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Karratha Liquid Waste Treatment Plant and Waste Transfer Station (L8332/2009/3) Hottpad - Works Approval Supporting Document Prepared for: Cleanaway 6 September 2019 3402AA_Rev2

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Page 1: Hottpad - Works Approval Supporting Document

Karratha Liquid Waste

Treatment Plant and Waste

Transfer Station

(L8332/2009/3)

Hottpad - Works

Approval Supporting

Document

Prepared for:

Cleanaway

6 September 2019

3402AA_Rev2

Page 2: Hottpad - Works Approval Supporting Document

360 Environmental Pty Ltd

Disclaimer

This report is issued in accordance with, and is subject to, the terms of the contract between the Client and 360

Environmental Pty Ltd, including, without limitation, the agreed scope of the report. To the extent permitted by law, 360

Environmental Pty Ltd shall not be liable in contract, tort (including, without limitation, negligence) or otherwise for any use

of, or reliance on, parts of this report without taking into account the report in its entirety and all previous and subsequent

reports. 360 Environmental Pty Ltd considers the contents of this report to be current as at the date it was produced. This

report, including each opinion, conclusion and recommendation it contains, should be considered in the context of the report

as a whole. The opinions, conclusions and recommendations in this report are limited by its agreed scope. More extensive,

or different, investigation, sampling and testing may have produced different results and therefore different opinions,

conclusions and recommendations. Subject to the terms of the contract between the Client and 360 Environmental Pty Ltd,

copying, reproducing, disclosing or disseminating parts of this report is prohibited (except to the extent required by law)

unless the report is produced in its entirety including this cover page, without the prior written consent of 360 Environmental

Pty Ltd.

© Copyright 2019 360 Environmental Pty Ltd ACN 109 499 041

Document

Reference Revision

Prepared

by Reviewed by Admin Review

Submitted to Client

Copies Date

3402AA Rev 0 INTERNAL DRAFT HT TS - - 24/7/19

3402AA Rev 1 CLIENT DRAFT HT Cleanaway NL 1 25/7/19

3402AA Rev 2 CLIENT FINAL HT/AW Cleanaway NL 1 6/9/19

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3402AA Supporting Works Approvals Document Karratha Liquid Waste Treatment Plant (L8332/2009/3)

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Table of Contents

1 Background .................................................................................................. 1

1.1 Proponent Details .................................................................................................. 1

1.2 Scope of Works Approval Application .................................................................... 2

2 Hottpad Overview ........................................................................................ 3

2.1 Construction and Installation ................................................................................. 8

2.2 Treatment Process ................................................................................................. 9

2.3 Commissioning ..................................................................................................... 12

2.4 Water Management ............................................................................................. 13

2.5 Waste Management ............................................................................................. 13

2.6 Advantages of the Hottpad .................................................................................. 14

3 Regulatory Context .................................................................................... 15

3.1 Legislation ............................................................................................................ 15

4 Existing Environment .................................................................................. 16

4.1 Climate ................................................................................................................. 16

4.2 Landscape ............................................................................................................ 17

4.3 Topography .......................................................................................................... 17

4.4 Ambient Air Quality .............................................................................................. 17

4.5 Hydrology and Hydrogeology ............................................................................... 17

4.6 Environmentally Sensitive Areas .......................................................................... 18

5 Sensitive Receptors .................................................................................... 19

6 Environmental Impacts and Management ................................................... 20

6.1 Air Quality ............................................................................................................ 20

6.2 Noise .................................................................................................................... 22

6.3 Odour ................................................................................................................... 23

6.4 Fire ....................................................................................................................... 23

6.5 Cyclones and Flood Risk ...................................................................................... 24

7 Implementation Strategy ............................................................................ 25

7.1 Communication, Competency, Training and Awareness ...................................... 25

7.2 Reporting .............................................................................................................. 25

8 Contingency and Incident Response ........................................................... 27

8.1 Air Quality ............................................................................................................ 27

8.2 Noise and Odour .................................................................................................. 27

9 Limitations .................................................................................................. 29

10 References ................................................................................................. 30

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List of Tables

Table 1: Proponent Details ................................................................................................ 1

Table 2: Project Elements ................................................................................................. 3

Table 3: Estimated Construction Costs ............................................................................ 9

List of Figures

Figure 1: Site Location .................................................................................................... 32

Figure 2: Site Layout ....................................................................................................... 33

Figure 3: Sensitive Receptors ......................................................................................... 34

List of Plates

Plate 1: Site Layout at Karratha Waste Facility ................................................................ 5

Plate 2: Proposed Layout of the Hottpad System ............................................................. 6

Plate 3: Site Layout of Hottpad System ........................................................................... 7

Plate 4: Hottpad System proposed for the Karratha Facility ............................................ 8

Plate 5: Heating process and cross section view of the Hottpad ...................................... 9

Plate 6: Hottpad Process Overview ................................................................................ 10

Plate 7: Process flow of Hottpad ..................................................................................... 11

List of Appendices

Appendix A Hottpad Design Details

Appendix B Air Quality Assessment

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360 Environmental Pty Ltd 1

1 Background

Cleanaway Waste Management Limited (Cleanaway) is Australia’s leading waste

management, recycling and industrial services company. Cleanaway has recently acquired

Tox Free Australia Pty Ltd (Toxfree) who was the operator and licence holder of the

Karratha Liquid Waste Treatment Plant and Waste Transfer Station (the facility). The

facility currently accepts and treats liquid and solid waste from regional industries under

prescribed premises licence L8332/2009/3.

Cleanaway is proposing to install and operate a Heated Overland Thermal Treatment

(Hottpad) system at the facility. The Hottpad is designed to accept and treat hydrocarbon

sludge received from Barrow Island and other oil and gas operations. The Hottpad is the

subject of this Works Approval application and supporting document.

Following the approval of the Works Approval application, a Licence Amendment

application will be submitted to include Category 60 and change the name of the licence

holder from Toxfree Australia Pty Ltd to Cleanaway Co Pty Ltd.

1.1 Proponent Details

Table 1 provides the details of the proponent for the construction, installation and

operation of the Hottpad and the current licence holder details.

Table 1: Proponent Details

Proponent Details

Proponent Cleanaway Waste Management Ltd

Registered Office Level 4, 441 St Kilda Rd

MELBOURNE VIC 3004

ACN 101 155 220

Contact Person Les Egerton

Environmental Business Partner

92 Radium Street

Welshpool WA 6106

P: 08 9351 1338

E: [email protected]

Licence Details

Type Licence

Holder Tox Free Australia Pty Ltd (now owned by Cleanaway)

Premises Karratha Liquid Waste Treatment Plant and Waste Transfer

Station

Location Details Lot 126 on Plan 183297

Suburb COOYA POOYA WA 6714

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Licence Details

Local Government Karratha City

Date Issued 2016-04-29

Date Commenced 2015-03-30

Date of Expiry 2031-03-29

Category 61 - Liquid waste

facility

100 tonnes or more per year

40,000 tonnes per annual period

61A - Solid waste

facility

1,000 tonnes or

more per year

40,000 tonnes

per annual period

1.2 Scope of Works Approval Application

The purpose of this document is to meet the requirements of the Department of Water

and Environmental Regulation (DWER) Application for Works Approval pursuant to Part

V of the Environmental Protection Act 1986 (EP Act) and as a prescribed premise under

Schedule 1 Part 1 of the Environmental Protection Regulations 1987 (EP Regulations).

The Works Approval application is to support the installation, construction and

commissioning of the Hottpad at the Karratha Waste Treatment and Transfer Station.

Cleanaway is of the understanding that DWER will provide notification to Cleanaway as

to the ability to progress from commissioning to a time limited operation prior to a Licence

Amendment being issued.

Following consultation with DWER, it is understood that the Hottpad system will be

required to be regulated under Category 60: Incineration. Once the Works Approval is

obtained and construction has been completed, Cleanaway will submit a Compliance

Report and apply for a Licence Amendment prior to commencing operations.

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2 Hottpad Overview

The Hottpad is a novel process for the treatment of oil impacted wastes and sludges. It is

an ex-situ thermal remediation technology that will utilise smouldering combustion (i.e.

flameless) in a sustained thermal oxidation reaction to destroy hydrocarbons in oily sludges

derived from local oil and gas operations. Smouldering combustion is the exothermic

oxidation of an organic waste which is utilised as fuel. The reaction occurs at the fuel

surface and is limited by the rate of oxygen diffusion across this surface.

The process involves a short heating period to ignition and then followed by air injection

only (no additional heat is applied). Heat used to sustain the treatment process is provided

by the combustion of the waste itself (near complete conversion of waste to CO2) and

therefore the Hottpad system is different from incineration. The resulting reaction is

slower and lower in temperature than a flaming reaction (as used in incineration), and

under the right conditions, self-sustaining.

Due to the self-sustaining nature of the smouldering process, the energy requirements are

considerably lower than traditional thermal remediation technologies (such as incineration)

which leads to a less energy intensive remediation option and the process results in more

thorough treatment with limited by-products.

The key project elements of the Hottpad are outlined below in Table .

Table 2: Project Elements

Elements Description

Life of the Project ~25 years

Native Vegetation

Disturbance

Nil. Site is already cleared.

Site Components 2 x Containerized Heatpads (12.5m x 2.5 m). Each container will

comprise:

• Heater elements

• air injection

• emissions extraction canopy

• sprinkler quenching system

1 x Control room

2 x Gensets

1 x Injector blower

1 x Extractor blower

1 x Continuous Emissions Monitoring System (CEMS) (NOx, SOx,

CO2, CO, O2, PM)

1 x Exhaust Stack system

1 x odour treatment system if required

Operating hours 24 hours whilst in cycle

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Elements Description

Inputs

Hydrocarbon sludge 4,000 tonnes per annum (60 tonnes per week, 30 tonnes per 4 day

cycle)

Waste soil or clean

fill

Either/or both

Power 2 x Stamford 424 kW diesel generators or similar. Potential for

mains connection if/when available

Outputs

Treated soil Suitable for reuse in the Hottpad process or disposal to landfill

(investigating options)

Air emissions

(steam)

Steam, CO2, CO and small amounts of VOCs, NOx and SOx (See

Section 6.1).

Noise emissions Exhaust/extractor fans – the system will comprise an injection and an

extraction blower. Both are fitted with silencers and will operate at

low static pressures / low speeds which will noise generated during

operation to a minimum.

Diesel generators – power will be provided by one of two Stamford

450 kW diesel generators. The generators are within an enclosed

shipping container and will generally operate at around 80% during

the heating phase (12 hours) and 25% for the remainder of the

treatment (84 hours).

Dust emissions Dust will only be generated at the end of the cycle when the lid is

removed from the Hottpad system. Dust suppression sprinklers are

built into the system and will be utilised to manage any potential dust

emissions.

There will be no potential for dust emissions at the front end of the

process as the product is a sludge material.

Emissions to Water Nil

Emissions to Land Nil

Monitoring

CEMS Continuous emissions monitoring system (CEMS) at the exhaust

stack to measure exhaust gasses emitted from combustors. This is a

process measure and not intended for pollution control.

SmartFID SmartFID is a mobile device for continuous measurement of volatile

organic compounds (VOC). It works with a flame ionization detector

(FID) and converts hydrocarbon concentrations in a measuring gas

sample into an electrical signal. This happens with a hydrogen

diffusion flame and VOC-free air in a burner in an electrical field.

This is a process measure and not intended for pollution control.

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Plate 1: Site Layout at Karratha Waste Facility

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Plate 2: Proposed Layout of the Hottpad System

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Plate 3: Site Layout of Hottpad System

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2.1 Construction and Installation

The proposed site layout of the Hottpad at the Karratha facility is provided in Plate 2. A

typical final constructed and set up of the Hottpad is provided in Plate 3. The Hottpad

proposed for the Karratha facility is a provided in Plate 4, with a more detailed plan

included in Appendix A – the two containerised Hottpad system will be placed on a

hardstand area, self-bunded and completely enclosed (sealed). Plate 5 shows a cross

section view of the Hottpad and the proposed waste treatment ratios (clean fill vs. oily

sludge).

The structure will be pre-fabricated and brought to site via road train for final installation

and commissioning.

Plate 4: Hottpad System proposed for the Karratha Facility

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Plate 5: Heating process and cross section view of the Hottpad

Table 3 provides the estimated construction costs associated with the installation of the

Hottpad. These estimates have been used to calculate the appropriate Works Approval

application fee.

Table 3: Estimated Construction Costs

Aspect Detail

Prescribed Premises category Category 60

Capacity range 320 kilograms per hour

(30 tonnes per 4-day cycle)

Premises construction cost $550,000

Total Works Approval Fee

(www.der.wa.gov.au/WorksApprovalFeeCalculator)

$5,075.00

2.1.1 Power

Two Stamford 450 kW diesel generators will be used to power the Hottpad; alternatively,

the system may be powered through mains power. The heating phase will require the use

of a single generator operating at 80% power load and the smouldering phase will require

the use of a single generator operating at 25% power load. Atmospheric emissions from

each generator will be released via dedicated stacks and the units will be housed within a

standard container.

Fuelling of the generator will be undertaken via a mobile refuelling vehicle.

The proposed Hottpad system and associated diesel generator unit will be located within

the area labelled ‘Dangerous Goods Storage’ in Plate 1. This area is a concrete bunded

area in accordance with the Department of Mines, Industry Regulation and Safety

(DMIRS) Storage and handling of dangerous goods: Codes of Practice and the Dangerous

Goods Safety Act 2004.

2.2 Treatment Process

An overview of the treatment process is presented in Plates 6 and 7 and described as

follows:

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• Waste oil sludge is mixed with sand or clean fill material in an existing mixing pond,

located approximately 30 m south of the Hottpad

• The sludge/sand mixture is then transferred into the Hottpad containers and

covered with 0.5 m of clean sand

• The canopy is then placed on the Hottpad to capture emissions

• Smouldering combustion is initiated by heaters within the base of the pad

(~500˚C) and sustained by air injection from a blower mechanism

• Once smouldering is initiated heaters are turned off

• Emissions are collected by canopy and extraction blower.

The heating phase occurs over a period of 12-hours, followed by the smouldering phase,

which is expected to last up to 3.5 days.

Plate 6: Hottpad Process Overview

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Plate 7: Process flow of Hottpad

The following is an overview of the Process (email correspondence, Chevron 23 July 2019):

Combustion is the exothermic oxidation of carbon-based compounds (i.e., fuel) to primarily

carbon dioxide (CO2), water, and energy. The combustibility of non-aqueous phase liquids

(NAPLs) is a characteristic that has been successfully exploited through the ex-situ

incineration of NAPLs and contaminated soil (e.g., Howell et al., 1996); however,

incineration is achieved primarily via flaming combustion which is an energy inefficient

process (i.e., high heat losses), requiring the continuous addition of fuel and, often,

supplemental energy.

Smouldering combustion, by contrast, is the exothermic oxidation of a condensed phase

(i.e., solid or liquid) occurring on the fuel surface (Ohlemiller, 1985). Smouldering is limited

by the rate of oxygen-transport to the fuel’s surface, resulting in a slower and lower

temperature reaction than flaming. Importantly, smouldering can be self-sustaining (i.e.,

no energy input required after ignition) when the fuel is (or is embedded in) a porous

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medium. Self-sustaining smouldering occurs because the solid acts as an energy sink and

then feeds that energy back into the un-burnt fuel, creating a very energy efficient reaction

(Howell et al., 1996). Solid porous fuels such as polyurethane foam (Torero and Fernandez-

Pello, 1996), cellulose (Ohlemiller, 1985), and charcoal are typical media that exhibit self-

sustained smouldering.

For these materials, studies have demonstrated that the rate of propagation of the

combustion front and net heat generated are affected by the velocity (magnitude and

direction) of air flow, pore diameter of the medium, and the fraction of porosity occupied

by fuel, air and non-reacting materials (DeSoete, 1966). Smouldering reactions can leave

a carbon-based residue (oxygen limited reactions) or can result in complete combustion of

the fuel (fuel limited reactions) (Schult et al. 1995). The former is common in combustible

porous media where the char minimizes heat losses and enables the reaction to propagate.

The latter is common when the fuel is combined with an inert porous media that provides

the required insulation even in the fuel’s absence. While most research focuses on

smouldering of solid fuels, there are several examples of combustion of a liquid fuel

embedded in a porous matrix. Lagging fires occur inside porous insulating materials soaked

in oils and other self-igniting liquids (Drysdale, 1998). To enhance oil recovery, combustion

fronts are initiated in petroleum reservoirs to drive oil towards extraction points (Greaves

et al., 2000). However, the smouldering of liquids as a remediation technique is entirely

novel (Switzer et al., 2009).

NAPL smouldering is different from existing thermal remediation techniques. Thermal

remediation requires the continuous input of energy in order to primarily volatilize and, in

some cases, thermally degrade (pyrolize) and mobilize (via viscosity reductions) the

organic phase. All of these processes are endothermic and remediation continues as long

as externally-supplied energy input is sustained throughout the NAPL-occupied porous

medium. In contrast, NAPL smouldering has the potential to create a combustion front

that:

i. initiates at a single location with the NAPL-occupied porous medium

ii. initiates with a one-time, short duration energy input

iii. propagates through the NAPL-occupied medium in a self-sustained manner, and

iv. destroys the NAPL wherever the front passes.

2.3 Commissioning

Following the attainment of the Hottpad works approval and prior to obtaining a licence

amendment, it is proposed that the Hottpad will be subject to a 3-6 month commissioning

phase. The commissioning phase will consist of each component undergoing an integrity

test of all components prior to progressing into operations.

The commissioning phase will involve the following activities:

• Assembly and installation of the Hottpad

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• Testing all systems (electrical, plumbing, odour control etc.)

• Running a test cycle, involving:

o Acceptance of waste oil sludge

o Mixing of waste sludge with clean fill in an existing mixing pond

o Treatment of the mixture via combustion

An analytical program will be undertaken and involve monitoring of emissions through

CEMS and SmartFID to allow for optimisation of the process which will include an

assessment of the emissions profile of the system. This will allow for reconfigurations in

the treatment process to ensure air quality criteria is being met during operations.

2.4 Water Management

No water is required in the construction, installation or operation of the Hottpad system;

therefore no groundwater abstraction will be required and the proposed activities will not

intercept/interact with groundwater.

The nature of the Hottpad system is a bunded hardstand and therefore will not interfere

with surface water as it is a closed system. Cleanaway has already established surface

water management measures on site and is regulated by their prescribed premises licence

L8332/2009/3. Surface water management will continue to be managed in accordance

with the licence (i.e. washdown water is directed and treated through the liquid waste

treatment plant, water sumps and bunded areas are managed so that contaminated water

does not leave site, freeboard is maintained in ponds etc.).

Water for dust suppression around the site (including the Hottpad) will be obtained from

the Treated Waste Water tanks, as required.

2.5 Waste Management

Other than oily sludge to be treated via the Hottpad, no additional hazardous materials will

be used in the Hottpad treatment process.

Cleanaway has stringent waste acceptance procedures at the Karratha facility to ensure

that only appropriate and approved waste materials are brought onto the site for

treatment. Prior to accepting any oily sludge waste, testing of the material will be

undertaken to ensure it meets the criteria for the Hottpad system. The receipt of sludge is

already approved under the existing Licence Condition 1.2.5.

Based on a field trial of the Hottpad operation at Chevron’s Batangas operations the oily

sludge before treatment was 25,000 – 35,000 mg/kg TPH (total petroleum hydrocarbon)

and after treatment the material was <200 mg/kg TPH.

The waste soil generated from the Hottpad process will be disposed of at an approved

landfill facility or re-used in the process. Alternative methods for using the waste soil will

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also be investigated. Cleanaway has existing procedures to ensure that the treated waste

sludge/material is tested prior to being placed in landfill. These procedures will ensure

that the material is disposed of in accordance with DWER’s Landfill Waste Classification

and Waste Definitions 1996 (as amended 2018) under the Environmental Protection Act

1986.

All other waste associated with the site will be managed in accordance with the existing

licence conditions (L8332/2009/3).

2.6 Advantages of the Hottpad

Currently, waste sludge from oil and gas operations that is received at the Karratha facility

is stored temporarily before being transported to facilities in Victoria for thermal

destruction (Geocycle). The Hottpad provides an alternative to this transportation and

thus reduces the overall environmental (greenhouse gas) footprint whilst providing

logistical and commercial benefit. The Hottpad does not require additional fuel and

reduces emissions from transporting the waste whilst also reducing overall traffic.

The Hottpad system is scalable and mobile and thus can be adjusted according to a

facilities requirements or waste acceptance volumes. Additionally, the final treated waste

material is suitable for reuse.

The Hottpad system is aligned to the objectives as set out in the Waste Authority’s Waste

Strategy 2030 including ‘generating less waste and manage materials locally’, ‘recovering

more value and resources from waste’, and ‘managing waste responsibly’.

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3 Regulatory Context

3.1 Legislation

3.1.1 Part V of the Environmental Protection Act 1986

Listed as a prescribed premise under Schedule 4 – Part 1 of the EP Regulations, the

activity has the potential to generate noise and air emissions that may impact nearby

receptors. Part V of the Act covers the control of pollution. According to Schedule 4 of

the EP Regulations, the proposal requires a Works Approval and Licence amendment prior

to the commencement of operations.

In 2004, amendments to the EP Act introduced provisions for regulating the clearing of

native vegetation. If it is intended for native vegetation to be cleared, a permit needs to

be obtained. Since the site is already cleared, there is no requirement to disturb any native

vegetation and thus a clearing permit is not being sought.

DWER is the agency responsible for the environmental assessment and regulation of the

Karratha Waste facility and clearing permits.

3.1.2 Planning and Development Act 2005

The Planning and Development Act 2005 provides for an efficient and effective system of

land use planning in WA. The aim of the Act is to promote sustainable use and

development of the land. The site is located within the City of Karratha Local Government

Area (LGA).

The requirement to submit a Development Application is currently being investigated.

Cleanaway will ensure that relevant Local Government approvals are obtained prior to the

system being installed or operated.

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4 Existing Environment

4.1 Climate

The site is located within the Pilbara region of Western Australia. The Pilbara has an arid

tropical climate with two distinct seasons, a hot and wet summer from October to April

and a mild winter from May to September. The region features low rainfall, primarily falling

in late summer due to the influence of tropical cyclones and the monsoon, which can cause

periods of high humidity and thunderstorms. Along the central Pilbara coast the cyclone

season runs from mid-December to April peaking in February and March (BOM 2019)

The closest Bureau of Meteorology (BoM) weather station is at Karratha Aero (004083)

located approximately 11 km North of the site. The average annual rainfall recorded at

Karratha Aero was 296.7 mm over the recording period from 1971 to 2019. Average

temperatures fluctuate between an average minimum of 26.7°C and maximum of 35.6°C

in Summer, and an average minimum of 13.8°C and 26.3°C in winter (Graph 1).

Graph 1: Mean Rainfall and Temperature for Karratha Aero (Station Number: 004083) from 1971 to 2019

In semi-desert-tropical areas the highest evaporation rates occur during high temperature

days, with evaporation falling during the wet season. Annual Pan Evaporation within the

region is between 3,200 – 3,600 mm (Bureau of Meteorology, 2018). The prevailing winds

exhibit distinct seasonal patterns, with a dominant westerly component evident during the

spring and summer months, with more frequent easterly winds occurring during the winter

0

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50

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70

80

0

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25

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Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Rai

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m)

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°C)

Rainfall

Max. temperature

Min. temperature

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months. Greater variability and more frequent light winds are evident during the autumn

months.

4.2 Landscape

The site lies within the Pilbara Bioregion and Roebourne subregion (PIL4). The Roebourne

subregion is described as quaternary alluvial and older colluvial coastal and sub-coastal

plains with grass savannah of mixed bunch and hummock grasses, and dwarf shrub steppe

of Acacia stellaticeps or A. pyrifolia and A. inaequilatera. Uplands are dominated by Triodia

hummock grasslands. (Kendrick and Stanley 2001).

The site lies within the mapped Horseflat System (281Hf) soil-landscape unit which is

described as Gilgaised clay plains supporting Roebourne Plains grass grasslands and minor

grassy snakewood shrublands (Department of Agriculture and Food WA [DAFWA] 2012).

4.3 Topography

The topography across the site is mapped entirely as 25 mAHD indicating a relatively flat

site.

4.4 Ambient Air Quality

The Department of Water and Environment Regulation (DWER) carried out the Pilbara Air

Quality Study (PAQS) between 1998 and 2000. The study included monitoring for ozone,

NOx and SO2 within the Karratha townsite (Ramboll 2019).

The maximum 1-hour average ozone concentration recorded for Karratha during the study

period was 0.06 ppm. This concentration is considered to be well above natural levels for

the region and likely associated with bushfire events. The 95th percentile 1-hour average

concentration was 0.04 ppm (Ramboll 2019).

The maximum 1-hour average NO2 concentration measured at Karratha was 0.062 ppm

(126 μg/m3) and the annual average remained below 0.002 ppm (4.0 μg/m3). The

maximum 1-hour average SO2 concentration measured at Karratha was 0.134 ppm (378

μg/m3). The maximum 24-hour average was 0.006 ppm (17 μg/m3), while the annual

remained below 0.001 ppm (2.8 μg/m3) (Ramboll 2019).

4.5 Hydrology and Hydrogeology

4.5.1 Surface Water

The operation is located within the Indian Ocean Surface Water Division, and the Port

Hedland Coastal Basin. The Coastal sub catchment covers an area of 7,443 km2. Water

drains towards to the coast via several ephemeral drainage lines. There are no lakes, rivers

or significant water bodies within the site (Department of Water and Environmental

Regulation, 2016) (Figure 3). The Site is within the Proclaimed Pilbara Surface Water

Area.

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4.5.2 Groundwater

The project occurs within the Pilbara Groundwater area. Based on groundwater monitoring

at Cleanaway’s waste facility located 250 m north of the site, groundwater levels can be

expected to range from 8.97 metres below ground level (mbgl) and 9.82 mbgl (360

Environmental, 2019).

There are no Public Drinking Water Source Areas (PDSWA) within proximity to the Project

(DWER 2019). The nearest PDSWA is the Harding River, which is approximately 36 km

south east of the site.

4.6 Environmentally Sensitive Areas

The site is not mapped within any Environmentally Sensitive Areas (ESAs), with the

nearest located approximately 40 km north of the study area, on the Burrup Peninsula

(DWER 2018).

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5 Sensitive Receptors

The EPA’s (2005) Guidance for the Assessment of Environmental Factors – Separation

Distances between Industrial and Sensitive Land Uses recommends a minimum separation

distance of 1,000 m between ‘Incineration for organic waste’ sites and sensitive receptors.

There are no sensitive receptors within 1,000 m of the site.

No hazardous materials will be used in the processing of the Hottpad system. The waste

to be treated contains hydrocarbons and oily sludge.

5.1.1 Human Receptors

The three nearest sensitive receptors located within 5 km of the site include (Figure 3):

• Stayover at Ausco - serviced accommodation for mining and resource workers in the

Karratha region, located approximately 2 km to the north north-east of the site

• Bayton – a residential suburb located approximately 6.5 km north-west of the site.

• The MAC Village Karratha – serviced accommodation for mining and resource

workers in the Karratha region, located approximately 6.8 km to the north-east of the

site.

Operations will occur over a full 24 hour cycle, however filling and/or emptying operations

will be restricted to the hours of 6:00am – 6:00pm Mondays to Sundays.

5.1.2 Natural Receptors

There are no significant natural receptors surrounding the premises boundary and

therefore the installation and operation of the Hottpad is not likely to impact natural

receptors. The site is cleared of vegetation and the premises is mostly surrounded by

already cleared and/or disturbed areas. There are no natural water sources within the

surrounding area, the closest water feature is an ephemeral water course 300 m to the

west of the premises. There are no environmentally sensitive areas within the vicinity of

the premises.

Dust emissions may be generated by the installation of the Hottpad, however this is not

expected to be significant and given the large buffer of cleared areas surrounding the site,

it is not likely to have a significant impact on surrounding vegetation. Additionally, dust

management and mitigation measures will be continued as per Licence 8322/2009/3

which include dust suppression using treated wastewater from holding tanks. These

measures will further reduce the risk of dust emissions associated with installation and

operation of the Hottpad.

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6 Environmental Impacts and Management

6.1 Air Quality

An air dispersion modelling assessment was undertaken by Ramboll Australia Pty Ltd

(Ramboll) to determine the likely air quality impacts associated with the two operational

phases of the proposed Hottpad system; heating and smouldering (Ramboll 2019,

Appendix B). The model was undertaken for the key contaminants that may be present in

atmospheric emissions from the proposed Hottpad system and associated diesel

generators. The maximum predicted ground level concentrations (GLCs) of the modelled

compounds were compared against the relevant ambient air quality criteria.

Predicted GLCs were estimated using the AERMOD model and a meteorological dataset

primarily developed using measured meteorological data from the BoM Karratha Airport

Station. The emission estimates for the Hottpad system were derived from emissions

testing data provided by Chevron, as reported for their Batangas operations. The samples

were collected upstream of any emissions treatment systems at the Batangas site and the

maximum concentrations measured across all sampling events for each of the monitored

compounds were conservatively applied in the calculation of the emission estimates. The

emission estimates for the diesel generators were derived from emission factors published

by the National Pollutant Inventory (NPI) for combustion engines and fuel usage rates for

the nominated power loads, as provided by Chevron.

Key pollutants of concern that were assessed in the modelling included carbon monoxide

(CO), oxides of nitrogen (NOx), sulfur dioxide (SO2), particulate matter (PM10 and PM2.5);

sulphide compounds including carbon disulphide (CS2) and hydrogen sulphide (H2S);

hydrogen chloride (HCl), hydrogen fluoride (HF), mercury and a suite of volatile organic

compounds (VOCs) including (but not limited to) benzene, toluene, xylenes,

Benzo(a)pyrene (B[a]P) (as a marker for Polycyclic Aromatic Hydrocarbons [PAHs]).

The air quality criteria used in the assessment is DWER’s Guidance Statement for Risk

Assessments (DWER 2017), which lists Specific Consequence Criteria to be considered

in determining public health and environment impacts. The publications containing air

quality criteria relevant to this assessment include:

• National Environment Protection (Ambient Air Quality) Measure (NEPC 2015)

• National Environment Protection (Air Toxics) Measure (NEPC 2011)

• Approved Methods for the Modelling and Assessment of Air Pollutants (AMMAAP)

in New South Wales (NSW EPA 2016).

In the absence of NEPM and/or NSW EPA standards for other relevant compounds,

ambient air quality criteria and health protective guidelines have been sourced from other

reputable authorities, namely the California Office of Environmental Health Hazard

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Assessment (OEHHA) (Ramboll 2019). See Table 1 of Appendix B for the specific

Ambient Air Quality Criteria.

6.1.1 Potential Impact

GLCs were predicted for both the smouldering and heating phases and compared against

relevant ambient air quality for the protection of human health and odour annoyance. The

cumulative impact upon existing air quality in the Karratha region was also determined for

each operating phase operating scenario, using ambient air quality monitoring data

reported for the PAQS.

6.1.1.1 Smouldering Phase

The maximum GLCs predicted for the smouldering phase (i.e. in conjunction with a single

generator operating at 25% power load) are expected to remain below the corresponding

air quality criteria for each of the modelled compounds (Ramboll 2019).

• The maximum predicted 24-hour PM2.5 GLC most closely approaches the relevant

criteria, equal to 92% of the corresponding NEPM Standard. However, contours of

the maximum predicted 24-hour average PM2.5 GLCs indicate that this concentration

is expected to occur onsite and the predicted GLCs fall below 20% of the NEPM

Standard within 100 m of the site boundary. At the nearest sensitive receptor, the

maximum predicted 24-hour average PM2.5 GLC is equal to 0.6% of the NEPM

Standard. The highest annual average PM2.5 GLC is expected to equal 42% of the

corresponding NEPM

• The maximum predicted 24-hour average PM10 GLC is equal to 47% of the

corresponding NEPM Standard. At the nearest sensitive receptor, the maximum

predicted 24-hour average PM10 GLC is equal to 0.7% of the corresponding standard.

The annual average PM10 GLCs are predicted to be less than 14% of the annual

NEPM Standard

• The maximum predicted 1-hour NO2 concentration is equal to 42% of the

corresponding NEPM Standard and is expected to occur within close proximity of the

modelled sources. At the nearest sensitive receptor, the maximum predicted 1-hour

NO2 GLC is equal to 1.6% of the NEPM Standard. The annual average NO2 GLCs

are predicted to be less than 15% of the annual NO2 NEPM Standard.

6.1.1.2 Heating Phase

• The maximum predicted 24-hour average PM2.5 and PM10 GLCs (i.e. in conjunction

with a single generator operating at 80% power load) are expected to exceed the

corresponding NEPM Standards. However, these GLCs are considered highly

conservative and are likely to represent an overestimate of the expected impacts as

the model has assumed continuous emissions across each 24-hour period, while the

heating phase is only expected to last for a duration of 12-hours. Furthermore, the

predicted exceedances are restricted to an area within 80 m of the site boundary and

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predicted GLCs fall below 50% of the NEPM Standards within 100 m of the site. At

the nearest sensitive receptor, the maximum predicted 24-hour average PM10 and

PM2.5 GLCs are equal to no more than 1.2% of the corresponding NEPM Standards

• The maximum predicted 1-hour NO2 concentration is equal to 84% of the

corresponding NEPM Standard and is also expected to occur within close proximity

of the modelled sources. At the nearest sensitive receptor, the maximum predicted

short-term NO2 GLC is equal to 34% of the corresponding Standard

• The maximum GLCs for the remaining modelled compounds are predicted to be equal

to or less than 11% of the corresponding air quality criteria, and less than 1% at the

nearest sensitive receptor

• The results of the cumulative assessment indicate that at the nearest sensitive

receptor, the maximum 1-hour NO2 GLC is predicted to increase from 51% to 66% of

the corresponding NEPM Standard. The cumulative SO2 GLCs are predicted to

increase by no more than 1% of the applicable NEPM Standards.

6.1.2 Management

An analytical program comprising the collection of samples at pre-peak, peak and post-

peak emissions concentrations for three representative batches will be undertaken once

the system is operational to assess the emissions composition. The collected data may be

compared to the data used as an input for the emissions modelling submitted as part of

this works approval.

6.2 Noise

Potential noise emissions from the Hottpad operations will be the diesel generators and

exhaust stacks which could contribute to added noise within the area.

6.2.1 Potential Impact

The nearest sensitive receptor is 2 km north north-east of the prescribed premises and

unlikely to be significantly impacted by the operations of the Hottpad.

6.2.2 Management

All of the onsite equipment is located at least 40 m from the road and approximately 85 m

from the nearest office building which should provide ample buffer zone for site workers.

Noise exposure for workers in the immediate vicinity of the plant during operations may

be managed through administrative controls (ie. managing duration of exposure) and PPE

(hearing protection). One blower is approximately 5 m from the site boundary. The closest

neighbouring property is the Cleanaway site to the North, which is an industrial facility.

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6.3 Odour

6.3.1 Potential Impact

Since the nearest sensitive receptor is 2 km away from the site, it is unlikely that odour

will pose a risk or annoyance.

6.3.2 Management

The Hottpad system includes an odour treatment system at the emissions stack which is

designed to adjust the rate of aspiration of EcoSorb as required, based on input from the

CEMS.

An odour assessment will be undertaken, using a Scentroid olfactometer, to provide an

understanding of odour characteristics and to allow for the optimisation of the odour

treatment system.

6.4 Fire

The southern portion of the prescribed premises and the surrounding area is mapped as a

Bush Fire Prone Area by the City of Karratha and Department of Fire and Emergency

Services (DFES) (DFES 2018).

6.4.1 Potential Impact

The operation of the Hottpad itself is unlikely to pose a fire ignition risk as its an internally

closed system and air flow is used to fuel the combustion process (not an ignition flame).

The system is not pressurised and therefore low risk of explosion. However, the operation

of the generators used to power the airflow injector has the potential to exacerbate a

bushfire originating outside of the site and the ability to ignite a bushfire.

The prescribed premises site is cleared of vegetation and surrounded by a 5 m firebreak

on all sides. Additionally, the western boundary is parallel to the Rio Tinto rail line and

thus has an additional firebreak buffer of approximately 80 m. The eastern boundary is

parallel to the Warlu road and has an additional firebreak buffer of approximately 50 m.

Therefore the potential for a bushfire to impact the site or vice versa is relatively low.

6.4.2 Management

Cleanaway will manage the risk of fire through:

• Fire extinguishers available in all vehicles, machinery and at all buildings

• Fire extinguishers will be maintained

• Hottpad internal safety systems (e.g. alarms, and automatic system shut offs)

• Employee inductions and training to include emergency muster points, job hazard

analysis (JHA) and Hottpad safety operation systems

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• Maintenance of emergency equipment will be managed through weekly environment

& safety inspection checklist while the site is operational

• Regular monitoring of the DFES bushfire website for any nearby fires and implement

early action if necessary

• Maintain firebreaks around premises boundary.

6.5 Cyclones and Flood Risk

The site is located in the cyclone prone Pilbara region. The cyclone season in Karratha is

from the start of November to the end of April.

6.5.1 Potential Impact

The site may be prone to damaging winds and inundation from flooding due to cyclones

and cyclone related weather.

6.5.2 Management

All infrastructure associated with the Hottpad will be designed to be engineered in

accordance with Australian standards for cyclone ratings.

During the cyclone season, the site manager will monitor the DFES and BoM websites for

cyclone warnings daily. During the cyclone season a 7-day outlook is issued daily by BoM

and indicates the risk of tropical cyclone activity in the region with ratings from low to high.

All buildings and facilities will be designed and engineered in accordance with Australian

standards for cyclone ratings.

In the event of a cyclone developing in the Pilbara region, the following will be

implemented:

• Cyclone tie down activities to commence

• All personnel evacuate from the site

• Once the cyclone has passed a damage assessment is undertaken and recovery can

commence

• Once deemed safe, operations can resume.

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7 Implementation Strategy

7.1 Communication, Competency, Training and

Awareness

All employees, contractors and labour hire personnel will undertake a site induction prior

to being authorised to commence work. The site induction environmental content will cover

Cleanaways Environmental Management System as well as the various environmental

aspects, impacts and controls, emergency response, reporting and legislation relevant to

the inductee and their work. The site induction will involve an onsite orientation that

includes location of chemical spill kits, muster points, waste receptacles. Induction records

will be kept.

7.1.1 Internal Communication

Communications of environmental issues will be undertaken through:

• Cleanaway’s Environmental Management System:

o Environmental Policy

o Weekly Environmental & Safety Inspection Checklist

o Environmental Incident & Hazard Report Form

o Environment Management Review Form (review conducted every 3 years).

• HSE notice boards displaying:

o Incident alerts

o Environmental Risk Registers

• Emergency contact numbers.

7.1.2 External Communication

It is anticipated that works carried out at the site will have a negligible negative impact on

the local community. A complaints register will be maintained to monitor any community

complaints regarding the premise and its operations.

In the event that circumstances change so the local community is adversely impacted,

communication and consultation measures will be undertaken. This will include recording

of the complaint, follow up with the party that lodged the complaint and reporting of how

the complaint was addressed or resolved.

7.2 Reporting

Cleanaway will maintain a register of all incidents and complaints. All incidents will be

recorded within 24 hours of the incident occurring, where resources are available. Incidents

will be reported to external parties and regulators as required.

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Annual Environmental Reporting (AER) will be submitted to DWER which will include a

complaints register, disturbance areas, waste disposal and production outputs.

A compliance report detailing the ‘as built’ Hottpad and compliance with any works

approval conditions will be submitted to DWER.

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8 Contingency and Incident Response

Cleanaway has stringent Health, Safety and Environment (HSE) management systems

and procedures across all of their sites.

All employees and personnel involved in the operation of the Hottpad will be trained and

inducted. This will include:

• Job Hazard Analyses (JHAs) for each step of the Hottpad operation

o Training before operations start

o On-site operational training and handover by technology partners and experts

o On-going technical support available as necessary

• The Hottpad system will be equipped with safety features and continuous monitoring

systems:

o Centralised system display and controls

o Temperature, pressure, and flow measurement systems

o Continuous emissions monitoring system.

Overall, the treatment process is a controlled process, therefore treatment ceases when

air flow is stopped.

8.1 Air Quality

Annual stack testing will be included in the Annual Environmental Report for an initial

period of two years.

8.2 Noise and Odour

In the event of a noise or odour related complaint from external stakeholders, Cleanaway

will:

• Notify the supervisor immediately but no later than 2 hours of receiving the complaint

• Check the nature of the activities being conducted

• Note and record the weather conditions including wind direction and strength

• Investigate sources of noise and identify all practical measure to reduce noise

• Cease or reduce noisy or vibration generating activities where practically possible

and

• Undertake any other possible corrective actions immediately.

Odour is not expected to a nuisance due to the large distances of sensitive receptors,

however in the event that odour complaints are received several options for treatment

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include: air scrubbers (water sprayers), thermal oxidizers or granulated activated carbon

(GAC).

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9 Limitations

This report is produced strictly in accordance with the scope of services set out in the

contract or otherwise agreed in accordance with the contract. 360 Environmental makes

no representations or warranties in relation to the nature and quality of soil and water

other than the visual observation and analytical data in this report.

In the preparation of this report, 360 Environmental has relied upon documents,

information, data and analyses (“client’s information”) provided by the client and other

individuals and entities. In most cases where client’s information has been relied upon,

such reliance has been indicated in this report. Unless expressly set out in this report, 360

Environmental has not verified that the client’s information is accurate, exhaustive or

current and the validity and accuracy of any aspect of the report including, or based upon,

any part of the client’s information is contingent upon the accuracy, exhaustiveness and

currency of the client’s information. 360 Environmental shall not be liable to the client or

any other person in connection with any invalid or inaccurate aspect of this report where

that invalidity or inaccuracy arose because the client’s information was not accurate,

exhaustive and current or arose because of any information or condition that was

concealed, withheld, misrepresented, or otherwise not fully disclosed or available to 360

Environmental.

Aspects of this report, including the opinions, conclusions and recommendations it

contains, are based on the results of the investigation, sampling and testing set out in the

contract and otherwise in accordance with normal practices and standards. The

investigation, sampling and testing are designed to produce results that represent a

reasonable interpretation of the general conditions of the site that is the subject of this

report. However, due to the characteristics of the site, including natural variations in site

conditions, the results of the investigation, sampling and testing may not accurately

represent the actual state of the whole site at all points.

It is important to recognise that site conditions, including the extent and concentration of

contaminants, can change with time. This is particularly relevant if this report, including

the data, opinions, conclusions and recommendations it contains, are to be used a

considerable time after it was prepared. In these circumstances, further investigation of

the site may be necessary.

Subject to the terms of the contract between the Client and 360 Environmental Pty Ltd,

copying, reproducing, disclosing or disseminating parts of this report is prohibited (except

to the extent required by law) unless the report is produced in its entirety including this

page, without the prior written consent of 360 Environmental Pty Ltd.

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10 References

360 Envitonmental Pty Ltd. Annual Groundwater Monitoring Report 2018- Coova Pooya

Waste Management Facility. Report prepared for Cleanaway Pty Ltd . Perth, 2019.

Bureau of Meterology . Monthly Climate data statistics. 2019 .

<http://www.bom.gov.au/climate/data/.>.

Department of Agriculture and Food WA. Soil-landscape systems of Western Australia

(GIS dataset). . perth , 2012.

Department of Fire and Emergency Services . “Bush Fire prone Areas - GIS Dataset .”

2018.

Department of Water and Environmental Regulation . Clearing Regulations -

Environmentally Sensitive Areas GIS Dataset. Perth , 2018.

DeSoete, G. “Stability and propagation of combustion waves in inert porous media.” The

Combustion Institute: Pittsburgh, PA Eleventh International Symposium on

Combustion (1966): 959-966.

Drysdale, D. An Introduction to Fire Dynamics. 2nd . New York: John Wiley and Sons,

1998.

Environmental Protection Authority. “Guidance Statement No. 3 Separation Distances

between Industrial and Sensitive Land Uses.” 2005.

Greaves, M., et al. “Air injection into light andmedium heavy oil reservoirs: combustion

tube studies on West of Shetlands Clair oil and light Australian oil.” Chem. Eng.

Res. Des 78 (2000): 721–730.

Howell, J. R., M. J. Hall and J. L Ellzey. “Combustion of hydrocarbon fuels within porous

inertmedia.” Prog. Energy Combust. Sci (1996): 121-145.

Kendrick, P. and F. Stanley. “Pilbara 4 (PIL4- Roebourne) .” 2001.

Ohlemiller, T. J. “Modeling of smoldering combustion propagation.” Prog. Energy

Combust. Sci. 11 (1985): 277–310.

Ramboll. “Karratha Cleanaway Hottpad Remidiation System - Air Quality System.” 2019.

Schult, A., et al. “Propagation and extinction of forced opposed flow smolder waves.”

Combust. Flame 101 (1995): 471-490.

Switzer, C, et al. “Self-Sustaining Smoldering Combustion: A Novel Remediation Process

for Non-Aqueous-Phase Liquids in Porous Media.” Environ. Sci. Technol 43

(2009): 5871–5877.

Torero, J. L. and A. C Fernandez-Pello. “Forward smolder of polyurethane foam in a forced

air flow.” Combust. Flame 106 (1996): 89–109.

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FIGURES

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North West Coastal Hwy

Karra

tha

Tom

Pric

eR

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LegendPrescribed PremisesBoundary

State Roads

DAMPIER

KARRATHA

LOCALITY MAP

DATEPROJECT ID

HT FJ

- NOTE THAT POSITION ERRORS CAN BE >5M IN SOME AREAS

- LOCALITY MAP SOURCED LANDGATE 2017

- OTHER DATA SOURCED LANDGATE 2018

- AERIAL PHOTOGRAPHY SOURCED LANDGATE 2018

(© Western Australian Land Information Authority 2018)

0

HORIZONTAL DATUM AND PROJECTION

CleanawayKarratha Liquid Waste TreatmentPlantWorks Approval Application

COPYRIGHT: THIS DOCUMENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMMISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.

Figure 1 Site Location

SL

0 300 600

Meters

19/07/20193402

K:\Projects\9.0 APP\3402 Cleanaway Karratha Works Approval\3402 Fx Background Maps.mxd

GDA 1994 MGA Zone 50

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t (08) 9388 8360

f (08) 9381 2360

w www.360environmental.com.au

@ A41:20,000

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Karra

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om

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LegendPrescribed Premises

Boundary

State Roads

Indicative Site LayoutExhaust Stack

Hottpad

DAMPIER

KARRATHA

LOCALITY MAP

DATEPROJECT ID

HT FJ

- NOTE THAT POSITION ERRORS CAN BE >5M IN SOME AREAS

- LOCALITY MAP SOURCED LANDGATE 2017

- OTHER DATA SOURCED LANDGATE 2018

- AERIAL PHOTOGRAPHY SOURCED LANDGATE 2018

(© Western Australian Land Information Authority 2018)

0

HORIZONTAL DATUM AND PROJECTION

CleanawayKarratha Liquid Waste TreatmentPlantWorks Approval Application

COPYRIGHT: THIS DOCUMENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMMISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.

Figure 2 Site Layout

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GDA 1994 MGA Zone 50

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t (08) 9388 8360

f (08) 9381 2360

w www.360environmental.com.au

@ A41:2,509

A

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Stayoverat Ausco

MAC VillageKarratha

Baynton

LegendPrescribed Premises

Boundary

State Roads

Buffer 1km

Buffer 2km

Sensitive Receptors

DAMPIER

KARRATHA

LOCALITY MAP

DATEPROJECT ID

HT FJ

- NOTE THAT POSITION ERRORS CAN BE >5M IN SOME AREAS

- LOCALITY MAP SOURCED LANDGATE 2017

- OTHER DATA SOURCED LANDGATE 2018

- AERIAL PHOTOGRAPHY SOURCED LANDGATE 2018

(© Western Australian Land Information Authority 2018)

0

HORIZONTAL DATUM AND PROJECTION

CleanawayKarratha Liquid Waste TreatmentPlantWorks Approval Application

COPYRIGHT: THIS DOCUMENT IS AND SHALL REMAIN THE PROPERTY OF 360 ENVIRONMENTAL. THIS DOCUMENT MAY ONLY BE USED FOR THE PURPOSE FOR WHICH IT WAS COMMISSIONED AND IN ACCORDANCE WITH THE TERMS OF ENGAGEMENT FOR THE COMMISSION. 360 ENVIRONMENTAL DOES NOT HOLD ANY RESPONSIBILITY FOR THE MISUSE OF THIS DOCUMENT.

Figure 3 Sensitive Receptors

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APPENDIX A Hottpad Design Details

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12422

238 138

306

7

375

2148 A

A ISO CONTAINER CORNERS

FORKLIFT REMOVABLE ROOF

2437

5.4°

SECTION A-A

GRIDMESH FLOORINNER FACE

HINGES

HINGED LOCKING BAR WITH FINGERS

PROPOSED HOTBOX

REVISION TABLEREV. ZONE DESCRIPTION DATE

A ISSUED FOR APPROVAL 20/02/19B ISSUED FOR APPROVAL 1/04/19

TITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:50

1

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT BKQ 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON IT REMAINS THE PROPERTY OFKQuipWA.WRITTEN PERMISSION MUST BE OBTAINED FROM KQuipWA TO COPY OR REPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ABN 48 073 690 552

TEL: (08) 9353 2666

FAX: (08) 9353 1355

Page 41: Hottpad - Works Approval Supporting Document

PROPOSED HOT BOXTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:30

2

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT BKQ 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON IT REMAINS THE PROPERTY OFKQuipWA.WRITTEN PERMISSION MUST BE OBTAINED FROM KQuipWA TO COPY OR REPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ABN 48 073 690 552

TEL: (08) 9353 2666

FAX: (08) 9353 1355

Page 42: Hottpad - Works Approval Supporting Document

9544

306

7

1600

BB

C

C

12422

AIR INLET

HOT BOX ASSEMBLYTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:75

3

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT BKQ 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON IT REMAINS THE PROPERTY OFKQuipWA.WRITTEN PERMISSION MUST BE OBTAINED FROM THE KQuipWA TO COPY OR REPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ABN 48 073 690 552

TEL: (08) 9353 2666

FAX: (08) 9353 1355

Page 43: Hottpad - Works Approval Supporting Document

SECTION B-B

DUST SUPRESSION SPRINKLERS

MIST SPRINKLERS

SECTION B-BTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:25

4

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT BKQ 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON IT REMAINS THE PROPERTY OFKQuipWA.WRITTEN PERMISSION MUST BE OBTAINED FROM KQuipWA TO COPY OR REPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ABN 48 073 690 552

TEL: (08) 9353 2666

FAX: (08) 9353 1355

Page 44: Hottpad - Works Approval Supporting Document

SECTION C-CSCALE 1 : 25 AIR INLET

SECTION C-CTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:10

5

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT BKQ 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON IT REMAINS THE PROPERTY OFKQuipWA.WRITTEN PERMISSION MUST BE OBTAINED FROM KQuipWA TO COPY OR REPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ABN 48 073 690 552

TEL: (08) 9353 2666

FAX: (08) 9353 1355

Page 45: Hottpad - Works Approval Supporting Document

3000

11120

AA

B

B

FLEXIBLE HOSE AIR OUTLET

HOT BOX ASSEMBLY

REVISION TABLEREV. ZONE DESCRIPTION DATE

A ISSUED FOR APPROVAL 20/02/19B ISSUED FOR APPROVAL 1/04/19C ISSUED FOR APPROVAL 10/05/19D ISSUED FOR APPROVAL 16/05/19E ISSUED FOR APPROVAL 16/07/19

TITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:100

1

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 46: Hottpad - Works Approval Supporting Document

1000 NO ROOF

SECTION A-A

SPRINKLER WATER SUPPLY

SPRINKLERS HOLMANBRASS BUTTERFLY SPINNERS

DUST SUPPRESION SPRINKLERSMAGNUM MMVB/B MINI VALVE

SECTION A-ATITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:30

2

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 47: Hottpad - Works Approval Supporting Document

4000

SECTION B-B

2 OFF ISOLATION VALVES

8" NB INLET PIPE

2 x 4" NB PIPES

SECTION B-BTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:40

3

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 48: Hottpad - Works Approval Supporting Document

HINGES

HINGED LOCKINGBAR WITH FINGERS

D

D

C

C

FF E

E

GG

FORKLIFT REMOVABLE ROOF

5.9°

SECTION D-D

INNER FACE

SECTION C-CSCALE 1 : 20

GRIDMESH SUPPORT FRAMES

H

SECTION G-GDETAIL H

SCALE 1 : 10

HIGH TEMPERATURE GASKETAROUND PERIMETER OF DOORS

PROPOSED HOTBOXTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:50

4

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 49: Hottpad - Works Approval Supporting Document

J

DETAIL JSCALE 1 : 15

PROPOSED HOT BOXTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:30

5

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 50: Hottpad - Works Approval Supporting Document

SECTION F-F

28 HEATER ELEMENTS

AIR INLET

SECTION F-FTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:25

6

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 51: Hottpad - Works Approval Supporting Document

SECTION D-D

SECTION D-DTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:30

7

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 52: Hottpad - Works Approval Supporting Document

K

K

L

L

300

J

J

SPRINKLERS NOT SHOWN

SECTION K-KSCALE 1 : 15

AIR OUTLET

SPRINKLER WATER SUPPLY PIPE

SECTION L-LSCALE 1 : 15

FORK POCKET

LID TO HAVE LOCATINGFINGERS IN EACH CORNERTO ASSIST FITTING ON TO HOT BOX

30

0 H

OLE

SECTION J-J

ROOFTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:50

8

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 53: Hottpad - Works Approval Supporting Document

SECTION E-E

HEATER ELEMENT

ELECTRICAL ACCESS COVER

HEATER ELEMENT OUTER COVER

HEATER ELEMENT MOUNTING PLATE

AIR CHAMBER

NOTE: NO FASTENEERS SHOWN FORACCESS COVERS OR MOUNTING PLATES

SECTION E-ETITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:5

9

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 54: Hottpad - Works Approval Supporting Document

4" NB PIPE

2" NB PIPE

AIR INLET PIPINGTITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:20

10

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 55: Hottpad - Works Approval Supporting Document

B325MPU GRIDMESH17.7 kPA (UNIFORMLY DISTRIBUTED)

STAINLESS STEELWOVEN MESH #40SSWO 00415 1246

MESH DETAILS

LOAD BAR

LOAD BAR

B325MPU GRIDMESH17.7 kPA (UNIFORMLY DISTRIBUTED)

TITLE

SIZE

PROJECT

SCALE

DWG

CREATED DATE

REV1:20

11

--

DRAWN

CHECKED

APPROVED

KM

SHEETPLANT ETLC 00035-P

20/02/19

THIS DRAWING AND THE INFORMATION ON ITREMAINS THE PROPERTY OFTHE LIFTING COMPANY.WRITTEN PERMISSION MUST BE OBTAINEDFROM THE LIFTING COMPANY TO COPY ORREPRODUCE THE WHOLE OR PARTOF THIS DRAWING.ACN 097 438 269

TEL: (08) 9353 4333

FAX: (08) 9353 3377PTY LTDTHE LIFTING COMPANY

TLC

Page 56: Hottpad - Works Approval Supporting Document

3402AA Supporting Works Approvals Document Karratha Liquid Waste Treatment Plant (L8332/2009/3)

Cleanaway Waste Management Ltd

360 Environmental Pty Ltd

APPENDIX B Air Quality Assessment

Page 57: Hottpad - Works Approval Supporting Document

Intended for

Compliance Monitoring Pty Ltd.

O n behalf of

Chevron Environmental Technology Centre

Document type

Draft Report

Date

16 April, 2019

KARRATHA CLEANAWAY HOTTPAD REMEDIATION SYSTEM AIR QUALITY ASSESSMENT

Page 58: Hottpad - Works Approval Supporting Document

Ramboll Australia Pty Ltd.

ACN 095 437 442

ABN 49 095 437 442

Ramboll

Suite 3, Level 2

200 Adelaide Terrace

East Perth

WA 6004

A ustralia

T +61 8 9225 5199

F +61 8 9225 5155

https://ramboll.com

KARRATHA CLEANAWAY HOTTPAD REMEDIATION SYSTEM

AIR QUALITY ASSESSMENT

P roject name Karratha Cleanaway Hottpad Remediation System Air Quality Assessment

P roject no. 318000659

Rec ipient Compliance Monitoring

V ersion Final

Date 16/04/2019

P repared by Ruth Peif fer

C hecked by Martin Parsons

A pproved by Nick Houldsworth

Page 59: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

i

CONTENTS

1. Introduction 1 2. Site Description 2 2.1 Site Description 2 2.2 Regional Meteorology 2 2.3 Ambient Air Quality 3 3. Process Overview 4 4. Air Quality Criteria 6 5. Air Dispersion Modelling and Methodology 9 5.1 Air Dispersion Model 9 5.2 Meteorological Data 9 5.3 Model Parameterisation 10 5.3.1 AERMET 10 5.3.2 AERMOD 10 5.4 Source Parameters and Emission Estimates 11 5.5 Treatments of Oxides of Nitrogen Concentrations 13

5.6 Short-Term Averaging Periods 13 6. Modelling Results 15 6.1 Smouldering Phase 15 6.2 Heating Phase 24

7. Summary 30 8. References 32 9. Disclaimer and Limitations 33

TABLES

Table 1: Ambient Air Quality Criteria 6 Table 2: Summary of Source Parameters and Emission Estimates 12 Table 3: Peak-to-Mean Ratios 14 Table 4: Maximum Predicted GLCs – Smouldering Phase 15 Table 5: Summary of Source Contributions to Maximum Predicted PM2.5,

PM10 and NO2 GLCs – Smouldering Phase 17 Table 6: Maximum Predicted Cumulative GLCs – Smouldering Phase 24 Table 7: Maximum Predicted GLCs – Heating Phase 24 Table 8: Summary of Source Contributions to Maximum Predicted PM2.5,

PM10 and NO2 GLCs – Smouldering Phase 25 Table 9: Maximum Predicted Cumulative GLCs – Heating Phase 26

Page 60: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

ii

FIGURES

Figure 1: Site Location 2 Figure 2: Terrain Contours 3 Figure 3: Process Overview 4

Figure 4: Site Layout 5 Figure 5: 2017 Annual Wind Rose – Karratha Airport 10 Figure 6: Maximum Predicted 24-hour Average PM2.5 GLCs – Smouldering

Phase 18

Figure 7: Maximum Predicted Annual Average PM2.5 GLCs – Smouldering

Phase 19 Figure 8: Maximum Predicted 24-hour Average PM10 GLCs – Smouldering

Phase 20

Figure 9: Maximum Predicted Annual Average PM10 GLCs – Smouldering

Phase 21 Figure 10: Maximum Predicted 1-hour Average NO2 GLCs – Smouldering

Phase 22

Figure 11: Maximum Predicted Annual Average NO2 GLCs – Smouldering

Phase 23 Figure 12: Maximum Predicted 24-hour Average PM2.5 GLCs – Heating

Phase 27 Figure 13: Maximum Predicted 24-hour Average PM10 GLCs – Heating

Phase 28 Figure 14: Maximum Predicted 1-hour Average NO2 GLCs – Heating

Phase 29

APPENDICES

Appendix 1 AERMET Input Files

Appendix 2 AERMOD Input Files

Appendix 3 BPIP Input Files

Page 61: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

1

1. INTRODUCTION

Chevron’s Australasian Business Unit (ABU) and Cleanaway Waste Management Ltd (Cleanaway)

are proposing to construct a Heated Overland Thermal Treatment Pad (Hottpad) remediation

system at the ToxFree Karratha Waste Handling Facility (the site). The Hottpad system will utilise

smouldering combustion to treat oily sludges derived from local operations. Two dedicated diesel

generators will be installed to provide power for the proposed Hottpad system.

Compliance Monitoring Pty Ltd (Compliance Monitoring) requested Ramboll Australia Pty Ltd

(Ramboll) undertake an air dispersion modelling assessment to determine the likely air quality

impacts associated with the two operational phases of the proposed Hottpad system; heating and

smouldering. This report presents the approach, methodology and results of air dispersion

modelling for the proposed system operating under each of the modelled scenarios. The

maximum predicted ground level concentrations (GLCs) of the modelled compounds have been

compared against the relevant ambient air quality criteria.

The key pollutants of concern that have been assessed in the modelling include criteria pollutants

carbon monoxide (CO), oxides of nitrogen (NOx), sulfur dioxide (SO2), particulate matter (PM10

and PM2.5); sulphide compounds including carbon disulphide (CS2) and hydrogen sulphide (H2S);

hydrogen chloride (HCl), hydrogen fluoride (HF), mercury and a suite of volatile organic

compounds (VOCs) including (but not limited to) benzene, toluene, xylenes, Benzo(a)pyrene

(B[a]P) (as a marker for Polycyclic Aromatic Hydrocarbons [PAHs]).

Page 62: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

2

2. SITE DESCRIPTION

2.1 Site Description

The proposed Hottpad system will be installed at the existing ToxFree Karratha Waste Handling

Facility, located on Warlu Road, Karratha Western Australia (Figure 1). The site is located

approximately 6.4 km south-southeast of the Karratha townsite, with the nearest sensitive

receptor being the Ausco Stayover accommodation camp, located approximately 2 km north-

northeast of the site.

Figure 1: Site Location

The site and immediate surrounds are relatively flat, with terrain heights of around 30 m above

sea level within an approximate 500 m radius. There is an area of elevated terrain that lies

approximately 1 km to the west of the site that increases to over 100 m above sea level (Figure

2).

2.2 Regional Meteorology

Karratha has a hot semi-arid climate, with temperatures remaining warm to hot year-round.

Diurnal winter temperatures generally range from 10°C to 27°C, while summers remain very hot

with diurnal temperatures ranging from 26°C to 36°C (Bureau of Meteorology [BoM], 2019). The

region features low rainfall, primarily falling in late summer due to the influence of tropical

cyclones and the monsoon, which can cause periods of high humidity and thunderstorms. A

second rainfall peak can occur in early winter due to the influence of occasional cold fronts. The

prevailing winds exhibit distinct seasonal patterns, with a dominant westerly component evident

during the spring and summer months, with more frequent easterly winds occurring during the

winter months. Greater variability and more frequent light winds are evident during the autumn

months.

Key Site Boundary Nearest Sensitive Receptor

Page 63: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

3

Figure 2: Terrain Contours

2.3 Ambient Air Quality

The Department of Water and Environment Regulation (DWER) carried out the Pilbara Air Quality

Study (PAQS) between 1998 and 2000 (Department of Environmental Protection [DEP], 2002).

The study included monitoring for ozone, NOx and SO2 within the Karratha townsite.

The maximum 1-hour average ozone concentration recorded for Karratha during the study period

was 0.06 ppm (DEP, 2002). This concentration is considered to be well above natural levels for

the region and likely associated with bushfire events (Department of Environment [DoE], 2004).

The 95th percentile 1-hour average concentration was 0.04 ppm (DEP, 2002).

The maximum 1-hour average NO2 concentration measured at Karratha was 0.062 ppm

(126 µg/m3) and the annual average remained below 0.002 ppm (4.0 µg/m3) (DEP, 2002).

The maximum 1-hour average SO2 concentration measured at Karratha was 0.134 ppm

(378 µg/m3). The maximum 24-hour average was 0.006 ppm (17 µg/m3), while the annual

remained below 0.001 ppm (2.8 µg/m3) (DEP, 2002).

Page 64: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

4

3. PROCESS OVERVIEW

The Hottpad system is an ex-situ thermal remediation technology which utilises smouldering

combustion to treat contaminated soils and liquids. Smouldering combustion is the exothermic

oxidation of an organic waste which is utilised as fuel. The reaction occurs at the fuel surface and

is limited by the rate of oxygen diffusion across this surface. The resulting reaction is slower and

lower in temperature than a flaming reaction (as used in incineration), and under the right

conditions, self-sustaining. Due to the self-sustaining nature of the smouldering process, the

energy requirements are considerably lower than traditional thermal remediation technologies

(such as incineration) which leads to a less energy intensive remediation option and the process

results in more thorough treatment with limited by-products. The Hottpad system has been

developed by Chevron and is currently employed in the treatment of oily sludge at Chevron’s

Batangas operations in the Philippines.

An overview of the treatment process is presented in Figure 3. The heating phase occurs over a

period of 12-hours, followed by the smouldering phase, which is expected to last up to 3.5 days.

Figure 3: Process Overview

The Hottpad system will be powered by two Stamford 424 kW diesel generators. As advised by

Chevron, the heating phase will require the use of a single generator operating at 80% power

load and the smouldering phase will require the use of a single generator operating at 25% power

load. Atmospheric emissions from each generator will be released via dedicated stacks and the

units will be housed within a standard container.

A layout of the existing site is presented in Figure 4. The proposed Hottpad system and associated

diesel generator unit will be located within the area labelled ‘Dangerous Good Storage’.

Page 65: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

5

Figure 4: Site Layout

Source: Chevron ETC

Key

Hottpad Exhaust Stack

Generator Housing

Buildings

Page 66: Hottpad - Works Approval Supporting Document

Ramboll - Karratha Cleanaway HOTTPAD Remediation System

6

4. AIR QUALITY CRITERIA

In February 2017 the Department of Water and Environmental Regulation (DWER) published the

Guidance Statement for Risk Assessments (DWER, 2017) which lists Specific Consequence Criteria

to be considered in determining public health and environment impacts. The publications

containing air quality criteria relevant to this assessment include:

• National Environment Protection (Ambient Air Quality) Measure (NEPC, 2015);

• National Environment Protection (Air Toxics) Measure (NEPC, 2011); and

• Approved Methods for the Modelling and Assessment of Air Pollutants (AMMAAP) in New South

Wales (NSW EPA, 2016).

The National Environment Protection (Ambient Air Quality) Measure specifies ambient air quality

standards for criteria pollutants including CO, NO2, SO2, PM10 and PM2.5, to allow for the protection

of human health. The National Environment Protection (Air Toxics) Measure specifies monitoring

investigation levels for a number of air toxics, including benzene, toluene, xylenes and B(a)P,

established for use in assessing the significance of monitored levels of air toxics with respect to

protection of human health.

The AMMAAP (NSW EPA, 2016) specifies statutory impact assessment criteria for modelling and

assessing emissions of air pollutants from stationary sources in the state. Impact assessment

criteria have been established for various individual toxic air pollutants and also for individual

odorous air pollutants, including (but not limited to) mercury, benzene and H2S. The NSW EPA

(2016) odour assessment criteria for H2S are intended to be compared to the predicted 99th

percentile ‘peak’ GLCs of H2S on the time scale of less than one second (i.e. nose-response-time

average).

Ramboll has previously received advice from the DWER is that there is some uncertainty

surrounding the application of the NSW EPA (2016) odour assessment criteria for H2S in Western

Australia, as it varies according to population density, and therefore the relevant Queensland

odour criteria may also be referred to for assessing H2S odour impacts. The Queensland

Environmental Protection (Air) Policy 2008 (Air EPP), specifies an acceptable concentration for H2S

in ambient air of 0.0049 ppm (6.8 µg/m3) for a 30-minute averaging period for protecting the

aesthetic environment, taken to include odour. Section 5.6 for details of the method used to

derive ‘peak’ and short-term concentrations.

In the absence of NEPM and/or NSW EPA standards for other relevant compounds, ambient air

quality criteria and health protective guidelines have been sourced from other reputable

authorities, namely the California Office of Environmental Health Hazard Assessment (OEHHA).

The ambient air quality criteria relevant to this assessment are presented in Table 1.

Table 1: Ambient Air Quality Criteria

Compound Averaging Period Criteria (µg/m3) Source

CO 8-hour 11,254

NEPC (2015) NO2

1-hour 246

Annual 62

SO2

1-hour 572

24-hour 229

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Ramboll - Karratha Cleanaway HOTTPAD Remediation System

7

Compound Averaging Period Criteria (µg/m3) Source

Annual 57

PM10

24-hour 50

Annual 25

PM2.5

24-hour 25

Annual 8

Benzene 1-hour 29 NSW EPA (2016)

Annual 10 NEPC (2011)

B(a)P (as PAHs) Annual 0.0003

Formaldehyde 1-hour 20 NSW EPA (2016)

24-hour 54 NEPC (2011)

Toluene

1-hour 360[1] NSW EPA (2016)

24-hour 4,113 NEPC (2011)

Annual 411

Xylenes

1-hour 190[1] NSW EPA (2016)

24-hour 1,185 NEPC (2011)

Annual 948

Acetaldehyde 1-hour 42[1]

NSW EPA (2016) 1,3-Butadiene 1-hour 40

Chloromethane 1-hour 1900

Ethanol 1-hour 2,100[1]

Acetone 1-hour 22,000

NSW EPA (2016) Butyl Mercaptan 1-hour 7[1]

Acrylonitrile 1-hour 8

Vinyl Acetate Annual 200 OEHHA (2017)

MEK 1-hour 3,200[1]

NSW EPA (2016) n-Hexane 1-hour 3,200

MIBK 1-hour 230 NSW EPA (2016)

Chlorobenzene 1-hour 100[1]

NSW EPA (2016)

Ethylbenzene 1-hour 8,000

Styrene 1-hour 120[1]

Trimethylbenzene 1-hour 2,200

Bromomethane 1-hour 350

Chloroethane 1-hour 48,000

Acrolein 1-hour 0.4

2-Propanol 1-hour 41[1]

NSW EPA (2016) Ethyl acetate 1-hour 12,100[1]

Cyclohexane 1-hour 19,000

NSW EPA (2016) Methyl Methacrylate 1-hour 120[1]

Chlorobenzene 1-hour 100[1]

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Ramboll - Karratha Cleanaway HOTTPAD Remediation System

8

Compound Averaging Period Criteria (µg/m3) Source

Methyl Mercaptan 1-hour 0.5[1]

Dioxins and Furans 1-hour 2.0E-06 NSW EPA (2016)

COS 1-hour 660

OEHHA (2017) Annual 10

CS2 1-hour 70[1]

NSW EPA (2016)

H2S Peak 2.8[2]

30-minute 6.8 Air EPP (2008)

HF 24-hour 2.9

NSW EPA (2016) HCl 1-hour 140

Mercury (inorganic) 1-hour 1.8

Notes

1. Impact assessment criteria for individual odorous pollutants (NSW EPA, 2016)

2. Based upon odour annoyance, specified as a function of population density. Impact assessment

criteria provided for populations of ~125.

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5. AIR DISPERSION MODELLING AND METHODOLOGY

5.1 Air Dispersion Model

The Gaussian dispersion model American Meteorological Society/Environmental Protection Agency

Regulatory Model (AERMOD) was used in this study to predict the potential air quality impacts of

atmospheric emissions from the proposed Hottpad system.

AERMOD is a current-generation air dispersion model that incorporates concepts such as

planetary boundary layer theory and advanced methods for handling complex terrain and was

developed to replace the Industrial Source Complex Model-Short Term (ISCST3) as a US

Environment Protection Agency (USEPA) preferred model for most local scale regulatory

applications. AERMOD incorporates the Plume Rise Model Enhancements (PRIME) building

downwash algorithms, which provide a more realistic handling of downwash effects than previous

approaches. AERMOD has been used extensively throughout Australia, for numerous air

dispersion modelling studies.

5.2 Meteorological Data

A meteorological dataset suitable for use with the air dispersion model AERMOD has been

developed using measured meteorological data from the BoM Karratha Airport Station (located

approximately 11 km north of the site), for the 2017 calendar year. The hourly averages were

reviewed for completeness and missing data were replaced using a combination of interpolation

and prognostic data generated by The Air Pollution Model (TAPM).

TAPM was developed by the Australian Commonwealth Scientific and Industrial Research

Organisation (CSIRO) and consists of coupled prognostic meteorological and air pollution

dispersion model components. The meteorological component of TAPM predicts the local -scale

meteorological features, such as sea breezes and terrain-induced circulations, using the larger-

scale synoptic meteorology as boundary conditions combined with other data including terrain,

land use, soil and surface types.

An annual wind rose derived from the hourly average wind speed and direction data provided by

BoM is presented in Figure 5, illustrating the dominant westerly component.

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Figure 5: 2017 Annual Wind Rose – Karratha Airport

5.3 Model Parameterisation

5.3.1 AERMET

AERMET is the meteorological pre-processor for AERMOD. AERMET (Version 16216) was used to

process the meteorological measurements obtained for the BoM Karratha Airport monitoring site.

In the absence of site-specific upper air meteorological data, TAPM generated temperature

profiles were used also in combination with the measured 10 m surface temperatures to calcula te

hourly mixing heights for input into AERMET.

The option that have been selected for processing the hourly surface data within AERMET are

described below:

• Adjust Surface Friction Velocity (ADJ_U*): This is considered a regulatory default option for the

current model version (16216) when processing site-specific data that does not include

turbulence measurements (sigma-theta and/or sigma-w).

The surface roughness, albedo and Bowen ratio values were based on the Environment Protection

Authority Victoria (Vic EPA) 2013 recommendations for surface characteristics to be used to

develop meteorological data file for AERMOD.

The AERMET inputs files are included as Appendix 1.

5.3.2 AERMOD

AERMOD (Version 16216r) was set up with a grid covering an area of 10 km by 10 km and using

grid spacing of 100 m.

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AERMOD was run using the Rural Dispersion Coefficient and the Adjusted Friction Velocity and

Low Wind (Adjust Horizontal Meander) options were selected, in-line with the treatment of

meteorological data within AERMET.

Terrain elevation data for the model domain were obtained from the US National Aeronautics and

Space Administration’s (NASA) Shuttle Radar Topography Mission (SRTM3/SRTM1) and

incorporated into AERMOD using the AERMAP terrain processor.

Building wake effects were incorporated into AERMOD using the Building Profile Input Program

(BPIP) – Plume Rise Model Enhancements (PRIME) building algorithm. The dispersion of emissions

may be affected by building wakes where the building height is 40% or more of the stack height,

and where the stack is located within a radius of five times the building height. The buildings

included for their potential to cause building wake effects upon the emission stack are shown in

Figure 4. Information provided by Chevron was used to define the location and dimensions for

input to the BPIP.

The AERMOD model input file is included as Appendix 2, and the BPIP input file is included as

Appendix 3.

5.4 Source Parameters and Emission Estimates

A summary of the physical parameters of the Hottpad system and diesel generator exhaust

stacks, exhaust characteristics, and emission estimates applied in the modelling is provided in

Table 2. The physical source parameters and exhaust characteristics for the Hottpad system and

diesel generators were provided by Chevron.

The emission estimates for the Hottpad system were derived from emissions testing data provided

by Chevron, as reported for their Batangas operations. The samples were collected upstream of

any emissions treatment systems at the Batangas site and the maximum concentrations

measured across all sampling events for each of the monitored compounds were conservatively

applied in the calculation of the emission estimates.

The emission estimates for the diesel generators were derived from emission factors published by

the National Pollutant Inventory (NPI) for combustion engines (NPI, 2008) and fuel usage rates

for 25% and 80% power loads, as provided by Chevron. For modelling purposes it has been

assumed that only one generator (nominally Generator 11) will be in operation at any point in

time, in line with the proposed process schedule.

1 A sensitivity analysis was undertaken to determine the difference in predicted air quality impacts associated with either Generator 1 or Generator

2 operating in conjunction with the Hottpad system. The predicted GLCs were more conservative when it was assumed Generator 1 was in

operation (as opposed to Generator 2) and the air quality impact assessment was subsequently completed on this basis.

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Table 2: Summary of Source Parameters and Emission Estimates

Release

Characteristics Units Hottpad Stack

Generator 1 –

25% Power

Load

Generator 1 –

80% Power

Load

Location mE 476,328 476,330 476,330

mN 7,698,800 7,698,789 7,698,789

Stack Height m 10 3.0 3.0

Stack Diameter m 0.25 0.25 0.25

Volumetric Flowrate Nm3/s 0.55 0.20 1.28

Exit Velocity m/s 12.9 8.2 26.1

Temperature °C 52 265 265

Emission Estimates

CO g/s 7.22 0.13 0.37

NOx g/s 0.0032 0.60 1.73

SO2 g/s 0.16 0.00014 0.00041

PM10 g/s 0.017[1] 0.043 0.12

PM2.5 g/s 0.017[1] 0.042 0.12

Benzene g/s 0.011 0.00013 0.00037

B(a)P (as PAHs) g/s ND 2.02E-09 5.78E-09

Formaldehyde g/s ND 0.00016 0.00045

Toluene g/s 0.0062 5.60E-05 0.00016

Xylenes g/s 0.0015 3.91E-05 0.00011

Acetaldehyde g/s ND 0.00011 0.00030

1,3-Butadiene g/s 0.0024 5.36E-06 1.54E-05

Chloromethane g/s 0.00062 ND ND

Ethanol g/s 0.0037 ND ND

Acetone g/s 0.021 ND ND

Butyl Mercaptan g/s 0.00011 ND ND

Acrylonitrile g/s 0.001 ND ND

Vinyl Acetate g/s 0.0018 ND ND

MEK g/s 0.0044 ND ND

n-Hexane g/s 0.0042 ND ND

MIBK g/s 0.00024 ND ND

Chlorobenzene g/s 9.0E-06 ND ND

Ethylbenzene g/s 0.00079 ND ND

Styrene g/s 0.00055 ND ND

Trimethylbenzene g/s 0.00016 ND ND

Bromomethane g/s 1.7E-05 ND ND

Chloroethane g/s 9.0E-05 ND ND

Acrolein g/s 0.00054 ND ND

2-Propanol g/s 0.00092 ND ND

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Release

Characteristics Units Hottpad Stack

Generator 1 –

25% Power

Load

Generator 1 –

80% Power

Load

Ethyl acetate g/s 3.9E-06 ND ND

Cyclohexane g/s 4.5E-05 ND ND

Methyl Methacrylate g/s 3.1E-05 ND ND

Chlorobenzene g/s 8.5E-06 ND ND

Methyl Mercaptan g/s 0.00054 ND ND

Propylene g/s 0.026 ND ND

Dioxins and Furans g/s 6.6E-11 ND ND

COS g/s 0.039 ND ND

CS2 g/s 0.0029 ND ND

H2S g/s 0.00049 ND ND

HF g/s 0.00053 ND ND

HCl g/s 0.00069 ND ND

Mercury (inorganic) g/s 0.00053 ND ND

Notes

1. Stack testing data reported for PM. Conservatively assumed to represent 100% PM10 and 100% PM2.5.

2. ND – no data.

5.5 Treatments of Oxides of Nitrogen Concentrations

A key element in assessing the potential environmental impacts from ground level NO 2

concentrations is estimating NO2 concentrations from modelled NOx emissions. The final NO2

concentration is a combination of the NO emitted as NO2 from the source stacks and the amount

of NO that is converted to NO2 by oxidation in the plume after release.

Generally, after the NOx is emitted from the stack, additional NO2 is formed as the plume mixes

and reacts with the surrounding air. There are several reactions that both form and destroy NO2,

but the primary reaction is oxidation with ozone according to the following reaction:

NO + O3 → NO2 + O2

This reaction is essentially instantaneous as the plume entrains the surrounding air. It is limited

by the amount of ozone available and by how quickly the plume mixes with the surrounding air.

Therefore the ratio of NO2 to NOx increases as the plume disperses downwind.

In order to predict NO2 concentrations, Ramboll has applied the USEPA Ozone Limiting Method

(OLM). This method assumes that ozone is the limiting reagent (i.e. the ozone concentration is

less than the remaining NOx concentration) and requires an NO2 to NOx in-stack ratio. In the

absence of a site-specific in-stack ratio, it has been assumed that 10% of NOx emissions are NO2

(a common assumption for combustion sources). The 95th percentile hourly average ozone

concentration of 0.04 ppm as reported in the PAQS (DEP, 2002) was applied in the OLM.

5.6 Short-Term Averaging Periods

Models such as AERMOD simulate dispersion based on hourly average meteorological data, and

therefore the predicted GLCs are considered to be valid for averaging periods of one hour and

longer. However, the evaluation of odour impacts requires the estimation of short-term

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concentrations of less than one hour, and so adjustment factors are applied to the hourly

averaged model results.

The prediction of ‘peak’ short-term concentrations on the time scale of a second can be obtained

by applying a ratio to the hourly averaged model results, often referred to as the peak-to-mean

ratio. Peak-to-mean ratios depend upon the type of source, atmospheric stability and distance

downwind. The relevant peak-to-mean ratios recommended by the NSW EPA (2016) have been

applied in the estimation of peak concentrations (Table 3).

Table 3: Peak-to-Mean Ratios

Source type Pasquill-Gifford

Stability Class Near-field Far-field

Wake-affected point A - F 2.3 2.3

The adjustment used to derive 30-minute average concentration predictions was calculated in

accordance with the power relationship presented in Turner (1970) (Equation 1) and equates to a

factor of approximately 1.15 times the hourly averaged model results.

𝐶2 = 𝐶1 × (𝑡1

𝑡2

)0.2

Equation 1

𝐶1 = Concentration averaged over time (t1);

𝐶2 = Concentration averaged over time (t2);

𝑡1 , 𝑡2 = Given averaging periods.

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6. MODELLING RESULTS

6.1 Smouldering Phase

The maximum GLCs predicted for the smouldering phase of the Hottpad system (i.e. in

conjunction with a single generator operating at 25% power load) are summarised in Table 4. The

maximum concentrations predicted throughout the model domain and at the nearest sensitive

receptor are presented and compared against the relevant ambient air quality criteria for the

protection of human health and odour annoyance.

Table 4: Maximum Predicted GLCs – Smouldering Phase

Compound Averaging

Period

Criteria Maximum Predicted GLC

Model Domain Nearest Receptor

µg/m3 µg/m3 % of

Criteria µg/m3

% of

Criteria

CO 8-hour 11,254 1,362 12% 60 0.53%

NO2 1-hour 246 103 42% 3.828 1.56%

Annual 62 9.5 15% 0.034 0.06%

SO2

1-hour 572 39 6.8% 4.923 0.86%

24-hour 229 12 5.3% 0.445 0.19%

Annual 57 2.8 4.9% 0.042 0.07%

PM10 24-hour 50 24 47% 0.158 0.32%

Annual 25 3.5 14% 0.015 0.06%

PM2.5 24-hour 25 23 92% 0.156 0.62%

Annual 8 3.4 42% 0.015 0.19%

Benzene 1-hour 29 2.7 9.3% 0.341 1.18%

Annual 10 0.2 2.0% 0.003 0.03%

B(a)P (as PAHs) Annual 0.0003 1.5E-07 0.1% 5.2E-10 <0.01%

Formaldehyde 1-hour 20 0.2 1.2% 0.005 0.02%

24-hour 54 0.1 0.2% 0.0004 <0.01%

Toluene

1-hour 360[1] 1.5 0.4% 0.190 0.05%

24-hour 4,113 0.5 0.01% 0.017 <0.01%

Annual 411 0.1 0.03% 0.002 <0.01%

Xylenes

1-hour 190[1] 0.4 0.2% 0.047 0.02%

24-hour 1,185 0.1 0.01% 0.004 <0.01%

Annual 948 0.03 <0.01% 0.0004 <0.01%

Acetaldehyde 1-hour 42[1] 0.2 0.4% 0.003 0.01%

1,3-Butadiene 1-hour 40 0.6 1.4% 0.074 0.18%

Chloromethane 1-hour 1900 0.1 0.01% 0.019 <0.01%

Ethanol 1-hour 2,100[1] 0.9 0.04% 0.111 0.01%

Acetone 1-hour 22,000 5.0 0.02% 0.635 <0.01%

Butyl Mercaptan 1-hour 7[1] 0.03 0.4% 0.003 0.05%

Acrylonitrile 1-hour 8 0.2 3.1% 0.032 0.40%

Vinyl Acetate Annual 200 0.03 0.02% 0.0005 <0.01%

MEK 1-hour 3,200[1] 1.1 0.03% 0.135 <0.01%

n-Hexane 1-hour 3,200 1.0 0.03% 0.127 <0.01%

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Compound Averaging

Period

Criteria Maximum Predicted GLC

Model Domain Nearest Receptor

µg/m3 µg/m3 % of

Criteria µg/m3

% of

Criteria

MIBK 1-hour 230 0.1 0.03% 0.007 <0.01%

Chlorobenzene 1-hour 100[1] 0.002 <0.01% 0.0003 <0.01%

Ethylbenzene 1-hour 8,000 0.2 <0.01% 0.024 <0.01%

Styrene 1-hour 120[1] 0.1 0.1% 0.017 0.01%

Trimethylbenzene 1-hour 2,200 0.04 <0.01% 0.005 <0.01%

Bromomethane 1-hour 350 0.004 <0.01% 0.001 <0.01%

Chloroethane 1-hour 48,000 0.02 <0.01% 0.003 <0.01%

Acrolein 1-hour 0.4 0.1 32% 0.016 4.07%

2-Propanol 1-hour 41[1] 0.2 0.5% 0.028 0.07%

Ethyl acetate 1-hour 12,100[1] 0.001 <0.01% 0.0001 <0.01%

Cyclohexane 1-hour 19,000 0.01 <0.01% 0.001 <0.01%

Methyl

Methacrylate 1-hour 120[1] 0.007 0.01% 0.001 <0.01%

Methyl Mercaptan 1-hour 0.5[1] 0.1 26% 0.016 3.29%

Dioxins and

Furans 1-hour 2.0E-06 0.0 0.8% 2.0E-09 0.10%

COS 1-hour 660 10 1.4% 1.212 0.18%

Annual 10 0.7 6.9% 0.010 0.10%

CS2 1-hour 70[1] 0.7 1.0% 0.089 0.13%

H2S Peak 2.8[2] 0.3 10% 0.035 1.24%

30-minute 6.8 0.1 2.0% 0.017 0.25%

HF 24-hour 2.9 0.04 1.4% 0.001 0.05%

HCl 1-hour 140 0.2 0.1% 0.021 0.01%

Mercury

(inorganic) 1-hour 1.8 0.1 7.0% 0.016 0.89%

Notes

1. Impact assessment criteria for individual odorous pollutants (NSW EPA, 2016).

2. Based upon odour annoyance, specified as a function of population density. Impact assessment

criteria provided for populations of ~125.

The results presented in Table 4 indicate that the maximum predicted GLC s are expected to

remain below the corresponding air quality criteria. The maximum predicted 24-hour PM2.5 GLC

most closely approaches the relevant criteria, equal to 92% of the PM2.5 24-hour average NEPM

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Standard. However, contours of the maximum predicted 24-hour average PM2.5 GLCs (

Figure 6) indicate that this concentration is expected to occur onsite and the predicted GLCs fall

below 20% of the NEPM Standard within 100 m of the site boundary. At the nearest sensitive

receptor, the maximum predicted 24-hour average PM2.5 GLC is 0.2 µg/m3, equal to 0.6% of the

NEPM Standard. The highest annual average PM2.5 predicted to occur is 3.4 µg/m3, equal to 42%

of the corresponding NEPM Standard and is also expected to occur within close proximity of the

emission sources (

Figure 7).

The maximum predicted 24-hour average PM10 GLC is 24 µg/m3, equal to 47% of the

corresponding NEPM Standard (Table 4). The peak concentration is predicted to occur within the

site boundary (Figure 8) and at the nearest sensitive receptor the maximum predicted 24-hour

average PM10 GLC is 0.2 µg/m3, equal to 0.3% of the corresponding standard (Table 4). The

predicted highest annual average PM10 GLC is 3.5 µg/m3, equal to 14% of the annual NEPM

Standard (Table 4).

The maximum predicted 1-hour NO2 concentration of 103 µg/m3 is equal to 42% of the

corresponding NEPM Standard and is expected to occur within close proximity of the modelled

sources (Figure 10). At the nearest sensitive receptor, the maximum predicted 1-hour NO2 GLC is

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3.8 µg/m3, equal to 1.6% of the NEPM Standard (Table 4). The highest annual average NO2 GLC

is predicted to be 9.5 µg/m3 (15% of the annual NO2 NEPM Standard), while at the nearest

receptor the annual average NO2 GLC is predicted to be 0.03 µg/m3 (Table 4).

The percentage contributions of each modelled source to the maximum predicted PM2.5, PM10 and

NO2 GLCs for the smouldering phase of the Hottpad system are presented in Table 5. These data

indicate that the maximum predicted GLCs for these compounds are being driven by emissions

from the generator stack, which are subject to building wake effects as the height of the

generator exhaust stack is less than 40% of the height of nearby building structures (including

the container unit housing the generators). The subsequent entrainment of exhaust gases

released by short stacks in the wake of a building can result in much higher GLCs close to the

source than the model would otherwise predict.

Table 5: Summary of Source Contributions to Maximum Predicted PM2.5, PM10 and NO2 GLCs – Smouldering Phase

Compound Averaging

Period

Criteria Maximum

Predicted GLC2 Percentage Contribution

µg/m3 µg/m3 Hottpad Generator 1

NO2 1-hour 246 103 0.2%[1] 99.8%[1]

PM10 24-hour 50 24 3.1% 96.9%

PM2.5 24-hour 25 23 3.1% 96.9%

Notes

1. Estimated contributions based on predicted NO x GLCs.

The maximum GLCs for the other criteria pollutants CO and SO2 are predicted to remain equal to

or less than 12% of the corresponding NEPM Standards throughout the modelled domain (Table

4). The predicted peak H2S concentration of 0.3 µg/m3 is equal to 10% of the NSW EPA (2016)

odour assessment criteria and has conservatively been derived from the maximum predicted 1-

hourly average (as opposed to the 99th percentile) (Table 4). At the nearest sensitive receptor,

the peak GLC is predicted to be 0.04 µg/m3. The 30-minute average H2S GLCs also remain well

below the Queensland Air EPP criteria, equal to no more than 2.0% of the 6.8 µg/m3 criteria

value.

Of the modelled VOCs, acrolein most closely approaches the relevant criteria with the maximum

predicted 1-hour average GLC being 0.1 µg/m3, equal to 32% of the NSW EPA (2016) criteria. At

the nearest sensitive receptor however, the maximum predicted 1-hour average GLC is equal to

4.1% of the corresponding criteria. The maximum predicted 1-hour average GLC for methyl

mercaptan is 0.1 µg/m3, equal to 26% of the NSW EPA (2016) criteria, while at the nearest

sensitive receptor the maximum predicted 1-hour average GLC is equal to 3.3% of the criteria.

The maximum predicted GLCs for all other modelled compounds are equal to no more than 10%

of the corresponding air quality criteria for all relevant averaging periods, while at the nearest

sensitive receptor, the maximum predicted GLCs are equal to no more than 1.2% of the relevant

criteria (Table 4).

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Figure 6: Maximum Predicted 24-hour Average PM2.5 GLCs – Smouldering Phase

+ Nearest Sensitive Receptor

__ Site Boundary

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Figure 7: Maximum Predicted Annual Average PM2.5 GLCs – Smouldering Phase

+ Nearest Sensitive Receptor

__ Site Boundary

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Figure 8: Maximum Predicted 24-hour Average PM10 GLCs – Smouldering Phase

+ Nearest Sensitive Receptor

__ Site Boundary

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Figure 9: Maximum Predicted Annual Average PM10 GLCs – Smouldering Phase

+ Nearest Sensitive Receptor

__ Site Boundary

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Figure 10: Maximum Predicted 1-hour Average NO2 GLCs – Smouldering Phase

+ Nearest Sensitive Receptor

__ Site Boundary

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Figure 11: Maximum Predicted Annual Average NO2 GLCs – Smouldering Phase

+ Nearest Sensitive Receptor

__ Site Boundary

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Cumulative air quality impacts have been estimated by adding the GLCs predicted at the nearest

sensitive receptor to the background air contaminant levels measured in the Karratha area during

the PAQS, as summarised in Table 7.

Table 6: Maximum Predicted Cumulative GLCs – Smouldering Phase

Compound Averaging

Period

Criteria Background1 Nearest

Receptor Cumulative

µg/m3 µg/m3 % of

Criteria µg/m3 µg/m3

% of

Criteria

NO2

1-hour 246 126 51% 3.8 130 53%

Annual 62 4.0 6.5% 0.03 4.0 6.5%

SO2

1-hour 572 378 66% 4.9 383 67%

24-hour 229 17 7.4% 0.5 18 7.6%

Annual 57 2.8 4.9% 0.04 2.8 5.0%

Notes

1. Background air contaminant levels measured in the Karratha area during the PAQS.

The results of the cumulative assessment indicate that at the nearest sensitive receptor, the

maximum 1-hour NO2 GLC is predicted to increase from 51% to 53% of the corresponding NEPM

Standard (Table 6). The cumulative annual average NO2 GLC is only expected to increase by

0.4 µg/m3 and remains equal to less than 10% of the annual NEPM Standard. The cumulative SO2

GLCs are predicted to increase by no more than 1% of the applicable NEPM Standards (Table 6).

6.2 Heating Phase

The maximum predicted GLCs for the Hottpad system operating during the heating phase (i.e. in

conjunction with a single generator operating at 80% power load) are summarised in Table 7. The

maximum concentrations predicted throughout the model domain and at the nearest sensitive

receptor are presented for emissions shared by both the Hottpad system and diesel generators

only; and compared against the relevant ambient air quality criteria for the protection of human

health and odour annoyance.

It is noted the predicted 24-hour average GLCs (including SO2, PM2.5, PM10, toluene and xylenes)

are considered to be overestimates of the likely air quality impacts as the model has

conservatively assumed continuous emissions, modelled on an hourly time-step throughout the

modelled year; whereas the duration of the heating phase is expected to be limited to 12-hours at

a time.

Table 7: Maximum Predicted GLCs – Heating Phase

Compound Averaging

Period

Criteria Maximum Predicted GLC

Model Domain Nearest Receptor

µg/m3 µg/m3 % of

Criteria µg/m3

% of Criteria

CO 8-hour 11,254 1,166 10% 57 0.5%

NO2 1-hour 246 207 84% 37 15%

SO2 1-hour 572 39 6.7% 4.9 0.9%

24-hour 229 12 5.3% 0.4 0.2%

PM10 24-hour 50 51 102% 0.3 0.6%

PM2.5 24-hour 25 50 199% 0.3 1.2%

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Compound Averaging Period

Criteria Maximum Predicted GLC

Model Domain Nearest Receptor

µg/m3 µg/m3 % of

Criteria µg/m3

% of

Criteria

Benzene 1-hour 29 2.7 9.2% 0.3 1.2%

Formaldehyde 1-hour 20 0.3 1.6% 0.01 0.05%

Toluene 1-hour 360[1] 1.5 0.4% 0.2 0.1%

24-hour 4,113 0.5 0.01% 0.02 0.00%

Xylenes 1-hour 190[1] 0.4 0.2% 0.05 0.03%

24-hour 1,185 0.2 0.01% 0.004 0.00%

Acetaldehyde 1-hour 42[1] 0.2 0.5% 0.01 0.02%

1,3-Butadiene 1-hour 40 0.6 1.4% 0.1 0.2%

Notes

1. Impact assessment criteria for individual odorous pollutants (NSW EPA, 2016).

The results presented in Table 7 indicate that during the heating phase, the maximum predicted

24-hour average PM2.5 and PM10 GLCs are expected to exceed the corresponding NEPM Standards.

However, these GLCs are considered highly conservative and are likely to represent an

overestimate of the expected impacts as the model has assumed continuous emissions acr oss

each 24-hour period, while the heating phase is only expected to last for a duration of 12-hours.

Furthermore, contours of the maximum predicted 24-hour average PM2.5 and PM10 GLCs (Figure

12 and Figure 13 respectively) indicate that the predicted exceedances are restricted to an area

within 80 m of the site boundary and fall below 50% of the NEPM Standard within 100 m of the

site. At the nearest sensitive receptor, the maximum predicted 24-hour average PM10 and PM2.5

GLCs are equal to no more than 1.2% of the corresponding NEPM Standards.

The maximum predicted 1-hour NO2 concentration of 207 µg/m3 is equal to 84% of the

corresponding NEPM Standard and is also expected to occur within close proximity of the

modelled sources (Figure 14). At the nearest sensitive receptor, the maximum predicted 1-hour

NO2 GLC is 37 µg/m3, equal to 15% of the NEPM Standard (Table 7).

The percentage contributions of each modelled source to the maximum predicted PM2.5, PM10 and

NO2 GLCs for the heating phase of the Hottpad system are presented in Table 8. These data

indicate that the maximum predicted GLCs for these compounds are being driven by emissions

from the generator stack. As described in Section 6.1, emissions from this source are subject to

building wake effects as the height of the generator exhaust stack is less than 40% of the height

of nearby building structures (including the container unit housing the generators). The

subsequent entrainment of exhaust gases released by short stacks in the wake of a building can

result in much higher GLCs close to the source than the model would otherwise predict.

Table 8: Summary of Source Contributions to Maximum Predicted PM2.5, PM10 and NO2 GLCs – Smouldering Phase

Compound Averaging

Period

Criteria Maximum

Predicted GLC2 Percentage Contribution

µg/m3 µg/m3 Hottpad Generator 1

NO2 1-hour 246 103 0.01%[1] 99.9%[1]

PM10 24-hour 50 24 2.4% 97.6%

PM2.5 24-hour 25 23 2.5% 97.5%

Notes

1. Estimated contributions based on predicted NO x GLCs.

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The maximum GLCs for the remaining modelled compounds are predicted to be equal to or less

than 10% of the corresponding air quality criteria, and less than 1.2% at the nearest sensitive

receptor (Table 7).

Cumulative short-term air quality impacts have been estimated by adding the GLCs predicted at

the nearest sensitive receptor to the background air contaminant levels measured in the Karratha

area during the PAQS, as summarised in Table 9.

Table 9: Maximum Predicted Cumulative GLCs – Heating Phase

Compound Averaging

Period

Criteria Background1 Nearest

Receptor Cumulative

µg/m3 µg/m3 % of

Criteria µg/m3 µg/m3

% of

Criteria

NO2 1-hour 246 126 51% 37 163 66%

SO2

1-hour 572 378 66% 4.9 383 67%

24-hour 229 17 7.4% 0.5 17 7.6%

Notes

1. Background air contaminant levels measured in the Karratha area during the PAQS.

The results of the cumulative assessment indicate that at the nearest sensitive receptor, the

maximum 1-hour NO2 GLC is predicted to increase from 51% to 66% of the corresponding NEPM

Standard (Table 9). The cumulative SO2 GLCs are predicted to increase by no more than 1% of

the applicable NEPM Standards (Table 9).

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Figure 12: Maximum Predicted 24-hour Average PM2.5 GLCs – Heating Phase

+ Nearest Sensitive Receptor

__ Site Boundary

__ PM2.5 NEPM Standard

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Figure 13: Maximum Predicted 24-hour Average PM10 GLCs – Heating Phase

+ Nearest Sensitive Receptor

__ Site Boundary

__ PM10 NEPM Standard

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Figure 14: Maximum Predicted 1-hour Average NO2 GLCs – Heating Phase

+ Nearest Sensitive Receptor

__ Site Boundary

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7. SUMMARY

Chevron and Cleanaway are proposing to construct a Hottpad remediation system at the ToxFree

Karratha Waste Handling Facility. The Hottpad system will utilise smouldering combustion to treat

oily sludges derived from local operations and will be powered by two dedicated diesel generators.

The treatment process involves a 12-hour heating phase, which requires the use of a single

generator operating at 80% power load; followed by a 3.5 day smouldering phase that utilises a

single generator operating at 25% power load.

Air dispersion modelling has been undertaken for the key contaminants that may be present in

atmospheric emissions from the proposed Hottpad system and associated generators, to assess

the potential impacts upon ambient air quality. Predicted GLCs have been estimated using the

AERMOD model and a meteorological dataset primarily developed using measured meteorological

data from the BoM Karratha Airport Station.

The emission estimates for the Hottpad system were derived from emissions testing data provided

by Chevron, as reported for their Batangas operations. The samples were collected upstream of

any emissions treatment systems at the Batangas site and the maximum concentrations

measured across all sampling events for each of the monitored compounds were conservatively

applied in the calculation of the emission estimates. The emission estimates for the diesel

generators were derived from emission factors published by the NPI for combustion engines and

fuel usage rates for the nominated power loads, as provided by Chevron.

GLCs were predicted for both the smouldering and heating phases and compared against relevant

ambient air quality for the protection of human health and odour annoyance. The cumulative

impact upon existing air quality in the Karratha region were also determined for each operating

phase operating scenario, using ambient air quality monitoring data reported for the PAQS.

The key findings of the air dispersion modelling assessment are as follows:

Smouldering Phase

• The maximum GLCs predicted for the smouldering phase are expected to remain below the

corresponding air quality criteria for each of the modelled compounds.

• The maximum predicted 24-hour PM2.5 GLC most closely approaches the relevant criteria,

equal to 92% of the corresponding NEPM Standard. However, contours of the maximum

predicted 24-hour average PM2.5 GLCs indicate that this concentration is expected to occur

onsite and the predicted GLCs fall below 20% of the NEPM Standard within 100 m of the site

boundary. At the nearest sensitive receptor, the maximum predicted 24-hour average PM2.5

GLC is equal to 0.6% of the NEPM Standard. The highest annual average PM2.5 GLCs is

expected to equal 42% of the corresponding NEPM.

• The maximum predicted 24-hour average PM10 GLC is equal to 47% of the corresponding

NEPM Standard. At the nearest sensitive receptor, the maximum predicted 24-hour average

PM10 GLC is equal to 0.7% of the corresponding standard. The annual average PM10 GLCs are

predicted to be less than 14% of the annual NEPM Standard.

• The maximum predicted 1-hour NO2 concentration is equal to 42% of the corresponding NEPM

Standard and is expected to occur within close proximity of the modelled sources. At the

nearest sensitive receptor, the maximum predicted 1-hour NO2 GLC is equal to 1.6% of the

NEPM Standard. The annual average NO2 GLCs are predicted to be less than 15% of the annual

NO2 NEPM Standard.

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• Analysis of the predicted GLCs indicates that the maximum predicted GLCs of PM2.5, PM10 and

NO2 are being driven by emissions from the generator stack(s), which are subject to building

wake effects as the height of the generator exhaust stack(s) is less than 40% of the height of

nearby building structures (including the container unit housing the generators).

• The cumulative maximum 1-hour NO2 GLC is predicted to increase from 51% to 53% of the

corresponding NEPM Standard. The cumulative annual average NO2 GLC remains equal to less

than 10% of the annual NEPM Standard. The cumulative SO2 GLCs are predicted to increase by

no more than 1% of the applicable NEPM Standards.

Heating Phase

• The maximum predicted 24-hour average PM2.5 and PM10 GLCs are expected to exceed the

corresponding NEPM Standards. However, these GLCs are considered highly conservative and

are likely to represent an overestimate of the expected impacts as the model has assumed

continuous emissions across each 24-hour period, while the heating phase is only expected to

last for a duration of 12-hours. Furthermore, the predicted exceedances are restricted to an

area within 80 m of the site boundary and predicted GLCs fall below 50% of the NEPM

Standards within 100 m of the site. At the nearest sensitive receptor, the maximum predicted

24-hour average PM10 and PM2.5 GLCs are equal to no more than 1.2% of the corresponding

NEPM Standards.

• The maximum predicted 1-hour NO2 concentration is equal to 84% of the corresponding NEPM

Standard and is also expected to occur within close proximity of the modelled sources. At the

nearest sensitive receptor the maximum predicted short-term NO2 GLC is equal to 34% of the

corresponding Standard.

• The maximum GLCs for the remaining modelled compounds are predicted to be equal to or

less than 11% of the corresponding air quality criteria, and less than 1% at the nearest

sensitive receptor.

• The results of the cumulative assessment indicate that at the nearest sensitive receptor, the

maximum 1-hour NO2 GLC is predicted to increase from 51% to 66% of the corresponding

NEPM Standard. The cumulative SO2 GLCs are predicted to increase by no more than 1% of

the applicable NEPM Standards.

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8. REFERENCES

Bureau of Meteorology (BoM). 2019. “Climate statistics for Australian locations. Karratha Aero”.

Retrieved March 2019. http://www.bom.gov.au/climate/averages/tables/cw_004083_All.shtml

Department of Environment (DoE). 2004. “Pilbara Air Quality Study Summary Report”. Air Quality

Management Branch, Department of Environment. August 2004.

Department of Environmental Protection (DEP). 2002. “Monitoring of Ambient Air Quality and

Meteorology during the Pilbara Air Quality Study”. Technical Series 113. Department of

Environmental Protection, Perth WA. September 2002.

Department of Water and Environment Regulation (DWER). 2017. “Guidance Statement: Risk

Assessments.” February 2017.

National Environment Protection Council (NEPC). 2011. “National Environmental Protection (Air

Toxics) Measure.” September 2011.

National Pollutant Inventory (NPI). 2008. “Emission Estimation Technique Manual for Combustion

Engines”. Commonwealth of Australia. June 2008.

New South Wales Environment Protection Authority (NSW EPA). 2016. “Approved Methods for the

Modelling and Assessment of Air Pollutants in New South Wales.” November 2016.

Turner, B. 1970. ”Workbook of Atmospheric Dispersion Estimates.” Revised 1970.

Environmental Protection Authority Victoria (Vic EPA). 2013. “Guidance notes for using the

regulatory air pollution model AERMOD in Victoria”. EPA Victoria. October 2013.

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9. DISCLAIMER AND LIMITATIONS

This document is issued in confidence to Compliance Monitoring for the purposes of undertaking

an air quality assessment of emissions from the proposed Chevron ETC Hottpad Plant, to be

located in Karratha WA. It should not be used for any other purpose.

The report must not be reproduced in whole or in part except with the prior consent of Ramboll

Australia Pty Ltd and subject to inclusion of an acknowledgement of the source. No information as

to the contents or subject matter of this document or any part thereof may be communicated in

any manner to any third party without the prior consent of Ramboll Australia Pty Ltd.

Whilst reasonable attempts have been made to ensure that the contents of this report are

accurate and complete at the time of writing, Ramboll Australia Pty Ltd disclaims any

responsibility for loss or damage that may be occasioned directly or indirectly through the use of,

or reliance on, the contents of this report.

© Ramboll Australia Pty Ltd

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APPENDIX 1

AERMET INPUT FILES

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******************************************************** ** AERMET - STAGE 1 Input Produced by: ** AERMET View Ver. 9.4.0 ** Lakes Environmental Software Inc.

** Date: 2019/02/26 ** File: E:\Chevron\Cleanaway\AERMET\Cleanaway Karratha.IN1 ******************************************************** JOB REPORT Cleanaway_Karratha.RP1 MESSAGES Cleanaway_Karratha.MG1

ONSITE ** Location of the Onsite Data File ** X:\Projects_and_Clients\Compliance Monitoring\Chevron\318000659 - Cleanaway\Model Inputs\Met Data\Karratha_2017.csv

DATA KARRAT~1.CSV QAOUT Cleanaway_Karratha.OQA XDATES 2017/01/01 TO 2017/12/31 LOCATION SiteID 20.810S 116.780E 0 33.00

OBS/HOUR 1 THRESHOLD 0.5 OSHEIGHTS 10 READ 1 OSYR OSMO OSDY OSHR TT01 RH01 PRES WS01 WD01 PRCP TSKC MHGT

FORMAT 1 FREE AUDIT MHGT PRCP PRES RH TT WD WS RANGE MHGT 0 < 4000 -999

RANGE PRCP 0 <= 25400 -9 RANGE PRES 9000 < 10999 99999 RANGE RH 0 <= 100 999 RANGE TT 0 < 45 99 RANGE WD 0 <= 360 999

RANGE WS 0 <= 50 999

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******************************************************** ** AERMET - STAGE 2 Input Produced by: ** AERMET View Ver. 9.4.0 ** Lakes Environmental Software Inc.

** Date: 2019/02/26 ** File: E:\Chevron\Cleanaway\AERMET\Cleanaway Karratha.IN2 ******************************************************** JOB REPORT Cleanaway_Karratha.RP2 MESSAGES Cleanaway_Karratha.MG2

ONSITE QAOUT Cleanaway_Karratha.OQA MERGE

OUTPUT Cleanaway_Karratha.MRG XDATES 2017/01/01 TO 2017/12/31

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******************************************************** ** AERMET - STAGE 3 Input Produced by: ** AERMET View Ver. 9.4.0 ** Lakes Environmental Software Inc.

** Date: 2019/02/26 ** File: E:\Chevron\Cleanaway\AERMET\Cleanaway Karratha.IN3 ******************************************************** JOB REPORT Cleanaway_Karratha.RP3 MESSAGES Cleanaway_Karratha.MG3

METPREP DATA Cleanaway_Karratha.MRG LOCATION SiteID 20.810S 116.780E -8 MODEL AERMOD

OUTPUT aermet.sfc PROFILE aermet.pfl XDATES 2017/01/01 TO 2017/12/31

METHOD WIND_DIR NORAND METHOD STABLEBL ADJ_U* METHOD CCVR SUB_CC METHOD TEMP SUB_TT ** Primary Surface Characteristics FREQ_SECT SEASONAL 1

SECTOR 1 0 360 ** Period - Sector - Albedo - Bowen Ratio - Surface Roughness SITE_CHAR 1 1 0.2500 4.0000 0.15000 SITE_CHAR 2 1 0.2500 6.0000 0.15000

SITE_CHAR 3 1 0.2500 6.0000 0.15000 SITE_CHAR 4 1 0.2500 3.0000 0.15000

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APPENDIX 2

AERMOD INPUT FILES

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** **************************************** ** ** AERMOD Input Produced by:

** AERMOD View Ver. 9.4.0 ** Lakes Environmental Software Inc. ** Date: 4/9/2019 ** File: E:\Chevron\Cleanaway\AERMOD\Cleanaway_Karratha_R02\Cleanaway_Karratha_R02.ADI ** ****************************************

** ** **************************************** ** AERMOD Control Pathway **************************************** ** **

CO STARTING TITLEONE E:\Chevron\Cleanaway\AERMOD\Cleanaway_Karratha\Cleanaway_Karratha.is MODELOPT CONC AVERTIME 1 PERIOD POLLUTID OTHER RUNORNOT RUN

ERRORFIL Cleanaway_Karratha_R02.err CO FINISHED ** **************************************** ** AERMOD Source Pathway **************************************** **

** SO STARTING ** Source Location ** ** Source ID - Type - X Coord. - Y Coord. ** LOCATION HOTT POINT 476328.320 7698800.760 33.310 ** DESCRSRC HOTT Pad Stack

LOCATION GEN1_N POINT 476329.710 7698789.300 33.180 ** DESCRSRC Generator 1 - Normal Operations LOCATION GEN2_N POINT 476331.440 7698778.030 33.070 ** DESCRSRC Generator 2 - Normal Operations LOCATION GEN1_S POINT 476329.710 7698789.300 33.180 ** DESCRSRC Generator 1 - Start-up Operations LOCATION GEN2_S POINT 476331.440 7698778.030 33.070

** DESCRSRC Generator 2 - Normal Operations LOCATION GEN1_S_V POINT 476329.710 7698789.300 33.180 ** DESCRSRC Gen 1 Start-up, increased velocity ** Source Parameters ** SRCPARAM HOTT 1.0 10.000 325.000 12.91000 0.254 SRCPARAM GEN1_N 1.0 3.000 538.000 8.20000 0.250

SRCPARAM GEN2_N 1.0 3.000 538.000 8.20000 0.250 SRCPARAM GEN1_S 1.0 3.000 538.000 26.10000 0.250 SRCPARAM GEN2_S 1.0 3.000 538.000 26.10000 0.250 SRCPARAM GEN1_S_V 1.0 3.000 538.150 39.54832 0.203 ** Building Downwash ** BUILDHGT HOTT 0.00 0.00 0.00 0.00 0.00 0.00

BUILDHGT HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDHGT HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDHGT HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDHGT HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDHGT HOTT 0.00 0.00 0.00 2.60 2.60 2.60

BUILDHGT GEN1_N 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_N 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_N 2.90 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_N 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_N 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_N 2.90 10.00 10.00 10.00 2.60 2.60

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BUILDHGT GEN2_N 2.90 2.90 2.90 2.90 2.90 2.90 BUILDHGT GEN2_N 2.90 2.90 2.90 2.90 2.90 2.90 BUILDHGT GEN2_N 2.90 2.90 2.60 2.60 2.60 2.90 BUILDHGT GEN2_N 2.90 2.90 2.90 2.90 2.90 2.90

BUILDHGT GEN2_N 2.90 2.90 2.90 2.90 2.90 2.90 BUILDHGT GEN2_N 10.00 10.00 10.00 10.00 2.60 2.90 BUILDHGT GEN1_S 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S 2.90 2.60 2.60 2.60 2.60 2.60

BUILDHGT GEN1_S 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S 2.90 10.00 10.00 10.00 2.60 2.60 BUILDHGT GEN2_S 2.90 2.90 2.90 2.90 2.90 2.90 BUILDHGT GEN2_S 2.90 2.90 2.90 2.90 2.90 2.90 BUILDHGT GEN2_S 2.90 2.90 2.60 2.60 2.60 2.90

BUILDHGT GEN2_S 2.90 2.90 2.90 2.90 2.90 2.90 BUILDHGT GEN2_S 2.90 2.90 2.90 2.90 2.90 2.90 BUILDHGT GEN2_S 10.00 10.00 10.00 10.00 2.60 2.90 BUILDHGT GEN1_S_V 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S_V 2.60 2.60 2.60 2.60 2.60 2.60

BUILDHGT GEN1_S_V 2.90 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S_V 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S_V 2.60 2.60 2.60 2.60 2.60 2.60 BUILDHGT GEN1_S_V 2.90 10.00 10.00 10.00 2.60 2.60 BUILDWID HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDWID HOTT 0.00 0.00 0.00 0.00 0.00 0.00

BUILDWID HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDWID HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDWID HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDWID HOTT 0.00 0.00 0.00 6.59 5.62 6.96 BUILDWID GEN1_N 8.85 10.47 11.77 12.71 13.27 13.42

BUILDWID GEN1_N 13.17 12.51 12.61 12.53 12.07 11.25 BUILDWID GEN1_N 5.93 8.60 7.37 6.59 5.62 6.96 BUILDWID GEN1_N 8.85 10.47 11.77 12.71 13.27 13.42 BUILDWID GEN1_N 13.17 12.51 12.61 12.53 12.07 11.25 BUILDWID GEN1_N 5.93 28.35 27.55 25.91 5.62 6.96 BUILDWID GEN2_N 4.02 4.88 5.59 6.13 6.48 6.64

BUILDWID GEN2_N 6.59 6.35 6.47 6.64 6.60 6.36 BUILDWID GEN2_N 5.93 5.32 7.37 6.59 5.62 3.04 BUILDWID GEN2_N 4.02 4.88 5.59 6.13 6.48 6.64 BUILDWID GEN2_N 6.59 6.35 6.47 6.64 6.60 6.36 BUILDWID GEN2_N 28.29 28.35 27.55 25.91 5.62 3.04

BUILDWID GEN1_S 8.85 10.47 11.77 12.71 13.27 13.42 BUILDWID GEN1_S 13.17 12.51 12.61 12.53 12.07 11.25 BUILDWID GEN1_S 5.93 8.60 7.37 6.59 5.62 6.96 BUILDWID GEN1_S 8.85 10.47 11.77 12.71 13.27 13.42 BUILDWID GEN1_S 13.17 12.51 12.61 12.53 12.07 11.25 BUILDWID GEN1_S 5.93 28.35 27.55 25.91 5.62 6.96

BUILDWID GEN2_S 4.02 4.88 5.59 6.13 6.48 6.64 BUILDWID GEN2_S 6.59 6.35 6.47 6.64 6.60 6.36 BUILDWID GEN2_S 5.93 5.32 7.37 6.59 5.62 3.04 BUILDWID GEN2_S 4.02 4.88 5.59 6.13 6.48 6.64 BUILDWID GEN2_S 6.59 6.35 6.47 6.64 6.60 6.36 BUILDWID GEN2_S 28.29 28.35 27.55 25.91 5.62 3.04

BUILDWID GEN1_S_V 8.85 10.47 11.77 12.71 13.27 13.42 BUILDWID GEN1_S_V 13.17 12.51 12.61 12.53 12.07 11.25 BUILDWID GEN1_S_V 5.93 8.60 7.37 6.59 5.62 6.96 BUILDWID GEN1_S_V 8.85 10.47 11.77 12.71 13.27 13.42 BUILDWID GEN1_S_V 13.17 12.51 12.61 12.53 12.07 11.25 BUILDWID GEN1_S_V 5.93 28.35 27.55 25.91 5.62 6.96

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BUILDLEN HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDLEN HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDLEN HOTT 0.00 0.00 0.00 0.00 0.00 0.00

BUILDLEN HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDLEN HOTT 0.00 0.00 0.00 0.00 0.00 0.00 BUILDLEN HOTT 0.00 0.00 0.00 13.17 12.51 12.61 BUILDLEN GEN1_N 12.53 12.07 11.25 10.08 8.60 7.37 BUILDLEN GEN1_N 6.59 5.62 6.96 8.85 10.47 11.77

BUILDLEN GEN1_N 6.13 13.27 13.42 13.17 12.51 12.61 BUILDLEN GEN1_N 12.53 12.07 11.25 10.08 8.60 7.37 BUILDLEN GEN1_N 6.59 5.62 6.96 8.85 10.47 11.77 BUILDLEN GEN1_N 6.13 27.36 25.61 23.08 12.51 12.61 BUILDLEN GEN2_N 6.64 6.60 6.36 5.93 5.32 4.55 BUILDLEN GEN2_N 3.64 2.62 3.04 4.02 4.88 5.59

BUILDLEN GEN2_N 6.13 6.48 13.42 13.17 12.51 6.47 BUILDLEN GEN2_N 6.64 6.60 6.36 5.93 5.32 4.55 BUILDLEN GEN2_N 3.64 2.62 3.04 4.02 4.88 5.59 BUILDLEN GEN2_N 28.29 27.36 25.61 23.08 12.51 6.47 BUILDLEN GEN1_S 12.53 12.07 11.25 10.08 8.60 7.37

BUILDLEN GEN1_S 6.59 5.62 6.96 8.85 10.47 11.77 BUILDLEN GEN1_S 6.13 13.27 13.42 13.17 12.51 12.61 BUILDLEN GEN1_S 12.53 12.07 11.25 10.08 8.60 7.37 BUILDLEN GEN1_S 6.59 5.62 6.96 8.85 10.47 11.77 BUILDLEN GEN1_S 6.13 27.36 25.61 23.08 12.51 12.61 BUILDLEN GEN2_S 6.64 6.60 6.36 5.93 5.32 4.55

BUILDLEN GEN2_S 3.64 2.62 3.04 4.02 4.88 5.59 BUILDLEN GEN2_S 6.13 6.48 13.42 13.17 12.51 6.47 BUILDLEN GEN2_S 6.64 6.60 6.36 5.93 5.32 4.55 BUILDLEN GEN2_S 3.64 2.62 3.04 4.02 4.88 5.59 BUILDLEN GEN2_S 28.29 27.36 25.61 23.08 12.51 6.47

BUILDLEN GEN1_S_V 12.53 12.07 11.25 10.08 8.60 7.37 BUILDLEN GEN1_S_V 6.59 5.62 6.96 8.85 10.47 11.77 BUILDLEN GEN1_S_V 6.13 13.27 13.42 13.17 12.51 12.61 BUILDLEN GEN1_S_V 12.53 12.07 11.25 10.08 8.60 7.37 BUILDLEN GEN1_S_V 6.59 5.62 6.96 8.85 10.47 11.77 BUILDLEN GEN1_S_V 6.13 27.36 25.61 23.08 12.51 12.61

XBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 XBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 XBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 XBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 XBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 XBADJ HOTT 0.00 0.00 0.00 -23.87 -23.64 -23.50

XBADJ GEN1_N -11.72 -11.04 -10.03 -8.71 -7.13 -5.33 XBADJ GEN1_N -3.37 -1.30 -0.93 -0.96 -0.96 -0.93 XBADJ GEN1_N 5.72 -0.78 -0.67 -0.54 -0.40 -0.57 XBADJ GEN1_N -0.81 -1.03 -1.22 -1.37 -1.48 -2.04 XBADJ GEN1_N -3.22 -4.31 -6.03 -7.89 -9.51 -10.84 XBADJ GEN1_N -11.84 -73.53 -74.34 -72.89 -12.12 -12.04

XBADJ GEN2_N 0.10 0.46 0.79 1.11 1.39 1.62 XBADJ GEN2_N 1.81 1.95 1.26 0.21 -0.85 -1.88 XBADJ GEN2_N -2.85 -3.74 -11.30 -11.73 -11.80 -6.22 XBADJ GEN2_N -6.74 -7.06 -7.16 -7.04 -6.71 -6.18 XBADJ GEN2_N -5.45 -4.57 -4.30 -4.23 -4.03 -3.71

XBADJ GEN2_N -61.92 -63.79 -63.71 -61.70 -0.72 -0.25 XBADJ GEN1_S -11.72 -11.04 -10.03 -8.71 -7.13 -5.33 XBADJ GEN1_S -3.37 -1.30 -0.93 -0.96 -0.96 -0.93 XBADJ GEN1_S 5.72 -0.78 -0.67 -0.54 -0.40 -0.57 XBADJ GEN1_S -0.81 -1.03 -1.22 -1.37 -1.48 -2.04 XBADJ GEN1_S -3.22 -4.31 -6.03 -7.89 -9.51 -10.84

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XBADJ GEN1_S -11.84 -73.53 -74.34 -72.89 -12.12 -12.04 XBADJ GEN2_S 0.10 0.46 0.79 1.11 1.39 1.62 XBADJ GEN2_S 1.81 1.95 1.26 0.21 -0.85 -1.88

XBADJ GEN2_S -2.85 -3.74 -11.30 -11.73 -11.80 -6.22 XBADJ GEN2_S -6.74 -7.06 -7.16 -7.04 -6.71 -6.18 XBADJ GEN2_S -5.45 -4.57 -4.30 -4.23 -4.03 -3.71 XBADJ GEN2_S -61.92 -63.79 -63.71 -61.70 -0.72 -0.25 XBADJ GEN1_S_V -11.72 -11.04 -10.03 -8.71 -7.13 -5.33

XBADJ GEN1_S_V -3.37 -1.30 -0.93 -0.96 -0.96 -0.93 XBADJ GEN1_S_V 5.72 -0.78 -0.67 -0.54 -0.40 -0.57 XBADJ GEN1_S_V -0.81 -1.03 -1.22 -1.37 -1.48 -2.04 XBADJ GEN1_S_V -3.22 -4.31 -6.03 -7.89 -9.51 -10.84 XBADJ GEN1_S_V -11.84 -73.53 -74.34 -72.89 -12.12 -12.04 YBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00

YBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 YBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 YBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 YBADJ HOTT 0.00 0.00 0.00 0.00 0.00 0.00 YBADJ HOTT 0.00 0.00 0.00 2.68 -0.88 -3.94

YBADJ GEN1_N -3.47 -4.28 -4.96 -5.49 -5.85 -6.04 YBADJ GEN1_N -6.04 -5.86 -5.74 -5.45 -5.00 -4.40 YBADJ GEN1_N -3.45 -2.82 -1.64 -0.07 1.51 2.55 YBADJ GEN1_N 3.47 4.28 4.96 5.49 5.85 6.04 YBADJ GEN1_N 6.04 5.86 5.74 5.45 5.00 4.40 YBADJ GEN1_N 3.45 14.93 4.31 -6.44 -1.51 -2.55

YBADJ GEN2_N -2.22 -1.59 -0.92 -0.21 0.50 1.20 YBADJ GEN2_N 1.85 2.46 2.99 3.42 3.76 3.98 YBADJ GEN2_N 4.07 4.05 2.49 2.16 1.76 2.78 YBADJ GEN2_N 2.22 1.59 0.92 0.21 -0.50 -1.20 YBADJ GEN2_N -1.85 -2.46 -2.99 -3.42 -3.76 -3.98 YBADJ GEN2_N 17.57 9.01 0.17 -8.67 -1.76 -2.78

YBADJ GEN1_S -3.47 -4.28 -4.96 -5.49 -5.85 -6.04 YBADJ GEN1_S -6.04 -5.86 -5.74 -5.45 -5.00 -4.40 YBADJ GEN1_S -3.45 -2.82 -1.64 -0.07 1.51 2.55 YBADJ GEN1_S 3.47 4.28 4.96 5.49 5.85 6.04 YBADJ GEN1_S 6.04 5.86 5.74 5.45 5.00 4.40 YBADJ GEN1_S 3.45 14.93 4.31 -6.44 -1.51 -2.55

YBADJ GEN2_S -2.22 -1.59 -0.92 -0.21 0.50 1.20 YBADJ GEN2_S 1.85 2.46 2.99 3.42 3.76 3.98 YBADJ GEN2_S 4.07 4.05 2.49 2.16 1.76 2.78 YBADJ GEN2_S 2.22 1.59 0.92 0.21 -0.50 -1.20 YBADJ GEN2_S -1.85 -2.46 -2.99 -3.42 -3.76 -3.98

YBADJ GEN2_S 17.57 9.01 0.17 -8.67 -1.76 -2.78 YBADJ GEN1_S_V -3.47 -4.28 -4.96 -5.49 -5.85 -6.04 YBADJ GEN1_S_V -6.04 -5.86 -5.74 -5.45 -5.00 -4.40 YBADJ GEN1_S_V -3.45 -2.82 -1.64 -0.07 1.51 2.55 YBADJ GEN1_S_V 3.47 4.28 4.96 5.49 5.85 6.04 YBADJ GEN1_S_V 6.04 5.86 5.74 5.45 5.00 4.40

YBADJ GEN1_S_V 3.45 14.93 4.31 -6.44 -1.51 -2.55 SRCGROUP HOTT HOTT SRCGROUP Gen1_N GEN1_N SRCGROUP Gen2_N GEN2_N SRCGROUP Gen1_S GEN1_S

SRCGROUP Gen2_S GEN2_S SRCGROUP GEN1_SV GEN1_S_V SO FINISHED ** **************************************** ** AERMOD Receptor Pathway ****************************************

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** ** RE STARTING INCLUDED Cleanaway_Karratha_R02.rou

RE FINISHED ** **************************************** ** AERMOD Meteorology Pathway **************************************** **

** ME STARTING SURFFILE "..\..\AERMET\Cleanaway Karratha.SFC" PROFFILE "..\..\AERMET\Cleanaway Karratha.PFL" SURFDATA 0 2017 UAIRDATA 0 2017 PROFBASE 33.0 METERS

ME FINISHED ** **************************************** ** AERMOD Output Pathway **************************************** **

** OU STARTING RECTABLE ALLAVE 1ST RECTABLE 1 1ST POSTFILE 1 GEN1_SV UNFORM Cleanaway_Karratha_R02.AD\Postpro.POS 31 ** Auto-Generated Plotfiles SUMMFILE Cleanaway_Karratha_R02.sum

OU FINISHED ** **************************************** ** Project Parameters **************************************** ** PROJCTN CoordinateSystemUTM

** DESCPTN UTM: Universal Transverse Mercator ** DATUM World Geodetic System 1984 ** DTMRGN Global Definition ** UNITS m ** ZONE -50 ** ZONEINX 0 **

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APPENDIX 3

BPIP INPUT FILES

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'E:\Chevron\Cleanaway\AERMOD\Cleanaway_Karratha\Cleanaway_Karratha.is' 'P' 'METERS' 1.00000000 'UTMY' 0.0000

16 'BLD_1' 1 33.48 'Material Receiving Shed' 4 10.00 476346.57 7698723.93 476345.00 7698741.86 476366.92 7698743.78

476368.49 7698725.85 'BLD_2' 1 33.01 'Generator Housing' 4 2.60 476330.51 7698777.26 476328.78 7698789.54 476331.16 7698789.87 476332.89 7698777.59

'BLD_3' 1 32.99 'Office' 4 2.80 476413.88 7698780.68 476412.17 7698792.86 476418.85 7698793.80 476420.57 7698781.61

'BLD_4' 1 32.97 'Offices & Crib' 4 2.80 476422.88 7698782.00 476421.13 7698794.45 476436.20 7698796.56 476437.95 7698784.12 'BLD_5' 1 32.90 'Admin'

4 2.80 476423.68 7698798.20 476422.70 7698805.14 476435.02 7698806.87 476436.00 7698799.93 'BLD_6' 1 32.96 'Managers Office'

4 2.90 476427.11 7698767.58 476425.31 7698780.42 476438.67 7698782.30 476440.48 7698769.46 'BLD_7' 1 32.99 'Crib' 4 2.80

476410.53 7698763.76 476408.86 7698775.64 476414.89 7698776.49 476416.56 7698764.61 'BLD_8' 1 33.10 'Workshop' 4 8.00

476489.18 7698715.87 476489.18 7698737.87 476511.18 7698737.87 476511.18 7698715.87 'BLD_9' 1 32.89 'Quarantine Bays' 4 10.00 476520.74 7698619.74

476518.23 7698643.61 476565.97 7698648.63 476568.48 7698624.76 'BLD_10' 1 32.12 'Quarantine Offices' 4 3.40 476569.37 7698626.78

476565.82 7698660.59 476568.80 7698660.90 476572.36 7698627.09 'BLD_11' 1 34.27 'Gorgon Shed' 4 7.00 476376.67 7698526.15 476370.82 7698567.74

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476389.64 7698570.39 476395.49 7698528.79 'BLD_12' 1 32.56 'Workshop Office' 4 3.40

476512.10 7698720.28 476512.10 7698737.28 476515.10 7698737.28 476515.10 7698720.28 'BLD_13' 1 33.37 'Site Office' 4 2.90

476438.70 7698639.02 476438.28 7698642.00 476452.14 7698643.94 476452.56 7698640.97 'BLD_14' 1 34.00 'Lab Storage' 4 2.80 476420.71 7698583.28

476420.29 7698586.25 476430.19 7698587.64 476430.61 7698584.67 'BLD_15' 1 32.90 'Office (near Admin)' 4 2.80 476417.89 7698801.41

476416.92 7698808.35 476419.89 7698808.76 476420.86 7698801.83 'BLD_16' 1 33.03 'Control Room' 4 2.90 476335.74 7698778.06 476333.46 7698777.78

476332.70 7698783.97 476334.98 7698784.25 5 'HOTT' 33.31 10.00 476328.32 7698800.76 'HOTT Pad Stack' 'GEN1_N' 33.18 3.00 476329.71 7698789.30 'Generator 1 - Normal Operations' 'GEN2_N' 33.07 3.00 476331.44 7698778.03 'Generator 2 - Normal Operations'

'GEN1_S' 33.18 3.00 476329.71 7698789.30 'Generator 1 - Start-up Operations' 'GEN2_S' 33.07 3.00 476331.44 7698778.03 'Generator 2 - Normal Operations'

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10 Bermondsey Street West Leederville WA 6007 t (+618) 9388 8360 f (+618) 9381 2360PO BOX 14, West Perth WA 6872

w 360environmental.com.au e [email protected]

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Les Egerton

From: Arqum Hayat <[email protected]>Sent: Thursday, 26 September 2019 9:03 AMTo: Les EgertonSubject: RE: DWER Presentation - working Rev1.pptx

Hi Les,  I have spoke to the EHO and confirm Planning & Environmental Health approval is not required.   Please contact me if you have any queries.   Kind regards,   

Arqum Hayat Planner/Compliance Officer 

 Direct: (08) 9186 8509 Email: [email protected]  Tel: (08) 9186 8555 Fax: (08) 9185 1626  www.karratha.wa.gov.au Disclaimer:  This email message and any attached files may contain information that is confidential and subject of legal privilege intended only for use by the individual or entity to whom they are addressed. Ifyou are not the intended recipient or the person responsible for delivering the message to the intended recipient be advised that you have received this message in error and that any use, copying, circulation, forwarding, printing or publication of this message or attached files is strictly forbidden, as is the disclosure of the information contained therein. If you have received this message in error, please notify the sender immediately and delete it from your Inbox. The views expressed in this email are those of the author, and do not represent those of the City of Karratha unless this is clearly indicated. You should scan this email and any attachments for viruses. The City of Karratha accepts no liability for any direct or indirect damage or loss resulting from the use of any attachments tothis email.      

From: Les Egerton <[email protected]>  Sent: Thursday, 26 September 2019 8:38 AM To: Arqum Hayat <[email protected]> Subject: FW: DWER Presentation ‐ working Rev1.pptx  Hi Arqum  Further to  discussions with Council staff, including the EHO, regarding the above activity I was of the understanding that we were to receive an email indicating that this activity did not require additional planning approval due to its small scale and the activity fitting in with the current approval.  I have searched my emails and cannot find the comms from the City of Karratha on this matter.  If you have already sent it can you please re‐send or alternatively flick me over an email confirming the same.   I am about to submit documentation to DWER on this activity and will require email comms indicating that Council Approval is not required. 

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 I apologise if you have already sent this email previously.  Kind regards  Les Egerton  Environmental Business Partner   92 Radium Street, Welshpool, 6106 P: +61 8 9351 1338   M: +61 499 333 283     E: [email protected] | www.cleanaway.com.au   

  Please consider the environment before printing this email.    

From: Les Egerton  Sent: Friday, 23 August 2019 2:00 PM To: [email protected] Subject: FW: DWER Presentation ‐ working Rev1.pptx    Les Egerton  Environmental Business Partner   92 Radium Street, Welshpool, 6106 P: +61 8 9351 1338   M: +61 499 333 283     E: [email protected] | www.cleanaway.com.au   

  Please consider the environment before printing this email.   ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________  ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________