Cristal Mining Australia Ltd. MSP Waste Management Plan

Transcription

1 Cristal Mining Australia Ltd MSP Waste Management Plan

2 Abbreviations Rev No. Document No. Description Approval Details Date A Draft for Cristal approval B Draft for submission to the Department of Planning and Infrastructure Approved Final Approved by the Director- General January 2013 September Table 2 amended GHD and Cristal October Annual Review Cristal November GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

3 Abbreviations Abbreviation AEMR AR ARPANSA Bq Cristal BHCC CE DA DECC DECCW DOP DNR DPI EIS EMS Full Title Annual Environmental Management Report Annual Return (as required by the EPL) Australian Radiation Protection and Nuclear Safety Agency Becquerel. One Becquerel is defined as the activity of a quantity of radioactive material in which one nucleus decays per second. In this Plan Bequerels are expressed as Bq/gram. Cristal Murray Basin/Cristal Mining Australia Pty Ltd Broken Hill City Council Country Energy Development Application NSW Department of Environment and Climate Change (now OEH) NSW Department of Environment, Climate Change and Water (now OEH) NSW Department of Planning and Infrastructure Department of Natural Resources (responsibility now split between OEH and NOW) NSW Department of Primary Industries (part of NSW T&I) Environmental Impact Statement Cristal Murray Basin Environmental Management Strategy EPA NSW Environment Protection Authority (part of OEH) EP & A Act Environmental Planning and Assessment Act 1979 EPL GHD HMC Environmental Protection Licence GHD Pty Ltd Heavy Mineral Concentrate LPMA NSW Lands Property Management Authority (abolished April 2011) MOP MSP NMP NOW NPWS NSW NSW T&I Mining Operations Plan Mineral Separation Plant (Broken Hill) Noise Management Plan New South Wales Office of Water NSW National Parks and Wildlife Service New South Wales NSW Department of Trade and Investment, Regional Infrastructure and Services (formerly Industry and Investment NSW) OEH NSW Office of Environment and Heritage (formerly DECC & DECCW) OEMP Operational Environment Management Plan POEO Act 1997 Protection of the Environment Operations Act 1997 RMP RMS WAMP WSC Radiation Management Plan NSW Roads and Maritime Authority (formerly RTA) Waste Management Plan Wentworth Shire Council 3 GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

4 Limitations This report has been prepared by GHD Pty Ltd (GHD) for Cristal Mining Australia Ltd (Cristal) and may only be used and relied on by Cristal for the purpose agreed between GHD and Cristal as provided in section 1.1 and 1.2 of this report. GHD otherwise disclaims responsibility to any person other than Cristal arising in connection with this report. GHD also excludes implied warranties and conditions, to the extent legally permissible. The services undertaken by GHD in connection with preparing this report were limited to those specifically detailed in the report and are subject to the scope limitations provided in the report. GHD s scope of works was limited to updating Cristal s environmental documentation into standardised templates that are consistent with ISO and address Cristal s most recent approval requirements. GHD has relied on information provided in existing plans, the specific requirements stated within licences, permits and approval conditions provided to GHD and advice provided by Cristal on the status of works and implementation of management measures for the pre-construction and construction phase works. GHD has updated documents based on advice from Cristal relating to their current operations and management practices. GHD has not proposed new mitigation or management measures. Where GHD has identified deficiencies or anomalies in the existing plans, these have been updated based on additional information provided by Cristal. It is not within GHD s scope of works to undertake a detailed risk assessment for environmental aspects, including impacts from radioactive materials, or to provide specialist advice on the suitability of mitigation measures or to devise new mitigation measures. The opinions, conclusions and any recommendations in this report are based on conditions encountered and information reviewed at the date of preparation of the report. GHD has no responsibility or obligation to update this report to account for events or changes occurring subsequent to the date that the report was prepared. GHD has prepared this report on the basis of information provided by Cristal which GHD has not independently verified or checked beyond the agreed scope of work. GHD does not accept liability in connection with such unverified information, including errors and omissions in the report which were caused by errors or omissions in that information. 4 GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

5 Development consent(s) & project approval modification On 20 October 2014, the Secretary for the Minister for Planning issued Cristal with the following Notice of Modification(s) for Cristal s operations in the Murray Darling Basin: Ginkgo Mineral Sands Project (DA ), Modification 11. Snapper Mineral Sands Project (PA 06_0168), Modification 5. Mineral Separation Plant (DA ), Modification 3. In relation to these modifications, Cristal acknowledges the following: Minor changes will be required to the Environmental Management Strategy (EMS, ) and subordinate management plans to reflect the changes required to department names, acronyms and abbreviations. Specific changes will be required to individual documents to reflect changes to consent conditions which affect future operational management requirements. The Notice(s) of Modification are appended to the EMS and Environmental Management Plans affected by specific condition changes prescribed in the above modification notices. Cristal is committed to amending the EMS and affected management plans in general accordance with Section 6.1 of the EMS in such that minor changes (not affecting operations) will be completed within 3 years of the date of the issue of the above Modifications. Plans impacted by changes to specific conditions effecting operations will be updated within 3 months of the completion of internal audits of these plans (May 2015), with the exception of the MSP Noise Management Plan (603243), which is required to be updated by 31 March 2015 (Schedule 2, Condition 3.6A, MSP Mod 3). 5 GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

6 Table of contents Limitations... iii Development consent(s) & project approval modification... iv 1. Introduction Purpose of the Management Plan Scope of the Management Plan Document succession Project description Environmental Impact Statement Waste generation Non-process waste Summary of potential environmental impacts Environmental management framework Relationship to other environmental management plans Legislative requirements and project environmental approvals Activities must be carried out in a competent manner Roles and responsibilities Training and inductions Complaint, non-conformance and incident management Environmental reporting and correspondence Audits of the EMP Review and update of WAMP Waste management program Objectives Performance standards Non-process waste management strategy Process waste management strategy Waste management mitigation measures Environmental monitoring and inspections Contingency measures References GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

7 Table index Table 1 Estimated quantities of wastes from MSP circuits... 4 Table 2 MSP waste streams... 6 Table 3 Approval documents for the MSP Table 4 Regulatory consent conditions applicable to this WAMP Table 5 Non-process waste management strategy Table 6 Process waste management strategy Table 7 Waste management mitigation measures Figure index Figure 1 MSP Mineral Separation Process... 3 Figure 2 Cristal s environmental management framework... 8 Figure 3 Environmental management documents for Cristal s operations in the Murray Basin in NSW GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

8 1. Introduction 1.1 Purpose of the Management Plan Cristal Mining Pty Ltd (Cristal) operates a number of mineral sands mines and a mineral separation plant in the Murray Basin. Cristal s sites in the Murray Basin have collectively been referred to as the Murray Basin sites for the purpose of this document. This Waste Management Plan (WAMP) has been created for the management of general and hazardous waste at the Mineral Separation Plant (MSP) in Broken Hill. 1.2 Scope of the Management Plan The WAMP provides an overview of the environmental management and performance requirements related to waste of the MSP. This WAMP includes: The requirements for environmental management of waste for operations at the MSP as stipulated by regulatory approvals for the project; The responsibilities for implementing this WAMP; A description of the environmental controls and associated limits to meet objectives, targets and regulatory approval requirements; and An overview of the environmental monitoring programs and contingency measures associated with environmental mitigation measures. Further details on the Environmental Management Framework for Cristal s operations at this site are provided in Section Document succession Cristal has previously developed the following plans to manage waste: MSP Waste Process and Management Plan (WPMP-R01-A, August 2006); and MSP Waste Management Plan (WAMP-R01-E, June 2006). This WAMP supersedes the documents listed above, which are now obsolete. This WAMP has been prepared on the basis of information contained within the original management plans and advice received from Cristal regarding current activities and management measures. Development of new measures to manage waste is outside GHD s scope. Cristal is required to submit management plans to the Department of Planning and Infrastructure for approval. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

9 2. Project description The Environmental Management Strategy (EMS, see Section 2 below) provides details on the current operations at the MSP within the Murray Basin in NSW. Waste is considered to be an environmental aspect that requires management to minimise impacts associated with activities for the project. 2.1 Environmental Impact Statement An Environmental Impact Statement (EIS) was completed for the MSP in 2001 (Bemax 2001). The EIS and EA documents were prepared in accordance with the requirements of the NSW Environmental Planning and Assessment Act 1979 (EP & A Act), to accompany the Development Application (DA) submitted by Bemax (now Cristal) for the Project. 2.2 Waste generation Process waste The separation process utilised at the MSP is detailed in Figure 1. The separation produces a waste stream containing monazite (which is radioactive). GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

10 GINKGO MINE Salt Washing Facility WHIMS Circuit Ilmenite Concentrate LEGEND Tank / Surge Bin Water Input Dry Mineral Separation Circuit Wet Gravity Separation Circuit Dewatering Cyclone Reject Processing Flow Product Process Water Output Dewatering Cyclone Leucoxene Concentrate Non-Magnetic Concentrate Dewatering Cyclone Ilmenite Concentrate Stockpile Leucoxene Concentrate Stockpile Non-Magnetic Concentrate Stockpile Transport to MSP MINERAL SEPARATION PLANT MAGNETIC MINERALS NON-MAGNETIC MINERALS Concentrate Stockpile Mineral Dryer High Tension Magnetic Separation Rejects To Rejects Stockpile via Dewatering Cyclone Spirals and Wet Tables Concentrate Dewatering Cyclone Concentrate Stockpile Water Circuit Refer to Figure 6 Leucoxene Storage Shed Rail Loadout Non-Magnetics Concentrate Stockpile Rail Loadout Rejects Stockpile Dewatering Cyclone Ilmenite Concentrate Stockpile Mineral Dryer To Rejects Stockpile Water Circuit Refer to Figure 6 Water Circuit Refer to Figure 6 High Tension Magnetic Separation Rejects Dewatering Cyclone Rejects Magnetic Separation Klin (Fluid Bed Roaster) Dewatering Cyclone Dewatering Cyclone To Rejects S tockpile Water Circuit Refer to Figure 6 Water Circuit Refer to Figure 6 Roasted Ilmenite Storage Shed Rail Loadout Sulphate Ilmenite Stockpile MSP Mod i f i c a t i o n FIGURE 8 MSP Process Flow Sheet - Stage 2 SEE BMX MSP_016D Figure 1 MSP Mineral Separation Process GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

11 Process wastes generated from the separation process are: silica and quartz from the feed preparation circuit; monazite and silicate minerals from the ilmenite and leucoxene circuits; and silicate minerals from the zircon and other dry circuits. Table 1 provides estimates of quantities of wastes from MSP circuits. Table 1 Estimated quantities of wastes from MSP circuits Waste Source Waste Quantity (t/pa) Feed Preparation Circuit 54,400 Leucoxene Circuit 12,000 Ilmenite Circuit 24,400 Rutile Circuit 7,200 Zircon Circuit 22,400 Total 130,000 The 130,000 tonnes per annum estimate is the same as the (updated) EPL limit. Process waste materials from the wet plant and dry plant have different radiation activity levels due to the handling of the monazite fraction. The dry plant removes monazite and other wastes (mostly quartz) which are classified as hazardous materials. The wet plant however, does not remove the monazite from the mineral concentrate and therefore the resulting waste stream is classified as inert waste in accordance with Waste Classification Guidelines. Process wastes can be separated into the following waste streams; MSP rejects (approximately 36,300 tonnes per annum); Inert Process Wastes (approximately 24,100 tonnes per annum; Stack discharge; and Baghouse dust (approximately 3,600 tonnes per annum) MSP rejects The MSP rejects are made up of blended wastes from the wet and dry plants. The MSP rejects emit low levels of radiation. This is due to the fact that heavy mineral sands ore bodies contain traces of the natural radioactive elements uranium and thorium together with their daughter nuclide. One process waste (monazite) generated at MSP has a higher level of radioactivity. The monazite fraction of the MSP rejects determines the overall radioactivity levels of the MSP rejects. As detailed in the Murray Basin Waste and Landfill Management Plan and Cristal Radiation Management Plan, monazite waste is managed as follows: On separation from the product zircon mineral, the monazite reject stream is directed to a process sump where it is moistened and blended with other waste streams to produce MSP rejects; The MSP rejects are then stored as a damp ( pugged or slurried) waste material with a total activity level of under 100 Bq/g; GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

12 The MSP rejects are then stored in a concrete storage bay fitted with overhead sprinklers; Each truckload of MSP rejects is sampled with a gamma radiation meter at 1 m and the reading recorded on the Shippers Declaration Form; and Stockpiled pugged MSP rejects are subsequently backloaded into mineral concentrate trucks for disposal at the Ginkgo Mine. Given the radiation level of this material is less than 100 Bq/g, under Part 3 of the EPA Waste Classification Guidelines the waste is not classified as hazardous. The MSP rejects are dense and not prone to dusting, presenting an inherently low hazard material. They do not require shielding and persons can work near it for an extended period (about 100 hours) before approaching or exceeding the Annual Radiation Dose Limit for Members of the Public as set by the Radiation Control Regulations If there is no dust suspension in the air, then radiation dose by inhalation will not occur as a secondary pathway for whole body radiation exposure. Refer to the Cristal Radiation Management Plan for further detail on MSP rejects Inert process wastes On a small scale basis, the inert process waste material is reused as sand for making concrete that is used in shotcreting tunnels in nearby underground mine workings. In accordance with Waste Classification Guidelines, the criteria adopted for the levels of radioactivity that permit wastes to be classified in the inert waste category are recognised as being below regulatory concern, and the disposal of such material does not require formal approval. Cristal has received advice from the NSW EPA that this waste can be reused Stack discharge Small amounts of dust material are emitted from the MSP stack Baghouse dust Dust control systems within the MSP discharge their collected material (mineral and dust) in one of two ways. In the majority of instances, material is slurried and returned into the wet separation plant to be re-processed. Alternatively the dust from the collection units is collected and mixed with the MSP rejects. 2.3 Non-process waste A summary of the various waste streams expected to be generated from the offices, workshop, processing plant and ancillary activities at the MSP is provided in Table 2. Ancillary activities means those activities associated with the MSP including transportation of mineral concentrate, delivery of materials and operation of mobile equipment. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

13 Table 2 MSP waste streams Waste Waste Type Waste Generation Source Offices Workshop MSP Ancillary /Store Process Activities Non-Liquid Waste Putrescible and inert miscellaneous material. Sewerage Sludge Cans, containers Packagingpaper/cardboard/ plastic Wood Pallets Wood Misc. Batteries Scrap Steel Drums Tyres Hydrocarbon containers, oil filters, absorbents etc. Oil contaminated soils/silts Metal shavings Liquid Waste Human effluent Solvents Paints/ Preservatives and by products Waste oil Waste Grease Oil/fuel contaminated water Paint/metal/solvent contaminated water GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

14 2.4 Summary of potential environmental impacts Significant impacts potentially associated with operations were assessed in the EIS for the MSP development. Mitigation measures that regulatory authorities (for example, the DOP, EPA, RMS and local councils) deemed as being required to reduce potential risks to an acceptable level were identified and included in the Conditions of Approval and the Environment Protection Licence (EPL) (Table 3 and Table 4). A preliminary, high-level risk assessment for the Murray Basin sites was created as part of the update of the EMS. This high-level assessment was a subjective assessment based on Cristal s knowledge of site operations to-date and Cristal s advice on existing controls in reducing risks. Further details on this risk assessment are provided in the EMS. A summary of the potential environmental impacts for waste at the MSP is provided below: Exposure of personnel to hazardous (radioactive) substances; Mismanagement of process waste; Improper classification of waste; and Mismanagement of non-process waste. The mitigation measures outlined in this document are based on the requirements of regulatory consent conditions (Table 4) and industry best practice. Mitigation measures for the management of waste are provided in Section 4 of this document. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

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

16 3.1 Relationship to other environmental management plans The structure of the environmental management documentation is presented in Figure 3. This WAMP makes direct reference the following environmental management documentation listed in Figure 3: Mineral Separation Plant Operational Environmental Management Plan (OEMP) (GHD (Draft), November 2012); Murray Basin Operations Transport Management Plan and Code of Conduct (TMP) (GHD (Draft), September 2012); Murray Basin Radiation Management Plan (RMP) (Hunter Valley Radiation Services, January 2012); and Snapper and Ginkgo Waste and Landfill Management Plan (WLMP) (Currently under review by GHD). This management plan should be read in conjunction with the above management plans as appropriate. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

17 Companywide Integrated Management System (Environment and Safety) Murray Basin Operations Environmental Management Strategy Ginkgo Snapper Mineral Separation Plant Murray Basin Operations Community Consultation Plan Murray Basin Operations Traffic Management Plan & Code of Conduct Murray Basin Operations Radiation Management Plan Murray Basin Operations Environmental Monitoring Program Ginkgo Painted Burrowing Frog Management Plan Ginkgo Mining Operations Plan Ginkgo Mine Closure Plan Ginkgo DMU Salinity and Rehabilitation Management Plan Ginkgo Integrated Mining Rehabilitation Environmental Management Plan Pollution Incident Res ponse Management Plan Air Quality Management Plan Cultural Heritage Management Plan Water Erosion and Sediment Control Management Plan Waste and Landfill Management Plan Noise Management Plan Bushfire Management Plan Flora and Fauna Management Plan Land Management Plan Snapper Mining Operations Plan Pollutant Incident Response Management Plan Effluent Management Plan Operational Environment Management Plan Air Quality Management Plan Energy Savings Management Plan Water Management Plan Emergency Response Management Plan Safety Management Plan Noise Management Plan Waste Management Plan Cultural Heritage Management Plan Construction Environment Management Plan Noise Management Protocol Erosion and Sediment Control Plan Safety Study Fire Study Risk Hazard Analysis Energy Savings Management Plan Borefield Impact Management Plan Offset Management Plan Figure : Environmental Management Documentation for Cristal Operations in the Murray Basin in NSW 10 GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

18 3.2 Legislative requirements and project environmental approvals Project regulatory approvals Cristal is required to create, maintain and implement EMPs in accordance with the approval conditions for the MSP. There are two regulatory approval documents that contain conditions for environmental management that Cristal must adhere to for operations at this site. This WAMP has been created to address the specific requirements of the regulatory approval documents. The current regulatory approval documents are provided in Table 3 below. The requirements of these regulatory approvals are provided in Table 4. With regards to Conditions of Approval granted for the MSP under the Environmental Planning & Assessment Act 1979 it is noted that development consent for the MSP was granted pursuant to Section 80(1) (Part 4) in May Table 3 Approval documents for the MSP Approval Document Document Number Current revision date Mineral Separation Plant Conditions of Approval DA December 2008 Mineral Separation Plant Environmental Protection Licence EPL September 2013 GHD Report for Cristal Mining Au

19 Table 4 Regulatory consent conditions applicable to this WAMP Condition number Condition details Section in WAMP Mineral Separation Plant DA Classification of controlled waste (m) The Applicant must accurately identify the waste, in accordance with Condition 6.4(c)(vii), and determine if the waste is a controlled waste within the meaning of the NEPM. NOTE: The waste producer must check with the agency in the State or Territory of destination to determine whether waste is classified as a controlled waste under the NEPM. Unless advised otherwise by the agency of the State or Territory of destination, any waste included in Appendix 1 of this licence is a controlled waste for the purposes of the NEPM. Application for a consignment authorisation (n) If the waste is transported from the Premises to another participating State or Territory, the Applicant must comply with all Conditions attached to the consignment authorisation issued by an agency or a facility delegated by an agency in the destination State or Territory. Refer to Murray Basin Operations Transport Management Plan and Code of Conduct Schedule 2, Condition 3.12 Waste Management NOTE: The waste producer is required by the Protection of the Environment Operations (Waste) Regulation 1996 to obtain, prior to the waste being dispatched, a consignment authorisation from an agency, or a facility delegated by an agency, in the destination State or territory to allow the movement of controlled waste. Waste movements Sections 4.5 and (o) (p) (q) If the waste is transported from the Premises to another participating State or Territory, the Applicant must ensure that the waste is transported to a place that can lawfully be used as a waste facility for that waste. The Applicant must ensure that the waste transporter is licensed as required by the agency of each participating State or Territory through which the waste is transported. The Applicant must: retain a copy of the waste transport certificate for the waste for a period of not less than 4 years from the time the form was completed, and make the copy of the waste transport certificate available for inspection by an authorised officer on request. NOTE: The waste producer is required by the Protection of the Environment Operations (Waste) Regulation 1996 to complete a GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

20 Condition number Condition details Section in WAMP waste transport certificate for the waste. This should be done in accordance with the instructions printed on the certificate and the required copy of the waste transport certificate should be forwarded to the agency in the State of destination. Waste Management Section 4.5 (s) (t) (u) The Applicant must not cause, permit or allow any waste generated outside the Premises to be received at the Premises for storage, treatment, processing, reprocessing or disposal or any waste generated at the Premises to be disposed of at the Premises, except as expressly permitted by a licence under the POEO Act This Condition only applies to the storage, treatment, processing, reprocessing or disposal of waste at the Premises if it requires an environment protection licence under the POEO Act Except as provided by any other Condition of this Consent, only the hazardous, industrial or group A waste listed below may be generated or stored at the Premises. NOTE: Radioactive waste assessed as hazardous or industrial waste under Section 3.5 of the Wastes Guidelines. (v) The total tonnage of waste defined in Condition 3.12(u) of this Consent generated or stored at the premises must not exceed 300,000 tonnes per annum. Schedule 2, Condition 4.5 Waste Monitoring (a) (b) Conditions 3.12 and 7.3 apply to the movement of the types of hazardous and/or industrial and/or Group A waste as listed in Condition 3.12(u), within NSW. Conditions 3.12 and 7.4 apply to the movement of the types of hazardous and/or industrial and/or Group A waste as listed in Condition 3.12(u), into and out of NSW. As addressed in GHD audit, there are no conditions 7.3 and 7.4 in the current DA. An Opportunity for Improvement was identified for this licence condition to be amended. Schedule 2, Condition 4.6 Monitoring and Reporting Conditions The results of any monitoring required to be conducted by the EPA s general terms of approval, or a licence under the POEO Act 1997, in relation to the development or in order to comply with the load calculation protocol must be recorded and retained as set out in Subclauses (b) and (c). (b) All records required to be kept by the EPA licence must be: in a legible form, or in a form that can readily be reduced to a legible form; Sections 3.6 and 4.6 kept for at least 4 years after the monitoring or event to which they relate took place; and GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

21 Condition number Condition details Section in WAMP (c) produced in a legible form to any authorised officer of the EPA who asks to see them. The following records must be kept in respect of any samples required to be collected: the date(s) on which the sample was taken; the time(s) at which the sample was collected; the point at which the sample was taken; and the name of the person who collected the sample. Schedule 2, Condition 4.7 Requirement to Monitor Radiation The Applicant shall monitor radiation levels in accordance with the requirements set out in the Environment Protection Licence issued by the DECC. The Applicant must ensure that blended waste to be disposed of outside the premises is analysed to ensure characterisation in accordance with DECC waste disposal guidelines and is disposed of at a place licensed by the DECC to lawfully accept that class of waste. Refer to Cristal Radiation Management Plan Section 4.5 [The Applicant shall prepare and implement a] Waste Management Plan to outline measures to minimise the production and impact of waste produced at the MSP during commissioning and operation, through the implementation of waste reduction, reuse and recycling principles. The Plan shall meet the requirements of the EPA and Council, should there be any. The Plan shall include, but not necessarily be limited to: Sections 2.2 and 2.3 identification of the types and quantities of waste materials produced on the site during commissioning and operation of the MSP; Schedule 2, Condition 6.4 programs aimed at minimising the production of waste at the site through the implementation of operational and Section 4 (c) vii Waste Management management measures; Plan details of potential reuse and recycling avenues for waste materials produced on the site, including collection and Section 4 handling procedures; details of appropriate disposal routes in the event that reuse and recycling avenues are not available or are not Section 4 practicable; programs for involving and encouraging employees and contractors to minimise domestic waste production on the site Section and reuse/ recycle where appropriate. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

22 Condition number Condition details Section in WAMP procedures to ensure that any liquid and/or non liquid waste generated and/or stored at the Premises is assessed and classified in accordance with the EPA Environmental Guidelines: Assessment, Classification and Management of Liquid and Non-Liquid Wastes, in force as at 1 July Section 4 These guidelines have been updated (refer to Section procedures and a monitoring program to ensure that all wastes generated, stored or land filled at the premises, or transported from the premises for disposal, are correctly classified under the Waste Guidelines for purposes permitted by this licence or, in the case where the waste is transported from the premises, that the waste entered on the associated waste data form is correctly classified under the Waste Guidelines. Section 4 Procedures and a monitoring program to ensure that the requirements of The Code of Practice and Safety Guide for Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing, 2005 are complied with; and Section Procedures and a monitoring program to ensure that the requirements of the Code of Practice for the Safe Transport of Radioactive Materials, revised 2001 (Commonwealth of Australia) and the NSW Road and Rail Transport (Dangerous Goods) Act 1997 are complied with. Refer to Murray Basin Operations Transport Management Plan and Code of Conduct Prior to the commencement of the development the Applicant must have confirmation in writing from the EPA that the Waste Management Plan, submitted in compliance with Condition 6.4 is acceptable to the EPA. The Applicant must implement a Waste Management Plan that is acceptable to the EPA. Prior approved versions of the WAMP and WPMP. Activities must be carried out in a competent manner Licensed activities must be carried out in a competent manner. Refer to MSP OEMP (GHD ) Attachment Number 1 Mandatory Conditions for all EPA Licences Operation Conditions This includes: (a) the processing, handling, movement and storage of materials and substances used to carry out the activity; and (b) the treatment, storage, processing, reprocessing, transport and disposal of waste generated by the activity. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

23 Condition number Condition details Section in WAMP Mineral Separation Plant EPL L4 Waste L4.1 No waste received onto the MSP site from The licensee must not cause, permit or allow any waste to be received at the premises, except the wastes expressly referred to in other sites. the column titled Waste and meeting the definition, if any, in the column titled Description in the table below. Any waste received at the premises must only be used for the activities referred to in relation to that waste in the column titled Activity in the table below. Any waste received at the premises is subject to those limits or conditions, if any, referred to in relation to that waste contained in the column titled Other Limits in the table below. This condition does not limit any other conditions in this licence. Code Waste Description Activity Other Limits NA General or Specific Waste that meets all the conditions of a As specified in each NA exempted waste resource recovery exemption under particular resource Clause 51A of the Protection of the recovery exemption Environment Operations (Waste) Regulation 2005 NA Waste Any waste received on site that is below licensing thresholds in Schedule 1 of the POEO Act, as in force from time to time - NA L4.2 The quantity of hazardous and/or restricted solid waste generated and/or stored at the premises must not exceed 122,900 tonnes per year. Section 4.2. O5 Processes and Management The licensee must ensure that any waste generated and/or stored at the premises is assessed and classified in accordance with the EPA Waste Classification Guidelines as in force from time to time. Section 4.5. O6 Waste Management The licensee must prepare and implement a Waste Process and Management Plan for the Premises. Note: The Waste Process and Management Plan must be prepared and implemented to ensure compliance with the conditions of this Licence and relevant Environmental legislation. This WAMP. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

24 3.2.2 Relevant legislation and other requirements A full legislative register is provided in the EMS (2012); Acts, Regulations and policies specific to this WAMP are listed below. Acts Environmental Planning and Assessment Act 1979 (NSW) Mining Act 1992 (NSW) Protection of the Environment Operations Act 1997 (NSW) Radiation Control Act 1990 (NSW) Waste Minimisation and Management Act 1995 (NSW) Work Health and Safety Act 2011 (NSW) Regulations Protection of the Environment Operations (General) Regulation 2009 (NSW) Protection of the Environment Operations (Waste) Regulation 2005 (NSW) Radiation Control Regulation 2003 (NSW) Work Health and Safety Regulation 2011 (NSW) (as pertaining to Dangerous Goods Storage) Policies Movement of Controlled Waste National Environmental Protection Measure (NEPM) (EPHC 2010) Reducing Waste: Implementation Strategy (DECCW, 2011) Relevant Standards, Codes of Practice and Guidelines AS : 2006 Mobile waste containers AS 1940: 2004 The storage and Handling of Flammable and Combustible Liquids AS 1692: 2006 Steel tanks for Flammable and Combustible Liquids Code of Practice for the Safety Transport of Radioactive Material (ARPANSA, 2008) Code of Practice and Safety Guide for Radioactive Protection and Radioactive Waste Management in Mining and Mineral Processing (ARPANSA, 2005) EPA Waste Classification Guidelines) 3.3 Roles and responsibilities Overall roles and responsibilities for environmental management at the MSP are outlined in Cristal s EMS. Management of operations at Ginkgo and Snapper are overseen by the Mine Manager, with support from Cristal s Environmental Department as required. 3.4 Training and inductions Overall training and induction requirements for Cristal s operations in the Murray Basin are outlined in Cristal s EMS. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

25 Waste Management will be a component of the site induction program and also topic specific training packages will be developed. The following areas will be covered in such training programs: Importance of reducing and recycling waste; Minimum requirements for avoiding/minimising, recycling/reusing and disposing of waste from the MSP; Environmental risks and effects of products from the time that they are made and purchased to the time that they are disposed, i.e. cradle to grave management; Spill Response Procedures including clean-up procedures and use of spill containment materials, spill preventative measures and the handling and storage of hazardous materials; Specific radiation safety training for personnel including employees, contractors and transporters will be provided by authorised personnel and will include: Radiation inductions for all new personnel; Annual re-inductions, principally targeting personnel moving bulk material; and On-demand training. All truck drivers carrying waste, before their first trip, will be required to attend a Driver s Radiation Safety and Accident Response Briefing, and will be given a manual containing all key standing instructions. This document will be signed for and kept on file. 3.5 Complaint, non-conformance and incident management Complaint, non-conformance and incident management for Cristal s operations in the Murray Basin is described in Cristal s EMS. 3.6 Environmental reporting and correspondence Cristal is required to submit and Annual Environmental Management Report (AEMR) to the Director-General of DOP under Condition 7.1 of the Conditions of Approval for MSP. A waste management summary report is provided in the AEMR, and includes: Quantity and composition of process waste dispatched from Ginkgo Mine over the 12- month period; Results of the waste auditing program; and Any variations to approvals obtained for the waste management strategy. Condition R1.1 of the EPL requires Cristal to submit an Annual Return (AR) to the EPA. Condition R1.9 specifies that the AR will include: An analysis and interpretation of monitoring results; and Actions taken to correct identified adverse trends. 3.7 Audits of the Environmental Management Plan Condition of Approval 4.1 of Schedule 2 requires that Cristal conduct an Independent Environmental Audit every three years or as otherwise directed by the Director-General of the Department of Planning. Matters to be covered by the Independent Environmental Audit are described in Cristal s EMS. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

26 A waste auditing program is implemented as part of monthly environmental inspections at the MSP. The auditing program provides a mechanism to ensure that waste generated at the MSP is collected and handled appropriately as outlined in the WAMP. Specifically, the waste auditing program reviews: Classification of waste generated at the MSP is in accordance with the EPA Waste Classification Guidelines; Monitoring of waste generation and disposal using a waste inventory system; Waste dispatched from the MSP has the required waste tracking data forms completed prior to transportation including a consignment authorisation number; Management of radiation waste is in compliance with the requirements of the Code of Practice and Safety Guide for Radioactive Protection and Radioactive Waste Management in Mining and Mineral Processing (2005). Active participation of personnel in the reduction and recycling of waste materials; Waste separation at the point of generation, correct storage in the appropriate waste receptacles (including appropriate signage) and presence of waste information placards around site; and Waste is only dispatched to landfills that are licensed to receive that class of waste. 3.8 Review and update of WAMP The Condition of Approval 6.5 of Schedule 2 outlines requirements for revision and update of EMPs. The WAMP is reviewed, and if necessary revised, to the satisfaction of the Director General, within three months of: (a) The submission of an Annual Environmental Management Report (AEMR); (b) The submission of an incident report; (c) The submission of an Independent Environmental Audit Report; and (d) Any modification of the regulatory consent conditions. Further details on the requirements for review and update of EMPs are provided in the EMS. The Waste Management Program (refer to Section 4) will be reviewed annually and updated when necessary. Prior to cessation of the processing of minerals at the MSP, the Waste Management Program will be reviewed, updated and prepared as a final Waste Management Program including details for decommissioning. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

27 4. Waste management program In order to manage waste on the MSP site, Cristal has developed a Waste Management Program to manage process and non-process wastes. 4.1 Objectives The objective of the Waste Management Program is to: Ensure management and disposal of all general and hazardous wastes is in accordance with the relevant legislative, project approval and licencing requirements. Minimise the production and impact of non-process wastes produced at the MSP through the implementation of the waste minimisation hierarchy: 4.2 Performance standards The following performance outcomes have been identified against the objectives of the WAMP. The objectives will be achieved if: Disposal of waste materials is according to: Code of Practice and Safety Guide for Radioactive Protection and Radioactive Waste Management in Mining and Mineral Processing (ARPANSA, 2005); and EPA Waste Classification Guidelines. All waste is disposed of to a facility appropriately licenced to accept the waste; The quantity of hazardous and/or restricted solid waste generated and/or stored at the premises does not exceed 300,000 tonnes per year; and The waste minimisation hierarchy is implemented. 4.3 Non-process waste management strategy A non-process waste management strategy is implemented to facilitate the effective management of non-process waste generated from MSP activities. An outline of the strategy is provided in Table 5. The Environmental Officer is responsible for monitoring and maintaining the non-process waste management strategy. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

28 Table 5 Non-process waste management strategy Waste Type Minimise Re-use/Recycle Treatment / Destruction Proposed Disposal Site Non-liquid waste Putrescible and inert miscellaneous material. - Compost Compost & place in colour coded skip BHCC Landfill Cans, recyclable containers Bulk purchase Collect for recycling Crush & place in colour coded skip Recycling Contractor Packaging - paper/cardboard/ plastic Bulk Purchase Collect for recycling Crush & place in colour coded skip Recycling contractor Wood pallets Avoid damage Return for reuse Place in laydown area BHCC Landfill Wood misc. (incl non-standard pallets) - Store/stockpile for future use Place in laydown area Recycling contractor Batteries - - Place in laydown Recycling area contractor Scrap Steel - Collect for Place in colour Recycling recycling coded skip contractor Drums Identify bulk supply/storage Return to supplier To be empty, then crush BHCC Landfill or recycle Hydrocarbon Avoid spills. - Place in Transport off site containers oil Placement of hazardous waste by licenced filters, hydrocarbon spill skip hazardous waste absorbents, etc. kits contractor Oil contaminated Avoid spills. - Place in Transport off site soils / silts Placement of hazardous waste by licenced spill kits skip hazardous waste contractor Tyres - Collect for return Place in laydown Recycling to supplier area contractor Paint scrapings / - - Place in Transport off site by products hazardous waste by licenced skip hazardous waste contractor Metal shavings - - Place in colour Recycling coded skip contractor GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

29 Waste Type Minimise Re-use/Recycle Treatment / Destruction Proposed Disposal Site Fixed Radiation Gauges OEH approval required for disposal of any radioactive source Liquid waste Human effluent On site waste water treatment system Waste oil Avoid spills Collect for recycling Store in on-site oil tanks Recycling contractor Paints / Placement of - Place in Transport off site Preservatives spill kits hazardous waste by licenced skip hazardous waste contractor Solvents Utilise "tool Collect for Collect in Transport and wash" solvent recycling supplied drums disposal by recycle baths. and store licenced Placement of. according to AS contractor spill kits Waste Grease - Collect for recycling Store in on-site grease waste container Recycling contractor Oil / fuel Avoid spills. Extract pollutant Pump out Transport off site contaminated Placement of and discharge contaminated by licenced water spill kits clean water water to hazardous waste wastewater contractor storage tank Paint / metal / Avoid spills. Extract pollutant Pump out Transport off site solvent Placement of and discharge contaminated by licenced contaminated spill kits clean water water to hazardous waste water wastewater contractor storage tank Effluent treatment and discharge An effluent treatment and discharge system is in place to manage human effluent and waste process water. The main element of the effluent management system is an aerated treatment system. The system consists of primary (anaerobic) treatment, an aeration unit, a clarifier unit and a disinfection and irrigation unit. The aerated treatment system accepts sewage from the plant amenities buildings and water backwashed from the on-site tertiary treatment system (used to treat water imported from Country Energy). The effluent from the aerated treatment system is reused on site as irrigation water for trees planted around site. Cristal has approval to discharge water from the effluent treatment system to the effluent utilisation area. The effluent utilisation area has been allowed to naturally revegetate with shrubs and grasses to assist nutrient uptake. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

30 4.3.2 Domestic waste production Recycling programs are in place at the site to manage domestic waste (paper, cardboard, cans, bottles, etc.). Recycling bins are available for staff to separate recyclable materials. 4.4 Process waste management strategy A process waste management strategy is implemented to facilitate the effective management of process waste generated from MSP activities. An outline of the strategy is provided in Table 6. The Environmental Officer is responsible for monitoring and maintaining the process waste management strategy. Table 6 Process waste management strategy Waste Type Treatment Disposal Site MSP rejects Burial. Ginkgo Mine. Inert Process Wastes Reused as per Section Process water Recycled, treated and discharged MSP as per Sections and Baghouse dust Reprocess or discharged as per Process water recycling An onsite tertiary treatment system treats recycled water from Country Water for use as process water at the MSP. Water drained from the stockpiles is filtered through blue rock and cloth before being returned to the tertiary treatment system. Waste process water is disposed of as per Section Waste management mitigation measures Mitigation measures for waste are detailed in Table 7. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

31 Table 7 Waste management mitigation measures Impact Mitigation Measure Monitoring Improper Classification of Waste No waste generated outside the MSP is to be received at the MSP for storage, treatment, processing, reprocessing or disposal, except as specific by Condition L4.1 of the EPL. Refer to Section Waste materials will be assessed in accordance with the technical assessment procedure outlined in the EPA Waste Classification Guidelines. Refer to Section 4.6. Waste materials are assessed in accordance with the Movement of Controlled Wastes NEPM (EPHC, 2010). Refer to Section 4.6. Waste material to be transported from the MSP to Ginkgo Mine will be classified as hazardous on the basis they contain radioactive material from the separation circuit. Refer to Section 4.6. The site requirements for waste management will be displayed at prominent positions across the MSP in the form of charts outlining the correct disposal methods for the different waste streams. Refer to Section 3.7 Receptacles will be clearly labelled in accordance with AS Mobile waste containers - Part 7: colours, markings and designation requirements. Refer to Section 3.7 Training to be provided as per Section 3.4. Refer to Section 3.7. Mismanagement of Non-Process Waste Cristal will investigate options for utilising waste material for re-use on site or if not suitable, to utilise local services to re-use / recycle recyclable waste materials produced on site. Volumes of recycled material reported in AEMR as per Section 3.6. Minimising the volume of the hazardous wastes by investigating the use of alternative products. Preferential use of suppliers who deliver in bulk and accept the return of packaging for reuse / recycling. Encouraging suppliers to remove empty containers or used products when supplying replacements as part of purchasing agreements. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

32 Impact Mitigation Measure Monitoring At the point of generation, waste will be directly transferred to nearby waste receptacles suitable for transportation to reuse, recycling or disposal facilities. A recycling program will be established for recyclable materials in consultation with the BHCC. Materials to be recycled will be separated at the MSP and disposed of to the colour coded waste receptacles for collection by recycling contractors. Refer to Section 3.7 Refer to Section Where waste is required to be disposed, material will be to either be: Transported by a licensed waste transporter to BHCC landfill in accordance with a waste agreement (Non-hazardous material); or Collected by licenced hazardous waste contractors for disposal at a facility licenced to accept hazardous waste. All dangerous goods on site (including waste hydrocarbons and chemicals) will be stored in accordance with the relevant Australian Standards including AS (The Storage and Handling of Flammable and Combustible Liquids) and AS 1692 (Tank Storage of Fuels) and licensing requirements. These requirements include that: Refer to Section 30 Storage facilities will be bunded with an impervious material to contain at least 110% of the largest container; All valves in the bunding (for the release of rainwater) will be equipped with a locking mechanism; Signs will be displayed for each substance stored within the facility illustrating the substance name, dangerous goods class, packaging group and emergency response details; All containers will display product information including the product name, UN number, dangerous goods class and packaging group; Storage facilities will have effective measures to exclude rain and surface stormwater run- off from the storage area; and Storage facilities will have easy access for emergency response and spill clean-up GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

33 Impact Mitigation Measure Monitoring teams. Exposure of Personnel to Hazardous (Radioactive) Substances To minimise employee radiation dosages and associated potential environmental impacts, the following measures will be implemented: Separate dust collection for the section of the circuit handling monazite; TLD Personnel Radiation Badges. Further details on radiation provided in the Cristal Radiation Management Plan. Provision of an industrial vacuum system to minimise potential dust exposure that have elevated radiation levels; Provision of a separate enclosure within the MSP for items of equipment that handle the streams containing any elevated monazite contents; and Pugging of any dust collected to eliminate the dust hazard at its source. All process waste drivers are to be licensed to transport hazardous waste. Driver certifications to be kept on file. Mismanagement of Process Waste at MSP A composite sample from the waste stockpile will be collected during each shift worked at the MSP. X-ray fluorescence monitoring of the Uranium (U) and Thorium (Th) levels in the waste stream will then be carried out on the composite sample. The U and Th levels would then be used to calculate the radioactivity levels of the waste stream per shift and, therefore, the activity levels of each load of waste backloaded to the Ginkgo Mine. Refer to Section Monitoring of background radiation levels will be undertaken to detect ambient dose equivalent microsieverts (µsv) in the environment prior to and during operations. Monitoring will be undertaken across the MSP site and at areas of higher radiation potential. Radiation measurements are conducted regularly on composite samples by quantitative gamma spectrometry and reported as specific activity for each gamma-emitting radionuclide (Bequerels/gram). Radiation assessments are conducted to ensure radioactivity levels remain below occupational health and safety and environmental exposure limits throughout the mineral processing operations. As per the 2011 AEMR (p 7): GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

34 Impact Mitigation Measure Monitoring In August 2009 a variation was made to the EP Licence to remove conditions relating to monitoring requirements. The requirements to monitor the concentration of radiation from the leucoxene dryer baghouse and the concentration of Type 1 and Type 2 substances in samples of the blended waste disposed of outside the premises on a quarterly basis was removed from the licence conditions. After three years of monitoring results the data obtained had suitably characterised the respective concentrations and continued monitoring was deemed unnecessary. Annual radiation monitoring of the entire waste stream by quantitative gamma spectrometry (entire waste stream). The total tonnage of process waste (hazardous and/or restricted solid waste) generate or stored at the premises must not exceed 120,400 tonnes per annum. Mismanagement of Waste Dispatches from MSP to Ginkgo Transport of process waste is managed under the: Murray Basin Operations Transport Management Plan and Code of Conduct (September 2012) Murray Basin Radiation Management Plan (Hunter Valley Radiation Services, January 2012) Snapper and Ginkgo Waste and Landfill Management Plan (December 2012). Refer to these plans for further details. Specific responsibilities pertaining to managing waste at the MSP site are detailed with each plan. Refer to relevant management plans. Any waste dispatched from the MSP to Ginkgo Mine requires a consignment authorisation number to be issued from the Ginkgo Mine prior to transport. A written application will be made to the consignee to obtain a consignment authorisation number. The application will contain the following information: As per Section A statement describing the waste and identifying the waste class in accordance with Schedule 1 of the Protection of the Environment Operations Act 1997 (Section 1.3.2); GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

35 Impact Mitigation Measure Monitoring An estimate of the amount of waste to which the application applies; Whether the consignment will consist of a single load or multiple loads; An estimate of the total period required for transportation of the consignment; The date of dispatch of at least the first load in the consignment; and Copies of all information used by the consignor to classify the waste. An approved Dangerous Good s Shippers Declaration is to be completed which documents all waste details required for the waste material tracking system (Appendix B of Murray Basin Traffic Management Plan and Code of Conduct). A copy of the Dangerous Good s Shippers Declaration is to be provided to the person transporting the waste. For the waste transportation vehicles, gamma radiation readings must be taken outside the side surface of the truck, and at 1 metre from the truck, to determine Transport Index and hence the placard category number. Readings must also be taken inside the driver s cabin after the truck is loaded. GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

36 4.6 Environmental monitoring and inspections As detailed in the MSP OEMP, an environmental monitoring program will be implemented to monitor and measure the environmental performance of the MSP, in accordance with development consent conditions, environmental licences and other statutory requirements. Documents from all inspections and monitoring will be maintained and filed at the MSP site office. The Environmental Officer will be responsible for the maintenance and implementation of the environmental monitoring program Monthly environmental inspections As outlined in Section 3.7, a waste auditing program is implemented as part of the monthly environmental inspections. During the monthly environmental inspection, the storage of dangerous goods will also be assessed for compliance against requirements detailed in Table Non-process waste monitoring A waste monitoring program is implemented to ensure all waste generated at the MSP are collected and handled appropriately as outlined in the WAMP. MSP operations generate several types of wastes as outlined in Table 2. Movement of nonprocess waste from the MSP is monitored. The waste monitoring program monitors and records: The types of waste being transported from the MSP; The volume of waste; and The destination for each consignment. A summary of activities undertaken during the 12-month period will be reported in the Annual Environmental Monitoring Report (Section 3.6). Non-process waste monitoring is the responsibility of MSP Store-person Process waste monitoring The radioactivity of process waste is monitored at the MSP. The total activity of the MSP rejects is measured and recorded for each consignment. All records are monitored by Cristal. All monitoring is undertaken in accordance with the Code of Practice and Safety Guide for Radioactive Protection and Radioactive Waste Management in Mining and Mineral Processing (ARPANSA, 2005). GHD Report for Cristal Mining Au Waste tracking Waste movements from the MSP which require tracking include: Radioactive process waste; and Non-process wastes requiring tracking under Protection of the Environment Operations (Waste) Regulation These wastes are monitored in accordance with Condition of Approval 3.12 of the MSP development consent. A waste material tracking system will be implemented to monitor: The types of waste being transported from the MSP. A statement identifying the waste class will be provided in accordance with Schedule 1 of the Protection of the Environment Operations Act 1997 ; The volume of waste to which each consignment applies;

37 The number of loads per consignment; The destination for each consignment; The total period required for transportation of the consignment; and The date of dispatch and receiving dates of at least the first load in the consignment. Information related to each consignment of waste will be recorded and retained for a period of at least 4 years as required by Protection of the Environment Operations (Waste) Regulation 2005 (NSW). Records will be maintained to ensure consignments sent to each destination can readily be identified and accessed. This includes all records relating to individual consignment authorisation numbers (including Waste Data Forms). In addition, the following monitoring results will be maintained: Radiation readings from waste transport trucks; Daily composite sample results; Quarterly quantitative gamma spectrometry results; and Type I and Type II metals results. Waste tracking is the responsibility of MSP Manager. 4.7 Contingency measures Exception reporting The NSW EPA is to be notified, in writing, within 48 hours in the event that any of the following occurs: The refusal by a person to whom the MSP has applied for a consignment authorisation number in accordance with Condition 3.12(d) to issue such a number; The refusal of a transporter to transport waste after arriving at the MSP for the purposes of transporting that waste; A transporter who transports, or attempts to transport, waste without a waste data form completed to the extent required; The refusal of a consignee to accept waste from the MSP; The failure of the MSP to receive written confirmation of receipt of waste from a consignee within 21 days of dispatch, or where a transporter has provided written notification of a revised date of delivery as set out in Condition 3.12(i) within 21 days of that date; or The notification by a transporter of a revised date of delivery which is more than 90 days after the date of dispatch of the waste. For further notification requirements pertaining to breaches of the POEO Act or the EPL, refer to the Cristal EMS Unusually high radioactivity in MSP rejects As described in Section 2.2.2, monazite wastes are blended with inert process wastes to reduce to total radioactivity of the MSP reject to the vicinity of 190 Bq/g on average. MSP rejects that show higher than the average radiation reading (for example, Bq/g) are covered under the current practices detailed in Section and would be blended at an appropriate ratio with inert wastes to ensure consistency in the radioactivity of the MSP rejects waste stream (i.e. in the vicinity of 100 Bq/g). GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/

38 4.7.3 Mixed wastes Improperly mixed wastes impact the ability of Cristal to effectively implement the Waste Management Program as described in this Section. In the event that mixed wastes are identified as an issue at the MSP site, an investigation will be undertaken to determine: The status of waste signage and colour coded bins around the site; The adequacy of waste information provided during site induction; Whether site waste disposal locations are impacting the successful implementation of the Waste Management Program; and The need for refresher training, in the form of a Toolbox Talk or otherwise, for site personnel. The outcome of the investigation will determine the appropriate course of action.

39 5. References Broken Hill Mineral Separation Plant New South Wales, Environmental Impact Assessment (Resource Strategies on behalf of Bemax Resources Pty Ltd, November 2001) Code of Practice and Safety Guide for Radioactive Protection and Radioactive Waste Management in Mining and Mineral Processing (ARPANSA, 2005) Code of Practice for the Safety Transport of Radioactive Material (ARPANSA, 2008) EPA Waste Classification Guidelines Environmental Planning and Assessment Act 1979 (NSW) Mining Act 1992 (NSW) Protection of the Environment Operations Act 1997 (NSW) Protection of the Environment Operations (General) Regulation 2009 (NSW) Radiation Control Act 1990 (NSW) Radiation Control Regulation 2003 (NSW) Waste Minimisation and Management Act GHD Report for Cristal Mining Australia Ltd - MSP Waste Management, 31/29166

40 GHD 57 Orange Avenue Mildura, Victoria 3500 T: (03) F: (03) E: GHD 2014 This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited. G:\31\29166\WP\ docx Document Status Rev No. Author Reviewer Approved for Issue Name Signature Name Signature Date 0 R Deves D Kovacs D Kovacs 17/12/ C Bright J Stephens 2 C Bright J Stephens M Braithwaite M Braithwaite 14/2/2012 M Braithwaite D Kovacs 03/11/2014

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