Part V Works Approval, Licences and Registrations)
6.2 Emissions
Construction
Construction of both the Inert Premise and the Putrescible Premise have the potential to produce gaseous and dust emissions.
Dust emissions may be generated by heavy machinery/ vehicle movements on unsealed surfaces, in addition to activities including stripping and stockpiling topsoil, and excavating trenches/ cells. Due to the short construction timeframe of both the Inert Premise and the Putrescible Premise, dust
emissions generated during construction are short-term and would only occur during daylight hours.
If unmitigated, dust emissions have the potential to impact human health and amenity, and may also impact (via smothering) surrounding vegetation and fauna.
Air emissions may be generated during construction of the Inert Premise and the Putrescible Premise via the use of equipment and mobile vehicles. These have the potential to emit NOx, SO2, CO2, PM10
and volatile organic compounds (VOCs). Air emissions during the construction phase are expected to be minor and have a negligible impact to air quality given the short timeframe to construct the premises (1-2 weeks).
The management controls presented in Section 7 are expected to mitigate any potential impacts of dust and air emissions on people, vegetation or fauna; particularly given the closest sensitive receptor (the accommodation village) is at least 2 km from the Inert Premise and/or the Putrescible Premise (refer to Section 5).
Operation
The operation of both the Inert Premise and the Putrescible Premise may generate gaseous and dust emissions. Dust emissions may be generated during the operation of the Inert Premise and/or the Putrescible Premise through:
• Movement of vehicles on unsealed roads when delivering waste to the landfill
• Windblown dust when capping and covering of wastes with earthen material
• Maintenance activities.
If unmitigated, dust emissions have the potential to impact human health and amenity, and may also impact (via smothering) surrounding vegetation and fauna.
Air emissions may be generated through the operation of the Inert Premise and the Putrescible Premise through the use of diesel/ULP powered vehicles use or landfill maintenance if it is required.
Page 28 of 78 However, this is expected to be minor and on an as needs basis. Air emissions produced during the operation of the Inert Premise and/or the Putrescible Premise are not expected to have a significant impact on air quality.
The management controls presented in Section 7 are expected to mitigate any potential impacts of dust and air emissions on people, vegetation or fauna; particularly given the closest sensitive receptor (the accommodation village) is at least 2 km from the Inert Premise and/or the Putrescible Premise (refer to Section 5).
Noise Emissions Construction
An increase in ambient noise can be expected from the operation of machinery/ vehicles during construction of the Inert Premise and the Putrescible Premise. Noise emissions during construction will be limited to the operation of heavy equipment and vehicles. Noise emissions will not involve blasting, impulsive or vibratory equipment. Noise emissions will be temporary and are expected to be minor due to the small number of heavy equipment/ vehicles required and the short construction timeframe (1-2 weeks) for both the Inert Premise and the Putrescible Premise.
If unmitigated, noise emissions have the potential to affect human health and amenity at sensitive receptors and may deter fauna from habitats in proximity of the Inert Premise and/or the Putrescible Premise.
The management controls presented in Section 7 are expected to mitigate any potential impacts of noise emissions on people or fauna; particularly given the closest sensitive receptor (the
accommodation village) is at least 2 km from the Inert Premise and/or the Putrescible Premise (refer to Section 5). Furthermore, areas surrounding the Inert Premise and Putrescible Premise have been previously cleared of native vegetation, limiting fauna habitat in the vicinity of the premises.
Operation
The operation of both the Inert Premise and the Putrescible Premise may generate noise emissions, contributing to higher levels of ambient noise. Noise generating activities will be limited to the use of heavy equipment and vehicles, the dumping of wastes into the landfills and maintenance activities.
If unmitigated, noise emissions have the potential to affect human health and amenity at sensitive receptors and may scare aware fauna within the vicinity of the Inert Premise and/or the Putrescible Premise.
A Noise Assessment was completed for the entire Earl Grey Lithium Mine (Lloyd George 2019). This assessment determined that during worst-case meteorological conditions, noise at the nearest sensitive receiver (the accommodation village) is predicted to exceed the assigned levels. The accommodation facilities are located within the DE for the mine and, therefore, are not required to comply with the ‘assigned levels’ for occupied premises under the Environmental Protection (Noise) Regulations 1997. However, Covalent aims to ensure noise levels during operation of the Inert Premise and Putrescible Premise are within acceptable criteria to protect the health and amenity of the camp residents.
The management controls presented in Section 7 are expected to mitigate any potential impacts of noise emissions on people or fauna; particularly given the closest sensitive receptor (the
accommodation village) is at least 2 km from the Inert Premise and/or the Putrescible Premise (refer
Page 29 of 78 to Section 5). Furthermore, both the Inert Premise and the Putrescible Premise has been previously cleared of all native vegetation, limiting fauna habitat in the vicinity of the premises.
Odour Emissions Construction
The construction of the Inert Premise and the Putrescible Premise is not expected to generate odour emissions that will impact on the closest sensitive receptor (the accommodation village).
Operation
The operation of the Inert Premise is not expected to produce odours, due to the type of inert wastes disposed to this landfill category (see Section 2.3.4).
The operation of the Putrescible Premise may produce offensive odours as the putrescible waste breaks down. If unmitigated, odour emissions have the potential to impact human health and amenity of the surrounding environment. However, given the remote nature of the premise (at least 2 km from the closest receptor), and disturbed condition of the surrounding environment, impacts to human health and amenity are expected to be negligible.
Appropriate design, management, inspection, and maintenance of the Premise (refer to Section 7) will mitigate odour emissions during operation of the Putrescible Premise.
Light Emissions Construction
Construction of the Inert Premise and the Putrescible Premise will take place during daylight hours (between 6.30 am and 6 pm), with minimal lighting required to ensure safe operation of plant, machinery and access.
Given the closest receptor (the accommodation village) is more than 2 km from the Inert Premise and Putrescible Premise, use of lights by plant, machinery and vehicles is not expected to impact residents of the accommodation village. Lighting can disorient and distract fauna. However, given the short timeframe for construction and minimal lighting required, impacts to fauna are not expected.
Operation
Both the Inert Premise and the Putrescible Premise will operate during daytime hours only (between 7am and 5pm), seven days a week. Lighting will only be required on an ‘as needs’ basis, to ensure safe operation of vehicles/machinery and safe access to the premises.
Where possible, lighting will be installed to ensure directional downward illumination to minimise excessive light glare and potential impacts to fauna. Given the minimal lighting requirements and that the closest receptor (the accommodation village) is 2 km south of the Putrescible Premise, the impact of light emissions on residents and fauna during operations is expected to be negligible.
Page 30 of 78 Emissions to Land and Water
Construction
Hydrocarbons, and hazardous waste
Hazardous materials will not be stored or used on site during the construction of the Inert Premise and/or the Putrescible Premise.
A small quantity of fuel will be stored onsite during construction for refuelling of heavy machinery and vehicles, and this will be managed via the management and mitigation measures put in place by Covalent (refer to Section 7). Fuel used for refuelling will be stored within the central, bunded fuel farm that will have the capability for refuelling service trucks and heavy vehicles.
Impacts to groundwater are not expected given groundwater is estimated to occur from
approximately 58 m bgl (Section 5.5.2). Impact to surface water is also considered unlikely due to the construction of numerous earth bunds across the mine site (between 1988 and 2001) which have effectively diverted surface drainage around most of the Earl Grey Lithium Project DE (Section 5.5.3).
The design and management measures presented in Section 7 are expected to minimise the risk of discharges offsite. Therefore, contamination of land and water from hydrocarbon spills during construction of the Inert Premise and/or the Putrescible Premise is not expected.
The construction of the Project will comply with the Environmental Protection (Unauthorised Discharges) Regulations 2004.
Soil Erosion and Sedimentation
During construction of the Inert Premise and Putrescible Premise, topsoil (from within the premise footprint) will be stripped to a depth of approximately 200 mm and stockpiled nearby. Removal of topsoil and stockpiling of stripped material may compromise the stability of soils resulting in potential erosion and sedimentation of surface water (if located proximal to the premises).
Sedimentation impacts to surface waters is not expected due to the construction of numerous earth bunds across the mine site (between 1988 and 2001) which have effectively diverted surface drainage around most of the Earl Grey Lithium Project DE (Section 5.5.3).
Impacts to soils via erosion in the vicinity of the Inert Premise and the Putrescible Premise is possible, due to the excavation works required for construction.
No contaminated sites are within the vicinity of the Putrescible and/or the Inert Premise and
therefore it is unlikely that the soils are contaminated. No asbestos fibres have been found within 30 m of the natural ground surface during soil testing within the proposed Putrescible and Inert Premise.
Given the proposed premises are shallow (within 10 m of the natural ground surface), the risk of encountering asbestos fibres is low.
The management measures presented in Section 7 are expected to minimise the risk of erosion during construction of the Inert Premise and Putrescible Premise. Therefore, the risk of erosion and
sedimentation of surface water is not expected.
Page 31 of 78 Operation
Hydrocarbons and hazardous waste
Hazardous materials will not be stored within the Inert Premise and/or the Putrescible Premise during the operation these facilities. A small quantity of fuel will be stored onsite during construction for refuelling of heavy machinery and vehicles, and this will be managed via the management and mitigation measures put in place by Covalent (refer to Section 7). Fuel used for refuelling will be stored within the central, bunded fuel farm that will have the capability for refuelling service trucks and heavy vehicles.
There is the potential for accidental spills to occur when handling hydrocarbons during the operation of the Inert Premise and/or the Putrescible Premise. However, the design and management measures presented in Section 7 are expected to minimise the risk of discharges offsite. With these measures in place and given the negligible volume of fuel required to operate the premises, contamination of land and water from hydrocarbon spills is not expected.
No discharges of materials outlined in the Environmental Protection (Unauthorised Discharges) Regulations 2004 will occur offsite and therefore, no impacts to groundwater, surface water,
surrounding fauna, vegetation, or flora is expected during the operation of both the Inert Premise and the Putrescible Premise.
The operation of the plant will comply with the Environmental Protection (Unauthorised Discharges) Regulations 2004.
Windblown Wastes
The operation of both the Inert Premise and the Putrescible Premise has the potential to result in windblown litter, which may affect the amenity of the surrounding mine area and attract feral
animals. The attraction of feral animals can result in the predation and replacement of native fauna in the surrounding area.
Given the management measure in place (refer to Section 7), no impacts to the amenity of the area or native fauna is expected during the operation of the Inert Premise and the Putrescible Premise. In accordance with the Environmental Protection (Rural Landfill) Regulations 2002, a fence will be constructed around the respective boundaries of both the Inert Premise and the Putrescible Premise.
This will prevent waste from being washed or blown outside of the vicinity and will prevent feral animals from accessing the landfill.
Fires
The operation of both the Inert Premise and the Putrescible Premise has the potential to increase fire risk. Some materials disposed (see Section 2.3.4 and 3.3.4) may be combustible under certain
conditions or if contacted with particular materials. Fire can impact surrounding vegetation and fauna, and can pose a risk to nearby sensitive receptors.
Inert Premise is completely cleared of vegetation and, therefore, the risk of fire spreading outside of the Inert Premise is unlikely. The Putrescible Premise is surrounded by vegetation and, therefore, poses a higher risk of fire spreading to adjacent vegetation. Covalent will implement management measures to reduce the risk of fire and the spread to surrounding vegetation.
Given the management measure in place (refer to Section 7), the risk of fire is not expected to be significantly increased during the operation of the Inert Premise and the Putrescible Premise.
Page 32 of 78 Stormwater and Leachate
If not appropriately designed, landfill premises have the potential to collect stormwater runoff promoting seepage of contaminants to soil, groundwater (if shallow/ connected) and surface water (if located proximal to the premises).
The design and management measures presented in Section 7 are expected to minimise the risk of stormwater collecting in the Inert Premise and/or Putrescible Premise, and ensure that diverted stormwater is appropriately managed to prevent impacts to the surrounding environment.
The operation of landfill premises has the potential to result in seepage of landfill leachate to soil, groundwater (if shallow/ connected) and surface water (if located proximal to the premises). Landfill leachate may contain contaminants which can impact water quality, or elevated nutrients which can impact the health of surface waters (through processes such as eutrophication).
Impacts to groundwater are not expected given groundwater is estimated to occur from
approximately 58 m bgl (Section 5.5.2). Impact to surface water is also considered unlikely due to the construction of numerous earth bunds across the mine site (between 1988 and 2001), which have effectively diverted surface drainage around most of the Earl Grey Lithium Project DE (Section 5.5.3).
There still remains the potential for impacts to soils; however, given the nature of wastes to be disposed to the Inert Premise (see Section 2.3.4) and Putrescible Premise (see Section 3.3.4), impacts relating to leachate are unlikely.
The design and management measures presented in Section 7 are expected to minimise the risk of leachate from the Inert Premise and/or the Putrescible Premise impacting soils.
Soil Erosion and Sedimentation
Erosion of cover fill is considered unlikely given the soil types identified by MBS Environmental (2017) (refer to 5.4.3). Both the Putrescible Premise and the Inert Premise are located within Soil Type 302 which is considered stable and not susceptible to erosion. Soil excavated from the premises during construction, will be used in the first instance as fill to cover waste, preserving any topsoil for use on outer surfaces at closure of the premise. Due to the relatively flat nature of the final rehabilitated surface, erosion is expected to be negligible. Any risks associated with soil erosion will be managed through appropriate design of the premises, in addition to monitoring and corrective actions as detailed in Section 7.6.5 and Section 8.
MBS Environmental noted that the surface soil horizon (upper 200 mm) which occurs across the Earl Grey Lithium Project DE is suitable for rehabilitation purposes. This material will be stripped and stockpiled during construction, for use as outer surface cover material at closure of the Inert Premise and Putrescible Premise (and as required during operation of the premises if erosion of cover fill is observed). This material is referred hereon as ‘topsoil material’.
Sedimentation impacts to surface waters is not expected due to the construction of numerous earth bunds across the mine site (between 1988 and 2001) which effectively divert surface drainage around most of the Earl Grey Lithium Project DE (Section 5.5.3).
No contaminated sites are within the vicinity of the Putrescible and/or the Inert Premise and
therefore it is unlikely that the soils are contaminated. No asbestos fibres have been found within 30 m of the natural ground surface during soil testing within the proposed Putrescible and Inert Premise.
Page 33 of 78 Given the proposed premises are shallow (within 10 m of the natural ground surface), the risk of encountering asbestos fibres is low.
The management measures presented in Section 7 are expected to minimise risks associated with soil during operation of the Inert Premise and Putrescible Premise.
Page 34 of 78
7 Emissions Management Controls
The construction and operation of the premises will be undertaken in accordance with the Works Approval Instrument issued to Covalent and the Environmental Protection (Rural Landfill) Regulations 2002. The Covalent Lithium Construction Environmental Management Plan (COV-0000-EN-PLN-0001) provides controls on managing the following emissions.