HIsmelt - Rio Tinto
Rio Tinto Iron Ore
HIsmelt Kwinana Lease
Final Closure Plan
22 March 2012
Document: RTIO-HSE-0135290
Mineral Field Number: 70
Contact Details:
Managing Director – HIsmelt
37 Belmont Avenue,
Belmont, WA, 6984
Corporate closure planning statement
The Rio Tinto iron ore group considers closure planning to be an integral part of its business. The process of preparing for closure begins in the early stages of project development, and continues throughout the life of the mine.
A team of in-house rehabilitation and closure planning specialists has been established to manage this aspect of our operations. A Rehabilitation and Closure Working Group has been established to facilitate integration of closure planning into the broader mine planning framework, and to oversee the research and improvement projects recommended in each closure study. In this way, RT iron ore aims to continually improve both its understanding of closure risks, and the strategies employed to mitigate them.
This report documents the current closure knowledge base for the HIsmelt Kwinana site.
It outlines the objectives that need to be met at closure, the strategies and plans to be employed to achieve them, and provides the criteria that will be used to assess closure success.
I hereby certify that to the best of my knowledge, the information within this Final Closure
Plan is true and correct and addresses relevant requirements of the Guidelines for
Preparing Mine Closure Plans approved by the Director General of Mines.
Allan Jackson
General Manager, Climate Change
Water and Environment
Denise Goldsworthy
Managing Director - HIsmelt ii
DMP/OEPA Guidelines Checklist
Q Report Checklist Y/N Page Comments
1 Has the checklist been endorsed by a senior representative within the operating company?
Y
2-5 Questions relevant to DMP administration of closure plans
-
-
6 Does the project summary include land ownership details, location of the project, comprehensive site plans and background information on the history and status of the project?
Y 10-16
Report submitted to EPA to support project assessment/compliance
7 Has a consolidated summary or register of closure obligations and commitments been included?
Y 17-25
8 Has information relevant to mine closure been collected for each domain or feature?
Y 68 Further information available in
Detailed Study Report (Onyx, Nov
2011)
9 Has a gap analysis been conducted to determine if further information is required in relation to closure of each domain or feature?
Y 69-70 Further information available in
Detailed Study Report (Onyx, Nov
2011)
10 Have all stakeholders involved in closure been identified?
Y 52-53
11 Has a summary or register of stakeholder consultation been provided, with details as to who has been consulted and the outcomes?
Y 54-56
12a Does the report include agreed post-mining land use? Y 57-58
12b Does the report include closure objectives? Y 59-63
12c Does the report include a conceptual landform design diagram?
72-78 No diagram provided as this is applicable to mine closure, however descriptive information has been provided
13 Does the report identify all potential (or pre-existing) environmental legacies which may restrict the post mining land use (including contaminated sites)?
Y 94-95 iii
Q Report Checklist Y/N Page Comments
14 Does the report identify all (known) key issues impacting mine closure objectives and outcomes?
15 Does the report include proposed management or mitigation options to deal with these issues?
Y 99-103
Y 95-98 Further information available in
Detailed Study Report (Onyx, Nov
2011)
16 Have the process, methodology and rationale been provided to justify identification and management of the issues?
Y 105Further information available in
108 Detailed Study Report (Onyx, Nov
2011)
17 Does the report include an appropriate set of specific completion criteria and/or closure performance indicators?
Y 99-103 Rehabilitation success criteria have been developed for progressive rehabilitation to be conducted within the next five years of operation (i.e. prior to the next closure study update).
However; completion criteria will be developed and agreed as the site approaches closure. A discussion of the RT iron ore approach to the development of completion criteria is provided on page 94
18 Does the report include costing methodology, assumptions and financial provision to resource closure implementation and monitoring?
Y 104A closure cost estimate has been
105 prepared as a component of this study, and is referenced in this report.
Costing methodology has been summarised in this report.
19 Does the report include a process for regular review of the financial provision?
Y 107
20 Does the report include a summary of closure implementation strategies and activities for the proposed operations or for the whole site?
Y 91-93 Strategies and plans will be reviewed and updated throughout the life of the mine.
21 Does the report include a closure work program for each domain or feature?
Detailed implementation plans will be developed as the site approaches closure.
22 Have site layout plans been provided to clearly show each type of disturbance?
Y App B
23 Does the report contain a schedule of research?
Y 110 iv
Q Report Checklist Y/N Page Comments
24 Does the report contain a schedule of progressive rehabilitation activities?
Y 80-82 The report provides a conceptual indication of when various domains may become available for progressive rehabilitation.
25 Does the report include details of how unexpected closure and care and maintenance will be handled?
N/A The site remains in a current state of care and maintenance and preparing for closure
26 Does the report contain a schedule of decommissioning activities?
Y 81-82
27 Does the report contain a schedule of closure performance monitoring and maintenance activities?
Y 116-
117
28 Does the report contain a framework, including methodology, quality control and remedial strategy for closure performance monitoring including postclosure monitoring and maintenance?
Y 117 Additional detailed monitoring and maintenance plans will be developed as the site approaches closure.
29 Does the mine closure plan contain a description of management strategies including systems and processes for the retention of mine records?
Y 120 v
DEC
DIA
DITR
DMP
DOM
DoW
DRF
DSD
DSI
EAP
EP Act
EMP
EPA
EPBC Act
Table of acronyms (General & HIsmelt specific)
ACM
AHD
ALWA
AMD
ARI
AWT
ASU
BHP
BIF
BWT
CER
CS Act
CSIRO
EIL
FPA
Asbestos Containing Material
Australian Height Datum
Air Liquide Western Australia
Acid and Metaliferrous Drainage
Average Recurrence Interval
Above Water Table
Air Separation Unit
Broken Hill Proprietary Ltd
Banded Iron Formations
Below Water Table
Consultative Environmental Review
Contaminated Sites Act 2003
Commonwealth Scientific and Industrial Research
Organisation
Department of Environment and Conservation
Department of Indigenous Affairs
Department of Industry, Tourism and Resources
1
Department of Mines and Petroleum
Dolomite
Department of Water
Declared Rare Flora
Department of State Development
Detailed Site Investigation
Employee Assistance Program
Environmental Protection Act
Environmental Management Plan
Environmental Protection Authority
Environment Protection and Biodiversity Conservation
Act 1999
Ecological Investigation Level
Fremantle Port Authority
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
1
Note that the DITR was abolished as a result of Commonwealth departmental restructuring in 2007. vi
GARD
Guide
HIL
HIOps
HKJV
HRDF
ILUA
IOCI
IOHR State
Agreement
JV
KBB1
KIA
KWRP
Lease
LFA
MCA
Global Acid Rock Drainage Guide; available at www.gardguide.com/index.php/Main_Page
Health Investigation Level
HIsmelt Operations Pty Ltd
HIsmelt Kwinana Joint Venture
HIsmelt Research and Development Facility
HIsmelt
HIsmelt
HIsmelt
HIsmelt
Indigenous Land Use Agreement
Indian Ocean Climate Institute
Iron Ore (Hamersley Range) State Agreement Act 1963
HIsmelt
Joint Venture
Fremantle Ports Kwinana Bulk Berth No.1
Kwinana Industrial Area
Kwinana Water Reclamation Plant
Kwinana Hismelt Lease, including subleases
Land Function Analysis
Minerals Council of Australia
Mtpa
MUI
NAF
OEPA
PAF
PAH
PER
RDL
Million tonnes per Annum
Multi-User Infrastructure
Non Acid Forming
Office of the Environmental Protection Authority
Potential Acid Forming
Polycyclic Aromatic Hydrocarbon
Public Environmental Review
Department of Regional Development
RPS RPS Group
RT iron ore Rio Tinto
RTIO
SCARD
SEWPaC
Rio Tinto Iron Ore group
Spontaneous Combustion and Acid Rock Drainage
Department of Sustainability, Environment, Water,
Population and Communities
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
HIsmelt
SRE
TDS
TEC
TPH
WALA
Short Range Endemic
Total Dissolved Solids
Threatened Ecological Community
Total Petroleum Hydrocarbon
Western Australia Land Authority
HIsmelt
HIsmelt vii
Contents page
Corporate closure planning statement
Purpose and scope of this final closure plan
Past and future closure planning for the site
Lease Applicable to the Plan Area
Closure obligations and commitments
Important elements of the general legislative framework
Guidelines for Preparing Mine Closure Plans (DMP/EPA)
Legal obligations relating to specific aspects
Legal obligations relating to decommissioning
Kwinana Joint Venture Agreement
Industrial Gases Supply Agreement
viii
Sublease of Merchant Mill Building
Legal obligations relating to rehabilitation
Legal obligations relating to decontamination
Legal obligations relating to Traditional Owners
Legal obligations relating to local communities
Corporate closure planning requirements
Collection and analysis of closure data
Predicted climate change projections
Ground and surface water interactions
Environmental and social values of water at the site
The effect of HIsmelt operations on water systems
Baseline vegetation communities
Pre-existing Contamination (Baseline)
ix
Non-Indigenous cultural heritage values
Synergies with the Kwinana Industrial Area
Post-Lease land use and closure objectives
Description of objectives that apply to all RT iron ore sites
Safe, stable and compatible landforms
Appropriate environmental outcomes
Cost effective closure implementation
Description of HIsmelt specific objectives
The site to be left as an industrial block suitable for next use
No change in contaminated sites status
Closure outcomes are effectively communicated
Assessment of closure options for the site
The role of sustainability assessment in closure planning
Option 1: Sale of Plant Insitu
Option 2: Transferral of Plant and Technology Offshore
Option 3: Selective sale of plant
Outcomes of the sustainability assessment
Assessment of economic factors
Assessment of environmental factors
Consolidation of economic, environmental and social factors
Other possible sustainability benefits
Identification and management of closure issues
x
Closure implementation: final landform strategy
Process for selecting a final landform configuration
Strategies for the remediation of specific domains
33 Proposed additional landform studies
General rehabilitation management strategies
Progressive rehabilitation / remediation
Revegetation and surface stabilisation plans
General rehabilitation methods
Strategies to achieve biodiversity objectives
Achieving appropriate environmental outcomes
Avoiding harm to habitat and the native ecology
Recycled water management strategies
Strategies for managing ground water quality
Strategies to achieve water-related objectives
Strategies for closure aspects
Strategies for the management of closure aspects
Management of Health, Safety and Environment (HS&E) Aspects
Development of completion criteria
Process for developing criteria
Lease specific completion criteria
Financial provision for closure
Principles of RT iron ore closure cost estimation
Estimate Method and Assumptions
xi
Unexpected closure and temporary closure
Health and Safety Management Plan
Closure monitoring and maintenance
Management of information and data
Management of information and data
xii
List of figures
Figure 2 Mean Monthly - Temperature, Rainfall and Evaporation .................................... 27
List of tables
Table 1 - Summary of Climatic Data for BP’s Kwinana Refinery from 1955 to 2001 ........ 26
Table 14 Expected components of the closure monitoring program ............................. 117
xiii
List of Appendicies
APPENDIX A – DOCUMENT REFERENCE
APPENDIX C - ENVIRONMENTAL MANAGEMENT PLAN
RPS Contaminated Sites Report
RPS Slag Geochemical Investigation
ATC Slag Geotechnical Investigation
xiv
Purpose and scope of this final closure plan
This report documents the outcomes of a closure plan conducted by Rio Tinto’s iron ore group (RT iron ore) as the manager for the Kwinana HIsmelt Lease.
1. Final Closure Plan Purpose
The report has been prepared with the following objectives in mind:
Specific compliance drivers (e.g. compliance with Ministerial Statement 610);
Specific approval drivers (e.g. support for approval of final closure);
To meet key Government expectations, as outlined in the Guidelines for Preparing
Mine Closure Plans
2
;
Compliance with the Rio Tinto corporate Closure Standard
3
;
Compliance with the Rio Tinto corporate Closure Planning Statement
Early identification of likely site-specific closure issues;
Documentation of closure objectives for the site;
Early development of strategies to meet these objectives;
Assessment of risks associated with proposed closure objectives and strategies;
Identification of actions that should be conducted during site demolition or operation to mitigate these risks, and enable efficient and effective closure ;
Estimation of costs associated with closure, developed to an intended accuracy of
+10% /-15% and
Development of a multi-disciplinary information resource.
2
Department of Mines & Petroleum and Office of the Environmental Protection Authority, Guidelines for
Preparing Mine Closure Plans, June 2011, http://www.dmp.wa.gov.au/documents/Mine_Closure(2).pdf
3
Rio Tinto, Rio Tinto Closure Standard , RTIO-HSE-0020698
2
2. Final Closure Plan outline
This document is divided into several broad sections, as follows:
A corporate closure planning statement and report endorsement ;
A statement of the scope and purpose of this closure plan;
A project overview that establishes the context of the mining / Lease operation within the broader landscape;
A register of closure obligations and commitments relevant to the project;
An environmental knowledge base that describes the current understanding of environmental and technical issues that may be relevant to closure of the site;
A social knowledge base that describes the current understanding of social issues that may be relevant to closure of the site;
A communication register to summarise the general outcomes of stakeholder consultation that has occurred to date that is relevant to closure of the site;
Identification of a post-lease land use and closure objectives that describe the outcomes to be achieved by closure of the site;
Identification of key closure issues and risks and how they can be managed;
A description of completion criteria and that have been agreed with the land owner and will be employed to measure successful implementation of closure;
A final landform strategy that outlines the proposed final landform configuration, and documents actions proposed to achieve it;
A biodiversity review that documents the actions to be taken to minimise biodiversity impacts;
A heritage management review that documents the actions to be taken to preserve cultural heritage values when relevant;
A decommissioning strategy that documents how infrastructure will be removed from the site;
A decontamination strategy that documents how areas of contamination will be managed at closure;
An information management strategy that documents how records will be managed prior to, during and subsequent to closure;
A communication strategy that documents how stakeholders will be involved during closure planning and implementation;
A post-closure management strategy that documents how performance against closure objectives will be measured;
A summary of actions proposed to improve closure outcomes; and
The process used to develop a closure cost estimate .
3
3. What is a closure plan?
Rio Tinto considers that planning for closure of a site is a critical business process that demonstrates a commitment to sustainable development. Closure planning involves the development of strategies to avoid or mitigate potential social and environmental impacts associated with site closure, to an extent that is fiscally appropriate.
Closure plans provide the framework for planning and ultimately implementing the closure of Rio Tinto mine sites and are regularly updated to account for changes such as:
Amendments to the site or mine plan;
Improvement of the site closure knowledge base (e.g. through the implementation of research actions); and
Evolving stakeholder expectations.
The detail increases as the site knowledge base develops.
One output of the plan is a closure cost estimate, prepared to an accuracy that increases as the site approaches closure. This leads to the establishment of a closure provision for the site, ensuring that funds will be available to close the site effectively. This report outlines the process that has been used to develop the cost estimate, with the estimate itself contained in a separate referenced report due to its commercial sensitivity.
When the site moves to within five years of scheduled closure, a final closure (or decommissioning) plan is prepared. The final closure plan builds upon strategies developed in earlier studies and details how they are to be implemented.
4
4. Past and future closure planning for the site
Closure plans are reviewed on a regular basis in accordance with both internal and external planning obligations
4
.
A previous Closure plan for the HIsmelt site was conducted in 2006 and reported in May
2007. This was the first closure plan for the site.
As this report is the Final Closure Plan there will not be any further studies conducted prior to scheduled closure. This detailed plan allows for implementation of the closure strategies that have been developed for the site. Completion criteria have been finalised and endorsed by stakeholders, and included in this Final Closure Plan.
4
The internal Rio Tinto Closure Standard requires closure plans to be formally reviewed on a 5-yearly basis,
5
5. Inclusions and exclusions
A site description and site context is provided in Section 7 of this document.
The scope of this closure plan includes definition and specification of the site closure obligations, completion criteria, methods and plans necessary to:
Relinquish the HIsmelt Lease (“the Lease”, see further definition in section 7) including any contained sub-leases to the Land Owner (West Australian Land
Authority – WALA)
Removal of all fixtures and infrastructure introduced to the Lease by Rio Tinto, its agents and its joint venture partners
Remediate the land occupied by the Lease to its baseline state (refer section 12 for definition of baseline)
Comply with all obligated environmental requirements
Comply with Rio Tinto corporate and Joint Venture requirements for mine and Lease closure
The scope of this closure plan excludes:
Planning and Works to do with the removal of fixtures and infrastructure that is a legacy from previous Lease tenants and the removal of contamination that may have also been introduced to the Lease by any previous tenants
The remediation of land to its native or virgin state but to allow return of the Lease to its industrial use classification.
Past and future closure planning for the site
The Rio Tinto Closure Standard requires closure plans for each site to be reviewed every five years. Plans will:
Incorporate improvements that have been made to the closure knowledge base in the course of the site development, and through the implementation of research projects;
Review closure objectives and indicative completion criteria to ensure they remain relevant and consistent with stakeholder expectations;
Incorporate management strategies for various aspects of closure, prepared to an increasing degree of detail relevant to the stage of operation; and
Update the closure cost estimate to an increasing level of accuracy as strategies are progressively developed, and underlying assumptions are validated.
The first Closure Plan was prepared in 2006 by SKM who undertook a preliminary closure plan for the site. This document, SKM – Preliminary Closure Planning Study (2006) , had primarily an environmental focus as this was the prevailing area of concern for control at the time.
A Decommissioning Plan is normally prepared approximately five years prior to the scheduled closure, however in this situation the Joint Venture partners requested that the
5 yearly update of the Closure Plan be to the accuracy consistent with a decommissioning plan, and is reported here in the Final Closure Plan.
6
In early 2011 Onyx Projects continued with the closure plan process by capturing the criteria and Lease data and analysing this to form plans, schedules and costs which were necessary to align previous studies and research to the Rio Tinto Closure Standard. The
Rio Tinto Closure Standard requires a two stepped approach by first completing an Order of Magnitude study and then from this developing a Detailed Closure (or
Decommissioning) plan. The associated plan reports are referenced in Appendix A.
Order of Magnitude Phase
Definition / Knowledge Base
Complete
Removal
Concepts / Closure Strategy
Partial Removal / Partial
Recovery
Maximum Recovery
(Wholesale Sale)
Engineering / Technical Study
Financial Study / Estimate +/- 30%
Detailed (Feasibility) Phase
Developed Knowledge Base
Chosen Closure Strategy
Closure Management Plans
Deconstruction Estimate +10%,-15%
7
Project overview
This section provides a description of the site, and provides a context for the operations within the broader landscape.
8
6.
6.1
Site context
Location
The HIsmelt Lease is located in Kwinana, Western Australia at the Kwinana Industrial
Area approximately 40 kms south of the Perth CBD and on the coast (Figure 2). The
Lease is located at the southern end of Leath Road.
6.2
Figure 1 Location Plan
Reference to drawing DS-028 in Appendix B illustrates the HIsmelt Lease in the context of its situation in the adjacent Kwinana local industry.
Land use
The land is government owned by the West Australian Land Authority (WALA) and is managed by its vicarious entity Land Corp. Assets located on the Head (HIsmelt) Lease are the responsibility of Rio Tinto, with assets on the Sub-leases being the responsibility of the HIsmelt Kwinana Joint Venture (HKJV) partners and Wesfarmers / Air Liquide JV respectively. Refer section 22 for details on the key stakeholders.
The HIsmelt lease site had originally been utilised by BHP since the early 1950 ’s when there was a steel rolling mill built on the site. Products included fence posts treated with creosote.
9
6.3
In the late 1960 ’s, BHP began construction of a blast furnace, power station, pig iron mill and sinter plant. As a result of the operations there were considerable stockpile areas and broad use of the Lease until the blast furnace, power station and sinter plant were closed in the early 1980 ’s. In the main, these were later demolished in the early 1990’s in order to make way for the HIsmelt Research and Development Facility (HRDF).
Notwithstanding this several building structures and buried infrastructure remain on the
Lease as a legacy from this early land use.
The main purpose of the HRDF was to develop the processes proposed by the HIsmelt concept and demonstrate its viability. This pilot facility shut down operations in 1999 and was later demolished. The site became part of Land Corp ’s holdings. In 2002 the current
HIsmelt (HKJV) Plant began construction and commenced production in 2005. The Plant operated until 2008 after which it was placed into a care and maintenance status following a market downturn.
The Lease is currently occupied by buildings and structures which are both remnant from the previous BHP occupation, as well as the HIsmelt Plant and the associated facilities and ancillary structures developed by Rio Tinto and its HKJV partners.
The Lease has been classified by the Department of Environment and Conservation as
“Contaminated – Restricted Use” in 2008 and is only permitted to be used for industrial and commercial purposes.
Tenure
Rio Tinto iron ore mines and sites are located on Crown land that is overlain with leases of various types: freehold title is generally not applicable.
Two layers of leases are applicable to mines and sites: pastoral leases and other types of lease.
6.3.1 Pastoral Leases
A pastoral lease does not exist in the Kwinana Industry area and is not applicable to this
Final Closure report.
6.4 Lease Applicable to the Plan Area
6.4.1 HIsmelt Lease
The Head Lease is an agreement between the WA Government (WALA) and Rio Tinto ’s entity HIsmelt Corp. An additional adjoined Lease described as Lot 12 for which an identical lease agreement exists, completes the “HIsmelt Lease” description. The boundaries of the full HIsmelt Lease are illustrated on drawing DS-000 included in
Appendix B.
6.4.2 Sub-leases
On the HIsmelt Lease there are several sub-leases, the main one of these is the HIsmelt
Kwinana Joint Venture (HKJV) Sublease on which the HIsmelt Plant and majority of its infrastructure is located. Adjoined to the HKJV Sub-lease is the Wesfarmers / Air Liquide
10
JV Sub-lease. On this sub-lease is the Air Separation Unit (ASU) which supplied the
HKJV Plant with its industrial gases. Drawing DS-000 in Appendix B also illustrates the location of the sub-leases.
The Sublease agreements are between HIsmelt Corp. and the aforementioned stakeholders. The Sublease agreements contain the same remediation (“make-good”) conditions “back to back” as the HIsmelt Lease.
Further details in respect to the various lease agreement details are contained in the
Knowledge Base Report – Legal, dated 3 rd
February 2011 .
A sublease agreement has also been established between HIsmelt Corp and Cockburn
Cement Industries which permits the use of the previous BHP Merchant Mill building and surrounding land located on the northern boundary of the Lease. This sublease is scheduled to expire prior to the proposed HIsmelt closure.
Drawing DS-001 in Appendix B highlights third party land users and sub-lease areas.
6.5 Joint Venture arrangements
The HIsmelt Kwinana Joint Venture (HKJV) is comprised of four parties (the Project
Participants) being;
HImet (a vicarious Rio Tinto entity),
Nucor Australia,
China Shougang International Trade and Engineering Corporation and
Mitsubishi Corporation Iron and Steel Pty Ltd.
It is this entity that owns the HIsmelt Plant and is bound to the HKJV Sublease agreement.
11
An entity known as HIsmelt Operations Pty Ltd (HIOps) was established to oversee and manage the entire day to day Plant operations on behalf of the HKJV as well as the management of all HIsmelt Lease and Sublease matters. HIOps is a wholly owned subsidiary of Rio Tinto.
12
7. Overview of operations
7.1.1 HKJV Sublease
As previously mentioned the HKJV plant began operations in 2005 to produce high carbon iron as feedstock for steel making. The Plant ceased production operations late in 2008 and has been in a non-operational, care and maintenance status since. The Plant is broken down into key process areas which include;
raw materials handling,
raw materials preparation,
smelt reduction and casting,
blast systems,
off-gas systems,
waste gas systems and
Plant systems, as well as others.
Refer to Drawings DS-031, DS-032 and KWIN1-00-AH-00-008 in Appendix B for Plant and facilities layout.
7.1.2 HIsmelt Lease
Outside of the HKJV Sublease, there exist buildings, facilities and infrastructure in the main which are legacy items from the previous lease holder. Notwithstanding this there are some elements which were established by the HKJV and are associated with the functioning and operations of the HKJV Plant. These are;
Drainage systems and storage pond
Eastern Workshop
Process water lines to drainage pond
Kwinana Water Recycling Plant (KWRP) water lines
Gas feed
Power feed and
Waste stockpiles
The balance of buildings, fixtures, infrastructure and other site additions were added by the previous lease holder and are summarised as follows;
Old admin training offices
Waste water tank
Large workshop – West
HIsmelt warehouse – West
Weighbridge building
Pig iron stockpile (Export Pad) area
13
BHP Merchant Mill Shed
BHP export warehouse
BHP amenities, office, old gatehouse
Administration buildings – currently utilised by HIOps
Security office
Substation 3 and Main switch yard
Roads, car parks and various services and infrastructure (both live and redundant)
Waste product land fill (putrescible, mixed, and blast furnace waste)
Refer to drawings DS-033 and DS-034 in Appendix B for location information regarding the above.
14
8. Current Lease layout
Refer to drawing DS-000 in Appendix B for improved information in respect to the HIsmelt lease and the location of the Subleases.
15
Closure obligations and commitments
This section provides a review of the legal and other obligations.
A number of general legislative obligations apply to all sites at all times. Whilst these may be important to consider during closure, this section concentrates on obligations that are specific to closure of this site. A review of generic closure obligations was conducted by Freehills in 2008
5
.
A review of closure obligations and commitments has been undertaken as part of this final closure plan, with key obligations and commitments summarised in this report.
6
5
Freehills, Generic Closure Obligations, draft report for discussion, 16 July 2008, RTIO-CR-0016834
6
Reference Document RTIO-HSE-0135290
16
9.
9.1
9.2
Important elements of the general legislative framework
State Agreement legislation
A State Agreement is an Act of the Western Australian Parliament to regulate mining activities that are of economic or strategic importance to the State. All of Rio Tinto’s
Western Australian iron ore mines are subject to State Agreement
7
. The Department of
State Development (DSD) is the responsible agency.
A key consequence of State Agreements is that they override the Mining Act 1978 requirement to submit closure plans to the Department of Mines and Petroleum (DMP).
State Agreements are structured so that Environmental Protection Act 1986 (EP Act) requirements apply. Sites subject to State Agreements are therefore subject to environmental impact assessment by the Environmental Protection Authority (EPA), and to works approval and licensing by the Department of Environment and Conservation
(DEC).
The HIsmelt Plant is not subject to a State Agreement. However, the HIsmelt Plant was developed in part to satisfy 'further processing' requirements contained in the schedule to the Iron Ore (Yandicoogina) Agreement Act 1996 (WA). By letter dated 16 December
2002 the Minister for State Development acknowledged that the HIsmelt Stage 1 Plant was accepted by the State as satisfying two thirds of the secondary processing obligations under clause 23(2) of the State Agreement upon first metal production from the Stage 1 plant.
Ministerial Statements
Ministerial Statements are the end result of the environmental process outlined in Part IV of the EP Act.
Part IV of the EP Act outlines the process whereby approval is given to significant projects by the Minister for the Environment, under advice from the Environmental
Protection Authority (EPA). The approval process is a public one, with several opportunities for a public right to appeal its nature and content.
Further, Part IV approvals have explicit and/or implicit precedence over other approvals.
For example, S41 of the EP Act prohibits decision making authorities from making decisions until the Ministerial approval process is complete. S55 (4) of the EP Act requires that subsequent environmental approvals and licences must be consistent with the Part IV approval. Whilst there are no such formal restrictions on other types of approvals (e.g. planning approvals, heritage approvals), it is rare for them to be inconsistent.
The EPA expects closure plans to be submitted with approvals documentation to facilitate the incorporation of closure issues into its environmental impact assessment.
7
Note that whilst all RTIO mine sites are covered by State Agreements, some ancillary areas (e.g. camps, infrastructure services, etc) may be located outside the Agreement boundary.
17
9.3
Ministerial Statement 610 for the HIsmelt Plant was granted on 18 November 2002. The proponent of Ministerial Statement 610 is HIsmelt Ops.
Condition 6-2 of Ministerial Statement provides that:
'At least six months prior to the anticipated date of closure, or at a time agreed with the Environmental Protection Authority, the proponent shall prepare a Final Closure
Plan designed to ensure that the site is left in an environmentally acceptable condition to the requirements of the Minister for the Environment and Heritage on advice of the Environmental Protection Authority ’
The Final Closure Plan shall address:
(1) removal or, if appropriate, retention of plant and infrastructure in consultation with relevant stakeholders;
(2) rehabilitation of all disturbed areas to a standard suitable for the agreed land use(s); and
(3) identification of contaminated areas, including provision of evidence of notification and proposed management measures to relevant statutory authorities.'
Under Condition 6-3, HIsmelt Ops must implement the Final Closure Plan until such time as the Minister for the Environment and Heritage determines (on advice from the EPA) that the proponent's closure responsibilities are complete.
Condition 6-4 requires HIsmelt Ops to make the Final Closure Plan available to the public, to the requirements of the Minister of the Environment and Heritage (on advice from the EPA).
In addition to the Final Closure Plan, HIsmelt Ops gave a commitment in Schedule 2 to the Ministerial Statement (Commitment 1) to prepare an Environmental Management
Plan ( EMP ) for the Site, which includes Management Plans for, amongst other things,
'Decommissioning and Closure'. The EMP has been prepared as a part of this process and is contained in Appendix C.
Mining Proposals
Mining proposals are issued under the Mining Act 1978 . This is the primary legislation under which mine closure is regulated in Western Australia and the Department of Mines and Petroleum (DMP) is the responsible agency.
In accordance with amendments to the Mining Act made in 2010, all new Mining Proposal applications are required to contain a Mine Closure Plan prepared in accordance with the
DMP/EPA Guidelines for Preparing Mine Closure Plans (2011).
Mining Act requirements also apply to operational areas that are not covered under State
Agreement legislation. Some mining areas (e.g. waste dumps, fines dams) and ancillary infrastructure (e.g. mining camps) may fall into this category.
18
The HIsmelt Lease is not associated with a Mining Proposal or State Agreement and the outcomes sought from these processes are analogous to the obligations (specifically environmental) which are contained within the Ministerial Statement 610 described previously.
The HIsmelt Lease is considered a ‘Mine Site’ under Mines Regulations and for the government management of safety and environmental matters and thus closure planning of the Lease will similarly adhere to the Department of Mines and Petroleum ’s closure guidelines.
9.3.1 Guidelines for Preparing Mine Closure Plans (DMP/EPA)
The DMP and EPA have issued guidelines to establish standards for closure plans
8
being submitted to Government. The guidelines have legislative weight because the Mining Act
1978 has been amended to specifically require closure plans that comply with the guidelines to be submitted with mining proposals, and reviewed on a 3-yearly basis.
The EPA has indicated that it expects compliant closure plans to be submitted for mines being assessed under Part IV of the EP Act. For mines that are subject to State
Agreements, it may delegate ongoing regulatory authority to the DMP.
Rio Tinto recognises that the Guidelines for Preparing Mine Closure Plans provide a suitable format for development of mine closure plans, and this closure plan has been prepared to comply with the key elements and structure of the guidelines.
Despite Kwinana HIsmelt not being bound to a State Agreement or Mining Proposal, much of these requirements are mirrored in the Ministerial Statement 610 and this final closure plan report has been prepared to comply with the key elements and structure of the guidelines. Consultation with the DMP and EPA confirmed that the final closure plan submission is to align with these guidelines.
8
DMP & EPA, Guidelines for Preparing Mine Closure Plans, June 2011
19
10. Legal obligations relating to specific aspects
10.1 Legal obligations relating to decommissioning
A general principle enshrined by the State Agreements within which RT iron ore sites operate is that infrastructure reverts to the State Government upon closure unless otherwise agreed. With respect to the Kwinana HIsmelt site there is no State Agreement applicable, however legal obligations for returning the Lease to the State Government exists and are contained within the Lease Agreement.
Additional obligations to do with some of the HIsmelt Plant infrastructure exist due to the provision by the Commonwealth Government of a funding grant for Multi-User
Infrastructure (MUI).
Other legal obligations associated with final closure are;
The Kwinana Joint Venture Agreement between the JV Parties dated 30 January 2002
(Kwinana Joint Venture Agreement)
The Wesfarmers and Air Liquide JV Sublease and
Supply agreements with third party suppliers of goods and services which remain in place from the Plant development and operational phase.
Sub-lease agreements with adjacent local businesses
10.1.1 HIsmelt Lease Agreement
By the last day of the term of the relevant lease, remove from the applicable premises all:
improvements of a capital nature effected or carried out by the HIsmelt on those premises and which have become fixtures;
all other fixtures, fittings, temporary facilities, signs and chattels belonging to or brought onto those premises by HIsmelt Corp or otherwise situated on those premises prior to the commencement date of the term;
fill in, consolidate and level off all excavations in the land and generally make good that removal; and
surrender and deliver up possession of those premises to WALA clean tidy and free from rubbish and in a condition in accordance with HIsmelt Corp's obligations under the applicable lease.
10.1.2 Multi-User Infrastructure
Obligations exist under the Deed between the Commonwealth of Australia via Invest
Australia and primarily Rio Tinto with the adjoined interest of the HKJV partners
(described in the Deed as the Project Participants) whereby a grant was issued for the development of the Multi User Infrastructure (MUI) on the Plant. Conditions exist in relation to the availability of the MUI for the continued use of third parties on commercial terms until the 31 st
December 2012.
MUI items are described in detail in Schedule 3 of the Deed and in summary include the following;
20
The Air Separation Facility (Plant owned and located on the Wesfarmers and Air
Liquide Sublease)
Raw Materials Bulk Handling
Waste Heat Recovery Facility
Water Recycling Facility
The MUI Deed has subsequently been terminated by mutual consent on 21 st
December
2011 via a Deed of Termination.
10.1.3 Kwinana Joint Venture Agreement
The Kwinana Joint Venture Agreement provides that JV Parties must unanimously agree to terminate the joint venture. The approval of the Final Closure Plan and accompanying budget for execution of that Plan should form part of this process. The joint venture will continue to operate until:
all joint venture activities are wound up;
the Kwinana Site is remediated; and
the Kwinana Facility is sold.
JV Property is required to be offered for sale by way of open tender.
In a circular resolution dated 24 December 2010, the JV partners agreed to work towards closure, by the commencement of closure studies and works required for removal of plant
/ rehabilitation and termination of the joint venture.
10.1.4 Industrial Gases Supply Agreement
The Final Closure Plan includes timelines and phasing for the decommissioning of the Air
Separation Unit ( ASU ) operated by Air Liquide WA (ALWA).
HIsmelt Operations may terminate the Industrial Supply Agreement by notice to ALWA where the HIsmelt Plant is to cease to operate.
The Industrial Air Supply Agreement will terminate 2 months following the receipt of the notice by ALWA, provided that HIsmelt Operations has paid ALWA the 'Termination
Amount', plus reasonable demobilisation costs. The Termination Amount is derived from a formula in Schedule 7 of the Agreement, and equals ALWA's forecast internal rate of return for a 15 year supply period.
HIsmelt Corp permits ALWA to hold over the Air Liquide Sublease for as long as may be necessary for it to rehabilitate the ASU Site to a clean and level condition down to the top of the concrete pads and otherwise in accordance with the covenants and obligations in that respect, of its part contained in the Air Liquide Sublease.
In a circular resolution dated 12 December 2011, the JV partners agreed to terminate the
Industrial Gas Supply Agreement, pay outstanding monies and arrange for removal of plant.
21
Rehabilitation of the sublease will then be considered as part of the overall HIsmelt lease works.
10.1.5 Water Supply Agreement
HIsmelt Operations have notified the termination of the Water Supply Agreement by notice to the Water Corporation, citing the HIsmelt Plant is to cease to operate on 19 th
January 2011. HIsmelt Operations continue to pay the Water Corporation the Post
Termination Monthly Fee for the remainder of the Term of the Water Supply Agreement, less funds raised by on-selling of the water to third parties.
The agreement terminates in April 2012.
10.1.6 Sublease of Merchant Mill Building
A sublease has been established between HIsmelt Corp and Cockburn Cement
Industries for the use of the Merchant Mill building and adjacent surrounding land. This agreement has a one month notice period to terminate should this be required prior to the termination date of end December 2012.
10.2 Legal obligations relating to rehabilitation
Obligations exist under the Ministerial Statement 610 as well as through the Lease
Agreement requirements to ‘make-good’ as described in the previous section. The baseline for the rehabilitation obligations is to restore the land to within the acceptable parameters for land zoned as Industrial Use. Furthermore, as there had previously been a heavy industrial use application, prior to the commencement of land use by Rio Tinto and the Joint Venture, rehabilitation will be benchmarked against the land condition state at the time of hand-over to Rio Tinto.
In summary the requirements to rehabilitate the land occupied by the Lease require returning it to the baseline / hand-over condition and / or within the acceptable parameters of Industrial zoned land.
Baseline environmental studies and monitoring have been undertaken by HIsmelt
Operations in order to establish the criteria for rehabilitation. Further information is contained in the Knowledge Base Report – Environmental in respect to this.
10.3 Legal obligations relating to decontamination
The Contaminated Sites Act 2003 is the key legislation governing contaminated sites in
Western Australia, including mine sites. Companies are required to report known or suspected contaminated sites; however, the threshold for reporting, which relies on a source, pathway and receptor model, is relatively high for remote mine sites. Once a site has been reported, it receives a classification which determines any action required.
For the Kwinana HIsmelt Lease, it was previously a “contaminated site” but was not classified until the legislation was enacted in December 2006. The Lease status has preexisted the commencement of the agreements and conditions which were entered into between the State Government and Rio Tinto.
22
The obligations relating to decontamination therefore extend to any effect beyond the time of the commencement of the Lease Agreement and the Ministerial Statement, as well as the classified limits deemed acceptable for Industrial land.
Baseline environmental studies, progressive monitoring and a Detailed Site Investigation
(RPS September 2011 – Report No: C11076:3) have been commissioned by HIsmelt
Operations in order to establish the criteria for decontamination. Further information is contained in the Knowledge Base Report – Environmental in respect to this.
10.4 Legal obligations relating to Traditional Owners
Aboriginal heritage sites are protected under the Aboriginal Heritage Act 1972 . Aboriginal heritage sites consist of both Archaeological (where material remains associated with past Aboriginal land use) and anthropological sites (places of spiritual importance and significance to Aboriginal people).
With regard to indigenous cultural heritage, there have not been any aboriginal heritage sites identified in the Heritage Council of Western Australia (HCWA) database conducted on 17.05.2011 within the site boundaries of the HIsmelt Lease.
Due to the current and previous land use of the site, potential to impact unknown historical cultural heritage sites within the site is considered unlikely.
Despite this, the Environmental Management Plan (EMP) will cover the management of aboriginal and cultural heritage sites that may be discovered during the decommissioning phase of the project.
10.5 Legal obligations relating to local communities
There are no legal or binding obligations associated with the local communities however there has existed a regime of local community support and sponsorship that was developed by HIOps over the years. The Knowledge Base Report – Social may be referenced to provide complete details in this respect.
23
11. Corporate closure planning requirements
All Rio Tinto businesses have an internal corporate requirement to undertake closure planning in accordance with the Rio Tinto Closure Standard
9
. The intent of this standard is to ensure that Rio Tinto managed activities are left in a condition which minimises adverse impacts on the human and natural environment, and that a legacy remains which makes a positive contribution to sustainable development.
Compliance with the Rio Tinto Closure Standard requires:
Commencement of planning for closure from project inception to enable closure considerations to be incorporated into project design;
Developing and maintaining a Knowledge Base for the environment in which the operation is located. This must include:
○ Characterisation of the socio-economic, cultural, biotic and abiotic environments
○ National, regional and local legal and regulatory requirements for closure
○ Agreements made with stakeholders
Developing and maintaining closure strategies that promote a multidisciplinary approach to closure and post-closure;
Maintaining a Closure Plan based on preferred options developed through the closure strategies process. This plan addresses closure objectives and preliminary completion criteria, consultation and communication processes, rehabilitation, technical solutions, and risks associated with closure options;
Development of a closure provision, to a specified accuracy that improves as the site moves closer to closure;
Reviews of closure plans for each site on a regular basis, taking into account developments that may influence closure scope, strategies or implementation; and
Development of a final decommissioning plan five years prior to scheduled closure.
Whilst generally structured towards mining operations, this business ethos is extended to the closure of the HIsmelt Lease and the internal closure standards have been applied accordingly.
9
Rio Tinto, Rio Tinto Closure Standard , RTIO-HSE-0020698
24
Collection and analysis of closure data
This section forms part of the closure knowledge base, and is intended to:
Summarise key baseline data;
Document the outcomes of research and studies;
Identify knowledge gaps and document how these will be addressed.
Outlines the current understanding of environmental aspects that may be relevant to the development of closure strategies.
The closure knowledge base will evolve over time, and information collated in this section reflects current knowledge at the time of preparation of the report.
25
12. Climate
12.1 Monitoring stations
The Kwinana area is described as having a Mediterranean climate, characterised by hot dry summers and mild wet winters. Climate data has been sourced from the Bureau of
Meteorology averages for BP’s Kwinana Refinery for the period 1955 to 2001, and summarised in Table 1.
12.2 Rainfall
Rainfall in the Kwinana region is seasonal and the majority is confined to the winter months (June to August) (Figure 2). Mean monthly rainfall is highest in June at 165.8 mm, with an average of 18 rain days. Rainfall in July is similar with a monthly mean of
160.5 mm over an average of 19 rain days. The lowest mean monthly rainfall is 8.4 mm in December, with an average of three rain days. The average annual rainfall is 768.6 mm, with an average of 113 rain days per year.
A comprehensive table of average rainfall distributions for the Kwinana area has been provided by the Bureau of Meteorology and is contained within the RPS - Detailed Site
Investigation Report No: C11076:3, HIsmelt Facility, Extended Lease Area Report of
September 2011 . This report is referenced within the Environmental Knowledge Base.
Summary information is included in table 1 below.
12.3 Temperature
The mean annual maximum and minimum temperatures for Kwinana are 23°C and
14.4°C, respectively. The highest temperatures are usually experienced in February, when the mean daily maximum temperature is 29.4°C and the mean daily minimum temperature is 19.1°C. Minimum temperatures occur in July, when the mean daily maximum and minimum temperatures are 17.6°C and 10.6°C, respectively. Figure 3 presents the mean maximum and minimum tempe ratures recorded at BP’s Kwinana
Refinery each month.
Table 1 - Summary of Climatic Data for BP’s Kwinana Refinery from 1955 to 2001
Month
January
February
March
April
May
June
July
August
September
October
November
December
Annual
Mean
Annual Total
Temperature
(
C)
Mean Daily
Maximum
Mean Daily
Minimum
18.7
29.1
29.4
27.6
24.3
21.0
18.7
17.6
17.9
19.3
21.3
23.9
26.7
23.0
19.1
17.8
15.5
13.1
11.7
10.6
10.5
11.3
12.5
14.9
17.0
14.4
Relative Humidity
(%)
9 am Mean
52
53
56
63
69
74
74
72
68
61
56
53
63
Evaporation
*
(mm)
3 pm Mean Mean Daily
55
54
54
58
62
65
66
65
63
60
58
56
60
8.5
8.2
6.2
4.1
2.3
1.8
1.8
2.3
3.2
4.7
6.4
7.8
4.8
1750
Rainfall
(mm)
Mean
10.9
16.0
16.9
41.2
107.9
165.8
160.5
106.6
68.6
41.7
24.0
8.4
768.6
Mean No. of
Rain Days
2
113
2
4
8
13
18
19
16
13
9
6
3
Notes: * Evaporation data is from Bureau of Meteorology’s Medina research station, for the period 1983 to 2001
Source: Bureau of Meteorology, Kwinana BP Refinery and Medina Station (for evaporation data only)
26
35
30
25
20
15
10
5
0
Maximum
Minimum
Jan Feb Mar Apr May Jun Jul
Month
Aug Sep Oct Nov Dec
300
250
200
150
100
50
0
Evaporation (mm)
Jan Feb Mar Apr May Jun Jul
Month
Aug Sep Oct Nov Dec
Figure 2 Mean Monthly - Temperature, Rainfall and Evaporation
12.4 Winds
Winds in the Kwinana region result from both large-scale (synoptic) winds associated with low and high pressure systems, and local thermally-influenced winds. Typically, strong offshore breezes occur during the daytime followed by corresponding onshore breezes as the land cools during the evening. This sea breeze/land breeze cycle is typical of coastal environments.
Synoptic winds in the Kwinana region are generally from the east. During spring and summer, the easterly winds are disrupted by the sea breeze from the south-west and south-south-west, which is generally an afternoon weather phenomenon.
Annual wind roses showing the predominant easterly and south westerly winds are presented in Figure 4.
27
Figure 3 Annual Wind Roses from Kwinana
(Source: Department of Environmental Protection (DEP) Hope Valley Meteorological Station)
12.5 Predicted climate change projections
A study by CSIRO Marine and Atmospheric Research
10
used a number of models
11
to make climate change projections for the whole of Australia. Modelling was undertaken for various greenhouse gas scenarios, and the findings below are based on mid-range global warming scenarios. The study found:
An average temperature increase of between 1°C and 1.5°C between 1990 and
2030;
An average temperature increase of between 3°C and 4°C between 1990 and 2070;
A reduction of up to 5% rainfall during the months of December to February, and a reduction of up to 5% annual rainfall, by 2030 (relative to 1990);
A reduction of up to 5% rainfall during the months of December to February, and a reduction of up to 10% annual rainfall, by 2070 (relative to 1990).
Note that there is a high degree of uncertainty regarding predictive climate modelling, and research is currently being undertaken by the Indian Ocean Climate Institute (IOCI) to verify and validate modelling assumptions
12
.
10
Suppiah et al, Australian climate change projections derived from simulations performed for the IPCC 4 th
Assessment Report, Aust. Met Mag (2007) 131-152
11
A total of 23 models were assessed to validate accuracy with historical Australian climate data, with 15 demonstrating sufficient accuracy to be used in the study.
12
Refer to IOCI website http://www.ioci.org.au/index.php?menu_id=14 for further information on current research projects.
28
13. Topography
The site is relatively flat with an average elevation of around 5m Australian Height Datum
(AHD). Parts of the site have been covered with compacted fill.
Further information in relation to the site topography is detailed in section 4.0 within the
RPS Report - Detailed Site Investigation, HIsmelt Facility, and Extended Lease Area
Report of September 2011 .
29
14. Geology
The Kwinana Industrial Area is located within the Quindalup Dunes system of the Swan
Coastal Plain. The Quindalup Dunes are the youngest of the Swan Coastal Plain dunes, and occur as a series of elongated dunes generally running parallel to the coastline
( Bolland, 1998; WRC ). The HIsmelt site is typical of the coastal deposits of the area, and consists of Safety Bay Sand (Holocene age) overlying Tamala Limestone (Pleistocene to
Holocene age).
The Safety Bay Sand is calcareous, white, medium-grained sand that consists of shell fragments, quartz and some (minor) feldspar. The sand is composed predominantly of carbonate skeletal or shell grit and may have a carbonate content of more than 50% by weight.
It is approximately 20m thick within the HIsmelt site and is generally uncemented although in some areas it is cemented with calcium carbonate to form weak to moderately strong limestone ( Dames & Moore, 1993 – Reference 19099-002-071 ).
The Safety Bay Sand overlies a discontinuous basal layer up to 2m thick of silty clay and clayey sand; this clay layer is generally dark grey to greenish grey and contains variable amounts of shell. The top of the formation is generally sandy to gravelly and consists of shell grit and shell fragments. The bottom half of the formation to the Tamala Limestone is shelly firm clay ( Dames & Moore, 1993 – Reference 1099-002-071 ).
The Tamala Limestone comprises a sandy, yellow to brown limestone, generally coarse to medium-grained, that comprises quartz sand, shell fragments and minor clayey lenses
( Corporate Environmental Consultancy, 2002 ). Within the HIsmelt site, the Tamala
Limestone is approximately 12m thick and comprises variably cemented limestone, sandstones, calcarenite and carbonate sands ( URS 2003 – Reference 19099-028-
562/578-F5494 ).
In addition to the natural soils the site also contains fill materials (as detailed in Golders
Associates, 2000 - Report 1251-4370 ) which include the following:
Clean Fill, which is mainly shallow fill, comprising reworked safety bay sand mixed with minor amounts of gravel or imported soil and construction debris.
Dredge Spoil (from offshore dredging for the ship loading facilities) comprising poorly sorted fine-grained sand or silty sand with some shell debris.
BHP Blast Furnace Slag which was a by-product of pig iron production and has a similar metal composition to clean fill.
Industrial Fill occurs widely across the site and was generally found in layers less than
0.5 m thick.
Records indicate that the majority of fill materials (excluding a stockpile of HIsmelt slag) was deposited previous to the occupation of the site by Rio Tinto and the HKJV. During operations (2005 – 2008) there was a slag deposition and processing area set aside in the upper north-west corner of the lease area.
Further site geology and soils mapping is contained in section 4.0 within the RPS Report
- Detailed Site Investigation – Reference C11076-3, HIsmelt Facility, ‘Extended Lease
30
Area Report ’ of September 2011 . This report is also referenced within the Environmental
Knowledge Base.
14.1 Materials inventory
An inventory of broad material types relevant to closure is presented in table 2. Data presented is based on current knowledge should be considered indicative.
Table 2 - Material inventory
Waste material
Material with significant
AMD potential
Material
Volume (m3)
0
Material with significant fibre risks
0.00025
0.005 Material suitable to be used for capping
Inert mineral waste
(hard – low erodibility)
Inert mineral waste
(soft – high erodibility)
Soil (Topsoil/subsoil)
0.21
0
0
Comments
Synthetic mineral fibre lagging in Plant
Limestone in car parks and laydown areas
Blast furnace slag excluding legacy slag material. This material may be suitable for site land forming and fill
14.2 Geochemical characterisation
RPS was engaged to undertake a geochemical assessment of slag material onsite. The purpose of the assessment was to determine the suitability of the slag for retention and reuse onsite from an environmental and human health risk perspective. The assessment also required collection and analysis of samples for landfill classification, should the risk to human health or the environment prove unacceptable and the material require offsite deposal. ATC Williams also completed a geotechnical investigation of the slag material and reported on the suitability of this material for reuse and retention onsite from a geotechnical perspective.
Assessment of an area of BHPB buried slag was completed for comparative purposes only. RT iron ore does not intend to excavate or dispose of this material as it was preexisting onsite prior to the HRDF/Hismelt operations commencing.
RPS collected a total of 58 slag samples from across the areas of interest and analysed them for a total metal and leachable metals. For the purpose of determining the risk to human health or the environment from the slag, RPS compared these results to the DEC
Assessment Levels for Soil, Sediment and Water (2010). Following comparison of the analytical results against DEC guidelines a site specific conceptual site model and risk assessment was developed. The CSM and risk assessment concluded that although total metal and leachable metal concentrations were detected above EILs, FWGs,
MEPGs and low reliability trigger values, the risk to the receiving marine environment is considered low and acceptable. Metal concentrations were also detected in the leachate
31
above DoH (2006) guidelines. However the likelihood for site workers’ health to be impacted via dermal contact with groundwater used for reticulation or dust suppression is low and as such the overall risk to human health was considered low and acceptable.
Therefore the human health and environmental risks posed from the onsite retention or reuse of any of the slag materials assessed is considered low.
Given the likelihood for some of the assessed slag material to be required to be taken offsite for disposal RPS compared analytical results against the DEC Landfill Waste
Classification and Waste Definitions 1996 (As amended December 2009). It is acknowledged that for the volume of material assessed additional samples may be required in order to fully satisfy a receiving landfill. However based on the results obtained the following classifications were determined, as presented in Table 3 below.
Table 3 – Landfill Classification of Slag Material
Slag Type
Stockpile Area A
Landfill Classification
Class 1, however additional samples may be required
(may need to segregate low volume aluminium impacts for Class 3 disposal)
Stockpile Area B and C02 Class 1
Stockpile Area C Class 3
Laid Slag Area Class 1, however additional samples may be required to support UCL95 result
BHPB Buried Slag Class 3
Given the mixture of materials within the slag stockpiles from Area A, and the extent of dried sludge material in stockpile B06, it is likely that these stockpiles will require offsite disposal. In addition it may be necessary to screen or sort the material from stockpiles
B01 to B05, C02, C07 and C08 so as to make the material geotechnically suitable for reuse onsite. Given the homogenous nature of materials in stockpiles C01, C03 to C06 and C11 to C14 RPS consider that this material will most likely be suitable for reuse onsite. Given the high percentage of iron skulls and scrap metal identified in stockpiles
A06, B07, B08, C09 and C10 RPS considers this material will not be suitable for reuse onsite and will be sent offsite for metal recycling.
In summary each of the slag types assessed are considered suitable for retention and reuse onsite from a human health and environmental perspective only. All material would be suitable for disposal to either a Class 1 or Class 3 landfill if removed from site; however a minor number of additional samples may be required prior to a landfill accepting this material.
It was not possible to definitively identify which of the buried slag material was distinctly from BHPB operations due to the chemical and physical similarities between the two types of slag material.
32
Reference to the RPS Slag Geochemical Investigation report included in Appendix E should be made for further details.
14.3 Geotechnical
ATC Williams undertook a geotechnical analysis of slag on the Lease which was either in insitu deposits or located in stored stockpile. Slag in stockpile was examined to determine if it was suited to land filling application on the Lease. Full details of the findings are included in the Appendix E report – ATC Slag Geotechnical Investigation.
14.3.1 Laid Slag Area
Based on the findings of the investigation, the existing base course materials should be suitable to support modular portable buildings, or serve as equipment lay down area for the plant de-construction works. Contact bearing pressures for stanchion pads/raised structures should be limited to 200 kPa to maintain tolerable pavement deflections. For structures other than portable buildings, foundation bases should be constructed in the sand fill or natural sand substrate at a minimum depth of 0.5 m. The base of footing excavations should be proof compacted to a minimum dry density ratio of 95% MMDD prior to concrete placement.
14.3.2 Buried Slag Area
The fill profile below the buried slag area comprised variable granular fill, consisting of fine to coarse sand fill and fine to coarse gravel fill with variable quantities of cobbles and boulders. Cobble and boulder fill consisting of slag, brick and concrete was also encountered. A thin layer of coal sludge was locally encountered in T13. The base of the buried slag was not confirmed in two test holes which were excavated to a maximum of
2.4 m. The thickness of the fill is inferred to be at least 4 m deep below the raised plateau in the west of the area.
Estimated percentages for the fill materials encountered were as follows:
Sand Fill 46%
Gravel Fill
Cobbles/Boulders
Coal Sludge
28%
25%
1%
The granular fill materials contain a significant proportion of oversize and are generally unsuitable as engineered fill in their current state. Screening of the fill to < 75 mm with possible crushing of the oversize materials is recommended to produce a consistent material with acceptable compaction characteristics.
The layer of cobble fill encountered in T19 is reasonably well sorted comprising clean cobbles with small boulders (up to 0.3 m diameter) and it is anticipated that the fill could be used in its current state for select engineering applications such as rip-rap or gabion wall fill, subject to viable quantities of the material being available.
33
14.3.3 Stockpile Fill
The stockpiled fill materials are variable in their grading and compaction but are generally considered as potential engineering fill sources with appropriate screening and crushing.
The end product would be suitable for compaction to high density ratios and should provide high CBR values for permanent support. Testing and screening of existing stockpiles has been successfully carried out previously in stockpile Area C.
34
15. Water
The Safety Bay Sand and the Tamala Limestone Formations contain unconfined aquifers
( Dames and Moore, 1990b ). At a regional level the aquifers in the Sand and Limestone are considered to form a single aquifer system. The aquifer is referred to as the
Superficial Aquifer and the site is located within the Jandakot Mound division of the
Aquifer. However, detailed investigations indicate that the flow paths within the KIA are more complex and that the aquifers can be separated on the basis of hydrostatic head and natural groundwater quality ( Barnes & Whincup, 1981 ).
Figure 4 Regional Groundwater Contours
35
The direction of groundwater flow is generally to the North West under a hydraulic gradient of approximately 1 in 2500 ( Dames & Moore, 1990b ). Fresh groundwater overlies the saline marine water in the aquifer. As groundwater flowing from the Jandakot
Mound approaches the coast at Cockburn Sound it is forced over the dense saline wedge and then discharges into the shallow near shore zone ( D.A.Lord, 2001 ). Some of the fresh groundwater mixes with the salt water at the interface and tends to remain in the sediments beneath Cockburn Sound. However, most of the groundwater rises up the interface and discharges into Cockburn Sound ( Barnes & Whincup, 1981 ). Regional groundwater contours are presented on Figure 5.
Groundwater flow through the Tamala Limestone is highly variable and ranges between
200 and 2000m per year ( Davidson, 1995 ). Groundwater flow through the Safety Bay
Sand is significantly slower at around 20m per year ( D.A.Lord, 2001 ).
The Tamala Limestone is the most productive and widely used aquifer in the Kwinana area with permeabilities in the order of 500 to 1500m/day. The Safety Bay Sands are unconsolidated and well compacted with permeability in the order of 10 to 20m/day
( Barnes & Whincup, 1981 ).
RPS conducted a Detailed Site Investigation of the HIsmelt lease in 2011 to examine the ground water characteristics. The findings are contained within the RPS Report - Detailed
Site Investigation, HIsmelt Facility, and ‘Extended Lease Area Report’ of September
2011 . This report is referenced within the Environmental Knowledge Base.
15.1 Pre-Lease hydrogeology
15.1.1 General
Six groundwater monitoring bores (BH1 to BH6) were installed around the HRDF site in
1990 to provide baseline data on the groundwater which would have been impacted by previous industrial activities in the area. During the operation of the HRDF, the 6 groundwater bores were regularly sampled and the results compared to historical records to determine whether the activities were impacting the groundwater system. All results were reported to the DEC on an annual basis.
BH4 was lost due to construction works in late 1990. Two additional monitoring bores were established (BH7 and BH8) in 1991 and another two bores (BH9 and BH10) established in 1993. Bores BH5, BH6 and BH7 are background bores located to the east of the site. All other bores monitor the groundwater under the site.
Groundwater monitoring of these bores was undertaken on a bi-annual basis between
1990 and 1993 prior to the commissioning of the HRDF. The frequency of monitoring was increased to quarterly once the HRDF was operational. Monitoring continued on a quarterly basis even after the HRDF was placed on care and maintenance.
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Figure 5 HKJV Monitoring bore locations
Prior to the construction of the HKJV Plant the agreed network of monitoring bores was expanded to include a total of 15 bores prior to August 2006. These bores were gauged, sampled and analysed for a suite of compounds in general accordance with the requirements of the previous operating license and subsequent amendments made in consultation with HIsmelt. The locations of the bores are shown on Figure 6.
Analytical results at the Lease site were compared with the DEC aquatic ecosystems
(marine and freshwaters) assessment criteria and the irrigation waters guidelines when aquatic ecosystem criteria were not available.
15.1.2 Groundwater Levels
During 2003 – ( Reference URS, 2003 ) , URS’s investigations found that depth to groundwater over the site was between 3.5m and 4.5m below surface. The reduced groundwater elevation is around 0.57 to 1.14m AHD from west to east indicating that flow is to the west.
15.1.3 Groundwater Quality
Groundwater samples were analysed for the following parameters in accordance with the requirements of the DEC operating licence:
Table 3 - Groundwater Parameters
Bores
BH1 to BH3, BH5 to BH7,
BH8A
BH9:
Parameters pH, electrical conductivity (EC), total dissolved solids
(TDS), sodium (Na), calcium (Ca), magnesium (Mg), chloride (Cl), sulphate (SO4), bicarbonate (HCO3),
nitrate (NO3), dissolved carbon, dioxide (CO2), arsenic
(As), and soluble iron (Fe).
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BH1, BH3 and BH6:
BH1, BH6, BH7 and BH8A:
BH5 and BH6:
BH6, BH7 and BH8A:
BH5, BH6 and BH7:
BH1 and BH3:
BH21, BH23 to BH26, Evap.
Pond:
BH23 to BH26, Evap. Pond:
Total iron (Fe).
Chemical oxygen demand (COD) and total organic carbon
(TOC).
Dissolved total chromium (Cr).
Dissolved selenium (Se).
Non sulphate sulphur.
Total recoverable hydrocarbons (TRH). pH, electrical conductivity (EC), total dissolved solids
(TDS), sodium (Na), calcium (Ca), magnesium (Mg), chloride (Cl), sulphate (SO4), bicarbonate (HCO3), nitrate (NO3), dissolved carbon dioxide (CO2), chromium (Cr), selenium (Se), cadmium
(Cd), lead (Pb), nickel (Ni), arsenic (As), zinc (Zn) and
Dissolved iron (Fe soluble).
Total Persulphate Phosphorus (P).
15.2 Pre-lease surface hydrology
Surface drainage on the site was installed by BHP for its steel mill, sinter plant, blast furnace and power station. A network of drains services the north western portion of the lease around the old rolling mill and workshops, as well as the south western portion of the lease, which includes the area previously leased by HIsmelt for the HRDF.
The BHP drainage systems historically discharged into Cockburn Sound via a concrete drainage channel (Southern Drain) at the south-western portion of the Fremantle P orts’
Kwinana Bulk Terminal area, or a drain at the north-western portion of the site (Northern
Drain) near the Fremantle Ports’ Kwinana Bulk Berth No.1 (KBB1). The drain outlets are both located on Fremantle Ports’ Kwinana Bulk Terminal site.
15.3 Ground and surface water interactions
During the construction of the HRDF the drainage system on what is now the HKJV
Sublease was modified to prevent site runoff from entering the BHP drainage discharge system. The bulk of the HRDF site runoff was directed to two drainage sumps (numbers 1 and 2). Soak wells were also installed at the boundary of the HRDF lease to capture runoff and allow the water to seep into the superficial aquifer (Figure 7).
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Figure 6 Surface water drainage system and soak wells
With the construction of the HIsmelt Plant, the drainage system in the area occupied by the coal, ore and dolomite stockpiles was modified to capture all storm water runoff and direct it to an evaporation pond at the south east corner of the Lease. From the pond the water was pumped to the clarifier on the western end of the HKJV site for retention and used for cooling slag.
Wash waters from the areas around the HKJV Hot Metal Desulphurisation Plant building, which had the potential to be contaminated through contact with raw materials or cooling water chemicals, was captured in a concrete sump and pumped to the clarifier.
The north-western portion of the broader HIsmelt lease area has a pre-existing drainage network that captures storm water runoff from the roads and around the rolling mill buildings. The drainage system contains a number of drainage sumps and silt traps that capture any suspended solids prior to the water being discharged through the northern drain.
The area between the rolling mill building and the HKJV lease, which was used as a laydown area by BHP for the steel mill does not have a drainage system, surface water in this area would simply flow to a low point and seep into the soil.
The undeveloped area to the east of Leath Road is not currently served by a drainage network. Surface water in this area would be absorbed by or seep into the porous soil.
On the southern boundary of the HKJV lease area, a large double lined evaporation pond was installed by the HKJV. The initial purpose of the pond was to capture storm water runoff from the stockpile area with a maximum inflow capacity of a 1 in 50 year 72 hr. duration storm event.
As the Plant production increased, consistent with the goal of being a zero discharge site, there was a requirement to better utilise the ponds storage capacity to also hold excess process water. Upon approval from the DEC, a feedback loop was designed and installed into this pond so that a further increase in water use efficiency could be achieved.
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In times of low production, excess water was diverted to the pond and when the plant production rates again increased and cooling water was required, the pumping system returned the water from the pond and into the plant thereby reducing for a short time the requirement to source water from offsite.
Lease drainage following Closure is discussed in section 38.
15.4 Environmental and social values of water at the site
The HIsmelt site is within an industrial area with no planned water abstraction for human or livestock consumption, or agricultural use. Groundwater discharge if required is expected to be to the marine environment of Cockburn Sound to the west. Therefore, the guidelines referenced for assessment of groundwater quality at the site in order of application are:
Aquatic Ecosystems – Marine Waters.
Aquatic Ecosystems – Fresh Waters.
Agricultural - Irrigation Waters.
15.5 The effect of HIsmelt operations on water systems
Groundwater elevations following the operation of HIsmelt were within the range historically observed for the site prior to 2003 ( RPS, 2011 ). Groundwater flow was confirmed to be in a north-westerly direction across the site towards Cockburn Sound as previously noted. Higher groundwater levels were observed within the immediate vicinity of the evaporation pond, which may be attributed to minor leaks from the pond.
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16. Biodiversity
16.1 Baseline vegetation communities
The site is within an area that has been extensively cleared and used for industry over several decades. There were no areas of remnant vegetation remaining on the site that were cleared for the Project. However, revegetation programs were initiated after construction of the HKJV Plant was completed in 2005 to comply with proponent commitments and the Plant grounds have subsequently developed.
The key areas of this revegetation activity were along the east/west access road directly adjacent to the stockpile conveying systems. Irrigated by the clarified discharge from the site’s BioMax system, several dozen Eucalypts were established for the visual amenity and dust buffer between the stockpile and the plant. Also, the grounds immediately surrounding the main site administration building were developed and planted with local endemic species of native vegetation. The establishment of both these areas was considered to be a great success and has also resulted in a small community of Quenda
(Southern Brown Bandicoots) re-inhabiting the grounds (see below).
16.2 Rare and priority flora
Due to the Lease having been completely cleared in past with continuous use as an industrial site thereafter there has been little opportunity for rare or priority flora species to develop.
Further there are no Threatened Ecological Communities or Bush Forever Sites within the Kwinana Industrial Area.
16.3 Fauna
Due to the clearing of vegetation on the site for previous developments, there are no faunal habitats for native species other than those areas that have been established as greening areas around the site.
No fauna surveys were conducted at the site as the degraded nature of the area suggests that the presence of native non-mobile species is unlikely. However, as a result of the revegetation activities and feral pest management and removal (foxes and cats), some endemic populations of Southern Brown Bandicoots have been observed repopulating the immediate areas around the main administration building.
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17. Contaminated sites
The Site forms part of a larger industrial complex area that was subject to a variety of industrial uses since 1954 including operation of a blast furnace, operation of a power house, operation of a steel merchant mill, raw material and product storage, production of waste materials, storage of waste materials including the disposal of slag, dusts and demolition waste, mixed and putrescible wastes. These are land uses that have the potential to cause contamination as per the guideline "Potentially Contaminating
Activities, Industries and Land Uses" ( Department of Environment, October 2004 ).
The Department of Environment and Conservation classified the HIsmelt lease as
“Contaminated – Restricted Use” on the 7/11/2008. The restriction only permits industrial and commercial land use activities. The primary reason provided for the classification related to soils containing widespread industrial slag and cinders that contain heavy metals exceeding Ecological Investigation Levels but below Health Investigation Levels for industrial and commercial land use.
17.1 Pre-existing Contamination (Baseline)
In order to assess site conditions and identify potential environmental liabilities associated with the lease arrangement, a baseline environmental assessment of the land covered by the Lease Agreement was undertaken ( URS, 2003 ). Areas identified as being contaminated are as follows ( URS, 2003 ):
25,000L Diesel Above-ground Storage Tanks : Contamination of a silt layer to the west of a bunded area has been identified as early as 1990. Contamination is present at levels between 0.8 and 1.9m below ground and the impact appears to be limited in lateral and vertical extent. No impact to groundwater in the vicinity of the storage tank. Aromatic hydrocarbon concentrations in the excess of the draft
Department of Environment and Conservation (DEC) Ecological Investigation
Level (EIF) and Health Investigation Level (HIL) – category F (for Industrial lands) guidance criteria were identified.
Power House Oil Supply : Soil with TPH concentrations above the 2003 draft
DEC EIL (aromatic fraction was also above the 2003 draft DEC HIL F) guidelines was identified along a section of the former power house oil pipeline, as well as residual hydrocarbon within the pipes. The full length of the former oil supply pipeline and its pathway was not determined.
Areas of Infill: Silicate and ferrous slag material, blast furnace residue and waste construction materials were identified in the eastern portion of the lease area, where local occurrences of elevated metal concentrations and Polycyclic
Aromatic Hydrocarbon (PAH) compounds were identified. Investigations showed that previous general demolition of the BHP plant and facilities on site appear to have been limited to above ground features, within the power house area and the area to the west of the HIsmelt Research and Development Facility constructed in 1991. Large concrete footings were found, along with an old rail line and utility services. Four former sea water supply pipelines were also found in the power house area.
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Localised Areas of Staining: Some small localised areas of surface staining
(hydrocarbons) were identified. It was noted that there is potential for the existence of other areas of localised hydrocarbon staining.
Slag/Ash Waste Materials: Seven locations were identified containing contaminants such as arsenic, chromium, copper, zinc and PAH compounds. The majority of these samples were collected from fill containing slag or furnace residue materials.
BHP Fence Post Plant: The fence post plant was located on the northern side of the BHP merchant mill and contained a tar bath and tar processing equipment on a concrete floor. A concrete base was recorded during site investigations and residual tar material was identified.
Merchant Mill Ponds: Land Corp, the current owner of the site, has previously undertaken site investigations which identified Total Petroleum Hydrocarbon
(TPH) compounds (both aliphatic and aromatic) and metals.
Western Lagoon: Blast furnace dust was identified within the western lagoon area, and comprised black silty sand to sandy silt at depths ranging from 0.25m to 0.9m. Chemical analysis identified concentrations of benzo(a)pyrene and
PAHs above the 2003 draft HIL F guidelines. Elevated metal concentrations were also reported in some samples. This area was remediated by the Land Owner in approximately 2002.
Merchant Mill Gas Station Underground Storage Tank: Excavations undertaken within the vicinity of the old BHP petrol station on the northern side of the merchant mill identified an underground storage tank, approximately 3.5m by
2.2m in size, however the contents and integrity of the storage tank were not investigated.
Merchant Mill Scale Pit : The merchant mill scale pits were used to collect metal scale removed from steel during processing. The scale pits were found to be filled with rubble, metal and wood. Analysis of the material found elevated levels of zinc.
Merchant Mill Substations: Thirteen transformer stations, containing four redundant transformers and one live transformer, were present on the northern side of the merchant mill building at the time of the investigation. The bases of the transformer stations had signs of staining and elevated levels of TPH and
PAH.
Groundwater: Groundwater monitoring wells installed to the base of the Safety
Bay Sand formation found low level concentrations of nickel and zinc, as well as
TPH.
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Zones of possible soil contamination
The drawing above (and included in Appendix B) highlights zones of possible surface soil contamination as a result of the lease use prior to HIsmelt.
Contaminated sites at HIsmelt have the potential to cause long term impacts on soils, surface water and groundwater quality. Under the Lease Agreement, remediation of some areas, identified by URS (2003) , may be the responsibility of Land Corp as these areas of contamination are the result of historical contaminating activities and were not the result of current HIsmelt operations.
Hismelt Operations conducted a post operations assessment for contamination and this was reported by RPS in September 2011.
This Detailed Site Investigation (DSI) was undertaken to determine whether any soil or groundwater contamination has occurred on site as a result of the construction and operation of the HIsmelt Commercial Plant between 2003 and 2011.
A single Asbestos Containing Material (ACM) fragment was identified at the former BHP
Power House location and determined to be representative of pre-2003 conditions.
However consideration should be given to the appropriate management of asbestos contaminated soils in this area, should intrusive earth works be conducted here in the future.
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Asbestos contamination area
Comparison of the groundwater conditions against historical data indicates a slight increase in zinc and sulfate concentrations above pre-2003 conditions potentially due to both on and off site activities. However limited off site historical data was available to confirm historic and current background zinc conditions. Zinc concentrations were reported in 2006 as being representative of groundwater concentrations within the
Kwinana Industrial Area (KIA), ( HIsmelt, 2006 – Reference KWIN1-00-VH-03-201 ).
Elevated nickel concentrations were also detected but are not considered to be a result of site activities and are most likely due to up gradient nickel impacted groundwater migrating on site (leaching from the limestone capped landfill).
Concentrations of nitrate and iron were also detected within the HKJV Sublease and
Extended Lease Areas above relevant water guidelines, but the concentrations detected were below pre-2003 historic maximums for the site. Nitrate and dissolved iron concentrations detected in 2011 were within their respective ranges reported by DoW
(2010) for groundwater in this area. Therefore site activities have not lead to a decrease in groundwater quality compared to pre-2003 and up gradient groundwater conditions.
Elevated concentrations of Total Dissolved Solids (TDS), Electrical Conductivity (EC), chloride and sodium were detected across both the HKJV Sublease and Extended Lease
Areas and at the off-site bore BH6. These elevated concentrations are considered to be due to sea spray deposition from Cockburn Sound, reduced rainfall infiltration into the underlying superficial aquifer and abstraction of groundwater. A slight increase in groundwater salinity for the Cockburn Sound area was also reported by the Department of Water (DoW) (2010), when comparing data from 1992 to 2007.
Although some elevated concentrations for metal, nutrient and inorganic parameters were identified within the groundwater above marine and non-potable exposure guidelines
(MWG and DoH 2006), the risk to the environment and human health from these parameters and concentrations are considered low.
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Given the findings of this Detailed Site Investigation RPS concludes that although site activities may have led to very minor localised increases in metal and inorganic parameter concentrations, the concentrations detected are considered acceptable for an industrial facility and are not considered to pose a risk to the environment and or human health.
RPS recommended that no additional intrusive works or remediation measures are considered necessary.
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Social knowledge base
This section outlines the current understanding of social aspects that may be relevant to the development of closure strategies.
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18. Heritage Values
Several studies and reviews of the Lease and surrounding areas have not revealed any heritage value of any nature. This is discussed further below.
18.1 Relevant Aboriginal groups
In compiling their 2011 Detailed Site Investigation, RPS conducted a search of the
Department of Indigenous Affairs, Aboriginal Heritage Inquiry System and found no indications of any Aboriginal Heritage Sites on the lease. This report is referenced within the Environmental knowledge base.
It is worth noting that this search was undertaken as an independent and current review as previous investigations by HIOps in 2002 and URS in 2011 arrived at the same conclusion.
18.2 Ethnographic values
There are no established ethnographic values associated with the HIsmelt Lease or the adjoined properties which is in keeping with its industrial zoning status.
18.3 Archaeological sites
Several independent investigations performed over the tenure of the lease have not revealed any archaeological sites or interests. This is to be expected as the area is zoned industrial by the government authorities and this aspect is likely to have been considered as part of the zoning process. Notwithstanding this, the project environmental management plan will be structured to include training for observance of archaeological artefacts and the management thereof.
18.4 Non-Indigenous cultural heritage values
The HIsmelt Lease has only been subject to developme nt since the mid 1950’s and the developments were of a basic and industrial use nature. Structures remaining on the
Lease are essentially modern / storage buildings which present no cultural heritage in terms of architecture or form. Further investigation in respect to cultural heritage was performed by RPS in their Detailed Site Investigation in 2011. RPS resolved that there were no listings pertaining to the site on the National Heritage Register for European
Heritage nor were there any listings with the Heritage Council of WA. This report is referenced within the Environmental knowledge base.
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19. Profile of local community
The HKJV sublease is located within the Kwinana Industrial “Strip” within the local government area of the Town of Kwinana and is located approx. 5 km from the Town
Centre. The Kwinana Industrial Area is a long-established heavy industrial zone. The closest residential area to the plant is approx. 3 km to the south-east.
19.1 Community sponsorship
HIsmelt have had an active community sponsorship programme, which has included sponsorship of the following programmes ( SKM 2006 ):
The Naragebup-Rockingham Regional Environment Centre: This is a not for profit centre owned and operated by the local indigenous Naragerbup community that aims to provide educational programs that promote the benefits of managing the environment in order to sustain quality of life. HIsmelt provided funding to the Naragebup-Rockingham
Regional Environment Centre for three years, which allowed Naragebup's Education
Office to expand. The relationship concluded in 2008 when HIsmelt went into Care and
Maintenance.
Cockburn Wetlands Education centre: The Cockburn Wetlands Education centre is located in the Beeliar Regional Park, and is managed by a committee comprised of representatives of the Wetlands Conservation Society, Bibra Lake Scouts, Friends of the
Cockburn and the local community. HIsmelt assisted with funding a part-time officer at the Cockburn Wetlands Education centre in 2005. The relationship concluded in 2008 when HIsmelt went into Care and Maintenance.
The Smith Family-Kwinana Learning for Life Program: HIsmelt Corporation, HIsmelt
Operations and the Rio Tinto WA Future Fund have committed more than $620,000 over three years to support The Smith Family – Kwinana Learning for Life program and its new
Grandparents Program. Learning for Life provides financial, personal and educational support for disadvantaged students in the local area, while the Grandparents Program provides a support network for grandparents who are the primary and secondary care givers to their grandchildren. In December 2008 the HIsmelt employees made their final contribution to the Smith Family. Since mid-2009, the Smith family have found additional local sponsorship and Rio Tinto Future Fund has become a 3 year sponsor.
The Real World Science Project initiative: HIsmelt and HIOps is a major sponsor of the
Real World Science Project, which aims to encourage students about science and lift the profile of science. The relationship concluded in 2008 when HIsmelt went into Care and
Maintenance.
General: HIsmelt also has a number of community partnerships. Information regarding the HIsmelt financial contributions to community groups has not been included in this document. Recent closure studies ( Onyx 2011 ) has indicated that sponsorship activity has steadily been reduced since 2008 to the point where there are no current funding commitments. Discontinuation of funding due to closure will not have any lasting impact.
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19.2 Synergies with the Kwinana Industrial Area
HIsmelt is a full member of the Kwinana Industrial Council (KIC), a business association that aims to promote co-existence of industry, the community and the environment in the
Kwinana Industrial Area.
There are currently 13 full members and 29 associate members in the KIC. Establishment and development of synergies with other industries in the Kwinana Industrial Area is encouraged by the KIC. The relationship was beneficial for HIsmelt as it has allowed them to access parts of Kwinana Industries Mutual Aid (KIMA) which provides emergency services to industry by utilising other business emergency response teams. It also has a bond with the Community Industry Forum (CIF) which allows community access to industry representatives.
The HIsmelt facility currently has the following synergies in place with other industries:
HIsmelt uses recycled water from the Water Corporation Kwinana Reclamation Plant;
Gypsum produced by flue gas desulphurisation was being transferred to Cockburn
Cement for use as a set modifier; however gypsum is currently not being produced; and
O2 and NO2 produced by Air Liquide are used in the HIsmelt process.
Whilst closure of the HIsmelt facility will impact on some of the KIC, industrial synergies, suppliers and customers, contractual undertakings which are in place with the suppliers will provide fair restitution.
HIsmelt will remain part of the KIC during deconstruction to enable access to both the
KIMA and CIF.
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20. Workforce
There are currently approximately 10 HIsmelt employees at HIsmelt with an approximate
50/50 mix of skills of technical and trade background involved in management and care & maintenance tasks.
The options for redeployment / reassignment of these employees are to: a) Move into the HIsmelt Research/Technology team, b) Move into other Rio Tinto/Rio Tinto iron ore businesses/operations, or c) Have their roles determined as redundant. a. Move into the HIsmelt Research/Technology team
There is no impediment to redeploying operational staff into the HIsmelt technology group, provided they had the required skill, competence and training to safely carry out the tasks assigned to them. Should the HIsmelt Plant or technology be redeployed / transferred to third parties, further opportunities for staff involvement is likely to be available.
This may occur by transferring the suited staff to undertake duties as required by the
HIsmelt technology group.
To the extent that there is the opportunity to undertake short or longer term international assignments, this may present as an attractive proposition for some employees. b. Move into other Rio Tinto/Rio Tinto iron ore businesses/operations
Since the commencement of Care and Maintenance, there have been offers made to employees of Hismelt Operations to transfer to other Rio Tinto and Rio Tinto iron ore businesses / operations. There has been a mixed response to motivating HIsmelt staff to transfer outside of Kwinana.
The attractiveness of the standard Rio Tinto Australia severance package combined with a buoyant labour market in Western Australia has meant that most employees offered roles on a FIFO or residential basis have declined to take these offers. This has been particularly the case for the employees in operator or trades roles.
Under the terms of the Rio Tinto Australia Redundancy Policy the application of severance packages offers can be avoided where an offer can be provided to the employee who has comparable alternative employment. Rio Tinto does not, however, have any other operations within a reasonable distance of Kwinana.
Most of the staff are in operator or trades roles, and are resident in the immediate vicinity or to the south of the Kwinana Plant site. It may not be an option to require employees to travel significantly greater distances to work than they were required to do when they were hired at Kwinana. c. Redundancy
In the event that RT iron ore could not arrange either of the options above at final closure, the final option would be to invoke the Rio Tinto Australia Redundancy Policy. RT iron ore have had significant experience in the application of this Policy at HIsmelt since March
2009.
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The process is as follows:
Ascertain and demonstrate the role(s) concerned are surplus to RT iron ore requirements. This includes potentially being able to show why particular employees were chosen instead of others.
Advise and consult with the employees concerned,
Ascertain if there were suitable employment options within RT iron ore or other Rio
Tinto businesses/operations,
If there were no suitable roles then there would need to be further discussions with the employees concerned and follow the processes set out in the Rio Tinto Australia
Redundancy Policy. This includes calculating the indicative severance payments/package, agreeing the timing with the employee around their departure from the business and offering outplacement, Employee Assistance Program (EAP) and similar support services.
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Stakeholder consultation
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21. Key stakeholders
The following key stakeholders have been identified. It should be noted that this list is dynamic, and that it will be developed in significantly greater detail as the site approaches closure:
Key Stakeholders
Rio Tinto;
HIsmelt Kwinana Joint Venture partners;
○ Rio Tinto Iron Ore
○ Nucor Australia
○ China Shougang International Trade & Engineering Organisation
○ MC (Mitsubishi Corporation) Iron and Steel
Australian Commonwealth Government;
West Australian Land Authority (WALA);
Fremantle Port Authority;
Air Liquide;
Wesfarmers Air Liquide Joint Venture;
Water Corporation of WA;
Department of Mines and Petroleum (DMP);
Environmental Protection Authority (EPA);
Department of Environment and Conservation (DEC);
Town of Kwinana;
Other Stakeholders
Kwinana Industrial Council
Tyco Water;
Cockburn Cement;
Department of State Development (DSD);
Department of Water (DOW);
Rio Tinto shareholders;
RT iron ore employees and contractors.
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22. Communication register
Table 4 documents communications undertaken to date that may be relevant to the development or implementation of closure strategies for the site.
Table 4 - Communication register
Title of communication
Date(s) Stakeholders Outcomes
Preliminary
Closure Plan
WA State Gov’t
JV Partner
Federal Gov’t
2006
9/2/11
10/2/11
Consultation with stakeholders was not undertaken for this plan, but will be undertaken for future closure planning plans.
Dept. of Mines
& Petroleum
The primary concerns of the DMP for the objectives would be:
Safety of the works
Compliance with the criteria of other agencies
Meet the DMP guidelines for closure
Nucor
Feb 2011 Invest Aust.
Summary of Nucor Position
Nucor wants the closure done quickly and cheaply
Nucor looking at developing a facility in Louisiana and are looking for some possible parts from HIsmelt, earlier than 2012
Nucor are happy with the study scopes presented, and may not attend the CSSC meeting in March
Advised of intentions to commence Closure planning
WA State Gov’t 10/2/11 Department of
Environment
&
Conservation
The primary concerns of the DEC for the objectives would be:
There should not be too many environmental issues from the DEC view. The licence already states it is nil emissions and nil discharges
For the deconstruction activity - will fall under the Town of Kwinana control, not DEC
Slag processing will be complete by mid-2011, then the operating licence would be revoked, as no further operations from site
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Title of communication
Date(s) Stakeholders Outcomes
Land Owner
Supplier
Stakeholder
Stakeholder
Land Owner
JV Partners
22/2/11
WA State Gov’t
14/3/11
16/3/11
16/3/11
16/3/11
21/3/11
22/3/11
Land Corp
Office of EPA
Air Liquide
WA
The primary concerns were:
Compliance to MS610
Consultation with stakeholders
Continuance of monitoring and reporting until closure implemented
Evidence submission to prove MS610 compliance
OEPA would need to approve the
Closure Plan before starting work
Completion Criteria will be needed
Discussion on needs from ALWA for closure and interactions. ALWA will need to plan removal of the plant.
Town of
Kwinana
Discussion on general aspects of Hismelt closure occurred as part of discussions for a separate lease.
Kwinana
Industry
Council
Discussed the closure and the ToK management of closure activities. The primary concerns were:
Who will be the next tenant
Need to involve Town Planning Dept.
Need to consult Development
Application Unit
Discussion advising of intentions. KIC feedback related to potential uses for the site and future plans for the Kwinana
Industrial area
Land Corp The primary concerns were:
Potential land use for James Point
Best to clear the site, as unsure what buildings are needed
Nucor
Mitsubishi
Shougang
HImet
Discussion on the scope of closure, the regulations pursuant in WA, formats for the study, budget and potential consultants to be utilised.
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Title of communication
Date(s) Stakeholders Outcomes
Land Owner
Stakeholder
Stakeholder
17/6/11
4/7/11
5/8/11
Land Corp
Town of
Kwinana
Fremantle
Ports
Discussions on closure objectives:
Prefer all HKJV installations be removed
Leave buildings that are safe if existed at start of lease
Contaminated soils review to use for start of next lease
Flat and stable site
The lease could be relinquished or reassigned
Discussion on the management of closure works:
Planning approval required for demolition
Include request for crushing concrete
Costs approx. $37k
Will require dust & noise management plans
Discussion on the navigation lights on the old BHP chimney. Confirmed they are no longer needed by the ports.
Stakeholders 5/8/11 Various Notification of the Heads of Agreement with
JSPL for possible relocation of steelwork in the plant.
Land Owner 29/8/11 Land Corp Progress update and discussion on future of the lease
Land Owner &
WA State Gov’t
6/9/11 Land Corp
DSD
Progress update and discussion on future of the lease
WA State Gov’t
13/9/11 Dept. of Mines
& Petroleum
Discussion on the management of decommissioning. DMP would continue to manage the site during the works.
Federal Gov’t
Land Owner
22/9/11
27/9/11
Invest Aust.
Land Corp
Discussion on third party access
Discussion on lease options and initial discussion on closure objectives / criteria
WA State Gov’t 3/10/11 Dept. of Mines
& Petroleum
Discussion on the Electrical aspects of the closure
Federal Gov’t
12/10/11 Invest Aust. Discussions on termination date for Deed
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Title of communication
Date(s) Stakeholders
JV Partners 15/12/11 Shougang
Nucor
Mitsubishi
WA State Gov’t
8/2/12 Land Corp
WA State Gov’t 23/2/12 OEPA
Outcomes
Update the JV partners on progress of the closure plan and sought approval to finalise the work for submission
Update on progress of the closure plan, discussions with potential future lease parties, clarification of items that would remain at lease handover and the management of works
Discussion on the submission of the Final
Closure Plan formats and timing, the salvage of items for resale, and early works.
Desired start date of July 2012 for main works.
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Post-Lease land use and closure objectives
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23. Post Lease land use
Due to the Department of Environment and Conservation ’s classification in 2004 of the
Lease being a “contaminated site – restricted use”, the Site is restricted to industrial and commercial land uses, excluding primary schools, childcare facilities and other sensitive commercial land uses.
Future land use will be defined and assigned by Land Corp as appropriate.
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24. Rio Tinto closure objectives
A consolidated list of RT iron ore closure objectives is presented in Table 5, with objectives 1 to 7 being standard Rio Tinto iron ore objectives, and 8 to 10 being specific
HIsmelt objectives. .
Table 5 - Closure objectives
No.
1
2
3
4
5
6
7
8
9
10
Objective
Preserve, protect and manage the cultural heritage values of the area, in cooperation with the Traditional Owners and other stakeholders
Develop and implement strategies for closure which consider the implications on local communities
Achieve completion criteria which have been developed with stakeholders and agreed with Government
Develop landforms that are safe and stable and compatible with the surrounding environment and post-mining land use
Achieve environmental outcomes that are compatible with the surrounding environment
Implement a workforce strategy which addresses the impacts of closure on employees and contractors
Achieve successful closure in a cost effective manner
The site to be left in a level, safe and stable condition and as an industrial block suitable for next use – zoned as a heavy special engineering site.
No change in the contaminated sites status of the lease due to impacts from the
RT and JV operations
Closure outcomes are effectively communicated to stakeholders
24.1 Description of objectives that apply to all RT iron ore sites
RT iron ore has developed a general vision for closure of all its sites. The closure vision contains seven closure objectives, as outlined below.
24.1.1 Cultural heritage values
Objective 1: Preserve, protect and manage the cultural heritage values of the area, in cooperation with the Traditional Owners and other stakeholders.
Rio Tinto’s iron ore group acknowledges the strong links that Traditional Owners have with their land, and respects Native Title claims and determinations.
This general objective is presented for alignment to general RT iron ore closure practices, however is not relevant to the HIsmelt site as described elsewhere in this report.
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24.1.2 Cultural heritage values
Objective 2: Develop and implement strategies for closure which consider the implications on local communities
The mining industry is a major employer in Pilbara communities. Closure of sites with residential populations can therefore have significant impacts on the local community.
Effective closure planning recognises these impacts and develops strategies to mitigate them.
This general objective is presented for alignment to general RT iron ore closure practices, however is not relevant to the HIsmelt site as described elsewhere in this report.
24.1.3 Completion criteria
Objective 3: Achieve completion criteria which have been developed with stakeholders and agreed with Government
Rio Tinto’s iron ore group has a general long term objective of relinquishing its sites to the
Government. However, this will not happen without achieving agreement on the completion criteria.
This closure plan provides the completion criteria that have been agreed with stakeholders during the Final Closure Plan process.
24.1.4 Safe, stable and compatible landforms
Objective 4: Develop landforms that are safe and stable and compatible with the surrounding environment and post-mining land use
Due to the nature of iron ore mining, it is not realistic to expect that landforms will be reinstated to pre-mining states. Assessment is therefore required to determine alternative landform configurations that achieve suitable outcomes at reasonable cost.
Compatibility with the surrounding environment and selected final land use is a key consideration.
Safety and stability are generally considered to be minimum requirements for final landforms. This does not mean that landforms will not erode, but that erosion rates are not significantly greater than for similar natural landforms, and do not compromise public safety or rehabilitation outcomes.
This general objective is presented for alignment to general RT iron ore closure practices, however is not relevant to the HIsmelt site as described elsewhere in this report. The safe and stable aspect for HIsmelt is the defining of an industrial block suitable for the next industrial application, and is agreed as a flat site sith remaining structures as agreed with the Land Owners.
24.1.5 Appropriate environmental outcomes
Objective 5: Achieve environmental outcomes that are compatible with the surrounding environment
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It is acknowledged that the act of land use will generally lead to localised loss of habitat.
Pre-use assessment of impacts and effective stewardship during operations will minimise the extent and significance of such losses, and ensure that regional biodiversity is not compromised.
In achieving environmental outcomes that are compatible with the surrounding environment, measures must also be taken to prevent unacceptable environmental pollution.
This general objective is presented for alignment to general RT iron ore closure practices, however is not relevant to the HIsmelt site as described elsewhere in this report. In the
HIsmelt context, the environmental outcomes relate to the re-established flora and fauna colonies, and the water contamination aspects, as described in this plan.
24.1.6 Workforce management
Objective 6: Implement a workforce strategy which addresses the impacts of closure on employees and contractors
Closure of any site has implications for site personnel, and for contractors that provide services to the site. In many cases, site closure will force personnel and their families to relocate.
Direct transfer to other sites will be a viable option for many employees. However, not all employees will be able to transfer to comparable positions at other mines. Other options, such as career changes within the company, redundancy or retirement may be applicable. The company needs to discuss available options with its employees to enable the most appropriate opportunities to be progressed.
Strategies are also required to facilitate a smooth transition for employees affected by closure. This includes provision of training opportunities as the site approaches closure and relocation assistance for those that require it.
Rio Tinto generally has no legal obligations to non-employee service providers upon closure of the site. However, the implications of closure on such providers will be considered where appropriate.
24.1.7 Cost effective closure implementation
Objective 7: Achieve successful closure in a cost effective manner
Cost effectiveness is an important consideration in the assessment of closure options.
Whilst it would be desirable to achieve the best possible environmental and social outcomes, the ability to do so may be limited by economic viability. Less expensive options may still deliver acceptable (but not necessarily the best) environmental and social outcomes.
A sustainable development approach is taken in the Rio Tinto closure planning process, whereby the social, environmental and economic implications of closure options are considered, and those which achieve the best overall outcomes are selected.
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24.2 Description of HIsmelt specific objectives
Several additional objectives have been drafted to take into account specific environmental and social values associated with the HIsmelt Lease area.
24.2.1 The site to be left as an industrial block suitable for next use
Objective 9: To leave the site in a level, safe and stable condition and as an industrial block suitable for the next use – zoned as a heavy special engineering site
This objective has been agreed with the Land Owner.
It is generally considered to be a minimum requirement for all final landforms to be safe and stable. In the industrial context and considering the surroundings of the Kwinana strip, this has been agreed to mean returning the site to a safe and stable industrial bock zoned as heavy engineering, this is consistent with the site usage since mid-1950s.
24.2.2 No change in contaminated sites status
Objective 10: To leave the site in a state where the pre-existing contaminated sites status is not degraded further due to impacts from the operations of RT iron ore and the HKJV
This objective has been agreed with the Land Owner.
The site has a history of industrial use and contamination has been found prior to the occupation of the current lessees, this objective recognises this legacy condition and the need to ensure that the future use of the site is not compromised due to the occupation of the HIsmelt operation.
24.2.3 Closure outcomes are effectively communicated
Objective 11: To ensure the closure outcomes are effectively communicated to all stakeholders
This objective has been agreed with the Land Owner.
This objective is to ensure the effective transfer of information to the relevant stakeholders upon requests for data.
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Assessment of closure options for the site
This section summarises the outcomes of an assessment of potential closure options to identify preferred closure strategies.
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25. The role of sustainability assessment in closure planning
Sustainable development aims to deliver more value with less impact. It occurs when social and environmental factors are considered in investment decisions.
The achievement of sustainable development principles is a stated aim of Rio Tinto and is relevant to RT iron ore closure planning. It is realistic to assume that closure will have some impact to the social and environmental context in the area. However, impacts can be minimised by selecting and implementing the most appropriate closure options.
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26. Sustainability assessment
In the case of HIsmelt operations, an assessment of the likely outcomes of Final Closure showed little option other than to sell the plant or parts of it, rather than sale insitu. These options were compared to total demolition and recycling of the waste. The greatest value was determined to be salvage for reuse of some items in the plant.
26.1 Assessed closure options
26.1.1 Option 1: Sale of Plant Insitu
Shortly after being placed in a care and maintenance state, options to transfer ownership to a third party with continuation of operations in Kwinana where sought out by HIOps on behalf of the HKJV. After over two years of solicitation, no parties with a viable interest were determined.
26.1.2 Option 2: Transferral of Plant and Technology Offshore
The HIsmelt technology has been researched and developed for over 15 years and Rio
Tinto is motivated to continue with this development to the point of demonstrated commercialisation. With no local interest in continuing the operation and development of the existing Plant in Kwinana, the HIOps turned their attention to offshore interests.
In August 2011 a Memorandum of Understanding was signed with Jindal Steel and
Power Ltd for the Plant (or its key components) and technology to be transferred to
Jindal’s Angul steel manufacturing site in India. In December 2011 Jindal advised that they no longer had a significant interest in the Plant.
26.1.3 Option 3: Selective sale of plant
This option incorporates the salvage of items of equipment of Jindal Plant for local sale.
The local sale will be for items that are readily transferable to non-HIsmelt operations, being such items as pumps and valves, etc.
HIsmelt is currently undertaking an engineering study into this option, which will be complete prior to the commencement of works for closure. This salvage work will only occur for items that can be reclaimed safely and economically.
26.2 Outcomes of the sustainability assessment
26.2.1 Assessment of economic factors
The assessment of economic factors showed that continuing existing operations in
Kwinana WA was not suited to an increased scale which was necessary to reduce supply costs needed to make the process economically viable.
Further the increasing cost of energy inputs from gas and electricity also placed pressure on the ongoing economic viability of operations.
Economic modelling has shown the viability of the process is best suited as part of an integrated steelworks facility. This does not exist in Kwinana.
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26.2.2 Assessment of environmental factors
The HIsmelt technology and the Kwinana Plant itself is a highly environmentally efficient facility relative to existing conventional world steel making facilities. The transferral of the technology to interests in developing countries with large steel production capability may assist in improving environmental outcomes. RT iron ore will continue to pursue this option in to the future.
26.2.3 Assessment of social factors
Whilst the continuation of operations in the Kwinana district would deliver social benefits as it has in the past, the placement of the Plant into a care and maintenance state has permitted a gradual removal from the developed social obligations thereby avoiding any sudden affect or impact. The buoyant West Australian economy has also meant the majority of HIsmelt employees have been able to find alternative work either within Rio
Tinto or externally. For this reason the closure of the Plant has had minimal social impact.
Should the Plant be relocated to a location such as India where the population is large and the country’s development status is still improving, the opportunity for social benefit is vast.
26.2.4 Consolidation of economic, environmental and social factors
The outcomes of the assessment clearly point to transferring and advancing the technology through license to a reputable steel producing company in a developing country.
The Plant itself is to be demolished and salvage of viable equipment maximised with the balance of materials scrapped for recycling or disposed of appropriately.
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27. Preferred closure option
Based on the outcomes of the sustainability assessment, the transferral of the Plant and
HIsmelt technology offshore combined with salvage of items for local sale is the preferred option
13
. It has been selected because:
There was no viable local interest in the plant sale in situ
There is minimal or no social impact on the local community or employees by closing the Plant
The proliferation of the HIsmelt technology to countries with environmental and social pressures provides global benefits
Following the removal of any valuable aspects of the Plant (above foundations), the remaining structures and fixtures would be removed by demolition and disposal with recycling of the waste materials maximised. The site would be formed to the agreed final landform, and the lease would be returned to the Land Owner for an industrial use site.
27.1 Other possible sustainability benefits
To complete the sustainability process for the HIsmelt Plant, HIsmelt Operations are and will continue to work with the Land Owner to incorporate any other infrastructure or assets developed in a way that will assist future industry.
An example of the MUI that has already been transferred to a third party is the raw materials stacker / reclaimer.
Other important and valuable infrastructure includes;
The KWRP pipeline (recycled water)
Gas metering and associated pipelines
Process water pipelines to the drainage pond used for recycling water
The raw materials stockpile yard and associated drainage infrastructure
The Contractor services and facilities provisions
The improved site drainage
Ground water monitoring wells
Several buildings and various car parks
Other opportunities also exist for future low volume product exporters via the integration with the adjacent Fremantle Port Facility of materials handling equipment.
13
It should be noted that a number of broad assumptions were made during the sustainability assessment regarding the economic, environmental and social implications associated with each option. If one or more key assumptions prove to be incorrect, a different closure option may be more favourable.
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Identification and management of closure issues
The DMP/EPA
Guidelines for Preparing Mine Closure Plans
identifies a number of issues for the closure of mines. Broad strategies for the management of these issues, and any others that have been identified for this site are documented in this section. Greater detail is provided in the management plans that follow in subsequent sections of this report.
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28. Potential closure issues
The DMP/EPA Guidelines for Preparing Mine Closure Plans identify several issues as relevant to mine site closure generally. These are provided in Table 6, and crossreferenced to a relevant RT iron ore management plan or strategy.
The company maintains integrated systems to manage environmental and social risks, and these will continue to apply following closure. Decommissioning studies and planning will be conducted and further developed as the site approaches closure. The implementation plans will be developed to sufficient detail to ensure that all issues are appropriately managed. It should be noted that RT iron ore operates numerous mines and sites, and will continue to do so when HIsmelt closes.
Table 6 - Issues relevant to HIsmelt site closure
Issue RT iron ore strategy or plan
Hazardous materials
Hazardous and unsafe facilities
Hazardous Waste Management Plan (RTIO-HSE-0018164)
Iron Ore Infrastructure Decommissioning Strategies
(RTIO-CR-0021242)
Contaminated Sites Management Plan (RTIO-HSE-0035253) Contaminated sites
Radioactivity Assessed as a low risk for RT iron ore operations
Fibrous Minerals Management Plan (RTIO-PDE-0062061) Fibrous (including asbestiform) minerals
Non-target metals and target metal residues in wastes
Mineral Waste Management Procedure (RTIO-HSE-
0040347)
Management of landform Final Landform Strategy (this report)
Adverse impacts on surface and groundwater quality
Water Strategy (this report)
Design and maintenance of surface water management structures
Water Strategy (this report)
Cleaner Air Management Plan (RTIO-HSE-0074373)
Biodiversity Strategy (this report)
Dust emissions
Flora and fauna diversity and threatened species
Visual amenity
Heritage issues
Final Landform Strategy (this report)
Heritage Strategy (this report)
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Closure implementation: final landform strategy
This plan documents a conceptual final landform configuration, and outlines how RT iron ore intends to achieve it.
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29. Process for selecting a final landform configuration
Consideration of final landform design is important at an early stage of project development, as it may influence critical operational design and implementation decisions. The process for developing a final landform configuration involves:
Identifying Rio Tinto closure objectives (Section 235) that may be relevant to final
landform design;
Developing potential landform design options that are consistent with the RT iron ore closure vision, and are likely to achieve relevant closure objectives;
Sustainability assessment of potential options to arrive at a preferred final landform
Stakeholder consultation to confirm that the preferred final landform configuration is likely to be acceptable; and
Modelling the effects of the preferred landform configuration on environmental systems.
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30. Closure Domains
For the Hismelt closure plan the domains have been defined in terms o f “Lots”.
These Lots have been set depending on the sub lease boundaries and the natural segregation of the lease areas according to their use. Reference to drawing DS-022 in
Appendix B illustrates the layout and definition of these Lots
These areas also isolate the legacy items.
30.1 Legacy items
The consultation process has included discussion associated with legacy structures, fixtures and infrastructure left by previous tenants. The table below summarises the status of key aspects to do with the final landform;
Table 7 - Recommended measures for final landform
Item
1
2
3
4
5
6
7
Category
General
BHP Legacy
Structures (Above and below ground)
Owner Agreed
Agreed
Agreed
Recommended Measures
All controlled substances and waste products (to do with the Plant and periphery) are to be removed from site
All Plant process materials and substances to be removed from site
Structures that are verified by a structural engineer to be safe and stable are to remain
BHP Clarifier Tank
BHP Redundant
Buried Services /
Structures
Pending
Agreed
Agreed
Although a legacy structure, it is recommended for enhanced safety for the structure to be drained, removed and the void filled with clean fill.
All pre-existing discovered structures and services that are known to HIsmelt or discovered are to be identified on basic marked up drawings to be supplied to the
Land Owner
To remain
BHP Legacy
Landform (fill, roads and car parks)
HIsmelt Pig Iron
Export Pad, conveyor and infrastructure
HIsmelt Eastern
Workshop
Pending
Pending
This facility developed by HKJV will be valuable to either the adjacent land user
Fremantle Port Authority – (FPA) or a future Lease tenant. This facility is in good and operable condition and currently integrated into the FPA
’s export system
This building is in good condition and provides a significant storage volume.
This would be an asset to the land Owner
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Item
8
9
10
11
12
13
14
15
Category
HIsmelt Admin,
Security & Training
Buildings
HIsmelt car park
Stockpile Yard
Drainage Pond and connected recycled water service system
KWRP Water
Service
Gas Hub and
Buried Gas Service
Owner Agreed
Pending
Agreed
Pending
Pending
Pending
Pending
Recommended Measures
These buildings are in good condition, modern and fully serviced. This would be an asset to the land Owner, (Built by Rio
Tinto during the time of the demonstration plant, which was prior to existing lease arrangement which commenced in 2002).
A large sealed carpark was developed by
HKJV adjacent to the north entrance of
Leath Rd. This presents as an asset to the
Land Owner and is likely to be useful for future land users
A large portion of the stockpile yard is sealed with bitumen, the balance is limestone hardstand. This presents as an asset to future land users as a storage area once completely cleared.
Note large portions of the facility have a subsoil drainage system in place, and to avoid ground water contamination, only inert materials should be stored in this area to avoid the risk of leaching.
Is used to collect runoff from the stockpile yard. If the land owner were to agree that the stockpile yard is to remain then this pond is likely to be required as well.
The pond was utilised to recycle water for process purposes and infrastructure remains in place which is in very good operable condition. This may present as an asset to a future land user.
This service line is of large supply capacity and in very good condition. It is owned by the Water Corporation but installed by
HKJV. This service supplies high quality recycled water to Kwinana industry and is considered an asset to the Land Owner with likely good potential for future use.
This service provided natural gas to the
HIsmelt Plant and is likely to be of future use.
HRDF Slag Landfill
HIsmelt drainage and sumps
Pending
Agreed
This material is a by-product and remnant from the HRDF Plant operations. It has been placed over similar material deposited by BHP to fill the land to a useful common contour. The RPS DSI indicates that it does not pose an environmental threat. Agreement should be sought to leave this in place.
Drainage system on the HKJV sublease to be removed and the sumps filled
16
17
HIsmelt
Contractors
Services
HIsmelt Plant
(above ground)
Pending
Agreed
Services for Contractor facilities were provided in a separable area. This includes a large sewage system, power and telecommunications. These services are of high capacity and may be useful for future land users.
To be removed entirely
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Item
18
Category
HIsmelt Plant
(below ground)
Owner Agreed
Agreed
Recommended Measures
To be removed entirely except piles below
2m depth
19
20
Contamination
HIsmelt Slag
Agreed
Pending
Identified BHP legacy contamination to be marked up on basic drawings and supplied to land Owner. This contamination is to remain
– undisturbed.
Based on RPS DSI September 2011, there is no HKJV remediation required.
The HIsmelt slag is inert and suitable for fill material of excavations previously occupied by the foundations
Currently being tested for Geotechnical and Geochemical properties
Agreements is being sought to utilise the material prior to importing fill material
Refer to Onyx Projects ’ Kwinana HIsmelt Plant, Removal of Concrete and Underground
Services, Detail Study Report November 2011 for work methods and estimates.
30.2 Final Landform Configuration
The HIsmelt site sits within a long-standing heavy industrial precinct. The site has in the past been largely cleared and levelled by previous tenants as well as current. Under the requirements of the existing lease, the RT iron ore must remove all additions and improvements, including services, unless otherwise agreed, fill any voids created and grade the site level along existing / natural contours.
A consultative process between RT iron ore and the Land Owner to agree the closure criteria is well progressed with tacit agreement received ( ref Land Corp, 02P056, 8
November 2011 ) however increased scope and definition is necessary to agree the final landform. This is important as the Lease Agreement which, if interpreted literally, would require the removal from the site of assets and infrastructure which presents significant value to the future industrial use of the land.
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31. Strategies for the remediation of specific domains
The entire HIsmelt lease has been segregated into remediation domains (Lots) of generally unique landform characteristics. Reference to drawing DS-022 in Appendix B illustrates the layout of these Lots.
For each Lot a Detailed Data Sheet has been prepared ( Onyx, Detailed Study November 2011 ) and which provides full scope of work details as well as highlighting the existing fixtures which are proposed to remain.
During the Onyx study, attention was given to discerning the fixtures and waste stockpiles that were left by the previous lease tenants. Generally there is clear and traceable evidence to show this, however waste stockpiled on the lease east of Leath Road is more difficult to apportion responsibility for, particularly as the depth of the stockpiles cannot easily be ascertained.
Notwithstanding this, the following can be summarised;
The previous lease tenant (BHP) stockpiled a large portion of waste in this area which was naturally low lying land. This includes general and industrial waste as well as blast furnace slag. A significant portion of this waste (the southern half) was capped by the Land Owner using limestone.
During the operations of the HRDF Plant, blast furnace slag was added over the top of the BHP waste primarily in the northern half. The depth of the addition is not readily determinable however the full depth by both depositors is known to be around 3m.
During the operations of the current HIsmelt Plant, further waste has been placed on the surface (primarily iron skulls) in this area albeit in significantly lesser quantity.
As the land fill (slag) waste product deposited has not been classified by the
Environmental Scientist (RPS) as constituting any hazard, and as it is of similar nature to earlier deposits previously accepted by the Owner, RT iron ore has proposed to the
Owner that this material be permitted to remain in situ.
The Owner has as a consequence requested Geotechnical and Geochemical testing of this material, the results of which has been summarised in section 15.2. Further details are included in Appendix E.
Strategies for the rehabilitation of the specific Lot domains are summarised in Table 8 below.
32.
Table 8 - Key characteristics of preferred final landform design
ITEM
ID
Item
RT01 Old Admin Training Offices
RT02 Waste Water Tank
RT03 Large Workshop - West
RT04 HIsmelt Warehouse - West
RT05 Weighbridge Building
RT06 Pig Iron Stockpile (Export Pad) Area
RT07 Eastern (KRT) Workshop
RT08 BHP Merchant Mill Shed
RT09 BHP Export Warehouse
LOT
ID
JV-1
JV-1
JV-1
JV-1
JV-1
Description
Remove and clear land
Remove and level land
Leave
Leave
Leave
RT-J Leave if agreed with Owner
RT-D Leave if agreed with Owner
RT-M Leave
RT-L Leave
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32. ITEM
ID
RT15
RT16
RT17
Substation 3
HV Substation
Sealed Roads
Item
RT10 BHP Amenities, Office, Old Gatehouse
RT11 HIOps Admin Buildings
RT12 Security Office
RT13 Storm Water Drain Pond
RT14
RT18
Lease Land General
HKJV Plant & HIsmelt Sublease
LOT
ID
RT-N Leave
Description
RT-G Leave if agreed with Owner
RT-H Leave if agreed with Owner
RT-C Leave if agreed with Owner
All Lots Remove surface waste and stabilise
JV-2 Leave if agreed with Owner
RT-H Leave if agreed with Owner
All Lots Leave if agreed with Owner
JV-1 to
JV-4 incl.
Remove structures, fixtures, non-valuable infrastructure, wastes, fill and level land and stabilise surface as agreed with
Land Owner
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33 Proposed additional landform studies
As recent studies are current, detailed, and contain no recommendation for additional work and with no further activity planned to occur on the Lease, there is no requirement to undertake additional landform study work.
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33. General rehabilitation management strategies
The following documents outline generic approved rehabilitation strategies for RT iron ore businesses:
Landform Design Guidelines
14
: Outlines waste dump design principles;
Rehabilitation Handbook
15
: Provides guidelines on topsoil management, rehabilitation targets, revegetation and monitoring.
These strategies are referred to and applied where applicable by all RT iron ore driven business activities and therefore will be referred to for the HIsmelt Closure activities.
14
RTIO, Pilbara Iron Landform Design Guidelines , RTIO-HSE-0015708
15
RTIO, Rehabilitation Handbook, RTIO-HSE-0011608
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34. Progressive rehabilitation / remediation
RT iron ore aims to undertake progressive rehabilitation of sites when activity in those areas is scheduled to cease in order to:
Comply with Government’s expectations for progressive rehabilitation;
Build further internal expertise in relation to rehabilitation;
Validate assumptions made when developing closure strategies;
Effect a measure of dust control, as the footprint of disturbed land is reduced; and
Lessen the task at the point of closure.
The availability of land for rehabilitation is linked to the decommissioning plan. This section outlines the current planned timing of progressive rehabilitation, and documents the strategies to be employed for Lots that are scheduled for rehabilitation in the near future.
Testimony to this statement is the early establishment of bushland settings between the
Stockpile area and Administration area, and around the administration offices.
34.1 Current remediation schedule
An indication of the timing for rehabilitation of specific Lots is provided in Table 9, and is largely dependent on the timing of internal stakeholder approvals and government approvals. There are opportunities for earlier Lot handover however the land Owner has advised that it is not agreeable to a staged or partial hand-back process at this juncture.
Consultation with the Owner to date has indicated a preference for the Lease being returned as a single parcel. For this reason the remediation of many of the Lots has been scheduled to coincide to avoid re-work and increase work efficiency.
Reference to drawing DS-022 in Appendix B should be made for the location of Lots across the Lease.
Table 9 - Current rehabilitation schedule
Lot Indicative rehabilitation date
RT-A Sep 2013
Comments
RT-B
RT-C
Sep 2013
Sep 2013
Limestone capped area. Little work required and could be handed back early
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
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RT-D
RT-E
RT-F
RT-G
RT-H
RT-I
RT-J
RT-K
RT-L
RT-M
RT-N
JV-1
JV-2
JV-3
JV-4
Jan 2013
Jan 2013
Jan 2013
Dec 2013
Jan 2014
Apr 2013
Mar 2013
Mar 2013
Apr 2013
May 2013
May 2013
Feb 2013
Jul 2013
Nov 2013
Aug 2013
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
Will be one of the last Lots to be handed back as this Lot contains the administration building
Will be one of the last Lots to be completed as this includes the Contractor’s facilities
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
This Lot is currently being used by the FPA
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
This Lot is currently being used by Cockburn
Cement Industries
This Lot is currently being used by Cockburn
Cement Industries and Tyco
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
*Contains ASU Plant
Depending upon the agreed level of remediation required this Lot is likely to be available for early hand-back.
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* It should be noted that the ASU plant will remain in place unit March 2013 due to the requirements from ALWA. Therefore there will be a requirement to protect this area from damage during demolition of surrounding plant.
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35. Revegetation and surface stabilisation plans
35.1 General rehabilitation methods
Revegetation
The site is within an area that has been extensively cleared and used for industry over several decades. There were no areas of remnant vegetation remaining on the site that were cleared for the Project. The industrial lands upon which the HKJV site is located does not require the restoration of the site to its native / pre-industrial use condition. The lease once returned to the land Owner will likely continue to be used for heavy industrial purposes.
Despite this, revegetation programs were initiated after construction of the HKJV Plant was completed in 2005.
The key areas of this revegetation activity were along the east/west access road directly adjacent to the stockpile conveying systems. Irrigated by the clarified discharge from the site’s BioMax system, several dozen Eucalypts have been established for visual amenity and a dust buffer between the raw materials stockpile area and the Plant. Also, the grounds immediately surrounding the main site administration building has undergone revegetation, developed by planting using local endemic species of native vegetation.
Surface Stabilisation
As several areas of the Lease will be disturbed when structures are demolished and removed there will be a requirement to stabilise the surface until its future use is decided.
In order to reduce surface water run-off, stabilise the soils and reduce large volumes of windborne dusts from leaving the site, seeded hydro-mulching of the site has been recommended. The approach taken to stabilising the surface is to be developed further in the HIsmelt specific project environmental plan. This plan has been prepared as part of the detailed engineering study ( Onyx, November 2011 ) and this plan specifically addresses the management of surface erosion. Control measures include;
Avoiding clearing large areas at one time
Increasing clearing activities during the wetter months
Stabilising cleared areas progressively behind the work front
Utilising an appropriately specified seeded hydro-mulch
Surface stabilisation and rehabilitation is a topic of high priority as the Lease is prone to strong winds due to its close proximity to the coast.
Refer to Onyx Projects ’ Kwinana HIsmelt Plant, Removal of Concrete and Underground
Services, Detail Study Report November 2011 , Appendix H, HIsmelt Environmental
Management Plan .
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36. Strategies to achieve biodiversity objectives
The following site closure objectives are relevant to biodiversity management:
Achieve environmental outcomes that are compatible with the surrounding environment;
Avoid harm to habitat and the native ecology that has developed in recent years
36.1 Achieving appropriate environmental outcomes
Environmental Management for the site can be categorised into two aspects. Existing circumstances and those associated with the closure activities (primarily decommissioning).
Existing Circumstances
The “ HIsmelt Decommissioning Study Knowledge Base Report – Environment March
2011 ” for the HIsmelt Lease provides a good initial source of information in relation to the exposure, history, examination and contamination of the land. In particular this report summarises the extensive testing of soil and ground water that has occurred over time. It summarises that whilst the site is contaminated, levels are well below required Health
Investigation Level (HIL) limits. The report is centred towards pre-existing (baseline) circumstances and contamination of soils and ground water in particular. This is discussed in Section 18 of this report.
Decommissioning Activity Related
Upon commencement of Lease Closure and ultimately decommissioning, a new range of potential environmental impacts are introduced and will require specific management attention. These are summarised as;
Control of spills from hazardous fluid products such as process chemicals and hydrocarbons associated with the decommissioning equipment.
Control of hazardous and non-hazardous particulate matter. This includes dust generated through demolition activities, control of synthetic material fibres generally found in lagging and potential hazardous dust created through the removal of refractory. Investigation into the composition of flaking paints on some of the structures prior to removal to determine if they are lead-based is recommended as is investigation into any possible residual asbestos dusts in the same buildings. In addition, attention should be paid to the management of remnant dust, generally found at storage locations used for process products and chemicals.
Disturbance of controlled water flow paths and storage devices. In particular attention to the management of water flow from material stockpile locations whilst stored product or remnants remain.
Noise caused by demolition activities. In particular associated with concrete demolition.
Vibration disturbance. As an example caused by structures being demolished and falling to the ground
Nuisance caused to the public and local businesses by increased vehicular traffic to and from the Lease
Maximisation of the recycling of materials and management of waste generally
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Destruction of habitat. Several areas in and around the Lease have developed habitats and the influence of demolition on these habitats requires a managed approach. Examples are the nesting of sea birds on the lease or fire destruction of adjacent bush.
Greenhouse gas emissions
Heritage. This relates mainly to Aboriginal sites and / or artefacts, none of which have been identified in the Decommissioning Study.
A HIsmelt Environmental Management Plan has been developed ( Onyx Detailed Study
November 2011 ) and provides a structure for developing and controlling these management topics.
36.2 Avoiding harm to habitat and the native ecology
Over the years the Lease has generally recovered in some areas from its originally established state as cleared and barren land. This is particularly true for the north eastern portion of the lease east of Leath Rd and adjacent to the administration building.
The recovery of native flora, and the reduction of industrial activity in these areas, has permitted the migration of some native fauna species such as bandicoots, lizards, snakes and birds. Whilst it is entirely possible that these areas will be developed in future years, it is the intention of RT iron ore and the HKJV to avoid disturbing the native ecology wherever possible.
Risks to the disturbance have been considered in the closure pre-planning activities (risk studies and the preparation of environmental management plans) and have been articulated in the respective documents as part of the Detail Study ( Onyx, November
2011 ).
Key risks are;
General habitat destruction through access for demolition or clean-up activities
Creation of bush fire through closure activities
Direct impacts on ecology by demolishing structures (i.e. impact, vibration, dust, spills etc.)
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Water strategy
This water strategy addresses how RT iron ore intends to address the various water impacts at closure.
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37. Recycled water management strategies
37.1 Existing systems
RT iron ore understands the importance of managing water resources well to ensure conservation, quality and the avoidance of environmental impact.
During the HIsmelt lease tenure, RT iron ore and its partners ensured a robust ground water monitoring regime was in place and that engineering design of the Plant, as well as operational processes, were in place to prevent soil and ground water contamination.
Further, designs included systems to maximise the use of and recycling of Plant process water.
The ground water monitoring regime and changes thereto are discussed in Section 16.
The systems established to utilise and recycle Plant process water are valuable assets some of which also are associated with the Invest Australia, Multi User Infrastructure
(MUI). This infrastructure is of high capacity and in very good condition and by the very nature (and intent) of being MUI, would be suited to future land users. For this reason it would seem highly probable that the Land Owner could agree to maintain these systems intact subject to their being prepared for a period of non-use and protection. The alternative is that they are removed under the make-good requirements of the terms of the Lease.
The established water management systems are;
The Kwinana Water Recycled Pipeline (KWRP) which is a pipeline established to feed the Plant from the Kwinana industry recycled water system located external to the lease and managed by the Water Corp.
The stockpile yard drainage system and the associated lined drainage pond located east of HKJV sublease.
The recycled process water lines that were established to both feed surplus to the drainage / evaporation pond from the Plant (effluent treatment area) and draw from the same pond when re-use could be accommodated.
It is intended that the continuation of consultation and finalisation of the Lease detailed make-good scope with the Land Owner will resolve the Owner ’s intention for these systems.
37.2 Strategies for managing ground water quality
Section 16 of the report discusses the history of ground water monitoring that has occurred on the Lease to firstly establish a baseline and subsequently to observe changes.
This culminated in the Detailed Site Investigation ( RPS September 2011 ) which studied the existing circumstances in 2011 (3 years after Plant operations ceased) and reported the findings.
With the removal of any potential sources of contamination, and based on the reported recommendations by RPS, there is no apparent reason to continue ground water monitoring or undertake further analysis. This point is to be confirmed by the
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Environmental Protection Authority following submission of the closure report. The HKJV have agreed with the Land Owner that the monitoring will be maintained until the lease is handed over to either Land Corp or to a third party.
It is worth noting that there is at least 17 functional bores and monitoring wells across the
Lease. The locations are defined in the RPS DSI and it will be important to the Owner that these well points are protected and maintained for future use (particularly for continued ground water monitoring as the land progresses to alternative uses).
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38. Surface water management
38.1 Drainage management
Surface water and the drainage of the site have been considered and management measures are detailed within Onyx Projects ’ Kwinana HIsmelt Plant, Removal of
Concrete and Underground Services, Detail Study Report November 2011, Appendix H,
Environmental Management Plan.
In addition, the methodology proposed by Onyx ( Detailed Study, November 2011 ) to decommissioning the Plant and infrastructure, involved removing the HKJV developed drainage infrastructure last. At that time the site will be devoid of associated sealed catchment areas and surface water will be able to infiltrate the ground as would occur naturally otherwise.
Due to the topography of the lease, there is no risk of surface water “sheeting” or generating flow paths that will affect the adjacent land occupants.
It is worth noting that the developed lease drainage system comprises a network of past tenant legacy and newly developed aspects. This system is in good condition and functions well. Like much of the infrastructure discussed, the drainage system is likely to be effective for future land users depending upon how they intend to configure the site.
As such the Land Owner has agreed to leave this infrastructure in place as part of the
Lease specific completion criteria (section 43.4).
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39. Strategies to achieve water-related objectives
The following site closure strategies are relevant to water resources and have been proposed in the Lease closure Environmental Management Plan in relation to water use activities (e.g. dust suppression) to do with the decommissioning. These are:
Utilising existing stored water in the old clarifier tank (west side of lease)
Transferral of water from the Effluent Treatment Plant clarifier to the drainage pond for later use.
Utilising Kwinana industry recycled water provided by Water Corp and available on site
Supplementary supply from existing non-potable bores but which are classified as safe for agricultural use
There is no intention to draw water from potable mains supply.
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Strategies for closure aspects
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40. Strategies for the management of closure aspects
The following aspects are (or will be) addressed by generic strategies that apply to all RT iron ore mines and sites. Whilst draft plans have been prepared as part of the Detailed
Studies, the specific implementation plans will be further developed as the site approaches closure:
Decommissioning
16
;
Decontamination
17
;
Workforce management (to be developed); and
Communication and consultation (draft developed)
40.1 General Strategy
An important first step for the closure strategy is to have clearly defined the scope and objectives of all the key stakeholders. Consultation and criteria establishment are key processes for this purpose and are discussed in separate sections of this report. This is an essential starting point which forms the baseline from which the strategies are developed.
To develop the scope and criteria, a process of formulation from obligations in existing agreements and government requirements were collated with items identified during stakeholder consultation. For the purposes of previous studies and this report, the context of closure is to cease all operations on the Lease and to remove from the Lease all fixtures, buildings, facilities, structures, signs, chattels and services above the ground and below the ground. Where there is a continuity of a facility, structure or service below this level, then these will be removed to an agreed practical depth.
The definition includes the restoration of the land to its likely pre-development levels in a state free of rubbish and introduced contamination where such contamination and land restoration is defined by the requirements of the Land Owner. This is generally contained within the articles of the Lease agreement.
The concept for restoring the leased land involves processes staged as study, planning, approvals, decommissioning / de-energisation, demolition and land remediation. Of these staged aspects, only demolition requires discussion of options as this is where variation exists. Depending on the desired level of managed salvage value recovery, a few options are available, these range through;
No managed salvage or recovery of Lease assets (described as “ground zero” demolition)
Minimal recovery and salvage of Lease assets with minimal opportunity for return
Emphasis on recovery and salvage of Lease assets with reasonable opportunity for return
16
Iron Ore Infrastructure Decommissioning Strategies, December 2009, RTIO-CR-0021242
17
Contaminated Sites Management Plan, January 2007, RTIO-HSE-0035253
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Emphasis on Recovery Strategy
This is the strategy which will be adopted for decommissioning whereby following approvals, a Project Management team is established to complete and implement the management plans and schedule. Of these plans, a key aspect will be the tendering and award of two main contracts. These are;
Demolition works
Land wastes removal, rehabilitation, and stabilisation
There are likely to be several other contract works packages and these will be described in a project specific project Procurement Plan.
The demolition works which are specialised in nature are required to be awarded to a reputable ‘Class 1’ demolition contractor. Importantly the Execution Planning phase involves planning time to develop methods for demolishing the aspects and areas of the
HIsmelt Lease with particular attention to any complex structures. To do this well requires the involvement of a demolition specialist and a component of the Onyx Detail
Study for Plant Demolition ( Onyx – DS, April 2012 ) has included the involvement of such a contractor in the development of work method statements and the engineering approach for the demolition of the complex structures. These will become the template from which demolition activities will be planned and applied during the execution phase.
The recovery approach involves planning the removal of viable to recover equipment, by prioritising the removal of equipment assets with the highest return versus cost to remove ratio. This work would be undertaken prior to Plant demolition. Following this the strategy involves sequentially clearing the various areas of the Lease of all equipment situated above the foundations, sorting the materials into stockpiles of like constituents and processing these into sizes suited for safe transport off site for either salvage/recycling or as disposed waste.
Reinforced concrete foundations and buried services are then removed and it is suggested that this aspect of the works similarly fall within the demolition contractor ’s scope. The foundations would be broken into sizes safe for transport and there would be minimal processing occurring on site.
The second main contract for award will be land rehabilitation. This work is primarily controlled earthworks and is suited to contractors which own and operate the required earthmoving equipment. With the appropriate contractor management and oversight processes in place, there will not be a need to seek an environmental land rehabilitation specialist contractor for this work. This is based on the RPS Study which indicates there is no requirement for removing contamination due to the very low levels existing.
Notwithstanding this, general civil contractors with the experience in civil works would form part of the contractor prequalification criteria.
40.2 “Early Works” Decommissioning
Due to schedule constraints the entire HIsmelt lease cannot be relinquished at an earlier time unless the Land Owner is willing to except a partial hand-back scenario. Land Corp has indicated during consultation that this is not their preference.
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Therefore based on the availability of the substantial closure period, the works should ideally be managed to be performed progressively over the greater portion of time allotment. This will permit works to be let in small independent packages for which greater control can be afforded, and to minimise total manning levels on the lease at any one time. In respect to the latter this provides increased safety, reduced support needs, potentially higher productivity and lower industrial relations risks.
Performance of early works will be dependent on the correct approvals from the relevant parties and approval from the JV partners, and is intended to be the time prior to the
HKJV Plant demolition.
An area of the HIsmelt Lease, for which access is restricted, is the ALWA, ASU Plant which due to the sublease arrangement will not be available for final demolition and remediation until at least March 2013.
Subject to the Land Owner’s agreement for the retention of developed assets and infrastructure, the areas available for early works are to the west and east of the HIsmelt
Plant and comprise warehouse and other basic buildings. There would appear to be no impediment for removing these and as well as the pig iron stockpile facility as early works.
The most important aspect of early works on the HIsmelt Lease relates to the removal of wastes located above ground level. Much of this is benign however there are also identified stockpiles of controlled wastes. Whilst low in quantity, asbestos has been identified to exist in some legacy structures which are planned to remain. Should they be required to be removed this should be conducted by licensed contractors in advance of the main works particularly to avoid the potential for concerns of personal welfare by members of the project workforce.
Particular caution will also be required in the lease at the location of a previous power station (i.e. in the raw materials stockpile area – west side) during the execution planning phase; this is to confirm that no asbestos materials remain in the soil.
A detailed examination of the site has revealed the following deposits which are legacy sites and will remain or are recommended to be removed as early works;
Table 10 - Legacy Items
Item Waste Class
Legacy Items:
Mixed contaminated waste
Class 2 or 3
Location
Billet yard
Lot Ref
RT-L
Asbestos drain gutters Special Type 1
Oil Contaminated Soils
Septic System Sludge
Controlled
Waste
Controlled
Waste
Export warehouse and
Merchant Mill
RT-L
Cockburn
Vehicle Parking
RT-N
Mill Workshop
Toilets
RT-I
Quantity
2,500 m
3
20 m
3
*TBD
*TBD
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Item
To be removed:
Pond Sediments
Septic Tank Sludge
Waste Class
*TBD
Controlled
Waste
Location
HIOps Admin former septic system
Lot Ref
Drainage Pond RT-C
RT-G
Septic Tank Sludge
Controlled
Waste
BioMax Septics
Septic System Sludge
Septic System Sludge
Controlled
Waste
Controlled
Waste
Contractor
Amenities
Contractor
Offices Area
Refractory Linings
Hydrocarbon
Contaminated Soils
Controlled
Waste
Controlled
Waste
Billet Yard
Stack
Former Diesel
Tank Site
Hydrocarbon
Contaminated Soils
Controlled
Waste
*To be determined during execution phase.
Petrol/Diesel
Bowser
Location
JV-4
RT-H
RT-I
RT-M
JV-1
RT-N
Quantity
*TBD
*TBD
*TBD
*TBD
*TBD
30m
3
*TBD
*TBD
The Onyx Detailed Study revealed that there is a potential for a significant amount of blast furnace slag waste required to be removed if not approved by the Land Owner as suitable for fill material on site. If so, this will be scheduled to begin ahead of the other decommissioning activities and in particular before structural demolition works begin in order to reduce traffic and activity interaction.
Note there are no restrictions or approvals necessary for land remediation and general site clean-up activities. This work can be undertaken at any time and HIOps have begun a general waste removal program for this purpose during the care and maintenance operation.
40.3 Project Management
Project Management is scheduled to commence following receipt of Government
Approval and the draft Project Management Plans (ref Project Execution Plan in Onyx
Detailed Study November 2011 ) propose that the management be undertaken in two phases. These are;
The Execution Planning phase
The Execution phase
The earlier planning phase would be undertaken in the Decommissioning Engineer ’s head office followed by a mobilisation to site ahead of the Execution phase.
The organisational chart below illustrates a proposed integration of the Decommissioning
Engineer and Environmental consulting entities into the HIOps management team.
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Important to note is that there is likely to be several work packages or projects which will be undertaken as part of the entire lease closure. These are;
The decommissioning of the HIsmelt Rio Tinto Lease (broader lease)
The decommissioning of the Plant on the HIsmelt HKJV sublease
The decommissioning of the Plant on the HIsmelt ALWA sublease
The removal of foundations and in-ground services associated with the HKJV &
ALWA subleases.
RT iron ore is a key stakeholder in all of these packages and a single management entity with a structure consistent with the organisation chart below would be suited for coordination and cost efficiency.
Project Steering
Committee
PROJECT MANAGER
Hismelt
DECOMMISSIONING
MANAGER
Hismelt Operations
SUPPORT TEAM
Decommissioning
Engineer (EPCM)
PROJECT MANAGER
Environmental
Closure Consultant
Hismelt Facility
Security
Deconstruction
Security
LEADER
Admin &
Compliance
Officer
Environmental
Engineer
Safety Manager
Snr Engineer
/
Planner
Deconstruction
Superintendent
Deconstruction
Contractor
Admin Clerk
Materials Manager
Land Rehabilitation
Contractor
The HIOps integration is suggested to gain access to the site knowledge and the experience contained within the HIOps group. Where teams can integrate well, greater efficiency and outcomes in project delivery are gained. Ultimately this will yield improved safety, performance and cost benefits.
Obvious benefits that can be gained by leveraging the engagement of the existing HIOps resource base will be;
Site security
Established Emergency Response capability
Lease hazard knowledge
Experience with Owner process requirements and standards
Familiarity with the local Kwinana industry community and established protocols
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Access to general site and lease knowledge
Whilst the above organisation chart illustrates roles occupied by the Decommissioning
Engineer it is considered that some of these roles would be performed by any available suitably skilled HIOps employees.
A knowledge base document (Knowledge Base - Team Integration) has been prepared by HIOps for this purpose. Reference is to be made to this when preparing the final management team structure.
The alternative option is to adopt a traditional contracting model whereby clear hierarchy and separation exists between the various team entities.
The various management team roles are illustrated in the organisation structure and are representative of a typical structure. However one role for distinction is the role of
Materials Manager. This role is recommended as a means of probity for the control and documentation of materials and assets which leave the site and is necessary for quality assurance as a minimum. Should a steel salvage recovery option be adopted as part of the demolition process then this role will gain increased significance.
Roles and responsibilities for the above positions are described in section 8 of the Project
Execution Plan ( Onyx detailed Study, November 2011 ).
40.4 Process
The success of the project management is reliant upon a well-structured management system and comprehensive planning. The Project Management Plan is the foundation for this and the following plans have been developed in draft template form for this purpose;
Execution Plan
Safety
Environmental
Quality Assurance
Employee & Industrial Relations
Communications
Contracting / Procurement Plan
Traffic Management
Further key plans, particularly in Risk and Financial Control, as well as an additional tier of sub-plans, may be structured to support the above elements. These plans are to be finalised by the Decommissioning Engineer during the Execution Planning phase.
40.5 Management of Health, Safety and Environment (HS&E) Aspects
Previous sections have discussed the structure of management resources, the systems and the processes for the management of the Lease Closure. In order to complete the process of effectively activating the management strategy, the core requirements of the various plans and required outcomes (the key deliverables) need to be transferred via work processes and communicated at the work face to the executing teams.
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To do this, all work activities are to be indexed using a Work Breakdown Structure (WBS) and the various groups of activities will have work plans prepared for them that capture the requirements of the key deliverables. An example is the specification in the work plan of safety processes and steps associated with an activity to avoid personal injury or harm occurring. These work plans are described as Work Method Statements (WMS’s) and are assigned to the work activities by the level of complexity of risk associated with the activity. For this reason two standards (or templates) for WMS’s have been developed.
These are;
Basic WMS’s
Complex WMS’s
Each standard WMS provides a format for working through the activity process whilst addressing the key deliverable requirements assigned to the Closure project. This ensures that personnel engaged in performing the activity can undertake the task without having first read and understood all the project management plans in the entirety, as the essence of these – particularly for HS&E are articulated in the WMS’s.
WMS’s are developed in the first instance by a member of the project management team that has examined the engineering aspects of the work and performed a desk top analysis of the processes. These personnel will be familiar with the project management plans and the key deliverables and ensure these aspects are captured in the WMS. A process of secondary checking / verification using a more senior member of the project management team is included in the development phase of the WMS. The WMS is then finalised through communication and improvement of the detailed aspects via the collaborative involvement of the executing team members in a workshop forum.
Appendix D to this report includes an outline of the overall method proposed for demolition of the Plant with a focus towards the management aspects of HS&E. A basic and complex WMS have been included as part of this method to demonstrate the template proposed and the nature of work (i.e. complex or basic) to which they are applied.
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Development of completion criteria
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41. Completion criteria
41.1 What are completion criteria?
Completion criteria can be defined as the indicators used to determine whether closure objectives have been met. They are used to measure the success of closure implementation against objectives, and to facilitate relinquishment of the mining tenure.
RT iron ore aims to have completion criteria agreed with stakeholders prior to the site closure.
RT iron ore recognises that the process of developing criteria needs to commence early to provide clear performance goals for progressive rehabilitation conducted during the mine’s operational phase. It also provides some contingency in the event of unplanned closure.
41.2 Process for developing criteria
RT iron ore makes the following commitments with respect to the development of completion criteria:
Criteria will be linked back to closure objectives, and will enable assessment of whether each objective has been met;
Criteria will be measurable;
Stakeholders, including Government, will be engaged in the development and agreement of completion criteria as the site approaches closure; and
Completion criteria will be drafted and agreed with stakeholders as a component of a decommissioning study to be conducted when the site is five years from scheduled closure.
41.3 Lease specific completion criteria
Pursuant to the consultation process between RT iron ore and the Land Owner, broad completion criteria and objectives have been established as outlined in the following table.
Table 11 - Lease specific completion criteria
Agreed Closure Objectives
The site to be left in a level, safe and stable condition and as an industrial block suitable for the next use – zoned as a heavy special engineering site
Agreed Closure Criteria
Facilities installed by RT and the JV have been removed, excluding those items specifically stated as being acceptable to remain
For all existing facilities, structures, buildings and buried services that were existing prior to Rio Tinto and JV partners occupation of the site: o Original buildings have been assessed for structural integrity and shown to be safe and stable, and remain as is o Building improvements performed by RT and JV partners remain o All pre-existing facilities, structures, buried services, etc. that are discovered during the decommissioning study have been noted on drawings and provided to Land
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Agreed Closure Objectives
No change in the contaminated sites status of the lease due to impacts from the RT iron ore and HKJV operations
Agreed Closure Criteria
Corp
The facilities installed by RT and the JV partners have been removed: o Steel work has been removed in entirety o Concrete foundations and slabs have been removed where practical o The extra deep footings under the ALWA plant (pilings) have been cut off and removed at 2m below ground level o Buried services have been removed o The gas hub installed by RT and JV partners remains o The transformer / power upgrade remains o Roads / asphalt areas remain
Voids have been filled to create a level site
A reputable third party has undertaken a suitable contaminated sites assessment to compare the 2003 baseline contaminated sites status to the current status
This report demonstrates no change in the industrial site status
Closure outcomes are effectively communicated to stakeholders
Relevant reports have been provided to Land Corp including the contaminated sites report
A copy of the decommissioning study has been provided to relevant parties
Environmental Monitoring of the site has been maintained until Rio Tinto and the JV partners hand over the lease to another party (Land Corp or other)
The third party has assumed the environmental duties for the site
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Financial provision for closure
RT iron ore considers specifics of the closure cost estimate to be commercially sensitive information. Closure cost assumptions and calculations are contained in separate reports.
This section outlines the general process used to develop the closure cost estimate.
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42. Principles of RT iron ore closure cost estimation
Closure cost estimates are determined based on methods outlined in the Rio Tinto
Closure Standard and the Rio Tinto Accounting Policy.
Two closure costs will normally be developed:
A Present Closure Obligation (PCO) which is indicative of costs associated with closure of the site given its current footprint; and
A Total Project Closure (TPC) cost which predicts the cost (in current terms) associated with closure at the end of the life of the lease. The TPC includes areas that are not currently approved, but that feature within the life of lease plan and that are considered likely to be developed in the future.
The cost estimates consider the following components:
Decommissioning (i.e. removal of infrastructure)
18
;
Final landform construction;
Biodiversity management (i.e. revegetation);
Heritage management;
Decontamination;
Workforce management (i.e. training costs and redundancy payments)
19
;
Monitoring costs;
Costs associated with the development of a Final Decommissioning Plan;
Costs associated with undertaking a final shutdown of operations;
Allowance for failed rehabilitation or pollution that may necessitate rework of rehabilitation areas;
Assignment of indirect costs in accordance with Rio Tinto Accounting Policy; and
Inflation of the cost estimate by a 10% contingency factor.
Cost estimates have been prepared by Onyx as part of the Order of Magnitude and
Detailed Studies and were developed in the following areas;
Table 12 - Cost Estimate Aspects
Study
Order of Magnitude Study – HKJV Sublease
+/- 30% accuracy
Aspect
Removal of Plant, foundations and services via complete demolition.
Minimal attention to recovery.
Land restoration
18
The decommissioning cost estimate assumes that infrastructure will be demolished and removed from site to a certified landfill. Opportunities for salvage and recycling will be sought as the site approaches closure.
19
Workforce management costs will only be included in the TPC.
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Study
Order of Magnitude Study
– Rio Tinto Lease
+/- 30% accuracy
Order of Magnitude Study
– ALWA Sublease
+/- 30% accuracy
Detailed Study
– HKJV Sublease (includes
ALWA Sublease). Excludes Plant
+10% /- 15% accuracy
** Note above foundation structures and equipment removal costs were part of an agreement to be removed by a third party.
Detailed Study – Rio Tinto Lease
+10% /- 15% accuracy
Viability Estimate. Removal of Strategic Assets
+/- 30% accuracy
Aspect
Removal of above surface fixtures via complete demolition
Waste materials.
Removal of below ground services developed by RT or the HKJV.
Minimal attention to recovery.
Land restoration
Removal of Plant, foundations and services via complete demolition.
Minimal attention to recovery.
Land restoration
Removal of foundations only
Removal of services and in-ground infrastructure
Removal of waste materials
Increased attention to recovery.
Land restoration
Removal of above surface fixtures
Waste materials.
Below ground services developed by RT or the HKJV.
Increased attention to recovery.
Land restoration
Removal by engineered extraction of nominated Plant assets
Removal of Offgas Duct and Offgas Hood by engineered extraction
Removal by engineered extraction of ASU
Plant equipment and assets only.
Viability Estimate. Removal of ASU Plant
+/- 30% accuracy
Detailed Study Plant Demolition – HKJV
Sublease only.
+10% /- 15% accuracy
Net recovery value of viable equipment and assets
Demolition and removal of Plant structures
Recovery value of scrap metals
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42.1 Estimate Method and Assumptions
The estimate prepared for the Detailed Study is current and is within an accuracy of
+10% / -15%. The purpose of the closure cost valuation is to provide a clear understanding of the worst case financial exposure.
The key difference between the Detailed Study cost estimate and the previous Order of
Magnitude cost estimate is;
Originally the removal of the Plant was excluded from the scope due to a third party
(Plant purchaser) expressing an interest to purchase and remove
When the third party changed to salvage of parts of the plant, a value assessment was conducted on the salvage items
A further separate study was subsequently prepared to examine the cost of final salvage of items and detailed demolition of the remaining steel infrastructure
There has been more detailed examination applied to all aspects
The removal of concrete foundations and services at the ALWA sublease has been included
General lease clean-up requirements have been examined in detail and priced accordingly
The estimate has been prepared utilising proprietary estimation software and has been compiled in accordance with the Rio Tinto Closure Cost Estimating Guidelines. The following exclusion elements as set out in the study scope have been maintained;
Process equipment and associated infrastructure located on the Kwinana JV Sublease, as removed by others
The HV substation
The FPA Conveyor system
Funds that may be generated through opportunities of salvage or recycling have been kept separate.
Calculation sheets have been prepared by Onyx and are included in the Detailed Study report. These form an important aspect of the Basis of Estimate.
The Lot Detail Datasheets also in the Detail Study report provide the definition of scope for remediation across the Lease.
Note that for commercial reasons the actual estimate is contained in a separate referenced report. The estimate has been compiled on a ‘first principles’ basis utilising the anticipated schedule and resourcing described in the respective sections of this report.
Separate specialised Contractor quotations were sought to validate the estimate.
Reference to item 6.2.3 of the ‘ Rio Tinto Closure Cost Estimating Guidelines’ , “Owner’s
Costs”, articulates requirements for which no allowance has been made in the estimate.
These are;
Owner’s engineering and administrative staff during the closure period. Includes salaries, benefits, travel and accommodation, rent and running costs
Insurances, including those during plant closure, motor vehicle, public and professional liability
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Council rates and charges for the land during the closure and post-closure monitoring period
External consultants (except those mentioned above), including legal, HR, community, financial, etc.
Government fees, licenses, approvals etc.
Other costs associated with maintaining the Plant such as security services
The estimate has been prepared on current 2012 rates and an escalation examination has indicated an increase of 5% would be appropriate for a commencement of closure activities in 2013.
The final estimate of costs is dependent on the finalisation of closure criteria and as such a “worse case” scenario has been reported by Onyx
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Closure implementation
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43. Research actions
Closure planning is an ongoing process, and closure studies are periodically reviewed to maintain currency. The research actions outlined in Table 14 have been identified as having the ability to improve closure outcomes by:
Filling gaps in the knowledge base;
Validating assumptions made in this conceptual closure study; or
Predicting the impacts of closure strategy implementation.
Table 14 is unlikely to represent a complete list of research actions that will be undertaken prior to closure of the site. However; it does represent actions that are recommended prior to site closure (currently scheduled for 2012).
Table 13 - Research actions
Action
Characterisation of blast furnace slag properties for use as site land fill
Consultation and documentation of lease relinquishment scope with Owner, particularly to do with the retainment by the Owner of the developed assets
Review cost inputs at 6 month intervals
Consideration of works at the previous power station site for potential asbestos materials in soil
Timing
March 2012
March 2012
June 2012
Pre-execution
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44. Unexpected closure and temporary closure
The HIsmelt site has been on care and maintenance since December 2008. Accordingly the unexpected closure scenario has occurred.
As this is the Final Closure Plan there is no consideration of temporary or unexpected closure, as all aspects are detailed in this plan.
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Risk assessment
RT iron ore has undertaken an assessment to identify threats and opportunities associated with closure of the site.
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45. Risk assessment
As part of the Onyx closure studies, risk assessment workshops were held on May 17 th and October 5 th
, 2011 and were attended by RT iron ore personnel from the following operational areas:
Risk management;
Rehabilitation and closure;
Environmental;
Technical projects;
HIOps Management;
Aside from the risk assessment workshops, a desktop study was also undertaken by
Onyx in the Detailed Study Report ( Onyx, November 2011 ) to consider risks during closure execution. To this end both Rio Tinto corporate requirements and the closure execution exposures (particularly environmental and safety) have been considered.
A risk assessment report to do with Rio Tinto corporate review requirements prepared in accord with the associated procedure has been produced for internal review
20
. RT iron ore considers this risk assessment report to be confidential.
Other key closure execution risks have been captured in the Detailed Study Reports
( Onyx, November 2011 and April 2012 ). A total of 82 risks were assessed using the RT iron ore criterion and classification matrix and assessed using the Onyx assessment tool and scale. The results are summarised broadly in the charts below.
Detailed information in relation to the actual risks and associated controls are available in the Onyx Detailed Study Reports ( Onyx, November 2011 and April 2012 ).
The intent of the study of the execution phase risks is that it forms a reference from which the relevant project management plans are later developed during the project execution
20
Reference to risk assessment report (confidential report not for external distribution)
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phase and which are used to place in process the control strategies recommended from the study. The management plans will be instrumental for managing the identified execution risks.
It is noted that risks derived through the various studies are of a high order level and did not consider the day to day risks associated with the actual closure execution activities.
Rio Tinto has existing well developed and mandatory processes for this purpose. To this end a comprehensive program of risk management processes are employed on all Rio
Tinto managed projects.
45.1 Health and Safety Management Plan
As discussed in the previous section, closure execution risks are managed by purpose developed project management plans. As is typical, the prevalent risks are associated with safety and environment. Draft management plans were prepared during the Detailed
Studies ( Onyx, November 2011 )
The management of health and safety during the execution phase is to be undertaken by the project management team (Decommissioning Engineer) and systems and processes will conform to the Rio Tinto HSEQ management system.
For this purpose it is necessary that the Decommissioning Engineer prepare a detailed health and safety plan as part of the Project Management Plan suite to be employed in execution. Due to the high risk finding associated with on-site traffic movements, a separate Project Traffic Management Plan will also be prepared to support the safety plan.
The draft Health and Safety Plan established during the Detail Study provides a structure for a future more comprehensive plan. In particular it will be necessary to provide more controls to the demolition works elements. Competency requirements and protocols for the demolition work force are other elements which will be given particular consideration.
Similarly there is a requirement for a demolition contractor to prepare a reciprocating
Health and Safety and Traffic Management Plan. This plan must respond in greater detail to the same elements of traffic management, demolition activities, competency and training.
In developing the health and safety plans to the increased detail, the following are aspects of health and safety that are particular to the HIsmelt Lease and were distinguished in the risk management process previously discussed.
Possible residues of asbestos dust on or in the BHP legacy structures
Dust created by breaking refractory (note some refractory contains chromium 6 which is particularly hazardous to health)
Asbestos gutters and downspouts on old BHP legacy structures
Air borne fibres from lagging materials, and asbestos
Other product dust particles (e.g. ferrous, lime, magnesium etc.)
Possible lead-based paint flaking off steel
Traffic management
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Stored energy in demolished structures (e.g. springing metal)
Prevention of early collapse of weakened structures / components
Underground hazards of voids, services (known and redundant) and buried wastes
Working below or in proximity to HV overhead power lines
45.2 Environmental Management Plan
Upon commencement of Lease closure and ultimately deconstruction, a new range of potential environmental impacts are introduced and will require specific management attention. As with safety, the risk review process identified controls being required for the following;
Control of spills from hazardous fluid products such as process chemicals and hydrocarbons associated with demolition equipment.
Control of hazardous and non-hazardous particulate matter. This includes dust generated through deconstruction activities, control of synthetic material fibres generally found in lagging and potential hazardous dust created through the removal of refractory. Investigation into the composition of flaking paints on some of the structures to determine if they are lead-based is recommended as is investigation into any possible residual asbestos dusts in the same buildings. In addition, attention should be paid to the management of remnant dust, generally found at storage locations used for process products and chemicals.
Disturbance of controlled water flow paths and storage devices. In particular attention to the management of water flow from material stockpile locations whilst stored product or remnants remain.
Noise caused by demolition activities. In particular associated with concrete demolition.
Vibration disturbance. As an example caused by structures being demolished and falling to the ground or as part of concrete removal techniques
Nuisance caused to the public and local business by increased vehicular traffic to and from the Lease
Maximisation of the recycling of materials and management of waste generally
Greenhouse gas emissions
Heritage. This relates mainly to Aboriginal sites and / or artefacts. Whilst none have been identified in the Detail Studies and Investigations, preservation of possible artefacts remains a potential albeit low risk.
The project Environmental Management plan will be prepared for managing these key risk aspects.
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Closure monitoring and maintenance
This section outlines the likely features of the post-closure monitoring plan.
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46. Closure monitoring program
The primary purpose of closure monitoring is to assess whether closure objectives have been met for the site. The program will be finalised as the site approaches closure, and this current plan outlines the principles that will be employed rather than specific details.
46.1 Phases of monitoring
For the purposes of this plan, monitoring is assumed to be conducted in several phases including:
Baseline monitoring, which is conducted prior to operations commencement. Results that are relevant to closure are summarised in the environment knowledge base;
Operational monitoring, which occurs throughout the life of the lease. Results that are relevant to closure are incorporated in the environment knowledge base when it is reviewed from time to time;
Pre-closure monitoring, which occurs as the site approaches closure to provide a baseline against which closure performance can be assessed;
Closure monitoring, which is conducted during the period of active site closure
(assumed to be two years following the cessation of operations); and
Post-closure monitoring, which is conducted on an regular basis until either:
○ There is a demonstration that closure objectives have been met and that the site is able to be relinquished; or
○ Parameters being monitored reach a steady state.
This plan only considers pre-closure, and closure monitoring based on recommendations that no post closure monitoring is required ( RPS DSI, September 2011 ). Due to the nature of the Lease being land set aside for industrial use in an established industrial zoned precinct, it is likely to be re-leased and the next tenant will be required to continue with an environmental condition monitoring program. This has been agreed as part of the completion criteria for the site.
The requirement for post-closure monitoring will ultimately be decided by the Land Owner via their environmental agent – the EPA.
46.2 Expected monitoring program
The monitoring program will be finalised during development of a Final Decommissioning
Plan as the site approaches closure. However; the program could be expected to include components indicated in Table 15. The monitoring program will focus on measuring performance against indicative completion criteria.
The monitoring program will be sufficiently flexible to enable adjustments if results indicate that more or less monitoring is warranted at any particular phase.
In assessing the monitoring program, the EPA may make recommendations concerning what conditions, if any, should be imposed on the project in the event that it is approved.
Ministerial conditions commonly include a requirement to prepare and implement an environmental management plan (EMP) to control and monitor the environmental impacts of the project.
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The monitoring program shall include control measures in accordance with relevant standards. Monitoring is required to assess the effectiveness of these measures and for compliance purposes. The key objective being the monitoring program is to protect human health and the environment by ensuring that on-site management practices are adequate.
Table 14 Expected components of the closure monitoring program
Aspect
Erosion monitoring
Pre-closure
Phase
Active closure
Postclosure
*
Dust monitoring
Water quality monitoring
Contaminated sites assessment
*
*
*
* Hydrology/hydrogeology study
* = Conducted by Land Owner or new Lessee
Reference to the closure objectives and criteria agreed with the Land Owner and outcomes derived from table 15 will be used to support the compliance with the agreed aspects.
Active closure monitoring will continue until relinquishment of the lease to the Land
Owner. Post closure monitoring will be the responsibility of the Land Owner or new lessee, as per closure criteria stipulated in section 41.3.
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47. Post-closure maintenance
A final decommissioning report will be prepared by the Decommissioning Engineer prior to the final lease hand-over to the Land Owner. This will include any recommendations for future monitoring and maintenance, as well as providing the Land Owner with the lease land features at the time of closure (hand-back) including information to do with the discovered fixtures, infrastructure and waste that are the legacy from previous tenants.
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Management of information and data
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48. Management of information and data
RT iron ore group operates a comprehensive document management system, with electronic records of all key information and data. The document system, known as Iron
Ore Document Management System (IODMS) is linked to other business units within the
Rio Tinto group of companies, and processes are in place to ensure that the data contained within this system is appropriately backed up and protected. Each document stored within this system is given a unique document number which identifies the document and enables it to be accessed. This system will continue to operate following site closure, and all relevant data will be retained accordingly.
An audit will be conducted prior to closure to ascertain whether there is any additional information stored in hard copy form at the site. Such data will be scanned and entered into the appropriate electronic database system to ensure that it is appropriately retained.
Hard copies of confidential information stored at the site (such as employee records) will be destroyed at the time of closure.
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Appendices
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APPENDIX A – DOCUMENT REFERENCE
Document Description:
Rio Tinto STCLO_D4 V4 Closure Standard
– October 2010
Guidelines for Preparing Mine Closure Plans June 2011 - EPA
SKM – Preliminary Closure Planning Study (2006)
Kwinana HIsmelt Plant – Order of Magnitude to Decommission Study Report – June 2011 (Onyx
Projects)
Kwinana HIsmelt Lease
– Order of Magnitude to Decommission Study Report – June 2011
(Onyx Projects)
Air Liquide HIsmelt Air Separation Unit
– Order of Magnitude to Decommission Study Report –
June 2011 (Onyx Projects)
Kwinana HIsmelt Plant Removal of Concrete and Underground Services – Detail Study Report –
November 2011 (Onyx Projects)
Kwinana HIsmelt Lease Decommissioning Study – Detailed Study Report – November 2011
(Onyx Projects)
Detailed Site Investigation HIsmelt Facility Extended Lease Area
– Sept 2011 (RPS)
Knowledge Base
– Team Integration (J Wilks – Oct 2011)
Rio Tinto Closure Standard, RTIO-HSE-0020698
Mining Act 1978 (WA)
Land Administration Act 1997 (WA)
HIsmelt Knowledge Base Report - Environmental
HIsmelt Knowledge Base - Financial
HIsmelt Knowledge Base - JV
HIsmelt Knowledge Base - Legal
HIsmelt Knowledge Base - Operations
HIsmelt Knowledge Base - Social
Document Description:
Generic Closure Obligations, draft report for discussion, Freehills - 16 July 2008, RTIO-CR-
0016834
Environmental Protection Act 1986 (WA)
Iron Ore (Yandicoogina) Agreement Act 1996 (WA)
Contaminated Sites Act 2003 (WA)
Australian climate change projections derived from simulations performed for the IPCC 4 th
Assessment Report, Aust. Met Mag (2007) 131-152
Global Acid Rock Drainage (GARD) Guide
RT iron ore, Pilbara Iron Landform Design Guidelines, RTIO-HSE-0015708
RT iron ore, RTIO(WA) Spontaneous Combustion and ARD (SCARD) Management Plan for
Operations, RTIO-HSE-0010872
RT iron ore, Rehabilitation Handbook, RTIO-HSE-0011608
Iron Ore Infrastructure Decommissioning Strategies, December 2009, RTIO-CR-0021242
Contaminated Sites Management Plan, January 2007, RTIO-HSE-0035253
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APPENDIX B - DRAWINGS
1 DS-000 Full HIsmelt Lease with HKJV Lease and Air Liquide (ALWA) Sub-lease
2 DS-008 Possible Areas of Contamination
3 DS-022 HIsmelt Lease Remediation Lot Layout
4 DS-028 Local Area Land Use
5 DS-031 HKJV Plant Areas
6 DS-032 HKJV Lease
7 DS-033 Buildings, Fixtures, Infrastructure
8 DS-034 HKJV Responsibilities on the HIsmelt (RT) Lease
9 DS-035 Previous Indications of Asbestos Contamination
10 KWIN1-00-AH-00-008 Rev 1 HIsmelt Plant Critical Services Plot Plan
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126
127
128
APPENDIX B
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130
131
132
133
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APPENDIX C - ENVIRONMENTAL MANAGEMENT PLAN
APPENDIX D – HSE METHODOLOGY
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APPENDIX E – RPS REPORT
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