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Works Approval Applica�on No.3 2019 Sandy Ridge Facility 03 October 2019 HS00-1760150200-22627 Prepared for: Department of Water and Environmental Regula�on Prepared by Tellus Holdings Ltd Waste Storage, Processing and Permanent Isola�on Categories 61A, 61, 65 and 66

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Page 1: Sandy Ridge Facility · 2019-10-29 · HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1 1 PURPOSE AND SCOPE OF APPLICATION This Works Approval Application (Application) seeks

Works Approval Applica�on No.3

2019

Sandy Ridge Facility

03 October 2019HS00-1760150200-22627

Prepared for:Department of Water and Environmental Regula�on

Prepared by Tellus Holdings Ltd

Waste Storage, Processing and Permanent Isola�on Categories 61A, 61, 65 and 66

Page 2: Sandy Ridge Facility · 2019-10-29 · HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1 1 PURPOSE AND SCOPE OF APPLICATION This Works Approval Application (Application) seeks

SANDY RIDGE FACILITY WORKS APPROVAL APPLICATION

CLASS IV AND CLASS V PRESCRIBED PREMISES CATEGORIES 61, 61A, 65 AND 66

Final | October 2019

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 ii

Table of Contents

Abbreviations ............................................................................................................................ vii

Definitions of terms and acronyms .............................................................................................. ix

1 Purpose and scope of Application ......................................................................................... 1

2 Background .......................................................................................................................... 3

3 Overview of Premises ........................................................................................................... 6

3.1 Introduction .................................................................................................................... 6 3.2 Waste inspection and surface storage ............................................................................ 8 3.3 Liquid waste immobilisation ......................................................................................... 16 3.4 Permanent isolation of waste ....................................................................................... 18 3.5 Storm water catchment and retention ......................................................................... 21 3.6 Raw water supply and treatment ................................................................................. 23 3.7 Exclusions to the Premises ............................................................................................ 24

4 Legislative Context ............................................................................................................. 26

4.1 Summary of approvals and tenure ............................................................................... 26 4.2 Part IV of the EP Act ...................................................................................................... 26 4.3 Contaminated sites ....................................................................................................... 26 4.4 Part V of the EP Act ....................................................................................................... 27 4.5 Radiation Safety Act 1975 ............................................................................................. 29

5 Location and Siting ............................................................................................................. 30

5.1 Siting and context ......................................................................................................... 30 5.2 Sensitive premises......................................................................................................... 30 5.3 Sensitive receptors and specified ecosystems .............................................................. 31 5.4 Groundwater and water sources .................................................................................. 31 5.5 Conceptual site model .................................................................................................. 32

6 Modelling and Monitoring Data .......................................................................................... 35

7 Risk Assessment ................................................................................................................. 45

7.1 Determination of emission, pathway and receptor ...................................................... 45 7.1 Consequence likelihood and treatment of risk events ................................................. 47 7.2 Acceptability and treatment of Risk Event ................................................................... 50 7.3 Potential discharges – storage of waste ....................................................................... 50 7.4 Risk assessment - Above-ground storage of Class IV and Class V wastes impacting on soil and vegetation ................................................................................................................... 59 7.5 Risk assessment – Contaminated stormwater impacting on soil and vegetation ........ 61 7.6 Risk assessment – WIP waste impacting on soil and vegetation .................................. 63 7.7 Summary of acceptability and treatment of Risk Events .............................................. 64

8 Controls ............................................................................................................................. 67

8.1 General controls ............................................................................................................ 67

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 iii

8.2 Storage, handling and permeant isolation of LLW ........................................................ 69 8.3 Waste isolation in near-surface geological repository ................................................. 69 8.4 EP Act regulatory controls............................................................................................. 71

9 Conclusion .......................................................................................................................... 72

10 References ......................................................................................................................... 73

Appendix A: Construction Quality Assurance Plan ..........................................................................

Appendix B: Supporting Figures .....................................................................................................

Appendix C: Supporting Drawings ..................................................................................................

Appendix D: Sandy Ridge Dangerous Goods License DGS022452 .....................................................

Appendix E: Radiation Management Plan ......................................................................................

Appendix F: Sandy Ridge Soil Sampling Analysis & Radionuclide Analysis ........................................

Appendix G: Waste Acceptance Criteria ..........................................................................................

Appendix H: Waste Acceptance Procedure .....................................................................................

Appendix I: Waste Zoning Guide .....................................................................................................

List of Figures

Figure 1-1 Site Layout and phasing of Sandy Ridge Facility works approvals. ........................................ 2 Figure 2-1 Regional location of the Sandy Ridge Facility ........................................................................ 5 Figure 3-1 Sandy Ridge Facility Infrastructure Area layout. ................................................................... 7 Figure 5-1 Distance to sensitive receptors ............................................................................................ 33 Figure 5-2 Sandy Ridge Facility Conceptual Site Model during operations. ......................................... 34 Figure 6-1 Drill holes and survey locations and where groundwater has been encountered .............. 39 Figure 6-2 Soil sampling locations ......................................................................................................... 40 Figure 6-3 Location of electroseismic and electrotulleric survey lines at Sandy Ridge ....................... 41 Figure 6-4 Data trace points for survey line 3 showing relative values of potential hydraulic conductivity ........................................................................................................................................... 42 Figure 6-5 3D model showing ESKT vales across the Sandy Ridge site looking north .......................... 42 Figure 6-6 ESKT result for survey line 1 at Sandy Ridge and interpreted basement level indicated in dark blue ............................................................................................................................................... 43 Figure 6-7 ESKT result for survey line 3 at Sandy Ridge ........................................................................ 43 Figure 6-8 ESKT result for survey line 3 at Sandy Ridge ........................................................................ 44 Figure 8-1 Proposed environmental monitoring stations during operations. ...................................... 70

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 iv

List of Tables

Table 1-1 EP Act Part V approvals phasing............................................................................................. 1 Table 4-1 Relevant approvals and tenure achieved for the Facility to date ......................................... 27 Table 5-1 Off-site premises receptors and distance from site activity boundary ................................ 30 Table 5-2 On-site premises receptors and distance from site activity boundary ................................ 30 Table 5-3 Distance to sensitive receptors and specified ecosystems from the site activity boundary. .............................................................................................................................................................. 31 Table 5-4 Distances to regional groundwater and other water sources from the site activity boundary .............................................................................................................................................................. 32 Table 6-1 Summary of soil and ground conditions ............................................................................... 35 Table 7-1 Risk rating matrix .................................................................................................................. 47 Table 7-2 Risk criteria table................................................................................................................... 48 Table 7-3 Risk treatment table. ............................................................................................................ 50 Table 7-4 Environmental Risk Events – construction emissions, pathways and receptors .................. 51 Table 7-5 Environmental Risk Events – operations emissions, pathways and receptors ..................... 54 Table 7-6 Risk Assessment Summary - Operations. .............................................................................. 65 Table 8-1 Proposed environmental monitoring.................................................................................... 68

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 v

Document control

The signatures below certify that this Works Approval Application has been reviewed, accepted and demonstrates that the signatories are aware of all the requirements contained herein and are committed to ensuring their provision.

Name Signature Position Date Prepared by Richard Phillips

General Manager HSECQ 27/09/2019

Reviewed by Julie Mahony

Manager –Environment & Compliance

03/10/2019

Stephen Hosking

General Manager – Project Development

02/10/2019

Approved by Richard Phillips

General Manager HSECQ 03/10/2019

Amendment record

This Works Approval Application is reviewed, audited and updated to ensure its continuing relevance to the systems and process that it describes. A record of contextual additions or omissions is given below:

Page No. Context Version Date

Company proprietary information

The electronic version of this Works Approval Application is the latest version. It is the responsibility of the individual to ensure that any paper material is the current version. The printed version of this procedure is uncontrolled, except when provided with a document reference number and version in the field below:

Document Ref. HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 Ver 0

Uncontrolled Copy Controlled Copy Date 03/10/2019

Tellus Holdings Ltd owns and is responsible for the copyright in this document. All rights reserved. Neither the whole nor any part of this document may be reproduced, stored in or transmitted in any form by any means (electronic, mechanical, reprographic, recording or otherwise) without the prior written consent of Tellus Holdings Ltd.

Page 8: Sandy Ridge Facility · 2019-10-29 · HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1 1 PURPOSE AND SCOPE OF APPLICATION This Works Approval Application (Application) seeks

Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 vi

Works Approval details

Applicant Tellus Holdings Ltd ABN 97 138 119 829 ACN 138 119 829 Registered business address Level 10, Suite 2

151 Castlereagh Street Sydney, NSW 2000

Prescribed premises • Category 61

• Category 61A

• Category 65

• Category 66

Premises Sandy Ridge Facility Various Lots, Shire of Coolgardie

Interpretation

In this Works Approval:

• any reference to an Australian or other standard, guideline or code of means the version of the standard, guideline or code of practice in force at the time of submitting this Works Approval Application and includes any amendments to the standard, guideline or code of practice which may occur from time to time during the assessment of the Works Approval Application; and

• unless specified otherwise, any reference to a section of an Act refers to that section of the Environmental Protection Act 1986 Western Australia (WA).

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 vii

ABBREVIATIONS

ABN Australian Business Number

ACN Australian Company Number

ADT Articulated Dump Truck

ARI Annual Recurrence Interval

CBR California Bearing Ratio

CSM Conceptual Site Model

DWER Department of Water and Environmental Regulation

EP Act Environmental Protection Act 1986 (WA)

ESKT electroseismic hydraulic conductivity tomography

FIBC Flexible Intermediate Bulk Container

HIL Health Indicator Level

hr hour

HV Heavy vehicle

IBC Intermediate Bulk Container

ISO International Standards Organisation

IWDF Intractable Waste Disposal Facility

ID Identification

Km kilometres

kW kilowatts

LV Light vehicle

m metres

mm millimetres

MS Ministerial Statement

Regulations EP Regulations 1987 (WA)

RS Act Radiation Safety Act 1975 (WA)

SPR Source Pathway Receptor

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 viii

tpa tonnes per annum

WAC Waste Acceptance Criteria

WAP Waste Acceptance Procedure

WIP Waste Immobilisation Plant

WSC Waste Supply Contract

WZG Waste Zoning Guide

% percent

‘ foot

“ inches

Page 11: Sandy Ridge Facility · 2019-10-29 · HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1 1 PURPOSE AND SCOPE OF APPLICATION This Works Approval Application (Application) seeks

Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 ix

DEFINITIONS OF TERMS AND ACRONYMS

Terms, acronyms and abbreviations

Definitions

Application means this Works Approval Application Contaminant means a substance or object in contact or mixed with a material that

presents, or has the potential to present, a risk of harm to human health, the environment or any environmental value.

Contaminated soil means soil that has a substance in it at above background concentrations that presents, or has the potential to present, a risk of harm to human health, the environment or any environmental value.

Class IV refer to the definition of near-surface geological repository. Class V refer to the definition of near-surface geological repository. Discharge has the same meaning given to that term under the EP Act. Emission has the same meaning given to that term under the EP Act. Environmental harm has the same meaning given to that term under the EP Act. Facility means the Sandy Ridge Facility. Hazardous waste means the 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, carcinogenic, and radioactive).

Intractable waste means waste whose toxicity or chemical or physical characteristics make it difficult to dispose of or treat safely, and is not suitable for disposal in Class I, II, III and IV landfill facilities.

Material environmental harm has the same meaning given to that term under the EP Act. Minister the Minister responsible for the EP Act and associated regulations. Near surface geological repository

means the Sandy Ridge Facility capable of accepting and permanently isolating contaminated soils and intractable wastes.

On-site means within the prescribed premises boundary. Pollution has the same meaning given to that term under the EP Act. Prescribed premises has the same meaning given to that term under the EP Act. Proponent refers to Tellus Holdings Ltd. Reportable event means an exceedance above the target limit. Risk Event where an emission is expected, a receptor which may be exposed to that

emission through an identified actual or likely pathway, and a potential adverse effect to the receptor from exposure to that emission.

Serious environmental harm has the same meaning given to that term under the EP Act. Sensitive receptors and ecosystems

areas of high conservation value and special significance that may be impacted as a result of prescribed activities resulting in emissions and discharges from the Facility.

Treatment means physical, chemical or biological processing of a waste for disposal or reuse.

Unreasonable emission has the same meaning given to that term under the EP Act. Works refers to the Works described in Chapter 3, at the locations shown in

Chapter 6 of this Works Approval Application to be carried out at the Premises.

Works Approval refers to this document, which evidences the grant of the works approval by the CEO under s.54 of the EP Act, subject to the Conditions.

Waste has the same meaning given to that term under the EP Act. Waste Acceptance Criteria means Tellus Waste Acceptance Criteria.

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1

1 PURPOSE AND SCOPE OF APPLICATION

This Works Approval Application (Application) seeks approval under Part V of the Environmental Protection Act 1986 (EP Act) to construct, commission and operate the Sandy Ridge Facility (Facility) under Categories 61, 61A, 65 and 66 listed in Schedule 1 of the Environmental Protection Regulations 1987 (Regulations).

The extent of physical and operational limits of the Facility are described in Table 2 of Attachment 1 to Ministerial Statement No. 1078 (MS 1078). Approvals under Part V of the EP Act are to be conducted in phases as shown in Table 1-1 and diagrammatically shown in Figure 1-1.

This Application provides high level information about the management, handling and treatment of low level radioactive waste (LLW) for context only, as these activities are regulated under the Radiation Safety Act 1975 (RS Act). See Section 4.5 for more detail.

Table 1-1 EP Act Part V approvals phasing.

Phase Application Timing Description Status WAA0 August 2017 Works approval application for mining,

chemical, radioactive waste facility. W6089/2017/1 withdrawn April 2019.

WAA1 April 2019 Works approval application for mining-related infrastructure, Cat 12, 64 and 89.

W6243/2019/1 granted May 2019.

WAA2 September 2019 Category 61 and 61A for short-term and temporary1 above-ground waste storage, but no waste processing, in the East Yard during construction of the main Facility. This may include NORM waste storage which is subject to separate approval by the WA Radiological Council under the WA Radiation Safety Act 1975 (RS Act).

Submitted 26 September 2019 (Tellus 2019).

WAA3 September 2019 Additional aboveground infrastructure related to Category 61 and 61A plus Category 65 and 66 for Class IV and Class V waste handling, processing and in- cell permanent isolation of chemical and Low Level Radioactive waste.

This application.

REG1 November 2019 Registration application for Category 64 and Category 89 to be submitted with compliance report for Class II landfill and waste water treatment plan installation.

Pending construction/installation.

LIC1 December 2019 Licence application for Category 61 and 61A to be submitted with compliance report for East Yard above-ground waste storage.

Pending construction of temporary waste area in East Yard.

LIC1 Amend

February 2020 Licence amendment to add category 12 for mobile screening plant during construction.

Pending mining of the first Cell.

LIC1 Amend

August 2020 Licence amendment to add category 65 and 66. Pending construction.

1 Temporary is defined as the period of construction for the Sandy Ridge Facility.

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Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use.Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied.

Coordinate System:GDA 1994 MGA Zone 51

SANDY RIDGE FACILITYCat 65 & 66 WORKS APPROVAL

Site LayoutFigure 1-1

±

Putrescible Landfill

Landfill access road

Accommodation village

Accommodation access road (with water pipeline)

Site access road

Water pipeline route

TSR0387_WWAv3_SiteLayout.mxd

Legend5m Contours

Proposed infrastructure design

Proposed Mining Area

Works Approval Application 1 (W6234-2019-1)

Works Approval Application 2

Works Approval Application 3

Mine Pit 1

Settlement sumpBrine pond

Topsoil stockpile

Prescribed Premises Boundary

Treated wastewater irrigation area (discharge point)

Flood levee

Version: BDate: 3/10/2019

Overburden stockpiles (1-4)123

4

Mine Pit 3Mine Pit 4 Mine Pit 2

Mining Area

480

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470465

460

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Solar panel farm

SP-ID:GL00-2017072102-712Data in this map is sourced from © State of Western Australia (Department of Mines, Industry, Regulation and Safety) 2018.

Infrastructure area

Septic System (discharge point)

465

460

480

± 0 125 250 375 500m

Legend

Prescribed Premises Boundary

Drawn by: RM

Category No. Category Description

12Screening 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.

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

89

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 Class ification and Waste Definitions 1996” published by the Chief Executive Officer and as amended from time to time) is accepted for burial.

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

61ASolid waste facility: premises (other than premises within category 67A) on which solid waste produced on other premises is stored, reprocessed, treated, or discharged onto land

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

61ASolid waste facility: premises (other than premises within category 67A) on which solid waste produced on other premises is stored, reprocessed, treated, or discharged onto land

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 Class ification and Waste Definitions 1996” published by the Chief Executive Officer and as amended from time to time) is accepted for burial.

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 Class ification and Waste Definitions 1996” published by the Chief Executive Officer and as amended from time to time) is accepted for burial.

Page 14: Sandy Ridge Facility · 2019-10-29 · HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1 1 PURPOSE AND SCOPE OF APPLICATION This Works Approval Application (Application) seeks

Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 3

2 BACKGROUND

Tellus is developing an open-cut kaolin mine and complementary near-surface geological waste repository accepting Class IV and Class V waste (referred to as the Facility). The Facility is located approximately 75 kilometres (km) north-east of Koolyanobbing in the Shire of Coolgardie in the Goldfields Region of WA (Figure 2-1).

MS 1078 for the Facility was published on 26 June 2018. Australian Government Approval (EPBC2015/7478) was published in January 2019. A minor amendment to the size of the development envelope in MS 1078 was made in February 2019.

The assessment of the proposal under Part IV of the EP Act by the Environmental Protection Authority considered the sites suitability for an intractable waste facility and potential adverse impacts on terrestrial environmental quality. Subsequently, MS 1078 included conditions for factors that are often regulated under Part V of the EP Act:

• Condition 9 requires Tellus to develop and implement a Leachate Monitoring and Management Plan to control impacts to soil.

• Condition 12 requires Tellus to develop and implement a Waste Facility Decommissioning and Closure Plan to demonstrate how the site will be closed so that it will be safe in the long-term.

This Application does not duplicate the risk assessment and management of the above issues. It summarises the key issues for context where the activities may result in emissions or discharges.

Due to the dual nature of the Facility, Mining Act 1978 tenure and Crown Lease/Easements are required under the Land Administration Act 1997. This Application is being submitted for assessment by Department of Water and Environmental Regulation (DWER) in parallel to the final stages of the development of the Crown Lease by Department of Planning, Lands and Heritage.

In accordance with Tellus’ strict Waste Acceptance Criteria (WAC), presented in Appendix G, 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 an either spade-able solid or concrete monolith. The added materials will increase the total mass of the waste. Depending on the required waste treatment formulation, the mass of permanently isolated waste may be up to 220,000 tonnes per annum (tpa). 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 as listed in Table 2 of Attachment 1 to MS 1078.

Construction for mining related infrastructure in line with W6243/2019/1 commenced in September 2019 and is scheduled for a period of approximately 10 months. This Application seeks approval for

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 4

above ground waste acceptance and storage, waste processing and permanent isolation of Class IV and Class V intractable waste materials.

Page 16: Sandy Ridge Facility · 2019-10-29 · HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 1 1 PURPOSE AND SCOPE OF APPLICATION This Works Approval Application (Application) seeks

Kalgoorlie

Koolyanobbing!(

!(

!(

!(

Carina Mine Camp

IWDF Mt Walton East

CarinaMine Pit

!(

Ex-Jaurdi Pastoral Station Homestead

!(

!(

Coolgardie

Southern Cross

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Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use.Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied.

± SANDY RIDGE FACILITYCat 65 & 66 WORKS APPROVAL

Legend

IWDF Access Road

Principal Road

Railway

Development Envelope

Local Government AuthorityBoundaries

DBCA Lands Specified Ecosystems: PotentiallyOccuring Priority EcologicalCommunities

TSR0383_WWAv3_RegionalLocation.mxd

!(

Sandy Ridge Facility

"!(

Kalgoorlie

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics,CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User CommunitySources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS,NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (HongKong), (c) OpenStreetMap contributors, and the GIS User Community

Western Australia

Sandy Ridge Facility

IWDF Access Road

Figure 2-1 Regional Location

PERTH-KALGOORLIE RAILWAY

GREAT EASTERN HIGHWAY

Clear and Muddy Lakes Nature ReserveRowles Lagoon Conservation Park

Goldfields Woodlands National Park Goldfields WoodlandsNational Park

Victoria Rock Nature Reserve

Scahill Timber Reserve

Yallari Timber ReserveKangaroo Hills Timber Reserve

Karamindle Forest

Boorabbin National Park

Dulagdin Nature ReserveYellowdine Nature Reserve

Mount Manning- Helena and AuroraRanges Conservation Park

Mount Manning Range Nature Reserve

KambaldaNature Reserve

Sh

ire

of

Co

olg

ard

ie

Sh

ire

of

Yilg

arn

Version: ADate: 27/09/2019

Coordinate System:GDA 94 MGA Zone 51

Data in this map is sourced from: © Commonwealth of Australia (Geoscience Australia) 2018 and © State of Western Australia (Department of Mines, Industry Regulation and Safety) 2018.

Ex-Jaurdi Pastoral Lease

Wallaroo RockConservation Park

SP-ID:GL00-2017072102-709

Hunt Range BIF

Lake Giles(northern Yerilgee Hills)BIF

Finnerty Range / Mt Dimer / Yendilberin Hills BIF

Drawn by: RM

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Sandy Ridge Works Approval Application No.3 HS00-1760150200-22627 / TSR-5-SR-02200-AP-REP-0003 6

3 OVERVIEW OF PREMISES

3.1 Introduction This section describes key waste infrastructure to be constructed, commissioned and operated at the Facility associated with waste acceptance, storage (Category 61 and 61A), processing and permanently isolating Class IV (Category 65) and Class V (Category 66) intractable wastes within a near-surface geological repository. The premises map is presented in Figure 1-1 and detailed layout of the Infrastructure Area is presented in Figure 3-1.

The elements described in Section 3 are the subject of this Application. An accompanying Construction Quality Assurance Plan (Appendix A) has been developed to ensure compliance with the relevant Works Specification detailed.

The information described is supported by a waste management lifecycle process flow chart and Waste Zoning Guide (WZG) contained in Appendix I.

Section 3 does not describe mining activities, as mining is regulated by Department of Mines, Industry Regulation and Safety and has been approved under Mining Proposal Reg ID 75521.

As outlined in Section 1, this Application does not detail the aspects of radiation management in regard to waste, as this is regulated under the RS Act. Section 3 provides high level information about the management, handling and treatment of LLW for context only.

This Application has grouped Categories 61, 61A, 65 and 66 infrastructure as follows:

• Waste inspection and operational surface storage.

• Liquid waste immobilisation.

• Permanent isolation of waste within waste Cells.

• Storm water catchment and retention.

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220750

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50

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00

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Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use. Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied.

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SANDY RIDGE FACILITYCAT 65 & 66 WORKS APPROVAL

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Version: ADate: 27/09/2019

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Works Approval 1 (W6234-2019-1)

Works Approval 2 (Cat 61 & 61A Temporary Storage)

Works Approval 3 (Cat 65 & 66)

Drawn by: DS

ID Infrastructure1Flood levee2Fire Risk Store Area3W h eel wash facility4Site entry car/bus parking5Site entry gates6Veh icle inspection area7Radiation scanner8Main office9Go line10Emergency veh icle station11East yard (solids)12RO Plant13W ater handling facility14Container staging unloading15Container staging storage area16W aste Inspection Facility17Fire water facility18Storm water retention pond19Service water pond20Laboratory and office21W aste Immobilisation Plant "W IP"22W aste Inspection & W IP Dispensing Facility23W orkshop and Laydown yard24W aste immobilisation plant loading25100† cement storage silo26Graded kaolin bulk hoppers27HV and LV washdown facility28Power facility29HV and LV refueling facility30HV and LV mobile plant workshop31Solar panel farm32Stormwater sump west33Stormwater sump north

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3.2 Waste inspection and surface storage The Facility will be operated in accordance with the Dangerous Goods Safety (Storage and Handling of Non-Explosives) Regulations 2007 and in accordance with Dangerous Goods Licence DGS022452 (see Appendix D).

Solid wastes may be stored in either the East Yard (see Section 3.2.3) or the Mixed Store (see Section 3.2.2). Liquid/sludge wastes may be stored in either the Mixed Store or the Radioactive Waste Warehouse and Yard (see Section 3.2.5.

During operations, above-ground storage time for wastes at Sandy Ridge is expected to be about 14 days for onsite verification testing in accordance with the Tellus’ WAP. Some waste may occasionally be longer due to operational constraints.

MS 1078 limits the duration of above-ground waste storage to 12 months. Tellus will store materials ‘like with like’ wherever possible and in accordance with its DG licence (Appendix D).

3.2.1 Waste inspection bays

The information explained below is supported by Figure B1 in Appendix B.

On entering the site, the consignment’s waste documentation would be reviewed and inspected at the front gate and waste inspection bays (respectively). The exterior of the truck and containers and non-containerised bulk items would also be inspected at this point.

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 material, it is to be halted and escorted to the quarantine area for further investigation and action in accordance with Tellus’ Radiation Safety Management Plan and Standard Operating Procedures2.

The waste inspection bays are intended to allow for the opening, evaluation and inspection of the waste receptacles that are transported to the Facility in a sealed container. The inside of the shipping container (or other transport container e.g. drums) 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.

Containers will be partially unloaded from the incoming road train vehicles. Typically trucks of varying trailer configuration but maximum shall be a B-Triple (36.5 m) onto the bays, or from Container storage as applicable. A minimum of two bays are required. The waste package would be

2 Tellus’ Radiation Safety Management Plan and Standard Operating Procedures for low level radioactive waste for the premises are being assessed and approved separately by the WA Radiological Council under the Radiation Safety Act 1975.

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audited against the customer’s pro forma to confirm the volume and type of waste delivered is as described in the customer’s documentation.

If the documentation is not present or is incomplete, Tellus would be unable to confirm that the packaging and transport standards have been met, the truck would be quarantined within a hardstand (temporary yard) area. Tellus would not turn around a truck until a full investigation was carried out and advice sought from DWER while any uncertainties or discrepancies are resolved between Tellus and the waste customer.

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 contained and managed in accordance with the methodology outlined in the Facility’s Operating Strategy. Contaminated shipping containers will be cleaned in a bunded area.

If the waste manifest meets packaging and transport standards as per the Waste Supply Contract (WSC) and the WAC, trucks with containers would proceed through the gate to the waste storage areas (refer to Sections 3.2.2 and 3.2.3).

Consignments would be weighed using a reach stacker fitted with a weightometer. At this point the waste would be considered delivered, but not accepted. The shipping container remains in the Mixed Store or East Yard until it is scheduled to be moved into the waste cell. Waste storage will be in accordance with Dangerous Goods Storage Licence DGS022452.

When scheduled, sludge wastes are transferred directly to the Waste Immobilisation Plant (WIP) (refer to Section 3.3 for more information on the WIP).

Each container would be tracked and logged in an electronic record system which forms part of Tellus’ Enterprise Resource Planning system3. This will track 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 customer.

The construction and operational requirements of the waste inspection bays are:

• Covered area providing protection from rain ingress.

• Spatial area for the unloading and storage of 24 standard pallets (unstacked).

3 Tellus’ proposed internal business system

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• Minimum covered spatial area shall allow for ease of access by associated mobile plant, namely a laden container lifter, forklift traffic, LV and pedestrian allowances.

• Traversable blind catchment sumps.

• Structure to be rated for area.

• Appropriate flooring (i.e. concrete) to associated work areas.

• Potable water for safety showers and eye wash stations.

Drawings

Refer to drawing number: A3-4 General Arrangement Plan and Elevations in Appendix C

3.2.2 Mixed Store

Mixed Store will be operated in accordance with Dangerous Goods Storage Licence DGS022452 (Appendix D) and can be used to store solid and/or liquid wastes.

The Mixed Store is to be used to store containers within their nominated waste groups, pending either delivery to the waste disposal cell, laboratory sampling, laboratory sampling test results or storage of empty containers awaiting removal from site.

A digital waste management system will assist waste storage planning and will record waste movements. Accordingly, the location and nature of all wastes will be known at any time. Each container will be logged and tracked using the electronic records system.

Containers may also be quarantined if their contents do not meet the WAC and require investigation/further action. These details will be logged in the electronic records system.

Empty containers may be stored anywhere in the Mixed Store or East Yard as they have no consequence from an environmental or human safety perspective.

A section of the Mixed Store or East Yard (see Section 3.2.3) may be set aside on a campaign-basis for consignments of bulk waste items (e.g. contaminated sleepers or pipes) that do not require transport or storage in sea containers and, can be safely stored with minimal containment due to the insolubility of their contamination.

Upon return from the waste Cell, the containers are cleaned (if required) at the bunded area in the Radioactive Waste Area.

Liquid wastes

The Mixed Store will store sludges, liquid wastes in containers within their nominated waste zoning groups as per Dangerous Goods Licence DGS022452. Liquid/sludge wastes may also be stored in the Radioactive Waste Area (see Section 3.2.5.

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As defined in supporting detailed design engineered drawings, an appropriate paving type will be used in areas where liquid/sludge wastes are to be stored. The layout i.e. waste storage zones, will need to be flexible to cater for the changing amounts and types of wastes at the Facility, which will vary over time.

The design criteria for the Mixed Store will be as follows:

• Vehicles – laden container lifter, light vehicles and road train vehicles.

• Minimum slope – 0.5 %

• Minimum of 1.5m between ends of the containers and a minimum of 0.5 m between container lengths.

• Rainwater containment 100yr ARI for 72 hours.

• Container storage area shall be block paved with an appropriate base course capable of supporting all associated works and equipment.

• Suitable yard lighting to provide safe working environment.

• Rainwater collected and drained to the yard containment pond.

• Pavement Type A as follows:

o 80mm block paving and base course as nominated below:

25 mm bedding sand.

200 mm thick cement modified silcrete/laterite (with a minimum soaked CBR of 80 %) and approximately 1 % cement by mass.

200mm thick cement stabilised in situ material and approximately 2 % cement by mass.

Compacted subgrade CBR 15 % minimum.

o Block paved areas to be dry swept with Bentonite clay.

Drawings

• Refer to drawing numbers: A3-5 Facility Processing Facility Plant Arrangement and A3-6 Bulk Earthworks Layout in Appendix C for location and layout.

• Refer to drawing number: A3-7 Pavement Type Details in Appendix C for pavement specification

3.2.3 East yard

East yard will be used for the storage of dry and bulk solid waste materials and will be operated in accordance with Dangerous Goods Storage Licence DGS022452.

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The requirements for the East Yard area are:

• Pavement Type C as follows:

o Area to be cleared, shaped and proof rolled and compacted.

o 250mm select fill compacted to 95 % MMDD.

o Compacted subgrade CBR 15 % minimum.

• Needs to be free drain away from the facility into a run off pond.

• Be suitable for the container handler.

Drawings

• Refer to drawing numbers: A3-5 Facility Processing Facility Plant Arrangement and A3-6 Bulk Earthworks Layout in Appendix C for location and layout.

• Refer to drawing number: A3-7 Pavement Type Details in Appendix C for pavement specification.

3.2.4 Flammable risk store

The flammable risk store will be used to store containers within their nominated waste groups pending laboratory sampling or consolidation prior to off-site disposal to appropriately licenced third-party waste facilities capable of handling flammable waste, and storage of empty containers awaiting removal from site. Flammable materials are not permitted in the waste Cell (as defined in the Sandy Ridge WAC).

The flammable risk store will be operated in accordance with Dangerous Goods Storage Licence DGS022452.

The requirements for the flammable risk store are:

• Pavement Type A as follows:

o 80mm block paving and a base course as nominated below:

250mm thick cement modified silcrete/laterite compacted to 95 % Maximum Modified Dry Density (MMDD).

Compacted subgrade with a CBR of 15 %.

All block paved areas to be dry swept with bentonite clay.

o Rainwater containment to a 100 ARI annual recurrence interval (ARI) for 72 hours with drainage to a sump that can be manually pumped out.

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Drawings

• Refer to drawing numbers: A3-8 Flammable Goods Mechanical Arrangement and A3-9 Flammable Goods Civil Arrangement in Appendix C for location and layout.

• Refer to drawing number: A3-7 Pavement Type Details in Appendix C for pavement specification.

3.2.5 Low level Radioactive Waste warehouse and yard

Overview of LLW approval process for Sandy Ridge

In September 2019, Tellus submitted the WA Radiation Health Unit (RHU) a Site Registration Application under the RS Act. If granted, the Registration will permit Tellus to accept LLW for storage at the Facility. The Site Registration Application was supported by a Radiation Management Plan (RMP) and Standard Operating Procedures for managing hazards associated with storing and handling LLW at the premises. The RMP is attached in Appendix E.

In October 2017, Tellus submitted a pre-operational Safety Case to the RHU covering hazards associated with permanently isolating LLW inside a Cell. The same document covered long term exposure hazards to humans and the receiving environment (also known as post-closure risk assessment).

Both documents are currently under assessment by the RHU and Radiological Council. A copy of the Safety Case can be made available upon request.

Details of the radioactive waste warehouse and yard

The radioactive waste warehouse and yard are used to receive and store low level radioactive materials, NORM solids/liquids and pastes (both radioactive and non-radioactive), and Disused Sealed Radioactive Sources, which are delivered in packaging or as required by the Facility’s Radiation Management Plan and/or Dangerous Goods Licence.

The radioactive waste warehouse will:

• Enable the unloading and inspection of containers laden with radioactive material.

• Enable the repacking/filling of containers with radioactive waste that has been consolidated in the radioactive warehouse.

• Enable the transfer of liquid waste to the WIP.

• Provide a means of baling empty Intermediate Bulk Containers (IBC) and Flexible Intermediate Bulk Containers (FIBC) and heavy steel drums.

• Provide dedicated, access controlled, temporary storage areas for radioactive wastes.

The radioactive waste yard will:

• Enclose the radioactive waste warehouse.

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• Be utilised to store both non-radioactive and radioactive sludges and liquids.

• Enclose the liquid waste unloading component of the WIP.

• Be utilised to store both empty and loaded half height 20’ containers used for WIP-treated waste material.

Access to both the radioactive waste warehouse and yard shall be controlled. For example, vehicle access will be via controlled access gates into the yard. Personnel access shall be via the controlled laboratory access and scanning room.

The requirements of the radioactive waste container yard include:

• Storage for approximately 40 containers or International Standards Organisation (ISO) liquid containers double stacked

• Storage for approximately 12 containers (half height) servicing the WIP facility

• Include covered area for container unloading, inspection and/or packing – area shall 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 (yard) and forklift for inspection, shedding and liquid waste unloading areas.

• Shall allow for secure controlled handover of container from Road Train Vehicle delivery, to the Heavy Vehicle for transport to the waste cell.

• Sumps must be suitable for a:

o 1 in 100 ARI for 72 hours (open yard area).

o 110 % pf a 20’ ISO liquid container.

o 110 % of IBC.

• Pavement Type A (in the yard):

o 80 mm block paving and base course (as nominated below).

o 25 mm bedding sand.

o 200 mm thick cement modified silcrete/laterite (with a minimum soaked California Bearing Ratio [CBR] of 80 %) and approximately 1 % cement by mass.

o 200 mm thick cement stabilised in situ material and approximately 2% cement by mass.

o Compacted subgrade CBR 15 % minimum.

o All block paved areas to be dry swept with bentonite clay.

• Closed circuit television.

• Access card entry or similar access restricting measure.

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• Electric gates (pedestrian and container lifter) – two sides of the yard.

• Suitable yard lighting to provide safe working environment.

• Fire detection system.

• Potable water for safety showers, washdown, flushing.

Details of LLW isolation in waste Cell

Refer to Section 3.4.2.

Drawings

• Refer to drawing number: A3-10 General Arrangement Plan and Elevations in Appendix C for location and layout.

• Refer to drawing number A3-7 in Appendix C for pavement specification.

3.2.6 Liquid waste unloading area

The waste liquid unloading area is to be a bunded slab capable of handling drums, IBC’s and ISO liquid containers. It shall be utilised for both non-radioactive and radioactive liquids and sludges. Following the relevant inspection and waste acceptance procedure (WAP) (Appendix H), the liquid waste container will be placed in the liquid waste unloading slab. The container will be connected to the dispensing pump system to transfer the contents to the WIP.

The requirements for the waste liquid unloading slab include:

• Close in location to the WIP mixer.

• Suit unloading from 20’ ISO liquid containers, IBC’s and drums.

• Nominal flow = 15 m3/hr.

• Maximum flow = 24 m3/hr.

• Fluid is waste sludge at ambient temperature.

• Pump discharge head for selection purposes = 400 kPa.

• Preferred pump = Verderflex VF80.

• Pump motor = minimum 12 kW (vendor to confirm requirements).

• Pump to be powered by a Variable Speed Drive, speed to be manually set by operator.

• Pump suction piping to be manifolded to allow suction from;

o 10 off IBCs (each individually valved).

o 5 off 20’ ISO liquid containers (each individually valved).

o The floor sump.

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o Raw water flushing points(s) at the outer end of suction manifolds(s)

• Construction

o Bunded slab within radiation store / warehouse building.

o Bund should be able to store at least 110 % of the total 20’ ISO liquid container. Sizing or screen to ensure that any possible spray is directed to the bunded or drain area.

o Slab should drain to blind floor sump. Emptied by the Waste Pump.

o Pump suction and discharge piping to be HDPE, PE100, PN8, DN110.

o Piping between suction manifolds(s) valves and IBC’s / 20’ liquid containers to be wire wound suction hose.

o Remote head type magnetic flowmeter to be in a vertical rise section of pipe between waste pump and WIP. Flowmeter head unit and display to be located close to waste pump.

o Digital pressure transmitter to be located immediately downstream of waste pump.

o PLC control – fully integrated as single system with WIP PLC.

• Services

o Washdown water (raw water) for manual washdown and flushing of waste vessels and floors areas.

o Raw water flush (clean in place) form outer end of waste pump suction manifold(s), through the pump, to a point immediately upstream of the WIP suction manifold(s), through the pump, to a point immediately upstream of the WIP mixer and returning back to 20’ ISO liquid container in sump area required.

o Safety shower and eye wash station (potable water).

o Compressed air main (minimum 25 mm ID pipe) from workshop compressor to be available close to waste pump, terminated in a ball valve.

Drawings

Refer to drawing number: A3-11 Radioactive Inspection Facilities Warehouse – Concrete Arrangement in Appendix C for Concrete Arrangement.

3.3 Liquid waste immobilisation

3.3.1 Waste Immobilisation Plant

The WAC allows for liquids and sludges to be accepted at the Facility and stored on the surface in appropriately bunded areas. The wastes will be fully characterised during the Level 1 Basic

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Characterisation to ensure that they can be safely treated in the WIP prior to issuing the Waste Services Contract.

The WIP is to be used to prepare/stabilise received waste sludge/liquid for disposal within the waste cell by mixing the supplied waste with a combination of mined kaolin and/or cement. 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 Facility are described below. Tellus 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 immobilised and placed in the cell. The oily sludge would then be mixed with controlled measures of binding and immobilising materials such as kaolinised granite or cement, to produce a cement-like slurry.

• Non–oily liquid and sludge - Other wastes in either liquid or sludge form would 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 kaolinised 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.

The mix created by the WIP is discharged into a half height 20’ container that is located on a rail mounted trolley under a mixer. Small batches may alternatively be discharged into disposal packages.

The half-height 20’ container will be located on a purpose-built trolley so that the container can be moved on the rail support system to allow the reach stacker to pick up the container and load on an Articulated Dump Truck (ADT) for disposal in the waste cell.

Containers of immobilised waste will be transported to the current waste cell or stored within the Radioactive Yard awaiting disposal. The immobilised waste would either be transferred from the sea container into the waste cell or placed in the cell in disposal packages. The direct placement slurry would be allowed to set in-place in the cell and later covered with kaolinised granite.

The key requirements for the WIP are as follows:

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• 30 tonnes per hour throughput.

• Constituent dosing and measurement will be carried out automatically.

• Cement will be directed from a bulk 100 tonne storage silo. The silo shall be allowed to be pneumatically loaded from a B-triple powder tank.

• Suitable lighting to provide safe working environment.

• Liquid waste pumped from 20’ ISO liquid containers, IBC’s or drums via bunded pipelines.

• Kaolin manually machine loaded into feed bin then conveyed to planetary mixer.

• Operator will have the ability to choose what mix design to use through a touch panel programmable logic controller interface.

• The WIP control system shall record and output (to file type suitable for importation into Microsoft Excel software) all batches run, including constituent weights for all materials by batch.

Drawings

Refer to drawing number: A3-12 General Arrangement Plan and Elevations in Appendix C for General Arrangement.

3.4 Permanent isolation of waste

3.4.1 Cell planning

Sea containers would be stored in a storage yard 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. Placement of wastes in the Cell will be in accordance with the Waste Zoning Guide (Appendix I).

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 co-ordinate.

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.

3.4.2 Waste Cell and mining area

The mining area is to operate in a manner where one Cell is in operation (for permanent isolation of Class IV and Class V waste) at a time. The Cell is to be excavated (including access ramp) and on completion the mining void will become a Cell that is backfilled with waste and then “capped” with previously excavated clay and overburden material.

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Cell excavation and waste backfilling operations are to be undertaken under a pre-inflated air dome cover. The Cell dome cover will have an airlock door for entry and egress and span the width and length of each Cell. Prior to placing waste into the cell, the air dome would be in place covering the entire cell. The purpose of the air dome is 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.

Localised drainage around the Cell is also required to prevent ingress of water into the void during waste operations. The water will be directed to a settlement sump. If required, water within the settlement sump will be pumped out and can be re-used within the WIP process. In addition, an clay cored earth bund / levee will be constructed on the perimeter of the Facility to prevent any surface water ingress into the waste infrastructure area and Cells (refer to Figure 3-1).

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.

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. Chemical waste types would be placed ‘like-with-like’ for safety reasons and for potential future recovery (if identified as potentially valuable). LLW waste materials would be permanently isolated within a concrete cylindrical shaft as depicted in Figure B3 in Appendix B.

Appendix B illustrates how different waste types (chemical and LLW) are intended to be physically separated within the waste Cell i.e. in a ‘like for like manner’.

Spaces 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.

Localised Cell excavated material is expected to be graded, stockpiled and available (for operational optimisation) close to the Cell to aid with backfilling and capping operations. Some excavated material of a grade suitable for stabilisation and solidification of waste may be stored at the WIP (in suitable quantities). Additionally, a stockpile of kaolin will be developed and held at the kaolin stockpile for potential future export and processing requirements.

It is important to note that Cell excavation and waste backfilling operations are not to impact the geological isolation integrity of existing and future Cells. This means there will be no blasting operations for future Cell development.

The requirements of the waste Cell and mining area are as follows:

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• Open cut pit.

• Minimum Cell size of 80 m x 160 m x 30 m.

• The first pit shall be fully excavated before waste emplacement commences.

• Subsequent pits shall be excavated while placement of Class IV and Class V waste materials continue in the adjacent Cell.

• No blasting operations shall be used or considered, silcrete (rock) layers shall be mechanically mined only.

• Equipment - HV, LV, fuel tanker and lighting plant but primarily articulated dump trucks (ADT’s) and wheel loaders

• Vehicle loads – Fully laden ADT (i.e. with fully packaged 20’ container) down ramp; loaded ADT going up ramp.

• Speed – Maximum of 15 km/hr

• Surface – Unsealed.

• Average HV’s per day – 30.

Surface drainage around the waste Cells will be typically graded away from the waste Cells to the catchment / settlement ponds in the south west corner of the mining area. If required, water within the settlement pond will be pumped out and can be re-used within the WIP process.

Drawings

Refer to drawing numbers: A3-13 GA Plan & Elevations showing air dome, A3-14 GA Earth works Plan & Elevations, A3-15 GA Concrete Blocks Plan & Elevations and A3-16 Settlement pond GA Plan & Elevations in Appendix C for General Arrangement and Elevations.

3.4.3 Capping Cells

After a low permeability seal is installed, more compacted backfill and a clay domed cap would be situated on the top of the Cell, to shed rainfall. Figure B3 in Appendix B illustrates how wastes would be contained within the Cells.

Waste cells will be closed progressively, with one cell being capped and closed while the next cell is being developed. This process, along with the closure and decommissioning of the waste infrastructure, is detailed in the Waste Facility Decommissioning and Closure Plan required by MS 1078.

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.

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3.5 Storm water catchment and retention

3.5.1 General

Water from external catchments (i.e. from rain events) is to be diverted around the facility in order to prevent ingress through the facility and possible contamination. Surface water drainage requirements are as follows:

• 1:100 ARI over 72 hours.

• Construction and operation:

o Earthen drains / rock stabilisation / culverts as required.

o Cut off drains as required preventing flooding of the site.

o Drainage isolation points as required.

3.5.2 Yard capture pond

The yard capture pond will be constructed to collect treated water from the washing facilities and stormwater from the container storage area. The yard capture pond will allow for the retaining, monitoring and handling of any contaminated water and will be joined with the service water pond.

The water will be used to condition backfill material in Class IV and Class V waste placement operations.

The requirements of the yard capture pond are as follows:

• High level overflow or balance level to the service water / retention pond.

• Capacity to handle 100 year ARI for 72 hours from allocated capture area.

• Excavated/formed HDPE lined pond.

• Stock fence perimeter.

• Life buoys and egress ropes/mats inside pond.

• Equipment:

o Electric pump and standpipe shared with the service water pond.

o Minimum 100 l/s.

o Suitable height for 30,000 litre tank mounted on a 6x6 ADT.

o Air key/remote operated.

• Feeds:

o Treated washdown water and HV/LV mobile plant workshop sump water.

o Rain infiltration/storm water from container yard.

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Drawings

Refer to drawing numbers: A3-17 Service Water and Yard Capture Ponds Plan and A3-18 Service Water and Yard Capture Ponds Sections in Appendix C for General Arrangement and Sections.

3.5.3 Service water pond

The service pond is to be sized to suit both mining operations and processing/potable water production operations, excluding storage of any brine water.

The requirements of the service water pond are as follows:

• Excavated / formed HDPE lined pond.

• Stock fence for perimeter.

• Life buoys and egress ropes/mats inside pond.

• Equipment:

o Electric pump and standpipe shared with the yard capture pond.

o Minimum 100 l/s.

o Suitable height for 30,000 litre tank mounted on a 6x6 ADT.

o Air key / remote operated.

o Level control for automatic raw water supplement.

• Feed - Raw water from bore transfer tank.

• Consumption requirements – Waste backfill and dust suppression in mining operations.

Drawings

Refer to drawing numbers: A3-19 General Arrangement South Catchment Pond, A3-20 General Arrangement West Catchment Pond and A3-17 Service Water and Yard Capture Ponds in Appendix C for General Arrangement.

3.5.4 Brine pond

The construction turkeys’ nest shall be utilised in the future as a brine pond. The pond shall be lined and fenced to prevent livestock entering. The water will be consumed in the backfilling and mining operations within the waste Cell.

During construction, the pond shall be manually filled by the contractor from the raw water pipeline. Once the works are complete, the pond shall have water supplied via the brine output from the water treatment facility while retaining the original raw water supply infrastructure.

The requirements of the brine pond are as follows:

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• Excavated / formed HDPE lined pond.

• Stock fence for perimeter.

• Life buoys and egress ropes/mats inside the pond.

• Equipment:

o Electric pump and standpipe.

o Minimum 100 l/s.

o Suitable height for a 30,000 litre tank mounted on a 6x6 ADT.

o Air key/remote operated.

o Level control for automatic raw water supplement.

• Feeds:

o Waste water from the RO plant

Drawings

Refer to drawing number A3-21 Earthworks Arrangement – Brine in Appendix C for Earthwork Arrangement.

3.6 Raw water supply and treatment

3.6.1 Raw water supply

Raw water is to be supplied from a bore to be installed northwest of Carina Mine Pit. The raw water will be required to be drawn from a new bore to be constructed North West of the disused Carina Mine Pit.

The project requires a robust method of transferring the raw water from the Carina Mine Pit to support the site. The minimum requirements for the water transfer system include:

• Power supply:

o Diesel power

o Bulk diesel storage to be supplied to support consumption; fuel supply should last a minimum of one week

• Equipment:

o Duty / standby transfer pumps with two interchangeable different flow setpoints:

o Telemetry for remote control and monitoring.

o Staging tank shall provide at least one hour of storage capacity.

o The pipeline from the bore to the site shall be buried below any potential radiant heat zone caused by a bush fire and include all required air valves and scour points.

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o The pipe shall be a minimum of 160 mm OD.

Drawings

Refer to drawing number A3-22 General Arrangement 12388-L-029, A3-23 Brine pond 12388-L-030, A3-24 Mine NPI water facilities 12388-L-031, A3-25 Spray filed arrangement 12388-L-032, and A3-26 Bore filed headworks arrangement 12388-L-033 in Appendix C for Arrangements.

3.6.2 Water treatment facility

The potable water facility shall treat the incoming raw water from the bore and allow for the water to be reticulated to the points of use at the facility and the village.

The requirements of the water treatment facility:

• Potable water drinking guidelines and applicable Australian and New Zealand Environment Conservation Council and Australian standards.

• Single system for potable water production to cater for the Facility and Village usage.

• Waste to discharge to the brine pond.

• Potable, fresh water and raw water storage shall cater for fire reserve and residence time. Fresh water to be used for fire water and supply for washdown.

• Combined potable and raw water storage shall provide at least three days of uninterruptible potable supply.

• Potable water facility shall control the operation of the raw water supply to the Facility.

• Construction:

o Turnkey modular package.

o Pre-filtration unit shall be employed to minimise the requirement for the fouling and consequential replacement of any pre-filters / treatment filters.

• Equipment:

o Electric pump (10 l/s capacity) connected directly to fresh water storage tank.

o 100 mm lay flat lose connection.

Drawings

Refer to drawing number A3-24 in Appendix C.

3.7 Exclusions to the Premises • The Access Road and ground water supply from Carina Iron Ore Mine are not prescribed

activities/infrastructure and are therefore not subject to Part V approvals.

• A Critical Containment Infrastructure Report, as described in DWER’s Guideline: Industry Regulation Guide to Licensing, does not apply to this Application because the Facility is not

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an engineered landfill. As described in MS 1078, the Facility is a near-surface geological repository and does not rely on engineered barriers.

• Instead, the Facility can rely on the passive safety of the geology (in the form of weathered kaolinised granite). The environmental hazards and risks of the near-surface geological waste repository at Sandy Ridge has been considered and approved by MS 1078 and EPBC2015/7478.

• Raw water supply was described in the Sandy Ridge Mining Works Approval No.1 W6243 and therefore, does not form part of this Application.

• Waste water treatment plant and spray field was described in the Sandy Ridge Mining Works Approval No.1 W6243 and therefore, does not form part of this Application.

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4 LEGISLATIVE CONTEXT

4.1 Summary of approvals and tenure The Australian Government granted approval for the Facility in January 2019 (EPBC2015/7478) under Section 133 of the Environmental Protection Biodiversity Conservation Act 1999.

Table 4-1 summarises approvals that have been achieved and are relevant to the Facility.

4.2 Part IV of the EP Act

4.2.1 Ministerial Statement 1078

MS 1078 applies to the Premises. Several environmental and compliance Conditions apply to the Facility and are summarised below:

• Condition 4-1 requires Tellus to maintain a Compliance Assessment Plan.

• Condition 4-6 requires Tellus to submit a Compliance Assessment Report.

• Condition 8-2 requires Tellus to engage and independent waste expert to undertake an annual audit of the waste disposal operations.

• Condition 9-2 requires Tellus to prepare a Leachate Monitoring and Management Plan prior to the commencement of waste receival.

• Condition 10-5 requires Tellus to prepare a construction Flora and Vegetation Management Plan.

• Condition 11-2 requires Tellus to prepare a construction Environmental Management Plan to ensure impacts to terrestrial fauna are minimised.

• Condition 12-1 requires Tellus to prepare a Waste Facility Decommissioning and Closure Plan.

4.3 Contaminated sites The Premises is not reported as a Contaminated Site. Once Class IV and/or Class V has been emplaced in the waste cell, it is expected the site will be registered on DWER’s contaminated sites register. DWER will decide on the level of remediation required (if any) at the appropriate time.

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Table 4-1 Relevant approvals and tenure achieved for the Facility to date

Legislation Approval reference Subsidiary Approval Part 9 of the Environmental Protection Biodiversity Conservation Act 1999

2015/7478 Tellus Holdings Ltd Approval to construct and operate an open-cut kaolin clay mine, arid near-surface geological waste repository within the mine voids, and associated infrastructure for the storage, treatment, recovery and permanent isolation (disposal) of hazardous and intractable wastes (including low level radioactive waste

Part IV of the EP Act MS 1078 Tellus Holdings Ltd Approval to implement proposal to construct and operate a dual open cut kaolin clay mine and a near-surface geological waste repository accepting Class IV and Class V waste.

Section 45C under Part IV of the EP Act

MS 1078 Tellus Holdings Ltd Approval to increase development envelope and relocate groundwater bore location.

Mining Act 197E Registration ID 75521

Tellus Holdings Ltd Approval for Mining Proposal with a Mine Closure Plan on G 16/21, L 15/361, L 15/362, L 16/119, L 16/121 and M 16/54.

Planning and Development Act 2005

DAP/17/01318 Tellus Holdings Ltd Accept DAP/17/01318 is appropriate for consideration as a “Waste Disposal Facility” land use and compatible with the objectives of the zoning table in accordance with Local Planning Scheme No 5 of the Shire of Coolgardie. Approve DAP Application reference DAP/17/01318 and accompanying plans in accordance with Clause 68 of the Planning and Development (Local Planning Schemes) Regulations 2015 and the provisions of the Shire of Coolgardie Local Planning Scheme No.5

Dangerous Goods Safety Act 2004

DGSO22452 Tellus Holdings Ltd A licence authorising the holder to store dangerous goods within WA in accordance with the application and any conditions.

Land Administration Act 1997

Under assessment Tellus Holdings Ltd Grant of Crown Lease is anticipated in November 2019.

Radiation Safety Act 1975 Under assessment Tellus Holdings Ltd Site Registration and licence to accept and dispose low level radioactive waste.

4.4 Part V of the EP Act To implement the authority granted under MS 1078, this Application is seeking a Works Approval for the construction of the Facility under prescribed premises Categories 65 and 66 being for Class IV and Class V waste disposal. The phasing of approvals under Part V is summarised in Table 1-1.

A separate application for works approval Categories 61 and 61A (Solid and Liquid and Solid waste facility, Tellus 2019) was submitted to DWER on 26 September 2019 (WAA2). That application

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sought approval to construct a small secure facility in which to store low-risk wastes during the construction of the full Sandy Ridge Facility.

The current Application (WAA3) seeks to broaden the scope of infrastructure associated with Categories 61 and 61A to store, treat and manage Class IV and Class V wastes at the Facility.

4.4.1 Application regulations, standards and guidelines

In preparing this Application, Tellus has considered the following guidance statements within the WA legislative framework under the EP Act and EP Regulations. They are:

• Guidance Statement: Regulatory Principles (July 2015)

• Guidance Statement: Setting Conditions (October 2015)

• Guidance Statement: Risk Assessments (February 2017)

• Guidance Statement: Environmental Siting (November 2016)

4.4.2 Reporting of incidents

Under Section 72 of the EP Act, Tellus will report all discharges of waste that have caused or are likely to cause pollution, material harm or serious environmental harm.

4.4.3 Offences and defences

The EP Act and its regulations set out several offences including:

• Offence of emitting an Unreasonable Emission from any Premises under s.49.

• Offence of causing Pollution under s.49.

• Offence of dumping Waste under s.49A.

• Offence of discharging Waste in circumstances likely to cause Pollution under s.50.

• Offence of causing Serious Environmental Harm (s.50A) or Material Environmental Harm (s.50B).

• Offence of causing Emissions which do not comply with prescribed standards (s.51).

• Offences relating to Emissions or Discharges under regulations prescribed under the EP Act, including materials discharged under the Environmental Protection (Unauthorised Discharges) Regulations 2004 (WA).

• Offences relating to noise under the Environmental Protection (Noise) Regulations 1997 (WA).

Under Section 53 of the EP Act it is an offence for a holder of a Works Approval if emissions are caused, or altered, from a Prescribed Premises unless done in accordance with a Works Approval, Licence or the requirements of a closure notice or an environmental protection notice. Therefore,

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this Application seeks the approval to lawfully emit and discharge contaminants within the Facility within limits and conditions set by DWER.

4.5 Radiation Safety Act 1975 This Application (see Section 3) provides high level information about the management, handling and treatment of low level radioactive waste (LLW) for context only. The management and disposal of NORM / LLW is regulated under the RS Act by way of a site Registration. The Registration application to accept, store, handle and permanently isolate LLW is supported by a Radiation Management Plan (RMP) and a Facility Operational Safety Case.

Both documents detail the potential environmental and human health hazards associated with that prescribed activity and, describe control measures to avoid and reduce radiation exposure. The WA Radiological Council, supported by the Radiation Health Unit, is the responsible decision-making authority for the RMP and Operational Safety Case and Site Registration to accept, manage and permanently isolate LLW at Sandy Ridge Facility.

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5 LOCATION AND SITING

5.1 Siting and context The Facility is located approximately 75 kilometres (km) north east of Koolyanobbing (Figure 2-1).

5.2 Sensitive premises Based on the current use and zoning of the site, and publicly available information for off-site areas, the potential sensitive premises include:

• Off-site premises; and

• On-site premises.

5.2.1 Off-site premises

Sensitive off-site premises include hospitals, schools, day-care facilities and, elderly housing. The nearest sensitive premises matching this criterion are a minimum of 75 km from the Facility (Koolyanobbing shown in Figure 2-1). Due to the remoteness of the Facility, Tellus has identified other off-site premises which have been adopted for hazard assessment applicable to this Application. The distances to these premises are detailed in Table 5-1.

Table 5-1 Off-site premises receptors and distance from site activity boundary

Sensitive off-site premises Distance from prescribed activity Mount Walton Intractable Waste Disposal Facility (IWDF)

Approximately 7 km to the east of the Facility (Figure 5-1).

Carina Mine Camp Approximately 50 km to the south (Figure 5-1). Ex-Jaurdi pastoral station homestead Approximately 50 km to the south (Figure 5-1).

5.2.2 On-site premises

Sensitive on-site premises adopted for this Application are set within a 5 km radius of the site activity boundary. The nearest sensitive on-site premises matching this criterion are in Figure 5-1 and listed in Table 5-2.

Table 5-2 On-site premises receptors and distance from site activity boundary

Sensitive on-site premises Distance from prescribed activity Mine Infrastructure Area including administration and warehouse buildings

Between 0 and 100 m

Waste Cell 0 m Facility accommodation village Approximately 2 km to the south west of the Facility (Figure

5-1).

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5.3 Sensitive receptors and specified ecosystems Sensitive receptors and specified ecosystems4 are areas of high conservation value and special significance that may be impacted as a result of prescribed activities resulting in emissions and discharges from the Facility. Sensitive receptors and specified ecosystems pertinent to this Application are listed in Table 5-3. The distances to sensitive receptors and specified ecosystems are shown in Figure 5-1.

Table 5-3 Distance to sensitive receptors and specified ecosystems from the site activity boundary.

Sensitive receptors or ecosystems Distance from prescribed activity Human health On-site workers On-site visitors to the Facility Environmental Mount Manning Range Nature Reserve Approximately 50 km to the north west of the Facility (Figure 5-1). Mount Manning-Helena and Aurora Ranges Conservation Park

Approximately 60 km to the north west of the Facility (Figure 5-1).

Clear and Muddy Lakes Nature Reserve

Approximately 60 km to the east of the Facility (Figure 5-1).

Rowles Lagoon Conservation Park Approximately 60 km to the east of the Facility (Figure 5-1). Wallaroo Rock Conservation Park Approximately 60 km to the south-east of the Facility Figure 5-1). Deborah Lake Approximately 75 km to the west of the Facility (Figure 5-1). Biological component - priority flora Several Priority species of Lepidosperma spp Calytrix sp within the

Facility Development Envelope.

5.4 Groundwater and water sources There is no developed aquifer within the Facility’s development envelope. Where groundwater has been encountered, it occurs in natural traps in the deepest parts of the basement surface at great distances from the proposed site activity boundary.

Extensive desktop and field research undertaken between 2014 and 2019 indicates there is not any surface recharge of groundwater in the survey area combined with a significant horizon of low permeability in the kaolinite and saprock horizons (Geo9, 2019). The nearest distance to other groundwater and/or water sources is listed in Table 5-4.

There are no natural surface water features within 50 to 75 km of the site activity boundary (refer to Figure 5-1). Once constructed, the Facility will create artificial stormwater retention ponds to drain the mine infrastructure and administration buildings (Figure 5-2).

4 Specified ecosystems are identified in Appendix 1 of DWER’s Environmental Siting guidance note. The only specified ecosystem that applies to the Facility is ecological communities Priority species 1-5.

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Table 5-4 Distances to regional groundwater and other water sources from the site activity boundary

Groundwater and water sources Distance from prescribed activity Environmental value Carina borefield Approximately 15 km to the south west of the

Facility. Hypersaline groundwater supply

Boorabbin paleochannel Approximately 30 km to the east of the Facility.

Hypersaline groundwater supply

Walleroo paleochannel Approximately 30 km to the east of the Facility.

Hypersaline groundwater supply

Lake Deborah Approximately 75 km to the south-east of the Facility.

Salt Lake

Perth to Kalgoorlie water pipeline Approximately 110 km to the south of the Facility.

Potable water supply

5.5 Conceptual site model An Operational Site Conceptual Model (CSM) shown in Figure 5-2 was prepared for this Application to illustrate how the natural and built environments at the Facility interact.

More specifically, it was developed as a visual representation of the biological, physical and chemical processes that explain how contaminants move from sources (i.e. the WIP or waste Cell) through local environmental media (i.e. soil, water or air) to environmental receptors or, to off-site or on-site premises such as humans, plants or animals.

Tellus propose to use the CSM an iterative process of characterising and / or recording site contamination at the Facility based on available information and data.

The CSM must be viewed in conjunction with Figure 5-1 to appreciate the scale of the Facility, particularly with respect to distances of off-site premises from the site activity boundary. Figure 5-2 shows:

• Local topography, geology, hydrogeology (or lack thereof), surface drainage and the potential for underground contaminant pathways.

• Current land use for the site (unallocated Crown Land).

• The location, extent and nature of proposed infrastructure.

• Source contaminant areas.

Please note – a Waste Facility Decommissioning Closure Plan is under preparation for the Facility. It will be lodged to the CEO of DWER for Approval in October 2019.

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Koolyanobbing

Carina Iron Ore Mine Camp

Mt Walton Intractable Waste Disposal Facility

Carina Iron Ore Mine Pit

Ex-Jaurdi Pastoral Station Homestead

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200000

240000

240000

280000

280000

320000

320000

6600

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Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either patially or temporally accurate or fit for a particular use.Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied.

± SANDY RIDGE FACILITYCat 65 & 66 WORKS APPROVAL

Sensitive Premises and Receptorsin the vicinity of Sandy Ridge

Legend

!( Locality

!( Sensitive premises

Prescribed Premises

Development Envelope

Specified ecosystems: PotentiallyOccuring Priority EcologicalCommunities

Local Government Authority Boundaries

DBCA lands

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50 km

IWDF access road

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Service Layer Credits: Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO,USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI,Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS User CommunitySource: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS,AeroGRID, IGN, and the GIS User Community

IWDF Access Road

Figure 5-1

PERTH-KALGOORLIE RAILWAY

Clear and Muddy Lakes Nature ReserveRowles Lagoon Conservation Park

Mount Manning- Helena and AuroraRanges Conservation Park

Mount Manning Range Nature Reserve

Sh

ire

of

Co

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ard

ie

Shire of Menzies

Version: ADate: 3/10/2019

Sandy Ridge Access Road

Coordinate System:GDA 94 MGA Zone 51

Data in this map is sourced from: © Commonwealth of Australia (Geoscience Australia) 2018 and © State of Western Australia (Department of Mines, Industry Regulation and Safety) 2018.

Ex-Jaurdi Pastoral Lease

Ex-Jaurdi Pastoral Lease

Wallaroo Rock Conservation Park

SP-ID:GL00-2017072102-722

Facility Mine Infrastructure Area

Facility Accommodation Camp

25 km

50 km

Koolynanobbing

SouthernCross

Koora Retreat

Coolgardie

KalgoorlieCarinaMine Camp

Sandy RidgeFacility

Sh

ire

of

Yilg

arn

Mount Manning Range Nature Reserve

Mount Manning- Helena and AuroraRanges Conservation Park

Drawn by: RM

Lake Deborah

Lake Giles(northern Yerilgee Hills) BIF

Hunt Range BIF

Finnerty Range / Mt Dimer / Yendilberin Hills BIF

Finnerty Range / Mt Dimer / Yendilberin Hills BIF

Ex-Jaurdi

Carina Iron Ore Mine Pit

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High evaporation

Arid zone sparsely vegetated

MonitoringBore

SRMB159

MonitoringBore SRMB161

MonitoringBore

SRMB162

Granite (3500m thick)Kaolin (weathered Granite) (15 - 45m thick)Silcrete (3 - 7m thick)Yellow clayey sands and laterite gravel (2m thick)

SANDY RIDGE FACILITY

Low rainfall

No local or regional aquifer system

Waste CellClass IV/ Class V

OPERATIONAL CONCEPTUAL SITE MODEL

WaterTreatment

Facility

Warehouses & Administration

Container YardClass IV / Class V

StormwaterPonds

Figure 5-2

NOT TO SCALE

SecurityFence

30 m20 m10 m

SecurityFence

North-West South-East

Approved: RP

Date: 02.10.2019

Drawn: RM

WIP

HumanReceptor

40 m50 m

250 m

Air Dome

Class IV / Class V Waste Permanent Isolation

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6 MODELLING AND MONITORING DATA

6.1.1 Modelling

Extensive modelling for the Facility was undertaken during the Part IV assessment. This included landform evolution modelling, permeability, hydrology, hydrogeology, infiltration and seepage modelling. Further information can be found in the Sandy Ridge Public Environmental Review (PER) (Tellus, 2016). In April, May and September 2019, further field research and desktop modelling was completed for soils, groundwater and background radiation (respectively). The results of that work are summarised in Section 6.1.2.

6.1.2 Monitoring and environmental baseline data

The information presented in this section compliments and further supports baseline environmental data prepared for the PER.

Geology

Detailed descriptions of site geology are contained within the Facility’s PER (2016) and in Sandy Ridge WAA 2. A summary of ground conditions is provided in Table 6-1.

Table 6-1 Summary of soil and ground conditions

Lithology Description Topsoil (sand) Yellow-brown, sandy topsoil, with some silt and roots, encountered at all test

locations, with the exception of IA-TP74, IA-TP77 and IA-TP79, varying between 0.1 m and 0.2 m in thickness

Slightly silty sand Medium dense becoming dense with depth, yellow-brown slightly silty sand, underlying the topsoil and from surface at IA-TP74, IA-TP77 and IA-TP79, to depths of between 0.3 m (IA-TP74) and at least 2.0 m (IA-TP77 termination depth). Loose sand was recorded at IA-TP78, between 0.15 m and 0.45 m. Roots varying between 5 mm and 40 mm in diameter were also recorded at IA-TP76, IA-TP78 and IA-TP79, to depths of between 0.3 m and 1.0 m.

Slightly silty sand Medium dense becoming dense with depth, yellow-brown slightly silty sand, underlying the topsoil and from surface at IA-TP74, IA-TP77 and IA-TP79, to depths of between 0.3 m (IA-TP74) and at least 2.0 m (IA-TP77 termination depth). Loose sand was recorded at IA-TP78, between 0.15 m and 0.45 m. Roots varying between 5 mm and 40 mm in diameter were also recorded at IA-TP76, IA-TP78 and IA-TP79, to depths of between 0.3 m and 1.0 m

Slightly clayey sand, clayey sand and sandy clay

Dense and hard, light brown and light grey-white, slightly clayey sand, clayey sand and sandy clay, with some gravel, below the above slightly silty sand at IA-TP72 and the sandy gravel at IA-TP74 and IA-TP77, to a maximum test pit termination depth of 2.0 m

Silcrete High strength, yellow brown and brown silcrete, below the above clayey sand at IA-TP74, to a test pit termination depth of 1.3 m. Test pit refusal was experienced into this material when using a 14 tonne excavator, equipped with a 350 mm wide toothed bucket. (Figure 1-5).

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Groundwater The Facility does not occur within a groundwater area proclaimed under the Rights in Water and Irrigation Act 1914. Monitoring for groundwater within the development envelope has been undertaken since 2015. Where groundwater has been encountered it occurs in natural traps in the deepest parts of the basement surface of the weathered granite (kaolin) and unweathered granite.

Figure 6-1 shows historic drill holes and where water was encountered are marked in blue. It also shows previously interpreted basement contours indicating the strong correlation between depth to basement and groundwater occurrence. It confirms the interception of groundwater occurs outside of the proposed mine infrastructure area and proposed Class IV and Class V waste cells.

Geo9 have prepared a draft electroseismic and electrotelluric survey and mapping report for the Facility. The aim of the project is to incorporate the seismoelectric and electrotelluric survey results into the existing geological models from prior drilling programs and the geophysical and geological information.

A survey strategy of three traverses across the Sandy Ridge site was designed to investigate the potential location of any groundwater on the site and identify any potential movement pathways away to the surrounding area. In total, 171 survey points were recorded. Point spacing was 50 m along each of the survey traverses. Survey data has been processed to a depth of 100m.

• Survey line 1 extends for 1500 m and consists of 31 points.

• Survey line 2 extends for 2800 m and consists of 57 points, parallel to line 1, located 850m to the south.

• Survey line 3 extends for 4 km, perpendicular to the first 2 survey lines. Line 3 was located to pass through the centre of the area where water has been encountered at depth during the prior drilling programs.

Survey data was then built into a 3D model alongside the previous drilling data to correlate between the two data sets. Drilling and survey data was initially used to interpret the likely basement depth across the survey lines which was then incorporated into the hydrogeological interpretation.

Data traces for Points 117-136 along Line 3 are shown in Figure 6-4. The seismoelectric data shows the relative values of potential hydraulic conductivity. The thickness of the drill tube modulates to give an indication of relative values of permeability (i.e. potential hydraulic conductivity). The wider the data trace the more permeable the subsurface at the point indicated. The data traces are coloured to display the same electroseismic hydraulic conductivity tomography (ESKT) data to aid in distinguishing the data.

The ESKT colours are on a pseudocolour spectrum with the lowest values in blue ranging through to the highest values in red. The same logic applies to Figures Figure 6-6 to Figure 6-8.

ESKT is an indicative measure of hydraulic conductivity (K in Darcy’s Law), or the ease at which a fluid, water in this case, can flow through a porous medium. The ESKT data measures potential

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hydraulic conductivity as a normalised percentage relative to the highest value found across the site, the maximum being 100%.

Figure 6-5 shows a 3D view of the entire model presenting only the ESKT data. Data tubes modulate and are pseudo-coloured to represent the modelled ESKT values. Areas of highest relative ESKT are easily identifiable as wider red/orange tube sections. There are very few areas of high ESKT observed across the site and where they are, they appear isolated with no real horizontal connectivity to suggest any likelihood of potential aquifer development.

A summary of results for the three survey lines is provided below.

Survey line 1: ESKT values are low across this northern survey line and there is little evidence of any groundwater potential in this part of the site. ESKT results are presented in Figure 6-6.

Survey line 2: Is the southernmost of the two northeast-southwest and runs from Point 32 to Point 88 cutting across the middle of the main drilling program for the Facility. ESKT results are presented in Figure 6-7. The area between Points 39 and 44 has the highest ESKT response in the survey area and is potentially a wet area along this survey line. The ESKT response again is seen at, and below the bottom of a basin-like structure in the basement topography and extends to approximately 90m depth, again suggestive of a vertical fracture system. This is the most significant area of elevated ESKT seen on the site but occurs well outside the limits of the mine footprint.

Survey line 3: Survey Line 3 confirms what the 2 southwest – northeast survey lines indicated. On the higher ground north of Survey Line 1 (which crosses Line 3 at Point 138) the modelled relative hydraulic conductivity is very low with little evidence of any groundwater potential in this area (refer to Figure 6-8).

The electrotelluric interface results show very good correlation with previous site drilling results and provide a valuable insight into the subsurface geology and hydrogeology of the site.

There does not appear to be any surface recharge of groundwater in the survey area with a significant horizon of low permeability indicated in the kaolinite and saprock horizons. High ESKT response in the surface overburden is not seen extending through the kaolinite horizon at any point.

The granite basement across the site is irregular in nature with several subsurface ridges and basins evident. Where groundwater has been encountered in historical drilling campaigns, it occurs in natural traps in the deepest parts of the basement surface. There does not appear to be any significant ESKT response developed horizontally in the survey orientations, other than within the confines of the basement lows which appear to act as groundwater traps.

The areas of elevated ESKT and potential groundwater occur along each survey line in and beneath these modelled basement lows. In most of these basement lows, the ESKT response is seen extending to depth directly beneath the areas of elevated ESKT and may be indicative of near-vertical faulting and/or fracturing.

The areas of highest potential permeability appear well below the kaolinite horizons in the solid granite basement. Relative permeability appears in mostly vertical structures, possibly where fracturing has been preserved in the hard rock.

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Surface water

The Facility does not occur within a surface water area and irrigation districts proclaimed under the Rights in Water and Irrigation Act 1914.

A desktop review of GEODATA waterbodies (Geoscience Australia, 2019) and multiple field inspections confirmed there are no natural or artificial surface water bodies within the approved Facility development envelope.

Soil and permeability

A search of DWER’s contaminated sites database (2015 and 2019) confirmed the site holds no records of contaminated soils.

Baseline soil sampling over the mining lease area (Figure 6-2) occurred in 2015 and more recently in April and September 2019. Soils were sampled for metals, asbestos and radionuclides. Appendix F includes a summary report on field activities and sampling undertaken in (SoilWater Group, 2019), a spreadsheet with the metals results compared to WA Health Indicator Level (HIL) guidelines. The results indicate that baseline / background levels are below HIL guideline values for metals5. Radon 226 and Caesium 137 recorded elevated background levels against detection limits.

Permeability modelling and testing was undertaken during the PER. The results are explained in Sandy Ridge Works Approval Application Number 2. In summary, plausible permeability values of between 1 x 10-6 m/s (0.08 m/day) and 1 x 10-5 m/s (0.8 m/day), are suggested for the slightly silty sand, sandy gravel and weakly cemented sand. The underlying clayey sand, sandy clay and silcrete should be assumed as impervious for drainage purposes, with presumptive permeability values of less than 1 x 10-7 m/s (0.008 m/day).

Permeability testing was conducted on drill hole samples collected at Sandy Ridge and tested in a NATA approved laboratory. An extract of the permeability results for silcrete taken from bore holes onsite indicated a silcrete permeability of 4.944 x10-8m/s and 5.012 x 10-8 m/s

5 Please note, conservative levels were included in the HIL for methyl mercury rather than total mercury, and chromium VI rather than total chromium.

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Coordinate System:GDA 1994 MGA Zone 51

SANDY RIDGE FACILITYCAT 65 & 66 WORKS APPROVAL

Groundwater Bores andGroundwater Levels

Figure 6-1

±TSR0389_WWAv3_Gwater_Cells.mxd

Legend5m Contours

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Prescribed Premises Boundary

! Drillhole location

!( Monitoring Bore location

Sandy Ridge FacilityPrescribed Premises Boundary

Version: CDate: 2/10/2019

SP-ID:GL00-2017072102-719Data in this map is sourced from © State of Western Australia (Department of Mines, Industry, Regulation and Safety) 2018.

Drawn by: RM

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Depth to Granite/WaterContour (m)

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SRMB159DTW: DryEOH (m): 28.00

SRMB160DTW: DryEOH (m): 35.50

SRMB161DTW: DryEOH (m): 22.00

SRMB162DTW: 42.10EOH (m): 43.00Water Column (m): 0.90

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Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use.Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied.

Coordinate System:GDA 1994 MGA Zone 51

SANDY RIDGE FACILITYCat 65 & 66 WORKS APPROVAL

Soil Sampling LocationsFigure 6-2

±TSR0386_WWAv3_SoilSampling.mxd

Legend! Soil Sampling Location

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Proposed infrastructure footprint

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Prescribed Premises Boundary

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Version: ADate: 3/10/2019

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Tellus Holdings Ltd makes every effort to ensure this map is free of errors but does not warrant the map or its features are either spatially or temporally accurate or fit for a particular use.Tellus Holdings Ltd provides this map without any warranty of any kind whatsoever, either expressed or implied.

Coordinate System:GDA 1994 MGA Zone 51

SANDY RIDGE FACILITYCat 65 & 66 WORKS APPROVAL

Electroseismic and ElectrotelluricAquifer Mapping Survey

Figure 6-3

±TSR0392_WWAv3_ElectroseismicSurvey.mxd

LegendElectroseismic/Electrotelluricsurvey line

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5m Contours

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Version: ADate: 3/10/2019

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SP-ID:GL00-2017072102-723Data in this map is sourced from © State of Western Australia (Department of Mines, Industry, Regulation and Safety) 2018.

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Figure 6-4 Data trace points for survey line 3 showing relative values of potential hydraulic conductivity

Figure 6-5 3D model showing ESKT vales across the Sandy Ridge site looking north

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Figure 6-6 ESKT result for survey line 1 at Sandy Ridge and interpreted basement level indicated in dark blue

Figure 6-7 ESKT result for survey line 3 at Sandy Ridge

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Figure 6-8 ESKT result for survey line 3 at Sandy Ridge

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7 RISK ASSESSMENT

This section identifies the hazards and risk associated with potential emissions and discharges and the proposed environmental monitoring at the Facility to verify the robustness of infrastructure design and operational controls.

A detailed risk assessment for determining the likelihood and consequence of the prescribed activities associated with storing solid, liquid and LLW waste was included in Appendix 3 of Sandy Ridge Works Approval Application No.2 (document reference SR00-299429885-22573). As the management of LLW is regulated under the RS Act, the risk assessment is not addressed here.

7.1 Determination of emission, pathway and receptor

7.1.1 Overview

In undertaking its risk assessment for this application, Tellus has given consideration to DWER’s guidance statement Environmental Siting (November, 2016) and Risk Assessments – Part V, Division 3, Environmental Protection Act 1986 (February 2017).

Tellus has identified potential emissions pathways and potential receptors to establish whether there is a hazard or Risk Event which requires detailed risk assessment. To establish a Risk Event there must be an emission or a receptor which may be exposed to that emission through an identified actual or likely pathway, and a potential adverse effect to the receptor from exposure to that emission.

Where there is no actual or likely pathway and/or no receptor, the emission will be screened out and will not be considered as a Risk Event.

In addition, where an emission has an actual or likely pathway and a receptor which may be adversely impacted, but that emission is regulated through other mechanisms such as Part IV of the EP Act, that emission will not be risk assessed further and will be screened out through the risk assessment process. Table 7-4 presents risk events associated with construction activities.

7.1.2 Emissions and pollutant sources

The Public Environmental Review (Tellus 2016) for the Facility identified several potential emissions and sources across the site. The following have been included in this Application as they are considered the most likely sources of emissions and pollutants:

• Potential leakage from stored wastes.

• Potential leakage from the WIP.

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7.1.3 Pathways

The potential pathways for the migration of the impacts in both soil and groundwater detected at the site include:

• Vertical seepage originating from surface spills and leaks, and from primary sources such as tanks, lines and pumps, through the surface material into the underlying natural material (red and yellow sands).

• Vertical leaching of stored liquid wastes.

• Horizontal leaching of isolated wastes.

• Dermal contact and incidental ingestion with hydrocarbons or NORM in shallow soil.

• Lateral migration of surface discharge to offsite native vegetation.

• Migration of vapours from hazardous wastes stored on site.

• Migration of vapours by volatilisation from contaminated surface water contained within the stormwater retention ponds.

7.1.4 Receptors

Refer to Section 5.2 and 5.3.

7.1.5 Exposure pathway assessment

For potential exposure to be present, a source-pathway-receptor (SPR) linkage must be identified. Once identified, the likelihood of this SPR linkage causing an unacceptable risk to human health or the environment has been quantified through a risk assessment (i.e. the PER).

A qualitative assessment of SPR linkages is presented in the following tables and a visual representation of the preliminary CSM is shown in Figure 5-2.

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7.1 Consequence likelihood and treatment of risk events Risk ratings were determined for risk events in accordance with Risk Assessments – Part V, Division 3, Environmental Protection Act 1986 (February 2017) as shown in the risk rating matrix in Table 7-1

Table 7-1 Risk rating matrix

Consequence

Like

lihoo

d

Slight Minor Moderate Major Severe

Almost Certain Medium High High Extreme Extreme

Likely Medium Medium High High Extreme

Possible Low Medium Medium High High

Unlikely Low Low Medium Medium High

Rare Low Low Low Medium High

Tellus undertook an assessment of the consequence and likelihood of the Risk Events in accordance with Table 7-2.

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Table 7-2 Risk criteria table

Likelihood Consequence The following criteria has been used to determine the likelihood of the Risk Event occurring

The following criteria has been used to determine the consequences of a Risk Event occurring Environment Public health 6 and amenity (such as air and

water quality, noise and odour). Almost certain

The risk event is expected to occur in most circumstances.

Severe • onsite impacts: catastrophic.

• offsite impacts local scale: high level or above.

• offsite impacts wider scale: mid-level or above.

• Mid to long-term or permanent impact to an area of high conservation value or special significance 7.

• Specific Consequence Criteria (for environment) are significantly exceeded.

• Loss of life.

• Adverse health effects: high level or ongoing medical treatment.

• Specific Consequence Criteria (for public health) are significantly exceeded.

• Local scale impacts: permanent loss of amenity.

Likely The risk event will probably occur in most circumstances.

Major • onsite impacts: high level.

• offsite impacts local scale: mid-level.

• offsite impacts wider scale: low level.

• Short-term impact to an area of high conservation value or special significance.

• Specific Consequence Criteria (for environment) are exceeded.

• Adverse health effects: mid-level or frequent medical treatment.

• Specific Consequence Criteria (for public health) are exceeded.

• Local scale impacts: high level impact to amenity.

Possible The risk event could occur at some time.

Moderate • onsite impacts: mid-level.

• offsite impacts local scale: low level.

• Adverse health effects: low level or occasional medical treatment.

6 In applying public health criteria, DWER may have regard to the Department of Health’s Health Risk Assessment (Scoping) Guidelines. 7 Determination of areas of high conservation value or special significance should be informed by the Guidance Statement: Environmental Siting.

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• offsite impacts wider scale: minimal.

• Specific Consequence Criteria (for environment) are at risk of not being met.

• Specific Consequence Criteria (for public health) are at risk of not being met.

• Local scale impacts: mid-level impact to amenity.

No risk events during the construction phase were deemed to warrant detailed risk assessment under the EP Act (see Table 7-4).

Three risk events during operation phase were deemed to warrant detailed risk assessment under Part V of the EP Act (see Table 7-5. These are presented in Section 7.4, Section 7.5 and Section 7.6.

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7.2 Acceptability and treatment of Risk Event DWER will determine the acceptability and treatment of Risk Events in accordance with the Risk treatment listed in Table 7-3.

Table 7-3 Risk treatment table.

Rating of Risk Event Acceptability Treatment Extreme Unacceptable Risk Event will not be tolerated. DWER may refuse

application. High May be acceptable. Subject to

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

Medium Acceptable, generally subject to regulatory controls.

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

Low Acceptable, generally not controlled.

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

7.3 Potential discharges – storage of waste

The Facility is in a remote area within the Goldfields region (Figure 2-1). The Facility is not accessible by public roads and is not open to public access.

No local or regional groundwater aquifer has been identified, removing the possibility of groundwater contamination and ingesting contaminated groundwater.

The nearest surface waterway is greater than 50 km from the Facility (Figure 5-1) and, Tellus considers that there is no off-site premises risk to public health caused by the proposed activities

Potential environmental discharges and their subsequent risk to the environment have been identified in this Section. Proposed controls for identified hazards and risks are described in Section 8.

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Table 7-4 Environmental Risk Events – construction emissions, pathways and receptors

Risk Events Proceed to detailed risk assessment?

Justification

Source / activities Potential emissions

Potential receptors

Potential pathway

Potential adverse impact

Mining/Cells Area

Clearing of native vegetation to develop Cells.

Unauthorised clearing

Native vegetation Clearing vegetation

Reduced biodiversity

N/A Assessed and approved under Part IV of the EP Act (refer MS 1078).

Earthworks to develop Cells.

Noise • IWDF.

• Carina Mine Camp.

Air/wind dispersion

Reduced amenity

No No sensitive receptors likely to be impacted. Local scale impacts: low level impact to amenity. • Carina Mine Camp is in care and

maintenance, with a part-time care-taker in attendance.

• The IWDF is operated on a campaign-basis, last campaign was in 2008.

Mining is regulated by Department of Mines, Industry Regulation and Safety under the Mining Act 1978.

Dust No

Infrastructure Area

Clearing of native vegetation to develop infrastructure area.

Unauthorised clearing

Native vegetation Clearing vegetation

Reduced biodiversity

N/A Assessed and approved under Part IV of the EP Act (refer MS 1078).

Earthworks to develop infrastructure area.

Noise • IWDF.

• Carina Mine Camp.

Air/wind dispersion

Reduced amenity

No No sensitive receptors likely to be impacted. Local scale impacts: low level impact to amenity.

Dust No

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Risk Events Proceed to detailed risk assessment?

Justification

• Carina Mine Camp is in care and maintenance, with a part-time care-taker in attendance.

• The IWDF is operated on a campaign-basis, last campaign was in 2008.

Fuel for construction contained with an above ground self-bunded fuel tank

Hydrocarbon spills Waste (treated and untreated)

Soils and vegetation

Direct discharge Seepage

Soil Contamination and vegetation health impacts.

No • Extensive groundwater investigations have been carried out by Tellus, and no aquifer has been identified. A layer of 2-3m of low-permeability clayey sand overlies a 3m thick layer of a extremely low permeability silcrete material. Contamination of soil 2-3m below ground level is unlikely. In the event of a spill the affected area would be excavated to recover contaminated material for disposal.

• Storage in accordance with the Dangerous Goods Safety Act 2004: Dangerous Goods Licence, DGSO22452.

Groundwater n/a n/a No There is not considered to be a pathway to groundwater.

Surface Water n/a n/a No There is not considered to be a pathway for overland flow of surface water.

Installation and commissioning of waste immobilisation plant.

Odour IWDF Carina Mine Camp

Air/wind dispersion

Health and amenity

No • The IWDF is operated on a campaign-basis, last campaign was in 2008.

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Risk Events Proceed to detailed risk assessment?

Justification

• Carina Mine Camp is in care and maintenance, with a part-time care-taker in attendance.

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

Waste (treated and untreated)

Groundwater n/a n/a No There is not considered to be a pathway to groundwater.

Surface Water n/a n/a No There is not considered to be a pathway for overland flow of surface water.

Stormwater drainage management

Contaminated stormwater

Soils and vegetation

Overland flow. Seepage from retention ponds. Overtopping of ponds

Soil Contamination and vegetation health impacts.

No • W6243 considered the controls proposed for stormwater management and ponds at the Premises.

• There are limited opportunities for stormwater contamination during construction.

• There is not considered to be a pathway for overland flow of surface water.

• Management of "Early Wastes" accepted for storage in East Yard during construction are the subject of Sandy Ridge Works Approval Application No.2 (our document reference SR00-299429885-22573).

Groundwater n/a n/a No There is not considered to be a pathway to groundwater.

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Risk Events Proceed to detailed risk assessment?

Justification

Surface Water

n/a n/a No There is not considered to be a pathway for overland flow of surface water.

Table 7-5 Environmental Risk Events – operations emissions, pathways and receptors

Risk Events Proceed to detailed risk assessment?

Justification

Source / activities Potential emissions Potential receptors Potential pathway

Potential adverse impact

Mining/Cells Area

Clearing of native vegetation to develop Cells.

Unauthorised clearing Native vegetation Clearing vegetation

Reduced biodiversity

N/A • Assessed and approved under Part IV of the EP Act 1986 (refer MS 1078).

• Maximum of 202.3 ha approved for clearing of mine pits/waste cells.

• Implementation of approved Flora and Vegetation Management Plan as required by Condition 10-6 of MS 1078.

Earthworks to develop Cells.

Noise • IWDF.

• Carina Mine Camp.

Air/wind dispersion

Reduced amenity

No • No sensitive receptors likely to be impacted. Local scale impacts: low level impact to amenity.

• Carina Mine Camp is in care and maintenance, with a part-time care-taker in attendance.

Dust No

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Risk Events Proceed to detailed risk assessment?

Justification

• The IWDF is operated on a campaign-basis, last campaign was in 2008.

• Mining is regulated by Department of Mines, Industry Regulation and Safety under the Mining Act 1978.

Isolation of Class IV and Class V waste materials including LLW in cells

Leachate generation from within cell

Soils Water ingress to cell generating leachate.

Contamination of soil.

No • Assessed and approved under Part IV of the Environmental Protection Act 1986 (refer MS 1078) and will be managed via implementation of the Leachate Monitoring and Management Plan required by condition 9 of MS 1078.

• Also managed via a Deep Groundwater Monitoring and Management Plan required by condition 2 of EPBC Act approval 2015/7478.

• There is not considered to be a pathway to groundwater or a pathway for overland flow.

Groundwater n/a n/a No

External Gamma radiation exposure

Humans and biodiversity

Air Radiation exposure / sickness. Reduced biodiversity.

Yes • Potential adverse impacts on human health and biodiversity associated with radiation exposure for the Facility are being assessed by the WA Radiation Health Unit and Radiological Council under the RS Act and therefore not presented here.

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Risk Events Proceed to detailed risk assessment?

Justification

Infrastructure Area

Unloading, loading and storage of wastes above-ground. Operating above-ground equipment Vehicle movements

Noise IWDF and Carina Mine Camp

Air/wind dispersion

Reduced amenity

No No sensitive receptors likely to be impacted. Local scale impacts: low level impact to amenity. • The IWDF is operated on a

campaign-basis, last campaign was in 2008.

• Carina Mine Camp is 50 km south of the Facility. Furthermore, it is under care and maintenance, with a part-time care-taker in attendance.

Dust

Fuel storage and refuelling Hydrocarbon spills Subsurface soils.

Native vegetation.

Direct discharge, contaminated stormwater discharge.

Contamination of soil. Impacts to native vegetation.

No • Refuelling facilities are designed in accordance with AS 1940 and will be managed as per standard industry practices.

• Storage is managed under the Dangerous Goods Safety Act 2004. The Facility has an approved Dangerous Goods Licence, DGSO22452.

Above-ground storage of Class IV and Class V wastes

Waste (untreated and treated)

Soil underlying storage areas

Infiltration Soil contamination through release of chemicals.

Yes In the event of failure of controls, there may be impacts to soils and vegetation adjacent to the infrastructure area.

Vegetation to perimeter of infrastructure area

Direct discharge due to extreme rainfall event

Impact to vegetation health if inundated with

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Risk Events Proceed to detailed risk assessment?

Justification

contaminated water.

Groundwater n/a n/a No There is not considered to be a pathway to groundwater.

Surface Water n/a n/a No There is not considered to be a pathway for overland flow of surface water.

Contaminated stormwater

Soils. Native vegetation.

Seepage from ponds or from LLW Radioactive (and sludge) Waste Area.

Soil contamination, reduced vegetation health

Yes In the event of failure of controls, there may be impacts to onsite soils and vegetation.

Note flora and vegetation is to be managed in accordance with the approved Flora and Vegetation Management Plan required by condition 10 of MS 1078.

Overtopping of ponds or overflow from LLW Radioactive (and sludge) Waste Area.

Operating waste immobilisation plant

Odour IWDF 5 km to east Caretaker at Carina Mine Camp 50 km to south.

Air/wind dispersion.

Human health and amenity

No • The IWDF is operated on a campaign-basis, last campaign was in 2008.

• Carina Mine Camp is in care and maintenance, with a part-time care-taker in attendance.

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

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Risk Events Proceed to detailed risk assessment?

Justification

Waste (untreated and treated)

Soils. Native vegetation.

Direct discharge. Contaminated stormwater flow.

Contamination of soil. Impacts to native vegetation.

Yes In the event of failure of controls, there may be impacts to onsite soils and vegetation.

Groundwater n/a n/a No As shown in Figure 5-2, the Facility lacks a credible pathway to groundwater.

Surface Water n/a n/a No As shown in Figure 5-2, the Facility lacks a credible pathway for overland flow of surface water.

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7.4 Risk assessment - Above-ground storage of Class IV and Class V wastes impacting on soil and vegetation

7.4.1 Description of above-ground storage of Class IV and Class V wastes impacting on soil and biodiversity.

Class IV and Class V wastes proposed to be accepted are deemed intractable due to their chemical and/or physical characteristics. A waste spill or leak may adversely impact local soils and biodiversity if there were no controls in place.

7.4.2 Identification and general characterisation of emission

The WAC presented in Appendix G, is used to determine the acceptability of waste at the Facility. If an emission were to occur, it would likely have characteristics of one or more of these Class V wastes.

7.4.3 Description of potential adverse impact of emission

Chemical discharges may result in localised impacts to soil contamination and indirectly lead to impacts on vegetation health. A release of contaminated soils, including NORM contaminated soils, may result in localised soil contamination only.

7.4.4 Applicant controls

The location of the Facility was selected based on the climatic and geological characteristics that make the site suitable for containing intractable wastes, consistent with the Basel Convention concerning chemical waste disposal and the requirements of the Code of Practice for the near-surface disposal of radioactive waste in Australia (NHMRC, 1992). Those same site characteristics that make the site suitable for a near surface geological repository also make the site suitable for above-ground storage of wastes awaiting disposal.

Waste acceptance is governed by a strict WAC, with only solid wastes (once treated/immobilised) to be disposed in Cells.

Wastes will be stored in their primary waste packages in appropriate freight containers within dedicated waste zoning groups as per the Dangerous Goods Safety (Storage and Handling of Non-Explosives) Regulations 2007 in accordance with Dangerous Goods Licence DGS022452, where applicable.

Pavement types and civil earthworks have been designed to provide appropriate drainage management for the different storage areas within the infrastructure area (i.e. Radioactive (and sludge/liquid) Waste Facility, Mixed Store and East Yard). See also Section 7.5.

Wastes stored in containers will only be removed and managed in concrete bunded, covered facilities.

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Vehicular traffic will be excluded from waste storage areas by bunding, fencing and/or signage, procedures and training. The only vehicle authorised in waste storage areas will be the reach stacker.

• The Mixed Store will be constructed with Pavement Type A.

• Stormwater from the Mixed Store will drain to the HDPE-lined Stormwater Retention Pond in the west of the Infrastructure Area. The sump has been designed to contain a 100 ARI 72-hour storm event.

• All solid chemical waste will be stored in a primary storage package (e.g. steel drum, bulka-bag) within a sea container.

• All storage packages will have clear readable chemical labels.

• Sea containers will be stacked and segregated as per storage requirements (below) for the East Yard area of the Sandy Ridge Goods license DGS022452 (Appendix H).

• Sea containers will remain closed unless they need to be opened to prevent or mitigate a discharge of waste to the environment.

• Stormwater from the East Yard will be drained to a sump north-west of the infrastructure area. The sump has been designed to contain a 100 ARI 72-hour storm event and will be lined with clay during operations.

• All solid chemical waste will be stored in a primary storage package (e.g. steel drum, bulka-bag) within a sea container.

• All storage packages will have clear readable chemical labels.

• Sea containers will be stacked and segregated as per storage requirements (below) for the East Yard area of the Sandy Ridge Goods license DGS022452 (Appendix D).

• Sea containers will remain closed while in storage areas, unless they need to be opened to prevent or mitigate a discharge of waste to the environment.

7.4.5 Consequence

If a waste spill or leak occurred and seeped or flowed to soil and vegetation, the potential impact to the receiving environment is considered by Tellus to be slight: restricted to minimal impacts on a local scale. Contaminated material would be recovered and disposed in a waste cell.

7.4.6 Likelihood

The likelihood of an uncontrolled discharge from waste storage areas would be dependent on a civil engineering design failure, transport packaging failure and procedural controls failing at the same time coinciding with a storm event.

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Based on the above reasoning Tellus considers that the likelihood of an uncontrolled discharge of waste to soil or vegetation from the above-ground waste storage areas is unlikely (soil) or rare (vegetation).

7.4.7 Overall rating of above-ground storage of Class IV and Class V wastes

The overall risk rating is low.

7.5 Risk assessment – Contaminated stormwater impacting on soil and vegetation

7.5.1 Description of contaminated stormwater impacting soil and vegetation

If a waste spill or leak occurred in waste handling areas (refer to Section ) and the material was washed by stormwater into the on-site Stormwater Retention Pond or was discharged from the sludge/liquid waste handling area, it may either seep into the underlying soil or overtop to soil and vegetation.

7.5.2 Identification and general characterisation of emission

The Waste Acceptance Criteria (WAC, presented in Appendix G) is used to determine the acceptability of wastes at the Facility.

7.5.3 Description of potential adverse impact of emission

Uncontrolled chemical discharges may result in localised impacts to soil and indirectly to impacts on vegetation health in the surrounding area. A release of NORM sludge or soils may result in adverse soil impacts at a local scale.

7.5.4 Applicant controls

The Facility site selection criteria included compliance with hydrogeological site characteristics of Basel Convention Technical Guidelines on Specially Engineered Landfill, namely avoiding sites with drinking water sources, flood-prone regions and separation distance above water table. Sandy Ridge is in an arid region with approximately 250 mm rainfall per year, lacks the presence of a local or regional groundwater aquifer and, is in an arid zone with no history of flooding.

The on-site Stormwater Retention Pond has been designed to contain a 100-year ARI, 72 hour storm event. It is lined with a High Density Polyethylene (HDPE) liner. If the pond reaches capacity and overtops, it has been designed to overflow into the Raw Water Pond located immediately adjacent, which is also HDPE-lined.

“Clean” stormwater upslope of the Infrastructure Area will be diverted away from the Infrastructure Area by a flood levee to the east. In addition, storage yards have been graded to ensure that runoff from clean areas does not enter the catchment and unnecessarily increase the amount of water captured in the ponds.

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Stormwater collected in the Stormwater Retention Pond (and Raw Water Pond if there has been overflow into it) will be sampled for contaminants prior to use on-site (see Section 8). If results indicate concentrations of contaminates greater than site trigger levels, water will be used in waste cells (e.g. for compaction).

Waste inspection areas have been designed with roofs to exclude rainwater and sealed concrete floors i.e. areas where wastes are opened, inspected and handled.

Stormwater management is self-contained within the Radioactive Waste Area (i.e. it does not flow to the Stormwater Retention Pond), draining to blind concrete sumps or a sump in the Liquid Waste Unloading area. Drainage catchment in this area is designed to contain the largest volume waste container expected (e.g. an ISO container).

The Radioactive Waste Area’s storage yard is a block-paved yard that also drains to concrete, blind sumps from which spills can be recovered.

Spills will be recovered and treated in the WIP for disposal in a Cell.

7.5.5 Consequence

If contaminated stormwater was discharged to soil and vegetation, the impact is considered slight: restricted to minimal impacts on a local scale. Contaminated material can be recovered and disposed in a waste cell.

7.5.6 Likelihood

A discharge of contaminated stormwater from the LLW Radioactive Waste Area, Stormwater Retention Pond or Raw Water Pond would rely firstly on contamination through transport packaging failure and procedural controls failing coinciding with a storm event. Secondly, the stormwater containment would need to fail through:

1. Under estimate the capacity of the LLW Radioactive Waste Area’s WIP Waste Bund. 2. Under estimate the storm event, i.e. a larger than 1 in 100-year, 72 hour event. 3. Failure of the HDPE liner in the Stormwater Retention Pond or Raw Water Pond causing

seepage to ground; or 4. Failure of the pond wall(s) releasing water to soil and vegetation.

Based on the above reasoning Tellus considers that the likelihood of an uncontrolled discharge of contaminated stormwater to soil or vegetation from the Stormwater Retention Pond is unlikely.

7.5.7 Overall rating for stormwater management

The overall risk rating is low.

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7.6 Risk assessment – WIP waste impacting on soil and vegetation

7.6.1 Description of WIP seepage or loss of containment on land or soils

An uncontrolled release of waste from the WIP, either untreated liquid/sludge or treated spade-able product, may result in impacts to soil and vegetation health.

7.6.2 Identification and general characterisation of emission

The WAC, presented in Appendix G, is used to determine the acceptability of wastes at the Facility. If an emission were to occur, it would likely have the characteristics of a Class IV or Class V waste.

7.6.3 Description of potential adverse impact of emission

Waste (either treated or untreated) discharges may result in localised impacts to soil and indirectly impacts on vegetation health. A release of NORM may result in localised soil impacts.

7.6.4 Applicant controls

Above ground piping that dispenses liquid/sludge waste from the WIP Waste Bund is under low pressure and located within a concrete bund. Concrete bunding has blind concrete sumps to contain spills. The dispensing pump(s) are to be fitted with emergency stop buttons which, in the event of a spill or leak, will avoid/minimise the volume of material spilt.

The planetary mixer is an enclosed machine, limiting the opportunity for spills. It will be installed within a concrete bund with capacity for a 1:100 ARI 72-hour event, with a blind sump to contain spills. The planetary mixer is designed with an underside discharge point which will direct the spade-able mix directly into a sealed, half-height container. The half-height container will have a closable lid to further reduce the chance of emissions.

The WIP will be manned at all times when in operation.

The technical specifications of the WIP are listed in Section 3.3.1.

7.6.5 Consequence

If material was discharged to soil and vegetation from the WIP, the impact to the receiving environment is considered slight: restricted to minimal impacts on a local scale. Contaminated material can be recovered and disposed in a waste cell.

7.6.6 Likelihood

The likelihood of an uncontrolled discharge from the WIP impacting the environment would be dependent on a failure in the design and/or construction of the bunding, piping or the planetary mixer itself. In addition, the spilt material would then have to seep or flow overland to discharge to soil or vegetation.

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Based on the above reasoning Tellus considers that the likelihood of an uncontrolled discharge of waste to soil or vegetation from the WIP is unlikely (soil) or rare (vegetation).

7.6.7 Overall rating of WIP seepage and loss of containment on land and soils

The overall risk rating is low.

7.7 Summary of acceptability and treatment of Risk Events A summary of the risk assessment and the acceptability of the risk events presented in Section 7 are presented in Table 7-6 below. Additional general site controls are listed in Section 8. Due to the designed, engineered controls, the natural geology and hydrogeology of the site and proposed procedural controls, no risk events are considered unacceptable.

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Table 7-6 Risk Assessment Summary - Operations.

Risk Events Controls Consequence* Likelihood* Risk Reasoning Sources/Activities Potential

emissions Potential receptors Potential

pathway Potential adverse impacts

Mixed store operation

Storage of Class IV and Class V wastes

waste (untreated and treated)

Soil adjacent to and beneath the Mixed Store

Infiltration soil contamination through release of chemicals. Impact to vegetation health if inundated with contaminated water.

Site selection - arid, dry climate. Wastes will be stored in locked sea-containers. Stormwater management with capacity for a 100 year ARI, 72-hour storm event. Engineered paving. Vehicular traffic excluded from waste storage areas.

Slight Unlikely Low Vegetation adjacent to the Mixed Store is well represented locally and regionally. The closest conservation-significant flora species is approximately 700m to the south of the Mixed Store. The potential consequence is therefore slight, and localised. Vegetation contaminated

stormwater discharge

Impact to vegetation health if inundated with contaminated water.

Slight Rare Low

Stormwater drainage management

Contaminated stormwater

Soils. Native vegetation.

Seepage from ponds

Soil contamination, reduced vegetation health

Flood levee to divert "clean" stormwater away from the Infrastructure Area. Stormwater management with capacity to contain 1-in-100 ARI 72-hour storm event. Stormwater retention pond, raw water pond and brine pond will be HDPE-lined. Maintain freeboard on ponds at all times. Stormwater sampled for contaminants prior to use for dust supression. If contaminated, water will be used in waste cells. Inspection and treatement of waste conducted in concrete bunded areas.

Slight Unlikely Low No sensitive receptors likely to be impacted.

Overtopping of ponds

Slight Unlikely Low

Liquid Waste and Radioactive Waste Area

Stormwater drainage management

Contaminated stormwater

Soils. Native vegetation.

Seepage from active waste areas

Soil contamination, reduced vegetation health

Roof and concrete floors in waste inspection bays where wastes are opened, inspected and handled. Drainage is self-contained within the Area. Spills will be recovered an

Slight Unlikely Low No sensitive receptors likely to be impacted.

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Risk Events Controls Consequence* Likelihood* Risk Reasoning Overland flow treated in the WIP for

disposal in a Cell. Wastes stored inside transport packaging on engineered-paving yard, drain to concrete, blind sumps.

Slight Unlikely Low

Operating waste immobilisation plant

Operating waste immobilisation plant

waste (treated and untreated)

native vegetation and soils

direct discharge soil contamination, reduced vegetation health

WIP is an enclosed machine, in concrete bund designed for 100 year ARI 72-hour event, with trafficable kerb and blind sumps to capture spills. Dispensing pump is low-pressure/low flow rate. Piping from WIP waste bund to WIP is bunded and will be manned at all times during operation. Piping and WIP will be fitted with emergency off function to cease operation in the event of a spill. Discharge from the WIP is to sealed shipping containers with lids, for direct placement in waste cell.

Slight Unlikely Low No sensitive receptors likely to be impacted.

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8 CONTROLS

8.1 General controls The following general controls will be implemented to control the event risks identified in Section 7:

• Elimination

o The nearest surface water course is located greater than 50 km from the Facility.

o No ground water aquifer beneath Sandy Ridge site.

o Silcrete layer two metres below ground level has very low permeability.

o Waste accepted will not be flammable or combustible.

o No underground storage tanks on-site for liquid waste.

• Engineering Controls

o Flood levee to divert clean stormwater away from Infrastructure Area.

o Stormwater management with capacity for a 1 in 100 ARI 72-hour event.

o Waste will be contained in appropriate primary packaging that meets Tellus’ WAC and Chain of Custody requirements.

o Storage containers/tanks, piping, handling areas, delivery areas and process tanks located within secondary containment areas.

o Storage containers and secondary containment materials will be impermeable to the substance being stored and will not react with the substance being stored.

o Primary packages loaded into a sea container and sea containers onsite is kept locked and closed.

o Firebreak will be installed on site perimeter of Sandy Ridge.

o Fire truck and site Emergency Service Officer onsite to provide asset protection during fire event.

o Water cart available to provide extra water for fire fighting efforts.

• Administrative Controls

o Inspection of waste packages upon arrival at the Facility. o Sea containers inspected for structural integrity prior to acceptance onsite. o Separation distances will facilitate incompatible chemicals not coming into contact

during spills, leaks or fires. o Testing of containment ponds before use of water on-site. o Spill kits containing absorbent material appropriate to the type of substance being

used on-site.

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o Recovery drums/containers compatible with the substances which may be put in them.

o Implementation of Emergency Response Management Plans and Procedures. o Documented daily inspection of waste storage areas. o Monitoring of environmental parameters as shown in Figure 8-1. Proposed

monitoring schedule is presented in Table 8-1.

Table 8-1 Proposed environmental monitoring.

Monitoring Location(s)

Parameter Target

Proposed Monitoring Frequency

Duration

Village. WWTP effluent (refer to W6243/2019/1)

Quarterly spot samples in accordance with W6243/2019/1.

WWTP Irrigation Area.

Vegetation health, ponding, weeds.

Quarterly in accordance with W6243/2019/1 and approved Flora and Vegetation Management Plan.

Putrescible landfill. Waste disposed. Litter

< 500 tonnes per year

Monthly Annually Weekly

To year 26

Retention Pond. Stormwater prior to discharge anywhere other than Cells Area.

Grab sample after rainfall event resulting in water in Retention Pond (refer to W6243/2019/1).

To year 26

Raw Water Pond. Raw water if Retention Pond overflows and prior to discharge anywhere other than Cells Area

Grab sample (refer to W6243/2019/1).

To year 26

Future (subject to Phase 2 and Phase 3 works approvals) 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

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Monitoring Location(s)

Parameter Target

Proposed Monitoring Frequency

Duration

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

<= Cymod8 estimate

continuous monitoring, monthly data

TBA – probe life dependent (estimate up to 10 years) Moisture at base of

silcrete/laterite <= Cymod estimate

continuous monitoring, monthly data

Moisture at base of lower clay layer

<= Cymod estimate

continuous monitoring, monthly data

Cell 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, monthly samples

To year 26

8.2 Storage, handling and permeant isolation of LLW Controls for the storage, handling and permanent isolation of LLW will be assessed and regulated under the RS Act (refer to Section 1 and Section 4.5).

8.3 Waste isolation in near-surface geological repository As outlined in Section 2 the assessment of the proposal to develop the Sandy Ridge Facility under Part IV of the EP Act considered the sites suitability for an intractable waste disposal facility and potential adverse impacts on inland waters and terrestrial environmental quality. This Application does not seek to duplicate that assessment and respectfully directs the reader to Section 10.5 of the Public Environmental Review (Tellus 2016) which contains a comprehensive environmental impact risk assessment of the natural geological barrier provided by the site.

Further, Condition 9 of MS 1078 require Tellus to ensure the impacts to soil quality are minimised through the implementation of a Leachate Monitoring and Management Plan approved by the Chief Executive Officer of DWER. The management and disposal of NORM / LLW is regulated under the Radiation Safety Act 1975 by way of a site Registration assessed and granted by the Radiological Council (see Section 4.5).

8 CyMod Systems Pty Ltd (2016). The Assessment and Long-Term Recharge to Encapsulated Waste Isolation Cells – Sandy Ridge Project.

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Proposed Environmental MonitoringStations during Operations

SANDY RIDGE FACILITYCat 65 & 66 WORKS APPROVAL

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8.4 EP Act regulatory controls Tellus will submit a compliance construction report to DWER and a licence application for assessment prior to commencing operation of the activities described in this application.

Environmental monitoring will be conducted in accordance with:

• Proposed monitoring of emissions and discharges as per the schedule in Table 8-1

• Sandy Ridge Leachate Monitoring and Management Plan (in preparation) to be approved by DWER CEO in accordance with Condition 9 of MS 1078.

• Sandy Ridge Flora and Vegetation Management Plan approved by DWER CEO in accordance with Condition 10 of MS 1078.

• Sandy Ridge Construction Fauna Management Plan approved by DWER CEO in accordance with Condition 11 of MS 1078.

• Sandy Ridge Waste Facility Decommissioning and Closure Plan (in preparation) to be approved by DWER CEO in accordance with Condition 12 of MS 1078.

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9 CONCLUSION

This application has assessed the risks of activities prescribed in Schedule 1 of the EP Regulations on the Sandy Ridge Facility during construction, commissioning and operation. It has been undertaken with due consideration of potential environmental hazards and risks against baseline data gathered between 2015 and 2019.

Based on the potential for environmental and human health hazards and risks presented in Section 7 and the proposed controls described in Section 8, it is recommended the Works Approval for Categories 61, 61A, 65 and 66 be granted subject to conditions proportionate to the determined controls and necessary administration and reporting requirements under Part V of the EP Act.

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10 REFERENCES

Geo9 (2019). Sandy Ridge Project Seismoelectric and Electrotelluric Survey Report. Unpublished report (DRAFT) for Tellus Holdings Ltd. May 2019.

Tellus Holding Ltd. (2016). The Proposed Sandy Ridge Facility Public Environmental Review. Final Report. December 2016. Available at: http://www.epa.wa.gov.au/proposals/sandy-ridge-project#

Tellus Holding Ltd. (2019). Sandy Ridge Facility Temporary Waste Storage – Works Approval Application 2 Supporting Document – Categories 61 and 61A. Unpublished application for works approval under Part V of the Environmental Protection Act 1986. 26 September 2019.