Rasp Mine. Zinc Lead Silver Project Project Approval No January Community Lead Management Plan

Transcription

1 Rasp Mine Zinc Lead Silver Project Project Approval No January 2011 February 2012

2 This page has been left blank intentionally. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 2 of 32

3 Table of Contents 1. Introduction Purpose Scope Project Approval Conditions Referenced Documents Roles and Responsibilities BHOP Responsibilities General Manager Environment & Community Officer Managers Supervisors and Superintendents Employees External Responsibilities Child and Family Health (Broken Hill) Broken Hill Lead Reference Group Predicted Blood Lead Levels Introduction Receptors Major Exposure Pathways and Lead Sources Tolerable Daily Intake Bioaccessibilty of Lead Lead Predictions Rasp Mine Lead Dust Management Exposed Areas - Existing and Project-related Free Areas Unsealed roads Sealed roads ROM Stockpile Wind Erosion TSF Wind Erosion TSF Dust Management Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 3 of 32

4 4.7. Transfer to/from Crushed Ore Storage Bin Ventilation Exhaust Unloading Ore to ROM Stockpile Front End Loader Operation / Apron Feeder Hopper at the ROM Pad Crusher Circuit Concentrate Handling Work Clothes Construction Dust Management Dust Monitoring Human Health Risk Assessments Contingency Measures Free Areas Active Mining Areas BHOP Funding Contributions Consultation and Communication Consultation BHOP Consultative Group Broken Hill Lead Reference Group Communication Air Quality Monitoring Data Lead Blood Level Monitoring Data Reporting Incident Reporting Internal External Regular Reporting Weekly Head of Departments Meeting Responsibility Environment & Community Officer Rasp Mine Website (raspmine.com.au) Responsibility Environment & Community Officer Annual Return and Annual Environment Management Report Responsibility Environment & Community Officer Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 4 of 32

5 Annual DP&I Report Responsibility Environment & Community Officer Human Health Risk Assessments - Responsibility Environment & Community Officer Air Quality Complaints Management Auditing and Review Auditing Review Tables Table 1 - Summary list of selected receptors Table 2 - Predicted incremental blood Pb levels in children aged 0.5 to 7 years Table 3 - Rasp Mine ambient air quality and meteorological monitoring program Figures Figure 1 - Receptors Figure 2 - Major exposure pathways Figure 3 - Increase-Decrease in predicted annual lead deposition from original modeling combined with lead risk zones Figure 4 - Locations for ambient air quality and meteorological monitoring sites associated with the Rasp Mine Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 5 of 32

6 1. Introduction 1.1. Purpose The purpose of this Plan is to outline the management measures undertaken by the Rasp Mine to minimize the potential for blood lead contamination in the community and how these measures will be assessed, monitored and communicated to the community. The Plan outlines the arrangements for reasonable contributions towards the cost of public health monitoring, particularly in relation to child blood lead levels, and public education campaigns about the health risks associated with lead Scope This Plan applies to activities of the Rasp Mine within the City of Broken Hill Project Approval Conditions This (CLMP) has been developed in accordance with the Project Approval 07_0018 January 2011 and has been prepared in consultation with the Broken Hill Lead Reference Group, including the NSW Department of Health (Western Area Health Service) and the Broken Hill City Council. In accordance with the Project Approval, Schedule 3 Conditions 12 and 13, the CLMP addresses the following: Outlines BHOP contributions towards the cost of: - public health monitoring, particularly in relation to child blood lead levels, and tracking of this data over time; and - public education campaigns about the health risks associated with lead, including lead hygiene, lead and children, tank water lead risks and soil lead contamination risks Identifies additional reasonable and feasible measures that could be implemented by BHOP either on site or in the areas adjoining the site to minimise the potential lead impacts of the project and free areas Details a program for the staged implementation of the measures identified in (d) above in the event that dust emissions are higher than predicted or the public health monitoring suggests further action is required to reduce blood lead levels in the environment surrounding the site; and Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 6 of 32

7 Provides a detailed communication strategy, outlining how the relevant dust and blood level monitoring data would be reported on the BHOP website along with any relevant public education material. Schedule 3 Condition 14 outlines the requirements to update the updated Human Health Risk Assessment, within one year of the commencement of operation of the Project and every five years thereafter. This update shall: Be prepared by a suitably qualified expert whose appointment is endorsed by the Director General of the Department of Planning & Infrastructure Take into account monitoring data required to be collected under the Project Approval and other such information as may be relevant to the assessment; and Be submitted to the Director General (DoP&I), Office of Environment and Heritage and the Far West Local Health District within one month of its completion. Where relevant, requirements as outlined in Schedule 4 of the Project Approval have also been addressed in this CLMP Referenced Documents Rasp Mine Project Approval 07_0018, January 2011 Revised Statement of Commitments, BHOP, January 2011 Preferred Project Report, BHOP, September 2010 Environmental Assessment Report, BHOP, July 2010 Rasp Mine Health Risk Assessment Report, Toxikos Pty Ltd, 2010 Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 7 of 32

8 2. Roles and Responsibilities 2.1. BHOP Responsibilities General Manager Provide resources to support the implementation of this Plan Environment & Community Officer Maintain and update this Plan. Provide information to Weekly Head of Department Meetings. Communicate the Plan to Rasp Mine personnel. Attend Broken Hill Lead Reference Group meetings. Arrange and attend BHOP Consultative Group meetings. Maintain information on the Rasp Mine web site. Arrange budgets for reasonable cost contributions. Audit BHOP performance against this Plan. Provide reports as required under this Plan Managers Implement air quality control measures in their areas of responsibility including those designed to prevent / minimise lead dust exposure to the community Supervisors and Superintendents Implement air quality control measures in their areas of responsibility including those designed to prevent / minimise lead dust exposure to the community Employees Implement air quality control measures in their work areas including those designed to prevent / minimise lead dust exposure to the community External Responsibilities Child and Family Health (Broken Hill) Direct BHOP financial contributions to expenditures consistent with the BHOP Project Approval 07_0018 January 2011 conditions. Provide details on funded items to BHOP for auditing purposes. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 8 of 32

9 Broken Hill Lead Reference Group Review and provide feedback to BHOP on this Plan. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 9 of 32

10 3. Predicted Blood Lead Levels 3.1. Introduction Broken Hill Operations Pty Ltd engaged Toxikos Pty Ltd (Toxikos) to undertake a Human Health Risk Assessment (HHRA) of its proposed activities for the recommencement of mining on Consolidated Mine Lease 7, the Rasp Mine. This report was presented as Annexures I(A) and I(B) of the Rasp Mine Environmental Assessment Report July The following provides a summary of baseline information and the predictions for potential impacts from the operation of the Rasp Mine Receptors Receptors were selected and used during the HHRA to assist in identifying and assessing the risks to health by the community. A location map with all receptors is provided in Figure 1. In the HHRA, for ease of report reading and presentation, selected receptors were presented in summary tables in the text. These receptors were selected after consideration of: proximity to mine activity, the historical lead health risk zones in Broken Hill town (Boreland et al. 2002, 2009a; Lyle et al. 2006) (Section 2.2) used by the Greater Western Area Health Services to organise and interpret lead biomonitoring data (Boreland 2010, Lesjak 2010), and predicted dust deposition (low, medium, high) from the mine lease site (as predicted by Environ Pty Ltd who conducted a detailed analysis of dust lift off from the mine lease site and that associated with the mine processes (Environ 2010a) with air dispersion modelling techniques used to predict the fate of the dust over nearby areas. ) The summary list of receptors is provided in Table 1. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 10 of 32

11 Broken Hill Operations Pty Ltd Rasp Mine Figure 1 - Receptors Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 11 of 32

12 Table 1 - Summary list of selected receptors Selected Receptor Residences 1. Piper Street North 2. Piper Street Central 3. Eyre Street North 4. Eyre Street Central 5. Eyre Street South 8. Old South Road 9. South Road (2) 10. Garnet & Blende Streets 23. Eyre Street North (3) 32. Crystal Street (2) 36. Crystal Street (5) 38. Gypsum Street (1) Other Locations 11. Alma Bugdlie Pre-School 12. Playtime Pre-School 14. Broken Hill High School 17. Broken Hill Public School 18. Rainbow Pre School 3.3. Major Exposure Pathways and Lead Sources The HHRA reviewed the history of elevated blood lead levels in Broken Hill, particularly those of children, and the major exposure pathways for lead bearing dust to enter the body; ingestion, inhalation and dermal contact, Figure 2. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 12 of 32

13 Figure 2 - Major exposure pathways PM 10 Pb infiltration into home PM 10 Pb Pb deposition from TSP onto soil TSP Pb Wind lift of dust from lease areas unaffected by mine activity (free areas) Direct exposure to Pb in soil Soil & dust tracked indoors roads ROM process Incremental exposures to lead at discrete residences Dust sources due to proposed mine activity The study concluded that for young children the highest risk group, the 95 to 98% of lead intake came about from ingestion of soil, primarily from hand to mouth activity. Dust deposition occurs from mine derived total suspended particulates (TSP) that are transported by wind. The sources contributing to the TSP can be divided into those related to the mine process (5%) (sealed and unsealed active roads, ore handling, the ore stockpile, crushing, ventilation shafts etc) and those that are non-process related (95%) (areas of the mine lease surface not involved with the day to day operation of the mine, the so called free areas ). It was found that the majority of dust came from areas of the lease where no mining activities would be undertaken - the expansive open areas of the lease that are vulnerable to wind take up. Following testing of this material it was also found that the lead from this dust has about five times greater ability to be absorbed into the human body. This was due to the long term weathering of this material giving it a greater ability to break down. It was also noted that there were a number of other sources of lead dust and potential exposure to lead in the community including: Lead based paint, particularly when house renovations were being undertaken; Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 13 of 32

14 Natural lead contained in local soils, being close to the ore body soils surrounding the Line Of Lode have elevated lead content; and Historic mining activities, particularly smelting at the turn of the last century that would have deposited particulate matter throughout the Broken Hill area Tolerable Daily Intake The World Health Organisation has determined a level at which the human body can absorb lead as 3.6 µg/kg/d. According to the Toxikos assessment the community group most likely to take up lead are toddlers (6 months to 3 years) via ingestion. The worst case prediction by Toxikos for the average intake of lead is 2.1 µg/kg/d which is 60% of the tolerable daily intake. Of this 96 percent is from existing background sources (ie diet, water, existing residential soil and current airborne dust) and 4 percent is from the proposed mining activities. The exposure to thirteen other metals was also assessed by Toxikos who concluded that the proposed mining activities were unlikely to materially change current background exposures to these metals. The combined hazard index for these metals was only 0.05, considered negligible against a target index of Bioaccessibilty of Lead The HHRA used the physiologically based extraction test (PBET) for determining the bioaccessibility of metals from surface soil at the mine site and from mine ore. This involved simulating the leaching of a solid matrix in the human stomach and small intestine under feed and fasting conditions. This test was conducted by entox at Queensland University who have experience in using this model. Testing was conducted for soils form both road surfaces and open areas of the mine site and from mine ore. The results indicated that the average bioaccessibility of lead from surface dusts was 7.3% and that from mine ore was 1.4%. The higher result for surface dusts was consistent with expectations. Weathering of lead sulphide results in the formation of sulphate and since this substance is more soluble than lead sulphide it would be expected that the bioaccessibility and bioavailability of weathered lead from existing surface dust would be greater than that of the fresh ore Lead Predictions The National Health and Medical Research Council of Australia determined in 2005 that all Australians should have a blood lead level of less than 10 µg/dl and that follow up action is recommended where this is exceeded. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 14 of 32

15 Toxikos used US EPA modelling to predict blood lead levels in children due to accumulation of lead in soil over 15 years of the proposed life of the Rasp Mine and exposure to mine emissions, and / or assumed background concentrations of lead in soil. This model particularly applies to children and it caters for lead exposure via ingestion of soil and indoor dust, diet, water and inhalation of airborne outdoor dust together with indoor dust. Receptor 8 was found by Toxikos ot be the most affected with a predicted incremental increase in blood lead level of 0.75 µg/dl, and Receptor 3 (the second most affected receptor) the increase is 0.31 µg/dl. Table 2 - Predicted incremental blood Pb levels in children aged 0.5 to 7 years Child Age Receptor R R R R R R R R R R R R R R R R In September 2010 BHOP determined to relocate the processing plant and rail siding to the north east end of the Lease and engaged ENVIRON to update the air assessment. With the relocation of the processing plant predicted lead concentrations and deposition rates at the most affected receptor under revised modelling are lower than those Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 15 of 32

16 predicted at the most affected receptor within the original air assessment in the EA (refer Air Quality Assessment Addendum - Proposed Relocation of the Processing Area, ENVIRON, September 2010). ENVIRON found that the Maximum predicted lead concentrations and deposition rates at the most affected receptor were now summarised as: Maximum incremental lead concentrations of 0.064µg/m 3 at R8 under previous modelling compared to 0.036µg/m 3 at R27 for Scenario 2 modelling (representing a reduction of approximately over 40%); and Lead deposition rates of 0.45g/m 2 /annum at R8 under previous modelling compared to 0.15g/m 2 /annum at R27 for Scenario 2 modelling (representing a reduction of over 65%). Further, ENVIRON concluded that it is likely that receptors experiencing maximum Project-related incremental lead impacts will be located in the zones with less risk. According to the HHRA, Boreland et al. (2009) defined five risk zones in describing hazards posed for soil lead concentrations based on the 1992 soil lead concentration measurements documented in Lyle et al. (2006). Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 16 of 32

17 Figure 3 - Increase-Decrease in predicted annual lead deposition from original modeling combined with lead risk zones Figure 1 shows that the relocation of the processing area is anticipated to deliver a decrease in lead deposition increments both within areas of higher population density and the higher soil lead Risk Zones (e.g. Risk Zones 1-2) relative to the air assessment scenario. In view of the above, ENVIRON concluded that the conclusions made within the HHRA remain valid. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 17 of 32

18 4. Rasp Mine Lead Dust Management A number of dust control measures have been identified in the EAR and summarised in the BHOP Revised Statement of Commitments, January The objective of these measures is to minimise dust and lead bearing dust generation from BHOP activities and from general wind take up of dust across the surface areas of CML7 for which BHOP has responsibility. The requirements for dust monitoring are also included in these commitments, the Project Approval (07_0018) and BHOP s Environment Protection Licence An Air Quality Management Plan will be implemented by BHOP outlining the responsibilities and actions for managing and monitoring dust at the Rasp Mine and an Occupational Lead Management Plan which addresses specific issues dealing with personal hygiene of employees, blood lead sampling and action guidelines. A program for the regular maintenance of pollution control equipment to ensure that it is functioning at optimal performance levels will be developed. The following summarises the main dust control measures Exposed Areas - Existing and Project-related Free Areas Exposed areas have the potential for dust generation by wind take-up. These areas compose the free areas where there will be no land disturbance from the mine activities and operational areas associated with the mining activities. A dust control strategy for all exposed areas of BHOP s CML7 surface areas has been developed and outlines the following strategies for the control of dust generated from these exposed areas: Application of chemical dust suppressant; Restriction of vehicle or work access to the free areas ; Restriction of surface disturbances within the free areas ; Trafficable areas will be clearly demarcated by guide posts and signs; Vehicles will be prohibited from driving off of trafficable areas without a job related purpose; Identification and remediation of areas where fines or silt has built up (typically after heavy rain storms); and Remediation of any stabilised exposed area disturbed due to works carried out on site. Stabilisation refers to the treatment of areas with chemical dust suppressants, to be applied according to the manufacturer s specifications, with the purposed of achieving a control efficiency of at least 80%. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 18 of 32

19 Remediation will include, but not be limited to, removal and burial of fine material, capping with inert waste rock, or additional use of chemical dust suppressants Unsealed roads For safety reasons, an 800m section of unpaved haul road will be located from the base to the top of the Kintore Pit. Secondary service roads that receive minimal traffic will also be unsealed. The following strategies apply specifically to unsealed roads: Chemical dust suppressant will be applied to achieve a minimum dust control efficiency of 80% to all unsealed roads on the site including the unsealed portion of the haul road; A grate is to be installed between the unsealed and sealed sections of the haul road to minimise dust track-on from trucks; Whereas chemical dust suppression by water cart represents the standard unpaved road dust control measure, static water sprays are already installed on the unsealed haul road and a portion of the service roads. These sprays will be maintained; Provision will be made, and responsibility assigned, for timely clean up of temporary sources of dust on chemically stabilised roads; and Speed restriction on unpaved haul roads is to be a maximum of 40 km/hour Sealed roads Consistent with the requirements of Condition 6 of Schedule 3 of the Rasp Mine Development Consent MP 07_0018, 4.5km of roads under BHOP operational control will be sealed prior to the commencement of ore extraction. In addition the following strategies apply specifically to sealed roads: All sealed areas intended to carry vehicular traffic are to be kept clean; Periodic use of a PM 10 -certified street sweeper to clean sealed roads to reduce dust below a maximum silt loading; Minimum frequency of street sweeper use to be determined through road silt load testing during the operation phase; Regular inspections are to be made to ensure that dust suppression activities are sufficient to control dust generated from roads; Level of loads of haul trucks will be inspected to avoid spillage of material onto roadways; All vehicles entering beyond the boom gate will be required to be cleaned before they exit onto public roads using the site s dedicated wheel wash; Storm water drainage will be designed and maintained to prevent water erosion onto paved roads; and Spillages and other temporary sources of dust on the sealed roads will be cleaned up in a timely manner, and traffic rerouted around spills until they are removed. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 19 of 32

20 4.4. ROM Stockpile Wind Erosion The ROM stockpile has the potential for dust generation from wind take up. Provision has been made within the Project design for the following engineering controls: Static wind breaks will be used to deflect wind to reduce dust entrainment. Water sprays will be mounted on the ROM stockpile wind breaks and directed at stockpiles and haul truck dumping areas. Wind break heights are to be a minimum of 2m above the maximum height of the ROM pile, and are to be positioned on either side of the ROM pad. Wind breaks are to be arranged in a series of rows orientated east-west, being perpendicular to the prevailing wind direction. Chemical dust suppressant to be used around traffic areas (FEL, haul trucks). Ore is to be dumped and recovered from piles located between the linear wind breaks. Access is provided at either end for ROM placement / reclamation respectively TSF Wind Erosion The source of dust from the tailings facilities will primarily be wind blown dust. A dust control strategy for the Tailings Storage Facility (TSF) been developed, Procedure Tailings Storage Facility Dust Management covering both construction and operational activities TSF Dust Management There are two tailings storage facilities proposed for the Rasp Mine, TSF1 an additional lift to a current storage facility located in the centre and to the south east of CML7 near Eyre Street, and TSF2 deposition of tailings into the disused Blackwood Pit located to the north east of TSF1. An extensive management plan to minimise dust generation has been prepared for TSF1 and is included in the Air Quality Management Plan and associated procedures. BHOP currently plans to deposit tailings into TSF2 or Blackwoods Pit and review the requirement for tailings to be deposited in TSF1. The dust control measures proposed for TSF1 will apply to TSF2 towards the end of the life of the facility when the level of tailings is closer to surface level. At this time the video equipment (as required under Project Approval conditions), the construction methods, the dust mitigation and contingency measures will be implemented. It is not anticipated that this level will be reached for approximately 5 to 8 years. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 20 of 32

21 4.7. Transfer to/from Crushed Ore Storage Bin Material handling of crushed material is potentially a major source of dust in the processing area. Provision has been made within the Project design for the following engineering controls: All above ground conveyors and transfer points prior to the grinding circuit (SAG and ball mills) are to be enclosed, (Project Approval, Schedule 3 Condition 9 ). Conveyors will be fitted with dust extraction reporting to insertable dust collectors. The crushed ore bin will be fitted with in insertable dust collector to filter the air discharged during filling. This will comprise of a series of fabric filter bags cleaned by reverse air jet Ventilation Exhaust Post-commissioning stack testing shall be conducted at the ventilation shaft to establish compliance with the criteria set out in the Project Approval. Details are described in Section 4.6 of the Rasp Mine Air Quality Monitoring Program If post-commissioning stack testing does not easily satisfy the above criteria (i.e. if the ventilation shaft is not a wet shaft, as is expected) water sprays will be installed and used during blasts to maximise suppression of dust in the underground mine Unloading Ore to ROM Stockpile The working areas around the ROM stockpile have the potential to generate dust from vehicle movements, depositing ore and wind take-up. A dust control strategy for the ROM stockpile area has been developed and includes the following dust control strategies specific to unloading ore to the ROM stockpile: ROM stockpile wind break-mounted water sprays will be automatically activated as haul trucks enter the ROM stockpile wind breaks for ore dumping; If the operator is satisfied that the ore being dumped has sufficient moisture to prevent dust emissions, the automatic sprays can be overridden to prevent the ore becoming too wet; Inspection of the ROM stockpile wind break-mounted water sprays shall be conducted as a minimum once per shift to ensure effective operation; Operators are to visually monitor dust caused by dumping and take appropriate actions to control the level of dust (addition of a dedicated watercart / varying or ceasing operations). Operators are to visually monitor dust from the ROM stockpile and additional water will be applied to the stockpile to avoid wind erosion. Chemical dust suppressant is to be applied as per manufacturer s specifications to all trafficked areas (FEL and dump trucks) within the ROM stockpile area. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 21 of 32

22 4.10. Front End Loader Operation / Apron Feeder Hopper at the ROM Pad There is potential for dust to be generated from the dumping of ore onto the apron feeder and into the crusher. Ring nozzle water sprays (atomised sprays) will be installed on the apron feeder hopper to the crushing circuit and negative pressure will take this airflow to the crushing circuit bag-house. Additionally, provision is made for operational dust control measures, including: Inspection of the ring nozzle water sprays shall be conducted as a minimum once per shift to ensure effective operation, and Loading to the apron feeder is not to be undertaken during adverse weather conditions (high winds) Crusher Circuit Material handling of crushed material is potentially a major source of dust in the processing area. Provision has been made within the Project design for the following engineering controls: The crusher circuit (jaw (primary) crusher) is to be fully enclosed within a permanent structure. The enclosed structure over the ROM bin is to extend five meters out, over the front end load feed area. This extension sits flush onto the steel wing walls and is designed to prevent particulate wind entrainment around the top of the ROM bin. This crusher circuit enclosure will be kept under negative pressure (approximate airflow into the bag house of 9,700 L/s) and vented via an appropriately sized baghouse with a high (>99%) control efficiency. Four dust extraction points report to the bag house - two points in the roof of the crusher circuit enclosure, and two over the conveyor; Consistent with Condition 7 of Schedule 3 of the Rasp Mine Development Consent MP 07_0018, the enclosure and associated emissions controls will be operated and maintained to ensure that visible fugitive emissions from the enclosure are minimised. In the event that sustained (>5 minutes) visible dust is observed to be emitted from the crusher circuit enclosure, crushing will be ceased, and the cause established and rectified prior to crushing activities recommencing. The integrity of the crusher circuit bag house will be monitored through pressure drop alarms to indicate bag breakthrough, and via the point source monitoring detailed within the Air Quality Monitoring Program. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 22 of 32

23 4.12. Concentrate Handling Provision has been made within the Project design for the following measures to control dust from the concentrate loading area: Concentrate loading will take place in an enclosed building (solid roof and side walls) with rubber curtains at the points of entry and exit points for the concentrate container trucks; Once the concentrate container has reached capacity a lid will automatically be placed on the container to maintain moisture content of the product (anticipated to be 9%) and eliminate any dust emissions during transport to the rail load out, and subsequently to port; and A concentrate container wash facility will be installed to remove and collect any potential spillage from the concentrate container trucks. Material collected will be returned to the process Work Clothes On-site laundering facilities are provided to negate the need for work clothes to be taken off site for washing. Employees and contractors are required to change clothes prior to leaving site if they have been working on the mine site (past the boom gate) Construction Dust Management In addition to the application of the above dust control strategies BHOP has committed to use the following dust management measures during the construction phase: Excavation area to be hosed down prior to removal of material via a dedicated water cart and/or water sprays; Water sprays installed along the temporary waste rock transport route; Water sprays utilised during the placement of rockfill layers during construction of the TSF embankment after spreading and again during compaction; and Sprinkler systems will be used to aid dust suppression on material stockpiles. These basic requirements will be written into the contracts of contractors, where applicable, and provided during the site induction of all construction contractors Dust Monitoring The Air Quality Monitoring Program was developed by ENVIRON and documents the statutory conditions, standards, locations and reporting requirements for air quality monitoring undertaken by BHOP across its mining operations and neighbouring properties. It also addresses the requirements as outlined in the Approval Conditions and Commitments by BHOP including: Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 23 of 32

24 Installation of real-time air quality monitoring to assist in the active management of emissions; Undertaking sampling to quantify road surface silt loadings on an ongoing basis; and Continuation and expansion of the existing air quality management program to include high volume samplers, dust deposition jars and real time monitors; Data gathered through air quality monitoring demonstrates the effectiveness of the Air Quality Monitoring Plan and evaluates performance against continual improvement objectives. Table 3 summarises the locations and parameters for air quality monitoring. Table 3 - Rasp Mine ambient air quality and meteorological monitoring program Site No. Parameters Monitored Units of Measure Averaging period Sampling Frequency DDG1 Insoluble solids, Pb g/m²/month monthly, annual monthly DDG2 insoluble solids, Pb g/m²/month monthly, annual monthly DDG3 insoluble solids, Pb g/m²/month monthly, annual monthly DDG4 insoluble solids, Pb g/m²/month monthly, annual monthly DDG5 insoluble solids, Pb g/m²/month monthly, annual monthly DDG6 insoluble solids, Pb g/m²/month monthly, annual monthly DDG7 insoluble solids, Pb g/m²/month monthly, annual monthly TSP-HVAS TSP, Pb µg/m³ annual 24 hours, every 6 days PM10-HVAS1 PM 10, Pb µg/m³ 24 hour, annual 24 hours, every 6 days PM10-HVAS2 PM 10, Pb µg/m³ 24 hour, annual 24 hours, every 6 days TEOM1 PM 10, Wind Speed / Direction TEOM2 PM 10, Wind Speed / Direction µg/m³ µg/m³ 24 hour, annual 24 hours, continuous 24 hour, annual 24 hours, continuous AWS Meteorological Parameters Temperature (2m and 10m), wind speed / direction, rainfall, sigma theta, solar radiation 15-minute Continuous Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 24 of 32

25 Figure 4 - Locations for ambient air quality and meteorological monitoring sites associated with the Rasp Mine DDG Human Health Risk Assessments Within one year of the commencement of operation of the Project, and every five years thereafter, in line with the Project Approval conditions, BHOP shall update the human health risk assessment prepared for the project and presented in the EA. The updated assessments shall: Be prepared by a suitably-qualified expert whose appointment has been endorsed by the Director-General; Take into account monitoring data collected under this approval, and such other information as may be relevant to the assessment; and Be submitted to the Director-General DoP&I, the OEH and the Western Area Health Service within one month of completion. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 25 of 32

26 BHOP will also provide a presentation to the Broken Hill Lead Reference Group regarding the findings of these reviews Contingency Measures As outlined above BHOP has instigated an extensive range of measures to prevent and minimise the generation of lead bearing dust from the Rasp Mine. The following contingency measures have been identified: Free Areas As highlighted in the HHRA the majority of lead bearing dust (95%) leaving the site is from the free areas. It is currently proposed to use chemical dust suppressants to minimise dust from these areas. Where dust monitoring results indicate that dust levels have increased a review of the chemical dust suppressant program will be instigated to investigate if methods of application and / or concentrate are effective. The results of this investigation may: Increase the area for application of the chemical suppressant. Increase the concentration of the chemical suppressant. Investigate other newly available chemical suppressants that are more effective. Provide capping over sections of the free areas with inert waste rock Active Mining Areas As highlighted in the HHRA the active mining areas accounts for 5% of lead bearing dust from the site. BHOP have proposed an extensive range of dust mitigation measures as outlined above, where dust monitoring results indicate that dust levels have increased the following measures may be implemented: Sealing of secondary roads. Ceasing of dust generation activities with specific wind conditions, for example from a particular direction and / or at particular wind speeds. Installing a dust tracking system to better identify dsut generating sources. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 26 of 32

27 5. BHOP Funding Contributions BHOP shall make reasonable contributions to the Broken Hill Child & Family Health Centre annually for the purposes of: Public health monitoring, particularly in relation to child blood lead levels; and tracking this data over time; and Public education campaigns about the health risks associated with lead, including lead hygiene, lead and children, tank water lead risks and soil lead contamination risks. The Broken Hill Child & Family Health Centre shall submit items for financing consideration to BHOP by the end of August each year. Items will be in line with above criteria and consistent with the Broken Hill Lead Health Program. BHOP will review items against the criteria listed above and identify items for financial support. BHOP will incorporate funding support in annual budgets and provide funding to the Broken Hill Child & Family Health Centre by end of November each year. BHOP funding will be up to $50,000 in any calendar year. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 27 of 32

28 6. Consultation and Communication 6.1. Consultation BHOP Consultative Group BHOP will provide a copy of this Plan and seek feedback from the BHOP Consultative Group, where the Group is available Broken Hill Lead Reference Group BHOP will provide a copy of this Plan and seek feedback from the Broken Hill Lead Reference Group. Comments shall also be sought for any proposed changes to the Plan Communication Air Quality Monitoring Data BHOP provides summary information regarding its air quality monitoring on its web site. This includes summary data and a review of the data against relevant criteria. In addition BHOP provides raw air quality monitoring data to the Far West Local Health District Lead Blood Level Monitoring Data BHOP will provide a link from its web site to the Far West Local Health District information web site which will provide information on lead blood level monitoring data and will also contain relevant information on public education material. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 28 of 32

29 7. Reporting 7.1. Incident Reporting Internal Air quality internal incidents are defined as a deviation of visible dust generation from normal operations. All air quality incidents shall be recorded and reported on the BHOP system for incident reporting. The supervisor of the area where the incident occurred is responsible for investigating and reporting the incident External For external reporting purposes an incident is defined (Project Approval) as: A set of circumstances that causes or threatens to cause material harm to the environment, and/or breaches or exceeds the limits or performance measures/criteria in this Approval. In terms of air quality reports required, an incident is defined as any exceedence of the air quality criteria summarised in Table 2, Table 3, Table 4, Table 5 and Table 6 of the Air Quality Monitoring Program. BHOP is required to report incidents to the DoP&I and any other relevant agencies (refer Project Approval Schedule 4 Condition 5) this may include: Office of Environment and Heritage Department of Primary Industries Land Property and Information, NSW Broken Hill City Council Notification shall be made as soon as practicable after BHOP becomes aware of the incident and a written detailed report shall be provided within seven days of the date of the incident. The Environment & Community Officer will be responsible for preparing reports to the relevant government agencies which will be signed off by the Operations Manager prior to submission. In terms of air quality reports required, an incident is defined as any exceedence of the air quality criteria are summarised in Table 2, Table 3, Table 4, Table 5 and Table 6 of the Air Quality Monitoring Program. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 29 of 32

30 Notification is to include all contextual information relevant to the incident, such as prevailing meteorological conditions, extraordinary events (e.g. bushfires, prescribed burning, dust storms, fire incidents, illegal activities), as well as site activities and preventative action undertaken (if applicable) during the incident. Incident reporting should additionally contain information on diurnal trends and pollution roses (a graphical representation of wind direction plotted against concurrent particulate concentration, similar to a wind rose), as applicable Regular Reporting The following regular reports will be submitted: Weekly Head of Departments Meeting Responsibility Environment & Community Officer Summary of incidents, including cause and actions taken (or to be taken) to prevent a recurrence. Summary of monitoring results, where available Rasp Mine Website (raspmine.com.au) Responsibility Environment & Community Officer Summary of air quality monitoring results, updated quarterly. Summary of community complaints, updated monthly. Updates of the Human Health Risk Assessments. A current approved copy of the CLMP. A link to the Far West Local Health District information regarding blood lead levels and public health Annual Return and Annual Environment Management Report Responsibility Environment & Community Officer An Annual Return outlining monitoring results, non-compliances (in regards to the Environment Protection Licence 12994) and community complaints shall be prepared on the appropriate form and submitted to the OEH as required each year. The Annual Environmental Management Report (AEMR) will be provided to government agencies for consultation and submitted to Department of Primary Industries each year Annual DP&I Report Responsibility Environment & Community Officer Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 30 of 32

31 In accordance with Project Approval (Schedule 4 Condition 3) an environment performance review shall be conducted annually and provided to the DoP&I. These review reports shall commence at the end of June 2012 and annually thereafter. This review will: (a) (b) (c) include a comprehensive review of the monitoring results and complaints records of the project over the past year, which includes a comparison of these results against the: relevant statutory requirements, limits or performance measures/criteria; monitoring results of previous years; and relevant predictions in the documents EAR, PPR and their respective response to submissions and BHOP Revised Statement of Commitments (January 2011); identify any non-compliance over the past year, and describe what actions were (or are being) taken to achieve compliance; and identify any trends in the monitoring data over the life of the project. The AEMR will be submitted to the Director General DP&I to meet this condition Human Health Risk Assessments - Responsibility Environment & Community Officer In line with the Project Approval copies of the updates for the Human Health Risk Assessment shall be provided within one month of completion to: Director General DoP&I; Office of Environment and Heritage; Far West Local health District; In addition BHOP will provide copies to the BHCC, the Broken Hill Lead Reference Group and post a copy of the report on the BHOP web site Air Quality Complaints Management Any air quality related complaints will be recorded in the complaints register and fully investigated to find root causes and corrective actions implemented where necessary. Additionally the following measures will be undertaken during complaint and incident investigation: Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 31 of 32

32 Instigation of complaints-driven ambient air quality monitoring, as required (refer Rasp Mine Air Quality Monitoring Program); and Review of relevant management practices / operational procedures will be undertaken to systematically identify and implement options to modify site practices, to ensure effective control of dust-generating activities so as to achieve the air quality objectives stated in this plan. All complaints will be documented according the procedure for complaints handling. The following additional information shall also be recorded: Date; Specific Time; Prevailing Meteorology (wind speed / direction); Location of incident; Frequency of emission; and Duration of emission. 8. Auditing and Review 8.1. Auditing BHOP will undertake an annual audit of this Plan to identify any non-compliances with performance and identify remedial actions as required. Non-compliances and remedial actions will be incorporated into the Annual Environment Management Report. The Environment & Community Officer is responsible for completion of this audit Review The CLMP shall be reviewed, and if necessary revised, every three years. In this review the following shall be consulted: BHOP Consultative Group Broken Hill Lead Reference Group The amended document shall then be submitted to the DoP&I for approval. Approved By: Operations Manager Issue Date: February 2012 Revision No: 1 Revision Date: February 2015 Page 32 of 32