PART H: Management systems

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1 PART H: Management systems

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3 8. Iluka EHSMS 8.1 Introduction Iluka has an Environment, Health and Safety Management System (EHSMS) made up of various standards, guidelines and forms. The key elements of Iluka s corporate environmental management programmes are outlined in the Corporate Environmental Management Policy. This policy articulates Iluka s intentions and principles for environmental management for all operations. The policy provides a contextual framework for setting environmental objectives and targets. Departmental managers and supervisors are responsible for ensuring the environment policy is adequately communicated to all employees and contractors Environmental management at the Jacinth-Ambrosia site will be implemented in accordance with the Iluka EHSMS to ensure that management and monitoring programmes reflect best practice. The EHSMS provides a framework for achieving continual environmental improvement. The EHS management system cascades down from a corporate to site level, and is documented within the: Iluka Environment Policy twelve corporate standards and associated procedures, guidelines, forms and training that describe minimum requirements for all Iluka operations Jacinth-Ambrosia Mineral Sands Mining Project Operations MARP (this document) provides detail as to how the twelve corporate standards are implemented at a site level (refer to Section 8.2 below) and provides environmental management details for the project (based on the identified environmental risks). MARP(Ops) management plans contain details, schedules and responsibilities for environmental management. procedures and work instructions. All contractors will be required to complete their activities in accordance with the requirements of the EHSMS. The EHSMS requires both Iluka and the contractor to develop site induction and emergency management procedures (including emergency). 8.2 Components of the Iluka EHSMS The Iluka EHSMS contains 12 Standards that form the foundation for all Iluka operations across. The 12 Standards detail key elements of environmental management that will be implemented during Jacinth-Ambrosia operations. Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations) Page 155

4 An outline of the 12 EHSMS Standards is provided below: 1. Leadership and Policy details how leadership and policy principles relating to EHS are developed and implemented as part of the Iluka EHSMS. 2. Organisation and Responsibility EHS responsibilities and accountabilities are defined and communicated to staff and contractors. This is facilitated via position descriptions, inductions and work specific training. 3. Communication EHS matters are communicated internally and externally via a number of methods. Internal communication methods include meetings, s, and notice boards. Generally external communications are based on project requirements and include newsletters, field days, workshops etc. 4. Contractor Management EHS requirements are communicated to contractors during the pre-selection process. Contract risk assessments are conducted to establish the minimum level of management and supporting documentation required from contractors. All contractors receive site inductions prior to commencing work. 5. Risk and Hazard Management risk and hazard identification for all Iluka operations and projects is undertaken as part of project development and operations. As outlined in Section 7 an environmental risk register associated with the Jacinth Ambrosia project has been developed and identifies environmental risks, risk level and controls. The register provides the basis from which the environmental management requirements during operations have been developed. 6. Incident investigation and reporting staff and contractors are encouraged to report all environmental hazards and incidents using the Iluka incident reporting system. Hazards and incidents are investigated according to the potential and actual risk levels. 7. Emergency Crises and Preparedness potential environmental emergency scenarios are identified within the environmental hazard register. In the event of an environmental emergency, the site Emergency Plan would be enacted. 8. Procedures and Training all visitors and personnel undertaking work on site receive an induction. The induction includes information on environmental hazards and controls. Additional job specific training is undertaken as required. 9. Operational management the management of the key environmental hazards (as identified in this MARP(Ops)) are outlined in specific management plans (refer to Part I of this MARP(Ops)). Appropriate environmental management of day to day activities is also identified via task risk assessments such as Job Safety Analysis and Take Environmental management this standard details how Environmental Management Principles relating to EHS shall be developed and implemented as part of the Iluka EHSMS. Details of environmental management practices to be implemented during the Jacinth-Ambrosia project are detailed within the management plans as contained in Part H of the MARP(OPS). Page 156 Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations)

5 11. Monitoring as with the environmental management standard, this details how Monitoring principles shall be developed and implemented as part of the EHSMS. Details of the monitoring to be undertaken during the Jacinth-Ambrosia project are detailed within the management plans and contained in Section of this MARP(Ops). 12. Auditing assurance regular inspections of the site and EHS management system audits are undertaken and actions tracked to closure. Further information on a number of specific elements of the EHSMS Standard is discussed in detailed in Sections below including: site induction environmental emergency management contractor performance management system communication requirements monitoring and reporting; and non conformance and corrective action requirements Site induction Site induction responsibilities will be shared by both Iluka and the contractors. A comprehensive induction will be developed and implemented to ensure that all workers have a thorough understanding of: the environmental issues associated with mine operations the environmental management requirements for the project (i.e. those requirements as outlined in this MARP(Ops)); and their responsibilities in relation to minimising the environmental impacts associated with operational activities Environmental emergency management Environmental emergency management responsibilities will be shared by both Iluka and the contractors. A comprehensive induction is required to ensure that all have a thorough understanding of: the environmental emergency management requirements for the project; and their responsibilities in relation to reporting environmental emergency incidences during operations Contractor performance management system The contractor performance management system to be implemented during operations incorporates the following steps and requirements: Major contractors will be selected on the basis of whether they have sufficient environment, health and safety management systems in place. Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations) Page 157

6 Prior to tendering, prospective contractors will be required to complete a prequalification questionnaire which requests information on management systems and current performance. Representatives from the Iluka EHS group will review information provided by prospective contractors and make recommendations for short listing. Short listed contractors will be required to submit a detailed Environment Health and Safety (EHS) Management Plan that includes information on their system policies and procedures. The EHS Management Plan will be reviewed by representatives from the Iluka EHS group for compliance to the Iluka EHS Management System Standard. A risk workshop will be held for each major contract to identify major risks associated with the scope of works. Relevant persons from the contractor and Iluka will participate in the workshop. It is in this workshop that the environmental issues and management requirements as outlined in this MARP(Ops) will be identified and discussed. Regular progress meetings will be conducted with all major contractors (during the completion of the works) to review the performance of the contract Communication During operations, environmental matters will be communicated internally and externally via a number of methods. Internal communication with contractors and Iluka employees will include meetings, s, and notice boards. External communication during operations will include: Newsletters Far West Coast (FWC) Liaison Committee meetings Environment Health Safety (EHS) Workshop for local businesses; and Local Community and Business Briefings Monitoring and reporting Compliance inspections and auditing Inspections and audits will be undertaken during operations to assess the level of compliance against the requirements of the project (including this MARP(Ops) and associated management plans Non conformance and corrective action In the event a non conformance with the MARP(Ops) or associated management plans, a non conformance and/or corrective action request (or similar) outlining the details of the non conformance will be issued. Follow up and verification of the implementation of the associated corrective action that was required will also be undertaken. Page 158 Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations)

7 Details of all non conformances and corrective action requests associated with the MARP(Ops) and associated management plans will be maintained on project files and reported as required in the annual Mining and Rehabilitation Compliance Report Management commitments A summary of the management commitments to be implemented during operations are detailed in Table 8.1 below. Table 8.1 Management commitments MANAGEMENT COMMITMENTS No. 0(i) 0(ii) 0(iii) 0(iv) Commitment Induction will be undertaken to ensure that all workers and visitors have a thorough understanding of: the environmental issues associated with operational activities the environmental management requirements for the project their responsibilities in relation to minimising the environmental impacts associated with the project. A contractor performance management system will be implemented during operations Environmental matters will be communicated internally and externally Inspections and audits will be undertaken to assess the level of compliance with the MARP(Ops), performance objectives and assessment criteria, monitoring methods and processes and Iluka s EHS Management System Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations) Page 159

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9 9. Regulatory requirements 9.1 Lease conditions The lease conditions for ML6315, EML6316, MPLs 110 and 111 are contained in Appendix A. Tables contained in Section J summarise where in the MARP(Ops) these conditions have been addressed or provides comment that demonstrates that the condition(s) has been or will be complied with. 9.2 Significant environmental benefit Iluka will initially meet Significant Environmental Benefit (SEB) requirements through contribution to the Native Vegetation Fund. Iluka developed an SEB proposal in conjunction with key Government stakeholders which was approved by the Native Vegetation Council (NVC) in May 2008., The approved approach covers all SEB requirements for the mine site (approved under the Mining Act 1971 (SA)), and Ooldea Road. Ongoing review of this approach to SEB management will be undertaken in consultation with regulatory authorities. Further details regarding the SEB requirements for the project are detailed in the Native Vegetation Management Plan developed for the project. 9.3 Reporting Mining and rehabilitation compliance report Lease condition number 7 for ML6315, EML6316 and MPLs 110 and 111 requires Iluka to provide to PIRSA an annual Mining and Rehabilitation Compliance Report (MARCR) detailing operations carried out on the ML, EML and MPLs and compliance with the approved MARP and lease conditions. The MARCR must be provided to PIRSA within two months of the anniversary of the lease grant (or at an alternate period as agreed with PIRSA). This report is required to summarise compliance monitoring activities, and provide some evidence that the lease is compliant with regulatory requirements. PIRSA will use the reports to better target compliance monitoring activities, and a detailed report that clearly demonstrates compliance may result in reduced compliance monitoring and enforcement activities by PIRSA. As specified in the lease conditions, MARCRs prepared by Iluka will be in general made available to the public. A public report that clearly demonstrates compliance may also improve relationships with key stakeholders, and result in less complaints and uncertainty concerning operations. The contents of the MARCR are not specified in the lease conditions, however the following issues in general will be addressed: summary of the major mining activities undertaken in the reporting year and proposed activities for the following year Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations) Page 161

10 summary of environmental management and rehabilitation activities for the reporting year and proposed activities for the following year a summary of consultation and any complaints received from third parties a statement of compliance with the obligations under the lease conditions, and the approved MARP for the year a statement of action taken to rectify any non-compliance detected either by PIRSA inspections, or internal monitoring, and to prevent recurrence a statement on the effectiveness of any previously undertaken action to rectify noncompliance any new environmental hazards detected during the year, that were not previously documented to PIRSA (e.g. at the time the MARP was approved); and environmental incidents that have occurred and how these incidents were managed. The MARCRs shall also be prepared in accordance with PIRSA Minerals Regulatory Guidelines MG 3 Guidelines for miners: preparation of a mining and rehabilitation compliance report (MARCR) for Mining Operations, Revision 1.3, May SEB Reporting requirements for Iluka s SEB commitments require the preparation of an annual report that includes details concerning: areas cleared over the previous twelve months (30 June 30 June) against work areas, e.g. haul/access roads, mine site, processing plant etc. any reconciliation of actual clearance areas against estimates from previous years estimates of proposed clearance for the following 12 month period outcomes of any monitoring undertaken on the impacts of dust on adjacent native vegetation any breaches of statutory requirements (e.g. lease conditions, MARP(Ops and associated plans), including remediation works that may have been undertaken; and reporting on any on ground SEB outcomes (if identified and endorsed). To avoid duplication of reporting processes to both the Native Vegetation Council and PIRSA, one single report addressing these requirements and the requirements of the MARCR may be prepared however final determination regarding the acceptability of this single report will be further discussed with the Native Vegetation Council MARP(Ops) amendments and review Review of the MARP(Ops) will be undertaken annually by Iluka to assess how operations have progressed and to identify whether amendments to the MARP(Ops) are required. It is envisaged that this review will be undertaken as part of the MARCR preparation process. In the event that the MARP(Ops) requires updating, the amended document will be submitted to PIRSA for approval. In addition, the MARP(Ops) will be revised in the event that Iluka considers that changes in operation or activities results in the potential to impact environmental outcomes. Page 162 Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations)

11 In addition, it is PIRSA policy that a MARP will in general be required to be reviewed and updated at least every 7 years however PIRSA may request an earlier review if: the lease or MPL renewal occurs in less than 7 years from the previous grant or renewal, or the MARP has proven (from compliance inspections) to be inadequate to address the environmental risks associated with the operation, or there has been a change of operator/lease owner (i.e. on lease transfer), or there has been a change of community/stakeholder expectations in regard to the operations Independent audit of outcomes If requested by the Director of Mines, Iluka must undertake an independent audit of achievement of the environmental and/or closure outcomes in the MARP. The audit must be undertaken by an independent expert approved, in writing, by the Director of Mines. The written audit report will be made available to the public, in a manner and form as determined by the Director of Mines Relinquishment of lease / licence Prior to the relinquishment of the ML and MPLs associated with the project, the Lessee must provide to the Minister and the Minister for Environment and Conservation a satisfactory Mine Completion Report which demonstrates achievement of the closure criteria as specified in the current MARP(Ops). Further details regarding the closure activities and lease relinquishment are contained within the Mie Closure Plan. Iluka must undertake an independent audit of achievement of the environmental and/or closure outcomes in the Report. The audit must be undertaken by an independent expert approved, in writing, by the Director of Mines and the Minister for Environment and Conservation. The written audit will be made available to the public, in a manner and form as determined by the Director of Mines and the Minister fro Environment and Conservation Non-compliance with outcomes In the event that Iluka identifies non-compliant criteria that demonstrate a breach of the environmental outcomes; Iluka will report details to the Director of Mines. In the event that a non compliance with outcomes becomes apparent, Iluka will provide the report within five business days of becoming aware of the non- compliance, unless otherwise agreed with PIRSA. Jacinth-Ambrosia Mineral Sands Mining Project Mining and Rehabilitation Program (Operations) Page 163

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