Application form: Works Approval / Licence / Renewal ... Form: Works Approval, Licence, Renewal, Amendment or Registration (July 2017 v7) 1 IR-F09 v7.0 Application form: Works Approval

Application Form: Works Approval, Licence, Renewal, Amendment or Registration (July 2017 v7) 1 IR-F09 v7.0

Application form:

Works Approval / Licence / Renewal Amendment / Registration

Part V, Division 3, Environmental Protection Act 1986 Environmental Protection Regulations 1987

Application Type

INSTRUCTIONS: • The application form must be completed with all relevant information attached. This form is a statutory requirement

under section 54(1)(a) for works approval applications, section 57(1)(a) for licence applications, section 59B(1)(a) for amendments, and regulation 5B of the Environmental Protection Regulations (EP Regulations) 1987 for registration.

• If an application form has been submitted which is incomplete or materially incorrect, the CEO will decline to deal with the application under the Environmental Protection Act 1986 (EP Act) and advise the Applicant accordingly.

• The instructions set out in this application form are general in nature. • A reference to ‘you’ in these instructions is a reference to the Applicant. • “Works approval” only applies for new works approvals. “Licence” only applies for new licences. For Premises which

already have a works approval or licence, please select “Amendment”. If there is an existing Licence, please apply for a Licence Amendment, rather than a Works Approval Amendment.

• Concurrent applications for a Works Approval and Licence (or registrations) are encouraged. This means only a single application is submitted.

• Applicants seeking further information relating to requirements under the EP Act, are recommended to review the Act through the State Law Publisher (www.slp.wa.gov.au). Schedule 1 of the EP Regulations contains the categories of Prescribed Premises. The EP Regulations are also available from the State Law Publisher’s website.

• For Premises where activities fall within more than one category of Prescribed Premises, ALL categories must be identified. This applies for existing Prescribed Premises seeking renewal or amendment, as well as new Prescribed Premises.

• If there is insufficient space on any part of this form, please continue on a separate sheet of paper and attach to this form.

This is an application for: [select only one option] under Part V, Division 3 of the EP Act

Please see Guidance Statement: Decision Making for more information relating to the process for assessing and determining applications.

☑ Works Approval Concurrent Works Approval and Licence or Registration Licence

Existing registration number(s): [ ] Existing Works Approval number(s): [ ]

Renewal Existing Licence number: [ ]

Amendment Number of the existing Licence or Works Approval to be amended: [ ]

Registration (Works Approval already obtained) Existing Works Approval number(s): [ ]

Where clearing of native vegetation is required, has a clearing application already been submitted?

In accordance with the Guidance Statement: Decision Making, where clearing of native vegetation is of an exempt kind under the Environmental Protection (Clearing of Native Vegetation) Regulations 2004 or is being assessed by a relevant authority which would lead to an exemption under Schedule 6 of the EP Act, the clearing will not be reassessed by DWER or be subject to any additional controls by DWER.

If the proposed clearing action is to be assessed in accordance with, or under, an Environment Protection and Biodiversity Conservation Act (EPBC Act) accredited process, such as the assessment bilateral agreement, the Clearing Permit Application Form Annex C7 – Assessment bilateral agreement must be completed separately.

Yes – clearing application number: [ ] No – this application includes clearing

☑ N/A – clearing application not required. Explain why (e.g. no clearing required, or an exemption applies): The proposed Project site is largely cleared of vegetation as a result of vegetation clearing and disturbance from previous land uses. A small section of vegetation of less than 0.2 ha will be cleared for the purposes of constructing roadways, buildings and fences associated with the proposal. As the area expected to be cleared is less than 5 ha, is not riparian vegetation nor considered to be environmentally sensitive and will be cleared for the purposes of the construction roadways, buildings and fences associated with the proposal, an exemption is considered applicable.

This application is for the following categories of Prescribed Premises:

39 - Chemical or oil recycling 61 - Liquid waste facility 61A - Solid waste facility (specify all Prescribed Premises category numbers)

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

https://www.der.wa.gov.au/our-work/regulatory-framework



https://www.der.wa.gov.au/our-work/clearing-permits/46-clearing-permit-application-forms

https://www.der.wa.gov.au/our-work/clearing-permits/46-clearing-permit-application-forms

Department of Water and Environmental Regulation


☑ All activities that meet the definition of a Prescribed Premises as set out in Schedule 1 of the EP Regulations have been specified above (tick if Yes).

Completion Matrix The matrix below explains what sections are required to be completed for different types of applications.

Application Form Section New Application/ Registration Renewal Amendment

Part 1 Applicant details – section 1.1 ● ● ●

Part 1 Applicant details – section 1.2 onwards ● ● Δ

Part 2 Premises ● ● Δ

Part 3 Proposed activities ● ● ●

Part 4 Other approvals ● ● Δ

Part 5 Fit and competent operator ● ● N/A

Part 6 Emissions and waste ● ● Δ

Part 7 Siting and location ● ● N/A

Part 8 Submission of any other relevant information ● ● If required.

Part 9 Proposed fee calculation ● ● ●

Part 10 Submission of application ● ● ●

Acknowledgement and signature ● ● ●

Attachment 1A: Proof of occupier status ● ● N/A

Attachment 1B: ASIC company extract ● ● N/A

Attachment 2: Premises map/s ● ● Δ

Attachment 3A: Description of activities ● ● Δ

Attachment 3B: Map for proposed area to be cleared (only applicable if clearing is proposed)

● ● N/A

Attachment 4: Other approvals and consultation documentation

● ● Δ

Attachment 6A: Emissions and discharges If required. If required. If required.

Attachment 6B: Waste acceptance If required. If required. If required.

Attachment 7: Siting and location ● ● Δ

Attachment 8: Other relevant information If required. If required. If required.

Attachment 9: Proposed fee calculation ● ● ●

Attachment 10: Request for exemption from publication If required. If required. If required.

Key: ● Must be submitted Δ to the extent changed/required in relation to the amendment N/A Not required with application, but may be requested subsequently depending on DWER records “If required” Sections for applicants to determine.



Part 1. Applicant Details

INSTRUCTIONS: • The Applicant must be an individual(s), a company, body corporate, or public authority, but not a partnership, trust, or

joint-venture name. Applications made by or on behalf of business names or unincorporated associations will not be accepted.

• If applying as an individual, your full legal name must be inserted. • If applying as a company, body corporate, or public authority, the full legal entity name must be inserted. • Australian Company Number's (ACN) must be provided for all companies or body corporates. • Details for a contact person must be provided for DWER inquiries in relation to your application. This contact person

can be a consultant if authorised to represent the Applicant. • Companies or body corporates making an application must nominate an authorised representative from within their

organisation. If you are applying as an individual, you are the representative. • Details of the occupier of the Premises must be provided. One of the options must be selected and if you have been

asked to specify, please provide details. For example, if “Lease holder” has been selected, please specify the type of lease (for example, pastoral lease, mining lease or general lease) and provide a copy of the lease document(s). Note that contracts for sale of land will not be sufficient evidence of occupancy status.

1.1 Applicant name/s (full legal name/s): [the proposed holder of the works approval, licence or registration]

BMT Australia Pty Ltd

ACN (if applicable): ACN 614 363 647

1.2 Trading as (if applicable):

1.3 Authorised representative details: [the person authorised to receive correspondence and notices under the EP Act – all correspondence will be sent to this email address apart from statutory notices served under the EP Act (see below)]

Name

Position

Telephone

Email

1.4 Address for notices to be served under the EP Act: [this must be a physical address to which a notice under the EP Act may be hand delivered]

Level 3, 1060 Hay Street

West Perth WA 6000

1.5 Postal address for general correspondence: [if different from 1.4]

PO Box 1395

West Perth WA 6872



1.6 Contact person details for DWER inquiries relating to the application (if different from the authorised representative): [for example, could be a consultant or a site based employee]

Name

Position

Organisation (if different to Applicant)

Address (if different from above)

Telephone

Email

1.7 Occupier status: [Occupier is defined in section 3 of the EP Act and includes a person in occupation or control of the Premises.]

Registered proprietor on certificate of title

Lease holder (please specify, including date of expiry of lease) ☑

Lease is currently being finalised. The intended duration is 20 years.

Public authority that has care, control or management of the land

Other (please specify – for example, joint venture operating entity. Note: Contractual arrangements will need to be provided to evidence occupancy arrangements)

Attachments N/A Yes

1.8 Attachment 1A: Proof of occupier status

Copies of certificate of title, lease or other instruments evidencing proof of occupier status including the expiry date or confirmation that there is no expiry date have been provided and labelled as Attachment 1A.

Lease to be

provided once

issued.

1.9 Attachment 1B: ASIC current company information extract

A current company information extract purchased from the ASIC website(s) for all new applications/registrations has been provided and labelled as Attachment 1B.

☑



Part 2. Premises

2.1 Premises legal description (whole or part to be specified): [Land description: volume and folio number, lot or location number(s), Crown lease or reserve number, pastoral lease number or mining tenement number of all properties, as shown on title details registered with Landgate AND street address]

Part of Lot 101, Plan 73740

Cnr Burton Pl and Donaldson Rd

Kwinana Beach, WA

Premises name (if applicable):

2.2 Local Government Authority area: [City, Town or Shire]

City of Kwinana

2.3 GPS or map coordinates: [GPS coordinates (latitude and longitude) must be provided where cadastre or mining tenements are not used as the Premises boundary]

Approximate coordinates. To be confirmed when lease has been finalised. SW: 384957.26 mE, 6434109.56 mN NW: 384957.26 mE, 6434163.58 mN 384967.62 mE, 6434174.26 mN NE: 385030.73 mE, 6434174.26 mN SE: 385030.73 mE, 6434109.56 mN

Attachments N/A Yes

2.4 Attachment 2: Premises map/s

An aerial photograph, map and site plan of the Premises must be included as an attachment to this application form labelled Attachment 2. You must provide an aerial photograph of sufficient scale showing the Prescribed Premises. You must also provide a map or maps of the Prescribed Premises, identifying: • layout of key infrastructure and buildings, clearly labelled; • the Premises boundary; • emission and discharge points (with GPS coordinates where

available); • sensitive receptors and land uses; and • all areas proposed to be cleared (if applicable). Maps must contain a north arrow, clearly marking the area in which the activities are carried out. The map or maps must be of reasonable clarity and have a visible scale.

☑



Part 3. Activities (including clearing)

INSTRUCTIONS: • You must provide a description and the scope, size and scale of all prescribed activities of Schedule 1 to the EP

Regulations including the maximum production or design capacity of each prescribed activity. • If applying for a Works Approval or Licence amendment involving the construction of new infrastructure, you must

provide information on infrastructure to be constructed and how long construction is expected to take. You must confirm if commissioning is to occur and how long it will take.

• If applying for a Works Approval or Licence amendment not involving the construction of new infrastructure, provide details of the proposed amendment.

• You must identify all emission sources on the Premises map/s. • You must also provide information on activities which directly relate to the Prescribed Premises category which have,

or are likely to result in, an emission or discharge.

3.1 Description/overview:

Mercury is a naturally occurring element that is commonly found in the oil and gas industry. Removal of mercury from natural gas feedstocks is required to minimise exposure of personnel to mercury contaminated material and to prevent the corrosion of aluminium-based components within gas processing plants. Natural gas processing facilities typically utilise adsorption processes such as catalysts to remove mercury from the natural gas stream, resulting in the generation of mercury contaminated wastes. The majority of these by-products are currently kept in temporary storage or shipped to Europe for treatment.

BMT Australia Pty Ltd is proposing to build and operate a Mercury Treatment Plant (MTP) that will process a range of mercury contaminated wastes including sludges, catalysts and filters from liquefied natural gas (LNG) projects located within Western Australia. The process involves heating the contaminated material in electrical furnaces to ‘boil off’ the volatile contaminants, including Volatile Organic Compounds (VOCs), hydrogen sulphide (H2S) and mercury. A vacuum distillation unit will be utilised to condense vapours generated from the heating process and remove traces of mercury, VOCs and H2S that may be present in the retort off-gas.

Recovered mercury will be stabilised by reacting with sulphur to form mercury sulphide, known as cinnabar and will be stored in drums prior to transport to an approved long-term storage facility via a licensed controlled waste transport contractor.

The process design proposed for the Kwinana MTP replicates the existing mercury treatment plant that is operated by BMT in the Netherlands.

3.2 Estimated operating period of Premises (for example, based on estimated infrastructure life):

20 years

3.3 Proposed date/s for commencement of works (if applicable): Upon receipt of Works Approval

3.4 Proposed date/s for commissioning of works (if applicable): Q1 2018

3.5 Proposed date/s for commencement of operations (if applicable): End of Q2 2018

3.6 Maximum production or design capacity for each category applied for (based on infrastructure operating 24 hours a day, 7 days a week): [Refer to categories listed on page 1. Units must be consistent with Schedule 1 of the EP Regulations]

Cat 39 - 1,000 tpa Cat 61 - 1,000 tpa Cat 61A - 1,000 tpa

3.7 Estimated/actual throughput for each category applied for: [Refer to categories listed on page 1. Units must be consistent with Schedule 1 of the EP Regulations]

Cat 39 - 1,000 tpa Cat 61 - 1,000 tpa Cat 61A - 1,000 tpa

3.8 Proposed activities: You must provide details of proposed activities, identifying: • scope, size and scale, including details as to frequency and production or design capacity; • key infrastructure and equipment; • description of processes or operations (a process flow chart may be included as an attachment); • emission/discharge points; • locations of waste storage or disposal; and • activities occurring during construction, commissioning and operation (if applicable). Additional information relating to the proposed activities may be included in Attachment 3A (see 3.10 below).



The Kwinana MTP will be operated 24 hours a day, seven days a week and will process up to 1,000 tpa of mercury contaminated wastes from natural gas processing facilities within WA.

Infrastructure & Equipment

The Kwinana MTP will comprise a four-storey process building and single-level administrative and warehouse buildings, plus covered outside storage. The process building will house the mercury treatment plant, comprising the preparation area, retorts, cooling area, collection vessels and process gas emissions scrubber technology. The warehouse building will store the incoming waste prior to treatment plus any minor chemicals and equipment to support the operations in accordance with required regulations, standards and / or guidelines. The administrative building will house the control room, offices, laboratory and staff amenities. The covered outside storage will be used to store liquid nitrogen, residual waste products and activated carbon filters.

A layout of the proposed MTP is provided in the attached Works Approval Supporting Document (Attachment 3A).

Process Description

The incoming wastes, comprising sludges, catalysts and filters with a mercury content ranging from 0.5% to 1.5% by mass, will be packaged in accordance with dangerous goods transportation requirements and transported to the site by a licenced contractor. The packaged wastes will be offloaded from the delivery trucks within the BMT warehouse and any material containing free water and/or sludge will be stored in an appropriately bunded area.

Onsite analysis of incoming wastes will be undertaken to determine metal content, including the concentration of mercury. Pre-processing (e.g. shredding of filters and/or removal of water from sludges) may be required depending on the condition of the waste. Incoming product will be batch processed according to waste type (e.g. sludges, catalysts or filters).

The Kwinana MTP will have three banks, each comprising five retorts. The pre-processed waste will be fed into buckets via a loading arm, which in turn are manually loaded into the retorts via crane. The retorts will be heated via an electrical heating system to above the temperature required to break the mercury bonds with the waste material. The mercury is boiled-off and the gases are passed to the vacuum distillation unit.

The residue in the buckets is allowed to cool and will then be removed from the retorts. The waste will be analysed for compliance with the requirements of the relevant waste disposal contractor for contaminants such as mercury, other metals and VOC content. The buckets will be emptied to either a skip bin for collection by the relevant licensed disposal contractors or re-drummed for recycling at a metal recycler, depending on the residual characteristics.

The vacuum distillation unit will be utilised to condense vapours generated from the retorts and remove traces of mercury, VOCs and H2S that may be present in the retort off-gas. The retort off-gas will be drawn through a cyclone and approximately 80% of the mercury contained within the off-gas will be condensed, forming liquid mercury and a heavy ends fraction known as mercury butter. On completion of batch processing, the mercury is drawn off to a mercury vessel and the mercury butter is manually let off to a drum. Mercury butter is reprocessed in a subsequent batch. The uncondensed vapours from the cyclone are then cooled using cooling water resulting in further condensation. Condensed material is collected and drained to a collection vessel and then sent to a storage tank for later offsite disposal. The processed mercury will be stabilised by reacting with sulphur to form mercury sulphide, known as cinnabar. This naturally occurring form of mercury no longer gives off mercury vapour and hence is considered to be stabilised. The cinnabar powder will be stored in drums prior to transport to an approved long-term storage facility via a licensed controlled waste transport contractor.

Further details of the process are provided in the attached Works Approval Supporting Document (Attachment 3A).

Emission Points

Uncondensed vapours from the process are first passed through a series of activated carbon filters to remove residual contaminants, prior to release to atmosphere via the emission stack. The emissions control system will be fitted with two separate activated carbon filters to allow regular maintenance to be carried out, and to ensure the continuous availability of the emissions control system in the event of an equipment failure in one of the units. The grade of active carbon selected for use in the filters is specifically designed for H2S removal and the presence of sulphur aids in the removal of mercury vapour. The process building Heating, Ventilation and Air Conditioning (HVAC) system will also pass through activated carbon filters designed to remove fugitive atmospheric concentrations of mercury, VOCs and H2S that may be present inside the Process building. The HVAC system output will be combined with the residual contaminants prior to release to atmosphere via the emission stack.

Further details of the emission control system are provided in the attached Works Approval Supporting Document (Attachment 3A).

Waste Storage and Dispatch

The stabilised mercury will be stored in powder form in steel drums located in the warehouse building, prior to



offsite disposal at a suitable geological repository. Solid wastes including hydrocarbons, treated PPE and plastic drums will be collected by an approved waste contractor for disposal at a nominated Class III landfill, in accordance with the relevant landfill waste classifications. Treated active carbon will be collected by an approved hazardous waste contractor for offsite incineration. Treated spent catalyst will be sent to metal recyclers for recovery of valuable metals. If the catalyst is suitable for re-use, it may be returned to the originating company or the catalyst company. Water contaminated with soluble hydrocarbons from the treatment process will be stored in a tank located within the outside storage area for collection and disposal by a licensed waste contractor.

Attachments N/A Yes

3.9 Attachment 2: Premises map

Emission/discharge points are clearly labelled on the map/s required for Part 2.4 (Attachment 2). ☑

3.10 Attachment 3A: Proposed activities

Additional information relating to the proposed activities has been included in Attachment 3A (if required). ☑

Clearing Activities [3.11 to 3.16 are only required if the application includes clearing of native vegetation]

3.11 Proposed clearing area (hectares and/or number of individual trees to be removed):

3.12 Proposed method of clearing (or final land use):

3.13 Period within which clearing is proposed to be undertaken: [for example, May 2017 – June 2017]

3.14 Purpose of clearing:

Clearing Activities - Attachments N/A Yes

3.15 Attachment 3B: Map of area proposed to be cleared

You must provide an aerial photograph or map of sufficient scale showing the proposed clearing area and Premises boundary or if you have the facilities, a digital map on CDROM of the area to clear as an ESRI shapefile with the following properties: • Geometry type: Polygon Shape • Coordinate system: GDA 1994 (Geographic

latitude/longitude) Datum: GDA 1994 (Geocentric Datum of Australia 1994).

3.16 Attachment 3C: Additional information for clearing assessment

Additional information to assist in the assessment of the clearing proposal may be attached to this application (for example, reports on salinity, fauna or flora studies or other environmental reports conducted for the site).



Part 4. Other Approvals and Consultation

INSTRUCTIONS: • Please provide copies of all relevant documentation indicated below, including any conditions, exclusions, or expiry

dates. • Where planning approval is required, in accordance with the Guidance Statement: Land Use Planning, DWER’s formal

determination will only be made after the relevant planning decisions have been made. • Major Project means:

• A State Development Project, where the lead agency is the Department of Jobs, Tourism, Science and Innovation (including projects to which a State Agreement applies); or

• A Level 2 or 3 Major Resource Project, as defined by the Department of Mines, Industry Regulation and Safety.

N/A No Yes

4.1 Is the proposal a Major Project? ☑

4.2 Has the proposal been referred to the Environmental Protection Authority?

☑

4.3 Is the proposal subject to a Ministerial Statement(s) under the EP Act? ☑

If yes, please specify statement number(s):

4.4 Has the proposal been referred and/or assessed under the EPBC Act (Commonwealth)? ☑

If yes, please specify referral, assessment and/or approval number:

4.5 Has the proposal obtained all relevant planning approvals? ☑

If planning approval is not necessary, please provide details indicating why:

BMT are in the process of obtaining Planning Approval for the Kwinana MTP, pursuant to the City of Kwinana’s Town Planning Scheme No. 2.

4.6 For renewals or amendment applications, are the relevant planning approvals still valid (that is, not expired)? ☑

4.7 Has the proposal obtained all other necessary statutory approvals? ☑

If no, please provide details of approvals already obtained, outstanding approvals and expected dates for obtaining these outstanding approvals:

BMT will submit a Planning Application to the City of Kwinana by end of September 2017. The assessment of this application is expected to be concurrent with this Works Approval application.

After receipt of the planning approval, BMT will obtain a Building Licence from the City of Kwinana prior to commencement of any construction.

BMT will obtain a Dangerous Goods Site Licence for the storage of mercury, mercury containing compounds and residual materials contaminated with hydrocarbons prior to the commencement of storage of dangerous goods onsite, anticipated in early 2018.

N/A No Yes

4.8 Has consultation been undertaken with parties considered to have a direct interest in the proposal (that is, interested parties or persons who are considered to be directly affected by the proposal)? DWER will give consideration to submissions from interested parties or persons in accordance with the Guidance Statement: Decision Making.

☑

Attachments N/A Yes




Application Form: Works Approval, Licence, Renewal, Amendment or Registration (July 2017 v7)10 IR-F09 v7.0

4.9 Attachment 4: Other approvals and consultation documentation

Details of other approvals specified in Part 4 of this application, including copies of relevant decisions and any consultation undertaken with direct interest stakeholders have been provided and labelled Attachment 4.

☑

Part 5. Fit and Competent Operator

Note: • Under this section, DWER will undertake an internal due diligence of the Applicant’s fitness and competency based

on DWER’s compliance records. • If you wish to provide additional information for DWER to consider in making this assessment, you may provide that

information as a separate attachment. N/A No Yes

5.1 If the Applicant is an individual, has the Applicant ever held a Licence or Works Approval under Part V of the EP Act?

☑

5.2 If the Applicant is a corporation, has any director of that corporation ever held a Licence or Works Approval under Part V of the EP Act?

☑

5.3 If yes to 5.1 or 5.2 above, specify the name of company and/or Licence or Works Approval number:

5.4 If the Applicant is an individual, has the Applicant ever been convicted, or paid a penalty, for an offence under a provision of the EP Act, its subsidiary legislation or similar environmental protection legislation in Australia?

☑

5.5 If the Applicant is a corporation, has any director of that corporation ever been convicted, or paid a penalty, for an offence under a provision of the EP Act, its subsidiary legislation or similar environmental protection legislation in Australia?

☑

5.6 If the Applicant is a corporation, has any person concerned in the management of the corporation, as referred to in section 118 of the EP Act, ever been convicted of, or paid a penalty, for an offence under a provision of the EP Act, its subsidiary legislation or similar environmental protection legislation in Australia?

☑

5.7 If the Applicant is a corporation, has any director of that corporation ever been a director of another corporation that has been convicted, or paid a penalty, for an offence under a provision of the EP Act, its subsidiary legislation or similar environmental protection legislation in Australia?

☑

5.8 Has the Applicant had a licence or other authority suspended or revoked due to a breach of conditions or an offence under the EP Act or similar environmental protection legislation in Australia?

☑

5.9 If the Applicant is a corporation, has any director of that corporation ever had a licence or other authority suspended or revoked due to a breach of conditions or an offence under the EP Act or similar environmental protection legislation in Australia?

☑

5.10 If the Applicant is a corporation, has any director of that corporation ever been a director of another corporation that has ever had a licence or other authority suspended or revoked due to a breach of conditions or an offence under the EP Act or similar environmental protection legislation in Australia?

☑

5.11 If Yes to any of 5.3 - 5.9 above, you must provide details of any convictions, penalties paid for an offence or licences or other authorisation suspended or revoked:



Part 6. Emissions and Waste

INSTRUCTIONS: • Please see Guidance Statement: Risk Assessments and provide all information relating to emission sources,

pathways and receptors relevant to the application. • You must provide details on sources of emissions (for example, kiln stack, baghouses or discharge pipelines)

including fugitive emissions (for example, noise, dust or odour), types of emissions (physical, chemical, or biological), and volumes, concentrations and durations of emissions.

• The potential for emissions should be considered for all stages of the proposal (where relevant), including during construction, commissioning and operation of the Premises.

No Yes

6.1 Are there potential emissions arising from the proposed activities? ☑

If yes, identify all potential emissions arising from the proposed activities and complete the Emission Table below.

☑ Gaseous and particulate emissions (e.g. emissions from stacks, chimneys or baghouses)

Dust (e.g. from equipment, unsealed roads and/or stockpiles)

☑ Wastewater discharges (e.g. treated sewage, wash water, or process water discharged to lands or waters)

☑ Waste and leachate (e.g. emissions through seepage, leaks and spills of waste from storage, process and handling areas)

Noise (e.g. from machinery operations and/or vehicle operations)

Odour (e.g. from wastes accepted at putrescible landfills)

☑ Contaminated or potentially contaminated stormwater (e.g. stormwater with the potential to come into contact with chemicals or waste materials)

Electromagnetic radiation*

Other (please specify) [ ]

*For electromagnetic radiation, copies/details of other relevant approvals (such as from the Department of Mines, Industry Regulation and Safety or the Radiological Council) must be provided where applicable.

Details of any pollution control equipment or waste treatment system including control mechanism to ensure proper operation of this equipment must be included in the proposed controls column of the Emissions and Discharges Table below. Details of management measures employed to control emissions should also be included.

Additional rows may be added as required and/or further information may be included as an attachment (see 6.3).

Emissions and Discharges Table:

Source of emission or discharge

Emission or discharge type

Volume and frequency

Proposed controls

Location (on site layout plan -see 3.7)




Uncondensed vapours from the process are first passed through a series of activated carbon filters to remove residual contaminants, prior to release to atmosphere via the emission stack.

Gaseous emissions

The proposed MTP will be operated 24 hours a day, 7 days a week. The contaminated material is treated in batches with staggered starting times resulting in near continuous flow of emissions. Emissions from the proposed MTP may contain traces of mercury, hydrogen sulphide (H2S) and VOCs. The estimated concentrations of these compounds in the exhaust gas are: Mercury = 0.002 ppm H2S = 1.0 ppm Benzene (as an indicator for VOCs) = 1.0 ppm

The proposed MTP will be fitted with an emissions control system comprising activated carbon filters. The grade of active carbon selected for use in the filters is specifically designed for H2S removal and the presence of sulphur aids in the removal of mercury vapour. During operations, continuous H2S monitoring upstream of the final activated carbon filter will be used as an indicator of performance for the emission control system, and will act as an early warning system to prevent contaminant ‘break-through’ of the activated carbon filter system. Failsafe mechanisms will also be put in place that prevent the process from operating without the emissions control system.

The emission stack is located on top of the eastern side of the Process Building.

During operations, sewerage from non-process areas (e.g. toilets, kitchen and showers) will go to a City of Kwinana approved onsite effluent treatment system.

Treated sewage

Emissions from the wastewater treatment system are expected to be minimal based on the small number of personnel on site.

Laundry water will be captured in a tank and tested for contamination prior to discharge to the sewerage system. In the unlikely event that testing indicates the laundry waste water is contaminated, it will be recycled into the process.

Adjacent to the eastern side of the Administrative Building



During operations the primary sources of potential surface water and groundwater impacts are related to the handling of chemicals agents and waste products and the potential contamination of stormwater runoff.

Potentially contaminated stormwater

NA

A Spill Response Plan will be implemented to deal with spillages and leaks. The plan will include details on methods of containment, collection and disposal and training of personnel. Recovery procedures for chemical spillages will be developed and implemented. The process building and warehouse will have impermeable floors and be designed so that liquids cannot leave the buildings. Collection sumps will allow for the collection of any spilled material or firefighting water and will be tested for contamination prior to either offsite disposal or return to the process for treatment. Tanks outside the building will be surrounded by bunds designed to contain a quantity of liquid to the volume of the largest container plus 10% with a sufficient bund wall height to capture jetted liquid ejected from a split tank and will be covered to minimise the ingress of stormwater.

NA



Incorrect storage and disposal of waste and hazardous materials have the potential to result in contamination of groundwater, surface water and/or soil, impacts to flora and fauna, poor visual amenity and offensive odours and health and safety issues.

Waste and leachate NA

All hazardous materials will be handled in accordance with the requirements of the Dangerous Goods Safety Act 2004 and its subsidiary regulations. Hazardous liquids will be collected and removed from site for recycling or disposal in an approved liquids disposal area. The site storage area will be suitably bunded and of an impervious nature to prevent soil and groundwater contamination in the event of accidental spillage. Inert wastes generated during construction and operation that are not suitable for recycling will be disposed of at a suitably classed landfill in accordance with the Health Department and DWER requirements.

NA

No Yes

6.2 Is there waste accepted, buried, stored or recycled on the Premises? (includes leachate and contaminated stormwater generated and stored on the Premises)

☑

Solid waste types must be described with reference to Landfill Waste Classification and Waste Definitions 1996 (as amended December 2009) and the Environmental Protection (Controlled Waste) Regulations 2004. Liquid waste types must be described with reference to the Environmental Protection (Controlled Waste) Regulations 2004. Detail must be provided on storage type (for example, hardstand and containment infrastructure), capacity, likely storage volumes and containment features (for example, lining and bunding).

Additional rows may be added as required and/or further information may be included as an attachment (see 6.3).

Waste Acceptance Table:



Waste type Quantity (e.g. tonnes, litres, cubic metres)

Storage infrastructure (including specifications)

Monitoring (if applicable)

Location (on site layout plan – see 3.7)

Inorganic Chemicals 1,000 tpa

Waste will be packaged and transported to site in accordance with dangerous goods transportation requirements. The packages will be offloaded from the trucks within the BMT warehouse in areas that are compliant with the requirements of the Dangerous Goods Safety Act 2004 and applicable regulations. Any material containing free water and/or sludge will be stored in an appropriately bunded area. Stabilised mercury will be stored in powder form in steel drums located in the warehouse building, prior to offsite disposal at a suitable geological repository

NA Warehouse

Soils and Sludge 1,000 tpa

Waste will be packaged and transported to site in accordance with dangerous goods transportation requirements. The packages will be offloaded from the trucks within the BMT warehouse in areas that are compliant with the requirements of the Dangerous Goods Safety Act 2004 and applicable regulations. Any material containing free water and/or sludge will be stored in an appropriately bunded area.

NA Warehouse



Attachments N/A Yes

6.3 Attachment 6A: Emissions and discharges (if required)

If required, further information for Part 6.1 has been included as an attachment labelled Attachment 6A. ☑

6.4 Attachment 6B: Waste acceptance (if required)

If required, further information for Part 6.2 has been included as an attachment labelled Attachment 6B. ☑

Part 7. Siting and Location

7.1 What is the distance to the nearest sensitive land uses (that is, a residence or other land use which may be affected by an emission or discharge associated with the proposed activities):

The nearest residence is located in Medina in the City of Kwinana, approximately 2 km southeast of the proposed Project site.

No Yes

7.2 Are the Premises located within, or within close proximity to, any Specified Ecosystems? (See Guidance Statement: Environmental Siting)

☑

If no, identify the distance in which there are no Specified Ecosystems. If yes, provide details of the Specified Ecosystems and the distance to these:

The distance and direction of the nearest Specified Ecosystems to the proposed Project site are:

• Sloanes Reserve Nature Reserve, 3.5 km south east; • Bush Forever Site 349 (associated with Leda Swamp), 5.3 km southeast; • Long Swamp Swan Coastal Plain Wetland, 3.2 km northeast; and • Cockburn Sound Policy Boundary, 2 km west.

7.3 If yes to 7.2, you must also provide further information including details on topography, geology, soil type, depth to groundwater and quality of groundwater at the Premises. For Premises answering no to 7.2, additional information including topography, geology, soil type, groundwater depth and water quality is recommended to be included if this information is available.

The site and immediate surrounds are relatively flat, with terrain heights of no more than 10 m above sea level within an approximate one kilometre radius. There is a ridge of elevated terrain that lies approximately 4 km to the east of the site that increases to over 30 m above sea level. The Residue Disposal Areas (RDAs) located approximately 4 km to the north east of the site form the highest landscape feature in the area, reaching to 60 m above sea level. The surface geology of the site is characterised by Safety Bay Sands which are part of the Quindalup Dune System. Safety Bay Sands are mostly unconsolidated Aeolian calcareous dune sands which are high in lime, but low in soluble salts. The Safety Bay Sand unconformably overlies the Tamala Limestone which is generally a calcareous cemented sand of varying degrees of cementation, often with a surface kankar and is generally of Aeolian origin. The Perth Groundwater Atlas indicates depth to groundwater at the site ranges between 6.0 m to 7.0 m. Groundwater flow is inferred to be westwards towards the ocean. The site is within the Jandakot Mound Area and the groundwater in the area typically ranges in salinity from 500 mg/L to 1,000 mg/L Total Dissolved Solids (TDS).

Attachments N/A Yes

7.4 Attachment 7: Siting and location

You must provide details and a map describing the siting and location of the Premises, including identification of distances to sensitive land uses and/or any Specified Ecosystems.

☑




Part 8. Submission of Any Other Relevant Information

Attachments No Yes

8.1 Attachment 8: Additional information submitted

Applicants seeking to submit further information may include information in Attachment 8. Where supplementary documentation is submitted, please specify the name of documents below.

☑

List title of supplementary document/s attached: AS110873 BMT Australia Kwinana Mercury Treatment Plant WAA_Final_170726.pdf

Part 9. Proposed Fee Calculation

INSTRUCTIONS: Fee calculators are available online to assist in completing this section.

• Licence: www.der.wa.gov.au/LicenceFeeCalculator • Works approval: www.der.wa.gov.au/WorksApprovalFeeCalculator • Amendment:: www.der.wa.gov.au/AmendmentFeeCalculator

Different Fee Units apply for different fee components. Fee Units may also have different amounts depending on the period in which the calculation is made.

9.1 Only the relevant fee calculations are to be completed as follows: [tick to indicate sections completed - for concurrent applications, each relevant fee section is to be completed]

☑ Section 9.3 for Works Approval Applications Section 9.4 for Licence Applications Section 9.5 for Registration Applications Section 9.6 for Amendment Applications Section 9.7 for applications requiring clearing

of native vegetation

9.2 All information and data used for the calculation of proposed fees has been provided in section 9.8

9.3 Proposed Works Approval fee

Proposed Works Approval fee (see Schedule 3 of the Environmental Protection Regulations 1987) Fees relate to the cost of the works, including all capital costs (inclusive of GST) associated with the construction and establishment of the works proposed under the Works Approval application. This includes, for example, costs associated with earth works, hard stands, drainage, plant hire, equipment, processing plant, relocation of equipment and labour hire.

Costs exclude: - the cost of land; - the cost of buildings to be used for purposes unrelated to the purposes in respect of which the Premises are,

or will become, Prescribed Premises; costs for buildings unrelated to the Prescribed Premises activity or activities; and

- consultancy fees relating to the works.

Fee component Proposed fee

Cost of works:

http://www.der.wa.gov.au/LicenceFeeCalculator

http://www.der.wa.gov.au/WorksApprovalFeeCalculator

http://www.der.wa.gov.au/AmendmentFeeCalculator



9.4 Proposed Licence Fee

Detailed licence fee calculations

Part 1 Premises component (see Part 1 of Schedule 4 of the Environmental Protection Regulations 1987) The production or design capacity should be the maximum capacity of the Premises. For most categories the production or design capacity refers to an annual rate. The figure should be based on 24 hour operation for 365 days, unless there is another regulatory approval or technical reason that restricts operation. The Premises component fee applies to the category incurring the highest fee unit number in accordance with regulation 5D(2) of the EP Regulations. Insert additional rows as required.

Category Production or design capacity Fee units

Sub total $

Part 2 Waste (see Part 2 of Schedule 4 of the Environmental Protection Regulations 1987) If your Premises includes one or more of the following categories specify any applicable Part 2 waste amounts. Do not include Part 3 waste components of these discharges in the below sections. Categories: 5, 6, 7, 8, 9, 12, 14, 44, 46, 53, 54A, 70, 80 or 85B Part 2 waste means waste consisting of –

(a) tailings; or (b) bitterns; or (c) water to allow mining of ore; or (d) flyash; or (e) waste water from a desalination plant.

If your Premises does not fall into one of the categories listed above, or there are no applicable Part 2 waste amounts, the sub total for this section will be $0. Insert additional rows as required.

Discharge quantity (tonnes/year) Fee units

Sub total $

Part 3 Waste - Discharges to air, onto land, into waters (see Part 3 of Schedule 4 of the Environmental Protection Regulations 1987) Choose the appropriate location of the discharge and enter the discharge amount(s) in the units specified in the EP Regulations. This should be the amount of waste expected to be discharged over the next 12 months, expressed in the units and averaging period applicable for that waste kind (for example, g/minute or kg/day). Amounts can be measured, calculated, or estimated and can be based on data acquired over the previous 12 months, but should be based on the maximum Premises capacity and not the forecast operating hours. Where there are discharges, all prescribed waste types must be considered in the fee calculation. If a specified waste type is not present in the discharge, this must be justified using an appropriate emission estimation technique (for example, sampling data, industry sector guidance notes, National Pollution Inventory guides and emission factors).



Discharges to air

Discharges to air Discharge quantity (g/min) Discharges to air Discharge rate

(g/min)

Carbon monoxide Nickel

Oxides of nitrogen Vanadium

Sulphur oxides Zinc

Particulates (Total PM) Vinyl chloride

Volatile organic compounds Hydrogen sulphide

Inorganic fluoride Benzene

Pesticides Carbon oxysulphide

Aluminium Carbon disulphide

Arsenic Acrylates

Chromium Beryllium

Cobalt Cadmium

Copper Mercury

Lead TDI (toluene-2, 4-di-iso-cyanate)

Manganese MDI (diphenyl-methane di-iso-cyanate)

Molybdenum Other waste

Subtotal $

Discharges onto land or into waters Discharge quantity

1. Liquid waste that can potentially deprive receiving waters of oxygen (for each kilogram discharged per day) —

(a) biochemical oxygen demand (in the absence of chemical oxygen demand limit)

(b) chemical oxygen demand (in the absence of total organic carbon limit)

(c) total organic carbon

2. Biostimulants (for each kilogram discharged per day) —

(a) phosphorus

(b) total nitrogen

3. Liquid waste that physically alters the characteristics of naturally occurring waters —

(a) total suspended solids (for each kilogram discharged per day)

(b) surfactants (for each kilogram discharged per day)

(c) colour alteration (for each platinum cobalt unit of colour above the ambient colour of the waters in each megalitre discharged per day)

(d) temperature alteration (for each 1°C above the ambient temperature of the waters in each megalitre discharged per day) —

(i) in the sea south of the Tropic of Capricorn

(ii) in other waters



4. Waste that can potentially accumulate in the environment or living tissue (for each kilogram discharged per day) —

(a) aluminium

(b) arsenic

(c) cadmium

(d) chromium

(e) cobalt

(f) copper

(g) lead

(h) mercury

(i) molybdenum

(j) nickel

(k) vanadium

(l) zinc

(m) pesticides

(n) fish tainting wastes

(o) manganese

5. E coli bacteria as indicator species (in each megalitre discharged per day) —

(a) 1,000 to 5,000 organisms per 100 ml

(b) 5,000 to 20,000 organisms per 100 ml

(c) more than 20,000 organisms per 100 ml

6. Other waste (per kilogram discharged per day) —

(a) oil and grease

(b) total dissolved solids

(c) fluoride

(d) iron

(e) total residual chlorine

(f) other

Subtotal $

Summary – Proposed licence fee

Part 1 Component

Part 2 Component

Part 3 Component

Total proposed licence fees: $



9.5 Prescribed Fee for Registration

A fee of 24 units applies for an application for registration of Premises, unless the occupier of the Premises holds a licence in respect of the Premises in accordance with section 5B2(c) of the Environmental Protection Regulations 1987.

☑ (Tick to acknowledge)

9.6 Works Approval or Licence Amendment Fee

Proposed Works Approval and Licence Amendment fee (see Schedule 4 Part 1 of the Environmental Protection Regulations 1987 (the Regulations)) The fee prescribed for an application for an amendment to a Works Approval or Licence is based on a unit value for 2016–2017 of $3.40 per unit, calculated (in accordance with regulation 5BB of the Regulations):

• for a single category of Prescribed Premises to which the Works Approval or Licence relates, by using the fee unit number corresponding to the Prescribed Premises category and relevant production or design capacity threshold in Schedule 4 Part 1 of the Regulations.

• for multiple categories of Prescribed Premises to which the Works Approval or Licence relates, by using the highest fee unit number corresponding to the Prescribed Premises categories and production design or capacity threshold in Schedule 4 Part 1 of the Regulations.

The relevant fee unit under Schedule 4 Part 1 of the Regulations for calculating the application form amendment fee is to be determined by reference to the actual production or design capacity reported for the preceding year’s annual licence fee. If an annual licence fee has not previously been paid or is not applicable as is the case for works approvals, the fee unit for an application for amendment is to be determined by reference to the production or design capacity currently prescribed in the Licence or Works Approval.

Fee Units Proposed fee

$

9.7 Prescribed Fee for Clearing Permit

In accordance with the Guidance Statement: Decision Making , where a concurrent application for clearing of native vegetation is made, DWER may elect to either jointly or separately determine the clearing component of the application. Where DWER separately determines the clearing component of a concurrent application, the application will be deemed to be an application for a clearing permit under section 51E of the EP Act and the CEO will waive the payment of the fee prescribed for an application for clearing permit. Note: If a clearing permit application has been separately submitted and accepted by DWER, a refund for the clearing permit application will not be provided where DWER determines to address clearing requirements as part of a related works approval application.

(Tick to acknowledge)

9.8 Information and Data Used to Calculate Proposed Fees

The detailed calculations of fee components, including all Information and data used for the calculations are to be provided as attachments to this application. Please specify the relevant attachment number in the space/s provided below.

Proposed fee for works approval Attachment No

Details for cost of works

Proposed fee for licence Attachment No

Part 1: Premises

Part 2: Waste types

Part 3: Discharges to air, onto land, into waters




Part 10. Submission of Application NOTE: Information submitted as part of this application may be made publicly available. If you wish to submit information that you believe to be commercially sensitive or otherwise confidential, then you should submit that information in an attachment to this application labelled Attachment 10 with a written statement of reasons why you request that each item of information be kept confidential. DWER will take reasonable steps to protect genuinely confidential or commercially sensitive information. Please note in particular that all submitted information may be the subject of an application for release under the Freedom of Information Act 1992. All information which you would propose to be exempt from public disclosure has been separately placed in Attachment 10 (located at the end of this form). Grounds for claiming exemption in accordance with Schedule 1 to the Freedom of Information Act 1992 must be specified.

A full, signed electronic copy has been submitted via: [email protected] ☑

OR A full hard copy has been sent to: APPLICATION SUBMISSIONS Department of Water and Environmental Regulation Locked Bag 33 Cloisters Square PERTH WA 6850

mailto:[email protected]



ATTACHMENT 10 - Confidential or Commercially Sensitive Information

Request for Exemption from Publication

Information which you consider should not be published on the grounds for claiming exemption in accordance with Schedule 1 to the Freedom of Information Act 1992 must be specified in this Attachment.

NOT FOR PUBLICATION IF GROUNDS FOR EXEMPTION ARE DETERMINED

Section [x]:

Ground for claiming exemption:

Section [x]:

Ground for claiming exemption:

Documents

Application form: Works Approval / Licence / Renewal ... Form: Works Approval, Licence, Renewal, Amendment or Registration (July 2017 v7) 1 IR-F09 v7.0 Application form: Works Approval