Environmental Protection Act 1986 - der.wa.gov.au€¦ · Part 9 Proposed fee calculation Application form ... (for example, pastoral lease, mining lease or general lease) and provide

A: Suite 2, Level 10, 151 Castlereagh Street, Sydney, NSW, 2000 T: +61 2 8257 3395 | F: +61 2 8233 6199 | E: [email protected] W: Tellusholdings.com.au | ABN: 97 138 119 829

Our ref: TSR-3-PO-02200-AP-REP-0001

Department of Water and Environmental Regulation

30 August 2017

, Sandy Ridge Facility Works Approval and Licence Application Tellus Holdings Ltd is proposing to develop the Sandy Ridge Facility in the Goldfields region of Western Australia. The proposal is currently being assessed under Part IV of the Environmental Protection Act 1986 (Assessment No. 2057) (EP Act) as a Public Environmental Review.

In order to streamline the environmental impact assessment and regulation of the Sandy Ridge Facility under Part V of the EP Act, Tellus is submitting this works approval and licence application to be parallel-processed by the Department of Water and Environmental Regulation.

The application consists of:

• Cover letter (this letter) containing an Application Index and Request for Exemption from Publication.

• Application Form – Works Approval / Licence • Sandy Ridge Works Approval and Licence Application Supporting Document.

If you have any questions or require further information about the Sandy Ridge Facility proposal, please do not hesitate to contact me on:

Sandy Ridge Facility Works Approval and Licence Application Cover letter

Tellusholdings.com.au |

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Table 1. Sandy Ridge Works Approval and Licence Application Index.

Sandy Ridge Works Approval and Licence Application Index Based on the Completion Matrix.

Application Form Section New Application/ Registration

Location in Sandy Ridge Application

Part 1 Applicant details – section 1.1 ● Application form

Part 1 Applicant details – section 1.2 onwards ● Application form

Part 2 Premises ● Application form

Part 3 Proposed activities ● Application form

Part 4 Other approvals ● Application form

Part 5 Fit and competent operator ● Application form

Part 6 Emissions and waste ● Application form

Part 7 Siting and location ● Application form

Part 8 Submission of any other relevant information ● Application form

Part 9 Proposed fee calculation ● Application form

Part 10 Submission of application ● Application form

Acknowledgement and signature ● Application form

Attachment 1A: Proof of occupier status ● Section 1.1.1 and Appendix

1A of Application Supporting Document

Attachment 1B: ASIC company extract ● Appendix 1B of Application Supporting Document

Attachment 2: Premises map/s ● Application Supporting

Document Figure 1-1, Figure 1-3 and Figure 1-5

Attachment 3A: Description of activities ● Application Supporting Document (throughout)

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

● Not applicable

Attachment 4: Other approvals and consultation documentation

● Section 1.1.1 Application Supporting Document

Attachment 6A: Emissions and discharges If required. Section 3 Application Supporting Document

Attachment 6B: Waste acceptance If required. Appendix 2 and Section

2.2.2 Application Supporting Document

Attachment 7: Siting and location ● Figure 1-1 Application Supporting Document

Attachment 8: Other relevant information

If required. Cover letter

Sandy Ridge Works Approval and Licence

Application Supporting Document

Attachment 9: Proposed fee calculation ● Appendix 5 Application

Supporting Document - CONFIDENTIAL

Attachment 10: Request for exemption from publication If required. Sandy Ridge application coverletter

Sandy Ridge Facility Works Approval and Licence Application Cover letter

Tellusholdings.com.au |

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Table 2. Request for Exemption from Publication (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]: Appendix 5 of the Application Supporting Document and Part 9.3 of this form

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 Sandy Ridge Project is currently being assessed under Part IV of the Environmental Protection Act 1986. Upon issue of a Ministerial Statement, it will be exempt from the requirement for further native vegetation clearing approval.

This application is for the following categories of Prescribed Premises:

[12,61,64,65,66,85] (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



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]

ACN (if applicable):

1.2 Trading as (if applicable): N/A

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]

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

As above

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: Registered proprietor on certificate of title



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

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

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)

Tellus holds a Section 91 licence (Lic 00276/2015_A6498996, expiry 17 August 2018) under the Land Administration Act 1997 to access the area of land over which the Sandy Ridge Facility is proposed. The Section 91 licence allows Tellus to conduct surveys, investigations and related activities while an application for a crown lease is being progressed. In addition Tellus currently holds exploration tenement E16/440 under the Mining Act 1972 and has submitted a mining lease application over the proposed Sandy Ridge Facility development area. As discussed with DWER, Tellus understands that the works approval application can be assessed by DWER while land tenure is being progressed by the Department of Planning, Lands and Heritage. Further, Tellus acknowledges that the works approval cannot be granted until after the proposal has been approved under Part IV of the Environmental Protection Act 1986.

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.

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]

Crown Land. Proposed development envelope (prescribed premises boundary) is formed by the combination of:

Mining Lease M16/540,

G16/21 (granted)

L16/121 (pending), and

L16/119 (pending).

Premises name (if applicable): Sandy Ridge Facility

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

Shire of Coolgardie and Shire of Yilgarn

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]

N/A, see part 2.1

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:

Tellus Holdings Ltd (Tellus) propose to develop an open-cut kaolin mine and complementary hazardous and intractable waste storage facility with supporting above ground infrastructure. The storage facility would provide for the safe and secure storage and permanent isolation of up to 100,000 tpa of incoming waste. The open cut kaolin mine and complementary storage facility is referred to as the ‘Sandy Ridge Facility’.

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

25 years (estimated from December 2017 to December 2042)

3.3 Proposed date/s for commencement of works (if applicable): Estimated start date for construction – December 2017

3.4 Proposed date/s for commissioning of works (if applicable): Refer to Section 4 of Application Supporting Document. Category 85: December 2017 Category 65&66: March 2018 Category 64: April 2018 Category 12: April 2018 Category 61: November 2018

3.5 Proposed date/s for commencement of operations (if applicable): December 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]

Refer to Table 1-1 of Application Supporting Document. 12 – 876,000 tonnes per year 61 – 110,376 tonnes per year 64 – 500 tonnes per year (limited by waste generated at site) 65 and 66 – combined 280,000 tonnes per year (limited by 100,000 tonnes per year accepted at the facility) 85 – 50 m3 per day

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]

Refer to Table 1-1 of Application Supporting Document. 12 – 220,000 tonnes per year 61 – 40,000 tonnes per year 64 – 500 tonnes per year 65 and 66– combined 280,000 tonnes per year 85 - 50 m3 per day

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).

Refer to Application Supporting Document

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): Pending (Assessment Number 2057)

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: Bilateral Assessment with above

4.5 Has the proposal obtained all relevant planning approvals?

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

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:

Refer to Table 1-3 of Application Supporting Document

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

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.




Application Form: Works Approval, Licence, Renewal, Amendment or Registration (July 2017 v7) 10

IR-F09 v7.0

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:



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The Tellus Board of Directors is highly experienced in the waste, utility and infrastructure sectors and hold or have held previously directorships in many of Australia’s largest corporations. Examples of the entities that Tellus directors are also directors of or have previously been directors of include:

• Downer Group – one of Australia’s largest diversified engineering and construction companies, with approximately 19,000 employees and a market capitalization > $3 billion. Further information available at www.downergroup.com.

• Energy Queensland – the entity formed from the combined of Ergon and Energex, the government owned electricity distribution and retail businesses in Queensland, incorporating >$24 billion worth of assets across 1.7 million square kilometres of geographic area, 205,000 km of electricity network (overhead and underground) and approx. 7,000 employees. Further information is available on www.energyq.com.au

• Networks NSW – incorporating Ausgrid, Endeavour Energy and Essential Energy, including 283,000 km of electricity network and 13,000 employees.

• DUET Group – the energy infrastructure group holding interests in entities such as United Energy (electricity distribution network covers 1,472km² of south-east Melbourne and the Mornington Peninsula), Multinet Gas (a Victorian gas distribution company with a network covering 1,860km² of the eastern and south-eastern suburbs of Melbourne), Dampier to Bunbury Pipeline, etc.

• Charter Hall – One of Australia’s leading property groups with a total managed property portfolio of $19 billion which covers 213 commercial properties around Australia.

• WSN Environmental Solutions – former NSW government owned waste business.

• Cleanaway – the large Australian waste management business

With respect to questions 5.7 and 5.10. Tellus is not aware of specific instances of any breaches or convictions for such corporations, however given the corporations in some instances have very long corporate lives (ie Ausgrid has been operating for more than 100 years), and manage very large projects involving significant and diversified licences and approvals, Tellus expects that at some stage in some part of their corporate lives, there will be instances of the matters referred to in questions 5.7 and 5.10.

http://www.downergroup.com/

http://www.energyq.com.au/



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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) [ ]




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*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)

Screening plant dust unknown Mist sprays Various through construction and operations

Wastewater treatment plant irrigation areas

Treated wastewater

Up to 50 m3 per day

Effluent treatment, double-walled discharge pipe, fencing, signage, inspections

Refer Figure 1-3 in Application Supporting Document.

Mobile equipment and plant Noise unknown

Plant and equipment to meet Australian Standards

Throughout

Infrastructure Area

Contaminated stormwater unknown

Asphalt sealed, concrete active waste handling areas, self-bunded shipping containers, procedures.

Refer Figures 1-3, 1-6 and 3-1 in Application Supporting Document

Class II landfill Odour unknown

Construction and operation in accordance with Rural Landfill Regulations

Refer Figure 1-3 in Application Supporting Document

LLW, NORM wastes

electromagnetic radiation

Refer to section 2.2 Application Supporting Document

Refer to section 2.2 Application Supporting Document




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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)

Putrescible waste

500 tonnes per year N/A N/A


Intractable and other wastes in accordance with the approvals for the site

Up to 280,000 tonnes per year

Extensive geological kaolin deposit - Refer Application Supporting Document

Refer section 3 Application Supporting Document


Contaminated solid waste meeting criteria specified for Class IV landfills

With previous See previous See previous See previous

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



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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):

Residences The nearest sensitive receptor is the Mount Walton Intractable Waste Disposal Facility (IWDF), which is located approximately 5.5 km east of the proposed development envelope of the Sandy Ridge Facility. Mount Walton IWDF operates infrequently on a campaign style basis during day time operating hours, with the most recent operation being conducted in 2008. There are permanent camp facilities to accommodate five personnel, however, no permanent workforce is located at the Mount Walton IWDF. Given the distance from the proposed development envelope to the camp facilities at the Mount Walton IWDF, the infrequent operations at the Mount Walton IWDF, similar operating hours (during a campaign) to the Sandy Ridge Facility (i.e. day time) and the low numbers of temporary workers, noise and odour impacts are highly unlikely to impact people at the Mount Walton IWDF. The next nearest sensitive receptor to the proposed development envelope of the Sandy Ridge Facility are tourists residing at the Jaurdi Homestead (approximately 51 km away), the Carina Iron Ore Village (approximately 52 km away), and Koolyanobbing (approximately 75 km away). Conservation reserves There are several lands managed by the Department of Biodiviersity, Conservation and Attractions (DBCA) located within the vicinity of the proposed development envelope of the Sandy Ridge Facility. These are: - Mount Manning Range Nature Reserve,

located approximately 9.8 km to the north-west.

- Mount Manning – Helena and Aurora Ranges Conservation Park, located approximately 19.8 km to the west.

- Boorabbin National Park, located approximately 100 km to the south.

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:

DBCA managed lands – the closest is Mount Manning Range Nature Reserve, located approximately 9.8 km to the north-west. TEC/PEC – closest is Finnerty Range / Mt Dimer /Yendilberin Hills BIF, approximately 12.5 km to the south 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.




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FOR INFORMATION ONLY Please refer to the following: - Section 9.2 and Section 10.3 (Terrestrial environmental quality) of the PER. - Section 9.4 and Section 10.5 (Inland waters environmental quality) of the PER. - Appendix A.4 of the PER - Sandy Ridge Project Western Australia Regional Geology and Geological

Evolution (CRM, 2016). - Appendix A.5 of the PER - Sandy Ridge Project Soils Assessment (Landloch, 2015). - Appendix A.7 of the PER - Sandy Ridge Landform Evolution Modelling (Landloch, 2016). - Appendix A.10 of the PER - Sandy Ridge Kaolinite Project Surface Water Assessment and Management

Plan (Rockwater, 2016a). - Appendix A.10 of the PER - Sandy Ridge Kaolinite Project Surface Water Assessment and Management

Plan: Addendum (Rockwater, 2016b). - Appendix A.11 of the PER - Hydrogeological Studies for the Sandy Ridge Project (Rockwater, 2015). Appendix A.12 of the PER - The Assessment of Long-term Recharge to Encapsulated Waste Isolation Cells – Sandy Ridge Project (CyMod, 2016). The PER is available at http://www.epa.wa.gov.au/proposals/sandy-ridge-project

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.

The Sandy Ridge Facility would be located approximately 75 kilometres (km) north-east of Koolyanobbing, in the Shire of Coolgardie, within the Goldfields Region of Western Australia (WA). The closest sensitive receiver is the Carina Mine Camp, approximately 50 km to the south. The Mount Walton Intractable Waste Disposal Facility (IWDF) is 5 km to the east. See Figure 1-1 in the Application Supporting Document.

http://www.epa.wa.gov.au/proposals/sandy-ridge-project



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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: Coverletter – Tellus Holdings Ltd Sandy Ridge Works Approval Application

Sandy Ridge Facility Works Approval and Licence Application Supporting Document.

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: approximately. Please see Appendix 5 to the Application Supporting Document.

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

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

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



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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

12 876,000 tonnes per year 300


64 500 tonnes per year 24

65 With Category 66 (below) 655


85 50 m3 per day 24

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

Note applicable

Sub total $ 0

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).



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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 $ 0

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)

1.5 kg/d

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

unknown

(c) total organic carbon unknown

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

(a) phosphorus 0.4 kg/d

(b) total nitrogen 1.5 kg/d

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

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

Not applicable – no discharges to water

(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




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

(a) aluminium WWTP - unknown

(b) arsenic WWTP - unknown

(c) cadmium WWTP - unknown

(d) chromium WWTP - unknown

(e) cobalt WWTP - unknown

(f) copper WWTP - unknown

(g) lead WWTP - unknown

(h) mercury WWTP - unknown

(i) molybdenum WWTP - unknown

(j) nickel WWTP - unknown

(k) vanadium WWTP - unknown

(l) zinc WWTP - unknown

(m) pesticides WWTP - unknown

(n) fish tainting wastes WWTP - unknown

(o) manganese WWTP - unknown

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

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

<1000cfu per 100 ml in 0.05 megalitre per day

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

Not applicable

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

Not applicable

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

(a) oil and grease 1.5 kg/d (in 50 m3)

(b) total dissolved solids unknown

(c) fluoride unknown

(d) iron unknown

(e) total residual chlorine unknown

(f) other Total suspended solids 1.5 kg/d (in 50 m3

Subtotal $

Summary – Proposed licence fee

Part 1 Component

Part 2 Component 0



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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) Not applicable

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

Not applicable $

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) Not applicable The Sandy Ridge Project is currently being assessed under Part IV of the Environmental Protection Act 1986. Upon issue of a Ministerial Statement, it will be exempt from the requirement for further native vegetation clearing approval

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 See Appendix 5 of the Application Supporting Document

Proposed fee for licence Attachment No

Part 1: Premises See Appendix 5 of the Application Supporting Document

Part 2: Waste types See Appendix 5 of the Application Supporting Document




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Part 3: Discharges to air, onto land, into waters See Appendix 5 of the Application Supporting Document



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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]

SANDY RIDGE WORKS APPROVAL AND LICENCE APPLICATION SUPPORTING DOCUMENT

| August 2017 (TSR-3-PO-02200-AP-REP-0001)

DOCUMENT CONTROL

Rev Issue date Description Originator Checked Approved A July2017 Draft for Review Tellus Holdings Ltd B 25/08/2017 Revised Draft as

per internal review

Tellus Holdings

0 30/08/2017 For issue Tellus Holdings

Table of Contents

Document Control........................................................................................................................ 1

Abbreviations ............................................................................................................................... i

Glossary...................................................................................................................................... iii

1 Summary .............................................................................................................................. 1

1.1 Overview ......................................................................................................................... 1 1.2 Scope, size and scale of the Sandy Ridge Facility .......................................................... 20 1.3 Key infrastructure and equipment ................................................................................ 22

2 Description of operations.................................................................................................... 25

2.1 Mining operations ......................................................................................................... 25 2.2 Class IV and V waste operations ................................................................................... 30 2.3 Infrastructure description ............................................................................................. 56

3 Emissions and discharge points ........................................................................................... 89

3.1 CLASS IV and V waste storage and disposal .................................................................. 89 3.2 Screening plant ............................................................................................................. 93 3.3 Class II landfill ................................................................................................................ 93 3.4 Wastewater treatment plant ........................................................................................ 93 3.5 Stormwater management ............................................................................................. 96

4 Construction and commissioning activities .......................................................................... 98

4.1 Construction camp ........................................................................................................ 98 4.2 Class II landfill ................................................................................................................ 99 4.3 Screening ....................................................................................................................... 99 4.4 Early waste acceptance ................................................................................................. 99

5 References ....................................................................................................................... 100

Appendix 1A: Approvals Granted ....................................................................................................

Appendix 1B: ASIC company extract ...............................................................................................

Appendix 2: Waste Acceptance Criteria ..........................................................................................

Appendix 3: Waste Acceptance Procedure ......................................................................................

Appendix 4: Waste Zoning Guide ....................................................................................................

Appendix 5: Works Approval and Licence Application Fees .............................................................

List of Figures

Figure 1-1. Regional location of proposed Sandy Ridge Facility. ............................................................ 2 Figure 1-2. Artist impression of the proposed Sandy Ridge Facility. Mining pit/cells are in the background. Supporting aboveground Infrastructure Area is in the foreground. ................................. 3 Figure 1-3. Proposed Sandy Ridge site layout. ........................................................................................ 3 Figure 1-4. Summary of stakeholder issues raised during consultation on Sandy Ridge Facility since 16 December 2016. ................................................................................................................................. 7 Figure 1-5. Open cut kaolin mine creates the voids. A canopy is erected (left). The voids are used for the safe and secure storage of waste (right). ......................................................................................... 9 Figure 1-6. Conceptual layout of Sandy Ridge Infrastructure Area. ..................................................... 21 Figure 2-1. Artist impression of layout of mine pits at year six. ........................................................... 25 Figure 2-2 Conceptual view of a cell being prepared, roof canopy and pump near ramp entry ......... 26 Figure 2-3 Cross section of a typical mine pit ....................................................................................... 27 Figure 2-4 Normal sequence of mining and waste isolation ................................................................ 29 Figure 2-5 Potential volume and type of waste by NEPM code that may be accepted at the Sandy Ridge Facility ......................................................................................................................................... 31 Figure 2-6. Examples of suitable waste packaging for transport to Sandy Ridge. ................................ 32 Figure 2-7 Waste Management process flow chart .............................................................................. 35 Figure 2-8 Conceptual Sandy Ridge Facility process flow diagram ....................................................... 37 Figure 2-9 Placement of wastes within the waste cell and a roof canopy covers the cell ................... 42 Figure 2-10 Cell containment of hazardous and radioactive wastes .................................................... 48 Figure 2-11. Illustration of Disposal Package (right) and Deflection Plug (left). ................................... 50 Figure 2-12. Borehole disposal of sealed radioactive sources (BOSS). ................................................. 51 Figure 2-13. Radioactive waste storage (shaft in cell). ......................................................................... 52 Figure 2-14. Conceptual design of low level radioactive waste isolation shaft in cell. ........................ 53 Figure 2-15. Hazardous waste inspection bay designed layout. ........................................................... 57 Figure 2-16. Designed layout of radioactive area (with WIP waste bund). .......................................... 63 Figure 2-17. Waste Immobilisation Plant (WIP) process. ..................................................................... 65 Figure 2-18. Example of a planetary mixer. (Source: http://www.batchcrete.net.au/wp-content/uploads/2015/09/Planetary-Mixer.jpg). ................................................................................. 66 Figure 2-19. Waste Immobilisation Plant (WIP) Layout. ....................................................................... 67 Figure 2-20. Designed layout of fuel farm and light vehicle refuelling area. ........................................ 70 Figure 2-21. Workshop designed layout. .............................................................................................. 72 Figure 2-22. Vehicle washdown and refuelling facility design. ............................................................. 74 Figure 2-23. Designed wheel wash facility at front gate. ..................................................................... 75 Figure 2-24. Typical designed road cross sections. ............................................................................... 77 Figure 2-25. BlivetTM Packaged Sewage Treatment System Process Diagram – indicative of the type of system to be used at Sandy Ridge Facility. ........................................................................................... 82 Figure 2-26. Proposed design of camp/village WWTP irrigation area. ................................................. 86 Figure 2-27 Proposed design of Class II landfill..................................................................................... 88 Figure 3-1. Proposed environmental monitoring at Sandy Ridge Facility. ........................................... 92

List of Tables

Table 1-1. Activities at Sandy Ridge Facility that are prescribed in Schedule 1 of the Environmental Protection Regulations 1987. .................................................................................................................. 4 Table 1-2. Approvals obtained for the Sandy Ridge Facility. .................................................................. 5 Table 1-3. Key approvals for the Sandy Ridge Facility. ........................................................................... 6 Table 1-4. Hazardous and intractable chemical wastes accepted and not accepted at the Sandy Ridge Facility ................................................................................................................................................... 10 Table 1-5. Radioactive waste accepted and not accepted at the Sandy Ridge Facility ........................ 11 Table 1-6. Assessment of Sandy Ridge against NHMRC (1992) site selection criteria. ........................ 12 Table 1-7: Proposed development envelope characteristics that meet Basel Convention Technical Guidelines on Specially Engineered Landfill siting characteristics criteria ........................................... 16 Table 1-8: Proposed development envelope characteristics that meet Basel Convention Technical Guidelines on Specially Engineered Landfill site selection criteria ....................................................... 17 Table 1-9. Key characteristics of the Sandy Ridge Facility. ................................................................... 20 Table 2-1 Top 10 waste types likely to be accepted at the Sandy Ridge Facility .................................. 31 Table 2-2. Example of cell scheduler for tracking of waste from sorting to placement and storage of ‘like with like’. ....................................................................................................................................... 43 Table 2-3: Hazardous waste inspection bay specification. .................................................................. 56 Table 2-4. Design Criteria for Container Storage Yard. ......................................................................... 59 Table 2-5. Radioactive Area design specifications. ............................................................................... 61 Table 2-6: General Evaporation Pond Specifications. .......................................................................... 64 Table 2-7: General Waste Immobilisation Plant Specifications. .......................................................... 67 Table 2-8. Fuel farm and Power Generation Design Specifications. ..................................................... 68 Table 2-9. Workshop Design Specifications. ......................................................................................... 71 Table 2-10. Indicative Sandy Ridge Facility water balance ................................................................... 78 Table 2-11. Indicative chemistry of Carina bore aquifer. ..................................................................... 79 Table 3-1. Proposed operational environmental monitoring related to Class IV/V Wastes at Sandy Ridge Facility. ........................................................................................................................................ 90 Table 3-2. Sandy Ridge Wastewater Treatment Plant effluent targets and proposed monitoring. ..... 95 Table 3-3. Proposed Retention Pond and Raw Water Pond water monitoring parameters prior to general site use. .................................................................................................................................... 97 Table 4-1. Indicative Sandy Ridge development schedule. .................................................................. 98

i

ABBREVIATIONS

ADT Articulated Dump Truck

ARPANSA Australian Radiation Protection and Nuclear Safety Agency

BOD Biological Oxygen Demand

Bq/kg Becquerels per kilogram

Bq/m3 Becquerels per cubic metre

CSY Container Storage Yard

DCN Dispatch Confirmation Notice

EC Electro-conductivity

ha hectares

HDPE high-density polyethylene

HV Heavy vehicle

IAEA International Atomic Energy Agency

ISO International Organisation for Standardisation

IWDF Intractable Waste Disposal Facility

kL kilolitres

L Litres

LLW Low Level Radioactive Waste

LV Light vehicle

m metres

m3 cubic metres

mg milligrams

MinRes Mineral Resources Limited

mm millimetres

NORM Naturally Occurring Radioactive Material

ii

NEPM National Environmental Protection Measures

pa per annum

pH potential of hydrogen

RO Reverse Osmosis (water treatment plant)

SRS sealed radioactive sources

TDS Total Dissolved Solids

tpa tonnes per annum

tpd tonnes per day

WAC Waste Acceptance Criteria

WAP Waste Acceptance Procedure

WIP Waste Immobilisation Plant

WSA Waste supply agreement

WWTP Waste water treatment plan

WZG Waste Zoning Guide

iii

GLOSSARY

Active cell life The period during which a cell is open for the purposes of waste deposition.

Australia’s Exclusive Economic Zone as defined in defined in the Seas and Submerged Lands Act 1973.

Cell An excavation or cut made beneath the ground for the purpose of encapsulating waste

Cell capped Upper kaolin cap layer fully installed but not yet rehabilitated.

Cell closed After 10 years of subsidence monitoring, capped cell is closed by adding a layer of overburden and topsoil for revegetation.

Pit An excavation or cut made at the surface of the ground for the purpose of extracting ore and which is open to the surface.

Sandy Ridge Facility The Proposal is to develop a dual revenue business comprising an open cut kaolin mine that would mine kaolin, and would use the voids resulting from mining for the permanent isolation of hazardous and intractable waste using a best practice safety case.

Retention Pond Lined surface water runoff storage pond located adjacent to the Raw Water Pond. In the event of heavy rainfall events, captured stormwater will be retained in the Retention Pond for re-use.

Year 26 The 26th year after commencement of operations.

Year 46 The 46th year after commencement of operations.

Sandy Ridge –Works Approval Application Attachment 3A Supporting Document | Page 1 of 117

1 SUMMARY

1.1 Overview Tellus Holdings Ltd (Tellus) propose to develop an open-cut kaolin mine and complementary waste storage and disposal facility with supporting above ground infrastructure: referred to as the Sandy Ridge Facility. Current market conditions make kaolin processing and export unviable, however mined material may be stockpiled for use for processing when market conditions are favourable. Tellus Holdings will apply for a licence amendment when that occurs.

The Sandy Ridge Facility would be located approximately 75 kilometres (km) north-east of Koolyanobbing, in the Shire of Coolgardie, within the Goldfields Region of Western Australia (WA). The closest sensitive receiver is the Carina Mine Camp, approximately 50 km to the south. The Mount Walton Intractable Waste Disposal Facility (IWDF) is 5 km to the east (Figure 1-1).

The waste storage facility would provide for the safe and secure storage and permanent isolation of up to 100,000 tonnes per annum (tpa) of waste. Of the 100,000 tpa of waste accepted at Sandy Ridge Facility, approximately 60,000 tpa may be solid wastes. The remainder (40,000 tpa) is expected to be liquid/sludge wastes.

In accordance with strict Waste Acceptance Criteria, liquid or sludge waste must be immobilised before being placed inside the waste cell. To achieve this, kaolinised granite mined from the cells and (in some cases cement or other binders) will be blended with the liquid/sludge to immobilise the contaminants so that they become a spade-able solid. The added materials will increase the mass of the waste. Depending on the nature of the liquid waste, the total tonnes permanently isolated may be up to 220,000 per annum. Added to the 60,000 tpa of solids accepted at the front gate, the total mass placed in the waste cells may be up to 280,000 tpa.

In this document, a mine pit is defined as an excavation or cut made at the surface of the ground for the purpose of extracting ore and which is open to the surface. Once mining of a pit is completed and it ready for waste storage and isolation activities, it is termed a ‘cell’

Sandy Ridge –Works Approval and Licence Application Supporting Document | Page 2 of 101

Figure 1-1. Regional location of proposed Sandy Ridge Facility.


An artist impression of the proposed Sandy Ridge Facility is provided in Figure 1--2and the proposed site layout is shown in Figure 1-3.

Figure 1-2. Artist impression of the proposed Sandy Ridge Facility. Mining pit/cells are in the background. Supporting aboveground Infrastructure Area is in the foreground.

Figure 1-3. Proposed Sandy Ridge site layout.


The likely activities prescribed in Schedule 1 of the Environmental Protection Regulations 1987, are listed in Table 1-1. The facility has been designed and will be operated such that the only emissions are expected to be dust from a mobile screening plant and treated wastewater discharged via two spray fields.

Brief outlines of the mining and waste disposal processes at Sandy Ridge are provided in section 1.1.1 and section 1.1.2. Detailed descriptions of all potentially prescribed activities and related activities are provided in section 2.

Table 1-1. Activities at Sandy Ridge Facility that are prescribed in Schedule 1 of the Environmental Protection Regulations 1987.

Category No.

Category description Prescribed capacity

Proposed capacity

12 Screening etc. of material: premises (other than premises within category 5 or 8) on which material extracted from the ground is screened, washed, crushed, ground, milled, sized or separated.

50 000 tonnes or more per annum

120,000 tpa

61 Liquid waste facility: premises on which liquid waste produced on other premises (other than sewerage waste) is stored, reprocessed, treated or irrigated.

100 tonnes or more per annum

Up to 40,000 tpa waste treated, to be disposed as Class IV.

64 Class II or III putrescible landfill site: premises on which waste (as determined by reference to the waste type set out in the document entitled “Landfill Waste Classification and Waste Definitions 1996” published by the Chief Executive Officer and as amended from time to time) is accepted for burial.

More than 20 but less than 5000 tonnes per annum

500 tpa during construction (reducing to 250 tpa during operations)

65 Class IV secure landfill site: premises on which waste (as determined by reference to the waste type set out in the document entitled “Landfill Waste Classification and Waste Definitions 1996” published by the Chief Executive Officer and as amended from time to time) is accepted for burial.

Not applicable

Acceptance of a combined total of up to 100,000 tpa. 66 Class V intractable landfill site: premises on

which waste (as determined by reference to the waste type set out in the document entitled “Landfill Waste Classification and Waste Definitions 1996” published by the Chief Executive Officer and as amended from time to time) is accepted for burial.

Not applicable

85 Sewage facility: premises — (a) on which sewage is treated (excluding septic tanks); or (b) from which treated sewage is discharged onto land or into waters.

More than 20 but less than 100 m3 per day

Construction – 55 m3 Operations - 25 m3 per day


1.1.1 Other Approvals and consultation

The Sandy Ridge project is owned by Tellus Holdings Ltd, and present tenure is a granted Exploration Licence (E16/440) and a General Purpose Lease (G16/21), see Appendix 1A: Approvals Granted to date.

The underlying land is Unallocated Crown Land and it is not regarded as having any current or future value for mining (of minerals other than kaolin), nor is it regarded as valuable for agricultural or cultural purposes.

The project will operate under the Mining Act 1978 (WA) (Mining Act) for any kaolin mining and future mineral processing activities and the Environmental Protection Act 1986 (WA) (EP Act) for all waste-related activities. Both Acts require different forms of tenure.

The waste storage and isolation activities require title under the Land Administration Act 1997, (Lands Act) which would comprise a Crown Lease (or Reserve) for the main facility and waste cells and Easements for access roads and the water supply infrastructure.

Any future kaolin mining or mineral processing activities require tenure in the form of a Mining Lease and other ancillary tenure (General Purpose Lease and Miscellaneous Licences) under the Mining Act. A Mining Lease Application (M16/540) has been lodged but will not be granted until the Minister for the Environment has approved the project.

The project is currently being assessed under Part IV of the EP Act (Assessment Number 2057). Upon Ministerial approval, the project will require further approval to construct and operate waste storage and isolation activities under Part V of the EP Act (this application). The same activity requires tenure under the Lands administered by the Department of Planning, Lands and Heritage. Approvals obtained to date for the Sandy Ridge Facility are presented in Table 1-2.

Table 1-2. Approvals obtained for the Sandy Ridge Facility.

Approval Decision Making Authority Status (date approval obtained)

Grant of exploration lease under Section 86 of the Mining Act 1978 (WA)

Department of Mines and Petroleum

E16/440 granted (see Appendix 1A: Approvals Granted to date)

Grant of a general purpose lease under Section 86 of the Mining Act 1978 (WA)

Department of Mines and Petroleum

G16/21 granted 21 Mar 2017 (see Appendix 1A: Approvals Granted to date)

Land administration and land tenure under the Land Administration Act 1997 (WA)

Department of Lands Section 91 Licence granted for geotechnical and feasibility studies (Appendix 1A: Approvals Granted to date).

Key approvals in process for the Sandy Ridge Facility are presented in Table 1-3.


Table 1-3. Key approvals for the Sandy Ridge Facility.

Approval Decision Making Authority Status (expected date for obtaining approval)

Approval for the Sandy Ridge Facility under Section 133 of the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) (Cth)

Department of Environment and Energy

Controlled Action (nuclear actions sections 21 and 22A). EPBC 2015/7478. Bilateral Assessment with OEPA.

Statement that the Sandy Ridge Facility may be implemented under Section 45 of the Environmental Protection Act 1986 (EP Act) (WA)

Minister for Environment Assessment 2057 Response to Submissions report finalised. Awaiting DWER to publish.

Works Approval (under Section 54) and Licence (under Section 57) of the EP Act


Subject of this application.

Mining lease under Section 71 of the Mining Act 1978 (WA)

Department of Mines, Industry Regulation and Safety

Application submitted 19 August 2015. Grant is subject to issue of Ministerial Statement under Part IV of the EP Act.

Miscellaneous licences under Section 91 of the Mining Act 1978 (WA)


As per above.

Mining Proposal and Mine Closure Plan under Section 82A (2) of the Mining Act 1978 (WA)


Submitted with Mining Lease application (see above). Approval is subject to grant of mining lease and issue of Ministerial Statement under Part IV of the EP Act.


Department of Planning, Lands and Heritage

Submitted application under Section 165. Anticipated grant December 2017.


Department of Planning, Lands and Heritage

Crown Lease and Easement application is in development.

Aboriginal land interests because native title processes would need to be followed for the valid grant of tenure under the Native Title Act 1993

Department of Mines and Petroleum and the Department of Lands

Complete. No native title claimants.

Registration (under Section 28)/Disposal Permit (under Section 34) under the Radiation Safety Act 1975 (WA)

Radiological Council of Western Australia

Application package is in development.

Radiation Management Plan under Part 16 of the Mines Safety and Inspection Regulations 1995 (WA)


Application package is in development.

Licence to Construct or Alter Well Water under Section 26D of the Rights in Water and Irrigation Act 1914 (WA) (RIWI Act)


Pending grant of land access (either Miscellaneous Licence under the Mining Act 1978, or provisions under the Land Administration Act 1997.

Licence to Take Water under Section 5C of the RIWI Act


Pending land access and issue of 26D licence under the RIWI Act.

Dangerous Goods Site Licence under Part 4 of the Dangerous Goods Safety


Licence will be sought prior to commencing operations.


Approval Decision Making Authority Status (expected date for obtaining approval)

Act 2004 (WA) and Dangerous Goods Safety (Storage and Handling of Non-explosives) Regulations 2007 (WA) Development approval under Section 162 and building permits for construction of buildings under Part 2 of the Planning and Development Act 2005 (WA) and Building Act 2011 (WA)

Shire of Coolgardie Application is in development.

Project management plan under Regulation 3.13 of the Mines Safety and Inspection Regulations 1995 (WA)


Project Management Plan is in development.

Consultation conducted to date

A comprehensive program of stakeholder engagement was conducted as part of the Public Environmental Review (PER) under Part IV of the EP Act (see Table 6-2 of the PER). This commenced in 2012 and continues today. Stakeholder submissions received on the PER and Tellus’ consideration of, and responses to those submissions are published in the Sandy Ridge Facility Response to Submissions Report (Tellus, 2017).

Figure 1-4summarises the issues that have been discussed with stakeholders since the Sandy Ridge PER was published in December 2016. The main four topics raised during this period were approvals, land tenure, waste management and closure of the facility.

Figure 1-4. Summary of stakeholder issues raised during consultation on Sandy Ridge Facility since 16 December 2016.

Stakeholders that have been consulted directly relevant to the works approval and licensing of Sandy Ridge, include:

• DWER – Industry Regulation Branch

• DWER – Contaminated Sites Branch

• DoH - Radiation Health Unit


• DMIRS – Environment Division

• DPLH – Major Projects

• DPLH – Contaminated Sites Unit

1.1.2 Kaolin mining

Up to 200,000 tpa of kaolinised granite would be extracted using the open cut method of mining. The surface of each pit would be cleared of vegetation and stockpiled (for later reuse in rehabilitation). The pit would then be opened by excavation of the topsoil, subsurface soils and laterite. Topsoil and subsurface soils will be stockpiled adjacent to the cell area for later use in rehabilitation.

Following this, surface mining is used to remove the hard, dense silcrete layer that overlays the kaolin which is then removed by excavator and truck. Overburden would be stockpiled adjacent to the cells in readiness for capping cells that are to be closed. Ore would be screened into separate stockpiles of different grades of kaolinised granite located adjacent to the pit (See Figure 1-3) for use either in immobilising wastes or for backfilling around wastes that are deposited in cells.

1.1.3 Waste storage and isolation

Waste Acceptance Criteria (WAC, see Appendix 2: Waste Acceptance Criteria) will be used to determine whether a waste stream is suitable for acceptance at the Sandy Ridge Facility. If the waste is found to be acceptable in accordance with Tellus’ WAC, a contractual agreement will be used to specify any treatment and packaging requirements for the waste prior to it leaving the customers site. These steps are taken to ensure waste material is safely transported to Sandy Ridge.

Waste would be transported mostly via rail to Kalgoorlie and then via road by reputable licensed transport contractors to the proposed Sandy Ridge Facility. Waste arriving would be inspected, sampled and unloaded in line with a strict Waste Acceptance Procedure (WAP, see Appendix 3: Waste Acceptance Procedure). Wastes will be temporarily stored on hardstand storage areas until they are placed in waste disposal cells in accordance with waste zoning protocol (Appendix 4) and operational management plans. Above-ground storage time for wastes at Sandy Ridge is expected to be less than 1 week for most wastes, but may be longer due to operational constraints. Tellus will store materials ‘like with like’ wherever possible and in accordance with its Waste Zoning Guide (WZG [refer to Appendix 4]). Some temporary surface storage may be required to ensure waste types can be placed appropriately within a cell.

The waste cells would be filled with packaged waste in layers, placed ‘like-with-like’ (see section 2.2.5 Waste placement in Cell for more detail). Each layer would also be compacted and further layers added until approximately seven metres (m) below the ground surface. At this depth, a 3 m thick layer of low permeability clay would be placed on top of the waste to seal the waste layers and to prevent water ingress into the cell. Compacted gravel and laterite backfill would then be placed on the clay layer. A clay domed cap would then be situated on the top of the cell, to horizontally shed rainfall for the duration of a subsidence monitoring period. At the completion of the 10-year


subsidence monitoring period, excess kaolinised granite and soil would be placed over the domed clay cap to enable re-vegetation.

During the waste storage and isolation process, a roof canopy would be positioned over the cell to exclude rainfall prior to the capping layer being installed (Figure 1-4).

Figure 1-5. Open cut kaolin mine creates the voids. A canopy is erected (left). The voids are used for the safe and secure storage of waste (right).

The cells would be designed and managed to allow for future waste recovery opportunities – that is, wastes would be stored like-with-like and the final disposal locations of all waste would be tracked and logged for future reference. At some point in the future, a recovery technology park would be established to support research and development into ways to release waste materials back into the circular economy.

In the first year of operation, about 55,000 tpa of waste material would be disposed of at the Sandy Ridge Facility. After a short ramp-up period of approximately 6 years, the full capacity of 100,000 tpa is assumed to be reached.

Hazardous and intractable waste primarily from the mining, oil and gas, chemical, manufacturing, agricultural, and remediation industries would be accepted at the proposed Sandy Ridge Facility. Wastes would also be accepted from the State Emergency Services such as hazardous material resulting from man-made or natural disasters. Accepted waste materials would come from WA, the Australian mainland and Australia’s Exclusive Economic Zone waters.

Hazardous and intractable chemical waste accepted and not accepted at the Sandy Ridge Facility

Hazardous and intractable chemical waste that would and would not be accepted at the Sandy Ridge Facility are summarised in Table 1-4. Specific detail of accepted and not accepted wastes is defined in the Waste Acceptance Criteria (Appendix 2: Waste Acceptance Criteria).


Table 1-4. Hazardous and intractable chemical wastes accepted and not accepted at the Sandy Ridge Facility

Hazardous and intractable wastes (NEPM 75) Accepted on site (surface

storage)2

Accepted below ground in waste cells2

Hazardous and intractable wastes (NEPM 75) subject to meeting the characteristics criteria below.

• Liquid and sludges 1

• Explosive wastes 1

• Flammable liquids or solids 1

• Self-combusting wastes or wastes that can generate a gas-air mixture which is toxic or explosive

1

• Highly corrosive or oxidizing

• Gases

• Clinical waste such as infectious hospital waste and body parts

• Municipal solid waste such as putrescible household and commercial waste

• Putrescible wastes not generated at Sandy Ridge Facility, which rot such as household rubbish

• Uncertified waste which cannot be identified or has not undergone characterisation testing

• Reacts with the repository geology such as dissolving it or producing a gas

1Normally excluded unless modified before disposal or during disposal so the operational or post closure safety of the waste cell and facility is not compromised. 2 = accepted, = not accepted. 1= normally excluded but possibly suitable

Radioactive wastes accepted and not accepted at the Sandy Ridge Facility

Radioactive waste that would and would not be accepted at the Sandy Ridge Facility are listed in Table 1-5. Examples of low level radioactive waste that would be accepted include medical isotopes, smoke detectors, and sealed gauges. The WAC (Appendix 2: Waste Acceptance Criteria) states the radiation criteria for waste acceptance. In summary, the proponent has set a dose constraint of 0.3 milli sievert (mSv)/a as for critical members of the public e.g. waste transport truck driver, which is well below the 1 mSv/a per annum limit set by Australian Radiation Protection and Nuclear Safety Agency (ARPANSA). To put this in context, the public dose limit equals three chest X-rays per year. One CT cat scan alone is 7 mSv, which is 23 times higher than the exposure dose constraint set by Tellus and seven times higher than the dose limits set by ARPANSA.

The WAC identifies that Naturally Occurring Radioactive Material (NORM) up to Low Level Radioactive Waste (LLW) activity content will be accepted at Sandy Ridge.

Nuclear waste storage or disposal services would not be provided at the Sandy Ridge Facility. The Sandy Ridge Facility has not been nominated as a potential National Radioactive Waste Management Facility. No such nomination is planned and no such nomination would be accepted should it be made by any other party.


Table 1-5. Radioactive waste accepted and not accepted at the Sandy Ridge Facility

Radioactive wastes1 ( = accepted, = not accepted) Accepted on site (surface

storage)

Accepted below ground in waste cells

NORM up to LLW activity levels such as, oil and gas industry scale

LLW such as smoke detectors, exit signs, industrial gauges and medical isotopes

Intermediate level (ILW) and high level waste (HLW) such as reprocessed spent nuclear fuel and components with high levels of radioactivity

Nuclear waste from power generation and defense use

1 Classification of Radioactive Waste – ARPANSA RPS20

1.1.4 Site suitability

This section outlines the climatic and geological characteristics of the Sandy Ridge Facility location that make the site suitable for containing intractable wastes, consistent with Basel Convention in regard to chemical waste disposal and the requirements of the Code of Practice for the near-surface disposal of radioactive waste in Australia (NHMRC, 1992) in regard to LLW disposal.

Code of Practice for the near-surface disposal of radioactive waste in Australia

Consultation with ARPANSA and the Radiation Health Branch of the WA Department of Health has indicated that the Code of Practice for the near-surface disposal of radioactive waste in Australia (NHMRC, 1992) is the applicable code for the establishment of a near surface geological repository in WA. As outlined in Table 1-6 the proposed development envelope meets all the NHMRC (1992) site selection criteria and is an ideal location for a near surface geological repository.

‘Near surface disposal’ means the disposal of radioactive waste in structures located approximately 30 metres below and/or above the natural ground surface and covered by a layer(s) of natural and/or manufactured materials (NHMRC, 1992).


Table 1-6. Assessment of Sandy Ridge against NHMRC (1992) site selection criteria.

Criteria (extracted from NHMRC, 1992) Proposed development envelope characteristics a The Facility site should be located in an area

of low rainfall, should be free from flooding and have good surface drainage features, and generally be stable with respect to its geomorphology.

The proposed development envelope averages just over 250 mm of rainfall per annum and evaporation is greater than 2,000 mm per annum (BoM, 2015a). This means very little rainfall occurs across the proposed development envelope and generally water would evaporate before it infiltrates. The proposed development envelope is not subject to flooding, nor is it predicted to be in the future. The site is at very low risk of encountering cyclones. There are no defined surface watercourses or water bodies in the proposed development envelope. The proposed development envelope is located close to the top of a watershed which means that catchment areas for surface water flows are small. The proposed development envelope sits within the Archean Yilgarn Block and is geologically typical of areas overlying deeply weathered granite domes. Landforms within the proposed development envelope have been in place for about 250 million years. It is a combination of a virtually flat plateau, cemented surface layers, and semi-arid conditions that creates the stable geomorphology of the area (CRM, ~ 2016).

b The water table in the area should be at sufficient depth below the planned disposal structures to ensure that groundwater is unlikely to rise within five metres of the waste, and the hydrogeological setting should be such that large fluctuations in the water table are unlikely.

Hydrogeological investigation of the proposed development envelope confirms no regional aquifer is present. This is consistent with findings at the nearby IWDF, as no groundwater has been detected in monitoring bores since monitoring began in 1995 (Department of Finance, 2014). This confirms that the absence of groundwater is a regional phenomenon within the extensive kaolinite deposit.

c The geological structure and hydrogeological conditions should permit modelling of groundwater gradients and movement, and enable prediction of radionuclide migration times and patterns.

The top of the clays and the base of the surface layer of permeable soils are delineated by a thick layer of highly impermeable silcrete which acts to limit vertical migration of groundwater or infiltrating surface water. The silcrete layer and very high available climatic energy ensures that even very large rainfall events are contained within the top few metres of ground, and are subsequently evaporated before the water can infiltrate to create an aquifer.

d The disposal site should be located away from known or anticipated seismic, tectonic or volcanic activity which could compromise the stability of the disposal structures and the integrity of the waste.

The proposed development envelope is within an area with the lowest hazard rating for earthquakes in Australia. This means there is a very low risk of earthquakes affecting the structural stability of the waste cells. The proposed development envelope is situated on the Archaean Yilgarn Shield, within the central portion of the eastern section of the Indo-Australian Plate. This eastern section is, in general, moving at around 5.6 cm per year towards the north-east (Hammonds, 2012). This rate of movement and the location of the proposed development envelope within a seismically quiet portion of a stable shield is very unlikely to cause any significant tectonic activity (uplift,


Criteria (extracted from NHMRC, 1992) Proposed development envelope characteristics subsidence, or fracturing) in any timeframe relevant to the Sandy Ridge Facility (CRM, 2016). There has not been any igneous activity in the region for over 1,000 million years. There is no reason to expect that there would be any sub-surface or surface volcanic activity within this part of the stable craton for at least 50 million years (CRM, 2016).

e The site should be in an area of low population density and in which the projected population growth or the prospects for future development are also very low.

The proposed development envelope is located in an area with no population; the nearest population centre is a non-permanent camp approximately 52 km away. The nearest town (Koolyanobbing) is 75 km away. The proposed accommodation camp would be located at least 3 km from the proposed operational Sandy Ridge site. Owing to the isolated location of the Sandy Ridge Facility, there is no projected future development at either the proposed accommodation village or surrounding the Sandy Ridge site.

f The groundwater in the region of the site which may be affected by the presence of a Facility should ideally not be suitable for human consumption, pastoral or agricultural use.

Hydrogeological investigation of the proposed development envelope confirms no regional aquifer is present. Groundwater in the region is likely to be within fractured rock aquifers at significant depths. Based on information from the Carina Iron Ore Mine, groundwater is extremely salty, and close to the concentration of sea water. It does not have any beneficial use for human, pastoral or agricultural use.

g The site should have suitable geochemical and geotechnical properties to inhibit migration of radionuclides and to facilitate repository operations.

The storage and permanent isolation cells would be surrounded by several kilometres of competent kaolin and underlain by at a minimum thickness of 5 m of undisturbed natural kaolin. The kaolin within the proposed development envelope has an in-situ permeability of the order of 1 x 10-7 m/s which means it would act as an aquiclude and retard the flow of water both vertically and horizontally. The Soils and Materials Characterisation report (Landloch 2015) presents information on kaolin properties which confirm that it has a significant cation exchange capacity and the ability to absorb and retain cations. Whilst kaolin is not the most active clay, it still typically has a cation exchange capacity in the range 3–15 which means that it has a substantial capacity to capture and retain positively charged ions such as those associated with heavy metals and most radionuclides. This coupled with the large volume of kaolin surrounding the cells and the absence of groundwater means that there is an extremely large capacity to absorb and retain contaminants in the unlikely event that they were to leach from the storage or permanent isolation cells.

h The site for the Facility should be located in a region which has no known significant natural resources, including potentially valuable mineral deposits, and which has

There is no evidence to suggest that there is potential for economic mineral or hydrocarbon deposits beneath the kaolin deposit. The economically mineable kaolin would be recovered during the Sandy Ridge Facility.


Criteria (extracted from NHMRC, 1992) Proposed development envelope characteristics little or no potential for agriculture or outdoor recreation use.

There is no potential for medium to high value agriculture.

The proposed development envelope is remote from towns and within a semi-arid climate, and highly unlikely to be used for outdoor recreation use.

i The site should have reasonable access for the transportation of materials and equipment during construction and operation, and for the transport of waste into the site.

The proposed development envelope is accessible from all parts of Australia via major roads, highways and ports. Tellus is in discussions with the WA Government (Department of Finance) regarding an access agreement to use the IWDF access road and have also been discussing an easement for the IWDF access road with the Department of Lands.

j The site should not be in an area which has special environmental attraction or appeal, which is of notable ecological significance, or which is the known habitat of rare fauna and flora.

The development does not contain any Environmentally Sensitive Areas or Matters of National Environment Significance. No rare (referred to as ‘Threatened’ under State and Commonwealth legislation) flora or fauna habitats have been identified within the proposed development envelope. Therefore, the proposed development envelope has no special environmental attraction or appeal.

k The site should not be located in an area which is of special cultural or historical significance.

An aboriginal heritage survey did not record any evidence of Aboriginal heritage sites (registered or previously unrecorded) or ethnographic values in the proposed development envelope. A search of the Land, Approvals and Native Title Unit (Government of Western Australia, 2015) indicated there are no registered native title claims over the proposed development envelope. There are no world heritage, Commonwealth or national or state heritage listed places in the proposed development envelope.

l The site should not be located in reserves containing regional services such as electricity, gas, oil or water mains.

No regional services infrastructure is located beneath the proposed development envelope.

m The site should not be located in an area where land ownership rights or control could compromise retention of long-term control over the Facility.

The proposed development envelope is located on Crown Land.

* Bureau of Meteorology ~ Continental Resource Management Pty Ltd

Basel Convention

In Article 4, paragraph 2 (b), the Convention requires each party to take the appropriate measures to “ensure the availability of adequate disposal facilities for the environmentally sound management of hazardous or other wastes, that shall be located, to the extent possible, within it, whatever the place of their disposal”. Disposal is defined as any operation specified in Annex IV of the Convention, which includes “specially engineered landfill (e.g., placement into lined discrete cells which are capped and isolated from one another and the environment, etc.)”. According to this definition, the Facility is classified as a specially engineered landfill; however, these types of facilities are commonly referred to as geological repositories.


Annex 1A and 1B of the Basel Convention Technical Guidelines on Specially Engineered Landfill provide siting characteristics and site selection criteria that should be considered while siting a hazardous waste landfill facility, which are given in Table 1-7 and Table 1-8 respectively. The Facility meets all the criteria outlined in the Technical Guidelines and is an ideal location for the disposal of hazardous wastes.


Table 1-7: Proposed development envelope characteristics that meet Basel Convention Technical Guidelines on Specially Engineered Landfill siting characteristics criteria

Siting Characteristics criteria Proposed development envelope characteristics Hydrogeological Characteristics All drinkable water supply points, and distances between these points, in the area surrounding a landfill should be identified. The landfill must be located far enough away from these sources so that in the event of an accident and contamination, there will be enough time to provide warning and alternative drinking water supplies to communities that rely on the water aquifer that could be contaminated.

There are no surface water supply points in the nearby vicinity of the Facility. The high evaporation rates and low rainfall levels prevent the formation of permanent surface water and the nearest water source is the Carina Iron Ore pit, which is close to sea water in salinity, and therefore unfit for consumption without prior treatment. Hydrogeological studies completed at the proposed Sandy Ridge site and at the adjacent IWDF have found no evidence of a groundwater aquifer in the region.

The surface hydrology of an area also should be considered, so as to avoid areas prone to flooding or susceptible to erosion. At a minimum, 100 years of return time of frequency, is recommended for flooding.

Due to the arid climate, the proposed development envelope is not prone to flooding, and weathering and erosion in the area is extremely slow. The present surface has not changed for at least the past 2.6 million years (CRM, 2016) except for the addition of wind-blown sand, and possible minor redistribution of lateritic pebbles

In studying the hydrology of an area, seasonal variations in water table depth, and the table's maximum historical height, must be determined. The depth of a landfill bottom must be placed some meters above the maximum water table increase.

The IWDF groundwater monitoring began in 1995, with bores at depths ranging from 24 to 41m BGL, and no groundwater has ever been detected. It is anticipated that the water table depth is well below the weathered granite.

Geographical The most important geographical factor involved in choosing a landfill site is the stability of the area. The morphology of a location also must be carefully considered.

No earthquakes have occurred at the proposed location of the cells. Australia is located on the Indo-Australian Plate, and there are no plate boundaries on the continent, therefore tectonic plate activity is not experienced in WA. There are no active or dormant volcanoes in WA. Current weathering and erosion in the area is extremely slow

Depending on geographical and morphological factors, three different types of landfills are generally constructed: superficial, depression and slope. In addition, underground structures located in lithologically stable areas are sometimes used for the disposal of highly toxic stable wastes.

The design and characteristics of Sandy ridge make it closer to the “underground structures” definition and as such potentially suitable for the disposal of highly toxic stable wastes.


Table 1-8: Proposed development envelope characteristics that meet Basel Convention Technical Guidelines on Specially Engineered Landfill site selection criteria

Site Selection Criteria Proposed development envelope characteristics Engineering Geophysical site (geographical criteria): Should be large enough to accommodate waste for life of production facility.

The proposed development is 1004.2 ha, only 276.05 ha of which is currently proposed to be cleared. This assumes an average of one waste cell per year over the operational lifespan of 25 years. Should expansion be required and approved, there is ample space towards the north of the current proposed pit/cell area.

Proximity: Locate as close as possible to production or treatment facility to minimize handling and reduce transport cost. Locate away from water supply (suggested minimum 500 feet) and property line (suggested minimum 200 feet, more for landfill gas).

The Sandy Ridge Facility is planned to accept waste from all over Australia, and the State and National road and rail transport networks are considered sufficient for the quantities and types of materials being delivered to the site. The Carina Pit bore is to be the water source and is located 13 km away

Access: Should be all-weather, have adequate width and loan capacity, with minimum traffic congestion; one way system on site whenever possible

Site access roads have been preliminarily designed to suit a maximum of a 36.5 m long road train configuration. An existing unsealed access road would be utilised to access Sandy Ridge and new unsealed access roads would be created. On average, there are only 32 rain days per year, and access is not expected to be restricted by weather conditions except in extreme weather events.

Topography: Should minimize earth-moving, take advantage of natural conditions. Avoid natural depression and valleys where water contamination is likely.

The proposed development envelope has very low relief. It consists of flat to gently undulating sand plains and low rises and is typical of landscape which occurs over deeply weathered granite rocks. The topography ranges from about 460 m above sea level to 490 m above sea level and generally rises slightly from west to east

Geology: Avoid areas with earthquakes, slides, faults, underlying mines, sinkholes, and solution cavities.

The proposed development envelope is a deeply weathered granitoid terrane that generally comprises four main lithologies, colluvial sand and gravel with mottled zone laterite, silcrete, kaolinitic clay, and granitoid basement. It is tectonically stable, with no underlying mines, sinkholes, cavities, etc.

Soils: Should have natural clay liner or clay available for liner, and final cover material available.

The cells would be located within the kaolinitic clay bed, with a minimum of 5m of kaolinised granite remaining between the bottom of the cell and the weathered granite layer. The excavated kaolinitic material will be utilised in backfilling and capping operations.

Environmental Surface water: Locate outside 100-year floodplain. No direct contact with navigable water. Avoid wetlands.

There are no creeks or channels running through the proposed development envelope and surface water runoff would only be generated from very infrequent


Site Selection Criteria Proposed development envelope characteristics high rainfall events. The likelihood of water pooling on the surface for longer than 12 hours is very low, due to sandy soils.

Groundwater: No contact with groundwater. Base of fill must be above high groundwater table. Avoid sole-source aquifer. Avoid areas of groundwater recharge.

No groundwater aquifer has been intersected during targeted groundwater investigation, or during exploration drilling. Based on the analysis of drilling samples and activities, the water table is inferred to be well below the weathered granite. The location is arid, with low rainfall and high evaporation rates, and there is little if any net recharge.

Air: Locate to minimize fugitive emissions and odour impacts. Dust is considered to be the most significant airborne emission resulting from the Sandy Ridge Facility. Dust suppression and management measures would be implemented to minimise dust impacts where possible. There are no sensitive receptors located within 50 km of the development envelope

Terrestrial and aquatic ecology: Avoid unique habitat area (important to propagation of rare and endangered species) and wetlands.

Four regional vegetation associations occur within the proposed development envelope, as defined by Beard (1972), each of which have greater than 97% of their Pre-European extent remaining in the Southern Cross IBRA Subregion. The area proposed to be cleared would not result in any changes to the conservation status of these vegetation associations and, therefore, the overall regional impact on fauna habitat would not be significant. The proposed development envelope is in an arid climate, with no wetlands nearby.

Noise: Minimise truck traffic and equipment operation noise. Best practice noise management would be implemented during the operation of the mine to ensure compliance with the Environmental Protection (Noise) Regulations 1997. The nearest permanent sensitive receptor is approximately 50km away (Carina Iron Ore Mine Accomodation Village).

Land use: Avoid populated areas and areas of conflicting land use such as parks and scenic areas.

The location of the proposed development envelope is remote and the nearest neighbour is the IWDF camp, which is 6km away and does not have any permanent residents. The land is currently vacant and undisturbed Crown Land, with no future mining potential.

Cultural resources: Avoid areas of unique archaeological, historical and paleontological interest.

Desktop studies and field surveys have found that no heritage sites (registered or unrecorded) occur within the proposed development envelope.

Legal/regulatory: Consider national, regional and local requirements for permits. The Sandy Ridge Facility takes account of national, regional and local requirements


Site Selection Criteria Proposed development envelope characteristics Public/political: Gain local acceptance from elected officials and local interest groups

Various phases of stakeholder consultation for the Sandy Ridge Facility has been completed. To date, neutral to broad support has been received. Stakeholders include:

• Local Indigenous groups and Traditional Owners. • Local communities of Coolgardie and Kalgoorlie. • Local, State and Australian Government departments. • Local businesses in Coolgardie and Kalgoorlie.

Economic Property acquisition: Actual land cost plus related costs. Not reported in this document Site development: Excavation, grading, liner, new roads, and other development costs.

Not reported in this document

Annual costs: Fuel costs, operating labour, maintenance, land preparation, utilities, and overhead.

Not reported in this document

Salvage value: Do not consider: site probably will not be an asset Not reported in this document


1.2 Scope, size and scale of the Sandy Ridge Facility The key characteristics of the Sandy Ridge Facility are summarised in Table 1-9 and shown in Figure 1-3. The components of the infrastructure area are shown in Figure 1-6.

Table 1-9. Key characteristics of the Sandy Ridge Facility.

Summary of the Proposal ELEMENTS Activity Size/Capacity Description Native Vegetation Clearing

Up to 276.05 hectares (ha) comprising (approx.): Pits/cells 200 ha Infrastructure area 17 ha Camp/Village 2.5 ha Class II landfill 2 ha Access roads 22 ha Water pipeline 28 ha Future technology park 4 ha

Within a 1004.2 ha Development Envelope.

Class IV and Class V waste disposal cells

Acceptance of no more than 100,000 tpa. Maximum amount accepted 2,500,000 t over a 25 year period.

See first six waste cells on Figure 1-3. Each cell measures 80m x 160m x ~20 -30 m depth. Future cells will be progressively developed northwards. See borehole disposal area on Figure 1-3.

Class II waste disposal

Class II landfill. 500 tpa during construction (reducing to 250 tpa during operations)

See Class II landfill on Figure 1-3. Disposal of putrescible waste generated on site.

Infrastructure Area

Up to 17 ha (initially approx. 7 ha) See Figure 1-6. Area in which waste is received, checked, stored and treated before placement in cells. Also contains ancillary infrastructure.

Waste Immobilisation Plant

40,000 tonnes waste per annum. (in Infrastructure Area)

Area 12 on Figure 1-6. Mixer to immobilise waste sludge with inert materials e.g. concrete and kaolinized granite.

Wastewater Treatment Plants and irrigation area

Combined max. capacity to 50 kL/d. Mine office – 5 m3 per day Construction camp - 25 kL/d Permanent village – 25 kL/d Mine office spray field - 0.1 ha Camp/Village irrigation – 1.2 ha

Up to 3 systems operated in phases with capacity of 50 kL/d during construction reducing to 30 kL/d during operations. Mine office - Area 1 on Figure 1-6, with

discharge sprayfield see Area 15 on Figure 1-6.

Camp/Village – see irrigation area on Figure 1-3.

Water pipeline 13 km long Polywelded pipe from a groundwater bore adjacent to Polaris/Mineral Resources Carina Iron Ore Mine.

Groundwater use Carina Pit bore approximately 0.18 gigalitres per annum

See inset on Figure 1-3. Water tanks (Area 1 on Figure 1-6) supplied via a water pipeline (see previous).

Screening Plant 100 tph to process up to 120,000 tonnes per annum

Contract for double-deck screen, with luffing/slewing discharge conveyor. Various locations within the Development Envelope.


Figure 1-6. Conceptual layout of Sandy Ridge Infrastructure Area.


1.3 Key infrastructure and equipment This section lists the key infrastructure that would be constructed and used for the kaolin mining and the waste storage and isolation operation at the Sandy Ridge Facility. A list of equipment used during construction and operation of the Sandy Ridge Facility is also provided.

1.3.1 Key infrastructure

Infrastructure that would be constructed and used for the mining operation includes:

• Open cut mining pits (later used as waste cells) approximately 160 m long, 80 m wide and 23 m deep (depending on local stratigraphy, with a maximum depth of 30 m). Twenty-five pits are currently proposed.

• Ore stockpile area.

• Contractor offices and laydown yard including repair and maintenance facilities for earthmoving and fixed plant equipment, mobile equipment refuelling and washdown facility (including oily water separator and storage), reverse osmosis water plant, saline water and Retention Ponds.

Infrastructure that would be constructed and used for the waste storage and isolation operation is shown in Figure 1-3 and includes:

• Waste cells created by the pits left from kaolin mining.

• Relocatable waste cell roof canopy on a rail or wheel system (see Figure 1-5).

• Container hardstand.

• Hazardous waste inspection area.

• Radioactive waste inspection area, warehouse and packaging building.

• Waste laboratory.

• Waste immobilisation plant (WIP) facility comprising waste storage bunkers, consumables storage, blending and mixing equipment and stormwater management system. This is anticipated to be similar in size and layout to a small concrete batching plant.

• Liquid waste evaporation ponds.

• Administration office area, secure site fencing and gatehouse incorporating a radiation detection portal.

In addition to the above infrastructure, the following activities would be undertaken:

• Installation of a temporary construction camp.

• Upgrade of the Mount Walton IWDF access road and intersection at Great Eastern Highway.

• Construction of site access roads and internal haul roads.

• Construction of a permanent accommodation camp.


• Construction of a groundwater bore and pumping station in the Carina Mine area and associated water pipeline to Sandy Ridge.

• Construction of administration building and carpark (including offices, first aid, training centre, communications, lunch room and ablutions).

• Establish a Class II landfill.

• Installation of wastewater treatment systems.

• Installation of water tanks for raw and potable water.

• Installation of diesel storage tanks, piping reticulation and bowsers.

• Installation of switchboards and generators.

• Erection of a fence around infrastructure area and pits/cells area.

1.3.2 Equipment

The likely plant and equipment required during construction would include:

• Light vehicles.

• Excavators.

• Dump trucks.

• Fuel truck.

• Front end loaders.

• Vibrating rollers.

• Cranes.

• Water trucks.

• Dozers.

• Graders.

• Prime movers and trailer sets.

• Low loaders.

• Drills.

• Scrapers.

• Continuous surface miner.

• Mobile screening plant.

• Concrete batch plant.

• Cherry pickers and elevated work platforms.

• Generators.

• Water pumps.

• Forklifts.

• Temporary services and utilities.

The likely plant and equipment required during operation would include:

• Articulated dump trucks (ADT).

• Continuous surface miner.

• Conveyors.

• Forklifts.

• Front end loaders.

• Emergency Response Vehicles.

• Excavators.

• Graders.

• Generators.

• Light vehicles.


• Vibrating rollers.

• Telehandlers.

• Water trucks.

• Scrapers.

• Service vehicles.

• Waste Immobilisation Plant.

• Electronic personal dosimeters

• Fixed radiation portal monitor.

• Handheld isotope identifier.

• Handheld contamination and dose rate monitors.

• Stationary hand and foot contamination monitor.

• Fixed area radiation monitors.

• Portable Radon monitor.


2 DESCRIPTION OF OPERATIONS

This section describes the nature of dual use at the site i.e. mining activities and near surface geological repository activities and the necessary infrastructure required to support site operations. Where appropriate, this section also references how the surface infrastructure relates to potential emissions and discharges.

The activities described below have been assessed in the PER for potential adverse impacts on terrestrial environmental quality. The same activities will require regulation by the Department of Water and Environmental Regulation (DWER) because they are prescribed under Schedule 1 of the Environmental Protection Regulations 1987 and may result in emissions or discharges (refer to Chapter 3 for more information on emissions and discharges).

2.1 Mining operations Mining would be carried out in campaigns on a frequency commensurate with the volume of wastes to be isolated and the size of cells excavated. The frequency of mining campaigns is likely to commence every 18 months, but the actual frequency is dependent on the depth of mining in each area, the demand for kaolin products and the timing of waste deliveries.

Depending on the depth of the mine pit, a single waste cell would hold approximately 30,000 to 75,000 tonnes of waste material.

2.1.1 Sequence of pits

Pits would be constructed in sequence along a common alignment whenever possible, before moving to an adjacent alignment and returning in the opposite direction (Figure 2-1).

Figure 2-1. Artist impression of layout of mine pits at year six.


Current mine planning is for approximately 25 pits to be constructed. Each mine pit and waste cell would be nominally 160 m long, 80 m wide and 23 m deep (depending on local geology, with a maximum depth of 30 m).

The cell would be covered by a roof canopy, most likely consisting of a steel lattice frame with a fabric covering that would be approximately 85 m wide and 150 m long. This allows the roof canopy to be relocated from one pit to the next on temporary rail tracks or wheels. The purpose of the roof is to prevent rainfall from entering the waste cell during the waste storage and isolation operation (refer to Figure 2-2).

There are some waste types which may be placed in a cell without a roof as the materials being placed are not immediately leachable in the unlikely event of rain during a waste campaign. Any such cell construction would be designed with a drainage sump to enable pumping out of any direct precipitation whilst the cell is open.

Figure 2-2 Conceptual view of a cell being prepared, roof canopy and pump near ramp entry

2.1.2 Cross section of a typical pit

A cross section of a typical mine pit is shown in Figure 2-3. Based on exploration drilling results, the average overburden (sandy clay, laterite gravel and silcrete) thickness is about 6 m. Beneath the overburden, the kaolinised granite (i.e. the mineral resource) is on average 17 m thick (6 m to 23 m thick). Beneath the kaolin zone is a saprock zone (kaolinite, including some incompletely weathered granite). Below the saprock zone (23.5 m to 28.5 m) is unweathered granite (beyond 28.5 m, typically at >30 m).


Figure 2-3 Cross section of a typical mine pit


2.1.3 Mining method

The principal mining method would be open cut to extract the overburden and kaolin ore. The surface area of each kaolin pit would be cleared of vegetation. Cleared vegetation and topsoil would either be directly-returned to a closed cell that is ready to be rehabilitated or be stockpiled for later use in rehabilitation. The pit would then be opened by excavation of the subsurface soil and laterite. Following this, there would be continuous mining of the hard, dense silcrete layer that overlays the kaolinised granite, and then removed by truck. Subsoils, lateritic gravel and silcrete would be stockpiled separately for later re-use in closing cells (see Backfilling of cell – hazardous waste). The location of sub surface soil and laterite stockpiles are shown on Figure 1-3.

The kaolinised granite would then be recovered by conventional earthmoving equipment, i.e. scrapers, excavator and trucks. Based on drilling results, the kaolinised granite is very dry at approximately 10% moisture, and is free-digging. The kaolinised granite mining plant fleet would likely consist of a continuous miner, front-end loader, excavator and articulated dump trucks and scrapers for near-surface material. The dump trucks would deposit the kaolinised granite in stockpiles adjacent to the pit (seeError! Reference source not found.Figure 1-3).

Screening

A mobile double-deck screening plant will likely be contracted on a campaign-basis to screen kaolinised granite for use in the waste immobilisation plant (WIP, see section 2.3.3). Up to 180,000 tonnes of screened material may be consumed for immobilising liquid wastes annually. However, screening campaigns may process twice this amount to stockpile material for two years of WIP operation.

A mobile screening plant will likely be contracted during construction of the Sandy Ridge Facility. It is assumed that the plant used during construction will be of the same specifications as the plant(s) used for campaigns during operations (see section 3.1).

2.1.4 Excavation to the pit base

The elevation of the base of the pits would vary depending on the location of the mineral resource and the elevation of the top of the saprock. Mine-planning activity would ensure that at least 5 m of kaolinised granite remains in situ between the bottom of the pit and above the top of the unweathered granite. This would be achieved through mine planning drilling. The location of each drill hole would be surveyed so that any hole penetrations within the mining pit areas would be known, and any locations where ‘over-drilling’ below the pit floor elevation has taken place would be carefully backfilled with compacted kaolinitic material. This process would ensure that the drilling activities do not provide potential contaminant pathways in the unweathered granite if, in the unlikely event, a contaminated plume was ever generated from the cells.


2.1.5 Transition from mine pit into waste cell

In a typical cycle, one new mining pit would be excavated with the mining activities being scheduled to finish just prior to the previous pit (now a waste cell) being completely filled (refer to Figure 2-4). This would minimise the time that a completely mined pit would remain open to the weather. All surfaces within the pit would be graded to manage any precipitation which would run-off to an in-pit sump. The in-pit sump would be maintained in a dry state by a diesel powered portable pump, discharging to a settlement sump at surface level.

Figure 2-4 Normal sequence of mining and waste isolation

2. Roof canopy located over

mine void, cell partially filled

with waste

3. Excavation of next mine pit commences

4. Final filling and initial

compacting of waste cell with a

kaolin seal

5. Roof canopy relocated over new mine void

while remainder of cap is

completed.

1. Mine pit excavated


2.2 Class IV and V waste operations The framework for accepting hazardous and intractable wastes (Class IV and Class V) at the Sandy Ridge Facility are underpinned by the following key documents:

• Waste Acceptance Policy.

• Waste Acceptance Criteria (WAC – see Appendix 2: Waste Acceptance Criteria).

• Waste Acceptance Procedure (WAP – see Appendix 3: Waste Acceptance Procedure).

• Waste Zoning Guide (WZG – see Appendix 4: Waste Zoning Guide).

Details of each document are briefly discussed below.

2.2.1 Waste acceptance policy

The Tellus corporate Waste Acceptance Policy outlines the scope and function of the WAC, the WAP and the WZG that will be implemented at each operating site, including the Sandy Ridge Facility. The Waste Acceptance Policy also summarises International, Commonwealth and State legislation, codes of practice and guidelines that are applicable to near surface geological repositories.

2.2.2 Waste acceptance criteria

The objective of the WAC is to establish and explain to regulators, customers and other stakeholders:

• The criteria that would be applied for the exclusion of certain types of wastes.

• The criteria that would be applied to the acceptance of certain types of wastes.

• The requirement for suitable packaging and the criteria that would be applied for packaging acceptance.

The proponent’s WAC established for the Sandy Ridge Facility, lists waste types which can and cannot be accepted to achieve safe operation and environmental protection in the longer term at the Sandy Ridge Facility (Appendix 2: Waste Acceptance Criteria).

The facility has been located and designed to store and dispose of the majority of the NEPM 75 hazardous and intractable wastes types, subject to them meeting strict WAC. These criteria have been developed with the aim of using internationally recognised best practice and set out waste characteristics which would and would not be suitable for storage or disposal in a near surface geological repository.

Table 2-1 lists the top 10 main wastes likely to be accepted at the Sandy Ridge Facility using the NEPM 15 and NEPM 75 descriptions. For planning purposes, the proponent is assuming the top 10 waste type may account for approximately 90 % of the waste volume at Sandy Ridge.


Table 2-1 Top 10 waste types likely to be accepted at the Sandy Ridge Facility

NEPM 15 Description NEPM 75 Description N Soil / sludge N205 Residues from industrial waste

treatment/disposal operations N Soil / sludge N120 Soils with controlled waste N Soil / sludge N150 Fly ash, excluding that generated from

Australian coal fired power stations N Soil / sludge N220 Soils with asbestos J Oils J120 Waste oil and hydrocarbons mixtures D Inorganic chemicals D220 Lead compounds C Alkalis C100 Basic solutions or bases in solid form D Inorganic chemicals D110 Inorganic fluorine compounds excluding calcium

fluoride (Spent Pot Liner) D Inorganic chemicals D230 Zinc compounds n/a NORM n/a NORM

Figure 2-5 below describes the potential volume and type of waste by NEPM 75 code that may be accepted at the Sandy Ridge Facility. The top 10 main wastes that the proponent is using for planning purposes account for the majority of the waste volume. Figure 2-5 also illustrates, the facility is mostly a chemical hazardous waste facility (approximately 93%), but is also applying to accept around 6% NORM and sealed radioactive sources (SRS) up to LLW classification (1% volume).

Figure 2-5 Potential volume and type of waste by NEPM code that may be accepted at the Sandy Ridge Facility

Waste packaging for transport, storage and permanent isolation will be suitable for the type of waste and form or transport, storage and isolation. Packaging must fulfil criteria listed in section 3 of the WAC (Appendix 2: Waste Acceptance Criteria). These were developed by Tellus on consideration of the Mt Walton Intractable Waste Disposal Facility packaging requirements. These are consistent with industry best practices and are compliant with the Australian Code for the Transport of Dangerous Goods by Road and Rail (2016).


Examples of suitable waste packaging are illustrated in Figure 2-6.

Figure 2-6. Examples of suitable waste packaging for transport to Sandy Ridge.

2.2.3 Waste acceptance procedure

The WAP (Appendix 3: Waste Acceptance Procedure) describes how Tellus will assess a waste stream against the WAC to determine whether it is acceptable for disposal at the Sandy Ridge Facility. Three levels of assessment, each involving sample testing, are:

• Level 1 – Basic Characterisation

• Level 2 – Compliance Testing

• Level 3 – Onsite Verification.

This approach ensures that:

• Only materials that can be safety handled are delivered.

• The waste customer is aware of the appropriate packaging and transport standards that need to be met for acceptance of the waste.

• Staff are prepared for all waste deliveries and can immediately assess delivered waste to ensure that it is suitable.

In addition to considering the specific characteristics of the waste, consideration would also be given to how the wastes would perform in the conditions of storage and permanent isolation. This assessment would be performed by a senior chemist who has the necessary skill in determining such matters.


If the waste meets the WAC, a Dispatch Confirmation Notice (DCN) would be issued to the waste owner to agree that the waste can be transferred to the Sandy Ridge Facility.

Compliance testing

When waste has been deemed acceptable on the basis of a basic characterisation it shall subsequently be subject to compliance testing prior to shipment to Sandy Ridge Facility. If the results of the compliance testing verify that the critical parameters of the waste are consistent with the basic characterisation of the WAC, it can be transported to Sandy Ridge.

Onsite verification

Each load of waste delivered to Sandy Ridge shall be visually inspected before and after unloading, and the required documentation shall be checked. This will be carried out in the hazardous waste inspections bays (see area 5 in Figure 1-6) or in the radioactive waste inspection bays (see area 8 in Figure 1-6), depending on the nature of the incoming waste.

The waste may be accepted at the Facility; if it is the same as that which has been subjected to basic characterisation and compliance testing, and which is described in the accompanying documents. If this is not the case, the waste will not be accepted and will be quarantined. Tellus will determine the testing requirements for on-site verification, including where appropriate rapid test methods.

2.2.4 Waste zoning guide

Upon acceptance and delivery to Sandy Ridge Facility, wastes will be handled and stored in compliance with the WZG to prevent dangerous interactions between incompatible wastes (Appendix 4: Waste Zoning Guide). Segregation would be achieved by storing and handling incompatible goods in separate areas and/or by the use of physical barriers or distances within the same area, in accordance with the Dangerous Goods Safety Act 2004.

Tellus’ guidance for segregating incompatible dangerous goods will follow the Australian/New Zealand Standard AS/NZS 3833 The Storage and Handling of Mixed Classes of Dangerous Goods in Packages and Intermediate Bulk Containers which is referenced in the code of practice1 which, in turn, supports the National Standard. The proponent would adopt the segregation protocols presented in AS/NZS 3833 for all waste materials that are stored onsite prior to in-cell permanent isolation or storage.

Systems and procedures will be developed and enforced, and personnel involved in the storage and handling of hazardous or dangerous goods will be trained and supervised to ensure segregation is maintained at all times.

Further information on chemical and LLW zoning is provided in the WZG (see Appendix 4).

1 Page 29 The National Code of Practice for the Storage and Handling of Workplace Dangerous Goods NOHSC:2017(2001)


2.2.5 Waste management process

Tellus’ waste management process is shown in Figure 2-7. The process commences when a waste owner requests to send waste to the Sandy Ridge Facility. The waste owner would be requested to complete a pro forma (see Figure 4-2 in the WAP: Appendix 3: Waste Acceptance Procedure) which would provide details on:

• Origin of waste (indicate name of waste-producing facility).

• Identify/describe intractable or hazardous waste constituents.

• Classification and coding under the NEPM.

• Volume and weight of package(s).

• Description and quantification of waste form (solid, sludge, liquid or gas) and applicable material safety data sheets (if available).

• A comprehensive chemical analysis of representative samples performed by a National Association of Testing Authorities certified laboratory.

• Description of previous treatment/conditioning.

• Radiation dose rate on the surface of any packaging.

• Presence of alpha emitters, if any.

• Concentration of radioactivity as Becquerels per kilogram (Bq/kg) or Becquerels per cubic metre (Bq/m3) and/or total radioactivity.

• Description of package and container.

• Any specific additional information advice, especially procedures and warnings related to accidental damage to the container.

• Transport mode and request for transport contractor approval.

• Requested date for delivery to Sandy Ridge (if approved by Tellus Holdings).

Tellus will assess the customer enquiry against the WAC and will determine whether to enter into a Waste Supply Agreement (WSA) with the customer and if so, what conditions to include in the Agreement. Conditions could address issues such as sampling by an independent National Association of Testing Authorities of Australia (NATA)-accredited third-party and compliance testing and scheduling.

If all three levels of Upon signing of a WSA, Tellus will issue a DCN


Figure 2-7 Waste Management process flow chart


Waste transport

Along with the DCN, Tellus will notify the waste owner of the packaging and transport standards that the waste owner must comply with. These standards would be in line with best practice which is currently defined in the following documents:

• Packaging of waste for transport to the facility must be in accordance with the Australian Code for the Transport of Dangerous Goods by Road and Rail (Australian Dangerous Goods Code; Commonwealth of Australia, 2016, edition 7.4) for all dangerous goods, with the exception of radioactive material.

• All radioactive materials must be transported in accordance with the Code for the Safe Transport of Radioactive Material (ARPANSA, 2014b) and the Radiation Safety (Transport of Radioactive Substances) Regulations 2002 (WA) or applicable legislation in each state/territory through which the waste is transported.

• Transport arrangements would conform to the Environmental Protection (Controlled Waste) Regulations 2004 and equivalent legislation in other states and territories and the NEPM.

The customer’s pro forma and the DCN would be logged in an electronic document management system.

Waste receival

Figure 2-8 shows the conceptual Sandy Ridge Facility Process flow. The process of waste receival is described below.


Figure 2-8 Conceptual Sandy Ridge Facility process flow diagram


Front gate processes

On entering the site, the consignment’s waste documentation/DCN would be reviewed at the front gate. The exterior of the truck and containers and non-containerised bulk items would be inspected at this point. In the event of NORM and LLW deliveries, external surface levels of radioactivity would be measured.

If the documentation is not present or is incomplete, Tellus would be unable to confirm that the packaging and transport standards have been met, and the truck would either be turned away from the facility or directed to a quarantined hardstand (temporary yard) area while any uncertainties or discrepancies are resolved between Tellus and the waste customer.

If the documentation meets packaging and transport standards as per the WSA and the WAC, trucks with containers would proceed through the gate to the waste storage area.

Immediately after the gate is the drive through radiation detector. The detector will be calibrated to measure radiation levels and indicate go/no-go according to a pre-set threshold. If the truck is flagged as not containing radioactive waste, the truck is to proceed as directed. If the truck is flagged as carrying radioactive waste, it is to be halted and escorted to the radioactive waste inspection bay or radioactive unloading area for further investigation and action.

Trucks with non-containerised bulk items that require no further inspection can continue through site to a hardstand for scheduled direct placement into the cell.

Hardstand and hazardous waste inspection area

Trucks would drive from the front gate to a hardstand temporary yard. Hazardous wastes will go to the hazardous waste inspection bays, while radioactive wastes will be delivered direct to the radioactive warehouse area (refer to Figure 1-6). The following process occurs in both inspection areas.

Consignments would be weighed using a reach stacker fitted with a weightometer. At this point the waste would be considered delivered, but not accepted. Shipping containers would be removed from the truck and externally inspected in accordance with operational procedures, and may remain unopened on the hardstand for a period of time to suit the current activities at the site.

The truck would pick up empty shipping containers and could leave the facility after being inspected for cleanliness. Vehicle washdown facilities are available if inspection has identified possible contamination (see section 2.3.7).

From the hardstand, the following steps would occur:

1. The transport waste container would be moved to the waste inspection area, where the container would be placed on the concrete floor of the inspection bay and inspected.

2. The inside of the shipping container (or other transport container e.g. drums for radioactive waste) would be inspected to check for damaged/leaking waste packages (this may require


removal of some packages). If they are found to be in accordance with the WAP, a selection of waste packages can be removed for Level 3 verification testing. The waste package would be audited against the customer’s pro forma to confirm the volume and type of waste delivered is as described in the customer’s documentation. The outcome of the review of documentation would be:

a. If the documentation is incomplete or does not match the waste that has arrived, the package would be held pending liaison with the waste customer.

b. If documentation is complete, the waste packages would be inspected for damage and leaks. If the packaging is damaged significantly the pallet would be held whilst a solution is agreed between Tellus and the waste customer. Any damaged or leaking waste package would be made safe as soon as possible to minimise worker or environment exposure to the waste. The waste package would be ‘made safe’ in accordance with the methodology outlined in the facilities Operating Strategy. Contaminated shipping containers will be cleaned in a bunded facility (see section 2.3.2).

Please note, an outline Operating Strategy was included in the Sandy Ridge PER and is currently being updated by Tellus. It can be made available to DWER upon request.

3. The samples would be tested as described in the Operating Strategy (see above) and confirmed that waste matches documentation.

4. The removed waste packages would be repacked and the shipping container closed, and transferred to the Container Storage Yard (CSY).

5. The shipping container remains in the CSY until it is scheduled to be moved into the waste cell.

6. When scheduled, liquid or sludge type wastes are either transferred to an evaporation pond to be reduced in volume, or transferred directly to the WIP.

Each container would be tracked and logged in an electronic record system which forms part of Tellus’ Enterprise Resource Planning system2. This will tack waste through each handling stage so that its location is known and can be communicated to the regulator or customer, if requested.

For bulk solid items (such as sleepers, and piping) the load would be inspected and sampled in the truck before being unloaded into a bulk storage building, vessel, tank, hopper, covered bunker or hardstand area. The frequency of inspection and sampling of waste packages would be adjusted over time as confidence increases in the consistency and reliability of deliveries from any particular customer.

2 Tellus’ proposed internal business system


Above-ground temporary storage

Wastes will arrive in appropriate waste packaging (see section 2.2.2) as per transport requirements. for temporary storage. After inspection and/or verification testing and treatment (refer to Figure 2-7) palletised packaging (i.e. drums or other packaging secured to pallets) will be transferred to shipping-containers which will be placed in the above-ground temporary storage area (CSY).

The Container Storage Yard is to be used to store containers within their nominated waste groups (as per the WZG see Appendix 4: Waste Zoning Guide) pending either delivery to the waste disposal cell, laboratory sampling, laboratory sampling test results or storage of empty containers awaiting removal from Site. Tellus will also have ownership of a number of containers that will be used for local site transportation of waste, these containers will also be stored within the CSY.

Waste treatment or conditioning

The WAP allows for some liquids and sludges to be accepted at Sandy Ridge. The wastes will be fully characterised during the Level 1 Basic Characterisation to ensure that they can be safely treated in the WIP, prior to issuing the waste supply agreement.

Evaporation ponds may be used to reduce the volume of water-based liquid waste types before blending with absorbent materials in the WIP. Deliveries of suitable liquid wastes would be discharged from the delivery vessel on a sealed and bunded area, with the liquids flowing by gravity into the pond. Two ponds will be used to increase the evaporation surface area and to allow one pond to be taken off-line periodically for cleaning of any settled solids.

As the evaporation pond liquids concentrate through evaporation of water, concentrated liquor will be withdrawn by pump and transferred by double walled pipe to the WIP or into an ISO tank vessel if required. Settled solids (when cleaned out) will be disposed of as a sludge or slurry through the WIP.

The objective of the WIP is not to chemically denature the waste but to convert it into an immobile state which binds the liquid phases with a combination of kaolin and or cement. Cement will be purchased from a third party and stored onsite. The treated solidified waste can then be deposited into a cell where it will no longer pose a risk of subsidence or free liquid discharge.

The likely processes for waste treatment or conditioning that may be implemented at the Sand Ridge Facility are described below. The proponent would safeguard that the pre-treatment processes do not result in unacceptable emissions or discharges to the environment.

• Oily sludge - Hydrocarbon sludge containing NORM and/or heavy metals cannot always be recovered or safely disposed of using existing treatment processes such as biodegradation, oxidisation, stabilisation or incineration.

Oily sludges would be delivered in either intermediate bulk containers inside shipping containers, or as bulk liquids in a tanker truck, with the former being more likely. Oily sludges would be stored until such time as they are ready to be placed in the cell. The oily sludge would then be mixed with controlled measures of binding and immobilising materials such as


kaolinized granite or cement, to produce a cement-like slurry which would either be placed directly into the waste cell or in disposal packages. The direct placement slurry would be allowed to set in-place in the cell and later backfilled with kaolinised granite.

• Non–oily liquid and sludge - Other wastes in either liquid or sludge form would ideally be reduced in volume, filtered or dried before delivery to the Sandy Ridge Facility, preferably by an existing waste management contractor. In the event of some liquid wastes not being able to be treated or only being partially treated (to a sludge), immobilisation treatment would be provided for these wastes using kaolinized granite and or cement. Immobilisation would typically take place with both materials being added to a mixing device.

In the event of drums of waste being delivered where a liquid has separated in transport from a paste, absorbent material would need to be added into the drum or container to absorb the released liquid before the waste can be placed in a cell.

• Radioactive waste (sealed radioactive sources [SRS]) - SRS would be received at site and stored in the radioactive waste area, in the form which they were transported. No further processing of SRS takes place at the site. Packaged wastes are transferred to the borehole disposal shaft (see Figure 2-12) or radioactive waste isolation cell (see Figure 2-14).

• Radioactive waste (NORM and other) - Material containing NORM may require conditioning or treatment to achieve a physical form suitable for placement in a cell (refer to ‘oily sludge’ and ‘non-oily liquid and sludge’ above).

NORM or radioisotope contaminated solid materials may require any voids to be filled with kaolinitic material or cement grout either prior to placement or once in the cell. Examples of such materials could include piping, process machinery, demolition rubble and personal protective equipment.

Cell planning and inventory assessment – storage of like with like

Sea containers would be stored on the hardstand until that waste type is ready to be placed in the cell in accordance with the cell scheduler. Bulk materials would also be stored until required in the cell.

The cell scheduler is an electronic planning and inventory assessment tool to effectively manage space within the cell and to ensure the entire batch of a certain type of waste (e.g. arsenic), can be placed in a designated location within the cell that is ready to receive the waste. The cell scheduler would be integrated with the electronic records system so that each waste package is tracked and its location and depth within the cell logged with a survey coordinate.

The electronic records system would track each waste package from the point where it is accepted on-site until it is placed in the cell. An example of the cell scheduler and tracking system integration is shown in Table 2-2 while Figure 2-9 illustrates how different waste types are intended to be physically separated within the waste cell i.e. in a ‘like for like manner’.


Figure 2-9 Placement of wastes within the waste cell and a roof canopy covers the cell

Different waste types


Table 2-2. Example of cell scheduler for tracking of waste from sorting to placement and storage of ‘like with like’.

Scheduled date for placement

Scheduled time for placement

Shipping container

No

Package ID (number from

tracking system)

Contents Cell for storage/isolation

Layer and Section in

Cell

Actual date of placement

Actual time for placement

RFID/barcode Surveyor Survey coordinates of boundaries of stored

waste (MGA94)

Elevation (mAHD) of

waste

Date of isolation

10 Oct 2017 9 am 1 D2009-001-001 Arsenic trioxide

2017 – Cell 2 Layer 2 – Section M

10 Oct 2017 9.20 am D2009-001-001

DH 220,001 6638000

472 10 Jan 2018

9 am 1 D2006-003-002 Arsenic trioxide

2017 – Cell 2 Layer 2 – Section M

10 Oct 2017 9.30 am D2006-003-002

DH 220,001 6638000

472 10 Jan 2018

9 am 1 D4009-129-003 Cyanide 2017 – Cell 2 Layer 2 – Section M

10 Oct 2017 9.40 am D4009-129-003

DH 220,001 6638000

472 10 Jan 2018

21 Oct 2018 10.30 am 2 X3456-222-001 Solidified pesticides

2018 – Cell 1 Layer 3 – Section G

21 Oct 2018 10.30 am X3456-222-001

AS 220,001 6,639,000

480 21 Nov 2018

10.30 am 2 F4567-204-002 Solidified pesticides


21 Oct 2018 10.45 am F4567-204-002

AS 220,001 6,639,000

480 21 Nov 2018

10.30 am 2 G3450-765-003 Solidified pesticides


21 Oct 2018 10.55 am G3450-765-003

AS 220,001 6,639,000

480 21 Nov 2018

10.30 am 2 H4367-765-004 Solidified pesticides


21 Oct 2018 11.30 am H4367-765-004

AS 220,001 6,639,000

480 21 Nov 2018


When the cell scheduler indicates that a particular container is scheduled for placement, it would be loaded onto a waste haul ADT and driven into the cell. The shipping container would be removed from the waste haul ADT and placed on the floor of the cell adjacent to the designated disposal and isolation area.

The shipping container would be opened and the pallets of waste packages removed in accordance with the Operating Strategy.

There are situations where an entire shipping-container would be placed in a cell. In this case, holes would be cut into the roof, cement grout or concrete poured in place (to remove airspace) and the filled container would then be buried with its contained waste.

Bulk material in a form suitable for placement would be transported from the surface storage area to the cell by an ADT when required and placed directly into a cell.

Prior to unpacking shipping containers into the cell, the roof canopy would be in place. The roof would run on rails or wheels and would cover the full length of an active waste cell. The purpose of the roof canopy would be to exclude water from the cell until it is capped, to avoid the generation of leachate within the cell and avoid any potential structural impacts that may affect the integrity of the cell walls. There are some waste types which may be placed in a cell without a roof as the materials being placed are not immediately leachable, such as some contaminated soils and contaminated railway sleepers. Whilst the cell is under construction, it would be designed with a drainage sump to enable pumping-out of any direct precipitation.

Radioactive LLW would be managed separately from other wastes and would have a dedicated shaft constructed either within the cell (refer to Figure 2-10 and Figure 2-11) or in a purpose-made borehole (see Figure 2-12). Handling of all radioactive materials would be in accordance with a Radioactive Waste Management Plan which will be developed after detailed design and in accordance with the requirements of the site registration by the Radiological Council under the Radiation Safety Act 1975. Equipment and larger objects may be filled with kaolinitic material or cement grout/concrete either prior to placement in the cell, or in situ.

Shaft placement would normally be reserved for higher activity LLW. In general, (though dependent upon activity and isotope presence), NORM would not be placed in shafts; rather, they would be placed in a designated area in the open area of the waste cell. Whenever possible, the cell layout would have all shaft storage of radioactive materials at one end of the cell, with the adjacent space used for NORM, and hazardous wastes in the rest of the cell.

Survey coordinates of each placed waste package or area of bulk waste placement would be recorded. Each section of the cell would be surveyed and depths of stored waste updated in the electronic records system. Once the waste customer’s shipping container or bulk materials have been placed in the cell, a Placement Certificate would be issued to the waste customer.


Waste placement in Cell

Waste packages would be contained within the kaolin mine void. The base and walls of the void would comprise kaolin clays which are naturally of low permeability. The natural kaolin would effectively act as a liner as this material is present in a significant thickness and is more impermeable in the long-term than a synthetic liner (e.g. high-density polyethylene [HDPE], geomembrane or concrete), which would break down and disintegrate over geological time (i.e. 10,000 years).

The waste cells would be filled in layers with multiple sections in each layer containing wastes of similar characteristics (to segregate the different waste types). Waste types would be placed ‘like-with-like’ for safety reasons and for potential future recovery (if identified as potentially valuable). All space between waste packages would be backfilled with kaolinised granite and compacted to minimise air or void space. Small amounts of liquid will be added to aid compaction. If this approach is not taken it may result in settlement which could impair the performance of the cell cap. Each layer would be compacted, until approximately 7 m below the ground surface, where a thick capping layer of low permeability clay (referred to as a ‘seal’) would be installed to prevent water ingress into the cell. Following this, more compacted backfill and a clay domed cap would be situated on the top of the cell, to shed any landing rainfall.

Figure 2-10 illustrates how co-disposed hazardous and radioactive wastes would be contained within the cells. The conceptual design of the cells has been independently reviewed by Eden Nuclear and Environment of the United Kingdom (refer to Appendix A23 of the PER). The review concluded “that the design of the Sandy Ridge Facility is excellent and that the proposed multibarrier system offers very good prospects of excellent long-term performance that would be comparable or in excess of that for many other LLW isolation facilities in other countries. This is facilitated by the favourable hydrological and hydrogeological environment”. Recommendations were made for further investigations with respect to the outline safety case and activity concentrations of LLW. These recommendations have been addressed in the WAC and WZG documents.

The encapsulation of wastes within each cell would be subject to rigorous engineering design and compaction testing to ensure the properties of the constructed cell is a close analogue of the existing geological and hydrogeological conditions at the site, which naturally excludes water from the kaolinitic soils located beneath the silcrete layer. A feature survey of the cell would be conducted to confirm the cell is constructed in accordance with the engineering design.


The bottom of the mine void would be a minimum of 5 m above the unweathered/fresh granite bedrock or any detected free water.

A base layer of waste is placed on one side of the floor of the mine void. Wastes of different types are segregated by internal compacted kaolin walls which are typically 3 m wide. The height of each waste layer and barrier wall is the equivalent of the height of a waste package, typically 0.9 metres. Waste packages are placed tightly next to each other in a row. Granular material is backfilled between and around the waste packages to fill any air spaces. The shafts for radioactive waste are constructed approximately 3 m apart from each other and with a 3 m barrier between the shafts and the chemical waste layer.

A thin (300 mm) layer of compacted granular material is placed over the chemical waste layer. Compaction testing would be carried out in accordance with AS1289.5.8.13 to confirm material is compacted to the density required by the engineering design. The next layer of chemical waste packages is placed on the kaolin compacted layer along with the three metre wide kaolin separation barrier. The shafts for radioactive waste continue to be constructed.

A three metre thick capping layer of kaolin is compacted onto the second waste layer if waste of an incompatible type is to be placed immediately above. The shafts for radioactive waste continue to be constructed.

3 Australian Standard for testing soils for engineering.

>5m

Chemical waste

Radioactive waste shafts

5m 3m clay


The next layer of waste packages is tightly placed on the thick capping layer and backfilled with granular material to exclude air pockets and voids. The separation barrier is maintained in the middle of the cell. The radioactive waste is lowered into the shafts. Between each radioactive waste package, a 200 mm millimetre layer of kaolin is compacted into place.

A thin (300 mm minimum) layer of compacted granular material is placed over the chemical waste layer. Compaction testing would be carried out in accordance with AS1289.5.8.1 to confirm material is compacted to the density required by the engineering design. The next layer of chemical waste packages is placed on the kaolin compacted layer along with the 3 m wide kaolin separation barrier. Radioactive waste continues to be lowered into the shafts. Between each radioactive waste package, a 200 mm layer of kaolin is compacted into place.

A 3 m thick capping layer of kaolin is compacted onto the fourth waste layer if waste of an incompatible type is to be placed immediately above. Radioactive waste continues to be lowered into the shafts. Between each radioactive waste package, a 200 millimetre layer of kaolin is compacted into place.

A fifth layer of waste is placed in the cell. Concrete lids are fitted into each radioactive shaft. A 3 m thick kaolin cap is placed on the waste packages and concrete lids and is keyed into the surrounding silcrete and clay.

A 4 m thick layer of compacted crushed silcrete and laterite material, with some kaolinised granite or clayey sand is placed between the kaolin cap and the natural ground surface.

Radioactive waste


The compacted kaolin clay dome cap is placed over the cell. The final capping layer is formed of compacted kaolinised granite material (permeability approximately 6.0 x 10-8 m/s) and placed in the form of a dome, so as to shed stormwater from the structure into perimeter V drains, which flow to a sump. The cap would have a 1:20 gradient and be an approximate thickness of two metres in the middle, thinning as it slopes to integrate into the landscape. Subsidence monitoring of the cap would commence.

Excess kaolinised granite, subsoil and topsoil is replaced on the cap after the cessation of subsidence monitoring.

Figure 2-10 Cell containment of hazardous and radioactive wastes

The protection of water quality has been considered throughout the cell design, which specifically incorporates the following features to avoid water entering the cell:

• No liquids would be placed in the cell unless absorbed into kaolinised granite such that no free liquid can be generated.

• A roof canopy over the cell prevents rainfall directly into the cell while it is open.

• The roof canopy is guttered to collect and dispose of collected rainwater. This will drain to the Cell Area settlement sump (see Figure 1-3. Proposed Sandy Ridge site layout.).

• Operational mine safety bunding around each cell prevents the entry of surface water flow while the cell is open (such flows only occur in extreme rainfall events).

• The absence of a highly impermeable HDPE or concrete seal allows natural and gradual venting of any minor quantities of gases (should they be produced) without pressure damage to a man-made liner or cap system.

• Wastes are stored below ground level (and well below silcrete level) which reduces the likelihood of erosion ever exposing waste.

• The natural topsoil/subsurface soil, thick clay domed cap and the compacted clay layer at approximately four to seven metres depth minimises water ingress and erosion. Based on


modelling results, net recharge to the topsoil/subsoil is 1.4 mm per year. Vertical flow below the cap is 0.8 mm per year, into the compacted silcrete and laterite backfill to the compacted kaolinised granite seal/layer. Below this layer the rate of water movement is 0.008 mm per year. These vertical fluxes are extremely low, illustrating that the risk of water ingress into the cell is negligible.

Borehole disposal of sealed sources

Tellus is proposing to use two methods to isolate/dispose of sealed radioactive sources; in a segregated shaft within a waste cell (see LLW shaft packing), or in boreholes separate from waste cells. The method of disposing SRS in boreholes is described in IAEA technical document “IAEA-TECDOC-1644 BOSS: Borehole Disposal of Disused Sealed Sources”. This method is illustrated in Figure 2-12.

Tellus is liaising with the Radiation Health Unit and the Radiological Council as part of the Sandy Ridge registration application under the Radiation Safety Act 1975 to assess the benefits and management of using the borehole disposal method (IAEA, 2011).

Under the Borehole disposal of sealed radioactive sources (BOSS) method, an area in the northern-most section of the cells area where the kaolinized granite is deepest would be set aside for a series of boreholes into which containerised sealed sources would be placed. Boreholes would be developed using dry drilling methods, creating a shaft between 20-30 m deep. No less than 5 m of kaolinized granite below the shaft would be retained as a buffer to the granite bedrock (refer to Figure 2-3). Locations of boreholes would be recorded in the Sandy Ridge electronic tracking system.

Sealed sources meeting the Sandy Ridge WAC would be conditioned by the waste generator and their specialist contractor off-site at an appropriately registered facility prior to shipment to Sandy Ridge. Conditioning is the process of placing of disused sealed sources into a lead capsule commonly referred to as a “pig”. The purpose is to physically protect the sealed source from damage and radionuclide release and to provide standard-sized packaging that can be easily handled for transport.

When the “pig” is delivered and accepted at Sandy Ridge, it would be placed into the Disposal Package. The Disposal Package is larger 316 L4 stainless steel container, into which the “pig” is placed to allow it to smoothly slide down the borehole. Each borehole can house multiple Disposal Packages, each separated vertically by a plug of bentonite clay.

At the top of each borehole, a Deflection Plug will be installed at a nominal depth of between 2 – 3 m below ground level, within a layer of silcrete. A Deflection Plug is a 316 L stainless sleet cylinder

4 316L stainless steel is a type of stainless steel that is enhanced with addition of molybdenum to provide superior corrosion resistance compared to 304 stainless steel.


filled with cement and closed at each end. The top end is sloped such that it would deflect an unwitting drill bit before it could intersect Disposal Packages further down the borehole.

Figure 2-11 shows an example of a “pig”, the proposed Disposal Package and Deflector Plug designs. The remaining 2-3 m of borehole above the Deflection Plug will be backfilled with local soil material.

Boreholes would be spaced on a 2.5 m x 2.5 m spacing to ensure the structural integrity of each borehole is not adversely affected by its neighbours. Figure 2-12. Borehole disposal of sealed radioactive sources (BOSS). shows the proposed borehole structure. Detailed records would be retained by Tellus of all sealed sources disposed of by this method, including their placement depth and lateral location.

Figure 2-11. Illustration of Disposal Package (right) and Deflection Plug (left).


Figure 2-12. Borehole disposal of sealed radioactive sources (BOSS).

LLW shaft packing

It is preferable that LLW of higher activity are not combined with hazardous waste storage; therefore, vertical shafts would be constructed within the cell from prefabricated concrete or steel liners surrounded by natural materials to provide shielding (refer to Figure 2-10).

A number of shafts would be constructed within a cell using pre-formed cylindrical shaft segments. As the cell is progressively filled in waste layers to approximately seven metres below the ground surface, more pre-formed segments would be stacked upon each other to create a shaft. A buffer of compacted kaolinised granite would be placed around each segment to provide further isolation from chemical waste at the same level (refer to Figure 2-13 and Figure 2-14).


Figure 2-13. Radioactive waste storage (shaft in cell).

Radioactive waste could be placed into the shaft at any time, but it is expected that the placement of hazardous chemical waste and pre-fabricated shaft segments surrounding the shafts would progress to several metres of depth before radioactive waste placement occurs, so as to provide vertical physical separation between the radioactive waste and workers on the active surface.

Radioactive waste packages would be lowered into the shaft and then backfilled with kaolinitic material to fill void spaces. Higher activity wastes may be backfilled with concrete slurry. A substantial pre-fabricated lid would be emplaced as a temporary cap on top of placed radioactive waste in the shaft to prevent un-authorised access or incidental exposure. When the shaft is filled with waste to the base of cap level (approximately seven metres below ground level), a permanent lid would be put in place and the structure covered by the cell cap materials as described previously.

LLW waste storage

placed inside concrete

shaft located within the waste cell


Figure 2-14. Conceptual design of low level radioactive waste isolation shaft in cell.


Backfilling of cell – hazardous waste

Once the base layer of waste packages is in place, granular material would be backfilled to completely fill any voids between the waste packages. This would be done to minimise the risk of subsidence or settlement of the covering material, creating a solid structure with no voids. Additional granular backfill would be placed on top of the completed layer of waste packages, compacted sufficiently to allow the safe movement of vehicles without damage to the waste packages below. Additional layers of waste would be stored then backfilled and compacted in the same manner. Compaction will be aided by the addition of liquid and testing would be carried out in accordance with AS 1289.5.8.1–2007 Methods of testing soils for engineering purposes – Soil Compaction and density tests – Determination of field density and field moisture content of a soil using a nuclear surface moisture density gauge – Direct transmission mode.

Following the placement of the final waste layer, capping layers are used to fill the remaining void and cover the completed waste cell. This would occur at approximately 7 m below the ground surface. These serve to provide a barrier:

• Between the waste materials and the surface.

• To prevent water infiltration.

• To prevent erosion.

Initially kaolinised granite would be used for this layer. Compacted kaolinised granite material has a permeability of approximately 6.0 x 10-8 m/s (Douglas Partners, 2015) and would be 3 m thick. When kaolin processing is established (not the subject of this application) waste kaolin from the kaolin refining circuit would be used as the seal (first capping layer). This material has a compacted permeability of approximately 3.0 x 10-8 m/s (Douglas Partners, 2015) and would be 3 m thick.

The roof canopy is moved to the next cell after the second complete lift (600 mm ) of the capping layer is placed over the waste. Prior to removing the roof an internal temporary sump would be created in a portion of the cell and on top of the first 300 mm cap so that any stormwater can be contained and pumped from the cell.

The remaining thickness of backfill up to the surrounding natural ground level is filled with compacted crushed silcrete and laterite material, with some kaolinised granite or clayey sand material used if additional volume is required. This layer would be typically 4 m thick (refer to Figure 2-10).

The cycle then repeats, as required. Should the kaolin production and waste disposal activities increase in scale due to market demand, the frequency of this cycle would simply increase.

Cell dome capping

The final cell cap layer is constructed with a domed upper surface and is built from compacted kaolinised granite material with a permeability of approximately 6.0 x 10-8 m/s (Douglas Partners, 2015) and would be 2 m thick in the centre.


The dome is designed to shed stormwater from the structure into perimeter V drains, which flow to a settlement sump. The cap would be monitored for subsidence for a period of 10 years in accordance with the Waste Facility Decommissioning and Closure Plan (refer to Appendix A18 of the PER). Following the monitoring period, topsoil would be respread and seeded. Vegetation monitoring would be conducted for 10 years.

Cell revegetation

After 10 years with no signs of subsidence, overburden and topsoil will be replaced over the cell cap and will be seeded with local provenance plant species. A Rehabilitation Management Plan will be developed in consultation with the Department of Biodiversity, Conservation and Attractions (previously Department of Parks and Wildlife) and Department of Mines, Industry Regulation and Safety (previously Department of Mines and Petroleum).


2.3 Infrastructure description

2.3.1 Hazardous waste inspection area

The hazardous waste inspection area operates as the primary truck unloading area for all but radioactive materials and liquid wastes. These will be inspected in the radioactive and NORM waste area (see section Radioactive warehouse and container yard2.3.2).

The hazardous waste inspection area will allow for the loose storage and management of palletised / bulk / bagged (flexible intermediate bulk container - FIBC) solid waste. In addition, it will facilitate the sorting and management of compromised packaged waste; damaged packaging and/or packaging with greater than acceptable void space.

The waste inspection bays are intended to allow for the opening, evaluation and inspection of the waste packages that are shipped to site in a container. Generally, containers will be unloaded from incoming trucks onto the bays, or when the bays are already occupied, deposited into the temporary container area within the storage container yard. A minimum of two inspection bays are planned, allowing one for general use and another for general use or for problematic or compromised waste receptacles. A third bay may be constructed if throughput justifies the additional cost.

The covered bays will allow for containers to be opened and the contents inspected and sampled on a sealed concrete pad. As the wastes are solid and containerised, the facility will be a dry operation. In the event of a spill, cleanup will be via vacuum.

The design specifications of the waste inspection bays are listed in Table 2-3. The designed layout is shown in Figure 2-15.

Table 2-3: Hazardous waste inspection bay specification.

Criteria Requirements

Design Criteria • Covered area typically an awning as part of waste warehouse.

• Laden container lifter, forklift traffic, light vehicle (LV) and pedestrian allowances.

Construction • Rated for area.

• Concrete pad in work areas.

Equipment • Portable forced ventilation such as fans etc. via mobile ventilation units, as required.

Services • Potable water for safety shower and washdown.


Figure 2-15. Hazardous waste inspection bay designed layout.

Container storage yard

The CSY is to be used to store containers within their nominated waste zoning groups (refer to WZG in Appendix 4) pending either delivery to the waste disposal cell, laboratory sampling, laboratory sampling test results or storage of empty containers awaiting removal from site. Each container will be logged and tracked using the electronic records system.

The CSY will be designed such that stormwater will be directed to sumps which in turn will be gravity fed to the Retention Pond (see section 2.3.9).

Staging container storage area

The staging container storage area is used to store and coordinate waste that is ready for delivery to the waste disposal cell. Waste containers are to be organised to enable a dedicated heavy vehicle to transfer containerised waste to the waste disposal cell. Heavy vehicle operations are to all be one way with no crossover or interaction with any other onsite traffic (excluding container loaders).


Wheel/vehicle washing may be required for any vehicles that traverse between haul roads and the facility roads.

Temporary container storage area

The temporary container storage yard is used as an isolation area until waste identification is verified by the laboratory (Level 3 Onsite Verification as per the WAP, see Appendix 3: Waste Acceptance Procedure), after which storage (staging container storage area) or disposal operations are undertaken. This area may form part of the staging container area dependent upon the on-site management system.

Warehouse waste container yard

The warehouse waste container yard is used to store Tellus owned empty containers. Tellus owned containers are used for transferring warehouse stored waste to the waste disposal cell.

Upon return from the waste disposal cell the containers are cleaned (if required) at the container washdown facility (refer to section 2.3.8 for more information), prior to storage at the container return yard. This area may form part of the staging container area dependent upon the on-site management system.

Container return yard

The container return yard is used to store client owned containers prior to dispatch from site via recently unloaded road trains. Upon return from the waste disposal cell the containers are cleaned (if required) at the container washdown facility, prior to storage at the container return yard.

Quarantine container return yard

The quarantine container return yard is used when waste received on site does not meet the waste acceptance criteria and is required to be isolated and readied for return to the owner of the waste. It should be located close to the road train loading/ unloading so that if it is not cleared it can be quickly loaded onto a road train and removed from Site. This area may form part of the container return yard.

A section of the container storage yard may be set aside on a campaign basis for consignments of bulk waste items (e.g. contaminated sleepers or pipes) which do not require transport or storage in sea containers.

The design specifications of the container storage yard are listed in Table 2-4.


Table 2-4. Design Criteria for Container Storage Yard.

CRITERIA REQUIREMENTS

Design Criteria Area Quantity Staging Containers • (estimated 350) 20ft container

triple or double stacked

Temporary Container • (estimated 20) 20ft container triple or double stacked

Warehouse Waste Container • (estimated 20) 20ft container triple or double stacked (empty)

Container Return • (estimated 20) 20ft container triple or double stacked (empty)

Quarantine • 6 x 20ft container triple or double stacked

• Allowances for waste type zone segregation.

• Vehicles – laden container lifter, light vehicle and road trains.

Construction • Asphalt sealed (minimum) with demarcation for road train traffic to relevant areas.

• Contoured such that rainwater is directed to sump(s) and gravity flows to the Retention Pond (see section 2.3.9).

Other • Yard lighting and Closed Circuit Television (CCTV) oversight.

2.3.2 Radioactive warehouse and container yard

Transport trucks carrying radioactive waste will report to the radioactive area after initial screening at the Sandy Ridge front gate.

The radioactive area will be a purpose-built for receival and temporary storage of sealed sources, NORM and LLW solids and pastes. In addition, all liquids/ sludges, regardless of whether they are radioactive or not, will be inspected in the radioactive area and dispensed to the WIP.

The radioactive area will be designed and operated in compliance with the Radiation Safety Act 1975 (RS Act) and consistent with ARPANSA guidelines. A registration for Sandy Ridge Facility will be sought from the Radiological Council as is required under the RS Act. A detailed radiation safety management plan (currently in development) will be submitted to the Radiological Council for approval as part of the registration application and, eventually, a radiation permit. This section of the works approval application provides the general specifications of the radioactive area such as they relate to potential environmental pollution controls.

The radioactive area will be a controlled area, requiring security pass access, with 1.8 m cyclone fencing topped with three strands of barbed wire. The area will be fitted with radiation area


monitors and personnel will wear electronic personal dosimeters. The facility will consist of a truck unloading area, container yard, and a covered, concrete-slab warehouse with three sections:

1. Waste inspection bay. 2. Shredding and baling room. 3. Concrete bund for sludge/liquids to be dispensed to the WIP (see section 2.3.4).

The container unloading/storage area will have an asphalt surface over a concrete-strengthened basecourse. Earthworks design and the asphalt surface will direct surface water runoff to the WIP waste bund.

Wastes will be unloaded using a reach stacker with a weightometer and placed in the inspection bay for inspection and verification testing or, if the inspection bay is occupied, in a temporary storage area in the container yard. Wastes are not considered “accepted” at this stage.

Level 3 Verification Testing (refer to Figure 2-7 and WAP in Appendix 3: Waste Acceptance Procedure) for radioactive LLW wastes will include using hand-held Geiger counter to measure the emission levels to ensure they are consistent with the waste agreement and consignment manifest documents. If the consignment is found to be consistent with the waste agreement, the waste is considered “accepted”. It will then be either temporarily stored in the yard or treated in the WIP before placement in the waste cell.

Packaging requirements for NORM and LLW wastes are described in the WAC (Appendix 2: Waste Acceptance Criteria), including drums on pallets, International Organisation for Standardisation (ISO) liquid containers to packaging within shipping-containers. Upon acceptance in the Radioactive Area, solid wastes will be consolidated into shipping containers for temporary storage in the container yard until scheduled for placement in the waste cell. Similarly, sludges/liquids in IBCs will be temporarily placed into shipping containers until they are scheduled for treatment in the WIP.

Shipping containers that contain drums or IBCs containing sludge/liquid will be opened during the initial verification assessment. This task will be conducted in the inspection bay within the radioactive waste warehouse. The warehouse is designed with Colorbond® (or similar) roof and concrete slab floor draining to two concrete sumps; one sump in the inspection bay and one sump in the WIP waste bund area (see below). If a sludge/liquid container is found to have been compromised, it will be managed within this sealed area and any contaminated recovery materials will be packaged up for disposal in the waste cell.

Sludge/liquid wastes will remain in their transport containers until they are scheduled for treatment in the WIP. When schedule for treatment, they will be transferred in their container to a concrete bund called the WIP waste bund (see Figure 2-16). The WIP waste bund is located within the radioactive area but will be used to dispense both radioactive and non-radioactive liquid wastes to the WIP. Sludge/liquid containers will be connected to inbuilt pumps piped to the WIP (see section 2.3.3). This dispensing system of pumps and pipelines will be either fully bunded in concrete or sleeved (i.e. double-walled) to prevent spills, and will be manned at all times during operation.


The WIP waste bund drains to an in-built concrete sump which can also be pumped via pipelines to the WIP for treatment.

A facility to shred and bale used IBCs and wood pallets (both radioactive and non-radioactive) is incorporated into the Radioactive Area. Prior to shredding, IBCs will be flushed with clean water in the WIP waste bund. Potentially contaminated shipping containers will also be washed in this facility. Wastewater from washing IBCs / shipping containers and from cleaning down the shredding/baling facility will be contained in the sump and pumped to the WIP for treatment.

Surface water contamination is a very low risk in the radioactive area. Due to the strict nature of transport and storage packaging requirements, sealed-source radioactive wastes and solid wastes pose no threat of contamination in a storm event. Sludge/liquid wastes will be in ISO tank containers or packaged within sealed shipping containers while in storage. The radioactive area will drain to the sump at the WIP waste bund. Stormwater reporting to this sump will be treated in the WIP for disposal in a cell.

The design specifications of the Radioactive Area are listed in Table 2-5. The Radioactive Area designed layout, including the WIP waste bund, is shown in Figure 2-16.

Table 2-5. Radioactive Area design specifications.


Design Criteria Yard • Storage for a minimum of 16 shipping containers or ISO liquid containers

double stacked.

• Include covered area for container unloading, inspection and/ or packing – area should allow for at least 20 standard pallets to be unloaded and prevent any water ingress in the front of the container.

• Suitable for laden container lifter.

• Shall allow for secure controlled handover of container from transport truck side to the reach stacker.

Inspection Bay • Concrete slab.

• Rollover bund appropriate to exclude stormwater ingress.

Shredding & Baling • Concrete slab.

• Rollover bund appropriate to exclude stormwater ingress.

WIP waste bunds • Concrete.

• Capacity to hold 100% of volume of waste container(s) to be processed.

• Waste containers to be in bund only during waste treatment or for de-contaminating wash.



• Bund(s) to drain to sump with in-built pump which is piped to WIP.

Construction Yard • Asphalt sealed.

• 1.8 m cyclone fenced topped with 3-strand barbed wire.

• Stormwater drains to WIP Waste Bund sump via covered culvert-style drain.

Inspection Bay • Colourbond roof.

• Concrete slab.

• Drains to in-built sump with covered culvert-style drain to adjacent WIP waste bund.

Shredding & Baling • Colourbond roof.

• Concrete slab which drains to WIP waste bund sump.

WIP waste bunds • Colourbond roof.

• Bund(s) valved to sump.

Mobile equipment running surface concrete slab draining to WIP sump and Inspection Bay sump.

Equipment • Radiation area monitor with audible and visual alarm

• CCTV

• Restricted access with security card entry.

• Electronic gates.

• Area lighting.

• Sump pump for inspection bay.

• In-built sump pump for WIP waste bunds.

• Water cannon for container washing.

• Shredder.

• Baler.

• Safety shower.


Figure 2-16. Designed layout of radioactive area (with WIP waste bund).

2.3.3 Evaporation ponds

Two evaporation ponds may be used to reduce the volume of water based liquid wastes before immobilisation. Each pond will be approximately 80m by 60m in area (4,800 m2 each) and built using cut-to-fill methods. The ponds will be HDPE lined and have a chainlink perimeter fence. The delivery vessel unloading area will be a bunded concrete pad draining by gravity into one of the ponds. The liquor (i.e. waste that has concentrated via evaporation) withdrawal pump will be a similarly bunded area above pond level, draining back into one pond.

The ponds will be constructed with a minimum depth of 1.2 m. This allows for a 0.5 m operating depth, plus 0.176 m (rounded to 0.2 m) for a 72 hour 1:100 year rainfall event, plus a 0.5 m freeboard for safety and wind-driven wave action. Depth markers will be used to ensure that the 0.5 m operating depth is not exceeded, and hence no overflow point is required.


The pond floor will be graded to one corner where a slightly deeper sump will be constructed to allow wash-out of any collected (precipitated or wind-blown) sediment. Any pond washings and sediment will be treated as any other liquid or sludge in the facility and will be immobilised before placement in the waste cell.

Prior to any liquid being placed into an evaporation pond, checks will be done to confirm that no adverse or unexpected reaction will take place between the new liquid and the existing pond contents. Regular monitoring of the salinity and chemistry of the pond liquor will be used to ensure that precipitation of solids in the ponds is minimised. The operational aim will be to evaporate as much water from the liquor as possible without forming precipitates which would necessitate regular emptying of the ponds and removal of those solids. As the liquor reaches a concentration where precipitation is imminent, liquor will be withdrawn and immobilised before placement in a cell.

The evaporation ponds may be used to reduce the volume of rainwater run-off collected from the container yard area. The design specifications of the evaporation ponds are listed in Table 2-6.

Table 2-6: General Evaporation Pond Specifications.


Design Criteria • 2 of, 80 m x 60m (or equivalent), 4,800 m2 each, total 9,600 m2.

• Minimum of 1.2 m depth, consisting of 0.5 m operating depth, 0.2 m storm event rainfall allowance and 0.5m additional freeboard.

• Depth markers used to ensure operating depth is not exceeded.

• Discharge from delivery vessel by gravity flow into one pond or the other. on a gravity drained, bunded, concrete area.

• Discharge directly to the WIP or into a transportable tank from a pump station above grade.

• Liquid piping to WIP sleeved with leak detection.

Construction • HDPE lined, perimeter fenced.

• Discharge vessel area is a gravity drained (to pond), bunded, concrete area.

• Discharge pump station on a bunded, gravity drained (to pond) concrete pad.

• Pond floor is graded to a deeper area to enable collection of washings.

Other • Nil

2.3.4 Waste immobilisation plant

The waste immobilisation plant (WIP) will be used to stabilise certain types of waste prior to disposal within the cell. Solid particulate waste and sludges/liquids meeting the WAC can be treated in the


WIP by mixing them with a combination of mined kaolinised granite, cement and fly/bottom ash. Cement and fly/bottom ash would be stored adjacent to the WIP in accordance with relevant Australian Standards. Initially, Tellus plans to commence WIP operation using kaolinised granite and cement. Other immobilisation ingredients may be introduced as the need arises, pending future waste consignments.

The planetary mixer proposed to be installed is able to produce up to 30,000 tonnes per hour of treated waste. However, of this 30,000 tonnes, approximately 42% is the non-solid waste and the rest is made up of the immobilising materials. The percentage waste throughout rate will vary greatly depending on the liquid content of the waste being treated.

Up to 40,000 tonnes per annum of non-solid wastes are anticipated to be treated in the WIP. Tellus Holdings has commissioned K-UTEC Salt Technologies to develop WIP “recipes” (i.e. proportion of waste to stabilising agents) for the likely sludge/liquid wastes and solid particulate wastes to be accepted for treatment at Sandy Ridge. Figure 2-17 shows the process flow of the WIP.

Figure 2-17. Waste Immobilisation Plant (WIP) process.

Once accepted to site, sludge/liquid wastes awaiting immobilisation will be stored in their transport containers in either the radioactive container yard where applicable, or the main container storage yard. Dilute water based wastes may be evaporated in the evaporation ponds. When the waste is


scheduled for treatment in the WIP, the waste container will be placed in one of the WIP waste bunds (see section 2.3.2). The WIP waste storage bunds will be fitted with pumps connected to piping to the WIP. Piping containing wastes will be sleeved with leak detection.

Waste (and cement if required) will be dispensed to a planetary mixer (a closed industrial version of a domestic mix-master, see Figure 2-18) automatically via weight hoppers. Screened kaolin (mined from Sandy Ridge, see section 2.1) will be fed via a front-end loader into a hopper to be conveyed into the mixer. Weigh hoppers ensure the proportions are controlled as per the immobilisation “recipe”. Water is added to the mixture to initiate the cement to set. While the mixture is still pliable, it is discharged from the mixer directly into half-height shipping containers with lids. Lids are closed and containers are loaded onto a truck for transport to a waste cell for direct placement.

The mixer and piping can be flushed with water between waste treatments. Wastewater from this flushing process is discharged in the same way as treated waste, i.e. into a water-proof storage container. It will be used to aid the kaolin compaction process in the waste cells. All products and wastes generated from the WIP are contained and disposed of to the waste cells. They will not be discharged to the environment.

General WIP design criteria are listed in Table 2-7 and the design of the WIP facility is in Figure 2-19.

Figure 2-18. Example of a planetary mixer. (Source: http://www.batchcrete.net.au/wp-content/uploads/2015/09/Planetary-Mixer.jpg).

http://www.batchcrete.net.au/wp-content/uploads/2015/09/Planetary-Mixer.jpg

http://www.batchcrete.net.au/wp-content/uploads/2015/09/Planetary-Mixer.jpg


Table 2-7: General Waste Immobilisation Plant Specifications.


Design Criteria • Day shift only.

• Maximum of 40,000 tonnes per year

• Constituent dosing and measurement will be carried out automatically.

• Sludge/liquid piped from 20 ft ISO liquid containers, IBC’s or drums stored in the WIP waste bund in radioactive area (see section 2.3.2).

• Kaolin manually machine loaded (e.g. front end loader) into feed bin.

• Cement will be from a dedicated silo fed by pneumatic (air driven) bulk unloading. Bag filter in silo air vent.

• Sludge/liquid piping to be sleeved with leak detection.

Construction • Concrete slab with drainage to sump and/or bunding.

• Captured wastewater to be pumped to a 20’ ISO Liquid Container for re-use during compaction of kaolin in waste cells.

Other • Mixer is closed circuit, with discharge to sea-containers.

Figure 2-19. Waste Immobilisation Plant (WIP) Layout.


2.3.5 Power generation, bulk fuel storage and light-vehicle refuelling

The Sandy Ridge Facility will be powered in the main by diesel-powered generators. There are expected to be three generators, with a total installed capacity of 2 megawatts (MW).

Diesel for power generation and for fuelling mobile equipment will be stored in two double-skinned (i.e. self-bunded) diesel tanks, each of 55,000 litre capacity. The diesel storage will be bollarded to prevent accidental collisions by mobile equipment.

Fuel deliveries, road train refuelling and light-vehicle (LV) refuelling is in a bay adjacent to the fuel storage tanks. The refuelling bay will be a concrete pad with inbuilt blind sump which can be pumped-out in the event of spills or rainfall. Recovered spill/stormwater from the sump will be considered contaminated and will be pumped out and transferred to the WIP for treatment (see section 2.3.3).

Bulk fuel storage (including LV refuelling facilities) design specifications are listed in Table 2-8. The facility design is shown in Figure 2-20.

In addition to diesel power generation, lower power consuming components of the operations have been ear-marked for solar power. This will likely include the accommodation camp and the administration buildings.

The HV refuelling area has been co-located with washdown facilities for HV and LV. It is designed to be on concrete pad with drainage to in-built sumps to capture spills (see section 2.3.7).

Table 2-8. Fuel farm and Power Generation Design Specifications.


Design Criteria • Fuel storage as per relevant Australian Standards.

• Fuel transfer points fully bunded

• 2 x 55,000 L double skinned fuel tanks.

• Sleeved/bunded fuel piping

• Road Train refuelling and deliveries to storage tanks.

• LV refuelling.

• Direct connection to diesel fuelled power generators.

Fuel Storage Unload and LV Refuelling Facility

• Common contained/ bunded slab with local sump.

• Single tanker unloading.

• Unloading pump.

• Loading bowser.

• Fuel management system.

• Accessible for road trains / LV / bus.



HV Refuelling Facility (co-located with the vehicle washdown facility [refer to section 2.3.6])

• Transfer pump.

• Contained bunded slab with local sump.

• High flow loading bowser.

• Fuel management system.

• Accessible for ADT / fuel truck / water cart etc.

Diesel Generators • 2 x 1000 kVa generators plus 1 x 500 kVa generator (totals 2MW)

• Automatic transfer.

• Self-bunded with day tanks (belly tanks).

Fuel • Diesel – direct feed to generators.

Other • Real-time monitoring of diesel fuel tank(s) and fuel use, to the facility office.

• Oily water treatment, treated water, recovered waste fuel and sediment will be treated in the WIP (see section 2.3.3) and disposed to waste cells.

Equipment • Portable suction pump (for sump pumping and transfer to oily water separator or waste storage tank).

• Emergency Response vehicle.

• Spill kits.


Figure 2-20. Designed layout of fuel farm and light vehicle refuelling area.


2.3.6 Workshop

A workshop will be installed to perform basic service and maintenance of mobile and fixed plant. It has been designed with a concrete floor with in-built sump that is plumbed to an oily water separator.

A fenced yard area connected to the workshop will be used for the storage of mobile plant, equipment currently being serviced, and the associated spares and equipment required for their operation.

Workshop design specifications are listed in Table 2-9. The facility design is shown in Figure 2-21.

Table 2-9. Workshop Design Specifications.


Design • Jacking of HVs.

• Container lifter maintenance.

• LV maintenance.

• Repairs of immobilisation plant fixed equipment e.g. chutes, guards, pumps etc.

• Road trains, LVs and HV shall be able to drive through the facility.

General Construction

• Typically dome shelter with integral double stack 40 ft containerised stores and office. Bottom levels of the container shall be self bunded and accessible for storage.

• Bunded concrete slab with sump and associated oily water treatment system. Treated oily water is to be pumped out for disposal in the WIP (see section 2.3.3).

• External dangerous goods store for lubricants and aerosols – lubricants manually collected.

Services • LED high bay and flood lighting (task specific).

• Compressed air and tyre inflation system – minimum working pressure of 1000kPA.

• Power including welding outlets.

• Tyre change pad external to the facility.


Figure 2-21. Workshop designed layout.


2.3.7 Vehicle washdown and heavy vehicle refuelling facility

There will be a combined facility for manually washing mobile equipment and HV refuelling (Figure 2-22). It has been designed with:

• a concrete pad with rollover bunding • fast-fill fuel bowsers • spill kits • fire protection equipment • water cannons on elevated platforms • drainage to an in-built sump.

All vehicles exiting Sandy Ridge will be washed down at the entry/exit gate (see section 2.3.8). In addition, heavily soiled mobile equipment will be washed down at the purpose-built facility shown in Figure 2-22. Fresh water (i.e. water treated in the reverse osmosis plant - see section 2.3.10) but not chlorinated to potable status) will be used for washdown.

Wastewater will be directed from the sediment sump to the oily-water separator for treatment. The oily water separator will be designed to achieve treated water quality of no more than 15 mg/L. The treated water will report to an ISO-tank which, when full, can be used in the WIP (see section 2.3.3) or to aid compaction in a waste cell.

The sediment sump is designed to be accessible by a front-end loader for routine cleanout of sediments. Sediment would be transferred to a half-height shipping container with a lid (or similar) for disposal in a waste cell. If sediment is too wet, it can be transferred to the WIP for treatment (see section 2.3.3).


Figure 2-22. Vehicle washdown and refuelling facility design.


2.3.8 Wheel wash facility

All vehicles exiting Sandy Ridge will pass through a purpose-built wheel washing facility to minimise the risk of contaminated soils being carried onto the access road (Figure 2-23). Fresh water (i.e. water treated in the reverse osmosis plant – see section 2.3.10 - but not chlorinated to potable status) will be used for washdown. The facility will be located at the front gate (refer Figure 1-6) and has been designed with an automatic spray system to wash mud/dirt off then drain to an in-built concrete sediment sump. Wastewater will be pumped to the Brine Pond (see section 2.3.10) for re-use in waste cells for dust suppression or to aid compaction. The wash facility will also have a manual high-pressure spray gun to remove more stubborn materials.

Radiation checks will be done on all exiting vehicles at the gate before they leave site.

Figure 2-23. Designed wheel wash facility at front gate.

2.3.9 Stormwater management

Regional access roads and internal access roads

The existing IWDF access road will be used to access Sandy Ridge. A new Sandy Ridge access road will intersect the IWDF access road approximately 95 km north of Great Eastern Highway (see Figure 1-1). The Sandy Ridge Access Road will be approximately 10 km long and built to similar specifications as the IWDF access road, namely two-way, open surface draining with cut-off drains to direct stormwater off the running surface.


Internal access roads will be built with 4% fall to v-drains. In operational areas, internal access roads will have v-drains and windrows directing runoff to regularly spaced infiltration sumps (i.e. stormwater will be contained). Infiltration sumps can be periodically cleaned out to re-establish capacity and drainage if necessary. Material excavated during cleanout can be disposed of in a waste cell.

Typical road design cross sections are shown in Figure 2-24

Mining/Cells area

Rainfall in active mine pits will be directed to in-pit sumps which can be pumped out using a mobile pump if necessary (see Figure 2-2). Pumps will discharge to the nearest settlement sump.

Settlement sumps will be constructed downslope from active pits/ cells by pushing up in-situ materials (see Figure 1-3 ). V-drains from pits/ cell canopy will direct stormwater flows to a settlement sump. As new pits are developed, new settlement sumps will be established to capture the runoff in the active area. Settlement sumps will be designed to overflow after settling out entrained sediment. Captured water will be used for dust suppression within the mine/cell area. Sump capacity will be re-instated regularly by removing clay and disposing of it in a waste cell.

As mentioned in section 2.2.5, the active waste cell will be covered by a roof canopy. Incidental rain drainage from the cell access ramp (which may be beyond the canopy) will be directed via kaolinitic granite road berms to an in-cell sump. Water collected in the in-cell sump will be used to aid compacting of backfill material over and between wastes.

.


Figure 2-24. Typical designed road cross sections.


Infrastructure area

The civils design for the Infrastructure Area will direct surface water runoff to the HDPE-lined Retention Pond (see Figure 1-6). The Retention Pond will be designed to contain greater than a 1-in-100 year 72-hour storm event from the Infrastructure Area. In the unlikely event of a rain event exceeding this, the Retention Pond will overflow via the HDPE-lined weir to the neighbouring Raw Water Pond.

The Evaporation Ponds will be designed to contain greater than a 1-in-100 year 72-hour storm event directly precipitating into those ponds. They do not have an external catchment area other than the bunded pumping and delivery vessel areas.

Captured surface water from the Retention Pond will be used only for dust suppression and backfill compaction in the cells area or the WIP until water quality sampling verifies that it is contaminant-free (see section 3.5). At this time, it can be used throughout the facility e.g. for dust suppression on roads.

The Evaporation Ponds, Retention Pond and neighbouring Raw Water Pond will be fenced with stock-proof fencing to discourage fauna. There will be fauna egress points and life-buoys (for personnel) for each pond.

2.3.10 Water supply

An indicative water balance for the Sandy Ridge Facility is shown in Table 2-10.

Table 2-10. Indicative Sandy Ridge Facility water balance

Stream Water Type

Mon Average (m3/month)

WATER USE Village Operations - potable water Potable 401 Mining- potable water Potable 48

Infrastructure Container Washes Potable* 69 Vehicle Washes Potable* 173 Waste Immobilisation Plant Raw 504 Dust suppression Waste operations Raw 2,158 Mining operations Raw 915 North Entrance Road Raw 5,395

Fill and capping


Interstitial Fill Brine 762 Capping Brine 1,087

Direct consumption - Summary Potable water 691 Raw water 8,972 Brine 1,849 Total 11,512 ^ WATER SOURCES Groundwater supply 11,043 Rainfall reporting to Retention Pond 540 Total 11,583^

* reverse osmosis plant-treated but not chlorinated. ^ Difference between inputs and consumption totals is due to evaporation.

Groundwater bore

The primary source of water for Sandy Ridge will be an abstraction bore near the Mineral Resources Limited (MinRes) Carina mine pit located 12 km to the south-west of Sandy Ridge (see Figure 1-1). The bore location has been selected to intersect the same aquifer as Carina pit which has been monitored since July 2012. Tellus is in the process of defining the terms of an agreement with MinRes to access this aquifer. The chemistry of the Carina aquifer (and therefore presumably the nearby new bore) is shown in Table 2-11. These results are based on sampling conducted on 24 March 2015 (reference PE97555 R0), 20 May 2016 (reference PE108350) and 21 June 2017 (reference PE117291) and analysed by SGS.

Table 2-11. Indicative chemistry of Carina bore aquifer.

Analyte Unit Result pH pH units 7.2 - 7.7 EC @ 25°Celcius µS/cm 45,000 - 53,000 Total Dissolved Solids (TDS) mg/L 31,000 - 37,000 Total Alkalinity as CaCO3 mg/L 320 - 710 Nitrate and Nitrate N mg/L <0.2 - 7.4 Calcium mg/L 470 - 520 Chloride mg/L 16,000 - 19,000 Sulphate mg/L 3,100 - 3,700 Aluminium mg/L <0.10 Arsenic mg/L <0.10 Cadmium mg/L <0.005 Chromium mg/L <0.025 Copper mg/L <0.025 - 0.043 Iron mg/L <0.10 - 49 Lead mg/L <0.10 Magnesium mg/L 1,400 - 1,800


Manganese mg/L 0.11 - 2.1 Nickel mg/L 0.063 - 0.11 Potassium, mg/L 120 - 180 Selenium mg/L <0.25 Silver mg/L <0.025 Sodium mg/L 8,500 - 11,000 Zinc mg/L <0.05 - 0.07 Mercury mg/L <0.00005

Raw water from the Carina bore will be pumped to Sandy Ridge via a HDPE, welded pipeline fitted with telemetry for leak detection. Once at Sandy Ridge, it will be piped to two locations:

1. To a feeder tank for the reverse osmosis (RO) desalination plant (see below).

2. To an HDPE-lined cell Raw Water Pond. A standpipe will fill trucks with raw water for use in dust suppression throughout Sandy Ridge, and for aiding compaction in the waste cells.

Reverse Osmosis desalination plant

As indicated in Table 2-11, the existing groundwater is too saline for potable use, groundwater will be treated via a fully automatic RO plant. The system will be housed in a 20’ shipping container (or similar self-bunding) and will include chlorine dosing and UV sterilisation to treat around 3000 kL per month of groundwater to produce approximately 1200 kL per month of permeate (treated water). Some permeate will be used “as-is” in the waste immobilisation plant (see section 2.3.3) and wash-down facilities. This is referred to as “fresh water”. The bulk of the permeate will be further treated via chlorination and/or UV sterilisation to produce potable water.

Brine will be produced from RO plant at a rate of approximately 1800 kL per month and is a secondary source of water for Sandy Ridge. The contract to supply and install the RO plant had not been awarded at the time of submitting this application. Therefore, the specific make and model cannot be provided at this time. However, based on common systems performance, the RO brine at Sandy Ridge is expected to have TDS concentrations of around 50,000 – 60,000 mg/L.

Brine produced by the RO plant will be piped to an HDPE-lined sump located near the south of the materials stockpiles (see Figure 1-3). As the brine will be hypersaline (>35,000 TDS), the brine pipeline will either be double walled or fitted with telemetry leak detection with audible alarms.

Brine will be re-used only in waste cells i.e. for backfill compaction and other earthworks confined to the waste cells. Given the kaolinised geology of the waste cells and the very low permeability of kaolinized granite, brine is considered to be contained and not discharged to the environment.

Surface water

As outlined in section 1.1.4, Sandy Ridge is located in a semi-arid environment and has sandy topsoils. The infrequent rainfall quickly infiltrates into the sands and then is evaporated back to the atmosphere. There is therefore only a low prospect of using surface water runoff from the site as a


third potential source of water. However, stormwater may, on occasion, be captured in the settlement sumps in the Cells Area and from run-off reporting to the Retention Pond and can be used for dust suppression and compaction around wastes in the Cells Area. See also section 3.5.

2.3.11 Wastewater treatment plants

Wastewater treatment systems will be operated in phases during construction and into operations:

1. Construction camp 25 m3/day (in modules) 2. Construction camp 25 m3/day plus permanent village 25 m3/day 3. Construction camp 5 m3/day plus permanent village 25 m3/day plus Mine Office 5 m3/day 4. Permanent village 25 m3/day plus mine office 5 m3/day

In short, during construction and commissioning of Sandy Ridge, there will be up to three systems operating with a combined capacity of up to 50 m3/day to cater for approximately 100 people during the peak of construction. Treated sewage will discharge to two irrigation areas (refer to section 2.3.12 and section 3.4 for more information). As construction of the village is completed, the camp wastewater treatment plant (WWTP) will be downsized by removing modules, leaving the village WWTP and the mine office WWTP with a combined capacity of 30 m3/day, and their respective irrigation areas.

The WWTP are planned to be package-type systems made up of modules in series, which can be added and removed to alter the combined capacity. The Blivet system shown in Figure 2-25, is representative of common package-treatment processes.

The plants are contained in a self-bunded housing which can be installed above-ground or partially below ground.


Figure 2-25. BlivetTM Packaged Sewage Treatment System Process Diagram – indicative of the type of system to be used at Sandy Ridge Facility.

The treatment steps of the Blivet system are indicative of most aerobic treatment systems. They are listed and described below.

• Primary settlement area.

• Sludge storage (12 weeks minimum, depending on influent loadings).

• Biological treatment aerator.

• Secondary settlement area with sludge return pump.

• Tablet chlorinator.

• Metering pump (in bunded tank) to inject ferric sulfate to reduce phosphate in the effluent.

Primary settlement

Units receive raw sewage and settle the gross solids. The primary settlement zone reduces the suspended solids by 75 % and the biological oxygen demand (BOD) by 25 % to 30 %. This zone is relatively maintenance-free and contains no moving mechanical or electrical devices.

Denitrification zone

Effluent from the primary settlement zone is mixed with recycled flow from the end of the aeration zone. These two streams are mixed in a ratio of 1: 2 (or higher in some cases) and then enter the denitrification zone. The denitrification zone is composed of plastic media which provides a surface on which the denitrifying bacteria adhere. The denitrifying bacteria convert Nitrate (NO3) from the


recycled flow to Nitrogen (N2) gas. The BOD in the incoming effluent provides the carbon that is required for the bacteria to grow. This also has the advantage of reducing the BOD load to the aeration zone by approximately 20 %.

Aerobic zone

The combined flows from the denitrification zone is treated by means of an efficient and compact system (the aerator biozone) requiring minimal power input and maintenance. It is a combined fixed film reactor and active aeration system mounted on a horizontal shaft. The rotational media is a spiral formation enclosed in an outer drum to provide active aeration, intense surface area and net hydraulic lift. The biozone is self-cleansing and no extraneous pumping or sludge returns are required. For process efficiency, it is a plug flow system.

The BOD is removed to low levels in the first rotor/s as carbonaceous bacteria are more robust than nitrification bacteria. Once the BOD has been reduced to low levels, the nitrification bacteria begin to grow on the remaining rotor/s.

Splitter box

An important aspect of treating the effluent down to low nutrient levels is the recycle of flow back to the denitrification zone. The splitter box can be adjusted to recycle different flow ratios depending on the outlet effluent requirements.

Final settlement

The final settlement or Humus Tank is a discrete compartment denying ingress of untreated or partially treated liquor. The design is similar to the primary settlement tank on an upward flow basis. This zone has frequent automatic removal of sludge-to-sludge storage by means of a timed submersible pump. It also has a pump designed to return sludge to the aeration zone to maintain the concentration of nitrification bacteria within the aeration zone.

Sludge storage

Sludge storage is provided in the base of the units. Depending on the load applied there is approximately 12-weeks capacity provided. Desludging is carried out by suction- tanker. Tellus is liaising with the City of Kalgoorlie-Boulder to dispose of sludges to their facility in Boulder using an appropriately licensed controlled waste carrier.

2.3.12 Treated wastewater irrigation areas

Treated effluent from the WWTP will be discharged to two irrigation areas; one at the construction camp/permanent village and one at the mine office area (refer to Figure 1-3). Discharge pipelines from the WWTP to irrigation areas will be above-ground in a shallow trench to allow daily visual inspection. Pipelines will be double-walled.

Effluent irrigation is proposed to be approximately 0.6 ha of surface drippers for the construction camp, and 0.6 ha of fully fenced sprinkler irrigation area for the permanent village (i.e.


approximately 1.2 ha in total). The irrigation area for the mine offices will be a 0.12 ha fully fenced sprinkler area. Sizes, locations and configurations of irrigation sites have been based on Department of Water’s Water Quality Protection Note 22: Irrigation with Nutrient-Rich Wastewater (WQPN22). These are listed below and in section 3.4, and described in terms of the Sandy Ridge effluent irrigation areas.

• Zoned for compatible activities in the local government planning scheme.

The entire Sandy Ridge Facility, including the WWTP spray fields) is located on unallocated crown land, zoned mining/rural in the Shire of Coolgardie Town Planning Scheme No. 4.

• Remote from areas where odours or spray drift may cause local nuisance

The surface drippers proposed for the construction camp will not emit spray drift and will be located at least 50 m from the camp so as to not cause odours.

The spray fields will be located no less than 50 m from the camp / village / offices. Apart from personnel at Sandy Ridge, there are no sensitive receivers to odours within 50 km of the proposed WWTP and spray fields. The nearest residential receiver is Carina Mine’s accommodation camp, approximately 50 km to the south of Sandy Ridge.

• The minimum water table depth is two metres.

Hydrogeological assessment (Rockwater, 2015) concluded that there is no aquifer at Sandy Ridge Facility. A small saline (approx. 6,000 ppm TDS) water-bearing zone is located in the southwest of the pit/cells area, but outside the mine pits/cells area (see Rockwater, 2015 - Appendix A.11 of the Sandy Ridge PER). Subsequent bore monitoring indicates the water-bearing zone is over 20 m below ground level. This is more than 1.5 km from either of the effluent irrigation areas.

• Sufficient area of arable soil is available.

Not applicable. The Sandy Ridge Facility is not located in an arable area.

• Slope of land is less than one in twenty.

The Sandy Ridge Facility location consists predominantly of flat to gently undulating sand plain over weathered granite. The accommodation camp irrigation area slope is around 1 in 30 m and the mine office spray field is over 1 in 50 m.

• Appropriate buffers are retained to sensitive water resources.

There are no sensitive water receivers within the Sandy Ridge Facility development envelope. As the region is semi-arid with around 270 mm rain per annum and an evaporation rate of over 2000 mm per annum, any surface water flow is short-lived. Hence there are no creeks, rivers or lakes, with the exception of salt lakes. The water body to Sandy Ridge is a small chain of playa lakes south of Lake Barlee, approximately 50 km north.

• The irrigated areas are not subject to seasonal flooding. See previous.


The proposed layout of the camp/village irrigation area is shown in Figure 2-26. One half will be a surface dripper system for the construction camp. The other half will be a fully fenced sprinkler sprayfield.

The accommodation camp spray field is proposed to be located to the north of the camp, in vegetation as mapped as vegetation type Eucalyptus salmonophloia woodland over Eremophila oppositifolia open heath. This same sprayfield will be used by the WWTP when the permanent village is built.

The mine office spray field will be located in vegetation mapped as Acacia resinimarginea open heath, nominally to the west of the Infrastructure Area adjacent to the WWTP.


Figure 2-26. Proposed design of camp/village WWTP irrigation area.

Irrigation area as per WQPN 22 (not to scale)


2.3.13 Class II landfill

A Class II landfill will be established north of the accommodation camp (refer to Figure 1-3). It is estimated to receive up to 500 tpa during construction; generated from putrescible domestic waste associated with the construction camp plus construction-type wastes e.g. non-recyclable packaging. It will be designed and operated in accordance with the Environmental Protection (Rural Landfill) Regulations 2002.

The disposal rate will reduce to 250 tonnes of putrescible waste per annum during operations; generated from the kitchen, office and general management at Sandy Ridge.

As shown in Figure 2-27, the site will be fully fenced with stock-proof chainlink fencing to reduce windblown litter as well as to exclude fauna. The disposal area will be a series of trenches 2 m deep, 3 m wide and approximately 70 – 80 m long, progressively filled with waste and covered monthly with inert material. One trench will be operating at any one time, with a maximum tipping length of 30 m.

As stated previously, the Sandy Ridge Facility is located on a thick bed of kaolinised granite. This effectively forms a natural geological liner for the Class II landfill, hence no man-made liner is proposed. Similarly, no leachate sump is proposed, as kaolinised granite is of low permeability, hence any moisture from putrescible wastes will be contained in the immediate area.

There is no aquifer at Sandy Ridge. A small saline water-bearing zone 20 m below ground is located in the southwest of the pit/cells area (see section 2.3.12). Groundwater monitoring indicates the water-bearing zone is over 20 m below ground level.

Common recyclables (such as glass, paper, scrap metal etc.) will be recycled of offsite pending the availability of local recycling companies.


Figure 2-27 Proposed design of Class II landfill


3 EMISSIONS AND DISCHARGE POINTS

This section identifies the emissions, discharges and proposed monitoring at the Sandy Ridge Facility.

3.1 CLASS IV and V waste storage and disposal There are not anticipated to be any emissions or discharges from the Class IV/V waste disposal cells. This is discussed below.

Section 2.2 describes the controls and procedures that will be implemented for managing acceptance, testing and ultimate disposal of Class IV and Class V wastes into cells and boreholes.

Section 1.1.4 describes the natural kaolinitic geology and climate of the Sandy Ridge Facility location that make it a world-class natural geological waste repository. Deposited wastes are considered to be contained within cells.

In the absence of an unforeseen seismic event, fluke plane crash into the site or ice-age type climate change, deposited wastes will not be discharged to the environment beyond the kaolinised granite into which they were placed. Therefore, traditional landfill-centric methods of environmental monitoring are not considered appropriate for Sandy Ridge Facility. However, Tellus recognises the novelty of the Sandy Ridge Proposal in Australia, despite similarly designed facilities being well understood internationally. To increase the confidence of stakeholders and the scientific data available in Australia, Tellus will proactively commit to monitoring the performance of the facility.

The parameters that Tellus is proposing to monitor during operations to verify the robustness of the cell design and operational controls implemented at Sandy Ridge are listed in Table 3-1. These include cell integrity parameters and air quality (particulates and contaminants). Figure 3-1 shows the proposed environmental monitoring points at Sandy Ridge.


Table 3-1. Proposed operational environmental monitoring related to Class IV/V Wastes at Sandy Ridge Facility.

Monitoring Location

Parameter Target

Proposed Monitoring Frequency

Duration

Infrastructure Area Tonnes of waste accepted

100,000 tpa Upon acceptance, reported annually

To year 26

Front gate Radioactivity of deliveries

Background unless authorised

Every delivery vehicle

Active project life (to year 26)

Cell caps Subsidence (surveyed)

<1.2 m subsidence at highest point of the arc of cell cap

Annual To year 10*

Cell caps Subsidence (visual assessment)

No differential settlement.

Monthly To year 26

Cell caps Cap integrity (visual assessment)

No vegetation >0.5m high, no erosion (gullying) >0.20m deep, no fauna burrows >0.20m deep

Monthly To year 10* each cell

Cell caps Cap integrity (visual assessment)

No vegetation >3.0m high, no erosion (gullying) >0.40m

Annual After cell rehabilitation* to year 46

Cell caps (Cells 1 to 3, 2 per cell)

Moisture at base of upper clay cap

<= Cymod estimate

continuous monitoring, monthly data

TBA – probe life dependent (estimate up to 10 years)

Moisture at base of silcrete/laterite

<= Cymod estimate


Moisture at base of lower clay layer

<= Cymod estimate


Cell groundwater monitoring bores

Moisture Full suite of contaminants (if water present)

Zero free-water within 5m of the deepest waste (baseline)

quarterly annually

To year 26 Years 26 to 46

Village WIP Control

Air Quality – dust deposition and contaminants

<=10% above control

Continuous monitoring,

To year 26


Monitoring Location

Parameter Target

Proposed Monitoring Frequency

Duration

monthly samples

Radiation workers Radiation dose (worker)

<5 mSv per year^

Continuous daily

To year 26

Non-radiation workers

Radiation dose (public)

<10 µSv per year#

Continuous per event

To year 46

Each capped cell Radioactivity at cell surface and BOSS

TBA – pending baseline survey and in consultation with Radiation Health Unit

6 monthly to year 10*. Thereafter once every 10 years

To year 46

Each active cell Radon gas in cell 1000 Bq m3~ Continuous daily

Active cell life

NW Cells Area NE Cells Area SW Cells Area WIP

Radon gas at surface

1000 Bq m3~ Continuous monitoring per quarterly report

To year 46

Retention Pond See section 3.5 Grab sample after rainfall event resulting in water at Retention Pond.

To year 26

Raw Water Pond As per Retention Pond, see section 3.5

Grab sample if Retention Pond overflows and prior to discharge anywhere other than Cells Area.

To year 26

* At year 10, cells caps get covered with overburden and are revegetated. ^ ARPANSA (2002) dose limit for radiation workers is 20 mSv per year averaged over 5 years and no more than 50 mSv in any year. # ARPANSA (2002) dose limit for ‘public’ is 1 mSv per year. ~ ARPANSA (2016) recommended level for action in the workplace.


Figure 3-1. Proposed environmental monitoring at Sandy Ridge Facility.


3.2 Screening plant Kaolinised granite will be screened in campaigns and stockpiled for use in the WIP (see section2.3.3). Dust is likely to be generated at material transfer points, the conveyors and from the discharge head of the stacker conveyor. Proposed air quality monitoring locations are listed in Table 3-1 and shown in Figure 3-1.

As the ore is kaolinitic, water addition must be minimised to avoid clogging the moving parts of the screening plant. To minimise fugitive dust emissions, the wet-hire contract for the mobile screening plant will specify:

• Plant is to be designed and operated to minimise dust emissions e.g. ore moisture must be maintained at a level to prevent dust-generation but not clog the plant.

• Include a luffing stacker conveyor to minimise drop height for stockpiling.

• Consider ring-sprays at discharge head of the stacker conveyor

The screening plant will have a capacity of 100 tonnes per hour for 10-hour day shift campaigns, six days per week to produce 120,000 tonnes of screened material per annum. Two grades of kaolinised granite: sub-20 mm and sub-30 mm will be generated for use in waste immobilisation plant.

The screening plant may be operated at any location within the Facility, depending on which pit is being mined and which stockpile it is being stored in. Stockpiled material will initially be moistened until it develops a crust. The operating face of any stockpile (i.e. during reclamation) will be watered for dust suppression.

A mobile screening plant will also be contracted during construction of the Sandy Ridge Facility. It is assumed that the plant used during construction will be of the same specifications as the plant(s) used for campaigns during operations.

3.3 Class II landfill Tellus will record and report the monthly and annual volumes (m3) of waste disposed to the Class II landfill.

Section 2.3.13 describes the Class II landfill infrastructure and operation. It will be situated above a deep kaolinised granite formation that extends over 16 km north-south and over 20 km east-west, provided a world-class geological barrier. Hence the Class II landfill is not considered to generate discharges to land.

Windblown litter and scavenging fauna will be minimised through monthly covering of waste with inert material as well as the installation of a boundary fence.

3.4 Wastewater treatment plant During construction, WWTPs will discharge up to 50 m3/day of treated wastewater to land via two irrigation areas. This will reduce to 30 m3 /day during operations. The specifications of each WWTP


and proposed monitoring during commissioning and operations are provided in Table 3-2. According to Table 7 of the Guidelines for the Non-potable Uses of Recycled Water in Western Australia, no monitoring during commissioning/operation is required for exposure risk levels of “extra low”. However, consistent with industry standards, Tellus proposes to conduct monthly monitoring of the WWTP effluent during commissioning and quarterly monitoring during operations.

The irrigation areas have been sized on the assumption that the soil type and evaporation rate of the Sandy Ridge area result in it being the lowest risk category for eutrophication as per Table 2 of WQPN 22. Accordingly, the anticipated effluent quality will result in:

• Maximum inorganic nitrogen application rate of 480 kg/ha/yr, and

• Maximum inorganic phosphorous application rate of 120 kg/ha/yr.

The discharge pipelines from WWTP to irrigation areas will be above-ground in a shallow trench to allow daily visual inspection and will be double walled to reduce the risk of leaks.

Wastewater treatment will be carried out in enclosed tanks and insignificant odours will be produced. Odours may be generated at the spray field and sludge storage bins. This will be minimised by returning sludge to the aeration zone to maximise treatment.

Waste sludge is estimated to be generated at a rate of 8 m3 per month in the larger system at the camp and 5 m3 per month in the smaller system servicing the office area. Waste sludge will be pumped out periodically (anticipated to be every two to three months, depending on system throughput) by a controlled waste licensed waste collector and disposed of to a licensed facility for further treatment/disposal.

The discharge pipelines from WWTP to irrigation areas will be above-ground in a shallow trench to allow daily visual inspection and will be double walled to reduce the risk of leaks. Irrigation areas will be in uncleared native vegetation with naturally free-draining colluvial sand with gravel soils to make use of plant evapotranspiration to ensure there is no ponding of effluent. The size of irrigation areas have been designed to achieve discharges to land at concentrations consistent with WQPN 22 and Tables 11 and 12 of Department of Health’s Guidelines for the Non-potable Uses of Recycled Water in Western Australia. This equates to about a 1.2 ha irrigation area (i.e. that watered by the sprinklers) if we assume 100 people, to achieve N and P application rates shown in Table 3-2. The exposure risk level at Sandy Ridge is assumed to be extra low as Sandy Ridge is in a remote region with coarse free-draining sands, there is no sensitive surface water within 50 km, there is low eutrophication risk and the spray fields will be located over 50 m from any building or work area, fully fenced and signposted to exclude human contact.


Table 3-2. Sandy Ridge Wastewater Treatment Plant effluent targets and proposed monitoring.

Emission point reference Parameter Target

Averaging period

Proposed monitoring frequency

Commissioning Operations Camp Offices

Effluent flow rate

50 m3/day -construction 30 m3/day - operations

24 hours Continuous Continuous

Total Nitrogen (TN) 30 mg/L N/A Monthly spot sample Quarterly spot sample Total Phosphorus

(TP) <8 mg/L N/A Monthly spot sample Quarterly spot sample

Biochemical Oxygen Demand (BOD)

<30 mg/L N/A Monthly spot sample Quarterly spot sample

Total Suspended Solids (TSS)

<30 mg/L N/A Monthly spot sample Quarterly spot sample

pH 6.5-8.5 N/A Monthly spot sample Quarterly spot sample E.coli <1000 cfu per 100mL N/A Monthly spot sample Quarterly spot sample Oil and grease <30 mg/L N/A Monthly spot sample Quarterly spot sample Camp/Village Irrigation area

Vegetation – visual health

photographic N/A monthly Quarterly

Irrigation No effluent ponding No weeds

N/A weekly weekly

Office Sprayfield Vegetation – visual health

photographic N/A monthly Quarterly

Irrigation No effluent ponding No weeds

N/A weekly weekly


3.5 Stormwater management Stormwater management at Sandy Ridge Facility will be split into two main sectors: the cells area and the infrastructure area. Management will be consistent with Department of Water’s Water Quality Protection Note 52 – Stormwater Management at industrial sites (May 2010) to prevent potentially-contaminated stormwater being discharged to the environment. Stormwater is not considered to be released to the environment at Sandy Ridge Facility.

Mining/Cells area

Sandy Ridge Facility is located in a semi-arid environment with approximately 270 mm rain per year and a very high evaporation rate (over 2000 mm per year). Rainfall patterns are affected by the tail-end of cyclonic activity in the north of the state. Due to the sandy, well-draining topsoil and sandy clay layers to around 1.5 m depth (i.e. overlaying the relatively impermeable silcrete layer – see Figure 2-3), storm run-off is short-lived. However, as the cells area will expose kaolinised granite, if run-off occurs, it is likely to be turbid.

Around the mine pits/cells, surface water is excluded from the voids wherever possible with the use of:

• Flood levee constructed to the east of the Facility.

• Mine safety bunds around each mine pit, also acting to prevent flooding of mine pits.

• In-pit sumps on access ramps to capture any runoff.

• Surface water will drain to a settlement sump.

• Canopy prevents stormwater in waste cells.

Therefore, the likelihood of water contamination is low and the only contaminant expected to be in stormwater runoff in the mine/cells area is sediment. As outlined in section 2.3.9, on the rare occasion that rainfall results in surface flows, captured stormwater in the pits/cells area will be directed to sumps to settle out sediment. Captured water in sumps may be re-used for dust suppression or compaction in cells. Tellus does not propose to monitor stormwater in the mining/cells area.

Infrastructure area

As described in section 2.3, areas in which hazardous and/or radioactive waste is handled (outside of a sealed container) have been designed with concrete floors and sealed sumps to minimise the potential for release to the environment. Materials recovered from these areas will be treated in the WIP and/or disposed to the waste cells. There is expected to be no discharge to the environment of contaminated stormwater.

To further safeguard the environment, stormwater from the Infrastructure Area will be captured in the HDPE-lined Retention Pond (see section 2.3.9), with the exception of the Radioactive Area which is self-contained (see section 2.3.2). Although there is a very low risk of contamination from the


Infrastructure Area, captured surface water will be used only for dust suppression and backfill compaction in the cells area until grab-samples of water quality verify that it is contaminant-free.

Table 2-1 (section2.2.1) lists the top-ten wastes, by volume, that are expected to be sent to Sandy Ridge. At this stage, Tellus’ potential customers have not yet conducted waste characterisations to the level that would identify contaminants. As Tellus receives more accurate waste descriptions from waste generators through the WAP (see section 2.2.3), the contaminants will be clarified. Retention Pond sampling parameters will be refined at that stage. In the meantime, interim sampling parameters (Table 3-3) during operations are based on the contaminants assumed to be in wastes listed in Table 2-1. Targets are based on 10 x livestock drinking water criteria as cited in the National Water Quality Management Strategy Guidelines (ANZECC, 2000) and the Department of Water’s (2013) Water Quality Protection Note 68 Mechanical equipment wash down.

Tellus will take grab samples of water reporting to the Retention Pond to verify that it is uncontaminated prior to being used anywhere other than in waste cells. In the unlikely event that the Retention Pond overflows to the Raw Water Pond, the latter will also be tested and cleared prior to use anywhere other than in waste cells. Use of contaminated water within cells is considered contained (i.e. not discharged to the environment).

Stormwater from the Radioactive Warehouse Area will report to WIP waste bund sump (see section 2.3.2) and is not designed to report to the Retention Pond. During the first 12 months of operations, Tellus proposes to monitor for potential radioactive contaminants in the Retention Pond to verify the controls in the Radioactive Warehouse Area are effective.

Table 3-3. Proposed Retention Pond and Raw Water Pond water monitoring parameters prior to general site use.

Top-10 Waste NEPM 75 Description

Retention Pond Monitoring Parameter

Target

Residues from industrial waste treatment/disposal operations

Total Petroleum Hydrocarbons (TPH)

<15 mg/L^

Soils with controlled waste Electrical Conductivity <1800 µS/cm^ Fly ash, excl. from Australian coal fired power stations

Arsenic 5 mg/L*

Soils with asbestos Total Suspended Solids (TSS) <30 mg/L Waste oil and hydrocarbons mixtures BTEX cumulative <10 µg/L^ Lead compounds Total Lead 1 mg/L* Basic solutions or bases in solid form pH 5.5-8.5^ Inorganic fluorine compounds (Spent Pot Liner) excluding calcium fluoride

Total Flouride Total Aluminium

20 mg/L* 50 mg/L*

Zinc compounds Total Zinc 200 mg/L* Radiological assay# TBA – pending baseline

survey and in consultation with Radiation Health Unit

# To verify the radioactive waste controls are operating to design. ^ based on WQPN 68 * 10 x Recommended water quality trigger for livestock drinking water.


4 CONSTRUCTION AND COMMISSIONING ACTIVITIES

The Sandy Ridge Facility is proposed to be constructed, commissioned and operated in phases. An indicative schedule is provided in Table 4-1. Activities that are directly related to Part V of the Environmental Protection Act 1986 are highlighted.

Table 4-1. Indicative Sandy Ridge development schedule.

Construction Activity Timing Approvals in place December 2017 Construction camp including ~25 m3/d WWTP December 2017 Commission Construction camp WWTP December 2017 – February 2018 Road construction January – June 2018 Carina bore and pipeline February – March 2018 Construct permanent village including ~25 m3/d WWTP commissioning

March – June 2018

Commission permanent village WWTP (total combined capacity 50m3/d)

March 2018 – May 2018

Develop and deposit to first BOSS disposal bore hole March 2018 Establish and commence use of Class II Landfill April 2018 Isolate SRS in bore holes April 2018 Develop first mine pit (including screening plant) April – July 2018 Erect cell cover April – June 2018 Bulk earthworks for Infrastructure Area (including lined ponds)

April – June 2018

Surface-storage of low-risk wastes in temporary yard July 2018 Construct Reverse Osmosis Plant and mine office WWTP

July 2018

Commission Reverse Osmosis Plant and mine office WWTP

July- September 2018

Lay asphalt in infrastructure area October – November 2018 Bulk fuel storage installed October 2018 Commissioning Infrastructure Area facilities November – December 2018 Compliance audit report submitted to DWER December 2018 Operating Licence issued December 2018 Full Operation commences– waste placement and WIP operation

December 2018

4.1 Construction camp A modular trailer-based fly-camp followed expanding to a construction camp will be established in the area of the permanent village. Until the Carina Bore and pipeline are commissioned, water will be trucked in (most likely from Coolgardie or Kalgoorlie).

Up to 50 m3/day of sewage from the construction camp / village will be plumbed to a wastewater treatment plant as described in section 2.3.11 and section 3.4. The treated effluent will be


discharged to the location of the proposed permanent village irrigation area. Commissioning of each WWTP and irrigation discharge is anticipated to take three-months.

Tellus is seeking to register Sandy Ridge for Category 85 under Part V of the Environmental Protection Act 1986 by approximately February 2018.

4.2 Class II landfill Wastes generated during construction are proposed to be disposed of in the Sandy Ridge Class II landfill. With over 100 personnel on site during construction (i.e. for around 12 months), coupled with the building wastes and packaging, it is estimated that up to 500 tonnes of waste will be disposed of to the Class II landfill during the 12 months of construction. Recyclables will be removed offsite to local recycling facilities wherever possible.

Tellus is seeking to licence Sandy Ridge for Category 64 under Part V of the Environmental Protection Act 1986 by approximately April 2018.

4.3 Screening A mobile screening plant will be used by the construction contractor during construction. The specifications of the construction screening plant are planned to be the same as the plant that will be used to screen kaolinised granite during operations at Sandy Ridge as described in section 3.1.

Tellus is seeking to licence Sandy Ridge for Category 12 under Part V of the Environmental Protection Act 1986 by approximately April 2018.

4.4 Early waste acceptance Tellus propose to apply to licence Sandy Ridge Facility for Category 66 under Part V of the Environmental Protection Act 1986 by March 2018, prior to completing the full construction program. This will allow Sandy Ridge to accept:

• LLW sealed sources for disposal using the BOSS bore hole method.

• Low risk solid wastes or self -bunded wastes to be temporarily stored ready for disposal.

Low-risk solid or self-bunded non-solid wastes will be stored in either sealed self-bunded shipping-containers or other water-proof packaging, away from the construction area (see Figure 1-6). The temporary storage area will be one of the first constructed, with the flood levee, stormwater management and security fencing in place prior to accepting wastes.

Tellus is seeking to licence Sandy Ridge for Category 66 under Part V of the Environmental Protection Act 1986 by July 2018. First waste placement using the BOSS bore hole method is planned for April 2018.


5 REFERENCES

Australian Radiation Protection and Nuclear Safety Agency (2014). Code for the Safe Transport of Radioactive Material. Radiation Protection Series C-2.

Australian Radiation Protection and Nuclear Safety Agency (2016). Radon Exposure and Health. Factsheet dated July 2016. Accessed at https://www.arpansa.gov.au/sites/g/files/net3086/f/legacy/pubs/factsheets/RadonExposureandHealth.pdf on 16 August 2017.

Australian Radiation Protection and Nuclear Safety Agency (2002). Recommendations for Limiting Exposure to Ionizing Radiation (1995) (Guidance note[NOHSC:3022(1995)]) and National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)] (RPS No. 1), available at: http://www.arpansa.gov.au/pubs/rps/rps1.pdf

Australian and New Zealand Environment and Conservation Council (2000). National Water Quality Management Strategy, Australian and New Zealand Guidelines for Fresh and Marine Water Quality Volume 1.

Beard JS (1972). Vegetation survey of Western Australia. The vegetation of the Jackson Area, Explanatory Notes and Map Sheet, 1:250000 series. Vegetation Survey of Western Australia. Vegmap Publications, Sydney.

Bureau of Meteorology (2017a). Monthly Rainfall data for Coolgardie Western Australia. Accessed at http://www.bom.gov.au/jsp/ncc/cdio/weatherData/av?p_nccObsCode=139&p_display_type=dataFile&p_startYear=&p_c=&p_stn_num=012018 on 13 July 2017.

Bureau of Meteorology (2017b). Average annual, monthly and seasonal evaporation. Accessed at http://www.bom.gov.au/jsp/ncc/climate_averages/evaporation/index.jsp on 13 July 2017.

Continental Resources Management Pty. Ltd. 2016. Sandy Ridge Project Western Australia Regional Geology and Geological Evolution. Unpublished report prepared for Tellus Holdings Ltd. Appendix A.4 to the Sandy Ridge Public Environmental Review Report, December 2016.

CyMod Systems Pty Ltd (2016). The Assessment and Long-Term Recharge to Encapsulated Waste Isolation Cells – Sandy Ridge Project. Unpublished report for Tellus Holdings Ltd. August 2016. Appendix A.12 to the Sandy Ridge Public Environmental Review Report, December 2016.

Douglas Partners (2015). Report on Geotechnical Assessment. Sandy Ridge Project Goldfields, WA. Unpublished report for Tellus Holdings Ltd. May 2015.

Department of Finance, 2014. Performance and Compliance Report Intractable Waste Disposal Facility Mt Walton East January 2013 – December 2013. Revision 1. Department of Finance, Building Management Works.

https://www.arpansa.gov.au/sites/g/files/net3086/f/legacy/pubs/factsheets/RadonExposureandHealth.pdf

https://www.arpansa.gov.au/sites/g/files/net3086/f/legacy/pubs/factsheets/RadonExposureandHealth.pdf

http://www.arpansa.gov.au/pubs/rps/rps1.pdf

http://www.bom.gov.au/jsp/ncc/cdio/weatherData/av?p_nccObsCode=139&p_display_type=dataFile&p_startYear=&p_c=&p_stn_num=012018

http://www.bom.gov.au/jsp/ncc/cdio/weatherData/av?p_nccObsCode=139&p_display_type=dataFile&p_startYear=&p_c=&p_stn_num=012018

http://www.bom.gov.au/jsp/ncc/climate_averages/evaporation/index.jsp


Department of Health (2011). Guidelines for the Non-potable Uses of Recycled Water in Western Australia.

Department of Water (2008). Water Quality Protection Note 22: Irrigation with Nutrient-Rich Wastewater.

Department of Water (2010). Water Quality Protection Note 52 – Stormwater Management at industrial sites.

Department of Water (2013) Water Quality Protection Note 68 Mechanical equipment wash down.

Hammonds, M. 2012. Breaking plates. Australian Science, available at: http://www.australianscience.com.au/news/breaking-plates/

International Atomic Energy Agency, 2003, Considerations in the Development of Near Surface Repositories for Radioactive Waste (Technical Report Series 417), available at: http://www-pub.iaea.org/MTCD/Publications/PDF/TRS417_web.pdf

International Atomic Energy Agency (2011). BOSS: Borehole Disposal of Disused Sealed Sources: A Technical Manual. IAEA-TECDOC-1644. Waste Technology Section, International Atomic Energy Agency, Vienna International Centre, Austria.

Landloch 2015. Sandy Ridge Project Soil Assessment. Appendix A.5 to the Sandy Ridge Public Environmental Review Report, December 2016.

National Health and Medical Research Council, 1992, Code of practice for the near-surface disposal of radioactive waste in Australia – Radiation Health Series 35, available at: http://www.arpansa.gov.au/pubs/rhs/rhs35.pdf

Rockwater Pty Ltd. (2015). Hydrogeological Studies for the Sandy Ridge Project – Drilling, Permeability testing and Potential Water Sources Report. Appendix A.11 to the Sandy Ridge Public Environmental Review Report, December 2016.

pgv Environmental (2016). Sandy Ridge Project Exploration Tenement E16/440 – Flora and Vegetation Survey. Unpublished report for Tellus Holdings Ltd. Appendix A3b. to the Sandy Ridge Facility Public Environmental Review.

Standards Australia (2007) AS 1289.5.8.1 Methods of testing soils for engineering purposes – Soil Compaction and density tests – Determination of field density and field moisture content of a soil using a nuclear surface moisture density gauge – Direct transmission mode.

Tellus Holdings Ltd (2017). The Proposed Sandy Ridge Facility Response to Submissions Report. Final Report August 2017.

http://www.australianscience.com.au/news/breaking-plates/

Sandy Ridge –Works Approval and Licence Application Supporting Document

APPENDIX 1A: APPROVALS GRANTED

Created 25/08/2017 11:32:35 Requested By: Michael Ingram/Page 1 of 1

MINING TENEMENT SUMMARY REPORT

EXPLORATION LICENCE 16/440 Status: Live

TENEMENT SUMMARY

Area: 20 BL Death Reason :

Mark Out : Death Date :

Received : 24/01/2012 12:48:43 Commence : 23/01/2013

Term Granted : 5 Years Expiry : 22/01/2018

CURRENT HOLDER DETAILS

Name and AddressTELLUS HOLDINGS LTDC/- MCMAHON MINING TITLE SERVICES PTY LTD, PO BOX 592, MAYLANDS, WA, 6931

DESCRIPTION

Remaining Blocks

Type Start Date No. of Blocks GraticulesMillion Plan Primary Blocks

Granted 23/01/2013 20 KALGOORLIE 1946 qvwxKALGOORLIE 2017 ekpKALGOORLIE 2018 abcdfghlmrwxy

Applied For 24/01/2012 20 KALGOORLIE 1946 qvwxKALGOORLIE 2017 ekpKALGOORLIE 2018 abcdfghlmrwxy

Description of Land NOT included in the grant of the Licence.

SHIRE DETAILS

Shire Shire No Start End AreaCOOLGARDIE SHIRE 1960 24/01/2012 20.00000 BL

RENT STATUS

Due For Year End 22/01/2018: PAID IN FULLDue For Year End 22/01/2019: $5,660.00

EXPENDITURE STATUS

Expended Year End 22/01/2017: EXPENDED IN FULLCurrent Year Commitment : $30,000.00


APPENDIX 1B: ASIC COMPANY EXTRACT


APPENDIX 2: WASTE ACCEPTANCE CRITERIA

SANDY RIDGE FACILITY WASTE ACCEPTANCE CRITERIA

Document No.: TCO‐6‐SR‐01300‐GE‐SPC‐0001

Final Report | August 2016

Version Date Description Signatures

Originator Checked Approved

0 10/08/2016 For issue S. Reece J. Livesey

R. Phillips

D van der Merwe

Table of Contents

Abbreviations ................................................................................................................................. i

Definitions .................................................................................................................................... iii

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

1.1 The Sandy Ridge Facility ................................................................................................. 1

1.2 Document Aims and Objectives ...................................................................................... 3

1.3 Intended Audience ......................................................................................................... 3

2 Waste Acceptance Criteria ..................................................................................................... 5

2.1 Introduction .................................................................................................................... 5

2.2 Excluded waste criteria ................................................................................................... 5

2.3 Chemical waste acceptance ............................................................................................ 9

2.4 Radioactive waste acceptance ........................................................................................ 9

3 Waste Packaging Criteria ...................................................................................................... 18

3.1 Packaging criteria .......................................................................................................... 18

3.2 Mitigating package failure ............................................................................................ 19

4 Bibliography ......................................................................................................................... 20

LIST OF FIGURES

Figure 1‐1: Sandy Ridge site location ...................................................................................................... 2

Figure 1‐2: Waste Acceptance Criteria Document Hierarchy ................................................................. 3

Figure 2‐1 Conceptual illustration of the waste classification system and potential permanent

isolation options ................................................................................................................................... 12

LIST OF TABLES

Table 2‐1: Summary of waste acceptance classifications at Sandy Ridge .............................................. 5

Table 2‐2: Example chemical wastes likely to be suitable for permanent isolation at Sandy Ridge ...... 9

Table 2‐3: Code of practice for the near surface disposal of radioactive waste in Australia (1992) ‐

waste classification summary ............................................................................................................... 11

Table 2‐4: Waste Acceptance Criteria (WAC) for the Facility for bulk NORM waste ........................... 14

Table 2‐5: Generic Concentration Limits for Sealed sources‐LLW for 100 year Institutional Control

Period (ICP) [Ref NHMRC (1992)] ......................................................................................................... 16

Table 2‐6: limits for common sources based on NHMRC near surface code (1992) ............................ 17

LIST OF APPENDICES

A1 Potential waste category list

A2 Packaging examples

i

ABBREVIATIONS


Bq Becquerel

EW Exempt Waste (Radioactive)

The Facility The Sandy Ridge Facility

g Gram

HLW High Level Waste (Radioactive)


TECDOC Technical Document published by IAEA

IBC Intermediate Bulk Container

ILW Intermediate Level Waste (Radioactive)

ISO International Organisation for Standardization


km Kilometres

kPa Kilopascals

L Litre

LLW Low Level Waste (Radioactive)

mSv/y Milli‐Sievert per year

NEPM National Environmental Protection Measure

NHMRC National Health and Medical Research Council

NORM Naturally Occurring Radioactive Materials

PPE Personal Protective Equipment

Tellus Tellus Holdings Ltd.

VLLW Very Low Level Waste (Radioactive)

ii

VSLW Very Short Lived Waste (Radioactive)


WAP Waste Acceptance Procedure

WZG Waste Zoning Guidelines

iii

DEFINITIONS

Cell ‐ an excavated area (pit) of kaolin which is below ground level which will be used for in cell

storage or permanent isolation of waste.

Conditions of storage – The term “in the conditions of storage” is used to differentiate between the

generic properties of a material and how those properties may be modified when that material is

placed into “in cell storage” or “permanent isolation” within a cell.

Dangerous goods – the Dangerous Goods Safety (General) Regulations 2007 defines “dangerous

goods” as any substance or article that is:

a) Found to be within any of the following classes or divisions under the Australian Dangerous

Goods Code: Class 1, Class 2, Class 3, Class 4, Class 5, Division 6.1, Class 8, or Class 9; unless

stated otherwise within the Code.

b) named or described in Schedule 1 of the Environmental Protection (Controlled Waste)

Regulations 2004

Geological repository (in the context of Sandy Ridge) ‐ The term geological repository is used to

mean a landfill facility constructed and with the equivalent properties of a Class IV or Class V Landfill

as defined in Landfill Waste Classification and Waste Definitions 1996 (As amended December 2009)

Western Australia Department Of Environment And Conservation. In the context of Sandy Ridge this

means an arid near‐surface facility used to permanently isolate waste. Geological repositories

provide the highest levels of containment through the use of carefully selected natural geological

barriers rather than reliance on man‐made liner systems and are increasingly recognised as a cost

effective and preferred method of permanently isolating difficult to manage wastes. The geological

barrier provides permanent isolation of wastes from the environment over the very long term and

creates additional opportunities for the future recovery and recycling of valuable materials from the

waste which can re‐enter the circular economy.

Hazardous waste ‐ Component of the waste stream which by its characteristics poses a threat or risk

to public health, safety or the environment (includes substances which are toxic, infectious,

mutagenic, carcinogenic, teratogenic, explosive, flammable, corrosive, oxidising and radioactive). As

defined in Landfill Waste Classification and Waste Definitions 1996 (As amended December 2009)

Western Australia Department Of Environment And Conservation

In Cell Storage – medium to long term below ground storage of wastes inside a cell with ongoing

opportunity to recover waste if required.

Intractable Waste ‐ Waste which is a management problem by virtue of its toxicity or chemical or

physical characteristics which make it difficult to dispose of or treat safely, and is not suitable for

disposal in Class I, II, III and IV landfill facilities. As defined in Landfill Waste Classification and Waste

iv

Notice and Certification Assurance program ‐ Tellus’ Notices and Certificates that include the

following: Customer Dispatch, Arrival and Rejection Notices and Tellus‐Acceptance©, Tellus‐

Storage©, Tellus‐Recovery© Tellus‐Solidification© and Tellus‐Permanent Isolation Certificates©.

Permanent Isolation – indefinite below ground storage of wastes determined suitable for

acceptance.

Storage – the short term above ground storage of materials following delivery and includes the time

awaiting sampling, analysis and management prior to movement for “in cell storage”.

v

Disclaimer:

The information contained in this document is for the purpose of supporting approvals

documentation and subsequently for use as an operational document for the Sandy Ridge Facility

only.

No section or element of this document may be removed from this document, reproduced,

electronically stored or transmitted in any form without the written permission of Tellus and should

be considered by any party other than Tellus to remain Commercial‐in‐Confidence. All rights

reserved.

All care and diligence has been exercised in interpreting data for the development of this document.

In any event, Tellus accepts no liability for any costs, liabilities or losses arising because of the use of,

or reliance upon, the contents of this report by any third party.

Tellus, as part of their continuous improvement activities will review and may update and amend this

document from time to time.

TCO‐5‐05‐002_0 Sandy Ridge Waste Acceptance Criteria.docx Page 1 of 21

1 INTRODUCTION

1.1 The Sandy Ridge Facility The proposed Sandy Ridge Facility (hereby referred to as the proposed “Facility”) is a dual use kaolin

mine with the voids created by mining used to store and permanently isolate hazardous and

intractable wastes. The site is located approximately 75 km northeast of Koolyanobbing, in the Shire

of Coolgardie, within the Goldfields Region of Western Australia (Figure 1‐1).

The location for the Facility was specifically chosen as its principal characteristics; semi–arid climate,

high rates of evaporation, geologically stable, natural geological barriers, no regional aquifer, no

surface water receptors, no flooding, low erosion rates, no heritage values, topography etc. satisfy

the requirements for a near surface geological repository for intractable and hazardous waste

storage and isolation purposes.

There are no sensitive receptors within the immediate vicinity of the proposed Facility. The nearest

operation is the Class V IWDF Mount Walton East Intractable Waste Disposal facility located

approximately 6 km to the east, which operates on a campaign basis and does not have permanent

residents. The nearest mining camp is the Carina Iron Ore Mine accommodation village located

approximately 52 km to the south east of the proposed Facility.

The arid and remote nature of the location, absence of nearby population, coupled with the site

characteristics make the site ideal for long‐term storage and permanent isolation of hazardous and

intractable waste.


Figure 1‐1: Sandy Ridge site location


1.2 Document Aims and Objectives The aim of this document is to present the Waste Acceptance Criteria (WAC) that will be applied at

the Facility. This document should be read in conjunction with the following:

Waste Acceptance Policy.

Waste Acceptance Procedure (WAP).

Waste Zoning Guide (WZG).

This document is part of a hierarchy of documents and is the tier 2 document which covers the WAC.

Lower tier documents provide greater detail on specific criteria and procedures.

The document hierarchy is presented in Figure 1‐2, which includes an equivalent suite of documents

for Tellus’ Northern Territory Chandler Project.

Figure 1‐2: Waste Acceptance Criteria Document Hierarchy

The objective of the Sandy Ridge WAC is to establish and explain to regulators, customers and other

stakeholders;

The criteria that will be applied for the exclusion of certain types of wastes.

The criteria that will be applied to the acceptance of certain types of wastes.

The requirement for suitable packaging and the criteria that will be applied for packaging

acceptance.

1.3 Intended Audience This document is intended initially for use by regulators responsible for assessing the facility and

issuing licences for the operation of the proposed Facility, and for the formation of procedures to

control the process by which waste producers and Tellus Staff will determine if the waste streams

may be suitable for storage or permanent isolation.

Tellus Waste Acceptance Policy

Sandy Ridge

Waste Acceptance Criteria

Waste Acceptance Procedure

Waste Zoning Guide

Apirnta Sidings



Waste Zoning Guide

Chandler



Waste Zoning Guide

TIER 1

TIER 2

TIER 3

TIER 4


The document will also be of interest to other stakeholders who wish to understand the approach

being followed by Tellus for waste acceptance, including the safe storage and permanent isolation of

wastes.

Finally, this document will be used by Tellus staff and their specialist advisors to establish the

framework that incorporates more detailed operational procedures which underpin this document.


2 WASTE ACCEPTANCE CRITERIA

2.1 Introduction Tellus is proposing to develop a world’s best practice facility designed for the storage and

permanent isolation of hazardous chemical waste. Tellus is also planning to accept waste arising

from the power, electronics, ceramics, mining, metals and minerals processing, oil and gas, water

and agricultural fertiliser industries that contains NORM. Tellus will apply for a Licence (Controlled

Action under Commonwealth legislation) to accept non‐nuclear low level radioactive waste (LLW)

such as sealed sources. The Sandy Ridge Environmental Scoping Document and Draft Public

Environmental Review state the wastes which will not be disposed of at the proposed Facility which

include; infectious materials, nuclear material1, intermediate and high level radioactive waste,

uncertified waste, and putrescible waste. A summary of the wastes which are proposed to be

accepted are presented in Table 2‐1.

Table 2‐1: Summary of waste acceptance classifications at Sandy Ridge

Waste classification Accepted

Chemical waste (NEPM Schedule A List 1: Waste categories) Yes

Naturally occurring radioactive waste (“NORM”) Yes

Low level radioactive waste (LLW) Yes

Intermediate level radioactive waste (ILW) No

High level radioactive waste (HLW) No

2.2 Excluded waste criteria It is normal when establishing waste acceptance criteria for storage and permeant isolation to first

determine which wastes, under normal circumstances, will not be accepted i.e. will be excluded. In

making this determination, and in keeping with best practice in similar facilities, including the Mount

Walton East Intractable Waste Disposal Facility (IWDF), wastes that may undergo undesired physical,

chemical or biological transformation after they have been deposited will not be accepted at Sandy

Ridge.

Materials possessing the following characteristics, unless they pass the WAC tests outlined in the

WAP, will normally be excluded from storage and permanent isolation at the Sandy Ridge Facility

1 Nuclear material as defined in the Nuclear Waste Storage and Transportation (Prohibition) Act 1999 ‐ is waste of a nuclear plant; or

results from the testing, use or decommissioning of nuclear weapons, whether or not that material has been conditioned or reprocessed


unless they can be modified to a form that makes them suitable for storage or permanent isolation,

and they subsequently pass the WAP tests.

2.2.1 Liquids

Unless they can undergo solidification/stabilisation processing to make them suitable for permanent

isolation, liquid wastes are to be excluded from permanent isolation at the proposed Facility. It is

assumed that containers containing liquids will eventually fail in the conditions of storage and allow

the liquid to seep into the encapsulating clay.

Although the adsorbent properties of the surrounding kaolin formation will prevent movement of

the wastes off‐site, it is possible that the loss of volume could damage the cap and allow infiltration

of water into the cell. Similarly, waste sludges are to be excluded from permanent isolation at the

Facility unless treatment can be applied to remove any free liquid and create a waste form which is

structurally sound and in keeping with maintaining the integrity of the cell capping.

2.2.2 Explosive materials

The following classes of materials, as defined by The Australian Code for the Transport of Dangerous

Goods by Road and Rail (2016) in the conditions of storage2 are not acceptable;

Class 1.1 – substances and articles that have a mass explosion hazard (a mass explosion is

one that affects almost the entire load virtually instantaneously).

Class 1.2 – substances and articles that have a projection hazard but not a mass explosion

hazard.

Class 1.3 – substances and articles that have a fire hazard and either a minor blast hazard or

a minor projection hazard or both, but not a mass explosion hazard. This includes substances

and articles that give rise to considerable radiant heat, or that burn one after another,

producing minor blast or projection effects or both.

Materials that are not themselves explosive but which have the potential to form or generate an

explosive atmosphere of gas or vapour may not be suitable for permanent isolation at the Facility.

This would depend on several factors such as the rapidity of vapour or gas generation and the

reactions involved and should be assessed by a suitably qualified person prior to acceptance being

confirmed.

2 The term in the conditions of storage is used to differentiate between the generic properties of a material and how those properties may

be modified when that material is placed into storage or is permanently isolated within a disposal cell.


2.2.3 Highly flammable materials

The following classes of materials, as defined in The Australian Code for the Transport of Dangerous

Goods by Road and Rail (2016), in the conditions of storage will not be accepted;

Class 3 – Flammable liquids. Liquids, or mixtures of liquids, or liquids containing solids in

solution or suspension which give off a flammable vapour at temperatures of not more than

60 °C, closed cup test, or not more than 65.6 °C, open‐cup test, normally referred to as the

flash point.

Class 4.1 – Flammable solids. Solids which, under conditions encountered in transport, are

readily combustible or may cause or contribute to fire through friction; self‐reactive

substances which are liable to undergo a strongly exothermic reaction; solid desensitised

explosives which may explode if not diluted sufficiently;

Class 4.2 – Substances liable to spontaneous combustion. Substances which are liable to

spontaneous heating under normal conditions encountered in transport, or to heating up in

contact with air, and being then liable to catch fire;

Class 4.3 – Substances which in contact with water emit flammable gases. Substances

which, by interaction with water, are liable to become spontaneously flammable or to give

off flammable gases in dangerous quantities.

Some substances that are flammable, such as wood and synthetic materials, may be acceptable for

permanent isolation if they require an open flame and oxygen for combustion since in the conditions

of storage they will be buried in an environment essentially devoid of both these characteristics.

Class 4.3 may be suitable in the conditions of storage due to the absence of water at the Facility.

2.2.4 Highly reactive materials

The following classes of materials, as defined in The Australian Code for the Transport of Dangerous

Goods by Road and Rail (2016), when in the conditions of storage will not be accepted:

Class 5 – Oxidising Substances. Substances that, while in themselves not necessarily

combustible, may, generally by yielding oxygen, cause, or contribute to, the combustion of

other materials.

Class 8 – Corrosive substances. Substances that, by chemical action, will cause severe

damage when in contact with living tissue, or, in the case of leakage, will materially damage

or even destroy, other goods or the means of transport; and may cause other hazards

Verification of the oxidising or corrosive nature of the material may be required, by a combination of

chemical (pH) and other corrosivity testing.


2.2.5 Gases

Gases will not be accepted at the Facility, even if altered into a liquid or solid form (e.g. compressed,

liquefied, dissolved, or adsorbed). Permanent isolation cannot be guaranteed, and gas migration

could cause a loss of volume within the permanent isolation cell, resulting in subsequent damage to

the capping system. This, in turn, leads to possible water infiltration into the cell, and uncontrolled

escape of the gas to the atmosphere.

2.2.6 Infectious materials

Infectious wastes such as “Clinical wastes” as defined in the Environmental Protection (Controlled

Wastes) Regulation 2004 includes waste generated by medical, nursing, dental, veterinary,

pharmaceutical or other related activity which is;

Poisonous or infectious.

Likely to cause injury to public health.

Contains human tissue or body parts.

The “Clinical and Related Waste Management Policy” has been developed and adopted by the

Government of Western Australia, Department of Health to control the permanent isolation of

clinical wastes.

2.2.7 Biodegradable materials

The IWDF Waste Acceptance Guidelines3 state that materials that are likely to decompose and

produce combustible hazardous gases, or wastes that decompose and become compressible are not

suitable for near‐surface disposal, since any significant volume reduction could compromise the

integrity of the capping system. In addition, gases generated within a waste cell have the potential

to create subsurface pathways, which could provide a route for subsequent rainwater ingress to the

cell. Such materials include organic, domestic wastes.

2.2.8 Nuclear material

The Nuclear Waste Storage and Transportation (Prohibition) Act 1999, defines nuclear waste as

material that is, or contains, a radioactive substance, provided that the material in question is either

waste from a nuclear plant, or waste resulting from the testing, use or decommissioning of nuclear

weapons, whether that material has been reprocessed or not. Wastes classified as nuclear wastes

will not be accepted at the proposed Sandy Ridge facility. For the avoidance of doubt the definition

of nuclear waste does not include waste that results from the use of the products of a nuclear plant.

3 Disposal Of Chemical Wastes At The Intractable Waste Disposal Facility, Mt Walton East Waste Acceptance Guidelines April 2011 Revision


2.3 Chemical waste acceptance

2.3.1 Introduction

The types and forms of chemical waste that are likely to be managed at the proposed Facility would

be generated from industry. Examples of these wastes and their NEPM code are listed in Table 2‐2.

Table 2‐2: Example chemical wastes likely to be suitable for permanent isolation at Sandy Ridge

NEPM code Waste description

N205 Residues from industrial waste treatment/disposal operations

D110 Inorganic fluorine compounds excluding calcium fluoride

N120 Soils contaminated with a controlled waste

N220 Asbestos

J120 Waste oil/water, hydrocarbons/water mixtures or emulsions

D220 Lead; lead compounds

C100 Basic solutions or bases in solid form

D230 Zinc compounds

J100 Waste mineral oils unfit for their original intended use

D300 Non‐toxic salts

B100 Acidic solutions or acids in solid form

N160 Encapsulated, chemically‐fixed, solidified or polymerised wastes referred to in this list

F100 Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish

M100 Waste substances and articles containing or contaminated with polychlorinated biphenyls, polychlorinated napthalenes, polychlorinated terphenyls and/or polybrominated biphenyls

N100 Containers and drums that are contaminated with residues of substances referred to in this list

N190 Filter cake contaminated with residues of substances referred to in this list

G110 Organic solvents excluding halogenated solvents

M250 Surface active agents (surfactants), containing principally organic constituents and which may contain metals and inorganic materials

A100 Waste resulting from surface treatment of metals and plastics

N150 Fly ash, excluding fly ash generated from Australian coal fired power stations

2.4 Radioactive waste acceptance

2.4.1 Introduction

The types and forms of radioactive waste that are likely to be managed at the proposed Facility

would be generated from:

Mining and processing of mineral ores or other material containing NORM, such as

phosphate minerals, mineral sands, coal, some gold bearing rocks and hydrocarbons. These

generally contain long lived radionuclides at relatively low concentrations. NORM such as


scales arising in the oil and gas industry may have higher activity concentration levels but

would still be categorised as low level wastes.

Intervention actions, which are necessary after accidents or to remediate areas affected by

past practices.

Medicine, research and industry (use of radioisotopes and sealed radioactive sources which

contains low activity concentrations).

Permanent isolation of disused sealed radioactive sources (including orphan sources).

All wastes need to be characterised by means of collecting information about the waste in order to

build up a picture of its properties. Data will be collected about the radiological, chemical and

physical properties of the waste. This information helps to decide how the waste should be handled,

packaged, stored and safely disposed of by the facility.

2.4.2 Classification of radioactive waste

Radioactive waste is defined as radioactive material in gaseous, liquid or solid form for which no

further use is foreseen, and which is controlled as radioactive waste by a regulatory body.

In Australia there are two principal documents which discuss the classification of radioactive waste:

The ARPANSA Safety Guide for the Classification of Radioactive Waste (2010) (RPS20).

NHMRC Code of practice for the near surface disposal of radioactive waste in Australia

(1992) (RHS35).

A system of categorising radioactive waste relating to near surface disposal is proposed in the

NHMRC Code of practice. The classification was based on international recommendations for

radioactive waste management adapted for the type of waste generated in Australia.

The categories suitable for near surface disposal are Category A, Category B and Category C.

Category S is not suitable for near surface disposal. This classification summarised in Table 2‐3. The

classification is only used by regulatory authorities to classify waste destined for disposal, not as a

general classification system.


Table 2‐3: Code of practice for the near surface disposal of radioactive waste in Australia (1992) ‐ waste classification summary

Waste category near surface code

Definition

Category A waste Category A waste covers solid waste with radioactive constituents, mainly beta or gamma emitting radionuclides. Long‐lived alpha‐emitting radionuclides should only be present at very low concentrations. This category of waste will comprise, predominantly, lightly contaminated or activated items such as paper, cardboard, plastics, rags, protective clothing, glassware, laboratory trash or equipment, certain consumer products and industrial tools or equipment. It may also comprise lightly contaminated bulk waste from mineral processing or lightly contaminated soils.

Category B waste Covers solid waste and shielded sources with considerably higher activities of beta‐ or gamma‐emitting radionuclides than Category A waste. Long‐lived alpha‐emitting radionuclides should be at relatively low levels. This category of waste will comprise, typically, gauges and sealed sources used in industry, medical diagnostic and therapeutic sources or devices, and small items of contaminated equipment.

Category C waste Covers solid waste containing alpha‐, beta‐ or gamma‐emitting radionuclides with activity concentrations similar to those for Category B. However, this waste typically will comp rise bulk materials, such as those arising from downstream processing of radioactive minerals, significantly contaminated soils, or large individual items of contaminated plant or equipment for which conditioning would prove to be impractical

Category S waste Covers waste that does not meet the specifications of Categories A, B or C. Typically this category will comprise sealed sources, gauges or bulk waste which contains radionuclides at higher concentrations than are allowable under Categories A, B or C.

The classification of radioactive waste has been defined in international standards developed by the

International Atomic Energy Agency (IAEA). The ARPANSA Safety Guide for Classification of

Radioactive Waste (2010) largely reflects this international guidance. It does not include quantitative

values of allowable activity content for each significant radionuclide.

Radioactive waste generated in Australia generally falls within the very short lived waste (VSLW),

very low level waste (VLLW), low level waste (LLW) or intermediate level waste (ILW) classifications.

Australia does not generate any electricity from nuclear power and therefore currently does not

generate any used fuel that would be classified as high level waste (HLW).

Figure 2‐1 presents a conceptual illustration of the waste classification system and potential

permanent isolation options. Tellus is seeking approval to accept radioactive wastes that will fall into

the EW, VSLW, SLW and LLW classifications.


Figure 2‐1 Conceptual illustration of the waste classification system and potential permanent isolation options

2.4.3 Acceptance criteria

The effective management of EW, VSLW, VLLW and LLW depends on knowledge of the waste

characteristics and the contained radioactivity.

The proposed Facility seeks approval for a wide variety of waste, ranging from lightly contaminated

soil to sealed sources. The design of the Facility allows for a range of containers to be used for

different types of waste, for example 200‐litre drums and engineered concrete canisters or other

modular containers or structures that meet containment and structural requirements

The property of radioactive waste varies, not only in terms of radioactive content and activity

concentration but also in terms of physical and chemical properties. A common characteristic of all

radioactive waste is its potential to present a hazard to people and to the environment, and it must

be managed so as to reduce any associated risk to acceptable levels as defined by regulations which

consider both the operational and post closure phases the Facility.


Predisposal management of radioactive waste

The overall objective of predisposal management of radioactive waste is to produce waste packages

that can be handled, transported, stored and disposed securely and safely. In addition to compliance

with individual dose limits, the practices that are adopted in waste conditioning, such as grouting,

packaging and other containment, shall be carried out so that any potential exposure will be as low

as reasonably achievable.

A brief summary of how Tellus proposes to manage radioactive waste accepted at the proposed

Facility is presented below. More detail on exposure control and waste management practices is

given in the Radioactive Waste Management Plan.

NORM containing pastes, sludges and liquids

Once delivered to site, NORM containing pastes, sludges or liquids will be stored in the radioactive

waste warehouse or in sea containers on hardstand (dependent upon activity). In campaigns, waste

will be unpacked, inspected and verified by laboratory testing. If required, the waste will then be

treated with absorbent and pozzolanic materials to form slurry, which will solidify and stabilise the

waste. The slurry can be poured into drums, moulds, or contained sections of the cell where it will

set. This waste will then be covered with kaolin or other suitable material which will be compacted

to maintain structural integrity of the cell.

Contaminated solid materials

Contaminated solid material such as pipes and valves will be stored in the radioactive waste

warehouse or in sea containers on a hardstand (dependent upon activity) until suitable space is

available in cell. Depending upon physical size and shape of materials, type and activity of radiation,

these wastes will either be:

Compacted into drums and filled with kaolin or cement grout prior to permanent isolation.

Crushed or cut to remove void space and remaining voids filled in with cement grout or

kaolin solids.

Placed in a sea‐container in the cell, holes cut in top of container and all void space filled

with cement grout.

These actions are taken to remove void space in the materials which could cause structural

instability within the cell with the potential to disturb the cell cap.

Contaminated soil or sands (bulk material)

Bulk contaminated soils or sands will be delivered to site in either bulk bags, shipping containers or

other appropriate transport vehicles, depending on volume and physical characteristics of the

material. Where possible, transport will be arranged to coincide with a campaign so it can be

disposed of directly into a cell, but if not viable, the material will be stored in the radioactive waste

warehouse. For large volumes of material, separate stockpile areas will be set up (ad hoc stockpiles),


and dust control measures introduced. These are discussed in the Radiation Management Plan and

include a designated stockpile area with concrete slab and bunded walls, closing stockpile with tarp

material, dust suppression agents and a monitoring program to confirm efficiency of controls

implemented. The bulk material can be disposed of directly in the cell, diluted or mixed with other

material, or set in concrete if required.

NORM and bulk wastes

In order to derive activity concentrations limits for individual radionuclides in NORM and bulk

wastes, two criteria have been used:

Dose rate to a human receptor post closure (with capping material in place) to not exceed a

dose constraint of 0.3 mSv in a year. An occupancy of 3.5 days a year was assumed as per

ARPANSA TRS No. 141 for an arid and remote site.

Dose rate to a human receptor upon intrusion (no capping) corresponding to 10mSv/y. as

per ICRP guidance on radiological criteria applied to human intrusion.

The RESRAD (Onsite) code was used, to determine radionuclide activity concentration levels in bulk

NORM wastes which would give rise to conditions as specified above for post closure and intrusion

scenarios. Details of assessment are presented in the Radiological Risk Assessment: Post Closure

report. Table 2‐4 summarises the radionuclide restrictions that will be applied at the Facility for the

disposal of NORM bulk wastes.

For bulk NORM wastes having mixtures of radionuclides, an additional constraint should be adhered

to so that the total dose from all radionuclides should not exceed relevant dose limits or constraints.

This is referred to as the summation rule and requires the following constraint:

Where Qi (Bq) is the actual activity of radionuclide i to be disposed and Qi,l (Bq) is the activity limit

for radionuclide if it were the only radionuclide to be disposed of.

Table 2‐4: Waste Acceptance Criteria (WAC) for the Facility for bulk NORM waste

Radionuclides Half Life Individual Radionuclide Activity Concentration of Bulk

NORM Waste (Bq/g)

(Bq/g) to achieve 10 mSv/y upon Intrusion

U‐238 4.468 billion years 1.0E+05

U‐234 246,000 years 2.0E+06

Th‐230 75,380 years 1.2E+04


U‐235 703.8 million 2.2E+04

Pa‐231 32,760 years 7.1E+03

Ra‐226 1600 years 1.8E+03

Th‐232 14.05 billion years 1.1E+03

Sealed sources

Sealed sources will, upon receipt, be stored in the radioactive waste warehouse, unpacked,

inspected and verified. After verification, sources will be secured in a 60 L drum inside a 200 L drum.

Cement slurry will be added to the 60 L drum to fill all the void spaces and to cover all the items. The

cement filled 60 L drums will be placed in the centre of a 200 L drum, which will then be filled with

concrete or equivalent materials. The 200 L drum will be marked with its identification number and

labelled. These drums will be stored until the shaft is prepared for disposal. Drums will then be

transferred to the cell, loaded into the shaft and covered with fill/grout.

WAC for the facility are based on the design of the facility, including, but not limited to, such items

as the engineered barriers, duration of institutional control and site specific characteristics such as

geology, low rainfall, lack of receptors, etc.

The activity of the radionuclides present in the radioactive waste packages will be limited in such a

way that the radiological impact of the site remains within acceptable levels during the operational

and post‐closure phases of the site. In accordance with International Atomic Energy Agency (IAEA)

waste are considered as a function of their half‐life and activity concentration. Radiation doses to

the public and workers as a consequence of waste management, storage and disposal activities are

not to exceed the dose limits in Regulations 59 and 60 of the ARPANS Regulations. The effective

dose limit for occupational exposure is 20 mSv annually, averaged over 5 consecutive calendar years.

However, the effective dose for a person subject to occupational exposure must not, in a year, be

greater than 50 mSv. The effective dose limit for public exposure is 1 mSv annually).

The ARPANSA Licensing of Radioactive Waste Storage and Disposal Facilities March 2013 explains

that waste acceptance should be undertaken in accordance with Section 2.6 of the Near‐Surface

Disposal Code, Specific criteria and requirements for waste acceptance and disposal. Guidance on

determining waste activity limits for low level waste in near‐surface disposal facilities is found in the

IAEA TECDOC Derivation of Activity Limits for the Disposal of Radioactive Waste in near Surface

Disposal Facilities (IAEA‐TECDOC‐1380, 2003).

The following generic limits will be adopted for the Sandy Ridge Facility (Category B levels as per

NHMRC (1992) and ARPANSA (2010)). Waste packages with activity concentration greater than

those specified in Table 2‐5 will not be accepted for disposal without reassessing the safety case and

seeking approval from the relevant regulatory bodies.

Waste acceptance criteria, and the specific limitations on activity, will follow the safety analysis,

during operations and for the long term, taking into account the applicable radiological criteria. The


Sandy Ridge site meets the general criteria for a near surface geological repository set by the

NHMRC (1992).

Table 2‐5: Generic Concentration Limits for Sealed sources‐LLW for 100 year Institutional Control Period (ICP) [Ref NHMRC (1992)]

LLW Concentration limit (Bq/kg) Concentration limit (Bq)4

100 years 100 years ICP

Tritium 1.00E+11 2.00E+13

Carbon‐14 5.00E+08 1.00E+11

Radium‐226 5.00E+06 1.00E+09

Alpha (α) emitting radionuclides (Am‐241,U‐238,PU‐239)

1.00E+08 2.00E+10

Beta (B) /gamma (γ)emitters with

half‐lives > 5y

1.00E+09 2.00E+11

Beta (B) /gamma (γ)emitters with

half‐lives ≤ 5y

no limit no limit

Table 2‐6 summarises the Waste Acceptance Criteria (WAC) proposed for the disposal of Sealed

Sources. The activity of the radionuclides present in the radioactive waste packages will be limited in

such a way that the radiological impact of the site is within the dose constraint limits under

foreseeable circumstances. Sources at activity Concentration levels above those specified in the

table will not be accepted for permanent isolation without re‐assessing the safety case and seeking

approval from the relevant regulatory bodies.

4 Assumes a bulk density of 1 kg/L. The concentration of a radionuclide in the waste package as presented for disposal is calculated by averaging the activity of the source over the weight of the whole conditioned package. For example, the activity of sealed sources, which have been conditioned by being embedded in a solid matrix, can be averaged over the weight of the solid waste matrix. However, to reduce the risks from any future inadvertent intrusion, only one sealed source should be incorporated in a single conditioned package. An industrial gauge source in its approved housing will most likely meet the requirements for disposal if embedded in concrete. In practice, a limit on the maximum activity per package for beta/gamma emitting radionuclides with half‐lives of 5 years or less, including cobalt‐60, will be imposed by occupational and transport considerations. ARPANSA (2010) Technical Report No. 152)


Table 2‐6: limits for common sources based on NHMRC near surface code (1992)

Radioisotope Symbol Half‐life Decay Concentration limit (Bq)*

100 years ICP

Americium‐241 Am‐241 432.17 y α 2.00E+10

Barium‐133 Ba‐133 10.74 years EC no limit

Caesium‐137 Cs‐137 30.07 years γ/β 2.00E+11

Californium‐252 Cf‐252 2.6 years α 2.00E+10

Carbon‐14 C‐14 5 715 years β 2.00E+11

Chlorine‐36 Cl‐36 301,000 years β 2.00E+11

Chromium‐51 Cr‐51 2.7 days EC no limit

Cobalt 57 Co‐57 271.8 days EC no limit

Cobalt‐60 Co‐60 5.27 years γ no limit

Gold‐198 Au‐198 2.7 days β no limit

Hydrogen‐3 (tritium) H‐3 12.32 years β 2.00E+11

Indium‐111 In‐111 2.80 days EC no limit

Iodine‐129 I‐129 15.7 million years β 2.00E+10

Iridium‐192 Ir‐192 73.8 days γ/B 2.00E+10

Krypton‐85 Kr‐85 10.5 years β 2.00E+11

Iron‐55 Fe‐55 2.74years EC no limit

Lead‐210 Pb‐210 22.6 years β 2.00E+11

Manganese‐54 Mn‐54 312.1 days EC no limit

Molybdenum‐99 Mo‐99 66 hours β no limit

Nickel‐63 Ni‐63 96 Years β 2.00E+11

Polonium‐210 Po‐210 138 days α 2.00E+10

Radium‐226 Ra‐226 1,600 years α 1.00E+09

Selenium‐75 Se‐75 120 days γ no limit

Sodium‐22 Na‐22 2.6 years γ no limit

Strontium‐90 Sr‐90 28.8 years β 2.00E+11

Technetium‐99m Tc‐99m 6.01 days γ no limit

Thallium‐204 Tl‐204 3.78 years β no limit

Thulium‐170 Tm‐170 129 days β no limit

Ytterbium‐169 Yb‐169 32 days EC no limit

Zinc‐65 Zn‐65 243.87 days EC no limit

*(alpha (α), Beta (β), Gamma (γ) or Electro capturing (EC))


3 WASTE PACKAGING CRITERIA

The Australian Code for the Transport of Dangerous Goods by Road and Rail (2016) details the

requirements for safe packaging and transport of hazardous materials, based on the classification of

the waste. Tellus requires that all customers adhere to the code to ensure packaging is appropriate

to the hazardous characteristics of the waste in question. Containment systems should normally

consist of one or more of the following packaging options;

20’ ISO shipping containers or 20’ ISO tank‐container.

Bulk bags in containers, on pallets or free standing.

215 Litre drums on pallets in containers.

1m3 IBCs in containers.

Small palletised goods in containers (e.g. radioactive materials).

Loose bulk in containers (e.g. contaminated soils).

Liquid tanker truck (e.g. bulk liquids or pastes) which will undergo solidification or

stabilization treatments.

Pneumatic tanker truck (e.g. bulk dry powder solids).

Solid materials on flatbed trucks (e.g. railway sleepers, O&G pipe, machinery).

Typical Packaging examples are presented in Appendix A.1

3.1 Packaging criteria The original IWDF Waste Acceptance Guidelines 2011 provide clear criteria for the packaging of

waste for delivery to the Mount Walton East site, which is presented below. Tellus have considered

the IWDF packaging requirements to be consistent with industry best practices; therefore waste

packaging delivered to the proposed Facility must fulfil the following criteria:

Not have a total measured weight of more than the Safe Working Load.

Be capable of being disposed of with the waste.

Be filled so as to contain no significant voids.

Be free of ruptures at the point of delivery.

Be free of external contamination at the point of delivery.

Not significantly deteriorate during the duration of storage, transport and handling when in

contact with the waste.

Remain intact during normal transport and handling procedures.

Be strong enough to be walked on if required.


Be clearly labelled with the waste owner’s name and identification number and material

description/name on opposite sides of the waste package.

Allow no leakage during normal transport and handling operations.

Be capable of containing all the waste whatever the orientation of the package.

3.2 Mitigating package failure It can be anticipated that packaging containers have the potential to fail in the conditions of storage

if no other consideration is given to the form of the packaging and wastes contained therein. To

minimise the likelihood and potential impacts of packaging failure, the following measures are

required to be undertaken:

Void spaces inside containers are to be minimised – packages shall be grout filled or similar

to remove voids inside any container that will be disposed with the waste.

Low density wastes (PPE etc.) should be baled or similarly compacted to the highest density

reasonably and practicably achieved (as close to 200 kPa as practical to be consistent with

the available backfill materials). This compaction activity should be undertaken prior to any

grout filling.

Low density wastes should be identified so that, as far as practicable during the receival

activity at site, be segregate for special attention in the development of the cell filling plan.

Low density waste should be packaged in smaller vessels, or should be packaged and

disposed as long shallow packages to reduce the scale of any settlement or failure.


4 BIBLIOGRAPHY

Australian Radiation Protection and Nuclear Safety Agency, 2010, Classification of Radioactive Waste

Radiation Protection Series Publication No. 20, available at:

http://www.arpansa.gov.au/pubs/rps/rps20.pdf

Australian Radiation Protection and Nuclear Safety Agency, 2010, Classification and Disposal of

Radioactive Waste in Australia – Consideration of Criteria for Near Surface Burial in an Arid Area,

available at: http://www.arpansa.gov.au/pubs/technicalreports/tr152.pdf.

Australian Radiation Protection and Nuclear Safety Agency, 2013, Licensing of Radioactive Waste

Storage and Disposal Facilities, available at: http://www.arpansa.gov.au/pubs/waste/WasteGuide‐

March2013.pdf

Australian Radiation Protection and Nuclear Safety Agency, 2005, Scientific Basis for the near Surface

Disposal of Bulk Radioactive Wastes Technical Report Series No. 141, available at:

http://www.arpansa.gov.au/pubs/technicalreports/tr141.pdf

Commonwealth of Australia, 2016, Australian Code for the Transport of Dangerous Goods by Road

and Rail, edition 7.4, available at:

https://infrastructure.gov.au/transport/australia/dangerous/dg_code_7e.aspx.

Department of Environment and Conservation, 1996 (as amended 2009), Landfill Waste

Classification and Waste Definitions, available at:

http://www.wasteauthority.wa.gov.au/media/files/documents/landfill_waste_classification.pdf

Department of Environment Regulation, 2014, Environmental Protection (Controlled Wastes)

Regulation 2004, available at:

https://www.slp.wa.gov.au/legislation/statutes.nsf/main_mrtitle_1387_homepage.html

Department of Health, 2016, Clinical and Related Waste Management Policy, available at:

http://www.health.wa.gov.au/circularsnew/attachments/1131.pdf

Department of Mines and Petroleum, 2016, Dangerous Goods Safety (General) Regulations 2007,

available at:


Department of Treasury and Finance, 2011, Disposal of Chemical wastes at the Intractable Waste

Disposal Facility (mount Walton East) – Waste Acceptance Guidelines.

Environment Agency, 2010, Waste Acceptance at Landfills, available at:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/296422/geho1110

btew‐e‐e.pdf


Health Department of Western Australia, 2007, Nuclear Waste Storage and Transportation

(Prohibition) Act 1999, available at:


International Atomic Energy Agency, 2003, Derivation of Activity Limits for the Disposal of

Radioactive Waste in near Surface Disposal Facilities (IAEA‐TECDOC‐1380), available at: http://www‐

pub.iaea.org/MTCD/publications/PDF/te_1380_web.pdf

National Environment Protection Council, 1998, National Environment Protection (Management of

Controlled Waste between States and Territories) Measure, available at:

https://www.legislation.gov.au/Details/F2012C00858/

National Health and Medical Research Council, 1992, Code of practice for the near surface disposal of

radioactive waste in Australia (RHS35), available at: http://www.arpansa.gov.au/pubs/rhs/rhs35.pdf

TCO‐5‐05‐002_0 Sandy Ridge Waste Acceptance Criteria.docx

A.1 Potential waste category list

Common industrial hazardous waste (NEPM basis)

Acidic solutions or acids in solid form B100

Animal effluent and residues (abattoir effluent, poultry and fish processing wastes) K100

Antimony; antimony compounds D170

Arsenic; arsenic compounds D130

Asbestos N220

Barium compounds (excluding barium sulphate) D290

Basic solutions or bases in solid form C100

Beryllium; beryllium compounds D160

Boron compounds D310

Cadmium; cadmium compounds D150

Ceramic‐based fibres with physio‐chemical characteristics similar to those of asbestos N230

Chlorates D350

Chromium compounds (hexavalent and trivalent) D140

Clinical and related wastes R100

Cobalt compounds D200

Containers and drums that are contaminated with residues of substances referred to in this list

N100

Copper compounds D190

Cyanides (inorganic) A130

Cyanides (organic) M210

Encapsulated, chemically‐fixed, solidified or polymerised wastes referred to in this list N160

Ethers G100

Filter cake contaminated with residues of substances referred to in this list N190

Fire debris and fire wash waters N140

Fly ash, excluding fly ash generated from Australian coal fired power stations N150

Grease trap waste K110

Halogenated organic solvents G150

Highly odorous organic chemicals (including mercaptans and acrylates) M260

Inorganic fluorine compounds excluding calcium fluoride D110

Inorganic sulfides D330

Isocyanate compounds M220

Lead; lead compounds D220

Mercury; mercury compounds D120

Metal carbonyls D100

Nickel compounds D210

Non‐toxic salts D300

Organic phosphorous compounds H110

Organic solvents excluding halogenated solvents G110

Organo halogen compounds—other than substances referred to in this Table. M160

Perchlorates D340

Phenols, phenol compounds including chlorophenols M150



Phosphorus compounds excluding mineral phosphates D360

Polychlorinated dibenzo‐furan (any congener) M170

Polychlorinated dibenzo‐p‐dioxin (any congener) M180

Residues from industrial waste treatment/disposal operations N205

Selenium; selenium compounds D240

Soils contaminated with a controlled waste N120

Surface active agents (surfactants), containing principally organic constituents and which may contain metals and inorganic materials

M250

Tannery wastes (including leather dust, ash, sludge’s and flours) K140

Tellurium; tellurium compounds D250

Thallium; thallium compounds D180

Triethylamine catalysts for setting foundry sands M230

Tyres T140

Vanadium compounds D270

Waste chemical substances arising from research and development or teaching activities, including those which are not identified and/or are new and whose effects on human health and/or the environment are not known

T100

Waste containing peroxides other than hydrogen peroxide E100

Waste from heat treatment and tempering operations containing cyanides A110

Waste from manufacture, formulation and use of wood‐preserving chemicals H170

Waste from the production and preparation of pharmaceutical products R140

Waste from the production, formulation and use of biocides and phytopharmaceuticals H100

Waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish

F100

Waste from the production, formulation and use of organic solvents G160

Waste from the production, formulation and use of photographic chemicals and processing materials

T120

Waste from the production, formulation and use of resins, latex, plasticisers, glues and adhesives

F110

Waste mineral oils unfit for their original intended use J100

Waste of an explosive nature not subject to other legislation T200

Waste oil/water, hydrocarbons/water mixtures or emulsions J120

Waste pharmaceuticals, drugs and medicines R120

Waste resulting from surface treatment of metals and plastics A100

Waste substances and articles containing or contaminated with polychlorinated biphenyls, polychlorinated napthalenes, polychlorinated terphenyls and/or polybrominated biphenyls

M100

Waste tarry residues arising from refining, distillation, and any pyrolytic treatment J160

Wool scouring wastes K190

Zinc compounds D230


A.2 Packaging examples

4 Plastic drums on a pallet

4 Plastic drums on a pallet ‐ clingwrapped

4 Steel drums on a pallet


Bulk bags on pallets

Plastic drums in sea containers

Bulk bags in sea containers


APPENDIX 3: WASTE ACCEPTANCE PROCEDURE

SANDY RIDGE FACILITY WASTE ACCEPTANCE PROCEDURE

Document No.: TCO‐6‐SR‐01400‐GE‐PRO‐0001




0 10/08/2016 Issued for use S. Reece J.Livesey

R.Phillips

D van der Merwe

Table of Contents

Abbreviations .................................................................................................................................. i

Definitions ..................................................................................................................................... iii

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

1.1 The Sandy Ridge Facility .................................................................................................. 1

1.2 Document aims and objectives ....................................................................................... 3

1.3 Intended audience .......................................................................................................... 4

2 Context ................................................................................................................................... 5

2.1 Waste Acceptance Criteria .............................................................................................. 5

2.2 Waste Acceptance Procedure ......................................................................................... 5

2.3 Waste Zoning .................................................................................................................. 6

3 Waste Characterisation ........................................................................................................... 7

3.1 Basic characterisation ..................................................................................................... 7

3.2 Compliance testing .......................................................................................................... 9

3.3 On‐site verification .......................................................................................................... 9

4 Gated Waste Acceptance Procedure ...................................................................................... 10

Gate 1 – Is the waste on the potential waste category list ...................................................... 12

Gate 2 – Has the waste been identified as likely for future recovery? .................................... 14

Gate 3 – Gases, liquids and sludges ......................................................................................... 14

Gate 4 ‐ Does the waste possess hazardous characteristics which, in the conditions of

storage, are explosive, corrosive, oxidizing, or highly flammable? ......................................... 15

Gate 5 – Is the waste potentially self combustible and liable to Auto‐Ignition? ..................... 20

Gate 6 – Can the waste generate a gas‐air mixture which is toxic or explosive? .................... 21

Gate 7 – Is the waste biodegradable? ...................................................................................... 22

Gate 8 – Is the waste an infectious hospital or clinical waste (H6.2)? ..................................... 22

Gate 9 – Does the waste have the potential to be infectious to animals or humans (H6.2)? . 23

Gate 10 – Tyres ........................................................................................................................ 23

Gate 11 – Conditions of Storage criteria. Can the waste and/or its container, release liquid,

or react with the host clay in the facility which could affect either the operational and/or

post closure safety of the facility? ........................................................................................... 24

Gate 12 – Is the waste radioactive? ......................................................................................... 25

Gate 13 – Does the waste meet the packaging criteria? ......................................................... 27

5 Radioactive Waste ................................................................................................................. 29

5.1 Waste Acceptance Procedure for radioactive waste .................................................... 29

5.2 Norm and bulk wastes .................................................................................................. 29

5.3 Sealed Sources .............................................................................................................. 30

6 Rejected Wastes .................................................................................................................... 33

7 Notification and Certification ................................................................................................ 34

7.1 Traceability, Approval System and Documents ............................................................ 34

7.2 Notification Service ....................................................................................................... 34

7.3 Documents ‐ Certification Service ................................................................................. 36

7.4 Waste Title and Management risk ................................................................................ 37

8 Bibliography .......................................................................................................................... 38

LIST OF FIGURES



Figure 4‐1: Waste Acceptance Procedure summary – (Refer to Appendix A.1 for Detailed Flow Chart)

.............................................................................................................................................................. 11

Figure 4‐2: Basic Characterisation Form ............................................................................................... 13

Figure 5‐1: Radioactive waste acceptance procedure .......................................................................... 32

Figure 7‐1: Tellus' traceability process .................................................................................................. 34

LIST OF TABLES

Table 4‐1: Uniform corrosion mass loss criteria ................................................................................... 17

Table 4‐2: Localised corrosion intrusion criteria ................................................................................... 17

Table 5‐1: Waste Acceptance Criteria (WAC) for the Facility for bulk NORM waste ............................ 30

Table 5‐2: Limits for common sources based on NHMRC near surface code (1992) ........................... 31

LIST OF APPENDICES

Gated waste acceptance process flow chart

Potential waste category list

i

ABBREVIATIONS

AC Acceptance Certificate

ASTM American Society for Testing and Materials


Bq Becquerel



IAEA TECDOC Technical Document published by IAEA

IBC Intermediate Bulk Container

ISO International Organisation for Standardization


kPa Kilopascals

m metre

MSDS Material Safety Data Sheet


NHRMC National Health and Medical Research Council


PIC Permanent Isolation Certificate

PPE Personal Protective Equipment

SC Storage Certificate


TOC Total Organic Carbon


WAP Waste Acceptance Procedures

ii

WCD Waste Classification Definitions


iii

DEFINITIONS



Conditions of storage ‐ The term “in the conditions of storage” is used to differentiate between the









Regulations 2004

















In Cell Storage ‐ medium to long term below ground storage of wastes inside a cell with ongoing


Intractable Waste‐ Waste which is a management problem by virtue of its toxicity or chemical or



iv

Definitions 1996 (As amended December 2009) Western Australia Department Of Environment And

Conservation

Permanent Isolation ‐ indefinite below ground storage of wastes determined suitable for

acceptance.

Storage ‐ the short term above ground storage of materials following delivery and includes the time


v

Disclaimer:



only.



be considered by any party other than Tellus to remain Commercial‐in‐Confidence. All rights reserved.






TCO‐5‐05‐003_0 Sandy Ridge Waste Acceptance Procedure.docx Page 1 of 39

1 INTRODUCTION


mine with the voids created by mining used to store and permanently isolate hazardous and

intractable wastes. The site is located approximately 75 km northeast of Koolyanobbing, in the Shire

of Coolgardie, within the Goldfields Region of Western Australia (Figure 1‐1).




the requirements for a near surface geological repository for intractable and hazardous waste









intractable waste.




1.2 Document aims and objectives The aim of this document is to present the Waste Acceptance Procedure (WAP) that will be used at

the proposed Sandy Ridge Facility to determine if wastes meet all of the acceptance criteria. This

document should be read in conjunction with the following:

Tellus Waste Acceptance Policy.

Sandy Ridge Waste Acceptance Criteria (WAC).

Sandy Ridge Waste Zoning Guide (WZG).

This document is part of a hierarchy of documents and is a tier 3 document as highlighted in Figure

1‐2 below. Tier 3 documents work together with tier 4 documents to provide details of specific

operational procedures and include the development of an assumed inventory1 for storage and

permanent isolation. The assumed inventory will in turn inform the licence application submitted to

the regulator.

The document hierarchy is presented in Figure 1‐2, and includes an equivalent suite of documents

for Tellus’ Northern Territory Chandler Project which includes the Apirnta rail sidings where waste

acceptance will be carried out..


Having established the overarching waste exclusion criteria to be applied at the proposed Facility

(refer to WAC), a gated WAP (this document), using specified test methods and criteria values will be

1 Due to the variability in the wastes that could be encountered at the proposed Facility, the assumed inventory is likely to be subject to change and should be considered as an initial guide for the acceptance of the various wastes listed. Changes to the inventory are to be controlled by a suitably qualified person(s) making decisions in accordance with the principles presented in this document.


Sandy Ridge



Waste Zoning Guide

Apirnta Sidings



Waste Zoning Guide

Chandler



Waste Zoning Guide

TIER 1

TIER 2

TIER 3

TIER 4


applied to determine if a waste can be accepted. The gated procedure is set out in Appendix A.1,

with an explanation of each step and corresponding test method provided in Section 3.

In addition to considering the specific characteristics of the waste, consideration is also given to how

the wastes will perform in the conditions of storage and permanent isolation. This assessment will

be performed by a suitably qualified person who has the necessary skill in determining such matters.

Wastes will need to pass through each waste acceptance “criteria gate” to be accepted for in cell

storage or permanent isolation at the Sandy Ridge facility.

1.3 Intended audience This document is intended initially for use by regulators responsible for assessing the facility and

issuing licences for the operation of the proposed Facility, and for the formation of procedures to

control the process by which waste producers and Tellus Staff will determine if the waste streams

may be suitable for storage or permanent isolation.



wastes.

Finally, this document will be used by Tellus staff and their specialist advisors to establish the

framework that incorporates more detailed operational procedures which underpin this document.


2 CONTEXT

Tellus Waste Acceptance Policy establishes the context and importance of effective Waste

Acceptance Procedures. The Policy states before waste can be accepted for storage or permanent

isolation at the proposed Sandy Ridge Facility, Tellus must be satisfied that the waste meets agreed

acceptance criteria, has been subject to the tests set out in the WAP and that the waste can be

accepted in accordance with Approvals and Licences issued by regulators.

2.1 Waste Acceptance Criteria WAC have been established to determine waste types which can and cannot be accepted when

considering the characteristics and design of the site to achieve safe operation of the facility and to

ensure long term environmental protection through containment of potential pollutants present

within the wastes. In some cases the criteria used will lead to straightforward “go or no go”

decisions based on compatibility with the site characteristics and WAC, and in other cases

acceptance values and parameters will be used.

Whilst Tellus will ensure that waste generators are aware of the WAC for the Facility, it is recognised

that on some occasions particular wastes presented will not conform to set criteria and re‐

evaluation of appropriate management techniques will be required so as to achieve the objective of

safe storage or permanent isolation so that the threat to the receiving environment is minimised or

prevented.

2.2 Waste Acceptance Procedure As part of the WAP it is necessary to first characterise the waste material. Tellus have adopted a

three stage approach to waste characterisation2, which is summarised below. The most detailed

characterisation takes place to determine if waste meets the overarching criteria and licence

conditions of the site, followed by further ongoing testing at levels 2 and 3 described below.

Level 1: Basic characterisation. This is a thorough determination, according to standardised

analysis and behaviour‐testing methods, of the characteristic properties of the waste.

Level 2: Compliance testing. This is periodic testing of regularly arising wastes by simpler

standardised analysis methods to determine whether a waste complies with licence

conditions and whether a waste with known properties has changed significantly.

Level 3: On‐site verification. This constitutes rapid check methods to confirm that a waste is

the same as that which has been subjected to compliance testing and that which is

described in the accompanying documents.


For acceptance at the proposed Sandy Ridge Facility wastes need to continually meet the acceptance

criteria laid down for the site in WAC document. Criteria compliance is therefore continually tested

by using the three levels of basic characterisation, compliance testing and on‐site verification, which

is outlined in detail in this document.

2.3 Waste Zoning After wastes have been accepted at the proposed Facility, it is important that they are both stored

and disposed of in a safe manner. The wastes that Tellus are planning to accept, many of which are

classified as Dangerous Goods, will be grouped into compatible waste type groups that can be stored

and disposed of together. Whilst in transit and surface storage Dangerous Goods Segregation

protocols will be adopted (AS/NZ 3833 Figure 6.1).

When the waste is placed into a cell for permanent isolation, waste zoning protocols will be

implemented, as presented in the WZG. The WZG have been developed to reflect the conditions of

storage within the cell and how the various wastes can be stored or permanently isolated without

adverse interaction. Adopting a zoning approach also increases the opportunity for potential future

recovery of certain materials for beneficial use.


3 WASTE CHARACTERISATION

As part of the WAP it is necessary to first characterise the waste material. Tellus have adopted a

three stage approach to waste characterisation3 which is summarised below. The most detailed

characterisation takes place to determine if waste meets the overarching criteria and licence

conditions of the site, followed by further ongoing testing at levels 2 and 3 described below.


analysis and behaviour‐testing methods, of the characteristic properties of the waste.

Level 2: Compliance testing. This is periodic testing of regularly arising wastes by simpler

standardised analysis methods to determine whether a waste complies with licence

conditions and whether a waste with known properties has changed significantly.




3.1 Basic characterisation4 Basic characterisation is the first step in the acceptance procedure and constitutes a full

characterisation of the waste by the waste producer by gathering all the necessary information for

safe disposal of the waste in the long term. Basic characterisation is required for each waste stream

and involves using test methods outlined in the gated acceptance procedure (see Section 4) to

determine whether the wastes pass all of the acceptance criteria

3.1.1 Functions of basic characterisation

Establish basic information on the waste (physical form, origin, composition, consistency,

and, where necessary and available, other relevant characteristic properties).

Provide basic information for understanding the behaviour of waste in the Facility conditions

of storage and options for treatment.

Detection of key variables (critical parameters) for compliance testing and options for

simplification of compliance testing (leading to a significant decrease of constituents to be

measured, but only after demonstration of relevant information). Characterisation may

deliver relationships between basic characterisation and results of simplified test procedures

as well as frequency for compliance testing.

3 UK Environment Agency Waste acceptance at landfills ‐ 2010 4 (2003/33/EC) COUNCIL DECISION of 19 December 2002 establishing criteria and procedures for the acceptance of waste at landfills pursuant to Article 16 of and Annex II to Directive 1999/31/EC


If the basic characterisation of waste shows that the waste fulfils the criteria for the Facility set out

in the WAC, the waste will be deemed to be acceptable. If this is not the case, the waste is not

acceptable. The producer of the waste or the person responsible for its management, is responsible

for ensuring that the characterisation information is correct.

The content of the characterisation, the extent of laboratory testing required and the relationship

between basic characterisation and compliance checking depends on the type of waste. A

differentiation can be made between wastes that are regularly generated in the same process and

wastes that are not regularly generated.

Wastes regularly generated in the same process

These are individual and consistent wastes regularly generated in the same process, where:

The installation and the process generating the waste are well known and the input

materials to the process, and the process itself, are well defined.

The operator of the installation provides all necessary information and informs Tellus of

changes to the process (especially changes to the input material).

The process will often be at a single installation; however, the waste may also be from different

installations, if it can be identified as single stream with common characteristics within known

boundaries (e.g. bottom ash from the incineration of municipal waste). For these wastes the basic

characterisation will comprise the fundamental requirements listed in Gate 1 of section 4 of this

document, and especially the following:

Chemical composition range for the individual wastes.

Range and variability of characteristic properties.

If the waste is produced in the same process but at different sites, information must be given on the

scope of the evaluation. Consequently, a sufficient number of measurements must be taken to show

the range and variability of the characteristic properties of the waste. The waste can then be

considered characterised and shall subsequently be subject to compliance testing only, unless

significant change in the generation processes occur.

For wastes generated from the same process at the same site, the results of the measurements may

show only minor variations in the properties of the waste, in comparison with the relevant

acceptance parameters. The waste can then be considered characterised, and shall subsequently be

subject to compliance testing only, unless significant changes in the generation process occur.

Waste sourced from facilities for the bulking or mixing of waste, from waste transfer stations or

mixed waste streams from waste collectors, can vary considerably in their properties. This must be

taken into consideration in the basic characterisation. Such wastes may fall under the following case.


Wastes that are not regularly generated

These wastes are not regularly generated in the same process in the same installation and are hence

not part of a well‐characterised waste stream. Each batch produced of such waste will need to be

characterised. The basic characterisation shall include the same fundamental requirements as for

basic characterisation. As each batch produced has to be characterised, no compliance testing is

needed in this case.

3.2 Compliance testing When waste has been deemed acceptable on the basis of a basic characterisation it shall

subsequently be subject to compliance testing to determine if it complies with the results of the

basic characterisation and the relevant acceptance criteria as laid down in the WAC. Compliance

testing, as with basic characterisation, will also normally be carried out at the waste producer site.

The function of compliance testing is to periodically check regularly arising waste streams are

compliant with the WAC. The initial basic characterisation will have identified critical parameters

(key waste properties) for each waste stream. Only a check on these critical parameters, as

determined in the basic characterisation, is necessary. The check has to show that the waste meets

the limits of acceptance for the identified critical parameters. The tests used for compliance testing

shall be one or more of those used in the basic characterisation.

Compliance testing shall be carried out at a frequency to be agreed with Tellus and must, in any

event, ensure that compliance testing is carried out in the scope and frequency determined by basic

characterisation.

3.3 On‐site verification Each load of waste delivered to Sandy Ridge shall be visually inspected before and after unloading,

and the required documentation shall be checked.

The waste may be accepted at the Facility, if it is the same as that which has been subjected to basic

characterisation and compliance testing, and which is described in the accompanying documents. If

this is not the case, the waste must not be accepted. Tellus will determine the testing requirements

for on‐site verification, including where appropriate rapid test methods.

Upon delivery, samples will be taken periodically. The samples taken will be kept after acceptance of

the waste for a period that will be determined by Tellus.


4 GATED WASTE ACCEPTANCE PROCEDURE

A gated WAP using specified test methods and criteria values will be applied to determine if a waste

can be accepted. Detailed explanations of each gate, its associated criteria and an applicable test

method(s) required to be used to confirm acceptance, are presented below, with a corresponding

detailed flow chart included in Appendix A.1. A summary of the overall procedure for

characterisation, compliance, acceptance and verification is set out in Figure 4‐1 below.

In addition to considering the specific characteristics of the waste for the purpose of permanent

isolation, consideration is also given to how the wastes will perform in the conditions of storage. This

assessment will be performed by a suitably qualified person who has the necessary skill in

determining such matters. Wastes will need to pass through all waste acceptance “criteria gates” to

be accepted for storage or permanent isolation at the Sandy Ridge facility.

From the point of waste generation, the flow diagram highlights that characterisation is performed

in accordance with the principles outlined above with the option to develop non‐standard operating

procedures for the management of non‐conforming wastes prior to or following receipt at the

proposed Facility.


Figure 4‐1: Waste Acceptance Procedure summary – (Refer to Appendix A.1 for Detailed Flow Chart)

Refer to

Appendix A.1

Waste exclusion may

occur during any stage of

characterisation. If this

occurs during the

verification stage

following delivery to site

waste will be returned to

the customer (see 7.2.5)


Gate 1 – Is the waste on the potential waste category list The first stage of assessing the potential suitability of a waste for storage and permanent isolation is

to determine whether the waste is on the facility’s potential waste category list. The list has been

developed by Tellus based on wastes that broadly have the physical and chemical properties that

meet the criteria for storage and permanent isolation at the facility. The list aims, insofar as is

possible at the outset, to exclude categories of wastes that would fail the site’s acceptance criteria

and are therefore considered unacceptable. In developing this list Tellus have referred to the

National Environment Protection (Movement of Controlled Waste between States and Territories)

Measure 1998 Schedule A and the Western Australia Environmental Protection (Controlled Waste)

Regulations 2004 Schedule 1 Controlled waste list.

A waste producer will be requested to provide information on the waste, using the Level 1 ‐ Basic

Characterisation Form presented in Figure 4‐2. The form contains the following elements of basic

characterisation;

Source and origin of the waste.

Information on the process producing the waste (description and characteristics of raw

materials and products).

Appearance of the waste (smell, colour, physical form).

Radiological assessment of the waste.

Dangerous Goods Code

Code according to the Basel Convention (Annex III) list of hazardous characteristics [Annex III

of the Basel Convention is included as Appendix A.2 of this document for ease of reference].

If the waste is deemed to be on the Potential Waste Category List, the remaining elements of basic

characterisation will be undertaken to provide the necessary information to allow the further steps

in the site’s acceptance procedure to be undertaken.

If the waste is deemed not to be on the Potential Waste Category List, Tellus may advise the

regulator that after modification or treatment, a waste not on the list would be acceptable for

storage and treatment. Advice would include a report from the suitably qualified person that

demonstrates that hazards have been reduced or managed to make that waste suitable for in cell

storage or permanent isolation.

The remaining elements of basic characterisation include;

Description of any waste treatment applied or to be applied, or a statement of reasons why

such treatment is not considered necessary.

Data on the composition of the waste.

Additional precautions to be taken when handling the material, particularly if classified as a

dangerous good.


An indication if the waste could be recycled or recovered now or in the future.

Figure 4‐2: Basic Characterisation Form

TO BE COMPLETED IN BLOCK CAPITALS OR TYPED No. of attached sheets: Sheets of analysis:

Waste Producer’s full name: ……………………………………………………………….

Address: …………………………………………………………………............................

…………………………………………………………………………………………………………..

…………………………………………………………………………………………………………..

Postcode: ……………………. Tel No: ……………………………………………………….

Place of collection (if different). Full name and address:

……………………………………………………………………………………………..

…………………………………………………………………………………………….

…………………………………………………………………………………………....

Postcode: ………………………. Tel No: ……………………………………….

Quantity: Method of Containment Collection Frequency:

Full chemical description:…………………………..………………………………………

…………………………………………………………….……………………………………………

……………………………………………………………….…………………………………………

Colour: Approx. pH:

Physical form: Approx. strength:

Process from which waste/material is derived, including details of any pre‐treatment: …………………………………………………………………………….

…………………………………………………………………………………………………………………………………..................................................................................

Will the waste/material vary? YES/NO if YES, in what way? …………………………………………………………………………………………………………………..

Does the waste/material smell? YES/NO if YES, give possible cause(s) ………………………………………………………………………………………………….

CLIENT’S DECLARATION OF CONSTITUENTS OF THE WASTE/MATERIAL (Delete as appropriate)

Include and specify any know toxic, dangerous or objectionable contaminants either against the entry or in

additional information box below

No. of samples taken

CONSTITUENT PRESENT IF YES, PLEASE SPECIFY CONSTITUENT PRESENT IF YES, PLEASE

SPECIFY

Acids YES NO Controlled drugs/POMs YES NO

Alkalis YES NO Oxidizing agents YES NO

Flammable liquids/Solids YES NO Reducing agents YES NO

Spontaneously combustibles YES NO Radioactive YES NO

Water‐reactive materials YES NO Cyanides (free/complex) YES NO

Oils, Fats, greases YES NO Ammonia/amines YES NO

Halogenated solvents YES NO Nitrates/nitrites YES NO

Phenols/halogenated phenols YES NO Agrochemicals YES NO

Sulphur compounds YES NO PCBs/PCTs YES NO

Explosives YES NO Bio‐hazardous materials YES NO

Metals/metal compounds YES NO Hazardous Characteristics

(Basel Convention Annex III)

Additional information; Dangerous Goods Code

Signed on behalf of the Waste Producer’s Name: Job Title: Date:

………………………………………….…. ……………………………………… …………………………….. ………………………………….


Test methods:

Review of waste information provided by customer and MSDS as supplied against the Potential

Waste Category list presented in Appendix A.3

Limit of acceptance:

Identified on Potential Waste Category list.

Gate 2 – Has the waste been identified as likely for future recovery? If a waste stream has the potential to be recycled or recovered in the future but there is currently no

viable process available that will be noted and the viability/availability of that option will be

periodically reviewed. The absence of a current viable route in accordance with the principles of

“Environmentally Sound Management5” will enable the waste to be accepted at the Sandy Ridge site

for storage.

Test methods:

Review of waste type, information supplied and MSDS against listed wastes.


Not applicable

Gate 3 – Gases, liquids and sludges Gas and liquid are assumed to mean the physical state of the waste at 25oC and 1 atm (STP), with a

sludge being a homogeneous mixture of solid and liquid materials which requires containment to

prevent the material from flowing.

Gate 3.1 – Is the waste a gas?

Gases will not be accepted for permanent isolation, this includes wastes which could reasonably be

expected to be gases in a free phase condition in the conditions of permanent isolation. This

exclusion will include wastes received as aerosols, liquids, or solids which may change form during or

following emplacement.

Test methods:

Review of MSDS.

5 The Basel Convention on the Control of Transboundary Movement of Hazardous Waste and their Disposal, which came into force in 1992, defines "environmentally sound management" as "taking all practical steps to ensure that hazardous wastes or other wastes are managed in a manner which will protect human health and the environment against adverse effects, which might result from such wastes."



The Australian Code for the Transport of Dangerous Goods by Road and Rail defines “gases” as

substances that have a vapour pressure greater than 300 kPa at 50°C, or are completely gaseous at

20°C and standard pressure of 101.3 kPa (STP).

Gate 3.2 – Is the waste a liquid or sludge?

Liquid and sludge wastes will not be accepted directly for permanent isolation at the proposed

Facility. This includes wastes received as liquids, or solids which may change form during or following

emplacement (i.e. may return to liquid phase during long term storage). Should a suitable

technology and process be available to permanently solidify the liquid to a suitable consistency then

it may be possible to dispose of the waste at the proposed Facility.

Test methods:

MSDS Review

Liquids test ASTM D 4359‐90:

Slump test (BS 1881: Part 102 or equivalent). A slump test involves the placing of a sample of

material into an inverted cone of known height. This is then placed the correct way onto a flat

surface. The surrounding cone is then slowly removed and the height of the resulting waste form will

be measured. The slump is calculated as the original height minus the height of the resultant waste

form and reported in mm.


The Australian Code for the Transport of Dangerous Goods by Road and Rail (2007) defines “liquids”

as substances that have a vapour pressure of not more than 300 kPa at 50°C, are not completely

gaseous at 20°C and standard pressure of 101.3 kPa, and have a melting point or initial melting point

of 20°C or less at standard pressure of 101.3 kPa. The code continues to state that a viscous

substance for which a specific melting point cannot be determined must be subjected to the ASTM D

4359‐90 test; or to the test for determining fluidity (penetrometer test).

Slump Test: The waste will fail the test and be deemed unsuitable for the facility, if the height has

dropped by 25% or more of the original height.

Gate 4 ‐ Does the waste possess hazardous characteristics which, in

the conditions of storage, are explosive, corrosive, oxidizing, or

highly flammable? Gate 4 sets out a number of generic exclusion properties of potential wastes, based on the reactivity

of the wastes. Each property should be considered independently from the others through the

gating process. A waste that fails in any one of these sub‐gates will be deemed as failing Gate 4 and

will not be accepted for permanent isolation at the proposed Facility. The hazardous characteristics


list is presented at Appendix . The conditions of storage will be considered when assessing these

criteria.

Gate 4.1 – Is the waste Explosive (H1)?

Wastes which are explosive will not be accepted directly for permanent isolation at the proposed

Facility. Should a suitable treatment or encapsulation method be identified to treat or manage the

wastes such that it is no longer explosive in the conditions of storage, it may be possible to accept

the waste material for permanent isolation or in cell storage. A suitably qualified person will be

required to determine if and when such wastes may be received and disposed at the proposed

Facility. Any treatment methodology for the stabilisation of the waste must be controlled and

undertaken by suitably qualified persons. Detailed risk assessment will be undertaken to ensure the

stabilisation and subsequent storage can be undertaken safely.

Test methods:

The United Nations Recommendations On The Transport Of Dangerous Goods, Manual Of Tests And

Criteria (United Nations Test Manual) gives a series of laboratory tests to determine whether a

substance is classified as explosive, and if so, what division falls into. As Tellus will not be accepting

any explosive material, irrespective of which division it falls into, only test types 1 and 2 will be

utilized at the proposed Facility.

The following Type 1 tests answer the question “is it an explosive substance?”

Test 1 (a): UN Gap test – assess ability of substance to propagate a detonation;

Test 1 (b): Koenen test – effects of intense heat under high confinement;

Test 1 (c) (i): Time/Pressure test – effects of ignition under confinement;

Test 1 (c) (ii): Internal ignition test – tendency to transition from deflagration to detonation.

If every test yields a negative result the waste is classified as non‐explosive and can be considered

for acceptance; however, if any of these tests give a positive result, the waste is then subjected to

Type 2 testing to determine the sensitivity.

Type 2 tests answer the question “is it too insensitive for acceptance into Class 1?” These tests use

the same basic apparatus and method but with minor variations, or less stringent criteria.


The substance is classified as "explosive" under the following conditions and will not be accepted:

Type 1: if any of the tests yields a positive (+) result; and

Type 2: if any of the tests yields a positive (+) result


Gate 4.2 – Is the waste Highly Corrosive (H8)?

Highly corrosive wastes will not be accepted for direct permanent isolation at Sandy Ridge. Should a

suitable treatment or encapsulation method be identified to treat or manage the wastes such that

they do not remain highly corrosive under the conditions of storage, it may be possible to accept the

waste material for permanent isolation or in cell storage. Any stabilisation shall be undertaken under

the instruction of the suitably qualified person.

Test methods:

The United Nations Test Manual recommends Test C.1 to determine the corrosive properties of

liquids and solids that may become liquids during storage and/or transport.

A representative sample of the waste is placed in contact with a minimum of 3 metal plates (one test

using steel, and another using aluminium) measuring 20 x 50 x 2 mm. One plate is submerged in the

solution, another is half submerged, and the final plate is suspended in the gas phase. The test

temperature is maintained at 55°C for at least one week before the metal plates are removed and

analysed for mass loss.


The results are based on both localised, and uniform corrosion. The material will be classified as

highly corrosive under the following conditions:

Uniform corrosion: the mass loss of the most corroded sample exceeds the values given in

Table 4‐1; or

Table 4‐1: Uniform corrosion mass loss criteria

Exposure time Mass loss

7 days 13.5%

14 days 26.5%

21 days 39.2%

28 days 51.5%

Localised corrosion: the depth of the deepest intrusion (to be determined

metallographically) into the metal surface exceeds the values given in Table 4‐2

Table 4‐2: Localised corrosion intrusion criteria

Exposure time Min. intrusion depth

7 days 120 µm

14 days 240 µm

21 days 360 µm

28 days 480 µm


Gate 4.3 – Does the waste have oxidising potential (H5.1)?

Oxidizing wastes will not normally be accepted directly for permanent isolation at the proposed

Facility. Should a suitable treatment or encapsulation method be identified to treat or manage the

wastes such that little or no oxidizing potential remains under the conditions of storage, it may be

possible to accept the waste material. Any stabilisation shall be undertaken under the instruction of

the suitably qualified person.

Test methods:

The United Nations Test Manual recommends using Test O.1 to classify oxidizing solids. This test is

designed to measure the potential for the material to increase the burning rate or burning intensity

of a combustible substance when they are thoroughly mixed, and to compare these characteristics

with that of potassium bromate.

The Recommendations On The Transport Of Dangerous Goods, Manual Of Tests And Criteria also

gives test methods for determining the oxidization potential of a liquid substance; however these

materials will be excluded in Gate 3.2 and therefore the tests will not be utilized at the proposed

facility


Substances that fail to ignite and burn under test conditions, or exhibits mean burning times greater

than that of a 3:7 mixture (by mass) of potassium bromate and cellulose, will not to be classified as

oxidising (H5.1).

Gate 4.4 – Is the waste a flammable liquids (H3)?

Flammable liquids will not be accepted directly for permanent isolation at the proposed Facility.

Should a suitable treatment or encapsulation method be identified to treat or manage the wastes

such that it is not flammable or liquid under the conditions of storage, it may be possible to accept

the waste material for permanent isolation or in cell storage.

The processing of flammable liquid waste materials should be undertaken only if safe to do so, and if

appropriate risk management and controls are in place. A suitably qualified person will be required

to determine if and when any potentially flammable wastes may be received and disposed at the

proposed Facility. Any treatment methodology for the stabilisation of the waste must be controlled

and undertaken by suitably qualified persons. Detailed risk assessment will be undertaken to ensure

the stabilisation and subsequent storage can be undertaken safely. Any treatment option must also

address the state of the waste such that the stabilised waste will be solid in the conditions of

storage.

Test methods:

Substances are classified as flammable liquids when their flash point is lower than 60°C in a closed‐

cup test, or lower than 65.6°C in an open‐cup test. It is expected that flash point tests will be


completed for liquids suspected to be flammable as part of the initial characterisation testing via one

or more of the following international standards:

ISO 1516 Determination of flash/no flash – closed cup equilibrium method

ISO 1523 Determination of flash point – Closed cup equilibrium method

ISO 2719 Determination of flash point – Pensky‐Martens closed cup method

ISO 13736 Determination of flash point – Abel closed cup method

ISO 3679 Determination of flash no flash and flash point – Rapid equilibrium closed cup

method

Material that is found to be a flammable liquid must undergo treatment to ensure that it is unable to

sustain combustion, and is no longer liquid. Test L.2 is designed to test the ability of a liquid to

sustain combustion, by exposing a small portion to flame under controlled conditions. The full

procedure and apparatus is given in Recommendations On The Transport Of Dangerous Goods,

Manual Of Tests And Criteria.

Even if the waste is modified so that it passes Test L.2, it will not be accepted at the proposed Facility

until Tellus is certain that it meets all other acceptance criteria.


The waste will be found to be capable of sustaining combustion if the following behavior is

observed:

The test sample ignites and sustains combustion when the test flame is off; or

The test sample ignites while the test flame is applied for 15 seconds and maintains

combustion for a minimum of 15 seconds after the flame has been turned off.

Intermittent flashing of the test sample material should not be interpreted as sustained combustion.

Gate 4.5 – Is the waste a flammable solid (H4.1)?

Highly flammable solid wastes will not normally be accepted directly for permanent isolation at the

proposed Facility. Should a suitable treatment or encapsulation method be identified to treat or

manage the wastes such that it is not flammable under the conditions of storage, it may be possible

to accept the waste material for permanent isolation or in cell storage. The processing of flammable

waste materials should be undertaken only if safe to do so, and if appropriate risk management and

controls are in place. A suitably qualified person will be required to determine if and when any

potentially flammable wastes may be received and disposed at the proposed Facility. Any treatment

methodology for the stabilisation of the waste must be controlled and undertaken by suitably

qualified persons.


Test methods:

Test N.1, taken from the Recommendations On The Transport Of Dangerous Goods, Manual Of Tests

And Criteria published by the United Nations, assesses the ability of a substance to propagate

combustion by igniting it and measuring the burning time.


Powdered, granular or pasty substances should be classified as Division 4.1 when the time of burning

of one or more of the test runs, in accordance with the test method is less than 45 seconds or the

rate of burning is more than 2.2 mm/s. Powders of metals or metal alloys should be classified when

they can be ignited and the reaction spreads over the whole length of the sample in 10 minutes or

less.

Gate 5 – Is the waste potentially self combustible and liable to

Auto‐Ignition? Wastes which are self combustible and/or prone to self‐ignition in the conditions of storage will not

be accepted for in cell storage or permenant isolation at the proposed Facility. Such wastes may be

reactive with soil moisture or incompatible with other waste types received at the facility for

permanent isolation. If it can be demonstrated that the waste can be encapsulated or isolated, or

transformed chemically and or physically to a form that is no longer combustible or prone to self‐

ignition, the waste may be able to be accepted for permanent isolation with controls in place.

The processing of self combustible and self‐igniting waste materials should be undertaken only if

safe to do so, and if appropriate risk management and controls are in place. A suitably qualified

person will be required to determine if and when any potentially combustible and self‐igniting

wastes may be received and disposed at proposed Facility. Any treatment methodology for the

stabilisation of the waste must be controlled and undertaken by suitably qualified persons. Detailed

risk assessment will be undertaken to ensure the stabilisation and subsequent storage can be

undertaken safely.

Test methods:

The Recommendations On The Transport Of Dangerous Goods, Manual Of Tests And Criteria outlines

test methods to identify two different types of spontaneous combustion properties:

Pyrophoric: Substances which ignite within five minutes of coming into contact with air.

These are the most liable to spontaneous combustion.

Self‐heating: substances which, in contact with air and without an energy supply, are liable

to self‐heating. These substances will ignite only when in large quantities (kilograms) and

after long periods of time (hours, days).

Solid pyrophoric substances are classified based on results from Test N.2. The test involves exposing

the material to air for 5 minutes to determine whether the material ignites, and the time taken for

ignition to occur.


Self‐heating substances are classified based on the results from Test N.4. The test involves exposing

samples of the material to air temperatures between 100°C and 140°C and measuring the

temperature of the material compared to the air temperature.


Test N.2: if the material does not ignite within 5 minutes of air contact, the material is not

pyrophoric.

Test N.4: a positive result is obtained if the material temperature exceeds that of the oven

temperature by 60°C during the testing time. Otherwise it will be negative. The material will not be

classified as self‐heating if:

A negative result is obtained in a test using 100mm cube sample at 140°C;

A positive result is obtained in a test using a 100mm cube sample at 140°C and a negative

result is obtained in a test using a 25mm cube sample at 140°C.

Gate 6 – Can the waste generate a gas‐air mixture which is toxic or

explosive? Gate 3.1 prevents the acceptance of gases for permanent isolation. Wastes that can generate a gas

air mixture that is toxic or explosive will also not be accepted at the proposed Facility for in cell

storage or permanent isolation. Some wastes which may react with water or other wastes to release

gases may be specifically excluded from permanent isolation. Alternatively, they may be managed

through encapsulation, or physically and chemically transformed to a form which is no longer

capable of releasing the toxic or explosive gases. In such cases, the method of management shall be

developed specifically for that waste type, and managed and recorded by the supervising chemist or

suitably qualified person.

Test methods:

The United Nations recommends Test N.5 to assess whether the substance will react with water to

produce a flammable gas. A small sample of the material is brought into contact with water under

controlled conditions.

A representative 500g sample of the waste will be reacted with concentrated hydrochloric acid (or

sodium hydroxide to determine ammonia release from wastes with pH>10) for a period of 1 hour

and absorption solutions used to absorb any toxic gases evolved. Appropriate analytical methods will

then be used to quantify the gases present which values are then compared with thresholds based

on concentrations required to create a toxic atmosphere at the bottom of the cell.


Based on the results from test N.5, the substance is classified as Class 4.3 if:

Spontaneous ignition takes place in any step of the test procedure


There is evolution of flammable gas at a rate greater than 1 Litre per Kilogram of the

substance per hour

Gate 7 – Is the waste biodegradable? Waste that is biodegrade, either by aerobic or anaerobic decomposition, are considered

unacceptable for in cell storage or permeant isolation. Therefore such wastes are excluded from the

facility. The wastes covered by this exclusion include:

Vegetable matter (including food and garden waste).

Animal matter (including food, animal parts, excreta, sanitary waste, animal fibre).

Mixed household, commercial and industrial waste.

Clinical waste (excluding pharmaceuticals).

Test methods:

Depending on the waste type, the total organic carbon (TOC) will be determined as part of the

testing under basic characterisation. It is envisaged that, in general, TOC will be the parameter used

as the organic content of any waste is of primary interest. The test method to be used will be based

on BS EN 13137:2001 or equivalent.


If the TOC content of the waste is <6%6 then it will be deemed acceptable for storage and

permanent isolation at Sandy Ridge by this criterion. Certain wastes that contain organic carbon, for

example railway sleepers impregnated with pesticides or certain hydrocarbon containing wastes, will

be treated on a case by case basis to determine a suitable permanent isolation concept that in the

conditions of storage will not compromise the integrity of the facility.

Gate 8 – Is the waste an infectious hospital or clinical waste (H6.2)? Hospital waste or other clinical waste arising from medical or veterinary establishments which are

infections as defined by property H6.2 in Annex III will not be accepted for permanent isolation at

the proposed Facility. Alternative higher order methods of management are generally available for

these wastes.

Test methods:

Material source identified. Visual inspection of waste.

6 the maximum TOC level permitted at a hazardous waste site ‐ EC Waste Acceptance Criteria Section 2.4.2



Zero hospital or clinical waste present in the waste load.

Gate 9 – Does the waste have the potential to be infectious to

animals or humans (H6.2)? Substances or wastes containing viable micro‐organisms or their toxins which are known or

suspected to cause disease in animals or humans will not be accepted for permanent isolation at the

proposed Facility. Alternative higher order methods of management are generally available for these

wastes.

Test methods:

Material source identified. Visual inspection of waste.


Zero infectious waste present in the waste load.

Gate 10 – Tyres Used tyres are a controlled waste, as listed in Schedule 1 of the Environmental Protection

(Controlled Waste) Regulations 2004.

Used tyres pose an environmental pollution risk mainly due the potential discharges and emissions

from tyre fires. In certain circumstances tyres, or the products of tyre reprocessing may be accepted

for permanent isolation at the Facility but only if it can be demonstrated that the waste can be

encapsulated or isolated, or transformed chemically and or physically to a form that is no longer

flammable (see Gate 4.1)

Test methods:

Visual Inspection


Compliance with all other criteria gates


Gate 11 – Conditions of Storage criteria. Can the waste and/or its

container, release liquid, or react with the host clay in the facility

which could affect either the operational and/or post closure safety

of the facility?

Gate 11.1 – Can the waste release free liquid in the conditions of storage?

Wastes that possess the ability to release liquid, self‐transport or move in the conditions of storage

will be excluded from the Facility. Typical examples include hygroscopic materials, which have the

ability to absorb water from the air, and wastes containing persistent organic pollutants that may

separate into two phases, i.e. solid phase and liquid phase.

Test methods:

A pressure test will be used to determine if a waste will separate into two phases, with the pressure

used being in excess of the maximum loading a waste could experience in the cell storage conditions

(i.e. the pressure experienced by a the bottom bulk bag at the bottom of the cell). A further test will

be carried out on wastes that pass the pressure test, but are considered to have the potential to

separate into two phases. This would include wastes that have the potential to retain liquid in

interstitial spaces, such as sand/water mixture and ion exchange resins.

A representative sample of the waste will be thoroughly mixed and subjected to a differential

pressure of 1.5 bar for 15 minutes. This will be done by either applying pressure to the material on a

filter or applying suction to the filter holding the material. Any displaced liquid will be measured as a

volume and reported as a percentage of the whole.

A representative sample of the waste will be thoroughly mixed and be stood on a glass sinter for a

period of 24 hours. If a liquid phase separates, the liquid will be measured as a volume and reported

as a percentage of the whole.


The waste will fail the test and be deemed unsuitable for the facility if greater than 1% w/w of liquid

is released.

Gate 11.2 – Does the waste possess the potential for an adverse reaction with the host

clay?

Wastes may have the potential to react with the host Kaolin clay. If basic characterisation indicates

the presence of any substance that is known to have the potential to react adversely with kaolin

clay, the waste will be tested to determine if there is any reaction that may adversely affect the

integrity of the clay barrier. Wastes exhibiting these properties that cannot be suitably modified or

contained will be excluded.


Test methods:

A representative sample of the waste will be mixed with kaolin clay from the Sandy Ridge mine and

left to stand for a period of 24 hours in a sealed container. The pressure and temperature within the

container will be monitored to determine if a reaction has occurred.


Changes in pressure compared to ambient conditions indicates a reaction involving gas formation is

occurring, while changes in temperature compared to ambient conditions indicates exothermic or

endothermic reaction is occurring, even if no gas is generated. Any wastes which is found to react

with kaolin will not be accepted for permanent isolation without stabilization treatment to make it

unreactive.

Gate 11.3 – Does the waste have the potential to yield another hazardous substance

(H13)?

Some wastes may change with time and produce intermediate products with differing properties to

the initial disposed product. Wastes may also react with the containers to produce products with

undesirable properties in the conditions of storage. Substances or wastes which, by interaction with

air, water or other wastes that are liable to yield other hazardous substances in dangerous quantities

need to be identified. Any waste which has the potential to yield other hazardous substances will

not be accepted at the proposed Facility. Wastes exhibiting or expected to exhibit these properties

that cannot be suitably modified or contained will be excluded.

Test methods:

To be determined on a case by case basis by competent person.


To be determined depending on waste streams considered.

Gate 12 – Is the waste radioactive?

Gate 12.1 – Generic waste acceptance criteria for radioactive waste

The following is a list of generic waste acceptance criteria7 for radioactive waste that will be

accepted at the proposed Facility. For waste to be acceptable for permanent isolation, the following

physical and chemical characteristics shall apply to all categories of waste. These requirements are

specified to minimise the potential hazard to personnel at the site, and to facilitate safe handling

7 Section 2.6 of the Near‐Surface Disposal Code, Specific criteria and requirements for waste acceptance and disposal.


during operations. The intention is to ensure the long‐term stability of the waste and reduce the

potential for dispersal of radionuclides from the site.

Waste shall not contain corrosive materials; waste containing inorganic acids, alkalis and

corrosive salts shall be treated to neutralise them and thereby to nullify the chemical effect

of these materials.

Where practicable, flammable or combustible materials, such as paper, plastics, cloth or

resins, shall be separated from non‐flammable solids and packaged, contained and labelled

in a proper manner.

Waste shall not contain or be capable of generating gaseous materials in quantities which

might lead to the release of harmful vapours or fumes, or compromise the integrity of the

facility.

Waste shall not contain material which will readily detonate upon impact, decompose

explosively, react violently with water or undergo vigorous exothermic reaction at normal

temperatures and pressures.

Waste containing pyrophoric material shall be treated, conditioned or packaged to render it

non‐flammable.

Liquid waste shall be solidified to be acceptable for permanent isolation. The final package

for permanent isolation shall comply with the stability requirements for the particular

category of waste.

As far as practicable, waste materials being disposed of should be free of biological

materials.

Radioactive waste contaminated with toxic, pathogenic or infectious material shall be

treated or conditioned to minimise both the potential hazard to site personnel and the long‐

term health risks to members of the public. Any treatment should be carried out in

accordance with relevant NHMRC guidelines such as National guidelines for the

management of clinical and related wastes (Australian Government Publishing Service,

Canberra, 1988) and Guidelines for laboratory personnel working with carcinogenic or highly

toxic chemicals (Australian Government Publishing Service, Canberra, 1990).

Waste which contains chelating agents shall be treated or conditioned to reduce the

possible long‐term effects of leaching by water, although water in the Sandy Ridge cells is

not expected.

Gate 12.2 – Radiological acceptance criteria

Refer to Section 5 of this procedure for specific activity and half‐life values for radioactive waste

acceptance.


Gate 13 – Does the waste meet the packaging criteria? The Australian Code for the Transport of Dangerous Goods by Road and Rail (2016) details the

requirements for safe packaging and transport of hazardous materials, based on the classification of

the waste. Tellus requires that all customers adhere to the code to ensure packaging is appropriate

to the hazardous characteristics of the waste in question. Containment systems should normally

consist of one or more of the following packaging options;

20’ ISO shipping containers or 20’ ISO tank containers

Bulk bags in containers, on pallets or free standing

215 Litre drums on pallets in containers

1m3 IBCs in containers

Small palletised goods in containers (e.g. radioactive materials)

Loose bulk in containers (e.g. contaminated soils)

Liquid tanker truck (e.g. bulk liquids or pastes) which will undergo solidification or

stabilization treatments

Pneumatic tanker truck (e.g. bulk dry powder solids)

Solid materials on flatbed trucks (e.g. railway sleepers, O&G pipe, machinery).

The original IWDF Waste Acceptance Guidelines 2011 provide clear criteria for the packaging of

waste for delivery to the Mount Walton East site, which is presented below. Tellus have considered

the IWDF packaging requirements to be consistent with industry best practices; therefore waste

packaging delivered to the proposed Facility should fulfil the following criteria;

Not have a total measured weight of more than the Safe Working Load

Be capable of being disposed of with the waste

Be filled so as to contain no significant voids

Be free of ruptures at the point of delivery

Be free of external contamination at the point of delivery

Not significantly deteriorate during the duration of storage, transport and handling when in

contact with the waste

Remain intact during normal transport and handling procedures

Be strong enough to be walked on if required


Be clearly labelled with the waste owner’s name and identification number and material

description/name on opposite sides of the waste package

Allow no leakage during normal transport and handling operations

Be capable of containing all the waste whatever the orientation of the package.

It should be anticipated that packaging containers have the potential to fail in the conditions of

storage if no other consideration is given to the form of the packaging and wastes contained therein.

To minimise the likelihood and potential impacts of packaging failure, the following measures are

required to be undertaken:

Void spaces inside containers are to be minimised – packages shall be grout filled or similar

to remove voids inside any container that will be disposed with the waste.

Low density wastes (PPE etc.) should be baled or similarly compacted to the highest density

reasonably and practicably achieved (as close to 200kPa as practical to be consistent with

the available backfill materials). This compaction activity should be undertaken prior to any

grout filling.

Low density wastes should be identified so that, as far as practicable during the receival

activity at site, be segregate for special attention in the development of the filling plan.

Low density waste should be packaged in smaller vessels, or should be packaged and

disposed as long shallow packages to reduce the scale of any settlement or failure.


5 RADIOACTIVE WASTE

5.1 Waste Acceptance Procedure for radioactive waste WAC for the facility are based on the design of the facility, including, but not limited to, such items

as the engineered barriers, duration of institutional control and site specific characteristics such as

geology, low rainfall, lack of receptors, etc.

The activity of the radionuclides present in the radioactive waste packages will be limited in such a

way that the radiological impact of the site remains within acceptable levels during the operational

and post‐closure phases of the site. In accordance with international atomic energy agency (IAEA)

waste are considered as a function of their half‐life and activity concentration. Radiation doses to

the public and workers as a consequence of waste management, storage and disposal activities

are not to exceed the dose limits in Regulations 59 and 60 of the ARPANS Regulations. The

effective dose limit for occupational exposure is 20 mSv annually, averaged over 5 consecutive

calendar years. However, the effective dose for a person subject to occupational exposure must

not, in a year, be greater than 50 mSv. The effective dose limit for public exposure is 1 mSv

annually).

The ARPANSA Licensing of Radioactive Waste Storage and Disposal Facilities March 2013 explains

that waste acceptance should be undertaken in accordance with Section 2.6 of the Near‐Surface

Disposal Code, Specific criteria and requirements for waste acceptance and disposal. Guidance on

determining waste activity limits for low level waste in near‐surface disposal facilities is found in the

IAEA TECDOC Derivation of Activity Limits for the Disposal of Radioactive Waste in near Surface

Disposal Facilities (IAEA‐TECDOC‐1380, 2003).

The following sections provide details on how the regulatory guidance has been applied in

establishing criteria for acceptance of NORM and bulk wastes and also for sealed sources.

5.2 Norm and bulk wastes In order to derive activity concentrations limits for individual radionuclides in NORM and bulk

wastes, two criteria have been used:

Dose rate to a human receptor post closure (with capping material in place) to not exceed a

dose constraint of 0.3 mSv in a year. Occupancy of 3.5 days a year was assumed as per

ARPANSA TRS No. 141 for an arid and remote site.

Dose rate to a human receptor upon intrusion (no capping) corresponding to 10mSv/y as per

ICRP guidance on radiological criteria applied to human intrusion.

The RESRAD (Onsite) code was used, to determine radionuclide activity concentration levels in bulk

NORM wastes which would give rise to conditions as specified above for post closure and intrusion

scenarios. Details of assessment are presented in the Radiological Risk Assessment: Post Closure


report. Table 5‐1 summaries the Radionuclide restrictions that should be applied in the Waste

Acceptance Criteria (WAC) for the Facility for the disposal of NORM bulk wastes.

For bulk NORM wastes having mixtures of radionuclides, an additional constraint should be adhered

to so that the total dose from all the radionuclides should not exceed relevant dose limits or

constraints. This is referred to as the summation rule and requires the following constraint:

Where Qi (Bq) is the actual activity of radionuclide i to be disposed and Qi,l (Bq) is the activity limit

for radionuclide i if it were the only radionuclide to be disposed of.

Table 5‐1: Waste Acceptance Criteria (WAC) for the Facility for bulk NORM waste

Radionuclides Half Life Individual Radionuclide Activity Concentration of Bulk

NORM Waste (Bq/g)

(Bq/g) to achieve 10 mSv/y upon Intrusion

U‐238 4.468 billion years 1.0E+05

U‐234 246,000 years 2.0E+06

Th‐230 75,380 years 1.2E+04

U‐235 703.8 million 2.2E+04

Pa‐231 32,760 years 7.1E+03

Ra‐226 1600 years 1.8E+03

Th‐232 14.05 billion years 1.1E+03

5.3 Sealed Sources Table 5‐2 summarises the Waste Acceptance Criteria (WAC) proposed for the disposal of Sealed

Sources. The activity of the radionuclides present in the radioactive waste packages will be limited in

such a way that the radiological impact of the site is within the dose constraint limits set by the

facility, under any foreseeable set of circumstances. Sources at activity Concentration levels above

those specified in the table will not be accepted for disposal without re‐assessing the safety case and

seeking approval from the relevant regulatory bodies.


Table 5‐2: Limits for common sources based on NHMRC near surface code (1992)

Radioisotope Symbol Half‐life Decay Concentration limit (Bq)*

100 years ICP

Americium‐241 Am‐241 432.17 y α 2.00E+10

Barium‐133 Ba‐133 10.74 years EC no limit

Caesium‐137 Cs‐137 30.07 years γ/β 2.00E+11

Californium‐252 Cf‐252 2.6 years α 2.00E+10

Carbon‐14 C‐14 5 715 years β 2.00E+11

Chlorine‐36 Cl‐36 301 000 years β 2.00E+11

Chromium‐51 Cr‐51 2.7 days EC no limit

Cobalt 57 Co‐57 271.8 days EC no limit

Cobalt‐60 Co‐60 5.27 years γ no limit

Gold‐198 Au‐198 2.7 days β no limit

Hydrogen‐3 (tritium) H‐3 12.32 years β 2.00E+11

Indium‐111 In‐111 2.80 days EC no limit

Iodine‐129 I‐129 15.7 million years β 2.00E+10

Iridium‐192 Ir‐192 73.8 days γ/B 2.00E+10

Krypton‐85 Kr‐85 10.5 years β 2.00E+11

Iron‐55 Fe‐55 2.74years EC no limit

Lead‐210 Pb‐210 22.6 years β 2.00E+11

Manganese‐54 Mn‐54 312.1 days EC no limit

molybdenum‐99 Mo‐99 66 hours β no limit

Nickel‐63 Ni‐63 96 Years β 2.00E+11

Polonium‐210 Po‐210 138 days α 2.00E+10

Radium‐226 Ra‐226 1,600 years α 1.00E+09

Selenium‐75 Se‐75 120 days γ no limit

Sodium‐22 Na‐22 2.6 years γ no limit

Strontium‐90 Sr‐90 28.8 years β 2.00E+11

Technetium‐99m Tc‐99m 6.01 days γ no limit

Thallium‐204 Tl‐204 3.78 years β no limit

Thulium‐170 Tm‐170 129 days β no limit

Ytterbium‐169 Yb‐169 32 days EC no limit

Zinc‐65 Zn‐65 243.87 days EC no limit

*(alpha (α), Beta (β), Gamma (γ) or Electro capturing (EC))

Before a radioactive waste can be accepted, Tellus must be satisfied that the waste meets its WAC

(refer to WAC). The WAP for radioactive waste is summarised in Figure 5‐1 below and discussed in

more detail in the WAP document. It should be noted that the second step on the flow chart “Advice

and await certificate” is a regulator step where a review of the permanent isolation application is

carried out prior to the issuing of a disposal certificate.


Figure 5‐1: Radioactive waste acceptance procedure


6 REJECTED WASTES

Wastes that do not meet the acceptance criteria may need to be rejected. This should not occur

frequently due to the first two Levels, compliance and verification testing that will take place. Level 3

on‐site verification may occasionally identify wastes that need to be rejected or some wastes may

fail waste packaging criteria tests.


analysis and behaviour‐testing methods, of the characteristic properties of the waste. This is

the key decision step in determining whether a waste can or cannot be accepted. This stage

takes place at the waste supplier site and only if the waste passes all of the WAC gates can

Tellus agree to accept the waste at the Sandy Ridge Facility.

Level 2: Compliance testing. After a waste stream has been accepted as meeting the Sandy

Ridge WAC Level 2 compliance testing is then periodically performed on regularly arising

wastes by simpler standardised analysis and behaviour‐testing methods to determine

whether a waste complies with licence conditions and whether a waste with known

properties has changed significantly. The tests focus on key variables and behaviour

identified by basic characterisation.




In the event that waste that cannot be accepted arrives at the site it will be placed into a specifically

identified quarantine area until arrangements can be made to modify it into a waste form suitable

for storage and disposal or to safely return it to the customer.


7 NOTIFICATION AND CERTIFICATION

7.1 Traceability, Approval System and Documents At all of its facilities, Tellus will adopt a rigid Quality Assurance, Traceability, Notification and

Certification System. This process is summarised in Figure 7‐1 and is designed to complement

tracking systems required by other legislation such as the Australian Code for the Transport of

Dangerous Goods by Road and Rail and the National Environmental Protection (movement of

controlled wastes between States and Territories) Measure.

Figure 7‐1: Tellus' traceability process

7.2 Notification Service Tellus will implement a notification service for management of the waste that is delivered to Sandy

Ridge. This will include;

N1 ‐ Dispatch Notice issued by Customer

N2 ‐ Dispatch Confirmation issued by Tellus

N3 ‐ Arrival Notice issued by Tellus

N4 ‐ Rejection Notice issued by Tellus if necessary


7.2.1 N1 ‐ Dispatch notice issued by Customer

Prior to dispatching waste to the Facility, the Customer must issue a Dispatch Notice to Tellus. The

Dispatch Notices must be issued so that deliveries are in accordance with the Waste Delivery Plan.

The Dispatch Notice will include information on the waste code, description, weight, volume, MSDS,

proposed date of delivery and Transport Plan. It is anticipated that following the issue of a Dispatch

Notice the Customer will secure all required approvals for transportation (e.g. NEPM approvals for

movement of controlled substances and Dangerous Goods), arranging packing and accredited

transporters.

7.2.2 N2 ‐ Dispatch confirmation notice issued by Tellus

Tellus will issue a Dispatch Confirmation Notice to the Customer, either confirming that the dispatch

may proceed; or may not proceed, including reasons (example: resources or space temporarily not

available). This will normally be issued within 5 Business Days of Tellus receiving evidence from the

Customer of all required approvals for transportation. Tellus is not required to accept waste at the

Facility unless Tellus has issued a Dispatch Confirmation Notice.

7.2.3 N3 ‐ Arrival notice issued by Tellus

All deliveries of waste must be booked in at least 48 hours prior to the arrival of the delivery. This is

to ensure that sufficient segregated storage is available for any particular waste stream. Un‐booked

deliveries may be subject to delays in unloading and/or may incur additional charges. Tellus will

issue an Arrival Notice to the customer confirming arrival of the delivery at the Nominated Facility

(provided that Tellus has issued a Dispatch Confirmation Notice in relation to that delivery). The

Arrival Notice will be generated at the weighbridge (in real time).

7.2.4 Inspection point

Following the issue of an Arrival Notice, at the Sandy Ridge Delivery Point, the waste will be

subjected to weighing, visual inspection of containers, and sampling. On‐site laboratory testing

(Level 3, On‐site verification checks) will be performed by qualified persons to analyse the waste

streams to determine if the waste acceptance criteria are satisfied and to ensure compliance with

any site licence Conditions of Acceptance. If the waste is accepted, this is the point of risk transfer

and an Acceptance Certificate is issued. If the waste is rejected, there is no transfer of risk, and a

Rejection Notice is issued. A representative sample will be taken from each delivery batch and waste

type. Details of third party analysis and a Material Safety Data Sheet will assist in the correct

identification.

The Conditions of Acceptance for the Nominated Facility will specify that the Customer must

provide:

Prior to unloading, documentation supporting that Waste was transported in accordance

with all required Approvals;


the weight card, which provides evidence of the gross weight of the delivery to be used as

the basis for billing;

documentation of Waste volume, and waste codes; and

acceptable packaging;

The waste must not comprise any unlawful material. The delivery must be consistent with the

Dispatch Notice from the Customer

7.2.5 N4 Rejection Notice N4 ‐ Rejection Notice issued by Tellus (if necessary)

If an Acceptance Certificate is not issued, the Customer will be issued a Rejection Notice and will

remain responsible for the delivery; and the rejected delivery will be managed in accordance with

the Rejection Procedure. The Procedure will provide that, amongst other things, Tellus may procure

the return of the delivery to the address in the Dispatch Notice (at the cost and risk of the

Customer).

Tellus may (in its sole discretion) elect, by notice in writing, to accept the delivery in which case

Tellus may treat and or repackage the waste at the cost of the Customer. If Tellus makes this

election, the waste will be deemed to be Acceptable Waste and an Acceptance Certificate will be

issued.

7.3 Documents ‐ Certification Service Tellus will implement a certification process post inspection for Acceptable Waste that is delivered

to the delivery point within the proposed Facility. This will include;

C1 ‐ Acceptance Certificate.

C2 ‐ Storage Certificate.

C3 ‐ Permanent Isolation Certificate.

C1 ‐ Acceptance certification (AC)

Assuming that the delivery of waste is compliant with the Conditions of Acceptance for the

Nominated Facility and has been taken to have been accepted at the Nominated Facility by both the

Inspection Manager and the Facility Manager then an Acceptance Certificate is issued

C2 ‐ Storage certificate (SC)

Tellus must place Acceptable Waste in a Storage Location and issue a Storage Certificate to the

Customer. This certificate will be issued within twenty business days of placement in the Storage

Location


C3 ‐ Permanent isolation certificate (PIC)

Tellus will isolate Acceptable Waste, and issue a PIC once that waste is in its final destination

(underground room or cell in the geological repository part of the Nominated Facility). This

certificate will be issued within twenty business days of placement in the final destination (refer to

Annexure).

7.4 Waste Title and Management risk

Title to the waste and management risk of the waste varies depending on wether the

waste is rejected, placed into storage or permanently isolated. This is summarised below;

Rejected waste:

Title to the waste and management risk remains with Customer and accordingly, neither title nor risk

pass to Tellus at any time.

Storage service:

Title in the waste remains at all times with the Customer (whether short or long term storage) and

the management risk in the waste passes to Tellus on issue of the Acceptance Certificate, for so long

as the Waste continues to comply with the Conditions of Acceptance. Risk passes back to Customer

at the end of the Storage Term.

Permanent isolation service:

Title and management risk in the waste passes to Tellus on the issue of an Acceptance Certificate

until the site is handed back to government.


8 BIBLIOGRAPHY

Australian Radiation Protection and Nuclear Safety Agency, 2013, Licensing of Radioactive Waste

Storage and Disposal Facilities, available at: http://www.arpansa.gov.au/pubs/waste/WasteGuide‐

March2013.pdf

American Society for Testing and Materials, 2012, Standard Test method for Determining Whether a

Material is a Liquid or a Solid (ASTM D 4359‐90), available at:

https://www.astm.org/Standards/D4359.htm

British Standards Institution, 2001, Characterisation of waste. Determination of total organic carbon

(TOC) in waste, sludges and sediments, available at:

http://infostore.saiglobal.com/store/details.aspx?ProductID=885923







Department of Environment Environmental Protection (Controlled Waste) Regulations 2004,

available at:


Department of Health, 2016, Clinical and Related Waste Management Policy, available at:

http://www.health.wa.gov.au/circularsnew/attachments/1131.pdf


available at:


Department of Treasury and Finance, 2011, Disposal of Chemical wastes at the Intractable Waste

Disposal Facility (mount Walton East) – Waste Acceptance Guidelines.

Environment Agency, 2010, Waste Acceptance at Landfills, available at:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/296422/geho1110

btew‐e‐e.pdf

European Union, 2003, Council Decision 2003/33/EC establishing criteria and procedures for the

acceptance of waste at landfills pursuant to article 16 of and Annex II to Directive 1999/31/EC,

available at: http://faolex.fao.org/docs/pdf/eur39228.pdf


International Atomic Energy Agency, 2003, Derivation of Activity Limits for the Disposal of

Radioactive Waste in near Surface Disposal Facilities (IAEA‐TECDOC‐1380, 2003), available at:

http://www‐pub.iaea.org/MTCD/publications/PDF/te_1380_web.pdf

International Organisation for Standardization, 2002, Determination of flash/no flash – Closed cup

equilibrium method (ISO 1516:2002), available at:

http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=28656

International Organisation for Standardization, 2002, Determination of flash point – Closed cup

equilibrium method (ISO 1523:2002), available at:


International Organisation for Standardization, 2016, Determination of flash point – Pensky‐Martens

closed cup method (ISO 2719:2016), available at:

http://www.iso.org/iso/home/store/catalogue_ics/catalogue_detail_ics.htm?csnumber=62263

International Organisation for Standardization, 2013, Determination of flash point – Abel closed cup

method (ISO 13736: 2013), available at:


International Organisation for Standardization, 2015, Determination of flash no flash and flash point

– Rapid equilibrium closed cup method (ISO 3679: 2015), available at:

http://www.iso.org/iso/home/store/catalogue_tc/catalogue_detail.htm?csnumber=61924

Joint Standards Australia/Standards New Zealand Committee, 2007, The Storage and Handling of

Mixed Classes of Dangerous Goods, in Packages and Intermediate Bulk Containers (AS 3833: 2007),

Standards Australia, Sydney

National Health and Medical Research Council, 1992, Code of Practice for the near Surface Disposal

of Radioactive Waste in Australia (RHS35), available at:

http://www.arpansa.gov.au/pubs/rhs/rhs35.pdf

National Health and Medical Research Council, 1988, National Guidelines for the Management of

Clinical and Related Wastes, Australian Government Publishing Service, Canberra.

Stewart B., R. Haski, 1990, Guidelines for Laboratory Personnel Working With Carcinogenic or Highly

Toxic Chemicals, Australian Government Publishing Service, Canberra.

United Nations Economic Commission for Europe, 2015, Recommendations on the Transport of

Dangerous Goods, Manual Of Tests and Criteria (Sixth revised edition), available at:

http://www.unece.org/fileadmin/DAM/trans/danger/publi/manual/Rev.6/1520832_E_ST_SG_AC.10

_11_Rev6_WEB_‐With_corrections_from_Corr.1.pdf

United Nations Environment Programme, 1989, Basel Convention on the Control of Transboundary

Movements of Hazardous Wastes and Their Disposal, available at:

http://www.basel.int/Portals/4/Basel%20Convention/docs/text/BaselConventionText‐e.pdf

TCO‐5‐05‐003_0 Sandy Ridge Waste Acceptance Procedure.docx

A.1 Gated waste acceptance process flow chart



A2

Gate 5:Is the waste potentially

combustible and liable to auto‐

ignition?

Can the waste be treated to render it non‐combustible and not liable to auto‐ignition?

Yes ExcludeNo

Yes

Gate 6:Can the waste

generate a gas‐air mixture which is

toxic or explosive?

No

Can the waste be treated to render it less hazardous?

Yes

Can the method of disposal/containment be altered to render less hazardous in the

condition of storage?

No ExcludeNo

Gate 7: Is the waste

biodegradeable?

No

Yes

Yes

ExcludeYes

Gate 8:Is the waste infectious hospital or

clinical waste per H6.2 in Annex III?

No

ExcludeYes

Gate 9:Does the waste have the potential to be infectious to animals or humans?

No

ExcludeYes

Gate 10:Does the waste consist of whole or shredded

tyres?

No

ExcludeYes

B

No

Can the waste be treated to render it non‐combustible and not liable to auto‐ignition?

No

Yes



A.2 Basel Convention Annex III: List Of Hazardous Characteristics

UN Class Code Characteristics

1 H1 Explosive An explosive substance or waste is a solid or liquid substance or waste (or mixture of substances or wastes) which is in itself capable by chemical reaction of producing gas at such a temperature and pressure and at such a speed as to cause damage to the surroundings.

3 H3 Flammable Liquids The word “flammable” has the same meaning as “inflammable”. Flammable liquids are liquids, or mixtures of liquids, or liquids containing solids in solution or suspension (for example, paints, varnishes, lacquers, etc., but not including substances or wastes otherwise classified on account of their dangerous characteristics) which give off a flammable vapour at temperatures of not more than 60.5ºC, closed‐cup test, or not more than 65.6ºC, open‐cup test. (Since the results of open‐cup tests and of closed‐cup tests are not strictly comparable and even individual results by the same test are often variable, regulations varying from the above figures to make allowance for such differences would be within the spirit of this definition.)

4.1 H4.1 Flammable Solids Solids, or waste solids, other than those classed as explosives, which under conditions encountered in transport are readily combustible, or may cause or contribute to fire through friction

4.2 H4.2 Substances or wastes liable to spontaneous combustion Substances or wastes which are liable to spontaneous heating under normal conditions encountered in transport, or to heating up on contact with air, and being then liable to catch fire

4.3 H4.3 Substances or wastes which, in contact with water, emit flammable gases Substances or wastes which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in dangerous quantities

5.1 H5.1 Oxidising Substances or wastes which, while in themselves not necessarily combustible, may, generally by yielding oxygen, cause or contribute to, the combustion of other materials.

5.2 H5.2 Organic Peroxides Organic substances or wastes which contain the bivalent‐o‐o‐structure are thermally unstable substances which may undergo exothermic self‐accelerating decomposition.

6.1 H6.1 Poisonous (Acute) Substances or wastes liable either to cause death or serious injury or to harm human health if swallowed or inhaled or by skin contact

6.2 H6.2 Infectious Substances Substances or wastes containing viable microorganisms or their toxins which are known or suspected to cause disease in animals or humans


8 H8 Corrosives Substances or wastes which, by chemical action, will cause severe damage when in contact with living tissue, or, in the case of leakage, will materially damage, or even destroy, other goods or the means of transport; they may also cause other hazards

9 H10 Liberation of toxic gases in contact with air or water Substances or wastes which, by interaction with air or water, are liable to give off toxic gases in dangerous quantities

9 H11 Toxic (Delayed or chronic) Substances or wastes which, if they are inhaled or ingested or if they penetrate the skin, may involve delayed or chronic effects, including carcinogenicity

9 H12 Ecotoxic Substances or wastes which, if released, present or may present immediate or delayed adverse impacts to the environment by means of bioaccumulation and/or toxic effects upon biotic systems

9 H13 Capable, by any means, after disposal, of yielding another material, e.g. leachate, which possess any of the characteristics listed above


A.3 Potential waste category list






Asbestos N220







Chlorates D350





N100





Ethers G100


















Perchlorates D340











M250





Tyres T140



T100







F100



T120


F110







M100



Zinc compounds D230


APPENDIX 4: WASTE ZONING GUIDE

SANDY RIDGE FACILITY WASTE ZONING GUIDE

Document No.: TCO‐6‐SR‐01400‐GE‐PRO‐0002




0 10/08/2016 For issue S. Reece J. Livesey

R. Phillips

D van der Merwe

Table of Contents

Abbreviations .................................................................................................................................. i

Definitions ...................................................................................................................................... ii

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

1.1 The Sandy Ridge Facility .................................................................................................. 1

1.2 Document aims and objectives ....................................................................................... 3

1.3 Intended audience .......................................................................................................... 3

2 Dangerous Goods Segregation ................................................................................................. 5

2.1 Introduction .................................................................................................................... 5

2.2 Regulatory context .......................................................................................................... 5

2.3 Segregation approach ..................................................................................................... 5

3 Chemical Waste Zoning ........................................................................................................... 8

3.1 Overview ......................................................................................................................... 8

3.2 Principles ......................................................................................................................... 8

3.3 Methodology ................................................................................................................. 10

4 Radioactive Waste Zoning ..................................................................................................... 13

4.1 NORM Waste ................................................................................................................ 13

4.2 Sealed sources ............................................................................................................... 14

5 Indicative waste zoning plan ................................................................................................. 15

6 Bibliography .......................................................................................................................... 16

LIST OF FIGURES



Figure 2‐1: Dangerous Goods Segregation Chart (Australian Standard AS3833 figure 6.1) ................... 7

LIST OF TABLES

Table 3‐1: Zones and generic hazards ..................................................................................................... 9

Table 3‐2: Zones for single hazard wastes ............................................................................................ 11

Table 3‐3: Zones for multi‐hazard wastes ............................................................................................. 11

Table 4‐1: Sealed source emplacement hierarchy ................................................................................ 14

i

ABBREVIATIONS

ASCC Australian Safety and Compensation Council


FIBC Flexible Intermediate Bulk Container


km kilometres

L Litres

m metres


NOHSC National Occupational Health and Safety




WAP Waste Acceptance Procedures


Zone AC Acidic Nature

Zone AL Alkaline Nature

Zone PT Poisonous or Toxic

Zone R Radioactive

Zone S Other

ii

DEFINITIONS



Conditions of storage ‐ The term “in the conditions of storage” is used to differentiate between the









Regulations 2004

















In Cell Storage ‐ medium to long term below ground storage of wastes inside a cell with ongoing


Intractable Waste‐ Waste which is a management problem by virtue of its toxicity or chemical or



iii

Definitions 1996 (As amended December 2009) Western Australia Department Of Environment And

Conservation

Permanent Isolation ‐ indefinite below ground storage of wastes determined suitable for

acceptance.

Storage ‐ the short term above ground storage of materials following delivery and includes the time


iv

Disclaimer:



only.



be considered by any party other than Tellus to remain Commercial‐in‐Confidence. All rights reserved.






TCO‐5‐05‐004_0 Sandy Ridge Waste Zoning Guide.docx Page 1 of 22

1 INTRODUCTION


mine with the voids created by mining used to store and dispose of hazardous and intractable

wastes. The site is located approximately 75 km northeast of Koolyanobbing, in the Shire of

Coolgardie, within the Goldfields Region of Western Australia (Figure 1‐1).




the requirements for a near surface geological repository1 for intractable and hazardous waste









intractable waste.

1 The term geological repository is used to mean a landfill facility constructed and with the equivalent properties of a Class IV or Class V

Landfill as defined in Landfill Waste Classification and Waste Definitions 1996 (As amended December 2009) Western Australia Department Of Environment And Conservation




1.2 Document aims and objectives The aim of this document is to present guidance on the development of the Waste Zoning Guide

(WZG) that will be applied at the proposed Facility. This document should be read in conjunction

with the following:

Waste Acceptance Policy.

Waste Acceptance Criteria (WAC).

Waste Acceptance Procedure (WAP).

This document is part of a hierarchy of documents and is a Tier 4 document, and is highlighted in

Figure 1‐2 below, which includes an equivalent suite of documents for Tellus’ Northern Territory

Chandler Project. Tier 4 documents work together with Tier 3 documents to provide an outline of

operational procedures. The WZG has been developed in response to the assumed inventory for

disposal which is presented as a Potential Waste Category List in Appendix A.1 of this document.


Having established the overarching exclusion criteria to be applied at the proposed Facility in the

WAC, a gated WAP using specified test methods and criteria values will be applied to determine if a

waste can be accepted and to ensure that wastes which may react with each other are identified and

grouped according to the principles of compatibility.

Reactive groups must be physically separated during the transport, receipt, storage and during

permanent isolation, this document outlines the procedure of waste segregation and zoning.

1.3 Intended audience This document is intended initially for use by regulators responsible for assessing the facility and

issuing licences for the operation of the proposed Facility. It will be used to support the formation of


Sandy Ridge



Waste Zoning Guide

Apirnta Sidings



Waste Zoning Guide

Chandler



Waste Zoning Guide

TIER 1

TIER 2

TIER 3

TIER 4


more detailed procedures to control the process by which waste producers and Tellus Staff will

determine if the waste streams may be suitable for storage or permanent isolation and how they

should be stored or permanently isolated in a safe manner.



wastes.


2 DANGEROUS GOODS SEGREGATION

2.1 Introduction To prevent dangerous interaction, dangerous goods should be kept apart (segregated) from all other

goods with which they are not compatible. Segregation can be achieved by storing and handling

incompatible goods in separate areas or by the use of physical barriers or distances within the same

area. Systems and procedures will be developed and enforced, and personnel involved in the storage

and handling of dangerous goods will be trained and supervised to ensure segregation is maintained

at all times.

2.2 Regulatory context In Western Australia, Dangerous Goods management is enforced under the Dangerous Goods Safety

Act 2004 and is regulated under the Dangerous Goods Safety (Storage and Handling of Non‐

Explosives) Regulations 2007 (the Storage and Handling Regulations). The Storage and Handling

Regulations introduce modern safety standards for the manufacture, processing, storage, use and

disposal of dangerous goods.

The regulations adopt, with only minor variance, the National Standard for the Storage and Handling

of Workplace Dangerous Goods (the National Standard), as produced by the National Occupational

Health and Safety Commission (NOHSC; now the Australian Safety and Compensation Council, ASCC).

Western Australia has retained a licensing system for dangerous goods.

In relation to dangerous goods, ‘handling’ includes manufacture, process, pack, use, sell, supply,

carry (including by pipeline) and disposal of dangerous goods. ‘Class’ means the number assigned to

dangerous goods which exhibit a common single or most significant hazard determined by the

criteria or listing in the Australian Dangerous Goods Code, an extract of the classes is included at

Appendix A.2

2.3 Segregation approach The application of waste acceptance criteria will exclude many dangerous goods from being

accepted for permeant isolation at site. It is however important to recognise some wastes, which

may be dangerous goods, may be delivered to site and undergo treatment on site (e.g. blending with

Kaolin clay) to make a waste form which meets Tellus’ WAC and is suitable for in‐cell permanent

isolation.

Therefore, arrangements need to be made for the safe storage of these wastes. Useful guidance for

segregating incompatible dangerous goods is provided in Australian/New Zealand Standard AS/NZS

3833 The Storage and Handling of Mixed Classes of Dangerous Goods in Packages and Intermediate

Bulk Containers which is referenced in the code of practice2 which, in turn, supports the National

2 Page 29 The National Code of Practice for the Storage and Handling of Workplace Dangerous Goods NOHSC:2017(2001)


Standard. Tellus will adopt the segregation protocols presented in AS/NZS 3833 for all waste

materials that are stored on site prior to in cell permanent isolation. The Dangerous Goods

segregation chart is presented in Figure 2‐1


Figure 2‐1: Dangerous Goods Segregation Chart (Australian Standard AS3833 figure 6.1)


3 CHEMICAL WASTE ZONING

3.1 Overview Applying the WAC (refer to WAC document) will result in a set of wastes that can be placed in a cell

for permanent isolation. The application of the criteria in effect limits the hazardous properties and

physical form of the wastes.

When analysing waste for acceptance, it is essential to ensure that wastes which may react with

each other are identified and classified into compatible groups

Following acceptance wastes will be segregated into zones to ensure wastes that have the potential

to react together are kept apart.

As well as segregating wastes during initial receipt and storage (refer to Section 2), accepted wastes

must be physically separated during permanent isolation., the most appropriate zone in the facility

in which to dispose of the waste will be selected by the competent person based on zone selection

principles and methodology.

Waste placement at Sandy Ridge will normally occur as individual packages which are transported

into the cell, and placed package by package in the assigned zones within the cells. In certain

situations, bulk placement of wastes may be utilised when it has been determined as appropriate to

do so by a suitably qualified person(s).

Isolation as a control measure is usually used to control physicochemical risks for hazardous

chemicals because of the consequences when incompatible materials interact. Hazardous chemicals

should be physically separated from any chemicals or other things that may be incompatible3. This is

achieved by a physical separation distance, barriers, or a combination of both. At the proposed

Facility these barriers may include the waste packaging, clay barriers, solidified and stabilised

wastes, passive chemical barriers such as lime, calcium apatite or zeolite and prior to backfilling the

use of separation distance.

3.2 Principles There are three key principles behind zone selection:

3 section 4.1 Managing the Risks of Hazardous Chemicals in the Workplace – Code of Practice 2012


Principle 1 ‐ Keep materials with different hazardous characteristics apart.

This is a general principle resulting in the zones presented in Table 3‐1. Hazardous characteristics for

wastes in the poisonous, toxic and special waste zones are defined by the Basel convention

presented in Appendix A.3.

Table 3‐1: Zones and generic hazards

Zone # Zone Generic Reason

PT

Poisonous (H6.1)

Acute health effects Toxic (delayed or chronic) (H11)

S Ecotoxic (H12) and other special waste Long term health effects and/or environmental risk (hazards often shared by substances)

R Radioactive waste Long term health effects and/or environmental risk

Principle 2 ‐ Prevent the mixing of acidic and alkaline wastes.

The mixing of acid and alkaline wastes could result in a chemical reaction, although the permitted

physical forms and containment of the wastes would make this highly unlikely. To ensure that

wastes which are acid or alkaline in nature are stored separately two zones are to be used for irritant

wastes:

Zone # Zone Generic Reason

AC Irritant (acidic nature) Chemical properties

AL Irritant (alkaline nature) Chemical properties

These zones take into account the potential for wastes that may be classed as PT [poisonous (H6.1),

toxic (delayed or chronic) (H11)] or S [Ecotoxic (H12) and other special waste] to also display acidic

or alkaline properties. Therefore, wastes which if mixed with water would generate an acidic pH

leachate may need to be placed in the Irritant (acidic) Zone. Wastes which when mixed with water

would generate an alkaline pH leachate may need to be placed in the Irritant (alkaline) Zone. It is not

physically possible for a waste to be both acidic and alkaline in nature.


Principle 3 ‐ Prevent the mixing of multi‐hazard incompatible materials.

The first stage in minimising the risk of incompatible materials mixing is to ensure that distinctly

acidic and alkaline materials are stored separately from other wastes as described in Principle 2 ‐

Prevent the mixing of acidic and alkaline wastes.

The next stage is to minimise the risk from incompatible multi‐hazard wastes. In general the

combinations of hazards within the cell will result in negligible risk of reaction, as the majority of the

residual hazards after the application of WAC relate to potential health and environmental effects

and not reactivity.

Therefore waste possessing combinations of the following hazardous characteristics could be stored

together: Poisonous (H6.1), Toxic (delayed or chronic) (H11), and Ecotoxic (H12). The Zone for multi‐

hazard wastes with these properties will be selected in accordance with the predominant hazard

property. This will be based on hazardous property threshold concentrations for the substances in

the waste.

Wastes that are an irritant and possess other hazardous properties will be considered for storage in

the appropriate Irritant Zone (acidic or alkaline). This is because the substances in the waste that

give rise to other hazardous properties should be stable in either the acidic or alkaline environment.

Therefore if such substances escaped from containment and mixed with other acid or alkaline

wastes in the same zone, it is unlikely to give rise to an incompatible reaction.

The Dangerous Goods Segregation protocols (AS/NZ 3833 Figure 6.1) will be utilised as a secondary

check to ensure the substances to be located within a zone are compatible, and to determine if

further risk mitigation is required within the cell such as suitable barriers between zones, or to

determine any subzones that may be required within a zone, particularly with respect to the “Other

Special Waste’ zone.

Finally the safety data sheets for substances within the wastes will be assessed in terms of reactivity

data, to determine if any of the substances possess any unusual reactive properties. Any waste with

unusual reactive properties would be subjected to further tests to determine stability, and rejected

if the suitability of the waste cannot be guaranteed.

3.3 Methodology Based on the above principles the zone for a particular waste will be selected using the following

steps.

Step 1 – Single hazard waste

Wastes that have been identified as possessing one hazardous property will be placed in the

appropriate zone as shown in Table 3‐2 below. Safety data sheets for substances within the waste

will be consulted for reactivity data, to ensure that the substances within the waste do not possess

any unusual reactive properties.


Zoning in accordance with Step 1 supports compliance with principles 1 and 2 outlined above.

Table 3‐2: Zones for single hazard wastes

Single Hazardous Characteristic Zone Zone #

Poisonous (H6.1) Poisonous & Toxic (delayed or chronic) Zone

PT Toxic (delayed or chronic) (H11)

Irritant – acidic in nature Irritant (acidic) Zone AC

Irritant – alkaline in nature Irritant (alkaline) Zone AL

Ecotoxic (H12) Ecotoxic and other Special Waste Zone

S

Radioactive waste Long term health effects and/or environmental risk

R

Step 2 ‐ Multi‐hazard Hazard Wastes

The zone selected for waste possessing more than one hazardous characteristic will be determined

using Table 3‐3. A suitably qualified person shall make any final determination on zone selection.

Waste subjected to further tests will be re‐assessed using the full acceptance decision tree.

Table 3‐3: Zones for multi‐hazard wastes

Hazardous Characteristics

Poisonous

(H6.1)

Toxic (delaye

d or

chronic)(H11)

Irritant – acidic in

nature

1

Irritant – alka

line in

nature

2

Ecotoxic (H14)

Rad

ioactive

Waste

Poisonous (H6.1) PT

Toxic (delayed or chronic)(H11)

PT PT

Irritant – acidic in nature1

AC AC AC

Irritant – alkaline in nature2

AL AL Not Permitted AL

Ecotoxic (H14) PT PT AC AL S

Rad Waste Not Possible Not Possible Not Possible Not Possible Not Possible R

1 Including wastes whose leachates during tests would be acidic pH 2 Including wastes whose leachates during tests

would be alkaline pH


Zoning in accordance with Step 2 supports compliance with principle 3 outlined above.

The use of this zoning methodology provides guidance for a suitably qualified and experienced

person to categorise and instruct the safe segregation of wastes expected at the proposed Facility

for storage and permanent isolation. The suitably qualified person shall make final judgements and

zoning based on their knowledge and experience.


4 RADIOACTIVE WASTE ZONING

Radioactive waste accepted for permanent isolation at Sandy Ridge falls into two broad categories of

NORM and sealed sources. The zoning approach differs for each category and is summarised below.

4.1 NORM Waste NORM waste is (unless otherwise proven) assumed to contain relatively long‐lived radioisotopes

such as Ra, U, and Th. NORM waste is expected to be delivered to site and placed in the following

forms and placed in the appropriate R zone in accordance with the following procedure;

4.1.1 Dry solids packaged in FIBCs or drums.

These would be placed the cell (not shaft) unless of particularly high activity concentration. Higher

activity NORM wastes will always be placed as deep as possible in the cell, with lower activity wastes

being located closer to the surface. The minimum depth of cover required will be assessed during

each waste campaign.

4.1.2 Bulk solids (e.g. contaminated soils or mineral concentrates such as monazite

sand).

These will be assessed by activity level and radionuclide/particle emitter type. Higher activity

materials will generally be placed deeper in the cell, but consideration will also be given to placing

alpha and beta particle emitters at shallower depths as the requirement for shielding at the surface

is less.

4.1.3 Sludges and liquids requiring solidification and stabilisation prior to placement.

Higher activity materials will generally be placed deeper in the cell, but consideration will also be

given to placing alpha and beta particle emitters at shallower depths as the requirement for

shielding at the surface is less.

4.1.4 Contaminated equipment.

Usually the nature of these materials is such that activity levels are low, and will be made lower by

adding fill (grout or compacted kaolinised granite). Higher activity materials will generally be placed

deeper in the cell, but consideration will also be given to placing alpha and beta particle emitters at

shallower depths as the requirement for shielding at the surface is less. The materials of

construction of the waste (e.g., steel pipe) and grout fill may provide a reasonable level of shielding

and allow relatively shallow placement.

4.1.5 Use of NORM as backfill

Bulk solids, and solidified sludges and solidified liquid NORM wastes may be used as interstitial fill

around 215 litre (L) drums inside the radioactive waste disposal shafts.


4.2 Sealed sources Sealed sources will, whenever possible, be placed in their original shielding package or 60 L drum

and cemented inside a 215 L steel drum. Depending upon the source activity and isotope, more than

one source may be placed inside a 215 L cemented drum.

The primary requirements of the 215 L drum cementing process will be to provide short term source

security and operational shielding for the staff handling and placing the waste. A secondary

requirement of the 215 L drum cementing process is to provide long‐term shielding and security

against human intrusion.

Sealed sources will be placed in the cell according to the following hierarchy.

Table 4‐1: Sealed source emplacement hierarchy

Sealed Source Characteristic In‐shaft Placement Criteria

Half‐life > 3 years Greater than 10m below natural ground level

Half‐life > 20 years Greater than 15m below natural ground level

Half‐life > 30 years Greater than 20m below natural ground level. Packages will be placed in order of half‐life, with the longest lived radionuclides at the bottom.


5 INDICATIVE WASTE ZONING PLAN


6 BIBLIOGRAPHY







Department of Mines and Petroleum, 2007, Dangerous Goods Safety (Storage and Handling of Non‐

Explosives) Regulations 2007, available at:


Department of Mines and Petroleum, 2015, Dangerous Goods Safety Act 2004, available at:



available at:


Joint Standards Australia/Standards New Zealand Committee, 2007, The Storage and Handling of

Mixed Classes of Dangerous Goods, in Packages and Intermediate Bulk Containers (AS 3833: 2007),

Standards Australia, Sydney

National Occupational Health and Safety Commission, 2001, Storage and Handling of Workplace

Dangerous Goods, National Standard [NOHSC: 1015 (2001)], available at:

http://www.safeworkaustralia.gov.au/sites/swa/about/publications/pages/ns200103storageandhan

dling

Safe Work Australia, 2012, Managing the Risks of Hazardous Chemicals in the Workplace – Code of

Practice, available at:

http://www.safeworkaustralia.gov.au/sites/swa/about/publications/pages/managing‐risks‐of‐

hazardous‐chemicals‐in‐the‐workplace

United Nations Environment Programme, 1989, Basel Convention on the Control of Transboundary

Movements of Hazardous Wastes and Their Disposal, available at:

http://www.basel.int/Portals/4/Basel%20Convention/docs/text/BaselConventionText‐e.pdf

TCO‐5‐05‐004_0 Sandy Ridge Waste Zoning Guide.docx

A.1 Potential Waste Category List






Asbestos N220







Chlorates D350





N100





Ethers G100


















Perchlorates D340











M250





Tyres T140



T100







F100



T120


F110







M100



Zinc compounds D230


A.2 Dangerous Goods Codes

Extract from pages 44‐46 of Australian Code for the Transport of Dangerous Goods by Road & Rail

Edition 7.4 Update, June 2016

Substances (including mixtures and solutions) and articles subject to this Code are assigned to one of

nine classes according to the hazard or the most predominant of the hazards they present. Some of

these classes are subdivided into divisions. These classes and divisions are:

Class 1: Explosives

Division 1.1: Substances and articles which have a mass explosion hazard

Division 1.2: Substances and articles which have a projection hazard but not a mass explosion hazard

Division 1.3: Substances and articles which have a fire hazard and either a minor blast hazard or a

minor projection hazard or both, but not a mass explosion hazard

Division 1.4: Substances and articles which present no significant hazard

Division 1.5: Very insensitive substances which have a mass explosion hazard

Division 1.6: Extremely insensitive articles which do not have a mass explosion hazard

Class 2: Gases

Division 2.1: Flammable gases

Division 2.2: Non‐flammable, non‐toxic gases

Division 2.3: Toxic gases

Class 3: Flammable liquids

Class 4: Flammable solids; substances liable to spontaneous combustion; substances

which, on contact with water, emit flammable gases

Division 4.1: Flammable solids, self‐reactive substances and solid desensitised explosives

Division 4.2: Substances liable to spontaneous combustion

Division 4.3: Substances which in contact with water emit flammable gases

Class 5: Oxidising substances and organic peroxides

Division 5.1: Oxidising substances

Division 5.2: Organic peroxides


Class 6: Toxic and infectious substances

Division 6.1: Toxic substances

Division 6.2: Infectious substances

Class 7: Radioactive material

Class 8: Corrosive substances

Class 9: Miscellaneous dangerous substances and articles, including environmentally

hazardous substances.

The numerical order of the classes and divisions is not that of the degree of danger.

Many of the substances assigned to Classes 1 to 9 are deemed, without additional labelling, as being

environmentally hazardous. Wastes must be transported under the requirements of the appropriate

class considering their hazards and the criteria in this Code.

Wastes not otherwise subject to this Code but covered under the Basel Convention may be

transported under Class 9.

For packing purposes, substances other than those of Classes 1, 2 and 7, Divisions 5.2 and 6.2, and

other than self‐reactive substances of Division 4.1, are assigned to three packing groups in

accordance with the degree of danger they present:

Packing group I: Substances presenting high danger;

Packing group II: Substances presenting medium danger; and

Packing group III: Substances presenting low danger.

The packing group to which a substance is assigned is indicated in the Dangerous Goods List in

Chapter 3.2.

Articles are not assigned to packing groups. For packing purposes any requirement for a specific

packaging performance level is set out in the applicable packing instruction.

Dangerous goods are determined to present one or more of the dangers represented by Classes 1 to

9 and divisions and, if applicable, the degree of danger on the basis of the requirements in Chapters

2.1 to 2.9.

Dangerous goods presenting a danger of a single class and division are assigned to that class and

division and the degree of danger (packing group), if applicable, determined. When an article or

substance is specifically listed by name in the Dangerous Goods List in Chapter 3.2, its class or

division, its subsidiary risk(s) and, when applicable, its packing group are taken from this list.


Dangerous goods meeting the defining criteria of more than one hazard class or division and which

are not listed by name in the Dangerous Goods List, are assigned to a class and division and

subsidiary risk(s) on the basis of the precedence of hazards in 2.0.3.

A.3 ANNEX III: LIST OF HAZARDOUS CHARACTERISTICS

UN Class Code Characteristics

1 H1 Explosive An explosive substance or waste is a solid or liquid substance or waste (or mixture of substances or wastes) which is in itself capable by chemical reaction of producing gas at such a temperature and pressure and at such a speed as to cause damage to the surroundings.

3 H3 Flammable Liquids The word “flammable” has the same meaning as “inflammable”. Flammable liquids are liquids, or mixtures of liquids, or liquids containing solids in solution or suspension (for example, paints, varnishes, lacquers, etc., but not including substances or wastes otherwise classified on account of their dangerous characteristics) which give off a flammable vapour at temperatures of not more than 60.5ºC, closed‐cup test, or not more than 65.6ºC, open‐cup test. (Since the results of open‐cup tests and of closed‐cup tests are not strictly comparable and even individual results by the same test are often variable, regulations varying from the above figures to make allowance for such differences would be within the spirit of this definition.)

4.1 H4.1 Flammable Solids Solids, or waste solids, other than those classed as explosives, which under conditions encountered in transport are readily combustible, or may cause or contribute to fire through friction

4.2 H4.2 Substances or wastes liable to spontaneous combustion Substances or wastes which are liable to spontaneous heating under normal conditions encountered in transport, or to heating up on contact with air, and being then liable to catch fire

4.3 H4.3 Substances or wastes which, in contact with water, emit flammable gases Substances or wastes which, by interaction with water, are liable to become spontaneously flammable or to give off flammable gases in dangerous quantities

5.1 H5.1 Oxidising Substances or wastes which, while in themselves not necessarily combustible, may, generally by yielding oxygen, cause or contribute to, the combustion of other materials.

5.2 H5.2 Organic Peroxides Organic substances or wastes which contain the bivalent‐o‐o‐structure are thermally unstable substances which may undergo exothermic self‐accelerating decomposition.

6.1 H6.1 Poisonous (Acute) Substances or wastes liable either to cause death or serious injury or to harm human health if swallowed or inhaled or by skin contact


6.2 H6.2 Infectious Substances Substances or wastes containing viable microorganisms or their toxins which are known or suspected to cause disease in animals or humans

8 H8 Corrosives Substances or wastes which, by chemical action, will cause severe damage when in contact with living tissue, or, in the case of leakage, will materially damage, or even destroy, other goods or the means of transport; they may also cause other hazards

9 H10 Liberation of toxic gases in contact with air or water Substances or wastes which, by interaction with air or water, are liable to give off toxic gases in dangerous quantities

9 H11 Toxic (Delayed or chronic) Substances or wastes which, if they are inhaled or ingested or if they penetrate the skin, may involve delayed or chronic effects, including carcinogenicity

9 H12 Ecotoxic Substances or wastes which, if released, present or may present immediate or delayed adverse impacts to the environment by means of bioaccumulation and/or toxic effects upon biotic systems

9 H13 Capable, by any means, after disposal, of yielding another material, e.g. leachate, which possess any of the characteristics listed above


APPENDIX 5: WORKS APPROVAL AND LICENCE APPLICATION FEES

5.1 Request for Exemption from publication Refer to the Sandy Ridge Facility Works Approval and Licence Application cover letter. Tellus respectfully requests that the works approval application fee calculations provided in section 5.2 and 5.3 of this Appendix be exempt from publication.


SS

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