MARDIE PROJECT PILOT EVAPORATION POND TRIAL · 2018-10-10 · • set the bund wall height of 4.2m...

MARDIE PROJECT PILOT EVAPORATION POND TRIAL

APPENDIX 3A (PROPOSED ACTIVITIES)

WORKS APPROVAL APPLICATION: CATEGORY 14:

AUGUST 2018

1 SYNOPSIS

This document presents information required for:

An application for a Works Approval for a Category 14: Solar salt manufacturing: premises on

which salt is produced by solar evaporation.

This document has been prepared for submission to the Department of Water and Environmental

Regulation.

Table of Contents

1 Synopsis .................................................................................................................. 2

1 Premise Details ....................................................................................................... 1

1.1 Applicant / Occupier Details .................................................................................... 1

2 Introduction ............................................................................................................. 1

2.1 Project .................................................................................................................... 1

2.2 Purpose .................................................................................................................. 1

3 Premise Details ....................................................................................................... 2

3.1 Legal Land Description ........................................................................................... 2

3.2 Prescribed Premise Location and Coordinates ....................................................... 3

4 Description of Existing Environment .................................................................... 6

4.1 Flora and Vegetation .............................................................................................. 6

4.2 Fauna and fauna habitats ....................................................................................... 7

4.3 Geology .................................................................................................................. 7

4.4 Topography and Soils ............................................................................................. 8

4.5 Climate ................................................................................................................... 9

4.6 Surface Hydrology ................................................................................................ 11

4.7 Ground Water ....................................................................................................... 12

5 Stakeholder Engagement ..................................................................................... 12

6 Prescribed Premise Category .............................................................................. 13

6.1 DWER Approvals .................................................................................................. 13

6.2 Documents associated with this proposal ............................................................. 13

6.3 Other Relevant Licenses / Permits ....................................................................... 14

6.3.1 DMIRS ..................................................................................................................... 14

6.3.2 Local Government ................................................................................................... 14

7 Proposal Description ............................................................................................ 15

7.1 Trial Evaporation Pond Project Objectives ........................................................... 15

7.2 Scope and scale of proposed activities ................................................................. 15

7.2.1 Key Characteristics .................................................................................................. 15

7.3 Pilot Evaporation Project Location ........................................................................ 16

7.4 Pilot Evaporation Ponds ....................................................................................... 18

7.4.1 Size ......................................................................................................................... 18

7.4.2 Construction Method ................................................................................................ 19

7.4.3 Source of Construction Materials ............................................................................. 20

7.4.4 Operational Management Plan ................................................................................ 21

7.5 Key Infrastructure & Equipment ............................................................................ 22

DWER – Works Approval Appendix 3A

Mardie Project – Pilot Evaporation Pond Trial 4

7.6 Unique processes to be tested ............................................................................. 22

7.7 Conservation Areas .............................................................................................. 22

7.8 Sensitive Receptors / Separation Distances ......................................................... 23

7.9 Commissioning ..................................................................................................... 23

8 Environmental management ................................................................................ 24

8.1 Process Emissions ............................................................................................... 24

8.2 Gaseous and Particulate Emissions ..................................................................... 24

8.3 Dust Emissions ..................................................................................................... 24

8.4 Odour Emissions .................................................................................................. 25

8.5 Noise Emissions ................................................................................................... 25

8.6 Discharges to Water ............................................................................................. 25

8.6.1 Stormwater Control / Emissions ............................................................................... 25

8.6.2 Surface Water Management .................................................................................... 25

8.7 Discharges to Land ............................................................................................... 26

8.8 Solid and Liquid Waste Management ................................................................... 27

8.9 Light Emissions ..................................................................................................... 27

8.10 Hydrocarbon/Chemical Storage ............................................................................ 28

8.11 Contaminated Sites .............................................................................................. 28

8.12 Other Emissions and Discharges .......................................................................... 29

9 Incident Response ................................................................................................ 29

9.1 Seawater Spill Response ...................................................................................... 29

9.2 Incident Response ................................................................................................ 29

9.3 Complaints ............................................................................................................ 30

10 Risk Assessment .................................................................................................. 31

10.1 Risk Assessment Process .................................................................................... 31

11 Cost of project ....................................................................................................... 32

12 Appendix ................................................................................................................ 33


1 PREMISE DETAILS

1.1 Applicant / Occupier Details

The occupier (Company) of the land subject to this Works Approval application / Licence to

Operate application is:

Mardie Minerals Pty Ltd

ACN: 152 574 457

Level 1, 15 Rheola Street

West Perth, Western Australia.

Mardie Minerals Pty Ltd is a wholly owned subsidiary of BCI Minerals Limited (ABN 21 120 646

924).

The contact person for this Works Approval application is:

Mr Michael Klvac

General Manager Corporate Affairs

BCI Minerals Limited

Phone: +61 8 63113406

Mobile: 0438 268 877

Fax: +61 8 6311 3449

Email: [email protected]

mailto:[email protected]


2 INTRODUCTION

2.1 Project

The Mardie Project aims to produce 3.5 million tonnes per annum (Mtpa) of high purity industrial

grade sodium chloride (salt) from seawater via solar evaporation, crystallisation and raw salt

purification. Through the crystallisation and processing of remaining bitterns, the Project will also

produce 75 thousand tonnes per annum (ktpa) of fertiliser grade SOP.

This trial program of works is to construct a nominal 1:10,000 scale system of ponds and

crystallisers to confirm the evaporation rates at each stage of the solar evaporation process on the

site at the same time recording atmospheric conditions and to prepare raw salts for pilot scale

processing off-site.

2.2 Purpose

The purpose of this document to apply for a Works Approval (WA) under Part V of the

Environmental Protection Act 1986 as prescribed under Section 54(1)(a) and Section 57(1)(a)

respectively of the Environmental Protection Regulations 1987,. This document therefore provides

the necessary information to support:

1. An application for a Works Approval; Category 14: Solar salt manufacturing: premises on

which salt is produced by solar evaporation under Schedule 1, Part 1 of the Environmental

Protection Regulations 1987

The WA Category 14 capacity being applied for is outlined in Table 1 below.

Table 1 WA and LTO Design Capacities

Category Number Category Description Production or Design

Capacity

14

Solar salt manufacturing:

premises on which salt is

produced by solar evaporation

NaCl 350 tpa



3 PREMISE DETAILS

3.1 Legal Land Description

The Project is owned 100% by Mardie Minerals Pty Ltd, a wholly owned subsidiary of BCI Minerals

Limited (BCI). The current tenement status is shown on Table 2.

Table 2- List of Mardie Tenements

Tenement Id Area (km2)

Current Holder Application

Date Grant Date Expiry Date

E08/1849 134.4 Mardie Minerals Pty Ltd 22-Feb-08 21-Nov-08 20-Nov-18

E08/2741 60.8 Mardie Minerals Pty Ltd 24-Jun-15 10-Feb-16 09-Feb-21

The tenements are indicated regionally on Figure 1, which also includes the native title claim

areas. The tenement overlies the Mardie Pastoral lease (Crown Lease CL453-1984) owned by

Citic Pacific Limited.

Current access to the site is from Northwest Coastal Highway and then the Mardie Station access

track.



Figure 1- Mardie Tenements Regional Location

3.2 Prescribed Premise Location and Coordinates

The proposed premise is located in Western Australia’s Pilbara coast, midway between the towns

of Dampier and Onslow. Current access to the site is from Northwest Coastal Highway and then

the Mardie Station access track. See Figure 2 for details of the actual premise boundary.


Figure 2 Proposed Prescribed Premise Boundary



Figure 3 – Proposed Pilot Evaporation pond boundary


4 DESCRIPTION OF EXISTING ENVIRONMENT

4.1 Flora and Vegetation

A total of 17 land cover types have been mapped for the Mardie Project, including 14 terrestrial

vegetation types. The Mardie Project is dominated by unvegetated algal mat and mudflat/salt flats.

The Trial Pond study area is also dominated by unvegetated mudflat/saltflat (Figure 3a) and to a

lesser extent Spinifex (Triodia spp.) steppe (Figure 3b), Prosopis (mesquite) shrubland (Figure 3c)

and Shrublands over Triodia spp. grasslands (Figure 3d). Mesquite is a Weed of National

Significance (WoNS) and the mesquite infestation at Mardie station is recognised as the largest

single infestation in Australia (Astron 2014; NHT 2003).

Figure 4 Vegetation types present within the Trial Pond study area

More detail on flora and vegetation can be found in the report prepared by Phoenix Environmental

Sciences (Attachment 4A)



4.2 Fauna and fauna habitats

Fourteen fauna habitats (Table 3) have been recognised for the Mardie Project, including four within

the Trial Pond study area. Fauna habitat within the Trial Pond study area is also dominated by

mudflat/saltflat, spinifex grassland and Prosopis shrublands (Figure 3). None of these habitats are

restricted within the Mardie Project or indeed regionally.

Table 3 Fauna habitat types Mardie Project and Trial Pond study areas

More detail on fauna and fauna habitats can be found in the report prepared by Phoenix

Environmental Sciences (Attachment 4A)

4.3 Geology

Regional geology is well mapped and as part of the Mardie Project detailed investigations have been

undertaken within the project area. The white area is clay to surface with or without a salt crust. The

light is unconsolidated alluvium consisting of beach sands and fine gravels. The Orange area is an

alluvium of clay, gravels and fine sands interspersed. The materials are loosely agglomerated in

some zones.



Figure 5 - Geology Map of Area

4.4 Topography and Soils

The area is very flat between 1.25m and 2.0m AHD over the entire mud/salt flats. Within the flats

the occasional island rises to a nominal RL of 4.4m AHD, the eastern edge of the mudflats

presents as a rise to approximately 4.5m AHD.

Figure 6 is a photo of the Error! Reference source not found. proposed pilot evaporation trial pond

area. The photo was captured from the raised island which is nominally 2m above the brown/white

clay. The gray scree consists of loose gravel rocks which overlay brown clays. The hypersaline



ground water is approximately 500mm below the clay surface. The quad bike tracks indicate the

direction of the proposed access track, in the distance on the slightly raised ground is a mixture of

spinifex and the declared pest (C2 control classification, DPIRD 2018) Prosopis sp1. (Mesquite).

Figure 6 - Proposed pilot evaporation pond area

4.5 Climate

The Mardie regional climate is classed by the Bureau of Meteorology (BoM) as ‘Grassland’

characterised by year-round hot weather. Rains occur predominately in the first half of the year

with summer rainfall related to tropical lows including cyclones and ex-tropical cyclones. Winter

rains are typically the result of the northern extent of large southern fronts. The Mardie Project has

undertaken detailed analysis of the BoM data and installed in wet and dry bulb temperature

loggers within the project footprint. Figure 7 indicates the long term mean rainfall and evaporation.



Figure 7 - Monthly Mean Rainfall and Evaporation

Figure 8 indicates the long term monthly mean maximum and minimum temperatures and the wind

speed at 9.00am and 3 pm.

Figure 8 - Mean Monthly Max, Min temperature and wind speed



Wind roses for 9:00am and 3:00pm at Mardie Station are shown on Figure 9. These indicate

morning Southerly to Easterly winds followed by afternoon Westerly to Northerly winds. The winds

will on average change the air over the solar ponds every 30 minutes reducing the impact of the

ponds on local relative humidity.

Figure 9 - Mardie Station Wind Roses

Figure 10 - Australian pan evaporation data

4.6 Surface Hydrology

A surface hydrology study has been completed as part of the Mardie Project Prefeasibility study.

The work included:



• a hinterland drainage study based on storm events and the impacts on the project area

• coastal inundation study based on tidal inundation of the project footprint.

The results of these studies have been used to:

• set the bund wall height of 4.2m AHD for a ARI of 1:100 year

• select the rock armor for bund wall protection, and

• design the project to allow east-west movement of flood waters without impacting the

Mardie project.

The studies have been used to select the site for the trial ponds ensuring that the ponds area

protected from both land and sea inundation and the site infrastructure is installed above the

maximum flood level.

The proposed pilot evaporation ponds have been situated on the east side of a mud flat island with

a 4.2m AHD high bund wall around the outside perimeter that will protect the ponds from storm

surge. Surface water from the east will flow around the pond structure and out onto the mud flats.

4.7 Ground Water

Samples of water from the mud flats have been collected and analysed which confirmed the water

table is between 0.3m and 0.8m below the surface the with salinity varying between 130,000uS/cm

and 210,000uS/cm, or up to 3 times the salinity of Mardie seawater which averaged 69,000 uS/cm.

No impact to the ground water is anticipated from a seawater pipeline leak because the mudflats

are regularly inundated by seawater at high tide.

No impact to the ground water salinity is anticipated from the pond area from seepage because:

• Ponds P1 to P7 are unlined and contain concentrated sea water which averaged will not

exceed the salinity of the underlying ground water.

• Pond P8 and all the crystallisers will be lined with a HDPE membrane preventing leakage.

5 STAKEHOLDER ENGAGEMENT

BCI has undertaken the following stakeholder consultation in regards to the Project with the

following stakeholders:

Table 4 Stakeholder Engagement

Stakeholder Discussion Outcome / Actions

Yaburara and Mardudunera People

Completed discussion with YM People CEO (Amanda Wheeler) regarding Project rationale, No objections were raised.

Completed heritage survey

Engaged in on-going discussions



Shire of Roebourne/City of Karratha

General discussion outlining the Project rationale and implementation activities. No objections were raised.

Initial discussions completed

DWER – EPA

Email discussion held regarding approvals required for the Pilot Evaporation Pond Trial Project. No approvals required under Part IV of EP Act. Discussion held with Vanessa Robinson and Peter Tapsell.

Discussion regarding applying for works approval and applying for Licence to Operate (LTO)

BCI to discuss project with DWER and DMIRS to gain Part V approval and Mining Act Approval

DMIRS

Overview of Mardie Project given and overview of trial pond project.

Agreed that work could be completed under a POW-E and Part V EP Act Approvals.

Discussion held with Danielle Risby and Matt Boardman

BCP to submit a POW and accompanying letter to Matt Boardman

Mardie Station On-site meetings, telephone and email discussions

Pilot evaporation pond works scheduled to minimise impact on station, Access through the station agreed with map signposting and instructions prepared.

Pilbara Mesquite Management Committee

Control of impacted mesquite during clearing, construction and operation

Works will use best practice clearing and control methods.

No objections or concerns were raised by any of the above stakeholders, providing the appropriate

approvals are granted. Please refer to Section 6.3 Other Relevant Licences/Permits for more

information on additional approvals.

6 PRESCRIBED PREMISE CATEGORY

6.1 DWER Approvals

No Part IV approvals required. Part V of EP Act approvals outlined in this submission

6.2 Documents associated with this proposal

The following documents related to the Project are outlined in the table below and are available on request.

Table 5 Site Surveys and assessments



Factor Study area Study effort

Vegetation Full Project and trial ponds Two-season, Level 2 survey. Local impact assessment report

Terrestrial Vertebrate Fauna

Full Project and trial ponds Habitat assessments; targeted surveys

Full Project and trial ponds Habitat assessments; targeted surveys

ASS Full Project and trial ponds Static testing of drill samples, Leachate, waste fines and process liquor

6.3 Other Relevant Licenses / Permits

6.3.1 DMIRS

POW No. 75407 and PMP No. PM450-316706 have been submitted. The quantity of diesel and minor other fuels stored on site will not require a Storage of Dangerous Goods Licence (DGL).

6.3.2 Local Government

Any applicable Local Government approvals required will be obtained from the Shire of Roebourne prior to commencement of construction. The Project and the proposed operations outlined in this application will be constructed and operated in accordance with approvals issued under the Mining Act 1978. As such, this infrastructure will not be subject to the Planning and Development Act 2005 or any other local government planning by-laws.



7 PROPOSAL DESCRIPTION

7.1 Trial Evaporation Pond Project Objectives

The purpose of the proposed works is to:

• confirm the evaporation rates at each brine density stage during solar concentration and

crystallisation;

• calibrate the results using recorded atmospheric conditions to long term BOM records;

• provide raw salt product samples for laboratory and pilot processing trials; and,

• produce samples of the resultant waste bitterns for characterisation.

7.2 Scope and scale of proposed activities

7.2.1 Key Characteristics

This works approval application relates to a pilot trial for the production of salt (NaCl), mixed

potassium salts for further processing into Sulphate of Potash (K2SO4) and waste bitterns for

characterisation.

Details of key characteristics relevant to Category 14 prescribed premises activities are

summarised in Table 6.

Table 6 - Key Characteristics

Project Element Description

Operational Purpose Pilot seawater solar evaporation trials

Location of Operations

Nominally 122km southwest of Karratha

Annual Production 350t of raw NaCl salt and 7.5t of mixed potassium and magnesium salts

Project Duration 24 months

Processing Method Solar evaporation of seawater

Tailings No tailings will be produced

Waste 60t of mixed NaCl and Magnesium salts

Reagents and Fuels

Diesel will be used to fuel the generators for supply of power and mobile equipment. Small amounts of unleaded fuel will be used in quad bikes used to access the seawater pump and periodically check the pipeline. No reagents will be used in the process.

Product Transport Product will be transported to Perth in 1 tonne bulka bags, IBC’s or sealed 20l plastic drums

Workforce 1-2 people, who will be accommodated at the local pastoral station or at Fortescue roadhouse village



Seawater abstraction Nominally 22,000m3 over 12 months

Other water requirements

Nil, provided via RO plant attached to pilot program

Power Requirements Nominal demand of 7.5 KVA provided by diesel generators for pumps and site laboratory

Estimated ground disturbance

3.2ha for the pond area. The sea water pipeline will be laid on the surface and removed on completion

7.3 Pilot Evaporation Project Location

The pilot evaporation trial access track will commence on a local station track at the north western

corner of E08/2740 and then continue north along the boundary of lease E08/1849 until it reaches

the trial site as indicated on Figure 11.



Figure 11 - Pilot Evaporation Project Location



7.4 Pilot Evaporation Ponds

7.4.1 Size

The proposed trial evaporation ponds will be contained within a bunded area 180m long by 120m

wide as indicated in Figure 12.

Figure 12 - Pilot Evaporation Pond Layout

The disturbance area will extend up to 40m outside the bund wall for the purpose of operating a

dozer and grader, allowing sufficient room to level the area, remove gravel scree and obtain

natural clays for wall and pond floor construction.

Table 7 lists the pond dimensions.

P5

P1

P2

P6

P7 P8C1 A

C2 A

C3 C4

C5C6

C7 C8 C9 C10

C11

Seawater

150

m

P3 P4

P

P

C2 B

C1

B

Lab

Store

Ge

n

Pan evaporators

Access track

160 m

P

P

Generator , RO Plant, fuel

natural island bank, 2.5m high



Table 7 - Pilot pond internal dimensions

The flat top of pond walls will be 2m wide with access ramps formed to allow safe operating access.

7.4.2 Construction Method

The area selected is within the proposed crystalliser area of the Mardie project and the intention is

to use and test local materials to validate broad area geotechnical testwork completed during the

Prefeasibility study. The bund wall construction consists of:

• Removal of highly permeable gravels from the surface and covering underlying clay

nominally 400-700mm below the surface.

• Construction of a bund wall clay core from the exposed clay base nominally 2m high

Pond Length

(m) Width

(m) Area (m2)

Fill Volume (m3)

P1 50 26 1292 650

P2 50 29 1457 730

P3 50 26 1300 650

P4 40 25 1000 500

P5 40 23 924 460

P6 40 12 482 250

P7 20 15 305 150

P8 18 12 209 100

C1 20 19.5 390 195

C2 20 19.5 390 195

C3 10 7.3 73 37

C4 10 6.6 66 33

C5 10 6.1 61 31

C6 10 5.3 53 27

C7 10 4.6 46 23

C8 10 7.2 72 36

C9 10 11.5 115 58

C10 10 11.6 116 58

C11 10 9.6 96 48



• Cover of the clay core using local gravels and fines materials blended to from a

compactable general fill material

• Lining of the outside of the bund wall with locally won light weight rock armour.

The internal pond walls for ponds P1 to P7 will be constructed similar to the external wall with the

top of wall height nominally 1m lower.

Crystallisers C1 to C11 will be lined with 1mm HDPE to allow the precipitated salts to be collected

for analysis.

Figure 13 indicates the proposed bund wall cross section and internal pond walls.

Figure 13 - external bund wall and internal pond wall sections

Pumps and weirs are located to control the flow of brine between the ponds. There are placed to

represent to proposed full scale operation.

The pan evaporators will be fabricated from stainless steel to BOM specifications and placed on

timber pallets.

7.4.3 Source of Construction Materials

Geotechnical work completed during the PFS and subsequent site inspection indicates the

selected site will have gravel/sand scree up to 600mm deep overlaying clay. The scree will be

graded into a stock pile windrow and blended and used as general fill to construct the bund wall.

Underlying clays will be excavated and used to build the clay core.

Clay Core

Compacted road base

General fill

Rock armor layer

Gravel Layer - removed to underlying clay to form core seal

1.4m0.5m

Average water level

Internal wall

Underlying Clay



Around the raised dune there is loosely agglomerated rock, which is proposed for the bund wall

armour rock. The material will be extracted using mechanical equipment without the need for

explosives.

7.4.4 Operational Management Plan

The Mardie Project pilot test work program has been developed to validate key PFS assumptions including:

• Collection of detailed weather parameters on a 30 minute interval basis

• Analysis of site specific evaporation rates for evaporation ponds and crystallisers

• Confirm civil construction techniques

• Produce crystallised salt samples for salt purification and SOP process plant testwork; and

• Produce raw salt product samples.

Once the ponds have been constructed seawater from the ocean will be pumped into ponds P1 to

P8 filling them to a depth of 500mm. As evaporation occurs brine densities will increase in each

pond. As each pond density reaches its design density it will be maintained by transferring brine

from up and down stream ponds which will be representative of the proposed continuous flow

design incorporated in the Mardie Project eight pond concentrator system. Pond 8 will have a brine

density just lower than when NaCl begins to precipitate. At this point it will be transferred into

Crystallisers where in C1 and C2 high purity NaCl is precipitated. The layout indicated two parallel

C1 and C2 Crystallisers. This is to allow 50% of the crystalliser to be drained to C3 and allow the

NaCl to be dry harvested by hand and using a bobcat. This will be representative of the high purity

raw salt from the proposed Mardie Project.

The brine is then transferred to the down stream crystallisers C3 to C11 and will follow the same

process. Because the volumes are much reduced a single crystalliser is proposed at the stage.

The precipitated salts at each crystalliser stage will be representative of the proposed Mardie

Project solar evaporation stages.

The continuous flow of brine through the ponds and crystallisers will be monitored daily and

seawater added into pond P1 to retain pond levels. This will be completed using a small

submersible electric pump and nominal 4.8km long 75dia HDPE pipeline.

After 12 months operation the predicted tonnes of salts listed in the key characteristics will be

produced.



The control pan evaporators will be filled with brine artificially concentrated (using heat lamps in a

laboratory) to the design density of each pond and crystalliser. Daily the net evaporation will be

recorded in each pan and the pan will be filled to the original starting level.

7.5 Key Infrastructure & Equipment

The key infrastructure associated with and supporting the proposed pilot trial ponds includes:

• Laboratory sea container and test equipment – used to complete daily site tests for each

pond brine to ensure that the system is operating within proposed design tolerances.

• Storage sea container – used to store tools and maintenance equipment.

• Diesel powered generator and bunded fuel tank – used to provide power to the laboratory

equipment and room and brine pumps.

• Seawater pump, local diesel generator and 4.8km 75mm dia HDPE pipeline.

• Water tanks – for storage of seawater ready for decant into pond 1 and to supply the RO

plant.

• Nominal 20 l/hr self-contained reverse osmosis for provision of fresh water to fill pan

evaporators, operate the laboratory and general washdown.

• Fresh water storage tank and dispensing pump.

• Mobile equipment – bobcat for minor pond maintenance, quad bike for seawater pump

and pipeline operation, 4WD vehicle for general use and out-loading of raw salts.

• Portable pump used as standby for pond to pond transfers and storm water management.

7.6 Unique processes to be tested

The pilot trials will test the solar evaporation of seawater to a brine density of 1.328, well past the

density of bitterns discharged from solar pond operations along the Western Australian coast,

which are typically around 1.25. Between the density of 1.25 and 1.328 little work has been

completed for coastal salt operations and this will be a unique process. This kind of evaporation

work has never been completed for the Mardie area and even fresh water pan evaporation records

are not included at the Mardie BOM site.

7.7 Conservation Areas

The Project area is not located within:

• an Environmentally Sensitive Area (ESA) as listed under the Environmental Protection

(EP) Act 1986.



• a ‘specified ecosystem’ as described in the Department of Environment Regulation

(DER), Environmental Siting Guidelines (2016)

• Conservation Reserve/ DBCA managed land (including Threatened or Priority

Ecological Community), Ramsar Site, Significant/ Nationally Important Wetland or a

Bush Forever Site. The nearest known specified ecosystem is Fortescue River delta.

This specified ecosystem is not proposed to be impacted by pilot trial ponds

development or disturbance foot print.

7.8 Sensitive Receptors / Separation Distances

No Threatened Ecological Communities (TECs) or Priority Ecological Communities (PECs) occur

within, or adjacent to the trial pond survey area. The only potential sensitive receptor within the

vicinity of the Project is the Mardie Pastoral station accommodation facilities for the Project

construction and operational employees and contractors.

During construction and initial operations of the trial pond, employees and contractors will be

accommodated at the Fortescue Roadhouse, approximately 35km from the proposed premises.

The EPA Guidance Statement 3. Separation Distances between Industrial and Sensitive Land

Uses (EPA 2005) doesn’t delineate a separation distance for salt evaporation activities. However,

Appendix 1, Table 1 did determine that there is a ‘Specified Ecosystem’ across the project area;

namely # 31. Acid Sulfate Soils (ASS) Risk Area (map, Pilbara Coastline Department of

Environment Regulation). An assessment for ASS was undertaken by Stantec (Stantec, 2017),

conducted in accordance with the Department of Environment Regulation (DER) 2015 Guidelines

for Identification and Investigation of Acid Sulfate Soils and Acidic Landscapes (DER, 2015). The

outcome of the assessment determined that due to the low ASS risk of surface soils within the

Project area, further investigations into the presence of ASS is not considered necessary, unless

disturbance is planned at greater depths (>1 mbgl). Therefore, no risk from ASS is expected due to

construction or operational activities of the proposed test ponds.

Furthermore, BCI will ensure that the proposed premise location will not impact sensitive receptors

within the Project locality, i.e. Mardie Station.

During operations, all employees and contractors for the Project will be accommodated at the

abovementioned Fortescue Roadhouse.

7.9 Commissioning

It is requested that commissioning of the trial ponds be undertaken under the Works Approval and

prior to submission of the required Compliance Document and granting of a Licence to enable



various components to be trialed and tested. This will enable testing of equipment whilst the

licence is being assessed.

Commissioning will consist of two stages, pre-commissioning and load commissioning and is

expected to take a maximum of three months. Pre-commissioning will consist of the electrical and

mechanical testing of the equipment. This will involve running or live testing all items of equipment

to confirm that they operate as per their intended function.

The system will then go through the load commissioning stage; namely the test ponds will be

operated to test and confirm all control functions including pumps and generators are working

correctly.

8 ENVIRONMENTAL MANAGEMENT

Emissions, Discharges and Waste will be responsibly managed as described in the following

sections.

8.1 Process Emissions

There are no planned process emissions from the pilot evaporation pond trials.

The pilot evaporation pond trials will use solar evaporation to reduce seawater to solids and a

small residue brine. The solid salts will remain in each pond forming part of the seepage and

bearing capacity testwork. Solids for off-site testwork will be dry harvested and placed in drums for

transport to laboratories. The residue liquor will be transferred to containers and be analyzed off

site for potential byproducts.

8.2 Gaseous and Particulate Emissions

Diesel generators will be used at the seawater pump and pilot evaporation ponds to generate

electrical power. The estimated operating demand at the seawater pump is 1.8kW and at the Pilot

evaporation ponds is 4.2 kW. Based on the manufacturers energy consumption and emissions

data the resultant emission of CO2 will be 3.4kg/hr, estimated to be 34kg of CO2 per day.

8.3 Dust Emissions

The Project will be situated a minimum of 9km away from Mardie Station. Based on the

configuration of the operations, there are no significant environmental receptors that are likely to

be affected by any dust that is generated through the Project activities.

Water trucks will be used on roads to suppress dust, if required. Visual dust monitoring will be

used to confirm that controls are effective or as a basis for implementing corrective action.



8.4 Odour Emissions

The Project will not emit any odour.

8.5 Noise Emissions

Water pumping activities, and power generation, will produce additional noise levels. However,

given that there are no sensitive receptors in proximity to the Project noise is not expected to be an

issue.

BCI understands that the Environmental Protection (Noise) Regulations 1997 apply. BCI will:

• Use equipment, machines and vehicles that would be the quietest, reasonably

available, consistent with operational requirements that would be routinely maintained

to ensure the effectiveness of noise suppression systems and equipment.

• Inform all personnel (including contractors) through site inductions of their

responsibilities and the importance of managing noise levels during the construction

phase and ongoing operations.

All construction and operations will be expected to comply with the Environmental Protection

(Noise) Regulations 1997 (noting that Clause 13 of the Regulations covers construction noise and

how it is managed through the Regulations).

8.6 Discharges to Water

There will be no discharges to water from the Project. The Project is regularly inundated with

seawater, so any potential discharges will be diluted.

8.6.1 Stormwater Control / Emissions

Rain falling directly into ponds will naturally evaporate. Rain falling inside the perimeter bund but

outside the ponds will evaporate or seep into the ground, identical to the current natural situation.

Should an unusual or extreme rain event occur water collected in the pond area will gravitate to a

sump where it will be tested before it is pumped over the bund wall into the environment, in this

type of extreme event the entire Mardie region is likely to be flooded and the mudflats under water.

8.6.2 Surface Water Management



The Pilot Evaporation ponds have been located against an existing naturally formed raised island

on the mud flats. The mud flat component is periodically inundated via two mechanisms:

• Tidal cycles, and

• Extreme rainfall events (cyclones).

Under normal tide cycles the area will be inundated for short periods on the highest tides several

times per month. The depth of seawater at hightide will not exceed 100mm unless there is an

extreme storm surge associated with the high tide. Measures to protect against an extreme event

include:

• construction of a perimeter bund wall with a top level set at the calculated 1:100 ARI.

• positioning of the ponds to the east side of the naturally occurring island away from direct

impact of ocean storm events,

• protection of the outside of the perimeter bund wall with rock material, to protect against

erosion

• installation of supporting infrastructure on the top of the island above the inundation level

of an extreme event

• installation of the seawater pump generator on raised ground above the calculated storm

inundation water level.

An extreme rainfall event can be associated with a cyclone. In these events surface water can flow

from the higher land to the east down onto the mudflats. The pilot evaporation ponds have been

positioned to allow any surface flow to pass along the natural creek lines either side of the

perimeter wall. Rock protection has been included to eliminate wall erosion.

Management measures will include:

• Any evidence of erosion, disturbance to natural drainage flow or impact on vegetation

must be reported to the Project Manager and be remediated as required;

• Site surfaces will be shaped to allow for natural drainage and to avoid pooling or

ponding on site;

• Disturbance will be minimized.

8.7 Discharges to Land

There will be no discharges to land from the Project.



8.8 Solid and Liquid Waste Management

Solid and liquid wastes generated from construction and ongoing operations may include:

• Inert wastes such as glass, paper, cardboard, wood, bricks, concrete, plastics, scrap

metal, obsolete or expired equipment (e.g. transformers, pumps and pipes);

• Domestic waste including the generation of putrescibles (e.g. kitchen scraps), non-

recyclable packaging and non-hazardous liquids;

• Sewage and wastewater from toilets and onsite ablutions; and

• Hydrocarbon waste generated from fuel spills.

BCI has an obligation to manage waste disposal in accordance with the Environmental Protection

Regulations 1987 and the Environmental Protection (Controlled Waste) Regulations 2004. These

regulations govern the general control of pollution and outline obligations regarding the

transportation and disposal of ‘controlled’ wastes.

BCI will implement the following management measures in regards to waste storage and disposal:

• Disposing of putrescible and inert waste to an appropriately licensed facility (off site),

• Collecting and treating ablution effluent prior to removal from site by approved

controlled waste carrier; and

• Maintaining and servicing equipment regularly.

8.9 Light Emissions

Additional lighting will be required to service the Project. Given the distance to the nearest

sensitive receptor, nuisance light is not expected to be an issue. There is potentially some impact

to local fauna from additional light emissions.

Managing impacts of light overspill on fauna during construction and operations will be conducted

through the implementation of the following management strategies:

• All external lighting will be targeted where possible, using shields and directional

lighting to minimise light spill beyond the required work area; and

• External lighting will use, where possible, red or low pressure sodium lights. Bright

white lights such as mercury vapour, metal halide or florescent will be avoided where

possible.

The design of these systems will be such that light spill to the surrounding environment will be

minimised as far as practicable.



8.10 Hydrocarbon/Chemical Storage

The design and construction of tanks, pipes and bunding will comply with all relevant regulations

under the Dangerous Goods Act 2004 (WA) to prevent and/or manage spills. Hydrocarbons and

chemicals will be stored in bunded areas. The bund will be constructed in an impervious material

to comply with Australian Standard (AS) 1940 – 2004 ‘The Storage and Handling of Flammable

and Combustible Liquids’ with a minimum retention capacity of 110%. Bunded areas will be

regularly maintained by inspecting the integrity of the bund, regularly cleaning out of the bund and

checking that any valves are sealed and kept in the closed position;

The following measures are proposed to be implemented to manage and mitigate potential issues

associated with hydrocarbon and chemicals handling during construction and operations at the

Project:

• Separation of hydrocarbon materials from other facilities and people, segregation from

stored dangerous goods, placarding, providing firefighting equipment at hydrocarbon

and chemicals storage and handling areas.

• Vehicles will be refuelled by a mobile fuel truck utilising drip trays;

• The diesel fuel will be pumped and not gravity fed into vehicles/generators and the

pump will be installed with a shut off device, so that the pump can be shut off in case of

an emergency. The shut off device will be easily accessible and clearly identified;

• The Project area will be equipped with spill kits and equipment that will be regularly

monitored and maintained. The kit will include sufficient quantities absorbent materials,

equipment for recovering spilled materials, containers for recovered materials and

personal protective equipment;

• In the case that a spill occurs, it will be reported immediately to the Site Manager and

the area around the spill will be isolated and mopped up using the spill response kit and

equipment;

• The waste from the spill will be stored separately and isolated, until the spill waste is

collected and disposed by a licensed contractor; and

• All site personnel will be made aware of the hydrocarbon management strategies

through training at inductions and ‘tool-box’ meetings.

8.11 Contaminated Sites

No known contaminated sites exist within the proposed premise boundary. The works proposed

are also unlikely to give rise to any contamination given the safeguards proposed in this document.



8.12 Other Emissions and Discharges

There are no further anticipated impacts to groundwater, soil hygiene, visual impact, flora and

fauna as the result of the implementation of this proposed works approval and ongoing operations.

No increase in the risk of incidents which may cause harm to the environment (or personnel) is

anticipated to occur because of the installation and operation of the trial ponds that have not been

considered in the risk assessment (See Section 11 for more details).

All management of emissions and discharges will be considered in line with the surrounding

receiving environment and implemented in line with approval guidelines and associated industry

best practice.

9 INCIDENT RESPONSE

9.1 Seawater Spill Response

Seawater could spill due to a leak in the seawater pipeline or a breach of the perimeter bund wall

and the internal pond walls.

A leak from the seawater pipeline is considered the most likely of the two events. Operational

protocols include a daily inspection. In additional the system has high and low pressure safety

switches and flow meter to confirm that the pump only operates when required and when the pump

is operating that water is flowing into the storage tank. The method of control will limit the volume

of a spill and corrective action would be undertaken to fix a leak if one occurs. The pipeline route

is across the mudflats which are inundated by seawater several times per month at high tide and

wherefore a small leak is unlikely to have any impact.

A breach of the perimeter bund wall has been considered by the project risk committee as the

major cause of a potential breach is a result of a severe cyclone where the damage is cause by

excessive wind and a storm surge at high tide. The bund wall design has been designed to protect

against a 1:100 ARI event. The response to the cyclone is to evacuate area project until it is safe

to return. I full evaluation of the project would be undertaken on return to the site and corrective

measures instigated.

9.2 Incident Response

If a potential pollution incident occurs (e.g. hydrocarbons spill), the Site Manager will be notified,

the activity causing the problem will cease and an investigation will be initiated immediately. The

following corrective action will be taken as soon as practicable:



• Recording of the date, time and reason for the incident;

• Estimation of the period over which the incident occurred;

• Determination of the extent of the emissions or discharges over that period and

potential or known environmental consequences;

• Establishment and implementation of corrective action taken or planned to mitigate

adverse environmental consequences; and

• Establishment of a corrective action to prevent a recurrence of the incident.

The Site Manager will advise DWER within 24 hours of becoming aware of an incident which may

have resulted in emissions which exceeded works approval limits.

The Project will be equipped with spill kits and spill response equipment that will be regularly

maintained. The kits include absorbent materials, equipment for recovering spilled materials,

containers for recovered materials and personal protective equipment. In the event of a fuel or

chemical spill, the spill will be contained and the source will be isolated and recovered immediately

using absorbent materials, which will then be placed in disposable drums or containers onsite.

Any contaminated soil or absorbent material resulting from a fuel or chemical spill will be removed

by a licensed contractor to an authorised waste disposal site. Where necessary, validation

sampling will be undertaken to verify that all contaminated soil has been removed. All spills that

may cause a significant environmental impact will be reported to the DWER as soon as

practicable.

All site personnel will be trained in the site’s procedure to follow in the event of a hydrocarbon spill

Once the incident has been investigated, the Site Manager will advise DWER in writing of the

status of corrective actions implemented to address the problem.

9.3 Complaints

The Project will record any complaints in the BCI Complaints Register. If a complaint is received, it

is most likely to be from an adjoining landholder, either the pastoralist from Mardie Station or

another lease holder. Records of any correspondence and dealing with the complainant will be

maintained.

Should a complaint be received, the Project Manager will contact any complainants that have

concerns related to the environmental issues and determine the nature of the issue. The Project

Manager will take steps to ensure that any identified impacts are addressed. If the issue relates to

matters covered by the licence issued under Part V of the EP Act, the Project Manager will advise



DWER of a valid complaint and advise in writing the corrective actions implemented to address the

problem.

10 RISK ASSESSMENT

BCI has completed a risk assessment of the pilot test pond activities proposed under this works

approval application and is offered to assist DWER with its own assessment.

Information on the biophysical setting within which the trial would take place is provided in Section

7.

Selected technical studies used to prepare the “Existing Conditions” summary are appended to the

works approval as Attachments 3C1 and 3C2.

10.1 Risk Assessment Process

The risk process was sourced from DER Guidance Risk Assessments - Part V, Division 3,

Environmental Protection Act 1986 (February 2017).

A risk register with further details on inherent and residual risk assessments for construction and

operations of the Mardie trial ponds is presented in Attachment 8A of the works approval

application.



11 COST OF PROJECT

The estimated capital cost of the project is highlighted in Table XX

Cost of Facilities

Prescribed Premise Capital Cost

Mobilisation costs $30,000

Construction costs of ponds $325,000

Laboratory costs $125,000

Total costs $480,000


12 APPENDIX

Appendix A - Mardie Trial Pond PoW Memo PhoenixEnvSci Appendix B - Stantec ASS Investigation

MARDIE PROJECT PILOT EVAPORATION POND TRIAL · 2018-10-10 · • set the bund wall height of 4.2m...

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