Environmental Protection Act 1986 Licence

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Environmental Protection Act 1986 Licence
Licence Amendment – BHP Port Operation 330Mtpa

Environmental Protection
Act 1986 Licence
(L4513/1969/18)
Amendment – BHP Port
Operations 330Mtpa
Supporting Documentation

June 2020

 `Jimblebar
 L5415/1988/9
 Licence Amendment Supporting
 Documentation
 (Including Information relating to Attachments 1 to 10)

         October 2017
Environmental Protection Act 1986 Licence
Licence Amendment – BHP Port Operation 330Mtpa

Contents
1.     Introduction ....................................................................................................................................... 7
       Background ......................................................................................................................................... 7
       Purpose of this Document.................................................................................................................... 7
       Applicant details .................................................................................................................................. 7
2.     Premises ............................................................................................................................................ 8
       Location .............................................................................................................................................. 8
     2.1.1.     Tenement Details ....................................................................................................................... 8
     2.1.2.     Local Government ...................................................................................................................... 8
3.     Other Approvals and Regulatory Context ........................................................................................ 8
       State Agreement ................................................................................................................................. 8
       Part IV EP Act – Ministerial Statement 1070 ........................................................................................ 9
       Part V of the EP Act........................................................................................................................... 11
     3.3.1.     Licence L4513/1969/18 ............................................................................................................ 11
     3.3.2.     Noise Regulation...................................................................................................................... 11
     3.3.3.     Native Vegetation Clearing Permit ............................................................................................ 12
       Other Regulatory Context .................................................................................................................. 12
     3.4.1.     Port Hedland Dust Management Taskforce .............................................................................. 12
     3.4.2.     Taskforce Recommendation Endorsement ............................................................................... 12
     3.4.3.     Whole of Government Approach............................................................................................... 13
     3.4.4.     DWER/DOH Industry Regulation Fact Sheet - Managing Dust in Port Hedland ......................... 13
     3.4.5.     Planning and Development Act ................................................................................................ 13
     3.4.6.     Port Hedland Voluntary Buy Back Scheme ............................................................................... 15
4.     Overview of Proposed Infrastructure Changes.............................................................................. 15
       Route Upgrades & Productivity Initiatives........................................................................................... 19
       South Yard Expansion 1 (SYE1) ........................................................................................................ 19
       South Yard Expansion 2 (SYE2) ........................................................................................................ 19
       Car Dumper 6 (CD6) ......................................................................................................................... 20
       Proposed Implementation Approach .................................................................................................. 20
5.     Emissions and Discharges ............................................................................................................. 24
       Air Emissions .................................................................................................................................... 24
     5.1.1.     Our Focus on Air Quality .......................................................................................................... 24
       Dust Management ............................................................................................................................. 25
     5.2.1.     Dust Monitoring ........................................................................................................................ 25
     5.2.2.     Ambient Air Monitoring ............................................................................................................. 26
     5.2.3.     Dust Management Leading Practice ......................................................................................... 28
     5.2.4.     Existing Dust Controls .............................................................................................................. 28
     5.2.5.     Ore Moisture ............................................................................................................................ 32
     5.2.6.     Continual Dust Improvement Works ......................................................................................... 32
     5.2.7.     Amenity Based Improvements .................................................................................................. 33
     5.2.8.     Proposed Additional Dust Controls ........................................................................................... 33
     5.2.9.     Wind Fences ............................................................................................................................ 34

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Environmental Protection Act 1986 Licence
Licence Amendment – BHP Port Operation 330Mtpa

      5.2.10.      Air Quality Assessment ......................................................................................................... 36
      5.2.11.      Overview of Dust Model ........................................................................................................ 36
      5.2.12.      LiDAR ................................................................................................................................... 37
      5.2.13.      Potential Emission Sources ................................................................................................... 38
      5.2.14.      Updates to the Dust Model for 330Mtpa ................................................................................ 38
      5.2.15.      Air Quality Assessment Criteria ............................................................................................. 39
      5.2.16.      Summary of Dust Assessment Results.................................................................................. 39
        Noise Emissions ................................................................................................................................ 40
      5.3.1.    Noise Model ............................................................................................................................. 40
      5.3.2.    Monitoring and Model Validation............................................................................................... 41
      5.3.3.    Equipment Noise Specifications ............................................................................................... 41
      5.3.4.    Operations and Maintenance.................................................................................................... 41
      5.3.5.    Upgrades and Major Works ...................................................................................................... 42
      5.3.6.    Summary of Additional Noise Controls ..................................................................................... 42
      5.3.7.    Summary of Noise Assessment Results ................................................................................... 43
      5.3.8.    Construction Noise ................................................................................................................... 46
        Discharge to Land and Water ............................................................................................................ 46
      5.4.1.    Relocation of Freshwater Recovery Pond ................................................................................. 46
      5.4.2.    Potential Acid Sulfate Soils....................................................................................................... 46
      5.4.3.    Contaminated Sites .................................................................................................................. 46
6.      Environmental Management ........................................................................................................... 46
7.      Conclusion....................................................................................................................................... 46
8.      Other Relevant Information............................................................................................................. 47
        Community Complaints...................................................................................................................... 47
        Stakeholder Consultation................................................................................................................... 47
9.      Fee Calculation ................................................................................................................................ 49
10.     References ....................................................................................................................................... 50
11.     IR-F09 Application Form Attachments ........................................................................................... 51
Appendix 1: Comparison of BHP controls against PPA Leading Practice Guidelines .......................... 52
Appendix 2: Dust Assessment Report (GHD, 2020) ................................................................................ 55
Appendix 3: Noise Assessment Report (Talis, 2020) .............................................................................. 55
Appendix 4: Proposed Noise Control Packages ..................................................................................... 56
Appendix 5: Stakeholder Consultation Presentation .............................................................................. 58

List of Tables
Table 1: Prescribed Premises Categories for L4513/1969/18 ...................................................................... 11
Table 2: Summary of Proposed Infrastructure Changes............................................................................... 16
Table 3: Proposed Dust & Noise Control Packages ..................................................................................... 20
Table 4: Proposed Dust Control Packages .................................................................................................. 34
Table 5: Modelled Dust Concentrations at Taplin St (BHP only)................................................................... 40
Table 6: Stakeholder Engagement .............................................................................................................. 48
Table 7: Calculation of Application Fee ....................................................................................................... 49
Table 8: Summary Attachment for IR-F09 Application Form (Specific to an amendment) ............................. 51

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Environmental Protection Act 1986 Licence
Licence Amendment – BHP Port Operation 330Mtpa

List of Figures
Figure 1: Licence L4513/1969/18 premises boundary                                                10
Figure 2: Overview of Proposed Infrastructure Changes                                            15
Figure 3: Proposed Changes to Infrastructure at Finucane Island                                  17
Figure 4: Proposed Changes to Infrastructure at Nelson Point                                     18
Figure 5: Overview of Proposed Projects and Control Packages                                     22
Figure 6: Proposed Implementation Approach                                                       23
Figure 7: Port Hedland Exports                                                                   24
Figure 8: Port Hedland Dust Regulation                                                           24
Figure 9: Integrated Support Tool                                                                25
Figure 10: BHP Air Quality Monitoring Network                                                    27
Figure 11: BHP’s Direct to Ship Operating Model                                                  28
Figure 12: BHP’s Hierarchy of Dust Controls (Existing and Proposed for 330Mtpa)                  29
Figure 13: Finucane Island - Dust Controls (existing and proposed)                               30
Figure 14: Nelson Point – Dust Controls (existing and proposed)                                  31
Figure 15: Pit to Port Moisture Management System                                                32
Figure 16: Proposed Wind Fence Location and Extent                                               35
Figure 17: Finucane Island Wind Fence modelling results from Computation Fluid Dynamics method   36
Figure 18: Dust Model Receptor Locations                                                         37
Figure 19: Reduction in modelled annual average PM10 (µg/m 3) contribution (BHP only)            39
Figure 20: Location of Noise Receivers (South Hedland and Port Hedland)                          41
Figure 21: Finucane Island – Noise Controls (existing and proposed)                              44
Figure 22: Nelson Point – Noise Controls (existing and proposed)                                 45

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Environmental Protection Act 1986 Licence
Licence Amendment – BHP Port Operation 330Mtpa

Glossary

 Abbreviation          Term
 ALARP                 As Low as Reasonably Practicable
 BHP                   BHP Billiton Iron Ore Pty Ltd
 BOC                   Bulk Ore Conditioning
 BWR                   Bucket Wheel Reclaimer
 BWS                   Belt Wash Station
 CAM                   Cumulative Air Model
 Category D cyclonic   Cyclonic event that has a mean wind speed of between 160 – 199 km/h and wind
 event                 gusts up to 255-279 km/h (BOM, 2020)
 CBD                   Central Business District
 CD                    Car Dumper
 CD6                   Car Dumper 6
 CNMP                  Construction Noise Management Plan
 dB(A)                 Decibels A-weighted
 DEM                   Dust Extinction Moisture
 DJTSI                 Department of Jobs, Tourism, Science and Innovation
 DoH                   Department of Health
 DSD                   Department of State Development (now DJTSI)
 DTS                   Direct to Ship
 DWER                  Department of Water and Environmental Regulation
 EMS                   ISO14001 certified Environmental Management System
 ENRMP                 Environmental Noise Reduction Management Plan
 EP Act                Environmental Protection Act 1986
 EPA                   Environmental Protection Authority
 FI                    Finucane Island
 FWRP                  Freshwater Recovery Pond
 HPU                   Hydraulic Power Unit
 HRA                   Health Risk Assessment
 IP50                  West End Improvement Plan No. 50.
 JTWG                  Joint Technical Working Groups
 km/h                  Kilometres Per Hour
 LGA                   Local Government Authority
 LiDAR                 Light Detection and Ranging
 LRP                   Lump Rescreening Plant
      -1
 ms                    Meters Per Second
                       Ministerial Statement 740 - Change to the conditions of MS433 &740 pursuant to
 MS1080
                       section 46 of the EP Act (approved on 18 December 2017)
                       Ministerial Statement 433 – Upgrade Dust Management at Finucane Island and
 MS433
                       Nelson Point, Point Hedland issued on 14 November 1996

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Environmental Protection Act 1986 Licence
Licence Amendment – BHP Port Operation 330Mtpa

 Abbreviation         Term
                      Ministerial Statement 740 – Change to the conditions of MS433 pursuant to
 MS740
                      section 46 of the EP Act (approved on 16 May 2007)
 Mtpa                 Million Tonnes Per Annum
 NP                   Nelson Point
 NVCP                 Native Vegetation Clearing Permit
 P                    Conveyor
 PPA                  Pilbara Ports Authority
 RU                   Route Upgrade
 SEG                  Stakeholder Engagement Group
 SL                   Ship Loader
 SPL                  Sound Power Level
 STK                  Stacker
 SY                   South Yard Nelson Point
 SYE1                 South Yard Expansion – Stage 1
 SYE2                 South Yard Expansion – Stage 2
 Taskforce            Port Hedland Dust Management Taskforce
 TS                   Transfer Station
 tph                  Tonnes Per Hour
 ULNI-H               Hybrid Ultra Low Noise Idler
 WA                   Western Australia
 WAPC                 Western Australian Planning Commission
 WY                   West Yard Finucane Island

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Licence Amendment – BHP Port Operation 330Mtpa

1. Introduction

          Background

The Port of Port Hedland is the largest bulk export terminal in the world and is one of Australia’s most important
pieces of economic infrastructure. A recent economic assessment of the Port was compiled by ACIL Allen
Consulting for The Port Hedland Industries Council (PHIC). The report found that the port’s economic
contribution in 2018/19 accounted for 20 per cent of WA’s Gross State Product, added $54.7 billion to WA’s
economy and is responsible for one in every 12 jobs throughout the State.

BHP Billiton Iron Ore Pty Ltd (BHP) has Port Operations in Port Hedland at Nelson Point and Finucane Island
(Port Operations) to support the export of iron ore products from mines located within the Pilbara region of
Western Australia (WA). The current approved production capacity for the loading of iron ore onto vessels at
BHP’s Port Hedland Port Operations is 290 million tonnes per annum (Mtpa).

Following an inquiry and report by the Environmental Protection Authority under section 46 of the Environmental
Protection Act 1986 (EP Act), the Minister for Environment approved on 18 December 2017, through the issue
of Ministerial Statement 1070, deletion of the implementation conditions in Ministerial Statements 433 and 740.
Furthermore, Condition 2 of Ministerial Statement 1070 states that the proposal may be implemented, subject
to any licence in relation to operations on Finucane Island and Nelson Point, Port Hedland under Part V of the
EP Act.

On 19 February 2018, the Department of Water and Environmental Regulation (DWER) issued BHP an
amended Licence (L4513/1969/18) which included an increase in the production capacity for iron ore loaded
onto vessels at BHP’s port facilities, at Nelson Point and Finucane Island, from 270Mtpa to 290Mtpa.

         Purpose of this Document
This supporting information document has been prepared to provide supplementary information to the Licence
Amendment Application for BHP’s Port Operations, as required under Section 59B of the EP Act.

This licence amendment application seeks to increase the approved production capacity (Category 58) under
the current Licence (L4513/1969/18), from 290Mtpa to 330Mtpa. This licence amendment application also
seeks approval to construct projects (route upgrades and major works) required to support the proposed
increase in production capacity. These projects remain subject to BHP’s internal project approval processes.

        Applicant details
BHP’s Port Operations consist of iron ore unloading, re-screening, stockpiling and ship loading activities at
Finucane Island Operations (west) and Nelson Point Operations (east), located on opposite sides of the Port
Hedland Inner Harbour.

This Licence application has been submitted by BHP as manager and agent for and on behalf of the Mount
Newman Joint Venture participants and the Mount Goldsworthy Mining Associates Joint Venture participants.

Licence Holder:

BHP Billiton Iron Ore Pty Ltd (ABN 46 008 700 981)
PO Box 7122
CLOISTERS SQUARE WA 6850

The key contact for this application is:
       Chris Serginson
       Manager Environment
       Phone: 0419 954 728
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Licence Amendment – BHP Port Operation 330Mtpa

        Email: chris.serginson@bhp.com
        Level 41, 125 St Georges Terrace
        Perth WA 6000 Australia

2. Premises
         Location
The current prescribed premise is located within Nelson Point and Finucane Island leases. The proposed works
(outlined in section 4) are located within the existing L4513/1969/18 premises boundary (refer to Figure 1). The
prescribed premise boundary relates to land owned by, or leased to, the Mount Newman Joint Venture
participants and the Mount Goldsworthy Mining Associates Joint Venture participants.

2.1.1. Tenement Details
The proposed infrastructure is located primarily on the following tenure:

 I123400              Nelson Point Wharf     Mount Newman Joint        Iron Ore (Mount Newman)
                                             Venture                   Agreement Act 1964 (WA)
 I123403              Nelson Point           Mount Newman Joint        Iron Ore (Mount Newman)
                                             Venture                   Agreement Act 1964 (WA)
 K693815              Under Harbour          Mount Newman Joint        Iron Ore (Mount Newman)
                      Tunnel                 Venture                   Agreement Act 1964 (WA)
 I126342              Finucane Island        Mount Goldsworthy         Iron Ore (Mount Goldsworthy)
                      Loop                   Joint Venture             Agreement Act 1964 (WA)
 J998595              Finucane Island        Mount Goldsworthy         Iron Ore (Mount Goldsworthy)
                                             Joint Venture             Agreement Act 1964 (WA)
 M653978              Goldsworthy Rail       Mount Goldsworthy         Iron Ore (Mount Goldsworthy)
 (formerly                                   Joint Venture             Agreement Act 1964 (WA)
 J998591)
 K693809              Pace Wharf             Mount Goldsworthy         Iron Ore (Mount Goldsworthy)
                                             Joint Venture             Agreement Act 1964 (WA)
 K693808              Harriet Point          Mount Goldsworthy         Iron Ore (Mount Goldsworthy)
                                             Joint Venture             Agreement Act 1964 (WA)
 K693814              Utah Jild              BHP Billiton Direct       Iron Ore Beneficiation (BHP)
 * See Note 1                                Reduced Iron Pty Ltd      Agreement Act 1996 (WA)
                                                                       (Repealed)
 G943533              Finucane Island        Mount Goldsworthy         Land Administration Act 1997
                      Substation             Joint Venture             (WA).

Note 1:
Clause (4)(c) of the Iron Ore Agreements Legislation (Amendment, Termination and Repeals) Act 2011 (WA)
(Termination Act) terminated the Iron Ore Beneficiation (BHP) Agreement Act 1996 (WA) (Beneficiation
Agreement) and provides a replacement lease would be granted in the name of Mount Goldsworthy Joint
Venturers and subject to Iron Ore (Mount Goldsworthy) Agreement Act 1964. The Joint Venturers and the
Pilbara Port Authority are currently finalising the replacement Utah Jild lease.

2.1.2. Local Government
The BHP Port Operations are located within the Town of Port Hedland.

3. Other Approvals and Regulatory Context

This section details the approvals that govern BHP’s Port Operations and provides context on the broader
regulatory landscape of Port Hedland.

        State Agreement
The Premises are held under the following State Agreement Acts:
   Iron Ore (Mount Newman) Agreement Act 1964 (WA); and
   Iron Ore (Mount Goldsworthy) Agreement Act 1964 (WA).

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Licence Amendment – BHP Port Operation 330Mtpa

       Part IV EP Act – Ministerial Statement 1070
The BHP Port Operations were previously subject to Part IV of the EP Act by virtue of Ministerial Statement
433 (MS433) and Ministerial Statement 740 (MS740).

In 2016, DWER advised BHP that dust regulated under both Part IV and Part V of the EP Act involved regulatory
duplication. As such, DWER and the then Office of the Environmental Protection Authority (EPA) determined
a consistent and singular regulatory approach for bulk handling port premises should be adopted.

In 2017, EPA undertook an inquiry into the conditions of Ministerial Statements 433 and 740 under section 46
of the EP Act at the request of the Minister for Environment. Subsequently the EPA released EPA Report 1608
in November 2017 (EPA 2017). EPA Report 1608 states “the EPA’s view is that the current application by BHP
for an increase in throughput from 270Mtpa to 290Mtpa, and any future increases, can be appropriately dealt
with under Part V of the EP Act.” Ministerial Statement 1070 was issued on 18 December 2017 under section
46 of the EP Act deleting each of the implementation conditions in Ministerial Statements 433 and 740.

By the current amendment application, BHP is seeking approval of future works and associated emissions to
facilitate an increase in production throughput capacity from 290Mtpa to 330Mtpa. Based on the EPA’s
recommendation in EPA Report 1608, BHP considers that a licence amendment to support the proposed future
upgrade works meets the objective of a consistent and singular regulatory approach for bulk handling port
premises, to avoid regulatory duplication.

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Licence Amendment – BHP Port Operation 330Mtpa

Figure 1: Licence L4513/1969/18 premises boundary

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Licence Amendment – BHP Port Operation 330Mtpa

         Part V of the EP Act
3.3.1. Licence L4513/1969/18
Pursuant to an application lodged by BHP in 2016, DWER conducted a risk-based assessment of BHP’s
Licence for an increase in throughput capacity from 270Mtpa to 290Mtpa.

Subsequently an amended environmental licence for Prescribed Premises (L4513/1969/18) was issued by
DWER under Part V of the EP Act for BHP’s Port Operations at Nelson Point and Finucane Island (Figure 1).
Table 2 outlines the prescribed activities currently approved under L4513/1969/18, in accordance with the
Environmental Protection Regulations 1987.

Table 1: Prescribed Premises Categories for L4513/1969/18

     Category Category description                     Category production Approved Premises
     number                                            or design capacity  production or design
                                                                           capacity

     5           Processing or beneficiation of        50 000 tonnes or         155 million tonnes per
                 metallic or non-metallic ore          more per year.           annual period.
     54          Sewage facility                       100 cubic metres or      260.9 cubic metres per
                                                       more per day.            day.

     58          Bulk material loading or unloading    100 tonnes or more       290 million tonnes per
                                                       per day.                 annual period.
     61          Liquid waste facility                 100 tonnes or more       8000 tonnes per annual
                                                       per year.                period.
     73          Bulk storage of chemicals, etc.       1 000 cubic metres in    63 336 cubic metres in
                                                       aggregate.               aggregate.

BHP is seeking through this licence amendment application to increase throughput capacity under Category
58 from 290Mtpa to 330Mtpa. No changes are requested to the remaining prescribed premise categories.

3.3.2. Noise Regulation
Environmental noise at BHP’s Port Operations is managed in accordance with an Environmental Noise
Reduction Management Plan (ENRMP).

The ENRMP sets out the following noise objectives for BHP’s Port Operations:

 ·    Reduce noise to as low as reasonably practicable, acknowledging growth, and where reasonably
      possible, comply with the requirements of the Environmental Protection (Noise) Regulations 1997
      (including seeking an exemption if necessary);
 ·    Where it is impracticable to comply with Environmental Protection (Noise) Regulations 1997, ensure
      continuous improvement is facilitated through a Noise Reduction Management Plan (NRMP);
 ·    Ensure that new plant and infrastructure being planned for the Port facilities particularly Prescribed Plant
      as defined by the Environmental Protection Act (1986), complies with the Environmental Protection
      (Noise) Regulations 1997 where land use planning constraints allow; and
 ·    Comply with the Western Australian Planning Commission’s State Planning Policy 5.4, Road and Rail
      Transport Noise and Freight Considerations in Land Use Planning where land use planning constraints
      allow.

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Licence Amendment – BHP Port Operation 330Mtpa
3.3.3.   Native Vegetation Clearing Permit
BHP currently holds a number of Native Vegetation Clearing Permits (NVCP) over the area of the existing
prescribed premises for L4513/1969/18 including CPS 7009/2, which supports clearing associated with,
railways, general port infrastructure and all associated infrastructure.
The proposed Finucane Island Wind Fence is being constructed on a previously built rail formation within the
prescribed premises boundary. As such the area has been previously disturbed, however if required BHP will
apply for an amendment to CPS 7009/2 to support any additional clearing that may be required for construction
of the wind fence.
         Other Regulatory Context

3.4.1. Port Hedland Dust Management Taskforce
In May 2009, the State Government established the Port Hedland Dust Management Taskforce (Taskforce) to
plan for and provide effective dust management strategies in Port Hedland. The former Department of State
Development, now the Department of Jobs, Tourism, Science and Innovation (DJTSI) chaired the Taskforce
that comprised representatives from government and industry, including BHP.

The Port Hedland Air Quality and Noise Management Plan (AQNMP) was released by DJTSI in 2010 and
subsequently adopted by the State Government, for ongoing air quality and noise management in Port Hedland.
The AQNMP details the implementation strategy for air quality and noise reduction in Port Hedland.

The Department of Health (DoH) released a Health Risk Assessment (HRA) report on the air quality in Port
Hedland in January 2016.

3.4.2. Taskforce Recommendation Endorsement
In response to the HRA report, DJTSI released the Port Hedland Dust Management Taskforce Report to
Government (August 2016) (Taskforce Report) for public comment on 9 August 2017.

The State Government released its response to the Taskforce Report on 15 October 2018. The Taskforce was
disbanded in October 2018 with accountabilities for Taskforce recommendations allocated to key government
agencies.

In particular, the State endorsed the following key Taskforce recommendations:
Health Risk Assessment
     o Interim guideline of 24-hour PM10 of 70μg/m3 (excluding natural events) continues to apply to
          residential areas of Port Hedland and that measures should be introduced to cap (and if possible,
          reduce) the number of permanent residents in dust-affected areas of Port Hedland.
Air Quality Monitoring
     o Full transfer of the operation and maintenance of the Port Hedland Industries Council (PHIC) air
          quality monitoring network to the DWER.
·    Industry Dust Management and Regulation
     o A coordinated risk-based review and assessment approach to managing dust in Port Hedland.
     o An independent third-party review and develop a dust management guideline for bulk handling port
          premises, outlining its expectations in relation to the assessment of dust impacts, dust control and
          monitoring requirements from these premises.
·    Local Government and Community
     o Town of Port Hedland works with key stakeholders to identify and mitigate dust from non-industry
          sources.
·    Noise
     o DWER working with industry to explore the feasibility of approvals under Regulation 17 of the
          Environmental Protection (Noise) Regulations 1997, where the prescribed noise standard cannot be
          met by individual premises.
     o Port Hedland Cumulative Noise study is used to inform land-use planning for the West End of Port
          Hedland.
·    Land-Use Planning
     o Appropriate planning controls be implemented to prohibit sensitive land uses and restrict population
          growth in the West End of Port Hedland.

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Licence Amendment – BHP Port Operation 330Mtpa

3.4.3. Whole of Government Approach
BHP supports the State Government’s holistic approach to resolving the land use conflict in the Port Hedland
West End, building on the implementation of the Dust Taskforce recommendations. This holistic approach
includes the following six elements:

1.   Modern planning principles applied to limit population exposure and population growth (progression of the
     Improvement Plan No. 50 and West End Improvement Scheme 1).
2.   Taskforce Interim Guidelines for PM10 particles (24-hour average of 70µg /m3) continue to apply in residential
     areas.
3.   Port Hedland Voluntary Buyback Scheme (PHVBS) to provide residents and landowners west of Taplin
     Street the opportunity to sell or relocate.
4.   Town planning program to increase green belts and establish redevelopment opportunities.
5.   Health exposure education on health risk management for those who choose to stay post-buy back, noting
     the outcomes of the scenarios described in the HRA concluded that 70µg/m3 for PM10 provided a similar
     level of protection to the current population of Port Hedland, as would the NEPM standard for PM10 of
     50 µg/m 3 in urban areas.
6.   Best Practice Dust Guidelines to be developed by independent consultants, in consultation with industry.

3.4.4. DWER/DOH Industry Regulation Fact Sheet - Managing Dust in Port Hedland
In 2018, DWER and DoH released the Industry Regulation Fact Sheet: Managing Dust in Port Hedland (DWER,
DoH, 2018) in response to the State Government endorsement of the Taskforce Recommendations.

In the fact sheet, DWER details the road map for improved industry practices.
The planned approach includes:

     ·   Developing and implementing best practice dust management guidelines for bulk handling port
         premises, designed to reduce emissions from port operators;
     ·   Taking control of the ambient air quality monitoring network, subject to negotiations over the
         configuration of the network and ensuring any incurred costs are covered by industry in accordance
         with the ‘polluter pays’ principle; and
     ·   Implementing a coordinated risk-based review and assessment of all port operator licences, to
         incorporate more robust regulatory controls in line with the best practice guidelines.

In addition, DWER (2018) provided guidance on its interim regulatory approach including:

     ·   DWER has proposed a five-year plan for the proposed improvements to be finalised. Planning controls
         will also take a considerable period before changes begin to take effect;
     ·   DWER will take a conservative approach to the assessment of any works approval, licence or
         amendment applications received for premises in the Port Hedland air shed, until the self-assessment
         stages of the process are completed and submitted;
     ·   Applicants will be encouraged to demonstrate no net increase to dust emissions in Port Hedland from
         port related activities. Where this isn’t demonstrated, DWER will consider further controls that may in
         part serve to offset any increase in dust emissions; and
     ·   Any changes to operations in the interim period will still be subject to the best practice dust
         management guidelines when they are defined, and port operators may be asked retrospectively to
         address any performance gaps that are identified.

3.4.5. Planning and Development Act
In August 2019, the State Government approved the Western Australian Planning Commission’s (WAPC)
recommendation for Port Hedland’s West End to be the subject of (the now gazetted) Improvement Plan No.
50 (IP50) and eventual gazettal of an Improvement Scheme.

The purpose of IP50 is to:
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Licence Amendment – BHP Port Operation 330Mtpa

    ·   Enable the WAPC to undertake all necessary steps to advance the planning and development within
        the plan area as provided for under Part 8 of the Planning and Development Act 2005 (PD Act);
    ·   Establish the strategic planning and development intent within the subject area; provide for a strategic
        planning framework endorsed by the WAPC, Minister for Planning and the Governor;
    ·   Authorise the preparation of an improvement scheme;
    ·   Provide the objectives of an improvement scheme; and
    ·   Provide guidance to the preparation of statutory plans, statutory referral documentation and policy
        instruments.

IP50 authorises the making of an improvement scheme, by resolution of the WAPC and approval of the Minister
for Planning. The following objectives will guide the preparation of the improvement scheme:
     · To provide a strategic planning framework to determine future land uses considering all land use
        options that takes into consideration physical, economic, social, and environment factors;
     · To provide a statutory planning instrument through which to implement the strategic planning
        framework and effectively guide the preparation of statutory plans, statutory referral documentation
        and policy (as may be required) to facilitate orderly and proper planning of the area; and
     · To implement the State Government response to the Port Hedland Dust Management Taskforce
        Report to State Government to prohibit sensitive land uses and restrict population growth in the West
        End of Port Hedland.

In March 2020, the WAPC advertised the Port Hedland West End Improvement Scheme No 1 for public
comment, with submissions due by 3 July 2020. The purposes and aims are articulated in the scheme
document as follows:
The purposes of this Scheme are to –
    a) set out the Commission’s planning aims and intentions for the Scheme area;
    b) set aside land as local reserves for public purposes;
    c) zone land within the Scheme area for the purposes defined in this Scheme;
    d) control and guide development including processes for the preparation of structure plans, activity
       centre plans, and local development plans;
    e) set out procedures for the assessment and determination of development applications;
    f) make provision for the administration and enforcement of this Scheme; and
    g) address other matters referred to in Schedule 7 of the Act.

Aims of this Scheme are -
   a) to provide a statutory planning instrument through which to implement the strategic planning
        framework and effectively guide the preparation of statutory plans, statutory referral documentation
        and policy (as may be required) to facilitate orderly and proper planning of the Scheme area;

    b) to implement the Government response to the Port Hedland Dust Management Taskforce Report to
       Government (2016) to prohibit sensitive land uses and restrict population growth in the West End of
       Port Hedland by prohibiting:
                 a. new residential development; and
                 b. development intended for use either exclusively or primarily by sensitive groups within the
                 general population including:
                         i. older people (over 65 years);
                         ii. people with pre-existing cardiovascular or respiratory disease;
                         iii. children and adults with pre-existing respiratory conditions (asthma, bronchitis,
                         chronic obstructive pulmonary disease); and
                         iv. children.
    c) to facilitate opportunities for investment and development of quality built form and public place design
       across the Scheme area and public foreshore reserve interfaces that recognise the iconic location and
       heritage significance of the Port Hedland West End.

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Licence Amendment – BHP Port Operation 330Mtpa

3.4.6. Port Hedland Voluntary Buy Back Scheme
In September 2019, the State Government announced the proposal to develop an industry funded Port Hedland
Voluntary Buy Back Scheme (PHVBS). The Pilbara Development Commission website states:

The PHVBS has been proposed in recognition that owners of residential properties in Port Hedland’s West End
are uniquely impacted by proposed planning changes proposed as part of the West End Improvement Plan
No. 50. The PHVBS covers residential properties within the Improvement Plan area.

The State Government is responding to the recommendations of the Taskforce Report, in part by developing
the PHVBS which recognises the fact that the owners of residential properties covered by Port Hedland’s West
End Improvement Plan No. 50 between Taplin Street and the Port will be impacted by recent and future
planning legislation.

The PHVBS is an important component of the WA Government’s holistic approach to resolving the West End
land use conflict and gives residents and landowners in the area the option to relocate or sell.

4.       Overview of Proposed Infrastructure Changes
This application proposes to undertake upgrades to existing equipment at Finucane Island and Nelson Point to
increase the production capacity of existing infrastructure through route upgrades/productivity initiatives and
through the installation of new infrastructure (major works) at Nelson Point, to increase overall throughout
capacity from 290Mtpa to 330Mtpa (Figure 2 and Table 2).

Figure 2: Overview of Proposed Infrastructure Changes

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Table 2: Summary of Proposed Infrastructure Changes

 Project                Summary of Works                                                  Location

 Route                · Bucket Wheel Reclaimer 6 (BWR6) Hydraulic Drive and Route      Finucane
 Upgrades/Productivity Upgrade to Ship Loader (SL) 5&6 at 13,500 tonnes per hour (tph) Island and
 initiatives          · BWR7 Hydraulic Drive and Route Upgrade to SL7&8 (13,500tph) Nelson Point
                      · BWR8 Hydraulic Drive and Route Upgrade to SL3&4
                        (11,400tph,12,500tph)
                      · BWR10 to SL7 and SL8 (via LRP20 to 18,000tph)
                      · LRP 2 upgrades to 18,000tph
                      · Upgrade CD3 to SL1 and SL2 (via P730) to 15,400tph
                      · Replacement of Ship Loader 3
                      · Upgrade DTS route to SL3 to 13,500tph
                      · Upgrade route from BWR8 to SL3 to 13,500tph.
 Major Works            · New stockpile (F area) in South Yard at Nelson Point            Nelson Point
 South Yard             · New reclaimer 11 (BWR11) at 15,400 (tph) to SL5 & 6
 Expansion – Stage 1    · New reclaimer 11 (BWR11) at 14,500tph feed rate to LRP3
 (SYE1)
                        · New reclaimer yard conveyor (P773 and Transfer Stations)
                        · Upgrade existing Stacker (ST6) to 16,000tph
                        · Upgrade inflow conveyors from car dumper 2 (CD2) and CD3 to
                          STK6 to 16,000tph
                        · Upgrade LRP3 to 14,500tph feed rate from BWR11
                        · Upgrade LRP3 feed conveyors to 14,500tph
 Major Works            · New stockpile (X area) in South Yard at Nelson Point            Nelson Point
 South Yard             · New Stacker (STK14) at 20,000tph
 Expansion - Stage 2    · New conveyors and associated transfer stations from CD2 and
 (SYE2)                   CD3 to new STK14
                        · LRP 3 upgrades to 18,000tph
 Major Works            ·   New Car Dumper 6                                              Nelson Point
 Car Dumper 6 (CD6)     ·   CD6 to Stackers SY (STK6, STK7, STK14)
                        ·   CD6 to Stackers NY (STK5, STK8)
                        ·   CD6 via conveyor P238 to SL1, SL2
                        ·   New Sample station for P238 (SS238)
 Major Works            · New route from CD2, CD3 and CD6 to SL5 & SL6 (P218)             Nelson Point
 SYE2 & CD6 shared      · New sample station for P218 route (SS218)
 scope                  · New route connection (P729 & P774) from BWR11 to SL1, SL2,
 (Works could be          SL5 & SL6 via P218, P238 & P730 conveyors
 completed under        · Modify and upgrade A & B berth conveyors and SL1 & SL2
 either SYE2 or CD6)

Figures 3 and 4 below provide an overview of the proposed changes at Nelson Point and Finucane Island.
Detailed descriptions of the proposed works are contained in the following Sections 4.1-4.4.

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Licence Amendment – BHP Port Operation 330Mtpa

Figure 3: Proposed Changes to Infrastructure at Finucane Island

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Licence Amendment – BHP Port Operation 330Mtpa

Figure 4: Proposed Changes to Infrastructure at Nelson Point

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Licence Amendment – BHP Port Operation 330Mtpa

     Route Upgrades & Productivity Initiatives
A number of route upgrades are being proposed at Finucane Island and Nelson Point:

·   Upgrade BWR 7 (Finucane Island) from 10,500 to 13,500 tonnes per hour (tph) and modify existing
    conveyors and transfer stations to LRP2, SL7 & SL8 to 13,500tph;
·   Upgrade BWR 8 (Finucane Island) from 10,500 to 13,500tph and modify existing conveyors and transfer
    stations to SL4 (12,500tph);
·   Upgrade BWR 6 (Nelson Point) from 10,000 to 13,500tph and modify existing conveyors and transfer
    stations to LRP3, SL5 & SL6 to 13,500tph;
·   Upgrade CD3 to SL1 and SL2 via P730 to 15,400tph;
·   Upgrade BWR10 route to SL7 and SL8 (via LRP2) to 18,000tph;
·   Replace Ship Loader 3 and upgrade;
·   LRP 3 upgrades to 18,000tph
·   CD5 route to SL3 to 13,500tph; and
·   BWR8 route to SL3 to 13,500tph.

The bucket wheel reclaimer and associated infrastructure works (for BWR6, BWR7 & BWR8) consist of the
following upgrades:

·   New hydraulic power unit (HPU) BWR drives on counter weight boom;
·   Replace existing electro mechanical drives with hydraulic drives;
·   Upgrade bearings and drive couplings;
·   Replace sliding chute;
·   Transfer chute upgrades;
·   Upgrades to buckets;
·   Upgrade boom conveyor drive pulley; and
·   New conveyor drives.

      South Yard Expansion 1 (SYE1)
BHP proposes to execute upgrade works to expand its south yard infrastructure at Nelson Point. The upgrades
would be undertaken in two stages. Stage 1 is further detailed in this section, with stage 2 detailed in section
4.3.

SYE1 includes the following infrastructure:
· A new bucket wheel reclaimer 11 (BWR11) which is designed to run at a maximum rate of 18,000tph;
· The BWR 11 will reclaim iron ore products from a new stockpile (Row F) to ship loader 5 & 6 (SL5, SL6) at
   a rate of 15,400 tph via conveyor P564;
· Route upgrade from the BWR 11 to Lump Rescreening Plant 3 (LRP3) via conveyor P510 at a rate of
   14,500 tph (from 10,500 tph);
· Route upgrades from car dumper 2 & 3 (CD2, CD3) to Stacker 6 at a rate of 16,000 tph; and
· Dust and noise controls detailed in sections 5.2 and 5.3 respectively.

     South Yard Expansion 2 (SYE2)
The second stage of the proposed South Yard Expansion works at Nelson Point includes the following
components:
· New stacker (Stacker 14) and stockyard row;
· Modification to existing and installation of new conveyors and transfer stations to receive ore from car
   dumper 2 and 3 and feed Stacker 14;
· Modification to existing and installation of new conveyors and transfer stations to Nelson Point ship loaders;
· Upgrade of lump rescreening plant;
· New sample stations aligned to new route alignments;
· Upgrades to the freshwater recovery system including installation of a new thickener plant to treat process
   water for reuse on site; and
· Dust and noise controls detailed in sections 5.2 and 5.3 respectively.

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Licence Amendment – BHP Port Operation 330Mtpa
The South Yard Expansion 1 & 2 would require ground improvement works to ensure the foundations can
support the new stockyard and associated infrastructure. Ground improvements will require mobile equipment
to install stone columns to strengthen the foundations. In order to install the stone columns, excavation and
dewatering is required. Management of soil and dewatering is discussed in section 5.4.

      Car Dumper 6 (CD6)
The proposed works at Nelson Point includes the construction of a new train unloading facility (CD6) and
associated materials handling equipment. The new car dumper would be located on an existing rail route
previously used for the ore car repair shop in Nelson Point. The proposed CD6 will be used to direct-feed ship
load and to feed the existing stockyards at Nelson Point.

The proposed works at BHP’s Nelson Point operations associated with CD6 include the following:
· New rotary car dumper, excavated vault and conveyor tunnel;
· Modification to existing conveyors and installation of new conveyors and transfer stations to receive feed
   from CD6 infrastructure;
· Upgrade of power and control system infrastructure;
· Modification to rail infrastructure and removal of some redundant lines;
· New traffic bridge over Nelson Point rail yard infrastructure; and
· Dust and noise controls detailed in sections 5.2 and 5.3 respectively.

The proposed CD6 development includes temporary works to enable construction of the car dumper, including
a dewatering system capable of lowering the water table during bulk earthworks and a hydrocarbon
decontamination plant and waste lagoon. Minor demolition works would also be required for the proposed
installation of CD6 and associated infrastructure including removal, refurbishment and relocation of buildings
and infrastructure.

       Proposed Implementation Approach
BHP has proposed a strategic approach to this licence amendment, which would afford flexibility to BHP to
determine the timing and order that the individual projects (comprising the works) could be executed. The
construction and operation of each project would be approved under the licence, along with the associated
increase in throughput capacity (Table 3). Each project has a suite of dust and noise controls as an integral
part of the works, which are designed to deliver a no net increase in noise emissions and an overall net
reduction in dust emissions (Table 3). The respective dust and noise control packages would be completed
prior to the associated increase in throughput capacity taking effect.

Table 3: Proposed Dust & Noise Control Packages

 Projects               Package          Dust Controls                Noise Controls      Approved
                                         (Detailed in                 (Detailed in        Throughput
                                         Section 5.2.7)               Appendix 4)         Capacity
                                                                                          (Category 58)
  • Route Upgrades       Package 1A       • South Yard belt wash        Hybrid Ultra Low 295Mtpa
    and Productivity                        stations                    Noise Idler
                                          • Sealing of open areas       Program
                                          • Fogging units in Car
                                            Dumpers
                                          • Vehicle reduction
                         Package 1B       • Finucane Island Wind        Scope related     303Mtpa
                                            Fence                       controls
  Major Works            Package 2A    • South Yard Wind Fence          Scope related     330Mtpa
  • South Yard          (With Package Scope related controls:           controls
    Expansion 1          1A and 1B)     − Reclaimer boom sprays
                                        − Automated stockpile
                                          water cannons
                                        − Belt wash station

  Major Works           Package 2B Scope related controls:              Scope related
  • South Yard         (With Package − Luffing stacker with             controls
    Expansion 2        1A, 1B and 2A)   boom sprays
                                      − Automated stockpile
                                        water cannons
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Licence Amendment – BHP Port Operation 330Mtpa

                                          − Belt wash station

  Major Works           Package 2C    Scope related controls:           Scope related
  • Car Dumper 6        (With Package − Enclosed with wet               controls
                        1A, 1B and       scrubber extraction and
                        2A)              collection system
                                      − Fogging unit
                                      − Belt wash station

Under this proposed approach the construction and operation of these projects could occur sequentially (in any
order) or with one or more projects executed concurrently if this need arises e.g. routes upgrades and major
works project.

As an example, if BHP proceeds first with increasing throughput above the current licenced capacity (290Mtpa)
through route upgrades, then the proposed works will be completed along with dust control package 1A and
noise control package 1A (Table 3), prior to throughput exceeding 290Mtpa. Throughput could then increase
up to 295Mtpa. Once dust and noise control packages 1B are completed, throughput could then increase up
to 303Mtpa.

In an alternate scenario, where BHP proceeds first with a major works package, for example SYE1, then the
proposed works will be completed along with dust and noise control package 2A (Table 3), prior to throughput
exceeding 290Mtpa. Under this scenario, BHP would also complete dust and noise control packages 1A and
1B. This approach is designed to ensure a no net increase in dust and noise emissions. Following the
completion of SYE1 and dust and noise control packages (1A, 1B, 2A), BHP could increase throughput capacity
to the full 330Mtpa. Completion of the remainder of the works (SYE2 & CD6) could then be done later as
required, along with the scope related controls (Package 2B and 2C respectively). Scope related controls are
those controls that would only be installed when the works are constructed.

Some dust and noise controls may be installed prior to the construction of the associated project, for example
the Finucane Island Wind Fence. It is intended that where these controls are installed earlier (ahead of the
associated works), it is for the benefit of the overall capacity upgrade from 290Mtpa to 330Mtpa and would
support the future implementation of the remaining works approved under this licence amendment.

SYE2 would be constructed after SYE1. A South Yard Wind Fence will be constructed with SYE1 to provide
dust reduction benefits for SYE1 & SYE2.

Once the full dust and noise control packages are installed and BHP is operating at 330Mtpa, this approach
has been designed to maintain a no net increase in noise emissions and achieve an overall reduction in BHP’s
dust emissions (refer to Sections 5.2 and 5.3).

Figures 5 and 6 included below further illustrate the proposed approach to the implementation of the projects
and the associated dust and noise control packages.

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Licence Amendment – BHP Port Operation 330Mtpa

Figure 5: Overview of Proposed Projects and Control Packages

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Licence Amendment – BHP Port Operation 330Mtpa

Figure 6: Proposed Implementation Approach

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Licence Amendment – BHP Port Operation 330Mtpa

5. Emissions and Discharges
Refer to Attachments 2 and 3 for detailed information regarding the assessment of dust and noise emissions.

        Air Emissions
5.1.1. Our Focus on Air Quality
BHP’s Port Operations were established in Port Hedland in the 1960’s before modern planning guidelines
recognized the benefits of separating industrial facilities and residential areas. Minimising the environmental
impact of our operations is as important to BHP as it is to the communities in which we operate.
To ensure the growth of our iron ore business is sustainable, environmental objectives have shaped the nature
of our port activities and the environmental controls and management practices that we have in place.
Port Hedland’s coastal location in the arid Pilbara region with low and variable rainfall levels, seasonal cyclonic
activity and consistently high temperatures means naturally occurring and anthropogenic dust sources (such
as urban and industrial development) contribute to the ambient air quality in Port Hedland and this creates
additional challenges.
Over time, our port activities have been streamlined by removing primary crushing and screening and re-
designed to enable a high proportion of our products to be loaded to ships directly from rail unloading facilities
to deliver material reductions in dust and noise emissions.
We have invested A$400m in environmental controls over the last 10 years. These controls are closely
regulated and operate continuously to eliminate and mitigate dust and noise emissions. A comprehensive dust
monitoring network is in place to enable us to monitor our emissions in real time and ensure emissions are kept
to a minimum.
With this approach by BHP and the efforts of other industry producers, the port’s environmental performance
has improved to ensure the sector operates within regulatory requirements, as volumes have increased to
levels that have made Port Hedland the largest bulk handling port in the world. This level of activity is delivering
significant social and economic benefits at a local, state and national level along with a strong track record of
environmental performance.

 Figure 7: Port Hedland Exports                          Figure 8: Port Hedland Dust Regulation

BHP is committed to continuing to improve dust management performance with this licence amendment.
BHP has assessed dust management practices at other Australian and International bulk commodity operations
and sought input from air quality experts and the operational teams who live and work in Port Hedland, to
design the dust and noise controls included in this licence amendment application.
Special attention has been given to improving our understanding of the conditions when natural and industrial
dust sources have the potential to combine and create elevated dust levels in the West End of Port Hedland.
With this knowledge, the licence amendment includes the extension of existing controls that have been shown
to be effective and the introduction of wind fences designed for Port Hedland conditions, to reduce the potential
for dust lift-off from stockpiles during strong seasonal winds.
The comprehensive package of dust and noise controls included in this licence amendment application forms
a key part of a broader plan by BHP to spend up to A$300M to improve dust management across our Pilbara
operations over the next 5 years. BHP is confident that with these controls in place, we can continue to increase
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Licence Amendment – BHP Port Operation 330Mtpa

throughput whilst minimising our contribution to dust and noise in Port Hedland. BHP recognises that this
approach will be further informed by DWER’s development of the best practice dust management guidelines
for bulk handling port premises.
         Dust Management
5.2.1.     Dust Monitoring
BHP operates a real-time monitoring network that consists of PM10 operational monitors and boundary monitors
(Figure 10). Operational monitors are located within the site to monitor potential dust sources along with
boundary monitors, which also measure concentrations to determine if management criteria levels are triggered
on the premise boundary. Where boundary monitoring indicates that the management criteria is triggered,
BHP implements the following management actions consistent with its requirements under the current licence
L4513/1969/18 (conditions 22 and 23):
   •     Bulk Ore Conditioning (BOC) sprays to be operating on all conveyors that are handling Iron Ore unless
         the ore moisture of the ore being handled is known to be at or above DEM;
   •     Stockpile cannons to run on deluge cycle;
   •     Undertake a boundary monitoring Trigger Investigation to identify the source of the management trigger
         criteria exceedance; and
   •     If identified to be caused from activities at the Premises, implement immediate dust abatement
         measures.
The boundary monitors are also used to measure dust concentrations against the reportable event criteria
defined in the licence. If these criteria are triggered, BHP will complete an investigation into the potential source
of emissions and controls in place at the time. The investigation outcomes are reported to DWER on a quarterly
basis in accordance with current licence conditions.
Data from our boundary monitoring network is also used to calibrate our emission estimates used in the
dispersion modelling, guide our continuous improvement on-site and the development of new controls.
BHP operates a dust monitoring dashboard and integrated support tool (Figure 9), which displays historical,
real time and predictive weather and PM10 data. The integrated support tool identifies the predicted wind
direction, wind speed, and estimated dust concentrations to enable BHP to respond proactively to manage site
dust emissions.

Figure 9: Integrated Support Tool

The dust monitoring tools track and report site performance against key dust metrics and licence compliance
requirements. The dashboard enables tracking and monitoring of the following:

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