Cristal Mining Australia Ltd. Murray Basin Mines Water, Erosion and Sediment Control Plan. 6 November 2014

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Transcription:

00 Cristal Mining Australia Ltd Murray Basin Mines Water, Erosion and Sediment Control Plan 6 November 2014

Revision History Rev No. Document No. Description Approval Details Date A 603264 Revised draft plan for Cristal August 2014 0 603264 Final Cristal and GHD October 2014 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 i

Abbreviations Abbreviation AEMR AR Cristal BHCC CE CEMP DA DECC DECCW DOP DNR DPI EIS EMS Full Title Annual Environmental Management Report Annual Return (as required by the EPL) Cristal Murray Basin / Cristal Mining Australia Broken Hill City Council Country Energy Construction Environmental Management Plan Development Application NSW Department of Environment and Climate Change (formerly DECCW) NSW Department of Environment, Climate Change and Water (now DECC as part of the OEH) NSW Department of Planning and Infrastructure Department of Natural Resources (responsibility now split between OEH and NOW) NSW Department of Primary Industries (part of NSW T&I) Environmental Impact Statement Cristal Murray Basin Environmental Management Strategy EPA NSW Environment Protection Authority (part of the OEH) EP & A Act Environmental Planning and Assessment Act 1979 EPL GHD HAR HMC Environmental Protection Licence GHD Pty Ltd Highway Acess Road Heavy Mineral Concentrate LPMA NSW Lands Property Management Authority (abolished April 2011) MOP Mining Operations Plan MSP NMP NOW NPWS NSW NSW T&I OEH Mineral Separation Plant (Broken Hill) Noise Management Plan New South Wales Office of Water National Parks and Wildlife Service New South Wales NSW Department of Trade and Investment, Regional Infrastructure and Services (formerly Industry and Investment NSW) NSW Office of Environment and Heritage OEMP Operational Environment Management Plan POEO Act 1997 Protection of the Environment Operations Act 1997 RTA NSW Road Transport Authority WHIMS WSC Wet High Intensity Magnetic Separator Wentworth Shire Council ii GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

Limitations This report: has been prepared by GHD Pty Ltd (GHD) for Cristal Mining Australia Ltd (Cristal) and may only be used and relied on by Cristal for the purpose agreed between GHD and Cristal as provided section 1.1 and 1.2 of this report. GHD otherwise disclaims responsibility to any person other than Cristal arising in connection with this report. GHD also excludes implied warranties and conditions, to the extent legally permissible. The services undertaken by GHD in connection with preparing this report were limited to those specifically detailed in the report and are subject to the scope limitations provided in the report. GHD s scope of works was limited to updating Cristal s environmental documentation into standardised templates that are consistent with ISO 14001 and addresses Cristal s most recent approval requirements. GHD has relied on information provided in existing plans, the specific requirements stated within licences, permits and approval conditions provided to GHD and advice provided by Cristal on the status of works and implementation of management measures for the pre-construction and construction phase works. GHD has updated documents based on advice from Cristal relating to their current operations and management practices. As Cristal s existing documentation has previously been approved by government agencies, GHD has not proposed new mitigation or management measures. Where GHD has identified deficiencies or anomalies in the existing plans, these have been updated based on additional information provided by Cristal. It is not within GHD s scope of works to undertake a detailed risk assessment for environmental aspects or to provide specialist advice on the suitability of mitigation measures or to devise new mitigation measures. The opinions, conclusions and any recommendations in this report are based on conditions encountered and information reviewed at the date of preparation of the report. GHD has no responsibility or obligation to update this report to account for events or changes occurring subsequent to the date that the report was prepared. GHD has prepared this report on the basis of information provided by Cristal which GHD has not independently verified or checked beyond the agreed scope of work. GHD does not accept liability in connection with such unverified information, including errors and omissions in the report which were caused by errors or omissions in that information. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 iii

Development consent(s) & project approval modification On 20 October 2014, the Secretary for the Minister for Planning issued Cristal with the following Notice of Modification(s) for Cristal s operations in the Murray Darling Basin: Ginkgo Mineral Sands Project (DA 251-09-01), Modification 10 Snapper Mineral Sands Project (PA 06_0168), Modification 4 Mineral Separation Plant (DA 345-11-01), Modification 3 In relation to these modifications, Cristal acknowledges the following: Minor changes will be required to the Environmental Management Strategy (EMS, 603277) and subordinate management plans to reflect the changes required to department names, acronyms and abbreviations. Specific changes will be required to individual documents to reflect changes to consent conditions which affect future operational management requirements. The Notice(s) of Modification are appended to the EMS and Environmental Management Plans affected by specific condition changes prescribed in the above modification notices. Cristal is committed to amending the EMS and affected management plans in general accordance with Section 6.1 of the EMS in such that minor changes (not affecting operations) will be completed within 3 years of the date of the issue of the above Modifications. Plans impacted by changes to specific conditions effecting operations will be updated within 3 months of the completion of internal audits of these plans (May 2015), with the exception of the MSP Noise Management Plan (603243), which is required to be updated by 31 March 2015 (Schedule 2, Condition 3.6A, MSP Mod 3). iv GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

Table of contents Limitations... iii Development consent(s) & project approval modification... iv 1. Introduction... 1 1.1 Purpose of the management plan... 1 1.2 Scope of the management plan... 1 1.3 Document succession... 1 2. Project description... 2 2.1 Water, erosion and sediment control... 2 2.2 Salinity... 2 2.3 Summary of relevant activities... 3 2.4 Summary of potential environmental impacts... 3 3. Environmental management framework... 5 3.1 Relationship to other Environmental Management Plans... 5 3.2 Legislative requirements and project environmental approvals... 8 3.3 Roles and responsibilities... 19 3.4 Training and inductions... 19 3.5 Complaint, non-conformance and incident management... 19 3.6 Environmental reporting and correspondence... 19 3.7 Audits of the WESCP... 20 3.8 Review and update of WESCP... 20 4. Environmental management program... 21 4.1 Objectives... 21 4.2 Performance standard... 21 4.3 Environmental mitigation measures... 21 4.4 Monitoring... 29 4.5 Contingency measures... 30 4.6 Reporting... 31 5. References... 32 Table index Table 1 Approval documents for the Murray Basin mines... 8 Table 2 Regulatory Consent Conditions Applicable to this WESCP... 9 Table 3 Water, erosion, sediment control and salinity mitigation measures... 25 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

Figure index Figure 1 Cristal s environmental management framework... 5 Figure 2 Environmental management documents for Cristal s operations in the Murray Basin in NSW... 7 Figure 3 Ginkgo Mine drainage structures... 35 Figure 4 Snapper Mine drainage structures... 36 Appendices Appendix A Figures Appendix B Design criteria GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

1. Introduction 1.1 Purpose of the management plan Cristal Mining Australia Ltd (Cristal) operates a number of mineral sands mines in the Murray Basin and a mineral separation plant (MSP) at Broken Hill in NSW. This Water, Erosion and Sediment Control Plan (WESCP) has been created for the management of water, erosion and sediment, including salinity management, at the Snapper mineral sands mine (Snapper)) and the Ginkgo mineral sands mine (Ginkgo) in the Murray Basin in south-west NSW. Cristal s mine sites in the Murray Darling Basin have collectively been referred to as the Murray Basin mines for the purpose of this document. 1.2 Scope of the management plan The WESCP provides an overview of the environmental management and performance requirements related to water, erosion and sediment control, including salinity management, at the Murray Basin mines. This WESCP includes: The requirements for environmental management of surface water, erosion and sediment and prevention of salinisation for operations at the Murray Basin mines as stipulated by regulatory approvals for the project; The responsibilities for implementing this WESCP; A description of the environmental controls and associated limits to meet objectives, targets and regulatory approval requirements; and An overview of the environmental monitoring programs and contingency measures associated with environmental mitigation measures. Further details on the Environmental Management Framework for Cristal s operations at this site are provided in section 3. Environment management and performance requirements relevant to groundwater are included in the Borefield Impact Management Plan. 1.3 Document succession This WESCP supersedes the following plans: Bemax Resources, Ginkgo Mineral Sands Project Integrated Erosion and Sediment Control Plan, May 2006; Bemax Resources, Ginkgo Mineral Sands Mine Site Water Management Plan, February 2012; and Bemax Resources, Snapper Mineral Sands Mine Water Management Plan, February 2008. This WESCP supersedes these above documents which are now obsolete. The new WESCP (this document) has been prepared on the basis of information contained with the original management plans and advice received from Cristal regarding current activities and management measures. Cristal is required to submit management plans to the Department of Planning and Infrastructure (DOP) for approval. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 1

2. Project description The Environmental Management Strategy (EMS, section 3.1) provides details on the current operations at Ginkgo and Snapper within the Murray Basin in NSW. Water, erosion and sediment control, including salinity management, are considered to be environmental aspects that require management to minimise impacts associated with activities for the project. 2.1 Water, erosion and sediment control An Environmental Impact Statement (EIS) was completed for the Ginkgo Mineral Sands Mine in 2001 (Bemax 2001b). An Environmental Assessment (EA) was completed for the Snapper Mineral Sands Mine in 2007. The EIS and EA documents were prepared in accordance with the requirements of the NSW Environmental Planning and Assessment Act 1979 (EP & A Act), to accompany the Development Application (DA) submitted by Bemax (now Cristal) for the Project. Stages 1 and 2 of the development involved construction activities related to mine preparation and have now been completed. Cristal is now in the operational mining phase. The water management measures and erosion and sedimentation mitigation measures outlined in this management plan are important at the Murray Basin mines to protect surrounding landscape features and existing site amenity. In particular, mitigation measures are designed to minimise the risks associated with erosion and sedimentation to the following: Clean water supplies on site; and Surrounding remnant vegetation. The closest watercourses to Ginkgo are Travellers Lake (10 km west) and Darling River (17 km east). The closest watercourses to Snapper are Travellers Lake (10 km northwest) and Darling River (30 km east). The closest watercourses to Crayfish are Travellers Lake (13 km west) and Darling River (14 km east). The risk of mining operations impacting these watercourses is low. There are no well-defined drainage channels within the Mine Lease Area (MLA) areas and surrounds. Some overland flow does during prolonged rainfall events and surface waters accumulate in topographic depressions and then evaporate or seep into the groundwater table over time. 2.2 Salinity Many saline areas in NSW (e.g. inland salt pans, brackish streams, coastal salt marshes and naturally saline soils) are the result of natural processes. Most newly salinised areas however, are often the result of particular land use practices, such as over-clearing, river regulation, irrigation or the cultivation of crops. Salinity is often divided into several different categories including: Dryland salinity; Irrigation salinity; Urban salinity; River salinity; and Industrial salinity. Irrigation salinity (i.e. due to over-irrigation of farm land, inefficient water use and poor drainage) and urban salinity (i.e. due to dryland salinity processes and over-watering of towns and urban areas) are not relevant to the Project. 2 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

The three different types of salinity relevant to the Project (i.e. dryland, river and industrial salinity) are described below. Dryland salinity Dryland salinity is the build-up of salt in the soil, usually as a result of a rising watertable. Evaporation of saline water at the soil surface tends to concentrate salts to the point where they affect the environment. In rural areas, dryland salinity associated with rising watertables is often caused by the loss of deep-rooted perennial trees, shrubs and grasses. The loss of vegetation is often caused by factors such as clearing, cropping with shallow rooted annual plants (such as wheat, barley, pasture, etc.) or overgrazing. Secondary to the loss of vegetation and/or poor land management practices are impacts such as soil salinity, sodicity, acidification and erosion. There is no known dryland salinity in the Project area. Industrial salinity Industrial salinity is often related to industrial processes whereby salt is concentrated in the water used. Mine sites often need to manage saline water from groundwater seepage and from rainwater coming into contact with active mining areas or spoil. Abandoned mines are also a major source of salinity in some areas. River salinity Surface water run-off from areas of dryland, irrigation and urban salinity may flow into creeks and rivers, raising the salinity of these waterbodies. 2.3 Summary of relevant activities Activities that have the potential to cause soil erosion and generate sediment at the Murray Basin mines are: Use of saline water for dust suppression; Vegetation clearing and topsoil stripping; Stockpiling of topsoil; Construction of roads and infrastructure; Construction of overburden emplacements; and Use of hazardous materials (such as hydrocarbons). 2.4 Summary of potential environmental impacts Significant impacts potentially associated with operations were assessed in the EIS or EA for each of the Murray Basin mines. Mitigation measures that regulatory authorities (for example, the DOP, EPA, RTA and local councils) deemed required to reduce potential risks to an acceptable level were identified and included in the Conditions of Approval and the EPL (Table 1 and Table 2). A preliminary, high-level risk assessment for the Murray Basin mines was created as part of the update of the EMS and is appended to this revised EMS. This high-level assessment was a subjective assessment based on Cristal s knowledge of site operations to-date and the effectiveness of existing controls in reducing risks. Further details on this risk assessment are provided in the EMS. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 3

A summary of the main potential environmental impacts for water, erosion, sedimentation and salinity at the Murray Basin mines are summarised below: Saline water used for dust suppression impacts surrounding vegetation; Saline water used for dust suppression increases salinity levels in soil; Run-off from stockpiles impacts surrounding vegetation; Spills and leaks of hazardous materials (such as hydrocarbons) enters drainage channels; and Changes to surface water flow regimes at the mines and surrounding areas and as consequence, potential impacts on vegetation features/landscape. The mitigation measures outlined in this document are based on the requirements of regulatory consent conditions (Table 1 and Table 2). The preliminary risk assessment (as appended to the EMS) identified the residual risk associated with waste following the implementation of the mitigation measures in this plan as low. The mitigation measures outlined in this WESCP are designed to minimise the potential impact of these above potential environmental impacts. 4 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

3. Environmental management framework The environmental management framework for Cristal s operations in the Murray Basin is based on the requirements of AS/ISO 14001:2004 (the standard). Major elements of the environmental management framework include: Project risk identification and assessment; Environmental objectives and measurable performance targets; Legal and other requirements; Roles and responsibilities for environmental management; Staff training and induction processes; Responding to and managing complaints, non-compliances and incidents; Environmental reports and correspondence for the project; Audits of the EMPs; and Review and update of the EMPs. This WESCP has been designed as a subordinate document to the Environmental Management Strategy (EMS, 2012), which provides the framework for all Cristal s operations at the MSP and at the Murray Basin mines. Each of the main components of the standard has been addressed in detail within the EMS. Information provided within this WESCP provides additional, specific details for erosion and sediment management. The Environmental Management Framework in place for Cristal s current operations in the Murray Basin in illustrated in Figure 1. Environmental Policy Provides overall direction for management actions, decisions and environmental commitments. Environmental Management Strategy Provides a framework for the delivery of environmental objectives, targets, programs and plans Procedures Step by step guides to implement environmental management Environmental Management Plans Details requirements to meet environmental performance objectives for key environmental aspects Registers, Forms & Data Databases Registers of incidents, plans & supporting documents & legal requirements Forms monitoring forms, inspection forms, incident & complaint forms etc Databases internal mechanisms for recording, tracking & managing key components of the EMS (incidents, monitoring, non-conformances, etc.) Figure 1 Cristal s environmental management framework 3.1 Relationship to other Environmental Management Plans The structure of the environmental management documentation is presented in Figure 1. This WESCP makes direct reference the following environmental management documentation listed in Figure 2: GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 5

Borefield Impact Management Plan; Ginkgo DMU Salinity and Rehabilitation Management Plan; and Snapper and Ginkgo Mining Operation Plans. This management plan should be read in conjunction with the above management plans as appropriate. 6 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

Companywide Integrated Management System (Environment and Safety) Murray Basin Operations Environmental Management Strategy Ginkgo Snapper Mineral Separation Plant Murray Basin Operations Community Consultation Plan Murray Basin Operations Traffic Management Plan & Code of Conduct Murray Basin Operations Radiation Management Plan Murray Basin Operations Environmental Monitoring Program Ginkgo Painted Burrowing Frog Management Plan Ginkgo Mining Operations Plan Ginkgo Mine Closure Plan Ginkgo DMU Salinity and Rehabilitation Management Plan Ginkgo Integrated Mining Rehabilitation Environmental Management Plan Snapper Mining Operations Plan Pollutant Incident Response Management Plan Effluent Management Plan Operational Environment Management Plan Air Quality Management Plan Energy Savings Management Plan Water Management Plan Pollution Incident Response Management Plan Air Quality Management Plan Cultural Heritage Management Plan Water Erosion and Sediment Control Management Plan Waste and Landfill Management Plan Noise Management Plan Bushfire Management Plan Flora and Fauna Management Plan Land Management Plan Emergency Response Management Plan Safety Management Plan Noise Management Plan Waste Management Plan Cultural Heritage Management Plan Construction Environment Management Plan Noise Management Protocol Erosion and Sediment Control Plan Safety Study Fire Study Risk Hazard Analysis Energy Savings Management Plan Borefield Impact Management Plan Offset Management Plan Figure 2 Environmental Management documents for Cristal operations in the Murray Basin in NSW

3.2 Legislative requirements and project environmental approvals 3.2.1 Project regulatory approvals Cristal is required to create, maintain and implement EMPs in accordance with the approval conditions for the Murray Basin mines. There are a number of regulatory approval documents that contain conditions for environmental management that Cristal must adhere to for operations at this site. This WESCP has been created to address the specific requirements of the regulatory approval documents. The current regulatory approval documents for this project are provided in Table 1 below. The requirements of these regulatory approvals to be addressed in this WESCP are provided in Table 2. With regards to Conditions of Approval granted for the Ginkgo and Snapper under the EP & A Act it is noted that: Development consent for Ginkgo was granted pursuant to section 76(A)9 & 80 (Part 4) in January 2002 Project Approval for Snapper was granted pursuant to section 75J (Part 3A) in August 2007 Table 1 Approval documents for the Murray Basin mines Approval Document Document Number Current revision date Ginkgo Mineral Sands Mine Development Consent Conditions DA 251-09-01 October 2010 Ginkgo Mining Lease ML No. 1504 6 March 2002 Ginkgo Mine Environmental Protection Licence EPL 12264 10 July 2012 Snapper Mineral Sands Mine Conditions of Project Approval DA 06-168 October 2010 Snapper Mining Lease ML No. 1621 10 July 2008 Snapper Mine Environmental Protection Licence EPL 12799 10 July 2012 8 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

Table 2 Regulatory Consent Conditions Applicable to this WESCP Condition number Condition details Section in WESCP Ginkgo (DA 251-09-01) 3.5 Prevention of Soil Erosion (a)all works involving soil or vegetation disturbance shall be undertaken with adequate measures to control and minimise soil erosion and the entry of sediments into any river, lake, waterbody, wetland or groundwater system. This plan details measures to control and minimise soil erosion and sedimentation. (b)the Applicant shall prepare and submit to the DECCW, I&I NSW and the Director-General for review, prior to the commencement of construction, an Integrated Erosion and Sediment Control Plan. The Plan shall be prepared and implemented, for any particular aspect of development prior to the commencement of construction or mining operations. The Plan shall include, but not be limited to: (i) Details of temporary and permanent sediment and erosion control systems to be used during both mine construction and operation, including for earthworks associated with landscaping; Refer to Ginkgo Mineral Sands Project Integrated Erosion and Sediment Control Plan, May 2006 for construction phase. Details of sediment and erosion control systems used during mine operation are detailed in section 4.3.1 and 4.3.2. (ii) Details of salinity management; section 4.3 (iii) Measures that will be employed to minimise soil erosion and the discharge of sediment and other pollutants to lands and/or waters during construction activities. The Plan should be prepared in accordance with the requirements for such plans outlined in Managing Urban Stormwater: Soils and Construction (available from the Department of Housing) or its latest version; Mine construction is complete and therefore this plan does not include these details. The superseded documents outlined in section 1.3 contain erosion and sediment controls for the construction phase. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 9

(iv) Measures developed and implemented to mitigate the impacts of stormwater runoff from the site following the completion of construction activities. The Plan should be consistent with the guidance contained in Managing Urban Stormwater: Council Handbook (available from the DECCW) or its latest version; 1 (v) Details of the proposed measures to maximise the retrieval of topsoil for subsequent use in the rehabilitation program; (vi) Consideration and management of erosion and sedimentation of surface watercourses / waterbodies, including all creeklines within the DA areas; (vii) Measures to construct banks, channels and similar works to divert stormwater away from disturbed and contaminated land surfaces such as mine workings, haul roads, overburden disposal areas, ore handling areas and wastewater treatment facilities; (viii) A program for reporting on the effectiveness of the sediment and erosion control systems and performance against objectives contained in the approved Plan, and EIS; (ix) Details of the management of soil stockpiles, erosion protection and long term viable use (where immediate use is not possible), soil stripping techniques and scheduling; (x) A program for reporting on the effectiveness of the soil stripping methods and performance against objectives contained in the EIS; (d) Sedimentation dams or other siltation control devices must be constructed to contain or treat surface water runoff from all areas disturbed by mining including overburden dumps, topsoil stockpiles, unsealed roads and areas cleared of vegetation. Sedimentation dams must be designed: Section 4.3 Section 4.3 Sections 2.1 Section 4.3 Sections 4.3 and 4.4 Section 4.3 Sections 4.3 and 4.4 Section 4 and Appendix B To provide, to the satisfaction of the DECCW, a minimum dam capacity appropriate to the area draining to each dam; So that maximum flow velocity through dams meet DECCW guidelines; 1 Managing Urban Stormwater: Council Handbook (NSW EPA 1997) is in draft form. 10 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

4 Water Management and Monitoring To prevent short circuiting; and If inflow is likely to contain oil or other deleterious floating matter a baffle must be installed at the outlet to prevent discharge of that matter. Notes: 1. The applicant must obtain all necessary approvals under the Water Act 1912 from NOW for water extraction and the provision of structures prior to mining operations commencing, 2. An approval by NOW will only be granted to the occupier, as defined in the Water Act 1912 of the lands where the works are located or used, unless otherwise allowed or authorised under the Water Act 1912. 3. When NOW grants an approval, it may require any existing approvals held by the Applicant relating to the land subject to this consent being surrended or let lapse. 4. All works subject to an approval under the Water Act 1912 shall be constructed, maintained and operated in a responsible manner that will minimise the possibility of damage being occasioned by them, or resulting from them, to any public or private property, and to ensure public safety. 5. The applicant must, prior to construction of all dams and embankments which fall within the provisions of the NSW Dams Safety Act, obtain approval from the NSW Dams and Safety Committee. All licenced work that is referrable under the NSW Dams and Safety Act shall be constructed and maintained in accordance with the provisions of that Act. 6. The Applicant must obtain all necessary approvals from NOW under Part 3A of the Rivers and Foreshores Improvement Act 1948 for any works subject to such an approval. Section 3.2.2 4.1 Water Management (i) The Applicant shall, prior to commencement of mining prepare an integrated Site Water Management Plan for the project operations to the satisfaction of the Director-General and DECCW, which shall include, but not be limited to, the following matters: Site water balance; Refer to Borefield Impact Management Plan. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 11

Management of the quality and quantity of surface and ground water within the areas covered by the Water Management Plan; Measures to prevent the quality of any surface / ground waters being degraded due to the operation of the mine workings; The installation of a network of monitoring bores as required to monitor impacts on groundwater aquifers; Details of water makeup and storage on site, including contingencies in the event of very wet or dry conditions occurring. This must provide a water balance for mine water demand; Measures to ensure that poorer quality class waters are effectively reused on the site including consideration of segregation of waters based on salinity classes and other levels of contamination; Details of any licensing requirements for any extractions, storages, or other constructions on the site; Projection of potential groundwater changes during mining (short term) and post mining (long term) with particular attention given to the affect of changes to groundwater quality and mobilisation of salts; A program for reporting on the effectiveness of the water management systems and performance against objectives contained in the approved site water management plans, and EIS. For surface water refer to section 4.3. Groundwater is covered in the Borefield Impact Management Plan. For surface water refer to section 4.3. Groundwater is covered in the Borefield Impact Management Plan. Groundwater is covered in the Borefield Impact Management Plan. Groundwater is covered in the Borefield Impact Management Plan. Section 4.3. Section 3.2.3 Groundwater is covered in the Borefield Impact Management Plan. Section 4.4 12 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

At least two months prior to construction of the extension to the initial sand residue dam, the Applicant shall revise the integrated Site Water Management Plan, in consultation with the DECCW and NOW and to the satisfaction of the Director-General, to include: (a) monitoring of the initial sand residue dam extension for signs of lateral salt water seepage; (b) details of compaction and moisture testing prior to use of the initial sand residue dam extension liner; and (c) Contingency plans to deal with any lateral water seepage or break down in the initial sand residue dam extension liner. (ii) Prevention of pollution of waters. (a) Except as may be expressly provided by a licence under the Protection of the Environment Operations Act 1997 in relation to the development, section 120 of the Protection of the Environment Operations Act 1997 must be complied with in connection with the carrying out of the development. The initial sand residue dam was constructed adjacent to the starter pit to contain saline groundwater and sand residues for the initial period of mine establishment. This phase is now complete and therefore this plan does not include these details. The superseded Ginkgo Site Water Management Plan (r section 1.3) contains these details. The purpose of this WESCP is to reduce the risk of pollution of waterways. (b) Waste water from the mining process must not be discharged onto adjoining roads, crown land or other persons land, any river, creek or watercourse, groundwater aquifer, any area of native vegetation or other wetlands, unless otherwise authorised by a licence under the Protection of the Environment Operations Act 1997. (iii) Perimeter Bunds Appendix B Any bund shall be designed for, amongst other things toe stability; forces from flooding, hydraulic pressures, seepage, attack from burrowing fauna and revegetation. (iv) Road Drainage Crossing Section 4.3 Erosion of the bed and banks upstream and downstream of the crossings shall be prevented with suitable scour protection. 4.3 Water Monitoring Surface and Groundwater Groundwater is covered in the GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 13

(a)the Applicant shall construct and locate surface and groundwater monitoring positions, as identified in the Site Water Management Plan (Condition 4,2(a)) to the satisfaction of the Director- General and NOW, prior to the commencement of mining operations works. Particular regard shall be paid to the project s impact on the groundwater quantity and quality and surface water quality and quantity and the options to minimise any identified adverse impacts; and (b) For each monitoring/discharge point or utilisation area specified below (by point number), the Applicant must monitor (by sampling and obtaining results by analysis) the concentration of each pollutant specified in Column 1 of Tables 1 and 2. The Applicant must use the sampling method, units of measure, and sample at the frequency, specified opposite in the other columns: Table 1. Point 2 Groundwater monitoring bores on the premises Borefield Impact Management Plan. There are no formalised surface water monitoring locations. Groundwater is covered in the Borefield Impact Management Plan. There are no formalised surface water monitoring requirements. Pollutant Units of measure Frequency Sampling Method Level Metres Monthly Inspection Total Dissolved Solids Mg/L Monthly Representative sample Note: In the table above, the monitoring boxes refer to the 5 monitoring wells on the premises described in the EIS. Table 2. Point 3 Groundwater monitoring bores outside the premises Pollutant Units of measure Frequency Sampling Method Level Metres Monthly Inspection Total Dissolved Solids Mg/L Monthly Representative sample Note: In the table above, the monitoring boxes refer to the 5 monitoring wells outside the premises described in the EIS. 14 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

(c) monitoring for the concentration of a pollutant discharged to waters or applied to a utilisation area required by condition 9.3.1(e) 2 must be done in accordance with: Not applicable. (i) the approved methods publication; or (ii) If there is no methodology required by the approved methods publication, these conditions of consent or in the licence under the protection of the environment operations act 1997 in relation to the development or the relevant load calculation protocol, a method approved by the DECCW in writing before any tests are conducted. (d) the results and interpretation of surface and groundwater monitoring are to be reported in the ANNUAL REVIEW. The Applicant shall also provide NOW with an electronic copy of all monitoring results, if requested. Groundwater is covered in the Borefield Impact Management Plan. 4.4 Initial Water and Residue Dam (a) The applicant must consult with the NOW and I&I NSW in relation to any dam construction proposed at the site. There are no formalised surface water monitoring requirements. The start-up water dams at Ginkgo and Snapper have been decommissioned. Refer to Section 4.3.1 and 4.3.2 Snapper (DA 06-168) Schedule 3, Condition 2 The Proponent shall prepare and implement a Water Management Plan for the project to the satisfaction of the Director-General. This plan must: (a) be prepared in consultation with the DECC and DWE by suitably qualified expert/s whose appointment/s have been approved by the Director-General; Prepared in consultation with NSW EPA and Department of Mineral Resources, reviewed and approved by these agencies. 2 Condition 9.3.1(e) does not exist in the current Ginkgo Development Consent. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 15

(b) be submitted to the Director-General for approval prior to carrying out any development on the site; and Section 1.3 (c) include: Erosion and Sediment Control Measures; Section 4. Surface Water Management Measures; and Section 4. Borefield Management Measures. Refer to Ginkgo and Snapper Borefield Impact Management Plan. Schedule 3, Condition 3 The Erosion and Sediment Control Measures must: (a) be consistent with the Managing Urban Stormwater: Soils and Construction manual (Landcom, 2004 or its latest version); Section 4 and Appendix A (b) identify activities that could cause soil erosion and generate sediment; Section 2.2 (c) describe measures to minimise soil erosion and the potential for the transport of sediment; Sections 4 (d) describe the location, function, and capacity of erosion and sediment control structures; and (e) describe what measures would be implemented to monitor and maintain the integrity of the structures over time. Sections 4 and Appendix A Sections 4.4.1 and 4.5.1 Ginkgo Mine Environmental Protection Licence (EPL 12264) O4.3 The licensee must prepare and implement an Erosion and Sediment Management Plan for the Premises. Note: The Erosion and Sediment Management Plan must be prepared and implemented to ensure compliance with the conditions of this Licence and relevant environment legislation. This plan details measures to control and minimise soil erosion and sedimentation. 16 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

L1 Except as may be expressly provided in any other condition of this licence, the licensee must comply with section 120 of the Protection of the Environment Operations Act 1997. The purpose of this WESCP is to reduce the risk of pollution of waterways. Snapper Mine Environmental Protection Licence EPL 12799 O4.3 The licensee must prepare and implement an Erosion and Sediment Management Plan for the Premises. Note: The Erosion and Sediment Management Plan must be prepared and implemented to ensure compliance with the conditions of this Licence and relevant environment legislation. This plan details measures to control and minimise soil erosion and sedimentation. L1 Pollution of Waters Except as may be expressly provided in any other condition of this licence, the licensee must comply with section 120 of the Protection of the Environment Operations Act 1997. The purpose of this WESCP is to reduce the risk of pollution of waterways. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 17

3.2.2 Relevant legislation and other requirements This project is subject to the requirements of the New South Wales Protection of the Environment Operations Act 1997 and it subordinate legislation. A full legislative register is provided in the EMS (2012); acts, regulations and policies specific to this WESCP are listed below. Acts Environmental Planning and Assessment Act 1979 Mining Act 1992 Water Management Act 2000 Soil Conservation Act 1984 Rivers and Foreshores Improvements Act 1948 Water Act 1912 Dams and Safety Act 1978 Regulations Protection of the Environmental Operations (General) Regulation 2009 Relevant Standards, Codes of Practice and Guidelines Managing Urban Stormwater: Soils and Construction, Volume 2E Mines and Quarries (NSW DECC 2008) Managing Urban Stormwater: Soils and Construction, Volume 1 (4 th Edition) (Landcom 2004b) Managing Urban Stormwater: Council Handbook, Draft (NSW EPA 1997) Design Manual for Soil Conservation Works Technical Handbook No. 5 (Soil Conservation Service of NSW 1986) Urban Erosion and Sediment Control Handbook Hunt, NSW Department of Conservation and Land Management (J.S. ed, 1992) Australian Rainfall and Runoff, Institute of Engineers Australia, current version 3 3.2.3 Licensing requirements The following water-related licences/approvals will be obtained prior to the commencement of relevant works. Protection of the Environment Operations Act, 1997 Cristal has obtained an Environmental Protection Licence (EPL) from the NSW EPA pursuant to the Protection of the Environment Operations Act 1997. The licence includes conditions for the pollution of waters in order to comply with section 120 of the Protection of the Environment Operations Act 1997. 3 At the time of writing this management plan (November 2012), this guideline was under review. This guideline needs to be periodically checked for currency to identify the most recent version of this guideline for use. 18 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

Rivers and Foreshores Improvement Act, 1948 (repealed) Ginkgo development consent condition 4 requires Cristal to obtain all necessary approvals under Part 3A Rivers and Foreshores Improvement Act 1948. This Act has since been repealed and as such this requirement is no longer applicable. Water Act 1912 Ginkgo development consent condition 4.2 (ii) requires Cristal to obtain a licence, under Part II of the Water Act 1912, for the pump and related infrastructure to extract water from the Darling River. It is considered highly unlikely that water will be extracted from the Darling River by Cristal. NSW Dams Safety Act, 1978 Where necessary, Cristal will obtain approval from the NSW Dams Safety Committee prior to construction of any dams and embankments, which fall within the provisions of the NSW Dams Safety Act 1978. 3.3 Roles and responsibilities Overall roles and responsibilities for environmental management at the Murray Basin mines are outlined in Cristal s EMS. The responsibility for this WESCP lies with the Senior Rehabilitation Advisor. 3.4 Training and inductions Overall training and induction requirements for Cristal s operations at the Murray Basin mines are outlined in Cristal s EMS. 3.5 Complaint, non-conformance and incident management Complaint, non-conformance and incident management for Cristal s operations at the Murray Basin mines is described in Cristal s EMS. 3.6 Environmental reporting and correspondence Conditions of Approval (Table 1) for the Murray Basin mines (Table 2), require that Cristal submit an Annual Environmental Management Report (AEMR) to the Director-General of the DOP. Details of information to be included in the AEMR are provided in Cristal s EMS. For water, erosion and sediment control, the AEMR should include but not be limited to details of: The effectiveness of the sediment and erosion control systems and performance against objectives contained in this WESCP (section 4) (Note: Ginkgo Condition of Approval (DA 251-09-01) requires reporting of the effectiveness of the sediment and erosion control systems and performance against objectives contained in the ESCP and EIS. For completeness EIS objectives have been incorporated into WESCP objectives.) Details of the sediment and erosion control strategies undertaken for the preceding 12 months; Any proposed modifications to erosion and sediment control strategies for the upcoming 12 month period; and Site water management system strategies and the effectiveness of management measures. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166 19

3.7 Audits of the WESCP Conditions of Approval (Table 1) for the Murray Basin mines require that Cristal conduct an Independent Environmental Audit every three years or as otherwise directed by the Director- General of the DOP. Matters to be covered by the Independent Environmental Audit are described in Cristal s EMS. Further detail of the how audits of EMPs will be conducted (including internal audits) is provided in the EMS. 3.8 Review and update of WESCP Conditions of Approval (Table 1) for the Murray Basin mines outline requirements for revision and update of EMPs. EMPs would be reviewed, and if necessary revised to the satisfaction of the Director General, within three months of: (a) the submission of an AEMR; (b) the submission of an incident report; (c) the submission of an Independent Environmental Audit Report; and (d) any modification of the regulatory consent conditions. Further details on the requirements for review and update of EMPs are provided in the EMS. 20 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

4. Environmental management program 4.1 Objectives To control soil erosion and sediment generation from areas disturbed by mining activities. To minimise the potential for activities to lower the water quality (particularly in terms of total suspended solids content) of downstream watercourses. To minimise salinisation caused by mining activities. To contain contaminated water on site in constructed dams to result in zero off-site discharges. To conserve water resources throughout all areas of the operation. Maximising the reuse/recycling of water to decrease the demand on external water supplies. 4.2 Performance standard The following performance outcomes have been identified against the objectives of the WESCP. The objectives will be achieved if: Erosion and sediment control structures conform with the NSW Government Managing Urban Stormwater: Soils and Construction (Volume 1, 4 th Edition) The Blue Book ; Active erosion is not evident along stormwater channels and retention systems; To maintain soil salinity at as close as possible to pre-mining levels, no increase in soil salinity due to mine practices resulting in dryland, river, or industrial salinity. Disturbance areas are restricted to operations areas; Up-slope stormwater flow is diverted around operational areas; Water run-off from operational areas is contained and recycled on-site; Water monitoring and response measures are established; and Exposed areas are stabilised and revegetated. 4.3 Environmental mitigation measures The erosion and sediment control structures that will be implemented during the operational phase are described below for the following Project components. These are shown on the figures in Appendix A. Erosion and sediment control structures will be designed in accordance with the criteria in Appendix B with design undertaken by the appointed Cristal engineer. 4.3.1 Ginkgo erosion and sediment control structures Initial laydown area The Stage 1 and Stage 2 laydown area have been mined out and form part of the mining area. There is still one laydown area at Ginkgo outside of the mine path between the Wet High Intensity Magnetic Separator (WHIMS) and overburden emplacement No. 1 (OB1). 21 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166

Mining area The mining area will effectively act as its own retention structure. The perimeter of the construction pit will be stripped an additional 20 metres to accommodate an access track. The access track will be bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Start-up water dam and tailings dam facility The start-up water dam and tailings dam facility has been decommissioned and will be rehabilitated in accordance with the DMU Salinity and Rehabilitation Management Plan. The catch drain and bunding structure surrounding the start-up water dam and tailings dam facility are maintained. Overburden emplacements Overburden emplacements OB1, OB2 and OB3 have been decommissioned and are in various stages of rehabilitation. Rehabilitation will be in accordance with the DMU Salinity and Rehabilitation Management Plan The catch drain and bunding structure surrounding the overburden emplacement are maintained. OB4 is a temporary overburden structure and will be mined through. Slimes Dam The slimes dam has been decommissioning and will be rehabilitated. DMU dam The DMU dam has been has been decommissioned and rehabilitated. The catch drain and bunding structure surrounding the DMU dam are maintained. Wet High Intensity Magnetic Separator (WHIMS) The WHIMS is operational and will be active for the life of the mine. Dirty water will be directed to a local retention structure located in the vicinity of the facility. The area will be bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Administration office, workshop and accommodation An area was stripped to accommodate the administration office, workshop and accommodation facilities for the life of the mine. Dirty water from these facilities are directed to a local retention structure located in the vicinity of the administration office, workshop and accommodation area. The area is bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Site access roads Access roads will be bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Access roads will be watered with saline groundwater for dust suppression purposes. Sediment sumps will be placed at regular intervals alongside all access roads, to contain all dirty water runoff within the sediment sumps for reuse. Groundwater salts collected in these sumps will be periodically removed and deposited with sand residues behind the dredge pond. Erosion of the bed and banks upstream and downstream of road drainage crossings will be prevented with suitable scour protection. 22 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mines Water Erosion and Sediment Control Plan, 31/29166