Preliminary Hazard

Analysis
Bulga Optimisation Project

December 2012
 Preliminary Hazard Analysis
Bulga Optimisation Project

December 2012

Prepared by
Umwelt (Australia) Pty Limited
on behalf of
Bulga Coal Management Pty Ltd

Project Director: John Merrell

Project Manager: David Holmes
Report No. 2869/R12/FINAL
Date: December 2012

Newcastle

PO Box 3024
75 York Street
Teralba NSW 2284

Ph. 02 4950 5322

www.umwelt.com.au
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Preliminary Hazard Analysis Executive Summary
Bulga Optimisation Project

Executive Summary
The Bulga Coal Complex (BCC) consists of two existing coal mining operations, the Bulga
Surface Operations and the Bulga Underground Operations. The Bulga Optimisation Project
(the Project) is a proposed continuation of the existing open cut operations to enable mining
to continue for a further approximately 22 years and allow the extraction of approximately
230 million tonnes (Mt) of additional run of mine (ROM) of coal (an additional approximately
200 Mt over existing approved extraction areas) to be mined by open cut methods from land
that is largely within the existing BCC disturbance footprint. The Project will enable existing
rates of production from the BCC to continue for the life of the Project, optimising utilisation
of existing infrastructure at the complex. No change is proposed to either the maximum
production rate from the open cut operations or the throughput of the coal handling and
preparation plant (CHPP), which is located adjacent to the Bulga Surface Operations MIA.

As a result of the Project the storage locations for a range of hazardous materials stored on
site will change. The potential impacts to off-site land users as a result of the relocation of
these hazardous materials was assessed in accordance with NSW Hazardous Industry
Planning and Assessment Guidelines (NSW Department of Planning (DoP) 2011).

The risk screening and classification process, undertaken in accordance with State
Environmental Planning Policy 33 – Hazardous and Offensive Development (SEPP 33),
indicated the storage quantity of ammonium nitrate emulsion (ANE) exceeds the screening
threshold for Class 5.1 materials. The Project is therefore considered potentially hazardous
and a preliminary hazard analysis (PHA) is required. The assessment of the Project in
accordance with Multi-level Risk Assessment (NSW DoP 2011a), indicated that the risks
associated with the storage of hazardous materials associated with the Project to the
surrounding land users are tolerable and therefore a Level 1 Qualitative assessment was
required for the PHA. Worst case consequence scenarios were considered in this
assessment process.

The two primary hazards identified by the Level 1 Qualitative assessment were an explosion
involving the BCC stores of Class 1.1 explosive materials and a fire incident involving the
store of ANE resulting in a toxic release of nitrogen dioxide. A hazard identification process
and qualitative risk assessment identified a range of technical and non-technical controls that
the BCC will put in place to minimise the risk of incidents that could result in off-site impacts.

Results of the risk screening and classification process undertaken has showed that if the
open cut explosives stores are located at least 600 metres from off-site land users then no
off-site impacts would result from any explosion incident involving the maximum storage
inventory of Class 1.1 materials. The risk screening and classification process undertaken
has also shown that if the ANE storage is located at least 1000 metres from off-site land
users then no off-site impacts would result from any fire incident resulting in a toxic release
involving the maximum storage inventory of ANE.

Results of the risk screening and classification process undertaken has showed that if the
underground explosives stores are located at least 80 metres from off-site land users then no
off-site impacts would result from any explosion incident involving the maximum storage
inventory of Class 1.1 materials.

The Project design will aim to maintain the above mentioned separation distances between
hazardous materials storages and off-site land users. In the event that the separation
distances cannot be maintained, the storage of hazardous materials would need to be
re-assessed in accordance with Multi-level Risk Assessment (NSW DoP 2011a).

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Preliminary Hazard Analysis Table of Contents
Bulga Optimisation Project

TABLE OF CONTENTS

1.0 Introduction ................................................................................. 1

1.1 Overview of Project .............................................................................. 1

2.0 Preliminary Hazard Analysis ...................................................... 5

2.1 Preliminary Risk Screening ................................................................. 7
2.2 Storage Quantity Screening ................................................................ 7
2.3 Transport Screening ............................................................................ 8

3.0 Risk Classification and Prioritisation ...................................... 11

3.1 Introduction ........................................................................................ 11
3.2 Methodology ....................................................................................... 11
3.3 Estimation of Consequences ............................................................ 12
3.4 Estimation of Probabilities of Major Accidents for Fixed
Installations ........................................................................................ 13
3.5 Criteria for Multi Level Risk Assessment ......................................... 14
3.6 Estimation of Societal Risk ............................................................... 14
3.6.1 Rank and Prioritise the Results ........................................................................15

4.0 Level 1 Qualitative Risk Assessment ...................................... 17

4.1 Introduction ........................................................................................ 17
4.2 Methodology ....................................................................................... 17
4.3 Level 1 Risk Criteria ........................................................................... 17
4.4 Hazard Identification .......................................................................... 17
4.4.1 Hazardous Materials.........................................................................................17
4.5 Hazard Study Results......................................................................... 19

5.0 Risk Management ...................................................................... 21

6.0 Conclusions ............................................................................... 23

7.0 References ................................................................................. 25

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FIGURES

1.1 Surrounding Environment – Greater Bulga Area ....................................... 1

1.2 Current Hazardous Materials Storage Locations ....................................... 1

1.3 Bulga Optimisation Project – Key Features................................................ 1

2.1 Overview of PHA Methodology .................................................................... 5

4.1 Areas Suitable for Hazardous Materials Storage ..................................... 19

APPENDICES
A WorkCover Dangerous Goods Acknowledgement of Notification

B IAEA Calculations

C Hazard Identification Worksheets

D AS 4360 Risk Criteria

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Preliminary Hazard Analysis Introduction
Bulga Optimisation Project

1.0 Introduction
The Bulga Coal Complex (BCC) consists of two existing coal mining operations, the Bulga
Surface Operations and the Bulga Underground Operations. The BCC is located in the
Hunter Valley within the Singleton Local Government Area (LGA) and is approximately
12 kilometres south-west of Singleton. The existing surface operations are located
approximately 4 kilometres to the south-east of the Bulga village and 4 kilometres north of
Broke village (refer to Figure 1.1). The BCC is operated by Bulga Coal Management (BCM).

The current Bulga Surface Operations are approved until 2025 however it is approaching the
physical limit of approved mining footprint. Underground mining operations are currently
approved to 2032.

The Project is a proposed continuation of the existing surface operations, including open cut
mining, for a further 22 years (approximately 10 years beyond the existing consent’s expiry
date). The Project will, amongst other things, allow an additional 200 million tonnes of coal
(approximately) to be mined by open cut methods from land that is largely within the existing
BCC disturbance footprint. The Project will enable existing rates of production from the BCC
to continue for the life of the Project, optimising utilisation of existing infrastructure at the
complex.

As a result of the Project the storage locations for a range of hazardous materials stored on
site will change (refer to Figure 1.2). The storage locations are also likely to change
throughout the life of the Project to accommodate the mining sequence. This report
considers the potential impacts to off-site land users as a result of the relocation of the
hazardous materials stored at BCC.

1.1 Overview of Project

The key features of the Project are summarised in Table 1.1 and are shown on Figure 1.3.

Table 1.1 – Key Features of the Bulga Optimisation Project

Major Project Proposed Operations

Components
Total Production Approximately 230 Mt ROM Coal over the life of the Project including
approximately 30 Mt of existing approved ROM coal reserves.
Annual Production No changes from current approved annual limits.
Limit Up to 12.2 Mtpa ROM coal from the Bulga Surface Operations and up to
20 Mtpa ROM coal through the CHPP.
Mine Life Approximately 22 years with further rehabilitation and closure works being
(Production) carried out after the end of this period.
Operating Hours 24 hours per day, 7 days per week.
Number of Continued employment of approximately 700 full time employees,
Employees decreasing towards the end of the Project.
Approximately 300 construction employees, predominately during the first
3 to 4 years of the Project.
Mining Methods Open cut mining (including some highwall mining).

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Preliminary Hazard Analysis Introduction
Bulga Optimisation Project

Table 1.1 – Key Features of the Bulga Optimisation Project (cont.)

Major Project Proposed Operations

Components
Mining Areas Mining in three contiguous pit areas:
• a western extension of the existing Bulga Pit and extraction of coal to
the base of the Woodlands Hill seam (the Main Pit area);
• an eastern extension of the Bulga Pit to mine the deeply dipping seems
in the Wittingham Coal Measures (The East Pit area); and
• deeper mining down to and including the Broonie seam series
(South Pit area).
A new pit area, known as the Bayswater Pit, mining shallow coal reserves
will also be developed to the northeast of the former Deep Pit. This pit will
ultimately be used for wet tailings storage.
The Project will also develop a new box cut in the highwall for accessing
existing approved underground mining areas.
Mine Infrastructure • A new open cut mine infrastructure area (MIA).
• A new underground MIA as its currently approved location will be
affected by the proposed open cut mining.
• Upgrades to the existing CHPP to improve throughput efficiency and
increase product yield.
• Changes to some Bulga Underground Operations infrastructure,
including conveyor location, where it will be affected by the proposed
open cut mining.
• Development of new haul roads to out-of-pit emplacement areas
including two new bridges over the realigned section of Broke Road.
• Enlargement of ROM and product coal stockpile areas.
• Construction and use of new approximately 3000 ML water storage
dam (Northern Dam) as part of the mine water system.
• Changes to mine and clean water diversion, management and
reticulation systems.
• Changes to ancillary infrastructure, including access roads and the
development of construction laydown areas.
Emplacement Areas Construction of two out-of-pit emplacement areas. The proposed Noise and
Visual Bund has been designed to minimise the noise and visual impacts of
the ongoing mining operations while the proposed Eastern Emplacement
Area enables overburden from the eastern side of the open cut operations
to be handled in a manner that minimises noise and air quality impacts to
the majority of residents around the Project area.
Overburden will also be emplaced in-pit.
Tailings and Tailings will be disposed of in the Deep Pit and Bayswater Pits with tailings
Rejects Strategy also potentially disposed of in the underground workings. Coarse rejects
and paste thickened tailings will be co disposed with overburden.
External Coal No change to approved annual maximum product transported by train.
Transport Continued use of Saxonvale Rail Spur.
Infrastructure Construction and use of a rail siding adjacent to the existing rail easement
capable of parking two coal trains awaiting loading at the BCC.
Electricity Realignment of sections of two 330 kV transmissions lines and other 66 kV
Infrastructure and 11 kV powerlines and other changes to associated electricity
infrastructure.
Public Roads Realignment of sections of Broke Road and Charlton Road and the
construction of haul road bridges over the realigned section of Broke Road.

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Table 1.1 – Key Features of the Bulga Optimisation Project (cont.)

Major Project Proposed Operations

Components
Pipelines and Other The relocation of the Broke Fordwich Private Irrigation District (PID) water
Services pipeline, Singleton Council Broke potable water supply pipeline and other
Infrastructure services (such as telecommunications infrastructure) which are associated
with the existing public road alignments.
Resource Definition Ongoing borehole drilling and sampling in and adjacent to mining areas to
Exploration better understand the coal resource, coal quality, geological conditions and
geotechnical constraints.
Rehabilitation Rehabilitation of areas disturbed by BCC operations, infrastructure and
construction.

A more detailed Project description is provided in the main text of the Environmental Impact
Statement (EIS) which this assessment accompanies.

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Preliminary Hazard Analysis Preliminary Hazard Analysis
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2.0 Preliminary Hazard Analysis

Under State Environment Planning Policy 33 – Hazardous and Offensive Development
(SEPP 33), a preliminary risk screening of a proposed development is required to determine
the need for a Preliminary Hazard Analysis (PHA). The preliminary screening involves
identification and assessment of the storage of specific dangerous goods classes that have
the potential for significant off-site effects. If, at the proposed location, and in the presence of
controls, the risk level exceeds the acceptable criteria for impacts on the surrounding land
use, the development is classified as ‘hazardous’ or ‘offensive’ industry and may not be
permissible within most land use zones in NSW.

A ‘hazardous industry’ under SEPP 33 is one which, when all locational, technical,
operational and organisational safeguards are employed continues to pose a significant risk.
An ‘offensive industry’ is one which, even when controls are used, has emissions which
result in a significant level of offence e.g. odour or noise emissions. A proposal cannot be
considered either hazardous or offensive until it is firstly identified as 'potentially hazardous'
or 'potentially offensive' and subjected to the assessment requirements of SEPP 33. A PHA
is required if a proposed development is 'potentially hazardous'.

A proposed development may also be 'potentially hazardous' if the number of traffic

movements for the transport of hazardous materials exceeds the annual or weekly criteria
outlined in Table 2 of Applying SEPP 33 (DoP 2011b). If these thresholds are exceeded a
route evaluation study is likely to be required.

Hazardous Industry Planning Advisory Paper (HIPAP) No. 6 – Guidelines for Hazard
Analysis (DoP 2011f) and Multi-level Risk Assessment (DoP 2011a) notes that a PHA should
identify and assess all hazards that have the potential for off-site impact. The expectation is
that the hazards would be analysed to determine the consequence to people, property and
the environment and the potential for hazards to occur.

An assessment of potential hazards and risk associated with the Project was conducted with
reference to the relevant NSW Department of Planning and Infrastructure (DP&I) hazardous
industry planning guidelines. The purpose of the assessment was to:

• establish the expected change in storage, handling and transport of dangerous goods
associated with the Project;

• identify potential hazard events that could lead to off-site impacts associated with the
change in storage, handling and transport of dangerous goods; and

• determine limitations with regard to storage quantities, on-site locations and traffic
movements for dangerous goods to minimise the possibility that the proposed design and
subsequent operations could lead to off-site impacts exceeding DP&I land use criteria.

The methodology used to identify and assess the hazards and respective failure scenarios
that have the potential for off-site impact is outlined in Figure 2.1. The details of how this
methodology is implemented are discussed in the respective sections of this report.

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SEPP 33 Screening involves compiling

Compilation of
information on the quantity of
Hazardous
Substance
hazardous materials used, the mode of
storage and location with respect to the
site boundary and the number and size
of annual and weekly road movements
SEPP 33 of the hazardous material.
Screening
A proposed development should be
considered potentially hazardous if the
storage or transport of hazardous
substances exceeds the respective
N
screening thresholds.
Does PHA not
SEPP 33 required Risk classification and prioritisation
Apply? involves ranking of the facility using
techniques to make broad estimates of
Y the consequence and likelihood of
accidents. The output is expressed in
Risk terms of individual and societal risk and
Minor is compared against respective criteria.
classification and consequences
prioritisation
A Level 1 analysis is a qualitative
assessment based on detailed hazard
identification. The objective is to
Level 1 demonstrate that the activity does not
Qualitative
pose a significant risk. Where the
Analysis
qualitative analysis cannot satisfactorily
demonstrate there will be no significant
risk, further analysis is required.
Level 2 Semi
Quantitative A Level 2 analysis supplements the
Analysis Level 1 analysis by quantifying the main
risk contributors to show that their
consequences are acceptable.
Level 3 A Level 3 quantitative analysis is
Quantitative
required when the screening and
Analysis
hazard identification process and/or risk
classification and prioritisation process
has identified risk contributors with
consequences beyond the site
Likelihood Consequence boundaries. The analysis requires a
Analysis Analysis comprehensive quantification of
significant consequences and their
likelihood.

Mitigation and Comparison The Risk Assessment compares the

management Risk Analysis against results of the risk analysis with the
options Criteria respective risk criteria. Where the level
of risk is not acceptable, risk
minimisation, mitigation and
management options need to be
Risk investigated.
Assessment

Figure 2.1 – Overview of PHA Methodology

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2.1 Preliminary Risk Screening

Preliminary risk screening is undertaken to determine the requirement for a PHA. SEPP 33
contains a number of assessment criteria for the storage quantities of hazardous material
that have the potential to create off site impacts.

2.2 Storage Quantity Screening

Table 2.1 contains a list of hazardous materials stored and used on the BCC site for the
Bulga Surface Operations and those located at the Bulga Underground Operations Mine
Infrastructure Area (MIA) that will be relocated as part of the Project. Table 2.1 also contains
the expected storage quantities associated with the Project and SEPP 33 screening criteria.
It should be noted that the types and quantities of hazardous materials to be stored on site
after Project implementation will not change from the types and quantities of hazardous
materials currently stored on site. However, the storage locations of some of these
hazardous materials will change as a result of the Project. WorkCover NSW
Acknowledgments of Notification of Dangerous Goods on Premises for the existing stores
listed in Table 2.1 are included in Appendix A.

Storage quantities for the class 2.1 flammable gases (liquefied petroleum gas and acetylene)
do not exceed the screening thresholds (refer to Table 2.1). Screening thresholds do not
exist for the class 2.2 compressed gases in the cylinder store (storage identifier CS) or for
diesel (combustible C1).

At this stage of the Project the final explosives storage locations are unknown and therefore
separation distances to off-site receptors are also unknown. The required separation
distance to the site boundary from a quantity of Class 1.1 explosives to ensure no intolerable
off-site overpressure impacts is determined using Figure 5: Class 1.1 Explosives
(Applying SEPP 33, NSW DoP, 2011b).

Assuming all open cut explosives storages will be located together, but suitable separation
distances are maintained between the explosives store and the ammonium nitrate emulsion
(ANE) store, the net explosive quantity to be considered for screening purposes is
110 tonnes. For 110 tonnes of class 1.1 explosive (refer to Table 2.1) the separation
distance to all off site receptors required to ensure screening thresholds are not triggered is
600 metres.

The underground explosives stores that will be relocated as part of the Project will be located
separately from the open cut explosives stores. The net explosive quantity to be considered
for the underground explosives stores is 101 kilograms. For 101 kilograms of class 1.1
explosive (refer to Table 2.1) the separation distance to all off site receptors required to
ensure screening thresholds are not triggered is 80 metres.

While the primary classification of the ANE is as an oxidising agent, this material may
explode under certain conditions resulting from heating and high impacts. If BCM chooses to
co-locate the ANE and Class 1.1 explosives, there is the potential for the ANE to
sympathetically detonate in the event of a Class 1.1 explosion. In this case the ANE is
treated as a Class 1.1 material for screening purposes and the net explosive quantity
considered is 180 tonnes (refer to Table 2.1). For 180 tonnes of Class 1.1 explosive the
separation distance to all off site receptors required to ensure screening thresholds are not
triggered is 750 metres.

BCM has committed to store all materials in accordance with appropriate buffer distances, as
discussed in further detail in Section 4.0.

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If the storages were to be located closer to the site boundary than indicated above, further
analysis would need to be conducted to determine whether the level of risk to off-site
receptors is tolerable.

Notwithstanding the above, the storage quantity of ANE exceeds the screening threshold for
class 5.1 materials and the Project is therefore considered potentially hazardous and a PHA
is required in support of the Development Application.

2.3 Transport Screening

Transport frequencies and quantities of hazardous materials to the BCC site for the Project
will remain at the same levels associated with the present mining operations. Therefore, no
further assessment is required.

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Table 2.1 – Hazardous Materials Inventory

Material Current ADG Project Storage Screening Threshold (t) Trigger SEPP 33
Storage Code/Division Capacity
Identifier
Acetylene, dissolved CS 2.1 140 m3 (150 kg) 200 kg at 20 m from site No
boundary
Argon, compressed CS 2.2 50 m3 N/A No
Carbon dioxide CS 2.2 250 kg N/A No
Nitrogen, compressed CS 2.2 110 m3 N/A No
Oxygen, compressed CS 2.2 (subclass 5.1) 450 m3 (600 kg) N/A (5,000 kg) No (No)
Liquefied petroleum gas CS 2.1 450 kg 16,000 L (10,000 kg) No
Compressed Gas, N.O.S. CS 2 87 m3 N/A -
Liquefied petroleum gas LPG1 2.1 7,500 L 16,000 L (10,000 kg) No
Diesel FF C1 1,550,000 L N/A -
Diesel Beltana 3 C1 55,000 L N/A -
Explosives – detonators MAG1 1.4B 100 kg N/A -
(100,000 detonators)
Explosives – detonators 1.1B 100 kg Screening thresholds dependant on distance to site
(100,000 detonators) boundary.
Explosives Beltana 1 1.1D 100 kg Screening thresholds dependant on distance to site
boundary.
Explosives – detonators Beltana 2 1.1B 1 kg Screening thresholds dependant on distance to site
(1000 detonators) boundary.
Explosives – boosters and detonating MAG2 1.1D 10 t Screening thresholds dependant on distance to site
cord boundary.
Explosives– boosters and detonating cord MAG3 1.1D 10 t Screening thresholds dependant on distance to site
boundary.
Explosives – ammonium nitrate fuel oil ANFO 1.1D 87 t Screening thresholds dependant on distance to site
boundary.
Oxidising liquid, N.O.S. - ammonium EMUL 5.1 70 t 5 Yes
nitrate emulsion
ADG Code – Australian Dangerous Goods Code
N.O.S – not otherwise specified

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Preliminary Hazard Analysis Risk Classification and Prioritisation
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3.0 Risk Classification and Prioritisation

3.1 Introduction

Multi-level Risk Assessment (MLRA) (DoP 2011a) suggests the use of a preliminary analysis
of the risks related to a proposed development to enable the selection of the most
appropriate level of risk analysis in the PHA. This preliminary analysis includes risk
classification and prioritisation using a technique adapted from the Manual for Classification
of Risk due to Major Accidents in Process and Related Industries (Manual for Classification
of Risk) (International Atomic Energy Agency – IAEA – 1993). A complete description of the
technique is presented in the MLRA (DoP 2011a). The technique is based on a general
assessment of the consequences and likelihoods of accidents and their risks to individuals
and society, and the comparison of these risks to relevant criteria to determine the level of
assessment required, be it qualitative or quantitative.

3.2 Methodology

The objective of the risk classification and prioritisation process is to identify whether the
risks identified as part of the SEPP 33 preliminary screening pose acceptable risks or
whether further assessment is required. The assessment involves the following steps:

• classification of the type of activities and materials inventories;

• estimation of consequences;

• estimation of probabilities of major accidents for fixed installations;

• estimation of societal risk;

• estimation of individual risk;

• evaluation of alternatives; and

• assessment using criteria to determine required level of risk assessment.

For each potentially hazardous activity information is required regarding the location, type,
production and storage condition of the activity, as well as name, physical state and amount
of hazardous substances involved. Table II of the Manual for Classification of Risk
(IAEA 1993) provides a guideline of required information.

If a facility has effective physical isolation and separation between the storage vessels with
the same dangerous goods classification, then the content of the largest storage vessel
would typically be used to estimate the effect of an incident.

When selecting the activities likely to have the potential to cause risk/damage, the following
should be considered:

• if more than one substance in the same activity can cause damage independently from
the other substances, analyse them separately;

• if a group of substances may act together, consider them as a single (equivalent)

substance; and

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• if a flammable substance is also toxic, both effects have to be accounted for. After
following the methodology within MLRA (DoP 2011a) it will be clear whether flammable
properties are important or not, compared with toxic properties.
Considering the site layout and location of hazardous activities or substances, the maximum
amount of hazardous substances that could be released in an accident for each activity has
been conservatively estimated (refer to Section 2.2).

3.3 Estimation of Consequences

Consequences of an accident depend on the type of substance, activity and the quantity
involved, as well as the population exposed to its effect.

The external consequences (Ca,s) of major accidents to humans are calculated using
equation (1) of IAEA (1993):

Ca,s = A x d x fa x fm

where: Ca,s = external consequences (fatalities per accident) where the subscript ‘a’
represents an activity and subscript ‘s’ represents a hazardous
substance
A = affected area (hectares; 1 ha = 104 m2)
d = population density in defined populated areas (persons/ha)
fa = correction factor for populated area
fm = correction factor for mitigation effects.

Alternatively, if the population (N) within the affected area is known, the consequence can be
estimated as follows:

Ca,s = N x fm

In accordance with the Manual for Classification of Risk (IAEA 1993) this calculation was
undertaken for all relevant hazardous substances and activities.

The only item triggering SEPP 33 thresholds (refer Table 2.1) was the storage of Class 5.1
ANE. The two primary hazards associated with ANE are explosion and nitrogen dioxide
generation. While ANE’s primary classification is not as an explosive, under certain
conditions it may be detonated. However, the consequence contours associated with an
explosion of ANE are much smaller than those associated with a toxic release resulting from
the heating of ANE. Given the separation distance from off-site land users associated with
the storage of ANE will be governed by the toxic release scenario, the explosion hazard
scenario was not considered further.

Upon exposure to excessive heat ANE can generate toxic nitrogen dioxide gas. It should
also be noted that BCM has a range of controls in place to minimise the possibility that the
ANE is exposed to excessive heating. For the purpose of this assessment, the maximum
storage quantity of ANE (70 tonnes) has been treated as a toxic gas inventory and used to
assess the potential impacts associated with a nitrogen dioxide generation from excessive
heating of the ANE. This approach should be viewed only as a guide as to whether further
assessment should be undertaken to consider credible toxic release scenarios.

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The effect category for a highly toxic gas storage of between 50 and 200 tonnes is GIII which
has an effect distance of between 1000 and 3000 metres (refer to MLRA (DoP 2011a)). As
not all of the ammonium nitrate is converted to nitrogen dioxide during decomposition, the
equivalent toxic gas storage quantity would be approximately 50 tonnes. Therefore the
maximum effect distance has been conservatively taken as the minimum effect distance of
1000 metres for a GIII event which would equate to a 50 tonne toxic gas release.

3.4 Estimation of Probabilities of Major Accidents for Fixed

Installations

The probability number (Ni,s) of major accidents to humans is calculated using equation (2) of
Manual for Classification of Risk (IAEA 1993):

Ni,s = N*i,s + n, + nf + n0 + np

where: N*i,s = the average probability number for the installation and the substance;
n, = probability number correction parameter for the frequency of
loading/unloading operations;
nf = probability number correction parameter for the safety systems
associated with flammable substances;
n0 = probability number correction parameter for the organisational and
management safety;
np = probability number correction parameter for wind direction towards
the populated area.

In accordance with the Manual for Classification of Risk (IAEA 1993) this calculation was
undertaken for all relevant hazardous substances and activities, the results of these
calculations are provided in Section 3.6.

This probability number was then converted into a probability Pi,s by means of Table XIV of
Manual for Classification of Risk (IAEA 1993) or directly, using the relationship between
N and P which is defined as:

N = Iog10 (P)

Pi,s defines the frequency (number of accidents per year) of accidents involving a hazardous
substance (subscript ‘s’) for each hazardous fixed installation (subscript ‘i’), which causes the
consequences that have been estimated previously.

The probabilities of major accidents at the facility during an explosion or toxic release event
are summarised in Appendix B.

The correction parameter n0 accounts for factors including the development’s safety
management, age of the plant, maintenance, documentation and procedures, safety culture,
training and emergency planning. For assessment purposes, this factor was given a value of
zero to represent average industry practice to provide a conservative estimate of the impact
of the site's safety and management procedures on any major accidents.

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3.5 Criteria for Multi Level Risk Assessment

The method of determining the assessment criteria recommended by DP&I is outlined in

Figure A1.3 of the MLRA (DoP 2011a). This figure shows the three criteria regions. Below
the lower criterion line the risk would be considered negligible. Above the upper criterion line
the risk would be considered intolerable. The region between the two criteria lines is
considered to be tolerable depending on the results of an evaluation of other risk criteria.

These criteria are used to determine the level of assessment required by the PHA as follows:

• Level 1 assessment – can be justified if the analysis of the facility demonstrates the
societal risk is negligible and there are no potential accidents with significant off-site
consequences;

• Level 2 assessment – can be justified if the societal risk estimates fall within the middle
region i.e. between the upper and lower criteria lines and the frequency of risk
contributors having off-site consequences is relatively low. The assessment must
demonstrate that the facility will comply, at least in principle, with the DP&I risk criteria,
based on broad quantification of the risk; and

• Level 3 assessment – is required if the societal risk estimates are in the intolerable zone,
or where there are significant off-site risk contributors and a level 2 assessment fails to
demonstrate that risk criteria will be met.

According to Section 3.1 of MLRA (DoP 2011a), quantification of the risk must be undertaken
on any component identified in the risk classification and prioritisation process which has off-
site consequences of greater than or equal to 1 at a frequency greater than 1 x 10-7 per year.

A summary of the estimation of consequences and probabilities of a toxic release resulting

from the heating of ANE and the detonation of the explosives stores (the aggregate of open
cut and underground storage quantities) is attached at Appendix B.

3.6 Estimation of Societal Risk

The risk to the public from each potentially hazardous activity is estimated by combining the
estimated consequences to humans and the probabilities of major accidents.

Using the results of the assessments undertaken in Section 5.3, the activities are classified
and grouped according to Manual for Classification of Risk (IAEA 1993). The details of the
scenarios modelled are outlined in Table 3.1.

Table 3.1 – Dangerous Goods Scenarios Modelled for Societal Risk

Descriptor Substance ADG Class Activity Hazardous Description

Event
S1 ANE 5.1 Storage Toxic ANE externally heated
Release releases NO2
S2 Explosives 1.1 Storage Explosion Entire store of
explosives detonates

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3.6.1 Rank and Prioritise the Results

With reference to Figure 9 of Manual for Classification of Risk (IAEA 1993) the priority
assessment risk categories correspond to the upper right hand side of the matrix of
probability versus consequence, i.e. activities with relatively high probability and high
consequences. However, it has to be taken into consideration that the concept of societal
risk also implies that risk of higher consequences, with smaller frequency, are perceived as
more important than those of smaller consequences with higher probabilities.

Chart 3.1 shows the cumulative risk associated with the toxic release and explosion hazards
listed in Table 3.1 relative to the societal risk criteria. The end point of the risk curve is within
the negligible region and therefore only a level 1 qualitative risk assessment is required
(refer to Section 4.0).

1.0E+00

1.0E-01
Societal Risk Criteria

1.0E-02 Cumulative Risk Plot

1.0E-03
Frequency (Accidents / Year)

Intolerable
1.0E-04

1.0E-05
ALARP
1.0E-06

1.0E-07

1.0E-08
Negligible
1.0E-09

1.0E-10
0.1 1 10 100 1000 10000
Consequence (Fatalities / Accident)

Chart 3.1 – Cumulative Risk Plot

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Preliminary Hazard Analysis Level 1 Qualitative Risk Assessment
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4.0 Level 1 Qualitative Risk Assessment

4.1 Introduction

A Level 1 assessment is associated with a qualitative analysis that uses words and
descriptive scales to determine the risk of each of the hazards identified in Section 3.6. This
risk is then assessed against qualitative criteria to determine whether the facility could cause
an accident of a magnitude significant in terms of risk to people or property, or harm to the
biophysical environment.

Low and acceptable risks can be allowed with minimal further treatment, however, if the risks
are significant a higher level of analysis is required.

4.2 Methodology

A Level 1 assessment requires (as a minimum):

• hazard identification using word diagrams, simplified fault/ event trees and checklists;

• generalised consequence analysis of key risk contributors to demonstrate that their

consequences are confined within the project boundaries. This analysis should
incorporate the results of the preliminary screening and risk classification and
prioritisation assessments;

• evaluation of the risks against the qualitative criteria in HIPAP No. 4 Risk Criteria for Land
Use Safety Planning (DoP 2011e);

• demonstration of adequacy of the proposed technical and management controls to

ensure ongoing safety of the proposed development; and

• should include all facilities which reported exceedances of initial screening thresholds.

4.3 Level 1 Risk Criteria

The risk criteria from Australian Standard AS 4360:2004 – Risk Management was used for
this Level 1 assessment. The risk criteria for consequence severity, frequency estimation and
risk matrix are provided in Appendix C.

4.4 Hazard Identification

4.4.1 Hazardous Materials

A brief summary of the properties of the hazardous materials associated with the Project is
provided below. Although risk screening (refer to Section 2.2) has shown that LPG and
diesel do not trigger screening thresholds, these materials have also been included in the
Level 1 assessment to ensure all credible hazardous events are considered.

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Explosives

An explosive material is a reactive substance that contains a large amount of potential

energy that when released produces an explosion resulting in the release of light, heat and
pressure. The explosives stored on the BCC site are Class 1.1 and Class 1.4. Class 1.1
explosives are considered to be a mass explosion hazard where almost all of the material is
affected instantaneously. Class 1.4 explosives are considered a minor explosion hazard with
the explosion largely confined to the package and no projection of fragments of appreciable
size or range.

Ammonium Nitrate Emulsion

ANE is a Class 5.1 oxidising agent and will support combustion of other materials as it
produces oxygen as one of its decomposition products. Toxic gases such as nitrogen
dioxide (NO2) and nitrous oxide (N2O) are also produced during decomposition of ANE.
Table 4.1 contains the one hour duration acute exposure guidelines for NO2. Only NO2
release has been assessed as it is considered to be the most toxic of the products of
combustion.

Solid AN may explode under certain conditions but does not readily explode. High
temperature, confinement and contamination are the primary factors influencing the
likelihood and severity of an AN explosion.

Table 4.1 – One Hour Duration NO2 Acute Exposure Guidelines

Criteria Concentration Definition

(ppm)
AEGL-1 0.5 Is the airborne concentration above which it is predicted that
the general population, including susceptible individuals, could
experience notable discomfort, irritation, or certain
asymptomatic non-sensory effects. However, the effects are
not disabling, and are transient and reversible upon cessation
of exposure.
AEGL-2 12 Is the airborne concentration above which it is predicted that
the general population, including susceptible individuals, could
experience irreversible or other serious, long-lasting adverse
health effects or an impaired ability to escape.
AEGL-3 20 Is the airborne concentration (expressed as ppm or mg/m3) of a
substance above which it is predicted that the general
population, including susceptible individuals, could experience
life-threatening health effects or death.
Source: Acute Exposure Guideline Levels for Nitrogen Dioxide, NAC for AEGL’s, 2008.

Liquefied Petroleum Gas (LPG)

LPG is stored under pressure in a liquefied state and is composed primarily of propane and
butane. At ambient pressure and temperature LPG presents in the gaseous state as a
flammable gas. Mixtures of LPG and air within the flammable range (LPG concentrations in
air of 2.5 per cent v/v to 9.5 per cent v/v) may be ignited and explode. The resulting
explosion is typically a deflagration rather than a detonation associated with high explosives.

Jet fires may also result if LPG pipe or vessel fitting leaks are ignited. If the pressurised
storage vessel is exposed to excessive heat a boiling liquid expanding vapour explosion
(BLEVE) may result.

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Diesel

Diesel is a combustible liquid which means that it has the potential to produce flammable
vapours, which are able to be ignited. As a combustible liquid, diesel is not a hazardous
substance unless stored in association with Class 3 flammable liquids.

4.5 Hazard Study Results

The two primary hazards identified associated with the Project were the explosion of the
Class 1.1D materials and the ANE and the potential for nitrogen dioxide release from the
ANE tank when exposed to a significant source of heat. Appendix C contains the hazard
identification worksheets.

The qualitative risks for each of these hazards have been assigned conservatively assuming
the storage may be close to the site boundary and/or off-site land users. For this reason the
risks for toxic release and explosion have a high ranking. Table 4.2 shows the required
separation distances from off-site land users to ensure no off-site impacts.

Table 4.2 – Separation Distances

Storage Hazard Distance to Off-Site Land User (m)

Underground Explosion 80 1
Explosives
Open Cut Explosives Explosion 600 1

ANE Toxic release 1,000 2

Note 1: Based on Applying SEPP 33 Figure 5 – Class 1.1 Explosives Overpressure Effects.
Note 2: Based on Multi-level Risk Assessment IAEA Table III – Effect Categories – Maximum Distance and Area of Effect.

BCC will locate the explosives and ANE storage to maintain the separation distances from
off-site land users set out in Table 4.2. Should, for a currently unforeseen circumstance, the
explosives and/or ANE need to be stored closer to off-site land users than shown in
Table 4.2 the potential for off-site impacts will need to be re-assessed. This assessment
may include a level of quantitative analysis such as air dispersion modelling and explosion
overpressure modelling. Figure 4.1 shows the areas within the BCC that are offset
600 metres and 1000 metres from any off-site land users including public roads through BCC
land. The offset distance of 80 metres for the Bulga Underground Operations explosives
store will be able to be readily met.

It is important to note that even if the storage locations are closer to off-site land users than
shown in Table 4.2 it does not mean the development is hazardous, just that further
assessment would be required.

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Bulga Optimisation Project

5.0 Risk Management

The control of risks is a continuous process where strategies are put into place to eliminate
risks wherever possible, mitigate the residual risks identified using appropriate control
measures, safeguards and procedures, and, lastly, accept the residual risk and manage the
impacts should the hazardous event occur. The risk control strategies and their
effectiveness are broadly described as:

• engineering control to either completely eliminate the risk (100 per cent effectiveness) or
to implement physical controls and safeguards (minimum 90 per cent effectiveness);

• administrative control based around procedures (maximum 50 per cent effectiveness);

and

• personnel control using training and the control of work methods (maximum 30 per cent
effectiveness).

The qualitative risk assessment identified a range of technical control measures and non-
technical safeguards and procedures that will be put in place to eliminate or mitigate the level
of risk associated with the operation of the facility.

Technical safeguards are those controls that are incorporated into the process or control
system hardware, software or firmware. Non-technical controls are management and
operational controls, such as security policies, operational procedures, maintenance
procedures and training. Technical and non-technical safeguards can also be divided into
preventive controls which inhibit or prevent hazardous events from occurring and detective
controls such as control system alarms that warn of unacceptable process deviations, or
security monitoring systems that initiate an alarm in the event of violations of security
protocols.

The technical control measures identified in Appendix C that will be implemented as part of
the Project include:

• locate the Class 1.1 explosives and ANE storages in accordance with the buffer
distances specified in Table 4.2;

• design of diesel tanks and refuelling systems in accordance relevant standards and
codes;

• design of hazardous materials storage area surface drainage systems to prevent spills or
runoff from storage areas entering surrounding land/waterways; and

• storage of dangerous goods in dangerous goods compliant stores (in accordance with
relevant Australian Standards) and appropriate segregation of incompatible dangerous
goods.

The non-technical safeguards and procedures identified in Appendix B include:

• update BCC emergency response plans and security plans in consideration of the
relocated explosives and ANE storages;

• implement appropriate housekeeping to minimise combustible materials within 30 metres

of ANE and explosives storages;

• on site speed limits and designated traffic flow directions to consider new storage
locations;

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• ensure all equipment/vehicles associated with the handling of ANE and explosives are
regularly inspected and maintained fit for duty in accordance with relevant standards;

• ensure all personnel involved in the handling and storage of ANE and explosives are
appropriately trained; and

• ongoing implementation of appropriate hot work/safe work procedures for works in the
vicinity of hazardous materials.

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Bulga Optimisation Project

6.0 Conclusions
An assessment of the risks associated with the storage and transport of hazardous materials
associated with the Project, conducted in accordance with NSW Hazardous Industry
Planning and Assessment Guidelines has found that the level of risk associated with the
Project to the surrounding land users is tolerable. Therefore the Project is not hazardous as
defined by SEPP 33.

The risk screening and classification process undertaken has shown that if the open cut
explosives are located at least 600 metres from off-site land users and the underground
explosives are located at least 80 metres from off-site land users then no off-site impacts will
result from an explosion incident involving the maximum storage inventories of Class 1.1
materials. The risk screening and classification process undertaken has also shown that if
the ANE storage is located at least 1000 metres from off-site land users then no off-site
impacts will result from a fire incident resulting in a toxic release involving the maximum
storage inventory of ANE.

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Preliminary Hazard Analysis References
Bulga Optimisation Project

7.0 References
NSW DoP 2011. Hazardous Industry Planning and Assessment Guidelines.

NSW DoP 2011a. Multi-level Risk Assessment.

NSW DoP 2011b. Applying SEPP 33 Hazardous and Offensive Development Application
Guideline.

NSW DoP 2011e. Hazardous Industry Planning Advisory Paper No. 4 – Risk Criteria for
Land Use Safety Planning.

NSW DoP 2011f. Hazardous Industry Planning Advisory Paper No. 6 – Guidelines for
Hazard Analysis.

National Advisory Council, Acute Exposure Guideline Levels for Nitrogen Dioxide, December
2008.

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 APPENDIX A
WorkCover Dangerous Goods
Acknowledgement of Notification
APPENDIX B
IAEA Calculations
 IAEA Risk Classification and Prioritisation

Reference
Multi Level Risk Assessment , NSW Department of Planning, January 2011.

Consequence Estimation
Maximum Affected External
Physical Effect Category Affected Mitigation
Scenario Substance Activity Distance Area Population Density Consequences,
Harm Table II(a) Population, N Factor, fm
(m) (ha) Ca,s
S1 ANE as toxic gas source Storage Toxic GIII 1000 157.1 0.5 79 0.1 7.9
S2 Class 1.1D and ANE Storage Explosion CI 100 1.6 0.5 1 1 0.8

Probability Estimation
Average Probability Loading Loading/Unloading Organisational Safety Wind Direction
Physical Population Probability Frequency, P
Scenario Substance Activity Number, N*i,s Unloading Correction Parameter, Correction Parameter, Correction
Harm Fraction Number, Ni,s (events/yr)
Table VII(a) Frequency nl nl Parameter, nl
S1 AN as toxic gas source Storage Toxic 6 50-200 -1 0 5% 1.5 6.5 3.2E-07
S2 Class 1.1D and ANE Storage Explosion 7 50-200 -1 0 5% 0 6 1.0E-06
 APPENDIX C
Hazard Identification Worksheets
 Hazard Identification

Date: 4-Oct-12 Job: Bulga Optimisation Project Job #: 2869B

Section/Area: Explosives and ANE Storage

Ref Asset Hazard Scenario Cause Consequence Current Barriers C L R Action

1 ANE Tank Toxic release Tank heated by adjacent Delivery truck fire or Fatality or injury to on- Separation distances IAEA classification and
fire causing AN to other combustibles in site personnel. between storage tank screening indicates that
decompose and release storage area on fire. Possible off-site fatality and combustibles to be the maximum range of
nitrogen dioxide. Bushfire or injury to sensitive maintained according to impact of a toxic release is
Lightning strike member of the relevant Dangerous 1000 m. If final storage
community. Goods codes and location is within 1000 m
standards.
5 E 15
of surrounding land users
ANE and explosives conduct dispersion
delivery contractors modelling of nitrogen
suitably trained and dioxide release and
qualified. estimate risks.
Site traffic/road rules.
2 Class 1.1D Explosion Fire or high impact Delivery truck fire or Fatality or injury to on- Explosives stored in Risk screening has shown
Magazines inititaes detonation of other combustibles in site personnel. accordance with that there will be no off-
entire storage quantity storage area on fire. Possible off-site fatality relevant Dangerous site overpressure impacts
of explosives Bushfire or injury to member of Goods codes and resulting from the
Lightning strike the community. standards. detonation of 110 tonnes
Explosives delivery of explosives (assuming
contractors suitably suitable separation from
trained and qualified. ANE) provided the
Hot work procedures. 5 E 15 magazine is located at least
Site traffic/road rules. 600 m from surrounding
land users. If final storage
location is within 600 m of
off-site land users conduct
explosion overpressure
modelling and estimate
risks.

Page 1 of 2
 Hazard Identification

3 ANE/ANFO Toxic release/ Truck crash and spillage Motor vehicle accident. ANE/ANFO entering ANE and explosives Ensure emergency
Delivery Environment of ANE/ANFO into on- natural watercoarse and delivery contractors response procedures are
site drainage system. impacting flora and suitably trained and updated when final
fauna. qualified. location of ANE/ANFO
Emergency spill tanks is known.
response procedures.
3 C 13
Ensure drainage systems
Site traffic/road rules. designed to prevent
contamination of
surrounding
land/waterways.
4 Class 1.1D Security/ Deliberate attempt to Malicious act. Fatality or injury to on- Site security. Ensure site security plans is
Magazines and Explosion detonate explosives. site personnel. updated to accomodate
ANE Tank Possible off-site fatality 5 E 15 new storage location.
or injury to member of
the community.

Page 2 of 2
 Hazard Identification

Date: 4-Oct-12 Job: Bulga Optimisation Project Job #: 2869B

Section/Area: Cylinder Store

Ref Asset Hazard Scenario Cause Consequence Current Barriers C L R Action

1 Workshop gas Fire/Explosion Fire or explosion Leaking fittings. Serious injury to on site Gas cylinders stored and
cylinders resulting from ignition Mobile equipment personnel. handled according to
of flammable gas leak impact. No off-site impacts. relevant DG codes and
from cylinder. standards.
All hoses and flame 1 C 4
ciutting equipment
equipment regularly
inspected and
maintained.

Page 1 of 1
 Hazard Identification

Date: 4-Oct-12 Job: Bulga Optimisation Project Job #: 2869B

Section/Area: Diesel Storage Tank

Ref Asset Hazard Scenario Cause Consequence Current Barriers C L R Action

1 Diesel Tank Fire Adjacent fire leads to Vehicle fire. Injury to on-site Diesel storage in
ignition of diesel. personnel from radiant accordance with
heat or smoke. AS1940.
Possible injury to off-site Diesel fuel is difficult to 3 E 6
community member ignite (combustible
from radiant heat or liquid rather than
smoke. flammable liquid).

Page 1 of 1
 Hazard Identification

Date: 4-Oct-12 Job: Bulga Optimisation Project Job #: 2869B

Section/Area: LPG Storage Tank

Ref Asset Hazard Scenario Cause Consequence Current Barriers C L R Action

1 LPG Tank BLEVE Adjacent fire or fire Vehicle impact initiates Fatality or injury to on LPG storage designed in Risk screening shows that
from LPG fitting leak fire. site personnel. accordance with the quantity of LPG is
initiates BLEVE. Introduced ignition Possible off site fatality relevant DG codes and below the threshold.
source initiates fire. or injury to sensitive standards. 4 E 10
member of the
community.
2 LPG Tank Fire Jet fire from leaking LPG Vehicle impact initiates Fatality or injury to on LPG storage designed in Risk screening shows that
fitting. fire. site personnel. accordance with the quantity of LPG is
Introduced ignition Possible off site fatality relevant DG codes and below the threshold.
source initiates fire. or injury to sensitive standards. 4 E 10
member of the
community.

Page 1 of 1
 APPENDIX D
AS 4360 Risk Criteria
 AS 4360 Risk Scoring System
Scoring Matrix
Likelihood 1 2 3 4 5
Level Insignificant Minor Moderate Major Catastrophic
A Almost Certain 11 16 20 23 25
B Likely 7 12 17 21 24
C Possible 4 8 13 18 22
D Unlikely 2 5 9 14 19
E Rare 1 3 6 10 15

Legend
18 to 25: EXTREME RISK; immediate action required;
10 to 17: HIGH RISK; senior management attention needed;
6 to 9: MODERATE RISK; management responsibility must be specified; and
1 to 5: LOW RISK; managed by routine procedures.

Qualitative Measures of Likelihood

Level Description
A Almost Certain The event is expected to occur in most circumstances
B Likely The event will probably occur in most circumstances
C Possible The event might occur at some time
D Unlikely The event could occur at some time
E Rare The event may occur only in exceptional circumstances

Qualitative Measures of Consequence or Impact or Severity

Level People Losses Environmental Equipment Production Loss
Harm Damage
1 Insignificant No injuries No-off site effects Low financial loss No production loss
2 Minor First aid treatment On-site release Medium financial loss Up to 1 day
immediately contained production loss

3 Moderate Medical treatment On-site release High financial loss Between 1 to 5 days
contained with outside production loss
assistance
4 Major Extensive injuries Off-site release with Major financial loss Between 5 to 20 days
no detrimental effects production loss

5 Catastrophic Death Toxic release off-site Huge financial loss More than 20 days
with detrimental effect production loss

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