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Collie Urea ProjectShotts Industrial Park, Shire of

Collie & Port of Bunbury

Perdaman Chemicals and Fertilisers Pty Ltd

Report 1358 May 2010

Environmental Impact Assessment Process Timelines Date

Progress stages

Time (weeks)

14/04/09

Level of Assessment set (date appeals process completed)

28/09/09

Proponent Document Released for Public Comment

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24/11/09

Public Comment Period Closed

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18/12/09

Proponent provides response to the issues raised.

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18/03/10

EPA report preparation.

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20/04/10

Proponent provides additional information requested by the EPA.

5

05/05/10

EPA report to the Minister for Environment

2

10/05/10

Publication of EPA report

1

24/05/10

Close of appeals period

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ISSN 1836-0483 (Print) ISSN 1836-0491 (Online) Assessment No. 1784

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Summary and recommendations This report provides the Environmental Protection Authority’s (EPA’s) advice and recommendations to the Minister for Environment on the proposal to establish a urea production plant in the proposed Shotts Industrial Park, 7.5 kilometres (km) east of Collie, by Perdaman Chemicals and Fertilisers Pty Ltd (Perdaman). The plant would process coal mined from the Griffin coal mine north of the Shotts Industrial Park into urea which would be transported by rail to Bunbury Port for export (See Figures 1 and 2). Elements of the project would consist of the urea production plant; a coal conveyor (approximately 8.5 km in length) linking the plant and coal mine; a water supply pipeline (approximately 7 km in length, linking with the Water Corporation’s 26 km pipeline from Wellington Dam); a wastewater pipeline to the Collie Power Station (approximately 5 km); a rail spur connected to the existing rail network; and a storage shed and shiploading facilities at Bunbury. Section 44 of the Environmental Protection Act 1986 (EP Act) requires the EPA to report to the Minister for Environment on the outcome of its assessment of a proposal. The report must set out: • The key environmental factors identified in the course of the assessment; and • The EPA’s recommendations as to whether or not the proposal may be

implemented, and, if the EPA recommends that implementation be allowed, the conditions and procedures to which implementation should be subject.

The EPA may include in the report any other advice and recommendations as it sees fit. The EPA is also required to have regard for the principles set out in section 4A of the EP Act.

Key environmental factors and principles The EPA decided that the following key environmental factors relevant to the proposal required detailed evaluation in the report: 1. vegetation and fauna habitat; 2. water supply; 3. air quality; 4. greenhouse gas; 5. noise emissions; and 6. wastewater disposal. There were a number of other factors which were relevant to the proposal, but the EPA is of the view that the information set out in Appendix 3 provides sufficient evaluation.

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Figure 1: Shotts Industrial Park - Location Map.

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Figure 2: Collie Urea Plant Site – Environmental Constraints.

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The following principles were considered by the EPA in relation to the proposal: (a) The precautionary principle; (b) The principle of intergenerational equity; (c) The principle of the conservation of biological diversity and ecological

integrity; (d) Principles relating to improved valuation, pricing and incentive mechanisms;

and (e) The principle of waste minimisation.

Conclusion The EPA has considered the proposal by Perdaman Chemicals and Fertilisers Pty Ltd to construct and operate a urea production plant in the Shire of Collie, and to transport the urea produced by rail to Bunbury Port for export. The proposed urea plant would be constructed within part of the proposed Shotts Industrial Park, 7.5 kilometres east of Collie. The EPA notes that while the Collie Urea Plant would be a minor contributor to the Collie airshed, the fact that there are predicted exceedances means the EPA’s objectives for this factor will only be met provided the emissions from Muja A/B are appropriately addressed during its refurbishment. The Collie Urea Plant would be a significant emitter of greenhouse gases and with the continued uncertainty over a Commonwealth carbon market, the EPA has recommended greenhouse gas abatement conditions addressing carbon capture and storage. In relation to noise, the EPA notes that the Shotts Industrial Park will have five development areas available. To prevent the Collie Urea Plant from constraining future industries within the Shotts Industrial Park, the EPA has recommended a condition specifying noise criteria at the buffer boundary. The EPA has concluded that it is unlikely that the EPA’s objectives would be compromised, provided there is satisfactory implementation by the proponent of the recommended conditions set out in Appendix 4, and summarised in Section 4.

Recommendations The EPA submits the following recommendations to the Minister for Environment:

1. That the Minister notes that the proposal being assessed is for construction and operation of a urea production plant in the proposed Shotts Industrial Park, 7.5 kilometres east of Collie, and for transport of the urea produced by rail to Bunbury Port for export;

2. That the Minister considers the report on the key environmental factors and principles as set out in Section 3;

3. That the Minister notes that the EPA has concluded that it is unlikely that the EPA’s objectives would be compromised, provided there is satisfactory implementation by the proponent of the recommended conditions set out in Appendix 4, and summarised in Section 4, including the proponent’s commitments;

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4. That the Minister imposes the conditions and procedures recommended in Appendix 4 of this report; and

5. That the Minister notes the advice contained in Section 5 of this report on the need for a “Collie Basin Environment Strategy” and advice regarding Greenhouse Gas emissions.

Conditions Having considered the information provided in this report, the EPA has developed a set of conditions which the EPA recommends be imposed if the proposal by Perdaman Chemicals and Fertilisers Pty Ltd to construct and operate a urea production plant in the proposed Shotts Industrial Park, 7.5 kilometres east of Collie together with the required infrastructure within corridors; and to transport the urea produced by rail to Bunbury Port for export is approved for implementation. These conditions are presented in Appendix 4. Matters addressed in the conditions include the following:

(a) the replacement of Black Cockatoo nesting trees which are removed during construction with artificial nesting boxes on a six-for-one basis;

(b) limiting noise emissions from the urea plant to allow room for other industrial users of lots in the Shotts Industrial Park;

(c) confirmation of air emissions to the Collie air-shed, including odour due to hydrogen sulphide;

(d) reporting on progress made towards the implementation of carbon capture and storage (CCS), retrofitting of CCS within five years of the technology becoming economically and technically proven, and preparation of a greenhouse gas abatement report; and

(e) orderly decommissioning of plant and equipment, and rehabilitation of disturbed areas.

Contents

Page Summary and recommendations.................................................................................i

1. Introduction and background.............................................................................1

2. The proposal .........................................................................................................1

3. Key environmental factors and principles.........................................................4

3.1 Vegetation and fauna habitat .....................................................................5

3.2 Water supply ............................................................................................10

3.3 Air quality ................................................................................................11

3.4 Greenhouse gas emissions .......................................................................14

3.5 Noise emissions .......................................................................................16

3.6 Wastewater disposal.................................................................................19

3.7 Environmental principles .........................................................................20

4. Conditions...........................................................................................................20

4.1 Recommended conditions........................................................................20

5. Other Advice.......................................................................................................21

5.1 Collie Basin Environment Strategy .........................................................21

5.2 Greenhouse gas emissions .......................................................................21

6. Recommendations ..............................................................................................22

Tables

Table 1: Summary of key proposal characteristics .......................................................2 Table 2: Maximum allowed noise contributions from individual development areas in

order to meet a cumulative noise level of 35dB(A) at the Shotts Buffer.....18 Figures Figure 1: Shotts Industrial Park - Location Map. Figure 2: Collie Urea Plant Site – Environmental Constraints. Figure 3: Vegetation Priority Areas. Figure 4: Cockatoo Feeding and Potential Breeding Areas.

Appendices 1. List of submitters 2. References 3. Summary of identification of key environmental factors 4. Indentified Decision-making Authorities and Recommended Environmental

Conditions 5. Summary of submissions and proponent’s response to submissions

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1. Introduction and background This report provides the advice and recommendations of the Environmental Protection Authority (EPA) to the Minister for Environment on the key environmental factors and principles for the proposal by Perdaman Chemicals and Fertilisers Pty Ltd (Perdaman), originally North West Chemicals and Fertilisers, to construct and operate a urea production plant in the Shire of Collie, and to transport the urea to Bunbury Port for export. Perdaman proposes to establish a urea production plant in the proposed Shotts Industrial Park, 7.5 kilometres (km) east of the town of Collie. The Shotts Industrial Park is being established by LandCorp to accommodate a total of five industrial sites of which the site of the urea plant would be the largest. Perdaman would lease the 124 hectares (ha) site from LandCorp. The urea plant would process coal mined from the Griffin coal mine north of the Industrial Park to urea which would be transported by rail to Bunbury Port for export. Annual production would be nominally 2.1 million tonnes, being a rate of approximately 6,200 tonnes per day. The project is being formally assessed due to the plant’s contribution to the Collie airshed, which may be approaching its capacity with respect to certain parameters/pollutants, and due to the plant’s significant demand for supply water and for the disposal outside the Collie area of wastewater produced during urea manufacture. Further details of the proposal are presented in Section 2 of this report. Section 3 discusses the key environmental factors and principles for the proposal. The environmental conditions to which the proposal should be subject, if the Minister determines that it may be implemented, are set out in Section 4. Section 5 provides ‘Other Advice’ by the EPA and Section 6 presents the EPA’s Recommendations. Appendix 5 contains a summary of submissions and the proponent’s response to submissions, and is included as a matter of information only and does not form part of the EPA’s report and recommendations. Issues arising from this process, and which have been taken into account by the EPA, appear in the report itself.

2. The proposal Perdaman Chemicals and Fertilisers Pty Ltd (Perdaman) proposes to establish a urea production plant in the proposed Shotts Industrial Park, 7.5 km east of Collie. The plant would process coal mined from the Griffin coal mine north of the Shotts Industrial Park into urea which would be transported by rail to Bunbury Port, 55 kilometres to the west, for export. Annual production would be nominally 2.1 million tonnes, being a rate of 6,200 tonnes per day. Elements of the project would consist of the urea production plant; a coal conveyor (approximately 8.5 km in length) linking the plant and coal mine; a water supply pipeline (approximately 7 km in length, linking with the Water Corporation’s 26 km

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pipeline from Wellington Dam); a wastewater pipeline to Verve Energy’s Collie Power Station (approximately 5 km); a rail spur connected to the existing rail network; and a storage shed and shiploading facilities at Berth 5, Bunbury Port. A draft Environmental Scoping Document (ESD) was submitted on 19 May 2009. The ESD was endorsed on 23 July 2009 (EPA meeting). The Public Environmental Review (PER) was released for public review for eight weeks from 28 September 2009 until 24 November 2009. Fifteen submissions were received to which the proponent provided responses in Public Environmental Review - Supplement and Response to Submissions on 18 December 2009. The key characteristics of the proposal are summarised in Table 1 below. A detailed description of the proposal is provided in Section 4 of Perdaman Chemicals and Fertilisers, Collie Urea Plant Public Environmental Review, September 2009. Table 1: Summary of key proposal characteristics

Element

Description

Collie plant site

Gasification plant 2.7 Mtpa of coal. Ammonia plant 3,500 tpd nominal capacity. Urea plant 6,200 tpd nominal capacity, granulated

product (Nominal 2.1 Mtpa). Plant site area Up to 124 ha of which not less than 20 ha

will be left vegetated. Coal stockpile Up to 370,000 tonnes. Ammonia storage Not more than 10,000 tonnes capacity in

refrigerated double-skin tank. Urea storage (plant) 100,000 tonnes maximum capacity, in fully

enclosed shed.

Bunbury Port Urea storage (port) 100,000 tonnes maximum capacity, in fully

enclosed shed. Urea shiploading system Travelling, (covered) conveyor-fed,

cantilever arm loader, with direct discharge to ship’s hold via chute.

Shipping frequency (urea) Up to 100 movements per year.

Inputs Coal Up to 2.7 Mtpa. Water Up to 12.0 GL/year from various Collie

Basin sources. Limestone Up to 150 ktpa. Urea formaldehyde Up to 10 ktpa (as UF 85). Power supply Total internal generation: 220MW Combined

cycle gas turbine. [130MW - gas turbine; 90MW – heat recovery steam turbine].

Energy efficiency Not less than 24 GJ/t urea (LHV).

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Element

Description

Materials transport

Coal conveyor 8.5 km approximate length, covered and mainly above ground.

Other products

Sulphur recovered (bio-sulphur) Up to 45 tpd. Slag (non-leaching) Up to 900 tpd - initially for mine backfill.

Wastes

Saline water - disposal via existing Collie Power Station saline pipeline to sea.

Not more than 3 Mlpd.

Abbreviations GJ/t gigajoules per tonne GL gigalitres (109 litres) GL/yr gigalitres per year ha hectares ktpa kilotonnes per annum

LHV lower heating value MLpd megalitres per day Mtpa megatonnes per annum MW megawatts tpd tonnes per day

The potential impacts of the proposal initially predicted by the proponent and described in the PER document and its Appendices and Supplement (See below) and their proposed management are summarised in Table i, Environmental Impact and Management Commitments, Executive Summary (page xii) of the proponent’s PER document. Since release of the PER, modifications to the proposal have been made by the proponent which include the following:

• Water Supply Pipeline

The proponent has reached in principle agreement with the Water Corporation to enable Perdaman to access the existing Wellington Dam off-take and pipeline to supply water to the urea plant. This avoids the need to construct a new pipeline from the dam and the associated corridor disturbance activity.

Of the 33km distance between the dam and the Industrial Park, new pipeline would be required for only seven kilometres north-west from the Shotts Industrial Park to connect to the existing pipeline. No construction would be required within the Wellington Dam National Park. Construction of the pipeline would be within existing cleared transmission line easements and would only require clearing of re-growth vegetation of less than five years in age.

• Wastewater Disposal

The proponent has reached in principle agreement to access the Verve Energy Collie Power Station pipeline for disposal of 3ML/day of wastewater.

• Odour Management The proponent used an incorrect odour criterion in the PER, thereby underestimating the potential odour impact of the urea plant.

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To address this and reduce odour emissions, the proponent will incorporate additional pollution control technology, by inclusion of a treatment stage to the low pressure vent stream from the Paques sulphur recovery unit. This would comprise a guard bed and catalyst which would in effect act as a filter. The proponent thereby intends to reduce hydrogen sulphide (H2S) emissions from the originally planned 20tpa to 8tpa.

3. Key environmental factors and principles Section 44 of the Environmental Protection Act 1986 (EP Act) requires the EPA to report to the Minister for Environment on the environmental factors relevant to the proposal and the conditions and procedures, if any, to which the proposal should be subject. In addition, the EPA may make recommendations as it sees fit. The identification process for the key factors selected for detailed evaluation in this report is summarised in Appendix 3. The reader is referred to Appendix 3 for the evaluation of factors not discussed below. A number of these factors, such as hazardous materials, transport, Aboriginal and European heritage, and amenity, are relevant to the proposal, but the EPA is of the view that the information set out in Appendix 3 provides sufficient evaluation. It is the EPA’s opinion that the following key environmental factors for the proposal require detailed evaluation in this report:

1. Vegetation and fauna habitat;

2. Water supply;

3. Air quality;

4. Greenhouse gas;

5. Noise emissions; and

6. Wastewater disposal. The above key factors were identified from the EPA’s consideration and review of all environmental factors generated from the PER document and the submissions received, in conjunction with the proposal characteristics. Details on the key environmental factors and their assessment are contained in Sections 3.1 to 3.6. The description of each factor shows why it is relevant to the proposal and how it will be affected by the proposal. The assessment of each factor is where the EPA decides whether or not a proposal meets the environmental objective set for that factor. The following principles were considered by the EPA in relation to the proposal:

(a) The precautionary principle;

(b) The principle of intergenerational equity;

(c) The principle of the conservation of biological diversity and ecological integrity;

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(d) Principles relating to improved valuation, pricing and incentive mechanisms; and

(e) The principle of waste minimisation.

3.1 Vegetation and fauna habitat

Description Vegetation The proposed urea plant would occupy an area of approximately 100 hectares (ha) within the 124 ha leased industrial site. Approximately 45% of the site is already cleared as a result of previous quarrying and farming. Of the currently vegetated area (67.5ha), approximately 20 ha would be retained. Flora and vegetation surveys were carried out in October 2007 (proposed Shotts Industrial Park), and in May and October 2009. The survey area comprised the Collie Urea Plant site; the conveyor, wastewater and water supply corridors; and Berth 5 at Bunbury Port. Generally, the vegetation within the survey area was in “Very Good” condition. However, a long history of disturbances and clearing has resulted in some areas being “Completely Degraded”. Four main vegetation associations were observed within the survey area: • Jarrah Forest / Woodland; • Mixed Open Woodland; • Wetlands / Damplands; and • Degraded / Cleared Areas.

Seven dominant families and seven dominant genera included 196 and 78 taxa, respectively. Additionally, two Priority Flora species, Pultenaea skinneri (Priority 4) and Acacia semitrullata (Priority 3) were located adjacent to the plant site. Two large populations of P. skinneri were recorded, along the wetland adjacent to the sand quarry in the eastern portion of the site, and the wetland in the southern portion of the survey area. A semitrullata is generally found in sandplains and swampy areas (See Figure 2). No Declared Rare Flora (DRF) were recorded within the survey area. No Threatened Ecological Communities (TEC) were noted within the survey area or within the vicinity of the site. The vegetation within the proposed Collie Urea Plant site is considered of ‘Least Concern’, with approximately 60 per cent of the pre-European extent remaining. The vegetation is also well represented at a local scale, within the Collie State Forest, Wellington National Park and Harris River State Forest. Vegetation within the site represents 0.0001% of the current extent. The proponent intends to locate plant to avoid clearing the best vegetation (See Figure 3).

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Fauna Habitat Five significant fauna species were identified as occurring within the survey area. These species are: • Forest Red-tailed Black Cockatoo (Calyptorhynchus banksii naso); • Baudin’s Black Cockatoo (Calyptorhynchus baudinii); • Carnaby’s Black Cockatoo (Calyptorhynchus latirostris); • Chuditch (Dasyurus geoffroii); and • Western Brush Wallaby (Macropus irma).

The habitat for each of these species occurs within the urea plant site and would be disrupted and/or removed during construction. In particular, potential cockatoo feeding and breeding areas occur on the site (See Figure 4). The proponent plans to minimise ecological and habitat loss through the plant design which would be guided by the following considerations: • vegetation assemblages with a high ecological value to be retained where not

central to the site; • vegetation patches adjacent to the area where Priority Flora has been identified

to be retained where not central to the site; • the area which has been previously cleared land is to be developed; and • vegetation which has high habitat value to be retained wherever possible.

The proponent has committed to a Fauna Management Plan prepared prior to clearing, and additionally, a Clearing Plan which would include opportunities for habitat linkages with State Forest land which is adjacent to the proposed Industrial Park. Where practicable, the proponent intends to retain large stags with hollows, and if they are required to be removed, they would be salvaged and provided to cockatoo care groups.

Submissions The main concerns raised in the submissions relate to:

• no land clearing or biodiversity offsets have been proposed for Shotts Industrial site, or along pipeline routes;

• no consideration of why the proposal cannot be constructed on previously cleared land;

• native vegetation clearing principles were not addressed in the PER; • no information showing whether the proposal would compromise any

vegetation type by taking it below the threshold level of 30% of the pre-clearing extent.

• no information provided to demonstrate there is comprehensive, adequate and secure representation of scarce or endangered habitats within the project area and/or in areas which are biologically comparable to the project area, protected in secure reserves; and

• need to ameliorate impacts on cockatoo breeding sites and to commit to habitat preservation.

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Figure 3: Vegetation Priority Areas.

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Assessment The EPA’s environmental objectives for this factor are to:

• protect Declared Rare and Priority Flora, and Specially Protected (Threatened) and Priority Fauna species and their habitats, consistent with provisions of the Wildlife Conservation Act 1950, and the Environment Protection and Biodiversity Conservation Act 1999; and

• maintain the abundance, species diversity, geographic distribution and

productivity of flora, vegetation communities, and fauna at species and ecosystem levels through the avoidance or management of adverse impacts and the improvement in knowledge.

Since the vegetation is well represented at a local scale and is not considered regionally significant, the EPA considers the highest value of the vegetation to be fauna habitat. The proponent has committed to a Flora Management Plan prior to construction, and Weed and Dieback Management Plans prior to clearing. Given that the vegetation is well represented, the EPA does not consider environmental conditions addressing the retention and management of vegetation to be necessary. The Commonwealth Department of the Environment, Water, Heritage and the Arts (DEWHA) is assessing the proposed site of the Shotts Industrial Park, of which the Collie Urea Plant site would be a significant part, separately and is expected to give attention to the loss of cockatoo habitat. The EPA notes the proponent’s intention to retain hollows where practicable, but considers that as a measure of protection, replacement with artificial hollows in a ratio of 6 to 1 is worthwhile. A condition is recommended to achieve this outcome (Appendix 4).

Summary Having particular regard to the: (a) vegetation being well represented; (b) proponent’s intended management; and (c) recommended conditions requiring installation of artificial nesting boxes, it is the EPA’s opinion that the proposal can be managed to meet the EPA’s environmental objectives for this factor.

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Figure 4: Cockatoo Feeding and Potential Breeding Areas.

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3.2 Water supply

Description The plant would require 12 Gigalitres (GL) of water per year. Water would be sourced from one or both of the following:

• Primary water supply – a source which would usually supply the major proportion of water demand; and

• Supplementary water supply – alternative water sources which would be

utilised to supplement the primary water supply to provide security of supply, while providing additional benefits through strategic improvements to water resource management.

Wellington Dam is the largest surface water catchment in the south-west of the State, with a capacity of 186GL, of which 85GL is currently allocated. The dam is under-utilised due to its high salinity level. The proponent has submitted a Surface Water Licence application to the Department of Water (DOW) to access this source. The proponent’s proposed water supply strategy principles are:

• maximise plant water use efficiencies to reduce demand on water sources; • utilise mine water as a primary water source when available; • utilise diversion water from the Collie River East Branch when available; and • reliance on water from Wellington Dam as a sole water supply option only

when supplementary water sources are unavailable. The proponent recognises that contingency options for water supply are an important issue to address due to the reliance of the supply strategy on surface water sources and the impacts of climate change on the availability and security of surface water resources for the life of the plant. Contingent sources of water include:

• trading arrangement with Harvey Water; • dewatering from mining operations; • desalinated diversion water from the Collie River East Branch; • treated water supplied by any water utility which may be established; and • purchase of potable water from Harris Dam.

At the request of the DOW, the proponent has committed to the preparation of a Water Management Strategy, a draft of which is presented in Appendix C of the PER.


• water re-use and recycling should be maximized before ocean pipeline discharge;

• preference for dry cooling rather than water cooling; • contingency for surface water supply in the event of dry years is not clear; and

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• water should not be drawn from the Collie Basin as it needs to recover.

Assessment The EPA’s environmental objective for this factor is to:

• maintain the quality of surface water and groundwater so that existing and potential uses, including ecosystem maintenance, are protected.

The EPA notes that the proposed development would require about 12GL of water per year which would be sourced mainly from the Wellington Dam. The proponent’s abovementioned water supply strategy principles are a valid approach to the supply of the very significant amount of water from within the South West catchment required for this proposal. The following amongst the proponent’s suggested contingency options for water supply are desirable:

• dewatering from mining operations; • desalinated diversion water from the Collie River East Branch; and • treated water supplied by any water utility which may be established.

Given the preparation of a comprehensive Water Management Strategy for the proposal, fully meeting the DOW’s requirements, this environmental factor should be adequately addressed. The EPA notes that the DoW will manage this issue through its licensing requirements. A condition under Part IV of the EP Act is therefore not warranted.

Summary The EPA considers that the issue of water supply has been adequately addressed and the proposal can meet the EPA’s objective for this factor provided that the proponent adheres to the requirements of the comprehensive Water Management Strategy and meets the licensing requirements of DOW.

3.3 Air quality

Description Potential air emissions during construction of the Urea Plant and the export facility at Bunbury Port would be from vehicle exhausts and dust generation from earthworks. Earthworks within the pipeline and conveyor corridors could lead to lesser amounts of dust. During operation, air emissions would arise from the following plant sections:

• coal milling and drying; • gasification (flare); • gas clean-up; • ammonia synthesis; • urea synthesis and granulation;

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• power island; and • air separation.

The original estimated emissions in tonnes per annum (tpa) from the plant are:

• sulphur dioxide (SO2) – 125 tpa; • oxides of nitrogen (NOx) – 360 tpa; • particulate matter, less than 10 microns (PM10) – 562 tpa; • carbon dioxide (CO2) – 3.4 Mtpa • carbon monoxide (CO) – 1131 tpa; • volatile organic compounds (VOCs) – 15 tpa; • methane (CH4) – 20 tpa; • ammonia (NH3) – 1378 tpa; and • hydrogen sulphide (H2S) – 20 tpa.

The main pollutants of concern in the Collie airshed are SO2 and particulates. The proponent undertook cumulative air emission modelling of current and proposed sources in the Collie airshed. The air dispersion modelling assumes continuous full load operation. The Air Pollution Model (i.e. TAPM, updated model, Version 4.0.3.) was used for the cumulative air shed modelling of emissions from the proposal and existing, approved and proposed other sources. The ground level concentrations (glc) of CO, NO2, O3 and PM10 and PM2.5 have been predicted. Impacts of NH3, H2S, VOCs, heavy metals and urea have been assessed for the Collie Urea Plant in isolation, using the AUSPLUME (v6) dispersion model. The proponent’s cumulative air quality modelling of the Collie airshed predicts that:

• there will be exceedances of the National Environment Protection (Ambient Air Quality) Measure (Air NEPM) standards predicted at sensitive receptors within the Collie airshed for 1-hour SO2, 24-hour PM10 and 24-hour PM2.5; and

• there will be exceedances of the Kwinana Environmental Protection Policy

(EPP) standard predicted at sensitive receptors within the Collie airshed for 1-hour SO2.

Dust may also arise from the coal conveyor at Collie and the export facility at Bunbury.


• public health impact; • detailed risk assessment using more accurate offsite population data; • impact of dust on Collie; • particulates impact on native vegetation;

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• need for real-time particulate monitoring; and • regular reporting to community.

Assessment The EPA’s environmental objective for this factor is to ensure that emissions do not adversely affect the environment or health, welfare and amenity of nearby land users by meeting statutory requirements and acceptable standards. The distance of the Collie Urea Plant site from surrounding land uses means that normal management measures should be adequate to control Construction Phase dust emissions. Due to the limited extent of earthworks at the export facility and in the pipeline and conveyor corridors, the EPA considers that dust from these sources should not be a significant issue. For the Operational Phases, the DEC advised that in each case, emissions from Muja A/B are the main contributor to predicted exceedances of the NEPM and Kwinana EPP within the Collie airshed; and the Collie Urea Plant contributes very little to the predicted ground level concentrations. The DEC also advised that there are no predicted exceedances by the Collie Urea Plant during a 100% flaring scenario. Given that flaring would occur for only 1.5% of the time there is a very strong argument for accepting that the effect of flaring would be acceptable. The EPA notes that Verve Energy intend to refurbish Muja A/B and continue to operate it for a further 10 to 15 years. The EPA understands that this refurbishment would include fitting of pollution control equipment. Although the urea plant is adding only a small increment to the cumulative emissions, the fact that exceedances are predicted means that the EPA’s objectives can only be met if the emissions from Muja A/B are addressed. The Collie Urea Plant is also a source of ammonia, hydrogen sulphide, volatile organic compounds, heavy metals and urea in the Collie airshed, with predicted concentrations compliant with relevant health criteria. The EPA notes that whilst the predicted concentrations of H2S meet the toxicity criterion, the proponent used an incorrect criterion for the potential odour impact from H2S. To address this error, the EPA requested additional modelling of H2S emissions and advice on potential pollution control equipment from the proponent. The results of this modelling suggest that H2S emissions would need to be reduced from 20 tpa to 10 tpa to avoid nuisance odour. The proponent intends to address this by reducing H2S emissions from the originally planned 20 tpa to 8 tpa. To achieve this, the proponent would add a treatment stage to the low pressure vent stream from the Paques sulphur recovery unit. This would comprise a guard bed and catalyst which would in effect act as a filter. The catalyst would attract and retain sulphur from the vent stream. Given that the proposed plant is new technology for Western Australia, the EPA recommends that a condition requiring the proponent to fully characterise the

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emissions (including H2S) during commissioning (conditions 7-1, 7-2 and 7-3) be included amongst the recommended conditions. The methodology to be employed in the stack testing should be that of Australian Standards and/or the US Environmental Protection Agency.

Summary Having particular regard to the: (a) results of cumulative air emissions modelling; (b) proponent’s intended management (including additional H2S control); and (c) recommended conditions requiring characterisation of emissions, it is the EPA’s opinion that the proposal can be managed to meet the EPA’s environmental objectives for this factor, provided that emissions from the Muja A/B power station are appropriately addressed during its refurbishment.

3.4 Greenhouse gas emissions

Description Once operational, the Collie Urea Plant would emit 3.4 Million tonnes per annum (Mtpa) of carbon dioxide (CO2). The main sources of CO2 are from the gasification of coal (2.5 Mtpa) and the generation of power (0.7 Mtpa). The power station proposed is a combined cycle gas turbine (CCGT) fuelled by syngas produced in the plant. The CO2 produced from the gasification process would be almost pure (99.5%) and at modest pressure making it suitable for carbon capture and storage (CCS) without further processing. The proponent is a member of the Carbon Sequestration Taskforce to ascertain the potential of the Lower Lesueur sandstone formation, located south of Lake Preston in the Southern Perth Sedimentary Basin, for CO2 storage. The Lower Lesueur formation could provide suitable storage potential and containment security for the likely volume of CO2 which would be sequestered from the Collie region. However, the geo-sequestration potential of this formation is considered to be only conceptually positive as it is based on very little data control (Varma et al., 2007). Extensive additional detailed work, well data collection, seismic acquisition and reservoir simulation needs to be undertaken to determine the viability of this formation as a suitable geo-sequestration site. The proponent’s PER indicates that the plant would be CCS-ready. The proponent does not intend to provide any direct offsets for greenhouse gas management.


• carbon capture/offset schemes should be subject to a PER; • various legislative mechanisms to limit GHG, including bonds;

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• request for details of how the proponent will ameliorate CO2 emissions; • request for details of how the plant will interact with the proposed Carbon

Pollution Reduction Scheme (CPRS); • alternatives to geo-sequestration; and • no provision of offsets for carbon emissions.

Assessment The EPA’s environmental objectives for this factor are to:

• minimise greenhouse gas emissions in absolute terms and reduce emissions per unit of product to as low as reasonably practicable; and

• mitigate greenhouse gas emissions, mindful of Commonwealth and State

greenhouse gas strategies and programs. The production of urea from coal has greater greenhouse intensity than the production of urea from natural gas and requires 1.5 times as much energy per tonne of ammonia produced (Prince 2007). The EPA recognises that, should the Lower Lesueur formation be found suitable, CO2 from the Collie Urea Plant would be much more practical to store than CO2 from the surrounding power stations which would require complex CO2 capture and purification processes. In line with recent power station assessments, conditions are recommended requiring the proponent to advise of progress towards CCS, and to install CCS within five years of it becoming viable in the absence of a Commonwealth CPRS or other national carbon market. The EPA believes that condition 8-1 should be imposed on the proponent requiring it to advise the EPA of progress made towards the implementation of CCS every five years. To ensure that CCS is installed within a reasonable time of the process becoming available, the EPA believes that condition 8-2 requiring that CCS be retrofitted to the Collie Urea Plant within five years of the EPA concluding that CCS is economically and technically proven. The federal government has recently announced that it is delaying implementation of its CPRS until at least 2013. With the continued uncertainty over the proposed CPRS, the EPA also believes that condition 8-3 should be imposed on the proponent requiring a Greenhouse Gas Abatement Report to be developed, prior to the commencement of the CPRS, which meets the following objectives:

• demonstrates that maximising energy efficiency and opportunities for future energy recovery have been given due consideration in the design of the power station;

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• ensures that the “greenhouse gas” intensity (i.e. tonnes of CO2-e produced per tonnes of urea produced) is equivalent to, or better than benchmarked best practice for urea production from coal; and

• achieves continuous improvement in “greenhouse gas” intensity through the

periodic review, and if practicable, adoption of advances in technology and process management.

These conditions are consistent with those recommended for Bluewaters Phases III and IV and the Coolimba Power Station proposals. The EPA considers the use of CCGT power generation is best practice for the baseload power required by the urea plant. The EPA has also provided “Other Advice” on greenhouse gas emissions to Government in Section 5 of this report.

Summary The EPA has concluded that the proposal can meet its environmental objectives for the factor of greenhouse gas emissions, provided that condition 8 is implemented.

3.5 Noise emissions

Description Collie Urea Plant The proposed plant site is surrounded by several existing large scale industries which produce noise, including:

• Griffin’s Muja and Ewington coal mines; • Wesfarmer’s Premier coal mine; and • Muja, Collie and Bluewaters power stations.

The district surrounding Shotts is sparsely populated. The nearest residences are located several kilometres from the proposed urea plant site. The old Buckingham townsite, now consisting of a small number of residents, is located within two km of the Wesfarmers Premier Coal mine and is known to be exposed to some noise from mining activity. The Collie Burn and Cardiff settlements are located south-west of Shotts. The proponent undertook noise modelling which predicts that noise levels would exceed the Environmental Protection (Noise) Regulations 1986 at three potential residential premises, and at one existing noise-sensitive premises, being the caretaker’s cottage at Stockton Pool, the nearby recreational area. Bunbury Port Noise from the Port is expected to be dominated by the conveyor, with maximum noise levels created by the train wagon dump-gate and wagon shunting.

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The closest residences are south-west of the Port, in the suburbs of East Bunbury and Bunbury. On the opposite side of the Port, to the north-east, are residences in Pelican Point. The proponent undertook modelling which showed that a 7dB reduction to the predicted LA10 noise level was needed to meet the Environmental Protection (Noise) Regulations 1986. The proponent has stated that a combination of engineering design features and continuous rail-car unloading practices would be employed in order to meet the Regulations. Infrastructure The equipment used for pipeline construction is typical of that used in an urban environment for general infrastructure construction. Residential areas in proximity to the alignment may experience some daytime noise impact.


• concern over room in Shotts Industrial Park for other industry; • noise criteria need to relate to Shotts Industrial Park buffer; • expanded noise emissions modeling, including impact of transport routes; • non-compliance at the Stockton Lake caretaker’s cottage; • predicted high noise levels at Stockton Lake; • need to demonstrate how overall noise power level of the urea plant can be

reduced; • need to undertake all noise control measures proposed by acoustic consultant

for Bunbury Port operations; and • regular reporting to community.

Assessment The EPA’s environmental objective for this factor is to protect the amenity of nearby residents from noise generated by construction activities associated with the proposal and operation of the plant by ensuring that the noise levels meet statutory requirements and acceptable standards. On 10 March 2010 the EPA set the level of assessment on the Shire of Collie “Local Planning Scheme 5 – Amendment 1” at “Not Assessed – Advice Given”. This amendment will create the Shotts Industrial Park through rezoning from “Rural” to “Industrial”. The Shotts Industrial Park will have five development areas for industrial premises. In considering this amendment, the implications of noise emissions and buffer requirements were investigated. To prevent the first industry establishing in the park constraining later entrants, the DEC Noise Branch recommended that notional sound power levels for each of the five development areas be included in the Structure Plan for the Shotts Industrial Park. EPA advice to the Shire of Collie on 25 March 2010 regarding the issue of noise for the amendment pointed out that “the cumulative noise generated from the Industrial

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Park must not exceed 35dB(A) at the boundary of the 3 km buffer and at the nearest sensitive land use.” The development area to be occupied by the Collie Urea Plant has recommended notional sound power levels of:

• Plant source: 122dB(A); and • Stack source: 116dB(A).

These notional sound power levels are based on a simple model and are indicative in nature. As part of the environmental assessment for developments in the Shotts Industrial Park, detailed modelling is required. The DEC also recommended noise contribution limits for the individual development areas in the Shotts Industrial Park as shown in Table 2 below. Table 2: Maximum allowed noise contributions from individual development areas in order to meet a cumulative noise level of 35dB(A) at the Shotts Buffer.

Maximum allowed noise contribution for plant operating during night hours – dB(A)

Development Area

Receiving point A on Shotts Buffer adjacent to private land to south-west of Shotts Industrial Park

Receiving point B on Shotts Buffer adjacent to private land to north-east of Shotts Industrial Park

Urea Plant 33 26 Char Plant 23 33 Development Area 1 16 16 Development Area 2 18 17 Development Area 3 16 18

Note: For industries in Development Areas 1, 2 and 3 where the operating hours do not include “night” hours as defined in the noise regulations, higher noise contributions may be allowed. The principal noise sources at the Collie Urea Plant would be the gasifier, the sulphur plant, the ammonia and urea synthesis units and the cooling towers. The DEC Noise Branch advised that, as presented in the PER, the Collie Urea Plant would constrain future industries, and that a reduction in overall sound power levels of around 5dB would be needed. The DEC recommended that the Collie Urea Plant be required to meet the individual noise contribution in Table 2, as distinct to just meeting the 35dB(A) assigned level in the Environmental Protection (Noise) Regulations 1986. To address this, conditions 6-1, 6-2 and 6-3 are recommended which require the proponent to identify the noise attenuation required and provide modelling which demonstrates that the Urea Plant can meet its noise contribution limit as specified in Table 2. (See condition 6 in Appendix 4).

Summary Having particular regard to the:

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(a) noise study undertaken for Shotts Industrial Park; and (b) recommended conditions, it is the EPA’s opinion that the proposal can be managed to meet the EPA’s environmental objective for this factor.

3.6 Wastewater disposal

Description The following wastewater streams would be produced from the plant and operations:

• wastewater from pre-treatment of raw supply water; • wastewater (brine return and reject water) from the water

treatment/desalination plant; • process wastewater (including cooling tower blowdown and process

blowdown water from the Gasifier water bath); • wastewater from the demineralisation plant; • domestic wastewater (greywater and blackwater); and • site stormwater runoff.

Some of the wastewater streams would be reused or internally pre-treated and recycled for use within the process plant. The remaining wastewater streams would be collected for treatment on-site in a wastewater treatment plant prior to disposal. The PER considered an option to concentrate wastewater onsite and to dispose to landfill, however in the response to submissions the proponent has confirmed that disposal of wastewater would be via the Collie Power Station / Verve Energy saline pipeline from where it would discharge approximately 800m offshore north of the Leschenault Estuary. In principle agreement has been reached by the proponent to access this pipeline for disposal of 3ML/day (1.095 GL/year) of wastewater in accordance with the existing DEC Licence issued under Part V of the EP Act.


• modelling of the marine impact of increased saline discharge at Binningup was not provided;

• wastewater from storage could leach or overflow into either groundwater or Stockton Lake. The DOW does not support storage of wastewater on site;

• information on emissions and waste volumes when plant is in unstable operation should be provided; and

• management of the saline wastewater in the event of a significant down time of the Verve pipeline which has leakage problems.

Assessment The EPA’s environmental objective for this factor is to:

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• ensure that emissions do not adversely affect the environmental values or the health and amenity of people and marine users by meeting statutory requirements and acceptable standards relating to marine water quality; and

• maintain the abundance diversity, geographic distribution and productivity of

benthic habitat and marine fauna at species and ecosystem levels through the avoidance or management of adverse impact and improvement in knowledge.

Given effective control of the quality of the wastewater stream from the Collie Urea Plant, and that the Verve Energy saline wastewater pipeline has the capacity to receive and transmit Perdaman’s wastewater to the ocean, whilst meeting DEC licence conditions, the EPA considers that sharing of the facility should prove to be an efficient utilisation of infrastructure.

Summary The EPA considers the issue of wastewater disposal has been adequately addressed and the proposal can meet the EPA’s objective for this factor. The Collie Urea Plant wastewater stream can be adequately managed under Part V of the EP Act with regulation of the final mixed wastewater discharged to the ocean. The EPA considers that environmental conditions for this factor are not required.

3.7 Environmental principles In preparing this report and recommendations, the EPA has had regard for the object and principles contained in s4A of the EP Act. Appendix 3 contains a summary of the EPA’s consideration of the principles.

4. Conditions Section 44 of the EP Act requires the EPA to report to the Minister for Environment on the environmental factors relevant to the proposal and on the conditions and procedures to which the proposal should be subject, if implemented. In addition, the EPA may make recommendations as it sees fit. In developing recommended conditions for each project, the EPA’s preferred course of action is to have the proponent provide an array of commitments to ameliorate the impacts of the proposal on the environment.

4.1 Recommended conditions Having considered the information provided in this report, the EPA has developed a set of conditions that the EPA recommends be imposed if the proposal by Perdaman Chemicals and Fertilisers Pty Ltd to construct and operate a urea production plant in the Shire of Collie, and to transport the urea to Bunbury Port for export, is approved for implementation.

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These conditions are presented in Appendix 4. Matters addressed in the conditions include the following:

(a) the replacement of Black Cockatoo nesting trees which are removed during construction with artificial nesting boxes on a six-for-one basis;

(b) limiting noise emissions from the urea plant to allow room for other industrial users of lots in the Shotts Industrial Park;

(c) confirmation of air emissions to the Collie air-shed, including odour due to hydrogen sulphide;

(d) reporting on progress made towards the implementation of carbon capture and storage (CCS), retrofitting of CCS within five years of the technology becoming economically and technically proven, and preparation of a greenhouse gas abatement report; and

(e) orderly decommissioning of plant and equipment, and rehabilitation of disturbed areas.

It should be noted that other regulatory mechanisms relevant to the proposal are:

• Works Approval and operating Licence under Part V of the EP Act;

• Wildlife Conservation Act 1950;

• Dangerous Goods Safety Act 2004; and

• Rights in Water and Irrigation Act 1914.

5. Other Advice

5.1 Collie Basin Environment Strategy Due to the considerable development pressure in the Collie area, the EPA considers there is a need for a “Collie Basin Environment Strategy” to address the following:

• a strategic review of environmental planning needs in the region;

• consideration of the implications of future mining and industrial proposals and associated infrastructure needs and water requirements on the environment of the Collie Basin; and

• issues of noise, air pollution, water management, ecological linkage and

vegetation clearing.

5.2 Greenhouse gas emissions The EPA considers it is unlikely that Carbon Capture and Storage (CCS) will become technically and commercially viable in Western Australia in the near future. The EPA notes that the CCS technology is now technically feasible, but the full chain of CCS – capture, transport and storage of carbon dioxide – has yet to be demonstrated for the full capacity of a coal-fired power station in Australia. Various demonstration projects

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and pilot plants currently demonstrate only part of the CCS chain. Therefore, proponents do not consider CCS technology as commercially feasible. To achieve substantial reductions in Greenhouse Gas (GHG) emissions on a global scale, the abatement process must be driven by governments across a range of existing and future emission sources. As a party to the Kyoto Protocol, Australia is obliged to limit its GHG emissions to no more than 108% of 1990 levels (around 600 Mtpa) up to 2012, and Australia is on track to achieve this. The Commonwealth Government’s long term goal is to achieve a reduction of 60% from 2000 levels by 2050. This would limit Australia to 221 Mtpa in 2050. Based on WA’s percentage of Australian emissions in 2007, this target would equate to around 28 Mtpa in 2050 for WA. The latest data from 2007 (Australian Government 2007) shows WA’s emission to be 76.3 Mtpa. Projects with existing environmental approval (but not yet included in the emissions inventory) could add more than 20 Mtpa to this amount. Additionally, there are currently proposals in the EPA assessment process, which if approved and constructed, would emit a further 36 Mtpa. Given potential total emissions of the order of 133 Mtpa, the task of reducing WA’s emissions to 28 Mtpa within four decades becomes daunting, especially when the long operational life of these projects is considered. It also highlights the importance of a joint Government/Industry focus on developing real options for geo-sequestration of carbon dioxide in Western Australia. In this regard, the EPA recognises that the Commonwealth Government, the Western Australian Government and industry are jointly investing in the Collie South West Hub Carbon Capture and Storage Project, currently underway in Western Australia’s South West, to research and develop carbon sequestration options in the State. The EPA encourages this initiative.

6. Recommendations The EPA submits the following recommendations to the Minister for Environment:

1. That the Minister notes that the proposal being assessed is for construction and operation of a urea production plant in the Shire of Collie, and transport of the urea to Bunbury Port for export;

2. That the Minister considers the report on the key environmental factors and principles as set out in Section 3;

3. That the Minister notes that the EPA has concluded that it is unlikely that the EPA’s objectives would be compromised, provided there is satisfactory implementation by the proponent of the recommended conditions set out in Appendix 4, and summarised in Section 4, including the proponent’s commitments;

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4. That the Minister imposes the conditions and procedures recommended in Appendix 4 of this report; and

5. That the Minister notes advice contained in Section 5 (“Other Advice”) of this report on the need for a “Collie Basin Environment Strategy” and advice regarding Greenhouse Gas emissions.

Appendix 1

List of submitters

Fifteen submissions were received on the PER for the proposed Collie Urea Project. Organisations:

1. Department of Environment & Conservation (DEC), Environmental Regulation (Noise)

2. Department of Environment & Conservation (DEC), Environmental Management Branch

3. Department of Indigenous Affairs (DIA) 4. Department of Mines and Petroleum (DMP) 5. Department of Water (DoW) 6. Forest Products Commission (FPC) 7. Shire of Collie 8. Friends of the Earth Southwest WA (FESWA) 9. Rural Action Group (RAG) 10. South West Environment Centre (SWEC) 11. Premier Coal 12. South West Integrated Management (SWIM)

Individuals:

1. G Yates 2. Anonymous 1 3. Anonymous 2

Appendix 2

References

Reference Material: Australian Government (2007) Australian National Greenhouse Accounts, State and Territory Greenhouse Gas Inventories 2007. Department of Climate Change, Commonwealth of Australia, Canberra ACT. GHD (2009a) Perdaman Chemicals and Fertilisers, Collie Urea Plant, Public Environmental Review; and Appendices Volumes 1 and 2, GHD, September 2009. GHD (2009b) Perdaman Chemicals and Fertilisers, Report for Collie Urea Project, Air Quality Assessment, GHD, November 2009. GHD (2009c) Perdaman Chemicals and Fertilisers, Report for Collie Urea Plant, Public Environmental Review Supplement and Response to Submissions, GHD, December 2009. GHD (2009d) Perdaman Chemicals and Fertilisers, Report for Collie Urea Plant, Conveyor, Wastewater and Water Supply Pipeline Route, Flora and Vegetation Survey, GHD, December 2009. Prince (2007) Initiating new projects in the ammonia sector, Presented at the International Fertilizer Industry Association Technical Committee Meeting, Workshop on Energy Efficiency and CO2 Reduction Prospects in Ammonia Production, 12-14 March 2007, Ho Chi Minh City, Vietnam, Prince, A., March 2007. Varma et al. (2007) Regional Study on Potential CO2 Geosequestration in the Collie Basin and the Perth Basin of Western Australia, Varma S, Dance T, Underschultz J, Langford RP, and Dodds K. Prepared for the Department of Industry and Resources and the Coal Futures Group (2007).

Appendix 3

Summary of identification of key environmental factors and principles

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Identification of Key Environmental Factors - Collie Urea Project, Shotts Industrial Park, Shire of Collie & Port of Bunbury - Assessment No. 1784.

Preliminary Environmental Factors Proposal Characteristics Government Agency and Public Comments

Identification of Key

Environmental Factors

BIOPHYSICAL Vegetation and flora (terrestrial – construction)

The proposal would result in the clearing of approximately 100 ha of native vegetation within the Shotts Industrial Park.

No land clearing or biodiversity offsets have been proposed for Shotts Industrial site, or along pipeline routes; No consideration of why proposal cannot be constructed on previously cleared land; Native vegetation clearing principles were not addressed in the PER; No information showing whether the proposal would compromise any vegetation type by taking it below the threshold level of 30% of the pre-clearing extent; and Particulates impact on native vegetation.

In view of the nature of the concerns which were raised in the comments received, the EPA considers that vegetation is a relevant environmental factor. Vegetation will be considered under the factor of “Vegetation and fauna habitat”. Considered to be a relevant environmental factor.

Fauna habitat (terrestrial – construction)

The proposal would result in the clearing of approximately 100 ha of native vegetation within the Shotts Industrial Park.

No land clearing or biodiversity offsets have been proposed for Shotts Industrial site, or along pipeline routes; No consideration of why proposal cannot be constructed on previously cleared land; Native vegetation clearing principles were not addressed in the PER; No information provided to demonstrate there is comprehensive, adequate and secure representation of scarce or endangered habitats within the project area and/or in areas which are biologically comparable to the project area, protected in secure reserves; and Need to ameliorate impacts on cockatoo breeding sites and to commit to habitat preservation.

In view of the nature of the concerns which were raised in the comments received, the EPA considers that fauna habitat is a relevant environmental factor. Fauna habitat will be considered under the factor of “Vegetation and fauna habitat”. Considered to be a relevant environmental factor.

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Water supply (operational)

Wellington Dam is under-utilised due to its high salinity, but is the preferred source of water for the proposal. The proponent has submitted a surface water licence application to the DOW for 12 GL of water per year.

Water re-use and recycling should be maximised before ocean pipeline discharge; Preference for dry cooling rather than water cooling; Contingency for surface water supply in the event of dry years is not clear; Water should not be drawn from the Collie Basin as it needs to recover; and The water supply pipeline construction management measures are insufficient to effectively manage environmental risk. DEC recommends a Pipeline Environmental Management Plan for the construction and operation phases.

A Local Water Management Strategy (Better Urban Water Management) is to be prepared which forms part of the DOW requirement of a Water Management Strategy. Considered to be a relevant environmental factor.

POLLUTION Air quality, including dust (operational)

As a large chemical production plant, significant polluting emissions to the atmosphere are potentially dust, SO2, NH3, and H2S, amongst others.

Public health impact; Impact of dust on Collie; Particulates impact on native vegetation; Need for real-time particulate monitoring; and Regular reporting to community.

In view of the potential emissions from the plant and the limited capacity of the Collie airshed, and the nature of the concerns raised in the comments received, the EPA considers that air quality is a relevant environmental factor. Considered to be a relevant environmental factor.

Noise (operational)

As a large chemical production plant, significant noise emissions are generated by a range of units within the plant, such as the coal conveyor,

Concern over room in Shotts Industrial Park for other industry; Noise criteria need to relate to Shotts Industrial Park buffer; Expanded noise emissions modelling, including impact of transport

Due to the potential for the cumulative noise generated from the Shotts Industrial Park to exceed 35dB(A) at the boundary of the 3km buffer and at the nearest

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stacker/reclaimer, coal milling and drying, gasifier, air separation unit, ammonia and urea synthesis units, and cooling towers.

routes; Non-compliance at the Stockton Lake caretaker’s cottage; Predicted high noise levels at Stockton Lake; Need to demonstrate how overall noise power level of the urea plant can be reduced; Need to undertake all noise control measures proposed by acoustic consultant for Bunbury Port operations; and Regular reporting to community.

sensitive land use, and the DEC comments, the EPA considers that noise is a relevant environmental factor. Considered to be a relevant environmental factor.

Waste disposal - liquid (operational)

Water which cannot be reused in the plant (2.4 to 2.8 GL/yr) would be treated on-site prior to disposal to the Verve Energy/Collie Power Station pipeline for ocean disposal.

Modelling of the marine impact of increased saline discharge at Binningup was not provided; Wastewater from storage could leach or overflow into either groundwater or Stockton Lake. The DOW does not support storage of wastewater on site; Information on emissions and waste volumes when plant is in unstable operation should be provided; and Management of the saline wastewater in the event of a significant down time of the Verve pipeline which has leakage problems.

The Collie Urea Plant wastewater stream can be adequately managed under Part V, EP Act regulation of the final mixed wastewater discharged to the ocean. The EPA considers that Part IV EP Act environmental conditions for this factor are not required. Considered to be a relevant environmental factor.

Waste disposal - solid (operational)

Solid waste generated during operation of the plant would be approximately 1300 t/day.

Not specifically addressed how waste material will be managed or disposed of; and No specific plan to dispose of coal wastes (slag).

Solid wastes, being mostly inert slag and slag fines, would initially be disposed of as backfill to mines. Eventually these wastes, a saleable bi-product overseas, may be used

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for road-making, etc. Not considered to be a relevant environmental factor.

Hazardous materials (operational)

The chemical reactions involved in urea production generate hazardous gases (carbon monoxide, hydrogen, hydrogen sulphide, hydrogen cyanide and principally ammonia). Parts of the process involve pressure vessels. Ammonia is stored in a 10 000 tonne refrigerated tank.

Detailed risk assessment using more accurate offsite population data. Pipelines and storage tanks should be constructed and tested for integrity prior to commissioning in accordance with the appropriate Australian standards. Regulation of these matters falls within the province of the Department of Mines and Petroleum, Dangerous Goods Safety Branch. Not considered to be a relevant environmental factor.

Groundwater

The process generates 3 ML/day of wastewater for disposal. Any temporary storage of this has the potential to enter the groundwater. Additionally, stored reactants and products may be distributed or spilled and enter the groundwater.

Need to avoid pollution of groundwater and surface water; and Need to prevent wastewater in storage leaching or overflowing into either groundwater or Stockton Lake.

Local Water Management Strategy (Better Urban Water Management) to be prepared. Not considered to be a relevant environmental factor.

SOCIAL SURROUNDINGS Aboriginal heritage (construction)

Although there are no known indigenous heritage sites within the proposed Shotts Industrial Park, there is potential for

There are no Indigenous heritage issues or concerns for the project; and A more rigorous indigenous consultation should be undertaken to include areas not covered by the Shotts Industrial Park report.

Compliance with the provisions of the Aboriginal Heritage Act 1972 would be required should sites be uncovered.

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locating sites during works

within the pipeline and conveyor corridors.

Not considered to be a relevant environmental factor.

OTHER Transport (operational)

The greater quantity of raw materials and products would not use road transport. Certain raw materials would, however, be transported by road.

Concerns regarding the capacity of the highway to sustain heavy use transporting infrastructure and the daily workforce; and Rail movement during peak traffic periods will impact local traffic - a Traffic Management Plan is requested.

The capacity of the road is the responsibility of Main Roads WA. Not considered to be a relevant environmental factor.

Greenhouse gas emissions (operational)

The Collie Urea Plant would emit 3.4 million tonnes per year of CO2, a significant contribution to greenhouse gases produced in Australia.

Carbon capture/offset schemes should be subject to a PER; Various legislative mechanisms to limit greenhouse gases, including bonds; Request for details of how the proponent will ameliorate CO2 emissions; Request for details of how the plant will interact with the proposed CPRS scheme; Alternatives to geo-sequestration; and No provision of offsets for carbon emissions.

In view of the very considerable amount of greenhouse gases generated by the urea plant, the EPA considers that greenhouse gas emissions is a relevant environmental factor. Considered to be a relevant environmental factor.

Public risk (ammonia storage) and transport of dangerous goods.

The chemical reactions involved in urea production generate hazardous gases (carbon monoxide, hydrogen, hydrogen

Increase in the number of ammonia storage vessels and thus reduction of the magnitude of any emergency events and therefore public risk; The proponent should detail any mitigation to risk that may be available

The EPA does not assess industrial risk. The urea plant would be classified

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sulphide, hydrogen cyanide and ammonia), and parts of the process involve high temperatures and pressure vessels. The stored ammonia reaction intermediate is in a 10 000 tonne double-skinned refrigerated tank.

from different technologies in ammonia production and coal gasification; Premier Coal's facilities are located about 1.3 km from the closest boundary. Risk management and emergency response strategies must be established and communicated for all people at or near the Shotts Industrial Park; The affected population is assumed to be all residences and businesses within 5 km of the proposed site, estimated at 120 persons including Stockton lake recreational area. This underestimates the position; and Risks Presented in this facility may not meet the EPA off-site individual risk criteria for fatalities from hazardous plant.

as a Major Hazard Facility and regulated under the Dangerous Goods Safety Act 2004 by the Department of Mines and Petroleum. Not considered to be a relevant environmental factor.

Bushfire risk The area is an extreme bushfire risk area.

The proponent should design and build the plant to include fire protection within its lease area and should not rely on fuel reduction and fire suppression activities within the State Forest; and The Fire Management Plan should adhere to the points in the DEC submission.

Information on bushfires has been provided to the proponent. Not considered to be a relevant environmental factor.

Decommissioning

At the end of its useful life, plant and equipment should be rendered safe, dismantled, and disposed of with as much recycling, particularly of ferrous and non-ferrous metals, as possible. The site should be left in an acceptable state for the next occupier.

Provision of a position statement on decommissioning.

Decommissioning is expected to take place in accordance with the requirements of the EP Act (Part IV), with a standard condition imposed by the Minister for Environment. Not considered to be a relevant environmental factor.

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Identification of Key Environmental Principles PRINCIPLES

Principle Relevant Yes/No

If yes, Consideration

1. The precautionary principle Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In application of this precautionary principle, decisions should be guided by – 1. careful evaluation to avoid, where practicable, serious or

irreversible damage to the environment; and 2. an assessment of the risk-weighted consequences of

various options.

yes The proposal has the potential to impact vegetation and fauna habitat, particularly the habitat of three species of black cockatoos observed in the area. Therefore, monitoring and management measures should be implemented to mitigate the impact and observe the effectiveness of management measures taken. Vegetation and fauna habitat is a relevant environmental factor in this EPA assessment report.

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

yes The proposal would result in the permanent reduction of a natural resource (coal).

3. The principle of the conservation of biological diversity and ecological integrity Conservation of biological diversity and ecological integrity should be a fundamental consideration.

yes The proposal would result in the loss of approximately 100 ha of native vegetation and has the potential to affect biological diversity and ecological integrity. Vegetation and fauna habitat, a sub-set of biodiversity, is a relevant environmental factor addressed in this report.

4. Principles relating to improved valuation, pricing and incentive mechanisms (1) Environmental factors should be included in the valuation

of assets and services. (2) The polluter pays principles – those who generate

pollution and waste should bear the cost of containment, avoidance and abatement.

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

(4) Environmental goals, having been established, should be

yes The proponent should be required to manage the gaseous and particulate emissions (including greenhouse gases), noise emissions, and liquid and solid wastes generated by the proposed development, as well as the final rectification of the site at decommissioning at the end of the useful life of the plant and equipment. The proponent should bear the costs associated with meeting their obligations in this regard.

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PRINCIPLES Principle Relevant

Yes/No If yes, Consideration

pursued in the most cost-effective way, by establishing incentive structure, including market mechanisms, which enable those best placed to maximize benefits and/or minimize costs to develop their own solution and responses to environmental problems.

5. The principle of waste minimisation

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

yes The proposal would generate gaseous, particulate, liquid and solid wastes. Hence, the proponent would be expected to address the waste hierarchy and minimise the generation of waste, and promote the reuse of waste and process bi-products.

Appendix 4

Identified Decision-making Authorities

and Recommended Environmental Conditions

Identified Decision-making Authorities

Section 44(2) of the Environmental Protection Act 1986 (EP Act) specifies that the EPA’s report must set out (if it recommends that implementation be allowed) the conditions and procedures, if any, to which implementation should be subject. This Appendix contains the EPA’s recommended conditions and procedures. Section 45(1) requires the Minister for Environment to consult with decision-making authorities, and if possible, agree on whether or not the proposal may be implemented, and if so, to what conditions and procedures, if any, that implementation should be subject. The following decision-making authorities have been identified for this consultation:

Decision-making Authority Approval

1. Minister for Environment Wildlife Conservation Act 1950 2. Department of Mines & Petroleum Dangerous Goods Safety Act 2004 3. Department of Environment & Con-

servation Environmental Protection Act 1986, Part V

4. Department of Indigenous Affairs Aboriginal Heritage Act 1972 5. Department for Planning 6. Minister for Water

Rights in Water and Irrigation Act 1914, Section 5C

7. Shire of Collie Planning approval 8. Main Roads WA Note: In this instance, agreement is only required with DMAs nos 1 and 6 since these DMAs are Ministers.

RECOMMENDED ENVIRONMENTAL CONDITIONS

STATEMENT THAT A PROPOSAL MAY BE IMPLEMENTED (PURSUANT TO THE PROVISIONS OF THE ENVIRONMENTAL PROTECTION ACT 1986)

COLLIE UREA PROJECT, SHOTTS INDUSTRIAL PARK, SHIRE OF

COLLIE AND PORT OF BUNBURY

Proposal: The proposal is for the construction and operation of a urea production plant within the proposed Shotts Industrial Park, located about 7.5 kilometres east of Collie. The plant will produce a nominal 2.1 million tonnes per annum of urea, which will be transported by rail to the Port of Bunbury for export.

The proposal is further documented in schedule 1 of this

statement. Proponent: Perdaman Chemicals and Fertilisers Pty Ltd Proponent Address: Level 4, 177 St George’s Terrace PERTH WA 6000 Assessment Number: 1784 Report of the Environmental Protection Authority: 1358 The proposal referred to in the above report of the Environmental Protection Authority may be implemented. The implementation of that proposal is subject to the following conditions and procedures: 1 Proposal Implementation 1-1 The proponent shall implement the proposal as documented and described in

schedule 1 of this statement subject to the conditions and procedures of this statement.

2 Proponent Nomination and Contact Details 2-1 The proponent for the time being nominated by the Minister for Environment

under sections 38(6) or 38(7) of the Environmental Protection Act 1986 is responsible for the implementation of the proposal.

2-2 The proponent shall notify the Chief Executive Officer of the Office of the

Environmental Protection Authority of any change of the name and address of the proponent for the serving of notices or other correspondence within 30 days of such change.

3 Time Limit of Authorisation 3-1 The authorisation to implement the proposal provided for in this statement shall

lapse and be void five years after the date of this statement if the proposal to which this statement relates is not substantially commenced.

3-2 The proponent shall provide the Chief Executive Officer of the Office of the

Environmental Protection Authority with written evidence which demonstrates that the proposal has substantially commenced on or before the expiration of five years from the date of this statement.

4 Compliance Reporting 4-1 The proponent shall prepare and maintain a Compliance Assessment Plan to the

satisfaction of the Chief Executive Officer of the Office of the Environmental Protection Authority.

4-2 The proponent shall submit to the Chief Executive Officer of the Office of the

Environmental Protection Authority, the Compliance Assessment Plan required by condition 4-1 at least six months prior to the first Compliance Assessment Report required by condition 4-6, or prior to ground-disturbing activities, whichever is sooner.

The Compliance Assessment Plan shall indicate:

1 the frequency of compliance assessments; 2 the approach and timing of compliance assessments; 3 the retention of compliance assessments; 4 reporting of potential non-compliances and corrective actions taken; 5 the table of contents of Compliance Assessment Reports; and 6 the public availability of Compliance Assessment Reports.

4-3 The proponent shall assess compliance with conditions in accordance with the Compliance Assessment Plan required by condition 4-1.

4-4 The proponent shall retain reports of all compliance assessments described in

the Compliance Assessment Plan required by condition 4-1 and shall make those reports available when requested by the Chief Executive Officer of the Office of the Environmental Protection Authority.

4-5 The proponent shall advise the Chief Executive Officer of the Office of the

Environmental Protection Authority of any potential non-compliance within two business days of that non-compliance being known.

4-6 The proponent shall submit its first Compliance Assessment Report within

fifteen months following the date of issue of this statement addressing the twelve-month period from the date of issue of this statement and then annually from the date of submission of the first Compliance Assessment Report.

The Compliance Assessment Report shall:

1 be endorsed by the proponent’s Managing Director or a person delegated to sign on behalf of the proponent’s Managing Director;

2 include a statement as to whether the proponent has complied with the conditions;

3 identify all potential non-compliances and describe corrective and preventative actions taken;

4 be made publicly available in accordance with the approved Compliance Assessment Plan; and

5 indicate any proposed changes to the Compliance Assessment Plan required by condition 4-1.

5 Black Cockatoo Nesting Trees 5-1 Within three months following removal of Carnaby’s, Baudin’s and Red-tailed

Black Cockatoo nesting trees which are removed during construction of the plant and infrastructure, the proponent shall replace all potential and confirmed Carnaby’s, Baudin’s and Red-tailed Black Cockatoo nesting trees removed during construction of the plant and infrastructure with artificial nesting boxes.

The proponent shall install and maintain for the duration of the project a

minimum of six nesting boxes per tree removed, in locations and to a standard determined following consultation with the Department of Environment and Conservation and the Commonwealth Department of Environment, Water, Heritage and the Arts.

5-2 The proponent shall monitor the use by Carnaby’s, Baudin’s and Red-tailed

Black Cockatoos of the artificial nesting boxes referred to in condition 5-1 and shall report the findings annually to the Chief Executive Officer of the Office of the Environmental Protection Authority and the Chief Executive Officer of the Department of Environment and Conservation.

6 Noise 6-1 Prior to applying for a Works Approval, the proponent shall provide a report to

the Chief Executive Officer of the Office of the Environmental Protection Authority and the Chief Executive Officer of the Department of Environment and Conservation, the objective of which is to demonstrate that the plant can be constructed to meet the cumulative 35 dB(A) assigned level for night time at the edge of the Shotts Industrial Park buffer, and which:

1 identifies those items of plant which require further noise attenuation; 2 details the measures to be incorporated in the plant design to achieve the

noise levels identified in condition 6-1(3); 3 includes revised noise modelling of the Collie Urea Plant (with the

measures identified in condition 6-1(2) to demonstrate that:

(1) a sound pressure level of 33 dB(A) can be achieved at Point A on Figure 4 (the south-west receiving point of the Shotts Industrial Park Buffer adjacent to private land); and

(2) a sound pressure level of 26 dB(A) can be achieved at Point B on

Figure 4 (the north-east receiving point of the Shotts Industrial Park Buffer adjacent to private land).

6-2 The proponent shall make the report described in condition 6-1 publicly

available in a manner approved by the Chief Executive Officer of the Office of the Environmental Protection Authority.

6-3 The proponent shall design, construct and operate the Collie Urea Plant to

ensure that noise emitted from the plant from 2200 hours on any day to 0700 hours Monday to Saturday and 0900 hours Sunday and public holidays does not exceed:

(1) a sound pressure level of 33 dB(A) at Point A on Figure 4 (the south-west receiving point of the Shotts Industrial Park Buffer adjacent to private land); and

(2) a sound pressure level of 26 dB(A) at Point B on Figure 4 (the north-

east receiving point of the Shotts Industrial Park Buffer adjacent to private land).

7 Air Quality 7-1 During commissioning, the proponent shall undertake stack testing in

accordance with Australian Standards AS 4323-1-1995 and/or United States Environmental Protection Agency methodology to fully characterise the pollutants emitted to air.

The pollutants to be measured shall include:

1. sulphur dioxide; 2. hydrogen sulphide; 3. oxides of nitrogen; 4. ozone; 5. particulates (as both PM10 and PM2.5); 6. polycyclic aromatic hydrocarbons; 7. volatile organic compounds; 8. metals; and 9. dioxins/furans.

7-2 Within three months following the stack testing required by condition 7-1, the

proponent shall submit a report on the stack testing to the Chief Executive Officer of the Office of the Environmental Protection Authority and the Chief Executive Officer of the Department of Environment and Conservation which:

1 details the methodology and results of the stack testing;

2 details the plant production rate at which the stack testing is undertaken; 3 compares the results of the stack testing with the expected emissions

described in the Public Environmental Review and associated documents listed on page 1 of schedule 1 (attached); and

4 identifies management actions to be undertaken in the event that actual

emissions are higher than described in the Public Environmental Review and associated documents listed on page 1 of schedule 1 (attached).

7-3 The proponent shall make the report on stack testing described in condition 7-2

publicly available in a manner approved by the Chief Executive Officer of the Office of the Environmental Protection Authority.

7-4 The proponent shall ensure that the emission rate of hydrogen sulphide is less

than 0.32 grams per second at all times. 7-5 The proponent shall undertake monitoring and reporting to the Chief Executive

Officer of the Office of the Environmental Protection Authority and the Chief Executive Officer of the Department of Environment and Conservation to demonstrate that the requirements of condition 7-4 are met.

8 Greenhouse Gas Abatement 8-1 The proponent shall advise the Chief Executive Officer of the Office of the

Environmental Protection Authority of progress made towards the implementation of carbon capture and storage every five years from the date of this statement.

8-2 The proponent shall retrofit carbon capture and storage for the carbon dioxide

from the gasification/gas cleanup process within five years of the Environmental Protection Authority concluding that carbon capture and storage is economically and technically proven.

8-3 Within three years following the date of this statement, and subsequently at

intervals of two years, the proponent shall prepare and submit to the Chief Executive Officer of the Office of the Environmental Protection Authority a Greenhouse Gas Abatement Report which meets the following objectives:

1 demonstrates that maximising energy efficiency and opportunities for

future energy recovery have been given due consideration in the design of the proposal;

2 ensures that the “greenhouse gas” intensity [i.e. tonne of carbon dioxide

equivalents (CO2-e) per tonne of urea produced] is equivalent to, or better than benchmarked best practice for coal-based urea production; and

3 achieves continuous improvement in “greenhouse gas” intensity through the periodic review, and if practicable, adoption of advances in technology and process management.

8-4 The proponent shall make the Greenhouse Gas Abatement Report required by

condition 8-3 publicly available in a manner approved by the Chief Executive Officer of the Office of the Environmental Protection Authority.

8-5 Conditions 8-2 and 8-3 continue to have effect and condition the implementation

of the proposal until such time as it is determined by the Chief Executive Officer of the Office of the Environmental Protection Authority that they are non-complementary to any Commonwealth greenhouse gas emissions trading scheme in force in Western Australia and the Minister for Environment provides notice in writing of concurrence with this determination.

9 Decommissioning 9-1 Prior to undertaking ground-disturbing activities, the proponent shall:

1 describe the rationale for the siting and design of plant and infrastructure as relevant to environmental protection;

2 prepare a plan for a care and maintenance phase; and 3 prepare an initial plan for the management of noxious materials following

closure. 9-2 At least six months prior to the anticipated date of closure, the proponent shall

meet the following decommissioning criteria:

1 removal or, if agreed in writing by the government and/or local government land use planning authorities, retention of plant and infrastructure agreed in consultation with relevant stakeholders / adjacent land-holders; and

2 rehabilitation of all disturbed areas to a standard suitable for the new land

use(s) as agreed pursuant to the consultation referred to in condition 9-2(1).

Procedures 1 The Minister for Environment will determine any dispute between the

proponent and the Office of the Environmental Protection Authority over the fulfilment of the requirements of the conditions.

Schedule 1 The Proposal (Assessment No. 1784) The Collie Urea Plant project will comprise of: 1 a urea manufacturing plant located at the Shotts Industrial Park, about 7.5

kilometres east of Collie.

The plant includes: • coal stockpile • coal preparation; • gasification; • gas adjustment; • acid gas cleanup; • ammonia synthesis; • urea synthesis; • urea granulation; and • power generation.

2 a urea storage and ship-loading facility at the Port of Bunbury. 3 support infrastructure including:

• rail sidings at Collie and the Port of Bunbury; • a coal conveyor from Griffin Muja coal mine to the urea plant site; • a wastewater pipeline from the urea plant site to the Verve Energy cooling

water pipeline five kilometres north; and • a water supply offtake pipeline from the Water Corporation supply

pipeline seven kilometres north-west of the urea plant site. The location of the various project components is shown in Figure 3 (attached). The main characteristics of the proposal are summarised in Table 1 below. A detailed description of the proposal is provided in Section 4 of Perdaman Chemicals and Fertilisers, Collie Urea Plant, Public Environmental Review, GHD (September 2009). Additional proposal information is included in:-

• Perdaman Chemicals and Fertilisers, Collie Urea Plant, Public Environmental Review; Appendices Volumes 1 and 2, GHD (September 2009);

• Perdaman Chemicals and Fertilisers, Report for Collie Urea Project, Air Quality Assessment, GHD (November 2009);

• Perdaman Chemicals and Fertilisers, Report for Collie Urea Plant, Public Environmental Review Supplement and Response to Submissions, GHD (December 2009); and

• Perdaman Chemicals and Fertilisers’ letter dated “20 May 2010” (sic) and received 20 April 2010, to the Mining and Industrial Assessment Branch, section 5 (page 2).

Schedule 1 (continued) Table 1: Summary of key proposal characteristics

Element Description

Collie plant site Gasification plant 2.7 Mtpa of coal. Ammonia plant 3,500 tpd nominal capacity. Urea plant 6,200 tpd nominal capacity, granulated

product (Nominal 2.1 Mtpa). Plant site area Up to 124 ha of which not less than 20 ha

will be left vegetated. Coal stockpile Up to 370,000 tonnes. Ammonia storage Not more than 10,000 tonnes capacity in

refrigerated double-skin tank. Urea storage (plant) 100,000 tonnes maximum capacity, in fully

enclosed shed.

Bunbury Port Urea storage (port) 100,000 tonnes maximum capacity, in fully

enclosed shed. Urea shiploading system Travelling, (covered) conveyor-fed,

cantilever arm loader, with direct discharge to ship’s hold via chute.

Shipping frequency (urea) Up to 100 movements per year.

Inputs Coal Up to 2.7 Mtpa. Water Up to 12.0 GL/year from various Collie

Basin sources. Limestone Up to 150 ktpa. Urea formaldehyde Up to 10 ktpa (as UF 85). Power supply Total internal generation: 220MW Combined

cycle gas turbine. [130MW - gas turbine; 90MW – heat recovery steam turbine].

Energy efficiency Not less than 24 GJ/t urea (LHV).

Materials transport Coal conveyor 8.5 km approximate length, covered and

mainly above ground.

Other products Sulphur recovered (bio-sulphur) Up to 45 tpd. Slag (non-leaching) Up to 900 tpd - initially for mine backfill.

Wastes

Saline water - disposal via existing Collie Power Station saline pipeline to sea.

Not more than 3 Mlpd.

Schedule 1 (continued) Abbreviations GJ/t gigajoules per tonne GL gigalitres (109 litres) GL/yr gigalitres per year ha hectares ktpa kilotonnes per annum

LHV lower heating value MLpd megalitres per day Mtpa megatonnes per annum MW megawatts tpd tonnes per day

Figures (attached) Figure 1: Shotts Industrial Park - Location Map (Source: PER Figure 2). Figure 2: Collie Urea Plant Site – Environmental Constraints (Source: PER Figure

17). Figure 3: Collie Urea Plant - Overall Plot Plan (Source: Proponent 27 April 2010). Figure 4: Structure Plan Map showing Noise Receiving Points A and B (Source:

LandCorp 23 April 2010). Note - The abovementioned Figures 1 and 2 are as included in the main body of this report.

Figure 3: Collie Urea Plant - Overall Plot Plan (Source: Proponent 27 April 2010).

Figure 4: Structure Plan Map showing Noise Receiving Points A and B (Source: LandCorp 23 April 2010).

Appendix 5

Summary of Submissions and Proponent’s Response to Submissions

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