment for IR-F09 Application Form (Specific to an amendment) ...... 51
3 Licence Amendment – BHP Port Operation 330Mtpa List of Figures Figure 1: Licence L4513/1969/18 premises boundary 10 Figure 2: Overview of Proposed Infrastructure Changes 15 Figure 3: Proposed Changes to Infrastructure at Finucane Island 17 Figure 4: Proposed Changes to Infrastructure at Nelson Point 18 Figure 5: Overview of Proposed Projects and Control Packages 22 Figure 6: Proposed Implementation Approach 23 Figure 7: Port Hedland Exports 24 Figure 8: Port Hedland Dust Regulation 24 Figure 9: Integrated Support Tool 25 Figure 10: BHP Air Quality Monitoring Network 27 Figure 11: BHP’s Direct to Ship Operating Model 28 Figure 12: BHP’s Hierarchy of Dust Controls (Existing and Proposed for 330Mtpa) 29 Figure 13: Finucane Island - Dust Controls (existing and proposed) 30 Figure 14: Nelson Point – Dust Controls (existing and proposed) 31 Figure 15: Pit to Port Moisture Management System 32 Figure 16: Proposed Wind Fence Location and Extent 35 Figure 17: Finucane Island Wind Fence modelling results from Computation Fluid Dynamics method 36 Figure 18: Dust Model Receptor Locations 37 3 Figure 19: Reduction in modelled annual average PM10 (µg/m ) contribution (BHP only) 39 Figure 20: Location of Noise Receivers (South Hedland and Port Hedland) 41 Figure 21: Finucane Island – Noise Controls (existing and proposed) 44 Figure 22: Nelson Point – Noise Controls (existing and proposed) 45
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Glossary
Abbreviation Term ALARP As Low as Reasonably Practicable BHP BHP Billiton Iron Ore Pty Ltd BOC Bulk Ore Conditioning BWR Bucket Wheel Reclaimer BWS Belt Wash Station CAM Cumulative Air Model Category D cyclonic Cyclonic event that has a mean wind speed of between 160 – 199 km/h and wind event gusts up to 255-279 km/h (BOM, 2020) CBD Central Business District CD Car Dumper CD6 Car Dumper 6 CNMP Construction Noise Management Plan dB(A) Decibels A-weighted DEM Dust Extinction Moisture DJTSI Department of Jobs, Tourism, Science and Innovation DoH Department of Health DSD Department of State Development (now DJTSI) DTS Direct to Ship DWER Department of Water and Environmental Regulation EMS ISO14001 certified Environmental Management System ENRMP Environmental Noise Reduction Management Plan EP Act Environmental Protection Act 1986 EPA Environmental Protection Authority FI Finucane Island FWRP Freshwater Recovery Pond HPU Hydraulic Power Unit HRA Health Risk Assessment IP50 West End Improvement Plan No. 50. JTWG Joint Technical Working Groups km/h Kilometres Per Hour LGA Local Government Authority LiDAR Light Detection and Ranging LRP Lump Rescreening Plant ms-1 Meters Per Second Ministerial Statement 740 - Change to the conditions of MS433 &740 pursuant to MS1080 section 46 of the EP Act (approved on 18 December 2017) Ministerial Statement 433 – Upgrade Dust Management at Finucane Island and MS433 Nelson Point, Point Hedland issued on 14 November 1996
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Abbreviation Term Ministerial Statement 740 – Change to the conditions of MS433 pursuant to MS740 section 46 of the EP Act (approved on 16 May 2007) Mtpa Million Tonnes Per Annum NP Nelson Point NVCP Native Vegetation Clearing Permit P Conveyor PPA Pilbara Ports Authority RU Route Upgrade SEG Stakeholder Engagement Group SL Ship Loader SPL Sound Power Level STK Stacker SY South Yard Nelson Point SYE1 South Yard Expansion – Stage 1 SYE2 South Yard Expansion – Stage 2 Taskforce Port Hedland Dust Management Taskforce TS Transfer Station tph Tonnes Per Hour ULNI-H Hybrid Ultra Low Noise Idler WA Western Australia WAPC Western Australian Planning Commission WY West Yard Finucane Island
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1. Introduction
Background
The Port of Port Hedland is the largest bulk export terminal in the world and is one of Australia’s most important pieces of economic infrastructure. A recent economic assessment of the Port was compiled by ACIL Allen Consulting for The Port Hedland Industries Council (PHIC). The report found that the port’s economic contribution in 2018/19 accounted for 20 per cent of WA’s Gross State Product, added $54.7 billion to WA’s economy and is responsible for one in every 12 jobs throughout the State.
BHP Billiton Iron Ore Pty Ltd (BHP) has Port Operations in Port Hedland at Nelson Point and Finucane Island (Port Operations) to support the export of iron ore products from mines located within the Pilbara region of Western Australia (WA). The current approved production capacity for the loading of iron ore onto vessels at BHP’s Port Hedland Port Operations is 290 million tonnes per annum (Mtpa).
Following an inquiry and report by the Environmental Protection Authority under section 46 of the Environmental Protection Act 1986 (EP Act), the Minister for Environment approved on 18 December 2017, through the issue of Ministerial Statement 1070, deletion of the implementation conditions in Ministerial Statements 433 and 740. Furthermore, Condition 2 of Ministerial Statement 1070 states that the proposal may be implemented, subject to any licence in relation to operations on Finucane Island and Nelson Point, Port Hedland under Part V of the EP Act.
On 19 February 2018, the Department of Water and Environmental Regulation (DWER) issued BHP an amended Licence (L4513/1969/18) which included an increase in the production capacity for iron ore loaded onto vessels at BHP’s port facilities, at Nelson Point and Finucane Island, from 270Mtpa to 290Mtpa.
Purpose of this Document This supporting information document has been prepared to provide supplementary information to the Licence Amendment Application for BHP’s Port Operations, as required under Section 59B of the EP Act.
This licence amendment application seeks to increase the approved production capacity (Category 58) under the current Licence (L4513/1969/18), from 290Mtpa to 330Mtpa. This licence amendment application also seeks approval to construct projects (route upgrades and major works) required to support the proposed increase in production capacity. These projects remain subject to BHP’s internal project approval processes.
Applicant details BHP’s Port Operations consist of iron ore unloading, re-screening, stockpiling and ship loading activities at Finucane Island Operations (west) and Nelson Point Operations (east), located on opposite sides of the Port Hedland Inner Harbour.
This Licence application has been submitted by BHP as manager and agent for and on behalf of the Mount Newman Joint Venture participants and the Mount Goldsworthy Mining Associates Joint Venture participants.
Licence Holder:
BHP Billiton Iron Ore Pty Ltd (ABN 46 008 700 981) PO Box 7122 CLOISTERS SQUARE WA 6850
The key contact for this application is: Chris Serginson Manager Environment Phone: 0419 954 728
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Email: chris.serginson@bhp.com Level 41, 125 St Georges Terrace Perth WA 6000 Australia
2. Premises Location The current prescribed premise is located within Nelson Point and Finucane Island leases. The proposed works (outlined in section 4) are located within the existing L4513/1969/18 premises boundary (refer to Figure 1). The prescribed premise boundary relates to land owned by, or leased to, the Mount Newman Joint Venture participants and the Mount Goldsworthy Mining Associates Joint Venture participants.
2.1.1. Tenement Details The proposed infrastructure is located primarily on the following tenure:
I123400 Nelson Point Wharf Mount Newman Joint Iron Ore (Mount Newman) Venture Agreement Act 1964 (WA) I123403 Nelson Point Mount Newman Joint Iron Ore (Mount Newman) Venture Agreement Act 1964 (WA) K693815 Under Harbour Mount Newman Joint Iron Ore (Mount Newman) Tunnel Venture Agreement Act 1964 (WA) I126342 Finucane Island Mount Goldsworthy Iron Ore (Mount Goldsworthy) Loop Joint Venture Agreement Act 1964 (WA) J998595 Finucane Island Mount Goldsworthy Iron Ore (Mount Goldsworthy) Joint Venture Agreement Act 1964 (WA) M653978 Goldsworthy Rail Mount Goldsworthy Iron Ore (Mount Goldsworthy) (formerly Joint Venture Agreement Act 1964 (WA) J998591) K693809 Pace Wharf Mount Goldsworthy Iron Ore (Mount Goldsworthy) Joint Venture Agreement Act 1964 (WA) K693808 Harriet Point Mount Goldsworthy Iron Ore (Mount Goldsworthy) Joint Venture Agreement Act 1964 (WA) K693814 Utah Jild BHP Billiton Direct Iron Ore Beneficiation (BHP) * See Note 1 Reduced Iron Pty Ltd Agreement Act 1996 (WA) (Repealed) G943533 Finucane Island Mount Goldsworthy Land Administration Act 1997 Substation Joint Venture (WA).
Note 1: Clause (4)(c) of the Iron Ore Agreements Legislation (Amendment, Termination and Repeals) Act 2011 (WA) (Termination Act) terminated the Iron Ore Beneficiation (BHP) Agreement Act 1996 (WA) (Beneficiation Agreement) and provides a replacement lease would be granted in the name of Mount Goldsworthy Joint Venturers and subject to Iron Ore (Mount Goldsworthy) Agreement Act 1964. The Joint Venturers and the Pilbara Port Authority are currently finalising the replacement Utah Jild lease.
2.1.2. Local Government The BHP Port Operations are located within the Town of Port Hedland.
3. Other Approvals and Regulatory Context
This section details the approvals that govern BHP’s Port Operations and provides context on the broader regulatory landscape of Port Hedland.
State Agreement The Premises are held under the following State Agreement Acts: Iron Ore (Mount Newman) Agreement Act 1964 (WA); and Iron Ore (Mount Goldsworthy) Agreement Act 1964 (WA).
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Part IV EP Act – Ministerial Statement 1070 The BHP Port Operations were previously subject to Part IV of the EP Act by virtue of Ministerial Statement 433 (MS433) and Ministerial Statement 740 (MS740).
In 2016, DWER advised BHP that dust regulated under both Part IV and Part V of the EP Act involved regulatory duplication. As such, DWER and the then Office of the Environmental Protection Authority (EPA) determined a consistent and singular regulatory approach for bulk handling port premises should be adopted.
In 2017, EPA undertook an inquiry into the conditions of Ministerial Statements 433 and 740 under section 46 of the EP Act at the request of the Minister for Environment. Subsequently the EPA released EPA Report 1608 in November 2017 (EPA 2017). EPA Report 1608 states “the EPA’s view is that the current application by BHP for an increase in throughput from 270Mtpa to 290Mtpa, and any future increases, can be appropriately dealt with under Part V of the EP Act.” Ministerial Statement 1070 was issued on 18 December 2017 under section 46 of the EP Act deleting each of the implementation conditions in Ministerial Statements 433 and 740.
By the current amendment application, BHP is seeking approval of future works and associated emissions to facilitate an increase in production throughput capacity from 290Mtpa to 330Mtpa. Based on the EPA’s recommendation in EPA Report 1608, BHP considers that a licence amendment to support the proposed future upgrade works meets the objective of a consistent and singular regulatory approach for bulk handling port premises, to avoid regulatory duplication.
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Figure 1: Licence L4513/1969/18 premises boundary
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Part V of the EP Act 3.3.1. Licence L4513/1969/18 Pursuant to an application lodged by BHP in 2016, DWER conducted a risk-based assessment of BHP’s Licence for an increase in throughput capacity from 270Mtpa to 290Mtpa.
Subsequently an amended environmental licence for Prescribed Premises (L4513/1969/18) was issued by DWER under Part V of the EP Act for BHP’s Port Operations at Nelson Point and Finucane Island (Figure 1). Table 2 outlines the prescribed activities currently approved under L4513/1969/18, in accordance with the Environmental Protection Regulations 1987.
Table 1: Prescribed Premises Categories for L4513/1969/18
Category Category description Category production Approved Premises number or design capacity production or design capacity
5 Processing or beneficiation of 50 000 tonnes or 155 million tonnes per metallic or non-metallic ore more per year. annual period.
54 Sewage facility 100 cubic metres or 260.9 cubic metres per more per day. day.
58 Bulk material loading or unloading 100 tonnes or more 290 million tonnes per per day. annual period.
61 Liquid waste facility 100 tonnes or more 8000 tonnes per annual per year. period.
73 Bulk storage of chemicals, etc. 1 000 cubic metres in 63 336 cubic metres in aggregate. aggregate.
BHP is seeking through this licence amendment application to increase throughput capacity under Category 58 from 290Mtpa to 330Mtpa. No changes are requested to the remaining prescribed premise categories.
3.3.2. Noise Regulation Environmental noise at BHP’s Port Operations is managed in accordance with an Environmental Noise Reduction Management Plan (ENRMP).
The ENRMP sets out the following noise objectives for BHP’s Port Operations:
· Reduce noise to as low as reasonably practicable, acknowledging growth, and where reasonably possible, comply with the requirements of the Environmental Protection (Noise) Regulations 1997 (including seeking an exemption if necessary); · Where it is impracticable to comply with Environmental Protection (Noise) Regulations 1997, ensure continuous improvement is facilitated through a Noise Reduction Management Plan (NRMP); · Ensure that new plant and infrastructure being planned for the Port facilities particularly Prescribed Plant as defined by the Environmental Protection Act (1986), complies with the Environmental Protection (Noise) Regulations 1997 where land use planning constraints allow; and · Comply with the Western Australian Planning Commission’s State Planning Policy 5.4, Road and Rail Transport Noise and Freight Considerations in Land Use Planning where land use planning constraints allow.
Page | 11 Licence Amendment – BHP Port Operation 330Mtpa 3.3.3. Native Vegetation Clearing Permit BHP currently holds a number of Native Vegetation Clearing Permits (NVCP) over the area of the existing prescribed premises for L4513/1969/18 including CPS 7009/2, which supports clearing associated with, railways, general port infrastructure and all associated infrastructure. The proposed Finucane Island Wind Fence is being constructed on a previously built rail formation within the prescribed premises boundary. As such the area has been previously disturbed, however if required BHP will apply for an amendment to CPS 7009/2 to support any additional clearing that may be required for construction of the wind fence. Other Regulatory Context
3.4.1. Port Hedland Dust Management Taskforce In May 2009, the State Government established the Port Hedland Dust Management Taskforce (Taskforce) to plan for and provide effective dust management strategies in Port Hedland. The former Department of State Development, now the Department of Jobs, Tourism, Science and Innovation (DJTSI) chaired the Taskforce that comprised representatives from government and industry, including BHP.
The Port Hedland Air Quality and Noise Management Plan (AQNMP) was released by DJTSI in 2010 and subsequently adopted by the State Government, for ongoing air quality and noise management in Port Hedland. The AQNMP details the implementation strategy for air quality and noise reduction in Port Hedland.
The Department of Health (DoH) released a Health Risk Assessment (HRA) report on the air quality in Port Hedland in January 2016.
3.4.2. Taskforce Recommendation Endorsement In response to the HRA report, DJTSI released the Port Hedland Dust Management Taskforce Report to Government (August 2016) (Taskforce Report) for public comment on 9 August 2017.
The State Government released its response to the Taskforce Report on 15 October 2018. The Taskforce was disbanded in October 2018 with accountabilities for Taskforce recommendations allocated to key government agencies.
In particular, the State endorsed the following key Taskforce recommendations: Health Risk Assessment 3 o Interim guideline of 24-hour PM10 of 70μg/m (excluding natural events) continues to apply to residential areas of Port Hedland and that measures should be introduced to cap (and if possible, reduce) the number of permanent residents in dust-affected areas of Port Hedland. Air Quality Monitoring o Full transfer of the operation and maintenance of the Port Hedland Industries Council (PHIC) air quality monitoring network to the DWER. · Industry Dust Management and Regulation o A coordinated risk-based review and assessment approach to managing dust in Port Hedland. o An independent third-party review and develop a dust management guideline for bulk handling port premises, outlining its expectations in relation to the assessment of dust impacts, dust control and monitoring requirements from these premises. · Local Government and Community o Town of Port Hedland works with key stakeholders to identify and mitigate dust from non-industry sources. · Noise o DWER working with industry to explore the feasibility of approvals under Regulation 17 of the Environmental Protection (Noise) Regulations 1997, where the prescribed noise standard cannot be met by individual premises. o Port Hedland Cumulative Noise study is used to inform land-use planning for the West End of Port Hedland. · Land-Use Planning o Appropriate planning controls be implemented to prohibit sensitive land uses and restrict population growth in the West End of Port Hedland.
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3.4.3. Whole of Government Approach BHP supports the State Government’s holistic approach to resolving the land use conflict in the Port Hedland West End, building on the implementation of the Dust Taskforce recommendations. This holistic approach includes the following six elements:
1. Modern planning principles applied to limit population exposure and population growth (progression of the Improvement Plan No. 50 and West End Improvement Scheme 1). 3 2. Taskforce Interim Guidelines for PM10 particles (24-hour average of 70µg /m ) continue to apply in residential areas. 3. Port Hedland Voluntary Buyback Scheme (PHVBS) to provide residents and landowners west of Taplin Street the opportunity to sell or relocate. 4. Town planning program to increase green belts and establish redevelopment opportunities. 5. Health exposure education on health risk management for those who choose to stay post-buy back, noting 3 the outcomes of the scenarios described in the HRA concluded that 70µg/m for PM10 provided a similar
level of protection to the current population of Port Hedland, as would the NEPM standard for PM10 of 50 µg/m3 in urban areas. 6. Best Practice Dust Guidelines to be developed by independent consultants, in consultation with industry.
3.4.4. DWER/DOH Industry Regulation Fact Sheet - Managing Dust in Port Hedland In 2018, DWER and DoH released the Industry Regulation Fact Sheet: Managing Dust in Port Hedland (DWER, DoH, 2018) in response to the State Government endorsement of the Taskforce Recommendations.
In the fact sheet, DWER details the road map for improved industry practices. The planned approach includes:
· Developing and implementing best practice dust management guidelines for bulk handling port premises, designed to reduce emissions from port operators; · Taking control of the ambient air quality monitoring network, subject to negotiations over the configuration of the network and ensuring any incurred costs are covered by industry in accordance with the ‘polluter pays’ principle; and · Implementing a coordinated risk-based review and assessment of all port operator licences, to incorporate more robust regulatory controls in line with the best practice guidelines.
In addition, DWER (2018) provided guidance on its interim regulatory approach including:
· DWER has proposed a five-year plan for the proposed improvements to be finalised. Planning controls will also take a considerable period before changes begin to take effect; · DWER will take a conservative approach to the assessment of any works approval, licence or amendment applications received for premises in the Port Hedland air shed, until the self-assessment stages of the process are completed and submitted; · Applicants will be encouraged to demonstrate no net increase to dust emissions in Port Hedland from port related activities. Where this isn’t demonstrated, DWER will consider further controls that may in part serve to offset any increase in dust emissions; and · Any changes to operations in the interim period will still be subject to the best practice dust management guidelines when they are defined, and port operators may be asked retrospectively to address any performance gaps that are identified.
3.4.5. Planning and Development Act In August 2019, the State Government approved the Western Australian Planning Commission’s (WAPC) recommendation for Port Hedland’s West End to be the subject of (the now gazetted) Improvement Plan No. 50 (IP50) and eventual gazettal of an Improvement Scheme.
The purpose of IP50 is to:
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· Enable the WAPC to undertake all necessary steps to advance the planning and development within the plan area as provided for under Part 8 of the Planning and Development Act 2005 (PD Act); · Establish the strategic planning and development intent within the subject area; provide for a strategic planning framework endorsed by the WAPC, Minister for Planning and the Governor; · Authorise the preparation of an improvement scheme; · Provide the objectives of an improvement scheme; and · Provide guidance to the preparation of statutory plans, statutory referral documentation and policy instruments.
IP50 authorises the making of an improvement scheme, by resolution of the WAPC and approval of the Minister for Planning. The following objectives will guide the preparation of the improvement scheme: · To provide a strategic planning framework to determine future land uses considering all land use options that takes into consideration physical, economic, social, and environment factors; · To provide a statutory planning instrument through which to implement the strategic planning framework and effectively guide the preparation of statutory plans, statutory referral documentation and policy (as may be required) to facilitate orderly and proper planning of the area; and · To implement the State Government response to the Port Hedland Dust Management Taskforce Report to State Government to prohibit sensitive land uses and restrict population growth in the West End of Port Hedland.
In March 2020, the WAPC advertised the Port Hedland West End Improvement Scheme No 1 for public comment, with submissions due by 3 July 2020. The purposes and aims are articulated in the scheme document as follows: The purposes of this Scheme are to – a) set out the Commission’s planning aims and intentions for the Scheme area; b) set aside land as local reserves for public purposes; c) zone land within the Scheme area for the purposes defined in this Scheme; d) control and guide development including processes for the preparation of structure plans, activity centre plans, and local development plans; e) set out procedures for the assessment and determination of development applications; f) make provision for the administration and enforcement of this Scheme; and g) address other matters referred to in Schedule 7 of the Act.
Aims of this Scheme are - a) to provide a statutory planning instrument through which to implement the strategic planning framework and effectively guide the preparation of statutory plans, statutory referral documentation and policy (as may be required) to facilitate orderly and proper planning of the Scheme area;
b) to implement the Government response to the Port Hedland Dust Management Taskforce Report to Government (2016) to prohibit sensitive land uses and restrict population growth in the West End of Port Hedland by prohibiting: a. new residential development; and b. development intended for use either exclusively or primarily by sensitive groups within the general population including: i. older people (over 65 years); ii. people with pre-existing cardiovascular or respiratory disease; iii. children and adults with pre-existing respiratory conditions (asthma, bronchitis, chronic obstructive pulmonary disease); and iv. children. c) to facilitate opportunities for investment and development of quality built form and public place design across the Scheme area and public foreshore reserve interfaces that recognise the iconic location and heritage significance of the Port Hedland West End.
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3.4.6. Port Hedland Voluntary Buy Back Scheme In September 2019, the State Government announced the proposal to develop an industry funded Port Hedland Voluntary Buy Back Scheme (PHVBS). The Pilbara Development Commission website states:
The PHVBS has been proposed in recognition that owners of residential properties in Port Hedland’s West End are uniquely impacted by proposed planning changes proposed as part of the West End Improvement Plan No. 50. The PHVBS covers residential properties within the Improvement Plan area.
The State Government is responding to the recommendations of the Taskforce Report, in part by developing the PHVBS which recognises the fact that the owners of residential properties covered by Port Hedland’s West End Improvement Plan No. 50 between Taplin Street and the Port will be impacted by recent and future planning legislation.
The PHVBS is an important component of the WA Government’s holistic approach to resolving the West End land use conflict and gives residents and landowners in the area the option to relocate or sell.
4. Overview of Proposed Infrastructure Changes This application proposes to undertake upgrades to existing equipment at Finucane Island and Nelson Point to increase the production capacity of existing infrastructure through route upgrades/productivity initiatives and through the installation of new infrastructure (major works) at Nelson Point, to increase overall throughout capacity from 290Mtpa to 330Mtpa (Figure 2 and Table 2).
Figure 2: Overview of Proposed Infrastructure Changes
15 Licence Amendment – BHP Port Operation 330Mtpa Table 2: Summary of Proposed Infrastructure Changes
Project Summary of Works Location
Route · Bucket Wheel Reclaimer 6 (BWR6) Hydraulic Drive and Route Finucane Upgrades/Productivity Upgrade to Ship Loader (SL) 5&6 at 13,500 tonnes per hour (tph) Island and initiatives · BWR7 Hydraulic Drive and Route Upgrade to SL7&8 (13,500tph) Nelson Point · BWR8 Hydraulic Drive and Route Upgrade to SL3&4 (11,400tph,12,500tph) · BWR10 to SL7 and SL8 (via LRP20 to 18,000tph) · LRP 2 upgrades to 18,000tph · Upgrade CD3 to SL1 and SL2 (via P730) to 15,400tph · Replacement of Ship Loader 3 · Upgrade DTS route to SL3 to 13,500tph · Upgrade route from BWR8 to SL3 to 13,500tph. Major Works · New stockpile (F area) in South Yard at Nelson Point Nelson Point South Yard · New reclaimer 11 (BWR11) at 15,400 (tph) to SL5 & 6 Expansion – Stage 1 · New reclaimer 11 (BWR11) at 14,500tph feed rate to LRP3 (SYE1) · New reclaimer yard conveyor (P773 and Transfer Stations) · Upgrade existing Stacker (ST6) to 16,000tph · Upgrade inflow conveyors from car dumper 2 (CD2) and CD3 to STK6 to 16,000tph · Upgrade LRP3 to 14,500tph feed rate from BWR11 · Upgrade LRP3 feed conveyors to 14,500tph Major Works · New stockpile (X area) in South Yard at Nelson Point Nelson Point South Yard · New Stacker (STK14) at 20,000tph Expansion - Stage 2 · New conveyors and associated transfer stations from CD2 and (SYE2) CD3 to new STK14 · LRP 3 upgrades to 18,000tph Major Works · New Car Dumper 6 Nelson Point Car Dumper 6 (CD6) · CD6 to Stackers SY (STK6, STK7, STK14) · CD6 to Stackers NY (STK5, STK8) · CD6 via conveyor P238 to SL1, SL2 · New Sample station for P238 (SS238)
Major Works · New route from CD2, CD3 and CD6 to SL5 & SL6 (P218) Nelson Point SYE2 & CD6 shared · New sample station for P218 route (SS218) scope · New route connection (P729 & P774) from BWR11 to SL1, SL2, (Works could be SL5 & SL6 via P218, P238 & P730 conveyors completed under · Modify and upgrade A & B berth conveyors and SL1 & SL2 either SYE2 or CD6)
Figures 3 and 4 below provide an overview of the proposed changes at Nelson Point and Finucane Island. Detailed descriptions of the proposed works are contained in the following Sections 4.1-4.4.
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Figure 3: Proposed Changes to Infrastructure at Finucane Island
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Figure 4: Proposed Changes to Infrastructure at Nelson Point
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Route Upgrades & Productivity Initiatives A number of route upgrades are being proposed at Finucane Island and Nelson Point:
· Upgrade BWR 7 (Finucane Island) from 10,500 to 13,500 tonnes per hour (tph) and modify existing conveyors and transfer stations to LRP2, SL7 & SL8 to 13,500tph; · Upgrade BWR 8 (Finucane Island) from 10,500 to 13,500tph and modify existing conveyors and transfer stations to SL4 (12,500tph); · Upgrade BWR 6 (Nelson Point) from 10,000 to 13,500tph and modify existing conveyors and transfer stations to LRP3, SL5 & SL6 to 13,500tph; · Upgrade CD3 to SL1 and SL2 via P730 to 15,400tph; · Upgrade BWR10 route to SL7 and SL8 (via LRP2) to 18,000tph; · Replace Ship Loader 3 and upgrade; · LRP 3 upgrades to 18,000tph · CD5 route to SL3 to 13,500tph; and · BWR8 route to SL3 to 13,500tph.
The bucket wheel reclaimer and associated infrastructure works (for BWR6, BWR7 & BWR8) consist of the following upgrades:
· New hydraulic power unit (HPU) BWR drives on counter weight boom; · Replace existing electro mechanical drives with hydraulic drives; · Upgrade bearings and drive couplings; · Replace sliding chute; · Transfer chute upgrades; · Upgrades to buckets; · Upgrade boom conveyor drive pulley; and · New conveyor drives.
South Yard Expansion 1 (SYE1) BHP proposes to execute upgrade works to expand its south yard infrastructure at Nelson Point. The upgrades would be undertaken in two stages. Stage 1 is further detailed in this section, with stage 2 detailed in section 4.3.
SYE1 includes the following infrastructure: · A new bucket wheel reclaimer 11 (BWR11) which is designed to run at a maximum rate of 18,000tph; · The BWR 11 will reclaim iron ore products from a new stockpile (Row F) to ship loader 5 & 6 (SL5, SL6) at a rate of 15,400 tph via conveyor P564; · Route upgrade from the BWR 11 to Lump Rescreening Plant 3 (LRP3) via conveyor P510 at a rate of 14,500 tph (from 10,500 tph); · Route upgrades from car dumper 2 & 3 (CD2, CD3) to Stacker 6 at a rate of 16,000 tph; and · Dust and noise controls detailed in sections 5.2 and 5.3 respectively.
South Yard Expansion 2 (SYE2) The second stage of the proposed South Yard Expansion works at Nelson Point includes the following components: · New stacker (Stacker 14) and stockyard row; · Modification to existing and installation of new conveyors and transfer stations to receive ore from car dumper 2 and 3 and feed Stacker 14; · Modification to existing and installation of new conveyors and transfer stations to Nelson Point ship loaders; · Upgrade of lump rescreening plant; · New sample stations aligned to new route alignments; · Upgrades to the freshwater recovery system including installation of a new thickener plant to treat process water for reuse on site; and · Dust and noise controls detailed in sections 5.2 and 5.3 respectively.
Page | 19 Licence Amendment – BHP Port Operation 330Mtpa The South Yard Expansion 1 & 2 would require ground improvement works to ensure the foundations can support the new stockyard and associated infrastructure. Ground improvements will require mobile equipment to install stone columns to strengthen the foundations. In order to install the stone columns, excavation and dewatering is required. Management of soil and dewatering is discussed in section 5.4.
Car Dumper 6 (CD6) The proposed works at Nelson Point includes the construction of a new train unloading facility (CD6) and associated materials handling equipment. The new car dumper would be located on an existing rail route previously used for the ore car repair shop in Nelson Point. The proposed CD6 will be used to direct-feed ship load and to feed the existing stockyards at Nelson Point.
The proposed works at BHP’s Nelson Point operations associated with CD6 include the following: · New rotary car dumper, excavated vault and conveyor tunnel; · Modification to existing conveyors and installation of new conveyors and transfer stations to receive feed from CD6 infrastructure; · Upgrade of power and control system infrastructure; · Modification to rail infrastructure and removal of some redundant lines; · New traffic bridge over Nelson Point rail yard infrastructure; and · Dust and noise controls detailed in sections 5.2 and 5.3 respectively.
The proposed CD6 development includes temporary works to enable construction of the car dumper, including a dewatering system capable of lowering the water table during bulk earthworks and a hydrocarbon decontamination plant and waste lagoon. Minor demolition works would also be required for the proposed installation of CD6 and associated infrastructure including removal, refurbishment and relocation of buildings and infrastructure.
Proposed Implementation Approach BHP has proposed a strategic approach to this licence amendment, which would afford flexibility to BHP to determine the timing and order that the individual projects (comprising the works) could be executed. The construction and operation of each project would be approved under the licence, along with the associated increase in throughput capacity (Table 3). Each project has a suite of dust and noise controls as an integral part of the works, which are designed to deliver a no net increase in noise emissions and an overall net reduction in dust emissions (Table 3). The respective dust and noise control packages would be completed prior to the associated increase in throughput capacity taking effect.
Table 3: Proposed Dust & Noise Control Packages
Projects Package Dust Controls Noise Controls Approved (Detailed in (Detailed in Throughput Section 5.2.7) Appendix 4) Capacity (Category 58) • Route Upgrades Package 1A • South Yard belt wash Hybrid Ultra Low 295Mtpa and Productivity stations Noise Idler • Sealing of open areas Program • Fogging units in Car Dumpers • Vehicle reduction Package 1B • Finucane Island Wind Scope related 303Mtpa Fence controls Major Works Package 2A • South Yard Wind Fence Scope related 330Mtpa • South Yard (With Package Scope related controls: controls Expansion 1 1A and 1B) − Reclaimer boom sprays − Automated stockpile water cannons − Belt wash station
Major Works Package 2B Scope related controls: Scope related • South Yard (With Package − Luffing stacker with controls Expansion 2 1A, 1B and 2A) boom sprays − Automated stockpile water cannons
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− Belt wash station
Major Works Package 2C Scope related controls: Scope related • Car Dumper 6 (With Package − Enclosed with wet controls 1A, 1B and scrubber extraction and 2A) collection system − Fogging unit − Belt wash station
Under this proposed approach the construction and operation of these projects could occur sequentially (in any order) or with one or more projects executed concurrently if this need arises e.g. routes upgrades and major works project.
As an example, if BHP proceeds first with increasing throughput above the current licenced capacity (290Mtpa) through route upgrades, then the proposed works will be completed along with dust control package 1A and noise control package 1A (Table 3), prior to throughput exceeding 290Mtpa. Throughput could then increase up to 295Mtpa. Once dust and noise control packages 1B are completed, throughput could then increase up to 303Mtpa.
In an alternate scenario, where BHP proceeds first with a major works package, for example SYE1, then the proposed works will be completed along with dust and noise control package 2A (Table 3), prior to throughput exceeding 290Mtpa. Under this scenario, BHP would also complete dust and noise control packages 1A and 1B. This approach is designed to ensure a no net increase in dust and noise emissions. Following the completion of SYE1 and dust and noise control packages (1A, 1B, 2A), BHP could increase throughput capacity to the full 330Mtpa. Completion of the remainder of the works (SYE2 & CD6) could then be done later as required, along with the scope related controls (Package 2B and 2C respectively). Scope related controls are those controls that would only be installed when the works are constructed.
Some dust and noise controls may be installed prior to the construction of the associated project, for example the Finucane Island Wind Fence. It is intended that where these controls are installed earlier (ahead of the associated works), it is for the benefit of the overall capacity upgrade from 290Mtpa to 330Mtpa and would support the future implementation of the remaining works approved under this licence amendment.
SYE2 would be constructed after SYE1. A South Yard Wind Fence will be constructed with SYE1 to provide dust reduction benefits for SYE1 & SYE2.
Once the full dust and noise control packages are installed and BHP is operating at 330Mtpa, this approach has been designed to maintain a no net increase in noise emissions and achieve an overall reduction in BHP’s dust emissions (refer to Sections 5.2 and 5.3).
Figures 5 and 6 included below further illustrate the proposed approach to the implementation of the projects and the associated dust and noise control packages.
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Figure 5: Overview of Proposed Projects and Control Packages
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Figure 6: Proposed Implementation Approach
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5. Emissions and Discharges Refer to Attachments 2 and 3 for detailed information regarding the assessment of dust and noise emissions.
Air Emissions 5.1.1. Our Focus on Air Quality BHP’s Port Operations were established in Port Hedland in the 1960’s before modern planning guidelines recognized the benefits of separating industrial facilities and residential areas. Minimising the environmental impact of our operations is as important to BHP as it is to the communities in which we operate. To ensure the growth of our iron ore business is sustainable, environmental objectives have shaped the nature of our port activities and the environmental controls and management practices that we have in place. Port Hedland’s coastal location in the arid Pilbara region with low and variable rainfall levels, seasonal cyclonic activity and consistently high temperatures means naturally occurring and anthropogenic dust sources (such as urban and industrial development) contribute to the ambient air quality in Port Hedland and this creates additional challenges. Over time, our port activities have been streamlined by removing primary crushing and screening and re- designed to enable a high proportion of our products to be loaded to ships directly from rail unloading facilities to deliver material reductions in dust and noise emissions. We have invested A$400m in environmental controls over the last 10 years. These controls are closely regulated and operate continuously to eliminate and mitigate dust and noise emissions. A comprehensive dust monitoring network is in place to enable us to monitor our emissions in real time and ensure emissions are kept to a minimum. With this approach by BHP and the efforts of other industry producers, the port’s environmental performance has improved to ensure the sector operates within regulatory requirements, as volumes have increased to levels that have made Port Hedland the largest bulk handling port in the world. This level of activity is delivering significant social and economic benefits at a local, state and national level along with a strong track record of environmental performance.
Figure 7: Port Hedland Exports Figure 8: Port Hedland Dust Regulation
BHP is committed to continuing to improve dust management performance with this licence amendment. BHP has assessed dust management practices at other Australian and International bulk commodity operations and sought input from air quality experts and the operational teams who live and work in Port Hedland, to design the dust and noise controls included in this licence amendment application. Special attention has been given to improving our understanding of the conditions when natural and industrial dust sources have the potential to combine and create elevated dust levels in the West End of Port Hedland. With this knowledge, the licence amendment includes the extension of existing controls that have been shown to be effective and the introduction of wind fences designed for Port Hedland conditions, to reduce the potential for dust lift-off from stockpiles during strong seasonal winds. The comprehensive package of dust and noise controls included in this licence amendment application forms a key part of a broader plan by BHP to spend up to A$300M to improve dust management across our Pilbara operations over the next 5 years. BHP is confident that with these controls in place, we can continue to increase Page | 24 Licence Amendment – BHP Port Operation 330Mtpa throughput whilst minimising our contribution to dust and noise in Port Hedland. BHP recognises that this approach will be further informed by DWER’s development of the best practice dust management guidelines for bulk handling port premises. Dust Management 5.2.1. Dust Monitoring
BHP operates a real-time monitoring network that consists of PM10 operational monitors and boundary monitors (Figure 10). Operational monitors are located within the site to monitor potential dust sources along with boundary monitors, which also measure concentrations to determine if management criteria levels are triggered on the premise boundary. Where boundary monitoring indicates that the management criteria is triggered, BHP implements the following management actions consistent with its requirements under the current licence L4513/1969/18 (conditions 22 and 23): • Bulk Ore Conditioning (BOC) sprays to be operating on all conveyors that are handling Iron Ore unless the ore moisture of the ore being handled is known to be at or above DEM; • Stockpile cannons to run on deluge cycle; • Undertake a boundary monitoring Trigger Investigation to identify the source of the management trigger criteria exceedance; and • If identified to be caused from activities at the Premises, implement immediate dust abatement measures. The boundary monitors are also used to measure dust concentrations against the reportable event criteria defined in the licence. If these criteria are triggered, BHP will complete an investigation into the potential source of emissions and controls in place at the time. The investigation outcomes are reported to DWER on a quarterly basis in accordance with current licence conditions. Data from our boundary monitoring network is also used to calibrate our emission estimates used in the dispersion modelling, guide our continuous improvement on-site and the development of new controls. BHP operates a dust monitoring dashboard and integrated support tool (Figure 9), which displays historical, real time and predictive weather and PM10 data. The integrated support tool identifies the predicted wind direction, wind speed, and estimated dust concentrations to enable BHP to respond proactively to manage site dust emissions.
Figure 9: Integrated Support Tool
The dust monitoring tools track and report site performance against key dust metrics and licence compliance requirements. The dashboard enables tracking and monitoring of the following:
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1. Live dust equipment performance (real time performance monitoring) 2. Historical dust equipment performance 3. Boundary monitor PM10 data 4. Boundary monitor PM10 data and wind direction prediction tool 5. Management triggers and reportable events 6. Licence summary monitoring site performance against operational license targets.
The dust monitoring tools enable the proactive management of dust emissions and ensures that BHP’s Port Operations continue to comply with its regulatory requirements. 5.2.2. Ambient Air Monitoring The Port Hedland ambient air monitoring network is currently managed by the Port Hedland Industries Council (PHIC) on behalf of industry members including BHP. The monitoring network consists of a number of reference sites across Port Hedland and the regulatory monitor located at Taplin Street.
3 BHP reports exceedances of the 24 hour average PM10 reportable event criteria of 70µg/m on a quarterly basis to DWER, based on monitoring data provided to BHP by PHIC. BHP undertakes an investigation of the exceedance including the activities being undertaken on-site and the controls in place, 12 hours prior to and after the time an exceedance was recorded, in accordance with licence conditions.
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Figure 10: BHP Air Quality Monitoring Network
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5.2.3. Dust Management Leading Practice DWER is understood to be currently developing best practice guidelines for bulk handling port operations in response to the Taskforce recommendations. As a key outcome of the Port Hedland Dust Management Taskforce Air Quality and Noise Management Plan (DSD, 2010), the Pilbara Ports Authority (PPA) has previously commissioned SKM to determine the effectiveness of dust control techniques across bulk handling facilities and to develop the Dust Management Leading Practice Guidelines (PPA, 2013). In preparing this licence amendment application, BHP has considered these guidelines, which are based on a review of national and international best practice and describe what is broadly considered to constitute leading practice for dust management in bulk materials handling processes. Refer to Appendix 1 for a comparison of BHP’s controls against the PPA Guidelines. BHP has also conducted a review of dust abatement controls used at other similar bulk handling port facilities across Australia and internationally. This review included Coal operations in NSW and Queensland and Iron Ore operations in the Pilbara and South America. These reviews have validated that BHP’s current controls in place are consistent with industry leading practice. The review also assisted with identifying additional controls such as wind fences, which are installed in other operations overseas and proven as an effective abatement for reducing emissions from stockpiles. Refer to section 5.2.7 for further details on the additional controls BHP is proposing in this licence amendment application. BHP considers the controls proposed to be implemented with the works, the subject of this licence amendment, will ensure that BHP continues to comply with leading industry practice in dust and noise control. Nevertheless, BHP looks forward to the introduction of the best practice guidelines and undertaking a self-assessment against those guidelines to identify any further areas for possible improvement. 5.2.4. Existing Dust Controls BHP’s Port Operations are configured to enable high Direct to Ship (DTS) capability, whereby a high proportion of ore is sent directly from Car Dumper to Ship Loader after is unloaded i.e. it is not stacked and then reclaimed in a stockyard. This is a significant dust and noise control as it avoids the double handling of ore and the associated potential generation of emissions. This operating mode is maximised wherever possible, as it also enables higher production volumes through the Port. BHP is a global leader in this emissions control when compared across Industry. Figure 11 below outlines this approach further.
Figure 11: BHP’s Direct to Ship Operating Model Figure 12 below outlines the existing dust controls (by equipment type) that BHP operates and maintains across its Port Operations, along with the additional controls proposed for this licence amendment. As Figure 12 indicates, BHP’s uses the hierarchy of control to provide a comprehensive approach to managing dust emissions that extends across all points of the ore handling system.
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Figure 12: BHP’s Hierarchy of Dust Controls (Existing and Proposed for 330Mtpa) Figures 13 and 14 below outline the locations of dust controls (existing and proposed) within the Port Operations.
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Figure 13: Finucane Island - Dust Controls (existing and proposed)
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Figure 14: Nelson Point – Dust Controls (existing and proposed)
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5.2.5. Ore Moisture Ore moisture is an important control for reducing dust emissions from the handling of iron ore. BHP is implementing an industry leading ore moisture management system across its supply chain in the Pilbara, from the mine pits to the port (Pit to Port). This enables iron ore to arrive into Port Hedland at a moisture level that limits the potential to generate dust emissions (Figure 15).
BHP’s Pit to Port approach reduces the frequency of dry ore arriving at the Port with the potential for emissions that contribute to elevated dust events. This also reduces the reliance on having to add moisture and ‘condition’ the ore at the Port, which also results in less water use within the Port Operations.
Figure 15: Pit to Port Moisture Management System The approach used to determine the relationship between ore moisture and the dust-generating potential of a product is known as the dust extinction moisture (DEM). DEM provides a guide on the moisture level required to minimise dust for different ore types and is determined through independent laboratory analysis and testing. The testing measures the total amount of dust generated from a material at different moisture contents and determines the optimal moisture level required for each product to minimise the generation of dust.
Through the deployment of the pit to port moisture management system, BHP is consistently improving the condition of the ore as it arrives into Port, to optimise ore moisture and minimise potential dust generation. BHP is progressing with upgrades to its supporting infrastructure and system controls to ensure ore moisture performance continues to meet the requirements under the operating licence (L4513/1969/18).
5.2.6. Continual Dust Improvement Works BHP has implemented a number of dust improvement initiatives on-site as part of its ongoing continuous improvement culture, in addition to the controls required by its operating licence (L4513/1969/18). The improvement initiatives have been identified by the team members working on-site and implemented to further reduce potential dust emissions from the Port Operations.
These dust improvement works include:
· Sealing and/or application of suppressants on open areas and roads. · Restricting access to open areas and roads to prevent traffic generated dust. · Optimisation of nozzle design for improved fogging coverage in Transfer Stations. · Improvements to dust curtain technology on Lump Rescreening Plants. · Redesign of soft skirts to improve containment of dust emissions from conveyor impact areas. · Simplified belt wash design to improve efficiency and reliability. · Improved spray system nozzles on belt wash systems to enhance spray pattern and cleaning efficiency and reduce water carryover on conveyor belts. · Improvements to operational reporting and monitoring capability in Dust Monitoring Dashboards. · Installation of the Finucane Island Hopper to reintroduce product into the supply chain. Aimed at reducing the volume of spillage material having to be stockpiled. · Reduction in static stockpiles on-site through mobile re-screening and loading into the plant. · Upgrades to the site water pipeline and improved piping specification to reduce impact of a pipe failure risk on water reliant dust controls. · Installed spillage curtains on conveyors to minimize ore spillage and potential dust emissions.
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· Improvements to Car Dumper 2 wet scrubber water recycling system. · Installation of cell dust cover in Car Dumper 2 and Car Dumper 4.
5.2.7. Amenity Based Improvements BHP has been undertaking work to enhance the amenity of the West End area for well over 10 years.
Key elements are: · West End Cleaning Program - The Program has been in place since 2008 and involves cleaning defined areas that the community and visitors enjoy accessing regularly e.g.; playgrounds, park infrastructure, main street of CBD. BHP manages the program as a local Indigenous Contracting opportunity tailored to support local Indigenous economic development.
· West End Amenity Improvements – BHP has spent over A$20M on amenity improvements, cultural programming and infrastructure in the West End over the past 10 years. Initiatives include o Park Improvements o Street-scaping, verge treatments & greening o Public art installations o West End Markets o Courthouse Gallery Refurbishment and associated programs o Port Hedland Visitors Centre o Silver Star café/restaurant o Outdoor events o The Web Business Hub
· West End Revitalisation Program – BHP has also committed an additional A$20M to help revitalise the West End over the next 5 years. Initial projects include: o A$3M West End greening program, focusing strongly on the CBD o Two Marapikurrinya Park ‘Pop-up’ shops delivered in partnership with the Town of Port Hedland o Repurposing two BHP owned properties, one as premises for the Port Hedland Men’s Shed Association and the other for the Port Hedland Chamber of Commerce to use to attract more businesses to the CBD
5.2.8. Proposed Additional Dust Controls The additional dust controls included with this licence amendment application (Table 4), are underpinned by a sound understanding of the underlying science and will add to a comprehensive hierarchy of existing dust management controls in place. The selection of these controls has been informed by world leading expertise and global benchmarking of dust management controls for bulk handling facilities. BHP’s proposed additional dust controls (Table 4) are grouped into packages that relate to the proposed projects as outlined in section 4.5.
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Table 4: Proposed Dust Control Packages
Package 1A Package 1B Package 2A Package 2B Package 2C
• South Yard belt • Finucane • South Yard Scope related Scope related wash stations Island Wind Wind Fence controls: controls: (P503 and Fence P505) Scope related • Stacker 14 • Car Dumper 6 • Sealing of open controls: luffing with enclosed with areas (Phase 1 boom sprays wet scrubber 1 extraction and & 2) • Reclaimer 11 • Automated collection fitted with boom stockpile water • Fogging units in sprays, system Car Dumpers cannons (X 1,2,3 (exit • Automated area) • Fogging unit in Car Dumper 6 conveyors) stockpile water • Belt wash (exit conveyor) cannons (F station (P770) • Vehicle area) • Belt wash emissions • Belt wash station (P236) reductions due station (P773) to reduction in site traffic1
1 Refer to Appendix 2 (GHD Air Quality Assessment Report)
5.2.9. Wind Fences BHP will further reduce potential stockyard emissions from its Port Operations with the use of wind fences. Wind fences are installed to control stockpile dust emissions in other parts of the world, including iron ore ports in Brazil and importing ports in Asia. BHP will develop the wind fences to withstand extreme cyclonic (Category D) weather events experienced in Port Hedland.
Wind can cause erosion on stockpiles and enable the iron ore dust-particles to become airborne. Wind fences slow the wind speeds and prevent the dust becoming airborne, controlling potential dust lift-off from stockpiles.
To be effective in shielding stockyards and reducing wind speeds, the wind fences are located up-wind and as close as practical to the open stockyard. BHP’s wind fence design incorporates learnings from other existing installations and has been tailored for Port Hedland conditions. The wind fence will be higher than the stockpile height1, with a mesh porosity of approximately 50%. The mesh porosity allows some of the wind to pass through the mesh. This reduces the wind turbulence downstream of the wind fence, as opposed to a solid wind fence, which increases downwind turbulence, resulting in increased dust.
Designing a ‘fixed’ mesh wind fence to resist a cyclonic wind speed of 88 ms-1 is not practical due to the extreme wind loading that the structure would have to withstand. Therefore, BHP will deploy a ‘release’ mesh system to limit the force applied to the structure by the mesh in these conditions. Release clips and locking strips secure the wind mesh at the bottom and sides of each curtain panel. During normal operation, all the clips and locking strips are in place and the wind loading is absorbed by the installation.
An optimal design wind speed of approximately 40 ms-1 has been selected as the point at which the mesh will release additional load applied to the structure. Once this design wind speed is reached, the mesh begins to unclip along its bottom and side edges progressively to allow the wind to spill through the wind fence. This will allow the curtain to flap in the wind and prevent the full wind load being transferred to the support structures during high wind events, preventing the structure from potentially collapsing.
BHP has four stockyards in Port Hedland; two located at Finucane Island (East Yard and West Yard) and two at Nelson Point (North Yard and South Yard). It is proposed to develop one wind fence at Finucane Island (FI) that reduces the potential for dust lift-off from both East Yard and West Yard (Package 1B) and another wind fence for Nelson Point that reduces the potential for dust lift-off from South Yard (Package 2A).
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View A – Finucane Island Wind Fence View B – South Yard Wind Fence
Figure 16: Proposed Wind Fence Location and Extent Dust control package 1B - Finucane Island Wind Fence: Installation of two sections of wind fence with a total length of ~1,100 metres and height between 24 to 31 metres (LHS of Figure 16).
Dust control package 2A – South Yard Wind Fence: Installation of one continuous wind fence with a total length of ~800 metres and height between 24 to 28 metres (RHS of Figure 16).
Computation Fluid Dynamic Modelling (Figure 17) indicates significant potential reductions in stockpile wind erosion with a wind fence in place, with the cooler colours showing slower wind speed and the warmer colours showing higher wind speeds.
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Figure 17: Finucane Island Wind Fence modelling results from Computation Fluid Dynamics method 5.2.10. Air Quality Assessment
5.2.11. Overview of Dust Model BHP has engaged GHD to undertake an air quality assessment to determine potential dust emissions associated with the proposed changes to BHP’s Port Operations and the benefit of the additional dust control measures. Refer to Appendix 2 (GHD Air Quality Assessment Report).
This assessment used the AERMOD dispersion model and adopted a methodology consistent with the air quality assessment provided previously to DWER in support of BHP’s 290Mtpa licence amendment application.
During 2014 and 2015, the Port Hedland Industries Council (PHIC) undertook an extensive cumulative air model (CAM) validation project, which was reviewed by DWER’s Air Quality Branch. This project determined that both AERMOD and CALPUFF dispersion models are suitable to use in determining the potential air quality impacts from industrial sources in Port Hedland.
The air quality assessment for this licence amendment application was completed using AERMOD to remain consistent with BHP’s previous assessment and other proponents in the region, particularly FMG and Roy Hill, which have recently used AERMOD for their approvals applications.
Consistent with the PHIC CAM, the dispersion modelling has used meteorological and background dust data from 2013 (PEL, 2016) and includes the cumulative emission estimations for the approved throughput of Pilbara Ports Authority (PPA), Fortescue Metals Group, Roy Hill and North West Iron Ore Alliance. The model is used to predict ground level PM10 concentrations at discrete receptors in Port Hedland (Figure 18).
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Figure 18: Dust Model Receptor Locations Refer to Appendix 2 (GHD Air Quality Assessment Report) for further information on the dispersion model configuration. 5.2.12. LiDAR BHP understands that LiDAR (Light Detection and Ranging) technology is of interest to the community and the regulator. LiDAR is a remote sensing technique that provides an approximation of particulate matter concentrations refracting through a laser pulse beam. LiDAR results can be calibrated to dust monitors to improve accuracy, but cannot differentiate between different forms of particulates e.g. dust, salt, water or other suspended particles, the size of particles or provide an accurate measurement of particulate concentrations.
In a naturally arid environment such as Port Hedland – with a range of industrial, natural and other background dust sources all potentially contributing to overall dust levels – attributing the source of dust can be complex. Consideration needs to also be taken in how LiDAR data is filtered and displayed (i.e. colours enhanced) to avoid misrepresenting the relative proportion of industry and other dust sources.
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BHP has considered results available from previous LiDAR campaigns conducted in Port Hedland including the results published by DWER from the short-term air quality monitoring campaign conducted in 2017 (Mapping dust plumes at Port Hedland using a LiDAR, Technical series - Report No. 2 February 2018). Information from these campaigns has been considered where relevant, as part of our continuous improvement approach to dust control on-site, as well as the design of the proposed dust control package for the works the subject of this licence amendment application.
Notwithstanding the role that LiDAR can play in contributing to an overall understanding of dust emissions in Port Hedland, BHP continues to favour the use of proven dust monitoring equipment that can accurately determine levels of the PM10 dust fraction, for measuring the effectiveness of dust controls. 5.2.13. Potential Emission Sources Since 2001, BHP has undertaken extensive site-specific measurement of potential dust emission sources across its Port Operations. As part of establishing the original dust model for BHP’s Port Operations, an intensive dust measurement program was conducted over a number of months. Field investigations included the measurement and ranking of dust emissions including from:
· Operational plant such as transfer stations, re-screening and shiploaders; · Stockpile operations such as stackers and reclaimers; · Wind erosion off stockpiles and open areas; and · Vehicle movements.
Dust emissions were measured under various meteorological conditions for the full range of ore types being handled by the operations and various ore moistures. Empirical relationships were determined for the dust generated for each source as a function of ore type, moisture content and wind speed.
An additional dust measurement program was undertaken in 2004, to ensure that emission estimates and assumptions made in the original assessment were still valid and that the empirical relationships were also still valid. The model was then validated against observed dust concentrations from the Port Hedland monitoring stations.
These measurements have continued to be updated over time to reflect changes in the operations and equipment on-site. Further dust measurement programs were undertaken in 2011, to ensure that the emission estimates, assumptions and the empirical relationships used in the modelling were still valid.
More recently, in addition to these measurement programs, monitoring data from BHP’s extensive operational dust monitoring network on-site was also assessed to improve the understanding of potential dust emission sources.
The purpose of these programs is to maintain an updated emissions inventory for the operations and to derive and improve over time, source-specific emission factors for equipment (train unloading, conveying, transfer stations, stacking, reclaiming, ship loading) and other potential dust sources including stockpiles and vehicle traffic on-site.
The site-specific measurements are also used to quantify and validate the effectiveness of dust controls on- site. These inputs also assist with updating the dispersion modelling used to predict potential air quality impacts. The methodology used to undertake the dispersion modelling is contained in Appendix 2 (GHD Air Quality Assessment Report). 5.2.14. Updates to the Dust Model for 330Mtpa BHP has continued to work on improving the inputs into its dispersion model to ensure it remains reliable and adequately reflects potential dust sources within BHP’s Port Operations. This focus on continuous improvement has resulted in the following three key enhancements to the dispersion model for this licence amendment application:
· Stockpile emissions estimates in the model were increased, based on detailed analysis of BHP’s boundary monitoring data, to better reflect the current site conditions.
· Adjustments to the model were made to reflect updated Dust Extinction Moisture (DEM) values for BHP’s products, based on quarterly testing conducted between 2014 and 2019. In addition, adjustments were made to align with current ore moisture requirements in BHP’s operating licence (L4513/1969/18).
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· The open area sources were updated in the model to better reflect the current site conditions.
Refer to Appendix 2 (GHD Air Quality Assessment Report) for further information on the improvements to BHP’s dust dispersion model.
5.2.15. Air Quality Assessment Criteria The air quality criteria used for the dust assessment (Appendix 2) supporting this licence amendment application, has been derived from the factsheet released by the Department of Water and Environmental Regulation (DWER) and the Department of Health (DoH) titled: Industry Regulation Fact Sheet: Managing Dust in Port Hedland (DWER and DoH, 2018), specifically:
Applicants will be encouraged to demonstrate no net increase to dust emissions in Port Hedland from port related activities. Where this isn’t demonstrated, DWER will consider further controls that may in part serve to offset any increase in dust emissions.
Furthermore, the criteria contained in the State Government endorsed Port Hedland Dust Management 3 Taskforce recommendation that: the current interim guideline of 24-hour PM10 of 70μg/m continues to apply to residential areas of Port Hedland, has also been considered in the dust assessment, with the results presented against the regulatory monitoring location at Taplin Street in Port Hedland.
5.2.16. Summary of Dust Assessment Results The extensive dust control package (outlined in section 5.2.4) is predicted to deliver a material reduction in BHP’s potential contribution to dust concentrations across all receptors in Port Hedland, including over 20% in the West End (Figure 19).
3 Figure 19: Reduction in modelled annual average PM10 (µg/m ) contribution (BHP only)
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Dust modelling supporting the current licence amendment application also predicts (Table 5) for BHP only (without background or other industry):
· BHP’s annual average PM10 concentrations at the regulatory monitoring location (Taplin Street) will reduce by up to 16% compared to a 290Mtpa base case. The maximum concentration will also reduce. · The proposal does not result in any exceedances of the interim air quality criteria (>70µg/m3 24-hour average) at Taplin St. Table 5: Modelled Dust Concentrations at Taplin St (BHP only)
3 Result - PM10 (µg/m ) 290Mtpa (Base Case) 330Mtpa (Future)
Maximum (daily) 68 52
Average (annual) 5.8 4.9
>70 (days) 0 0
For more information on the dust assessment results refer to Appendix 2 (GHD Air Quality Assessment Report).
Noise Emissions BHP’s Port Operations are located adjacent to the Town of Port Hedland. Due to historical land use planning, there is limited buffer between industry and residential areas. Environmental noise at BHP’s Port Operations is managed in accordance with an Environmental Noise Reduction Management Plan (ENRMP). The ENRMP includes several management measures such as noise monitoring, noise modelling, noise equipment specifications, operational and maintenance processes and noise reduction specific activities.
5.3.1. Noise Model BHP has developed and maintains a comprehensive Port Operations noise model, which allows noise levels to be predicted and managed. The existing facilities are dynamic operations, and as a result, the noise model has the capability of importing dynamic data sets such as SCADA (i.e. equipment data) and live weather to ensure that the model is as representative as possible of the actual operations for validation purposes. Additionally, noise source levels are changing over time due to wear and tear of noise emitting infrastructure and maintenance activities.
Consequently, the model is updated periodically with the latest measured noise source levels, to ensure that model accuracy remains current and representative of actual noise levels. Figure 20 shows the key noise receptors used in the 330Mtpa noise assessment and are consistent with previous noise assessments in Port Hedland.
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Figure 20: Location of Noise Receivers (South Hedland and Port Hedland) Each major equipment item included in this licence amendment application has been modelled, so that noise sources can be identified, and appropriate noise controls can be determined. Refer to Appendix 3 (Talis Noise Assessment Report) for a full list of the proposed new equipment.
5.3.2. Monitoring and Model Validation An ongoing noise monitoring and model validation program has been undertaken twice each year since 2008. The objective of this monitoring is to assess the levels of noise emissions outside the premises and to maintain a current and accurate model with which to assess BHP’s noise levels. It involves two distinct phases:
· Site measurements: For this component, noise source measurements of equipment items are taken on-site. These measurements are used to confirm the Sound Power Levels (SPLs) of equipment included in the model, as well as to evaluate if equipment noise levels are changing.
· Validation and Monitoring Measurements: Measurements are taken throughout the Town of Port Hedland at locations where noise from BHP’s Port Operations may be audible. These measurements are then used to validate the model (i.e. how accurate the model is predicting), to measure the potential contribution of noise from BHP’s Port Operation on surrounding areas and inform BHP’s noise management.
5.3.3. Equipment Noise Specifications BHP has established an internal noise equipment specification, which provides the acceptable maximum noise levels emitted and noise testing methods for new and modified stationary plant equipment, mobile equipment and living areas. The objective of BHP’s noise control specification is to minimise noise exposure to employees and minimise environmental noise impacts.
5.3.4. Operations and Maintenance The noise management philosophy adopted by BHP in its maintenance program at its Port Operations is to utilise the noise monitoring program to assess noise sources. Maintenance actions and upgrades are prioritised accordingly. Some of the typical noise management strategies include:
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· Planned Maintenance: identify and replace faulty equipment, change noisy conveyor idlers for low- noise idlers. Ensure silencers on air handling systems maintain their efficiency and installing sound barriers on new equipment such as fans. · Treatment: where required install noise barriers and louvres to transfer stations, drives and covering for elevated conveyors.
5.3.5. Upgrades and Major Works Considering the location of the Port Operations, the diversity of noise sources and the proximity and spread of surrounding, more sensitive land uses, makes the control of noise emissions from the Port Operations a complex undertaking. As a result, it is necessary to use a reliable and accurate predictive model to determine noise mitigation measures that are required to achieve BHP’s noise objectives and inform the design of new equipment or modification of existing infrastructure.
Adopting this approach has resulted in continuous noise improvements in the Port Operations. This has been achieved through modification of existing infrastructure, as well as through specific reduction measures installed on new plant and equipment. The noise control opportunities for both new and existing equipment are assessed as part of the environmental noise assessment process for proposed upgrades and major works. Refer to Appendix 3 (Talis Noise Assessment Report) for further information on the noise assessment methodology.
An ‘As Low as Reasonably Practicable’ (ALARP) process has been developed to assist in the selection of appropriate noise control measures for implementation. The ALARP process assesses noise attenuation options against specific criteria, including: · Noise abatement potential; · Safety; · Reliability; · Maintainability; · Operability; and · Life cycle costs.
Upon completion of a significant project, the predicted noise levels are measured to ensure that the noise criteria (including assumed manufacturer specification for equipment as applied in the model) have been met and to validate the model for the next project. If this verification testing identifies noise levels higher than manufacturer specifications or sources that cause unacceptable levels, then further mitigation measures will be investigated and prioritised.
5.3.6. Summary of Additional Noise Controls Following the processes defined in the ENRMP, the noise assessment identified a number of noise sources proposed as part of the works the subject of this licence amendment application, which will require noise controls. These controls include:
· Hybrid Ultra Low Noise Idler (ULNI-H) configurations on both new and selected existing conveyors. · Drive shielding. · Integration of noise controls into the design of Car Dumper 6 and associated dust extraction and ventilation system, including enclosures and noise panels. Refer to Appendix 4 for a full list of the proposed additional controls. To ensure that the reduction of each of the proposed noise controls are validated, various studies have been undertaken to quantify and understand the reduction. Some of these studies include the following:
· Long-term measurement of various conveyor idlers including low noise idlers, aimed at determining which idlers provide the best noise reduction over an extended period of time. The trial included the evaluation of the rollers noise levels, reliability, maintainability, and failure modes. This resulted in the selection of a roller configuration that is now classed as Ultra Low Noise Idler Hybrid (ULNI-H). ULNI- H fulfils all the requirements evaluated during the trial, including noise level reduction and reliability.
· Biannual field noise measurements, which are used to visually inspect and measure existing shielding and barriers.
· Field measurements of conveyors with varying belt widths and speeds to understand the relationship between these factors and the noise produced by the conveyor.
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5.3.7. Summary of Noise Assessment Results Noise modelling supporting this licence amendment application (with the additional noise controls outlined in Appendix 4) predicts a no net increase in potential noise levels from BHP’s Port Operations.
For further details, refer to the noise assessment (Appendix 3 - Talis Noise Assessment Report).
Figures 21 and 22 below outline the locations of noise controls (existing and proposed) within the Port Operations.
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Figure 21: Finucane Island – Noise Controls (existing and proposed)
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Figure 22: Nelson Point – Noise Controls (existing and proposed)
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5.3.8. Construction Noise If required under the Environmental Protection (Noise) Regulations 1997, BHP will prepare a Construction Noise Management Plan (CNMP) for submission to the Town of Port Hedland prior to construction.
Discharge to Land and Water
5.4.1. Relocation of Freshwater Recovery Pond BHP currently operates freshwater recovery plants (FWRP) at Finucane Island and Nelson Point, to remove sediment from water prior to reuse on site or discharge to approved discharge locations at Finucane Island and Nelson Point.
During the construction of the South Yard Expansion - Stage 2, the FWRP pond will need to be relocated to allow for the new stockyard and infrastructure. The indicative location of the FWRP pond is identified in Figure 4.
5.4.2. Potential Acid Sulfate Soils The proposed upgrades associated with the additional stockyards, wind fences and CD6 will require ground improvements or excavation which may require dewatering. Prior to dewatering, BHP will seek an approval for dewatering should it be required under the Rights in Water and Irrigation Act 1914.
As potential acid sulfate soils are known to be present in Port Hedland, any soils excavation and groundwater dewatering that may be required to support the proposed works, will be managed (where required) in accordance with DWER’s Guideline, Treatment and management of soil and water in acid sulfate soil landscapes (DER, 2015).
5.4.3. Contaminated Sites BHP has identified potential contaminated sites at Nelson Point and Finucane Island. These sites are registered with the Contaminated Sites Branch of DWER, in accordance with the Contaminated Sites Act 2003. A number of the proposed upgrades may have the potential to disturb these contaminated sites. BHP will manage contaminated groundwater and soil in accordance with the Contaminated Sites Act 2003.
6. Environmental Management The environmental aspects of BHP’s Port Operations are managed under the company’s ISO14001 certified Environmental Management System (EMS). The EMS describes the organisational structure, responsibilities, practices, processes and resources for implementing and maintaining environmental objectives at all of BHP’s WA Iron Ore sites.
Additionally, operational controls for environmental management are guided by BHP’s Charter Values. The Charter Values outline a commitment to develop, implement and maintain management systems for sustainable development that drive continual improvement and set and achieve targets that promote efficient use of resources. In order to give effect to the Charter Values, a series of “Our Requirements” documents have been developed, which outline the minimum, mandatory requirements for environmental management across BHP. BHP has also developed a Sustainable Development Policy for its WA Iron Ore operations. The Sustainable Development Policy outlines a commitment to setting objectives and targets to achieve sustainable outcomes and to continually improve our performance.
To support these documents, BHP has an internal Project Environmental and Aboriginal Heritage Review (PEAHR) system. The purpose of the system is to manage implementation of environmental, aboriginal heritage, land tenure and legal commitments prior to and during land disturbance. All ground disturbance activities will meet the requirements of the PEAHR system.
7. Conclusion
BHP proposes to undertake upgrades to existing equipment at Finucane Island and Nelson Point to increase the production capacity of existing infrastructure through route upgrades/productivity initiatives and through the installation of new infrastructure (major works) at Nelson Point, to increase overall throughout capacity from 290Mtpa to 330Mtpa.
BHP remains committed to continuing to manage potential dust and noise emissions with this licence amendment application. As demonstrated through this application, BHP’s effectively applies the hierarchy of control to provide a comprehensive approach to managing dust and noise emissions, which extends across all potential emission sources within its Port Operations.
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BHP has also assessed dust management practices at other Australian and International bulk commodity operations and sought input from air quality experts and the operational teams who live and work in Port Hedland, to design the additional dust and noise controls included in this licence amendment application. With the proposed growth in throughput capacity to 330Mtpa, the extensive dust and noise control packages proposed with this application are designed to deliver a material reduction in BHP’s potential contribution to dust concentrations across all receptors in Port Hedland and no increase in potential noise emissions from the premises.
BHP considers that the proposed amendment to L4513/1998/18 will not introduce unacceptable emissions or discharges during construction or operation.
8. Other Relevant Information
Community Complaints
A community complaints process is implemented by BHP to manage complaints associated with its operations in accordance with conditions 28 and 29 of Licence L4513/1989/18. A dedicated Community Contact Line is maintained to receive complaints 24 hours a day, 7 days a week. Complaints can also be made to a dedicated email. Complaints are logged into the SAP work management system, and actions assigned to appropriate BHP person. Complaints are also captured in BHP’s complaints register.
A review of complaints recorded by BHP since 2018, indicate that only two environmental complaints were received with one related to noise and one related to harbour discharge.
Stakeholder Consultation BHP has well established mechanisms to communicate regularly and to maintain a regular and ongoing dialogue with key stakeholders. Established mechanisms include:
1. Stakeholder Engagement Groups (SEG) in Port Hedland and Newman – held quarterly, the BHP Stakeholder Engagement Group (SEG) is an innovative forum for Pilbara stakeholders to engage on BHP related issues and have input into some aspects of planning for our operations;
2. Joint Technical Working Groups (LGA/BHP) in Port Hedland and Newman – held monthly, the JTWGs focus on open dialogue, mechanism for consultation, dealing with issues of mutual interest, raising concerns or discussing opportunities for collaborative initiatives and projects;
3. Pilbara Newsletter – published 3-4 times/year, the Pilbara Newsletter focuses on sharing information and raising public awareness of topical issues e.g.; air quality, port, rail, mines;
4. Site Tours for community stakeholders – An open invitation to any interested stakeholders or community groups;
5. Hedland Collective - Mechanism to engage collaboratively with State & Local Government and key Community organisations on joint planning, key priorities and key community issues that require collaborative effort; and
6. Port Hedland Industries Council (PHIC) – BHP is a member of PHIC and works collaboratively with other port users across areas of Air Quality, Noise, Marine and Community & Stakeholder Engagement for the benefit of the Port Hedland Community.
Building on these established mechanisms, for the purposes of ensuring comprehensive communication and engagement specifically with respect to this licence amendment application, a comprehensive Communications and Stakeholder Engagement Plan was implemented.
As part of this plan, a specific licence amendment consultation slide-pack was developed and shared with all stakeholders (Refer Appendix 5). The pack was shared with all stakeholders listed below (Table 7), and where online or face-to-face meetings have occurred, the pack was shared in advance of these sessions to allow stakeholders sufficient opportunity to review content.
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Table 6: Stakeholder Engagement Date of Method of Organisation Position/Stakeholders Engagement Engagement PORT HEDLAND / COMMUNITY Commissioner 29/4/2020 Face to Face Town of Port Hedland Chief Executive Officer with direct 05/05/20 Webex reports BHP Port Hedland Stakeholder Engagement Key BHP Community Stakeholders 5/05/2020 Webex Group Port Hedland Chamber of PHCCI Committee and Chief Face to Face + 4/05/2020 Commerce and Industry Executive Officer Webex Port Hedland Community PHCPA Committee 6/05/2020 Webex Progress Association Chief Executive Officer 12/05/2020 Webex PHIC Member Representatives 12/05/2020 Webex (Management Committee) Port Hedland Industries PHIC Member Representatives Ms Teams Council (Community & Stakeholder 12/05/2020 Meeting Engagement Working Group) MS Teams PHIC Key Stakeholders 13/05/2020 Meeting Care for Hedland Association Care for Hedland Association 7/05/2020 Webex Committee Port Hedland Ratepayers Association 4/05/2020 Face to Face Port Hedland Ratepayers Committee (Meeting 1) Association Port Hedland Ratepayers Association 14/05/2020 Face to Face Committee (Meeting 2) Karriyarra Aboriginal Chief Executive Officer 11/05/2020 Email / Phone Corporation Banjima Aboriginal Chief Executive Officer 16/6/2020 Phone Corporation Nyiyaparli Aboriginal Chief Executive Officer 16/6/2020 Email/Phone Corporation Pilbara Development Chair 1/05/2020 Face to Face Commission Chief Executive Officer Pilbara Ports Authority Chief Executive Officer 15/05/2020 Webex
Shire of East Pilbara President 24/04/2020 Phone
GOVERNMENT AGENCIES
Director General; Executive Director Department of Water and Regulatory Services; Director 24/04/2020 Email Environmental Regulation Regulatory Services
Director General; Executive Director Department of Water and Regulatory Services; Director 9/03/2020 Face to Face Environmental Regulation Regulatory Services
Department of Water and Licensing Officers, Air Quality and 28/11/2019 Face to Face Environmental Regulation Noise Branch Officers.
Department of Water and Licensing Officers, Air Quality and 5 & 6/5/2020 Webex Environmental Regulation Noise Branch Officers.
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Date of Method of Organisation Position/Stakeholders Engagement Engagement Department of Health (Environmental Health Manager Clinical Hazards 13/05/2020 Email/Phone Directorate) WA Country Health Service Chief Executive Officer 30/04/2020 Email WA Country Health Service Regional Director 30/04/2020 Email (Pilbara) Department of Jobs, Tourism, Director 24/04/2020 Email Science and Innovation
STATE PARLIAMENT Date of Method of Party Position Stakeholder Engaged Engagement Engagement Advisor/s, Minister's Labor Party Minister for Environment 24/04/2020 Email / Phone Office Minister for Ports; Advisor/s, Minister's Labor Party 24/04/2020 Email Regional Development Office Labor Party Member for Pilbara Member for Pilbara 24/04/2020 Email / Phone Minister for Mines and Advisor/s, Minister's Labor Party 24/04/2020 Email / Phone Petroleum Office Premier; Minister for Advisor/s, Minister's Labor Party 24/04/2020 Email State Development Office Liberal Leader of Opposition Leader of Opposition 4/05/2020 Email Party Liberal Chief of Staff Chief of Staff 4/05/2020 Email Party Liberal Shadow Minister for Shadow Minister 4/05/2020 Email Party Environment Liberal Shadow Minister for Shadow Minister 4/05/2020 Email Party Mines and Petroleum Liberal Shadow Minister for Shadow Minister 4/05/2020 Email Party Ports Liberal Shadow Minister for Shadow Minister 4/05/2020 Email Party Transport WA National Member for National Mining and Pastoral WA National Member 8/05/2020 Email Party Region WA Green Member for Greens Mining and Pastoral WA Green Member 8/05/2020 Email Party Region
9. Fee Calculation A fee of $9,520.00 is applicable to this licence amendment application. Table 7: Calculation of Application Fee
Largest Category Site Capacity Fee Units Unit Cost Licence Fee Category 58 More than 50,000 tonnes per year 1,400 $6.80 $9,520.00
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10. References
DER, 2015, Treatment and management of soil and water in acid sulfate soil landscapes. Department of Environment Regulation, Perth, Western Australia. DWER, DoH, 2018, Industry Regulation Fact Sheet: Managing Dust in Port Hedland, Department of Water and Environmental Regulation and Department of Health (WA), Perth Western Australia. DWER, 2018, Mapping dust plumes at Port Hedland using a LiDAR, Technical series - Report No. 2 February 2018, Department of Water and Environmental Regulation, Perth Western Australia DJTSI, 2016, Port Hedland Dust Management Taskforce Report to Government. Department of Jobs Technology, Science and Innovation, Perth, Western Australia. DSD, 2010, Port Hedland Dust Management Taskforce Air Quality and Noise Management Plan, Department of State Development, Perth Western Australia. GHD, 2013, Environmental Best Practice Port Development, report prepared for the Department of Sustainability, Environment , Water, Population and Communities, Canberra, Australia. GHD, 2020, BHP Billiton Iron Ore Pty Ltd, Port Hedland Port Operations - 330Mtpa Licence Application, Air Quality Assessment, GHD, Perth Western Australia PEL, 2016, Air Quality Assessment – 290Mtpa, BHP Billiton Iron Ore Port Operations, Pacific Environment Limited, Perth, Western Australia. PPA, 2013, Dust Management Leading Practice Guidelines, Pilbara Ports Authority, Perth, Western Australia Talis, 2020, Port Operations 330Mtpa Environmental Noise Assessment prepared for BHP, Talis, Perth Western Australia, WAPC, 2019, Improvement Plan No. 50: Port Hedland West End, Western Australian Planning Commission, Perth Western Australia
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11. IR-F09 Application Form Attachments The completion matrix below has been sourced from DWER’s IR-F09 Application Form - Works Approval, Licence, Renewal Amendment, Registration (Apr 2020, v12). The completion matrix defines the information required for different types of applications. Table 9 below details the sections of this document where the attached information required in the IR-F09 Application Form is included in this document. Table 8: Summary Attachment for IR-F09 Application Form (Specific to an amendment)
Application Form Requirement Supporting Document Reference
Attachment 2: Premises map/s Figure 1
Attachment 3B – Proposed activities Section 4
Attachment 5 – Other approvals and consultation Section 6, Appendix 5
Attachment 6A - Emissions and discharges Section 5, Appendix 1 to 4
Attachment 7: Siting and location Figure 1
Attachment 8: Additional information submitted Appendix 1 to 5
Attachment 9: Proposed fee calculation Section 7
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Appendix 1: Comparison of BHP controls against PPA Leading Practice Guidelines
Activity Leading Practice Example Implemented by BHP Uploading Moisture Control Moisture control of raw material to DEM BHP implementing a whole of product chain moisture improvement project to improve ore moisture from Pit to Port. Engineering Exposure to wind minimised In-loaded iron ore is unloaded through its car dumper infrastructure. Designs Conveyors The car dumpers are fitted with dust extraction and wet scrubbers Hoppers A negative pressure is maintained during in loading of ore. Bottom or top unloaded Car dumpers fully enclosed and fitted with dust extraction Equipment Dust collection system installed The car dumpers are fitted with dust extraction and wet scrubbers
Stacking Moisture Control Moisture control of raw material BHP implementing a whole of product chain moisture improvement project to improve ore moisture from Pit to Port. Bulk ore conditioning sprays are used to apply additional water to iron ore products that are below the DEM. Automated water cannons on its stockpiles.
Engineering Drop height (minimise) Stackers (luffing) installed in stockyards can reduce drop heights to reduce dust Designs potential for emissions. Stockpile formation, design, size New proposed wind fences to provide wind shielding to stackers at Finucane Island and South Yard. Equipment Water spray method on stockpiles Automated water cannons on stockpiles can be operated remotely to apply additional water in response to increase in wind conditions and potential dust emissions. Luffing/slewing type stackers to reduce drop height Stackers (luffing) installed in stockyards can reduce drop heights to reduce dust emissions. Luffing/slewing type stackers fitted with water sprays on the boom Boom sprays are fitted and operated to stackers at BHP’s Port Operation.
Practices Automation and application of wetting agent relative to current BHP currently uses a real time (10 min) dust dashboards to monitor wind weather measurements and forecast conditions and potential dust emissions, which enable BHP to implement dust controls as required to minimise dust.
Application of surface treatments to bind loose fine surface BHP applies suppressants to static stockpiles, to prevent the potential dust lift off material under adverse weather conditions e.g. water trucks associated with wind erosion.
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Activity Leading Practice Example Implemented by BHP
Stockpiles Moisture control Moisture control of raw material BHP implementing a whole of product chain moisture improvement project to improve ore moisture from Pit to Port. Bulk ore conditioning sprays are used to apply additional water to iron ore products that are below the DEM. Automated water cannons on its stockpiles. Engineering Shielding stockpiles from prevailing winds – wind fences or berms New proposed wind fences to provide wind shielding and reduce potential design Orientation of stockpiles (long direction and perpendicular to stockpile lift-off. prevailing wind) Enclosed stockpiles Equipment Water cannons used on all stockpile areas Automated water cannons on stockpiles that can be operated remotely to apply additional water in response to increase in wind conditions and potential dust emissions. Practices Automation of and application of wetting agent/surface wetting BHP currently uses a real time (10 min) tool to monitor wind conditions and relative to current weather measurements and forecast potential dust emissions, which enable BHP to implement dust controls as required to minimize dust. Application of surface treatments to bind loose fine surface BHP applies suppressants to static stockpiles, to prevent the potential for dust lift material under adverse weather conditions e.g. water trucks off associated with wind erosion. Reclaiming Moisture control Moisture control of raw material at Stockpile BHP is implementing a whole of supply chain moisture system to manage ore Use of wetting agents on stockpile moisture from Pit to Port. Bulk ore conditioning sprays are used to apply additional water to iron ore products that are below the DEM. Automated water cannons on its stockpiles. Engineering Shielding in use on equipment Bucket wheel reclaimers are installed with boom sprays around the bucket. design Stockpile traversing BHP operates rail mounted bucket wheel reclaimers, as such vehicular movement Distance and speed travelled by vehicles over stockpiles and is not as significant as in a dozer reclaimed operation. Only the static ore empty stockyards stockpiles require the use of a dozer. New proposed wind fences to provide wind shielding to reclaimers at Finucane Island and South Yard. Sealed road v’s unsealed roads Stacker and BWR access roads at NP and FI sealed Equipment Disturbance of the stockpile can be minimised by the method of BHP operates bucket wheel reclaimers, which include boom sprays to minimise reclaiming e.g. bucket wheel, dozers dust during reclaiming. Mechanical preparation of the stockpile for reclaiming and Reclaiming Design of bucket system
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Activity Leading Practice Example Implemented by BHP Use of dozers Only the static ore stockpiles require the use of a dozer. Static stockpiles are treated with a suppressant. Practices Clean up of spillages Ore spillage is removed and stockpiled for future reclamation. Static stockpiles are treated with a suppressant. Conveyors and Transfers Moisture control Moisture control of raw material - Water application (up to the BHP is implementing a whole of supply chain moisture system to manage ore DEM) i.e. surface treatment at each point of disturbance and on moisture from Pit to Port. each exposed conveyor Bulk ore conditioning sprays are used to apply additional water to iron ore products that are below the DEM.
Engineering Wind shielding of conveyors/Belt launders. Wind shielding is installed where possible design Equipment Integrated control systems to prevent overloading of conveyors to Fogging sprays are fitted to specific transfer stations. prevent spills Dust collectors also installed on specific transfer stations. Practices Belt washing stations Belt wash stations (BWS) are fitted to selected conveyors. Typically BWS are fitted to long conveyors. Clean-up of spills including under conveyors Belt scrapers and /or plough fitted to conveyors for preventing carry back. Work management strategies for under belt and transfer station cleaning. Wetting agent application Other control implemented Ship Loading Moisture control Fogging at point of loading BHP is implementing a whole of supply chain moisture system to manage ore moisture from Pit to Port. Bulk ore conditioning sprays are used to apply additional water to iron ore products that are below the DEM. Ship loaders are fitted with boom sprays and operated when vessels are being loaded. Equipment Ship loading booms are fitted with sprays at the loading chute Ship loaders are fitted with boom sprays and operated when vessels are being loaded Practices Automation of and application of wetting agent/surface wetting The ship loader height can be adjusted so that the drop heights from the ship relative to current weather measurements and forecast loader boom to the vessel hull is minimised where possible Application of surface treatments to bind loose fine surface material under adverse weather conditions
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Appendix 2: Dust Assessment Report (GHD, 2020) Appendix 3: Noise Assessment Report (Talis, 2020)
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