Ginkgo Mineral Sand Mine

Transcription

1 Ginkgo Mineral Sand Mine Environmental Audit of Compliance with Development Consent and Environment Protection Licence Cristal Mining Australia Pty Ltd DECEMBER 2018 TELFORD ENVIRONMENTAL CONSULTING SERVICES

2 Contents 1 Introduction Background Operations Approvals Audit Details Audit Objective Audit Scope Activity audited Period of time covered by the audit Exclusions from the audit scope Audit criteria Auditor Audit Method Site meetings and inspections Audit checklists Compliance assessment criteria Cristal personnel Interviewed Stakeholder involvement Documents viewed Limitations Audit Findings Comments Made by Stakeholder Contacts Audit Observations Regarding Stakeholder Comments Compliance with Development Consent Compliance Non-compliances Recommendations Implementation of Past Audit Recommendations Conclusion TELFORD Page ii

3 Appendices A. Endorsement of David Telford as auditor by Secretary B. Completed DC audit checklist Ginkgo Mine C. Completed EPL audit checklist Ginkgo Mine Document Control Revision Date Details Signature Draft 3 Dec 2018 Draft for review by Cristal Mining Final 3 Dec 2018 Final for issue to Cristal Mining TELFORD Page iii

4 1 Introduction 1.1 Background Operations Cristal Mining Australia Pty Ltd (Cristal) operates the Ginkgo Mineral Sand Mine at Nob Road, Pooncarie, NSW. The mine is located approximately 90 km north of Mildura and 180 km south east of Broken Hill. The mine uses a dredger and wet plant technology in a floating concentrator with subsequent processing at the mine to concentrate titanium-bearing mineral sands. Mineral sand concentrate from the mine, along with that from Snapper Mine, is delivered by road to the Broken Hill Mineral Separation Plant for further separation and concentration. Plant at the mine includes: dredge; floating concentrator plant (wet plant); stacker; water bores and overland piping; 10 km 22 kv supply overhead transmission line and associated sub-stations; and access/haulage roads. Note that due to a failure at the Ginkgo Mine concentrator, mineral concentrate production at the mine ceased on 15 September Accommodation is provided for Ginkgo Mine employees, contractors and visitors at the Ginkgo Mine Approvals The NSW Minister for Planning issued a project approval to Bemax Resources Limited (the original developer) for development of the Ginkgo mine. Operations at the mine are required to comply with conditions of the development consent. Schedule 5, Section 8 of the consent requires Cristal Mining to engage an independent person endorsed by the Secretary to conduct an annual audit to assess compliance with the requirements of the consent, licence and approvals. A copy of the endorsement is provided in Appendix A. Details of the Ginkgo Minerals Sands Mine consolidated development consent and environment protection licence used for this compliance audit are summarised in Table 1. Table 1 Details of project approval Application Number Applicant Type Date of last revision Cristal Mining Australia Limited Development consent 14 December Cristal Mining Australia Limited Environment protection licence 18 December 2015 TELFORD Page 1

5 2 Audit Details 2.1 Audit Objective To assess compliance of operations conducted by Cristal at the Ginkgo Mineral Sand Mine against the NSW Department of Planning development consent (DA ) and the NSW Environment Protection Authority environment protection licence Audit Scope Activity audited The audit assessed operations conducted by Cristal at the Ginkgo Mineral Sand Mine, Pooncarie, NSW subject to NSW Department of Planning development consent (DA ) and the NSW Environment Protection Authority environment protection licence Period of time covered by the audit The audit assessed activities reported in the annual performance statement for the three year period January 2016 to December Note that the audit was conducted on 11 to 13 November 2018, approximately one and a half months before the end of the reporting period. Ore mining and concentration figures were those from 1 January to 15 September 2018 as mine production ceased on that date due to a failure at the Ginkgo Mine concentrator. Other production and waste management figures for the 2018 calendar year were determined by adding the budgeted November and December quantities to those obtained from January to October Exclusions from the audit scope The scope of the audit was limited to the activities conducted at the Ginkgo Mine referenced in the project approval. Site sampling or monitoring was not conducted for the audit Audit criteria The audit considered compliance of operations at the premises with conditions specified in: NSW Department of Planning project approval, DA , consolidated 14 December 2017; and NSW environment Protection Authority licence Auditor The audit was conducted by Dr David Telford of Telford Pty Ltd. David is an EPA Victoria appointed environmental auditor of industrial facilities. Information presented in this audit report is subject to the limitations given in section 2.4 of this report. Appointment of David Telford to conduct the audit was endorsed by the Secretary of Planning (see Appendix A). TELFORD Page 2

6 2.3 Audit Method Site meetings and inspections An opening meeting was held with the Cristal Mining Environmental Superintendent, Murray Basin at the Ginkgo Mine offices on 12 November The Ginkgo Mine site and surrounding land was inspected on 12 and 13 November 2015 in the company of the Environmental Superintendent. Preliminary audit findings were discussed with the Environmental Superintendent, Murray Basin, Cristal Mining Australia on 14 November Audit checklists An audit checklist, based on the development consent Ginkgo Mine conditions, was prepared before the site visit. The audit checklist was completed during the audit with the recording of compliance rating and audit evidence against each licence condition. A copy of the completed Ginkgo Mineral Sand Mine development consent condition audit checklist is provided in Appendix B Compliance assessment criteria Compliance assessment criteria used for this audit were: Non-compliant Opportunity for Improvement Not Applicable. findings denote that the requirements of the permit condition have been met. Non-compliant denotes that part or all of the permit condition requirements have not been met. An opportunity for improvement is a practice that could be modified to improve environmental performance or management and does not denote a non-compliance. Not applicable denotes that the permit condition is not relevant due to expiry of its requirement or as Cristal has not conducted activities relevant to the condition during the audit period Cristal personnel Interviewed Cristal personnel who were interviewed during, or participated in the audit were: Brendan Isaacs Environmental Superintendent, Murray Basin Sites, Eastern Australia; Clayton Trengove Mineral Separation Plant Manager; Haaken Nielssen Environmental Manager, Murray Basin; Sam Summers Environmental Technician; and Pieter Bekker Mine Surveyor Superintendent Stakeholder involvement Prior to the site inspection, contact was made by or telephone with the following authority representatives: NSW Department of Planning and Infrastructure; NSW EPA; NSW Division of Resources and Energy; and NSW Office of Water. TELFORD Page 3

7 The representatives were contacted to seek comment on elements of Ginkgo Mine operations that they considered were of potential environmental concern and warranted particular attention during the audit Documents viewed Documents viewed during the audit included: Cost Review for Establishment & Maintaining of Crayfish Mine Biodiversity Area ( ). Herron Todd White, April 2018; Crayfish expansion Mining Operation Plan , December 2015; Crayfish Mine Conservation Bond submission correspondence NSW Department of Planning, June 2016; Crayfish Mine Conservation Bond calculation for Crayfish Mine Biodiversity offset area and additional offset areas 7 and 8 (MOD13), Cristal Mining (undated); Crayfish Mine Offset Management Plan, September 2015; Crayfish Mine Rehabilitation Cost Estimate, April 2016; Cristal Mining Ginkgo Haul Road, Road Safety Audit Report Existing Road. WaySafe, September 2015; Cristal Mining Ginkgo Haul Road, Road Safety Audit Response October 2015; Cristal Mining letter to Department of Planning and Environment advising commencement of mining activities at Crayfish, August 2108; Cristal Mining letter to Department of Planning and Environment with attached survey plans of Ginkgo Modification extraction limits, 23 April 2015; Cristal Mining letter to Wentworth Shire Council advising commencement of mining activities at Crayfish, August 2018; Cristal Radiation Management Plan, August 2015; Ginkgo and Snapper Mines Pollution Incident Response Environmental Management Plan, May 2018; Ginkgo and Snapper Mines Water Environmental Management Plan, October 2016; Ginkgo Mine monthly monitoring reports, published on company website; Ginkgo Mine Closure Plan, 2015; Ginkgo Mineral Sand Mine Annual Environmental Management Report 2015; Ginkgo Mineral Sand Mine & Crayfish Expansion Annual Environmental Management Report 2016; Ginkgo Mineral Sand Mine & Crayfish Expansion Annual Environmental Management Report 2017; Ginkgo Mineral Sands Mine Lodgement of Conservation Bond. NSW Department of Planning & Environment, 3 June 2016; Hydrocarbon Management. Doc. No. AP_ME_ , Rev 2 January 2016; Landfill and leachate holding dam construction verification report. GHD, 16 May Letter of approval of Flora and Fauna Management Plan (December 2015) and Aboriginal Cultural Heritage Management Plan (January 2016). NSW Department of Planning & Environment, January 2016; Letter of approval of Offset Management Plan. NSW Department of Planning & Environment, February 2016; Letter of approval of Traffic Management Plan and Code of Conduct (September 2015), Noise Management Plan (September 2015), and Air Quality Management Plan (September 2015) NSW Department of Planning & Environment, January 2016; MSP Air Quality, Management Plan, June 2017; MSP Dry Plant Emission Tests, Enviroscan, January 2018; MSP Pollution Incident Response Environmental Management Plan, May 2018; Murray Basin Mineral Sands Mines Cultural Heritage Management Plan, September 2015; Murray Basin Mineral Sands Mines Air Quality Management Plan, September 2018; TELFORD Page 4

8 Murray Basin Mine Flora and Fauna Environmental Management Plan, June 2017; Murray Basin Mines Noise Management Plan, July 2018; Murray Basin Mines Offset Management Plan, August 2018; Murray Basin Operations Environmental Management Strategy, December 2016; Traffic Management Plan and Code of Conduct, August 2015; Water Access Licence Limitations This report was prepared for Cristal Mining Australia Ltd [the Client] for the purpose of an audit of operations at the Ginkgo Mine for compliance against the development consent for the mine issued by the NSW Government Department of Planning (December 2017 modification). The contents of this report are based on information gathered during execution of the commission and on information provided by the Client. The conclusions presented in this report are conditional upon accurate and complete information being provided by the client. The representations (relevancy) of the information contained in this report are subject to, and conditional upon, site conditions, activities and personnel changes ( Factors ) as they occur from time to time. Accordingly, the report may need to be reviewed in light of the time that has elapsed since its release, and changes including but not limited to, the Factors outlined above. This report shall only be presented in full and may not be altered, amended, abbreviated or issued in part without prior approval by Telford. This report has been prepared by Telford for the sole use of the Client. No warranties, expressed or implied are offered to any parties other than the Client and no liabilities will be accepted for the use of this report by any third party. TELFORD Page 5

9 3 Audit Findings 3.1 Comments Made by Stakeholder Contacts Environment Protection Authority The EPA representative advised that the authority had no particular environmental issue to raise for the audit. Department of Planning and Environment The DPE representative advised that the department would be interested in the performance of the environmental management system, waste management, rehabilitation progress, and management of any incidents or non-compliances. Division of Resources and Energy The DRE representative advised that the division commented on the rate of progressive rehabilitation but had no specific concerns in that regard. A comment was also made on the control of grazing pressure on the Snapper mine lease by installation of an apron on the lease boundary fence, however, this matter is outside the scope of this audit of the Ginkgo Mine. 3.2 Audit Observations Regarding Stakeholder Comments Department of Planning and Environment Environmental management system Cristal Mining implements an environmental management strategy that identifies Cristal s processes for environmental planning, environmental management strategy implementation, checking and corrective actions, and review and improvement. This is structured consistent with the requirements of AS/NZS ISO and covers the Cristal Mining Murray Basin operations. It incorporates a register of legal and other requirements, environmental aspects and impacts initially identified in the EIS and EES prepared for the project, and a risk assessment that was updated in Environmental management objectives and performance outcomes are implemented through a suite of environmental management plans and the mine operation plan. Environmental performance at the Ginkgo Mine is monitored in accordance with the approved plans, and is reported annually in the Annual Environmental Management Report and other reporting commitments such as the annual return to EPA. Waste management Waste, comprising domestic waste and mineral concentrate wastes from the Mineral Separation Plant, is being managed in accordance with the development consent conditions through implementation of the Murray Darling Basin Mine Landfill and Waste Environmental Management Plan, May Rehabilitation progress See below. Management of incidents or non-compliances Cristal Mining has not, over the past three years, received any environmental complaints regarding their operations at Ginkgo Mine. Also, here have not been any incidents that have required notification of the Department of Planning and Environment or the Environment Protection Authority. TELFORD Page 6

10 Division of Resources and Energy The DRE representative advised that the division commented on the rate of progressive rehabilitation but had no specific concerns in that regard. A comment was also made on the control of grazing pressure on the Snapper mine lease by installation of an apron on the lease boundary fence. While this matter is outside the scope of this audit, during the audit, Cristal Mining is engaging a contractor to install this apron on the Snapper Mine boundary fence and that new Crayfish Mine boundary fence is being erected with an apron. Rehabilitation Areas of mining land are opened only when access is required for mining to avoid the unnecessary clearing of land. Overburden benches are cleared of vegetation m in advance of the dredge face, with vegetation and topsoil removed metres in front of that, and initial vegetation clearing 500 metres in front of that. A cumulative clearing distance in front of the dredging void is between 1,350 1,500 metres. Progressive rehabilitation is practised to stabilise topsoil and re-establish vegetation cover on disturbed areas when practicable taking seasonal weather conditions into account. These distances are identified in section of the Mine Operation Plan. Photo 1 View of the Off-path tails dam, seeded in 2016, with the landfill in centre of view Due to drought conditions, Cristal Mining has rehabilitated 23 of the budgeted 50 hectares of disturbed land this year (see Table 2). Overall, Cristal Mining has rehabilitated 38% of disturbed land. Table 2 Rehabilitation of disturbed land at the Ginkgo Mine Area End 2015 End 2016 End 2017 End 2018 Mine lease area (ha) 3,381 4,359 4,359 4,359 Disturbed area (ha) Rehabilitated area (ha) TELFORD Page 7

11 Photo 2 View of Overburden Dump 1, seeded in 2015, with Off-path tails dam in background Photo 3 View of the boundary of the Ginkgo MOD13 biodiversity offset area TELFORD Page 8

12 Other audit observations i. Compliance with groundwater licences and approvals The groundwater Certificate of Title No. WAL27915 limits the groundwater source share to 7,402 units (ML per year). Licensed groundwater extraction bores for Ginkgo Mine are listed in Table 3. Table 3 Details of Ginkgo Mine production bores Bore P1 P2 P3 P4 P5 P6 Licence Number 06BL BL BL BL BL BL Annual groundwater extraction totals for the audit period, listed below, are within the licensed total volume: ,954 ML ,313 ML ,290 ML to end of October. The volumes of groundwater extracted are recorded and summarised in the annual environmental management report. ii. Compliance with the Water Management Plan The Murray Basin Mineral Sands Mines Water Management Plan (October 2016) identifies environmental management requirements for surface water, erosion and sediment, bore management and prevention of salinization for operations at the Ginkgo Mine. This meets the requirement of Schedule 3 Condition 11 of the development consent. Compliance with specific requirements of the development consent and the environment protection licence is assessed in the completed audit checksheets in Appendix A. No noncompliances with these requirements were identified during the audit. Groundwater is used for watering of the internal haul road, and for supply of the reverse osmosis plant at Ginkgo mine for domestic use and to supply the cooling towers. There is not any take of water from a surface waterway for Snapper Mine. Groundwater encountered within the mining pit is not extracted for any purpose. Water Management Plan requirements for Snapper Mine are being met, with the bores being monitored quarterly for depth and total dissolved solids (TDS) levels. Samples of groundwater from each bore are analysed quarterly for major ions and metals by a commercial laboratory under NATA signatory. 3.3 Compliance with Development Consent Compliance Compliance with each condition of the development consent has been assessed and detailed in the checklist table provided in Appendix A. A summary of the audit results is provided in Table 4. TELFORD Page 9

13 Table 4 Summary of audit findings Audit finding Number of audit findings 73 Non-compliant 2 Opportunity for improvement 0 Not applicable 5 The audit determined that Cristal Mining complied with all but two conditions of the NSW Department of Planning project approval for Ginkgo Mine for the period January 2016 to December Non-compliances Two non-compliances were identified during the audit. Details of these non-compliances are provided in Table 5. Table 5 Opportunities for improvement Identifier Condition Requirement Finding NC-1 DC s.2, c. 2(b) The Applicant shall: (b) comply with the conditions of this consent. This condition has not been met due to non-compliance with two conditions of the Development Consent (see below). NC-2 DC s.2, c. 17A By 30 June 2018, unless otherwise agreed with the Secretary, the Applicant shall: (a) engage a registered surveyor to mark out the revised boundaries of the approved limits of extraction within the entire site; and (b) submit a survey plan of the revised boundaries with applicable GPS coordinates to the Secretary. (a) The MOD13 boundaries have not been marked out. Cristal Mining is proposing to discuss the logistics of this approval condition with the Department, given the strict survey controls in place at the mine using computerised GPS-based boundary location systems. (b) A survey plan of the revised boundaries with application boundaries has not been submitted to the Secretary. Cristal Mining is preparing one for submission. NC-3 DC s.3, c. 28(e)(xiv) The Applicant shall prepare and implement a Radiation Management Plan for the development to the satisfaction of the Secretary. This plan must: (e) include: xiv. a conceptual decommissioning plan. The Cristal Murray Basin Radiation Management Plan, August 2015 lists the requirements of (e) on pages 6 and 7 and addresses all requirements apart from (xiv). Mine decommissioning and dismantling activities are described in section of the Ginkgo Mineral Sands Mine & Crayfish Expansion Operation Plan , however, the plan does not include a reference to assessment of residual radiation levels. 3.4 Recommendations The recommendations for actions to improve the environmental performance of the development listed in Table 6 are made in accordance with schedule 5, condition 8(e) of the consent. TELFORD Page 10

14 Table 6 Recommendations Identifier Condition Finding Recommendation NC-2 DC s.2, c. 17A (a) The MOD13 boundaries have not been marked out. (b) A survey plan of the revised boundaries with application boundaries has not been submitted to the Secretary. Discuss the logistics of this approval condition with the Department, and reach a suitable agreement with the Secretary, as provided by the condition. NC-3 DC s.3, c. 28(e)(xiv) The Cristal Murray Basin Radiation Management Plan, August 2015 does not include a conceptual decommissioning plan Revise the Cristal Mining Murray Basin Radiation Management Plan to include a conceptual decommissioning plan, or to make reference to such a plan in another management plan that would be acceptable to the Department. This revision should also include specific details of monitoring of residual radiation at the surface of rehabilitated land. 3.5 Implementation of Past Audit Recommendations Audits of compliance with project approval conditions and the environment protection licence at Ginkgo Mine were conducted in 2008, 2011, and The 2015 audit identified no items of non-compliance with respect to the development consent. TELFORD Page 11

15 4 Conclusion Cristal Mining Australia operations at the Ginkgo Mine have continued over the past three years without any notifiable environmental incidents having occurred or complaints having been received. The environmental management team has maintained close monitoring of environmental impacts of the mine and has maintained progressive rehabilitation of disturbed land and protection of biodiversity offset areas. Management of mineral processing and mining equipment wastes and potentially contaminating materials such as hydraulic, lubricating, and fuel oils has avoided potential harm to the environment from those aspects of mining operations. The audit of compliance of operations at the Ginkgo Mine with the development consent conditions determined that they have complied with all but three conditions of the project approval. these are described above in Table 5. The first non-compliance (NC-1; DC s.2, c. 2(b)) is a technical non-compliance, as it is in part dependent on full compliance with all other development consent conditions. The second non-compliance (NC-2; DC s.2, c. 17A) is due to the MOD13 boundaries have not been marked out by a registered surveyor across the entire site, and a survey plan of the revised boundaries with applicable GPS coordinates not having been submitted to the Secretary. Cristal Mining is proposing to discuss the logistics of this approval condition with the Department. This non-compliance has not led to any environmental harm, as ground disturbance is strictly controlled using computerised GPS location controls in earthmoving equipment and direct supervision of ground-clearing activities. The third non-compliance (NC-3; DC s.3, c. 28(e)(xiv)) arises from the lack of a conceptual decommissioning plan in the Radiation Management Plan August 2015 (RMP). The RMP needs to be revised to include a conceptual decommissioning plan, or to make reference to such a plan. The plan should also include specific reference to requirements for monitoring of radiation at the surface of rehabilitated land to reflect the reference to this monitoring made in the Ginkgo Mine Closure Plan TELFORD Page 12

16 Appendix A Endorsement of Appointment of David Telford to conduct the audit TELFORD Page 13

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19 Appendix B Completed Development Consent Condition Audit Checklist Ginkgo Mineral Sand Mine TELFORD Page 14

20 Appendix A Ginkgo Mine Development Consent Conditions Audit Checklist NSW Planning and Environment Development Consent Conditions DA MOD 13 (December 2017) Schedule 2. ADMINISTRATIVE CONTROLS Obligation to minimise harm to the environment 1. In addition to meeting the specific performance criteria established under this consent, the Applicant shall implement all reasonable and feasible measures to prevent and/or minimise any material harm to the environment that may result from the construction, operation, or rehabilitation of the development. All required environmental management plans have been prepared and are being implemented. The design of the management plans is to prevent or mitigate environmental harm from mining activities. Terms of consent 2. The Applicant shall: (a) carry out the development generally in accordance with the EIS; and (b) comply with the conditions of this consent. 3. If there is any inconsistency between the above documents, the more recent document shall prevail to the extent of the inconsistency. However, the conditions of this consent shall prevail to the extent of any inconsistency. 4. The Applicant shall comply with any reasonable requirement/s of the Secretary arising from the Department s assessment of: (a) any strategies, plans, programs, reviews, audits, reports or correspondence that are submitted in accordance with this consent; (b) any reports, reviews or audits commissioned by the Department regarding compliance with this consent; or (c) the implementation of any actions or measures contained in these documents. Non-compliant NC-1 N/A N/A Cristal Mining has complied with the conditions of this consent in all operational areas, apart from Schedule 2 Condition 17A, and Schedule 3 Condition 28(e)(xiv). No inconsistency has been identified. There have not been any requirements received from the Secretary other than those specified in the permit. TELFORD Page 15

21 Limits on consent Mining operations 5. The Applicant may carry out mining operations on site until the 6 March Notes: Under this consent, the Applicant is required to rehabilitate the site and perform additional undertakings to the satisfaction of either the Secretary or DRG. Consequently this consent will continue to apply in all other respects other than the right to conduct mining operations until the rehabilitation of the site and these additional undertakings have been carried out satisfactorily. Ore extraction The operations are continuing within the date limit. 6. The Applicant shall not extract more than 19.9 million tonnes of ore from the site in any calendar year. 2016: 5,948,753 tonnes of ore extracted. 2017: 6,104,886 tonnes of ore extracted. 2018: 3,549,456 tonnes of ore extracted from 1 January 2018 until cessation of ore extraction on September 15 due to plant failure. Mineral concentrate production 7. The Applicant shall not produce more than 576,000 tonnes of mineral concentrate from ore extracted from the site in any calendar year. 2016: 124,440 tonnes of mineral concentrate produced. 2017: 79,759 tonnes of mineral concentrate produced. 2018: 60,680 tonnes of mineral concentrate up to 15 September, when mineral concentration at Ginkgo Mine ceased. Transportation limits 8. The Applicant shall not transport more than 975,000 tonnes of mineral concentrate from the site and the Snapper Mine combined in a calendar year. 9. The Applicant may only transport mineral concentrate off-site via the haulage route (see Appendix 2) using RMS approved vehicles. 10. The Applicant may transport heavy mineral concentrate between the Snapper Mine and the Ginkgo Mine, limited to a maximum of 4 vehicle movements per hour. 2016: 660,810 tonnes of mineral concentrate transported. 2017: 805,547 tonnes of mineral concentrate transported. 2018: 671,335 tonnes of mineral concentrate transported (total Ginkgo plus Snapper projected for entire year from Jan to Oct figures. The approved mineral concentrate transport route is the only route used. All haulage vehicles are RMS registered. There is an average of three heavy mineral concentrate transport vehicle movements per hour, with one truck running 24 hours per day, taking an average of 40 minutes per round trip. TELFORD Page 16

22 11. A maximum of 300,000 tonnes per annum of processed waste material may be transported to the Ginkgo and Snapper Mines from the Broken Hill Mineral Separation Plant = 104,319 tonnes of processed waste transported = 100,742 tonnes of processed waste transported = 61,941 tonnes of processed waste transported (forecast). Hours of operation 12. The Applicant may operate the site 24 hours a day, 7 days per week. The site is operated 24 hours a day, 7 days per week Structural Adequacy 13. The Applicant shall ensure that all new buildings and structures, and any alterations or additions to existing buildings and structures, are constructed in accordance with the relevant requirements of the BCA. Notes: Under Part 4A of the EP&A Act, the Applicant is required to obtain construction and occupation certificates for the proposed building works. Part 8 of the EP&A Regulation sets out the requirements for the certification of the development. N/A There have not been any new buildings constructed in the past three years. Demolition 14. The Applicant shall ensure that all demolition work is carried out in accordance with Australian Standard AS : The Demolition of Structures, or its latest version. N/A There have not been any demolition works conducted in the past three years. Operation of Plant and Equipment 15. The Applicant shall ensure that all plant and equipment used at the site, or any equipment used for monitoring the performance of the development is: (a) maintained in a proper and efficient condition; and (b) operated in a proper and efficient manner. The Mainpac scheduler is used to manage the maintenance of all Cristal Mining equipment. Contractors provide their own maintenance programs. Cristal signs off on contractors equipment, which needs a new compliance sticker for equipment coming onto site. The contractors do prestart inspections which are checked by Cristal periodically. TELFORD Page 17

23 Staged Submission of Strategies, Plans or Programs 16. To ensure the strategies, plans or programs under this consent are updated on a regular basis, and that they incorporate any appropriate mitigation measures to improve the environmental performance of the development, the Applicant may at any time submit revised strategies, plans or programs to the Secretary for approval. With the agreement of the Secretary, the Applicant may also submit any strategy, plan or program required by this consent on a staged basis. With the agreement of the Secretary, the Applicant may revise any strategy, plan or program approved under this consent without consulting with all the parties nominated under the applicable conditions of consent. Identification of Approved Extraction Limits 17. By 30 April 2015, unless otherwise agreed with the Secretary, the Applicant shall: (a) engage a registered surveyor to mark out the boundaries of the approved limits of extraction within the entire site; and (b) submit a survey plan of these boundaries with applicable GPS coordinates to the Secretary. 17A. By 30 June 2018, unless otherwise agreed with the Secretary, the Applicant shall: (a) (b) engage a registered surveyor to mark out the revised boundaries of the approved limits of extraction within the entire site; and submit a survey plan of the revised boundaries with applicable GPS coordinates to the Secretary. 18. While mining operations are being carried out, the Applicant shall ensure that these boundaries are clearly marked at all times that allows operating staff to clearly identify the approved limits of extraction. Revised management plans and strategies are submitted to the department as they are prepared. (a) A registered surveyor identified the boundaries of the approved limits and recorded the surveyed coordinates. Sections of the boundary were marked as the mine progressed. (b) Copies of plans were submitted to the department by on 23 April 2015 and hard copies posted on the same day. Non-compliant NC-2 (a) (b) The MOD13 boundaries have not been marked out. Cristal Mining is proposing to discuss the logistics of this approval condition with the Department, given the strict survey controls in place at the mine using computerised GPS-based boundary location systems. A survey plan of the revised boundaries with application boundaries has not been submitted to the Secretary. They are now being prepared for submission. Mining boundaries where mining operations are being conducted are marked using surveyors pegs and tape. Boundaries are marked using tapes and paint markings in vegetated areas. Machinery operators are provided with GPS coordinates of the boundaries, mine plans. TELFORD Page 18

24 Notification of Commencement 19. The Applicant shall notify the Department and Council of its intention to commence mining operations at least two weeks prior to the commencement of mining operations at the Crayfish Deposit. Cristal Mining notified the Department of Planning and Wentworth Shire Council prior to commencement of topsoil stripping on 6 August 2018, advising of a proposed start date of 21 August. Planning Agreement 20. If the Applicant and Council enter into a Planning Agreement in accordance with Division 6 of Part 4 of the EP&A Act that provides for the Applicant to contribute to the maintenance of the haulage route between the Silver City Highway and the Ginkgo Mine and the Auxiliary Roads outlined in Appendix 7, the Planning Agreement replaces Conditions 4, 7 and 8 of Schedule 2. Cristal Mining has not entered into a planning agreement with Wentworth Shire Council. NB: This actually refers to Schedule 3 not 2. Schedule 3 SPECIFIC ENVIRONMENTAL CONTROLS Transport 1. The Applicant shall consult with relevant leaseholders and negotiate reimbursement at current market values for stock losses attributable to development traffic or other project-related activities. Compensation for any livestock losses is negotiated with the leaseholder at the time of any loss occurring. Monitoring of Mineral Concentrate Transport 2. The Applicant shall: (a) (b) keep accurate records of the amount of mineral concentrate transported from the site (on a monthly basis); and make these records publicly available on its website at the end of each calendar year. (a) Mineral concentrate transport records are recorded on a daily basis. (b) Mineral concentrate transport records are reported in the Annual Environmental Management Report (AEMR), which is published on the company website. TELFORD Page 19

25 Traffic Management Plan 3. The Applicant shall prepare and implement a Traffic Management Plan for the development, to the satisfaction of the Secretary. This plan must: (a) (b) (c) (d) (e) be prepared in consultation with RMS and Council; be submitted to the Secretary for approval within 6 months of the date of consent for MOD 9, unless otherwise agreed by the Secretary; include transport of hazardous material measures that would be implemented to address the relevant requirements of the Code of Practice for the Safe Transport of Radioactive Materials (ARPANSA, 2001 or its latest version); include an annual Traffic Monitoring Program to determine the proportion of project-related vehicle use on the Auxiliary Roads as defined in Appendix 7; and include a Traffic Code of Conduct for all drivers transporting materials to and from the site and for employees, including the measures that would be implemented to prioritise the use of the haulage route and Nob Road. The first annual Traffic Monitoring Program (and subsequent annual Traffic Monitoring Programs as directed by the Secretary) shall incorporate the following local roads within the Wentworth Local Government Area (in addition to those defined in Appendix 7) to determine the project-related use of these roads: Old Broken Hill Road (between the Silver City Highway and Roo Roo Road); Roo Roo Road (between Old Broken Hill Road and the Haulage Route); Nob Road (between the Haulage Route and Polia Road); Polia Road (between Nob Road and High Darling Road); and High Darling Road (between Polia Road and Pooncarie Road). Traffic Management Plan and Code of Conduct (September 2015) approved by Department of Planning by letter dated 20 January Haulage Road 4. The Applicant shall maintain the sections of the haulage route on public roads between the Silver City Highway and the Ginkgo Mine (including for the intersection of the haulage route and the Silver City Highway) to the satisfaction of the relevant road authority. Ongoing maintenance is carried out on the haulage road. Cristal Mining has not received any complaints or notices from Shire of Wentworth or RMS. TELFORD Page 20

26 5. Within 6 months of the date of consent for MOD 9, unless otherwise agreed with the Secretary, the Applicant shall commission an independent suitably qualified and experienced person endorsed by the Secretary to undertake a road safety audit of the haulage route between the Silver City Highway and the Ginkgo Mine (including the private sections of the haulage route and the intersection of the haulage route with the Silver City Highway). This audit must: a) be undertaken in consultation with Council and RMS; and b) recommend any necessary measures to ensure that the road complies with any relevant road safety requirements. 6. Within 1 month of receiving the audit report, or as otherwise agreed with the Secretary, the Applicant shall submit a copy of the report to the Secretary, with a detailed response to any of the recommendations contained in the audit report, including a timetable for the implementation of any reasonable and feasible measures proposed to address the recommendations in the audit report. Any road works recommended in the Independent Road Safety Audit must be undertaken in accordance with this timetable to the satisfaction of the relevant road authority, unless otherwise agreed with the Secretary. Cristal Mining engaged WaySafe to conduct a road safety audit of the Ginkgo haul road between the Silver City Highway and the site. The audit was commissioned on 20 March 2015 and completed in September The report identified 16 Issues for Project Manager Consideration. Cristal Mining prepared a Road Safety Audit Response report in which a response and risk rating was identified for each issue for consideration. A copy of the audit report and the Cristal Mining response plan was sent by to the Department of Planning on 13 October Auxiliary Roads 7. The Applicant shall make annual contributions for the maintenance of the Auxiliary Roads in accordance with Appendix If directed by the Secretary in accordance with condition 4 of schedule 2, the Applicant shall make contributions to Council for standard maintenance activities (as defined in Appendix 7) on the additional local roads listed in condition 3 of schedule 3. The contribution shall be calculated in accordance with the methodology in Appendix 7. In determining whether additional contributions are warranted, the Secretary must have regard to: (a) the findings of the Traffic Monitoring Program (see condition 3 above); and (b) the residential location of the Applicant s workforce using the additional local roads. Cristal sends their road count results to Council, which compares them to Council s own counts, after which a percentage contribution from the mine is determined. Council then invoices Cristal for the percentage road usage. See Traffic Management Plan. No direction has been received from the Secretary. TELFORD Page 21

27 Soil & Water Note: Under the Water Act 1912 and/or the Water Management Act 2000, the Applicant is required to obtain the necessary water licences for the development. Cristal has obtained Water Access Licence 27915, which permits extraction of 7,402 ML per annum. Water Supply 9. The Applicant shall ensure that it has sufficient water for all stages of the development, and if necessary, adjust the scale of mining operations to match its available water supply and licenced water entitlements, to the satisfaction of the Secretary. Cristal has obtained Water Access Licence 27915, which permits extraction of 7,402 ML per annum. Groundwater at Ginkgo Mine is accessed using the following bores: Bore Licence Number P1 P2 P3 P4 P5 P6 06BL BL BL BL BL BL Water Pollution Groundwater usage has been: ,954 ML ,313 ML ,290 ML to end of October. 10. Unless an EPL authorises otherwise, the Applicant shall comply with Section 120 of the Protection of the Environment Operations Act 1997 during the carrying out of the development. There are no waterways in the area in which the mine is located. The closest waterway is the Darling River, which runs approximately 28 km to the east of the site. Wastes or other pollutants are not discharged to waters. TELFORD Page 22

28 Water Management Plan 11. The Applicant shall prepare and implement a Water Management Plan for the development to the satisfaction of the Secretary. This plan must be prepared in consultation with CL&W, by suitably qualified and experienced person/s whose appointment has been endorsed by the Secretary, and submitted to the Secretary for approval by 31 March 2016, unless otherwise agreed with the Secretary. This plan must include: The Murray Basin Mines Water Management Plan, September 2015 was prepared and a copy sent by to the Department on 18 September 2015 (incorrectly labelled as Borefield Impact Management Plan 2015 in the attachment). The plan has since been revised and is now titled the Ginkgo and Snapper Mines Water Environmental Management Plan, October (a) a water balance for the development that includes details of: sources and security of water supply; water licences; water make/use; and any water discharges; and 11 (b) management plans for the surface facilities, that include: a detailed description of water management systems for each site; measures to reuse and recycle water; measures to manage the quality and quantity of surface and ground water; salinity management measures including design measures to minimise any lateral seepage of brackish water from the water dams, emplacements areas and/or sand residue dams; contingency plans to deal with any lateral salt water seepage and/or leachate seepage or breakdown in the dam linings; and monitoring and reporting procedures, including: - the volume of pumped leachate; and - the holding dam water; and Section 2.5 of the Water Management Plan. Section 2.7 of the Water Management Plan. TELFORD Page 23

29 11 (c) erosion and sediment control measures that must: be consistent with the requirements of Managing Urban Stormwater, Soils and Construction Volume 2E Mines and Quarries, (DECC 2008), or the latest edition; describe measures to minimise soil erosion and the potential for the transport of sediment off site; describe the location, function, and capacity of erosion and sediment control structures; and describe what measures would be implemented o maintain these structures over time, and 11 (d) a Borefield Impact Management Plan that includes: data to benchmark the natural variation in groundwater levels and quality; a detailed program to monitor the groundwater impacts of the development; groundwater impact trigger levels for relevant landholder bores; and a protocol for the investigation, notification and mitigation of any identified exceedances of the groundwater impact assessment criteria. Noise Noise Impact Assessment Criteria Section 4.3 of the Water Management Plan. The Borefield Impact Management Plan has been incorporated into the Ginkgo and Snapper Mines Water Environmental Management Plan, October Borefield mitigation measures addressing the required actions are identified in section 4.4 of the Water Management Plan. 12. The Applicant shall ensure that the noise generated by the development does not exceed 35dB(A) LAeq(15 minute) at any residence on privately-owned land. Note: Noise generated by the development is to be measured in accordance with the relevant requirements, and exemptions (including certain meteorological conditions), of the NSW Industrial Noise Policy. Appendix 5 sets out the meteorological conditions under which these criteria apply, and the requirements for evaluating compliance with these criteria. However, these noise criteria do not apply if the Applicant has an agreement with the relevant landowner to generate higher noise levels, and the Applicant has advised the Department in writing of the terms of this agreement. Cristal Mining suspended noise monitoring in accordance with a written agreement made with the station owners and following consultation with the Department of Planning. See further details below. TELFORD Page 24

30 Noise Monitoring Program 13. The Applicant shall prepare and implement a Noise Monitoring Program for the development to the satisfaction of the Secretary. This plan must: (a) be submitted to the Secretary for approval within 6 months of the date of consent for MOD 9, unless otherwise agreed with the Secretary; (b) describe the measures that would be implemented to ensure compliance with the noise criteria and operating conditions in this consent; (c) include a monitoring program that: uses attended monitoring to evaluate the compliance of the development against the noise criteria in this consent; and defines what constitutes a noise incident, and includes a protocol for identifying and notifying the Department and relevant stakeholders of any noise incidents. Department sent a letter to 26/10/17 to Cristal Mining asking them to update the Noise Monitoring Plan to reflect the proposed suspension of noise monitoring. On 26 June 2018 the Department ed a request for the Noise Management Plan to be revised to include details of how compliance with condition 13(c) of this consent would be managed and demonstrated. Cristal Mining forwarded a revised Noise Management Plan to the Department on 25 October 2018 for its consideration. TELFORD Page 25

31 Air Quality Air quality criteria 14. The Applicant shall implement all reasonable and feasible mitigation measures to ensure that the particulate emissions generated by the development do not exceed the criteria listed in Tables 1, 2 and 3 at any residence on privately-owned land. Table 1: Long-term criteria for particulate matter Pollutant Averaging period d Criterion Total suspended particulate (TSP) matter Annual a 90 μg/m 3 Particulate matter < 10 μm (PM 10) Annual a 30 μg/m 3 Table 2: Short-term criteria for particulate matter Pollutant Averaging period d Criterion Total suspended particulate (TSP) matter Annual a 50 μg/m 3 Table 3: Long-term criteria for deposited dust Pollutant Averaging period Maximum increase in deposited dust level Maximum total deposited dust level c Deposited dust Annual a 2 g/m 2 /month a 4 g/m 2 /month Murray Basin Mineral Sands Mines Air Quality Management Plan September This has been updated to include Crayfish. Monitoring requirements are specified in section 4.5 of the plan. TELFORD Page 26

32 Operating conditions 15. The Applicant shall: (a) implement all reasonable and feasible measures to minimise odour and dust emissions generated by the development; (b) ensure all loaded vehicles entering or leaving the site (with the exception of vehicles transporting heavy mineral concentrate between Snapper Mine and Ginkgo Mine) have their loads covered; (c) minimise the air quality impacts of the development during adverse meteorological conditions and extraordinary events (see note d to Tables 1-3 above); (d) co-ordinate the air quality management on site with the air quality management of the Snapper Mine, to minimise cumulative air quality impacts; and (e) implement all reasonable and feasible measures to minimise the release of greenhouse gas emissions from the site, to the satisfaction of the Secretary. (a) Few potential odour sources are present on site. The onsite waste landfill is covered with inert material weekly to control odour and vermin. Pre-consumer vegetable kitchen wastes are fed to onsite hens. Sewage is treated using a purposebuilt system that has been increased in capacity to meet mine and accommodation camp needs. (b) All loaded vehicles entering or leaving the site are covered with fitted hydraulic to present loss of load during transport. (c) Dust control measures are specified in the Air Quality Management Plan and are implemented. (d) Air quality management on the Ginkgo site is being coordinated with the air quality management of the Snapper Mine. (e) Fuel conservation is exercised as a business imperative for all earthmoving equipment. This includes the minimisation of movement of earth including overburden through strategic mine planning. Cristal Mining requires all contractor vehicles to be properly maintained, which includes good engine condition, reducing excessive fuel burn. Air Quality Monitoring Program 16. The Applicant shall prepare and implement an Air Quality Monitoring Program for the development to the satisfaction of the Secretary. This plan must: (a) (b) (c) (d) be prepared in consultation with EPA, and submitted to the Secretary for approval within 6 months of the date of consent for MOD 9, unless otherwise agreed with the Secretary; describe the reasonable and feasible measures that would be implemented to ensure compliance with the relevant air quality criteria and operating conditions of this consent; describe the proposed air quality management system; and defines what constitutes an air quality incident, and includes a protocol for identifying and notifying the Department and relevant stakeholders of any air quality incidents. (a) Letter of approval of Air Quality Management Plan (September 2015) was received from NSW Department of Planning & Environment, January (b) (c) (d) The plan (section 4.3) describes air quality protection measures to ensure compliance with the consent. The plan (section 4) provides an air quality management program. Incidents and their management are defined in section 4.7 of the plan. TELFORD Page 27