application for licence environmental protection act 1996 · 2019. 11. 13. · application for...

Yara Pilbara Nitrates Pty Ltd

Application for Licence Part V, Division 3, Environmental Protection Act 1996

Technical Ammonium Nitrate Plant Burrup Peninsula

17 October 2019

56928/123287 (Rev 1)

JBS&G Australia Pty Ltd T/A Strategen-JBS&G

©JBS&G Australia Pty Ltd T/A Strategen-JBS&G56928/123287 (Rev 1) ii

Table of Contents

Abbreviations ........................................................................................................................... v

1. Introduction ................................................................................................................... 1

1.1 Background .......................................................................................................... 1

1.2 Regulatory framework ......................................................................................... 1

1.2.1 Federal legislation - Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) ....................................................... 2

1.2.2 Part IV of the EP Act ............................................................................. 2

1.2.3 Part V of the EP Act .............................................................................. 5

1.2.4 Legislative framework for assessing and managing potential impacts on rock art (petroglyphs) ..................................................................... 5

1.2.5 Contaminated sites .............................................................................. 9

1.2.6 Department of Mines, Industry Regulation and Safety (DMIRS) ......... 9

1.2.7 Approvals summary ............................................................................. 9

1.3 Integrated Management of Yara Pilbara operations ........................................ 10

1.4 Purpose and scope ............................................................................................ 11

2. Attachment 1A: Proof of occupier status .................................................................... 13

3. Attachment 1B: ASIC company extract........................................................................ 15

4. Attachment 2: Premises maps ..................................................................................... 21

5. Attachment 3A: Activities ............................................................................................ 26

5.1 Process overview ............................................................................................... 26

5.1.1 Nitric acid plant .................................................................................. 26

5.1.2 Ammonium nitrate solution plant ..................................................... 27

5.1.3 TAN prilling plant ............................................................................... 27

5.1.4 Loading, bagging and storage ............................................................ 28

5.1.5 Wastewater containment infrastructure ........................................... 28

5.1.6 Utilities ............................................................................................... 30

5.1.7 Hazardous material storage ............................................................... 30

5.2 Key infrastructure .............................................................................................. 30

6. Attachment 6A: Emissions and discharges .................................................................. 32

6.1 Emissions to air .................................................................................................. 32

6.1.1 Air emissions from Part IV assessment and PER ................................ 32

6.1.2 Air emissions from 2012 assessment updates (post works approval) ........................................................................................................... 34

6.1.3 Air emissions assessment from commissioning data ........................ 35

6.1.4 Ammonia emissions from unit 12 and unit 31/32 vents ................... 36

©JBS&G Australia Pty Ltd T/A Strategen-JBS&G56928/123287 (Rev 1) iii

6.1.5 Cumulative emissions impact assessment – future (normal) operations .......................................................................................... 39

6.1.6 Best practice air emissions performance – normal operations ......... 40

6.1.7 Updated air emission impact assessment – (future) start-up operations .......................................................................................... 40

6.1.8 Monitoring of air emissions ............................................................... 41

6.2 Discharges to water ........................................................................................... 43

6.3 Fugitive emissions (dust) ................................................................................... 43

6.4 Groundwater monitoring .................................................................................. 44

6.5 Noise emissions ................................................................................................. 45

6.6 Risk assessment ................................................................................................. 47

7. Attachment 7: Siting and location ............................................................................... 51

7.1 Residential and sensitive premises ................................................................... 51

7.2 Specified ecosystems......................................................................................... 51

7.3 Climate ............................................................................................................... 52

7.4 Topography........................................................................................................ 52

7.5 Hydrology .......................................................................................................... 52

7.6 Geology and soils ............................................................................................... 53

7.7 Hydrogeology and groundwater ....................................................................... 53

Limitations ............................................................................................................................. 56

References ............................................................................................................................. 57

List of Tables Table 1.1: Relevant conditions of MS 870 ............................................................................... 3

Table 1.2: Existing State and Commonwealth mechanisms and agreements that provide for the protection of the rock art on Murujuga ..................................................... 6

Table 1.3: Approvals................................................................................................................. 9

Table 1.4: Prescribed premises categories ............................................................................ 11

Table 1.5: Supporting attachments........................................................................................ 12

Table 4.1: Premises coordinates (MGA 94, Zone 50) ............................................................. 21

Table 5.1: Key infrastructure.................................................................................................. 31

Table 6.1: Emission points to air ............................................................................................ 32

Table 6.2: Atmospheric emissions characteristic of normal operations of the TAN Plant (as considered in the EPA Assessment) ................................................................ 33

Table 6.3: Atmospheric emissions characteristic of non-routine operations of the TAN plant (as considered in the EPA assessment)........................................................... 34

Table 6.4: Ambient air quality criteria ................................................................................... 34

Table 6.5: Predicted ground level concentrations (including background) during normal operations of the TAN Plant (2012 Updated Modelling) ................................ 35

©JBS&G Australia Pty Ltd T/A Strategen-JBS&G56928/123287 (Rev 1) iv

Table 6.6: Predicted ground level concentrations during non-routine operations of the TAN Plant (2012 Updated Modelling) .................................................................... 35

Table 6.7: Predicted maximum ammonia GLCs from dispersion modelling of YPN emissions – future (normal) TAN operations .................................................................. 38

Table 6.8: Cumulative emissions assessment - predicted maximum GLCs from dispersion modelling of YPN and YPF emissions – future (normal) operations ............... 40

Table 6.9: BACT air emission discharge concentrations – normal operations ...................... 40

Table 6.10: Air emission limits in current licence – Nitric Acid Plant start-up ....................... 41

Table 6.11: Predicted maximum GLCs from dispersion modelling of NAP stack emissions – start-up operations ......................................................................................... 41

Table 6.12: Emissions monitoring conditions ........................................................................ 42

Table 6.13: MS 870 groundwater requirements.................................................................... 44

Table 6.14: Groundwater monitoring .................................................................................... 45

Table 6.15: Noise monitoring October 2018 to June 2019 .................................................... 47

Table 6.16: Risk assessment summary ................................................................................... 48

Table 7.1: Receptors and distance from prescribed activity ................................................. 51

Table 7.2: Environmental values ............................................................................................ 51

Table 7.3: Surface water receptors ........................................................................................ 53

Table 7.4: Groundwater receptors ........................................................................................ 54

List of Figures Figure 1.1: Company structure .............................................................................................. 10

Figure 1.2: Yara Pilbara management structure as relevant to the TAN Plant operations ... 11

Figure 5.1: Simplified TAN Plant process flow ....................................................................... 26

Figure 6.1: Noise monitoring locations (N1 to N4) ................................................................ 46

Figure 7.1: Sensitive receptors ............................................................................................... 55

Appendices Appendix A MS 870 revised conditions

©JBS&G Australia Pty Ltd T/A Strategen-JBS&G56928/123287 (Rev 1) v

Abbreviations

Term Definition ARI Average Recurrence Interval ATU Aerobic Treatment Unit BACT Best Available Control Techniques BMIE Burrup and Maitland Industrial Estates CALM Conservation and Land Management CEMS Continuous Emissions Monitoring System CEO Chief Executive Officer CGA Cylinder Gas Audit DEC Department of Environment and Conservation DGJS Deep Gorge Joint Statement DJTSI Department of Jobs, Tourism, Science and Innovation DMIRS Department of Mines, Industry Regulation and Safety DoEE Department of Environmental and Energy DPLH Department of Planning, Lands and Heritage DSI Detailed Site Investigation DWER Department of Water and Environmental Regulation EP Environmental Protection EPA Environmental Protection Authority EPBC Environment Protection and Biodiversity Conservation ERA Ecological Risk Assessment EQC Environmental Quality Criteria EQMF Environmental Quality Management Framework GLC Ground Level Concentration HDPE High Density Polyethylene MAC Murujuga Aboriginal Corporation MDEA Methyl Diethanolamine MHF Major Hazards Facility MRASRG Murujuga Rock Art Stakeholder Reference Group MS Ministerial Statement MUBRL Multi User Brine Return Line OEMP Operational Environmental Management Plan OMEMP Operational Marine Environmental Management Plan PER Public Environment Review RAP Remediation Action Plan RATA Relative Accuracy Test Audit STP Sewage Treatment Plant TAN Technical Ammonium Nitrate TN Total Nitrogen TP Total Phosphorous USEPA United States Environmental Protection Authority WA Western Australia YPF Yara Pilbara Fertilisers YPN Yara Pilbara Nitrates

©JBS&G Australia Pty Ltd T/A Strategen-JBS&G 56928/123287 (Rev 1) 1

1. Introduction

1.1 Background

Yara Pilbara Nitrates Pty Ltd (YPN) operates a Technical Ammonium Nitrate (TAN) Plant located on Lot 3017 Village Road on the Burrup Peninsula. The TAN Plant was first commissioned in 2016 and can produce 350,000 tonnes of TAN per year.

The TAN Plant was assessed under Part IV of the EP Act and is subject to conditions under Ministerial Statement (MS) 870.

The TAN Plant was constructed under Works Approval W4701/2010/1 granted by the Department of Water and Environmental Regulation (DWER) under Part V of the Environmental Protection Act 1986 on 25 July 2013. In February 2016, YPN submitted the compliance document required for the works approval certifying that the works had been constructed in accordance with the conditions of the works approval. Commissioning of the TAN Plant commenced on 22 February 2016, with extensions to the duration of the works approval granted on 23 June 2016, 10 November 2016 and 13 December 2017 to allow completion of commissioning and progress with a licence amendment process to allow the plant to be operated.

The TAN Plant currently operates under Licence L7997/2002/11 granted by DWER. Licence L7997/2002/11 was first issued on 21 April 2015 for the adjacent liquid ammonia plant (Ammonia Plant) operated by Yara Pilbara Fertilisers Pty Ltd (YPF). The licence was amended on 29 June 2018 to include the operation of the TAN Plant and Ammonia Plant under a combined licence (current licence).

The current licence will expire on 20 April 2020. Accordingly, a new licence application is required

Through this application, YPN is seeking a materially equivalent licence grant for the TAN Plant as presently authorised under the current licence. In effect, this will extend the current licence duration beyond the existing licence term of 20 April 2020. It is intended that the current licence (which licenses both the TAN Plant and adjacent Ammonia Plant) will be replaced by a separate licence for each of the TAN Plant and Ammonia Plant.

1.2 Regulatory framework

The EP Act is the principle legislation in WA that provides for “the prevention, control and abatement of pollution and environmental harm” and for “the conservation, preservation, protection, enhancement and management of the environment”.

The object of the EP Act is to protect the environment of the state, having regard to a number of principles, including:

1. The precautionary principle, which holds that where there are threats of serious or irreversibledamage, lack of full scientific certainty should not be used as a reason for postponing measuresto prevent environmental degradation. In the application of the precautionary principle,decisions are to be guided by:

a. careful evaluation to avoid, where practicable, serious or irreversible damage to theenvironment

b. an assessment of the risk weighted consequences of various options.

2. The principle of intergenerational equity, which holds that the present generation should ensurethat the health, diversity and productivity of the environment is maintained or enhanced for thebenefit of future generations.


3. The principle of waste minimisation, which holds that all reasonable and practicable measuresshould be taken to minimise the generation of waste and its discharge into the environment.

4. Principles relating to improved valuation, pricing and incentive mechanisms, which include the‘polluter pays principle’ whereby those who generate pollution and waste should bear the costsof containment, avoidance or abatement.

The object and principles guide the overall application of the powers of the EP Act, and have been considered in the preparation of this application.

1.2.1 Federal legislation - Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)

The TAN Plant proposal was determined to be a controlled action under the EPBC Act. Assessment of the proposal was undertaken under the bilateral agreement between the State and Commonwealth environment departments and conditional approval was issued on 14 September 2011 (EPBC 2008/4546). Variations to the approval were approved under the EPBC Act on 10 February 2014 and 12 September 2017. Conditions relate to:

• discharge criteria for wastewater discharged to the MUBRL with reference to requirementsof MS 594 for the Ammonia Plant

• restricted application of larvicide and adulticide

• deterring birds from entering water ponds

• protection of the Dampier Archipelago (including Burrup Peninsula) National Heritage Place(National Heritage Place) via the implementation of following management plans:

o Construction Environmental Management Plan

o Operational Environmental Management Plan

o Aboriginal Heritage Management Plan

o Hazardous Materials Management Plan

o Emergency Response Management Plan

• restricted access with respect to work carried out in the National Heritage Place

• requirements for undertaking ambient air quality monitoring for specific gases and dust fornot less than 24 months from the commencement of construction until the expiry of theapproval

• requirements for annual surveys of rock art with a 2 km radius of the Premises to identifyany changes to be undertaken either by Yara Nitrates or through the provision of an annualpro-rata amount for the Burrup Rock Art Monitoring Program.

1.2.2 Part IV of the EP Act

Under Part IV of the EP Act, the Environmental Protection Authority (EPA) is responsible for assessing proposals that have a significant effect on the environment and reporting to the Minister for Environment on whether proposals should be implemented. The EPA also recommends conditions to mitigate the detrimental impact on the environment that a proposal may cause.

The EPA is required to have regard for the objects and principles of the EP Act, outlined above, as a condition of the valid exercise of its powers to assess and report on proposals under Part IV of the EP Act. The EPA encourages the application of all reasonable and practical measures to minimise harmful emissions to air, which can include facility design, technology choice, operation and closure. ‘Reasonable and practical’ measures include those that are reasonably practicable, having regard to,


among other things, local conditions and circumstances (including costs) and the current state of technical knowledge.

The TAN Plant was assessed under Part IV of the EP Act and is subject to conditions under MS 870. The scope and details of EPA’s assessment of the TAN Plant proposal are detailed in EPA Report 1379 published in January 2011 (EPA 2011).

There have been two changes to the proposal under s 45C of the EP Act. The changes were:

1. Removal of 'Wastewater' from the key proposal characteristics table – approved on 9 July 2013.

2. Decrease in Development Envelope and disturbance area and removal of TAN storage capacity –approved on 7 June 2017.

MS 870 contains conditions relevant to the assessment of emissions and discharges from the TAN Plant as shown in Table 1.1.

Table 1.1: Relevant conditions of MS 870 Condition Requirement Delegated Officer consideration 1-1 The proponent shall implement the proposal as documented and

described in schedule 1 of this statement subject to the conditions and procedures of this statement.

Specifications detailed in Schedule 1 relate to the design capacity of the plant and specified rates for emissions to air. EPA Report 1379 recommends regulation of emissions under Part V of the EP Act; however, emissions rates are specified under the key characteristics table of MS 870 (Schedule 1).

5-1 The proponent shall adopt and implement best practice pollution control technology as determined by the Chief Executive Officer of the Department of Environment and Conservation (DEC) on advice of the CEO to minimise all relevant emissions from the TAN prilling plant.

The assessment of best practice pollution control focuses on point source emissions to air rather than fugitive dust sources.

5-2 Prior to construction, the proponent shall prepare and implement an ambient air monitoring programme to the satisfaction of the CEO on the advice of the Chief Executive Officer of the DEC.

8-3 The proponent shall design, construct, and locate groundwater monitoring bores to the satisfaction of the CEO on advice of the DEC and the Department of Water, having regard for the outcomes of the hydrogeological studies required by condition 8-1 and the Department of Water’s Water Quality Protection Note 30 on Groundwater Monitoring Bores.

Groundwater monitoring requirements under MS 870 have been considered in determination of risk associated with potential emissions and discharges.

8-4 The proponent shall sample/monitor all groundwater bores required by Condition 8-3 every six months and shall set groundwater monitoring trigger values at a value of 10% above the baseline contaminant concentrations obtained from the hydrogeological studies required by condition 8-1.

8-5 In the event that monitoring required by condition 8-4 indicates an exceedance of trigger levels: The proponent shall report such findings to the CEO within 7 days of the exceedance being identified; The proponent shall provide evidence which allows determination of the cause of the exceedance; If determined by the CEO to be project attributable, the proponent shall submit actions to be taken to address the exceedance within 7 days of the determination being made to the CEO; The proponent shall implement actions to address the exceedance and shall continue until such time as the CEO determines that the remedial actions may cease; and The proponent shall submit bi-annually, or at a frequency defined to the satisfaction of the CEO, the results of monitoring required by condition 8-4 to the CEO, until such time as the CEO determines that reporting may cease.


The subsequent reviews of condition 5-1 of MS 870 are discussed below.

An integral component of the operation of the TAN Plant is the discharge of liquid waste to King Bay via the Multi-User Brine Return Line (MUBRL), as part of the Water Corporation’s Desalination and Seawater Supplies Project. The Water Corporation holds MS 567 and MS 594 for the use of the MUBRL to discharge industrial wastewater to King Bay.

Section 57(4) of the EP Act provides that the determination of an application for a licence shall not be contrary to or otherwise than in accordance with a Ministerial Statement (i.e. the new licence must be in accordance with MS 870, and MS 567 and MS 594). It is not the intention of the EP Act that a licence issued under Part V duplicate the requirements imposed under Part IV of the EP Act.

The requirements of the Ministerial Statements have been considered in the preparation of this application.

1.2.2.1 Best Available Technology (EPA review of Condition 5-1)

In November 2017, the Minister for Environment requested that DWER review compliance of MS 870 with reference to Condition 5-1: Air Quality. The purpose of the review was to determine whether contemporary best practice pollution control technology was being implemented at the TAN Plant.

Subsequent to a desktop technical review and a site visit in March 2018, DWER concluded that contemporary best practice pollution control technology has been incorporated in the design of the TAN Plant.

1.2.2.2 EPA inquiry under section 46 of the EP Act

In April 2018, the Minister for Environment requested that the EPA inquire into and report on the matter of changing implementation Condition 5-1: Air Quality in MS 870, to protect rock art.

The potential impacts on two key environmental factors: Air Quality and Social Surroundings were examined by the EPA during its inquiry.

In September 2019, the EPA published Report 1648, which considered the protection of rock art within the context of a review of MS 870. The EPA, in applying the precautionary principle, found that "there is currently no compelling scientific evidence which indicates that there is an immediate material threat of serious or irreversible damage to rock art from cumulative industrial air emissions within the Murujuga airshed", and further that "there is sufficient time for the monitoring and evaluation activities associated with the Murujuga Rock Art Monitoring Program to be undertaken and for definitive information in regard to whether cumulative industrial air emissions within the Murujuga airshed are adversely affecting rock art to be obtained".

The EPA considered that the present stack emissions limits within the current licence are an effective means of minimising the risk of air emissions impacting on rock art. The approach taken by the EPA has guided the preparation of this application with respect to rock art.

The EPA also considered that the conditions in Commonwealth approval EPBC 2008/4546 pertaining to ambient air quality monitoring and rock art monitoring did not need to be duplicated in Condition 5-1.

The EPA recommended that Condition 5 in MS 870 be deleted and replaced with an amended version. The recommended amended Condition 5 includes clear objectives to minimise air emissions in order to enable regional air quality to be maintained so that the environmental values of human health and amenity are protected, and to reduce the risk of impacts to rock art on Murujuga (the Dampier Archipelago and Burrup Peninsula).


As a result of this inquiry, the EPA concluded that the impacts to Air Quality and Social Surroundings are manageable, based on the imposition of the recommended new version of Condition 5 in place of the original version.

The new conditions recommended by the EPA are shown in Appendix A.

At the time of preparing this application, the inquiry process had not concluded, as the Minister for Environment and relevant decision-making authorities are to consider the EPA's recommendation and determine whether condition 5-1 should be amended.

EPA Report 1648 (and the EPA's relevant findings) has been considered in the preparation of this application.

1.2.3 Part V of the EP Act

The DWER regulates industrial emissions and discharges to the environment through a works approval and licensing process under Part V of the EP Act. The principles of the EP Act guide DWER’s environmental regulatory functions.

Industrial premises with potential to cause emissions and discharges to air, land or water are known as prescribed premises and trigger regulation under the EP Act. Prescribed premises categories are outlined in Schedule 1 of the Environmental Protection Regulations 1987 (EP Regulations). The EP Act requires a works approval to be obtained before constructing a prescribed premises and makes it an offence to cause an emission or discharge unless a licence or registration is held for the premises.

Pursuant to section 62(1) of the EP Act, conditions may be imposed on a licence for the purposes of the EP Act relating to the prevention of, control, abatement or mitigation of pollution or environmental harm. In preparing this application, consideration has been given to appropriate controls that comply with this legislative requirement.

As noted above, the EP Act requires that licences must be in accordance with or not inconsistent with a Ministerial Statement. Additionally, section 57(3)(b) of the EP Act provides that where the prescribed premises have been constructed in accordance with the requirements of a works approval issued under Part V of the EP Act, a licence must be granted and must be granted subject to conditions that are not inconsistent with the conditions imposed on the works approval. The TAN Plant was constructed in accordance with Works Approval W4701/2010/1, which was granted on 25 July 2013. The requirements of Works Approval W4701/2010/1 have been considered in the preparation of this assessment.

YPN holds Licence L7997/2002 for the operation of the TAN Plant. Licence L7997/2002 was first granted in 2005 for the operation of the Ammonia Plant. The licence was amended in June 2018 to include the operation of the TAN Plant.

In preparing this application, YPN has reviewed any changes in the relevant regulatory framework since the grant of the current licence. No significant changes were identified; therefore, the previous environmental assessments (including, where available, DWER decision reports) have been considered in the preparation of this application.

1.2.4 Legislative framework for assessing and managing potential impacts on rock art (petroglyphs)

Murujuga (the Dampier Archipelago, including the Burrup Peninsula and surrounds) is a unique ecological and archaeological area containing one of the largest collections of Aboriginal engraved rock art in the world. The rock art (petroglyphs) are of immense cultural and spiritual significance to Aboriginal people, and of national and international heritage value.

Existing legislative mechanisms and agreements that provide for the protection of the rock art on Murujuga are summarised in Table 1.2.


Table 1.2: Existing State and Commonwealth mechanisms and agreements that provide for the protection of the rock art on Murujuga Mechanism and (responsible government)

Date Summary of the provisions for the protection of the rock art on Murujuga

Aboriginal Heritage Act 1972 (AH Act) (WA)

Various The Department of Planning, Lands and Heritage (DPLH) maintains a Register of Aboriginal Places and Objects that includes more than 2,800 records for Murujuga. However, many more on Murujuga have not yet been registered. It is an offence under s.17 of the AH Act to excavate, destroy, damage, conceal or otherwise alter any Aboriginal site unless authorised by the Registrar of Aboriginal Sites (s.16) or the Minister for Aboriginal Affairs (s.18). Section 19 of the AH Act provides for the declaration and gazettal of Protected Areas, which are Aboriginal sites of ‘outstanding importance’. Once an area has been gazetted as a Protected Area, regulations may be made prohibiting or imposing conditions or restrictions on use of the Protected Area and activities (s.26). There are two areas on Murujuga declared as Protected Areas under s.19: the ‘Climbing Men’ site near Withnell Bay and the northern portion of the Burrup Peninsula. Section 15 of the AH Act requires the reporting to the Registrar of the location of anything to which there is a reasonable expectation the AH Act might apply.

Burrup and Maitland Industrial Estates Agreement Implementation Deed (the BMIE Agreement) (WA)

January 2003

The State Government entered into the BMIE Agreement with three Aboriginal groups (the NgarlumaYindjibarndi, the Yaburara-Mardudhunera and the Wong-Goo-Tt-Oo) in 2003. The BMIE Agreement enabled the State Government to acquire native title rights and interests in the Burrup Peninsula and parcels of land near Karratha. The BMIE Agreement allows for industrial development to progress at the southern end of the Burrup Peninsula, provided for the development of newly created conservation estate (Murujuga National Park) and ensures the protection of Aboriginal heritage. The Department of Jobs, Tourism, Science and Innovation (DJTSI) is the lead agency for the development of the Burrup Strategic Industrial Area and LandCorp is the estate manager.

Burrup Maitland Industrial Estates Agreement Additional Deed (WA)

January 2003

The State Government committed to organise and fund a minimum four-year study into the effects of industrial emissions on rock art within and near part of the industrial estate on the Burrup Peninsula.

Listing of the Dampier Archipelago as a National Heritage Place – Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) (Cwlth)

July 2007 The EPBC Act contains provisions relating to the listing of national heritage. The national heritage management principles are set out in Schedule 5B of the Environment Protection and Biodiversity Conservation Regulations 2000 and in the document Australia’s National Heritage: Applying the Principles. The Dampier Archipelago was assessed by the Australian Heritage Council in 2007 and found to meet five of the eight criteria for national heritage listing under the EPBC Act. The listing of the Dampier Archipelago ‘recognised the extraordinary extent, diversity and significance of petroglyphs, standing stones and circular stone arrangements of the place’. National heritage listing means that any proposed action that could have a significant impact on the National Heritage listed portion of the Burrup Peninsula must be referred to the Commonwealth Minister for the Environment as a matter of national environmental significance for assessment and decision.

EPBC Act Conservation Agreements (Cwlth)

July 2007 At the time of listing on the National Heritage List, EPBC Act Conservation Agreements were signed by the then Commonwealth Minister for the Environment and Water Resources with Woodside Energy Ltd, and with Hamersley Iron Pty Ltd and Dampier Salt Ltd (Rio Tinto). Under the agreements, these companies provide funding for research, management and monitoring of the National Heritage values of the place.

Ministerial Statement No. 757 Pluto Liquefied Natural Gas Development (Pluto LNG) (Woodside Energy Ltd) (WA)

December 2007

The offsets package for Pluto LNG required the rehabilitation/restoration of degraded areas that fall both outside of the lease and outside of areas of potential industrial development on the Burrup Peninsula, with a focus on Murujuga National Park and adjacent areas. The program initiated as a result of this requirement aims to rehabilitate and restore degraded areas on the Burrup Peninsula. It includes rock art site rehabilitation and restoration


Mechanism and (responsible government)

Date Summary of the provisions for the protection of the rock art on Murujuga

EPBC Act Approval (EPBC 2008/4546) for the Construction of the Technical Ammonium Nitrate Production Facility (TANPF) (Yara Pilbara Pty Ltd) (Cwlth)

September 2011 (variations were approved under the EPBC Act in 2013, 2014 and 2017)

The Commonwealth Minister for the Environment determined the proposal for the construction of the TANPF was a controlled action under the EPBC Act for likely impacts to the National Heritage Place. The Commonwealth Minister for the Environment approved the proposed action, with conditions relating to the protection of the National Heritage Place, including: contributing funds towards the implementation of the rock art monitoring program and reporting of results; providing the Department of the Environment and Energy (DoEE) with a management plan in the event that accelerated changes in the rock art are detected; and air-quality monitoring and emissions limits.

Murujuga National Park established (WA)

January 2013

Murujuga National Park, covering 4,913 hectares, is freehold land on Murujuga owned by the Murujuga Aboriginal Corporation (MAC) and leased back to the State Government. The granting of title to the non-industrial lands of the Burrup Peninsula was a result of the Burrup Agreement. Murujuga National Park is jointly managed by the Department of Biodiversity, Conservation and Attractions (DBCA) Parks and Wildlife Service and MAC through a partnership arrangement that operates under the provisions of the Conservation and Land Management Act 1984 (CALM Act). Together, the CALM Act and the Conservation and Land Management Regulations 2002 provide for the formal protection of the park’s values. Amendments to the CALM Act in 2012 allowed for: • joint management of Aboriginal land by DBCA• the addition of a management objective for DBCA-managed land to protect

and conserve the value of the lands and waters to the culture and heritage ofAboriginal people

• Aboriginal people to undertake certain customary activities on DBCA-managed lands and waters.

The focus of the Murujuga National Park Management Plan (2013) is to ensure protection and awareness of the cultural and natural values of the area.

The Deep Gorge Joint Statement (DGJS) (Cwlth)

July 2017 The DGJS, signed by the Australian Government, Woodside and Rio Tinto, reaffirms the commitments made under each of the bilateral Conservation Agreements to support the ongoing protection, conservation and management of the National Heritage values of Murujuga and the wider Dampier Archipelago.

1.2.4.1 Murujuga Rock Art Strategy

The Minister for Environment released the Murujuga Rock Art Strategy in February 2019 (DWER 2019). The strategy establishes the framework for the long-term management and monitoring of environmental quality to protect the rock art on Murujuga (the Dampier Archipelago and Burrup Peninsula) from the impacts of anthropogenic emissions that is consistent with the state government’s responsibilities under the EP Act.

1.2.4.2 Environmental Quality Management Framework

An Environmental Quality Management Framework (EQMF) will be implemented as part of the Murujuga Rock Art Strategy to provide a transparent, risk-based, and adaptive framework for monitoring and managing environmental quality to protect the rock art on Murujuga from anthropogenic emissions.

The EQMF will establish a common and agreed Environmental Quality Objective and scientifically based limits of ‘acceptable’ change. The successful implementation of the EQMF will require:

• the application of Environmental Quality Criteria (EQC) that are based on sound scientificinformation

• a monitoring program that is appropriately designed and implemented to make thenecessary measurements, to analyse the data and to report on the integrity or condition ofthe rock art and change in that condition


• a governance process that enables information to be assessed and appropriate managementactions to be implemented.

There are currently no existing or default guideline ‘trigger values’ for protecting the rock art from anthropogenic emissions that could be used as EQC. The development of interim EQC, based on the best available scientific information at the time, will be informed by the monitoring studies undertaken to underpin the design of the Murujuga Rock Art Monitoring Program.

1.2.4.3 Murujuga Rock Art Stakeholder Reference Group (MRASRG)

The Murujuga Rock Art Stakeholder Reference Group (MRASRG) was established by the Minister for Environment in September 2018 to facilitate engagement between the Murujuga Aboriginal Corporation (MAC) and key government, industry, and community representatives on the development and implementation of the Murujuga Rock Art Strategy.

The role of the MRASRG is to:

• contribute constructively to the monitoring and protection of rock art, being considerate ofall stakeholder views and provide advice to the DWER and the Minister for Environment onthe design, implementation and analysis of the scientific monitoring and analysis program

• consult, inform, and educate other stakeholders on matters referred by the DWER for inputor comment, including further development of the strategy, implementation of the strategy,and five yearly reviews

• inform the government’s broader consideration of other strategic issues relating to theprotection of the rock art on Murujuga.

1.2.4.4 Murujuga Rock Art Monitoring Program

The DWER is partnering with the MAC to oversee the development and implementation of a rock art monitoring program to determine whether the rock art on Murujuga is being subject to accelerated change. The purpose of the Murujuga Rock Art Monitoring Program is to monitor, evaluate, and report on changes and trends in the integrity of the rock art, specifically to determine whether anthropogenic emissions are accelerating the natural weathering, alteration, or degradation of the rock art. This will enable timely and appropriate management responses by the state government, industry, and other stakeholders to emerging issues and risks.

The objectives of the Murujuga Rock Art Monitoring Program are to:

• obtain data for comparison against the EQC to ascertain whether the Environmental QualityObjective is being achieved and the environmental value (the rock art) protected

• provide the state government, the MAC, industry, and the community with robust,replicable and reliable information on changes and trends in the integrity or condition of therock art on Murujuga

• ensure decisions regarding the protection of the rock art are based on the best availablescience

• inform the evaluation of the effectiveness of any measures taken to mitigate adverse effectson the rock art, including efforts to protect the rock art.

It is considered that the Murujuga Rock Art Monitoring Program (undertaken in accordance with the Murujuga Rock Art Strategy and EQMF) is an appropriate precautionary approach to managing the risk of impacts to rock art. Further, that the imposition of more restrictive emissions requirements in advance of the Murujuga Rock Art Monitoring Program is both unnecessary and inappropriate in terms of the legislative requirements of section 62(1) of the EP Act.


If the Murujuga Rock Monitoring Program results identify (on an individual site or cumulative basis) the need for further regulatory controls, such an outcome can be facilitated through a licence amendment process under section 59 of the EP Act.

1.2.5 Contaminated sites

The TAN Plant (Lot 3017) was classified by DWER as ‘possibly contaminated – investigation required’ under the Contaminated Sites Act 2003 on 7 December 2018. DWER’s notice of classification states that ‘accidental release of ammonium nitrate solution, leakage of corrosion inhibitor from a sub-surface pipe, and suspected leaks of ammonium nitrate contaminated wastewater during 2017 have resulted in soil contamination and migration of contaminants into groundwater’.

The reason for classification was stated as ‘ammonia, nitrates and nitrites in soil and groundwater’, which were detected during a series of contamination assessments carried out between 2017 and 2018. Over the past year, YPN has undertaken a significant number of inspections and repairs to the TAN Plant (TAN Recovery Project) to mitigate risk of further contamination.

An environmental consultant and contaminated sites auditor have been engaged, and a Detailed Site Investigation (DSI) was completed during 2019. On going works are being conducted in accordance with contaminated sites legislation and in consultation with DWER.

1.2.6 Department of Mines, Industry Regulation and Safety (DMIRS)

The TAN Plant includes several infrastructure items used for the storage and processing of chemicals. The premises is considered a Major Hazard Facility and is subject to the requirements of the Dangerous Good Safety (Major Hazard Facilities) Regulations 2007. The appropriate dangerous goods licences have been obtained under the Dangerous Goods Safety Act 2004 (refer to Table 1.3).

The Department of Mines, Industry Regulation and Safety (DMIRS) is the primary regulatory authority for regulating public health risks associated with the storage and handling of dangerous goods, including the risk of explosion.

The requirements of the Dangerous Goods Safety Act 2004 and Dangerous Goods Site Licence DSG021976, Security Sensitive Ammonium Nitrate Manufacture Licence SMA000031 and Dangerous Goods Pipeline Registration DPL001133 have been considered in the preparation of this report. It is not intended that the new licence duplicate these requirements, and this application has been prepared on that basis.

1.2.7 Approvals summary

Current approvals relevant to the TAN Plant are listed in Table 1.3 below.

Table 1.3: Approvals Legislation Number Subsidiary Approval

Environmental Protection Act 1986

Ministerial Statement Number 870 (MS 870)

Burrup Nitrates Pty Ltd

For construction and operation of a technical ammonium nitrate production facility within the King Bay/Hearson Cove Industrial Estate on the Burrup Peninsula. Granted 11 July 2011. Available from www.epa.wa.gov.au.

L7997/2002/11 Yara Pilbara Fertilisers Pty Ltd and Yara Pilbara Nitrates Pty Ltd

Licence regarding emissions and discharges from the Ammonia Plant and TAN Plant. Available from www.dwer.wa.gov.au.

Environment Protection and Biodiversity Conservation Act 1999 (Cth)

EPBC 2008/4546

Yara Pilbara Nitrates Pty Ltd (previously named Burrup Nitrates Pty Ltd)

Conditional approval was issued on 14 September 2011 (EPBC 2008/4546). Variations to the approval were issued on 18 December 2013, 10 February 2014 and 12 September 2017. Available from https://www.yara.com.au/about-yara/about-yara-australia/pilbara/yara-pilbara-nitrates/

http://www.epa.wa.gov.au/

http://www.dwer.wa.gov.au/

https://www.yara.com.au/about-yara/about-yara-australia/pilbara/yara-pilbara-nitrates/

https://www.yara.com.au/about-yara/about-yara-australia/pilbara/yara-pilbara-nitrates/


Legislation Number Subsidiary Approval

Dangerous Goods Safety Act 2004

DGS021976


Dangerous Goods Site Licence issued 23 February 2015. Expiry 23 February 2020.

SMA000031 Security Sensitive Ammonium Nitrate (SSAN) Manufacture Licence issued 23 February 2015. Expiry 23 February 2020.

SIE000049 SSAN Import/Export Licence issued 23 October 2017. Expiry 23 October 2022.

DPL001133 Dangerous Goods Pipeline Registration issued 13 May 2015. Expiry 13 May 2020.

Dangerous Goods Safety (Major Hazard Facilities) Regulations 2007

Approved Safety Report


Safety Report approved on 26 May 2015.

1.3 Integrated Management of Yara Pilbara operations

Yara Australia Pty Ltd (Yara), which is a wholly owned subsidiary of Norwegian owned Yara International ASA, is the operator of both the Ammonia Plant and TAN Plant pursuant to the terms of an operations management deed. The TAN Plant is owned by YPN, which is an incorporated joint venture that is owned 50% by Orica Investments Pty Ltd (Orica Investments) (a subsidiary of Australian explosives manufacturer Orica Limited (Orica)) and 50% by Yara Australia Pty Ltd. The company structure chart is shown in Figure 1.1.

Figure 1.1: Company structure


Under the terms of the shareholder agreement between Yara and Orica, YPN has no direct employees. Rather the TAN Plant and Ammonia Plant are run as an integrated site and all employees are directly employed by YPF (another wholly owned subsidiary of Yara). This includes site management, TAN Plant and Ammonia Plant operators, maintenance staff and Perth based corporate staff.

The organisation structure for the TAN Plant and Ammonia Plant is illustrated in Figure 1.2.

Figure 1.2: Yara Pilbara management structure as relevant to the TAN Plant operations

1.4 Purpose and scope

This document supports YPN’s application for a new licence to operate the TAN Plant. The following categories of prescribed premises listed in Part 1 of Schedule 1 of the Environmental Protection Regulations 1987 apply to the TAN Plant (Table 1.4).

Table 1.4: Prescribed premises categories Category number Description of category Category production or

design capacity threshold TAN Plant production or design capacity

31 Chemical manufacturing: premises (other than premises within category 32) on which chemical products are manufactured by a chemical process

100 tonnes or more per year

350,000 tonnes per year

This prescribed premises category applies under the current licence.

The document is structured to provide attachments required by DWER’s Application Form: Works Approval/Licence/Renewal/Amendment/Registration (February 2019, v 11) (Application Form).

Table 1.5 provides an overview of the Application Form supporting attachments and the relevant sections of this document that address each of the information requirements.


Table 1.5: Supporting attachments Application form attachments Section in this document Attachment 1A: Proof of occupier status Section 2 Attachment 1B: ASIC company extract Section 3 Attachment 2: Premises map/s Section 4 Attachment 3A: Proposed activities Section 5 Attachment 3B: Map for proposed area to be cleared Not required Attachment 4: Biodiversity surveys Not required Attachment 5: Other approvals and consultation documentation Not required Attachment 6A: Emissions and discharges Section 6 Attachment 6B: Waste acceptance Not required Attachment 7: Siting and location Section 7 Attachment 8: Other relevant information Not required Attachment 9: Proposed fee calculation Not required Attachment 10: Request for exemption from publication Not required

This application has been prepared in accordance with the regulatory framework described above and with consideration of the principles of the EP Act, the requirements of MS 870 and other approvals, and the following guidance relevant to applications for licences under Part V of the EP Act:

• Guideline: Industry Regulation Guide to Licensing (DWER 2019a)

• Guideline: Decision Making (DWER 2019b)

• Guidance Statement: Risk Assessments (DER 2017)

• Guidance Statement: Environmental Siting (DER 2016).


4. Attachment 2: Premises maps

The TAN Plant is located on part of Lot 3017 on Plan 50979, Village Road, BURRUP WA 6714. Yara Pilbara Nitrates Pty Ltd hold the lease for Lot 3017.

The prescribed premises boundary does not cover the entirety of Lot 3017 but encompasses all plant, equipment and monitoring areas relevant to the TAN Plant, including the pipeline corridor connecting it to the adjacent Ammonia Plant operated by YPF. The prescribed premises boundary is consistent with the disturbance footprint described in MS 870, with the exception of the connecting corridor

The coordinates of the prescribed premises boundary are show in Table 4.1 below and on the Premises Map.

Table 4.1: Premises coordinates (MGA 94, Zone 50) Easting Northing

1 477659 7719714 2 47845 7719624 3 478346 7719210 4 478207 7719210 5 478206 7719310 6 478013 7719310 7 478015 7719211 8 477659 7719211

The following maps are attached:

• Premises Map

• Infrastructure Map

• Map of Emission Points

• Map of Monitoring Locations.

LOT 2017 IN PLAN 50979

4783467719210

4782077719210

4782067719310

4780137719310

4780157719211

4776597719211

4776597719714

4784857719624

‐

‐

‐

‐

‐‐

‐

‐‐

‐‐

‐

‐

‐

‐

‐

‐

‐

‐

‐

‐

‐

‐

‐

HEARSON COVE RD

‐

‐

HEARSON

COVE RD

VILLAGE RD

Z

Client: Yara Pilbara Nitrates

Version: A Date 12/07/2019

Checked By: LT

Scale 1:10,000 at A4

Coord. Sys. GDA 1994 MGA Zone 50

Premises map

0 100 200

metres

File Name: W:\Projects\1)Open\Yara Pilbara Nitrates\56928 Seperate licence applications\GIS\Maps\R002_Rev_A\56928_01_PremisesLocn.mxdReference: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community. Reference: Nearmap Imagery flown 04/2019.

YARA PILBARA NITRATESTAN Plant

Job No: 56928

Drawn By: cthatcher

LegendLease boundary - TANPlantPremises boundary - TANPlantCadastral boundaryRoadsCorner coordinates

!

!

DAMPIER

KARRATHA

OVERVIEW

POND 1

POND 2

POND 4 POND 5

POND 3

POND 6

SEAWATER COOLING TOWER

BULK TAN STORAGE BUILDING

AMMONIUM NITRATE SOLUTION PLANT &TAN PRILLING PLANT

NITRIC ACID PLANT

NITRIC ACID TANKS

OFF SPEC AREA

BULK TRUCK LOADING

TAN BAGGING FACILITY&BAGGED TAN STORAGE

INFRASTRUCTURE MAP

ATU

ATU

ATU

ATU

ATU

jbailes

Rectangle

jbailes

Polygon

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

jbailes

Rectangle

""

""

A1 & A3

A2 & A4

Z



Checked By: LT

Scale 1:7,500 at A4


Map of emission points

0 100 200

metres

File Name: W:\Projects\1)Open\Yara Pilbara Nitrates\56928 Seperate licence applications\GIS\Maps\R002_Rev_A\56928_03_DischargePts.mxdReference: Nearmap Imagery flown 04/2019.


Job No: 56928

Drawn By: cthatcher

LegendLease boundary - TANPlantPremises boundary - TANPlantCadastral boundary

""Stack and vent dischargepoint

&<

&<

&<

&<

&<

&<

&<

&<&<

""

""

""

""

""

A1

A2

US2

DS1

DS2

DS3

DS4

DS5

DS6

DS7DS8

AA6

AA7

AA5

Z



Checked By: LT

Scale 1:7,500 at A4


Map of monitoring locations

0 100 200

metres

File Name: W:\Projects\1)Open\Yara Pilbara Nitrates\56928 Seperate licence applications\GIS\Maps\R002_Rev_A\56928_02_MonitoringLocs.mxdReference: Nearmap Imagery flown 04/2019.


Job No: 56928

Drawn By: cthatcher

LegendLease boundary - TANPlantPremises boundary - TANPlantCadastral boundary

""Ambient air monitoringlocation

&<Groundwater monitoringbores

"" Stacks


5. Attachment 3A: Activities

5.1 Process overview

The TAN Plant is designed to operate 24 hours a day, seven days a week and can produce 350,000 tonnes per year of TAN. The main feedstock for the process is liquid ammonia, which is transferred via pipeline from the adjacent Ammonia Plant.

The plant features three major process units, each producing a separate product in the manufacturing process:

• a dual pressure process nitric acid plant to convert ammonia and atmospheric air into nitricacid

• an ammonium nitrate solution plant to convert ammonia and nitric acid into ammoniumnitrate solution (intermittent product)

• a TAN prilling plant to convert ammonium nitrate solution into TAN prills (final product).

These processes are the same as those authorised under the current licence. Figure 5.1 shows an indicative schematic flowsheet of the manufacturing process.

Figure 5.1: Simplified TAN Plant process flow

5.1.1 Nitric acid plant

The nitric acid plant has a capacity to produce 760 metric tonnes per day (Mtpd) of nitric acid on a 100% equivalent basis (concentration of produced nitric acid 60% by weight) which is sent to the ammonium nitrate solution plant.


The raw materials required for the nitric acid plant are ammonia and oxygen (air). Liquid ammonia, fed from the adjacent Ammonia Plant is filtered, vaporised, superheated and mixed with air. The ammonia/air mixture is then passed through a platinum gauze catalyst where the ammonia is oxidised to form nitric oxide (NO) and water. Nitrous oxide (N2O) and nitrogen (N2) are also simultaneously produced.

The nitric oxide is cooled, and subsequently oxidised, to produce nitrogen dioxide (NO2). The nitrogen dioxide in then compressed to a higher pressure and added to the absorber where it is contacted and subsequently absorbed with water to produce nitric acid (HNO3) at a concentration of 60% by weight.

The nitric acid produced in the absorber contains dissolved nitrogen oxides which are removed in a bleaching column via the addition of hot air, with this bleach gas stream being recycled to the absorber. Gases not absorbed in the absorption tower are released as 'tail gas' and used as a cooling medium for the hot reactor gases from the initial reaction. Prior to discharge into the atmosphere, the tail gas is mixed with ammonia gas and enters a catalytic abatement reactor which reduces nitrogen oxides (NOx) in the gas to nitrogen and water resulting in cleaned tail gas being vented to the environment via the nitric acid plant stack.

Heat produced during the nitric acid production process is recycled in the heat recovery circuit where it is used for steam production and electricity generation.

Ammonia can be released from the nitric acid plant vent during start-up to ensure optimal pressure control prior to and in some cases during catalyst “light-off”, when the catalyst is heated to operating temperature. Venting is not required during normal operation.

5.1.2 Ammonium nitrate solution plant

The ammonium nitrate solution plant uses a pressurised reactor to produce ammonium nitrate solution (NH4NO3) from ammonia and nitric acid.

Nitric acid is neutralised using ammonia gas to produce the ammonium nitrate solution and steam. Superheated gaseous ammonia and preheated liquid nitric acid are injected into the bottom part of a natural circulation neutraliser. Steam produced by the neutralisation process is reused in the evaporation process.

The plant has capacity to produce 965 Mtpa of ammonium nitrate solution (93% by weight), which is either sent to the TAN prilling plant, stored for future use or sold as product.

5.1.3 TAN prilling plant

Prilling is the formation of round, solid porous spheres of ammonium nitrate and is the final product from the process. The product is formed in the prilling tower where the ammonium nitrate solution is pumped to the prilling nozzles which discharge droplets that crystallise as they fall from the top of the tower against a rising flow of air. The TAN prilling plant has the capacity to produce 915 Mtpd.

Prior to prilling, the ammonium nitrate solution is concentrated, via a falling film evaporator operating under vacuum, to increase the concentration of the product. Prills exiting the prill tower are dried to remove moisture, screened and fed to the fluidised bed cooler. Oversized and fine prills are removed and recycled whilst “on-spec” materials are cooled to optimal storage temperature and directed to a coating drum where anti-caking agents are sprayed on. Prior to prilling, ammonium nitrate can be combined with additives to produce either a higher or lower density grade depending on market requirements.

During the prilling process, some ammonia and ammonium nitrate (as fine particles) become entrained in the air. A scrubber is installed on the exhaust air stream of the prill tower to reduce the majority of ammonia and particulate ammonium nitrate. The air is then scrubbed again at the final


scrubber. In parallel to the prilling air scrubber, drying air is also scrubbed through the final scrubber to minimise emissions to the atmosphere from the common stack.

5.1.4 Loading, bagging and storage The final TAN product leaving the TAN prilling plant is round, solid, porous spheres of ammonium nitrate that is conveyed to the bulk store and then either bagged at the bagging facility in 1.2 tonne bags which are stored in blocks of about 300 tonnes or less, or conveyed directly into trucks.

Due to the ambient temperature of the Pilbara region, the bulk storage structure has a special roof construction to maintain temperatures within acceptable levels. Air conditioning has also been installed in the bulk storage area. Bags are stored with a minimum 7–9 m separation distance between each block. The storage configuration of product reduces the potential risk of neighbouring piles detonating. Floor markings in the storage area ensure that safe stacking zones are maintained despite the highly unlikely possibility of detonation.

The TAN Plant has been designated as a Class A Major Hazard Facility (MHF) by DMIRS. Handling and storage of the product is also managed under the Dangerous Goods Site Licence (DGS021976) in accordance with the Dangerous Goods Safety Act 2004 (DGS Act) and regulations, administrated by DMIRS.

A total capacity of 3,000 m3 of nitric acid is stored in two storage tanks and located in a bunded area with an acid resistant surface. Excess ammonium nitrate solution is stored at concentrations of 80-92% within a 500 Mt tank which is located within a bunded area. Ammonium nitrate solution is loaded on trucks from the ammonium nitrate storage tank for sale. The loading area has a bund and stainless-steel lined sump to collect any spills that may occur during loading. Liquids collected in the sump are directed to one of the contaminated water ponds (refer to Section 5.1.5) or removed from site if required.

5.1.5 Wastewater containment infrastructure

The site wastewater and stormwater management systems are designed to:

1. Manage all contaminated wastewater so that there is no contamination to ground.

2. Manage all stormwater such that:

a. clean stormwater runoff from sealed areas of the site (including roofs and roads) is capturedfor storage and evaporation in ponds 1 and 2

b. clean stormwater runoff from non-sealed areas is allowed to soak to ground, or once theground has become saturated is directed to ponds 1 and 2.

c. potentially contaminated stormwater is directed to designated storage facilities.

5.1.5.1 Contaminated water system

The contaminated water (process) system is designed to capture all contaminated process wastewater from identified point sources, including various process water flows discharged from plant equipment to grade or drain. It is also designed to deal with stormwater runoff from nearby sealed plant areas and non-sealed areas once the ground has become saturated and free-standing water is produced.

Since this system consists of sealed areas (coated concrete, roof surfaces, bunds etc.) and conduits (various channels, pipes etc.) that prevent infiltration to ground, any rainfall within this area is determined to be contaminated. It is therefore prevented from egress to ground and collected for treatment (primarily for oil removal and pH neutralisation), then stored in ponds 4 and 5 for evaporation.


5.1.5.2 Ponds 4 and 5

Ponds 4 and 5 are used for contaminated water storage and passive solar evaporation. They work in conjunction with the contaminated water system and are designed for receival of both process wastewater and contaminated or potentially contaminated stormwater.

Pond 5 was refurbished in March 2019 and is double lined with 1.5 mm thick conductive HDPE to achieve a permeability of less than 1 x 10-9 m/s. There are also multiple tell-tale leak detectors on pond 5 to allow monitoring of leakage rates if the upper liner degrades and develops leakage points. Pond 4 will also be refurbished in a similar manner to pond 5 prior to the commencement of operations in early 2020.

Ponds 4 and 5 have sufficient storage capacity for up to a 1:10 Year average recurrence interval (ARI) 24 hour rainfall event. If these ponds reach maximum capacity, excess contaminated wastewater can be pumped to ponds 1 or 2, or if required, sent off site for disposal.

5.1.5.3 Clean water system

The clean water system includes a designated catchment zone which is typically comprised of sealed, drain channels and connecting gravity-flow pipes and pits. Water collected within this system is only due to rainfall from buildings and roads.

The clean water system is designed to capture all rainfall runoff from various delineated sealed areas of the site (including roofs and roads) for storage in ponds 1 and 2. It is also designed to deal with stormwater runoff from nearby non-sealed areas once the ground has become saturated and free-standing water is produced. Since this system consists of areas that are identified as having no obvious impingement or collection of chemical contaminants, any rainfall within this catchment area is deemed as uncontaminated.

5.1.5.4 Ponds 1 and 2

Ponds 1 and 2 are currently used for clean water storage, passive solar evaporation and optional disposal via the Water Corporation’s Multi User Brine Return Line (MUBRL).

Ponds 1 and 2 work in conjunction with the clean water system. Currently the ponds are single lined (1.5 mm thick HDPE) to achieve a permeability of less than 1 x 10-9 m/s and have sufficient storage capacity for up to a 1:10 Year ARI 24 hour rainfall event.

Effective water and wastewater management on site is critical to the ongoing success of the TAN Plant. As an outcome of a recent water balance review and as discussed in Section 5.1.5.1, ponds 1 and 2 will be re-purposed to allow them to also receive contaminated water streams as a contingency storage option. While the ponds achieve the current licence lining requirement for contaminated water storage, these ponds will be upgraded to include double lining and leak detection as installed in ponds 4 and 5.

With ponds 1 and 2 repurposed to allow receival and storage of contaminated water streams, there will now be sufficient capacity to contain all contaminated and potentially contaminated wastewater flows generated on the site (noting that clean water will be directed off-site).

5.1.5.5 Sewage effluent system - Pond 3 and 6

Treated domestic wastewater from the five Aerobic Treatment Units is directed to ponds 3 (32.8 m x 20.8 m x 2.9 m) and 6 (15.6 m x 10.8 m x 1.5 m) for storage and evaporation. Both ponds are lined with 1.5 mm thick HDPE.


5.1.6 Utilities

5.1.6.1 Electricity

Electricity (8.5 Megawatt-hours [MWh]) is supplied from the Ammonia Plant (typically < 5 MWh) or generated on-site using process steam from the nitric acid plant (3.5 MWh).

5.1.6.2 Potable Water

Potable water is provided directly by the Water Corporation and up to 12 m3/hr demineralised water is supplied by the Ammonia Plant.

5.1.6.3 Cooling system (cooling towers)

Seawater for use in the cooling systems is provided by the Water Corporation's seawater intake associated with the Water Corporation's Desalinated Water and Seawater Supplies Project. Process cooling water is discharged to the adjacent Ammonia Plant and then into Water Corporation’s MUBRL.

5.1.6.4 Sewage treatment

Five Aerobic Treatment Units (ATUs) are used to treat domestic wastewater. Treated domestic wastewater is directed to Ponds 3 and 6.

The ATUs have a combined design capacity of 10.8 m3 per day, which is less than the 20 m3 design capacity threshold of Category 85 sewage facilities described in Schedule 1 Part 2 of the EP Regulations. The ATUs only treat sewage from office and welfare facilities and are not directly related to the TAN Plant primary activities.

5.1.7 Hazardous material storage

Nitric acid, ammonium nitrate solution, and hydrocarbons are stored on the TAN Plant, which is operated in accordance with the Dangerous Goods Safety (Major Hazardous Facility) Regulations 2007 and Licences (SMA000031 and DGS021976) granted under the Dangerous Goods Safety Act 2004 for the manufacture and storage of Dangerous Goods (including hydrocarbons and chemicals).

In addition to the licences granted under the Dangerous Goods Safety Act 2004 and associated regulations, hydrocarbons and chemicals are managed through the implementation of the following:

1. Yara Pilbara MHF Safety Report.

2. Yara Pilbara Emergency Management Plan.

3. Hazardous materials management standard within the TAN Plant Operation Environmental Management Plan (OEMP).

4. Yara Pilbara Waste Management Procedure.

5. Yara Pilbara Spill Procedure.

5.2 Key infrastructure

Key infrastructure for the TAN Plant as it relates to prescribed premises Category 31 is detailed in Table 5.1.


Table 5.1: Key infrastructure Key infrastructure Reference map Category 31: Chemical manufacturing Production/design capacity: 350,000 tonnes per year Ammonia is received via pipeline from the Ammonia Plant to produce nitric acid, ammonium nitrate solution and TAN prill. TAN Plant Nitric acid plant

Infrastructure Map

Nitric acid tanks (two storage tanks with a total capacity of 3,000m3) Ammonium nitrate solution plant Ammonium nitrate solution storage (500 metric tonnes) TAN prilling plant Bulk TAN storage building (12 000 tonnes) TAN bagging facility Bagged TAN storage building (1800 tonnes) Bagged TAN staging area (7000 tonnes) Bulk truck loading system (TAN and ammonium nitrate solution) Off-spec storage and treatment area Seawater cooling tower and closed loop cooling system Treated domestic wastewater pond 3 (32.8 m x 20.8 m x 2.9 m) Treated domestic wastewater pond 6 (15.6 m x 10.8 m x 1.5 m) Clean water/ contingency contaminated water pond 1 (42.35 m x 32.9 m x 2.9 m) Clean water/contingency contaminated water pond 2 (51.3 m x 60.8 m x 2.9 m) Contaminated water pond 4 (99.8 m x 29.0 m x 2.85 m) Contaminated water pond 5 (99.8 m x 29.0 m x 2.85 m) Five aerobic treatment units (ATUs)


6. Attachment 6A: Emissions and discharges

6.1 Emissions to air

Key emissions to air from the TAN Plant include point source emissions, comprising mainly ammonia and particulates (ammonium nitrate) from the common stack and oxides of nitrogen and ammonia from the nitric acid plant stack. During normal operation, ammonia is intermittently vented from the unit 31/32 (U31/32) ammonia vent located on the side of the prill tower. During start-up of the plant, there is the potential for ammonia to be vented from the unit 12 (U12) vent on the side of the absorber tower on the nitric acid plant.

Discharge points to air are shown in Table 6.1.

Table 6.1: Emission points to air

Source Emission type Frequency Controls Reference on Map of Emission Points and Infrastructure Map

Common stack (TAN prilling tower [unit 32]; drum dryers; fluid bed cooler)

NH3, PM Continuous (normal operation)

Three stage scrubbing system to comprise of following components: • independent

scrubber for prilling tower air emissions

• rotary brush scrubber for bleed air emissions

• final scrubber for rotary brush scrubber air emissions.

Attachment 2: Map of emission points Common stack (A1)

Nitric acid plant (unit 12) stack

NOx, NH3, N2O Continuous (normal operation)

Catalytic abatement system

Attachment 2: Map of emission points Nitric acid plant stack (A2)

Unit 31/32 ammonia vent

NH3 Intermittent Process control Attachment 2: Map of emission points Unit 31/32 vent (A3)

Unit 12 ammonia vent

NH3 Infrequent (start-up)

Process control Attachment 2: Map of discharge point locations Unit 12 vent (A4)

6.1.1 Air emissions from Part IV assessment and PER

Air emissions from the TAN Plant were assessed at the Public Environmental Review (PER) stage under Part IV of the EP Act. The proposal for the TAN Plant was granted approval at the time providing that:

• YPN adopted and implemented best practice pollution control technology to minimise NH3 and TSP emissions from the common stack

• emissions from the TAN Plant are regulated through Part V of the EP Act commensurate with the use of best practice pollution control technology.

The EPA noted that the expected NOx stack emission concentration from the nitric acid plant stack was consistent with the best practice emission concentrations listed in the:

• Fertilizers Europe Best Available Techniques for Pollution Prevention and Control in the European Fertilizer Industry Booklet No. 2: Production of Nitric Acid (Fertilizers Europe 2000)


• European Commission Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals – Ammonia, Acids and Fertilisers (European Commission 2007).

However, the EPA also noted that the expected NH3 and PM10 stack emission concentrations from the common stack would be above the best practice emission concentrations listed in the above documents. As a result, the EPA recommended that Condition 5-1 in MS 870 be imposed as follows:

5-1 The proponent shall adopt and implement best practice pollution control technology as determined by the Chief Executive Officer of the Department of Environment and Conservation (DEC) on advice of the CEO to minimise all relevant emissions from the TAN Plant ammonium nitrate prilling plant.

In September 2019, the EPA published Report 1648 (as part of the section 46 inquiry into Condition 5-1), which stated:

"A desktop technical review undertaken by the DWER and completed in March 2018, confirmed that contemporary best practice pollution control technology [e.g. wet scrubbers and an oxides of nitrogen (NOx) reduction unit equipped with a catalyst (i.e. a De-NOx reactor)] has been incorporated into the TANPF and that its performance compared favourably with relevant best practice stack emission concentration criteria under normal operating conditions (DWER 2018)".

"The EPA also notes that the amended licence includes stack emission concentration limits for NOx (as NO2), NH3, and nitrous oxide (N2O) from the TANPF nitric acid plant stack and for particulate matter and NH3 from the TANPF ammonium nitrate prilling plant common stack that are commensurate with relevant best practice stack emission concentration criteria under normal operating conditions".

6.1.1.1 Air emissions during normal operation (as described in the PER)

The TAN Plant consists of three major process components which are designed to operate independently of each other. In the PER, normal operations for each component were considered as:

• Nitric acid plant – 95% availability (approximately 345 days per year)

• Ammonium nitrate solution plant - 95% availability (approximately 345 days per year)

• TAN prilling plant - 90% availability (approximately 329 days per year).

Emission rates for key parameters as considered by EPA are shown in Table 6.2.

Table 6.2: Atmospheric emissions characteristic of normal operations of the TAN Plant (as considered in the EPA Assessment)

Source NOx (g/s)

NO2 (g/s) (note 1)

PM10 (g/s) (note 2)

NH3 (g/s)

Nitric acid plant 4.2 2.1 - 0.02 TAN prilling tower - 0 0.8 0.6 Nitric acid storage tank vent A

0.04 0.02 - -

Nitric acid storage tank vent B

0.04 0.02 - -

Power generation3 2.1 1.1 0.058 - (1) A 50% conversion of NOx to NO2 was assumed. (2) Emissions of ammonium nitrate dust from the prilling tower were assessed as PM10. (3) Emissions associated with power generation at the adjacent Ammonia Plant.


6.1.1.2 Air emissions during non-routine operation (as described in the PER)

Plant shutdowns are required in response to upset conditions, equipment failure or for maintenance; with start-ups then required to restore normal operations. Significant process venting is not required during shutdowns and start-ups. The closed-loop design of the TAN Plant generally only provides for discharges of major emissions through controlled emission sources.

The following non-routine operating scenarios were considered:

• cold start-up once per year (annual maintenance), with the start-up expected to take approximately six hours duration

• planned annual maintenance shutdowns

• biannual shut down of the nitric acid plant for catalyst replacement

• emergency shutdown which would result in the majority of emissions being released via the nitric acid plant stack. Emergency shutdowns are anticipated to be rare and are expected to be less than one hour in duration.

Emission rates for key parameters as considered by the EPA for non-routine operations are shown in Table 6.3.

Table 6.3: Atmospheric emissions characteristic of non-routine operations of the TAN plant (as considered in the EPA assessment) Source NOx (g/s) NO2 (g/s)

(note 1) PM10 (g/s)

(note 2) NH3 (g/s)

Nitric acid plant 39 19.4 0 0.1 TAN prilling tower 0 0 2.4 1.6 Nitric acid storage tank vent A 0.04 0.02 0 0 Nitric acid storage tank vent B 0.04 0.02 0 0 Power generation 2.1 1.1 0.058 0

(1) A 50% conversion of NOx to NO2 was assumed. (2) Emissions of ammonium nitrate dust from the prilling tower were assessed as PM10.

6.1.2 Air emissions from 2012 assessment updates (post works approval)

Subsequent to the granting of Works Approval W4701 in 2012, YPN initiated a revised air quality modelling assessment for the TAN Plant (ERM 2012). Ambient air quality criteria used in the assessment of emissions to air is shown in Table 6.4.

Table 6.4: Ambient air quality criteria

Parameter Criteria (µg/m3) Average Guideline

NOx (as NO2)

246 1 h

National Environmental Protection (Ambient Air Quality) Measure

61 Annual

SO2 520 1 h 226 24 h 56 Annual

CO 10300 8 h PM10 50 24 h

NH3 330 1 h Approved Methods for the Modelling and Assessment of Air Pollutants in New

South Wales (NSW 2005) 180 Annual

6.1.2.1 Summary of findings from revised 2012 assessment

Predicted GLCs of NO2 and NH3 decreased in the revised assessment compared to the data submitted at the PER stage. The results indicated that for normal operations predicted concentrations for all modelled species were below the adopted assessment criteria (Table 6.5).


Table 6.5: Predicted ground level concentrations (including background) during normal operations of the TAN Plant (2012 Updated Modelling)

NO2 SO2 TSP PM10 PM2.5 NH3 μg/m3 μg/m3 μg/m3 μg/m3 μg/m3 μg/m3

Average period

1hr 1yr 1hr 24hr 1yr 1yr 24hr 24hr 1yr 1hr

Searipple Rd (Karratha)

60.1 6.5 1.6 0.6 0.2 19.0 24.9 0.1 1.0 1.0

Balmoral Rd (Karratha)

55.5 6.5 1.2 0.6 0.2 18.9 24.6 0.0 0.8 1.1

Dampier 83.9 7.1 6.1 2.1 0.3 19.0 26.4 0.1 2.6 1.2 Hearson Cove 88.2 8.7 4.8 1.4 0.3 19.2 26.8 0.3 3.0 3.4 Deep Gorge 94.3 7.6 5.5 1.7 0.3 19.1 26.6 0.2 2.7 2.2 Maximum 186.2 10.2 13.1 3.9 0.7 19.3 30.2 0.4 6.4 7.0 Background 45.1 6.3 0.4 0.3 0.2 18.9 23.8 N/R N/R 0.9 Criteria1 246 61 520 226 56 90 50 25 8 330

(1) NEPM Ambient Air criteria applied to NO2, SO2, PM10 and PM2.5; criteria from Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (NSW 2005) applied to TSP, NH3.

(2) GLC values include background concentrations modelled. (3) N/R = Not Reported

Predictions for non-routine operations indicated that maximum GLCs could result in an exceedance of the NO2 1-hour criteria; however, modelling did not anticipate an exceedance of any ambient criteria at receptors (Table 6.6). Non-routine operations were expected to occur for up to six non-continuous hours per year, i.e. not continuously for a year as modelled. The potential for coincidence of worst-case atmospheric conditions and abnormal operations is low.

Table 6.6: Predicted ground level concentrations during non-routine operations of the TAN Plant (2012 Updated Modelling)

Parameter and units NO2 SO2 PM10 PM2.5 NH3

μg/m3 μg/m3 μg/m3 μg/m3 μg/m3 Average Period 1hr 1hr 24hr 24hr 24hr 1hr Searipple Rd (Karratha) 64 1.6 0.6 25 0.1 1.6 Balmoral Rd (Karratha) 64 1.2 0.6 26 0.2 2 Dampier 90 6.1 2.1 26 0.9 2.7 Hearson Cove 155 4.8 1.4 33 0.3 13.5 Deep Gorge 131 5.5 1.7 28 0 7.7 Maximum 300 13.1 3.9 38 1.8 31.8 Criteria1 246 520 226 50 25 330

(1) NEPM Ambient Air criteria applied to NO2, SO2, PM10 and PM2.5; criteria from Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (NSW 2005) applied to TSP, NH3.

(2) GLC values include background concentrations model.

In relation to the potential for air emissions from the TAN Plant to cause human health impacts, the revised assessment noted the following:

• the contribution of the TAN Plant is less than 1 μg/m3 or approximately 1% of the predicted ambient NO2 concentration

• the contribution of the TAN Plant to the concentration of pollutants in areas of human habitation is small and would not be discernible from natural hourly variation observed during ambient monitoring.

6.1.3 Air emissions assessment from commissioning data

The stack emissions data (CEMS and monthly stack monitoring) as presented in the commissioning report was reviewed by DWER in the context of previous air emissions modelling information available. The review identified that:


• emission rates for NH3 and NOx derived from monthly stack testing during commissioning were between 1.2 g/s and 2.2 g/s for NOx, and 0.003 g/s and 0.02 g/s for NH3. These rates aligned with those assessed at the works approval stage (and as discussed in sections above)

• statistical analysis of NOx emission rates derived from CEMS time series data, excluding non-operational periods, concluded that:

o emission rates were 1.48 g/s as the 95th percentile value, and 6.61 g/s as the 99th percentile. The value of 4.2 g/s used in the original modelling study to represent normal operations is between the 98th and 99th percentile, indicating that for the commissioning period, the plant was producing lower emissions than those assumed in the previous assessment

o the maximum emission rate was 81 g/s, which is much higher than the maximum emissions used to characterize abnormal operations. There would be potential for short-term elevated GLCs if these concentrations were to occur post commissioning. However, it is noted that these high concentrations occurred in the early commissioning period and were much higher than adjacent readings; the hourly averages were also comparable to the maximum emission rates modelled

• statistical analysis of the CEMS data showed that emission rates considered in the original modelling assessment were conservative

• statistical analysis of the time series data showed that higher emissions during abnormal operations are likely to be produced for less than 0.01% of time. Also, the higher emission rates noted are for periods of less than an hour. Modelling scenarios considered start-up emission rates for the entire year, which is a highly conservative approach to a modelling assessment.

6.1.4 Ammonia emissions from unit 12 and unit 31/32 vents

As described in the initial design documentation, some ammonia is expected to be discharged from the U31/32 vent (ammonium nitrate solution plant/TAN prilling plant) on a daily basis during normal operations; and also from the U12 vent (nitric acid plant) during start-ups.

6.1.4.1 Unit 12 and unit 31/32 initial design ammonia emissions

Initial design conditions were assessed as follows:

• U31/32 vent:

o once per day for 10 minutes

o design emission rate of 0.2 kg NH3 per hour, equates to total 33 g for 10-minute period per day.

• U12 Vent:

o design emission rate of 2.5 kg/h (not continuous)

o actual venting rate for normal operations during commissioning was 0 kg/h

o total emission for plant start-up estimated as 40 kg.

6.1.4.2 Unit 12 and Unit 31/32 revised ammonia emissions assessment

In 2018, the TAN Plant was shut down to commence the TAN Recovery Project, which has addressed issues with engineering design and equipment failures that has compromised the operability and environmental performance of the plant. As part of the engineering assessments carried out to identify the extent of repairs and improvements necessary to facilitate long-term operability of the plant, the emissions performance of the TAN Plant has been reviewed. This review has identified


discrepancies in ammonia venting from the U12 vent and U31/32 vent compared with the design specifications (as detailed in Section 6.1.4). More specifically, higher rates of ammonia emissions were determined for the U31/32 vent and the venting protocol for nitric acid plant start-ups has been modified from design.

Additional assessments, including revised control philosophies (as detailed in 6.1.4.3 and 6.1.4.4) and process modelling, have been carried out to establish the nature and extent of ammonia venting from the U12 and U31/32 vents.

6.1.4.3 Unit 12 ammonia vent – revised control philosophy

Ammonia is typically vented from the U12 vent to assist in pressure control prior to “light-off” of the ammonia converter when NH3 is oxidised to NO2 for ultimate production of nitric acid. However, YPN engineers have developed a new control philosophy and procedure whereby venting will not be required for control of ammonia pressure for start-ups. Pressure control is critical to maintain the correct ratio of ammonia to oxygen in the converter, with an explosion risk associated if incorrect ratios occur. This procedure will involve reducing the ammonia flow rate through the flow control valve to achieve the required upstream pressure for ratio control without a need to rapidly reduce pressure via venting of ammonia. The revised control procedure will be implemented ahead of the plant re-start following completion of the next phase of the TAN Recovery Project in early 2020.

Plant start-ups thereafter will not require venting of ammonia for pressure control. In the unlikely event that optimal pressure control cannot be achieved during start-up using the new control procedure, then ammonia may be vented from the U12 vent for plant and personnel safety reasons. The risks associated with such venting are discussed in Section 6.1.4.5.

To verify that no emissions from the U12 vent occur during the next start-up, the position of the vent control valve will be monitored and recorded through the TAN Plant control system. If the valve remains closed for the duration of the start-up this confirms that there are no emissions of ammonia.

6.1.4.4 U31/32 ammonia vent – revised control philosophy

A revised control philosophy has been developed by YPN engineers to minimise ammonia emissions from the U31/32 vent during normal operations. This will be implemented when the next phase of TAN Recovery Project concludes, and the plant is re-started; which is currently scheduled for early 2020. A process description is summarised as follows:

• liquid ammonia from the Ammonia Plant is fed to the U31 and U32 evaporators, which produce gaseous ammonia for reaction with nitric acid to form ammonium nitrate

• water present in the liquid ammonia feed accumulates in the evaporators leading to an increase in temperature and carryover of water (gas) to the ammonia gas

• currently, the ammonia water mixture is drained from the evaporators and directed to the ammonia purge stripper which separates most of the ammonia from the water, with the remaining weak ammonia / water mixture blown down to the atmospheric stripper and subsequently drained for disposal; residual ammonia vapours are vented to atmosphere during blowdown due to the pressure drop of approximately 5 bar

• draining of the evaporator is controlled via flow meters and occurs at frequent intervals to maintain required evaporator temperatures; the exact frequency varies based on the amount of water contained in the ammonia feedstock from the Ammonia Plant

• blowdown of the ammonia stripper occurs at frequent intervals, which are influenced by evaporator draining frequency, to maintain the level within a controllable range due to accumulation of water; typically, frequency of blowdowns is 2 – 5 times per day


• an initial higher ammonia emission rate occurs at the commencement of blowdown and ceases once blowdown is stopped. Blowdowns typically last 5 – 10 minutes in duration and are carried out multiple times a day; as such, the emission impacts will change from hour to hour depending on the venting cycle time.

The revised control philosophy involves maximising ammonia stripping in the ammonia stripper and reducing the amount of ammonia boiled off after blowdown and before draining. This is achieved by maximising the temperature in the ammonia stripper from the design value of 50 °C to a new value of 90 °C ± 10 °C. The revised philosophy also stops the addition of heat in the atmospheric stripper to prevent ammonia vapour boil off.

Residual vapours from the atmospheric stripper produced from the pressure drop between the ammonia stripper and atmospheric stripper will then be vented to atmosphere via the existing U31/32 vent.

This control philosophy is anticipated to recover and recycle almost all of ammonia that has been vented from blow-down of the evaporators and the purge stripper. The ammonia venting trial successfully demonstrated a theoretical calculated maximum ammonia hourly averaged emission of 4.5 g/s with a total max daily emission of 115 kg/day. The expected typical value is 4.5g/s one hourly average and daily total of 50 kg/day. The difference is based on the total water content in the ammonia and the subsequent change in blowdown frequency.

6.1.4.5 Updated emissions impact assessment – future (normal) operations

As discussed in Section 6.2.4.3, YPN has developed a revised operating strategy to recover and recycle ammonia from blow-down of U31/32 evaporators with reduction in venting. As such, the revised operating strategy is expected to produce negligible ammonia emissions using a conservatively calculated peak 1-hour average ammonia emissions discharge rate of 4.5 g/s from the U31/32 vent.

The actual recovery efficiency and vent ammonia emission rate will be validated once the plant is operational in early 2020 after completion of the TAN Recovery Project (refer to vent emissions verification section below).

Predicted ammonia GLCs from implementation of the revised operating strategy are shown in Table 6.7.

Table 6.7: Predicted maximum ammonia GLCs from dispersion modelling of YPN emissions – future (normal) TAN operations U31/32 NH3 vent emission rate scenario

Averaging period Criteria Deep Gorge Hearson Cove

Percentage of criteria for highest GLC at

sensitive receptors μg/m3 μg/m3 μg/m3 %

Future operation Max 1 h 330 361 115 109 2nd high 1 h 330 207 110 62 99.9%ile 330 37 52 16 99.5%ile 330 15 22 7 Annual 180 1 1 0.6

The maximum 1-hour average GLC of ammonia from the implementation of the revised blow-down procedures is predicted to exceed the criteria at Deep Gorge. The second highest 1-hour average and 99.9 and 99.5 percentile GLCs are well below the criteria.

The modelled GLCs are based on a conservative calculation of the ammonia emission rate and assume the emission occurs for the full hour, whereas the peak emission rate is predicted to occur for less than 10 minutes for each venting cycle. As such, the actual hourly average GLCs are highly likely to be lower than predicted.


Vent emissions verification

It is proposed that during the next TAN Plant start up, the revised U31/32 vent control philosophy will be implemented into normal operating procedures. At this point, additional monitoring of emissions will be carried out from the vent to confirm the calculated ammonia emission rate of 4.5 g/s. As part of the vent emissions verification work, YPN will commit to the following:

Within three months of the sustained start-up of the TAN Plant and the TAN Plant achieving 100% steady-state production, YPN will commence monitoring emissions from the U31/32 ammonia vent (emission point A3) to validate the revised emission rate design criteria of 4.5 g/s.

The results of the monitoring will be used to model ground level concentrations of ammonia at the nearest sensitive receptors and confirm the risk assessment of ammonia emissions from the TAN Plant. YPN will provide a report on the findings of the monitoring and assessment to DWER within three months of the completion of the monitoring.

It is anticipated that DWER will specify the implementation of the further vent monitoring, assessment and reporting work through conditions of the new licence.

6.1.5 Cumulative emissions impact assessment – future (normal) operations

A conservative approach has been adopted to predict the cumulative impact of emissions from both the Ammonia Plant and the TAN Plant by assuming the modelled maximum GLCs from each plant occur simultaneously at individual receptors. The predicted GLCs from both plants have been added together for assessment against the relevant criteria.

Emissions sources from each plant are also separated by at least 390 m (Ammonia Plant package boiler stack to TAN Plant nitric acid plant stack), which means that when the wind blows along the axis of those stacks, the emissions from the stack nearest to the wind will already be significantly diluted before the emissions from the next stack interact with the plume. A similar situation would occur for the alignments of the other stacks with various wind directions.

An assessment of cumulative impacts of emissions from the TAN Plant and Ammonia Plant, which includes a contribution from background pollutant levels, is summarised in Table 6.8. This assessment has considered the ammonia emissions expected from implementation of the revised U31/32 blow-down procedure once the TAN plant returns to operations after completion of the TAN Repair Project. A conservative approach has been adopted whereby the peak ammonia emission rate from U31/32 venting that is to occur for 1-hour each day, is assumed to occur at a time of worst-case meteorological conditions for dispersion of emissions.

The GLCs are derived from:

• the 2015 updated modelling of Ammonia Plant emissions (using AERMOD and KarrathaAirport meteorological data) scaled for use of Ammonia Plant meteorological data

• the 2019 modelling of TAN Plant emissions (using AERMOD and site meteorological data)which includes updated emissions inventory data.

While the assessment cannot determine where each of the maximum GLCs will occur and under what meteorological conditions, the approach is considered conservative as the potential for maximum GLCs to occur from both sources at the same time and at the same location is extremely unlikely.


Table 6.8: Cumulative emissions assessment - predicted maximum GLCs from dispersion modelling of YPN and YPF emissions – future (normal) operations

Parameter Criteria (µg/m3) Average

Deep Gorge

(µg/m3)

Dampier (µg/m3)

Karratha (µg/m3)

Hearson Cove

(µg/m3)

Maximum of criteria

(%) excluding

background

Background1 (µg/m3)

Maximum of criteria

(%) including

background NOx (as NO2) 246 1 h 5.96 4.29 1.94 11.38 4.6 45 23

61 Annual 0.47 0.22 0.057 1.16 1.9 6.3 12 NH3

330 1 h 34 8 3 11 10 0.9 10 180 Annual 0.09 0.02 0.004 0.21 0.12 N/R 13

TSP 90 24 h 0.11 0.069 0.033 0.26 0.29 18.9 21 PM10 50 24 h 0.055 0.035 0.016 0.13 0.26 23.8 48

(1) Background data from Burrup Peninsula Technical Ammonium Nitrate Production Facility Air Quality Assessment Update (ERM 2012). (2) N/R = Not Reported.

The cumulative assessment suggests predicted GLCs from operations combined with background levels of pollutants are below air quality criteria. As such, it is unlikely that adverse impacts would occur to human health at nearby sensitive receptors. The majority of impacts from NOx, TSP and PM10 emissions are due to background levels of these pollutants, whereas the impacts from NH3 emissions largely arise from TAN Plant operations, in particular from venting of NH3.

6.1.6 Best practice air emissions performance – normal operations

The TAN Plant design has incorporated best available control technologies (BACT) for management of emissions from the nitric acid plant and common stacks. The current licence includes emission limits which are based on guidance from European agencies that reflect BACT for ammonium nitrate manufacturing (Fertilisers Europe 2000 and European Commission 2007). These limits are to apply for normal operations (Table 6.9).

Table 6.9: BACT air emission discharge concentrations – normal operations Discharge point Emission Limit Units Reference conditions (note 1) Common stack (A1) PM 15 mg/Nm3 60-minute average, STP, dry, not adjusted for O2

NH3 10 mg/Nm3 60-minute average, STP, dry, not adjusted for O2 Nitric acid plant stack (A2) NOx (as NO2) 103 mg/Nm3 60-minute average, STP, dry, adjusted to 17% O2

NH3 0.75 mg/Nm3 60-minute average, STP, dry, adjusted to 17% O2 N2O 196 mg/Nm3 60-minute average, STP, dry, adjusted to 17% O2

Note 1: STP = 273.15K and 101.32 kPa

The above limits are contained within the current licence (noting corrections made in Table 6.10 to the reference conditions wrongly stated in the current licence).

6.1.7 Updated air emission impact assessment – (future) start-up operations

The impact assessment for venting of ammonia from the U12 vent concluded a low risk due in part to the low frequency of start-ups anticipated for future operations when the TAN Recovery Project is concluded, and the plant operates continuously for nominal six months at a time. Additionally, with the revised control philosophy, ammonia is not expected to be vented during start-ups. As such, controls in the form of monitoring and application of emission limits to the U12 vent are not considered necessary.

The existing licence includes concentration limits for NH3 and NOx emissions discharged from the nitric acid plant stack during start-up operations (Table 6.10). These limits are based on concentrations observed during plant start-ups that occurred during the commissioning works in 2016-2017.


Table 6.10: Air emission limits in current licence – Nitric Acid Plant start-up Discharge point Emission Limit (note 1) Units (note 2) Nitric acid plant stack (A2) NOx (as NO2) 1540 mg/m3

NH3 11.5 mg/m3 (1) The limit applies for 2 hours from commencement of start-up of NAP. Limits for normal operations then apply. (2) Units are 60-minute average concentrations, at 273.15K, 101.32 kPa, dry gas basis and adjusted to 17% O2

The risk assessment conducted by DWER for the current licence was informed by dispersion modelling that used Karratha airport meteorology. That assessment showed the maximum hourly average GLC for NOx and NH3 (including background concentrations) were 62% and 4% respectively of the air quality criteria at Hearson Cove. A medium risk rating was assigned by DWER to these emission parameters during start-ups.

More recent modelling conducted using site meteorological data has shown lower predicted GLCs at sensitive receptors compared with modelling conducted using Karratha airport data. Scaling of maximum 1-hour average GLCs for start-up emissions based on the difference in predicted GLCs for normal operations has informed the risk of impacts from nitric acid plant start-ups (Table 6.11). Annual average GLCs are not considered as start-ups are concluded within hours of commencement.

Table 6.11: Predicted maximum GLCs from dispersion modelling of NAP stack emissions – start-up operations Parameter Averaging

period Criteria Deep

Gorge Dampier Karratha Hearson

Cove Percentage

of criteria for highest

GLC at all sites

Background Percentage of criteria

for highest GLC at

sensitive receptors including

background μg/m3 μg/m3 μg/m3 μg/m3 μg/m3 % μg/m3 %

NOx (as NO2) 1 h 246 7.68 4.00 1.67 9.83 4.0 45 22.3 NH3 1 h 330 0.025 0.0067 0.0026 0.047 0.014 0.9 0.29

This assessment shows that the maximum predicted 1-hour average GLCs are well below the criteria for direct emissions impacts and in combination with the background levels of NOx and NH3. There is significant conservatism in this assessment, with the GLCs reported being the maximum hourly averages from the modelling year while start-ups are anticipated to nominally occur twice per year. A low likelihood is therefore associated with start-up emissions that prevail for one to two hours, twice per year, coinciding with the worst-case meteorological conditions for dispersion. The relatively low level of predicted impacts (in comparison with the criteria) and the low likelihood of coincident start-up and unfavourable meteorology suggests a low risk outcome from start-up events.

As such, emission limit controls applied to nitric acid plant start-ups are not considered necessary.

Emissions from the common stack at commencement of start-up are negligible, increasing to those observed during normal operations as the prilling process comes on-line. As a consequence, the limits for normal operation are appropriate for emissions from the common stack at all times.

Negligible emissions are also expected from the U31/32 vent during start-up (as will occur during normal operations) once the revised control procedures are implemented for recommencement of operations in early 2020.

6.1.8 Monitoring of air emissions

Details of emissions parameters and monitoring methods for monitoring and assessment of emissions are shown in Table 6.12. Quarterly stack testing of the common stack is conducted using the methods shown in Table 6.12.


Continuous monitoring of particulate emissions from the common stack is not necessary since the low concentrations measured in the quarterly testing indicate a low environmental risk and are unlikely to be detectable with the available continuous (particulate) emission monitoring (CEMS) technology. The relatively low levels of NH3 in the emissions also provide a low environmental risk. Those emissions are well managed by the scrubbing system, which uses continuous monitoring of scrubber water pH to ensure optimal conductions prevail at all times for efficient control of NH3 emissions. The pH monitoring and control system precludes a need for continuous monitoring of NH3 from the Common Stack.

Continuous monitoring of emissions from the nitric acid plant stack is carried out by a CEMS, which was designed and is operated as per specifications in the CEMS Code (DER 2016a).

Table 6.12: Emissions monitoring conditions

Discharge point

Monitoring location Parameter Frequency

Averaging period (note 1, note 2 & note 3)

Units (note 4)

Reference O2 adjustment

Monitoring method

Common stack

Monitoring point A1

Volumetric flow rate (note 5)

Quarterly 60 minutes m3/s N/A USEPA Method 2

Particulate matter

Quarterly 60 minutes mg/m3 g/s

N/A USEPA Method 17

NH3 Quarterly 60 minutes mg/m3 g/s

N/A USEPA CTM 027

Nitric acid plant stack

Monitoring point A2

Volumetric flow rate

Continuous 60 minutes m3/s N/A CEMS

NOx (as NO2) Continuous 60 minutes mg/m3 g/s

17% v/v CEMS

NH3 Continuous 60 minutes mg/m3 g/s

17% v/v CEMS

N2O Continuous 60 minutes mg/m3 g/s

17% v/v CEMS

Note 1: Averaging period for quarterly monitoring reflects duration of sampling for each parameter. Note 2: Averaging period for CEMS monitoring is calculated from 1 second past the hour to the commencement of the next hour (page 8 of CEMS code, definition of a “valid hour”). Note 3: CEMS Code requires 1-minute raw data to be stored indefinitely. The indicated 60-minute averaging period is for assessment against discharge limits in Table 6.9 and Table 6.10. Note 4: Volumetric flow rate unit (m3/s) and concentrations (mg/m3) are referenced to STP (273.15K and 101.32 kPa) as dry gas. Note 5: Volumetric flow rate requires measurement of temperature (included in USEPA method 2) and dry gas density (USEPA method 3a).

The CEMS Code includes requirements for biannual cylinder gas audits (CGA) and Relative Accuracy Test Audits (RATA) to be carried out, which involve emissions testing utilising USEPA methods 7E (for NOx), CTM027 (for NH3), CTM038 (for N2O) and method 3A (for O2). These audits are sufficient to demonstrate the ongoing capability of the CEMS, along with the daily zero and span drift checks carried out automatically by the CEMS control software. As such, quarterly testing of Nitric Acid Plant stack emissions is not required.

Monitoring is also not required for the U12 vent and U31/32 vent due to the low risks associated with ammonia emissions from these sources.

Continuous ambient air quality monitoring for ammonia is carried out at locations in the plant and on the plant boundary. The monitors are used to detect ammonia released from venting or inefficient flaring. The location of ammonia ambient monitors is detailed on the Map of Monitoring Locations in Attachment 2. The monitors are alarmed when ammonia concentrations reach 35 ppm allowing YPN to investigate the cause and take appropriate action.


6.2 Discharges to water

There are no direct discharges to water from the TAN Plant.

Process effluent is currently discharged via the adjacent Ammonia Plant and Water Corporation’s MUBRL which reports to the marine environment of King Bay. The MUBRL was approved by the Minister for Environment under MS 567 (June 2001) and MS 594 (June 2002). Wastewater entering the MUBRL is managed through a contract between YPF and the Water Corporation, which was executed on 20 March 2015.

Water Corporation has developed an Operational Marine Environmental Management Plan (OMEMP) which outlines the approach for managing the discharge of combined effluent from the MUBRL to achieve specified environmental objectives using a program of in-field and field-based monitoring. The specified ecological and environmental objectives are based on the EPA’s Pilbara Coastal Water Quality Consultation Outcomes (2006) report which recommended setting a high level of ecological protection for King Bay in areas outside of the MUBRL outfall mixing zone, and an area of low ecological protection within the mixing zone.

End-of-pipe trigger levels have been set through the OMEMP and act as initial indicators that the environmental objectives may not being met. The triggers were back calculated from the high protection trigger levels (ANZECC 99% level of protection) and take into consideration the predicted dilutions achieved at the outfall.

Although the Ministerial Statements and the OMEMP set a regulatory framework for managing the cumulative discharge from the MUBRL and specify water quality triggers for the combined effluent discharge, the OMEMP recommends that the management of discharges from each individual operator should be regulated under the respective EP Act licences or Ministerial Statements. As such, discharge limits are regulated through the licence for the Ammonia Plant, and monitored at monitoring point W4 within the Ammonia Plant.

This waste process presently occurs under the current licence.

6.3 Fugitive emissions (dust)

Trafficable areas of the TAN Plant are sealed, with non-trafficable areas predominantly gravelled. Ammonium nitrate dust can be generated in certain areas of the plant, including the:

• bagging plant

• truck loading area adjacent to the bulk store

• off-spec area.

Dust extraction equipment is located within the bagging and truck loading areas, with dust being managed in the off-spec area. Runoff/washdown from the truck loading and off-spec areas are directed to the contaminated surface water ponds. Fugitive dust is also managed through the following controls:

• trucks entering and exiting the plant must be cleaned prior to exiting the loading area

• bitumised roads within the plant are maintained in a clean state to minimise dust lift-off from truck movements

• a 20 km/hr speed limit is imposed on the plant.


6.4 Groundwater monitoring

Conditions of MS 870 require YPN to undertake detailed hydrogeological studies to quantify groundwater quality, groundwater flow direction and depth to groundwater beneath the plant and surrounding areas. Further requirements relating to the design, construction and location of groundwater monitoring bores, sampling, and establishment of trigger levels are also prescribed in MS 870 as described in Table 6.13.

Table 6.13: MS 870 groundwater requirements Condition Requirement 8-3 The proponent shall design, construct, and locate groundwater monitoring bores to the

satisfaction of the CEO on advice of the DEC and the Department of Water, having regard for the outcomes of the hydrogeological studies required by condition 8-1 and the Department of Water’s Water Quality Protection Note 30 on Groundwater Monitoring Bores.

8-4 The proponent shall sample/monitor all groundwater bores required by Condition 8-3 every six months and shall set groundwater monitoring trigger values at a value of 10% above the baseline contaminant concentrations obtained from the hydrogeological studies required by condition 8-1.

8-5 In the event that monitoring required by condition 8-4 indicates an exceedance of trigger levels: 1. The proponent shall report such findings to the CEO within 7 days of the exceedance

being identified. 2. The proponent shall provide evidence which allows determination of the cause of the

exceedance. 3. If determined by the CEO to be project attributable, the proponent shall submit actions

to be taken to address the exceedance within 7 days of the determination being made to the CEO.

4. The proponent shall implement actions to address the exceedance and shall continue until such time as the CEO determines that the remedial actions may cease.

5. The proponent shall submit bi-annually, or at a frequency defined to the satisfaction of the CEO, the results of monitoring required by condition 8-4 to the CEO, until such time as the CEO determines that reporting may cease.

Quarterly groundwater monitoring is undertaken to monitor for any quality changes associated with TAN Plant operations. The groundwater monitoring network as shown in the Map of Monitoring Locations (see Attachment 2) consists of a boundary network of and upstream and downstream wells sufficient to identify any quality changes or risk of off-site impacts.

The groundwater monitoring and analytical regime is specified in Table 6.14. The parameters align with the current licence except for MDEA and its by-products. MDEA is not used or produced on the TAN Plant; and results of groundwater monitoring for MDEA and its by-products have been below detection limits in all samples taken to date. Accordingly, these parameters do not form part of the suite of analysis required to be undertaken under MS 870.


Table 6.14: Groundwater monitoring

Parameter

Reference on Map of Monitoring Locations

Unit Frequency Averaging Period

Sampling method 1

Analytical method

pH

US2, DS1, DS2, DS3, DS4, DS5, DS6, DS7 and DS8

NA

Quarterly Spot sample AS/NZS 5667.11

In-field or YPF laboratory

Electrical conductivity µS/cm Redox potential mV Temperature oC Dissolved Oxygen % Ammonia as ammoniacal nitrogen (NH3-N)

Nitrate and nitrite Aluminium Cadmium Chromium (III) Chromium (VI) Copper Nickel Lead Sulfate Total dissolved solids Total Kjeldal nitrogen Total nitrogen as N and total oxidised Total recoverable hydrocarbons Total phosphorus as P Total organic carbon Total alkalinity Major cations (K+, Na+, Ca2+,Mg2+) Zinc

(3) All samples are measured and collected in a flow-through cell. (4) Where possible limits of reporting will be lower than the site-specific trigger values set for groundwater contaminants under MS 870. (5) Metal samples are filtered for analysis.

6.5 Noise emissions

Noise emissions from the TAN Plant are generated from process plant and equipment, including fans, blowers, compressors and pumps during operations. Noise mitigation measures implemented at the plant include:

• equipment such as compressors and pumps are located within enclosures, cases, blankets or are situated in a building as required

• silencers installed on vents

• pipework with acoustic cladding

• relief system for flow/ acoustically induced vibration and fatigue

• repairing, modifying or replacing high noise generating items

• selecting machinery with minimum noise levels.

During commissioning of the TAN Plant, the nitric acid plant compressor was identified as the primary source of noise. To mitigate the impact of noise from the compressor, external acoustic insulation was fitted to the compressor air inlet duct in August 2017.


During its assessment of the current licence, DWER concluded that cumulative noise levels at the nearest sensitive receptor (Hearson Cove) could be minimised by ensuring that all industrial facilities located in proximity incorporated noise attenuation measures on all identified significant noise sources to reduce noise levels, as practicable, at their respective plant boundaries to below the 65 dB(A) specified noise level in the Environment Protection (Noise) Regulations 1997 (Noise Regulations).

Noise monitoring during commissioning of the TAN Plant provided monitoring data reflective of cumulative noise emission levels at receptors. The noise monitoring was completed between 30 May 2016 and 17 May 2017 and involved:

o daily attended ‘spot’ measurements at Hearson Cove and the Premises boundary

o attended measurements at Hearson Cove conducted during TAN Plant performance testing that included 1/3 octave band analysis

o continuous monitoring on the south-eastern boundary of the Premises and at Deep Gorge between 27 April and 4 May 2017.

Review of the noise monitoring data indicated that ambient noise levels at Hearson Cove during the TAN Plant commissioning were below the 65 dB(A) level, except for a few occasions. Noise levels measured at the south-eastern boundary exceeded the 65 dB(A) level on one occasion (19 October 2016); however, the noise level at Hearson Cove for that day was 48 dB(A). On other occasions when the noise levels at Hearson Cove exceeded 65 dB(A), measured noise levels at the boundary were below 65 dB(A), indicating that ambient noise levels at Hearson Cove were influenced by other sources.

Noise monitoring was carried out at four locations on the TAN Plant and Ammonia Plant boundaries between October 2018 and June 2019 to check compliance with the Noise Regulations of combined noise emissions from both plants. The monitoring locations are shown in Figure 6.1.

Figure 6.1: Noise monitoring locations (N1 to N4)


Due to operational downtime of the TAN Plant and Ammonia Plant since the issue of the current licence, limited data is available at times when both plants are operating. However, the results of the monitoring show little variation in results regardless of whether only one plant or both plants are operating and demonstrate compliance with the 65 dBA criteria. The results of the monitoring and operational status of both plants is shown in Table 6.15 below.

Table 6.15: Noise monitoring October 2018 to June 2019

Date Wind Operational status Average LA10 (dB) N1 N2 N3 N4

16/10/18 Northeast Light breeze

TAN Plant not operating Ammonia Plant operating

58.7 52.8 45.8 37.5

20/12/18 Northwest Moderate


58 55.7 57.9 50.4

8/3/19 West Light-moderate


57.9 53.8 54.7 46.2

7/6/19 East Moderate

Ammonia Plant utilities only running TAN Plant operating

55.1 51.9 47.5 44.8

1/7/19 Northeast Moderate

Both plants operating 58.8 54.4 53.8 49.8

Given the TAN Plant’s demonstrated compliance with the 65 dB LA10 assessment criteria, no further control is considered necessary outside of regulation under the Noise Regulations.

6.6 Risk assessment

The identified emissions and discharges have been assessed in accordance with DWER’s Guidance Statement: Risk Assessments (DER 2017). A summary of the risk assessment is presented in Table 6.16.


Table 6.16: Risk assessment summary

Source Activity Emission Receptor Pathway Potential impact Controls Consequence Likelihood Risk

Nitric acid plant stack

Normal operation

NOx, N2O, NH3

Hearson Cove (beach recreation) Deep Gorge (tourism) Residential areas at Dampier and Karratha Workforce at King Bay Industrial Estate, Pilbara Port Authority and Woodside Facilities

Air/wind dispersion

Human health impacts Loss of amenity

• dual pressure process plant design to: o lower operational energy consumption

rates from increased combustion o efficiency o lower NH3 consumption during

operation o reduce concentration of N2O in tail gas;

and o provide longer equipment life

• use of catalytic abatement system to achieve lower NOx concentration in tail gas

• designed to recover waste heat from the exothermic process which is recycled through the steam system which reuses steam to generate electric power.

• CEMS monitoring • ambient air quality monitors for NH3.

Slight Almost certain

Medium

Ammonium nitrate solution plant (common stack)

NH3, PM • uses pressure reactor technology and is designed to produce no emissions to the atmosphere

• quarterly stack testing • ambient air quality monitors for NH3.

Slight Rare Low

TAN prilling plant (common stack)

NH3, PM10 • three stage scrubbing system to comprise of following components: o Independent scrubber for prilling tower

air emissions o Rotary brush scrubber for bleed air

emissions o Final scrubber for rotary brush scrubber

air emissions • quarterly stack testing • ambient air quality monitors for NH3.

Slight Almost certain

Medium

Unit 31/32 ammonia vent

NH3 • revised control philosophy (Section 6.1.4.4) • ambient air quality monitors for NH3.

Slight Unlikely Low



Unit 12 ammonia vent

Start-up

NOx, N2O, NH3

• Revised control philosophy (Section 6.1.4) will prevent need to vent during start up.

• ambient air quality monitors for NH3.

Minor Rare Low

TAN prilling plant Bulk TAN storage building TAN bagging facility Bulk truck loading system Off-spec storage and treatment area

TAN prilling, bagging and loading

PM Hearson Cove (beach recreation)

Air/wind dispersion

Human health impacts Loss of amenity

• the bulk storage shed operates at a positive pressure to maintain the humidity and temperature in the storage area (TAN prill degrades with moisture). The building is sealed and entrances have fan blowers which create an air curtain to keep air inside

• fines are screened out in the bulk storage shed prior to product being transferred via conveyor to the loading areas. Fines drop out into a storage bay. A front end loader is used to collect fines and transfer them to the off-spec hopper (outside the shed) for reprocessing. Loader buckets are quarter filled to minimise dust during transfer

• retractable loading arms with shrouds on the ends are installed at the truck loading area. Fines are screened out prior to transfer to the loading area, as they are not part of product specification, which reduces potential dust. Excess air goes back through the transfer chute to the prilling tower

• when bagging, the opening between the bag and the loading arm is sealed and no air escapes. Bags are clamped closed when filling is complete

• material is directed to the off-spec area if is there is a problem or if the product does not meet the required specification. Material is directed to two undercover storage bays on concrete hardstand. Once the issue with the plant is rectified, material in the off-spec area is removed from the storage bays using loaders and transferred to a hopper for reprocessing.

Minor Rare Low



Ponds 1 & 2 Ponds 4 & 5

Containment of contaminated wastewater

Contaminated wastewater

Groundwater King Bay marine ecosystem

Seepage Groundwater discharge

Degradation of marine water quality Ecological impacts

• double liner (1.5 mm thick HDPE) • leak detection systems • groundwater monitoring.

Minor Possible Medium

Contaminated water system

Capture of all contaminated wastewater from identified point sources Transfer of contaminated wastewater to ponds 1, 2, 4 & 5

Contaminated wastewater

Groundwater King Bay marine ecosystem

Seepage Groundwater discharge


• sealed areas (coated concrete, roof surfaces, bunds) and conduits (various channels and pipes) that prevent infiltration to ground

• leak detection systems.

Minor Rare Low

MUBRL Normal operation TAN Plant [and Ammonia Plant] process effluent

King Bay marine ecosystem

Direct discharge


• chemical treatment and precipitation of the cooling tower blowdown with the aim to reduce chlorine, bromine and other biocides to non-detectable levels

• steam stripping of process condensate and reformer jacket water blowdown, and recycle of polished water to prevent the discharge of ammonia and methanol.

Regulated under MS 567 and MS 594 and Ammonia Plant licence; and managed by Water Corporation through implementation of OMEMP

TAN Plant and equipment

Normal operation Noise Hearson Cove (beach recreation)

Air/wind dispersion

Loss of amenity

• equipment such as compressors and pumps are located within enclosures, cases, blankets or are situated in a building as required

• silencers installed on vents • pipework with acoustic cladding • relief system for flow/ acoustically induced

vibration and fatigue • repairing, modifying or replacing high noise

generating items • selecting machinery with minimum noise

levels.

Minor Rare Low

©JBS&G Australia Pty Ltd T/A Strategen-JBS&G www.jbsg.com.au | ABN 62 100 220 479

51

7. Attachment 7: Siting and location

The TAN Plant is located on the Burrup Peninsula, 11 km northwest of Karratha. The plant is in the Burrup Strategic Industrial Area; a well established strategic heavy industrial estate. Non-industrial land to the north and south of the plant form part of the Murujuga National Park, which is recognised for its cultural significance and ecological and biological diversity.

The Ammonia Plant is located adjacent to the premises to the west southwest.

7.1 Residential and sensitive premises

The distances to residential and sensitive receptors are shown in Table 7.1 and Figure 7.1.

Table 7.1: Receptors and distance from prescribed activity Residential and sensitive premises Distance from TAN Plant (measured from boundary) Hearson Cove beach (zoned conservation recreation and natural/landscapes City of Karratha Planning Scheme No.8)

550 m southeast

Deep Gorge (recreational area) (zoned conservation recreation and natural/landscapes City of Karratha Planning Scheme No.8)

1.2 km south

Industrial receptor –Pilbara Port Authority lease area (multiple users) including ammonia loading facilities (zoned strategic industry City of Karratha Planning Scheme No.8)

2.0 km west

Industrial receptor – Pluto LNG Project (zoned strategic industry City of Karratha Planning Scheme No.8)

1.6 km northwest

Industrial receptor – Karratha Gas Plant (zoned strategic industry City of Karratha Planning Scheme No.8)

2.5 km northwest

Industrial receptor – Parker Point Iron Ore Port (zoned strategic industry City of Karratha Planning Scheme No.8)

4.8 km southwest

Residential Premises – Dampier townsite 7.8 km southwest Residential Premises – Karratha townsite 11.7 km south southeast

7.2 Specified ecosystems

Specified ecosystems are areas of high conservation value and special significance that may be impacted because of activities at or emissions and discharges from the TAN Plant. Specified ecosystems have been identified in accordance with DWER Guidance Statement on Environmental Siting (DER 2016). The distances to specified ecosystems and other relevant ecosystem values are shown in Table 7.2.

Table 7.2: Environmental values Specified Ecosystem Distance from the Premises Parks and Wildlife Managed Waters

Murujuga National Park - Borders Lot 3017 to the east, 350 m from the boundary of the TAN Plant to the north and 800 m to the south. Deep Gorge, a popular site frequented by tourists containing rock art, is located 1.2 km south (measured from the Contaminated Water Ponds to the Deep Gorge car park).

Threatened Ecological Communities and Priority Ecological Communities

Several priority ecological communities have been identified in the area. Priority 1 ecological communities exist within 5 km of the TAN Plant including the Burrup Peninsula rock pool and rock piles communities. The Burrup Peninsula rock pile communities consist of short-range endemic land snails.

Threatened / Priority Flora No priority flora have been identified on the TAN Plant. Threatened / Priority Fauna State and Commonwealth listed threatened species of fauna have been identified

within a 10 km radius of the TAN Plant. Twenty four (24) migratory species have also been identified. Most threatened species within the area include marine animals which may use areas off Hearson Cove for feeding, breeding, nesting or resting.


52

Specified Ecosystem Distance from the Premises King Bay – mangroves and marine ecosystem

Supratidal flat located directly adjacent to the TAN Plant boundary to the south and east. Mangrove community located 600 m east of the plant boundary. The waters of King Bay are afforded a high level of ecological protection except for a one-hectare area surrounding the outfall, where industry discharges occur in King Bay and the surrounding Mermaid Sound. These areas have been afforded a low level of ecological protection and moderate level of ecological protection respectively.

Hearson Cove – marine tidal ecosystem

800 m to the southeast (measured from the eastern wall of the bulk storage shed).

National Heritage Listed place – Dampier Archipelago (including the Burrup Peninsula) (ID 105727)

The Dampier Archipelago including the Burrup Peninsula is listed on the National Heritage List due to the presence of rock engravings and other Aboriginal heritage sites such as stone arrangements. Nearest rock art to the TAN Plant is within 100 m.

7.3 Climate

The TAN Plant is located on the Burrup Peninsula within the Pilbara region of WA which has a tropical-arid climate with two distinct seasons; hot summers with periodic heavy rains (October-April) and mild winters with occasional rainfall (May-September). According to the Bureau of Meteorology (BoM, 2015) climate statistics for the nearest weather station at Dampier Salt (site no. 5061) show that mean maximum daily temperatures vary from 36.2 ⁰C in March to 26.2 ⁰C in July, and mean minimum daily temperatures vary from 26.5 ⁰C in February to 13.4 ⁰C in July. Average annual rainfall is approximately 273 mm and is predominantly associated with tropical cyclones or thunderstorms, while average evapotranspiration for the area generally exceeds 3000 mm.

7.4 Topography

The TAN Plant site was built at the toe of a hilly landscape. During construction, the northern portion of the site was cut, and excess material used as fill for the southern portion of the site. The site comprises the following two areas:

• on-pad: consists of the TAN Plant which is located on a constructed pad with an elevation of 5.5 mAHD; the southern portion of the on-pad area is built on a lower-lying area (supratidal flat)

• off-pad: consists of the non-operational portion of the site. Portions of the off-pad area have been reworked and/or has stockpiled material, but a large portion of it remains in a natural state. A rocky outcrop in the middle of the off-pad area is Aboriginal heritage listed and access is restricted.

7.5 Hydrology

The hydrology of the site and its surrounds are described as follows:

• fresh water flows are highly variable, characterised by short periods of very high flow that coincide with major rainfall events usually associated with tropical cyclone activity

• these periods of high flow are followed by dry periods sometimes lasting years

• topographical features suggest that surface water has historically flowed in a south-south-easterly direction through the site now used for the Ammonia Plant and TAN Plant site to the supratidal flat between King Bay and Hearson Cove (ERM 2012a)

• the soils of the lower slopes and tidal flat are highly permeable (ERM 2012a). Surface runoff that is not infiltrated concentrates in trapped low points within the supratidal flat or flows towards King Bay (Golder 2018)

• the distances to water sources are shown in Table 7.3.


53

Table 7.3: Surface water receptors Surface water receptors Distance from TAN Plant Environmental value Surface water (supra-tidal flat between King Bay and Hearson Cove)

The supra-tidal flat between King Bay and Hearson Cove is subject to flooding from storm surge events. A 1:100-year storm is expected to result in a storm surge of 5 mAHD.

Supra-tidal flats which connect to King Bay. Mangrove community located 600m of the boundary of the TAN Plant.

7.6 Geology and soils

The Burrup Peninsula is composed largely of an intrusive Proterozoic igneous rock outcrop known as the Gidley Granophyre. The base of the intrusion consists of a differentiated coarse-grained gabbro and the main body is a fine-grained granophyre.

The general geological profile of the TAN Plant was summarised by ERM (2012) based on geotechnical investigations. The soil stratigraphy is described as:

• silty or clayey sand: red brown, fine to medium grained, sub angular sand, poorly sorted with gravel being more frequent in the northern area of the Site and occasional cobbles being present, extending from between 0.5 m and 4.0 m

• granophyre: pale grey, generally weathered with rock becoming fresher and less fractured with depth extending to the maximum depth of 5.0 m with dolerite intrusions.

Golder (2001) noted that the granophyre consisted of pale grey and dark grey, fine to medium sized crystals which was distinctly weathered and generally becoming fresher with depth. The bedrock was locally fractured along thin iron-stained quartz seams, generally of high to extreme high strength, extending to a maximum depth of 15 m. Golder (2011) also noted dolerite in one borehole.

The tidal mudflats are comprised largely of sandy silts to silty sands generally brown to grey in colour with occasional variations of green, yellow and red mottling. The sediments are typically organically rich and often contain a thin veneer of shelly lenses. Soils in the area are generally alkaline due to high carbonate content originating from marine sands and underlying calcrete bedrock (SKM 2001).

7.7 Hydrogeology and groundwater

The modelled hydrogeology is based on the following:

• groundwater is predominantly located in fractured rock aquifers where it is stored in the fractures, joints, bedding planes and cavities of the rock mass

• the Hydrogeological Atlas (DoW website) indicates that the upper aquifer in this region is the low permeability, unconfined Pilbara Fractured Rock Aquifer

• groundwater recharge to this aquifer is directly related to rainfall events where water infiltrates the fractures of the surface rock or infiltrates from surface water flows

• these fractured rock aquifers are localised systems with little regional flow

• hyper-saline groundwater typically occurs beneath supratidal flat

• the shallow aquifer in this region is categorised as a Level 1 aquifer which indicates it is shallow and present within superficial deposits which are likely to be unconfined

• groundwater is generally shallow and follows the surface topography at a depth of between approximately 0.5 and 8 m below ground level. Depth to groundwater decreases towards the tidal flat and is anticipated to be higher during spring tides and following significant rainfall events.

Groundwater monitoring locations are shown in the Map of Monitoring Locations in Attachment 2.


54

Over 2017/18, groundwater levels peaked in December 2017 with levels ranging from 4.55 mAHD at bore US1 to 1.87 mAHD at DS1 in the south. Minimum levels occurred in June 2017 and varied from 4.21 mAHD at US1 in the north to 2.08 mAHD at DS1 in the south. The magnitude of the seasonal variation was limited and was greater in the northern bores.

An analysis of groundwater level variations within the TAN Plant indicated that the groundwater levels were not generally influenced by tidal fluctuations (Strategen 2017). Groundwater levels were measured at all locations at high tide and low tide and the differences in tide and groundwater levels were compared. On average, groundwater levels varied by 0.03 m and by no more than 0.1 m; average tidal variation was 2.6 m with a maximum of 3.2 m (Strategen 2017).

Groundwater flow is in a southerly to east south easterly direction towards the supratidal flats and on to King Bay.

The distances to groundwater are shown in Table 7.4.

Table 7.4: Groundwater receptors Receptor Distance from Tan Plant Environmental value Groundwater Groundwater is generally shallow and

typically at a depth of between approximately 0.5 and 8 metres below ground level. Depth to groundwater decreases towards the tidal flat. Variation is driven by tidal variation and rainfall. The TAN Plant is located within the Pilbara Groundwater Area and Pilbara Surface Water Area (proclaimed under the Rights in Water Irrigation Act 1914).

Water is not used for potable or industrial use. Groundwater flows to the southeast, towards the supra-tidal flats which connect to King Bay. Mangrove community located 600 m east of the boundary of the TAN Plant.

!!

!!

!!

!!

!!

!!

!!

HEARSONS COVEHEARSONS COVE

DEEP GORGEDEEP GORGE

KARRATHA GAS PLANTKARRATHA GAS PLANT

PLUTO LNG PROJECTPLUTO LNG PROJECT

DAMPIERDAMPIER

PORT OF DAMPIERPORT OF DAMPIER

KARRATHAKARRATHA

Z



Checked By: CT

Scale 1:105,000 at A4


Figure 7.1

0 1 2

Kilometers

File Name: W:\Projects\1)Open\Yara Pilbara Nitrates\56928 Seperate licence applications\GIS\Maps\R002_Rev_A\56928_07_1_SensitiveReceptors.mxdReference: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

YARA PILBARA NITRATESTAN PLANT

SENSITIVE RECEPTORS

Job No: 56928

Drawn By: cthatcher

LegendPremises boundary - TanPlant

!! Sensitive receptors


56

Limitations

Scope of services

This report (“the report”) has been prepared by Strategen-JBS&G in accordance with the scope of services set out in the contract, or as otherwise agreed, between the Client and Strategen-JBS&G. In some circumstances, a range of factors such as time, budget, access and/or site disturbance constraints may have limited the scope of services. This report is strictly limited to the matters stated in it and is not to be read as extending, by implication, to any other matter in connection with the matters addressed in it.

Reliance on data

In preparing the report, Strategen-JBS&G has relied upon data and other information provided by the Client and other individuals and organisations, most of which are referred to in the report (“the data”). Except as otherwise expressly stated in the report, Strategen-JBS&G has not verified the accuracy or completeness of the data. To the extent that the statements, opinions, facts, information, conclusions and/or recommendations in the report (“conclusions”) are based in whole or part on the data, those conclusions are contingent upon the accuracy and completeness of the data. Strategen-JBS&G has also not attempted to determine whether any material matter has been omitted from the data. Strategen-JBS&G will not be liable in relation to incorrect conclusions should any data, information or condition be incorrect or have been concealed, withheld, misrepresented or otherwise not fully disclosed to Strategen-JBS&G. The making of any assumption does not imply that Strategen-JBS&G has made any enquiry to verify the correctness of that assumption.

The report is based on conditions encountered and information received at the time of preparation of this report or the time that site investigations were carried out. Strategen-JBS&G disclaims responsibility for any changes that may have occurred after this time. This report and any legal issues arising from it are governed by and construed in accordance with the law of Western Australia as at the date of this report.

Environmental conclusions

Within the limitations imposed by the scope of services, the preparation of this report has been undertaken and performed in a professional manner, in accordance with generally accepted environmental consulting practices. No other warranty, whether express or implied, is made.

The advice herein relates only to this project and all results conclusions and recommendations made should be reviewed by a competent person with experience in environmental investigations, before being used for any other purpose.

Strategen-JBS&G accepts no liability for use or interpretation by any person or body other than the client who commissioned the works. This report should not be reproduced without prior approval by the client, or amended in any way without prior approval by Strategen-JBS&G, and should not be relied upon by other parties, who should make their own enquiries.


57

References

European Commission. 2007. Reference Document on Best Available Techniques for the Manufacture of Large Volume Inorganic Chemicals - Ammonia, Acids and Fertilisers. Retrieved from https://eippcb.jrc.ec.europa.eu/reference/BREF/lvic_aaf.pdf.

Environmental Resources Management (ERM). 2012. Burrup Peninsula Technical Ammonium Nitrate Production Facility Air Quality Assessment Update. Report prepared for Burrup Nitrates Pty Ltd. August 2012.

ERM. 2012a. Technical Ammonium Nitrate Production Facility - Hydrogeological and Hydrological Investigations. Report prepared for Yara Pilbara Nitrates.

Golder. 2018. Preliminary Hydrogeological Conceptual Site Model: Technical Ammonium Nitrate Plant. Report prepared for Yara Pilbara Nitrates.

Fertilizers Europe. 2000. Best Available Techniques for Pollution Prevention and Control in the European Fertilizer Industry Booklet No. 2: Production of Nitric Acid. Retrieved from http://fertilizerseurope.com/fileadmin/user_upload/publications/tecnical_publications/BATs/Booklet_2_final.pdf.

New South Wales. Department of Environment and Conservation. (2005). Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales. Retrieved from https://www.environment.nsw.gov.au/resources/air/ammodelling05361.pdf.

Sinclair Knight Merz (SKM). 2001. Proposed 2,000 tpd Ammonia Plant, Burrup Peninsula Western Australia, Public Environmental Review. Report prepared for Burrup Fertilisers.

Standards Australia. (1998). Water quality—Sampling Part 11: Guidance on sampling of groundwaters (AS 5667.11). Available from http://www.saiglobal.com.

Standards Australia. (2007). Methods for sampling and analysis of ambient air Part 1.1: Guide to siting air monitoring equipment (AS 3580.1.1). Available from http://www.saiglobal.com.

Standards Australia. (2014). Methods for sampling and analysis of ambient air Part 14: Meteorological monitoring for ambient air quality monitoring applications (AS 3580.14). Available from http://www.saiglobal.com.

Strategen. 2017. Tier 2 Risk Assessment for the Transport and Fate of Nitrogen Rich Groundwater Technical Ammonium Nitrate Plant. Report prepared for Yara Pilbara Nitrates.

Western Australia. Department of Environment Regulation (DER). (2016a). Guideline Continuous Emission Monitoring System (CEMS) Code for Stationary Source Air Emissions. Retrieved from https://www.der.wa.gov.au/images/documents/our-work/licences-and-works-approvals/Guideline_Continuous_Emission_Monitoring_System_Code.pdf.

Western Australia. Department of Environment Regulation (DER). (2016b). Guidance Statement Environmental Siting Part V, Division 3, Environmental Protection Act 198. Retrieved from https://www.der.wa.gov.au/images/documents/our-work/licences-and-works-approvals/GS-Environmental-Siting.pdf

Western Australia. Department of Environment Regulation (DER). (2017). Guidance Statement Risk Assessments. Retrieved from https://www.der.wa.gov.au/images/documents/our-work/licences-and-works-approvals/GS_Risk_Assessments.pdf

Western Australia. Department of Water and Environmental Regulation (DWER). (2019). Murujuga Rock Art Strategy, A monitoring, analysis and decision-making framework to protect Aboriginal rock art located on Murujuga (the Dampier Archipelago and Burrup Peninsula). Perth, WA.


58

Western Australia. Department of Water and Environmental Regulation (DWER). (2019a). Guideline: Industry Regulation Guide to Licensing. Retrieved from https://www.der.wa.gov.au/our-work/licences-and-works-approvals/publications.

Western Australia. Department of Water and Environmental Regulation (DWER). (2019b). Guideline: Decision Making. Retrieved from https://www.der.wa.gov.au/our-work/licences-and-works-approvals/publications.

Western Australia. Environmental Protection Authority (EPA). 2011. Technical Ammonium Nitrate Production Facility, Burrup Peninsula Report 1379. Retrieved from http://www.epa.wa.gov.au/sites/default/files/EPA_Report/Final%20EPA%20Report%20050111-web_0.pdf.

Western Australia. Environmental Protection Authority (EPA). 2019. Report and recommendations of the Environmental Protection Authority, Technical Ammonium Nitrate Production Facility, Burrup Peninsula – inquiry under section 46 of the Environmental Protection Act 1986 to amend Ministerial Statement 870. Retrieved from http://www.epa.wa.gov.au/sites/default/files/EPA_Report/1728-19%20-%20Technical%20Ammonium%20Nitrate%20Production%20Facility%20-%20EPA%20Report_0.pdf.

Western Environmental. 2015. Yara Pilbara Fertilisers Ammonia Plant Targeted Detailed Site Investigation Report - aMDEA Loss of Containment. Report prepared for Yara Pilbara Fertilisers.

https://www.der.wa.gov.au/our-work/licences-and-works-approvals/publications

https://www.der.wa.gov.au/our-work/licences-and-works-approvals/publications

http://www.epa.wa.gov.au/sites/default/files/EPA_Report/Final%20EPA%20Report%20050111-web_0.pdf

http://www.epa.wa.gov.au/sites/default/files/EPA_Report/Final%20EPA%20Report%20050111-web_0.pdf


59

Appendix A MS 870 revised conditions

Yara Pilbara Nitrate Pty Ltd

23 Environmental Protection Authority

RECOMMENDED ENVIRONMENTAL CONDITIONS

STATEMENT TO CHANGE THE IMPLEMENTATION CONDITIONS APPLYING TO

A PROPOSAL (Section 46 of the Environmental Protection Act 1986)

TECHNICAL AMMONIUM NITRATE PRODUCTION FACILITY,

BURRUP PENINSULA, CITY OF KARRATHA Proposal: The proposal is for the construction and operation of a

technical ammonium nitrate production facility (TANPF) on Site D within the King Bay/Hearson Cove Industrial Estate on the Burrup Peninsula. The proposal is located approximately 13 kilometres north-west of Karratha.

The proposal is further documented in Schedule 1 of

Statement 870.

Proponent: Yara Pilbara Nitrates Pty Ltd Australian Company Number: 127 391 422

Proponent Address: Level 5, 182 St Georges Terrace, PERTH WA 6000

Report of the Environmental Protection Authority: 1643 Preceding Statement/s Relating to this Proposal: 870

Pursuant to section 45 of the Environmental Protection Act 1986, as applied by section 46(8), it has been agreed that the implementation conditions set out in Ministerial Statement No. 870, be changed as specified in this Statement. Condition 5 of Ministerial Statement 870 is deleted and replaced with: 5 Air Quality 5-1 The Proponent shall manage the implementation of the Proposal to meet the

following objectives:

(1) minimise air emissions from the Proposal to assist in the maintenance of regional air quality in accordance with applicable air quality standards including, but not limited to, the National Environment Protection (Ambient Air Quality) Measure (NEPM) so that the environmental values of human health and amenity are protected; and

(2) minimise air emissions from the Proposal as far as practicable to assist in minimising the risk of adverse impacts to rock art on Murujuga.

5-2 Within twelve (12) months of the date of this Statement, unless otherwise

agreed by the CEO, the Proponent shall prepare and submit to the CEO a

Technical Ammonium Nitrate Production Facility


revised Air Quality Management Plan that describes how the Proponent will meet the following objectives:

(1) minimise air emissions from the Proposal to assist in the maintenance

of regional air quality in accordance with applicable air quality standards including, but not limited to, the NEPM so that the environmental values of human health and amenity are protected; and

(2) minimise air emissions from the Proposal as far as practicable to assist in minimising the risk of adverse impacts to rock art on Murujuga.

5-3 The revised Air Quality Management Plan must:

(1) specify the expected air emissions for the Proposal based on the current air pollution control technology selection and plant design for the Proposal;

(2) include a comparison of the expected air emissions for the Proposal

against international industry best practice for technical ammonium nitrate production facilities;

(3) include a comparison of the current air pollution control technology

selection and plant design for the Proposal against international industry best practice for technical ammonium nitrate production facilities;

(4) include provisions for monitoring of on-site meteorological conditions

including wind speed / direction, temperature, and rainfall rate to enable the data that is collected to be available for use in the forthcoming investigations associated with the Murujuga Rock Art Monitoring Program, with annual reporting to the CEO; and

(5) identify and describe the measures that the Proponent will implement to

minimise air emissions, including the adoption of advances in air pollution control technology and process management, and specify: (a) the timeframe within which each measure will be implemented;

and (b) the means to determine the effectiveness of each measure in

minimising air emissions. 5-4 After receiving notice in writing from the CEO that the revised Air Quality

Management Plan, or any subsequent revision of that plan, satisfies the requirements of Condition 5-2 and Condition 5-3, the Proponent shall: (1) commence implementation of the approved revised Air Quality

Management Plan; and

Yara Pilbara Nitrate Pty Ltd


(2) continue to implement the approved revised Air Quality Management Plan, or any subsequent revision, including the measures identified under Condition 5-3(5), for the remainder of the life of the Proposal.

5-5 Should monitoring of air emissions from the Proposal indicate that the

objectives of Condition 5-2 are not being met, the Proponent shall: (1) report the non-compliance in writing to the CEO within seven (7) days of

the non-compliance being identified; (2) investigate to determine the cause of the non-compliance; (3) provide a report to the CEO within 90 days of the non-compliance being

reported as required by Condition 5-5(1). The report shall include: (a) the cause of the non-compliance; (b) the findings of the investigation required by Condition 5-5(2);

(c) details of revised and/or additional management actions to be

implemented to prevent non-compliance; and

(d) relevant changes to proposal activities.

5-6 The Proponent shall, for information only, provide the CEO with copies of all reports and data relating to ambient air quality monitoring and rock art condition / integrity monitoring required under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 within one (1) month of their provision to the Commonwealth Government.

5-7 The Proponent may review and revise the Air Quality Management Plan or any

subsequently approved revisions. 5-8 The Proponent shall review and revise the Air Quality Management Plan or any

subsequently approved revisions every four years, or as and when directed by the CEO.

5-9 Any proposed revision of the Air Quality Management Plan must be submitted

to the CEO for approval. 5-10 The Proponent shall implement the latest version of the Air Quality

Management Plan which the CEO has confirmed by notice in writing satisfies the requirements of Condition 5-2 and Condition 5-3.

5-11 The Proponent shall make publicly available for the remainder of the life of the

Proposal in a manner approved by the CEO:

Technical Ammonium Nitrate Production Facility


(1) the approved Air Quality Management Plan, or any subsequently approved revision, within one (1) month of the relevant plan being approved by the CEO; and

(2) the reports referred to in Condition 5-3(4) and Condition 5-6 and associated data, within one (1) month of the relevant report being submitted to the CEO.

5-12 The Proponent shall continue to implement the current approved version of the

Air Quality Management Plan (Doc Ref: 0086269, February 2013) until notified by the CEO under Condition 5-4 that the revised Air Quality Management Plan meets the requirements of Condition 5-2 and Condition 5-3.

Abbreviations and Definitions Item Definition Murujuga The name given to the Dampier Archipelago and Burrup Peninsula

by the Traditional Owners and custodians of this area. As far as practicable

As far as reasonably achievable or feasible as determined by the CEO having regard to, among other things, local conditions and circumstances (including costs) and to the current state of technical knowledge.

Industry best practice

A method, process, or technique employed within a particular industry that has consistently shown through research and experience results superior to those achieved by applying other means, and can be used as a benchmark.

CEO The Chief Executive Officer of the Department of the Public Service of the State responsible for the administration of section 48 of the Environmental Protection Act 1986, or his delegate.


60

© JBS&G Australia Pty Ltd T/A Strategen-JBS&G

This document is and shall remain the property of Strategen-JBS&G. The document may only be used for the purposes for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited.

Document Distribution

Rev No. Copies Recipient Date

1 Electronic Yara Pilbara Nitrates Pty Ltd 17/10/2019

Document Status

Rev No. Author Reviewer Approved for issue

Name Name Signature Date

1 17/10/2019


61

application for licence environmental protection act 1996 · 2019. 11. 13. · application for...

Documents