section 38 referral supporting document · 2020. 6. 2. · section 38 referral supporting document...

100-TE-DC-0003_5

Report

Section 38 Referral Supporting Document

Pilbara Energy Generation Power Station

May 2020

45-10015-RP-EN-0001 Rev 145-10015-RP-EN-0001Rev 1

Section 38 Referral Supporting Document 45-10015-RP-EN-0001 Rev 1

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Section 38 Referral Supporting Document

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TABLE OF CONTENTS

1. INTRODUCTION .......................................................................................................... 7

1.1 Purpose and Scope ....................................................................................... 7

1.2 Proponent ...................................................................................................... 8

1.2.1 Company details ............................................................................................. 8

1.2.2 Proponent representative ................................................................................ 8

1.2.3 Referral contact ............................................................................................... 8

1.3 Environmental Impact Assessment Process .............................................. 9

1.4 Other Approvals and Regulation ................................................................. 9

1.4.1 Land Tenure.................................................................................................... 9

1.4.2 Decision-making authorities .......................................................................... 10

1.4.3 Other approvals required............................................................................... 10

2. THE PROPOSAL ....................................................................................................... 11

2.1 Background ................................................................................................. 11

2.2 Justification ................................................................................................. 11

2.2.1 Benefits of the Proposal ................................................................................ 11

2.2.2 Optimisation of the proposal .......................................................................... 13

2.2.3 Options and alternatives considered ............................................................. 13

2.2.3.1 Proposed scenario ........................................................................................ 13

2.2.3.2 Alternative power station option .................................................................... 14

2.2.3.3 Alternative locations and technologies .......................................................... 14

2.2.3.4 No development option ................................................................................. 14

2.3 Proposal description .................................................................................. 15

2.4 Local and Regional context ........................................................................ 16

2.4.1 Climate .......................................................................................................... 16

2.4.2 Physical environment .................................................................................... 17

2.4.3 Bioregions ..................................................................................................... 18

2.4.4 Land system.................................................................................................. 18

2.4.5 Hydrology ...................................................................................................... 19

2.4.6 Hydrogeology ................................................................................................ 19

2.4.7 Flora and vegetation ..................................................................................... 19

2.4.8 Conservation reserves .................................................................................. 20

2.4.9 RAMSAR wetlands ........................................................................................ 20

2.4.10 Other developments ...................................................................................... 20



3. STAKEHOLDER ENGAGEMENT .............................................................................. 20

3.1 Key stakeholders ........................................................................................ 21

3.2 Stakeholder engagement process ............................................................. 21

3.3 Stakeholder consultation ........................................................................... 21

4. ENVIRONMENTAL PRINCIPLES AND FACTORS .................................................... 23

4.1 Principles ..................................................................................................... 23

4.2 Greenhouse gas .......................................................................................... 25

4.2.1 EPA objective ................................................................................................ 25

4.2.2 Policy and Guidance ..................................................................................... 25

4.2.3 Receiving environment .................................................................................. 26

4.2.3.1 Surveys and studies ...................................................................................... 26

4.2.4 Assessment of impacts ................................................................................. 27

4.2.4.1 Gaseous emissions to air .............................................................................. 27

4.2.4.2 Greenhouse gas emissions in a broader context ........................................... 28

4.2.4.3 Cumulative impacts ....................................................................................... 29

4.2.5 Mitigation ...................................................................................................... 29

4.2.6 Predicted outcome ........................................................................................ 30

5. OTHER ENVIRONMENTAL FACTORS OR MATTERS ............................................. 30

5.1 Air quality .................................................................................................... 31

5.1.1 EPA objective ................................................................................................ 31

5.1.2 Policy and guidance ...................................................................................... 31

5.1.3 Receiving environment .................................................................................. 31

5.1.4 Assessment of impacts ................................................................................. 32

5.1.5 Mitigation ...................................................................................................... 33

5.1.6 Predicted outcome ........................................................................................ 33

6. OFFSETS ................................................................................................................... 33

6.1 Biodiversity offsets ..................................................................................... 33

6.2 Carbon offsets ............................................................................................. 34

7. MATTERS OF NATIONAL ENVIRONMENTAL SIGNIFICANCE ............................... 34

8. HOLISTIC IMPACT ASSESSMENT ........................................................................... 35

8.1 EPA Objectives ........................................................................................... 39



List of Tables

Table 1: Decision making authorities .......................................................................... 10

Table 2: State and local government approvals required for the Proposal................... 10

Table 3: Summary of the Proposal .............................................................................. 15

Table 4: Summary of the Proposal .............................................................................. 15

Table 5: Stakeholder consultation ............................................................................... 22

Table 6: EP Act Principles .......................................................................................... 23

Table 7: Modelled emissions and emission reductions from the Proposal and associated infrastructure ............................................................................... 27

Table 8: Calculated emissions from the PEG power station ........................................ 28

Table 9: Calculated emissions from the power station approved under MS993 .......... 29

Table 10: Reduction in generation and emissions through construction and operation of the PEG1 ....................................................................................................... 29

Table 11: Application of the mitigation hierarchy through the Proposal ......................... 30

Table 12. Maximum emission mass flow rates (per engine stack) ................................. 32

Table 13: Holistic Impact Assessment .......................................................................... 36

List of Figures

Figure 1: Pilbara Energy Connect Program .................................................................... 8

Figure 2: Likely generation scenario, when combined with solar generation and a battery system ............................................................................................... 13

Figure 3: Monthly averages for rainfall, evaporation and temperature, Wittenoom 1949-2019 .............................................................................................................. 17

Figure 4: 9am and 3pm average wind roses ................................................................ 17

Figure 5: Regional and local context ............................................................................ 43

Figure 6: Location ........................................................................................................ 44

Figure 7: Proposed site layout ...................................................................................... 45

Figure 8: Vegetation and flora receiving environment................................................... 46

Figure 9: Air quality receiving environment ................................................................... 47



LIST OF APPENDICES

Appendix 1: Greenhouse Gas Management Plan

Appendix 2: Air Emissions Impact Assessment

GLOSSARY

Abbreviation Definition CO Carbon Monoxide

CO2, CO2-e Carbon dioxide and carbon dioxide equivalent (emissions of other greenhouse gases are multiplied by their GWP so that their effects can be compared to equivalent emissions of carbon dioxide)

t Tonnes

GHG Greenhouse Gas

GJ Gigajoules

IPCC Intergovernmental Panel on Climate Change

kilotonne One Thousand Tonnes

m3 Cubic Metre

mbgl Metres Below Ground Level

MW, MWh Megawatt and Megawatt Hour

NGER, NGERS National Greenhouse and Energy Reporting System

PM Particulate Matter

PM10 and PM2.5 PM10 is particulate matter 10 micrometers or less in diameter, PM2.5 is particulate matter 2.5 micrometers or less in diameter.

NOx, NO2 Oxides of Nitrogen, Nitrogen Dioxide

PV Photovoltaic

SOx, SO2 Oxides of Sulphur, Sulphur Dioxide

SF6 Sulphur Hexafluoride

tCO2-e Tonnes of Carbon Dioxide equivalent

μg Microgram



1. INTRODUCTION

Pilbara Energy Generation Pty Ltd (PEG), a wholly-owned subsidiary company of Fortescue

Metals Group Ltd (Fortescue), proposes to develop a strategic Pilbara Energy Connect Program

which consists of a number of discrete projects including transmission infrastructure, gas fired

power generation and renewable energy generation such has solar and aeolian components

across several locations in the Pilbara Region of Western Australia (Figure 1). All of which can

exist independently of one another. This Project involves the development of the PEG power

station which is the subject of this referral (the Proposal). The energy generated by the power

station will be used to provide power to a range of Fortescue and Fortescue Joint Venture

Projects.

The new power generation facility (PEG power station), will be located on miscellaneous licence

L47/901, adjacent to the existing, Fortescue owned and operated, Solomon power station at the

Solomon Iron Ore Mine. The Proposal will involve the construction of 14 gas-fired reciprocating

engines with a combined maximum installed capacity of 165 MW (megawatt). It is expected that

the annual average throughput of the facility will be approximately 150 MW.

This supplementary report has been prepared in accordance with the Environmental Review

Document template.

1.1 Purpose and Scope

This document provides the supporting information for formal referral of the Proposal to the

Environmental Protection Authority (EPA) under Section 38 of the Environmental Protection Act

1986 (the EP Act). It has been prepared in accordance with Part IV Division 1 of the EP Act and

the Environmental Impact Assessment (Part IV Divisions 1 and 2) Administrative Procedures

2016.

This document presents the environmental factors relevant to the Proposal, details of completed

and ongoing investigations to assess potential environmental impacts and the management

proposed to achieve acceptable environmental outcomes.

The scope of this referral is limited to the development and operation of the PEG power station

that will be located adjacent the existing Solomon power station. The PEG power station will be

constructed with an installed capacity of 165MW, to produce on average 150 MW of power.



Figure 1: Pilbara Energy Connect Program

1.2 Proponent

Pilbara Energy (Generation), PEG, is a wholly-owned subsidiary of Fortescue.

1.2.1 Company details

Pilbara Energy (Generation) Pty Ltd (PEG)

ACN: 630 303 305

1.2.2 Proponent representative

Brett McGuire

Group Manager Environment

Level 2, 87 Adelaide Terrace

East Perth WA 6004

[email protected]

08 6218 8671

1.2.3 Referral contact

Sean McGunnigle

Manager Environmental Approvals

Level 2, 87 Adelaide Terrace

mailto:[email protected]



East Perth WA 6004

[email protected]

+61 438 958 771

1.3 Environmental Impact Assessment Process

There are no existing environmental approvals in place for the Proposal, however there are

several existing Fortescue environmental approvals that interact with this proposal. The

proposed power station is within the Solomon Iron Ore Mine footprint (MS1062).

The Proposal includes the development and operation of a new power station that is expected

to result in maximum annual greenhouse gas emissions of 609,696 tCO2-e and therefore will be

referred under Part IV of the EP Act to allow the EPA to determine whether the Proposal

requires formal assessment.

Although this Proposal will generate annual greenhouse gas emissions in excess of 100,000

tCO2-e, it does negate the need to construct a 221MW power station at North Star (approved

under MS993) and therefore results in a net reduction of greenhouse gas emissions of

approximately 568,727 tCO2-e/annum.

PEG consider that the likely environmental effects of this Proposal are not so significant to

warrant a formal assessment under Part IV. The predicted outcome of the impacts on

greenhouse gas results in a net environmental benefit (and less emissions) compared to the

construction and operation of a power station approved under MS 993. PEG is of the view that

the proposal can be assessed and regulated under Part V of the EP Act. Greenhouse Gas

emissions will be managed with the implementation of a site-specific Greenhouse Gas

management plan.

A self-assessment was undertaken by PEG of the significance of the impacts of the proposal in

reference to the DoEE Matters of Environmental Significance: Significant Impact Guidelines

(2013) and determined that the proposal will not have a significant impact on any matter of

National Environmental Significance (NES). Further detail is provided in Section 7.

The Proposal is not being referred under the Environment Protection and Biodiversity

Conservation Act 1999 (Commonwealth) (EPBC Act) or be subject to a State Agreement Act.

1.4 Other Approvals and Regulation

1.4.1 Land Tenure

The power station development envelope is located on L47/901 (live) for the purpose of a

‘power generation and transmission facility’.

mailto:[email protected]



Pastoral land affected by the Proposal includes Mt Florance Pastoral Station.

No File Notation Areas occur within the proposed PEG power station Development Envelope.

The nearest conservation reserve is Karijini National Park, located approximately 8 km south of

the proposed power station. There is relatively complex topography, including higher elevations

between the PEG power station and Karijini (Kendrick, 2002, cited in Appendix 2, page 38).

1.4.2 Decision-making authorities

The authorities listed in Table 1 have been identified as decision-making authorities (DMAs) for

the Proposal.

Table 1: Decision making authorities

Decision making authority Relevant legislation

Minister for Environment Biodiversity Conservation Act 2016 – Taking of flora and fauna

Environmental Protection Act 1986 – Section 38

Minister for Mines and Petroleum Mining Act 1978

• Programmes of Work

• Mining Proposals

Director General, Department of Water and Environmental Regulation

Environmental Protection Act 1986

• Part V Works Approval Licence

Environmental Protection (Clearing of Native Vegetation Regulations 2004)

• Clearing Permit

1.4.3 Other approvals required

The Proposal will require other state and local Government approvals (Table 2).

Table 2: State and local government approvals required for the Proposal

Proposal Activities Land Tenure/Access Type of Approval Legislation Regulating Activity

Construction and operation of infrastructure

Miscellaneous Licence Works Approval/Licence Environmental Protection Act 1986

Part V

Mining Proposal Mining Act 1978

The Proposal will require approval under the provisions of the Mining Act 1978 (Mining Act), as

the Proposal will be developed within Mining Act tenure. PEG will prepare and submit a Mining

Proposal in accordance with the Statutory Guideline for Mining Proposals in Western Australia,

March 2020 (Government of Western Australia 2020).



Licensing of the construction and operation of the PEG power station is required under Part V of

the EP Act, in the form of a works approval. Air emissions modelling has been completed given

the proposed size of the power station.

2. THE PROPOSAL

2.1 Background

The Solomon Iron Ore Project was assessed at the level of Public Environmental Review. The

Environmental Protection Authority (EPA) reported in November 2016 and Solomon was

approved on 3 October 2017 under Ministerial Statement 1062 (MS 1062). The PEG power

station will be constructed within an area previously cleared as part of the Solomon mining

operation activities.

The existing North Star Magnetite development was assessed at the level of Public

Environmental Review (PER). The Environmental Protection Authority (EPA) reported in June

2014 and North Star was approved on 5 January 2015 under Ministerial Statement 993 (MS

993). North Star (as amended) includes power being supplied to the mine area via an onsite

221 MW gas fired power station. To supply gas to the power station, the PER included the

construction of gas lateral from the existing Epic pipeline.

2.2 Justification

In January 2020, Fortescue announced the US$450 million Pilbara Generation Project, the next

stage of the Pilbara Energy Connect program. The Pilbara Generation Project complements the

US$250 million Pilbara Transmission Project announced in October 2019 and referred to the

EPA in November 2018. The project will provide low cost power to the energy efficient Iron

Bridge Magnetite Project. The Pilbara Generation Project includes 165MW of gas fired

generation, together with 150MW of solar photovoltaic (PV) generation (Lambda Junction solar

farm and North Star Junction solar farm) which will be supplemented by large scale battery

storage. All elements of the project; power station, PV generation and battery system can exist

independently of one another. This referral relates to the construction and operation of the

165MW gas fired power station (PEG power station - the Proposal) component of the Pilbara

Generation Project.

2.2.1 Benefits of the Proposal

The key benefit of this Proposal is a net reduction in greenhouse gas emissions when

compared to the previously approved 221 MW North Star power station, and negating the

requirement to build the North Star facility.

The net reduction in greenhouse gas emissions, when compared to the power station at North

Star approved under MS 993 (North Star power station) is achieved by:



• The procurement of extremely efficient engines (with a conservatively calculated

heat rate of ~9 GJ/MWh) to minimise greenhouse gas emissions and greenhouse

gas emission intensity. The 14 x 12MW Gas Reciprocating Engines proposed for

the PEG power station have been chosen for their advanced technology, are

highly efficient with very low emissions and heat rates. To compare the ~9

GJ/MWh efficiency from units to be procured for the PEG power station, the

Solomon power station as a whole achieves a heat rate of ~12 GJ/MWh A lower

heat rate results in an improved emission intensity, and in this case, results in a

25% reduction in greenhouse gas emissions per MWh.

• Reduction in the capacity of the power station due, in part to, future

supplementation with renewable energy from two proposed tracking photovoltaic

(PV) solar farms (outside of the scope of this Proposal but with an additional

combined capacity of 150 MW).

• An optimised dispatch strategy which involves units running at high loads (close to

optimal efficiency), units are added or subtracted from dispatch as power

requirements change (rather that running units at lower less efficient loads).

• A contemporary Power Management System (PMS), which uses complex

algorithms and seamlessly monitors, interacts, controls and provides for the most

efficient use of the entire generation network, meaning minimised fuel combustion.

While these engines have efficiency comparable to modern combined cycle power stations,

they use a fraction of the water that a gas turbine fitted with a heat recovery steam generator

would consume, these 14 engines combined are expected to use 7 kilolitres of water a week

under a worst-case scenario. For comparison water demand at the 122MW Solomon power

station is around 1300 to 1800 kilolitres per week (units fitted with heat recovery steam

generators would use even more). Circuit breakers, which are essential infrastructure for

electricity network, have been selected specially to avoid models filled with Sulphur

Hexafluoride (SF6), which is an extremely potent greenhouse gas. The 20, 100 and 500 year

global warming potentials for SF6 are considered to be 18,000, 23,800 and 31,300 times that of

CO2 respectively (Kovács et al. 2016).

In addition to the reduction and minimisation of greenhouse gases, the construction of the PEG

power station will also see a reduction in the gross emission and emission intensity of key

pollutants such as oxides of nitrogen (NOx), oxides of sulphur (SOx), carbon monoxide (CO) and

particulate matter (PM).

Another key benefit of this proposed location, when compared to the construction of a power

station at North Star, is that much of the infrastructure from the existing Solomon operations can

be utilised for the PEG power station. The proposed siting of the PEG power station has been

disturbed by previous activities, so further disturbance is not required. The construction of a gas

pipeline to the North Star site is also avoided by this Proposal, as there is no gas pipeline

currently existing to service this site.



2.2.2 Optimisation of the proposal

Further emission reduction, of both greenhouse gas, and key pollutants (oxides of nitrogen,

oxides of sulphur, carbon monoxide and particulate matter) will be realised with the integration

of proposed additions such as:

• The construction of a 60MW battery system to provide spinning reserve services.

The battery system will remove the need to dispatch fossil fuel generation to

provide these services. Which in the case of this network would mean the dispatch

of one of the Solomon power station 40MW gas turbines.

• The future construction of a transmission line linking Eliwana mine to the PEG

power station allowing the displacement of approved 20MW of diesel fired

generation at the Eliwana mine approved under MS1109 (Fortescue, 2018).

• The proposed construction of the two tracking PV solar farms, North Star Junction

and Lambda Junction, are expected to achieve high levels of penetration in

daylight hours (see Figure 2), and at peak solar generation (150MW) displace all

but 80MW of the PEG generation (compared to the 150MW of generation

expected overnight), and all generation from the Solomon power station.

Figure 2: Likely generation scenario, when combined with solar generation and a battery system

2.2.3 Options and alternatives considered

2.2.3.1 Proposed scenario

The location of this option is preferred as there is gas supply, previously cleared land and much

of the infrastructure required to support power generation and transmission are already in place.

PEG hold the view that due to the lack of disturbance, lower emissions (609,696 tCO2-e per

annum) and reduced emission intensity (0.464 tCO2-e/MWh) of the PEG power station (even

before solar and battery integration) that the PEG power station compares very favourably with

the alternative development option (construction of the North Star power station). This option

would ensure that development and operation of North Star approved under MS 993 (without



the development of the 221 MW power station) is able to proceed, with reliable and secure

energy supply, while also minimising environmental impact as far as practicable.

2.2.3.2 Alternative power station option

In the most likely alternative power supply scenario, the construction of the power station at

North Star approved under MS 993 would take place.

This power station would be larger in capacity and would have higher overall emissions

(1,196,423 tCO2-e per annum) and emission intensity (0.618 tCO2-e/MWh) of Greenhouse

Gases). Total emissions and emission intensity of pollutants such as NOx SOx, CO and PM

would also be proportionally higher due to the combustion of additional fuel.

The calculations for this scenario were based on the procurement of GE LM6000 gas turbines in

combination with Solar Titan Turbines, similar to that at Solomon power station. LM6000 gas

turbines offer high reliability, fast dispatch, dry low emission technology and best cost per

megawatt in their power class while occupying a small footprint (Baker Hughes, 2020) and fit

the specifications that were outlined (~40MW gas turbines) in the original North Star PER

(Fortescue, 2013), with auxiliary support from Solar Titans when increased from 120MW to

221MW. Two LM6000s and four Solar Titans are installed at Solomon power station, and data

from these units including heat rates was used in the calculation of emissions

This option would also necessitate the construction of an additional gas pipeline to the North

Star mine, which would involve fugitive emissions during normal operations as well as additional

clearing for both the power station and pipeline.

2.2.3.3 Alternative locations and technologies

Alternative locations were considered for siting the PEG power station, including within the area

approved for North Star under MS 993, however this would have required clearing, and the

construction of a new gas pipeline. The proposed location adjacent to the Solomon power

station makes use of previously cleared land and existing infrastructure (including the existing

Fortescue River gas pipeline).

Alternative technologies such as gas turbines were considered for the Proposal. These were

less efficient, and more greenhouse gas intensive. Integration of additional technologies,

including energy storage and renewable energy have been considered and will be investigated

throughout the life of the Proposal.

2.2.3.4 No development option

In a no-development scenario, there would be no potential environmental impacts. The no

development scenario would mean a halt to the further development of North Star approved

under MS 993, as it would be unable to proceed without an electrical power supply, this would



also mean that the Eliwana Project would be powered by an on-site power station, and would

be fired on diesel for the life of mine.

However, there would also be a loss of social and economic benefit at a local, regional and

state level, such as:

• New infrastructure for the Pilbara, including power transmission.

• A lack of employment and training opportunities for remote and isolated communities.

• The halt of development of the expansion to the existing North Star Project, which will

prevent the opportunity for the further optimisation and improved return on investment.

2.3 Proposal description

The Proposal consists of the construction and operation of the PEG power station that will be

located adjacent to the existing Solomon power station. The PEG power station will be

constructed with an installed capacity of 165MW, to produce on average 150 MW of power. The

Key Proposal Characteristics are presented in Tables 3 and 4.

Table 3: Summary of the Proposal

Proposal Title Pilbara Energy Generation Power Station

Proponent Name Pilbara Energy (Generation) Pty Ltd

Short Description The Proposal is for the construction and operation of a gas-fired power station, in the Pilbara bioregion of Western Australia. The Proposal will supply up to 150MW of power to the North Star mining operations and the Pilbara Transmission Project.

Table 4: Summary of the Proposal

Element Location Proposed Extent

Physical Elements

Clearing of native vegetation

N/A No additional clearing is required for the development of the PEG power station.

Operational Elements

Power generation Figure 5 & 6 Gas-fired reciprocating engines with an installed capacity of 165MW

Key infrastructure Figure 7 • 14 x gas reciprocating engines with installed

capacity of 165 MW

• 14 x exhaust stacks, approximately 18 m in height.

Supporting infrastructure Figure 7 • 50 KL self-bunded Oil Storage Tank

• 10 KL self-bunded Service Oil Tank

• 40 KL self-bunded Waste Oil Tank



Element Location Proposed Extent

• transformers (including approximately 1.5 KL of

insulating oil, self-bunded)

• black start diesel generator (1 KL diesel, self-

bunded)

• closed circuit external engine radiator cooling

systems

• oily water collection sumps and treatment plant

with holding tanks

• site storm water drainage

• site access roads.

2.4 Local and Regional context

The Solomon Iron Ore Project – Sustaining Production Public Environmental Review (PER)

(Fortescue, 2015) provided an extensive overview of the physical, biological and social

environment associated with the Solomon Project area, including the proposed location of the

PEG power station.

The Proposal is located within the Pilbara region of Western Australia, within the Shire of

Ashburton local Government areas.

2.4.1 Climate

Climatic conditions in the Pilbara region are arid to tropical, characterised by hot, wet summers

(October to April) and mild winters (May to September). Rainfall is generally low throughout the

year and is at its greatest in summer and autumn when storms and off-shore cyclonic activity

generate rainfall events (BoM, 2020, Van Vreeswyk et. al., 2004).

The closest operational Bureau of Meteorology weather station was established in 1949 in

Wittenoom, approximately 50 km to the east of the Proposal area. The mean annual rainfall at

Wittenoom is 461.8 mm with the majority of rainfall occurring between December and March

(BoM, 2020). Average minimum temperatures range from 11.6°C in July to 26.0°C in January.

Average maximum temperature varies between 24.3°C in July to 39.8°C in December (BoM,

2020). Between mid-December and April, the Pilbara region is susceptible to tropical cyclones,

which are capable of producing damaging winds, heavy rainfall, and flooding in inland areas.

Figure 3 shows the monthly averages for rainfall, evaporation and temperature, and Figure 4

shows the annual average wind roses for 9am and 3pm at Wittenoom.



Figure 3: Monthly averages for rainfall, evaporation and temperature, Wittenoom 1949-2019

Figure 4: 9am and 3pm average wind roses

2.4.2 Physical environment

The geological stratigraphy in the Pilbara region is relatively continuous. Similar geological

processes have occurred throughout the region resulting in the enrichment of iron deposits.



The Fortescue province lies over the Pilbara craton. The Hamersley Range was formed on the

late Archaean-Palaeoproterozoic metamorphosed banded iron formation, shales, dolerite,

carbonate, chert and rhyolite of the south Pilbara sub-basin. These rocks belong to the

Hamersley group and make-up part of the Ophthalmia fold belt. Tille (2006) described the

Hamersley plateau as hills and dissected plateau (with some stony plains and hardpan wash

plains) on sedimentary and volcanic rocks of the Hamersley basin. Much of the area is covered

with stony soils with shallow red loams and some red-brown non-cracking clays and red loamy

earths.

Acid drainage risk for soils within the Solomon Mine area is very low. As a result, investigations

have been focused on determining the risk of neutral metal drainage with extensive short- and

long-term leach testing of subsurface material. There has been no indication that any

metalliferous drainage has or is likely to occur from material in this area. Kinetic leach testing

also indicates that metalliferous drainage is unlikely to evolve over time.

2.4.3 Bioregions

The Proposal area is located in the Pilbara biogeographic region of the Interim Biogeographic

Regionalisation for Australia (IBRA) (Thackway & Cresswell, 1995) and within the Fortescue

Plains subregion near the boundary of the Hamersley subregion.

Kendrick (2002) described the Fortescue Plains subregion as “Alluvial plains and river frontage.

Extensive salt marsh, mulga-bunch grass, and short grass communities on alluvial plains in the

east. Deeply incised gorge systems in the western (lower) part of the drainage. River gum

woodlands fringe the drainage lines. Northern limit of Mulga (Acacia aneura). An extensive

calcrete aquifer (originating within a palaeo-drainage valley) feeds numerous permanent springs

in the central Fortescue, supporting large permanent wetlands with extensive stands of river

gum and cadjeput Melaleuca woodlands. Climatic conditions are semi desert tropical, with

average rainfall of 300 mm, falling mainly in summer cyclonic events. Drainage occurs to the

north-west.”

2.4.4 Land system

The Commonwealth Department of Agriculture and Water Resources, as part of the rangeland

resource surveys, has comprehensively described and mapped the biophysical resources of the

Pilbara region (Van Vreeswyk et al., 2004). As part of this process an inventory of land system

units, the Pilbara Regional Inventory (PRI) was established based on landform, soil, vegetation,

drainage characteristics and condition.

The PEG power station is situated within Boolgeeda land system, which is described as “stony

lower slopes and plains below hill systems supporting hard and soft spinifex grasslands and

mulga shrublands”.



2.4.5 Hydrology

The Proposal area lies in the Lower Fortescue River Watershed. The system has an intermittent

flow pattern resulting in rivers and creeks being dry for most of the year. Following significant

rainfall, channels in the region carry large volumes of water with peak flows usually occurring

within 24 hours of the rainfall event (MWH, 2010).

Three streams traverse operational areas of the Solomon Mine: Zalamea (South East Flow),

Kangeenarina (Central Flow) and Queens (West Flow). The eastern boundary of the Solomon

operation is formed by Weelumurra Creek (MWH, 2010). The PEG power station lies within the

subcatchment of an unnamed tributary to the Lower Fortescue River, to the north of the

Zalamea Creek Subcatchment.

2.4.6 Hydrogeology

The primary aquifer within the Solomon mine area is associated with secondary permeability

within the ochreous goethite lower Channel Iron Deposit (CID) unit. The enhanced permeability

is thought to be derived from interconnected vugs and cavities within the highly

altered/weathered lower CID.

Water quality is classified as fresh to marginal, with Total Dissolved Solids (TDS) ranging from

200 mg/L to 1,000 mg/L. Individual bore yields are variable, ranging from 50 L/s to 2,500 L/s

reflecting the interfingering relationship between the alluvium and colluvium. Groundwater flow

is a subdued reflection of topography, flowing from areas of high elevation to low elevation. The

water table is generally between 10 and 30 mbgl.

2.4.7 Flora and vegetation

Broad scale vegetation mapping of the Pilbara region has been completed by Beard (1975).

The Solomon Project is located within the Fortescue Botanical District of the Eremaean

Botanical Province (Beard, 1975). The vegetation of this province is typically open, and

frequently dominated by spinifex, acacias and occasional Eucalypts. The Solomon mine lies

predominantly within the Hamersley subregion, which is described as Mulga low woodland over

bunch grasses in valley floors and Eucalyptus leucophloia over Triodia on the ranges (Ecologia

Environment, 2014). The Solomon mine has been the subject of extensive biological survey

work, including flora and vegetation assessments covering the Proposed PEG power station

area in 2008, 2010, 2011 and most recently in 2014. Vegetation communities surrounding the

PEG power station are shown in Figure 8 and include:

• EllHcTw4: Eucalyptus leucophloia subsp. leucophloia low sparse woodland over

Hakea chordophylla tall sparse shrubland over Senna glutinosa subsp. glutinosa

mid sparse shrubland over Triodia wiseana closed hummock grassland.



• EllAiTw: Eucalyptus leucophloia subsp. leucophloia and Corymbia hamersleyana

low sparse woodland over Acacia inaequilatera tall sparse shrubland over Acacia

bivenosa and Senna glutinosa subsp. glutinosa mid sparse shrubland over Ptilotus

calostachyus low sparse shrubland.

2.4.8 Conservation reserves

Karijini National Park is located 8.3 km south of the Proposal. Karijini covers an area of 627,422

ha just north of the Tropic of Capricorn in the Hamersley Ranges. Karijini remains in relatively

undisturbed condition and has only been lightly grazed, although there is evidence of

exploration and mining activity at a number of locations.

The primary feature of the National Park is the deep, steep-sided gorges that are the focus of

the tourist activity during the cooler months of the year. Karijini is managed by the Department

of Biodiversity, Conservation and Attractions (DBCA) and is vested in the Conservation

Commission.

2.4.9 RAMSAR wetlands

The nearest Ramsar wetland is the Eighty Mile Beach Ramsar site consisting of Eighty Mile

Beach from Cape Keraudren to Cape Missiessy and Mandora Salt Marsh located 40 km to the

east (Commonwealth of Australia, 2014).

The PEG power station is located approximately 310 km south west of the Eighty Mile Beach

Ramsar site at the closest point.

2.4.10 Other developments

A number of existing iron ore mining operations are located in close proximity to the Proposal.

These include the following mines, located within ~ 50 km of the Proposal.

• Solomon Hub (Fortescue)

• Brockman 2 Nammuldi (Rio Tinto)

• Silvergrass (Rio Tinto)

• Western Turner Syncline (Rio Tinto)

3. STAKEHOLDER ENGAGEMENT

Extensive stakeholder consultation has been undertaken for the Solomon Iron Ore Project –

Sustaining Production proposal approved under Part IV of the EP Act pursuant to MS 1062.

While the proposed PEG power station does not fall within the scope of the Solomon Iron Ore

Mine, the stakeholder relationships are well established.



3.1 Key stakeholders

Key stakeholders relevant to the PEG power station include the following:

• Environmental Protection Authority (EPA)

• Department of Water and Environmental Regulation (DWER); including EPA

Services, Water and Regulation branches

• Department of Mines, Industry Regulation and Safety (DMIRS)

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

• Department of Planning, Lands and Heritage (DPLH)

• Shire of Ashburton

• Mt Florance Pastoral Station

• Yindjibarndi People

3.2 Stakeholder engagement process

Stakeholder consultation for the Proposal has formed part of the broader stakeholder

engagement strategy for Fortescue projects undergoing environmental approvals. The

overarching objectives of the strategy are:

• To inform stakeholders about the Proposal and its impacts to the environment and

to describe the outcomes of consultation on Proposal design

• To establish relationships with key stakeholders that enable ongoing dialogue

through implementation and regulation of the Proposal.

A summary of the stakeholder engagement and consultation undertaken to date with specific

relevance to the PEG power station is provided in Section 3.3. In accordance with Fortescue’s

Stakeholder Engagement Strategy, consultation with the key stakeholders listed above is

ongoing and will be undertaken on either a regular or ad-hoc basis, depending on the nature of

the relationship and the progression of the PEG power station Proposal.

3.3 Stakeholder consultation

Specific regulator consultation for the PEG power station has been undertaken with DWER

(regarding both Part IV and Part V regulation) and the Department of Mines, Industry Regulation

and Safety (DMIRS). The following stakeholders have also been consulted regarding the PEG

power station:

• Shire of Ashburton



• Mt Florance Pastoral Station

• Yindjibarndi People

Consultation undertaken is presented in Table 5.

Table 5: Stakeholder consultation

Stakeholder Date Issues/Topic Raised Proponent Response/Outcome

Yindjibarndi People + Brad Goode Associates

July 2011 Ethnographic Heritage Survey

No Heritage Sites recorded within L47/901

Yindjibarndi People + Alpha Archaeology

August 2011 and July 2012

Archaeological Heritage Survey

No Heritage Sites recorded within L47/901

Yindjibarndi People 13/11/2017 Native Title Determination N/A

Mt Florance Station 29/01/2019 PEC construction and operation of a power generation and transmission facility.

Access agreement signed for construction and operation of a power generation and transmission facility.

DMIRS 13/03/2019 Tenement application L47/901

Consultation process for tenement completed, granted 26/06/19

Shire of Ashburton 18/03/2019 Tenement application L47/901


Mt Florance Station 18/03/2019 Tenement application L47/901


Yindjibarndi People 05/04/2019 Notification of tenement application for L47/901

N/A

Yindjibarndi People 05/06/2019 No objections were received from the Yindjibarndi People for L47/901


DMIRS 26/06/2019 Tenement approval (no objections received)


DWER (EPA Services) 16/10/2019 Introduction to PEG Project – focus on PEG Solar Farms

PEG Solar Farms do not require Part IV referral

Mt Florance Station October 2019 Mt. Florance agreed to not lodge any objections to FMG / TPI tenure applications or mining related works within Mt. Florance to the South of the Solomon Railway.

General agreement that Fortescue can use areas south of the Solomon Railway Line for Mining purposes.

Mt Florance Station 19/10/2019 PEC tenures Deed of amendment agreed between PEC and Mt Florance.

DWER (EPA Services) 04/02/2020 Introduction to PEG Project – focus on PEG power station. Discussion

PEG to provide further information in letter



Stakeholder Date Issues/Topic Raised Proponent Response/Outcome

regarding approvals strategy and need for referral under Part IV

DWER (EPA Services) 13/02/2020 Correspondence to DWER following meeting on 04/02/2020, outlining case for non-referral

PEG to prepare s38 referral

Yindjibarndi People 12/03/2020 Discussion around impacts to cultural significance and emission numbers requested.

Fortescue confirmed no impact to cultural significance in the area, from construction or operation of Facility.

Fortescue supplied requested emission numbers.

DMIRS 19/03/2020 Pre-submission consultation

PEG to submit Mining Proposal application as discussed.

DWER (Part V) 19/03/2020 Pre-submission consultation

PEG to submit Works Approval application as discussed.

4. ENVIRONMENTAL PRINCIPLES AND FACTORS

This section identifies the environmental factors relevant to the Proposal and outlines the overall

assessment methodology presented in this document.

The environmental factors and objectives adopted by the EPA are listed in the Statement of

Environmental Principles, Factors and Objectives (SEP) (EPA, 2020a). The Proponent has

identified the following preliminary key environmental factors relevant to the Proposal:

• Greenhouse Gas

The Proponent considers the other environmental factors identified in the SEP are either not

relevant to the Proposal or are unlikely to result in a significant impact (refer section 5).

4.1 Principles

The Proponent’s consideration of the EP Act principles of environmental protection in relation to

the Proposal is detailed in Table 6.

Table 6: EP Act Principles

Principle Consideration

1. The precautionary principle

Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be

The proponent will maintain an environmental management system (EMS) that addresses activities with a potential to affect the environment. A key element of the EMS includes assessing risk to identify




used as a reason for postponing measures to prevent environmental degradation.

In application of this precautionary principle, decisions should be guided by:

a) careful evaluation to avoid, where practicable, serious or irreversible damage to the environment; and

b) an assessment of the risk-weighted consequences of various options.

potential impacts early in the process to enable planning for avoidance and/or mitigation. PEG has conducted scientific studies to understand the Proposal area and the potential risks to the environment. The proposal has sought to avoid, minimise and mitigate environmental impacts. The environmental risks associated with the Proposal have been assessed.

2. The principle of intergenerational equity

The present generation should ensure that the health, diversity and productivity of the environment is maintained and enhanced for the benefit of future generations.

The Proposal meets the principle of intergenerational equity by ensuring the health of the environmental values, maintaining ecological functions for future generations, whilst minimising any impacts on the environment.

PEG has identified measures to avoid and minimise impacts to these factors, such as siting the Proposal on already cleared land, and minimising emissions and emission intensity as far as practicable.

3. Principles relating to improved valuation, pricing and incentive mechanisms

(1) Environmental factors should be included in the valuation of assets and services.

(2) The polluter pays principles – those who generate pollution and waste should bear the cost of containment, avoidance and abatement.

(3) The users of goods and services should pay prices based on the full life-cycle costs of providing goods and services, including the use of natural resources and assets and the ultimate disposal of any waste.

Environmental goals, having been established, should be pursued in the most cost-effective way, by establishing incentive structure, including market mechanisms, which enable those best placed to maximise benefits and/or minimise costs to develop their own solution and responses to environmental problems.

PEG acknowledges the need for improved valuation, pricing and incentive mechanisms and endeavours to pursue these principles when practicable. For example:

• environmental factors have played a role in determining infrastructure types, specifications and locations.

• the cost of rehabilitation and closure has been incorporated into the costs of the product from the commencement of operation.

• There is currently no CO2-e pricing mechanism in place in Australia, but other key fees will be calculated for other key pollution generated under the EP Act.

• Given the intensity of the new power station is estimated at 0.464 tCO2-e/MWh, the proponent will not be required to offset any emissions in excess of the Benchmark-Emissions Baseline of .583 tCO2-e/MWh.

• PEG proposes to implement a Greenhouse

Gas Management Plan during development of

the Proposal, this plan can be found in

Appendix 2.

• PEG will adhere to the requirements outlined

in the National Greenhouse and Energy

Reporting Act, 2007 (NGER Act).

4. The principle of the conservation of biological diversity and ecological integrity

Conservation of biological diversity and ecological integrity should be a fundamental consideration.

The conservation of biological diversity and ecological integrity was a fundamental consideration in the assessment of this proposal. Clearing has been avoided and infrastructure sited away from ecologically significant areas.

5. The principle of waste minimisation

All reasonable and practicable measures should be taken to minimise the generation of waste and its discharge into the environment.

The efficiency of the proposed engines and integration of a battery for spinning reserve purposes, avoids significant quantities of air emissions.

Closed cooling systems minimise the production of waste water and design of the system ensures minimal production generation of waste hydrocarbon.




PEG’s approach to waste management, in order of priority is:

• avoid and reduce at source

• reuse and recycle

• treat and/or dispose.

4.2 Greenhouse gas

4.2.1 EPA objective

The environmental objective of the EPA’s Greenhouse Gas Emissions factor is: To reduce net

greenhouse gas emissions in order to minimise the risk of environmental harm associated with

climate change (EPA, 2020a).

4.2.2 Policy and Guidance

Instructions on how to prepare an Environmental Review Document (EPA, 2020c)

This guideline is relevant to all Environmental Factors and will only be discussed once in this

document. This EPA guideline provides a template for the structure of the Environmental

Review Document (ERD) and the minimum requirements for an ERD (including tables and

figures). It also provides guidance for preparing each section of the ERD and details the spatial

data requirements.

Statement of Environmental Principals, Factors and Objectives (EPA, 2020a)

This guideline is relevant to all Environmental Factors and will only be discussed once in this

document. This guideline communicates how the EPA undertake the following, during their

assessment process:

• considers the object and principles of the Environmental Protection Act, 1986

• uses environmental factors and objectives to organise and systemise

environmental impact assessment and reporting

• takes a holistic view of the environment and a proposal or scheme’s potential

impact on the environment

• considers significance when determining whether or not to assess a proposal or

scheme and recommend whether or not an assessed proposal or scheme may be

implemented

Environmental Factor Guideline - Greenhouse Gas Emissions (EPA 2020b)



This factor guideline communicates the environmental objective of the Greenhouse Gas

Emissions “to reduce net greenhouse gas emissions in order to minimise the risk of

environmental harm associated with climate change.” As well as communicating considerations

for EIA for Greenhouse Gas Emissions factor include, but are not necessarily limited to:

• application of the mitigation hierarchy to avoid, reduce and offset emissions

• the interim and long-term emissions reduction targets the proponent proposes to

achieve

• the adoption of best practice design, technology and management appropriate to

mitigate GHG emissions

• whether proposed mitigation is plausible, timely, achievable and is all that is

reasonable and practicable.

Technical Guidance - Mitigating Greenhouse Gas Emissions (EPA, 2019)

This document covers:

• Avoiding emissions through best practice design, benchmarking

• Continuous improvement to reduce emissions over the project life

• Offsets

• Reporting

National Greenhouse and Energy Reporting Act, 2007 (Commonwealth)

National framework for reporting and disseminating company information about greenhouse gas

emissions, energy production and energy consumption.

4.2.3 Receiving environment

The new power generation facility (PEG power station), will be located on L47/901, adjacent to

the existing, Fortescue owned and operated, Solomon power station at the Solomon Iron Ore

Mine. The location of the Proposal, in a local and regional context for greenhouse gas is shown

in Figures 4 and 5.

4.2.3.1 Surveys and studies

Greenhouse gas emissions contribute to a changing climate on a global scale. The effects of

the changing climate are predicted to be significant for Western Australia (EPA, 2020d).

Fortescue currently reports emissions in accordance with the requirements of NGER and NPI

for its operating sites. The reports are prepared internally, audited by an external party and

submitted to the relevant regulators. PEG will undertake the same reporting (NGER and NPI)

meeting the same high standards. Fortescue’s NGER reports can be found at the following



website http://www.cleanenergyregulator.gov.au/NGER/, PEG’s reports will be made available

on the same website when completed.

The maximum likely impact of this proposal in terms of greenhouse gas emissions will be

609,696 tCO2-e per annum. However, the net impact of this proposal will be that a greenhouse

gas reduction of 586,727 tCO2-e per annum is achieved, through a smaller and more efficient

power station (see Table 7 for details). additional emission intensity benefits are expected with

the integration of renewable generation and energy storage.

4.2.4 Assessment of impacts

4.2.4.1 Gaseous emissions to air

Annual greenhouse gas emissions from the PEG power station are estimated at 609,696 tCO2-

e. PEG hold the view that the Proposal will provide a net reduction in greenhouse gas

emissions to atmosphere compared to the construction and operation of the North Star power

station. Table 7 demonstrates how PEG replacing the North Star power station would reduce

total annual greenhouse gas emissions, and how future additions are calculated to provide

further reductions through displacement of fossil fuel combustion.

Table 7: Modelled emissions and emission reductions from the Proposal and associated infrastructure

Emission

Intensity

tCO2-e/MWh

Annual

Emissions

tCO2-e

Annual Reduction Compared to Approved scenario

tCO2-e

Modelled Annual benefits from PEG1

tCO2-e

Annual Net

benefit2

tCO2-e

North Star power station approved under MS 993

0.618 1,196,423 NA NA NA

Proposed PEG power station (gas only)

0.464 609,696 586,727 - -

Integration of Lambda and North Star Junction Solar Farms

- - - 64,627 185,075

Integration of 60MW Battery system for Spinning Reserve Services

- - - - 162,410

1This column illustrates modelled benefit to the PEG Gas fired emissions when PEG Gas fired generation is augmented by Solar

generation in a future scenario.

2Including other entities such as Solomon power station, but excluding reductions already counted in Annual Modelled reductions

from PEG

http://www.cleanenergyregulator.gov.au/NGER/



The calculations undertaken for Table 8 are based on likely scenarios, but are calculated in a

conservative way. Estimation techniques developed for NGER reporting were utilised where

applicable. Data collected at existing Fortescue operations was used to estimate the

greenhouse gas emissions where appropriate.

The already approved scenario was based on the procurement of GE LM6000 gas turbines in

combination with Solar Titan Turbines to construct a power station at North Star approved under

MS 993. Two LM6000s and four Solar Titan turbines are installed at Solomon power station,

and the specifications fit what was outlined, ~40MW gas turbines, in the original North Star PER

(Fortescue, 2013) with some of the difference between the original 120MW and the revised

221MW to be made up with Solar Titan units.

PEG has utilised data from the likely engine supplier. The PEG power station emissions were

calculated based on the highest likely dispatch of the power station, 150MW.

The net CO2-e benefit that the integration of a 60MW Battery system to provide Spinning

Reserve Services, is calculated on the assumption that one Solomon power station LM6000

would need to be continuously dispatched to provide this service. The minimum speed a

LM6000 unit could run at to provide this service would be 75%, so this figure (75%) was used in

the calculation.

4.2.4.2 Greenhouse gas emissions in a broader context

The Australian government publishes the National Greenhouse Gas Inventory as part of the

commitments made under the Kyoto Protocol. For the 2017 inventory year the Australian

greenhouse gas emissions were 530,840.90 kilotonnes (1,000 tonnes) of CO2-e within which

Western Australia’s contribution was 86,420.56 kilotonnes of CO2-e (Department of Industry,

Science, Energy and Resources, 2020). The annual maximum emission of greenhouse gases

estimated for the Proposal is 609.696 kilotonnes of CO2-e.

The estimated annual emissions are equivalent to 0.11% of the nation’s emissions and 0.7% of

Western Australia’s emissions. The GHG emission estimate results in an estimated emission

intensity of 0.464 tCO2-e per MWh (without integration of Solar generation or Energy Storage).

A summary of the estimated greenhouse gas emissions is provided in Table 8.

Table 8: Calculated emissions from the PEG power station

Source Quantity

Annual Power Generation (MWh) 1,314,000

Total Annual Greenhouse Gas Emission (tonnes of CO2-e) 609,696

Total Annual Greenhouse Gas Emission (kilotonnes of CO2-e) 609.696

Australia’s 2017 Greenhouse Gas inventory (kilotonnes) 530,840.90

% of Australia’s 2017 Greenhouse Gas inventory 0.115

Western Australia’s 2017 Greenhouse Gas inventory (kilotonnes of CO2-e) 86,420.56



% of Western Australia’s 2017 Greenhouse Gas inventory 0.705

Note: These calculations are before integration of a Battery System or Solar Generation.

However, the North Star power station would have had annual emissions estimated to be

equivalent to 0.225% of the nation’s emissions and 1.38% of Western Australia’s emissions.

The estimated GHG emission in the alternative scenario results in an estimate emission

intensity of 0.618 tCO2-e per MWh (without integration of Solar generation or Energy Storage),

these figures are detailed below in Table 9.

Table 9: Calculated emissions from the power station approved under MS993

Source Quantity

Annual Power Generation (MWh) 1,314,000

Total Annual Greenhouse Gas Emission (tonnes of CO2-e) 1,196,423




Western Australia’s 2017 Greenhouse Gas inventory (kilotonnes of CO2-e) 86,420.56


4.2.4.3 Cumulative impacts

PEG does not consider the Proposal’s estimated greenhouse gas emissions to significantly

increase the contribution of Western Australia’s emissions to the national greenhouse gas

inventory. In fact, when compared to the North Star power station, would provide a reduction

equivalent to around 0.679% of Western Australia’s total emissions (without including Solar or

Battery integration reductions). This is displayed in Table 10.

Table 10: Reduction in generation and emissions through construction and operation of the PEG1

Source Quantity

Reduction in Annual Fossil Fuel Power Generation (MWh) 621,960

Reduction Total Annual Greenhouse Gas Emission (tonnes of CO2-e) 586,727




Western Australia’s 2017 Greenhouse Gas inventor (kilotonnes of CO2-e) 86,420.56


1Compared to the calculated emissions from the North Star power station, and without integration of Solar or Battery at PEG.

4.2.5 Mitigation

PEG has applied the mitigation hierarchy to the Proposal in relation to greenhouse gas

emissions. Mitigation measures are summarised in Table 11.



Table 11: Application of the mitigation hierarchy through the Proposal

Category Mitigation

Avoidance The commencement of the Proposal avoids a calculated 586,727 tonnes of CO2-e emissions per annum compared to the operation of the power station approved under MS 993.

The Proposal avoids reliance on diesel fuel or the construction of an additional gas pipeline by siting at a location with an existing natural gas supply.

PEG has also avoided the procurement of Sulphur Hexafluoride (SF6) filled circuit breakers, because of the high warming potential that this gas has.

Future activities including the construction of Solar PV Generation and the integration of a battery system will each avoid significant quantities of greenhouse gas emissions.

Minimisation The proposal minimises the consumption of natural gas through the procurement of modern engines, innovative control system and through regular maintenance the engines and other infrastructure.

Management A greenhouse gas management plan will be adhered to by the proponent.

• PEG proposes to implement a Greenhouse Gas Management

Plan during development and implementation of the Proposal,

this plan can be found in Appendix 1.

• PEG will adhere to the requirements outlined in the National

Greenhouse and Energy Reporting Act, 2007 (NGER Act).

Research and modelling Modelling of emission reduction under different scenarios has been carried out for the operation of the PEG power station including with and without combinations of Solar Generation and a Battery System. All scenarios show significantly lower annual greenhouse gas emissions when compared to the operation of the North Star power station.

Offsets The Benchmark-Emissions Baseline will be supported by a Default Emissions Intensity for electricity generation (currently set at 0.583 tCO2-e/MWh, benchmarked by Australian Government to industry best-practice). GHG emissions from the PEG power station will be benchmarked against the Default Emissions Intensity. Given the intensity of the new power station is estimated at 0.464 tCO2-e/MWh, the proponent will not be required to offset any emissions in excess of the Benchmark-Emissions Baseline.

4.2.6 Predicted outcome

Under section 15 of the Environmental Protection Act 1986, the EPA has the objective to use its

best endeavours to protect the environment and to prevent, control and abate pollution and

environmental harm. PEG considers the Proposal is consistent with the EPA’s objective for the

Greenhouse Gas Emissions factor “to reduce net greenhouse gas emissions in order to

minimise the risk of environmental harm associated with climate change” (EPA, 2020) and that

the factor can be managed with the implementation of a site-specific Greenhouse Gas

management plan (Appendix 1), as the Proposal is considered to provide a net reduction in

greenhouse gas emissions compared to other development options (including those that are

already approved), and that modern technology and efficient engines are to be procured for the

Proposal. The estimated annual emissions are equivalent to 0.11% of the nation’s emissions

and 0.7% of Western Australia’s emissions.

5. OTHER ENVIRONMENTAL FACTORS OR MATTERS



5.1 Air quality

5.1.1 EPA objective

The environmental objective of the EPA’s Air Quality factor is: to maintain air quality and

minimise emissions so that environmental values are protected (EPA, 2020a).

5.1.2 Policy and guidance

The following policy and guidance is relevant to this factor:

• Statement of Environmental Principles, Factors and Objectives (EPA, 2020a)

• Environmental Factor Guideline: Air Quality (EPA, 2020d)

This guideline outlines how the EPA considers air quality in the environmental impact

assessment (EIA) process including:

• application of the mitigation hierarchy to avoid and minimise emissions, where

possible

• characterisation of potentially harmful emissions and the pathways by which they

may be released to air

• the application of technology appropriate to the potential environmental impacts

and risks

• the significance of the likely change to air quality as well as the environmental

values affected by those changes, in the context of existing and predicted

cumulative impacts

• whether proposed mitigation is technically and practically feasible

• whether siting of the proposal’s main emission sources takes into consideration

current and future sensitive land uses.

5.1.3 Receiving environment

An air quality assessment has been undertaken by SLR Consulting (2020; Appendix 2). This

assessment considered the air emissions resulting from the proposed 165 MW gas-fired PEG

power station in isolation, and cumulatively with the existing Solomon power station. Stack and

emission data for the proposed PEG power station engines were compiled based on the

supplier’s engine specifications data.

Ambient dust levels in the Pilbara region, are known to be elevated due to the semi-arid

landscape. Fugitive dust emissions from the Solomon Mine operations (and other mines in the

region) contributes to regional background particulate levels. The Fortescue ambient air quality



monitoring network was used to characterise the background particulate levels for PM10

between 2015 and 2019. The 2018 calendar year was used to derive a representative

background dataset. This annual average PM10 concentration during 2018 was above the

annual average ambient guideline value of 25 μg/m3 and included 30 days above the 24hr

average ambient guideline value of 50 μg/m3.

Dispersion modelling of NO2, SO2, PM10, PM2.5, CO and VOC (as formaldehyde, benzene,

toluene, ethylbenzene and xylene) emissions was performed using the CALPUFF dispersion

model. A 3-dimensional, 1-year meteorological data file was compiled using the WRF and

CALMET models for input in CALPUFF, incorporating observational data from the Fortescue

weather station located at Castle Camp. The modelling results showed that the maximum

ground level concentrations of NO2, SO2, CO and VOCs are all well below the relevant

assessment guideline values.

The nearest sensitive receptor to the PEG power station is Karijini National Park which is

located 8.3 km south of the proposal. There is relatively complex topography, including higher

elevations between the PEG power station and this receptor (Kendrick, 2002, cited in Appendix

2 page 38).

5.1.4 Assessment of impacts

Air emissions can affect both environmental receptors and human health if not managed

correctly. The main emissions from the PEG power station are emissions to air of nitrogen

oxide, carbon dioxide, sulphur dioxide and particulates (Table 12). These emissions have been

determined by the manufacturer and will be confirmed during commissioning.

Table 12. Maximum emission mass flow rates (per engine stack)

Emission Emission Rate (g/s)

75% Load 100% Load Start-up

NOx, Nitrogen oxides (Calculated as NO2) 1.5 2.0 4.0

CO, Carbon monoxide 4.4 5.8 11.6

SO2, Sulphur dioxide 0.17 0.22 0.44

PM, Particulate matter (as dry dust) 0.17 0.22 0.44

The emissions assessment indicates that emissions to air during commissioning and operations

will not exceed any applicable guideline values at receptor locations. Modelling indicates

pollutant concentrations will not exceed 25% of any relevant guidelines at receptors even under

worst case scenarios.

Construction activities associated with proposal that may cause dust emissions include:

• ground disturbance

• vehicle movement



The air emissions assessment indicates that particulate emissions from the proposed power

station will have a negligible impact on the annual average PM10 and PM2.5 in the region. The

assessment focussed on the potential incremental impacts of PM10 and PM2.5 emissions from

the PEG power station in the context of the existing background level due to the elevated

background concentrations in the region. This assessment found that the incremental annual

average particulate concentration predicted at the closest sensitive receptor to be less than

0.1µg/m3 in each of the modelled scenarios.

5.1.5 Mitigation

Fortescue has applied the mitigation hierarchy to the proposal in relation to air quality. Site

specific management measures include:

• Engineering design and procurements have considered energy efficiency,

greenhouse and other emissions in the selection of the reciprocating gas engine

technology to be used for the PEG power station

• The engines will be operated in line with manufacturer specifications to minimise

emissions.

• Restrict vehicle movements and speeds;

• Use water trucks for dust suppression on access tracks and high traffic areas.

5.1.6 Predicted outcome

PEG considers the Proposal is consistent with the EPA’s objective for the Air Quality factor to

maintain air quality and minimise emissions so that environmental values are protected (EPA,

2020a) and that the factor can be managed within the requirements of the EP Act and

regulations.

The results of the modelling found emissions to air during commissioning and operation of the

PEG power station “do not have potential for significant air quality impacts at the nearest

sensitive receptors and do not represent a constraint to the Project” from Particulate Matter,

Carbon Monoxide, Sulphur Dioxide or Oxides of Nitrogen. Modelling indicates pollutant

concentrations will not exceed 25% of any relevant guidelines at the closest sensitive receptor.

6. OFFSETS

Biodiversity and carbon offsets related to the Proposal are outlined below.

6.1 Biodiversity offsets

Environmental offsets are required in order to protect and conserve environmental and

biodiversity values for present and future generations. The WA Environmental Offsets Policy



(Government of Western Australia, 2011) and WA Environmental Offsets Guidelines

(Government of Western Australia, 2014) provide guidance on the approach needed to

determine biodiversity offset requirements for proposals. Application of these guidelines ensure

that consistent and accountable decisions are made under the Environmental Protection Act

1986.

The EPBC Act Environmental Offsets Policy (Department of Sustainability, Environment, Water,

Population and Communities, 2012) outlines the Commonwealth government’s approach to the

use of offsets under the EPBC Act. The Policy defines offsets as ‘measures that compensate

the residual adverse impacts of an action on the environment’.

The PEG power station will be constructed within in area that has been assessed and cleared

as part of the Solomon mining operation activities (MS 1062). No additional clearing of native

vegetation is required as part of this referral, as such no residual adverse impacts on the

environment from clearing and no further consideration has been given to biodiversity offsets.

6.2 Carbon offsets

The PEG power station will trigger the requirements of the National Greenhouse and Energy

Reporting (Safeguard Mechanism) Rule 2015 (Safeguard Mechanism) during the first year of

operation. The Safeguard Mechanism is triggered when a responsible emitter produces greater

than 100,000 tCO2-e during a financial year.

With forecast GHG emissions greater than 100,000 tCO2-e during a financial year, Fortescue

will apply for a Benchmark-Emissions Baseline under the Safeguard Mechanism based on the

following production variable, defined in Schedule 2 of the Safeguard Mechanism: Electricity

generation

The Benchmark-Emissions Baseline will be supported by a Default Emissions Intensity for

electricity generation (currently set at 0.583 tCO2-e/MWh, benchmarked by Australian

Government to industry best-practice). GHG emissions from the PEG power station will be

benchmarked against the Default Emissions Intensity. Given the intensity of the new power

station is estimated at 0.464 tCO2-e/MWh, the proponent will not be required to offset any

emissions in excess of the Benchmark-Emissions Baseline.

7. MATTERS OF NATIONAL ENVIRONMENTAL SIGNIFICANCE

The EPBC Act is administered by the DAWE and provides a legal framework for the protection

and management of nationally and internationally important flora, fauna, ecological communities

and heritage places, which are referred to as MNES. Specifically, the EPBC Act protects the

following MNES:

• World heritage places

• National heritage places



• Wetlands of international importance

• Listed threatened species and ecological communities

• Migratory species

• Commonwealth marine areas

• The Great Barrier Reef Marine Park

• Nuclear actions

• A water resource, in relation to coal seam gas development and large coal mining

development.

Pursuant to the EPBC Act, any proposed action that has or is likely to have a significant impact

on a MNES requires approval from the Commonwealth Minister for the Environment.

A self-assessment undertaken by Fortescue of the significance of the impacts of the PEG power

station in reference to the DoEE Matters of Environmental Significance: Significant Impact

Guidelines (2013) and determined that the PEG power station will not have a significant impact

on any matter of National Environmental Significance (NES).

8. HOLISTIC IMPACT ASSESSMENT

This referral provides an assessment of the potential environmental impacts associated with the

Proposal and the management strategies independently. In this section, Table 13 provides an

assessment that has been made regarding the themes of Land, Air, People, Water and Sea and

the interaction between the environmental factors.



Table 13: Holistic Impact Assessment

Theme Environmental Factor

Impact Predicted outcomes Management and Mitigation EP Act Principles

Se

a

Benthic communities and habitat

Impacts not considered as the Proposal is not coastal.

N/A N/A N/A

Coastal processes Impacts not considered as the Proposal is not coastal.

N/A N/A N/A

Marine Environmental Quality

Impacts not considered as the Proposal is not coastal.

N/A N/A N/A

Marine Fauna Impacts not considered as the Proposal is not coastal.

N/A N/A N/A

La

nd

Flora and Vegetation No clearing of vegetation is required for this Proposal.

N/A N/A N/A

Landforms Physical landforms will not be altered as a result of this Proposal.

N/A N/A N/A

Subterranean Fauna The Proposal is not considered to have an impact on subterranean fauna because there will be no significant ground excavations associated with the development.

N/A N/A N/A

Terrestrial Environmental Quality

Localised disturbance within an already disturbed development envelope. No significant excavations associated with the Proposal.

Proposal designed to minimise risk of land and soil contamination with minor quantities of hydrocarbons stored on site and oily water collection, storage and treatment infrastructure installed and maintained.

N/A N/A N/A

Terrestrial Fauna No clearing of terrestrial fauna habitat is associated with this Proposal.

N/A N/A N/A





Wa

ter

Inland waters Surface and groundwater hydrological

processes will not be altered by this

Proposal. Operational water use will be

7,000L/week under maximum

scenarios which will be supplied from

the existing Solomon mine process

water allocation.

N/A N/A N/A

Air

Air Quality Emissions of oxides of nitrogen, oxides of sulphur, carbon monoxide and particulates. Maximum concentration emission rates during normal operation, per engine stack are estimated at:

• NOx: 2.0 g/s

• CO: 5.8 g/s

• SO2: 0.22 g/s

• PM: 0.22 g/s

PEG considers the Proposal is consistent with the EPA’s objective for the Air Quality factor and that the factor can be managed within the requirements of the EP Act and regulations.

The results of the modelling found emissions to air during commissioning and operation of the PEG power station “do not have potential for significant air quality impacts at the nearest sensitive receptors and do not represent a constraint to the Project” from Particulate Matter (PM) Carbon Monoxide (CO), Sulphur Dioxide (SO2) or Oxides of Nitrogen (NOx).

Incremental annual average particulate concentration predicted at the closest sensitive receptor to be less than 0.1µg/m3 in each of the modelled scenarios.

Concentrations of Particulate Matter (PM) Carbon Monoxide (CO), Sulphur Dioxide (SO2) or Oxides of Nitrogen (NOx) will not exceed 25% of the relevant guideline at the closest sensitive receptor.

Non- greenhouse gas emissions to air will be managed under part V of the EP act, as well as being reported through NPI.


Air emission impact assessment modelling has assumed worst case scenarios, and has considered worst case scenarios from Solomon power station in cumulative modelling.


Emissions to air are reduced due to lower emission intensity, higher efficiency, and smaller capacity of power station compared to the operation of the North Star power station.


Emissions to air will be managed under part V of the EP act, annual fees will be calculated and paid where applicable.


Modelling has indicated no breach of guideline levels as sensitive receptors resulting from air emissions.



Greenhouse Gas Emissions

The Proposal will result in 609,696 tCO2-e per annum and emission intensity of 0.464 tCO2-e/MWh.

Under section 15 of the Environmental Protection Act 1986 (EP Act), the EPA has the objective to use its best endeavours to protect the environment and to prevent, control and abate pollution and environmental harm. PEG considers the Proposal is consistent with the EPA’s objective for the Greenhouse Gas Emissions factor “to reduce net greenhouse gas emissions in order to minimise the risk of environmental harm associated with climate change” (EPA, 2020) and that the factor can be managed by a greenhouse gas management plan, as the Proposal is considered to provide a net reduction in greenhouse gas emissions compared to other development options (including those that are already approved), and that modern technology and efficient engines are to be procured for the Proposal. The estimated annual emissions are equivalent to 0.11% of the nation’s emissions and 0.7% of Western Australia’s emissions.

The commencement of the Proposal avoids a modelled 586,727 tonnes of CO2-e emissions per annum compared to the operation of the North Star power station.

The Proposal avoids reliance on diesel fuel or the construction of an additional gas pipeline by siting at a location with an existing natural gas supply.

PEG will avoid the procurement of Sulphur Hexafluoride (SF6) filled circuit breakers, because of the high warming potential that this gas has.

The proposal minimises the consumption of natural gas through the procurement of modern engines, innovative control system and through regular maintenance the engines and other infrastructure.

A greenhouse gas management plan will be adhered to by the proponent.

• PEG proposes to implement a Greenhouse Gas Management Plan during development of the Proposal, this plan can be found in Appendix 1.

• PEG will adhere to the requirements outlined in the National Greenhouse and Energy Reporting Act, 2007 (NGER Act).


Greenhouse gas modelling has assumed worst case scenarios.




Given the intensity of the new power station is estimated at 0.464 tCO2-e/MWh, the proponent will not be required to offset any emissions in excess of the Benchmark-Emissions Baseline.


PEG will minimise emissions as far as practicable to support this principle.







Pe

op

le

Social Surroundings The remote location of the Proposal and 14km separation distance between the Dally camp and the Proposal ensures that there will be no adverse impacts on social surrounds due to air, noise or amenity.

The nearest heritage place is ~1.4km from the proposed power station and will not be impacted by the Proposal.

The closest conservation reserve is Karijini National Park, located 8.3 km south of the Proposal. Modelling in the air quality impact assessment (Appendix 2) indicated pollutant concentrations will not exceed 25% of any relevant guidelines at receptors even under worst case scenarios.

Mt Florance pastoral lease is an operating cattle station which includes a homestead located ~40km from the proposed power station and is not expected to experience any adverse impacts on social surrounds due to air, noise or amenity.

N/A N/A N/A

Human Health There are no communities near the Proposal and no sources of radiation for emissions to adversely impact human health.

Asbestos monitoring undertaken for the Solomon Iron Ore Project – Sustaining Production identified the decommissioned asbestos mine at Wittenoom Gorge was identified as potential source of contamination where water and wind erosion has potentially transported fibres to the Solomon Mine Site. Asbestos fibres were below the detection limit (0.01 fibres/mL) within the Solomon Mine Development Envelope in both the soil and air pump samples (Heggies, 2010 cited in Fortescue, 2015).

Human health is not expected to be significantly impacted as result of the proposed activities.

N/A N/A N/A



8.1 EPA Objectives

Terrestrial Environmental Quality

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

The holistic assessment has demonstrated that impacts to terrestrial environmental quality are

localised with no significant excavations associated with the development of the Proposal. The

Proposal will be designed to minimise the risk of land and soil contamination with minor

quantities of hydrocarbons stored on site and oily water collection, storage and treatment

infrastructure installed and maintained. The quality of land and soils can be maintained so that

the environmental values are protected.

The Proposal can be implemented to meet the EPA’s objective for this factor.

Greenhouse Gas

To reduce net greenhouse gas emissions in order to minimise the risk of environmental harm

associated with climate change.”

The Proposal is considered to provide a net reduction in greenhouse gas emissions when

compared to the North Star power station. The proponent will ensure the procurement of

extremely efficient engines to minimise greenhouse gas emissions and greenhouse gas

emission intensity. The 14 x 12MW Gas Reciprocating Engines proposed for the PEG Station

have been chosen for their advanced technology, are highly efficient with very low emissions

and heat rates. Greenhouse gas emissions will be reduced to as low as practicable, reporting of

greenhouse gas emissions is regulated under Federal legislation.

The Proposal can be implemented to meet the EPA’s objectives for this factor.

Air Quality

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

The air emission impact assessment carried out (Appendix 2), which included worst case

scenarios has demonstrated that no guidelines levels will be exceeded due to emissions from

the PEG power station, even in combination with the existing Solomon power station. Fortescue

considers that air quality can be managed under Part V of the EP Act. The Proposal can be

implemented to meet the EPA’s objectives for this factor

Social Surroundings

To protect social surroundings from significant harm.



The proposal will not impact to population centres, recreation or tourism values, or non-

Aboriginal heritage. PEG is committed to minimising impacts on Aboriginal heritage places in all

of its Proposal areas which includes wherever possible, avoidance of impacts on Aboriginal

heritage places. PEG will continue to work with the traditional owners, heritage professionals

and the regulatory body to mitigate and minimise the impact by undertaking additional research,

investigate recording and analysis and salvage and repatriation of cultural material.

The Proposal can be implemented to meet the EPA’s objectives for this factor.



REFERENCES

Baker Hughes (2020) LM6000, <https://www.bhge.com/lm6000> retrieved May 2020

Beard (1975) Vegetation Survey of Western Australia: Sheet 5 Pilbara. Perth: University of

Western Australia Press.

Bureau of Meteorology (BoM) (2020) Climate Data Online. Retrieved from Bureau of

Meteorology: http://www.bom.gov.au/climate/data/. Accessed 20 February 2020.

Commonwealth of Australia (2014) Celebrating Australia’s wetlands – A showcase of Australian

Ramsar sites (Department of the Environment)

Department of Industry, Science, Energy and Resources (2020) National Greenhouse Gas

Inventory, retrieved from < https://ageis.climatechange.gov.au/> May 2020

Department of Sustainability, Environment, Water, Population and Communities, (2012)

Environment Protection and Biodiversity Conservation Act 1999 Environmental Offsets Policy

Ecologia Environment (2014) Solomon Hub - Flora and Vegetation Assessment. Perth:

Unpublished Report for Fortescue Metals Group Ltd

EPA (2020a) Statement of Environmental Principles, Factors and Objectives. Western Australia:

Environmental Protection Authority (EPA)

EPA (2020b) Environmental Factor Guideline – Greenhouse Gas Emissions Western Australia:

Environmental Protection Authority (EPA).

EPA (2020c) Instructions on how to prepare an Environmental Review Document. Perth:

Environmental Protection Authority.

EPA (2020d) Environmental Factor Guideline: Air Quality. Environmental Protection Authority.

EPA (2019) Technical Guidance Mitigating Greenhouse Gas Emissions Western Australia:

Environmental Protection Authority (EPA).

Fortescue Metals Group (Fortescue) (2013) North Star Magnetite Project, Public Environmental

Review <

https://epa.wa.gov.au/sites/default/files/PER_documentation/NorthStarPER_20130816b.pdf>

Fortescue Metals Group (Fortescue) (2018) Eliwana Iron Ore Mine Project Public Environmental

Review

<http://www.epa.wa.gov.au/sites/default/files/PER_documentation2/Eliwana%20Iron%20Ore%2

0Mine%20FINAL%20Environmental%20Review%20Document.pdf>

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

https://ageis.climatechange.gov.au/

https://epa.wa.gov.au/sites/default/files/PER_documentation/NorthStarPER_20130816b.pdf



Fortescue Metals Group (Fortescue) (2015) Solomon Iron Ore Project – Sustaining Production

Public Environmental Review. Fortescue Metals Group Ltd.

Government of Western Australia (2014) WA Environmental Offsets Guidelines

Government of Western Australia (2011) WA ENVIRONMENTAL OFFSETS POLICY

Kendrick, P. (2002) Fortescue Plains Subregion in CALM 2002. Bioregional Summary of the

2002 Biodiversity Audit for Western Australia. Department of Conservation and Land

Management.

Kovács, Tamás & Wuhu, Feng & Totterdill, Anna & Plane, John & Dhomse, Sandip & Gómez-

Martín, Juan & Stiller, Gabriele & Haenel, Florian & Smith, Chris & Forster, Piers & García,

Rolando & Marsh, Daniel & Chipperfield, Martyn (2016) Determination of the atmospheric

lifetime and global warming potential of sulphur hexafluoride using a three-dimensional model.

Atmospheric Chemistry and Physics Discussions. 17. 1-32. 10.5194/acp-2016-671.

MWH (2010) Hydrogeological Assessment of the Solomon Project. Prepared for Fortescue

Metals Group Pty Ltd.

Tille, P J. (2006) Soil-landscapes of Western Australia's rangelands and arid interior.

Department of Agriculture and Food, Western Australia.

Van Vreeswyk, A. M., Payne, A. L., Leighton, K. A., & Hennig, P. (2004) An Inventory and

Condition Survey of the Pilbara Region, Western Australia. Department of Agriculture,

Government of Western Australia.

Figure 5: Regional and local context



Figure 6: Location



Figure 7: Proposed site layout



Figure 8: Vegetation and flora receiving environment



Figure 9: Air quality receiving environment



Appendix 1: Greenhouse Gas Management Plan



Appendix 2: Air Emissions Impact Assessment

section 38 referral supporting document · 2020. 6. 2. · section 38 referral supporting document...

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