ENVIRONMENTAL MANAGEMENT PLAN

Transcription

1 ENVIRONMENTAL MANAGEMENT PLAN

2 Toro Energy Limited ABN Level 3, 33 Richardson Street, West Perth, WA, DOCUMENT REF REVISION DATE PREPARED BY CHECKED AUTHORIZED AUTHORIZED FOR USE A Jun 2015 A Tandy L Chandler

3 TABLE OF CONTENTS 1 INTRODUCTION Purpose Structure of the EMP Scope of the EMP GENERAL DESCRIPTION Location Existing Physical Environment Climate Zones Temperature Rainfall Evaporation Local Geology Historical Land Use Lake Way and Lake Maitland Existing Social Environment Aboriginal Heritage Other Land Uses LEGAL AND OTHER REQUIREMENTS Relevant Legislation and Standards Key Project Approvals Ministerial Approvals Secondary and Tertiary Approvals VEGETATION AND FLORA MANAGEMENT PLAN Environmental Factor Purpose and Objective Relevant Legislation and Standards Existing Environment Region Vegetation Conservation Significant Species Rare and Priority Flora Species Tecticornia Roles and Responsibilities Environmental Management Purpose Potential Impacts Environmental Objective and Performance Indicators Environmental Management Strategies Monitoring Monitoring Programmes Weed Monitoring Vegetation Condition and Baseline Monitoring Rehabilitation Monitoring Interpretation of Results Trigger Levels Contingencies Review and Revision GROUNDWATER DEPENDENT VEGETATION MANAGEMENT PLAN Environmental Factor Relevant Legislation and Standards Existing Environment Roles and Responsibilities Overview of Potential Impacts Clearing Groundwater Abstraction Page iii

4 5.5.3 Drought Changes to Groundwater Characteristics Environmental Objectives, Targets and Indicators Management Strategies and Actions Key Strategies Monitoring and Management Actions Trigger Levels Contingencies Reporting Review and Revision TERRESTRIAL FAUNA MANAGEMENT PLAN Environmental Factor Relevant Legislation and Standards Existing Environment Vertebrate Fauna Species Short range Endemic Fauna Roles and Responsibilities Environmental Management Overview of Potential Impacts Clearing and Ground Disturbance Introduced Flora Deliberate Interference with Animals Interactions with Vehicles Noise and Vibration Light Dust Introduced Fauna Fire Hydrocarbon and Chemical Spills Waste Management Pregnant Liquor Solution and Other Evaporation Ponds Environmental Objectives Targets and Indicators Environmental Management Strategies and Actions Key Strategies Monitoring Trigger Levels Contingencies Reporting Review and Revision SUBTERRANEAN FAUNA MANAGEMENT PLAN Environmental Factor Introduction Relevant Legislation and Standards Existing Environment Centipede and Millipede Lake Way West Creek Borefield Lake Maitland and Borefield Roles and Responsibilities Environmental Management Potential Impacts Dewatering Pit Excavation Tailings Deposition Groundwater Reinjection Spills and Localised Contamination Environmental Objectives and Performance Indicators Page iv

5 7.8 Environmental Aspects and Management Strategies Monitoring Trigger Levels Contingencies Interpretation and Reporting Review and Revision SURFACE WATER MANAGEMENT PLAN Environmental Factor Purpose of the Plan Relevant Legislation and Standards Roles and Responsibilities Environmental Management Purpose Potential Impacts Management of Potential Impacts Environmental Objectives and Performance Indicators Environmental Aspects and Management Strategies Monitoring Trigger Levels Contingencies Reporting Review and Revision GROUNDWATER DRAWDOWN MANAGEMENT PLAN Environmental Factor Purpose of the Plan Relevant Legislation and Standards Legislation Standards and Guidelines Existing Environment Roles and Responsibilities Environmental Management Purpose Potential Impacts Managing Potential Impacts Environmental Objectives and Performance Indicators Environmental Aspects and Management Strategies Monitoring Trigger Levels Contingencies Reporting Review and Revision DUST MANAGEMENT PLAN Environmental Factor Purpose and Objective Relevant Legislation and Standards Existing Environment Region Climate Regional Dust Levels Objectives and Criteria Predicted Dust Emissions Roles and Responsibilities Environmental Management Potential Impacts Dust Management Measures Monitoring Standards and Guidelines Page v

6 System overview At source monitoring Interpretation of Results Trigger Levels Contingencies Review and Revision NOISE MANAGEMENT PLAN Environmental Factor Introduction Relevant Legislation and Standards Roles and Responsibilities Environmental Management Potential Noise Impacts Noise and Vibration Environmental Objectives and Performance Indicators Environmental Aspects and Management Strategies Design Monitoring Trigger Levels Contingencies Reporting Review and Revision FIRE MANAGEMENT PLAN Environmental Factor Introduction Relevant Legislation and Standards Existing Environment Roles and Responsibilities Environmental Management Purpose Potential Impacts Fire Management Internal Management Naturally Occurring Fires Prescribed Burns Environmental Objectives and Performance Indicators Environmental Aspects and Management Strategies Monitoring Reporting Review and Revision WASTE MANAGEMENT PLAN Environmental Factor Purpose Relevant Legislation, Approvals and Guidelines Legislation Guidelines Approvals Roles and Responsibilities Environmental Management Waste Streams General Wastes Non process Liquid Wastes Controlled Wastes Waste Management Hierarchy Waste Management Practices Monitoring Performance Indicators Records, Review and Reporting Page vi

7 14 REPORTING Annual Reports Annual Environment Report Annual Compliance Report Annual Radiation Report Reporting Of Non compliances Auditing and Review EMP Review EMP Audit DEFINITIONS AND ABBREVIATIONS REFERENCES TABLE OF FIGURES Figure 2.1: Project Location Figure 2.2: Location of the Processing Plant Figure 4.1: Land Systems of the Project Area Figure 9.1: Centipede and Millipede Modelled Drawdowns Figure 9.2: Lake Maitland Modelled Drawdowns Figure 9.3: Lake Way Modelled Drawdowns Figure 9.4: Lake Maitland Borefield Modelled Drawdowns Figure 9.5: West Creek Borefield Modelled Drawdowns Figure 10.1: Dust Deposition across the Centipede Deposit Figure 10.2: Predicted Dust Depositions at Lake Maitland Figure 10.3: Predicted Millipede Dust Deposition Levels Figure 10.4: Lake Way Dust Deposition TABLE OF TABLES Table 4.1: Roles and Responsibilities Table 4.2: Environmental Objectives and Performance Indicators Table 4.3: Environmental Aspects and Management Strategies Table 4.4: Trigger Levels for Vegetation Assessment Table 5.1: Summary of Groundwater dependent Vegetation in the Toro Energy Wiluna Uranium Project Table 5.2: Roles and Responsibilities Table 5.3: Objectives, Targets and Indicators Table 5.4: Management Actions Table 6.1: Roles and Responsibilities Table 6.2: Environmental Performance Indicators Table 6.3: Environmental Management Aspects and Strategies Table 7.1: Roles and Responsibilities Table 7.2: Environmental Objectives and Performance Indicators Table 7.3: Environmental Aspects and Management Strategies Table 7.4: Subterranean Fauna Monitoring Table 7.5: Stygofauna Impacts Trigger Levels Table 8.1: Roles and Responsibilities Table 8.2: Environmental Objectives and Performance Indicators Table 8.3: Environmental Aspects and Management Strategies Table 9.1: Roles and Responsibilities Table 9.2: Environmental Objectives and Performance Indicators Table 9.3: Environmental Aspects and Management Strategies Table 9.4: Mine Dewatering Monitoring Schedule Table 9.5: Borefield Monitoring Schedule Table 10.1: Location of Nearest Sensitive Receivers Table 10.2: Dust Management Objective and Performance Criteria Table 10.3: Roles and Responsibilities Page vii

8 Table 10.4: Australian Standards for Dust Monitoring Table 10.5: Risk Assessment and Contingency Actions Table 11.1: Roles and Responsibilities Table 11.2: Environmental Objectives and Performance Indicators Table 11.3: Environmental Aspects and Management Strategies Table 12.1: Roles and Responsibilities Table 12.2: Environmental Objectives and Performance Indicators Table 12.3: Environmental Aspects and Management Strategies Table 13.1: Roles and Responsibilities Table 13.2: Waste Management Practices Table 13.3: Waste Management Practices Page viii

9 1 INTRODUCTION 1.1 Purpose The purpose of this (EMP) is to outline the management of potential environmental impacts at the Wiluna Uranium Project (the Project), including its extension. This document contains a series of plans that were specified as being a requirement to implement the Project under federal Ministerial Approval (EPBC 2009/5174) and state Ministerial Approval (Ministerial Statement No. 913). The plans will also be used to support the extension to the Wiluna Uranium Project, which is currently undergoing assessment at both state and federal levels. This EMP has been prepared by Toro Energy Limited (Toro), as proponent of the Project. It is being submitted to the Environmental Protection Authority (EPA) with the Public Environmental Review (PER) as part of the environmental assessment and approvals process. This EMO has been prepared based on: Toro s Environmental Policy; Toro s Occupational Health and Safety Policy; Relevant Commonwealth and Western Australian legislation; Other legal obligations; Identified potential direct and indirect environmental impacts from risk assessments; Consultants reports; Relevant permits and standards; and Toro s commitment to continuous improvement. This plan is a live document that will be reviewed at least every two years; however, monitoring results may dictate that more frequent reviews are required. Reviews will also occur prior to Project construction, and any other changes to the Project that would require further evaluation and possible management of environmental hazards. 1.2 Structure of the EMP This EMP is designed to be a management tool for use by Toro personnel, contractors and visitors to ensure the highest standard of environmental management and protection is achieved throughout the life of the Wiluna Uranium Project. The EMP contains a series of specific plans to deal with environmental impacts identified by Toro. It outlines methods and procedures required to achieve the Project s environmental commitments and obligations. The specific aims of the EMP are to: Summarise the relevant environmental factors potentially affected by the Project; Detail control measures to be implemented to mitigate the potential environmental impacts of the Project; Designate roles and responsibilities to ensure accountability for compliance with the requirements of the EMP is maintained; and Detail the monitoring and reporting process. This EMP provides a reference for monitoring, reporting and auditing as necessary to minimise identified and potential environmental impacts of the Project. This EMP has been developed to: Demonstrate how Toro intends to minimise the potential impact of activities associated with the construction and operational phases of the Project; Describe proposed monitoring activities; Describe environmental management controls for the life of the Project; Page 1 1

10 Demonstrate reporting, auditing and review mechanisms; Provide a procedure for dealing with emergency events; Outline procedures for consultation and complaints; and Guide the development of other site specific plans and procedures relevant to the Project. 1.3 Scope of the EMP This EMP covers the following Project activities: Construction and mining at the Centipede/Millipede, Lake Maitland and Lake Way deposits; Construction and operation of a processing, product packing and handling facility; Development of the West Creek and Lake Maitland borefields; and General infrastructure including an accommodation village, mine administration buildings and workshops, haul roads, power generation and transmission facilities, communications systems and water and waste management. This EMP is broken into sections that each deal with specific issues or impacts. They are: Flora; Terrestrial fauna; Subterranean fauna; Groundwater drawdown; Surface water; Fire; Dust; Noise; Waste; and Closure and rehabilitation. The individual plans have been incorporated into one document to avoid unnecessary duplication and repetition. Background information relevant to the Project is included in Section 2 of this EMP. The specific management of environmental issues is then dealt with in the Environmental Management section in each plan. Page 1 2

11 2 GENERAL DESCRIPTION 2.1 Location The Wiluna Uranium Project is based on four deposits, Centipede, Millipede, Lake Maitland and Lake Way, located to the south east of the town of Wiluna in the northern Goldfields region of Western Australia (Figure 2.1). The Centipede, Millipede and Lake Way deposits are on the shores of Lake Way. Each deposit is shallow, existing between 1 15 m below natural ground level. Mining of the deposits would use surface miners and truck and shovel methods to access the ore. No drill and blast would required. The Lake Maitland deposit is slightly different in that it is situated in the body of, rather than on the shore of Lake Maitland. In other respects however, Lake Maitland is similar to the other three deposits in that it is shallow and surface miners can be used to mine it. Ore from all four deposits would be processed at a central processing facility located to the west of the Centipede and Millipede deposits (Figure 2.2). Tailings from all four deposits would be stored in the mined out Millipede and Centipede pit voids, which would be lined with compacted clay prior to tailings deposition. At Lake Way and Lake Maitland, waste rock would be used to fill the voids to ensure no open pits are left at Project closure. Progressive rehabilitation would be undertaken to minimise mining areas kept open throughout the life of the Project. No above ground structures would be left at Project closure, and the areas disturbed returned as close as practicable to pre mining conditions when mining ceases. Page 2 1

12 Figure 2.1: Project Location Page 2 2

13 Figure 2.2: Location of the Processing Plant 2.2 Existing Physical Environment Climate Zones Western Australia has three broad climate zones. The northern part is dry tropical, receiving summer rains in a wet season lasting from December to March. The south west corner of the state has a Mediterranean climate, with long hot summers and wet winters. The remainder, in which the Project area falls, is mostly arid desert. The climate in the Project area is arid to semi arid and is characterised by relatively low annual rainfall, hot dry summers and mild dry winters. In summer, anti cyclone systems are evident with hot days and easterly winds prevalent, and occasional thunderstorm activity. Remnant tropical cyclones occasionally move south west across the region. In winter, anti cyclones move from west to east, providing westerly winds across the region. Depressions result in frontal systems that can produce significant rainfall from late May to early August Temperature The closest weather station to the Project is the Wiluna weather station located at the town. The mean daily maximum temperatures at Wiluna range from 37.8 C in January to 19.2 C in July. Mean daily minimum temperatures range from 22.9 C in January to 5.3 C in July (BoM, 2015). Page 2 3

14 2.2.3 Rainfall The most relevant and long term rainfall record is available from Wiluna, located in the centre of the Lake Way catchment. The Wiluna rainfall record has a complete daily rainfall record available from 1907 to the present. The mean annual rainfall is approximately 257 mm, but varies from in excess of 700 mm to less than 50 mm. The highest and most reliable rainfall occurs between May and August. Intense tropical cyclone related rainfall events may occur between December and April (ibid) Evaporation The annual average evaporation within the Project area is more than 3400mm. The evaporation is highest in the summer months from November to February. Mean monthly evaporation always exceeds mean monthly rainfall (ibid) Local Geology Data from the Geological Survey of Western Australia (Elias and Bunting, 1982) indicates that the Project area is largely encircled by bedrock outcrop, as follows: In the northern and north western periphery of the Project area, the bedrock comprises the Finlayson Member of the Yerrida Group, described as a quartz arenite with subordinate siltstone. In the southern periphery, Archean granitoids occur (Yilgarn Craton). The eastern periphery of the Project area is dominated by metamorphosed Archaean felsic volcanic and volcaniclastic sedimentary rocks (Yilgarn Craton). The Geological Survey of Western Australia also indicates the following surficial geology in the Project area: Sheetwash deposits (comprising of clay, silt and sand) are reported to cover most of the Project area. Alluvium is indicated in areas shown to be watercourses. Calcrete outcrops along the upstream reaches of the West Creek River in the narrow valley passing through the Finlayson Range in the north of the Project area. A well developed, relatively extensive delta shaped body of calcrete extends from the West Creek Borefield to the edge of Lake Way. Exploration drilling in the vicinity of this borefield indicates that the calcrete is approximately 5 20 m thick, and that it extends further northwards beneath the soil cover. In summary, the Project area is mostly covered by alluvial sheetwash sediments, with calcrete zones developed along the main drainage system, all underlain by a number of consolidated Archaean and Proterozoic units Historical Land Use The Murchison Region, in which the Project lies, is sparsely populated. Non indigenous land use in the area has mainly involved mining and mineral exploration and pastoral activities. Considerable mineral exploration has been carried out in the Project area since the late 1970s. This has included extensive drilling, sampling and discharge of excess mine water into Lake Way. Previous tenement holders have also excavated costeans and pits to recover bulk samples for metallurgical testing. Existing disturbance in the Millipede Centipede area includes vehicular tracks and disturbance associated with grazing and pastoral uses of the land. The condition of vegetation in the Project area is described as generally being good to very good, although the effects of fire, grazing and low level exploration activities are apparent. The Project area is generally free of weed infestation. Page 2 4

15 2.2.7 Lake Way and Lake Maitland The Project area is characterised by large palaeodrainage systems spanning from north west to south east which have been largely in filled by sedimentary sands (palaeochannels), with overlaying clays. The position of these palaeochannels is marked by chains of salt lakes. Lake Way has a surface area of approximately 245 km 2 (Aquaterra, 2010). The lake forms the drainage basin for an 11,000 km 2 catchment (ibid). Elevations in the region range from RL490 m at the lake itself to RL650 in the upper reaches of the catchment. Lake Maitland forms part of a 150,000 km 2 catchment and lies down stream of Lake Way. Elevations at Lake Maitland vary from RL 470 m at the lake to RL 590 m in the upper reaches of the catchment (Golder Associates, 2011). Regional surface water flows are very intermittent and only occur after periods of heavy rainfall. The dry climate and high rates of evaporation mean that soils in the Project area soak up rainfall readily and it is only once these soils become water logged that surface water flows begin (ibid). Both Lake Way and Lake Maitland remain dry except after periods of heavy rainfall, and neither has been completely full since Cyclone Bobby in 1995 (RPS Aquaterra, 2010a). Moderate surface water sampling has been undertaken by Toro at locations accessible during periods of heavy rain. Generally water in the region is of high quality reflecting the origins of the water. Surface water quality remains high until flows interact with playas around lake edges of and between lakes Way and Maitland (ibid. 2010b). Once this interaction occurs, waters tend to become more saline reflecting the nature of the local soils and sediments. 2.3 Existing Social Environment Aboriginal Heritage The Wiluna People were awarded Native Title in 2013 to land which includes the Lake Way, Centipede and Millipede deposits. Since 2007, Toro has engaged the Wiluna People to undertake heritage surveys (both ethnographic and archaeological) across the three deposits. Toro s design of the Project has taken into account cultural heritage issues raised by the Wiluna People during this engagement. Toro has a Cultural Heritage Management Plan (a separate Appendix to this PER) that would with the management of heritage sites and a range of other issues in the Project area. There is currently no claim over the Lake Maitland deposit. Toro is working with Aboriginal People with an interest in Lake Maitland to assist them with the development and submission of a Native Title claim. Heritage surveys have been undertaken at Lake Maitland and Toro has committed to undertake any further survey work necessary to identify the cultural heritage values of the land on which development would occur. Land in the region has been used by Traditional Owners for law, ceremonial, hunting and other traditional activities. It is Toro s intention that at the cessation of mining, disturbed areas would be left in a condition that enabled a continuation of these activities Other Land Uses Historically, land in the vicinity of Wiluna has been used for the raising of sheep and cattle. The Project is situated entirely on the Lake Way, Millbillillie and Barwidgee pastoral leases that currently run cattle operations. Toro holds the leases to all three properties. Page 2 5

16 3 LEGAL AND OTHER REQUIREMENTS The Wiluna Uranium Project would comply with all relevant federal, state and local government laws and regulations. 3.1 Relevant Legislation and Standards A range of legislative and regulatory requirements and standards are applicable to each plan in this document. The relevant legislation, regulations and standards are outlined in the individual plans. 3.2 Key Project Approvals The key environmental approvals required to enable implementation of the Project are discussed below. All approvals, licences and permits would be maintained within Toro s Environmental Management System, with hard copies held on site for ready access by relevant personnel Ministerial Approvals Toro referred the Wiluna Project to both the Western Australian and federal governments on 27 October This referral was for proposed mining at Centipede and Lake Way and all associated infrastructure. The assessment for the Project was set at the Environmental Review and Management Program level by the Government of Western Australia the highest level that could be set. As the Project triggered the nuclear action clause of the Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act), it was also assessed at a federal level. On 10 October 2012, state approval was received for the Project and federal approval followed on 2 April The conditions of the approval from each level of government are contained within Ministerial Statement No. 913 (state) and Assessment EPBC 2009/5174 (federal). The plans required to comply with the various ministerial approvals are: Vegetation and Flora Monitoring Plan; Groundwater Dependent Vegetation Monitoring Plan; Tecticornia Survey and Research Plan; Stygofauna Monitoring Plan; Cultural Heritage Management Plan; and Wiluna Project (this document). All of these plans are to be developed and submitted to the various government agencies for approval three months before the scheduled commencement of Project construction Secondary and Tertiary Approvals Toro has developed a secondary and tertiary approvals register which outlines all other approvals required prior to the commencement of ground disturbing activities and then operations. The following activities would be required to be licenced under the Environmental Protection Act 1986 (EP Act) (WA), the Rights in Water and Irrigation Act 1914 (WA) and other relevant legislation prior to their commencement: Processing or beneficiation of metallic or non metallic ore; Mine dewatering; Waste water treatment plant construction; Concrete batching plant; Page 3 1

17 Desalination plant; Electric power generation; Construction for a landfill site; Section 5C licence to take groundwater; Permits to transport and export radioactive materials; and Building licences for facilities such as the accommodation camp and mine administration buildings. Page 3 2

18 4 VEGETATION AND FLORA MANAGEMENT PLAN 4.1 Environmental Factor To maintain representation, diversity, viability and ecological function at the species, population and community level. 4.2 Purpose and Objective The Wiluna Uranium Project would involve the progressive clearing of approximately of vegetation, including clearing for mine pits, access routes, processing infrastructure, haul roads and all other infrastructure required to allow mining. Clearing within government conditions of approval would occur on an as needed basis, with areas remaining undisturbed for as long as possible. The Project intends to practice progressive rehabilitation, ensuring that once disturbed areas are no longer required, they are returned to an agreed condition. Toro has a goal to return disturbed areas to as close to pre mining conditions as practicable. The purpose of this Vegetation and Flora Management Plan is to meet legislative and regulatory requirements and provide a framework for Toro to comply with all environmental obligations over the life of the Project. 4.3 Relevant Legislation and Standards Legislation and standards applicable to this management plan include: Environmental Protection and Biodiversity Conservation Act 1999 (Cwlth); Environmental Protection Act 1986 (WA); Wildlife Conservation Act 1950 (WA); and EPA Guidance Statement No. 51 Guidance for the Assessment of Environmental Factors, Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment. 4.4 Existing Environment Region The Interim Biogeographic Regionalisation for Australia (IBRA) classifies Australia into regions or bioregions of similar geology, landform, vegetation, fauna and climate characteristics (DSEWPAC, 2012). The Wiluna Uranium Project lies within the Murchison Bioregion which is described as having low hills and mesas separated by flat colluvium and alluvial plains. The region is further subdivided into the East Murchison and the Western Murchison subregions. The East Murchison comprises the northern section of the Yilgarn Craton and includes extensive areas of red sandplains and breakaway complexes with minor dune development (Cowan, 2011). The vegetation is dominated by mulga woodlands often rich in ephemerals, hummock grasslands, saltbush shrublands and Halosarcia shrublands. The climate is arid and receives an annual rainfall of less than 200 mm, mainly during winter. The subregion is characterised by its internal drainage, with salt lake systems associated with the occluded palaeodrainage system (ibid). Land systems are defined as areas or groups of areas for which there are recurring patterns of topography, soil and vegetation (Curry et al., 1994). The land systems in the Project area were mapped by Mabbut et al. (1963). The Project area incorporates 16 land systems, as shown in Figure 4.1. Page 4 1

19 Figure 4.1: Land Systems of the Project Area Vegetation Level 2 flora and vegetation surveys have been undertaken across all areas of the Project that may be disturbed. A Level 2 survey of the Millipede tenements was completed by Niche Environmental Services in Engenium undertook a Level 2 survey of the haul road and target surveys for species of conservation significance in 2014 and Outback Ecology Services undertook surveys across the Lake Maitland deposits between 2007 and These surveys were in addition to those undertaken to support the assessment of proposed mining at Centipede and Lake Way. The surveys identified that vegetation condition within the region was generally good, noting however, that mining and cattle grazing activities had impacted on vegetation communities. In summary, the surveys found that vegetation throughout the planned disturbance areas are well represented throughout the greater region and no Declared Rare Flora (DRF) were present. Several priority species were identified as occurring throughout the Project area, all of which are discussed below. 4.5 Conservation Significant Species Rare and Priority Flora Species No Declared Rare Flora were identified as occurring across the Project area in either historical database searches or in field surveys. At Millipede, Stackhousia clementii were found to be present at the southern end of Millipede tenement M53/1095. Specimens were recorded in nine different locations with around 300 individuals recorded in total. The species was widespread across the survey area and was found Page 4 2

20 outside planned disturbance areas. Targeted searches were undertaken across the Millipede tenements for Eremophila arachnoides Chinnock subsp. arachnoides. A significant search effort found that in the Acacia woodland habitat adjacent to and behind the planned mining areas, the density of the species was expected to be very high, approximately 55 plants per hectare. Across the haul road, two priority species were recorded as present, Eremophila pungens (Priority 4) and Tecticornia cymbaformis (Priority 3). Both species were present inside the haul road alignment corridor and were also found in areas outside the alignment. Tecticornia cymbaformis was also found to be present across the Lake Maitland deposit. Again, species were recorded both inside and outside the disturbance areas, meaning the Project would have little impact on the species. Cratystylis centralis (Priority 3) was also recorded at Lake Maitland, but again was also recorded outside the disturbance area. Overall, Project impacts on priority species are expected to be low due to the high levels of representation of priority species both inside and outside the disturbance areas Tecticornia Ecologia undertook surveys to further define Tecticornia communities and identify any species of conservation significance. Studies were undertaken across Millipede and Lake Maitland in mining and non mining areas and 16 communities were identified (Ecologia Environment, 2015). No species of conservation significance were recorded during the surveys. There was some degree of similarity between the communities found across each lake system and most taxa recorded during the surveys were abundant. 4.6 Roles and Responsibilities The roles and responsibilities for the implementation and management of the Flora and Vegetation Management Plan are provided in Table 4.1. Table 4.1: Roles and Responsibilities Position Responsibility Environmental Manager Implementation and maintenance of the plan. Undertake assessment and review of the effectiveness of the plan, and make changes as required. Ensure the outcomes of the management remain complaint with approvals. Environmental Superintendent Formulate and implement flora and vegetation surveys, monitoring programs and liaise with stakeholders regarding feral animal control. Ensure all staff are aware of their obligations in relation to this plan. Deliver flora and vegetation education and induction awareness training to field personnel. Maintain site records of surveys and implement monitoring programs. Operations Managers and Site Supervisors Ensure plan is being adhered to by staff. Ensure work is done in accordance with approvals. Participate in the management activities when required. Staff, visitors and contractors Minimise all impacts on flora and vegetation. Comply with written approvals for clearing. Report all incidents within 24 hours. Page 4 3

21 4.7 Environmental Management Purpose The purpose of this plan is to identify, assess and manage the potential impacts of the Project on the flora and vegetation within the operational areas. The goal is to maintain the abundance, diversity, geographic distribution and overall population and species viability of native flora and vegetation in the area, and to rehabilitate disturbed areas to a standard that is comparable to pre mining conditions. This would be done with local species of provenance that would produce a stable, self sustaining ecosystem Potential Impacts Clearing and Ground Disturbance Toro would need to disturb land to enable the construction of infrastructure critical to the Project including mine pits, access roads and the processing plant. Historically, the Project area has been disturbed by pastoral and mineral exploration activities. However, most of the area remains relatively undisturbed and further clearing would be required. Clearing may affect flora and vegetation in the following ways: Loss of individual plants, and the potential loss of entire species through the clearing of vegetation; Reduction in the extent of vegetation units; The split or fragmentation of vegetation units; Potential clearing of areas outside the designated clearing envelope; and The development of tracks or unauthorised clearing outside of approved areas Abstraction of Groundwater All four deposits to be mined as part of the Project occur at or below the water table and require dewatering to allow mining. This dewatering may have an impact on groundwater dependent vegetation, such as Tecticornia species that exist on the salt lake edges at Lake Way and throughout the lake at Lake Maitland. Groundwater dewatering modelling suggests that to dewater the ore bodies and allow for mining, there would be a drop in the regional water table that would take some years to recover after the cessation of mining. Introduced Flora The invasion of weeds into areas where none are presently recorded is a potential impact from development of the Project. Seeds may be carried on vehicles and machinery brought into the area, or in soil moved within the Project area. Weeds have the potential to impact on native vegetation in the following ways: Degradation of vegetation condition by out competing native species; Reduction in landform stability; and Reducing viable habitat for native fauna species. Ruby dock (Acetosa vesicaria) has been found in some areas across the Project, but has been successfully managed to date. Fire Management Accidental fires arising from mining activities could have a detrimental effect on surrounding flora and vegetation. Impacts could include loss of individual species and habitat, and alteration of the composition of vegetation communities. Page 4 4

22 Dust Dust is generated throughout the Project area from mining, processing and travelling on unsealed roads. Dust has the potential to impact vegetation through: Smothering Erosion; and Water used to control dust may be saline and could be detrimental to vegetation health Environmental Objective and Performance Indicators The environmental objectives and performance indicators are presented in Table 4.2. Table 4.2: Environmental Objectives and Performance Indicators Environmental Objective Maintain the native vegetation outside of areas of proposed disturbance Avoid or minimise impact on groundwater dependent ecosystems Avoid or minimise the introduction and spread of weed species Awareness of environmental outcomes by all site personnel. Performance Indicators No clearing outside of approved areas Clearing not to commence without an approved Toro clearing permit Area of clearing consistent with Project allowances No decline in the condition and foliage cover of trees in borefield areas No decline in condition, density and abundance of Tecticornia species outside of the 0.5 m drawdown contour across both Millipede and Lake Maitland No new weed species identified in the Project area Areas of known weed populations contained and if possible eradicated Induction and training of all personnel, with records available 4.8 Environmental Management Strategies The Environmental Aspects and Management Strategies are presented in Table 4.3. Page 4 5

23 Table 4.3: Environmental Aspects and Management Strategies Environmental Aspect Clearing and Ground Disturbance Management Strategy Disturbance to native vegetation and land clearing would be minimised and undertaken in accordance with Toro s Ground Disturbance Procedure. A site vegetation clearing permit must be completed and authorised by site Environmental Advisor prior to any ground disturbance. Clearing must not be conducted during or immediately after rain to reduce the risk of erosion and damage to soil structure. If populations of Priority species are identified within the Project boundary and disturbance to those areas cannot be avoided, the Department of Environmental Regulation (DER) must be consulted prior to ground disturbance. No unauthorised driving off tracks. Access to areas of native vegetation near the accommodation village and other Project areas would be restricted to minimise the risk of unauthorised disturbance. Areas no longer required during operations would be progressively rehabilitated and monitored in accordance with the Conceptual Mine Closure and Rehabilitation Plan. Where practicable, seed would be collected from plants prior to removal to ensure that the same genotype and correct taxa were rehabilitated into the area. Seed collected would be stored in air tight (but not plastic) containers to ensure their viability. Groundwater Abstraction Groundwater abstraction to be measured and within annual dewatering volume limits. At the 2 m, 1 m and 0.5 m drawdown contours established for the dewatering of Millipede Centipede, monitoring bores to be installed and continuously operated using down hole loggers. Dewatering to be revised or stopped should actual drawdown data conflict with modelled drawdown predictions. Dust Dust to be managed in accordance with Dust Management Plan. Where saline water is used for dust suppression, roads to be engineered so that runoff can be captured and disposed of appropriately. Establish vegetation monitoring along roads and in areas of high dust deposition, i.e. process plant, to ensure that vegetation health is maintained. Analog sites in non disturbed areas to be established for comparison purposes. Fire Implement the Fire Management Plan. Hot work permits to be obtained prior to any work that may create a fire or an ignition source. Fire extinguishers to be available in all workshops, offices and vehicles. Fire training provided to staff as required. Fire response to be addressed in Emergency Management Plan. Introduced Flora All earth moving equipment and other vehicles or machinery to be cleaned of all soil and seeds before mobilization into new clearing areas. Where possible, vehicles to be site dedicated. Areas within the Project area that are being stripped of topsoil to be checked for weeds prior to movement. The occurrence of weeds to be mapped annually and weed control to be undertaken for infestations. Page 4 6

24 4.9 Monitoring Prior to the commencement of operations, a series of monitoring sites would be established. These sites would be permanent and established in close proximity to areas to be disturbed and analogue sites located in areas that would not be impacted. The aim of the sites would be to allow for comparisons between communities inside and outside the impact area and to be able to account for regional impacts, such as drought. As areas are rehabilitated, quadrats would also be established to enable the success of the rehabilitation to be measured. These quadrats would be permanent and monitored at least annually to assess whether a functioning ecosystem is returning Monitoring Programmes During the life of the Project, ongoing flora and vegetation monitoring would occur. This monitoring would include: Annual flora and vegetation community surveys for vegetation condition to assess the difference between the impact and non impact quadrats; Six monthly monitoring along established transects for weeds in disturbed areas, along roads and in rehabilitated areas; Annual monitoring of quadrats for species richness, density and abundance; Annual monitoring of tree health at the two borefields where drawdown has the potential to lead to tree death, especially in prolonged periods of reduced rainfall; and The Tecticornia research plan would be implemented during rehabilitation to revegetate disturbed lake and lake play areas with Tecticornia species of provenance Weed Monitoring Ruby dock is a species that routinely colonises areas that have been disturbed (Niche Environmental Services, 2014). For this reason monitoring, transects in disturbed and rehabilitated areas would be established immediately after disturbance. These species generally germinate after periods of rainfall, so surveys would take place in April and September so that post rainfall surveys can occur. Where new populations were found, they would be added to the Project weed register and eradication in these areas would commence immediately. Where deemed appropriate, additional transects would be established to enhance the weed surveys Vegetation Condition and Baseline Monitoring Annual monitoring would occur at the quadrats established prior to construction of the Project. Monitoring would occur in spring or post rainfall, so that short lived herbs and annual species can be captured in the surveys. Photographs would be taken of the quadrat from a designated point (to be established) and an assessment of the plant health and diversity made. This system would enable comparisons of the quadrats to be made to past years or over the life of the Project and enable a timeline of the quality of the quadrat to be established. The reason for having quadrats inside and outside proposed disturbance areas is to assess the natural variance of ecosystem composition, which may be impacted by: Local and regional fires; Local and regional rainfall; Drought; and Temporal changes in climate. All monitoring that is done as part of the mine closure process would be detailed in the Mine Closure and Rehabilitation Plan. Page 4 7

25 4.9.4 Rehabilitation Monitoring The Project intends to progressively rehabilitate disturbed areas. The goal is to rehabilitate areas as soon as possible after they are no longer required to ensure that the Project s footprint remains as limited as possible. Rehabilitation monitoring would occur immediately once areas have been rehabilitated to initially consider issues, such as local gamma radiation levels, the depth of topsoil and the adequacy of topsoil coverage, to assess whether the ground has been physically returned to a condition suitable for the recovery of the ecosystem. Annual surveys would commence one year post rehabilitation to assess whether species are returning to disturbed areas. Surveys would assess species diversity and abundance, the presence of weeds and evidence of grazing. Ongoing monitoring would assess how the composition of the ecosystem is changing and analog sites in similar vegetation types and ecosystems would be used to gauge how the rehabilitation was progressing. The Tecticornia Survey and Research Plan would be implemented prior to the commencement of operations. This plan has been designed to both further identify local Tecticornia species and to identify methods to rehabilitate and restore Tecticornia populations across the Project area. The research and monitoring will be undertaken in accordance with the Tecticornia Survey and Research Plan and carried out by specialists from the Department of Parks and Wildlife (DPaW) and other research organisations and universities Interpretation of Results The results of the monitoring would be included in the Project s Annual Environmental Report (AER) and would discuss: Any changes in vegetation noted in the photographic record of the quadrats; Any decline in community health, including plant deaths and plants showing major signs of stress; Any unpredicted decline in plant health inside the direct impact areas; Any new occurrences of weeds in monitoring areas; and Results of rehabilitation, where relevant. All the photographs taken of quadrats across the year would be made available in the AER. Toro has committed to making all monitoring results and information public, and would publish the results of the monitoring on its website Trigger Levels The trigger levels relevant to vegetation that would determine when contingency actions are required are outlined in Table 4.4. Page 4 8

26 Table 4.4: Trigger Levels for Vegetation Assessment Aspect Trigger Level Comment Groundwater Drawdown Weed Infestation Changes in Groundwater Chemistry Decline in Plant Health When actual drawdown is seen to be greater than planned, the contingency measures would be implemented. Annual weed surveys show known weed populations have increased or find new weed species present in the project area. During the operation of the Project, variation of any parameter by more than 1 standard deviation from the mean value would be investigated and be the trigger for contingency actions. Comparisons between sites inside the impact area and analog sites outside show significant differences in leaf area index and observable decline in plant health Modelling is of worst case scenarios and does not allow for the establishment of water barriers. Toro predicts that with barriers in place, drawdown cannot exceed modelled predictions. Any exceedance would trigger the requirement for contingency actions. Controlling the spread of weeds into the Project area would be more cost effective than eradicating populations once they take hold. For this reason, contingency actions would start at the first sign of a negative change to plant communities. Toro has compiled four years of Project and regional groundwater chemistry. The analysis shows that variation within the groundwater is unusual, therefore small changes in groundwater chemistry would be investigated. Any significant differences in leaf area index and observable decline in plant health to trigger contingency actions Contingencies Where changes in plant health occur for reasons beyond the control of Toro, i.e. drought or fire, no contingency response is possible. Where changes in plant health are seen and which can be attributed to the Project, then the following remedial actions would be taken: If groundwater drawdown is found to be greater than the modelled scenarios, then the real time monitoring results would be used to recalibrate the model and new scenarios would be established. The dewatering plan and mine plan would be revised such that mining can occur using the new dewatering scenarios while maintaining the commitment not to drawdown more than 0.5 m at the original 0.5 m drawdown contour. If vegetation decline is due to dust impacts, additional dust control measures will be put in place. If vegetation decline is due to saline or hypersaline water escaping from haul roads, further engineering systems including drains and sumps would be constructed to capture this water. If weed infestations are found to be increasing and/or new species are found within the Project area, the weed control procedure would be revised. Further, stricter weed hygiene measures would be put into place. If plant health is seen to be declining at either of the borefields, the borefield operating strategy would be revised, and further sources of water sought. The water balance for the Project would also be reviewed to seek further water use efficiencies Review and Revision This plan would be reviewed at least annually and prior to any changes in Project configuration. Page 4 9

27 5 GROUNDWATER DEPENDENT VEGETATION MANAGEMENT PLAN 5.1 Environmental Factor To maintain representation, diversity, viability and ecological function at the species, population and community level. 5.2 Relevant Legislation and Standards Legislation and standards applicable to this management plan are: Environmental Protection and Biodiversity Conservation Act 1999 (Cwlth); Environmental Protection Act 1986 (WA); Wildlife Conservation Act 1950 (WA); and EPA Guidance Statement No. 51 Guidance for the Assessment of Environmental Factors, Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment. 5.3 Existing Environment A groundwater dependent ecosystem (GDE) is an ecosystem that requires access to groundwater so that ecological structure and function can be maintained (Murray et al., 2006). Within the broad definition of a GDE, there are three distinct groupings: Aquifer and cave ecosystems, which provide habitat for stygofauna; Ecosystems that are dependent on surface expressions of groundwater; these systems include rivers and streams, wetlands, mound springs and floodplains; and Ecosystems that are dependent on subsurface groundwater; there is no surface expression of groundwater required in this class of GDE (Eamus et al., 2006). The aquifer and cave ecosystems are recognised as habitat for fauna (Eamus et al., 2006; Humphrey et al., 2006) and whilst they may form part of the groundwater system associated with vegetation, they are not considered further in this strategy. The remaining two systems are generally defined and discussed in relation to vegetation, but this is not indicative of an absence of fauna or other life forms (Eamus et al., 2006). Of the two remaining systems, the subsurface GDE class is considered to be relevant to this strategy. The dependency on groundwater of a species within a GDE can be defined as facultative and obligate (ibid). A GDE is considered to be obligate if, at the species level, the presence of a species is dependent upon access to continuous, seasonal or episodic access to groundwater (ibid). A GDE is considered to be facultative if a species uses groundwater when it is available, but does not demonstrate any loss of vegetative cover in the absence of groundwater (O Grady et al., 2006). Defining whether a system is facultative or obligate is considered to be relevant to understanding how changes in groundwater access will impact the vegetation. During surveys conducted by Niche Environmental Services (2011a; 2014), a number of vegetation units were inferred as being groundwater dependent vegetation (GDV). The inference of dependency on groundwater was based on the criteria listed in Eamus et al. (2006). The GDV in the Project area was considered to be reliant on the subsurface presence of groundwater, as defined in Eamus et al. (2006). This assertion is based on the following: The groundwater or capillary fringe above the water table is likely to be within the rooting depth of any of the vegetation; A proportion of the vegetation remains green and is likely to be physiologically active during extended dry periods; Page 5 1

28 The vegetation associated with the subsurface groundwater is different, in terms of species composition and phenology, to the surrounding vegetation; and The annual use of water by vegetation is considered to be significantly greater than the annual rainfall. No direct assessment to develop an understanding of the environmental water requirements and degree of dependency on groundwater of the GDV was undertaken. Accordingly, the status is being inferred. The inferred GDV is located within the Centipede, Millipede, Lake Way deposits and the West Creek borefield. The inferred GDV recorded during the surveys is detailed in Niche Environmental Services (2011a ; 2014). No assessment was undertaken across the Lake Maitland deposit, but the Tecticornia species found on the lake playa are assumed to be groundwater dependent based on the Millipede and Centipede assessments. A summary of the inferred GDV, its location within the Project area and inferred groundwater preference is provided in Table 5.1. The inferred groundwater preference is based on data provided by RPS Aquaterra (2010a; 2010b). Table 5.1: Summary of Groundwater dependent Vegetation in the Toro Energy Wiluna Uranium Project Vegetation Unit Location Inferred Groundwater Preference Clay Plains Eucalyptus camaldulensis Open Woodland over Acacia spp. Borefield Brackish Clay plains Melaleuca interioris Low Forest B Borefield Brackish Claypan Frankenia spp. Dwarf Scrub Lake Way Saline Claypan Tecticornia spp. Heath and Dwarf Scrub Lake Way and Millipede Saline Creekline E. camaldulensis Woodland Borefield Brackish Drainage line E. camaldulensis Woodland Borefield Brackish Fringing M. xerophila Forest Centipede, Millipede and Lake Way Brackish Salt lake Frankenia spp. Dwarf Scrub Lake Way Saline Salt lake Tecticornia spp. Heath and Dwarf Scrub Centipede, Millipede, Lake Maitland and Lake Way Saline 5.4 Roles and Responsibilities The roles and responsibilities for this plan are outlined in Table 5.2. Page 5 2

29 Table 5.2: Roles and Responsibilities Position Responsibility Environmental Manager Implementation and maintenance of the plan. Undertake assessment and review of the effectiveness of this management plan. Environmental Superintendent Formulate and implement monitoring programs to monitor GDV health and groundwater drawdown Ensure all staff are aware of their obligations in relation to this plan. Maintain site records of surveys and implement monitoring programs. Operation Managers and Site Supervisors All Toro personnel, contractors and visitors Ensure the plan is being adhered to by all staff and contractors. Participate in compliance audits and inspections. Minimise impacts on native fauna from construction and mining activities. Report all incidents involving significant species. 5.5 Overview of Potential Impacts GDV is susceptible to changes in the availability and quality of groundwater. GDV generally has an underlying requirement for water, known as an environmental water requirement (EWR). The EWR is the amount of water required for the maintenance of ecological attributes of GDEs (Eamus and Froend, 2006). The EWR can be determined using methods as defined in Eamus & Froend (2006). Determining the EWR of a GDE requires an understanding of the groundwater requirements for maintaining ecosystem features (ibid). EWRs have a spatial and temporal context and include quantity and duration of access to groundwater (ibid). In the absence of determination of EWRs, an accurate assessment of impacts to GDV as a consequence of changes in groundwater cannot be made. Groundwater is considered to be critical for maintaining ecosystem processes such as flowering, seed set and germination, as well as the establishment and development of seedlings (Eamus et al., 2006). However, it is important to determine the degree of dependency on groundwater, as this will affect how changes to groundwater availability affect species and GDV (ibid). Understanding the degree of dependency can be used as a guide to develop the safe limits for changes to groundwater (ibid). A full assessment of impacts can only be made once baseline data for the GDV has been completed. The assessment should collect information in relation to the extent of use of groundwater, the degree of dependency and the current condition of vegetation. In particular, the degree of dependency on groundwater and potential impacts to changes in groundwater availability need to be understood, as this influences the potential scale of impact. Based on the current knowledge of the GDV, there are one direct and three indirect impacts associated with the Project. Direct impact: - Clearing. Indirect impacts: - Groundwater abstraction; - Drought; and - Changes to groundwater characteristics. Page 5 3

30 5.5.1 Clearing The main direct impact associated with GDV in the Project area pertains to clearing. The extraction of the ore would require clearing within four GDVs: The salt lake Tecticornia spp. Heath and Dwarf Scrub across both lake systems; The salt lake Frankenia spp. Dwarf Scrub; The Fringing Melaleuca xerophila Forest; and The two clay pan vegetation units. In addition to this, there may be a need to clear other GDV for the development of Project related infrastructure. The potential for direct impacts due to clearing ranges from low to high. While the extent of clearing and location of infrastructure required for the Project would be planned to ensure that impacts to GDV were minimised, the ore bodies are located under Tecticornia species vegetation units. These have been identified as GDV. The impacts to these units within the Project area are considered to be high. There would also be clearing within the Frankenia vegetation units and the Melaleuca vegetation units in the Centipede and Lake Way deposits. Impacts to these units as a consequence of clearing are considered to be moderate. There is limited clearing planned that would affect other GDV in the Project area. Therefore, impacts to these units are considered to be low Groundwater Abstraction The abstraction of groundwater from aquifers would potentially create an indirect impact on GDV. This is particularly relevant in the West Creek borefield, where the aquifer from which groundwater would be sourced is located under GDV, notably aquifers hosting Eucalyptus camaldulensis. The acceptable degree of change to groundwater levels should be determined by utilising a combination of assessments of environmental impacts to vegetation and community consultation on the impacts (Eamus et al., 2006). The potential for impacts to GDV as a consequence of groundwater abstraction is considered to be low to moderate. The projected rate of extraction and consequent reduction in the water table within the borefield has been modelled by RPS Aquaterra (2010a; 2010b). The analysis predicts a reduction of 4 m in the depth to groundwater in the borefield. To better understand how this compares to changes under natural conditions, data analysis is continuing Drought Drought impacts on the availability of groundwater by altering recharge rates of aquifers. Where recharge rates are reduced as a consequence of drought, there may be a reduction in the quality and availability of groundwater. Longer term changes to recharge rates may result in changes to the depth at which groundwater is available, which may reduce the capacity of GDV to access the groundwater. The effects of drought may be magnified due to interactions with proposed rates of groundwater abstraction. The potential for impacts due to drought are difficult to assess in detail. The characteristics of droughts, in relation to intensity and duration, are not uniform and are therefore not readily predicted. In the context of climate change, there is the potential that droughts may be longer than previously recorded. In this instance, drought impacts may be higher than currently predicted. To minimise impacts to GDV from the Project, monitoring of vegetation condition would be implemented and an assessment of requirements then made Changes to Groundwater Characteristics Species using groundwater have evolved to utilise water within a range of conductivity and containing certain chemicals. Changes to the quality or characteristics of groundwater are noted as Page 5 4

31 being important to GDEs (Eamus et al., 2006). The quality of groundwater in the Project area has been assessed by RPS Aquaterra (2010a; 2010b). Given that this information is available, monitoring in relation to changes can be made over time. Once linked with the condition of vegetation, the impacts of changes will be better understood. Considerations in relation to changes to groundwater characteristics and the factors leading to changes, such as spills, are dealt with in the Groundwater Drawdown Management Plan. The use of any hydrocarbons or other potential contaminants would be managed according to regulatory and licence conditions and best practice. Compliance monitoring would be used to ensure that these were adhered to. In addition to this, there would be appropriate spill management procedures in place to manage any incidents that could lead to contamination of groundwater. By using the combination of these, it is predicted that the potential risk of changes to groundwater characteristics would be low. 5.6 Environmental Objectives, Targets and Indicators A series of management objectives, targets and indicators have been developed to manage potential and direct impacts to fauna species: Objectives: What Toro aims to achieve. Targets: Defined objective levels. Indicators: Measures, which are either quantitative or qualitative, to determine whether the objectives have been met. Eamus (2009) lists two threats to GDEs: loss of habitat and loss of groundwater resources. Based on this, the overarching objective of this management plan is to develop a framework to reduce these impacts to GDV during the development and operation of the mine. The objectives have been defined in relation to GDV only, and do not consider objectives in relation to changes in groundwater, as these are detailed in the Groundwater Drawdown Management Plan. The key objectives in relation to GDV are: Minimise clearing of GDV; and Maintain the condition of GDV located over aquifers from which groundwater would be extracted. The environmental objectives, targets and indicators as determined by Toro for GDV management are shown in Table 5.3. Table 5.3: Objectives, Targets and Indicators Objectives Targets Indicators Minimise Clearing of GDV Maintain Condition of GDV Clearing envelopes of GDV within the Project area to be kept to the smallest extent. No unnecessary clearing of GDV to occur. Condition of GDV to be maintained to pre disturbance level. Clearing envelopes to be well defined and documented, with clearing undertaken only when required. No evidence of a loss of condition of GDV that is within or close to areas where groundwater abstraction is occurring or where the potential for contamination to groundwater exists. Page 5 5

32 5.7 Management Strategies and Actions Key Strategies Detailed GDV management documentation would be developed for the construction and operational phases of the Project. Documentation relevant to decommissioning would be developed during the operational phase. Documentation would include specific policies and standard operating procedures, and would be developed in collaboration with the Department of Parks and Wildlife (DPaW) Monitoring and Management Actions Monitoring and management actions, reporting and corrective actions are listed in Table 5.4. Table 5.4: Management Actions Objective Management Action Reporting Mechanisms Corrective Actions Minimise Clearing of GDV Maintain Condition of GDV Standard operating procedures (e.g. GDV boundaries to be clearly defined with appropriate documentation, such as by using remote sensing). Clearing of GDV only to occur if no other option is available. Standard operating procedures Audits, vegetation surveys and inspections Incident reports Baseline and annual monitoring to be undertaken. Analog sites to be established outside of impact areas for the purpose of comparison Audit and inspections (including review of groundwater extraction volumes and climate data) Review audit and inspection reports. Review assessment process and clearing envelopes to ensure objective of minimal clearing is met. Review audit and inspection reports (e.g. where negative changes to condition of vegetation are noted, review records of rates of extraction of groundwater and environmental conditions). 5.8 Trigger Levels The dewatering of the ore body and water abstraction at the borefields is managed under the Groundwater Drawdown Management Plan. This plan has established that outside the 0.5 m drawdown zone (without water barriers) Toro would have no impacts to vegetation, groundwaterdependent or otherwise. Where GDV health inside impact areas is found to be deteriorating in a manner worse than analog sites outside the impact areas, a review of the company dewatering processes would be undertaken. 5.9 Contingencies The contingency actions taken to eliminate or reduce the impacts on GDV outside the 0.5 m drawdown contours may include: Page 5 6

33 Reducing abstraction from West Creek borefield and increasing abstraction from the Lake Maitland borefield; The identification of, and approval of, a third source of water for the Project; A review of the mining sequence and schedule to assess whether a change in mining could lessen the impacts to GDV from drawdown; and A review of the water barrier construction to identify any areas of improvement Reporting The results of all monitoring undertaken to protect GDV would be included in the Toro Annual Environment Report and would be made publicly available on the Toro website Review and Revision This plan would be reviewed at least every two years, although more frequent reviews may occur if the review of monitoring data finds the management practices and processes specified in this plan are found to be inadequate in achieving the goals of the plan. Page 5 7

34 6 TERRESTRIAL FAUNA MANAGEMENT PLAN 6.1 Environmental Factor To maintain representation, diversity, viability and ecological function at the species, population and assemblage level. 6.2 Relevant Legislation and Standards Legislation and standards applicable to this management plan include: Environment Protection and Biodiversity Conservation Act 1999; Environmental Protection Act 1986; Wildlife Conservation Act 1950; EPA, Guidance Statement No. 56 Terrestrial Fauna Surveys for Environmental Impact Assessment in Western Australia; and EPA and DPaW (formerly known as DEC), Technical Guide Terrestrial Vertebrate Fauna Surveys for Environmental Impact Assessment. 6.3 Existing Environment Vertebrate Fauna Species Level 2 surveys and desktop studies have been undertaken across the entire Project area. The surveys found no threatened fauna species listed under the EPBC Act or Western Australian Wildlife Conservation Act 1950 (WC Act), or Priority fauna species listed under the Western Australian DER Priority Species List, nor have such species been previously recorded in the Project area. Four species of conservation significance have been identified as occurring across the Project area; the Rainbow Bee Eater (Merops ornatus), the Sharp Tailed Sandpiper (Calidris acuminatus); the Australian Bustard (Ardeotis australis) and the Crest Tailed Mulgara (Dasycerus blythi). Based on Database search results, available literature and findings of previous studies in the region, it is considered a further 17 conservation significant species may occur within the Project area, comprising: Five species listed under the EPBC Act and WC Act: the Mulgara (Dasycercus cristicauda Vulnerable and Schedule 1); Malleefowl (Leipoa ocellata Vulnerable and Schedule 1); Slenderbilled Thornbill (Acanthiza iredalei iredalei Vulnerable); Major Mitchell s Cockatoo (Cacatua leadbeateri Schedule 4); and Peregrine Falcon (Falco peregrinus Schedule 4); Three priority species listed under the Western Australia DER Priority Species List: Bush Stonecurlew (Burhinus grallarius P4); the Grey Falcon (Falco hypoleucos P4); and the Striated Grasswren (Amytornis striatus striatus P4); and Nine species listed as Migratory under the EPBC Act: the Fork tailed Swift (Apus pacificus pacificus); Eastern Great Egret (Ardea alba); Common Greenshank (Tringa nebularia); Wood Sandpiper (Tringa glareola); Common Sandpiper (Actitis hypoleucos); Curlew Sandpiper (Calidris ferruginea); Red necked Stint (Calidris ruficollis); Oriental Plover (Charadrius veredus); and Oriental Pratincole (Glareola maldivarum). This data represents the findings of Level 2 fauna surveys along the haul road alignment and Lake Maitland, as well as desktop investigations to support the findings of the Centipede and Lake Way Fauna surveys. Page 6 1

35 6.3.2 Short range Endemic Fauna Previous surveys have identified short range endemic (SRE) species Aname MYG177, Kwokan MYG175 and Urodacus yeelirrie as occurring across the Millipede, Centipede and Lake Way tenements (Outback Ecology Services, 2011a). Each species has been recorded outside the Project area as well, with Urodacus yeelirrie appearing to have a particularly widespread range. Surveys across Lake Maitland have not identified any potential SRE species as occurring there (Outback Ecology Services, 2011b). Habitats within the Project area that have a moderate to high potential to support SRE species include Melaleuca Stands, Chenopod Floodplain and the Mallee/Mulga complex over Spinifex. The Melaleuca Stands habitat is fringing and has a patchy distribution around Lake Way and does not appear to be well represented out of the project area. The Chenopod Floodplain and the Mallee/Mulga complex over Spinifex habitats are moderately to well represented at the local scale outside of the Project area (Outback Ecology Services, 2010). 6.4 Roles and Responsibilities The roles and responsibilities for this plan are outlined in Table 6.1. Table 6.1: Roles and Responsibilities Position Responsibility Environmental Manager Implementation and maintenance of the plan. Undertakes assessment and review of the effectiveness of this management plan. Environmental Superintendent Formulate and implement fauna surveys, monitoring programs and liaise with stakeholders regarding feral animal control and fire management. Ensure all staff are aware of their obligations in relation to this plan. Deliver fauna education and induction awareness training to field personnel. Maintain site records of surveys and implement monitoring programs. Operation Managers and Site Supervisors All Toro personnel, contractors and visitors Ensure the plan is being adhered to by all staff and contractors. Participate in compliance audits and inspections. Minimise impacts on native fauna from construction and mining activities. Report all incidents involving significant species. 6.5 Environmental Management Potential adverse direct and indirect impacts from the Project may include: Direct: - Habitat removal, loss and/or modification (including altered fire regimes); - Deliberate interference with animals (e.g. collecting, shooting, hunting); and - Interaction with vehicles. Indirect: - Noise and vibration; Page 6 2

36 - Light; - Dust; - Radionuclide concentration increase beyond natural background levels; - Introduced flora; - Introduced fauna; and - Putrescible waste (e.g. food scraps) from accommodation camp and other facilities. 6.6 Overview of Potential Impacts Clearing and Ground Disturbance The Project would involve clearing of native vegetation for the construction of key infrastructure, such as the processing plant, mine pits and haul roads. The potential impacts on fauna of this clearing and construction may include: Fragmentation of habitat; Loss of habitat; Loss of individuals during the clearing; and Loss of individuals through collisions with vehicles. No permanent water source is present within the Project area. Dewatering of mining pits may involve the creation of artificial water bodies via pumping of groundwater from the pits to evaporation ponds. Additional artificial water bodies including process water dams and turkey s nests may also be created as part of the Project. These may present a minor entrapment risk for vertebrate mammal species such as kangaroos (e.g. Macropus robustus, M. rufus) (Outback Ecology Services, 2010) Introduced Flora Environmental weeds may be brought in by mobile mining equipment. By establishing and growing faster than native species, weeds can occupy niches that would otherwise be occupied by native species. Over time, the competitive interactions between weed and native species can result in the loss of native species (Niche Environmental Services, 2011c). Weed invasion is widely recognised as having a negative impact on fauna species as it can alter the composition and structure of vegetation communities. Invasion by non native species typically results in declines in native plant species diversity, but the response of fauna may be more complicated (Outback Ecology Services, 2010). The invasive weed, Acetosa vesicaria (ruby dock) was recorded during surveys over the Centipede deposit. All other species of weeds recorded during the surveys within the Project area were not identified as being environmental weeds or declared plants pursuant to section 37 of the Agriculture and Related Resources Protection Act There are other species with the potential to occur in the Project area, based on known distribution and habitat preference. Critical amongst these are: Tamarix aphylla (athel pine); Opuntia stricta (prickly pear); Cenchrus ciliaris (buffel grass); and Eragrostis curvula (Africa lovegrass). It should be noted that these species are not currently known from within the Project area, but are considered to be species that, if introduced into the Project area, would have the capacity to establish and thrive (Niche Environmental Services, 2011c). The current known weed presence within the Project area is considered unlikely to have any lasting impact on faunal populations Deliberate Interference with Animals Deliberate interference with animals includes shooting, fauna collection (including eggs, skins and feathers) or deliberate disturbance. Management plans, policies and procedures would be implemented by Toro to ensure avoidance of deliberate interference with animals. Hunting by Traditional Owners occurs in the area (Niche Environmental Service, 2011b), e.g. kangaroo and Page 6 3

37 goanna. Access to the Project area would be restricted at various times and locations for safety reasons. Deliberate interference is therefore not considered to represent a major impact to local faunal populations Interactions with Vehicles Vehicle collisions typically only involve individual animals and are considered unlikely to have any lasting impact on a population Noise and Vibration The development of the Project would generate noise and substantial vibration due to machinery, the operation of the processing plant, power plant, heavy and light vehicles, and the general presence of people. General responses to noise across a wide variety of animal species range from interruptions in feeding and resting behaviour to complete abandonment of an area. Noise may lead to reduced population densities in small mammals, nest failure and decreased population densities in birds (Slabbekoorn and Ripmeester, 2008) and abandoning of roost sites and a reduced hunting efficiency in bats due to disturbance of their echolocation system. Constant levels of noise also interfere with species communication. This is known as acoustic interference (Parris and Schneider, 2009). Species that may be especially at risk of disturbed communication are those that use calls to communicate over larger distances such as the Bush Stone curlew, which is a listed Priority 4 species (Outback Ecology Services, 2010). The results of a noise assessment show that the noise from the proposed mine and processing plant is predicted to achieve compliance with the Environmental Protection (Noise) Regulations 1997 at all noise sensitive premises (Lloyd George Acoustics, 2011) Light The Project would result in an increase in exposure of fauna to artificial light. Artificial light from mining activities may have detrimental effects on resident bird, mammal and reptile species, as it may interfere with biological and behavioural activities that are governed by the length of day or photoperiod, including reproduction, dormancy, foraging and migration (Bradshaw and Holzapfel, 2007; Le Corre et al., 2002). Light pollution has also been shown to interfere with timing of songbird choruses, potentially leading to reduction in breeding success or survival (Miller, 2006; Outback Ecology Services, 2010). Unmanaged or poorly designed light sources may therefore have a negative impact on animals but, with management, it is considered unlikely that they would have any lasting impact on populations Dust Impacts to fauna species from dust are indirect, through potential impacts to their habitat and vegetation. It is considered unlikely that dust impacts would have any lasting impact on a population Introduced Fauna Introduced fauna cause fundamental changes to ecosystems, and have led to the decline and extinction of many species in Australia (Abbott, 2002; Ford et al., 2001; Short and Smith, 1994). Additionally, predation of native fauna by the fox and feral cat is listed as a key threatening process under the EPBC Act. A number of introduced species exist throughout the Project area including cattle (Bos taurus) camels (Camelus dromedaries), dogs (Canis lupus dingo), cats (Felis catus), rabbits (Oryctolagus cuniculus) and mice (Mus musculus). The introduction of these species has the potential to impact indigenous fauna by: Destroying habitat through over grazing and soil erosion; Page 6 4

38 Direct completion for scarce resources; and Direct predation by introduced carnivorous species. Introduced predators can proliferate as a result of mining projects, particularly if a high standard of housekeeping is not maintained. Introduced predator populations can increase if waste disposal sites are not correctly maintained, as these can become a readily available food source. This can lead to an increase in predators and may result in an increase in predation on native species. As these introduced species have been present for a considerable time, it is not considered that they will have a major impact on native populations within the Project area Fire Altered fire regimes caused by the Project have the potential to be detrimental to local fauna populations. Inappropriate or altered fire regimes have been identified as one of the main contributing factors in relation to the decline of some species (Maxwell et al., 1996). Fires cause habitat destruction and species with relatively poor powers of dispersal, such as SRE invertebrate fauna, are more likely to be directly impacted by fire. However, as SRE invertebrate fauna are not considered to be restricted to the Project area, fire is not considered to be a significant risk to populations Hydrocarbon and Chemical Spills Hydrocarbons and other chemicals, namely processing reagents, would be frequently used on site. The accidental spillage of these chemicals may impact on fauna by: Contaminating water and food sources; and Killing local vegetation and destroying habitat Waste Management The incorrect disposal of wastes may lead to an increase in the number of introduced species. The correct storage and disposal of waste would be implemented to ensure introduced species may not use wastes as a food source that encourages population explosions Pregnant Liquor Solution and Other Evaporation Ponds The Wiluna region is generally hot and dry and offers excellent potential to solar concentrate processing solutions or to evaporate excess water. These ponds would represent the only permanent water bodies in the region and could attract birds. The potential issues these ponds present to fauna are: Death from the injection of pregnant liquor solution; Entrapment in ponds; and Exposure to increased levels of uranium. 6.7 Environmental Objectives Targets and Indicators A series of management objectives, targets and indicators has been developed to manage potential and direct impacts to fauna species in relation to the Project: Objectives What Toro aims to achieve. Targets Defined objective levels. Indicators Measures which, are either quantitative or qualitative, to determine whether the objectives have been met. Table 6.2 shows the environmental performance indications for fauna management. Page 6 5

39 Table 6.2: Environmental Performance Indicators Objectives Targets Indicators Reduce habitat clearing Minimise detrimental impacts of fires to fauna No deliberate interference with animals by Toro staff or contractors Minimise potential fauna and vehicle interactions Minimise fauna egress to evaporation pond Minimise potential impacts to fauna from noise Light spillage to be minimised Minimise potential impacts from dust No net increase in radionuclide concentration in local fauna Reduce impacts from introduced flora from Toro operations Reduce impacts from introduced fauna as a result of Toro operations Minimise potential impacts to fauna from waste generated onsite Minimise potential impacts to fauna habitat Zero incident reports of fauna deaths/injuries from fire Zero incident reports of fauna interference Zero incident reports of fauna to vehicle interactions Zero incident reports of fauna accessing evaporation pond No observable impact on fauna species during construction and operation No observable impact on fauna breeding behaviour No observable impact on fauna species during construction and operation No net increase in radionuclide concentration in local fauna No introduction of new weeds into the Project area No further spread of weeds within the Project area No introduction of new introduced animal species into the Project area Management of introduced animal species within the Project area No observable impact on fauna species during construction and operation No vegetation clearing outside of authorised areas Results of fauna surveys and people observations Results of fauna surveys and people s observations Results of fauna surveys Results of fauna surveys Results of fauna surveys Results of fauna surveys Results of fauna surveys Results of laboratory analysis No introduction of new weeds into the Project area No further spread of weeds within the Project area Results of fauna surveys and observations Results of fauna surveys and people observations 6.8 Environmental Management Strategies and Actions Key Strategies Detailed fauna management documentation would be developed for the construction and operational phases of the Project. Documentation relevant to decommissioning would be developed during the operational phase. Documentation would include specific policies and standard operating procedures, and would be developed in collaboration with the DER. Page 6 6

40 The environmental management strategies for the plan are outlined in Table 6.3. Table 6.3: Environmental Management Aspects and Strategies Objective Management Action Reporting Mechanisms Corrective Actions Reduce Habitat Clearing Minimise Detrimental Impacts of Fires to Fauna No Deliberate Interference With Animals by Toro Staff or Contractors All significant fauna habitat to be identified, mapped and demarcated on site Clearing of significant fauna habitat to be avoided or minimised No off road driving unless in case of an emergency or permitted by the Environmental Officer No unauthorised clearing of vegetation (as per Toro vegetation clearing procedure) Retention of mature/large trees where practicable Progressive clearing of vegetation to allow fauna to disperse to other suitable areas Retention of fauna burrows where possible Standard operating procedures Undertake progressive rehabilitation Standard operating procedures (e.g. no campfires, no unauthorised fires) Employee/contractor inductions Design standards Fire Management Plan Employee/contractor inductions Standard operating procedures Monitoring of fauna via surveys Monitoring of habitat/vegetation via surveys Incident reports Inspections and audits Incident reports Inspections and audits Monitoring fauna via surveys People (e.g. visual observations) Incident reports Inspections and audits People (e.g. visual observations) Review of Vegetation Clearing and Soil Management Strategy; contractor compliance; inductions; and standard operating procedures Implementation of findings from review/reports Review of fauna management and fire management plans Review induction process Implementation of findings from reviews Implementation of findings from incident reports, audits and inspections Any incidents that result in the injury or death of conservation significant species would be reported to the DPaW and DER Specimens should be retained (i.e. stored in a freezer) for further examination by DPaW or the WA Museum. Page 6 7

41 Objective Management Action Reporting Mechanisms Corrective Actions Minimise Potential Fauna and Vehicle Interactions Minimise Fauna Egress to Evaporation Pond Minimise Noise Levels Light Spillage to Be Minimised Minimise Potential Impacts From Dust No Net Increase in Radionuclide Concentration in Local Fauna Employee/contractor inductions Speed limits to be observed by all vehicles within the project area Designated vehicle traffic routes Fences may be required in strategic areas where fauna are known to cross major transport routes Scaring devices Fauna egress points Potential construction of fences/netting All vehicles, plant and machinery to be operated within appropriate noise standards and relevant guidelines All vehicles, plant and machinery to be maintained and regularly serviced Incident reports Inspections and audits People (e.g. visual observations) Inspections and audits People (i.e. visual observations) Incident reports Monitoring introduced fauna via surveys People (e.g. visual observations) Inspections and audits Incident reports Design standards Monitoring fauna via surveys People (i.e. visual observations) Inspections and audits Incident reports Standard operating Inspections and procedures audits No unauthorised clearing Monitoring fauna of vegetation (as per Toro via surveys vegetation clearing People (e.g. visual procedure) observations) Progressive clearing of vegetation to allow fauna to disperse to other suitable areas Design standards Laboratory Standard operating analysis procedures Inspections and audits Incident reports Implementation of findings from incident reports, audits and inspections Any incidents that result in the injury or death of conservation significant species should be reported to the DER and DPaW Specimens should be retained (i.e. stored in a freezer) for further examination by DPaW, DER or the WA Museum. Review of Fauna Management Plan Implementation of findings from reviews and reports Review of Fauna Management Plan Review of maintenance routines Implementation of findings from review Repair damaged or failed components (vehicle; machinery; plant) Review of Fauna Management Plan Implementation of findings from reviews Review of Dust and Vegetation Clearing Management Plans Implementation of findings from reviews Review of Radiation Management Plan Implementation of findings from reviews Page 6 8

42 Objective Management Action Reporting Mechanisms Corrective Actions Reduce Impacts From Introduced Flora From Toro Operations Reduce Impacts From Introduced Fauna From Toro Operations Minimise Potential Impacts to Fauna from Waste Generated on Site Employee/contractor inductions Contractor management (pre cleaning of vehicles and machinery) Designated wash down area Standard operating procedures Weed Management Plan No pets to be permitted on site Feeding of any animal on site is to be prohibited Introduced animal management procedures Putrescible waste to be managed appropriately Putrescible waste to be managed appropriately General waste (e.g. aluminium cans, glass bottles) disposed of appropriately Waste Management Plan Monitoring introduced flora via surveys People (e.g. visual observations) Inspections and audits Incident reports Monitoring of introduced fauna via survey People (e.g. visual observations) Inspections and audits Incident reports Monitoring of introduced fauna via survey People (e.g. visual observations) Inspections and audits Incident reports Review of Weed Management Plan; contractor compliance; inductions; and standard operating procedures Implementation of findings from review Review of introduced animal management procedures; contractor compliance; inductions; and standard operating procedures Implementation of findings from review (for example, may include active control of feral animals) Review of Waste Management Plan; contractor compliance; inductions; and standard operating procedures Implementation of findings from review 6.9 Monitoring Toro would keep records of animal strikes, bird deaths and fauna removals from ponds. This information would be reported on in Toro s Annual Environment Report and be available on the company website. Regular monitoring of rehabilitated areas would be undertaken to support the closure and rehabilitation plan which would include fauna surveys to assess whether fauna is returning to disturbed areas. These surveys would also include targeted surveys for non native fauna, and include observations on any increase or decrease in populations. Feral animal control programmes would also be reported on. The number of baits set out and the result would be documented and compared to previous years to assess whether the programs are working or not. Where programs are not working, investigations into more successful programs would be initiated Trigger Levels Annual fauna and flora surveys would be used to determine whether contingency actions need to be put into place. Where introduced flora or fauna numbers are seen to be increasing, this would be a sign that management measures were not working adequately and additional measures were required. Page 6 9

43 6.11 Contingencies If monitoring indicates changes in fauna populations or that introduced flora or fauna were increasing in the Project are, Toro would review its management strategies. The contingency actions taken may include more rigorous weed and seed checks on plant entering and leaving site, further surveys across the Project to fully understand the ecosystem changes and a review of the Project risk analysis to assess whether fauna risks have been managed appropriately Reporting The Annual Environment Report would provide detailed information on the effectiveness and implementation of this plan. In addition, the report would provide details on the status of conservation significant fauna recorded within the Project area Review and Revision This plan would be reviewed following pre clearance surveys, then every two years thereafter. In the event that conservation significant species were identified within the Project area prior to the completion of any review period, the plan would be immediately revised. Page 6 10

44 7 SUBTERRANEAN FAUNA MANAGEMENT PLAN 7.1 Environmental Factor To maintain representation, diversity, viability and ecological function at the species, population and assemblage level. 7.2 Introduction The term subterranean fauna refers to both terrestrial (troglofauna) and aquatic (stygofauna) organisms that occur in underground water bodies and cavities. The host calcrete in which the Wiluna Uranium Project s ore bodies are located provides habitat for both troglofauna and stygofauna species and there is the potential for the Project to negatively impact either of these organisms. This plan outlines the potential impacts on subterranean fauna and develops specific management measures to protect these species. 7.3 Relevant Legislation and Standards Legislation and standards applicable to this management plan include: Environment Protection and Biodiversity Conservation Act 1999 (Cwlth); Contaminated Sites Act 2003 (WA); Environmental Protection Act 1986 (WA); Rights in Water and Irrigation Act 1914 (WA); Wildlife Conservation Act 1950 (WA); Agriculture and Related Resources Protection Act 1976 (WA); and EPA, Guidance Statement No. 54 Sampling of Subterranean Fauna in Groundwater and Caves; EPA, Guidance Statement No. 54A Sampling Methods and Survey Consideration for Subterranean Fauna in Western Australia; and Department of Water (DoW), Water quality protection guideline No 1 Water quality management in mining and mineral processing: an overview. 7.4 Existing Environment Centipede and Millipede A total of 75 samples from 64 holes were collected over three rounds of sampling in July 2007, November 2009 and August 2010 (Outback Ecology Services, 2012c). Of the 23 stygofauna species collected at Centipede (excluding Oligochaeta taxa), 13 species (56.5%) were demonstrated to have relatively widespread distributions, having been collected from other calcrete systems as part of this study or previous stygofauna surveys conducted in the Northern Yilgarn. Of the remaining 10 species detected only from the Hinkler calcrete to date, three species (Bathynellacea: Brevisomabathynella sp. SAM2; Copepoda: Schizopera sp. TK4 and S. TK7) have not yet been recorded from outside the Centipede deposit. One species is currently undescribed, the cyclopoid copepod Ameiropsyllus sp. TK1. As noted in Outback Ecology Services (ibid.), this undescribed species is not restricted to Centipede, having also been collected from the groundwaters of Lake Maitland. The wider distribution patterns of more than 10 other species also detected in, but not confined to, the Centipede deposit indicate the much wider occurrence of suitable habitat and the absence of a barrier to dispersal that would likely prevent Brevisomabathynella sp. SAM2, Schizopera sp. TK4 or S. TK7 from occurring outside the area to be mined. Instead, the apparent restricted distributions are Page 7 1

45 more likely to be an artefact of sampling failing to detect each species from outside the mining area and not a true depiction of these species having such restricted distributions. Both copepod species Schizopera sp. TK4 and S. TK7 may also occur from the Barwidgee calcrete near Lake Maitland, 72 km to the south east (ibid). Nine species of troglofauna were recovered from the Centipede/Millipede tenements. Four of the nine species detected were found only in that area. The absence of habitat in the floodplain areas considered suitable for troglofauna (such as calcretes with reasonably interconnected and humid subterranean air filled voids) suggests these species are more likely to be soil dwelling fauna (edaphobites) and not obligate inhabitants of subterranean environments (troglobites), which are more likely to have restricted distributions. The reasonable likelihood that these species occupy a soil fauna ecological niche, coupled with the adjacent and relatively widespread extent of the floodplain habitat fringing the Lake Way playa, suggests that these species are likely to be more widely distributed and not restricted to the immediate vicinity of the sites in the mine development area from which they were detected. In 2015, a targeted extension to the Centipede/Millipede survey was undertaken to assist with the preparation of this PER. The Centipede and Millipede deposits are a geological extension of the same ore body and should therefore hold the same subterranean fauna values. This is supported by the results of the targeted survey (MWH, 2015) Lake Way A total of 47 samples from 29 holes were collected over four rounds of sampling in November 2009, March, May and August Of the 20 stygofauna species collected from the Lake Violet and Uramurdah calcretes as part of this survey (excluding Oligochaeta taxa), 12 species (60%) have relatively widespread distributions, having been collected from other calcrete systems and/or the West Creek borefield area as part of this study or previous stygofauna surveys conducted in the Northern Yilgarn. One species (Copepoda: Kinnecaris sp. TK2), represented by a single specimen, was detected from inside the Lake Way deposit only. As was the case for Centipede/Millipede surveys mentioned above, the wider distribution patterns of 10 other species also detected in, but not confined to, the Lake Way deposit provides an indication of the much wider occurrence of suitable habitat and the absence of a barrier that would likely prevent Kinnecaris sp. TK2 from occurring outside the area to be mined. Instead, the apparent restricted distribution is more likely to be the failure of sampling to detect Kinnecaris sp. TK2 from outside the mining area and is not a true depiction of this species having such restricted distributions (Outback Ecology Services, 2012c). Nine troglomorphic species were recorded at the Lake Way deposit encompassing Uramurdah calcrete. All but one of these species, Haloniscus sp. OES6 (Isopoda), were found to occur outside the area surveyed. Because of the ecological niche likely to be occupied and the relatively widespread extent of floodplain habitat at Lake Way, it is considered unlikely that Haloniscus sp. OES6 would be restricted to the mine development area only West Creek Borefield A total of 46 samples from 16 holes were collected over five rounds of sampling in November 2009, May, August, and November Of the 17 stygofauna species collected from the proposed West Creek borefield area (excluding Oligochaeta taxa), nine species (53%) have been collected from other calcrete systems as part of this study or previous stygofauna surveys conducted in the Northern Yilgarn. The remaining seven species were not detected in this study from outside the modelled drawdown zones. The maximum modelled drawdowns range from: 2 m for Brevisomabathynella sp. SAM4, Chiltoniidae sp. SAM2 and Parabathynellidae sp. OES13; 3 m for Brevisomabathynella sp. SAM3 and Paramelitidae sp. SAM1; and Page 7 2

46 4 m for Kennecaris sp. TK1 and Parapseudoleptomesochra sp. TK2. The sampling conducted at West Creek for stygofauna satisfied the requirements recommended by the EPA Guidance Statement No. 54A Lake Maitland and Borefield Lake Maitland does not have a diverse or abundant subterranean fauna community compared to other areas in the Yilgarn such as Lake Way or Yarrabubba calcrete in the Murchison (Humphreys et al., 2009). The key outcomes of baseline studies at Lake Maitland were: Approximately 500 specimens were collected during four surveys at 50 sampling sites nine of these were outside the Project area; At all sites, inside and outside the Project area, the number of specimens caught was generally low, with the majority of sites yielding less than 10 specimens; At least half of the taxa recorded from groundwaters at Lake Maitland have a known distribution outside the Project area; The majority of positively identified taxa belong to the phylum Arthropoda (sub phylum Crustacea), classes Malacostraca, Ostracoda and Maxillopoda; and Little Well, a site associated with the calcrete aquifer west of Lake Maitland, yielded the most abundant samples, with at least six potentially stygal taxa (>250 specimens) recorded over four surveys. 7.5 Roles and Responsibilities The roles and responsibilities for subterranean fauna management are outlined in Table 7.1. Table 7.1: Roles and Responsibilities Position Responsibility Environmental Manager Implementation of this management plan Review the plan and make changes as required Environmental Superintendent Ensure staff are aware of their obligations under this plan Undertake stygofauna and troglofauna surveys as required Ensure dewatering monitoring is occurring Maintain site records of all monitoring Operations Managers and Site Supervisors Ensure the plan is being adhered to on site Participate in the management of this plan as required Staff, Contractors and Visitors Minimise impacts on the environment Report all incidents within 24 hours Clean up all spills 7.6 Environmental Management Potential Impacts Impacts from the Project can be categorised as being either direct or indirect. Direct impacts may include: Page 7 3

47 Groundwater abstraction; Dewatering during mining operations; Contamination of groundwater from spills and leaks; and Changes to groundwater chemistry. Indirect impacts may include: Changes in radionuclide concentrations in the environment above normal background levels; and Changes in groundwater flows due to altered sub surface hydrology during mining Dewatering As both troglofauna and stygofauna require either water or humidity in which to exist, the dewatering of the Project has the potential to impact both species. All of the ore bodies to be mined require dewatering, the extent of which is based on the size of the area to be mined, but at the ore bodies themselves local dewatering would lower the water table by 10 m. Modelling (RPS Aquaterra, 2010a) was undertaken to ascertain predicted total dewatering volumes during the life of mine and simulate the use of water barriers to assess their impacts on dewatering. Prediction Run 1 simulated the mining, without the use of cut off walls to help decrease inflow to the open pits, whilst Prediction Run 2 included the simulation of cut off walls installed around and within the mine area to help control groundwater inflows (RPS Aquaterra, 2010b). Field trials undertaken by Toro (2011) and Golder Associates (2011) have confirmed that the barriers have a similar effect in the field as in the model and can be used to limit water ingress. Field studies have shown that this ingress may be reduced by up to 80% (Toro, 2011). At the two borefields, modelling of the drawdown was been based upon expected water demands without the use of barriers. The modelling demonstrated that large drawdowns are confined to the immediate vicinity of the pumping areas and that in the context of the entire aquifer the drawdown is insignificant (RPS Aquaterra, 2010a) Pit Excavation Troglofauna specifically live in the voids and fissures present in the calcretes, in which the uranium is hosted. Mining would remove this calcrete and therefore remove local troglofauna habitat. Although mining would lead to the direct loss of habitat within the areas to be mined, the regional extent of the calcretes, the relative short durations of mining and the spatial distribution of both stygofauna and troglofauna ensure that the long term risk to any species is insignificant (Outback Ecology Services, 2012c, MWH, 2015) Tailings Deposition At Centipede and Millipede, mined pit voids would be used to store tailings created during the processing of the ore. The tailings would be highly alkaline and unsuitable as troglofauna habitat. Leaching of uranium and other contaminants from the tailings has the potential to affect downstream stygofauna populations. Toro has undertaken modelling to investigate how uranium in the groundwaters would increase due to seepage from the Tailings Storage Facility. The model found that, if unchecked, seepage could increase groundwater uranium concentrations significantly. Interactions between the tailings liquids and the clay barrier that would line the pits was input to the model, along with dilution and reduction due to lake sediments (as demonstrated by Toro during recent drilling). With these inputs it was found that seepage from the TSF would not lead to significant impacts to local groundwaters and would therefore not impact local subterranean fauna populations (Prommer et al, 2015). Page 7 4

48 7.6.5 Groundwater Reinjection The Project proposes to reinject mine pit water at the Lake Maitland deposit as a means of managing excess water. Water from the pit area would be generally hypersaline and not suitable for Project use. Reinjection of this hypersaline water into the fresh water systems of the Barwidgee calcrete can alter the salinity of the region and lead to widespread and potentially total habitat loss in the Barwidgee Calcrete, a listed Priority Ecological Community. Toro has identified a preferred borefield to the south of Lake Maitland in a region where the groundwater is saline (>14,000 mg/l salinity) (Pennington Scott, 2015). This region is separated from the Barwidgee Calcrete by some 6km and groundwater flows within the nominal borefield region flow away from the Barwidgee calcrete and back towards the lake (ibid). For this reason, it is considered unlikely that the reinjection of groundwater will pose a long term threat to local subterranean fauna populations Spills and Localised Contamination Spills or leaks from hydrocarbons or chemicals in the plant area, or from any vehicles or equipment on the mine site may contaminate soil and groundwater affecting subterranean fauna communities. On site chemicals and hydrocarbons would be stored in bunded containers which would be stored in areas away from drainage lines. Storage vessels and pipelines would be fitted with detection systems to promptly inform Toro of any leaks. In order for a leak to significantly impact stygofauna species, it would need to be a prolonged discharge or a catastrophic failure. Given the unlikelihood of such events occurring due to engineered storage (e.g. double lined/bunded fuel cells) and standard operating procedures, hydrocarbon and chemical spills would be identified and cleaned up and remediated in a timely manner. It is considered that groundwater contamination in this area would be a minor environmental impact. 7.7 Environmental Objectives and Performance Indicators The environmental objectives and performance indicators are outlined in Table 7.2. Table 7.2: Environmental Objectives and Performance Indicators Environmental Objective Maintain the abundance and diversity of subterranean fauna species occurring within the Project area Avoid or minimise adverse impacts on significant subterranean fauna species Ensure no long term or legacy impacts on subterranean fauna populations Performance Indicator Regular surveys of subterranean fauna show no long term changes in population density or composition Groundwater monitoring indicates no change in groundwater chemistry due to abstraction or reinjection Groundwater drawdown is kept at or below modelled drawdowns Groundwater recovery occurs at or faster than modelled recovery Subterranean fauna surveys show no decline in species or populations Post closure monitoring shows the leaching from tailings is not occurring Contaminant transport monitoring is at or below modelled levels Page 7 5

49 7.8 Environmental Aspects and Management Strategies The environmental aspects and management strategies are presented in Table 7.3. Table 7.3: Environmental Aspects and Management Strategies Environmental Aspect Management Strategy Pit excavation Pit outline identified early and surveyed for subterranean fauna Ongoing periodic sampling of bores within the proposed mine footprint Water barriers installed to prevent lateral flows of water and reduce the need for dewatering Dewatering and Reinjection Ongoing groundwater chemistry monitoring to ensure no changes to groundwater composition are occurring Monitoring of drawdown rates to ensure that drawdown is occurring as modelled Groundwater abstraction rates kept within approved Project limits Regional sampling of established subterranean fauna bores to ensure regional populations are persisting Regular monitoring of reinjection borefield for impacts such as mounding Tailings Deposition Mine voids to be lined with compacted clay prior to tailings deposition Water barriers installed during mining to prevent water ingress left in place, to prevent tailings egress Downstream monitoring to commence after tailings cells are backfilled to identify any leakage of contaminants specifically uranium and other radionuclides Spills and Contamination Spills to be cleaned up immediately Storage of fuels and reagents to be in bunded areas to prevent contamination of the environment Regular monitoring of local groundwaters for contaminants to identify whether fuels or reagents are making their way into the environment Changes in Water Quality Continued monitoring of local and regional bores to determine whether groundwater chemistry is being adversely impacted by mining Monitoring to include radionuclide concentrations to ensure that thee remain stable 7.9 Monitoring Subterranean fauna monitoring is outlined in Table 7.4. Page 7 6

50 Table 7.4: Subterranean Fauna Monitoring Aspect Frequency Pit Dewatering Volume Pumps to be fitted with meters Data to be collected monthly Reinjection Reinjection volumes to be monitored Drawdown Level loggers will be placed into monitoring bores to continually monitor drawdown at the mine sites and the borefields Pumps at the borefields to be fitted with meters and abstraction volumes are not to exceed section 5C limits Data to be recovered monthly Subterranean Fauna Populations Annual surveys of subterranean fauna Surveys may become biannual if populations are shown to be stable Reinjection Volume Reinjection pumps to be fitted with meters Volumes to be collected monthly Groundwater Quality Monthly analysis of basic water chemistry including EC, salinity, dissolved metals Quarterly analysis of radionuclides Annual analysis of organic compounds and potential contaminants Tailings Storage Facility Integrity Constant monitoring using real time data loggers that detect changes in EC, uranium concentration and other radionuclide concentrations Trigger Levels The following trigger levels would be established to inform Toro when contingency measures to manage subterranean fauna are to be implemented (Table 7.5). Table 7.5: Stygofauna Impacts Trigger Levels Impact Trigger Level Excess drawdown Level logger devices show that drawdown is occurring faster than modelled predictions Change in subterranean fauna community composition Changes in groundwater chemistry Annual surveys find a significantly reduced number of specimens based on baseline surveys Where groundwater monitoring finds that concentration of any analyte is more than two standard deviations from seasonally adjusted means contingency action would be taken. Reinjection is planned to occur inside the 14,000 mg/l salinity zone. If salinities in the zones that are less than 14,000 mg/l are found to increase by more than two standard deviations from seasonally adjusted averages, contingency actions would be taken Contingencies If a significant change is recorded that can be attributed to the Project, the following would occur: Page 7 7

51 If there is a saline water/oil/chemical spill, operations in that area would cease until the spill was halted and cleaned up (including removal of contaminated soil). Depending on the extent of contamination a survey to ensure all contaminated material has been removed, may be required. In the event the subterranean fauna survey identifies a species that may be localised to the Project area, further sampling outside the Project area may be undertaken to provide more certainty about the range of the species. Conservation measures may be taken in consultation with the DER and the WA Museum, which may include relocation of species. If groundwater drawdown is occurring at a faster rate than modelled, the mining method would be examined to determine if smaller mining cells can be implemented. If seepage in the TSF is identified, work would commence immediately on repairing any breach and further investigations will take place to find a permanent solution. Where salinity in the fresh/brine water systems was found to be increasing, the borefield configuration would be changed with those bores closest to the areas of salinity increase turned off to groundwater time to recover. If there was a prolonged drought, then the rate of abstraction would be monitored to assess rates of change and dewatering activities may be altered to minimise impacts on subterranean fauna communities Interpretation and Reporting Data would be analysed as it is gathered and aim to identify any trends and patterns and identify; Any spills; Any breaches of the TSF wall; The overall groundwater chemistry; and Groundwater abstraction rates. All data would be included in Toro s Annual Environment Report and made publicly available Review and Revision The stygofauna monitoring plan would be reviewed annually after the analysis of the monitoring data. Page 7 8

52 8 SURFACE WATER MANAGEMENT PLAN 8.1 Environmental Factor To maintain the quality of groundwater and surface water, sediment and biota so that the environmental values, both ecological and social, are protected. To maintain the hydrological regimes of groundwater and surface water so that existing and potential uses, including ecosystem maintenance, are protected. 8.2 Purpose of the Plan The Wiluna Uranium Project would require clearing of vegetation and the construction of haul and access roads to facilitate operations. This infrastructure would have an impact on surface water flows which may in turn impact the local environment. The purpose of this management plan is to identify the potential impact to surface water the Project would have and to outline specific management measures and performance indicators to ensure surface water quality and flows are maintained during the life of the Project. Surface water flows and quality post mining will be dealt with in the Project s Mine Closure and Rehabilitation Plan. 8.3 Relevant Legislation and Standards Legislation and standards applicable to this management plan include, but are not limited to: Environment Protection and Biodiversity Conservation Act 1999 (Cwlth); Environmental Protection Act 1986 (WA); Wildlife Conservation Act 1950 (WA); Environmental Protection (Unauthorised Discharges) Regulations 2004; Rights in Water and Irrigation Act 1914 (WA); Soil and Land Conservation Act 1945 (WA); National Water Initiative Objectives 2009; National Water Quality Management Strategy, No 7: Australian Guidelines for Water Quality Monitoring and Reporting, 2000; Australian and New Zealand Environment Conservation Council (ANZECC) and the Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ), Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC 2000). EPA Position Statement No. 2 Environmental Protection of Native Vegetation in Western Australia; and DoW, Stormwater Management Manual for Western Australia. 8.4 Roles and Responsibilities The roles and responsibilities are presented in Table 8.1. Page 8 1

53 Table 8.1: Roles and Responsibilities Position Responsibility Environmental Manager Implementation and maintenance of this plan Audits and review of the plan biennially or as required Environmental Superintendent Operations Managers and Site Supervisors Staff, Contractors and Visitors Ensure all staff are aware of their obligations under this plan Develop and implement monitoring programs to demonstrate the effectiveness of this plan Maintain records of monitoring Assist in the implementation and ongoing management of surface water Participate in audits and inspections as required Minimise the impacts on surface water from construction and mining activities Report incidents as they arise 8.5 Environmental Management Purpose The purpose of this plan is to outline the environmental management that would ensure the quality of surface water flows into Lake Way and Lake Maitland are not impacted by the Project. The environmental objectives of this plan are to: Ensure surface water quality remains unaffected by the implementation of the Project; To ensure surface water flows are affected as little as possible by the Project; and To ensure that the receiving environment through which surface waters flow is not impacted by changes in surface water quality Potential Impacts Process Plant The Project would utilise ponds to evaporate pregnant liquor solution prior to processing. In periods of heavy rainfall, there would be the potential for these ponds to over top and mix with surface waters carrying uranium bearing water into the environment. Haul and Access Roads The Project would require a number of access tracks as well as two haul roads for the movement of ore and vehicles. Haul roads have the potential to alter surface water flow patterns by blocking drainage lines and can lead to rain shadow effects downstream reducing the water available to downstream ecosystems. The haul roads would also require dust suppression during dry periods when material may become airborne. Toro proposes to use saline or hypersaline water for this purpose so that the less abundant good quality water remains available to other users. During heavy rain fall period s fresh surface water may become salty when it interacts with the haul roads which may adversely affect local flora. Runoff may also carry hydrocarbons and other contaminants that also have the potential to impact local flora populations. Page 8 2

54 Mining Pits Mining pits would expose uranium ore which can become mobile in waters and may dissolve in surface water when runoff enters the pit. Flows through the pits may escape into the local environment and could potentially lead to downstream uranium and other radionuclide contamination Management of Potential Impacts Process Plant The processing plant would be bunded to prevent surface water entering the plant and also to prevent potentially contaminated waters from exiting the plant. All water recovered from rainfall would be collected and directed into either the evaporation pond or added into the processing circuit. This would enable any potential uranium contaminants to be removed and lead to other contaminants being captured and retained within the tailings. Haul Roads To prevent the downstream rain shadow effects from disturbed surface water flows, environmental culverts would be included in haul and access road design. These culverts would collect surface water on one side of the road and redistribute it down surface water drainage lines on the other side of the road. As part of the haul road design, there would be drainage and sumps installed to catch surface water runoff. The edges of the road would also be bunded to prevent the egress of waters from the road into the surrounding vegetation. Regular monitoring of the sumps would occur to ensure that they are kept clean and free of debris. Mining Pits Mine pits would be bunded to withstand a probable maximum flood as required by the federal condition of approval (EPBC 2009/5174) for mining at Centipede and Lake Way. Toro would design pit bunds to withstand the 1 in 100 year average recurrence interval. Toro would ensure that no surface water is able to enter mined out pit voids, and that no runoff may leave mine pits and enter the receiving environment. A probable maximum precipitation 100 year flood event estimates that the lake would fill to a depth of 1.5 m above surface level. Accordingly, bunds would be designed to withstand this level of water. Ephemeral streams, such as Abercromby Creek that flows immediately to the south of the Centipede and Millipede deposits, would be diverted prior to mining. Approximately 1 km upstream of the two deposits, the stream splits into two arms, one running past the mine pits and the other running due north avoiding planned mining areas. Water would be diverted into this arm in an effort to maximise the distance between surface water flows and the Project (RPS, 2015). The pits at Millipede/Centipede would be used for tailings storage after they are mined out. During the deposition of tailings, the pits would remain inside the bunded walls of the operation, so no tails would be able to leave the Project area. In the event of large storms and the inability of Toro to contain all storm waters within the Project, Toro has reserved the right to discharge water onto the lake to enable operations to continue. In this case, surface water quality would be analysed for basic chemistry as well as for radionuclide contamination. Where the chemistry is at or below the guidelines for drinking water established in ANZECC 2000, approval would be sought to discharge water. Where the water exceeded a particular value it would be captured and used in the processing circuit or diverted to the evaporation ponds for disposal. Page 8 3

55 8.6 Environmental Objectives and Performance Indicators The Environmental Objectives and Performance Indicators are outlined in Table 8.2. Table 8.2: Environmental Objectives and Performance Indicators Environmental Objective To maintain the integrity, ecological functions and environmental values of surrounding environment To maintain the quantity and quality of surface water so that existing and potential environmental values, including ecosystem maintenance, are not adversely impacted Performance Indicator No loss or change of environmental values associated with changes in surface water regimes No impacts on vegetation outside the direct impact area as a result of surface water flow changes No escape of surface water from mining areas into the surrounding environment except in controlled circumstances Regional surface water quality remains consistent with baseline surface water quality monitoring No release of surface water from mining areas into the surrounding environment except in controlled circumstances 8.7 Environmental Aspects and Management Strategies The environmental aspects and management strategies are presented in Table 8.3. Table 8.3: Environmental Aspects and Management Strategies Environmental Aspect Management Strategy Process Plant Plant to be bunded to prevent surface water ingress and flood water egress Bunds designed to withstand the 1 in 100 years rainfall event Storm water in process plant collected and sent for evaporation or reused within the processing circuit When rainfall is to be discharged from the processing plant site, quality measurements shall be taken and discharge shall only occur when quality is at or below certain levels (ANZECC 2000) All chemicals to be stored correctly and area to be kept clean to limit water contamination Leak detection fitted on all chemical, reagent and hydrocarbon vessels to allow leaks to be repaired quickly and effected areas remediated. Spill kits available to allow for fast clean up Waste management plan to be implemented Haul Road Environmental culverts installed along haul road to prevent rain shadow effect Haul road to be bunded to prevent water ingress or egress after rainfall events Sumps and drainage installed along haul road to capture excess water Discharge of water possible only if water quality meets certain conditions (ANZECC 2000) Excess water collected and used for processing or within the processing circuit if possible Regular servicing of vehicles to prevent oil leaks and spills Regular clean up of drains and sumps to prevent silt build up Page 8 4

56 Environmental Aspect Management Strategy Mine Pits Pits bunded to exclude the 1 in 100 years event Water to be collected in empty voids to allow for the continuation of mining Water may be discharged to the lake if quality permits Abercromby creek diverted to separate it from mining areas Regular servicing of in pit machinery to prevent spills of contaminants In pit sumps to allow for the dewatering of pits Pits rehabilitated as soon as possible post mining to reduce problematic water retention 8.8 Monitoring Surface water monitoring in both lakes would commence during Project construction and continue throughout operations. The locations of this monitoring would be decided before the commencement of construction and reviewed before the commencement of mining and/or processing operations. Impacts to surface water quality would be managed through the mitigation of potential contaminant pathways that might be created during operation. Regular housekeeping, such as clean up of dust around the plant, the maintenance of vehicles and inspections of the haul road, would act to reduce the surface contaminants in and around the Project area and ensure that water coming into contact with these areas remains as clean as possible. Regular monitoring of pipelines and chemical and hydrocarbon storage areas would occur to ensure that no leaks or spills were occurring. Periodic aerial gamma surveys would be undertaken to ensure rehabilitation of disturbed areas returned these areas to pre mining gamma radiation levels. These surveys would also monitor areas downstream of water discharge locations to ensure no change in regional gamma measurements associated with waters from the Project. Periodic inspection of culverts, flood ways and stormwater management infrastructure would be undertaken, including assessment of adjacent vegetation, to determine if water ponding, water starvation or erosion was occurring that could affect vegetation health. All surface water management infrastructure (including fixed monitoring equipment) would be inspected after rainfall events. 8.9 Trigger Levels The results of annual flora surveys would be used to determine whether contingency actions should be taken. If vegetation health downstream of interrupted flows was seen to be deteriorating, the Project would take the contingency actions as outlined in Section Contingencies Should the monitoring indicate that the objectives of this plan were not being met, Toro would take remedial action which could include: The installation of further culverts to return natural sheet flows downstream of roads and haul roads; Revegetate disturbed areas quickly to prevent erosion; If revegetation was not an option, other methods of ground stabilisation would be investigated; and Reviewing bund height and design. Page 8 5

57 8.11 Reporting All surface water monitoring, inspections and audits would be included in Toro s Annual Environment Report. A copy of this report would be made publicly available on the Toro website Review and Revision This plan would be reviewed annually as surface water monitoring data was assessed. Where management methods were found not to be adequate, the plan would be updated to include more effective methods. The plan would also be reviewed after any significant rainfall events that may lead to a temporary disruption in operations. The aim of this review would be to determine whether the surface water management measures in place could be altered to allow mining to either continue during these periods or to allow mining to resume as quickly as possible after such events. Page 8 6

58 9 GROUNDWATER DRAWDOWN MANAGEMENT PLAN 9.1 Environmental Factor To maintain representation, diversity, viability and ecological function at the species, population and community level. To maintain the quality of groundwater and surface water, sediment and biota so that the environmental values, both ecological and social, are protected. To maintain the hydrological regimes of groundwater and surface water so that existing and potential uses, including ecosystem maintenance, are protected. 9.2 Purpose of the Plan Drawdown associated with the Project has the potential to impact GDV systems and in turn impact the fauna that exists within those ecosystems. The dewatering of the ore body is an inevitable consequence of mining and some impacts on the immediate environment are unavoidable. This plan aims to allow for mine dewatering whilst also setting up barriers at which the impacts would be managed and controlled. 9.3 Relevant Legislation and Standards Legislation The following legislation is applicable to this management plan: Rights in Water and Irrigation Act 1914 (WA); Environmental Protection Act 1986 (WA); and Environmental Protection and Biodiversity Conservation Act 2000 (Cwlth) Standards and Guidelines The following standards and guidelines are applicable to this plan; EPA, Position Statement No. 4 Environmental Protection of Wetlands; EPA, Position Statement No. 2 Environmental Protection of Native Vegetation; DoW, Operational Policy No Policy on water conservation/efficiency plans; DoW, Water Resource Allocation and Planning Series Report No. 45 Groundwater riskbased allocation of planning process; and DoW, Water Licensing Delivery Series Report No. 12 Western Australian Water in Mining Guidelines. 9.4 Existing Environment The four deposits to be mined are situated on the shores of a salt lake (Centipede, Millipede and Lake Way) or inside the lake itself (Lake Maitland). To allow safe operation, Toro proposes to undertake dewatering of the areas to be mined. Hydrological investigations across the four deposits have determined the volumes of water to be abstracted to enable mining and the predicted levels of drawdown associated with the dewatering. Figure 9.1 to Figure 9.3 show the predicted drawdowns associated with dewatering the deposits. Figure 9.1 has been developed based on a cumulative dewatering model that assumes both Centipede and Millipede deposits are being dewatered at the same time. The Lake Maitland and Lake Way figures are based on dewatering the deposits individually. Each figure assumes that no measures have been implemented to retard the ingress of water into the dewatering areas. Page 9 1

59 However, Toro has committed to installing compacted clay barriers which have been found in field trials to reduce water ingress into pits by up to 80% (Toro, 2011). Accordingly, it can be assumed that drawdowns associated with mine dewatering as depicted in the figures represent worse case scenarios unlikely to be encountered during operations. Figure 9.4 and Figure 9.5 show the predicted drawdown associated with the pumping and subsequent use of the two planned borefields. Figure 9.4 shows the drawdown from the borefield at Lake Maitland (Golder Associates, 2011). The outer most blue line shows the 0.5 m drawdown contour when the borefield is pumped at 1.3 GL/a for a period of 20 years. The yellow line shows how the drawdown would appear based on an annual abstraction rate of 1 GL/a for 13 years. Because the aquifer in the area is highly transmissive, there is little change between the two models (RPS, 2015). Figure 9.5 shows the predicted drawdown that would occur based on using the West Creek Borefield for a period of seven years and abstracting at a rate of 0.7 GL/a (RPS Aquaterra, 2010a). Figure 9.1: Centipede and Millipede Modelled Drawdowns Page 9 2

60 Figure 9.2: Lake Maitland Modelled Drawdowns Figure 9.3: Lake Way Modelled Drawdowns Page 9 3

61 Figure 9.4: Lake Maitland Borefield Modelled Drawdowns Page 9 4

62 Figure 9.5: West Creek Borefield Modelled Drawdowns Page 9 5

63 9.5 Roles and Responsibilities The roles and responsibilities for implementing this management plan are outlined in Table 9.1. Table 9.1: Roles and Responsibilities Position Responsibility Environmental Manager Implementation and maintenance of this plan Undertake an assessment of the effectiveness of the plan and make changes accordingly Environmental Superintendent Ensure the plan is being adhered to on site Ensure daily compliance with ministerial conditions and other approvals/licences Carry out monitoring and ensure records are kept and maintained Operations Managers and Site Supervisors Ensure that operations are adhering to this plan Participate in audits and inspections are required Staff, Contractors and Visitors Ensure dewatering is occurring in compliance with this plan Report incidents of excess dewatering or excess drawdown 9.6 Environmental Management Purpose The purpose of this plan is to identify management measures that would allow the Project to operate whilst still meeting groundwater drawdown restrictions and impact levels. Toro is required to ensure that outside of the 0.5 m drawdown contour there would be no adverse impacts on flora, vegetation, fauna (including subterranean) and groundwater quality. Specific management measures to monitor each of these areas are outlined in this plan Potential Impacts Flora and Vegetation If left unchecked, groundwater abstraction may lead to greater than predicted drawdowns and would impact those species and communities outside the 0.5 m drawdown contour. Limiting the availability of water to flora and vegetation communities may lead to stress on individual plants, death of individual plants and may reduce the flora and vegetation values of the local environment Fauna The direct impact associated with groundwater drawdown on fauna would occur to subterranean stygofauna populations. These species live within voids in the ground and are susceptible to habitat loss if excess dewatering and drawdown occurs. While Toro has shown that the range and distribution of these species is greater than previously thought, unmanaged dewatering could have significant impacts on stygofauna populations (Outback Ecology Services, 2012c). Indirectly, excess dewatering and drawdown would impact flora and vegetation, reducing the availability of resources and increase the competition for them. This may lead to reduced population sizes of many species and to the loss of populations and species within the greater region. Page 9 6

64 At the West Creek borefield local, Eucalyptus species are described as being groundwater dependent. Water levels within the borefield, measured by Toro, remain relatively stable as the borefield area acts as a sink for the local catchment. The impact of having relatively stable water levels is that the species are more sensitive to slight changes in the depth to water. Excess pumping of the West Creek borefield could lead to widespread drawdowns in the greater region which could adversely impact local Eucalyptus species. Groundwater Quality Excess dewatering has the potential to alter groundwater quality. As new water enters dewatered areas, there may be changes in groundwater chemistry including increases in salinity. Changes in salinity may impact the ability of flora to use the water and can directly impact flora communities and vegetation units. Changes in groundwater chemistry may also lead to an increase or decrease in dissolved metals, radionuclides and other contaminants that may make water unsuitable for pastoral uses and human consumption. Groundwater Levels The Project area lies within working cattle stations that are dependent on groundwater for their livestock. Excess dewatering and drawdown has the potential to dry out bores and wells used to water livestock and can have the same consequences on livestock as a severe drought. 9.7 Managing Potential Impacts Most of the impacts identified above are dependent on excess and unrestricted drawdown occurring. To manage this, Toro has committed to the installation of water barriers around mining pits to limit groundwater infiltration and reduce the volume of water that is required to be abstracted to allow mining to occur. In 2011, Toro under took a series of trials to assess different water barrier construction methods and materials to determine what type of barrier would work best (Toro, 2011). Two types of barrier, an HDPE liner and a compacted clay barrier were trialled in two areas of the Centipede deposit that were considered representative of the wider mining areas. Three sumps were installed and were initially pumped dry without barriers and the time taken for groundwater to return was measured. This was done several times to determine how water would behave in the mining areas. Next, two of the sumps were lined with a continuous sheet of HDPE plastic which was then secured in place with crushed waste rock material. These barriers had some effect in stopping the ingress of water; however, the construction of the barrier during the trail was imperfect, and large waste rock boulders ripped the HDPE plastic, reducing its effectiveness. In a third sump, a trench around the sump was dug and was continuously dewatered while a compacted clay barrier was installed. Once the barrier was complete, the dewatering pump was removed and the time taken for water to fill the sump was measured. The trial suggested that the clay barrier reduced water ingress by 80%. Due to the success of the clay water barrier, Toro would use it in the construction of the mine to reduce the volume of water to be abstracted. For this reason, drawdown curves generated during hydrological studies should be considered worse case scenarios. At each of the 1.0 m and 0.5 m drawdown contours, a series of bores would be established to monitor monthly for groundwater quality. They would be fitted with continuous level logging devices to also monitor drawdown in the region. By establishing these points, Toro would be able to continuously monitor modelled or planned drawdown versus actual data. With water barriers in place it is expected that drawdown would occur within planned rates. If this did not happen, Toro would be able to develop contingency actions prior to approved drawdown levels being exceeded. Page 9 7

65 9.8 Environmental Objectives and Performance Indicators The environmental objectives and performance indicators are outlined in Table 9.2. Table 9.2: Environmental Objectives and Performance Indicators Environmental Objective No impacts to flora, vegetation and fauna communities outside the 0.5m drawdown contour No impacts on other groundwater users in the Project area Performance Indicator No changes in plant health when impact sites are compared to non impact sites Drawdown at or below modelled levels Drawdown is at or below predicted levels Groundwater chemistry outside the 0.5m drawdown contour remains consistent with pre mining data 9.9 Environmental Aspects and Management Strategies The environmental aspects and management strategies for the Groundwater Drawdown Management Plan are outlined in Table 9.3. Table 9.3: Environmental Aspects and Management Strategies Environmental Aspect Management Strategy Mine Dewatering Water barriers installed around perimeter of the pit to reduce water ingress Mining to occur in compartments to reduce the need for excess abstraction Hydrology studies undertaken to assess worst case drawdown scenarios Monitoring points established in predicted drawdown areas and data to be compared with model predictions Regional groundwater chemistry monitoring to continue Borefield Water Abstraction Borefield to be licenced with maximum abstraction limit Limits not to be exceeded Monitoring points established in predicted drawdown areas and data to be compared with model predictions Vegetation health monitoring to commence both inside and outside the impact areas to enable vegetation health to be measured 9.10 Monitoring To ensure the drawdown at the mine and the borefields is occurring at or below model predictions, the monitoring outlined in Table 9.4 would be implemented. Page 9 8

66 Table 9.4: Mine Dewatering Monitoring Schedule Measurement Frequency Abstraction Volume Ongoing, pumps fitted with meters Drawdown in Monitoring Bores Real time ongoing monitoring using down hole level loggers Groundwater Chemistry in Monitoring Bores Monthly sampling of ph, EC, and dissolved metals Quarterly monitoring for radionuclides, total metals, major cations and anions Annual monitoring for hydrocarbons Regional Groundwater Chemistry Monthly sampling of ph, EC, and dissolved metals Quarterly monitoring for radionuclides, total metals, major cations and anions Annual monitoring for hydrocarbons Table 9.5 outlines the monitoring to be implemented at the borefields. Table 9.5: Borefield Monitoring Schedule Measurement Frequency Groundwater Abstraction Ongoing, pumps fitted with meters and abstraction restricted to approved volumes Groundwater Drawdown Ongoing, monitoring bores to be fitted with level loggers Borefield and Regional Groundwater Chemistry Monthly sampling of ph, EC, and dissolved metals Quarterly monitoring for radionuclides, total metals, major cations and anions Annual monitoring for hydrocarbons Vegetation Health Annual vegetation health surveys in established quadrats both inside and outside of impact areas 9.11 Trigger Levels Toro has undertaken modelling to assess how drawdown would occur and would use the model to predict annual drawdowns during operation. Where actual drawdowns are seen in real time to be exceeding modelled drawdowns, contingency actions would be taken Contingencies Where vegetation health is being affected by the Project, the operation of the borefield would be reviewed. This may include reducing pumping from one borefield and increasing pumping from another, or the intermittent use of the two borefields. Where this is still not satisfactory, Toro would search for a third acceptable source of water to reduce the load on the two existing sources of water. The use of water barriers and worse case hydrological modelling should ensure that groundwater drawdown is as or less than predicted. In the case that drawdown was found to be exceeding the modelling, further investigations into the mining sequence would occur to determine how dewatering could be reduced. These methods could include: Mining and dewatering of smaller compartments to reduce dewatering required; Page 9 9

67 Switching mining between deposits, to allow groundwater levels to recover before recommencing mining; and/or Reinjection of abstracted water upstream or into excess drawdown areas to replace the water abstracted should issues such as salinity not raise further issues Reporting The results of all monitoring undertaken as part of this plan would be reported in Toro s Annual Environment Report. All data would be made publicly available on the company website. Any instance of excess dewatering would be recorded as an incident and reported to the appropriate authority Review and Revision This management plan would be reviewed annually when the data is collected for the Annual Environment Report. The plan would also be reviewed in the event that current management strategies were not leading to outcomes that satisfy the objectives of the plan. Page 9 10

68 10 DUST MANAGEMENT PLAN 10.1 Environmental Factor The environmental factor associated with dust management is human health. The aim of the human health key environmental factor is to ensure that human health is not adversely affected by dust emissions. Dust can also impact flora and fauna populations if not properly managed 10.2 Purpose and Objective This Dust Management Plan has been prepared by Toro to describe management actions to be implemented during the construction and operational phases of the Project and to measure their effect. The plan addresses the following: Dust generated from the construction of site infrastructure; Dust generated from the extraction of mined materials; Dust generated from the transport and handling of mined materials; Dust generated from the maintenance of site infrastructure; and Dust generated as a result of wind erosion Relevant Legislation and Standards There are currently no relevant Western Australian standards related to permissible ground level dust concentrations. In lieu of such standards, and in accordance with the current Draft State Environmental (Ambient Air) Policy 2009 (the Draft Policy) (EPA, 2009) authorised under the EP Act, the Wiluna Uranium Project would aim to comply with the requirements of the National Environment Protection (Ambient Air Quality) Measure as varied (the NEPM) (NEPC, 2003). Where the NEPM does not specify a relevant dust criterion, reference would be made to the World Health Organisation Air Quality Guidelines (WHO, 2006) or other criteria determined by the Western Australian Department of Environment Regulation to be applicable to the local and regional context. For the purpose of the assessment presented in the PER and in this plan, additional performance criteria were obtained from the EPA s Environment Protection (Kwinana) (Atmospheric Wastes) Policy 1999 (EPA, 1999) and the New South Wales Department of Environment, Climate Change and Water Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (DECCW, 2005) Existing Environment Region The dominant land use within the Project area is pastoralism, and the Project is situated entirely on Lake Way, Millbillillie and Barwidgee pastoral leases. The closest sensitive receptor would be the accommodation camp to be located approximately 5 km to the south west of the Centipede and Millipede deposits. At Lake Maitland, a smaller camp would be established a similar distance from the mining area. Regular dust monitoring at these locations would occur to ensure exposure to workers was kept below designated levels. Additional sensitive receptors are at Lake Way Station (20 km south east of Centipede/Millipede), Barwidgee Station (40 km north west of Lake Maitland) and the town of Wiluna (15 km to the north of the Lake Way deposit). Due to the distance of the receptors from the operation, and the prevailing wind directions, it is unlikely that any change in airborne dust would occur at any of these receptor locations. Page 10 1

69 Climate Weather stations established at Centipede and Lake Maitland confirm that wind direction at both deposits is from the north east. Wind speeds are generally at their highest in the morning, gradually declining throughout the day and evening. Toro has established a series of dust monitoring stations at Centipede, Lake Maitland and along the proposed haul road. Currently dust deposition gauges are deployed. Prior to Project implementation active dust collection methods such as hi vol sampling and microvol sampling are planned. Due to the extremely low levels of background airborne dust, dust deposition results are analysed annually so that a reliable sample can be collected Regional Dust Levels Background dust levels throughout the Project area are highly variable due to atmospheric events such as dust storms, wind storms and heavy rainfall events. Dust generated by the Project has the potential to be significant due to: The clearing of vegetation, exposing soils prone to lift off; Infrequent rainfall events and high evaporation in the region leading to dry soils; Occasional high winds; and Haulage of ore from Lake Way and Lake Maitland to the processing plant The cumulative impact of natural dust generation coupled with dust generation from the Project has the potential to generate significant dust impacts. Microvol dust collection has been occurring at Centipede since The average monthly dust deposition at four stations is shown in Figure The locations of the dust deposition gauges are north, south, east and west of the cleared area used for the trial mine pit in 2010 and the water barrier trial in The figure clearly shows that dust deposition is variable. However, for most of the year there is a significant amount of dust deposited downstream of the prevailing wind direction, showing that soils in the Project area are easily mobilised by the wind. Page 10 2

70 Figure 10.1: Dust Deposition across the Centipede Deposit 10.5 Objectives and Criteria The Project is located in remote central Western Australia. The Draft Policy contains advice in relation to the interpretation of the NEPM criteria in remote areas, specifically: Where there is a reasonable likelihood that no sensitive areas will be present, the criteria may be achieved at the nearest sensitive receiver rather than the premises boundary, where sensitive receivers are defined as areas where humans reside or areas of cultural and/or environmental significance (including environmentally sensitive areas declared under the EP Act). It is expected that industry would adopt and achieve best practice management of its operation and emissions control, which may require emission limits to be set and monitored at the source. The nearest sensitive receivers to the proposed development are listed in Table Table 10.1: Location of Nearest Sensitive Receivers Receptor Distance 1 (km) Toro House 9.4 Apex Village 6.3 Wiluna township 12.6 Lake Way Station 28 Barwidgee Station 40 Millbillillie Station 7.7 Page 10 3

71 Receptor Distance 1 (km) Ngangganawili Community 5.2 Bondini Reserve 12.0 Proposed Village Centipede/Millipede Proposed Village at Lake Maitland Notes: 1. Distance from nearest operation related dust generating activity; 2. No legislative requirement for accommodation villages to meet the performance criteria. In accordance with the Draft Policy, a target of meeting the performance criteria developed for the Project at each of the above mentioned sensitive receivers would represent compliance with the overarching dust management objective of no adverse impacts to sensitive receivers as a result of the proposed development. Table 10.2 summarises the objective and criteria applied to the Project. Table 10.2: Dust Management Objective and Performance Criteria Objective No adverse impacts to sensitive receivers as a result of the proposed Wiluna Uranium Project Performance criteria to be met at nearest sensitive receivers Origin Measure Criteria (µg/m 3 ) NEPM (Air Quality Standards) PM (24 hour average) NEPM (Advisory standard) PM (24 hour average) PM (annual average) WHO PM (annual average) Kwinana EPP 1 TSP 90 (24 hour average) NSW DECCW 2 TSP 90 (annual average) Dust deposition Dust deposition 4 3 (total deposition) 2 3 (additional deposition) Notes: 1 Environmental Protection Authority Environment Protection (Kwinana)(Atmospheric Wastes) Policy 1999 (EPA 1999); 2. NSW Department of Environment, Climate Change and Water Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (DECCW 2005); 3. Measured in units of g/m²/month Predicted Dust Emissions Project dust emissions at the Lake Maitland and Centipede/Millipede and Lake Way deposits have been calculated (Figure 10.2 to Figure 10.4) (Air Assessments, 2015). These figures have been developed based on mining and stockpiling and processing and show the worst case predicted dust depositions in grams per square meter per month. The deposition rates are for total dust, which included both mineralised and non mineralised material. Toro has undertaken Environmental Risk of Ionising Contaminants (ERICA) modelling for these dust depositions that shows there are no adverse impacts to the workforce or receiving environment based on the predicted dust deposition models. The predicted dust deposition contours will be used as a guide to assess overall Project dust generation, with the target being to ensure dust generation levels at or below predicted values. Page 10 4

72 Figure 10.2: Predicted Dust Depositions at Lake Maitland Page 10 5

73 Figure 10.3: Predicted Millipede Dust Deposition Levels Page 10 6

74 Figure 10.4: Lake Way Dust Deposition Page 10 7