ASSESSMENT OF EFFECTS ON THE PHYSICAL ENVIRONMENT FROM THE TRANSTASMAN RESOURCES MARINE CONSENT APPLICATION: SEDIMENT PLUME MODEL Date: March 2014 Review by: Dr Chenonn Chin 2 Executive Summary 1. Trans-Tasman Resources Limited (TTR) is proposing to conduct iron ore extraction and processing operations in the South Taranaki Bight, involving the excavation of up to 50 million tonnes (27 million cubic metres) per year of seabed material containing iron sand. TTR has carried out a sediment plume model study and prepared technical reports related to the sediment model to support the application for marine consent lodged under the Exclusive Economic Zone and Continental Shelf (Environmental Effects) Act 2012 (EEZ Act). SKM has been engaged by the Environmental Protection Authority (EPA) to carry out an independent technical review of the sediment model study to ascertain the validity and accuracy of the model, highlight any shortcomings, and recommend measures which are required to satisfy the EEZ Act. 2. A set of nested model grids has been set up for the Regional Ocean Modelling System (ROMS) ocean model, an outer grid covering Cook Strait at a resolution of 2 km and a pair of alternative inner grids, one covering the South Taranaki Bight and the other a smaller area on Patea Shoals, both at 1 km resolution with the option of refining them to 500 m if necessary. 3. In general the sediment plume model is done appropriately, however we have two areas of concern: a. Number of sediment samples taken to calibrate the model, and b. Grid size 4. The ROMS ocean model or the hydrodynamic part of the model was well calibrated with measured tidal data which indicate its validity and accuracy. 2 5. The 20-year excavation covers an area of 65.76 km . Only two core samples that provide sediment particle size distribution data were presented to characterise the sediment in the working area. This is grossly inadequate for a mining operation of the scale and size proposed by TTR and does not allow the effects of Total Suspended Solid (TSS) to be adequately predicted by the model. 6. The results of the two core samples indicate there is a great variation of sediment characteristics with sediment depth. Mud contents of more than 50% and up to 82% are found in the samples. It is highly probable that the sediment in the large excavation area will also be variable. 7. It is unclear how the variation of sediment layers is accounted for in the sediment plume model. 8. TTR has proposed to not carry out the mining operation where the operation encounters a mud layer with high mud contents. This will reduce the uncertainty in the interpretation of the modelling results and the assessment of the environmental impacts. Based on this understanding the shortcomings of the sediment samples will not change the general assessment of low environmental impact. 3 9. The accuracy of the model will affect the working site and the surrounding areas but is unlikely to affect the coast near shore due to the strong wave environment where mud contents are unlikely to stay. Glossary 10. Relevant terms explained Sand Sediment with grain sizes between 63 μm and 2 mm. Silt Sediment with grain sizes between 2 and 63 μm. Clay Sediment with grain sizes < 2 μm Mud content Silt and clay components 11. List of acronyms EEZ Exclusive Economic Zone EPA Environment Protection Authority PSD Particle Size Distribution ROMS Regional Ocean Modelling System SKM Sinclair Knight Merz Ltd TTR Trans-Tasman Resources Ltd 4 Table of Contents Executive Summary ............................................................................................................................... 2 Glossary .................................................................................................................................................. 3 Table of Contents ................................................................................................................................... 4 Introduction ............................................................................................................................................ 5 Description of proposal ......................................................................................................................... 5 Description of sediment plume model............................................................................................ 5 Further information ................................................................................................................................ 6 Assessment of validity of sediment plume model ............................................................................. 7 Evaluation ............................................................................................................................................... 8 References .............................................................................................................................................. 9 Appendices ........................................................................................................................................... 10 5 Introduction 12. Trans-Tasman Resources Ltd (TTR) has submitted an application to the EPA for a marine consent to mine iron sand from an area in the South Taranaki Bight. The project involves excavation of up to 50 million tonnes (27 million cubic metres) per year of seabed material containing iron sand for processing on an offshore floating vessel. Approximately 10% of the material will be processed offshore into iron ore for export, with the remaining material returned to the seabed. 13. The mining operation will result in suspended sediment plumes and sediment deposition on the seabed that may cause environmental effects on the ocean environment. Dispersed sediment plumes could also reach the near-shore coastal environment. 14. The Environmental Protection Authority (EPA) has engaged Sinclair Knight Merz Ltd (SKM) to review the sediment plume model prepared by TTR to assess the effects of suspended sediment plumes produced by the mining operation. The review broadly includes the following: Critical appraisal of the application information in terms of assessment of effects of the activities on the environment, Assessment and management of the residual effects, and Critical appraisal of the application information in terms of the validity of the sediment plume model used. 15. TTR has prepared an overall impact assessment and 23 technical reports and a statement of evidence (see Appendix A) related to sediment plume modelling, oceanographic processes and the physical environment to support the application for a marine consent lodged under the Exclusive Economic Zone and Continental Shelf (Environmental Effects) Act 2012 (EEZ Act). The main documents reviewed are listed in Appendix A. 16. A table listing the reports previously reviewed by SKM is provided in Appendix B, with a summary of the reports’ key findings and issues identified in the review. Description of proposal Description of sediment plume model 17. TTR carried out the sediment plume modelling using a software package known as Regional Ocean Modelling System (ROMS) which can be a standalone model or coupled to atmospheric and /or wave models. The software appears to be widely used by the scientific community for a diverse range of applications including sediment plume modelling. ROMS is well suited for the sediment plume modelling for this project. 6 18. A set of nested model grids has been set up for the ROMS ocean model, an outer grid covering Cook Strait at a resolution of 2 km and a pair of alternative inner grids, one covering South Taranaki Bight and the other a smaller area on Patea Shoals, both at 1 km resolution with the option of refining them to 500 m if necessary. 19. The outer grid covering the Cook Strait is particularly important due to the dominant tidal movements across the strait which in turn has a significant influence on the tidal movement at the project site. The smaller inner grids provide more detailed input and output results at critical regions where the largest sediment movements and deposition are likely to occur. 20. One of the fundamental factors that affects the accuracy of a sediment plume model is the correct input of Particle Size Distribution (PSD) data spatially for the work site. The seabed is initially assumed to be populated with a combination of coarse sand (500–1000 μm, 20%), fine–medium sand (128–500 μm, 72%), very fine sand (63–128 μm, 6%), coarse silt (16–63 μm, 1.5%) and fine silt (4–16 μm, 0.5%). The proportions were initially based on seabed PSD data from the extraction area, and the fine sediment fractions (presumably silt size and below – it is not made clear in the reviewed reports) were then adjusted so that the model produced surface Suspended Sediment Concentrations (SSCs) of approximately the correct magnitude in the near-shore area. 21. TTR intends to mine iron sand to a sediment depth of 10 m. According to Reference 4 in Appendix A, two core samples; STH012RC and STH010RC, which contain information that relates the variation of PSD with sediment depth up to 15 m were supplied by TTR. The core sample STH012RC (close to Measurement Site 7) contains a high proportion of mud content ranging from 58% to 82% between sediment depths of 6m to 8m and from 7% to 27% of mud content between sediment depths of 9 m to 10 m. For the core sample STH010RC (close to Measurement Site 10), the mud content ranges from 2% to 4% from the seabed surface to 10 m sediment depth. From 10 m to 13 m, the mud content increases from 37% to 84%. From the results of these two samples, they indicate that there is a PSD variation with sediment depth. It is highly probable that sediment layers with high mud content at variable depths are likely to be found at the work site. Further information required 22. An accurate prediction in the sediment plume modelling normally requires a correct representation of the PSD inputs especially for the silt and clay components. A good representation or characterisation of the sediment over the relatively large working site in order to account for PSD spatial variations requires further bore samples to be taken from the mining areas and further information on how the variation in sediment layers is mitigated in the model. As it currently stands the report does not provide sufficient details for an accurate assessment of PSD effects. However, risks to the physical environment at the work site and surrounding area 7 are generally low as the seabed consists of mainly sandy material. The shortcomings of the sediment samples will not change the general assessment of the low environmental impact provided that TTR does not intend to carry out the mining operation when a mud layer is encountered. 23. The EPA provided SKM with 10 Statements of Evidence prepared on behalf of TTR, in response to a further information request and issues raised by the EPA, its independent reviewers and public submissions. The Statements of Evidence were specifically focussed on the physical environment, although some of the information presented was relevant to the assessment of the sediment plume modelling (Brown 2014; Orpin 2014; Hadfield 2014). Collectively, the information provided within these Statements of Evidence has been considered and incorporated into this review, where relevant. Assessment of validity of sediment plume model 24. In general the sediment plume model is done appropriately, however we have two areas of concern: a. Number of sediment samples taken to calibrate the model, and b. Grid size 25. The number of sediment core samples with detailed PSD (two) collected by TTR is not adequate enough to delineate the variable sediment layers or pockets over the many square kilometres of the working site and as such could significantly affect the modelling results. The annual 3 2 excavation of 50 million tonnes (27 million m ) roughly amounts to 3 km of excavation area per 2 annum. For 20 years of the operation, the total area involved is 65.76 km . To give a perspective 2 of the area involved, the area of Auckland central business district is about 4.3 km and that of Wellington is about half of that. The sediment PSD and spatial distribution in this large area certainly requires a number of field core samples to provide an accurate characterisation. More sediment core samples are required to delineate this issue. The number of core samples required depends on the spatial variability of PSD. Further information from Brown (2014) and Orpin (2014) has provided clarification on the PSD inputs to the model. While this additional information shows that the PSD inputs to the model are representative of the surficial sediment layers where a small number of cores were taken, further replication of cores would have been desirable to provide greater certainty in the level of variation. 26. It is unclear how the variation of sediment layers is accounted for in the sediment plume model. 27. The choice of grid size used in the model determines the accuracy of the results (Roberts, 2004). A smaller grid size means that more information or grid cells about the hydrodynamics (such as current velocity and direction) and sediment movements (e.g. transport or deposition) per unit 8 area are available. This is analogous to having more pixels (grid cells) in an image. The more pixels an image has the more definition the image has. 28. Over an area of interests such as at a dredging site and its surrounding area, grid sizes of ≤ 50 m x 50 m or 100 m x 100 m are normally used for a sediment simulation (e.g. APASA, 2012 and eCoast, 2013, respectively). The former project involved the dredging of pipeline trench crossing 3 the Narrows in Curtis lsland, Queensland. The dredged sediment volume was about 430,000 m . The later project involved the dredging of a harbour and the associated navigation channel and 3 spoil disposal in Vietnam. The dredged volume was about 4 million m .The choice depends on the model area covered, the computing resources available and the accuracy required. The minimum grid size of 500 m used by TTR appears to be too coarse to provide an accurate result of sediment deposition especially over the working site and its surrounding areas. These areas are likely to have the greatest variation of sediment deposition and environment impacts. A smaller inner grid, say, less than 50 m will provide a much better definition of sediment deposition over the area as opposed to the grid size used by TTR of 1km. 29. A smaller inner grid size of ≤ 50 m together with a better characterisation of the PSD spatial variations over the working site could be incorporated to better predict the intensity of sediment plumes in close proximity to the mining activity (within ~3 km) . Given the long duration of the model run, implications for the prediction of far-field sediment plumes are less of concern. The lack of sufficient input PSD data (derived from only a small number of sediment cores) is one the most significant limitations of the plume model. 30. The model should describe how the sediment layer data are integrated with the ROMS model. 31. The hydrodynamics part of the model appears to be accurate. This is reflected by the reasonably good agreement in both magnitude and phase in the tidal time series of the measured data and model results. The hydrodynamic forces are the drivers for sediment plumes. Evaluation 32. The lack of sample data coupled with the grid size used when carrying out this modelling makes it difficult to have confidence in the conclusions that have been drawn by TTR regarding the environmental effects of sediment re-distribution. After the first sediment plume review by SKM, TTR carried out further sensitivity analyses on the effect of grid size on the distribution of Suspended Sediment Concentration (SSC) and concluded that the 500 m grid size provides a better resolution of SSC distribution at the work site and its adjacent areas than those corresponding to the 1000 m grid. Further away from the work site, the two plumes are similar (Hatfield, 2014). SKM concurs with this as, normally a smaller grid size around the source is required to reduce the margin for error and increase confidence levels. 9 33. Inaccuracies in the plume model will affect the predictions that are made in relation to sediment deposition depth around the working site and spread over a wider area. In the near shore and surf zone areas, silt and clay particles are unlikely to settle due to the strong wave environment. The mining operation is unlikely to have any significant environmental effect on near shore and surf zone areas. 34. Despite the lack of adequate sediment representation and the grid size used, the environmental impact risks at the work site and its surrounding areas are low and TTR does not intend to mine the areas where mud contents are high. Based on this understanding we are of the opinion that any additional samplings or model refinement are unlikely to change the outcome of the assessment. References 1) Brown, M. 2014. Before the EPA Trans-Tasman Resources Ltd Ironsands Extraction Project. Statement of Evidence in Chief of Mr Matthew Brown on behalf of Trans-Tasman Resources Ltd. 27 pp. 2) Coastal Engineering Manual (CEM) 2006, USACE, Vicksburg. 3) Hadfield, M., 2014. Before the EPA Trans-Tasman Resources Ltd Ironsands Extraction Project. Statement of Evidence in Chief of Dr Mark Hadfield on behalf of Trans-Tasman Resources Ltd. 59 pp. 4) H. Roberts, 2004. Grid generation methods for high resolution finite element models used for hurricane storm surge prediction. Masters Thesis, Notre Dame University. 5) Narrows Crossing Dredge Plume Modelling, Hydrodynamic Modelling (Appendix E) 2012, Report prepared by APASA P/L for QGC Pte Ltd, Queensland. 6) Orpin, A.R., 2014. Before the EPA Trans-Tasman Resources Ltd Ironsands Extraction Project. Statement of Evidence in Chief of Dr Alan Orpin on behalf of Trans-Tasman Resources Ltd., 25 pp. 7) Vinh Tanh Power Plant Project – Dredge Plume Modelling, 2013. Report prepared by eCoast Pte Ltd for SKM. 8) Environmental Assessment Guideline for Marine Dredging Proposals, EAG7, EPA, Western Australia 10 Appendices Appendix A – Documents cited and reviewed 9) Coastal stability PHASE 2 report pp1-47.pdf 10) Coastal stability PHASE 2 report pp48-135.pdf 11) EEZ000004_Assessment_of_sediment_deposition_and_re_suspension_behaviour_of_tailings_ MTI_Holland_BV_July_2013_Appended.pdf 12) EEZ000004_Draft_Schedule_N_Part_2_Sediment_characterisation_analysis_particle_size_of_s amples.pdf 13) EEZ000004_Geological_Desktop_Summary_Active_Permit_areas_50753_(55581)_54068_and_ 54272_South_Taranaki_Bight_NIWA_August_2013.pdf 14) EEZ000004_Iron_sand_extraction_in_South_Taranaki_Bight_effects_on_trace_metal_contents_ of_sediment_and_seawater.pdf 15) EEZ000004_Multibeam_Survey_in_Southern_Taranaki_Bight_NIWA_April_2013_(including_bat hymetry_compilation).pdf 16) EEZ000004_Nearshore_Optical_Water_Quality_in_the_South_Taranaki_Bight_NIWA_May_201 3.pdf 17) EEZ000004_NIWA_sediment_plume_modelling_report.pdf 18) EEZ000004_Optical_Effects_of_an_iron_sand_mining_sediment_plume_NIWA_October_2013_ Appended.pdf 19) EEZ000004_Phase_1_Potential_effects_of_offshore_sand_extraction_on_physical_drivers_and _coastal_stability.pdf 20) EEZ000004_Potential_Effects_of_Trans_Tasman_Resources_Mining_Operations_on_Surfing_B reaks_in_the_Southern_Taranaki_Bight.pdf 21) EEZ000004_Satellite_ocean_colour_remote_sensing_of_the_South_Taranaki_Bight_from_2002 _to_2012_NIWA_October_2013.pdf 22) EEZ000004_Schedule_AG_Sediment_characterisation_Textural_comparison_of_grab_and_spe ar_samples_from_RC_cores_NIWA_May_2013.pdf 23) EEZ000004_Seascape_Natural_Character_and_Visual_Effects_Assessment_Graphic_Supplem ent.pdf 24) EEZ000004_Sidescan_Survey_of_South_Taranaki_Bight_Sediments_NIWA_April_2012 SECURE.pdf 25) EEZ000004_South_Taranaki_Bight_Baseline_Evironmental_Report_final_No_Appendices (not for noise).pdf 26) EEZ000004_South_Taranaki_Bight_Iron_Sand_Mining_Nearshore_Wave_Modelling_Phase_4_ Studies_NIWA_October_2013 SECURE.pdf 27) EEZ000004_South_Taranaki_Bight_Iron_Sand_Mining_Oceanographic_measurements_data report_NIWA_August_2012.pdf 11 28) EEZ000004_South_Taranaki_Bight_Iron_Sand_Mining_Project_Seascape_Natural_Character_a nd_Visual_Effects_Assessment.pdf 29) EEZ000004_Supporting_Information_for_Marine_Consent_Application_October 2013.pdf 30) Hadfield, M., 2014. Before the EPA Trans-Tasman Resources Ltd Ironsands Extraction Project. Statement of Evidence in Chief of Dr Mark Hadfield on behalf of Trans-Tasman Resourcs Ltd. 31) TTR_Wave_Modelling.pdf Appendix B - summary of the reports’ key findings by SKM previous review Name of report Purpose of report Key findings of review Trans-Tasman Overall impact assessment Some gaps arising from Resources Ltd South supporting the TTR application. uncertainties in the modelling, Taranaki Bight offshore distribution of a mud layer iron sand project: impact within sediments, and trace assessment (TTR 2013). metal concentrations in sea water. South Taranaki Bight Summarises environmental Generally appears to present factual baseline information from the South Taranaki best available information at environment report Bight to provide context for the TTR time of report preparation (MacDiarmid et al. 2011) proposal area. regarding physical environment. Multibeam survey in Presents results of a multibeam Routine technical data report. Southern Taranaki Bight bathymetry survey covering a Coverage of entire mine area number of areas relevant to the proposal. Sidescan survey of Presents the results of a sidescan Routine technical data report. South Taranaki Bight survey to identify the extent of Coverage of mine area not sediments bryozoans and sponges within an comprehensive. area being considered for disposal of dredge spoil. High resolution boomer Presents the results of a February Routine technical data report. survey in South Taranaki 2013 boomer survey to understand Survey does not cover the 12 Bight (Woelz and Wilcox the geometry of a sedimentary mine area. Refers to previous 2013) wedge in the South Taranaki Bight. survey that does cover mine area. Coastal stability in the Provides an assessment of the Comprehensive report South Taranaki Bight – effects of sand extraction on the presenting best available phase 2 potential effects landforms and geomorphic character information. of offshore sand of the shore, physical drivers (waves extraction on physical and currents) of coastal processes, drivers and coastal sediment processes and coastal stability stability. Schedule N, Part 2: Contains aspects of work on Results are only reported for Sediment sediment characterisation include: two cores. It is unclear how the characterisation analysis: - Analysis of samples from core horizons - Sampling methodology - Characterisation of particle sizefrequency distribution - Reporting related to sediment plume modelling. particle size of samples from cores (Orpin 2012) findings informed modelling. Schedule AG: Sediment Quantifies the potential loss of fines Report has significant characterisation – textual through handling and storage of implications for reliability of comparison of grab and muddy sediment in polyweave sacks. sediment plume modelling, to spear samples from RC the extent that PSDs assumed cores (Orpin 2013) in the modelling rely on spear samples that underestimate fines content. Geological desktop Provides a geological summary of summary the South Taranaki Bight area. South Taranaki Bight Presents a synthesis of the Methodology and data appear iron sand mining: oceanographic field measurements. to be best available oceanographic information. measurements data report Nearshore optical water Presents a synthesis of Methodology and data appear quality in the South measurements of background optical to be best available Taranaki Bight water quality and suspended information. sediment concentrations in the 13 nearshore region of the South Taranaki Bight. Satellite ocean-colour Presents results from earth- remote sensing of the observing ocean colour satellite South Taranaki Bight sensors to provide information on material naturally occurring in the water column. Seascape and natural Assessment of natural character, Unfinished draft report. Relies character and visual landscape/seascape and visual on long-term median model effects assessment amenity with regard to effects of the results without consideration of proposal. variability under differing environmental scenarios. Appears to make conclusions regarding potential ecological impacts related to natural character on superficial consideration of long-term median changes without reference to ecological sensitivities. Assessment of sediment Presents modelling on the near-field Uses appropriate model to deposition and re- behaviour of tailings arising from the assess near-field sediment suspension behaviour of proposal. deposition and predict source tailings (MTI Holland terms (fluxes of suspended 2013; note: 31 July 2013 and deposited sediment) for report reviewed, draft input into far-field modelling. version on website was not reviewed separately) South Taranaki Bight Presents estimations of the Further explanation and iron sand extraction concentration and deposition rates of justification for the PSD and sediment plume sediments released from the grid sizes applied to modelling modelling – phase 3 ironsand extraction operation. would increase confidence in studies (Hadfield 2013). model predictions. South Taranaki Bight Survey data (including site selection Provides new data on iron sand mining: and methodology) for 11-month shoreline dynamics that shoreline monitoring data beach monitoring programme. represents best available report information. 14 South Taranaki Bight Describes Phase 4 of numerical Detailed wave modelling using iron sand mining: modelling study to investigate the appropriate models and nearshore wave impacts of the proposal on wave resolution. Represents best modelling phase 4 conditions in the South Taranaki available information. studies (Gorman 2013). Bight. Potential effects of Assessment of the effects of the Valid assessment representing Trans-Tasman proposal on surfing breaks in the best available information. Resources mining Southern Taranaki Break. operations on surfing breaks in the Southern Taranaki Bight Iron sand extraction in Presents results of laboratory tests Appropriate methods. the South Taranaki with sediment from the mining areas Omission of mercury from Bight: effects on Christina and Diana. analyte list represents seawater trace metal potentially significant gap. concentrations (Vopel et Compares nickel elutriate al. 2013). concentrations to ANZECC/ ARMCANZ trigger value for 95% species protection whereas these guidelines recommend use of the 99% species protection value. Estimates that 160-fold dilution required for copper to meet 99% species protection value. Coastal stability in the Provides an assessment of the Comprehensive review Southern Taranaki Bight stability of the shoreline of the representing best available – Phase 1: historical and present day shoreline change South Taranaki Bight extending 130 information. km from about Opunake to Wanganui. Optical effects of an iron Considers the optical effects of Detailed experimental and sand mining sediment suspended sediment concentrations. modelling study representing plume in the South best available information Taranaki Bight region derived from model predictions of sediment plume. Model transects do not coincide with key sensitive receptor (North 15 and South Traps). Predictions based on long-term median suspended sediment concentration predictions, do not address variability.
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