Albemarle Lithium Pty Ltd Albemarle Kemerton …...A Lithium Hydroxide Product manufacturing Plant and associated infrastructure which is proposed to be established wholly within Lot

ALBEMARLER

Albemarle Lithium Pty Ltd

Albemarle Kemerton Plant

Best Available Techniques

BenchmarkingNovember 2017

GHD | Report for Albemarle Lithium Pty Ltd - Albemarle Kemerton Plant, 6136286 | i

AcronymsAEP Annual Exceedance Probability

AFW Amec Foster Wheeler Australia Pty Ltd

Albemarle Albemarle Lithium Pty Ltd

AS/NZS Standards developed by Standards Australia and Standards New Zealand whowork together to develop joint standards

BAT Best Available Technique

BREF Best Available Techniques Reference Document for the Non-Ferrous MetalsIndustries

CO Carbon Monoxide

CO2 Carbon Dioxide

dB(A) A-weighted decibels

DWER Department of Water and Environmental Regulation

EMP Environmental Management Plan

EMS Environmental Management System

EP Act Environmental Protection Act 1986

EPA Environmental Protection Authority

ISO International Organization for Standardization, an international standard-settingbody composed of representatives from various national standardsorganizations

KSIA Kemerton Strategic Industrial Area

NOx Nitrogen Oxides

SO2 Sulfur Dioxide

SO3 Sulfur Trioxide

tpa tonnes per annum

VOCs Volatile Organic Compounds

WA Western Australia

GHD | Report for Albemarle Lithium Pty Ltd - Albemarle Kemerton Plant, 6136286 | i

Defined Terms

Terms Definitions

Acid Roasted Solids Spodumene ore which has undergone all pyrometallurgical treatmentincluding calcining, grinding and roasting.

Albemarle Albemarle Lithium Pty. Ltd.

Albemarle KemertonPlant

A Lithium Hydroxide Product manufacturing Plant and associatedinfrastructure which is proposed to be established wholly within Lot 510Wellesley Road, Wellesley, and operated by Albemarle Lithium Pty Ltd.

Kemerton StrategicIndustrial Area (KSIA)

An Industrial Park 17 km north east of Bunbury established to provide alocation for downstream processing and value adding to the SouthWest’s primary resources. It comprises a 2,024 ha Industry Zone, 284 haAncillary Industry zone and 5,200 ha Industry Buffer Zone.

Lithium HydroxideProduct

Battery grade lithium hydroxide monohydrate (LiOH.H2O).

Plant Industrial processing infrastructure used to manufacture LithiumHydroxide Product from spodumene containing ore concentrate.

Proposal To construct and operate a Lithium Hydroxide Product manufacturingplant, in Kemerton Strategic Industrial Area.Including the construction and operation of a Lithium Hydroxide Productmanufacturing Plant (the ‘Plant’) and associated infrastructure including;administration facilities; workshop; supply warehouse / store; fuel andreagent storage; amenities, laboratory; control centre; watermanagement infrastructure and a service corridor.

Sodium Sulfate By-product

By product of the Lithium Hydroxide Product manufacturing process.Non-toxic white powder which is highly soluble in water.

Spodumene oreconcentrate

Naturally occurring lithium aluminosilicate material with crystalline zeolitestructure which is concentrated to 6.0% Li2O.

Tailings The residual solids, comprising aluminosilicate, gypsum and small levelsof other salts, after the lithium extraction process, includingapproximately 30% water.

Talison Talison Lithium Australia Pty. Ltd with operations in Greenbushes WA.

GHD | Report for Albemarle Lithium Pty Ltd - Albemarle Kemerton Plant, 6136286 | ii

Table of contentsAcronyms................................................................................................................................................... i

Defined Terms........................................................................................................................................... i

1. Background ....................................................................................................................................4

2. Comparison....................................................................................................................................5

3. Literature Review ...........................................................................................................................7

3.1 BAT 1 - Environmental Management System .....................................................................7

3.2 BAT 2 – Energy Management .............................................................................................8

3.3 BAT 3 and BAT 4 - Process Control ..................................................................................10

3.4 BAT 5 to BAT 9 - Diffuse Emissions ..................................................................................12

3.5 BAT 10 – Monitoring of Emissions to Air ...........................................................................16

3.6 BAT 11 - Mercury Emissions .............................................................................................16

3.7 BAT 12 - Sulfur Dioxide Emissions....................................................................................16

3.8 BAT 13 - NOx Emissions....................................................................................................17

3.9 BAT 14 to BAT 17 Emissions to Water, Including Their Monitoring ..................................17

3.10 BAT 18 Noise.....................................................................................................................19

3.11 BAT 19 Odour ....................................................................................................................20

4. References...................................................................................................................................22

Table indexTable 2-1 Point source air emission rate comparison for Albemarle Kemerton and Tianqi

Kwinana Plants ....................................................................................................................6

Table 3-1 BAT 1 Environmental Management System Requirements ....................................................8

Table 3-2 BAT 2 Energy efficiency techniques ........................................................................................9

Table 3-3 BAT 3 Process control techniques.........................................................................................11

Table 3-4 BAT 7 Techniques for prevention of diffuse emissions from storage ....................................13

Table 3-5 BAT 8 Techniques for prevention of diffuse emissions from handling and transport ............14

Table 3-6 BAT 10 monitoring requirements for emissions to air............................................................16

Table 3-7 BAT 13 Techniques for prevention of NOx emissions............................................................17

Table 3-8 BAT 15 Techniques for prevention or reduction of the generation of waste water................17

Table 3-9 BAT 17 Techniques for reduction of emissions to water through treatment ofwastewater.........................................................................................................................19

Table 3-10 BAT 18 Techniques for reduction of noise emissions..........................................................20

Table 3-11 BAT 19 Techniques for reduction of odour emissions .........................................................20

AppendicesAppendices B-I Correspondence

GHD | Report for Albemarle Lithium Pty Ltd - Albemarle Kemerton Plant, 6136286 | 4

1. BackgroundAlbemarle Lithium Pty Ltd (Albemarle) is proposing to construct and operate a LithiumHydroxide Product manufacturing Plant (Albemarle Kemerton Plant) within the KemertonStrategic Industrial Area (KSIA), 17 km north-east of Bunbury, Western Australia. GHD ispreparing a Section 38 referral under Part IV of the Environmental Protection Act 1986 (EP Act)for the Proposal. In a pre-referral meeting, the Department of Water and EnvironmentalRegulation (DWER) Environmental Protection Authority Services Unit (EPA Services)commented that the referral supporting document should include benchmarking of theproposed plant. The EPA Services was asked if they could provide guidance on the approachto benchmarking. Advice provided by the EPA Services unit was that there is no establishedguidance, but that information on appropriate methodology is readily available from varioussources (see Appendix A).

In the absence of any prescribed guidance, Amec Foster Wheeler and GHD developed aproposed benchmarking methodology based on a range of local and international sources,including:

1. Comparison of the Albemarle Kemerton Plant process, emissions and controls with theTianqi Lithium Hydroxide Process Plant currently under construction in Kwinana WA

2. Literature review to identify any recently constructed lithium plants or other industrialprocess plants in WA which use comparable techniques to the proposed AlbemarleKemerton Plant

3. Comparison of the Albemarle Kemerton Plant with the European Commission IndustrialEmissions Directive Best Available Techniques Reference Document for the Non-FerrousMetals Industries (BREF Document).

The rationale and outcomes of these benchmarking activities are discussed in this Report.


2. ComparisonThe Tianqi Australia Lithium Hydroxide Process Plant (Tianqi Plant) is currently underconstruction in Kwinana, Western Australia. The plant represents a suitable comparison forbenchmarking of the Albemarle Kemerton Plant as it is:

within the same regulatory jurisdiction, albeit with some additional requirements onatmospheric emissions associated with the Kwinana Industrial Area1; conditions applied toTianqi are therefore considered to provide a potentially conservative standard

has similar sized production trains (24,000 tonne per annum (tpa) Lithium HydroxideProduct manufacturing trains compared with the Albemarle Kemerton Plant 20,000 tpatrains;

spodumene ore concentrate will come from the same source (Talison GreenbushesOperation); and

is the only example of a lithium mineral conversation plant which has receivedenvironmental regulatory authorisation to be constructed in Australia.

A review of publically available information on the Tianqi plant found that the productionprocess and emission controls within the plant are predominantly the same as those proposedfor the Albemarle Kemerton Plant with one exception. The Tianqi plant will have rapid openingand closing automatic doors on the ore, tailings, and product (Lithium Hydroxide Product andSodium Sulfate By-product) warehouses or receival areas to ensure handling of potentiallydusty materials is undertaken within a sealed environment. The Albemarle Kemerton Plant isnot at detailed design phase and therefore the type of doors on buildings or warehouses wherethese products will be handled has not been designed. At the detailed design stage a numberof considerations will influence the decision as to whether rapid automatic doors will beincluded in the plant. These include:

the moisture content of the solids being handled;

whether misting can be used to control dust;

the frequency and type of access to the building or warehouse;

ventilation; and

atmosphere control requirements.

Comparison of the predicted point source emission rates from the Albemarle Kemerton Plantwith the Tianqi Plant has also been undertaken. The comparison is included in Table 2-1.

The Albemarle Kemerton Plant emissions are comparable to the Tianqi Plant, although for mostsources tend to be slightly higher. It is noted however, that due to the Plant being at conceptual(rather than detailed) design phase National Pollutant Inventory emission factors were used tocalculate combustion emissions for the Plant. Particulate emissions have also been based onan estimated emission rate (rather than equipment specifications) for the type of particulatecontrol equipment which is proposed. The emission rate is therefore likely to be anoverestimate. These emission rates, and air emission modelling for the Plant, will be furtherrefined as the plant progresses to detailed design stage.

1 Environmental Protection (Kwinana) (Atmospheric Wastes) Policy 1999 and Environmental Protection (Kwinana)(Atmospheric Wastes) Regulations 1992


Table 2-1 Point source air emission rate comparison for Albemarle Kemerton andTianqi Kwinana Plants (single process train)

Parameter

Nitrogen dioxide(g/s)

Sulfur dioxide (g/s)Carbon monoxide

(g/s)Particulates as

PM10 (g/s)

Albemarle Tianqi Albemarle Tianqi Albemarle Tianqi Albemarle Tianqi

Calcinerstack

0.153 4.9 0.01 0.0044 0.65 0.61 0.7135 0.4

Ball millstack

0.3233 0.11

Acid Roastflue

0.045 0.017 0.0022 0.00012 0.19 0.066 negligible

Acid Roastscrubber

0.0023 0.0017 negligible 0.0066

SodiumSulfate dryer

0.01 0.23 0.0004 0.00042 0.04 0.056 0.0678 0.014

Steam boiler 0.036 0.056 0.0018 0.16 0.08

Note: Emission rates for the above table have been sourced from GHD 2017 and Tianqi 2017.


3. Literature ReviewA literature review identified that the only other localities outside of Australia which have establishedMineral Conversion Plants (either Lithium Hydroxide or Lithium Carbonate) are in China, with oneadditional small plant also located in Brazil (Hatch 2017). Due to environmental protection standards inthese countries generally not meeting Australia’s standards, these plants are not considered suitablefor comparison purposes. No other comparable mineral processing plants were identified which use asimilar combination of pyrometallurgy and hydrometallurgy to the Lithium process.

Although there is no European guideline specific to Lithium , an assessment against the genericconsiderations for best available techniques (BAT) in the Best Available Techniques ReferenceDocument (BREF) for non-ferrous metals was considered a suitable benchmark as the Document isrecognised worldwide as representing best practice for emission control and monitoring. A workshopwas held between process engineers designing the Albemarle Kemerton Plant and GHD on 18September 2017 to undertake a comparison of the proposed Albemarle Kemerton Plant with the BATlisted in Chapter 11 Best Available Techniques Conclusions of the BREF Document. The outcomes ofthis assessment have been summarised in the following sections.

3.1 BAT 1 - Environmental Management System

In order to improve the overall environmental performance, BAT is to implement and adhere to anenvironmental management system (EMS) that incorporates all of the following features:

The required EMS features referred to in BAT 1 are listed in Table 3-1. Albemarle has a corporateEMS which is certified under Responsible Care 14001 (RC 14001), a management system initiative ofthe American Chemistry Council. This certification is considered to be equivalent to, and in somerespects more stringent than, ISO 14001 certification in the United States. The Albemarle corporateEMS meets all of the requirements of BAT 1, and will be applicable to the Albemarle Kemerton Plant.BAT 4 and BAT 6 are related to the EMS but are discussed in relevant sections.


Table 3-1 BAT 1 Environmental Management System Requirements

Item Technique

a. commitment of the management, including senior management;

b. definition of an environmental policy that includes the continuous improvement ofthe installation by the management;

c. planning and establishing the necessary procedures, objectives and targets, inconjunction with financial planning and investment

d. implementation of procedures paying particular attention to:i. structure and responsibility,ii. recruitment, training, awareness and competence,iii. communication,iv. employee involvement,v. documentation,vi. effective process control,vii. maintenance programmes,viii. emergency preparedness and response,ix. safeguarding compliance with environmental legislation;

e. checking performance and taking corrective action, paying particular attention to:i. monitoring and measurement,ii. corrective and preventive action,iii. maintenance of records,iv. independent (where practicable) internal or external auditing in order to

determine whether or not the EMS conforms to planned arrangementsand has been properly implemented and maintained;

f. review of the EMS and its continuing suitability, adequacy and effectiveness bysenior management;

g. following the development of cleaner technologies;

h. consideration for the environmental impacts from the eventual decommissioningof the installation at the stage of designing a new plant, and throughout itsoperating life;

i. application of sectoral benchmarking on a regular basis.

3.2 BAT 2 – Energy Management

In order to use energy efficiently, BAT is to use a combination of the techniques.

The energy management techniques referred to in BAT 2 are listed in Table 3-2.

The Plant does not incorporate the heat recovery energy management techniques which areapplicable to pyrometallurgical processing due to the technical difficulties resulting from dustgeneration in existing applications. Energy recovery options will further be considered during detaileddesign. The remaining energy management techniques are incorporated into the plant design wherethey are applicable to the Lithium Hydroxide Product manufacturing process.


Table 3-2 BAT 2 Energy efficiency techniques

Item Technique Applicability Workshop Outcome forAlbemarle Kemerton Plant

Performancea Energy efficiency

management system (e.g.ISO 50001)

Generally applicable Albemarle Corporation is anENERGY STAR Partner, andhas made a fundamentalcommitment to protect theenvironment through thecontinuous improvement ofenergy performance. Albemarleimplement an organisation-wideenergy management approach.

b Regenerative orrecuperative burners

Generally applicable The plant does not includeregenerative or recuperativeburners due to technical issuesexperienced with dust in the fluegas and energy recovery units

c Heat recovery (e.g. steam,hot water, hot air) fromwaste process heat

Only applicable forpyrometallurgicalprocesses

There is no heat recovery withinthe pyrometallurgical processhowever a heat exchanger isincluded in the plant design forthe product crystallisation stage.It has an integrated heatrecovery circuit.

d Regenerative thermaloxidiser

Only applicable whenthe abatement of acombustible pollutant isrequired

Not applicable to this process.

e Preheat the furnacecharge, combustion air orfuel using the heatrecovered from hot gasesfrom the melting stage

Only applicable forroasting or smelting ofsulphideore/concentrate and forother pyrometallurgicalprocesses

Not applicable to this processhowever the gas in the calcineris fed counter current to the feedso there will be some countercurrent heating.

f Raise the temperature ofthe leaching liquors usingsteam or hot water fromwaste heat recovery

Only applicable foralumina orhydrometallurgicalprocesses

Waste heat recovery is not usedas part of the leaching stagehowever a heat exchanger isused in the crystallisation stageto recover heat.

g Use hot gases from thelaunder as preheatedcombustion air

Only applicable forpyrometallurgicalprocesses

Heat recovery techniques arenot currently included in thedesign of the plant due to thetechnical difficulties resultingfrom dust generation in existingapplications.

h Use oxygen-enriched airor pure oxygen in theburners to reduce energyconsumption by allowingautogenous smelting orthe complete combustionof carbonaceous material

Only applicable forfurnaces that use rawmaterials containingsulphur or carbon

Not applicable as raw materialsdo not contain sulfur or carbon.

i Dry concentrates and wetraw materials at lowtemperatures

Only applicable whendrying is performed

Drying occurs at lowtemperatures



Performancej Recover the chemical

energy content of thecarbon monoxideproduced in an electric orshaft/blast furnace byusing the exhaust gasesas a fuel, after the removalof metals, in otherproduction processes orto produce steam/hotwater or electricity

Only applicable toexhaust gases with aCO content > 10 vol-%.Applicability is alsoinfluenced by thecomposition of theexhaust gas and theunavailability of acontinuous flow (i.e.batch processes)

Not applicable to this process.

k Recirculate the flue-gasback through an oxy-fuelburner to recover theenergy contained in thetotal organic carbonpresent

Generally applicable Not applicable to this process.

l Suitable insulation for hightemperature equipmentsuch as steam and hotwater pipes

Generally applicable The roast kiln is insulated toprevent heat loss. Calcinerscannot be insulated as to do sowould cause them to overheatand fail.

m Use the heat generatedfrom the production ofsulphuric acid fromsulphur dioxide to preheatgas directed to thesulphuric acid plant or togenerate steam and/or hotwater

Only applicable for non-ferrous metals plantsincluding sulphuric acidor liquid SO2 production

Not applicable as sulfuric acidproduction is not undertaken onSite.

n Use high efficiency electricmotors equipped withvariable-frequency drive,for equipment such asfans

Generally applicable. The plant design will specifyvariable frequency drive for highenergy electric motors. The useof high voltage motors vs lowvoltage motors is alsoconsidered for large drives, toensure the most efficient isselected

o Use control systems thatautomatically activate theair extraction system oradjust the extraction ratedepending on actualemissions

Generally applicable The plant control/monitoringsystem will be used to control airextraction.

3.3 BAT 3 and BAT 4 - Process Control

In order to improve overall environmental performance, BAT is to ensure stable process operation byusing a process control system together with a combination of the techniques given below:

The process control techniques referred to in BAT 3 are listed Table 3-3. The Albemarle KemertonPlant complies with all process control techniques which are applicable to the operation. The Plant willhave a computerised control system for operation of the plant which will incorporate the control andmonitoring requirements referred to.


BAT 4 requires that “In order to reduce channelled dust and metal emissions to air, BAT is to apply amaintenance management system which especially addresses the performance of dust abatementsystems as part of the environmental management system (see BAT 1).” All dust abatementequipment will be included in the Site’s preventative maintenance program to ensure it operateseffectively.

Table 3-3 BAT 3 Process control techniques

Item Technique Workshop Outcome forAlbemarle Kemerton Plant

Performancea Inspect and select input materials according to the

process and the abatement techniques appliedNot applicable to this process asinput materials are relativelyhomogenous.

b Good mixing of the feed materials to achieveoptimum conversion efficiency and reduce emissionsand rejects

Thorough mixing of the feedoccurs through the first threestages of the process. Feed to acalciner kiln fired with countercurrent with natural gas. Furthermixing occurs in the ball mill androast kiln.

c Feed weighing and metering systems Weighing and metering will beincorporated into the plantcontrol/monitoring system.

d Processors to control material feed rate, criticalprocess parameters and conditions including thealarm, combustion conditions and gas additions

Control of feed rate, processparameters, process conditionsand alarms will all be incorporatedinto the plant control/monitoringsystem.

e On-line monitoring of the furnace temperature,furnace pressure and gas flow

Monitoring of temperature,pressure and flow rates will beincorporated into the plantcontrol/monitoring system.

f Monitor the critical process parameters of the airemission abatement plant such as gas temperature,reagent metering, pressure drop, ESP current andvoltage, scrubbing liquid flow and pH and gaseouscomponents (e.g. O2, CO, VOC)

Plant control/monitoring systemwill monitor critical processparameters.

g Control dust and mercury in the exhaust gas beforetransfer to the sulphuric acid plant for plants includingsulphuric acid or liquid SO2 production

Not applicable to this process asthere is no sulfuric acid or SO2production on Site.

h On-line monitoring of vibrations to detect blockagesand possible equipment failure

Vibration monitoring will beincorporated into the plantcontrol/monitoring system.

i On-line monitoring of the current, voltage andelectrical contact temperatures in electrolyticprocesses

Not applicable as there are noelectrolytic processes for this plant.However, the plantcontrol/monitoring system willinclude monitoring of current,voltage and electrical contacttemperatures.

j Temperature monitoring and control at melting andsmelting furnaces to prevent the generation of metaland metal oxide fumes through overheating

Not applicable to this process asthere are no melting or smeltingfurnaces.


Item Technique Workshop Outcome forAlbemarle Kemerton Plant

Performancek Processor to control the reagents feeding and the

performance of the waste water treatment plant,through on-line monitoring of temperature, turbidity,pH, conductivity and flow

Not applicable as there is noWWTP for this plant.However, the plantcontrol/monitoring system willinclude controls and monitoring forreagent feed rates.The plant will include a ReverseOsmosis plant which willincorporate online monitoring ofrelevant process parameters viathe plant control/monitoringsystem.

3.4 BAT 5 to BAT 9 - Diffuse Emissions

BAT 5 requires that “In order to prevent or, where this is not practicable, to reduce diffuse emissions toair and water, BAT is to collect diffuse emissions as much as possible nearest to the source and treatthem.” The Albemarle Kemerton Plant addresses this requirement in the following ways.

Potential diffuse emission sources including reagents, feed (spodumene), products and tailingsare stored within contained covered storage areas to prevent emissions therefore collection ofemissions is not applicable to these processes

The plant will be a zero discharge Site for wastewater and potentially contaminated watertherefore there will be no diffuse emissions to water requiring collection.

The process plant includes dust extraction by means of baghouses or cyclones at all transferpoints and process stages where dust emissions are likely to be generated.

BAT 6 requires that “In order to prevent or, where this is not practicable, to reduce diffuse dustemissions to air, BAT is to set up and implement an action plan on diffuse dust emissions, as part ofthe environmental management system (see BAT 1), that incorporates both of the following measures:a) identify the most relevant diffuse dust emission sources (using e.g. EN 15445); and b) define andimplement appropriate actions and techniques to prevent or reduce diffuse emissions over a giventime frame.” As described above, the Albemarle Kemerton Plant has limited sources of diffuseemissions and incorporates controls to prevent and reduce these. As part of the BAT 1 EMSrequirements the Albemarle corporate EMS includes, following the development of cleanertechnologies, and performance checking and improvement. The Albemarle Corporate EMS alsoincludes commitment to minimising the footprint from operations by actively pursuing opportunities toreduce emissions, water and energy usage and waste created. This commitment ensures thatidentification of diffuse dust sources and implementation of actions to reduce dust emissions to air istherefore included in the EMS.

BAT 7 requires that “In order to prevent diffuse emissions from the storage of raw materials, BAT is touse a combination of the techniques given below.” The techniques to prevent diffuse emissions fromstorage referred to in BAT 7 are listed in Table 3-4. The Albemarle Kemerton Plant incorporates allrelevant techniques listed with the exception of water sprays. Water sprays are not able to be used fordust reduction as the Lithium Hydroxide Product manufacturing process requires that the feed andproduct are kept as dry as possible.


Table 3-4 BAT 7 Techniques for prevention of diffuse emissions from storage

Item Technique Workshop Outcome for AlbemarleKemerton Plant Performance

a Enclosed buildings or silos/bins for storingdust-forming materials such as concentrates,fluxes and fine materials

All dust forming materials will be stored incovered storage or silos/bins. Thisincludes spodumene ore concentrate,Lithium Hydroxide Product and SodiumSulfate By-product, tailings and reagents.

b Covered storage of non-dust-formingmaterials such as concentrates, fluxes, solidfuels, bulk materials and coke andsecondary materials that contain water-soluble organic compounds

Acid roasted solids will be stored within acovered storage area.

c Sealed packaging of dust-forming materialsor secondary materials that contain water-soluble organic compounds

All Lithium Hydroxide Product andSodium Sulfate By-product produced bythe plant will be packaged in enclosed,lined bags.

d Covered bays for storing material which hasbeen pelletised or agglomerated

Not applicable as there will be no storageof pelletised or agglomerated materials.

e Use water sprays and fog sprays with orwithout additives such as latex for dust-forming materials

Water sprays are not part of the processbecause materials must be kept as dry aspossible. This requirement is therefore notapplicable.

f Dust/gas extraction devices placed at thetransfer and tipping points for dust-formingmaterials

All feed points will either be enclosed orhave dust extraction if not enclosed andthe feed system will have negativepressure on.

g Certified pressure vessels for storingchlorine gas or mixtures that contain chlorine

Not applicable as there will be no chlorinestorage on the Site.

h Tank construction materials that areresistant to the contained materials

Tanks will be resistant to the containedmaterials

i Reliable leak detection systems and displayof tank's level, with an alarm to preventoverfills

All tanks will have level gauges withalarms linked to the processcontrol/monitoring system to detectpotential leaks.

j Store reactive materials in double-walledtanks or tanks placed in chemical-resistantbunds of the same capacity and use astorage area that is impermeable andresistant to the material stored

All tanks will be established in chemicallyresistant bunds with a capacity exceedingthat the contained tank.

k Design storage areas so that:- any leaks from tanks and delivery systemsare intercepted and contained in bunds thathave a capacity capable of containing atleast the volume of the largest storage tankwithin the bund;- delivery points are within the bund tocollect any spilled material

All tanks will be established in chemicallyresistant bunds with a capacity exceedingthat the contained tank. Delivery pointswill be within the bunded area.

l Use inert gas blanketing for the storage ofmaterials that react with air

Not applicable to this process



m Collect and treat emissions from storagewith an abatement system designed to treatthe compounds stored. Collect and treatbefore discharge any water that washes dustaway.

Emissions including SO3 gas from theroast kiln and dust from baghouses isrecycled back into process. All stormwaterfrom the Plant area, including bundedareas, will be returned to the Raw Wateror Plant run-off ponds for reuse.

n Regular cleaning of the storage area and,when needed, moistening with water

Regular cleaning and housekeepingwithin storage areas will be includedwithin operational procedures for the Site.

o Place the longitudinal axis of the heapparallel to the prevailing wind direction in thecase of outdoor storage

Not applicable to this process as there isno outdoor storage.

p Protective planting, windbreak fences orupwind mounts to lower the wind velocity inthe case of outdoor storage


q One heap instead of several where feasiblein the case of outdoor storage


r Use oil and solid interceptors for thedrainage of open outdoor storage areas. Useof concreted areas that have kerbs or othercontainment devices for the storage ofmaterial that can release oil, such as swarf


BAT 8 requires that “In order to prevent diffuse emissions from the handling and transport of rawmaterials, BAT is to use a combination of the techniques given below”. The techniques to preventdiffuse emissions from handling and transport referred to in BAT 8 are listed in Table 3-5. TheAlbemarle Kemerton Plant incorporates all relevant techniques listed with the exception of watersprays. Water sprays are not able to be used for dust reduction as the Lithium Hydroxide Productmanufacturing process requires that the feed and product are kept as dry as possible.

Table 3-5 BAT 8 Techniques for prevention of diffuse emissions from handling andtransport


a Enclosed conveyors or pneumatic systemsto transfer and handle dust-formingconcentrates and fluxes and fine-grainedmaterial

All conveyors outside of buildings will beenclosed or covered to prevent wateringress and dust egress.

b Covered conveyors to handle non-dust-forming solid materials

All conveyors outside of buildings will beenclosed or covered to prevent wateringress and dust egress.

c Extraction of dust from delivery points, silovents, pneumatic transfer systems andconveyor transfer points, and connection toa filtration system (for dust-formingmaterials)

Bag filters and cyclones will be used at alltransfer and delivery points and silo vents.



d Closed bags or drums to handle materialswith dispersible or water-solublecomponents

Lithium Hydroxide Product and SodiumSulfate By-product will be packaged in linedbags, stored in warehouses andtransported in enclosed containers.

e Suitable containers to handle pelletisedmaterials

Not applicable as there are no pelletisedmaterial required for this process.

f Sprinkling to moisten the materials athandling points

Water sprays are not part of the processbecause materials must be kept as dry aspossible. This requirement is therefore notapplicable.

g Minimise transport distances Reagents, Lithium Hydroxide Product andSodium Sufate By-product, spodumene oreconcentrate and tailings are transported viathe shortest and safest routes.

h Reduce the drop height of conveyor belts,mechanical shovels or grabs

Drop heights are reduced where it is costbeneficial to do so.

i Adjust the speed of open belt conveyors (<3.5 m/s)

All outside conveyors are enclosed orcovered. The maximum conveyor speed ispredicted to be 1 m/s

j Minimise the speed of descent or free fallheight of the materials

Speed is minimised.

k Place transfer conveyors and pipelines insafe, open areas above ground so thatleaks can be detected quickly and damagefrom vehicles and other equipment can beprevented. If buried pipelines are used fornon-hazardous materials, document andmark their course and adopt safeexcavation systems

The plant is designed to avoid roadcrossing for pipelines and conveyors wherepossible. The only road crossing is for thetailings conveyor which is a completelyenclosed chain conveyor above the road.

l Automatic resealing of deliveryconnections for handling liquid andliquefied gas

Carbon dioxide gas delivery connectionswill have automatic resealing of the deliveryconnection. Natural gas is delivered viapipeline so this requirement is notapplicable to this gas.

m Back-vent displaced gases to the deliveryvehicle to reduce emissions of VOC

Not applicable as there are no VOCsassociated with CO2 delivery.

n Wash wheels and chassis of vehicles usedto deliver or handle dusty materials

There will be no visible process generateddust on vehicle wheels leaving the Site.Washdown or other suitable technique willbe provided if necessary.

o Use planned campaigns for road sweeping Dust on internal and surrounding roads willbe prevented through operational controls.If required, road sweeping campaigns willbe included within operational proceduresfor the Site as a contingency.

p Segregate incompatible materials (e.g.oxidising agents and organic materials)

Incompatible materials will be appropriatelysegregated within the Site StoresWarehouse in accordance with relevantAustralian Legislation.

q Minimise material transfers betweenprocesses

Material transfers are minimised.


BAT 9, which relates to reduction of diffuse emissions from metal production, is not applicable to theAlbemarle Kemerton Plant as metal production is not part of the process.

3.5 BAT 10 – Monitoring of Emissions to Air

BAT is to monitor the stack emissions to air with at least the frequency given below and in accordancewith EN standards. If EN standards are not available, BAT is to use ISO, national or other internationalstandards that ensure the provision of data of an equivalent scientific quality.

The monitoring frequencies specified in BAT 10 have been summarised in Table 3-6. Air emissionmonitoring is typically specified in EP Act Part V licence requirements in accordance with the level ofemissions expected and risk associated with those emissions. Applicable USEPA Methods or CEMSin accordance with the DER CEMS Code are typically specified in Part V licences for air emissionmonitoring. The Site is expected to be licensed under Part V of the EP Act and will undertake airemission monitoring in accordance with the licence requirements. Stacks will be suitably designed toallow for installation of sampling ports with are compliant with AS 4323.1 and the DER CEMS code somonitoring can be undertaken. It is expected these requirements will as a minimum meet the BAT 10requirements.

Table 3-6 BAT 10 monitoring requirements for emissions to air

Parameter Monitoring frequency

Dust Continuous or Annually1

Any relevant metals (requirementswill be dependent on the compositionof feedstock)

Annually

SO2 Continuous or Annually1

NOx Continuous or Annually1

Note 1: For sources of high emissions, BAT is continuous measurement or, where continuousmeasurement is not applicable, more frequent periodic monitoring.

3.6 BAT 11 - Mercury Emissions

BAT 11, which relates to reduction of mercury emissions to air from a pyrometallurgical process, is notapplicable to the Albemarle Kemerton Plant as mercury emissions to air are not expected as part ofthe process.

3.7 BAT 12 - Sulfur Dioxide Emissions

In order to reduce emissions of SO2 from off-gases with a high SO2 content, and to avoid thegeneration of waste from the flue-gas cleaning system, BAT is to recover sulphur by producingsulphuric acid or liquid SO2.

BAT 12 is only applicable to plants producing copper, lead, primary zinc, silver, nickel and/ormolybdenum. The Albemarle Kemerton Plant is not expected to have a high SO2 content in off gases.The process does however include an acid scrubbing system for emissions from the Roast Kiln whichcaptures SO3. The captured SO3 is used to make a 10% acid which is reused in the process.


3.8 BAT 13 - NOx Emissions

In order to prevent NOX emissions to air from a pyrometallurgical process, BAT is to use one of thetechniques given below.

The techniques to prevent NOX emissions to air which are referred to in BAT 13 are listed in Table 3-7.

Table 3-7 BAT 13 Techniques for prevention of NOx emissions

Item Technique Workshop Outcome for Albemarle KemertonPlant Performance

a Low-NOx burners Low NOx burners are available from kiln vendorsand these types will be considered. Reduced NOxemissions and optimum flame shape is achievedwith the use of two primary air chambers.

b Oxy-fuel burners Oxy-fuel burners will be considered andimplemented if suitable or advised by the specifickiln vendor.

c Flue-gas recirculation (back throughthe burner to reduce the temperatureof the flame) in the case of oxy-fuelburners

Not applicable as Oxy-fuel burners are notexpected to be used.

3.9 BAT 14 to BAT 17 Emissions to Water, Including Their Monitoring

BAT 14 requires that “In order to prevent or reduce the generation of waste water, BAT is to use oneor a combination of the techniques given below.” The techniques to prevent or reduce generation ofwaste water referred to in BAT 14 are listed in Table 3-8. The Albemarle Kemerton Plant incorporatesall relevant techniques listed, predominantly through the Site stormwater management system designwhich focusses on containing stormwater, treating it and preferentially using it as process water.

Table 3-8 BAT 15 Techniques for prevention or reduction of the generation ofwaste water


Performancea Measure the amount of

fresh water used and theamount of waste waterdischarged

Generally applicable Water metering will be maintainedaround the plant to measure inputsand outputs as part of a Site waterbalance.

b Reuse waste water fromcleaning operations(including anode andcathode rinse water) andspills in the same process

Generally applicable The Site will reuse or evaporatewastewater. All wastewater will bereused unless the salinity is toohigh. High salinity water will beevaporated. The only water whichwill leave the Site will be in thetailings stream disposed off site (orin the event of an extreme rainfallevent).

c Reuse weak acid streamsgenerated in a wet ESP andwet scrubbers

Applicability may berestricted dependingon the metal andsolid content of thewaste water

The Plant includes an acidscrubbing system for emissionsfrom the Roast Kiln which capturesSO3. The captured SO3 is used tomake a 10% acid which is reusedin the process



Performanced Reuse waste water from

slag granulationApplicability may berestricted dependingon the metal and solidcontent of the wastewater

Not applicable as there is no slaggranulation as part of the process.

e Reuse surface run-off water Generally applicable Surface water on the Site will becollected. Uncontaminated run-offwill be collected separately frompotentially contaminated run-off. Allrun-off water will be re-used asprocess water.

f Use a closed circuit coolingsystem

Applicability may berestricted when a lowtemperature isrequired for processreasons

The Plant incorporates a closedcircuit cooling system. Scale isremoved from the cooling systemand sent off Site with the tailingsstream.

g Reuse treated water fromthe waste water treatmentplant

Applicability may berestricted by the saltcontent

Not applicable as there is nowastewater treatment plant on Site.

BAT 15 requires that “In order to prevent the contamination of water and to reduce emissions to water,BAT is to segregate uncontaminated waste water streams from waste water streams requiringtreatment.” All process water from the Site will be potentially contaminated, as will stormwater run-offfrom the Plant. Process water and potentially contaminated stormwater from the Plant area will becontained in the Raw Water Pond and Plant run-off pond and will be treated and used for processwater. Site run-off from carparks and buildings will be directed to a separate Site run-off pond and willbe reused as process water as required. It will have limited contamination resulting only from oil andfuel residues in the carpark and pick up of dust from surfaces.

BAT 16 requires the “use ISO 5667 for water sampling and to monitor the emissions to water at thepoint where the emission leaves the installation at least once per month (1) and in accordance with ENstandards. If EN standards are not available, BAT is to use ISO, national or other internationalstandards that ensure the provision of data of an equivalent scientific quality.” EP Act Part V licencerequirements typically specify that water monitoring is conducted in accordance with AS/NZS 5667which is generally equivalent to ISO 5667. The Site is expected to be licensed under Part V of the EPAct and will undertake water monitoring in accordance with the licence requirements. Discharge ofstormwater from the Site will only occur if necessary following extreme rain events which exceed the24 hour AEP 1% rain event (141 mm/day) for the Site. It is anticipated the Site will have been flushedof contaminants for up to 24 hours prior to discharge occurring and this water will be contained withinstorage ponds. Discharge which occurs following the flushing is not expected to be contaminated.Monitoring of the ponds will be undertaken so that in the event a water release is required the qualityis known. The requirements of BAT 16 are considered to be met by this approach to monitoring anddischarge.

BAT 17 requires that “In order to reduce emissions to water, BAT is to treat the leakages from thestorage of liquids and the waste water from non-ferrous metals production, including from the washingstage in the Waelz kiln process, and to remove metals and sulphates by using a combination of thetechniques given below.” The techniques to reduce emissions to water referred to in BAT 17 are listedin Table 3-9. The Albemarle Kemerton Plant generally complies with the requirements of BAT 17through the implementation of its stormwater collection and reuse framework. Any wastewater which is


not suitable for reuse will be evaporated with the salts being collected for disposal. The Plant has alsobeen designed with bunding around all reagent stores to collect any leakages which will be returned tothe reagent tank or process for use. Operational procedures will include housekeeping requirementsfor Site bunding to ensure bunds remain free of potential contaminants and ready access to spill kits.

Table 3-9 BAT 17 Techniques for reduction of emissions to water throughtreatment of wastewater


Performancea Chemical

precipitationGenerally applicable As part of the stormwater

management strategy, the Rotarycooling kiln will be used toevaporate brine from the RO plantand water which is too saline forprocessing. Salts generated fromevaporation will be filtered out anddisposed to an appropriate landfill.

b Sedimentation Generally applicable Scale dropping off the cooling kilnswill be removed from water usinginclined plate settlers. The scale willbe collected and disposed to anappropriate landfill.

c Filtration Generally applicable Filtration of wastewater is not part ofthe process

d Flotation Generally applicable Floatation is not applicable to thisprocess

e Ultrafiltration Only applicable to specificstreams in non-ferrousmetals production

Ultrafiltration is not applicable to thisprocess

f Activated carbonfiltration

Generally applicable Activated carbon filtration ofwastewater is not part of theprocess

g Reverse osmosis Only applicable to specificstreams in non-ferrousmetals production

Reverse osmosis is not applicableto this process (for wastewater).Reverse osmosis will only be usedfor treatment of plant feed water,not wastewater.

3.10 BAT 18 Noise

In order to reduce noise emissions, BAT is to use one or a combination of the techniques given below.

The techniques to reduce noise emissions referred to in BAT 18 are listed in Table 3-10. TheAlbemarle Kemerton Plant complies with all noise reduction techniques which are consideredappropriate for the operation given the distance to, and density of sensitive receptors.


Table 3-10 BAT 18 Techniques for reduction of noise emissions

Item Technique Workshop Outcome for Albemarle Kemerton PlantPerformance

a Use embankments to screenthe source of noise

Embankments are not considered necessary due to the Sitebeing located within a designated industrial area whichincludes a buffer between the industrial core and sensitivereceptors.

b Enclose noisy plants orcomponents in sound-absorbing structures

Noisy plant will be identified at the detailed design stage.The primary noise sources identified will be enclosed in asound proofing structure to ensure noise levels do notexceed 85 dBA at a distance of 1 m from the equipment.

c Use anti-vibration supportsand interconnections forequipment

Anti-vibration supports and interconnections will be usedwhere required.

d Orientation of noise-emittingmachinery

Re-orientation of primary noise sources will be undertaken iffeasible where it is shown significantly reduces noiseemissions.

e Change the frequency of thesound

It is unlikely this will be undertaken.

3.11 BAT 19 Odour

In order to reduce odour emissions, BAT is to use one or a combination of the techniques given below.

The techniques to reduce odour emissions referred to in BAT 19 are listed in Table 3-11. TheAlbemarle Kemerton Plant will not routinely produce odorous emissions. Odour emissions are onlylikely to occur if there is an ammonia leak at the plant. .The Plant complies with the relevant odourreduction techniques in relation to the use, handling and storage or ammonia on the Site.

Table 3-11 BAT 19 Techniques for reduction of odour emissions

Item Technique Applicability Workshop Outcome for AlbemarleKemerton Plant Performance

a Appropriate storageand handling ofodorous materials

Generallyapplicable

There are no odours from the process undernormal conditions however odour could occurin the event of an ammonia leak. Ammonia willbe stored within an appropriately designedpressure vessel. Low charge systems will beused to minimise the volume directed into theprocess.

b Minimise the use ofodorous materials

Generallyapplicable

Low charge systems will be used to minimisethe volume of ammonia directed into theprocess. Ammonia is the only odorous materialwhich will be used in the process.

c Careful design,operation andmaintenance of anyequipment that couldgenerate odouremissions

Generallyapplicable

Site operational procedures will be applicableto the use of ammonia and the maintenanceand operation of the ammonia storage vessel.The vessel will be included in the Sitemaintenance and inspection schedule to detectpotential problems.


Item Technique Applicability Workshop Outcome for AlbemarleKemerton Plant Performance

d Afterburner orfiltration techniques,including biofilters

Applicable onlyin limited cases(e.g. in theimpregnationstage duringspecialityproduction in thecarbon andgraphite sector)

Not applicable to this process as it does notproduce odour emissions.


4. ReferencesEnvironmental Protection (Kwinana) (Atmospheric Wastes) Policy 1999

Environmental Protection (Kwinana) (Atmospheric Wastes) Regulations 1992

Cusano, J, Gonzalo, M.R, Farrell, F, Remus, R, Roudier, S, Sancho; L.D, 2017. ‘Best Available Techniques(BAT) Reference Document for the Non-Ferrous Metals Industries, Industrial Emissions Directive2010/75/EU. Prepared for the European Commission.

GHD 2017. ‘Albemarle Kemerton Plant Air Quality Impact Assessment’. Prepared for Albemarle Lithium PtyLtd .

Hatch Pty Ltd, 2017, Study for the Development of Western Australia’s Lithium Resources and RelatedResearch and Processing Activities, Perth WA

Tianqi Lithium Australia Pty Ltd (Tianqi) 2017. Stage 2 Lithium Hydroxide Process Plant Works ApprovalW5955/2016/1 Amendment Application. Sourced from Department of Water and Environmental RegulationwebSite on 25 August 2017 [https://www.der.wa.gov.au/our-work/licences-and-works-approvals/lwa-applications]

Appendices

Appendix B-I Correspondence

Correspondence with EPA Services Unit Regarding Benchmarking

GHD

Level 10 999 Hay Street, Perth T: 61 8 6222 8222 F: 61 8 6222 8555 E: [email protected]

© GHD 2017

This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited.

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Document Status

Revision Author Reviewer Approved for Issue Name Signature Name Signature Date

Rev A A.Callegari F. Hannon F. Hannon

4/11/2017

Rev B A.Callegari F. Hannon F. Hannon

24/11/2017

Rev 0 A.Callegari F. Hannon F. Hannon

7/11/2017

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Albemarle Lithium Pty Ltd Albemarle Kemerton …...A Lithium Hydroxide Product manufacturing Plant and associated infrastructure which is proposed to be established wholly within Lot