Albemarle Lithium Pty Ltd...Albemarle Albemarle Lithium Pty. Ltd. Albemarle Kemerton Plant A Lithium...

ALBEMARLER

Albemarle Lithium Pty Ltd

Albemarle Kemerton Plant Environmental Management PlanNovember 2017

GHD | Report for Albemarle Lithium Pty Ltd - Albemarle Kemerton Plant, 6136286 | i

Document Control

Version No.

Version Date: Authorisation Signature

Rev A 04/10/2017 F. Hannon

Rev B 25/10/2017 F. Hannon

Rev 0 07/11/2017 F. Hannon

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Summary This Environmental Management Plan (EMP) is submitted to support environmental referrals under the Environmental Protection Act 1986 (EP Act) and Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) for the Albemarle Kemerton Plant which will be developed by Albemarle Lithium Pty Ltd (Albemarle). The following table presents the purpose of the EMP in the context of Western Australia Environmental Protection Authority (EPA) objectives.

Purpose of the Environmental Management Plan

Item Description

Title of proposal Albemarle Kemerton Plant

Proponent name Albemarle Lithium Pty Ltd

Purpose of the Environmental Management Plan

This EMP is submitted to support referrals under the EP Act and EPBC Act.

The purpose of this management plan is to provide a framework to ensure that activities related to the Albemarle Kemerton Plant will be managed so that the impacts on the environment are acceptable.

Key environmental factors and objectives

Flora and Vegetation

Terrestrial Fauna

Terrestrial Environmental Quality

Hydrological Processes

Inland Waters Environmental Quality

Air Quality

Social Surroundings.

This EMP is designed to be adaptive and will be updated over the life of the Project. Prior to commencement of construction Albemarle will update this EMP in consultation with relevant government departments. As such, this EMP remains a working document.

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Acronyms and Abbreviations AAMGL Annual average maximum groundwater level

AHD Australian Height Datum

AEP Annual Exceedance Probability

Albemarle Albemarle Lithium Pty Ltd

ANZECC Australian and New Zealand Environment and Conservation Council

ARI Average Recurrence Interval

ASS Acid Sulfate Soils

BAM Act Biosecurity and Agriculture Management Act 2007

BAT Best Available Technique

bgl below ground level

BMP Bushfire Management Plan

BREF Best Available Techniques Reference Document for the Non-Ferrous Metals Industries

CEMP Construction Environmental Management Plan

DBCA Department of Biodiversity, Conservation and Attractions

dB(A) A-weighted decibels

DER Department of Environment Regulation

DoEE Department of the Environment and Energy

DJTSI Department of Jobs, Tourism, Science and Innovation

DPLH Department of Planning, Lands and Heritage

DRF Declared Rare Flora

DWER Department of Water and Environmental Regulation

EIA Environmental Impact Assessment

EMP Environmental Management Plan

EP Act Environmental Protection Act 1986

EPA Environmental Protection Authority

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

ERSR Environmental Referral Supporting Report

GBRS Greater Bunbury Regional Scheme

GHG Greenhouse Gas

GJ Gigajoule

GKB Gnaala Karla Booja People

h Hour

Ha hectare

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HDPE High Density Polyethylene

IBRA Interim Biogeographic Regionalisation of Australia

ILUA Indigenous Land Use Agreement

km Kilometre

KPI Key Performance Indicator

KSIA Kemerton Strategic Industrial Area

m Metre

MS Ministerial Statement

MSDS Material Safety Data Sheet

m/s Metres per second

MW Megawatt

OEMP Overarching Environment Management Plan

OWMS Overarching Water Management Strategy

PASS Potential Acid Sulfate Soils

PEC Priority Ecological Community

RL Reduced Level

RO Reverse Osmosis

SCP Swan Coastal Plain

SO3 Sulphur trioxide

TARP Trigger Action Response Plan

TEC Threatened Ecological Community

tpa tonnes per annum

VOC Volatile Organic Compounds

WA Western Australia

WC Act Wildlife Conservation Act 1950

WAPC Western Australian Planning Commission

WoNS Weeds of National Significance

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Defined Terms

Terms Definitions

Acid Roasted Solids Spodumene ore which has undergone all pyrometallurgical treatment including calcining, grinding and roasting.

Albemarle Albemarle Lithium Pty. Ltd.

Albemarle Kemerton Plant

A Lithium Hydroxide Product manufacturing Plant and associated infrastructure which is proposed to be established wholly within Lot 510 Wellesley Road, Wellesley, and operated by Albemarle Lithium Pty Ltd.

Conservation Wetland Wetlands which support a high level of attributes and functions

Cristal Cristal Pigment Australia Limited. Cristal operates a titanium dioxide processing plant in the Kemerton Strategic Industrial Area

Kemerton Strategic Industrial Area (KSIA)

An Industrial Park 17 km north east of Bunbury established to provide a location for downstream processing and value adding to the South West’s primary resources. It comprises a 2,024 ha Industry Zone, 284 ha Ancillary Industry zone and 5,200 ha Industry Buffer Zone.

Lithium Hydroxide Product

Battery grade lithium hydroxide monohydrate (LiOH.H2O).

Multiple Use Wetland Wetland with few important ecological attributes and functions remaining.

Plant Industrial processing infrastructure used to manufacture Lithium Hydroxide Product from spodumene containing ore concentrate.

Proposal To construct and operate a Lithium Hydroxide Product manufacturing plant, in Kemerton Strategic Industrial Area. Including the construction and operation of a Lithium Hydroxide Product manufacturing Plant (the ‘Plant’) and associated infrastructure including; administration facilities; workshop; supply warehouse / store; fuel and reagent storage; amenities, laboratory; control centre; water management infrastructure and a service corridor.

Proposal area Part Lot 510 Wellesley Road, Wellesley, in which all construction and operational activities for the Proposal will be located within, including a service corridor off Marriott Road. The Proposal area is illustrated in Figure 1-2 and is 89.25 ha.

Resource enhancement Wetland

Wetlands which may have been partially modified but still support substantial ecological attributes and functions

Site As per the Proposal area.

Sodium Sulfate By-product

By product of the Lithium Hydroxide Product manufacturing process. Non-toxic white powder which is highly soluble in water.

Spodumene ore concentrate

Naturally occurring lithium aluminosilicate material with crystalline zeolite structure which is concentrated to 6.0% Li2O.

Swan Coastal Plain Low-lying coastal plain in the south west of Australia mainly covered with woodlands, with rare landscape features such as Holocene dunes and wetlands.

Tailings The residual solids, comprising aluminosilicate, gypsum and small levels of other salts, after the lithium extraction process, including approximately 30% water (Section 2.2).

Talison Talison Lithium Australia Pty. Ltd with operations in Greenbushes WA.

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Table of contents Defined Terms .......................................................................................................................................... v

1. Context, scope and rationale ......................................................................................................... 1

1.1 Proposal ............................................................................................................................... 1 1.2 Purpose and scope of this EMP .......................................................................................... 6

1.3 KSIA development requirements ......................................................................................... 6

1.4 Key environmental factors and impacts ............................................................................... 8

1.5 Rationale and approach ..................................................................................................... 10

2. Over-arching environmental management ................................................................................... 12 2.1 Management systems and implementation ....................................................................... 12

2.2 Over-arching KSIA environmental management documents ............................................ 14

2.3 EP Act Part V – Environmental Regulation........................................................................ 15

3. Environmental management plan provisions ............................................................................... 16

3.1 Flora and vegetation management .................................................................................... 16 3.2 Terrestrial fauna management ........................................................................................... 21

3.3 Terrestrial environmental quality management ................................................................. 25

3.4 Hydrological Processes ..................................................................................................... 30

3.5 Inland Waters Environmental Quality ................................................................................ 35

3.6 Air Quality .......................................................................................................................... 38 3.7 Social Surroundings ........................................................................................................... 43

4. Adaptive Management ................................................................................................................. 48

4.1 Benchmarking and Best-Practise ...................................................................................... 48

4.2 Environmental monitoring and corrective actions .............................................................. 48

4.3 Audits ................................................................................................................................. 48 4.4 EMP Revision .................................................................................................................... 49

5. Stakeholder Register .................................................................................................................... 50

5.1 Stakeholder management .................................................................................................. 50

6. References ................................................................................................................................... 51

Table index Table 1-1 Key proposal characteristics for the Albemarle Kemerton Plant ............................................. 2

Table 1-2 Key environmental factors, values, and impacts relevant to the Proposal .............................. 8

Table 1-3 Studies and surveys relevant to the Proposal area ............................................................... 10

Table 3-1 Flora and vegetation – Objective and KPIs ........................................................................... 17

Table 3-2 Vegetation and flora – Management actions and targets ...................................................... 18

Table 3-3 Terrestrial fauna – Objective and KPIs .................................................................................. 22

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Table 3-4 Terrestrial fauna – Management actions and targets ............................................................ 23

Table 3-5 Terrestrial Environmental Quality – Objectives and KPIs ...................................................... 26

Table 3-6 Management and Monitoring Action – Terrestrial Environmental Quality ............................. 27

Table 3-7 Hydrological Processes – Objectives and KPIs ..................................................................... 32

Table 3-8 Hydrological Processes – Management Actions and Targets ............................................... 33

Table 3-9 Inland Waters Environmental Quality – Objectives and KPIs ................................................ 35

Table 3-10 Inland Waters – Management Actions and Targets ............................................................. 36

Table 3-11 Air Quality – Objectives and KPIs ........................................................................................ 39

Table 3-12 Air Quality – Management Actions and Targets .................................................................. 40

Table 3-13 Social Surroundings – Objectives and KPIs ........................................................................ 43

Table 3-14 Social Surroundings – Management Actions and Targets .................................................. 44

Table 5-1 Albemarle Kemerton Plant EMP stakeholder consultation record ......................................... 50

Figure index Figure 1-1 Albemarle Kemerton Plant Location ....................................................................................... 3

Figure 2-1 Albemarle Kemerton Plant Organisational Chart .................................................................. 12

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1. Context, scope and rationaleThis Environmental Management Plan (EMP) has been prepared for the construction and operation of the Albemarle Kemerton Plant (the Plant). This section includes a summary of the proposal including its key features, information on the key environmental factors relating to construction of the Plant, the management approach that will be undertaken and the rationale for the approach.

1.1 Proposal

Albemarle Lithium Pty Ltd (Albemarle) proposes to construct and operate the Albemarle Kemerton Plant, a Lithium Hydroxide Product manufacturing Plant and associated infrastructure, within the Kemerton Strategic Industrial Area (KSIA) approximately 17 kilometres north-east of Bunbury, Western Australia (WA) (referred to as the Proposal). It is expected that the Plant will be classified as a Category 44 prescribed premise (metal smelting or refining) in accordance with the Environmental Protection Regulations 1987 (EP Regulations). Secondary categories 5 (processing or beneficiation of metallic or non-metallic ore), 31 (chemical manufacturing), 67 (fuel burning) and 73 (bulk storage of chemicals) may also apply to the Proposal.

Lithium hydroxide monohydrate (Lithium Hydroxide Product) will be produced from spodumene ore concentrate from the Talison Lithium Australia Pty Ltd (Talison) Lithium Operations located in Greenbushes, WA. Lithium Hydroxide Product will be transported from the Plant to Fremantle Port for export. Waste product (tailings) will be transported to a licensed Class III landfill facility for disposal. All transport will be via truck.

Development will commence in 2018 subject to final investment decision and receipt of required approvals. 89.25 (ha) of disturbance is required to develop the Proposal. Initial production is scheduled to commence by 2020 and the Plant has an intended operating life of approximately 25 years. The Plant will comprise a series of 20,000 tonne per annum (tpa) Lithium Hydroxide Product process trains. Initial production will commence with operation of a single train at a rate of 20,000 tpa, increasing in stages with the addition of up to four more 20,000 tpa trains to a potential output of 100,000 tpa of Lithium Hydroxide Product by around 2025.


1.1.1 Key Proposal characteristics

The Proposal area is shown in Figure 1-1. The key proposal characteristics for the Albemarle Kemerton Plant are identified in Table 1-1.

Table 1-1 Key proposal characteristics for the Albemarle Kemerton Plant

Proposal title Albemarle Kemerton Plant Proponent name Albemarle Lithium Pty Ltd Short description The Proposal is to construct and operate a Lithium Hydroxide

Product manufacturing Plant, in the KSIA, 17 km north- east of Bunbury, WA. The Proposal includes construction of up to five Lithium Hydroxide Product process trains and associated infrastructure including; administration facilities; workshop; supply warehouse / store; fuel and reagent storage; amenities, laboratory; control centre; water management infrastructure and a service corridor.

Element Proposed Extent Physical elements Lithium Hydroxide Product Production Plant and associated infrastructure

Clearing of no more than 87.7 ha of vegetation (54.31 ha native vegetation comprising 29.26 ha native vegetation and 25.05 ha previously cleared farmland with native vegetation re-growth) within the Proposal area.

Operational elements Waste Production from Lithium Hydroxide Product manufacturing (tailings)

Processing of up to 1 million tonnes of spodumene ore concentrate per annum to produce up to 100,000 tonnes of Lithium Hydroxide Product, 200,000 tonnes of Sodium Sulfate By-product and up to 1.1 million tonnes of tailings per annum. Tailings management will be undertaken by a separate entity and is not part of this Proposal.

Transport The key transport routes for the Proposal are: Transport of spodumene ore concentrate between

Greenbushes and KSIA Transport of packaged Lithium Hydroxide Product between

KSIA and Fremantle Port Transport of packaged Sodium Sulfate By-product between

KSIA and Fremantle or Bunbury Port Transport of tailings and return leachate between KSIA and a

Class III landfill, Transport will be via B-double trucks using the suitably rated

roads within the existing network.

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Project No.Revision No. 0

61-36286

Date 24/10/2017

Albemarle Lithium Pty LtdAlbemarle Kemerton Plant

Map Projection: Transverse MercatorHorizontal Datum: GDA 1994Grid: GDA 1994 MGA Zone 50

Paper Size ISO A3

Data source: Amec Foster Wheeler: KSIA zones - 20170908; GHD: Proposal area - 20171023; Landgate: Aerial photography (Virtual Mosaic) - 20170926, Roads - 20170821; Geoscience Australia: Geodata250K Topo - 2006. . Created by: mmikkonen

G:\61\36286\GIS\Maps\Working\6136286_1-2_Location_Rev0.mxdPrint date: 03 Nov 2017 - 13:26

Legend

KSIA IndustrialCore

KSIA Buffer

Proposal area

Local proposal extent

0 1 20.5

Kilometres

FIGURE 1-1


1.1.2 Key site development activities

The Site will primarily consist of the Plant, associated supporting infrastructure, access roads and utilities. The key development activities are summarised below and described in detail in the Environmental Referral Supporting Document (ERSD) (GHD 2017a).

Site development

Initial development works will involve clearing of vegetation via bulldozer and cut-and-fill earthworks. Some external fill may need to be imported to the site to raise and consolidate the ground level on the eastern side.

In addition to the excavation and fill earthworks, Albemarle will also establish a temporary diversion of a drain passing through the south east corner of the site.

Construction

Construction of the Plant will be undertaken in stages. Construction of the first of up to five 20,000 tpa Lithium Hydroxide Product processing trains is planned to commence in Q2 2018 and is expected to be completed by 2020. Construction of supporting infrastructure and services is also planned to be completed within this timeframe.

Construction works will include:

• Establishment of temporary construction facilities within the Proposal area. This willinclude demountable office/s, laydowns, site amenities, storage facilities, temporary waterstorage tanks and fuel supply with secondary containment

• Establishment of temporary site drainage for stormwater control

• Establishment of a service corridor between the Site and Marriott Road to provide accessduring the construction phase for import and export of equipment, personnel, constructionmaterials, infrastructure and wastes

• Ground preparation works for services, building and infrastructure development

• Installation of required services, buildings, process plant and supporting infrastructuresuch as storage tanks, bunding, ponds and water treatment plant

• Installation of amenities and associated septics. Accommodation is not required at thePlant

• Connection of site services

• Establishment of access roads for the Site and installation of access control points at thesite entry and exit

• Bitumising/hard surfacing of the majority of the Site. There will be minimal areas of openground and vegetation on the Site, apart from a vegetation screen along the easternboundary between the Site and Kemerton Road.

Operations

Process Description

The Plant will process up to one million tpa of spodumene ore concentrate (containing 6% lithium) via pyrometallurgical and hydrometallurgical unit operations to produce Lithium Hydroxide Product. The process also produces Sodium Sulfate as a commercial by-product (Sodium Sulfate By-product) and tailings as waste.


Services

The service corridor established between Marriott Road and the Site during the construction phase will be used to connect services to the Site to supply;

Electricity;

Natural gas;

Water; and

Telecommunications.

Natural gas will be the primary fuel source used to fire kilns, boilers and heat the product dryers. Gas will be piped at a rate of 100-300 GJ per hour per process train. Electricity will be supplied from the nearby Western Power sub-station with an initial typical load of 11 MW per process train. Service connections between existing infrastructure in the KSIA, and the Site, will be established by the relevant supplier who will be responsible for the works and approvals required to establish the connections.

Non-process wastes which will be generated by the Proposal include general site waste such as packaging, industrial, office and municipal wastes, and residual salts from water treatment. These will be collected on site and recycled where appropriate or landfilled at existing licenced landfills. There is no reticulated wastewater collection service within the KSIA. All non-process wastewater (from offices, amenities etc) will be treated via an on-site septic system.

Support Facilities

Ancillary infrastructure will be established within the Proposal area to support operation of the Albemarle Kemerton Plant. The infrastructure required includes:

Administration building / offices

Carpark

Boundary fencing

Workshop

Supply warehouse / store

Fuel storage area

Reagent storage areas

Amenities

Laboratory

Control centre

Water storage, supply and stormwater collection ponds.

Roads and Transport

The Albemarle Kemerton Plant will be accessed via Kemerton Road, a yet to be constructed road, immediately east of the site, running between Marriott Road and Wellesley Road North. The approvals and development of this road will be managed by LandCorp and is separate to this Proposal. The routing of the proposed road is provided in the KSIA Structure Plan (Raymond 2017).

The Plant will have controlled entry and exits off Kemerton Road joining to a bitumised primary access road which will navigate the perimeter of the site.


The road transport movements associated with transporting materials to and from the Plant include:

Transport of spodumene ore concentrate from the Talison Greenbushes Operation.

Transport of packaged Lithium Hydroxide Product and Sodium Sulfate By-product in shipping containers to Fremantle Port (or alternatively Bunbury Port in the case of sodium sulfate).

Transport of tailings to a licensed Class III landfill facility and return of the leachate to the Plant from the landfill.

Transport of reagents including sulfuric acid, sodium hydroxide, lime, limestone sand, phosphoric acid and diesel from local suppliers or distributors within a 155 km radius.

All transport is planned to be undertaken using B-double trucks with the exception of reagents which will be transported by suitably licensed carriers using appropriate road transport vehicles.

1.2 Purpose and scope of this EMP

This EMP is submitted with the environmental referrals in order to satisfy the Environmental Protection Authority (EPA) and the Commonwealth Department of the Environment and Energy (DoEE) that Albemarle can manage the Proposal so that impacts on the environment are acceptable.

The EMP includes the environmental management aspects of all activities undertaken by Albemarle, its employees and contractors. It includes the activities and infrastructure described in the accompanying referral documentation and summarised in Section 1.1.

This EMP has been developed as to document management actions throughout the life of the Project (design / implementation / operations and decommissioning / rehabilitation and closure). Additional activity / aspect management plans will be prepared that provide more detailed management requirements for specific components. These management plans include but may not be limited to those listed within this document.

The EMP has been developed in accordance with the EPA Instructions on how to prepare Environmental Protection Act 1986 Part IV Environmental Management Plans 2017.

1.3 KSIA development requirements

Development within the KSIA is required to meet the requirements of the Shire of Harvey Town Planning Scheme, and the Greater Bunbury Region Scheme (GBRS). In accordance with the GBRS, and specifications set out in Ministerial Statement (MS) 697 for the GBRS, an Environmental Management Plan may require preparation and implementation to achieve the objective of managing potential impacts of the proposed development.

Other requirements of MS 697 and the GBRS include that the Western Australian Planning Commission (WAPC) or local government may require the following to be prepared and implemented prior to approving development within the KSIA:

• A Drainage, Nutrient and Water Management plan where the Average Maximum Groundwater Level is less than 1.2 metres (m) below the natural ground surface, or where any proposed drainage could lead to degradation of wetlands or waterways

• A Preliminary Acid Sulfate Soils Assessment to be prepared where there is likely to be a significant risk of disturbing acid sulfate soils (ASS)

• Where the presence of ASS is confirmed, An Acid Sulfate Soil Management Plan.


Overarching Environmental, Bushfire and Water Management Plans have been prepared to support the KSIA Structure Plan (Raymond 2017) in accordance with the requirements specified in the GBRS and MS 697. These overarching plans have been developed to manage potential impacts of development in the KSIA on remnant vegetation, wetlands, fauna and visual amenity. Site specific management documents must be cognisant of the requirements of the overarching plans.


1.4 Key environmental factors and impacts

The key environmental factors identified as being relevant to the Proposal are outlined in Table 1-2. The relevance of each environmental factor to the Proposal is discussed in the ERSD (GHD 2017a). Table 1-2 also summarises the Proposal-specific environmental value, proposed impact activity and impact for each key environmental factor.

Table 1-2 Key environmental factors, values, and impacts relevant to the Proposal

EPA Factor Key Values Impact Activities Key Potential Impacts

Flora and vegetation

Up to 54.31 ha native vegetation

Up to 6.37 ha ‘Banksia Woodlands of the SCP’ TEC

118 plants of Priority 4 listed species (Acacia semitrullata)

Vegetation Clearing Permanent loss of identified key values

Indirect impacts from construction such as introduction of weeds/disease

Vehicle movements Introduction of weeds/disease to adjacent vegetation

Terrestrial Fauna

Conservation significant black cockatoo foraging habitat (62.62 ha) and breeding habitat (up to 14.45 ha including one potential breeding tree)

Vegetation Clearing Permanent loss of identified key values

Vehicle movements Fauna injury, death or displacement from fauna strike during construction and transportation

Terrestrial Environmental Quality

Agricultural land used as grazing farmland

Site preparation and earthworks

Exposure of Acid Sulfate Soils (ASS) resulting in environmental harm

Handling and storage of environmentally hazardous materials and waste (tailings)

Dust from processing activities

Transport of spodumene ore concentrate, tailings, products and reagents

Contamination of soil and land

Multiple-use geomorphic wetlands Changes to groundwater levels


EPA Factor Key Values Impact Activities Key Potential Impacts

Hydrological Processes

Low lying drainage area Vegetation clearing / Earthworks / Hard surfacing

Erosion and sedimentation due to altered surface water drainage

Changes in vegetation structure (groundwater dependent ecosystems – wetlands)

Inland Waters Environmental Quality

Water quality high in nutrients and salinity

Vegetation Clearing / Site preparation and earthworks

Salinisation from groundwater level rise.

Release of turbid or contaminated water

Handling and storage of environmentally hazardous materials and waste (tailings)

Stormwater management

Contamination of surface water and groundwater

Air Quality Industrial and rural air shed

Thirty-six sensitive receptors for air quality


Vehicle and equipment operation

Reduced air quality due to air emissions, including dust, combustion emissions and greenhouse gas

Plant operation Reduced air quality due to air emissions, including dust, combustion emissions and greenhouse gas

Social Surroundings

Cultural heritage locations within 5 km buffer


Potential for disturbance of buried artefacts / skeletal material

Low visual amenity value Site preparation / Construction activities / Plant operation

Reduced visual amenity

Thirty-six sensitive receptors to noise Construction / Plant operation and vehicle movements

Noise emissions, resulting in nuisance to sensitive receptors


1.5 Rationale and approach

1.5.1 Survey and study findings

The following studies and surveys have been undertaken within, or are relevant to, the Site.

Table 1-3 Studies and surveys relevant to the Proposal area

Studies Consultant Description

Flora and vegetation

Eco Logical Australia (ELA) (2017a)

ELA (2017b)

ELA (2017c)

GHD (2017d)

ELA mapped nine vegetation communities within the Site, of which two vegetation types represented ‘Banksia Woodlands of the SCP’ TEC. 118 locations of priority 4 species were identified.

Terrestrial fauna Eco Logical Australia (ELA) (2017a)

ELA (2017b)

ELA (2017c)

GHD (2017d)

ELA mapped seven vegetation communities that are suitable for foraging by black cockatoos. Of these, four habitats are suitable for black cockatoo breeding. Two potential breeding trees were identified within the Proposal area.

Terrestrial environmental quality

N/A Data gap. A site investigation will be undertaken to determine the presence, extent and severity of Potential Acid Sulfate Soils (PASS) that will require disturbance to develop the site.

Hydrological processes

Aquaterra (2002) Kemerton Water Study Phase 2. Defined the depth and extent of distinct groundwater units within the KSIA. Four groundwater units were identified.

Inland waters environmental quality

Aquaterra (2002) Kemerton Water Study Phase 2. Assessed groundwater quality throughout the KSIA. Groundwater was found to be high in nutrients and salinity, trending depending on the aquifer.

Air quality GHD (2017b) Air dispersion modelling, which demonstrated that air emissions will be below the assessed criterion.

Social surroundings

GHD (2017c) Noise modelling which demonstrated that noise emissions will be below the Environmental Protection (Noise) Regulations 1997 limits.

Goode (2011) Desktop and field surveys within the KSIA did not identify archaeological or ethnographic sites within the Proposal area.

WLJA (2007)

A landscape assessment within the KSIA identified the site to be within the Bassendean Plain, adjacent to a ridge that is a vantage point within the KSIA.

There are uncertainties in regards to the presence of PASS on site. This will be investigated prior to construction.


Pre-construction monitoring of groundwater depth, groundwater quality and, noise at sensitive receptors, will be undertaken to develop a baseline dataset.

1.5.2 Key assumptions and uncertainties

This EMP presents provisions based on full operating capacity (five trains, 100,000 tpa Lithium Hydroxide Product), expected to be reached around 2025. At the time of preparing this EMP, the starting capacity of the Plant will be a single train operating at 20,000 tpa. As the Plant expands, the intensity and magnitude of certain impacts such as air and noise emissions are expected to increase.

Air emissions from processing operations were estimated using emission factors from the NPI Emissions Estimation Technique Manual for Combustion in Boilers (DSEWPaC 2012). As such, the provisions are conservative.

1.5.3 Management approach

The management approach in this EMP is conservative, with the view of managing impacts during full capacity. The suite of existing information was used in developing the management approaches.

A hierarchical approach to manage the potential impacts from the Proposal has been used:

Avoidance: measure taken to avoid impact

Minimisation: measures taken to reduce the duration, intensity and/or extent of impact

1.5.4 Rationale for choice of provisions

The KSIA is likely to become more developed with industry during the life of the Plant. Management measures include assessment of cumulative impacts where applicable and will provide a base for additional cumulative impact assessment as further industry develops. Provisions are also included for impacts outside of the control of Albemarle such as storm events.


2. Over-arching environmental management 2.1 Management systems and implementation

Albemarle has a corporate Health Safety and Environment Management System (HSEMS) which is consistent with the principles of ISO14001. The HSEMS is certified under Responsible Care 14001 (RC 14001) for Albemarle’s US operations. RC 14001 is a management system initiative of the American Chemistry Council and is considered to be equivalent to, and in some respects more stringent than, ISO 14001.

The HSEMS identifies significant environmental, safety, health, security and product aspects that are used to define relevant policies and procedures of the HSEMS. These are reviewed on an annual basis. The significant environmental aspects which have been identified in the Albemarle HSEMS are:

Compliance with applicable legal or regulatory requirements associated with: – production of our products at our manufacturing sites and toll processing sites; and – disposal of wastes from our operations.

Incidents that could have environmental impact, upset neighbours, or result in regulatory non-compliance.

Emissions from our operations of the following: – Greenhouse gases – Toxic releases such as Toxic Release Inventory chemicals and Hazardous Air

Pollutants; and – Waste with hazardous characteristics.

Site contamination that could require remediation

Each Albemarle manufacturing site maintains a set of site specific HSE policies and procedures. Site specific policies and procedures will be developed and maintained in line with the HSEMS for the Albermarle Kemerton Plant.

2.1.1 Roles and responsibilities

The organisational structure which will apply to the Albemarle Kemerton Plant is provided in Figure 2-1.

Figure 2-1 Albemarle Kemerton Plant Organisational Chart


2.1.2 Communication

Albemarle will communicate and distribute environmental information to the workforce through the following methods: site inductions, toolbox meetings, training, pre-start meetings, on-site notice boards, electronic media, environmental alerts and incident reporting and investigations.

Albemarle has engaged with government departments, local government and neighbouring industries during the design and planning stage for the Proposal and will continue this engagement process through the development of the Proposal. Community consultation is also planned as the Proposal progresses through to commencement.

2.1.3 Environmental awareness training and inductions

Albemarle will ensure that all personnel, including subcontractors, are subjected to a site induction program that will include an environmental component. The site-specific induction will communicate:

• Requirements of relevant environmental management documentation (KSIA over-archingdocuments as well as Albemarle specific documents)

• Significant environmental values to be protected

• Control strategies for the management of environmental risk in day-to-day activities

• Roles and responsibilities for implementing management, monitoring and reportingassociated with the environment

• Applicable legislative responsibilities and requirements and the risks associated withnoncompliance.

Additional training will be provided to personnel, where applicable, which might include spill response or fire and emergency response.

Records of training and inductions will be maintained by Albemarle in a training register.

2.1.4 Complaints procedure

All environmental incidents/complaints and ‘near misses’ will be recorded within a register that will be developed and maintained by Albemarle. Incidents will be recorded by the person who causes or identifies the incident and complaints will be recorded by the person who receives the complaint (at the time it is received). Records to be obtained about a complaint include:

Contact details for person making complaint (name and phone number as a minimum)

Approximate location that issue was identified by complainant

Date, time and issue/s that complaint relates to.

2.1.5 Environmental incidents / non-compliances

Incident reporting and investigations are carried out per Albemarle procedure 03-1005, and root causes are determined. Corrective actions are implemented to address the root causes.

Incidents and ‘near misses’ and non-compliances with this EMP will be reported and investigated in accordance with Albemarle procedure 03-1005, and appropriate measures implemented to prevent recurrence. Where applicable, environmental incidents will be reported to the relevant government agency.

The following procedure will be implemented when a non-compliance occurs:

Investigate cause and raise an incident report

Implement contingency actions which may include:


– Review management measure’s practicality or relevance

– Improve training and education for all personnel

– Improve and implement increased protective measures as necessary

– Improve methods for marking clearing lines

– Install additional temporary fencing or signs.

Monitor outcomes.

2.1.6 Emergency response

Albemarle will prepare a Project-specific Emergency Response Plan. This Plan will detail how emergencies are responded to within the Proposal area, and outline any requirements for on-site Fire/Emergency Wardens and First Aid Officers.

2.1.7 Reporting

Albemarle will undertake reporting in accordance with regulatory and legislative requirements. It is expected that the Plant will be required to operate in accordance with a Part V EP Act licence which will specify annual environmental and compliance reporting requirements. Albemarle will submit an annual compliance report and annual environmental report to the Department of Water and Environmental Regulation (DWER) in accordance with the Part V licence requirements. The report will contain all required information.

In accordance with the requirements of Section 72 of the EP Act, Albemarle is required to report discharges of waste which have caused, or are likely to cause pollution, material environmental harm or serious environmental harm to DWER.

Albemarle will undertake to complete the specified reporting for each environmental factor detailed in Chapter 3 of this EMP.

2.2 Over-arching KSIA environmental management documents

As per details in section 1.3, Overarching Environmental, Bushfire and Water Management Plans have been prepared for the KSIA to manage potential impacts of development on remnant vegetation, wetlands, fauna and visual amenity. Albemarle has taken the requirements of these overarching management plans into consideration in the development of this EMP. Review of this EMP is required in the event of the overarching management plans being amended to ensure any variations are incorporated. An overview of the overarching documents is included below for reference:

• Kemerton Strategic Industrial Area Overarching Environmental Management Plan (OEMP),Prepared for LandCorp (ELA 2015) – the plan documents the environmental values of theKSIA and specifies management requirements for key environmental factors including floraand vegetation, terrestrial fauna, hydrological processes, inland water environmentalquality, terrestrial environmental quality, amenity, heritage, air quality, and human health.The management measures outlined in this EMP are aligned to the requirements of theOEMP

• Kemerton Strategic Industrial Area Overarching Water Management Strategy (OWMS),Prepared for LandCorp (RPS 2016) – the management measures outlined within theOWMS are designed to ensure maintenance of the pre-development hydrological regime ofthe KSIA as closely as possible while protecting ground and surface water resources. TheOWMS also specifies that proponents undertaking development within the KSIA arerequired to prepare a site specific Urban Water Management Plan in consultation withDWER (Water Services). The management measures outlined in this EMP are aligned tothe requirements of the OWMS


• Kemerton Strategic Industrial Area Bushfire Management Plan (BMP), prepared forLandCorp (Ruic Fire 2016) – the BMP identifies development conditions and emergencyresponse procedures to minimise the risk and impacts associated with bushfire in the KSIA.Development and operation of the site will be consistent with these provisions.

2.3 EP Act Part V – Environmental Regulation

The Plant is expected to be classified as a Category 44 prescribed premise (metal smelting or refining) in accordance with the Environmental Protection Regulations 1987 (EP Regulations). Secondary categories 5 (processing or beneficiation of metallic or non-metallic ore), 31 (chemical manufacturing), 67 (fuel burning) and 73 (bulk storage of chemicals) may also apply to the Proposal. Emissions and discharges from prescribed premises are regulated via works approval (construction) and licence (operation) issued under Part V of the EP Act. It is anticipated that a licence issued for the premises may contain management requirements relating to emissions to air, water, and land and associated monitoring and reporting requirements. Review of this EMP will be required when a works approval, licence or amendment to these documents is issued to ensure all requirements are incorporated.


3. Environmental management plan provisions Albemarle acknowledges that the provisions in this section of the EMP are legal requirements to be met. In order to comply with relevant environmental legislation and manage impacts to the local environment, Albemarle has defined objectives, outcome and management based provisions for each key environmental factor identified in the ERSD (GHD 2017a).

Some potential impacts may be relevant to several of the environmental issues/aspects detailed in the following sections. Where possible the relevant management actions and monitoring is detailed in one section to prevent unnecessary repetition.

3.1 Flora and vegetation management

3.1.1 Key impacts and risks

The following aspects have been identified as requiring management to minimise the potential for impacts to terrestrial flora and vegetation.

Construction

• Vegetation clearing: construction of the Proposal will result in the direct loss of up to 54.31 ha of native comprising 29.26 ha native vegetation and 25.05 ha previously cleared farmland with native vegetation re-growth. This includes up to 6.18 ha of native vegetation that aligns with the Banksia Woodlands of the Swan Coastal Plain TEC and the Low lying Banksia attenuata woodlands or shrublands Priority Ecological Community (PEC), and 14.99 ha of native vegetation associated with Multiple Use wetlands areas with little to no ecological value. Construction of the proposal will also result in the direct loss of 118 plants of Priority 4 listed species Acacia semitrullata

• Introduction and/or spread of weeds and dieback into adjacent vegetation: construction activities including the movement of personnel, vehicles and mobile plant, as well as the movement of soil and fill have the potential to spread weeds (including Declared Pests) and Dieback both within the Proposal area, and into adjacent areas

• Fragmentation of native vegetation within the KSIA (local area): vegetation clearing for construction of the Proposal will result in some fragmentation of vegetation by contributing to increased patches and/or edges at a local scale. Fragmentation of vegetation at a regional scale is not anticipated given the relatively small size of the Proposal area

• Loss of/damage to vegetation and flora from bushfire: the vegetation and flora within and surrounding the proposal area is susceptible to fire. Construction activities associated with the Proposal have the potential to accidently generate fire, which could spread from the Proposal area to the surrounding areas.

Operations

• Changes to vegetation structure and floristic composition: altered surface water drainage patterns and flow through implementation of the Proposal have the potential to indirectly adversely impact adjacent and/or off-site vegetation including areas representative of the Banksia Woodlands of the Swan Coastal Plain TEC. There are also two records of Drakaea elastica, which is listed as Endangered under the EPBC Act and Threatened under the Wildlife Conservation Act 1950 WC Act approximately 45 m from the northern boundary of the Proposal area.


3.1.2 Management objective, actions and targets

This section provides management measures for potential impacts on flora and vegetation. Specifically, it addresses vegetation clearing impacts, hygiene management and fire management.

No further specific management measures for flora and vegetation are required as management measures detailed in Section 3.4 for hydrological processes and Section 3.5 inland water quality adequately mitigate hydrology related impacts to flora and vegetation. The operational emissions are discussed in Section 3.6 Air Quality.

The objectives and key performance indicators (KPIs) are provided in Table 3-1, and management actions, targets and monitoring are provided in Table 3-2.

Table 3-1 Flora and vegetation – Objective and KPIs

EPA Objective: To protect flora and vegetation so that biological diversity and ecological integrity are maintained

Objective Key Performance Indicator

Prevent clearing or removal of vegetation outside of the Proposal area

No incidents of vegetation clearing outside of the approved clearing area

Minimise disturbance of vegetation and flora outside of the Proposal area

No incidents of fire originating within, and spreading outside of, the Proposal area

No significant or reportable decline of nearby DRF Drakaea elastica individuals, attributable to site activities

No significant or reportable decline to adjacent areas representative of the Banksia Woodlands of the Swan Coastal Plain TEC, attributable to site activities

Prevent introduction and/or spread of weeds into adjacent areas

No significant increase in weed cover within immediately adjacent areas/vegetation, attributable to site activities

Avoid introduction and/or spread of Dieback within adjacent areas

No new Dieback infestations identified within immediately adjacent areas/ vegetation resulting from Proposal activities


Table 3-2 Vegetation and flora – Management actions and targets

Management action Management target Monitoring Construction – vegetation clearing The Construction Environmental Management Plan (CEMP) will include management actions to be completed prior to and during vegetation clearing. This will include, but not be limited to: • All clearing boundaries to be clearly marked and

checked prior to commencement, during andpost clearing activities

• Any vegetation or trees that are to be retainedwill be marked accordingly to ensure they areavoided.

• No burning of cleared vegetative materials orburning within the Proposal area

• Vehicles and equipment shall not be drivenover, or parked on, vegetation and/or tree rootsas far as is practicable

• Cleared vegetation suitable for reuse willgenerally be reduced in size (chipping) andreused within soft landscaping works wherepossible. Where not suitable for re-use it will bedisposed of at an appropriate wastemanagement facility.

Compliance with pre-defined clearing limits and boundaries described within approval documents.

To include: • Daily construction area inspections to visually

check/review clearing boundaries and assessvegetation clearing, in particular, compliancewith statutory approvals.

• Maintain clearing register to ensure that themeasured extent of clearing is regularlyupdated

• Implement and maintain Incident ReportRegister.

Construction – vegetation disturbance The CEMP will include management actions relating to fire. This will include, but not be limited to: • All Shire restrictions on fire and machinery

movement should be strictly adhered to• No fires shall be lit within the Proposal area• Maintain all vehicles, plant and equipment in

good working order free of build-up of debrisand oil

• Machinery to be fitted with approved sparkarresting exhaust systems

No incidents of fire resulting from construction activities.

To include: • Daily checks of fire risk ratings, Shire warnings

and restrictions and subsequent communicationto staff during construction

• Implement and maintain Incident ReportRegister.


Management action Management target Monitoring • Construction personnel shall be trained in the

use of emergency fire suppressant equipment • All vehicles, plant and equipment to be fitted

with fire extinguishers and restricted to designated cleared areas

• Construction personnel will extinguish and report fires occurring within the proposal area to the Site Manager.

Construction – hygiene management The CEMP will include management actions relating to hygiene management. This will include, but not be limited to: • Vehicles, plant and equipment to be maintained

and cleaned to reduce the spread of weeds throughout the Proposal area

• Restrict movement of machines and other vehicles to the limits of the areas cleared.

• Any fill material sourced off-site must be certified clean fill

• As far as practical, clearing activities to occur during the dry months to reduce the risk of spreading Dieback

• Comply with the requirements of the BAM Act for listed Declared Pests recorded within the Proposal area.

No new weed infestations identified in areas adjacent to the Proposal area. No new Declared weeds identified within Proposal area and immediately adjacent areas as a result of construction activities. No new dieback infestations identified immediately adjacent to the Proposal area as a result of construction activities.

Monthly visual monitoring for new weed infestations in adjacent areas. Implement and audit of hygiene/wash down standards for vehicles and machinery. Implement and maintain Incident Report Register.

Operations – vegetation health Surface water flow and drainage to be managed as per the Water Management Plan

No decline of adjacent vegetation and flora, including nearby DRF Drakaea elastica individuals and areas representative of the Banksia Woodlands of the Swan Coastal Plain TEC.

Monthly photo monitoring of immediately adjacent vegetation, including DRF Drakaea elastica individuals and areas representative of the Banksia Woodlands of the Swan Coastal Plain TEC.

Contingencies and corrective actions Vegetation clearing non-compliance: • Investigate cause and raise an incident report • Implement contingency actions which may include:


Management action Management target Monitoring – Review practicality and relevance of management measures– Improve training and education for all personnel– Improve and implement increased protective measures as necessary– Improve methods for marking clearing lines– Install additional temporary fencing or signs.

• Monitor outcomes.Fire event as a result of construction activities: • Implement emergency evacuation and response plans• Investigate cause and raise an incident report.Hygiene non-compliance: • Investigate cause and raise an incident report• Implement contingency actions which may include:

– Review practicality and relevance of management measures– Improve training and education for all personnel– Improve and implement increased protective measures/controls as necessary– Review monitoring frequency and method.

• Monitor outcomes.Supplementary Studies and Reports CEMP – to be prepared by the construction contractor prior to development.


Monitoring detailed in Section 3.1.2 will ensure that Albemarle is managing clearing conducted on site and can ensure the clearing limit will not be exceeded. Monitoring will also verify that clearing was conducted within the boundary of the approved area.

3.2 Terrestrial fauna management


The following aspects have been identified as requiring management to minimise the potential for impacts to terrestrial fauna.

Construction

• Vegetation clearing: construction of the Proposal will result in the direct loss of up 87.7 ha of fauna habitat. This includes up to 62.62 ha of foraging habitat for the Threatened black cockatoo species (Carnaby’s, Baudin’s and Forest Red-tailed Black Cockatoos). Construction of the proposal will also result in up to 14.45 ha of black cockatoo potential breeding habitat including one potential breeding tree. There is also the potential to displace fauna species due to disturbance of fauna habitat

• Fragmentation of fauna habitat within the KSIA (local area): vegetation clearing for construction will result in some fragmentation of fauna habitat by contributing to increased patches and/or edges at a local scale. Fragmentation of fauna habitat at a regional scale is not anticipated given the relatively small size of the Proposal area

• Injury or mortality to fauna species: habitat removal, vehicle or machinery strike during construction has the potential to cause injury or death to fauna. Some species are more susceptible than others (e.g. can more readily evade injury such as birds).

Operation

Injury or mortality to fauna species: vehicle strike or collision (road kill) during the operational phase of the Proposal has the potential to cause injury or death to fauna

Displacement of fauna due to secondary impacts such as noise, vibration and light.


This section provides management measures for potential impacts on terrestrial fauna. Specifically, it addresses fauna injury/mortality.

No further specific management measures for terrestrial fauna are required as management measures detailed in Section 3.1 for vegetation clearing (fauna habitat loss) apply. The operational emissions are discussed in Section 3.6 Air Quality and Section 3.7 Social Surrounds.

The objectives and key performance indicators (KPIs) are provided in Table 3-3, and management actions, targets and monitoring are provided in Table 3-4.


Table 3-3 Terrestrial fauna – Objective and KPIs

EPA Objective: To protect terrestrial fauna so that biological diversity and ecological integrity are maintained.


Minimise impacts to terrestrial fauna species. No incidents of terrestrial fauna injury or death within the Proposal area during construction.

No incidents of terrestrial fauna injury or death as a result of Proposal implementation.


Table 3-4 Terrestrial fauna – Management actions and targets

Management action Management target Monitoring Construction – fauna injury/mortality The CEMP will include management actions to be completed prior to and during vegetation clearing. This will include, but not be limited to: • Immediately prior to vegetation clearing the

Proposal area should be trapped and surveyedby an appropriately licenced (under WC Act)and experienced ecologist to remove andrelocate any fauna that may be directlyimpacted by clearing. The relocation programwill require approval by the Department ofBiodiversity Conservation and Attractions(DBCA).

• Prior to the commencement of clearing, thearea will be searched for fauna and any faunafound will be relocated into the neighbouringvegetation. This will include ground searchesand tree hollow inspections.

• Vegetation clearing will be undertaken in stagesalong one front to give fauna the opportunity toescape.

• Fauna encountered in the Proposal area will begiven the chance to move on if there is no threatto the person’s safety in doing so. A suitablyexperienced and licensed person will beavailable at all times during the constructionphase to interact with fauna that cannot moveaway freely.

• All staff and contractors involved in clearingactivities will be inducted on the potentialimpacts to fauna and advised to stop works inthe vicinity of any injured or shocked animalsthat are encountered.

• If injured/sick animals are encountered, or eggsare removed from trees prior to clearing, a

No incidents of terrestrial fauna injury or death from construction activities.

Implement and maintain a Fauna Register (including encounters, injuries and deaths). Report all native fauna occurrences resulting in injury or death to DBCA. Implement and maintain Incident Report Register.


Management action Management target Monitoring nominated fauna carer listed under the Wildlife Hotline will be called to care for the animal.

• Native fauna encounters (including all faunainjuries and deaths) will be recorded.

Operations – fauna injury/mortality • All vehicles to stay on clearly designated roads

and tracks and adhere to speed limits.• Native fauna encounters (including all fauna

injuries and deaths) will be recorded.• Feeding of animals prohibited.• Implement feral animal control program as

required.

No incidents of terrestrial fauna injury or death outside of Proposal area during operations, which are attributable to the activities of Plant personnel or the Plant operation.

Implement and maintain a Fauna Register (including encounters, injuries and deaths). Report all native fauna occurrences resulting in injury or death to DBCA. Maintain feral animal register and ensure regularly updated. Implement and maintain Incident Report Register.

Contingencies and corrective actions Fauna injury/mortality non-compliance: • Investigate cause and raise an incident report• Implement contingency actions which may include:

– Review practicality and relevance of management measures– Improve training and education for all personnel– Improve and implement corrective actions as necessary

• Notify regulatory authorities as applicable.• Monitor outcomes.Supplementary Studies and Reports Pre-clearance surveys CEMP – to be prepare by the construction contractor prior to development.


3.3 Terrestrial environmental quality management


The following aspects have been identified as requiring management to minimise the potential for impacts to terrestrial environmental quality.

Construction

• Exposure of ASS: excavation of soils will only occur in the western half of the Proposalarea, which is up to 5 m higher than the eastern part. The ASS risk in this area is low tomedium therefore it is unlikely that PASS will be disturbed as part of excavation works toestablish site foundation. Excavation for foundation development is only expected to beundertaken within moderate to high PASS areas in the event that ground conditions areunsuitable to support the infrastructure load of the Plant, and the in-situ soils requiretreatment or removal and replacement. Site development also requires the division of anexisting drain passing through the south east corner of the Proposal area. There is a riskthat soils excavated from the drain, and the diversion excavation itself, may oxidise uponexposure and release sulphuric acid, iron compounds and metals if ASS are present

• Vegetation clearing that results in erosion and sedimentation – causing impacts to soilquality.

• Vegetation clearing resulting in dryland salinity: see hydrological processes for watermanagement (Section 3.4)

• Environmentally hazardous material release: direct contamination of soils and land couldoccur from release of fuel or chemicals from storage or handling areas.

Operations

• Hardstands resulting in impairment of soil function: the 89.25 ha Proposal area will belargely bitumised/hard surfaced. The life of the Project is 25 years. Topsoil will not bestockpiled as the duration of storage is likely to render the topsoil un-viable.

• Contamination of soils / surrounding environment from:

– Process dust emissions (Spodumene ore concentrate, tailings, Lithium HydroxideProduct or Sodium Sulfate By-product)

– release of environmentally hazardous materials from the fuel or reagent storageareas; or

– contaminated stormwater or process water discharge to the environment viaseepage or loss of containment.

• There will be no soil or land impacts within the Proposal area relating to disposal of tailingsas this material will be transferred to a Class III landfill. The landfill owner/operator will seekall necessary approvals for establishing a tailings storage cell at the landfill site.


This section provides management measures for potential impacts on terrestrial environmental quality. Specifically, it addresses ASS management, environmentally hazardous materials and stormwater.

The following documents will be prepared to provide further site specific information and management:


• Acid Sulfate Soils Investigation and ASS Management Plan (if required). This will includeinformation on monitoring to be undertaken during construction and post-construction andthe treatment and disposal of and PASS / ASS

No further specific management measures for terrestrial environmental quality are required as management measures detailed in Section 3.1 for flora and vegetation, Section 3.5 inland water quality adequately mitigate impacts to terrestrial environmental quality. The operational emissions are discussed in Section 3.6 Air Quality.

The objectives and KPIs are provided in Table 3-5, and management actions, targets and monitoring are provided in Table 3-6.

Table 3-5 Terrestrial Environmental Quality – Objectives and KPIs

EPA Objective: To maintain the quality of land and soils so that environmental values are protected


Prevent impacts to the environment due to contamination from ASS

No non-compliance with the DER (2015) ASS Guideline.

Prevent contamination to the surrounding environment from the release of hazardous materials / waste

No significant or reportable environmental incidents relating to hydrocarbons and hazardous materials

Minimise the occurrence of soil erosion during and following construction

Soil erosion consistent with surrounding environment within two years post construction.


Table 3-6 Management and Monitoring Action – Terrestrial Environmental Quality

Management Action Management Target Monitoring Acid Sulfate Soils Management Undertake an ASS investigation in accordance with DER (2015) prior to commencing land clearing.

Material characterisation and risk assessment completed prior to construction.

Audit compliance

If the investigation identifies that PASS may be disturbed by the Project an ASS Management Plan will be developed in accordance with DER (2015) and submitted with the site development application for DWER’s approval.

ASS Management Plan prepared to DWERs satisfaction.

Audit compliance

Implement ASS MP throughout life of Project. Groundwater and surface water quality is not degraded as a result of soil disturbance activities. No visual acid sulphate soil oxidation impacts result from the stockpiling of acid sulphate soils.

As per the approved ASS Management Plan.

Construction - Soil Impacts The CEMP will include: • Drainage treatments provided during construction to minimise

and /or direct runoff from cleared areas in order to minimise downslope erosion and sedimentation.

• If erosion from disturbed areas is evident – stabilisation techniques will be applied to prevent further erosion / runoff and sedimentation.

• Vehicle and machinery traffic will be confined to the disturbance area to prevent damage to retained vegetation / land.

The extent of soil erosion is consistent with surrounding land within two years following construction.

Visual signs of erosion from disturbed areas weekly or after substantial rainfall event. Assessed as part of the rehabilitation monitoring.

Construction – Hydrocarbon and Chemical Management


Management Action Management Target Monitoring The CEMP will include details on the handling and storage of hydrocarbons, chemicals and hazardous materials. This will include but not be limited to the following: • Material Safety Data Sheets (MSDS) to be retained on site in

a register• Refuelling vehicles are equipped with the spill response kits• Plant, vehicles and equipment are adequately maintained and

serviced to prevent leaks• All storage facilities for bulk hydrocarbons meet Australian

Standard AS1940:2004 and are licenced and operated inaccordance with the requirements of the Explosives andDangerous Goods Act 2004.

• Spill management procedures and Trigger Action ResponsePlans (TARP) in place to respond to releases.

Chemicals and fuels stored and handled within designated areas. No significant spills or leaks of hydrocarbons (in excess of 80 litres) outside areas designated for maintenance, refuelling or storage.

To include weekly inspections to identify spills and leaks and check that appropriate storage / handling and signage.

Operations – Waste and Tailings Management Tailings will be removed to an external licensed facility for disposal

No environmental incidents relating to waste management.

Audit compliance

Non-process wastes which will be generated by the Proposal include general site waste such as packaging, industrial, office and municipal wastes, and residual salts from water treatment. These will be collected on site and recycled where appropriate or landfilled at licenced waste management facilities

Non-process/domestic waste collected in designated areas. Sewage waste reports to a designated septic system

Visual checks for non-process waste.

Operations – Hydrocarbon and Chemical Management Storage and handling of all reagents, hydrocarbons and process materials will be undertaken within appropriately sized secondary containment direct release to soils or land is unlikely. Reagent storage facilities will be established in accordance with the Dangerous Goods Safety Act 2004 and associated Regulations. Material Safety Data Sheets (MSDS) to be retained on site in a register.

No significant or reportable environmental incidents relating to hydrocarbons and hazardous materials. Chemicals and fuels stored and handled within designated areas. No significant spills or leaks of hydrocarbons (in excess of 80 litres) outside areas designated for maintenance, refuelling or storage.

Monthly site inspection. Audit of transport operators’ procedure.

Incompatible materials will be appropriately segregated within the site Stores Warehouse in accordance with relevant Australian Legislation

As above As above

Spill management procedures and Trigger Action Response Plans (TARP) in place

As above As above


Management Action Management Target Monitoring Ensuring transport operators have effective emergency response plans and capability to respond to major and minor released of trucked materials

As above As above

Tanks • All tanks will have level monitoring and with alarms linked to

the process control/monitoring system• All tanks will be established in chemically resistant bunds with

a capacity exceeding that the contained tank. Delivery pointswill be within the bunded area

• All stormwater from the Plant area, including bunded areas,will be returned to the Raw Water or Plant run-off pond forreuse (except in extreme rainfall event > 24 hour AEP 1%event.

As above Monthly site inspection.

Contingencies and Corrective Actions ASS: If ASS monitoring is above the ASS MP internal targets: 1. Investigate the cause/significance of the issue and raise an incident report if deemed necessary2. Determine if remediation is required3. Develop and implement a remediation plan if necessary and consult the relevant government regulator as required4. Monitor outcomes.Hydrocarbon / Chemical spill: initiate spill response procedure, assess the significance of the spill, remediate and report to regulator (if required), monitor the effectiveness of corrective actions. Update the handling / storage procedure to prevent future event. Soil erosion: if soil erosion is evident undertake rehabilitation or erosion control measures. Monitor the effectiveness of controls. Supplementary Studies and Reports ASS Investigation – pre-development. ASS MP – if required after the investigation. CEMP – to be prepared by the construction contractor prior to development. Trigger Action Response Plans (TARP). Site Hazardous Materials / Chemicals Register.


3.4 Hydrological Processes


The following aspects have been identified as requiring management to minimise the potential for impacts hydrological processes:

Construction

• There is a requirement to divert an existing drain that will directly alter the existing surface water and groundwater flow regimes within the Proposal area. The diverted drain may also mobilise sediments that could cause erosion and scouring of the drain downstream and at the outlet into the Wellesley River.

• Dewatering may be required depending on the level of groundwater when construction commences. This will involve a limited lowering of the water table (a few metres) for a limited period (weeks)

• Construction of a hardstand area that will encompass the majority of the Proposal area will alter the natural topography that drains surface water eastwards towards the drain by creating a flat platform

• Loss or part loss of four geomorphic wetlands. Reduction in rainfall recharge to the superficial aquifer, which may change the amount of water available to wetlands.

Operations

• Change to vegetation structure within groundwater dependent ecosystems (i.e. wetlands) may change as a result of the relocation of the drain, which is likely to change local groundwater flow

• Stormwater management to prevent contamination, flooding, erosion and sedimentation.


Management of hydrological processes outlined within this document are congruent with the KSIA Over-arching Water Management Strategy (OWMS), with the exception of:

• Ponds will be lined, therefore there will be no infiltration to groundwater

• Enhancement/restoration works for wetlands abutting the Proposal area is not considered necessary, given that there is no potential impact to Conservation or Resource Enhancement geomorphic wetlands.

The Proposal has been developed to meet the objective of the OWMS:

• Effectively manage the risk to human life, damage to property and environmental degradation from water contamination, flooding and waterlogging

• Maintain water quality (surface and groundwater) within the development in relation to pre-development water quality

• Reduce potable water consumption within both public and private spaces using practical and cost-effective measures

• Implement best management practices in regards to industrial stormwater management

• Incorporate where possible, low maintenance, cost-effective landscaping and stormwater treatment systems.


Albemarle – Hydrological Design Components

Albemarle has taken into account hydrological processes through the design process, key design components are summarised below.

Site Development

The Proposal Area will be raised at least 1.5 m above the annual average maximum groundwater level (AAMGL), for the site. Establishing a minimum 1.5 m clearance between the site and the AAMGL is a requirement of the OWMS in accordance with water sensitive urban design principals.

Stormwater Management

Stormwater runoff will be treated as two separate streams on site;

A Plant run-off stream from the production area and roadways, and

A Site run-off stream from the administration, carpark and roof areas.

Plant run-off from the production area and roadways will be treated as a potentially contaminated water stream due to the possibility of containing process contaminants and reagents. Although run-off from the administration, carpark and roof areas is unlikely to contain a significant level of contaminants, it will be treated as a potentially contaminated water stream as it may collect process dust from buildings and the carpark or oil/fuel residues.

The stormwater management system has been designed to collect all stormwater run-off which will be preferentially used as process water. Potentially contaminated water from the Plant area and roadways will be directed to the Plant Raw Water Ponds and Plant run-off pond while stormwater from the administration, carpark and roof areas will be directed to the Site run-off pond via an oil/water separator. Stormwater from open areas will be directed to the collection ponds via gravity through culverts / open drains while stormwater from process bunds will be collected in sumps and pumped to the Raw Water or Plant run-off ponds if required.

The Site stormwater management system has been designed to allow for containment of all stormwater run-off from the Albemarle Kemerton Plant within the Raw Water, Plant run-off and Site run-off ponds up to a 24 hour AEP 1% rainfall event. There is the potential for flooding if the Site experiences a storm event which exceeds the 24 hour AEP 1% rainfall event. During such an event, when the Plant run-off pond and/or Site run-off ponds reach 95% capacity, run-off will be diverted away from the pond, to a culvert and discharged from the Site in a controlled manner. The water discharged is not expected to be contaminated as the first flush water collected in the ponds is likely to have collected all contaminants.

All ponds will be suitably constructed with compacted clay and HDPE lining (or an equivalent) to prevent seepage of potentially contaminated water. Level gauges will be used to monitor pond water levels and manage / direct run-off according to the stormwater management system described.

Water Supply

Potable water for the Proposal will be supplied by an external provider and will either be trucked to Site, or the provider will establish a connection to an existing supply line on the Old Coast Road.

Up to 150 m3/hr of process water will be required when the Plant is in full production (30 m3/hr per process train). A number of water sources will meet this requirement:

Stormwater

Non-potable water service provider; and


Process Water Recycling.


Table 3-7 Hydrological Processes – Objectives and KPIs

EPA Objective: To maintain the hydrological regimes of groundwater and surface water so that environmental values are protected

Proposal Key Performance Indicator

Prevent deleterious impacts on surface water and groundwater

Flow capacity maintained and groundwater / surface water quality within the background (pre-development) range.

No flooding evident within the Proposal area.

No impacts to adjacent wetlands – as per the site Water Management Plan specifications.

Minimise impacts to wetlands and groundwater dependent vegetation

Maintain the local / regional hydrology


Table 3-8 Hydrological Processes – Management Actions and Targets

Management actions Management targets Monitoring

Pre-development Prepare a Water Management Plan after initial groundwater sampling. Management Plan prepared that is

congruent with the OWMS. Audit compliance

Wetland Management Wetlands adjacent to the Proposal area will be managed in accordance with and guided by information provided in the Wetland Risk Analysis which accompanies the OWMS (RPS 2016), including (but not limited to): • Pre-development groundwater monitoring will be undertaken• Post-development groundwater monitoring will be undertaken over a

minimum of 5 years and as per EP Act part V Environmental Licencerequirements

• Opportunistic surface water flow monitoring will occur (i.e. after first flushevents)

• Roadside swales to be rated to 24 h 10% AEP (equivalent to 1:10 year ARIstorm event).

To be developed following pre-construction monitoring.

A Wetland Monitoring Programme will be prepared and implemented. This will include groundwater and surface water monitoring.

Construction – Drain Diversion • Construction of the drain diversion to occur in the dry season (December –

April) if practicable• The existing drain will not be impacted or infilled until construction of the

drain diversion is completed• Construction works within the drain diversion will be prioritised to ensure

the duration of any impacts are minimised• A Dewatering Management Plan will be developed if required.

Construction of the drain diversion will not result in detrimental impacts to the environment.

Audit compliance with timing through construction. Visual inspection for erosion / ASS during construction. Dewatering Management Plan to be developed if required.

Operations – Stormwater / Water Storage Ponds • In the event that Ponds on the site are filled (during an extreme event > 24

hour AEP 1% rainfall event) water shall be diverted away from the pondsand discharged from the Site in a controlled manner to avoid erosion andsedimentation impacts within and downstream of the Site. Control methodswill be documented in a site specific Water Management Plan.

Release of stormwater from the Site not result in detrimental impacts to the environment.

Audit compliance through operations.

• Water storage ponds levels will be monitored to call attention to potentialissues.

Collected stormwater will not overflow of leak from ponds

Monitorfreeboardof ponds through operations.

Contingencies and Corrective Actions



If flooding or overflow of ponds occurs on site, during construction or operations: 1. Investigate the cause/significance of the issue and raise an incident report if deemed necessary2. Attempt to contain flooding if practicable (i.e. use of bunding to re-direct floodwaters away from contaminated areas or areas susceptible to erosion)3. Determine if rehabilitation is required (i.e. if soil erosion is evident)4. Develop and implement a rehabilitation plan if necessary and consult the relevant government regulator as required5. Monitor effectiveness of controls.If monitoring identifies a non-compliance:• Investigate cause and raise an incident report• Implement contingency actions which may include:

– Review practicality and relevance of management measures– Improve training and education for all personnel– Improve and implement increased protective measures as necessary– Improve methods for marking clearing lines– Install additional temporary fencing or signs.

• Monitor outcomes.Supplementary Studies and Reports Groundwater and surface water level investigation – pre-development A Water Management Plan will be developed after pre-development monitoring On-going groundwater and surface water monitoring will occur during development and operations. Annual Environmental Review for Part V EP Act licence (submitted to DWER)


3.5 Inland Waters Environmental Quality


The following aspects have been identified as requiring management to minimise the potential for impacts to inland waters environmental quality:

Construction

• Erosion, sedimentation, scouring of the diverted drain or release of excessively turbid water

• Changes to groundwater levels in the Superficial aquifer associated with vegetation clearingand diverting the drain, potentially leading to salinisation

• Contamination of surface water and groundwater as a result of spills of contaminatedmaterial or stormwater run-off and exposure to PASS.

Operations

• Contamination of surface water and/or groundwater due to seepage or release ofcontaminated water


Management of Inland Water Environmental Quality outlined within this document are congruent with the KSIA OWMS.

No further specific management measures for Inland Waters Environmental Quality are required as management measures detailed in the following section will address potential impacts:

Section 3.3 for Terrestrial Environmental Quality: provides provisions for hydrocarbon /chemical and waste and erosion management

Section 3.4 Hydrological Processes: stormwater and wetland management

Section 3.6 Air Quality: contamination from dust.


Table 3-9 Inland Waters Environmental Quality – Objectives and KPIs

EPA Objective: To maintain the quality of groundwater and surface water so that environmental values are protected


Prevent deleterious impacts on surface water and groundwater

Groundwater / surface water quality within the background (pre-development) range.


Table 3-10 Inland Waters – Management Actions and Targets

Management actions Management targets Monitoring Design / Pre-construction Baseline monitoring will be undertaken for groundwater quality prior to construction. Surface water quality monitoring will be undertaken on an opportunistic basis (i.e. following first flush events).

To be established based on monitoring

Monitor to establish baseline conditions

Construction Management measures outlined in other Sections of this EMP address potential construction impacts to water quality and will be included in the CEMP.

As per CEMP requirements in other sections of the EMP

As per CEMP requirements in other sections of the EMP

Operations Ongoing groundwater quality monitoring and opportunistic surface water quality monitoring will occur in compliance with the OWMS (RPS 2016). This will include • Groundwater monitoring to occur for a minimum for 5 years• Surface water monitoring to occur on an opportunistic basis (i.e. following

first flush events)• Water quality will be compared to the ANZECC (2000) freshwater guidelines• Trigger values for the site will be calculated by adding 20% to the median

value calculated from baseline monitoring• Contingency measures will be implemented in the event of triggers values

being exceeded in two consecutive monitoring events.

Monitoring is conducted and trigger values are not exceeded

As per Water Management Plan

Avoidance of contaminated stormwater discharge impacts through the site’s capture and reuse of stormwater and process wastewater. All potentially contaminated water will report to lined ponds for treatment and reuse or evaporation.

Zero discharge of stormwater – unless via controlled discharge (see Section 3.4.2)

Automated monitoring of pond water levels with associated alarms.

Minimisation of potentially contaminated water releases through monitoring of levels, inspections for water storage areas and high level alarms. Contingencies and Corrective Actions If monitoring identifies a non-compliance: • Investigate cause and raise an incident report• Implement contingency actions which may include:

– Review practicality and relevance of management measures


Management actions Management targets Monitoring – Improve training and education for all personnel – Improve and implement increased protective measures as necessary – Improve methods for marking clearing lines – Install additional temporary fencing or signs.

Monitor outcomes. Supplementary Studies and Reports Groundwater and surface water level investigation – pre-development. A Water Management Plan will be developed and implemented after pre-development monitoring. On-going groundwater and surface water monitoring will occur during development and operations. Annual Environmental Review for Part V EP Act licence (submitted to DWER and Shire of Harvey)


3.6 Air Quality


The following aspects have been identified as requiring management to minimise the potential for impacts air quality

Construction

• Vegetation clearing and earthmoving that has the potential to generate dust emissions.

• Operation of vehicles and machinery will produce dust, combustion and greenhouse gasemissions.

Operations

• Operation of vehicles and machinery will produce combustion and greenhouse gasemissions.

• Operation of the Plant will produce process and greenhouse gas emissions.

• Health or aesthetic impacts to sensitive receptors due to pollutant and/or dust emissions.

3.6.2 Management Actions and Targets

Design / process plant selection air quality management

The Albemarle Kemerton Plant has been designed to include emission control measures considered to be Best Available Techniques (BAT) in accordance with the European Commission Industrial Emissions Direction Best Available Techniques Reference Document for the Non-Ferrous Metals Industries.

The objectives and KPIs are provided in Table 3-11 and management actions, targets and monitoring are provided in Table 3-12.


Table 3-11 Air Quality – Objectives and KPIs

EPA Objective: To maintain air quality and minimise emissions so that environmental values are protected.


Ensure impacts to air quality are reduced to as low as reasonably practical.

Equipment, technology and processes selected that reduce emissions and have high environmental performance

Minimise the generation of fugitive dust emissions during construction and operation

No evidence of dust impact on adjacent vegetation, buildings, structures, roads as assessed by opportunistic observations.

Minimise the generation of dust emissions from all material handling and storage areas including spodumene ore concentrate, acid roasted solids, tailings, Lithium Hydroxide Product and Sodium Sulfate By-product, and dust producing reagents.

Minimise the generation of dust emissions along transport routes

Comply with the National Environment Protection (Ambient Air Quality) Measure

No non-compliances with the National Environment Protection (Ambient Air Quality) Measure


Table 3-12 Air Quality – Management Actions and Targets

Management actions Management targets Monitoring Design The Proposal has been designed to minimise the generation of dust, atmospheric emissions, and greenhouse gas (GHG) emissions including the following features: • All dust forming materials will be stored in covered storage or silos/bins.

This includes spodumene ore concentrate, acid roasted solids, tailings,Lithium Hydroxide Product and Sodium Sulfate By-product, and dustproducing reagents.

• All Lithium Hydroxide Product and Sodium Sulfate By-product producedby the plant will be packaged in enclosed, lined bags and transported inenclosed containers.

• All transfer and delivery points will either be enclosed or have dustextraction.

• Where practical emissions including SO3 gas from the roast kiln anddust from baghouses are recycled back into process

• All conveyors outside of buildings will be enclosed or covered to preventwater ingress and dust egress.

• The maximum conveyor speed is predicted to be 1 m/s• Bag filters and/or cyclones are included for the following process stacks

or vents:o Calciner;o Ball mill;o Roast cooler; ando Sodium sulfate dryer.

• A four stage scrubbing circuit for the Roaster.• The Lithium hydroxide monohydrate dryer and cooler will have a wet

spray scrubber.• Energy efficiency will be a consideration when selecting and designing

plant and buildings.• Stacks will be suitably designed to allow for installation of sampling

ports with are compliant with AS 4323.1 and the DER CEMS code somonitoring can be undertaken.

No evidence of deposited dust in the environment surrounding Albemarle Kemerton Plant as a result of air emissions from the Plant.

Plant will either have continuous monitoring or a spot sampling program linked to parametric monitoring for air emission abatement equipment in accordance with Part V EP licence requirements.

Construction – Dust and GHG


Management actions Management targets Monitoring The CEMP will include management measures for dust, that will include but not be limited to: • Dust suppression measures will be regularly implemented on the site

during the construction phase • Daily monitoring of meteorological conditions to identify and prepare or

modify operations for conditions which increase the risk of windblown dust

• During high winds, if dust is being generated, earthmoving will be restricted if dust cannot be adequately managed.

• If required (and practicable), construction material shall be dampened • Clearing will be undertaken progressively to minimise the extent of soil

exposed • Vehicle speeds will be restricted to 25 km/h to minimise the generation

of dust • Establishment of a complaints register • The construction site shall be kept clean to minimise dust accumulation

within and surrounding the area

No complaints received from the community for dust generation during the construction phase. Vehicle speeds will be restricted to minimise the generation of dust.

Complaints register. Daily weather observation Daily visual checks for dust.

GHG emissions will be minimised through: • Vehicles and equipment will be maintained in accordance with

manufacturer’s specifications to minimise exhaust emissions. • Low emissions producing equipment will be selected (if possible).

Minimise GHG emissions Audit maintenance record for equipment

Operations – Dust, Atmospheric, and GHG emissions There will be no visible process generated dust on vehicle wheels leaving the site. Washdown or other suitable technique will be provided if necessary.

No visible dust from vehicles leaving the site.

Complaints register. Audit – washdown and dust management practices.

Minimisation of dust emissions during transport through enclosed or covered transport vehicles (tailings being an exception due to high moisture content unless drying of the surface causes dust) and sealed packaging and secondary containment of Lithium Hydroxide Product and Sodium Sulfate By-product . The shortest and safest routes will be identified for transport operations.

No dust emissions during transportation. Complaints register. Audit compliance

Ensure transport operators have effective emergency response plans and capability to respond to major and minor releases of trucked materials.

No spills occur without immediate action undertaken.

Operator pre-engagement review of response plans. Audit operator response / management.


Management actions Management targets Monitoring Dust on internal and surrounding roads will be prevented through operational controls. If required, road sweeping campaigns will be included within operational procedures for the site as a contingency.

No complaints received regarding dust on internal / external roads.

Complaints register. Visual checks.

GHG emissions will be minimised through: • Vehicles and equipment will be maintained in accordance with

manufacturer’s specifications to minimise exhaust emissions. • Low emissions producing equipment will be selected (if possible).

Minimise GHG emissions Audit maintenance record for equipment

Atmospheric emissions will be minimised through operation and maintenance of pollution control equipment in accordance with manufacturer’s specifications.

Atmospheric emissions comply with any regulatory limits set

Audit maintenance record for plant and equipment

Contingencies and Corrective Actions If there is a non-compliance with management actions or a community complaint: • Immediately investigate the cause of the non-compliance/complaint and take preventative actions to prevent further occurrences • Review practicality and relevance of management measures • Improve and implement increased protective measures as necessary • Consider further education of staff / contractors to ensure understanding and precent any re-occurrence If complaints are received these shall be managed to ensure a rapid response occurs. Supplementary Studies and Reports CEMP – to be prepared by the contractor. A complaints register will be developed and maintained. Vehicle / machinery / plant / equipment maintenance schedule to be prepared. Annual Environmental Review for Part V EP Act licence (submitted to DWER) Baseline Air Quality Assessment (pre-construction)


3.7 Social Surroundings


The following aspects have been identified as requiring management to minimise the potential for impacts to social surroundings

Construction

Heritage site disturbance during clearing and/or excavation works

Changes to land use within the Proposal area

Noise impacts to sensitive receptors, from noise emissions generated by construction activity on the site (equipment and vehicle operation, increased traffic on local road network)

Reduced visual amenity where construction occurs in areas visible from the road network.

Operations

Noise impacts to sensitive receptors through increased noise emissions from 24/7 operation of equipment and machinery

Noise impacts to sensitive receptors through increased traffic on local networks

Reduced visual amenity from stack air emissions and general processing activities

Socio-economic impacts (positive).

3.7.2 Management Actions and Targets


Table 3-13 Social Surroundings – Objectives and KPIs

EPA Objective: To protect social surroundings from significant harm.


Ensure noise emissions from the Albemarle Kemerton Plant comply with the Environmental Protection (Noise) Regulations 1997

Zero public complaints relating to noise associated with the Albemarle Kemerton Plant

Comply with the requirements of the Aboriginal Heritage Act 1972 including obtaining a Section 18 approval, if required

Records of site inspections/monitoring.

Protection of unknown heritage sites.

.


Table 3-14 Social Surroundings – Management Actions and Targets

Management actions Management targets Monitoring Design – Noise and Odour • Noisy plant will be identified at the detailed design stage. The primary noise sources

identified will be enclosed in a sound proofing structure to ensure noise levels do notexceed 85 dBA at a distance of 1 m from the equipment.

• Anti-vibration supports and interconnections will be used where required.• Re-orientation of primary noise sources will be undertaken if feasible where it is shown

to significantly reduce noise emissions.

Design to incorporate noise and vibrations controls.

Compliance with conditions in design criteria.

Odour: There Is not expected to be odours from the process under normal conditions however, odour could occur in the event of an ammonia leak. Low charge systems will be used to minimise the volume of ammonia directed into the process. Ammonia is the only odorous material which will be used in the process Ammonia will be stored within an appropriately designed pressure vessel.

Design to incorporate odour controls. Compliance with conditions in design criteria.

Design – Aboriginal Community Consultation Undertake consultation with the local Aboriginal community and archaeologists outlining the intended design, construction methods and timing. In particular, discuss: • Impacts to wetlands• Stormwater and drainage management• Employment opportunities• Naming of roads (if applicable)• Requirement for supplementary heritage surveys.Due consideration will be given to requests made by Aboriginal people regarding theprotection of Aboriginal Heritage and the recognition of Aboriginal culture and heritage.

Maintain communication with Aboriginal community representatives.

Stakeholder register to include details of communication.

Construction - Noise


Management actions Management targets Monitoring The CEMP will include management measures for noise, including: • Workforce inductions will include education in relation to the minimisation of noise and

vibration• Selecting machinery and adopting operational practices that will produce the lowest

practical level of noise and vibration• Construction activities (including materials transport) shall be limited between 0700 and

1900 Monday to Sunday, excluding public holidays (standard work hours) unless thefollowing is adhere to:

• Where construction activities are required outside of approved operating hours:– Prepare a Noise Management Plan (NMP)– Obtain approval for the NMP from the Shire of Harvey– Ensure all nearby residents are notified prior to works, with details of time period of

activity and summary of why the activity is required outside of usual hours– Reduce noise emissions as much as practicable.

• Maintenance schedules shall be followed to ensure that all equipment is in goodcondition

A complaints register shall be established and maintained.

Zero public complaints relating to noise associated with the Albemarle Kemerton Plant.

Integrity of machinery and vehicles during Pre-starts. Noise monitoring if complaints received.

Aboriginal Heritage - Construction



The CEMP will include management of Aboriginal heritage, including: • The induction shall address Aboriginal Heritage, including staff obligation with regards

to unknown heritage sites and values pursuant to the Aboriginal Heritage Act 1972 • If objects of significance to the Aboriginal community are found those works will cease

immediately and the sites will be investigated • A suitably qualified archaeologist will be engaged to assist with advice, consultation and

investigation of Aboriginal heritage matters as required • Management of any concerns surrounding Aboriginal heritage through consultation with

the South West Aboriginal Land and Sea Council • Should any Aboriginal heritage objects be identified they will be salvaged and managed

according to the advice from the archaeologist and Aboriginal community • If suspected skeletal remains are found, works will ceases and the incident be reported

immediately to the WA Police Service and Department of Planning, Lands and Heritage (DPLH). Works will not resume until the Police, DPLH and archaeologist are satisfied with the management.

The location and details of any newly discovered objects or remains will be reported to the DPLH.

Maintain communication with Aboriginal community representatives. Protection of unknown heritage sites.

Stakeholder register to include details of Aboriginal heritage consultation. Environmental incident register to include information on any uncovered heritage material, consultation, management and outcomes.

Operations - Noise During operations noise and odour will be managed through: • Selecting machinery and adopting operational practices that will produce the lowest

practical level of noise, odour and vibration. Maintain machinery / plant / equipment • All equipment which exceeds 85 dBA at a one metre distance will be established within

an acoustic enclose or suitable cladding • Consideration of bus services for Bunbury-based employees to reduce traffic and noise

impacts • Consideration of optimising truck movements to minimise night-time operations (for

later stages of operation) • Site operational procedures will be applicable to the use of ammonia and the

maintenance and operation of the ammonia storage vessel. The vessel will be included in the site maintenance and inspection schedule to detect potential problems.

Zero public complaints relating to noise / odour associated with the Albemarle Kemerton Plant.

Integrity of machinery / equipment / plant as part of maintenance schedule. Ad hoc noise monitoring if complaints received. Ongoing noise monitoring most affected sensitive receptor/s.

Operations – Visual Maintain vegetation buffers and planting of vegetation along boundaries to assist in screening the Proposal area where the Plant is visible to the Public.

Corrective Actions and Contingencies


Management actions Management targets Monitoring If there is a non-compliance with management actions or a community complaint: • Immediately investigate the cause of the non-compliance/complaint and take

preventative actions to prevent further occurrences • Review practicality and relevance of management measures • Improve and implement increased protective measures as necessary • Consider further education of staff / contractors to ensure understanding and precent

any re-occurrence If complaints are received these shall be managed to ensure a rapid response occurs.

Supplementary Studies and Reports A complaints register will be developed and maintained. Vehicle / machinery / equipment maintenance schedule to be prepared. Stakeholder register to be maintained. CEMP – to be prepared by the contractor. Annual Environmental Review for Part V EP Act licence (submitted to DWER)


4. Adaptive Management The adaptive management approach aims to reduce impacts by embedding a cycle of monitoring, reporting and implementing change (where required). This document applies the principles of adaptive management through monitoring, corrective actions and implementing changes. The EMP is intended to be dynamic and will be updated to reflect changes in management practices and the social and natural environment with time. This will also allow flexibility to respond new environmental impacts and adopt new technologies / management measures. Adaptive management has been embedded throughout this document, and the key adaptive management processes are described below.

4.1 Benchmarking and Best-Practise

As part of the design process, benchmarking of the proposed activities has been undertaken, through comparison to the current available information, including:

Comparison of the Albemarle Kemerton Plant process, emissions and controls with the Tianqi Lithium Hydroxide Process Plant currently under construction in Kwinana WA. Information for this comparison was sourced from the Tianqi 2017 Works Approval Application submitted to the Department of Water and Environmental Regulation (Tianqi 2017)

Literature review to identify any recently constructed lithium plants or other industrial process plants in WA which use comparable techniques to the proposed Albemarle Kemerton Plant

Comparison of the Albemarle Kemerton Plant with the European Commission Industrial Emissions Directive Best Available Techniques Reference Document for the Non-Ferrous Metals Industries (BREF Document). (GHD 2017e)

The design of the Plant was informed by, and management measures were developed based on, the outcomes of these benchmarking activities.

Albemarle is committed to continually improving the performance of its operations, and throughout the life of this Project will seek to procure equipment / plant / materials that demonstrate high environmental performance.

4.2 Environmental monitoring and corrective actions

Environmental monitoring and corrective actions are included within Section 3 for each aspect. This includes a combination of automated monitoring within the processing plant and on-ground monitoring throughout the construction and operational phases.

If environmental monitoring identifies a non-conformance with environmental conditions / EMP targets / relevant legislation or guidelines the incident will be reviewed and corrective actions implemented. These corrective actions will include changes to equipment / processes / management measures if required. Any changes to processes / management will be updated in the EMP. These changes will be communicated through site inductions / toolbox meetings.

4.3 Audits

To ensure the management measures outlined in this EMP are being adequately implemented and comply with relevant design and environmental standards, regular environmental audits will be undertaken. Auditing of the commitments outlined in this EMP will be undertaken as follows:

Regular system audits of the EMS and compliance procedures, including


– Prior to construction commencing – review of CEMP for compliance with the EMP andenvironmental conditions

– At completion of construction to identify and correct any non-conformances

– Yearly as part of the Annual Environmental Review

Regular site CEMP compliance inspections including audits of key Contractors’environmental management and monthly inspections. The Contractor will carry out weekly /daily compliance checks as per the CEMP

Persons responsible for environmental auditing will be suitably qualified.

A progress and compliance report will be prepared following the completion of each audit to document the effectiveness of the environmental management measures that have been implemented. Any non-compliance will be highlighted and addressed. Where audit finds show environmental management actions are not effective, the audit may recommend changes to procedures.

4.4 EMP Revision

The EMP review will take into account the adaptive management and continual improvement process. The EMP will be revised on an annual basis, with the overall EMP comprehensively reviewed every 5 years. These reviews will be based on assessment of monitoring trends, the social and natural environment, industry standard management practices and changes to regulations and/or regulatory requirements.

When operational the Site will fall under Albemarle's corporate HSE audit procedure 03-1007, to ensure its ongoing compliance to legal and other requirements of HSE systems at Albemarle facilities.


5. Stakeholder Register 5.1 Stakeholder management

5.1.1 Environmental stakeholders

The stakeholders who have a particular interest in the environment surrounding the Proposal Area will be consulted as required. Consultation will be undertaken individually unless requested otherwise. The following is a preliminary list of likely stakeholders:

Shire of Harvey

Department of Water and Environment Regulation (DWER)

LandCorp

Department of Planning, Lands and Heritage (DPLH)

Department of Jobs, Tourism, Science and Innovation (DJTSI)

Leschenault Catchment Council

Kemerton Industrial Park Consultative Committee

In preparing this EMP the following consultation specific to the preparation of the EMP has been undertaken. The consultation table below is an ongoing record of consultation undertaken relating to the EMP and will be updated as consultation relating to environmental management occurs.

Table 5-1 Albemarle Kemerton Plant EMP stakeholder consultation record

Stakeholder Date Type of Consultation

Persons Involved

Summary of Communication

Comments Received

5.1.2 Communications and stakeholder register

Environmental performance will be reported through the EP Act Part V licence reporting including an Annual Compliance Report and Annual Environmental Report.

Albemarle will maintain a stakeholder register, which documents communication with environmental stakeholders, any issues / concerns raised and the outcome of the consultation.

A Project Complaint and Response system shall be implemented to establish and maintain a system of records, documenting all information of complaint handling (see Section 2.1.4).


6. ReferencesANZECC 2000, ‘Australian and New Zealand Environment and Conservation Council (ANZECC) water quality guideline’. Prepared for or the Australian and New Zealand Environment and Conservation Council and the Agriculture and Resource Management Council of Australia and New Zealand.

Aquaterra 2002, ‘Kemerton Water Study Phase 2. Report Prepared for Kemerton Technical Working Group, comprising LandCorp, Department of Mineral and Petroleum Resources and the Water and Rivers Commission.

Department of Environment Regulation (DER) 2015, Identification and investigation of acid sulfate soils and acidic landscapes, revised June 2015.

Department of Sustainability, Environment, Water, Population and Communities (DSEWPaC) 2012. ‘National Pollutant Inventory: Emission Estimation Technique Manual for Mining’. Version 3.1.

Eco Logical Australia (ELA) 2015, ‘Kemerton Strategic Industrial Area: Overarching Environmental Management Plan’. Prepared for LandCorp.

Eco Logical Australia (ELA) 2017a, ‘Desktop Assessment of Selected Lots within Kemerton Industrial Area’. Prepared for S2V Consulting.

Eco Logical Australia (ELA) 2017b, ‘Kemerton Industrial Area: Additional Assessment of Proposed Access Road Area’. Prepared for S2V Consulting.

Eco Logical Australia (ELA) 2017c, ‘Kemerton Industrial Area Spring Flora and Fauna Survey’. Prepared for S2V Consulting.

Environmental Protection Authority (EPA), 2016. ‘Statement of Environmental Principles, Factors and Objectives’. Prepared for the Government of Western Australia. Retrieved September 2017 from: [http://www.epa.wa.gov.au/statement-environmental-principles-factors-and-objectives]

Environmental Protection Authority (EPA), 2017. ‘Instructions on how to prepare Environmental Protection Act 1986 Part IV Environmental Management Plans’. Prepared for the Government of Western Australia. Retrieved September 2017 from: [http://www.epa.wa.gov.au/forms-templates/instructions-part-iv-environmental-management-plans]

GHD 2017a, ‘Albemarle Kemerton Plant Environmental Referral Supporting Document’. Prepared for Albemarle Lithium Pty Ltd.

GHD 2017b. ‘Albemarle Kemerton Plant Air Quality Impact Assessment’. Prepared for Albemarle Lithium Pty Ltd.

GHD 2017c, ‘Albemarle Kemerton Plant Noise and Vibration Impact Assessment’. Prepared for Albemarle Lithium Pty Ltd.

GHD 2017d. ‘Albemarle Kemerton Plant Additional Area Biological Assessment ’. Prepared for Albemarle Lithium Pty Ltd.

GHD 2017e. ‘Albemarle Kemerton Plant Best Available Techniques Benchmarking’. Prepared for Albemarle Lithium Pty Ltd.

Goode, B. 2011, ‘A Site Identification Aboriginal Heritage Survey of the Proposed Kemerton Industrial Park in the Shire of Harvey, Western Australia’. Prepared for The South West Aboriginal Land & Sea Council (SWALSC).

Raymond, M, 2017, ‘Kemerton Strategic Industrial Area: Structure Plan’. Prepared by TPG for LandCorp and Department of State Development.


RPS 2016, ‘Kemerton Strategic Industrial Area: Overarching Water Management Strategy’. Prepared for LandCorp.

RUIC Fire 2016, ‘KSIA Bushfire Management Plan’. Prepared for Kemerton Strategic Industrial Area.

Tianqi Lithium Australia Pty Ltd (Tianqi) 2017. ‘Stage 2 Lithium Hydroxide Process Plant Works Approval W5955/2016/1 Amendment Application’. Retrieved on 25 August 2017 from: [https://www.der.wa.gov.au/our-work/licences-and-works-approvals/lwaapplications]

William James Landscape Architect (WJLA) 2007, ‘Kemerton Strategy Plan Landscape Assessment Study’. Unpublished report prepared for LandCorp.

GHD Level 10 999 Hay Street T: 61 8 6222 8222 F: 61 8 6222 8555 E: [email protected]

© GHD 2017 This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited. 6136286-14811/N:\AU\Bunbury\Projects\61\36286\Final Drafts\FINAL Reports\6136286-REP_Environmental Management Plan_R0.docx

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