Amendment Notice 1 - der.wa.gov.au · This amendment is made pursuant to section 59 of the...

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Works Approval: W5977/2016/1 1 Works Approval Number W5977/2016/1 Works Approval Holder Tianqi Lithium Australia Pty Ltd ACN 612 085 364 File Number DER2016/001280 Premises Lithium Hydroxide Processing Plant 61 Donaldson Road KWINANA BEACH WA 6167 Lot 201 on Deposited Plan 407762 Certificate of Title Volume 2914 Folio 662 Date of Amendment 25 October 2017 Amendment The Chief Executive Officer (CEO) of the Department of Water and Environmental Regulation (DWER) has amended the above Works Approval in accordance with section 59 of the Environmental Protection Act 1986 as set out in this Amendment Notice. This Amendment Notice constitutes written notice of the amendment in accordance with section 59B(9) of the EP Act. Date signed: 25 October 2017 Jonathan Bailes A/Senior Manager Industry Regulation (Process Industries) an officer delegated under section 20 of the Environmental Protection Act 1986 (WA) Amendment Notice 1

Transcript of Amendment Notice 1 - der.wa.gov.au · This amendment is made pursuant to section 59 of the...

Works Approval: W5977/2016/1 1

Works Approval Number W5977/2016/1

Works Approval Holder Tianqi Lithium Australia Pty Ltd

ACN 612 085 364

File Number DER2016/001280

Premises Lithium Hydroxide Processing Plant

61 Donaldson Road

KWINANA BEACH WA 6167

Lot 201 on Deposited Plan 407762

Certificate of Title Volume 2914 Folio 662

Date of Amendment 25 October 2017

Amendment

The Chief Executive Officer (CEO) of the Department of Water and Environmental Regulation (DWER) has amended the above Works Approval in accordance with section 59 of the Environmental Protection Act 1986 as set out in this Amendment Notice. This Amendment Notice constitutes written notice of the amendment in accordance with section 59B(9) of the EP Act.

Date signed: 25 October 2017

Jonathan Bailes

A/Senior Manager Industry Regulation (Process Industries)

an officer delegated under section 20 of the Environmental Protection Act 1986 (WA)

Amendment Notice 1

Works Approval: W5977/2016/1 2

Definitions and interpretation

Definitions

In this Amendment Notice, the terms in Table 1 have the meanings defined.

Table 1: Definitions

Term Definition

ACN Australian Company Number

Application refers to the Works Approval amendment application lodged by the Works Approval Holder on 4 August 2017

Category/ Categories/ Cat. categories of Prescribed Premises as set out in Schedule 1 of the EP Regulations

CEO means Chief Executive Officer

Decision Report refers to the Decision Report attached to Works Approval W5977/2016/1 granted on 21 September 2017

Delegated Officer an officer under section 20 of the EP Act

Department means the department established under section 35 of the Public Sector Management Act 1994 and designated as responsible for the administration of Part

V, Division 3 of the EP Act.

DWER Department of Water and Environmental Regulation

EPA Environmental Protection Authority

EP Act Environmental Protection Act 1986 (WA)

EP Regulations Environmental Protection Regulations 1987 (WA)

Hydro hydrometallurgical

LHPP Lithium Hydroxide Processing Plant

Minister the Minister responsible for the EP Act and associated regulations

MS Ministerial Statement

NEPM refers to the National Environmental Protection (Ambient Air Quality) Measure

Noise Regulations Environmental Protection (Noise) Regulations 1997 (WA)

Occupier has the same meaning given to that term under the EP Act.

PM Particulate Matter

PM10 used to describe particulate matter that is smaller than 10 microns (µm) in diameter.

Prescribed Premises has the same meaning given to that term under the EP Act.

Premises refers to the premises to which this Decision Report applies, as specified at the front of this Decision Report.

Works Approval: W5977/2016/1 3

Term Definition

Pyro pyrometallurgical

Risk Event as described in Guidance Statement: Risk Assessment

SDOOL Refers to the Sepia Depression Ocean Outfall Line that is the subject of MS 665 under Part IV of the EP Act

TAS Tianqi alumina silicates

tpa tonnes per annum

Works Approval refers to Works Approval W5977/2016/1 granted on 21 September 2016

Works Approval Assessment

refers to the Decision Report attached to the Works Approval as granted on 21 September 2016.

Amendment Notice

This amendment is made pursuant to section 59 of the Environmental Protection Act 1986 (EP Act) to amend the Works Approval issued under the EP Act for a prescribed premises as set out below. This notice of amendment is given under section 59B(9) of the EP Act.

This notice relates to amendments to increase the lithium hydroxide production capacity of the proposed Lithium Hydroxide Processing Plant (LHPP) from 24,000 tonnes per year (tpa) to 48,000 tpa.

The following guidance statements have informed the decision made on this amendment:

Guidance Statement: Regulatory Principles (July 2015)

Guidance Statement: Setting Conditions (October 2015)

Guidance Statement: Land Use Planning (February 2017)

Guidance Statement: Decision Making (February 2017)

Guidance Statement: Risk Assessment (February 2017)

Guidance Statement: Environmental Siting (November 2016)

Amendment description

Works Approval W5977/2016/1 (the Works Approval) was granted to the Works Approval Holder on 21 September 2016 to construct the LHPP, which will process spodumene ore concentrate into lithium hydroxide. Schedule 2 of the Works Approval specifies the works to be carried out at the Premises. The assessed lithium hydroxide production design capacity in granting the Works Approval was 24,000 tpa.

Construction of a duplicate pyrometallurgical (pyro) and hydrometallurgical (hydro) processing units to achieve a lithium hydroxide production capacity of 48,000 tpa was excluded from the Works Approval. However, the remainder of works for storage and handling of raw materials, lithium hydroxide product, waste by-products, stormwater and process wastewaters provisioned for a 48,000 tpa lithium hydroxide production capacity. The Works Approval also included construction of the hardstand for placement of potential duplicate processing units.

The Works Approval Holder lodged an application to amend the Works Approval on 4 August 2017 (the Application) to construct duplicate pyro and hydro processing units adjacent to the first units to increase the proposed lithium hydroxide production capacity to 48,000 tpa. The works to be carried out on the Premises will be the same as those outlined in Schedule 2 of

Works Approval: W5977/2016/1 4

the Works Approval, except that works will not just be limited to the “First Stage Pyro and Hydro Operations.”

The Works Approval Holder requested alterations to the Works Approval infrastructure requirements in Table 2 of Condition 8 of the Works Approval as a result of the duplicated processing units or minor variations to the proposed scope of works. Alterations relate to:

Duplication of pyro and hydro processing unit air emission points except that:

o no acid leach stack will be constructed on either set of processing units;

o a calciner refeed end stack and calciner refeed discharge end stack will be included on both sets of processing units;

o stack heights for the calciner fan stack, acid roast kiln stack, acid roast scrubber stack and sodium sulphate stack have been altered.

Update of the stormwater system to incorporate runoff from the additional pyro and hydro processing units; and

Infrastructure for proposed wastewater disposal to SDOOL including:

o revised pressure main specifications;

o increase in the wastewater storage tank capacity;

o increase in wastewater pump station pumpset flow capacity.

The duplication of pyro and hydro processing units and increase in lithium hydroxide production capacity will also increase waste by-production generation volumes as follows:

Sodium sulphate – increase from 43,900 tpa to 88,500 tpa;

Alumina silicates (TAS) – increase from 175,900 tpa to 345,250 tpa; and

Gypsum/limestone residues – increase from 26,100 tpa to 47,400 tpa.

Table 2 below details the relevant supporting information supplied by the Works Approval Holder and used in the assessment of the Application.

Table 2: Documents and information submitted to inform the assessment process

Document / information description Date received DWER document reference

Works Approval Amendment Application Form including:

Attachment A – Air Assessment

Attachment B – Noise Assessment

Attachment C – Water Supply and Wastewater Disposal Strategy

04/08/2017 A1503864

Email copy of air modelling input files associated with the Attachment A – Air Assessment

22/08/2017 A1512541

Email copy of land use planning approval from the Metro South-West Joint Development Assessment Panel

28/09/2017 A1532677

Email copy of additional noise and air assessment information in response to Delegated Officer queries via email on 22 September 2017

29/09/2017 A1532673

Works Approval: W5977/2016/1 5

Other approvals

Other approvals related to this Application are outlined in Table 3.

Table 3: Relevant approvals

Legislation Number Approval

Part IV of the EP Act MS 665 Granted to Water Corporation for the discharge of wastewaters to Sepia Depression via SDOOL. Condition 8 requires newly proposed discharges to be referred to EPA for consideration

Planning and Development (Local Planning Schemes) Regulations 2015

City of Kwinana Town Planning Scheme No.2

DAP/17/01261 Development approval for construction and use of stage 2 expansion

Air impact modelling

The Application included a revised air assessment and model to outline the predicted ground level impacts on receptors from the LHPP in isolation and cumulatively. As with the previous assessment, the most significant air quality impacts were expected from emissions of oxides of nitrogen (NOx) generated by the natural gas-fired kilns used in the heat treatment processes. The revised air assessment reflected a duplication of stack air emission points for the second pyro and hydro processing units with the following exceptions:

The leach stack has been removed from the design on both sets of processing units;

A calciner refeed end stack, and calciner refeed discharge end stack have been included in the design of both processing units (i.e. four stacks in total); and

Stack height variations on both sets of processing units.

The air assessment concluded that the leach stack, calciner refeed end stack, and calciner refeed discharge end stack did not contribute to the emissions of combustion gases or particulates; therefore, these changes were considered immaterial to the modelling outcomes.

The Delegated Officer sought clarification from the Works Approval Holder on the context of the air emission input values used in the model and what they represent in terms of plant operating conditions and potential emissions variability. The Works Approval Holder advised that the modelled air emissions were based on a steady state processing plant operating at full capacity. The Works Approval Holder does not expect significant variation in emissions as system redundancy, continuous monitoring, and process unit controls means that upset conditions are unlikely.

A comparison of predicted emission ground-level impacts at the nearest dwelling in Medina against NEPM standards is shown in Table 4 below.

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Table 4: Predicted cumulative ground-level impacts at the nearest dwelling (Medina)

Parameter Standard (µg/m3) Background value (µg/m3)

Modelled value (µg/m3)

Referenced Guideline

NOx 247 (1-hr max) 41 47.7 Air NEPM

SO2

572 (1-hr max) 39 39.1

Air NEPM

229 (24-hr max) 39 39

CO 11,254(8-hr max) 458 460 Air NEPM

PM (as PM10) 50 (24-hr max) 20.7 21.1 Air NEPM

Noise impact modelling

The Application included a revised noise assessment and model based on the original noise assessment. In the Works Approval Assessment, it was concluded that noise from the LHPP would comply with assigned noise levels specified in the Noise Regulations during the operational phase, subject to the Works Approval Holder implementing its proposed noise attenuation measures. The modelling found that LA10 noise levels during normal operations under normal and worst case meteorological conditions would be 10 dBA and 14 dBA respectively, below the assigned 35 dBA assigned level for the nearest highly sensitive premises in Medina.

The revised noise assessment, including additional information provided on 29 September 2017, confirmed that there had been some changes in estimated equipment sound power levels and that there would be an expected decrease in overall noise emissions. Specifically, the Works Approval Holder advised that it had removed some noise sources (calcine oversize crusher and microniser lithium hydroxide), applied acoustic treatments to other source sources to lower emissions (i.e. ball mill (calciner), fan and centrifuge units), and confirmed other sound power levels with vendors as a ‘not to be exceeded’ value.

The Delegated Officer queried the significant decrease in sound power level assigned for the ‘Truck B-double’ from 104 dBA in the original noise assessment to 85 dBA in the revised noise assessment. The Works Approval Holder acknowledged that such a change might not be justified and replaced the revised value with the original 104 dBA and re-ran the model with no other parameter or input value changes. A comparison of predicted noise levels against relevant assigned levels from the Noise Regulations is provided in Table 5 and includes both ‘Truck B-double’ sound power level scenarios for reference.

Works Approval: W5977/2016/1 7

Table 5: Predicted night LA10 noise levels (dB) during normal operating conditions

Receptor

Assigned night LA10 level

(dB)1

Predicted level – neutral conditions

(dB)

Predicted level – worst case

(dB)

Truck B double (85

dBA)

Truck B double (104

dBA)

Truck B double (85

dBA)

Truck B double (104

dBA)

Medina 35 10 10 13 14

North boundary

75

75 76 75 76

East boundary 60 62 61 63

South boundary 60 61 61 62

West boundary 55 56 57 59

Note 1: From Table 1 in r 8 of the Noise Regulations

The Noise Regulations specify that noise emissions are taken to significantly contribute to a level of noise if the noise emissions exceed a value which is 5 dB below the assigned level at the point of reception. A predicted worst-case noise level of 14 dB at the nearest sensitive receptor in Medina is below the assigned level (35 dB) and, therefore, will not significantly contribute to noise at that receptor.

Location and receptors

The previous Works Approval Assessment identified receptors as shown in Table 6. No new receptors or sensitive land uses have been identified.

Table 6: Receptors and distance from activity boundary

Residential and sensitive premises Distance from LHPP

Closest dwelling 2.35 km south-east in the residential suburb of Medina

Table 7 and Table 8 below list the relevant environmental receptors and groundwater resources in the vicinity of the LHPP, which may be receptors relevant to the Application.

Table 7: Environmental receptors and distance from activity boundary

Specified Ecosystem Distance from LHPP

Wetlands of International Significance – Forrestdale and Thompsons Lakes

Approx. 7.3 km northeast

Wetlands of national and regional significance – Spectacles North

Approx. 4.8 km east

Geomorphic Wetlands There are six Conservation category and nine Resource Enhancement or Multiple Use category wetlands located between 1 km and 4.7 km from the Premises.

Table 10 in the Works Approval Assessment contains additional information.

Cockburn Sound Approx. 1.2 km west

Works Approval: W5977/2016/1 8

Table 8: Groundwater distance and environmental value

Groundwater distance from LHPP Environmental value

Groundwater encountered at 6 m relative to groundwater level or 1 m relative to AHD.

Estimates may fluctuate between 0.5 m and 3 m due to seasonal variation and tidal variation / influence.

Groundwater contours indicate flow direction conservatively east to west towards Cockburn Sound

Groundwater salinity (as TDS) is between 1500 and 3000 mg/L and considered brackish.

The site is within the Kwinana Industrial Area which is described as unsuitable for domestic garden bores.

There are no sensitive groundwater resources on or near the Premises. Water is not used for potable use.

Consultation

The Delegated Officer publically advertised the Application seeking submissions from interested parties. The Delegated Officer also identified two external stakeholders that may have a direct interest in the subject matter of the application and wrote to them seeking comments. This included the City of Kwinana in relation to land use planning matters and the Water Corporation in relation to the proposed discharge to the SDOOL under Ministerial Statement 665.

The City of Kwinana confirmed that a Development Assessment Panel application (Reference DA9014) had been received on 7 August 2017. It advised that the application appeared to be consistent with the Application and that it had no objections to that Application. Subsequent to the City of Kwinana advice, the Works Approval Holder provided the Delegated Officer with a copy of the development approval for the construction and use of the duplicated pyro and hydro processing units, granted by the Metro South-West Joint Development Assessment Panel on 15 September 2017.

The Water Corporation advised that the proposed discharge to SDOOL remained within the bounds of the original Works Approval application and was still considered acceptable. The Water Corporation advised the Application indicated that mixing of LHPP wastewater and SDOOL wastewater would result in minimal impact on total volume or contaminant concentrations. The Water Corporation confirmed its previous advice that acceptance of the LHPP wastewater was subject to an Effluent Services Agreement and any responsibilities in Water Corporation’s SDOOL Monitoring and Management Plan.

The former Office of the EPA was amalgamated with the former Department of Water and Department of Environmental Regulation on 1 July 2017 to form DWER. The Delegated Officer sought comment from DWER’s EPA Services who advised that it had not yet received any referral from Water Corporation. EPA Services considered that Water Corporation should be consulted to provide advice in regards to whether it is able to accept the wastewater and continue to meet the outfall requirements of the SDOOL. The EPA will determine if the proposal referred subject to condition 8 of MS 665 will be assessed as a significant proposal under Part IV of the EP Act.

Risk assessment

Table 9 and Table 10 below describe the Risk Events associated with the amendment consistent with the Guidance Statement: Risk Assessments. Both tables identify whether the emissions present a material risk to public health or the environment, requiring regulatory controls.

Works Approval: W5977/2016/1 9

Table 9: Risk assessment for proposed amendments during construction

Risk Event Consequence rating

Likelihood rating

Risk Reasoning Potential emissions Source/Activities

Potential receptors

Potential pathway

Potential adverse impacts

Category 44: Metal smelting and refining

Fugitive dust associated with construction activities

Civil earthworks, wind erosion from disturbed soil surfaces, vehicle movements and infrastructure construction

Closest dwelling 2.35 km south-east in Medina

Air / wind dispersion

Health and amenity Moderate Possible Medium The Works Approval Holder included hardstand pad construction within the scope of the Works Approval as provision for a potential future duplication of pyro and hydro processing units. The specific additional works proposed by the Works Approval Holder do not present additional potential sources of fugitive dust during construction. The Delegated Officer also considers that there is sufficient separation distance to receptors and determined that the overall construction fugitive dust risk remains Medium (refer to section 9.5 of the Works Approval Assessment).

The Delegated Officer determined that existing controls on the Works Approval (Condition 9) remain adequate to address the risk of fugitive dust impacts during construction.

Noise associated with construction activities

Civil excavation / earthworks, building construction, equipment fabrication / installation, waste removal and construction materials transfer

Amenity Moderate Unlikely Medium The Delegated Officer reviewed the Noise Assessment included with the Application and was satisfied that the additional works do not change the conclusion of the previous assessment that construction noise would comply with the Noise Regulations.

Table 10: Risk assessment for proposed amendments during operation

Risk Event Consequence rating

Likelihood rating

Risk Reasoning Potential emission Sources/Activities

Potential receptors

Potential pathway

Potential adverse impacts

Category 44: Metal smelting or refining

Fugitive dust Raw material receipt, storage and handling

Lithium hydroxide bagging, handling and storage

Alumina silicates and gypsum residue by-product storage and handling

Alumina silicates and gypsum residue by-product storage and handling

Closest dwelling 2.35 km south-east in Medina

Air / wind dispersion

Health and amenity Moderate Unlikely Medium The Delegated Officer determined that there would be no change to the risk profile for operational fugitive dust impacts on receptors.

The proposed addition and operation of duplicate pyro and hydro processing units is not expected to be a potential source of fugitive dust. There are no proposed changes to other sources or activities that may generate fugitive dust during operations which are already the subject of design and construction requirements in Table 2 of the Works Approval.

Existing infrastructure requirements in Table 2 of the Works Approval address the risk of operational fugitive dust and remain adequate. No changes are required to the preliminary types of future licence controls summarised in Section 13 of the Works Approval Assessment are proposed.

Noise Raw material receipt, storage and handling

Processing and refining of materials including transfer through process

Product and waste-by-product storage and handling

Closest dwelling 2.35 km south-east in Medina

Air / wind dispersion

Amenity Moderate Unlikely Medium The Delegated Officer determined that there would be no change to the risk profile for operational noise impacts on receptors.

The Delegated Officer considered the Works Approval Holder’s revised noise assessment and modelling. Noise emissions are expected to comply with the assigned noise levels in the Noise Regulations and will not significantly contribute to noise levels at the nearest sensitive receptor in Medina.

Existing infrastructure requirements for the design of stationary equipment in Table 2 of the Works Approval address the risk of operational noise emissions and will apply to the duplicate pyro and hydro processing units.

Works Approval: W5977/2016/1 10

Risk Event Consequence rating

Likelihood rating

Risk Reasoning Potential emission Sources/Activities

Potential receptors

Potential pathway

Potential adverse impacts

Loss of process containment including stormwater contamination

Processing and refining of materials including transfer through process

Groundwater, potential hydraulic link to marine environment

Direct discharge and infiltration to groundwater

Impacts on the beneficial use of groundwater or marine ecosystem

Insignificant Rare Low The Works Approval Assessment identified the primary cause of operational impacts to be occasional small-scale discharges caused by spills, overflows or leaks. The Delegated Officer determined there would be no change to the risk profile.

Duplicate pyro and hydro processing units will be another source of potential spills, overflows, leaks and stormwater contamination; however, the same containment controls will be applied. The existing proposed stormwater system is designed to include the duplicated hydro and processing units. The Works Approval Holder has made minor variations to the system design.

No changes are required to preliminary types of future licence controls summarised in Section 13 of the Works Approval Assessment.

Point source emissions to air – combustion gasses and PM

Processing and refining of materials including transfer through process

Closest dwelling 2.35 km south-east in Medina

Air / wind dispersion

Health and amenity Minor Unlikely Medium The Delegated Officer considers that the NEPM ambient air standards are likely to be met during operation of the LHPP based on consideration of the Works Approval Holder’s air assessment. Exceedances of the NEPM and impacts on receptors will probably not occur in most circumstances if the Works Approval Holder implements its process monitoring and controls. While the overall risk remains unchanged, the consequence and likelihood ratings have been updated in accordance with the current version of Guidance Statement: Risk Assessment.

Cooling tower blowdown, boiler blowdown and demineralization plant reject water discharge into SDOOL

Wastewater storage and discharge Sepia Depression (Cockburn Sound)

Direct discharge Marine ecosystem impacts on Cockburn Sound

N/A N/A N/A Discharges to the Sepia Depression via SDOOL are regulated by MS665 granted to Water Corporation.

The Works Approval Holder is required to obtain an Effluent Services Agreement with Water Corporation, and condition 8 of MS665 requires all SDOOL discharge proposals to be referred to the EPA to determine whether the proposal requires more detailed assessment.

Works Approval: W5977/2016/1 11

Decision

Construction

The Delegated Officer determined that construction of the duplicate pyro and hydro processing units will not alter the risk of fugitive dust. Existing Works Approval condition 9 specifies fugitive dust management requirements during construction and remains adequate to address the risk.

Construction noise is expected to comply with the Noise Regulations.

Operation

The Delegated Officer determined there was no change to the risk profile for operational noise and fugitive dust emissions. The existing fugitive dust and noise infrastructure design requirements in condition 8, Table 2 of the Works Approval will apply to the duplicate pyro and hydro processing units and remain adequate to address the risk.

The Delegated Officer noted that the proposed stormwater system was assessed in granting the Works Approval and its design at that time incorporated the duplicated pyro and hydro processing units. The Works Approval Holder outlined minor variations in the Application, including updated stormwater system plans. The Works Approval will be amended to reflect the alterations proposed by the Works Approval Holder.

The revised air assessment and modelling concluded that air emissions from the duplicated pyro and hydro processing units would not increase the overall risk of impacts on receptors. The Delegated Officer noted the Works Approval Holder’s advice that modelling was based on steady-state operating conditions at full capacity as its process redundancy, monitoring and process control meant that upset conditions, and therefore increases in air emissions, were not expected. Section 13 of the Works Approval Assessment contains a summary of air emissions controls for a future licence including infrastructure requirements, monitoring and reporting. The Delegated Officer will give consideration to specific air emissions controls in assessing any future licence application.

Amendments will also include minor variations in infrastructure design requirements for the disposal of wastewater to the SDOOL as requested by the Works Approval Holder. The Delegated Officer’s key findings in section 5.2 of the Works Approval Assessment remain unchanged.

Works Approval Holder’s comments

The Works Approval Holder was provided with a copy of the draft Amendment Notice on 16 October 2017 for comment. The Works Approval Holder provided comments on 18 October 2017 requesting the following:

Update of the premises address details;

Correction of a typographical error in Table 9; and

Replacement of the general layout plan included in Appendix 2 with an updated version from the Application that depicts both Stage 1 and Stage 2 works.

The Delegated Officer did not object to any of the requested changes, noting that the updated premises address is consistent with the legal land description on DWER’s Geographical Information System.

Works Approval: W5977/2016/1 12

Amendment 1. The Definitions of the Works Approval are amended by the insertion of the definitions

below: CEO means Chief Executive Officer. CEO for the purposes of notification means: Director General, Department Administering the Environmental Protection Act 1986, Locked Bag 33, CLOISTERS SQUARE WA 6850, email: [email protected]. Department means the department established under section 35 of the Public Sector Management Act 1994 and designated as responsible for the administration of Part V, Division 3 of the EP Act.

2. Table 2 of the Works Approval is amended by the deletion of the text shown in

strikethrough below and the insertion of the red text shown in underline below.

Column 1 Column 2

Infrastructure Requirements (design and construction)

First Stage Pyro Operations and First Stage Hydro Operations

- Stacks with a minimum stack height as follows:

Calciner fan stack: 34.6 40 m

Acid roast kiln stack: 27 50 m

Acid roast scrubber stack: 24 19 m

Spodumene mill stack: 25 m

Acid leach stack: 20 m

Steam generator stack: 12 m

Sodium sulphate stack: 25 30 m

Calciner refeed feed end stack: 46 m

Calciner refeed discharge end stack: 33 m - All stacks must be fitted with sampling ports that are compliant

with the requirements of AS4323.1 and the CEMS Code to allow periodic emissions monitoring and installation of CEMS.

- A calciner baghouse filter capable of:

minimising particulate matter emissions from the calciner to less than 30 mg/m3 (STP dry) during normal operating conditions; and

detection and isolation of broken bags, without requiring a baghouse bypass situation to exchange or replace the broken bags.

- Spodumene mill baghouse filter capable of:

minimising particulate matter emissions from the spodumene mill to less than 30 mg/m3 (STP (dry) during normal operating conditions.

- An acid roast off-gas scrubber train as follows:

Venturi scrubber;

Entrainment separator;

Wet electrostatic precipitator;

Pressurised emergency water quench vessel;

Duty and standby pumps for all duties; and

capable of minimising sulphur acid emissions to less than 20 ppm during normal operating conditions.

Works Approval: W5977/2016/1 13

Column 1 Column 2

Infrastructure Requirements (design and construction)

Stormwater System

Designed in accordance with the Schedule 1: Stormwater Plan including: - Stormwater from the Northern site road, Stage 1 Pyro Area and

Stage 1 Hydro Area must be designed to direct runoff to Wedge Pit 1 and/or Wedge Pit 2 Delivery Area, Stage 1 & 2 Pyro Operations Areas, and the TAS Loading Area will be directed to two Water Quality Management Systems which include Wedge Pits, Storage Tanks and overflow pipes.

- Wedge Pits must:

be concrete lined and designed to capture suspended solids by sedimentation;

have a treatment chamber designed for storage requirements based on a 1 in 1 year ARI storm of 1 hour duration ; and

allow machinery (Bobcat) access for removal of accumulated solids.

- Storage Tanks ’TK A’ and ‘TK B’ (‘SW Tanks’) for the storage of treated water from Wedge Pits 1 and 2 respectively must be sized to store a 1 in 2 year ARI storm of 72-hour duration, taking process drawdown into account.

Disposal of wastewater to SDOOL

- Nominal 1,600m x DN80 GRE or DN100PE DN160 PE100 PN16 wastewater pressure main.

- Wastewater storage tanks capable of storing 120 kL during periods when discharge to SDOOL is unavailable.

- Wastewater storage tanks are to be fitted with water level sensors, temperature probes and sealed emergency overflow sumps.

- Waste pump station comprising due/standby pumpsets designed to operate at a minimum duty of 5 21 L/s.

- A magnetic continuous flowmeter must be installed to monitor the volume of wastewater discharged to SDOOL.

- A wastewater monitoring point comprising an auto sampler with instrumentation capable of:

periodically monitoring the quality of wastewater discharged to SDOOL; and

continuously monitoring temperature, conductivity, turbidity and pH.

3. Schedule 1 of the Works Approval is amended by the deletion of the Stormwater Plan

and General Layout Plan and the insertion of the Stormwater Plan and General Layout Plan attached in Appendix 2 of this Notice.

Works Approval: W5977/2016/1 14

4. The Table in Schedule 2 of the Works Approval is amended by the insertion of the red text shown in underline below.

Item Works Specifications/Drawings

1 Weighbridge

Site plans: General Layout

2 Truck wash

Site plans: General Layout

3 Lime sand Delivery, Spodumene Delivery and Spodumene Stockpile Building

Site plans: General Layout

4 TAS Storage, TAS Pelletising Plant and Filters Building

Site plans: General Layout

5 Leach Tanks Site plans: General Layout

6 First Stage Pyro and First Stage Hydro Operations

Site plans: General Layout

7 Conveyor system Site plans: General Layout

8 Na2SO4 and LiOH Product Bagging Building Site plans: General Layout

9 Na2SO4 Storage Warehouse Site plans: General Layout

10 Product Container Loading Area Site plans: General Layout

11 Acid & Caustic and Chemical/Oil Storage Areas Site plans: General Layout

12 Contingency wastewater storage tanks and connection to SDOOL

Site plans: General Layout

13 Stormwater System Site Plan: Stormwater Plan

14 Second Stage Pyro and Second Stage Hydro Operations

Site plans: General Layout

5. The Works Approval prescribed premises location is amended from the address below:

Lithium Hydroxide Processing Plant 12 Mason Road KWINANA BEACH WA 6167 Part of Lot 12 on Plan 39572 Certificate of Title Volume 2230 Folio 45

To the new address below: Lithium Hydroxide Processing Plant 61 Donaldson Road KWINANA BEACH WA 6167 Lot 201 on Deposited Plan 407762 Certificate of Title Volume 2914 Folio 662

Works Approval: W5977/2016/1 15

Appendix 1: Key documents

Document title In text ref Availability

1

DER, July 2015. Guidance Statement:

Regulatory principles. Department of

Environment Regulation, Perth.

N/A Accessed at www.der.wa.gov.au

2 DER, October 2015. Guidance Statement: Setting conditions. Department of Environment Regulation, Perth.

3

DER, February 2017. Guidance Statement:

Risk Assessments. Department of

Environment Regulation, Perth.

4 DER, February 2017. Guidance Statement: Decision Making. Department of Environment Regulation, Perth.

5 Ministerial Statement 665 MS665 Accessed at www.epa.wa.gov.au

6

NEPC, February 2016, National Environment Protection (Ambient Air Quality) Measure, National Environment Protection Council

NEPM Accessed at www.legislation.gov.au

7 Works Approval W5977/2016/1 (including Decision Report)

the Works Approval / Works Approval Assessment

Accessed at www.der.wa.gov.au

Works Approval: W5977/2016/1 16

Appendix 2 Stormwater Plan

Works Approval: W5977/2016/1 17

General Layout Plan