direct lndial: our ref: your ref...0 0 rocla ltd 130 fauntleroy avenue redcliffe wa 6104 att: vern...

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Rocla Ltd 130 Fauntleroy Avenue REDCLIFFE WA 6104

ATT: Vern Newton

Direct lndial: Our Ref: Your Ref:

9411 3446 1 42/002, 4412065

9 February 2015

DUST MANAGEMENT PLAN- BULK EARTHWORKS & QUARRY OPERATIONS 1712R RUSSELL ROAD WATTLEUP

Thank you for the submission of the Dust Management Plan (DMP) as required for the above works.

The City's Health Services has assessed your plans against the criteria set down in the Department of Environment document "Land development sites and impacts on air quality - A guideline for the prevention of dust and smoke pollution from land development sites in Western Australia", Dec 2004.

The scope of the proposed earthworks has been considered and you are hereby advised that the site has been classified with respect to dust risk potential according the two distinct operational phases which occur. During site clearing, topsoil stripping and overburden earthworks, the site will be classed as 3 or "medium to high" risk with a score of 558. While it has been noted in your DMP that, where possible, operations of this type will be scheduled for the wetter months of the year, it is important for you to note Condition 3 of the Notice regarding the bulk earthworks moratorium for Class 3 & 4 sites from 1 October to 31 March each year. You should be aware however that modifying preparation programmes, to reduce active works areas in particular, can significantly reduce site scores and therefore site classification and dust risk.

During standard excavation and quarrying operations, the site score reduces to 360, or a Class "2" low to medium risk site, principally due to the natural screening provided by the quarry design.

These classifications however indicate that a significant risk of dust or sand nuisance exists from this site should adequate management procedures not be installed and properly maintained. As a result, approval for your DMP has been issued in the form of a Notice with scheduled conditions attached, including your endorsed DMP. A copy has been forwarded to your consultant, Landform Research.

The City is pleased to work co-operatively with your company, according to both the approved DMP and the above conditions as agreed, on effectively reducing the potential for dust nuisance and sand drift from this site.

9 C01€:ville Crescent, Spearwvod WA 6163. PO Box 1215, Bibra Lake DC WA 6965. P (08) 9411 3444 F (08) 9411 3.333. ABrJ 27 471 341 209.

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As the occupier, you should be aware, however, that the following general requirements apply to development and operational works on this site:

1. Should bulk earthworks be undertaken outside the approved works area, the City will consider them to be in breach of the conditions of the Approval Notice.

2. All site works shall cease should a dust or sand drift nuisance caused by any works not be adequately addressed according to the above conditions of approval.

Pre-Start Site Meeting

You will note that the scheduled terms of the Notice require that a site meeting is held prior to works commencing on-site, so as to allow the City's Health Services to confirm that the approved measures for dust control are in place. Please contact either Phil Oorjitham or myself on 9411 3589 to arrange the appropriate site meeting.

Thank you for your assistance with completing the approval process. Please do not hesitate to contact the City's Health Services directly on the above number if you have any queries or require clarification of any issues contained within this approval.

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../ ROB IDDISCOMBE ENVIRONMENTAL HEALTH OFFICER

cc: Lindsay Stephens Landform Research 25 Heather Road ROLEYSTONE WA 6111

NOTICE OF CONDITIONS TO APPLY TO AN ACTIVITY TO BE CARRIED OUT ON LAND

Clause 5.11 of the City of Cockburn (Local Government Act) Amendment Local Law 2012

TO: Rocla Ltd 130 Fauntleroy Avenue REDCLIFFE WA 6104

Q WHEREAS:

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A You are the occupier of land situated at 1712R Russell Road WATTLEUP 6166 ("the Land").

B "The Land" is within the district of the City of Cockburn which has its offices at Cnr Rockingham Road and Coleville Crescent, Spearwood, WA.

C The Council of the City of Cockburn is of the opinion sand or dust may be released or escape from "the Land" as a result of the activity specified in the First Schedule which is to be carried out by you, the occupier, on "the Land" ("the Activity").

NOW TAKE NOTICE

1. You must carry out "the Activity'' in accordance with the conditions specified in the Second Schedule hereto ("the Conditions").

2. If you fail to carry out "ij;le Activity" in accordance with the Conditions, you will commit an offence and be liable upon conviction to a penalty not exceeding $5,000 and, if the offence is of a continuing nature, an additional penalty of $500 for each day or part of a day during which the offence has continued or, in the case of a body corporate, a penalty not exceeding $25,000 and, if the offence is of a continuing nature, an additional penalty of $2,500 for each day or part of a day during which the offence has continued.

Date: 9 February 2015

NICK��E� MANAGER HEALTH SERVICES

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FIRST SCHEDULE

"The Activity" is described as:

"The carrying out of (1) Class 3 bulk earthworks comprising clearing of vegetation, topsoil stripping, overburden earthworks and (2) Class 2 excavation & quarrying operations by the occupier under licence from 2015 to 2020.

SECOND SCHEDULE

1. "The Activity'' must be carried out in accordance with the dust management controls included in the Dust Management Plan (DMP) for "the Activity" as submitted to the City's Health Services on 7 January 2015 and also in compliance with the following additional requirements.

2. A site meeting shall be held between the occupier and the City's Environmental Health Officer prior to the commencement of any works on-site to ensure that "the Activity" will be carried out in accordance with the conditions of this Notice.

3. Bulk earthworks are prohibited within the City of Cockburn on Class 3 or 4 development sites between 1 October and 31 March annually.

4. The occupier shall satisfy the Manager Health Services that adequate site screening programmes are initiated and maintained for all worked areas of "the Land", and that an adequate water supply and site irrigation facilities are available at the site.

An adequate water supply and suitable water carting vehicle(s) in good working condition shall be available at the works site at all times.

5. All areas of "the Land" that are loose or exposed are to be stabilised by the use of appropriate dust suppressant materials such as water, hydromulch, seeded hydromulch, chemical, or physical soil stabilisation to ensure sand and dust does not escape or be released from "the Land" at any time.

After each area of clearing, earthworks or excavation is completed, if that area is to remain inactive for any period such as to represent a significant potential source of dust emissions, it should be stabilised by the Occupier with Dustex, mulch, seeded hydromulch, or revegetation as appropriate.

6. Should dust visibly cross the site boundary, dust suppression measures shall be increased immediately and works shall be modified accordingly. Should dust continue to be generated, all works shall cease immediately and the site shall be sufficiently stabilised by application of water until such a time as the wind conditions are appropriate to resume works.

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7. The occupier shall employ procedures to minimise escape of dust and sand from "the Land" onto surrounding roads and shall ensure that any accumulated material is removed on a regular basis, or as often as necessary to prevent such material becoming a source of dust nuisance.

8. Clearing, excavation work or any other activity that generates, or is likely to generate, dust or sand drift from "the Land", shall not be carried out where the wind is in excess of 25 knots. Where the wind is forecast by the WA Bureau of Meteorology to be in excess of 25 knots on any day, including non-working days, the site supervisor shall stabilize the site in anticipation of those conditions.

9. The Contractor shall ensure that the name and contact details (including the Site Manager's mobile number) of the person responsible for the works on this site, and to whom any dust complaints are to be addressed, are displayed at the site at all times.

10. After all works on "the Land" are completed and before the occupier has vacated the site, "the Land" shall be stabilised to the satisfaction of the Manager Health Services.

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Nl��w� NICK JONES MANAGER HEALTH SERVICES

9 February 2015

The applicant or any person aggrieved by this decision of the City's Health Service, is advised that they may apply to the State Administrative Tribunal, within 28 days of the date of issue of this approval document, for a review of the order or decision. A copy of the appeal shall also be forwarded to the City of Cockburn within the same time period.

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AGENDA ITEM 10.4

POLICY PREVENTION OF SAND DRIFT FROM SUBDIVISION AND DEVELOPMENT SITES

SPD7

Date First Adopted: 21 October 2003 Date Last Reviewed:

Division: Planning & Development

Status:

Strategic:

Administrative

Background:

[3 Key Result Area:

Vision:

Planning and Development of the City to achieve high levels of convenience, amenity and a sense of community.

Objective:

• To ensure that the planning of the City is based on an approach which has the potential to achieve high levels of convenience for its citizens.

• To ensure that the development will enhance the levels of amenity currently enjoyed by the community

[3 Business Unit: Planning Department

Service Unit: Environmental Health Services

Statutory Planning Services

Extensive clearing of remnant bushland as part of subdivisional and development works during summer months has generated a substantial number of complaints received by the Council. This has resulted in the review of the City's "Guidelines for the preparation of Oust Management Plans for Development Sites within the City of Cockburn" to proactively control the timing of bulk earthworks.

The Council's guidelines describe the problems associated with airborne dust emissions from development sites. The City requires the preparation of dust management plans for construction works associated with development sites and subdivisional works. These dust management plans are required to be submitted and approved prior to the commencement of works.

The City's dust management guidelines have assisted developers in preparing dust management plans. These guidelines are largely based on the DEP document titled "Land Development Sites and Impacts on Air Quality - A Guideline for the Prevention of Oust and Smoke Pollution from Land Development Sites in Western Australia" (25 July 1996). The DEP guidelines outline that during the summer of 1994-95, more complaints regarding dust impacts from land development sites were received by the DEP than for any previous summer. This prompted the preparation of the DEP guidelines, which deal with such issues such as the:-

AGENDA ITEM 10.4


• timing of development, development staging, • treatment of vegetation on site, • stabilisation of cleared areas, • hydromulch, chemical stabilisation; • contractual arrangements; and

SPD7

• procedure for the assessment and management of dust lift off (Site Classification Assessment Chart).

It is the developer's responsibility to schedule works on land development at the time in the year and in a way that reduces the potential impacts of dust to a practical minimum. The time of the year when these activities are carried out is critical since the least number of complaints occur during winter months.

The DEP Guidelines state:-

"Dust generated by bulk earthworks being done during the summer months, particularly with housing in close proximity, can adversely impact upon people who live near development sites. These effects may be reduced if developments can be staged in a sequence whereby bulk earthworks are carried out in the winter months and the completed earthworks "front" is kept to about 100 metres in advance of newly created lots."

The factors that affect airborne dust lift off from land development sites (other than the particle composition, density and size) are:-

• Wind velocity; • Amount of land area disturbed and exposed (includes adequacy of artificial

covers such as hydromulching); • Soil dryness/compaction; • Wind direction oscillation.

Purpose: The purpose of this Policy is to:-

1. incorporate the City's "Guidelines for the preparation of Dust Management Plans for Development Sites within the City of Cockburn" into this Policy.

2. adopt the above DEP procedure for the assessment of the potential for a development site to generate dust prior to site works commencing;

3. not allow bulk earthworks on Class 3 and 4 development sites between 1 October and 31 March ; and

4. put in place measures and contingency arrangements to manage the potential for dust leaving the site during and after development.

AGENDA ITEM 10.4


SPD7

Policy:

Measures

1 . All subdivisions and development must comply with the Environmental Protection Authority Guidelines for dust control in subdivisional areas.

2. All earthworks on development sites must be undertaken in compliance with a Dust Management Plan approved by the City's Health Services, prepared in accordance with the "Land Development Sites And Impacts On Air Quality: A Guideline For The Prevention Of Dust And Smoke Pollution From Land Development Sites In Western Australia" (DEP, November 1996).

3. All development sites shall be classified in accordance with the document "Land Development Sites And Impacts On Air Quality: A Guideline For The Prevention Of Dust And Smoke Pollution From Land Development Sites In Western Australia" (DEP, November 1996).

4. Bulk earthworks will be prohibited on Class 3 or 4 development sites between 1st October to 31st March annually. For the purpose of this policy, "Bulk earthworks" refers to site clearance, land re-contouring and cut and fill operations. Work such as construction of retaining walls, installation of sewers and construction of roads is considered to be "Civil earthworks".

5. Any Class 3 or 4 development sites which have undergone bulk earthworks prior to these dates, and where further civil works are not intended during the period 1st October to 31st March, shall be completely stabilised over this period. The standard of stabilisation required shall be no less than that achieved through hydro-mulching or similar method, to the satisfaction of the City's Principal Environmental Health Officer.

6. Bulk earth works will be permitted in all months on Class 1 and 2 development sites, subject to the approval by the City's Health Service, of a Dust Management Plan.

7. (a) Subject to (b) below, and in accordance with the approved Dust Management Plan, civil earth works will be permitted to be undertaken on all classes of sites over the period 1st October to 31st March, subject to an ongoing program of stabilisation on all exposed land prior to the completion of lots, to the satisfaction of the City's Principal Environmental Health Officer.

AGENDA ITEM 10.4


SPD7

(b) In respect to Class 4 development sites retaining wall construction may be permitted between 1st October to 31st March subject to the implementation of the Dust Management Plan, which shall provide for the complete ongoing stabilisation of all land affected by the construction of retaining walls.

8. In the case of subdivisions, it shall be the subdivider's responsibility to maintain dust suppression on development sites until such time as new certificates of title issue, from which point the responsibility for dust suppression shall shift to the new land owners.

Delegation: Refer to the Delegated Register.

DUST MANAGEMENT PLAN

REMOVAL OF LIMESTONE AND SAND

M?0/1275, RUSSELL ROAD, WATTLEUP

ROCLA QUARRY PRODUCTS

1.0 Environmental Dust

1.1 Dust Risk

Landform Research Land Sys1erns - Quarries - Envlronmen1

ABN 29 841 44:1 094

Excessive dust has the potential to impact on both the workers and the adjoining land.

Dust can originate from a number of operations and may impact on onsite workers, or travel offsite. Potential dust impacts are addressed by reducing the dust generated from the quarrying, processing and transport operations.

The main risk from dust is not the sand, but rather the fine organic particles that are generated during land clearing and reinstatement, and most importantly the fine particles generated by transport along limestone access roads and traffic areas.

Dust from some materials such as ground limestone can form smaller particles that are capable of blowing further or even becoming so fine that they become invisible.

1. Mining (predominantly coal) has been shown by (NSW Health} to have;

• PM <2.5 microns as 2- 5% of emissions • PM 2.5- PM1 0 microns as 15- 45% • PM>1 0 microns as 50- 70%.

(One micron is 1 I 1000 of 1 mm ) .

2. PM< 2.5 are invisible and called "fine particles". They are the main health issue and are caused by vehicle emissions whether they are along roads or on private land. Vehicle emissions will not occur at night or at other times when the site is not active.

Lindsay Stephens BSc (Geology), MSc (Plant Ecology) 25 Heather Road Roleystone WA 6111

Mem Aus Geomechanics Soc- MEIANZ- FIQA Tel9397 5145, [email protected]

Dust Management Plan, M?0/1275, Russell Road, Wattleup Rocla

3. PM 10 are invisible and called "coarse particles". They can be breathed in, but are removed by alveoli and mucous. (NSW Health). This dust may be generated when land is cleared and topsoil disturbed or the site is subject to traffic in summer.

4. PM>1 0 is visible dust and will, based on the resource, be the vast majority of the particles.

5. Sand particles are normally >50 microns. DEC 2011 (below) lists particle sizes of >50 um as not normally becoming airborne. That is the sand grains which move by saltation (bouncing) and are retained by the wall of the pit.

As all sizes of dust are likely to be generated together, there will be visible dust being generated when invisible dust is being formed. Therefore any visible dust present is a good sign and early indicator of a dust risk.

The main risk is therefore from the fine organic matter in the topsoil any clay within the sand and limestone or calcium carbonate that is broken down through lyre impacts or disturbance. There is also the risk from the crushing and tipping processes.

The site has been cleared during October - November 2013 and therefore the risk from dust during clearing is reduced.

Dust has the potential to be generated during most phases of the quarrying and crushing operation, particularly during summer. In winter the frequent rains greatly reduce the potential dust emissions.

Limestone is formed from sand grains bound together by grains of calcium carbonate held together by calcium carbonate cement.

Being softer than the sand grains the calcium carbonate is readily ground very fine from disturbance such as vehicle movements. The sand grains are hard and are not normally reduced in size even by traffic movements.

Calcium carbonate is an innocuous material that is a major component of bones and is required by all living organisms for their health and growth.

What makes calcium carbonate unique is that it is readily dissolved to calcium hydrogen carbonate by weak acids in rainfall and water applied to the site. Once dissolved, the calcium hydrogen carbonate readily precipitates to calcium carbonate as the water is evaporated. The calcium carbonate deposits on the surface of the land and any exposed limestone, readily forming a crust that stabilizes the surface and is not liable to any dust lift off unless disturbed by vehicle movements. Limestone which has been left even for a week or so becomes crusted and stabilised, with the crust thickening over time. This process can even occur from dew.

1.2 Climate and Soil Conditions

Through the winter months of May to September exclusive, there is little dust risk because rainfall exceeds evaporation. The rainfall is sufficient to wet the whole limestone profile to depth, with excess water reaching the water table.

In summer when evaporation exceeds rainfall, the limestone dries when exposed to the sunlight and atmosphere and is susceptible to crushing and grinding by vehicles.

Landform Research 2


However the limestone prior to excavation retains its moisture if there are no tree roots to extract moisture from depth. Without tree roots the moisture in the limestone can only be lost by capillary action and so stays moist to below 0.5 and 1 metre depth right through summer.

When excavating using a bulldozer there is very little dust even in summer.

On active areas that dry out, the dust can readily be generated. Normal practice is to treat this with water, which maintains the moisture content of the soil and limestone and mitigates dust generation.

1.3 Wind directions

The most comparable wind data is taken from Fremantle. This shows that the prevailing wind is from the north east and east at 9.00 am and the south west at 3.00 pm.

For the summer months, where February is a typical month, the wind directions are more variable at 9.00 am ranging from east through south east, south and south west. At 3.00 pm in February the winds are almost solely from the south west. The morning data shows that on some days the south westerly sea breeze is blowing at 9.00 am in February. The wind roses are included in this attachment.

The only direction that is likely to blow to the urban area to the south is from northerly winds, which are uncommon, and north easterly winds which blow on some mornings but at 9.00 am constitute only 21% of the time. At other times, such as 3.00 pm, north easterly winds are uncommon.

Therefore the risk of winds blowing towards the new urban areas to the south are interpreted to be perhaps just over 10% of the working day or days.

The perimeter bunds and vegetation provide effective wind breaks and wind screening. Winds crossing the site are slowed by the perimeter tree and shrub vegetation. This reduces the speed of the winds across the floor of the pit.

When winds exit the pit or cross out of the pit they have to travel across a vegetated buffer that slows the speed of the wind and allows the coarser particles to drop from suspension.

1.4 Assessment of Dust Risk

Environmental Dust

Excessive dust has the potential to impact on both the workers and the adjoining land.

Dust can originate from a number of operations and may impact on onsite workers, or travel offsite. Potential dust impacts are addressed by reducing the dust generated from the quarrying, processing and transport operations.

All nearby dwellings lie within Area 8 of the Kwinana Policy Area B. They are not sensitive premises under the normal definition but are exposed to higher levels of dust, controlled by the Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992. (attached).

Landform Research 3


Dust emissions fall under the Guidance for the Assessment of Environmental Factors, EPA, March 2000. Assessments of the potential dust risk are normally made using the Land development sites and impacts on air quality, Department of Environmental Protection and Conservation Guidelines, November 1996. These are still in place but are incorporated into the DEC 2011 Guideline for Managing the Impacts of Dust and Associated Contaminants from Land Development Sites, Contaminated Sites Remediation and other Related Activities.

Occupational dust associated with the quarrying processes falls under the Mines Safety and Inspection Act 1994 and Regulations 1995 overseen by the Department of Mines and Petroleum.

There are a number of management actions that can be taken in quarries to minimise dust generation or travel and these will be used wherever possible. The general management actions are summarised below together with the potential dust issues that relate to this site. The actions will be used where applicable and as the opportunity presents to minimise dust on this site.

All nearby dwellings lie within Area B of the Kwinana Policy (Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992). See Appendix 5 and Figure 2.

The surrounding land is used for quarrying, poultry farms and market gardens.

The buffers provided by the Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992 are to ensure that industrial land uses can be conducted within the Hope Valley Wattleup Redevelopment Area. If these buffers are not now to be adhered to then buffers will have to be contained within the Hope Valley Wattleup Redevelopment Area, thereby potentially significantly reducing the potential of the Area to support and sustain the proposed industry destined for the site, including the proposed nearby lntermodal Facility.

It is not acceptable to permit environmental dust to travel offsite or to be generated at levels that may impact on health and safety. Therefore every effort will be taken to minimise dust generation. The methods proposed are the same as those used in all limestone and sand quarries.

From sand and limestone extraction the main particles are sand sized particles from the sand itself and from the limestone.

For sand these are normally in excess of 0.5 mm and have a capability of moving by saltation and do not travel far, being easily stopped by vegetation, pasture, small banks or other features. For limestone the calcareous material can crush from transport and other activities into fine dust that is capable of blowing i f not treated with water.

Crushing and screening the limestone does not normally produce significant dust because even in summer the limestone remains moist. On the other hand the continuous traffic on the access roads and work areas is what generates the highest dust potential. These are the areas treated with water.

Dust can also be a potential problem during land clearing and reinstatement and during excavation and crushing in the summer months in times of strong winds.

When limestone is placed and not disturbed it readily develops a crust of reprecipitated calcium carbonate that tends to stabilise the surface. Also the fine particles are washed below the surface leaving only coarse material behind. Therefore bunds do not normally generate dust, and become stabilised after experiencing a winter.

Landform Research 4


Winds at 9.00 am vary from easterly on 49% of the time on summer mornings, with an early sea breeze, and from the south west at 9.00 am on 46% of the summer mornings.

Afternoon winds are predominantly south westerly (south to west) for 86% of the time in summer and 40% of the time in winter. These winds are strong and are normally all above 10 kph in summer, ranging up to > 30 kph on 20% of the time.

Winter winds are more variable and on average lighter, but have an easterly predominance in the morning and slight south westerly dominance in the afternoons.

The most likely time for dust to become an issue is on summer mornings when winds are easterly and during sea breezes on summer afternoons. With operations below natural ground level, protected by landform, bunding and large buffers, it is unlikely that dust will impact on nearby residences for afternoon sea breezes but could potentially impact on the four residences to the west on summer mornings under strong westerly winds, if visible dust is permitted to cross the boundary of the site.

It should be remembered that the most significant potential dust impact is occupational dust, which requires good environmental and health and safety management and is regulated by the Mines Safety and Inspection Act 1994 and Regulations 1995. When occupational dust is managed then environmental dust is also minimised.

Vegetated screening bunds are in place along Russell Road and are proposed along the other peri metres.

A water tanker is to be maintained on site during excavation when there is a risk of generating excessive dust. The capacity of the tanker is 10 000 L or similar. During potentially dusty conditions the water truck will make as many sweeps around the site as required, but normally 5 - 6 sets of sweeps around a limestone pit are required to suppress dust. In winter when rain occurs the water truck may only require one or two sweeps around the site or none in sufficient rainfall conditions.

The water is used to settle dust on the pit floor and reduce the dust emanating from any crushing operation.

Apart from the initial topsoil clearing and surface reinstatement, all operations are proposed to be conducted below natural ground level. Bearing in mind the distances involved and the dust suppression methods in place, dust should not impact on any dwellings.

Examination of aerial photography shows that there are possibly 11 dwellings at up to 200 metres and one at 210 metres from the edge of the proposed pit. Within 500 metres around 40 dwellings may be present.

The distances vary from 70- 210 metres to the north across Russell Road, 100- 160 metres east across Power Avenue and 60- 200 metres across Torgoyle Road.

All the nearby dwellings listed as lying within 200 metres of the proposed quarry lie within Area B of the Kwinana Policy. They are not sensitive premises under the normal definition but are subject to higher levels of allowable dust and noise, controlled by the Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992 and Environmental Protection (Noise) Regulations 1997. Appendix 5.

Landform Research 5

Dust Management Plan, M?0/1275, Russett Road, Wattleup Rocta

Of the 12 dwellings only 3 lie within the prevailing winds at distances of 130, 110 and 210 metres. The possible dwellings at 130 metres and 110 metres may in fact be sheds; it is unclear from the aerial photography but are counted here as dwellings because of the uncertainty. All other dwelling lie outside the prevailing winds of SSW and E.

Existing sand and limestone pits in other parts of Perth, are operated behind screening bunds, with buffers as small as 40 - 60 metres. For example Cockburn Cement at Fanstone Avenue in Munster, or ltalia Stone Group at Wattleup Road, and WA Limestone at Kerosene Lane and Wattleup Road. These are all approved limestone and sand pits that use bulldozers in continuous or campaign operations. They all have buffers of less than 100 metres.

These other quarries are able to operate as a result of earth bunding and effective dust management.

On this basis, and considering other approved limestone quarries, there would appear to be adequate potential to manage dust at the buffer distances proposed.

The category of dust risk is included in DEC 2011 Guideline for Managing the Impacts of Dust and Associated Contaminants from Land Development Sites, Contaminated Sites Remediation and other Related Activities. This document is not really applicable to mining because it is to be used to assess the mitigation required based on no mitigation.

It must be remembered that this guideline is not really appropriate for quarries. It was developed for subdivision earthworks at a time when dust management was a lower priority.

However the document can also be used to determine the risk of potential dust impacts of earthworks such as opening new ground and the removal of overburden and rehabilitation, which only occurs about once per year when the pit is being expanded or moving forward. These risks are summarised under the Table titled Dust Management Actions below.

All quarries have active and comprehensive dust management procedures in place and are required to do so to protect visual amenity and their staff. The Guidance has been used, but factored in is a reasonable amount of dust management. Using the normal dust management there is a negligible risk of dust impacting on sensitive premises west of the quarry.

The DEC in 2008 released a draft Guideline for the Development and Implementation of a Dust Management Plan.

The key Environmental Objectives for the operations are;

• Manage the potential for the generation of dust.

• Visually monitor dust levels and take steps to reduce the potential impact of dust on occupational and environmental aspects of the operation and local area.

The category of dust risk is included in DEC 2011 Guideline for Managing the Impacts of Dust and Associated Contaminants from Land Development Sites, Contaminated Sites Remediation and other Related Activities. This document is not really applicable to mining because it is to be used to assess the mitigation required based on no mitigation. Landform Research 6

Dust Management Plan, M70!1275, Russell Road, Wattleup Reel a

When making the assessments using the DEC Guideline there are several key points;

•

•

•

•

•

•

It is noted that the Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992 permit higher concentrations of suspended solids. Nearby dwellings lie within Area B of the Kwinana Policy.

The prevailing see breeze winds blow partially towards the dwellings to the north and north east. Of the 12 dwellings only 3 lie within the prevailing winds at distances of 130, 110 and 210 metres.

Dust risk is generally only in the dry summer months

The limestone readily crusts after wetting and becomes stabilised. I t is only trafficked areas of limestone that develop fine dust from the grinding of wheels.

The perimeter bunds and vegetation provide wind breaks and wind screening sand will be added to.

Effective water treatment of the limestone is used to wet down and manage dust risk.

1.5 Dust Risk Assessment from DEC 2011 (Appendix 1)

PART A Item Score

Number

1 Nuisance potential of the material High when trafficked and untreated -6

Low with effective water sprays and wetting down. - 2

When not trafficked, very low. - 1

2 Topography and vegetation Well screened with wide screening separations of vegetation operating

below natural qround level. - 1

3 Area of site activities Trafficked areas are 5 plus ha - 6

4 Type of work being undertaken Considering the natural moisture content of the limestone; partial earthworks below n atural ground level in summer- 6

When limestone is wet - 3

Summer total without d ust 1 9

measures Summer total with d ust measures 12

PARTS Item Score

Number

1 Distance to sensitive premises 1 00 500 metres - 1 2

2 Effect of prevailing wind Isolated land uses affected by one wind direction - 6

Summer total without d ust 1 8

measures Summer total with d ust measures 18

Landform Research 7

Activity

Land Clearing and excavation without dust suppression. Dwellings south of Kerosene Lane.

With dust suppression

Calculated Score 342

216

Dust Management Plan, M70/1275, Russell Road, Wattleup Rocla

Allocated Risk of Dust

Classification 2

Low Risk, but at the upper end. The recommended actions are included in the Dust M anagement Program.

Classification 2

Low Risk but at the bottom end near negligible risk during the wetter months. The recommended actions are included in the Dust M anagement Program. Commitments are made to cease work if dust cannot be managed.

• Best practise dust management procedures apply to quarries and are used on site. These are listed in the following table with a comment on how Rocla propose to manage potential dust issues.

The trigger for dust management is to be the generation of visual dust.

• The site supervisor is normally the loader driver or site weighbridge operator, who is in the best position to assess dust generation and to direct remediation.

No visible dust will cross the lot boundaries.

• On site operators are to be instructed to visually monitor dust, report and treat any visible dust.

2.0 Occupational Dust

Occupational dust associated with the quarrying processes falls under the Mines Safety and Inspection Act 1994 and Regulations 1995 overseen by the Department of Mines and Petroleum.

Rocla will provide induction and protective equipment for all persons on site.

The DMP require personal dust monitoring to ensure dust levels comply with health risk guidelines.

The dust management procedures used on site comply with these guidelines.

3.0 Dust Management

3.1 Issues and Management

There are a number of management actions that can be taken in quarries to minimise dust generation or travel and these are used wherever possible. The general management actions are summarised in the tables below, together with the potential dust issues that relate to this site. The actions are used where applicable and as the opportunity presents to minimise dust on this site.

Landform Research 8


A dedicated water truck is retained on site for the wetting down of roads and other dust suppression activities. In addition the access road is sealed and maintained.

Loads on trucks that have the potential to generate dust are required to be covered or wetted down.

Dust generated from earthworks is closely monitored and managed.

Actions that can be used to prevent or mitigate dust are standard quarry best practice and have been used on this site on an ongoing basis. Some methods are taken from the DEC 2011 Appendix 2 and others from quarry best practice.

Methods that are available, and will be selected from, are listed below. The most effective by far is the use of water management from a water truck, sprinkers, water canon or other such mechanism.

DESIGN AND SITE

1. Minimising the amount of ground open. 2. Minimising the amount of ground being subject to traffic. 3. Locating access roads away from sensitive premises. 4. Design of the pit to reduce wind speed and potential dust lift off. 5. Maintaining effective setbacks. 6. Constructing perimeter bunds to reduce wind speed. 7. Planting and maintaining tree buffers. 8. Providing wind break fencing generally and on top of bunds as required. 9. Maintaining a secure, fenced site, to prevent illegal access. 10. Rehabilitate and stabilise all completed areas as soon as practicable. 11. Clearing and replacing topsoil and overburden during wetter times; April to

October.

OPERATIONS

12. Locate active areas away from windy locations. 13. Locate active areas away from sensitive premises. 14. Working on the floor of the pit. 15. Operate some parts of the pit only when conditions are suitable. 16. Locating mobile plant and stockpiles in sheltered areas. 17. Design staging to minimise dust risk. 18. Conduct higher dust risk operations such as topsoil clearing and placement

during more favourable conditions. 19. Shut down equipment that is not required.

ACCESS AND HARDSTAND

20. Constructing the access roads from hard materials that resist dust generation.

21. Maintaining a water truck on site for road and other wetting down. 22. Using a sealant such as a polymer, chemical or emulsified oil or bitumen on

the access road to reduce water use. 23. Using sprinkers and water canon on roads, traffic areas and stockpiles.

PROCESSING

24. Applying water sprays and additives to crushing and screening cycles.

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25. Providing screening and shielding of mobile plant. 26. Use and maintain filters on all suitable plant. 27. Ensure regular appropriate emptying of filter collection devices. 28. Face hoppers away from prevailing winds. 29. Maintain reduced pressure in plant, hoppers and bins to prevent loss of

dusty air.

STOCKPILES

30. Minimise the number of stockpiles. 31. Maintain stockpiles in sheltered areas. 32. Reduce the elevation of stockpiles. 33. Limit the drop height to stockpiles and loading. 34. Locate finer products inside or screened by stockpiles of coarse materials.

TRANSPORT

35. Cover all loads. 36. Ensure all trucks are dust free and not carrying pebbles and other materials

outside the tray. 37. Choose the best transport routes. 38. Wet down or sweep the cross over and access roads.

HEALTH AND COMMUNITY

39. Maintain air conditioned cabins on all vehicles. 40. Provide a readily auditable trigger of no visible dust to cross the property

boundary in line with DER Licence and best practice in WA. 41. Conduct effective site induction and awareness training for all staff. 42. Training should include observation and mitigation where possible of all

dust emissions. 43. Providing a complaints investigation, mitigation and recording procedure. 44. Liaising with the owners/operators of the two nearby sensitive premises. 45. Ceasing operations when conditions are not favourable or when visible dust

is crossing the boundary. 46. Obtain the latest weather conditions to increase the awareness of dust risk. 4 7. Cease operations during adverse weather conditions. 48. Operate during wetter months or when the soils are moist.

Normally the stripping of overburden and topsoil and their subsequent use in rehabilitation will be undertaken during the wetter months to reduce the generation of dust.

Completed sections of the quarry are to be stabilised and not subject to traffic as soon as practical to reduce the area of open ground and help reduce wind speed.

In the event of dust management not being able to be achieved, and to minimise impact on adjoining land holders, the dust generating activities will be stopped until conditions improve, to minimise impact on adjoining land holders.

A record of all dust complaints is retained together with the mitigation measures used to reduce the dust impacts.

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ACTIVITY

GENERAL Legislation

Buffers

Landform

Tree Belt • Buffers


are readily stopped by tree belts and distance with which the site complies with Planning Guidelines Separating Agricultural and Residential Land Uses, Department of Natural Resources Queensland 1997( Pages 65 - 111) and Department of Health WA, 2012, Guidelines for Separation of Agricultural and Residential Land Uses which uses the same criteria (Pages 112- 118).

The Queensland Guidelines predominantly relate to agricultural spray drift, but based on particle size also relate to dust.

The Guidelines provide for a buffer of 300 metres for open agricultural land, dropping down to 40 metres where an effective tree belt is in place. The Western Australian Department of Health also uses the same guidelines.

The Guidelines are based on field studies and demonstrate the effectiveness of tree belts in providing screening against particulate travel.

The proposed excavation has buffers with perimeter bun ding along Russell Road. This will be extended around all sides of the excavation.

Examination of the aerial photographs included within the Mining Proposal shows that whilst the vegetation on the area of excavation is partially degraded, that to the east is largely intact. Also the distances to all residences to the north and north east are separated by significant partially vegetated to vegetated plant cover which provides for dust particulate screening. The dwellings to the south are not in the path of the prevailing winds blowing across the operational site.

3.2 Dust Management Actions

POSSIBLE OPERATIONAL RISK PROCEDURES SEVERITY and FREQUENCY

---- Comply with the provisions of the Mines Safety and Inspection Act 1994 and Regulations 1995.

---- Maintain adequate buffers to sensitive premises.

---- Locate activities behind natural barriers, landform and vegetation.

Landform Research

COMMITMENTS ON ACTIVITIES RISK CONDUCTED ON SITE AFTER

MANAGE MENT

Rocla will comply with the Act and ----

Regulations at all their pits.

Buffers are similar to existing ----

operating limestone quarries. See Figure 2.

All residents within 500 metres will be consulted during the assessment process. The design of the pit and staging has ----

been selected to provide the best screening. Excavation is conducted below the land su rface. Excavation will produce a significant void, some 1 0 - 15

metres below natural ground level. The processing and stockpile facilities are to be located on the base of the pit below ground level.

11

Landform ----

Staging ----

Pit design ----

Screening/ ----

Vegetation

MANAGEMENT Operation ----

Monitoring ----

Trigger ----

conditions

Landform Research

Work below natural ground level.

Push overburden and interburden dumps into positions where they can form screening barriers.

Design operational procedures and staging, to maximise the separation to sensitive premises.

Design the excavation to provide enhanced landform and constructed dust screening. Use landscape screening, wind breaks and tree belts.

Provide air conditioned closed cabins on plant Provide monitoring and supervision of the processing and other practices on site. Trigger conditions are used to determine when additional dust management is required.


This is proposed. ----

Excavation will produce a significant void, some 10 - 15 metres below natural ground level. The bunds are already in place to ----

elevations of 5 metres along Russell Road and will be added to as necessary. The bunds will be extended around the perimeter of the excavation area prior to extraction in each particular stage. The design of the pit and excavation ----

has been determined to operate from the floor of the pit from the centre outwards, always behind the face and bunds. Excavation is proposed to commence in the south western corner as this presents the most environmentally sound orientation for excavations. See above ----

Vegetation is in place around all ----

perimeters. New bunds that are to be constructed will be planted with local native trees and shrubs. During past discussions with Landcorp, interim seeding with grass will be used as a temporary surface stabilistation option. On the completed surfaces.

These are used on site for ----

operational mobile plant. A monitoring system is proposed. ----

see below "Trigger Conditions".

Most dust generated from processing ----

and vehicle movements has a very large visible component. Lesser risks emanate from excavation and opening new ground. The trigger for dust management is the generation of visual dust. The quarry manager and leading hands are ultimately responsible for site supervision of dust. A commitment is made that no visible dust will cross the lot boundaries. They travel around the operations and pit frequently and are in two way radio contact with all mobile plant. All operators on site are instructed to be vigilant to dust generation and management and report any excessive dust or potential dust

12

Adverse weather

Equipment failure

Training

Complaints

Monitoring

Moderate

Uncommon

Low

Uncommon

Landform Research

When winds are sufficiently strong, or other weather conditions are unacceptable, to negate the effects of dust management, operations will cease until conditions improve and compliance can be achieved. In the event of dust management not being able to be achieved through equipment failure operations will cease until full capability is restored. Conduct training programs on dust minimisation practices. Provide a complaints recording, investigation, action and reporting procedure such as Appendix 3 of Land development sites and impacts on air quality, Department of Environmental Protection Guidelines, November 1 996.

Provide a Monitoring procedure to minimise dust generation.


management issues. When trigger conditions are d etected and/or alerted relevant action is taken. This can include additional water suppression, modification of procedure, delay until more favourable conditions are present, use of alternative equipment etc as outlined in the Dust Management Plan. Rare adverse conditions are more likely to occur during summer mornings and summer afternoon sea breezes. In winter, stronger winds are normally associated with rain and therefore carry a reduced dust risk. This policy is used to minimise impact on adjoining land holders/ dwellings and the urban areas.

This is committed to.

Rocla will use on site induction and training to all personnel at all operations. All residents within 500 metres of the proposal will be consulted by Rocla during the assessment process. A record of all dust complaints is to be maintained together with the mitigation measures to b e used to reduce the dust impacts. All complaints relating to dust are to be investigated immediately on receipt of a complaint. Appendix 3 of Land development sites and impacts on air quality, Department of Environmental Protection Guidelines, November 1996, will form the basis of the methods on which a complaint on dust is dealt with. A record of complaints is maintained. Dust monitoring is conducted on site at all times by all operators and the quarry manager. This response is instantaneous and does not rely on monitoring equipment, which normally has time delays associated with it. The amount and source of dust is observed b efore any dust monitoring could trigger. Treatment is therefore more effective and targeted. When a significant source of dust is noticed it is dealt with by temporary

Low

Low

13

EARTHWORKS

Land Clearing

Overburden removal

Construction of bunds

Land restoration

Low

Once per year.

Low -

Once per year

Low - High -

Once per year

Low

Once per year.

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Schedule activities such as vegetation removal or topsoil stripping on exposed ridgelines at times when the materials are less likely to blow or d uring s uitable wind conditions.

Schedule activities such as overburden stripping on exposed ridgelines at times when the materials are less likely to blow or d uring suitable wind conditions.

Schedule activities such as ripping, overburden and topsoil spreading on exposed ridgelines at times when the materials are less likely to blow or d uring suitable wind conditions.

Dust Management Plan, M70/1275, Russell Road, Wattteup Recta

or permanent changes to procedures and equipment or treatment using the m ethods listed in the Dust Management Plan. A comprehensive liaison with the closest residents and the caretaker will provide a means of monitoring for visual dust at times of inactivity. See the Complaints above.

Normally the opening of new ground and the subsequent use in rehabilitation is undertaken in the drier months when the soils are still moist enough to s uppress d ust but not wet. This is necessary to minimise the risk of d ust generation and the spread of dieback spores if present. N earby residents will be notified prior to large scale clearing that may generate significant environmental dust.

Low

This is proposed. Low Overburden removal will be infrequent. Where possible overburden removal will be completed in wetter months or when winds are blowing away from sensitive premises.

Construction of bunds can lead the Low d ust generation if conducted in summer when the topsoils are dry. Where possible bunds will be constructed in drier months when the soils are still moist. If this is not possible water sprays and other wetting down will be used to reduce the potential for dust generation and movement. The bunds will be constructed prior to the excavation in each part of the pit. The bunds will be revegetated during the first winter following construction with local native trees and shrubs to assist in stabilizing their surface. This is proposed. Low Land restoration will be infrequent and normally conducted only once per year. Where possible clearing will be completed in wetter months or when winds are blowing away from sensitive premises. Completed sections of the q uarry are to be excluded from activity as soon as practical to reduce the area of active " uncrusted/stabilised" open ground. Stabilisation of the limestone will occur through lack of traffic, crusting

1 4

EXCAVATION Excavation

Loading Face

Low

Low level contin uous activity

at Low

Low level continuous activity

Landform Research

Oust Management Plan, M?0/1275, Russell Road, Wattreup Rocla

Excavate from the face using techniques that minimise the crushing of dry matter.

from wetting down the limestone and using whatever dust management actions are appropriate, as listed above in the Dust ManaQement Plan.

Excavation will be normally completed by bulldozer deep ripping and track rolling limestone. When freshly exposed at any time of year the limestone is normally moist and has less capabil ity to generate d ust. It is only when air dried that dust becomes a greater issue. Limestone that is wetted or rained upon rapidly stabilises and forms a hardened crust. This is resistant to erosion until disturbed by traffic. A range of actions will be used on areas that are susceptible to dust lift off s uch as sand and disturbed limestone. These will include watering, emulsion, windbreaks, and other stabilistion as required. A water truck is to be used as req uired to wet down the loading areas. The dust management actions listed above in the Dust Management Plan will be used as appropriate to minimise d ust generation and lift off. At the end of each day in summer the pit and active areas will be thoroughly wetted to minimise d ust lift off when the site is not active.

Ensure that products This will occur on the floor of the pit. to be loaded are moist Excavation normally does not and that the hardstand generate significant d ust. The d ust on which the loading originates from the wheel occurs is wetted down movements. or moist. Air dried product will be wetted down

with water canon or other methods. Operational hardstand will be wetted down when dry. Other contingencies will be used relating to operating times, additional water or sealant treatment and ceasing operations in adverse conditions. A water truck is to be used as required to wet down the loading areas. Water can also be applied from water canon, or sprinklers

Low

Low

1 5

Haulage Moderate Maintain haul road and - hardstand surfaces in Medium level good condition (free of continuous potholes, rills and activity product spillages) and

with suitable grades.

Reduce the length of the internal roads by maximising internal servicing efficiency.

Providing speed management on hardstand and the road network. Provide air conditioned closed cabins on plant. Treat access roads, hardstand and stockpile transport and loading areas with dust suppression sealant, water or seal coat.

PLANT - PROCESSING Hardstand Low Maintain hardstand traffic - surfaces in good

Low key ongoing condition (free of activities potholes, rills and

product spillages) and with suitable grades

Inactive Low - Moderate Leave the operations periods in a manner such that

dust lift off is minimised.

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Haul roads are to be regularly graded Low and maintained. They are to be watered regularly and have speed limits imposed. Alternatively they may be treated with stabilisers to reduce the potential for dust. At the end of each day, in summer or as required, the pit and active areas will be thoroughly wetted the minimise dust lift off when the site is not active. The haul roads are designed to reduce travel distance to save maintenance costs and time and to maintain efficiency and minimize greenhouse gas emissions. This is used.

All vehicles are air conditioned.

A dedicated water truck is to be maintained on site and used as required d uring the drier months.

The hard stand areas that are subject Low to traffic are limited in area b ut are able to be watered by the dedicated truck as required. Non traffic areas rapidly crust and stabilise. The bunding and perimeter Low vegetation will reduce wind speed and increase screening. At the end of each day, in summer or as required, the pit and active areas will be thoroughly wetted the minimise dust lift off when the site is not active. Inactive areas readily crust and seal the surface. A comprehensive liaison with the closest residents and the caretaker will provide a means of monitoring for visual dust at times of inactivity.

1 6

Processing Moderate

Continuous

Mobile and Moderate static plant -Operation Continuous

Loading and Stockpile Creation

TRANSPORT Road condition

Moderate

Continuous

Low -Moderate

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Dust Management Plan, M?0/1275, Russell Road, Wattleup Reel a

Treat processing areas Effective maintenance of the Low with water sprays, hardstand combined with adequate shields and d ust water treatment is used to minimise extraction. dust.

Maintain all plant in good condition.

Ensure mobile and static plant is provided with d ust extraction, shielding or filtration systems or wetting down as appropriate.

Shut down equipment when not in use.

Limit drop heights from conveyors and dump trucks.

Maintain access roads in good condition (free of potholes, rills and product spillages).

Water treatment is most commonly carried out by water truck. Crushing operations are to be watered as required to suppress d ust. Dust covers and equipment shields are maintained on all static plant where they are practicable. Continuous visual monitoring of d ust is used. Regular emptying of any d ust collection devices and the renewal of any filter devices is programmed in site operations. Rocla uses modern equipment that is maintained in good condition including the maintenance of d ust minimisation measures. Faults are repaired promptly. Operators are instructed to visually monitor dust, report and treat any visible d ust. Regular emptying of any d ust collection devices and the renewal of any filter devices is programmed. Dust management and monitoring forms part of the site ind uction programs. Faults are to be repaired promptly. Regular maintenance programs for all d ust suppression equipment are proposed. Dust management and monitoring forms part of the site ind uction programs. See Processin� above. Rocla uses this policy to save fuel and maintenance costs in addition to noise minimisation. This is used. It is a good safety and site management procedure.

The first 30 metres of road and cross over will be sealed. Effective maintenance of the hardstand and access road in addition to a sealed crossover will be used to minimise d ust. Moylan Road is sealed.

Low

Low

Low

1 7

Water and/or treat access roads and paved areas using a water tanker or sprinkler system.

Road Low Wet down or cover Transport - loads on trucks that

Frequent are likely to blow durina transport. Implement a site code outlining requirements for op erators and drivers. Maintain road trucks in a clean condition.

Avoid spillages on roads and clean up promptly.

Ensure that during loading, product does not become lodged on the sides of trucks from where it can fall off durina transoort. Drivers are to inspect trucks prior to leaving site. Any product not correctly located and secured is to be removed prior to exit from the site.

STOCKPILES Stockpiles Moderate Wet down stockpiles

- using water canon or On lot 6 only sprinklers as required.

Locate stockpiles behind bunds/ windbreaks or other screening barriers

Landform Research


S e e above. Internal roads are regularly watered as often as n ecessary to minimize dust gen eration. A dedicated water truck is to be retained on site and used when dust lift off is a potential hazard. Trucks are required to be covered or Low wetted down prior to exiting the site as required when transporting sandy and other materials that can blow. A site code and induction system is used.

Rocla and contractor road trucks are new and are maintained in a clean condition. Individual contractors are required to do likewise. Rocla has a policy of covering or Low wetting down loads as required and instructs drivers to report and clean uo spilla�es. This forms part of Rocla normal operational procedures.

This forms part of Rocla normal operational procedures.

Stockpiles will be assessed for their Low dust lift off potential and are treated accordingly. Where required wetting down is to be used. Sprinklers and water canon are proposed where n ecessary. Limestone stockpiles readily form a crust that protects from dust lift off. Sand from stockpiles moves by saltation up to 1 metre off the ground and is unlikely to escape the quarry faces as they will be located on the floor of the pit. This is normal practice. There are perimeter veg etated bunds in place. Finer materials will be located where dust liftoff is minimised.

18

Reduce the height of stockpiles. Low fiat stockpiles are less likely to be disturbed by wind than high conical ones. Wash crushed products where necessary. Locate coarser products around fine materials to assist wind protection of the finer products that are more likely to blow or contain greater amounts of dust. In extreme conditions stockpiles can be covered although this is often not practical.

Provide bunding, fencing and windbreaks around stockpiles and along the tops of bunds.

4.0 Dust Monitoring


The height of stockpiles is maintained at manageable levels that remain sheltered from the prevailing winds.

The limestone products do not need washing.

Not applicable to an operation such as this

This is not normally practical and liftoff will be managed by wetting down and locating stockpiles on the floor of the pit.

Perimeter buffer vegetation and bunding is in place

The most effective dust monitoring is the generation of visible dust.

The auditable condition is visible dust crossing the boundary of the premises; the lot boundary. This is the condition used on Department of Environment Regulation Licences and all other sand, limestone and hard rock quarries in Western Australia.

It is also the methods used by the Department of Mines and Petroleum to rapidly assess occupational dust on site.

For example Conditions of DER Licence L98355/2009/1 on WA Limestone Kerosene Lane Limestone Quarry state;

2.6.1

The licensee shall use all reasonable and practical measures to prevent and, where that is not practicable, to minimise dust emissions from the Premises.

2.6.2

The Licensee shall ensure that no visible dust generated by the activities of the Premises crosses the boundary of the Premises.

As invisible dust can be generated with the visible dust, recognising and dealing with visible dust is a very effective instantaneous method of recognizing excessive dust.



There are a number of mechanical dust monitors but only two are approved under Australian Standards. The mechanical measurement of dust can be difficult to obtain accurate results and a number of systems provide retrospective measurements only.

• Visual Dust Monitoring

Most dust generated from processing and vehicle movements has a very large visible component. Lesser risks emanate from excavation and land clearing.

The trigger for dust management is the generation of visual dust. The quarry manager and leading hand are ultimately responsible for site supervision of dust. This is the method required by the DER in the licence applying to the operations.

They will travel around the operations and pit frequently and are in two way radio contact with all mobile plant.

All operators on site will be instructed to be vigilant to dust generation and management and report any excessive dust or potential dust management issues.

When trigger conditions are detected and/or alerted, relevant action is taken. This can include additional water suppression, modification of procedure, delay until more favourable conditions are present, use of alternative equipment etc.

Human monitoring can detect potential dust risks prior, and take action prior, to the dust being generated. They also notice dust immediately such as from lyres, whereas machine monitoring has to rely on significant dust being generated, travelling to the boundaries of the premises and triggering an alarm. The operators would be negligent if they let the dust get to that level of impact prior to taking action.

Visual monitoring is even more effective when complemented by an extensive reporting and complaints process.

The photographs attached show how monitoring of visual dust is more effective than mechanical monitors located at the boundaries of a site.

Dust can be seen immediately it is generated, even if it is only a small amount. At that time it can be treated before it becomes a problem.

For dust to be detected by a mechanical monitor on the boundary, then there will have been large amounts of dust generated within the pit.

Notice on the attached photograph how far the site boundary would be from the active area. Notice have much dust would have to be generated for it to escape from the pits shown which illustrates that visual dust monitoring is the most effective instantaneous trigger for action.



Typical Limestone processing. Notice that any dust will be detected visually long before it escapes the pit. Once noticed water treatment can be applied before dust becomes an issue.

• Depositional Gauges

There is one depositional gauge that is designed to Australian Standard. It collects dust over a specified time such as a month, after which the dust is weighed. The collectors are non directional and there is no way of knowing from where the dust came. Being retrospective they are of little use during day to day management. The collector does not separate the various sized particles.

• Directional Depositional Gauge

These are depositional gauges that have four collectors arranged at the main compass points. They provide directional comparisons of the dust but again are real time measurement. They are not approved by Australian Standard but give directional information but does not separate the various dust sizes.

The dust measurements are again retrospective.

• Particle Counter

This is a small relatively inexpensive hand sized device. It can drift out of calibration relatively easily. It measures all particle sizes but does not give any ind ication of direction.

They are not approved by Australian Standard and give no directional information but separate the various dust sizes.

Landform Research 2 1


They can be left in place with alarms but, unless the data is combined with on site meteorological data, there can be no indication of the source of the dust.

During the day observing visible dust is similar but faster, and more reliable. At night or when the site is not manned treatment for dust can be made prior to closing for a break to minimise or negate dust lift off.

When the site is not being operated there will be nil or minimal generation of PM 2.5 because there will be no vehicle activity.

It is not believed that they offer any more effective management than observing visible dust as conditioned by the DER Licence.

• Beta Attenuation Monitor (BAM)

This is a larger more expensive machine. Dust is collected on a sticky tape, which is analysed by passing a Beta radiation beam through it.

It does not provide directional data and measures over a defined period such as one hour. It is not Australian Standard approved and is also retrospective in operation, although by only an hour or whatever time interval is set. It measures all particle sizes.

It can drift out of calibration relatively easily and a high level of operator skill is required for siting, operation and processing the results.

They are not approved by Australian Standard and give no directional information but separate the various dust sizes. An external power source is required.

It is not believed that they offer any more effective management than observing visible dust as conditioned by the DER Licence.

• Tapered Element Oscillating Microbalance (TOEM)

This is a large relatively expensive device that is Australian Standard approved.

A high level of operator skill is required for siting, operation and analysis of the results. An external power source is required, but generators themselves produce dust particles. A climate controlled enclosure is required. The TOEM normally costs up to $100 000 per annum to operate as specialist consultants are required to operate them

No directional information is provided but the TOEM can measure the various dust sizes. The device must be combined with separate wind monitoring.

They can be left in place with alarms but, unless the data is combined with on site meteorological data, there can be no indication of the source of the dust.

During the day observing visible dust is similar but faster, and more reliable. At night or when the site is not manned treatment for dust can be made prior to closing for a break to minimise or negate dust lift off.


It is not believed that they offer any more effective management than observing visible dust as conditioned by the DER Licence. Landform Research 22


• High Volume Sampler

This device draws a high volume of air across a filter paper, which is weighed from time to time. It is normally operated for 24 hourly periods. I t is Australian Standard approved and is directional, but is retrospective in providing data.

They are expensive, require a large external power source and require a high level of operator skill in siting, operation and processing.

Normally they are used for specific sites and not general monitoring.

• Visual Dust Monitoring

Most dust generated from processing and vehicle movements has a very large visible component. Lesser risks emanate from excavation and land clearing.

The trigger for dust management is the generation of visual dust. The quarry manager and leading hand are ultimately responsible for site supervision of dust. This is the method required by the DER in the licence applying to the operations.

They will travel around the operations and pit frequently and are in two way radio contact with all mobile plant.


When trigger conditions are detected and/or alerted, relevant action is taken. This can include additional water suppression, modification of procedure, delay until more favourable conditions are present, use of alternative equipment etc.

Human monitoring can detect potential dust risks prior and take action prior to the dust being generated. They also notice dust immediately such as from lyres, whereas machine monitoring has to rely on significant dust being generated, travelling to the boundaries of the premises and triggering an alarm. The operators would be negligent of they let the dust get to that level of impact prior to taking action.

Visual monitoring is even more effective when complemented by an extensive reporting and complaints process. Liaison with the closest sensitive premises is part of that process.

The effectiveness of the dust management is shown by no complaints regarding dust normally being received. No complaints are known relating to dust within the past five years.

A Liaison Program will be commenced with nearby and adjoining residents and the caretaker. They will be provided with a copy of the Dust Management Plan and contacts that can be used in the event that visible dust is noticed crossing the site boundary.

• Complaints and Reporting Mechanism

Visual monitoring is more effective when complemented by an extensive reporting and complaints process.



That reporting mechanism is enhanced by liaison with the closest sensitive premises who are in a position to alert the operators as required. Liaison with the closest residents assist residents who feel they have effective voice when it is used well.

A Liaison Program with nearby and adjoining residents and the caretaker can be very effective.

People within the program will be provided with a copy of the Dust Management Plan and phone and email contacts that can be used in the event that visible dust is noticed crossing the site boundary.

Liaison and lines of communication with the Local Authority and DER will also be undertaken.

An effective complaints mechanism is an essential part of the dust identification and management and is proposed.

Appendix3.

Procedures to be adopted following a complaint from a land development site

The procedures to be adopted by the developer following receipt of a dust-related complaint from a member of the public should be as follows:

Record the details of the complaint as specified below. The complaint form should be retained by the developer and be made available upon request by the local government or an authorised DEP officer.

Take measures to control any excessive dust by implementing the contingency arrangements which have been specified for the agreed site classification.

If the developer regards the complaint to be unjustified, then the developer should forward the details of the complaint to the local government within 24 hours.

As a guide, the procedures to be adopted by local government, following receipt of a dustrelated complaint from a member of the public or passed on by the developer, should be as follows:

Record the details of the complaint as specified below or on a local government-approved complaint form. The complaint fonn should be retained by the lOcal government and be made available upon request to an authorised DEP officer.

Evaluate the complaint by conducting a visual inspection,- preferably as soon as possible, taking into account the prevailing weather conditions which were being experienced at the time the complaint was lodged.

If the complaint is valid, instruct the developer to take measures to control any excessive dust by implementing the contingency arrangements which have been specified for the agreed site classification.

If the local government regards the complaint to be unjustified, contact the complainant and inform them of these findings.

If the local government is unable to resolve the complaint, after exhausting all possible avenues, then the local government may request advice from the DEP.



Appendix3.

Pollntion Incident Report Form - Land Development Sites

Sheet 3

Date: ... . . . . . . . . . . . . . . (!) Time: . ... ... . . . . . . . ... (2) Received by: . . . . . . . . . .. .. . . . . . . . . . . . . . . . ... (3)

From:

Name: .... . . . . ... . . . . . . . . . ... . . . . . ............ (4) Tel. N°·(s): .. . . . . . ... . .. . . . ... .. . ... . . . . . . . . . . . . . . . . . (5)

Address: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . ( 6)

Area/Suburb: . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (7) Municipality: . . . . . . . . , .... , ............... , . . . ...... (8)

Name of developer: ... . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . .. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (9)

Address of developer . . ... . . . . .. . . . . .. .. . . . . .. ... . . . . .. . . . . . . . . .. . .... . . . . . . . . . . . . . . . . .. .. . . .. . .. ... . ( 1 0)

Address of developntent: . . . . . ... . .. . ... . . .. . . . . ... . ... . .. .. .. . . . . . . . . . . ... . . . . . . . . . . . . ... . .. .. . ... . . ( 1 1 )

Type of complaint (Odour, Dust, Smoke, Noise, Other) . . . . ............. . . . . . . . . . . . . . . ......... ( l 2)

Details of Incident Received (effect/frequency): ........................................... , .......... ..

. . . . . . · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · · . . . . . . ( 13)

Referred to: ............................................ (l4) Date: ... . .. . . .... . . . . . . . . . . .. . . . . . . . . . (15)

Action Taken/Advice Given/Matter Referred to: ............................................ .

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

· · · · · · · . ... . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ( 1 6)

Recorded by: ..................................... (17)

5.0 Greenhouse Gas

Date: ...................................... ( I 8)

The development of the Perth Metropolitan Area has generated the need for limestone products, and if these cannot be obtained from this quarry they will be obtained from another.

Over the years trucks have become more efficient with respect to greenhouse gas emissions, particularly with the use of truck and trailer and road train configurations.

Rocla continues to seek ways to reduce the amount of fossil fuels used, and has obtained more efficient mobile plant and equipment when this has become economically available.

The internal design of the operations will try to minimise the haulage route to save energy use and potential impacts.



6.0 Proposed Methods to be used for monitoring dust

The dust monitoring will consist of a number of methods and

6.1 Visual Dust Monitoring

The trigger for dust management will be the generation of visual dust.

The quarry manager and leading hand are ultimately responsible for site supervision of dust and are in two way radio contact with all mobile plant.


When trigger conditions are detected and/or alerted, relevant action will be taken such as additional water suppression, modification of procedure, delay until more favourable conditions are present, use of alternative equipment etc.

Visual monitoring is even more effective when complemented by an extensive reporting and complaints process.

Liaison with the closest sensitive premises is part of that process.

The effectiveness of the dust management is shown by no complaints regarding dust normally being received. No complaints are known relating to dust within the past five years.

6.2 Remote video surveillance

Video cameras will be set up showing an overview of the operations, with particular reference to the excavation and processing on site.

The monitors will be used as a backup to on site visual monitoring, providing observations in locations that may not be visible to on site staff and to provide data at times when the site is not manned.

Recordings from the video monitoring will be made monthly or as required on Sundays and Public holidays to check for dust management when the site is not manned.

6.3 Boundary Static Monitors

Boundary static monitors will be installed at the boundary to north on Russell Road and south at Torgolye Road.

The monitors will be sampled monthly and the results retained records.

6.4 Particle Counter

Monitoring using a portable particle counter will be used for three days per month during the first summer months whilst the operations are located at the southern boundary and to check compliance with the National Environmental Protection Measure (NEPM) ambient air 24 hour PM1 0 goal of 50 ug/m3. This is the applicable level at residences.



The particle Counters are not approved by Australian Standard and give no directional information but separate the various dust sizes. They can be left in place with alarms but, unless the data is combined with on site meteorological data, there can be no indication of the source of the dust.

It is noted that the Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992 permit higher concentrations of suspended solids. Nearby dwellings lie within Area B of the Kwinana Policy. See Attached.


It is not believed that they offer any more effective management than observing visible dust but will be used to ensure that compliance with the NEPM is achieved.

6.4 Liaison

A Liaison Program will be commenced with nearby and adjoining residents.

They will be provided with a copy of the Dust Management Plan and phone and email contacts that can be used in the event that visible dust is noticed crossing the site boundary.

A sign will be placed at the entrance to the site and on Kerosene Road with contact phone numbers and email address to enable members of the community to contact the company in the event of a dust issue.

6.5 Complaints procedure

A complaints book that lists the items below will be used. The book will be available to officers of the City of Rockingham and DER.

• The complaint, • Nature of the complaint, time and date, • Source of the complaint,

Investigations of the complaint, • Results of the investigation, • If the complaint is valid, any mitigation actions that result, • Any communication with the complainant.



Dust Management - Applicable Legislation I Policies

• Guidance for the Assessment of Environmental Factors, EPA, March 2000. • Land development sites and impacts on air quality, DEP, 1996.

Department of Environmental Protection Guidelines, November 1996 and DEC 2008, A guideline for the development and implementation of a dust management plan.

• DEC 2011 Guideline for Managing the Impacts of Dust and Associated Contaminants from Land Development Sites, Contaminated Sites Remediation and other Related Activities.

Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992

Commitments to Dust Management

• Rocla will take the necessary steps to manage and contain d ust by implementing and maintaining the Dust Management Plan.

Attached

Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992


direct lndial: our ref: your ref...0 0 rocla ltd 130 fauntleroy avenue redcliffe wa 6104 att: vern...

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