W6326/2019/1 i

Application for Works Approval

Division 3, Part V Environmental Protection Act 1986

Works Approval Number W6326/2019/1

Applicant GrainCorp Liquid Terminals Australia Pty Ltd

ACN 001 849 805

File Number DER2019/000605

Premises Lot 108 Kwinana Beach Road

KWINANA BEACH WA 6167

Legal description -

Part of Lot 108 on Deposited Plan 400167

Certificate of Title Volume 2953 Folio 177

Date of Report 6 April 2020

Status of Report Final

Decision Report

Licence: L5109/1990/3 1

Table of Contents

1. Definitions of terms and acronyms ................................................................... 3

2. Purpose and scope of assessment ................................................................... 4

2.1 Application details .................................................................................................. 4

3. Background ......................................................................................................... 4

4. Overview of Premises......................................................................................... 5

4.1 Construction aspects .............................................................................................. 5

4.2 Commissioning aspects .......................................................................................... 5

4.3 Operational aspects ............................................................................................... 5

4.4 Infrastructure .......................................................................................................... 5

4.5 Exclusions to the premises ..................................................................................... 6

5. Legislative context.............................................................................................. 7

5.1 Contaminated sites ................................................................................................. 7

5.2 Other relevant approvals ........................................................................................ 7

6. Consultation by the Applicant ........................................................................... 7

7. Location and siting ............................................................................................. 8

7.1 Siting context .......................................................................................................... 8

7.2 Residential and sensitive premises ......................................................................... 8

7.3 Specified ecosystems ............................................................................................. 8

7.4 Groundwater .......................................................................................................... 9

7.5 Soil type ................................................................................................................. 9

7.6 Meteorology ........................................................................................................... 9

Wind direction and strength ............................................................................. 9

Rainfall and temperature ............................................................................... 10

8. Risk assessment ............................................................................................... 11

8.1 Determination of emission, pathway and receptor ................................................ 11

8.2 Consequence and likelihood of risk events ........................................................... 13

8.3 Acceptability and treatment of Risk Event ............................................................. 14

8.4 Risk Assessment – Leaks (Risk Event 1) ............................................................. 14

Description of Risk Event 1 ........................................................................... 14

Identification and general characterisation of emission .................................. 14

Description of potential adverse impact from the emission ............................ 14

Criteria for assessment.................................................................................. 14

Applicant controls .......................................................................................... 14

Consequence ................................................................................................ 15

Likelihood of Risk Event ................................................................................ 15

Licence: L5109/1990/3 2

Overall rating of Risk Event 1 ........................................................................ 15

8.5 Summary of acceptability and treatment of Risk Events ....................................... 15

9. Regulatory controls .......................................................................................... 16

9.1 Works Approval controls ....................................................................................... 16

10. Determination of Works Approval conditions ................................................ 16

11. Applicant’s comments ...................................................................................... 16

12. Conclusion ........................................................................................................ 17

Appendix 1: Key documents .................................................................................... 18

Schedule 1: Site plan of proposed development.................................................... 20

Schedule 2: Guidance statements ........................................................................... 22

Table 1: Definitions .................................................................................................................. 3

Table 2: Documents and information submitted during the assessment process ...................... 4

Table 3: Grain Corp Liquid Terminal facility Category 73 infrastructure .................................... 6

Table 4: Relevant approvals and tenure ................................................................................... 7

Table 5: Stakeholder consultation ............................................................................................ 7

Table 6: Receptors and distance from activity boundary .......................................................... 8

Table 7: Environmental values ................................................................................................. 9

Table 8: Groundwater .............................................................................................................. 9

Table 9. Identification of emissions, pathway and receptors during construction .................... 11

Table 10: Identification of emissions, pathway and receptors during operation ...................... 12

Table 11: Risk rating matrix.................................................................................................... 13

Table 12: Risk criteria table .................................................................................................... 13

Table 13: Risk treatment table ............................................................................................... 14

Table 14: Applicant’s proposed controls for Risk Event 1 ....................................................... 15

Table 15: Risk assessment summary ..................................................................................... 15

Table 16: Summary of regulatory controls to be applied ......................................................... 16

Table 17: Summary of conditions to be applied ...................................................................... 16

Licence: L5109/1990/3 3

1. Definitions of terms and acronyms

In this Decision Report, the terms in Table 1 have the meanings defined.

Table 1: Definitions

Term Definition

ACN Australian Company Number

Applicant GrainCorp Liquid Terminals Australia Pty Ltd

Category/ Categories/ Cat.

Categories of Prescribed Premises as set out in Schedule 1 of the EP Regulations

Decision Report refers to this document

Delegated Officer an officer under section 20 of the EP Act

Department means the department established under section 35 of the Public Sector Management Act 1994 and designated as responsible for the administration of Part V, Division 3 of the EP Act

DWER Department of Water and Environmental Regulation

EPA Environmental Protection Authority

EP Act Environmental Protection Act 1986 (WA)

EP Regulations Environmental Protection Regulations 1987 (WA)

KBJ Kwinana Bulk Jetty

mᶟ cubic metres

Noise Regulations Environmental Protection (Noise) Regulations 1997 (WA)

Premises refers to the premises to which this Decision Report applies, as specified at the front of this Decision Report

UDR Environmental Protection (Unauthorised Discharges) Regulations 2004 (WA)

Licence: L5109/1990/3 4

2. Purpose and scope of assessment

GrainCorp Liquid Terminals Australia Pty Ltd (Applicant) lodged an application for a works approval under Part V of the Environmental Protection Act 1986 (EP Act) on 11 November 2019 (the Application). The application is to construct and operate a bulk liquids terminal within Part of Lot 108, Kwinana Beach Road, Kwinana Beach. The Applicant intends to store liquids such as urea ammonium nitrate liquid fertiliser solution (UAN), tallow, vegetable and used cooking oils, industrial solvent and sodium hydroxide at the premises. The products will be delivered to the premises by pipeline from ships at the Fremantle Ports Kwinana Bulk Jetty (KBJ) and stored in dedicated tanks.

The proposed activities within the premises fall under the definition of prescribed premises in accordance with Category 73: bulk storage of chemicals of Schedule 1 of the Environmental Protection Regulations 1987. A works approval is required for the construction and installation of the twenty (20) storage/holding tanks and associated infrastructure that will make the premises prescribed. Following completion of the works the Applicant can apply to be registered.

This Decision Report presents an assessment of potential environmental and public health risks from emissions and discharges from the construction and operation of these activities.

2.1 Application details

Table 2 lists the documents submitted during the assessment process.

Table 2: Documents and information submitted during the assessment process

Document/information description Date received

Application Form and associated supporting information including:

17-239 GrainCorp Kwinana – Works Approval Application (iCubed Consulting Pty Ltd, November 2019)

17-329 GrainCorp Kwinana - Works Approval Supporting Documentation (iCubed Consulting Pty Ltd, October 2019)

17-329 GrainCorp Kwinana – Stormwater Management Plan (iCubed Consulting Pty Ltd)

11 November 2019 and

21 November 2019

3. Background

The Applicant specialises in the storage and handling of bulk liquids including edible oils and fats, chemicals and petroleum, and flammable and combustible liquids located throughout Australia and New Zealand. The proposed bulk liquids terminal is a new facility that will be constructed on DevelopmentWA owned land within the Kwinana Industrial Area, approximately 35 km south-west of Perth.

The lot, on which the premises is to be constructed, is currently vacant and has an approximate area of 57,000 m2 however, only a portion of this land is to be developed at this stage which amounts to 27,000 m2 (see site plan in Schedule 1). The area was historically a residential area with remnant disused roadways, below ground pipework and aboveground connecting hydrants. However, the land has been vacant for decades awaiting new industrial premises to be using the land.

The facility will comprise of aboveground bulk liquid storage tanks connected to bulk shipping terminals via a series of underground and aboveground pipelines. The transfer of liquids from storage tanks to road tankers will occur via loading gantries and then dispatched to local and regional clients.

Licence: L5109/1990/3 5

4. Overview of Premises

4.1 Construction aspects

The works are planned to be constructed over a period a period of 18 – 24 months followed by a commissioning phase during which storage of chemicals will increase up to the maximum of 45,000 m3.

Work on the premises will include vegetation clearing. The Applicant has applied for a clearing permit on 10 March 2020 for this. The Applicant will then undertake civil earthworks to establish the base foundation, internal roads and driveways, pedestrian pathways, hardstand, secondary containment drainage lines, storm water treatment system and infiltration trench. Steelwork infrastructure such as road tank gantries and storage tanks will be installed and erected.

Once construction works are complete and certified as compliant with construction specifications outlined in the works approval, the Applicant intends to apply for a registration for the premises.

4.2 Commissioning aspects

The Applicant provided information in the application relating to the projected emissions and discharges of commissioning following the completion of construction of works. This is anticipated to take a maximum of six months following successful completion of works. Function testing will be undertaken along the pipeline route to ensure it is operating as anticipated in a once off event. As the Applicant intents to apply for the premises to be registered following completion of the works, the commissioning and testing will occur while the works approval still applies.

4.3 Operational aspects

The premises will comprise of a series of tank farms storing chemicals such as urea ammonium nitrate liquid fertiliser solution (UAN), tallow, vegetable and used cooking oils, industrial solvent and caustic soda 33% (sodium hydroxide). The only dangerous goods to be stored are caustic soda (Class 8 – Corrosive substance) and a solvent (Solvesso deemed a Class 9 – Miscellaneous Dangerous Goods) in accordance with the Australian Dangerous Goods Code (ADG Code). Combustible liquids (C1 and C2) will be stored as per Section 5 of AS1940:2017. No volatile organic compounds (VOCs) will be stored at the facility. Leakage or spillage containment shall be as per Section 5.8.2 of AS 1940:2017 and be at least 110% of the capacity of the largest tank or 25% of the total capacity of all tanks within the bund.

Bulk liquid is transported by ship to KBJ and then transferred using the ships pumps via pipeline to dedicated storage tanks at the premises. Some products may be received by road tankers, stored on the premises then transferred by pipe to the KBJ and distributed by ship.

Standard operating hours for truck transport are expected to be from 6am to 6pm Monday to Sunday with the occasional 24 hour operation to meet customer requirements.

4.4 Infrastructure

The GrainCorp Liquid Terminal facility infrastructure, as it relates to Category 73 activities, is detailed in Table 3 and with reference to the Site Plan (attached in the Issued Works Approval).

Table 3 lists infrastructure associated with each prescribed premises category.

Licence: L5109/1990/3 6

Table 3: Grain Corp Liquid Terminal facility Category 73 infrastructure

Infrastructure Design and construction / installation requirements

Infrastructure location

1. Two (2) above- ground Urea Ammonium Nitrate (UAE) storage tanks with capacity of 13,500 m3 each

Tanks to be constructed according to applicable Australian Standards

Tank 2-01

Tank 2-02

2. Fourteen (14) above-ground Class C1 combustible liquid storage tanks with capacity of 1,250 m3 each

None specified Tank 1- 01 to

Tank 1-14

3. Four (4) above-ground Pre-receiving tanks with capacity of 60 m3 each

None specified PRT1

PRT2

PRT3

PRT4

4. Secondary containment Impervious bunds designed to Australian Standards to contain the greater of 25% of all vessels, or 110% of largest vessel

External bund – 2350 mm and 1500 mm

Internal bund – 600 mm

5. Hardstand All tanks will be installed on impermeable concrete slab which is graded to a collection sump within the secondary containment bund

Not specified

6. Four (4) non-flammable road tanker loading gantries. Each gantry is designed and installed to enable a single tanker loadout.

Auscol specific loadout gantry for recycled oils and tallow.

Gantry

7. Two (2) 300 mm above-ground transfer pipeline from KBJ to facility

One (1) 200 mm above-ground transfer pipeline from facility to KBJ

Lines fitted with pigging and purging facilities. Lines to be ANSI-150 flanged unless deemed unsuitable during detailed design.

Transfer pipeline connection to port via elevated pipe bridge

8. One (1) 2.5 MW gas fired boiler used to heat water and circulate in tanks that require heating to keep product viscosity low to enable transfer.

None specified Boiler Room

9. Stormwater management system – interceptor to treat hydrocarbon contaminated water

Water captured from the proposed impervious surface will be directed through the onsite infiltration traps located along the eastern boundary of the site, to be cleaned and slowly absorbed in the ground.

Interceptor

4.5 Exclusions to the premises

The following are excluded from the scope of this assessment:

pipelines to and from the premises; and

connections to utility services (water, electricity, gas, sewage).

Licence: L5109/1990/3 7

5. Legislative context

Table 4 summarises approvals relevant to the assessment.

Table 4: Relevant approvals and tenure

Legislation Number Subsidiary Approval

Planning and Development Act 2005 (WA)

N/A GrainCorp Liquid Terminals Australia Pty Ltd

Construction and operation of the premises is required to be undertaken in accordance with City of Kwinana development approval. Planning approvals are yet to be determined.

Environmental Protection Act 1986 (WA)

Clearing Permit

Applicant applied for a Clearing Permit on 10 March 2020

Dangerous Goods Safety Act 2004

Yet to be obtained

The storage and handling of Dangerous Goods will be subject to a Dangerous Goods site licence and a Dangerous Goods Pipeline Registration.

The Applicant states a DG Licence will be applied for prior to the operation or commissioning of the premises.

5.1 Contaminated sites

The lot on which the premises is to be constructed is currently listed as a potentially contaminated site and is still to be officially assessed by the Department. There have been no recent industrial activities within the premises, but some illegal dumping may have occurred and possibly some asbestos may be scattered on the premises. The Applicant has been advised by the Department to consult the Department of Health with regards to the removal of any scattered pieces of asbestos from the premises and to keep the Department informed about any actions regarding remediation works (email dated 30 October 2019).

5.2 Other relevant approvals

A number of planning approvals and permits are required before the commencement of construction or operational phases of the proposed bulk storage facility, as detailed in Table 4.

It is not expected that the project has the potential to or will have “significant” impact on the environment. A referral to the Environmental Protection Authority (EPA) under Section 38 of the EP Act was undertaken by the proponent. A decision “Not to Assess” was given by the EPA on 6 February 2020.

6. Consultation by the Applicant

Stakeholder consultation that has been undertaken during the pre-approvals phase of the project is detailed in Table 5.

Table 5: Stakeholder consultation

Stakeholder Comments

DWER “Pre-lodgement” meeting on 24 July 2019 to discuss Works Approval and licencing requirements, and suitability of pipeline route

Licence: L5109/1990/3 8

Stakeholder Comments

DMIRS “Pre-lodgement” meeting on 23 July 2019 to discuss suitability of pipeline route and licencing requirements

Fremantle Ports Authority “Pre-lodgement” meeting on 23 July 2019 to discuss pipeline route and Development Approval requirements

City of Kwinana Council “Pre-lodgement” meeting on 24 July 2019 to discuss Development Approval requirements

DevelopmentWA Direct communication between GrainCorp and DevelopmentWA for lease and access

Community and neighbouring

industries

The premises is located in the Kwinana Industrial Area (KIA) and the project is not anticipated to generate material impacts on the surrounding community.

Direct contact with immediate neighbours of the project – BIS Industries and Macrofertil has been informed of the proposed development.

Ongoing involvement with the Kwinana Industries Council (KIC) is to be explored post-approval.

7. Location and siting

7.1 Siting context

The existing environment within the premises is one that has been historically highly disturbed. The premises were part of a residential area from the early 1950s to the late 1990s or early 2000s. It was subdivided and occupied by several houses, roadways, and services such as pipes for water supply and sewerage.

There are several sand and gravel tracks along the boundaries and through the inside of the premises, as well as asphalt surfacing’s associated with the former roads.

Regrowth vegetation is mostly grass and shrubs with some mid-size trees up to 20 m in height, which is a mix of native regrowth and introduced species.

7.2 Residential and sensitive premises

The distances to residential and sensitive receptors are detailed in Table 6.

Table 6: Receptors and distance from activity boundary

Sensitive Land Uses Distance from Prescribed Activity

Bottle shop with owner’s residence 40 m to the south-west

Well’s Park 130 m to the south-west

Cockburn Sound 220 m to the west

Caravan Park and start of residential area of East Rockingham

1.8 km to the south-west

7.3 Specified ecosystems

Specified ecosystems are areas of high conservation value and special significance that may

Licence: L5109/1990/3 9

be impacted as a result of activities at or Emissions and Discharges from the premises. The distances to specified ecosystems are shown in Table 7. Table 7 also identifies the distances to other relevant ecosystem values which do not fit the definition of a specified ecosystem.

The table has also been modified to align with the Guidance Statement: Environmental Siting.

Table 7: Environmental values

Specified ecosystems Distance from the premises

Geomorphic Wetlands Geomorphic wetlands, Swan Coastal Plain (DBCA-019), are located 2.4 km to the east, and 1.7km to the south of the premises.

Cockburn Sound The premises sits within State Environmental (Cockburn Sound) Policy 2015 area

7.4 Groundwater

The distances to groundwater is shown in Table 8.

Table 8: Groundwater

Groundwater Distance from premises Environmental value

Groundwater The premises sits at 4 m AHD, and on average the water table is around 1 m AHD. The base of the aquifer is ~25 m AHD.

It is expected to flow approximately from the north-east to the west – south-west toward the coast.

Groundwater in the area is brackish, averaging between 1000-1500 mg/L.

Due to the sandy nature of the soils it is expected that surface water on the site likely infiltrates into the underlying soil.

7.5 Soil type

The Applicant provided with the application the “Report on Geotechnical Investigations” prepared by Douglas Partners (5 July 2019). The findings of that report were that the premises was extensively filled over with sand and significant amount of foreign material including glass, metal, plastic, brick and potential fragments of asbestos containing material.

The topography of the area is influenced by significant volumes of uncontrolled fill of sand and gravelly sand that has been deposited, rather than forming part of any formal development.

The premises is located on soil that is generally described as Safety Bay Sand (Passmore, 1967, 1970; Playford & Low, 1972). A CSIRO report to the Cockburn Sound Management Council (2006) specifies that Safety Bay Sand is visible along the coastal margin while aeolian sand dunes extends offshore into Cockburn Sound. Safety Bay Sand is primarily comprised of quartz skeletal sand, humic quartz sand (soil), calcrete sand, medium and coarse sand, shelly sand and beach rock. Due to the nature of the proposed work there is no risk to human health associated with the soil.

7.6 Meteorology

Wind direction and strength

Based on wind direction and speed from the Bureau of Meteorology’s weather station at Medina Research Centre, morning winds are predominately east and north/south-easterly. Afternoon winds are predominately southwest and westerly. It is important to note that this wind rose shows historical wind speed and wind direction data for Medina Research Centre and should not be used to predict future data.

Licence: L5109/1990/3 10

Figure 1: Roses of Wind Direction and Wind Speed in km/hr (April 1983 to Jan 2018)

Rainfall and temperature

Weather at Kwinana is warm and temperate with a Mediterranean climate of hot dry summers and cool wet winters. The average temperature across the year is 18.4 degrees Celsius.

W6326/2019/1 11

8. Risk assessment

8.1 Determination of emission, pathway and receptor

In undertaking its risk assessment, DWER will identify all potential emissions pathways and potential receptors to establish whether there is a Risk Event which requires detailed risk assessment.

To establish a Risk Event there must be an emission, a receptor which may be exposed to that emission through an identified actual or likely pathway, and a potential adverse effect to the receptor from exposure to that emission. Where there is no actual or likely pathway and/or no receptor, the emission will be screened out and will not be considered as a Risk Event. In addition, where an emission has an actual or likely pathway and a receptor which may be adversely impacted, but that emission is regulated through other mechanisms such as Part IV of the EP Act, that emission will not be risk assessed further and will be screened out through Table 9 and Table 10.

The identification of the sources, pathways and receptors to determine Risk Events are set out in Table 9 and Table 10.

Table 9. Identification of emissions, pathway and receptors during construction

Risk Events Continue to detailed risk assessment

Reasoning Sources/Activities

Potential emissions

Potential receptors

Potential pathway

Potential adverse impacts

Construction of the hardstand and above-ground storage tanks

Earthworks Asbestos fibres

Bottle shop at 250 m

Personnel at nearby industrial premises

Air / wind dispersion

Exposure to asbestos fibres can lead to severe health issues.

No

The Applicant will prepare an Asbestos Remediation Action Plan and only undertake surface-disturbing works under favourable weather conditions.

Dust suppressant and watering will be used as required and visual monitoring at the boundaries will ensure no emissions go beyond the premises.

The Delegated Officer considers that these measures and the short time-frame of construction are sufficient to manage this risk event.

W6326/2019/1 12

Risk Events Continue to detailed risk assessment

Reasoning Sources/Activities

Potential emissions

Potential receptors

Potential pathway

Potential adverse impacts

Noise Short term amenity impact No

As most activities will occur during day time and within a heavy industrial area, it is not expected that noise from the earth works equipment will cause any significant noise impacts

The Delegated Officer considers that the Noise Regulations are sufficient for regulating noise impacts during construction.

Dust Short term amenity impact No

The Applicant has committed to dust suppression measures and will ensure fugitive dust is not emitted from the earth works. General provisions of the EP Act applies.

Table 10: Identification of emissions, pathway and receptors during operation

Risk Events Continue to detailed risk assessment

Reasoning

Sources/Activities Potential

emissions Potential receptors

Potential pathway

Potential adverse impacts

Bulk storage of chemicals

Storage and handling of Class C1 combustible liquid and UAN.

Breach of containment causing discharge to land of the content of the tanks

Soil and groundwater underneath the premises.

Direct discharge Contamination of soil and groundwater

Yes See 8.4

W6326/2019/1 13

8.2 Consequence and likelihood of risk events

A risk rating will be determined for risk events in accordance with the risk rating matrix set out in Table 11 below.

Table 11: Risk rating matrix

Likelihood Consequence

Slight Minor Moderate Major Severe

Almost certain Medium High High Extreme Extreme

Likely Medium Medium High High Extreme

Possible Low Medium Medium High Extreme

Unlikely Low Medium Medium Medium High

Rare Low Low Medium Medium High

DWER will undertake an assessment of the consequence and likelihood of the Risk Event in accordance with Table 12 below.

Table 12: Risk criteria table

Likelihood

Consequence

The following criteria has been

used to determine the likelihood of

the Risk Event occurring.

The following criteria has been used to determine the consequences of a Risk Event occurring:

Environment Public health* and amenity (such as air

and water quality, noise, and odour)

Almost

Certain

The risk event is

expected to occur

in most

circumstances

Severe onsite impacts: catastrophic

offsite impacts local scale: high level

or above

offsite impacts wider scale: mid-level

or above

Mid to long-term or permanent impact to

an area of high conservation value or

special significance^

Specific Consequence Criteria (for

environment) are significantly exceeded

Loss of life

Adverse health effects: high level or

ongoing medical treatment

Specific Consequence Criteria (for

public health) are significantly

exceeded

Local scale impacts: permanent loss

of amenity

Likely The risk event will

probably occur in

most circumstances

Major onsite impacts: high level

offsite impacts local scale: mid-level

offsite impacts wider scale: low level

Short-term impact to an area of high

conservation value or special

significance^

Specific Consequence Criteria (for

environment) are exceeded

Adverse health effects: mid-level or

frequent medical treatment

Specific Consequence Criteria (for

public health) are exceeded

Local scale impacts: high level

impact to amenity

Possible The risk event

could occur at

some time

Moderate onsite impacts: mid-level

offsite impacts local scale: low level

offsite impacts wider scale: minimal

Specific Consequence Criteria (for

environment) are at risk of not being met

Adverse health effects: low level or

occasional medical treatment

Specific Consequence Criteria (for

public health) are at risk of not being

met

Local scale impacts: mid-level

impact to amenity

Unlikely The risk event will

probably not occur

in most

circumstances

Minor onsite impacts: low level

offsite impacts local scale: minimal

offsite impacts wider scale: not

detectable

Specific Consequence Criteria (for

environment) likely to be met

Specific Consequence Criteria (for

public health) are likely to be met

Local scale impacts: low level impact

to amenity

Rare The risk event may

only occur in

exceptional

circumstances

Slight onsite impact: minimal

Specific Consequence Criteria (for

environment) met

Local scale: minimal to amenity

Specific Consequence Criteria (for

public health) met

^ Determination of areas of high conservation value or special significance should be informed by the Guidance Statement: Environmental Siting. * In applying public health criteria, DWER may have regard to the Department of Health’s Health Risk Assessment (Scoping) Guidelines. “onsite” means within the prescribed premises boundary.

W6326/2019/1 14

8.3 Acceptability and treatment of Risk Event

DWER will determine the acceptability and treatment of Risk Events in accordance with the Risk treatment Table 13 below:

Table 13: Risk treatment table

Rating of Risk Event

Acceptability Treatment

Extreme Unacceptable. Risk Event will not be tolerated. DWER may refuse application.

High

May be acceptable.

Subject to multiple regulatory controls.

Risk Event may be tolerated and may be subject to multiple regulatory controls. This may include both outcome-based and management conditions.

Medium Acceptable, generally subject to regulatory controls.

Risk Event is tolerable and is likely to be subject to some regulatory controls. A preference for outcome-based conditions where practical and appropriate will be applied.

Low Acceptable, generally not controlled.

Risk Event is acceptable and will generally not be subject to regulatory controls.

8.4 Risk Assessment – Leaks (Risk Event 1)

Description of Risk Event 1

Risk Event 1 is described as follows:

“Liquid chemicals stored in above-ground storage tanks leaks from the tank(s) and secondary containment causing contamination of the soil and groundwater underneath.”

Identification and general characterisation of emission

Two 13,500 m3 capacity above-ground storage tanks will store UAN, up to fourteen 1,250 m3 capacity tanks will store Class C1 combustible liquids and four 60 m3 pre-receiving tanks will be for the treatment of tallow. If Risk Event 1 occurs this means that either a Class C1 combustible liquid or UAN is discharged into the environment.

Description of potential adverse impact from the emission

Chemicals can have a detrimental impact on soil and ground water when discharged to ground. The soil could be adversely contaminated and require removal and treatment while contaminated groundwater is expected to move towards Cockburn Sound, causing pollution.

Criteria for assessment

There are no specific criteria for environmental impact assessment for the proposed chemicals within the tanks.

Applicant controls

This assessment has reviewed the controls set out in Table 14 below.

W6326/2019/1 15

Table 14: Applicant’s proposed controls for Risk Event 1

Infrastructure Specifications and Standards

Urea Ammonium Nitrate storage tanks

Tanks to be constructed according to applicable Australian Standards.

Secondary containment Impervious bunds designed to Australian Standards to contain the greatest of 25% of all vessels, or 110% of largest vessel.

Leak detection All tanks to be located on impermeable concrete slab that is graded to a collection sump within the secondary containment bund for physical leak detection.

Stormwater management

system

Interceptor / Oil water separator for treatment of water contaminated with hydrocarbons.

Water captured from the proposed impervious surface will be directed through the onsite infiltration traps located along the eastern boundary of the premises, to be cleaned and slowly absorbed in the ground.

Aerobic treatment unit An aerobic treatment unit (ATU) to be installed to treat sewage generated by administrative and driver amenities, to be irrigated to irrigation area in the north-east corner of the premises.

Consequence

If Risk Event 1 occurs, then the Delegated Officer has determined that the impact of this will be of a mid-level at a local scale. Therefore, the Delegated Officer considers the consequence of Risk Event 1 to be Major.

Likelihood of Risk Event

The Delegated Officer has determined that the Risk Event 1 could only occur in exceptional circumstances (failure of all Applicant’s controls). Therefore, the Delegated Officer considers the likelihood of Risk Event 1 to be Rare.

Overall rating of Risk Event 1

The Delegated Officer has compared the consequence and likelihood ratings described above with the risk rating matrix (Table 10) and determined that the overall rating for the risk of Risk Event 1 is Medium.

8.5 Summary of acceptability and treatment of Risk Events

A summary of the risk assessment and the acceptability or unacceptability of the risk events set out above, with the appropriate treatment and control, are set out in Table 15 below. Controls are described further in section 9.

Table 15: Risk assessment summary

Description of Risk Event Applicant controls

Risk rating

Acceptability with controls (conditions on instrument)

1. Liquid chemicals stored in above-ground storage tanks leaks from the tank(s) and secondary containment causing contamination of the soil and groundwater underneath.

Infrastructure, Management, Monitoring

Major consequence

Rare likelihood

Medium Risk

Infrastructure to be conditioned

W6326/2019/1 16

9. Regulatory controls

A summary of regulatory controls determined to be appropriate for the Risk Event is set out in Table 16. The risks are set out in the assessment in section 8 and the controls are detailed in this section. The department will determine controls having regard to the adequacy of controls proposed by GrainCorp. The conditions of the Works Approval will be set to give effect to the determined regulatory controls.

Table 16: Summary of regulatory controls to be applied

Risk Event Controls

Infrastructure and equipment

Monitoring Reporting

Risk Event 1 • • •

9.1 Works Approval controls

The Works Approval conditions will be focused on the infrastructure that is proposed to be constructed. Reporting conditions will be included with regards to the construction of the infrastructure.

10. Determination of Works Approval conditions

The conditions in the issued Works Approval in Attachment 1 have been determined in accordance with the Guidance Statement: Setting Conditions.

The Works Approval will be issued for a period of three years, as this is the standard period for Works Approvals and it is anticipated that the works would be completed prior to the end of this period.

Table 17 provides a summary of the conditions to be applied to this works approval.

Table 17: Summary of conditions to be applied

Condition Ref Grounds

Infrastructure and equipment Conditions 1 to 3

These conditions are necessary to prescribe the works for which the Works Approval is issued. A requirement is included in these conditions to submit to the CEO an engineering certification that the infrastructure has been completed as per the Works Approval.

Record-keeping Conditions 4, 5 and 6.

These conditions are valid and are necessary administration and reporting requirements to ensure compliance.

DWER notes that it may review the appropriateness and adequacy of controls at any time and that, following a review, DWER may initiate amendments to the works approvals under the EP Act.

11. Applicant’s comments

The Applicant was sent a copy of the draft Decision Repot and Work Approval on 20 March 2020 and the department received a response on the 3 April 2020. Table 17 of the decision report was found to include obsolete conditions that are not included in the works approval. The Delegated Officer removed the unnecessary conditions so that the summary in Table 17 matches the conditions included in the works approval.

W6326/2019/1 17

12. Conclusion

The Applicant is able to apply for a registration for the operational phase of the premises. The works approval sets out the requirements for constructing and installing key infrastructure related to the risk of emissions. The Applicant is required to undertake an audit of compliance against the works approval requirements, including certification by an engineer.

It is the Applicant’s responsibility to ensure that it has complied with requirements of the works approval, undertaken necessary certifications and submitted its Environmental Compliance Report to DWER prior to operating the premises once it has applied for a registration.

This assessment of the risks of activities on the premises has been undertaken with due consideration of a number of factors, including the documents and policies specified in this Decision Report (summarised in Appendix 1).

Based on this assessment, it has been determined that the Works Approval will be granted subject to conditions commensurate with the determined controls and necessary for administration and reporting requirements.

Chris Malley

A/Manager, Process Industries

Delegated Officer under section 20 of the Environmental Protection Act 1986

W6326/2019/1 18

Appendix 1: Key documents

Document title In text ref Availability

1. 2

Category 73 Works Approval Application Form. GrainCorp, Kwinana Bulk Liquid Terminal.

Supporting documentation: Works Approval W6326/2019/1

W6326/2019/1 DWER record (A1839947)

2. 3 EPA EIA Proposal CMS 17728 Accessed at www.epa.wa.gov.au/

3. 3 DER, July 2015. Guidance Statement: Regulatory principles. Department of Environment Regulation, Perth.

DER 2015a

Accessed at www.dwer.wa.gov.au

4. 4

DER, October 2015. Guidance Statement: Setting conditions. Department of Environment Regulation, Perth.

DER 2015b

5.

DER, May 2016. Guidance Statement: Publication of Annual Audit Compliance Reports. Department of Environment Regulation, Perth.

DER 2016a

6. 5

DER, August 2016. Guidance Statement: Licence duration. Department of Environment Regulation, Perth.

DER 2016b

7. 6

DER, September 2016. Guidance Statement: Environmental Standards. Department of Environment Regulation, Perth.

DER 2016c

8.

DER, November 2016. Guidance Statement: Environmental Siting. Department of Environment Regulation, Perth.

DER 2016d

9.

DER, February 2017. Guidance Statement: Land Use Planning. Department of Environment Regulation, Perth.

DER 2017a

10. 7

DER, February 2017. Guidance Statement: Risk Assessments. Department of Environment Regulation, Perth.

DER 2017b

11. 8 DWER, June 2019. Guideline: Decision Making. Department of Water and Environmental Regulation, Perth.

DWER 2019a

W6326/2019/1 19

Document title In text ref Availability

12. 9

DWER, June 2019. Guideline: Industry Regulation Guide to Licensing. Department of Water and Environmental Regulation, Perth.

DWER 2019b

13. DWER, June 2019. Guideline: Odour emissions. Department of Water and Environmental Regulation, Perth.

DWER 2019c

14. National Environment Protection Assessment of Site Contamination Measure (ASC NEPM)

ASC NEPM 1999

Accessed at: http://nepc.gov.au/nepms/assessment-site-contamination

15.

Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand (ANZECC & ARMCANZ) (2000). Australian Water Quality Guidelines for Fresh and Marine Water Quality

ANZECC /

ARMCANZ

2000

Accessed at:

http://www.agriculture.gov.au/SiteColle

ctionDocuments/water/nwqmsguideline

-4-vol1.pdf

16.

Agriculture and Resource Management Council of Australia and New Zealand and Australian and New Zealand Environment and Conservation Council, Australian Guidelines for Sewerage Systems – Effluent Management (ARMCANZ/ANZECC 1997).

ANZECC

ARMCANZ

1997

Accessed at:

https://www.waterquality.gov.au/sites/d

efault/files/documents/effluent-

management.pdf

W6326/2019/1 20

Schedule 1: Site plan of proposed development.

Figure 2: Site plan for development is given below (in yellow).

W6326/2019/1 21

Figure 3: Proposed site layout

W6326/2019/1 22

Schedule 2: Guidance statements

The overarching legislative framework of this assessment is the EP Act and EP Regulations.

The guidance statements which inform this assessment are:

Guidance Statement: Regulatory principles (July 2015)

Guidance Statement: Setting conditions (October 2015)

Guidance Statement: Publication of Annual Audit Compliance Reports (May 2016)

Guidance Statement: Licence duration (August 2016)

Guidance Statement: Environmental Standards (September 2016)

Guidance Statement: Environmental Siting (November 2016)

Guidance Statement: Land Use Planning (February 2017)

Guidance Statement: Risk Assessments (February 2017)

Guideline: Decision Making (June 2019)

Guideline: Industry Regulation Guide to Licensing (June 2019)

Guideline: Odour emissions (June 2019)