Bauxite Hills Project. Supplementary Report to the. Metro Mining. Section 3 Introduction. Environmental Impact Statement

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1 Metro Mining Bauxite Hills Project Supplementary Report to the Environmental Impact Statement Section 3 Introduction

2 3 Introduction This section refers to submission comments relating to Chapter 1 Introduction of the EIS. More specifically in response to queries raised by EHP in their submission relating to the approvals required for the Project. 3.1 Project Approvals General Approvals Metro Mining has undertaken a review of the general approvals outlined in the EIS. Following the review, it was identified that Operational Works approval will be required for the placement of prescribed tidal works associated with the cyclone moorings. The anticipated approvals for the Project that were provided in Table 1-11 of the EIS have been updated to reflect the changes to the Mining Lease Applications (MLAs) associated with the acquisition of Gulf Alumina and the SRBP by Metro Mining and the requirement for Operational Works approval for the tidal works associated with the cyclone mooring facilities as shown at Table 3-1. Table 3-1 Project environmental approval requirements Permit/Approval/Licence Legislation Authority Comments Project Wide Environmental Authority EP Act EHP Under Schedule 2A of the EP Regulations, the Project is for mining bauxite which has an Aggregated Environmental Score (AES) of 97. This EA will cover mining areas and haul roads associated with the Bauxite Hills Project. The SRBP will have a separate EA for activities approved for that Project as outlined in section of this Supplementary Report. The Environmentally Relevant Activity (ERA) that is applicable to the updated Project is: ~ ERA 33 (1) Crushing, milling, grinding or screening more than 5,000 t in a year. Controlled Action Approval Mining Lease Mine Operations Permit to take water (surface water and/or groundwater) and approvals for related infrastructure EPBC Act Mineral Resources Act 1989 Water Act 2000 DotE DNRM DNRM The Project was referred on 11 August 2015 (EPBC 2015/7538) and on 18 September 2015, DotE declared the Project a controlled action under the EPBC Act. Resource tenure in the form of three mining leases (MLA 20676, MLA and MLA 20688) for minerals and infrastructure pursuant to the MR Act. A further application for a MLA pursuant to s316 of the MR Act for the haul road over ML 7024 (held by Rio Tinto Alcan) is in process. Previous MLAs and s316 application which are now redundant following the acquisition of Gulf Alumina and the utilisation of the SRBP will be withdrawn on approval of the Bauxite Hills Project. The Water Act 2000 provides the framework to regulate the use of surface waters and groundwater through water planning instruments. Under the Act, a person (including a corporation) must not take, supply or interfere with water unless authorised under the Act. An application to divert water from watercourses during construction and mine operational activities will be required for this Project. 3-1

3 Permit/Approval/Licence Legislation Authority Comments Licence to take water from the Great Artesian Basin (GAB) Transport Infrastructure Buoy Mooring Authority Marine Fuel Transfer Activity Permit Operational Works for Damage to Marine Plants and Tidal Works Water Act 2000 Transport Operations (Marine Safety) Act 1994 Port of Skardon River Port Rules Sustainable Planning Act 2009 DNRM Maritime Safety Qld Ports North Cook Shire Council and Referral Agency SARA The Project has been declared regionally significant by DNRM and an application for a water allocation is in progress. Note this application may be withdrawn should a sufficient water supply exist with the SRBP. Maritime Safety Queensland (MSQ) has a whole-of-state framework for approving buoy moorings. A Regional Harbour Master (RHM) may create some area-specific conditions. Undertaking refuelling activities at the BLF as it is within the Port Limits. Note this may not be required should an existing permit be held for the SRBP and noting that Metro Mining will use the approved SRBP fuel farm and distribution network. Any damage or removal of marine plants beyond the Mining Lease boundary and the placement of prescribed tidal works associated with the cyclone moorings and fixed tidal gauge. Waterway barrier works approvals are associated with waterway crossing outside of the MLA. As all waterway crossings will be within the MLs, under the conditions of an EA, separate waterway barrier works approvals are not required to be obtained. In accordance with Division 3 of the Fisheries Act 1994, waterway barrier works are dams, weirs or other barriers across a waterway. Metro Mining plans to avoid constructing any barriers across waterways by using culverts at creek crossings to enable fish passage in accordance with Austroads Guide to Road Design Part 5B Open Channels, Culverts and Floodways and by the Department of Agriculture and Fisheries (DAF) guidelines: Fish passage in streams: Design of stream crossings and Code for Self-Assessable Development and Minor Waterway Barrier Works Part 3: Culvert Crossings, Code number: WWWBW01 (April 2013). Section 11.3 provides further details on culvert design Metro Mining and Gulf Alumina Project Environmental Authority s With the acquisition of Gulf Alumina and as the owner of the SRBP, Metro Mining will effectively be the responsible party for both the Bauxite Hills Project EA and the SRBP EA. In their submission EHP queried the ERAs proposed for the Project that were listed in the EIS at Table 3-2. Metro Mining has undertaken further review of the relevant ERAs and noting the acquisition of Gulf Alumina and the ERAs approved for the SRBP, the ERAs listed in Table 3-2 are relevant specifically to Bauxite Hills Project EA. Table 3-2 Environmentally relevant activities for the Bauxite Hills Project ERA Reference Relevant Activity Location and Activity Summary Crushing, milling, grinding or screening more ML 20676, and (screening ERA 33 than 5,000 t in a year. will be undertaken in pit) After further review, several ERAs were considered not to apply as either the definition for the ERA specifically excludes resource activities conducted under an EA or were considered not to be relevant to the Project, or the activity does not exceed relevant trigger levels or the activity is already addressed in the SRBP EA. 3-2

4 The following ERAs were considered not to apply to the Bauxite Hills Project: ERA 16 extraction of material. The relevant activity does not include extracting material under an EA for a resource activity (Schedule 2, Part 11, Item 16 (2a)); ERA 49 - boat maintenance and repair - operating, on a commercial basis, a boat maintenance or repair facility for maintaining or repairing hulls, superstructure or mechanical components of boats or seaplanes. Metro Mining will not be undertaking any commercial boat maintenance and repair within the mining lease area, there will be no vessel maintenance area facility or slipway developed or proposed in the Project description 1. A marine contractor will be engaged for the provision of the specialised marine services; only minor on-board routine maintenance will be undertaken. If the contractor proposes to undertake boat maintenance (major engine and power plant service, hull cleaning, fibre glassing, surface coating, removal of anti-foul paint, abrasive blasting) it will be the contractor s obligation to use appropriate existing licensed facilities; ERA 50 (1) loading and unloading materials within 5 km of astronomical tide or 1 km of a watercourse and loading or unloading bulk materials in association with a port. The relevant activity does not include loading, unloading or stockpiling materials under an EA for a resource activity (Schedule 2, Part 11, Item 50 (2)). Such an activity is inherently part of the mining activity and therefore already subject to conditioning for such activities; ERA 50 (2) loading or unloading 100 t or more of bulk materials in a day or stockpiling bulk materials. The relevant activity does not include loading, unloading or stockpiling materials under an EA for a resource activity (Schedule 2, Part 11, Item 50 (2)). Such an activity is inherently part of the mining activity and therefore already subject to conditioning for such activities; and ERA 53 composting and soil conditioner manufacturing. This is not expected to be triggered as under 200 t of organic material or organic waste or more of compost or soils conditioners per year will not be generated. ERA 63 1(a)(i) - Sewage treatment for 100 to 1,500 equivalent persons with treated effluent discharges to an infiltration trench or irrigated. This ERA will apply to the SRBP accommodation camp. The relevant ERAs approved in the EA for the SRBP are listed in Table

5 Table 3-3 Environmentally relevant activities associated with the SRBP ERA Reference Relevant Activity Relevant ML ERA 8 (3) Chemical Storage - storing more than 500 m 3 of chemicals of class C1 or C2 combustible liquids under AS 1940 or dangerous goods class 3 under ML subsection (1)(c). ERA 15 Fuel burning using fuel burning equipment that is capable of burning at least 500 kg of fuel in an hour. ML ERA 33 Crushing, milling, grinding or screening more ML than 5,000 t in a year with an AES of 0. ERA 56 Regulated waste storage operating a facility for receiving and storing regulated waste for ML more than 24 hours with AES of 21. ERA 58 Regulated waste treatment operating a facility for receiving and treating regulated waste or contaminated soil to render the waste or soil ML non-hazardous or less hazardous with an AES of 90. ERA 60 Waste disposal operating a facility for disposing of less than 50,000 t per year of limited regulated waste and general waste AES of 50. ML Notifiable Activities In their submission EHP nominated additional notifiable activities to those listed in the EIS. In light of the acquisition of the SRBP, Metro Mining has undertaken a further review and does not anticipate any notifiable activities will apply to the Bauxite Hills Project. Notifiable activities identified in the Bauxite Hills Project EIS that will now be covered under the SRBP EA are listed in Table 3-4. Table 3-4 Notifiable activities for the SRBP that are relevant to the Bauxite Hills Project Item Number (Schedule 3 of the EP Act) 7 Description of Activity Chemical storage of more than 10 tonne of chemicals that are dangerous goods under the dangerous goods code. 23 Metal treatment or coating. 29 Petroleum product or oil storage in above ground tanks. 37 Waste storage, treatment or disposal storing, treating, reprocessing or disposing regulated waste including operating a sewage treatment facility with onsite disposal facilities. Note: Under Section 371 of the EP Act, the owner or occupier of land must notify EHP within 22 business days of becoming aware of the notifiable activity having occurred or going to occur on the subject land. 3-4

6 Of these notifiable activities, items 7 and 23 will be relevant to the operation of the SRBP MIA, port and BLF. Items 29 and 37, which will be relevant to the operations of the SRBP accommodation camp. For completeness, Metro Mining has considered the need and application of the following notifiable activities as part of the proposed Project: Notifiable activity 1 abrasive blasting minor abrasive blasting may be required; however, this will likely occur within an enclosed booth at the SRBP MIA or port area, if circumstances prevent the use of an enclosed booth then notification of activity will occur pursuant to the SRBP approvals requirements; Notifiable activity 20 landfill no landfill is proposed for the Bauxite Hills Project in addition to that approved for the SRBP; and Notifiable activity 27 pest control the Project will not store over 200 L of pesticide onsite. Should this requirement change then notification of the activity will occur. Consequently, no notifiable activities are considered relevant to the modified Project Mining Lease Mining Lease for Transport Since the submission of the EIS, Metro Mining has been in negotiations, and have agreed on a Heads of Agreement, with Rio Tinto Alcan to relocate the haul road between BH1 and BH6 east that was originally proposed on Metro Mining tenement (existing MLA ) to now occur on Rio Tinto Alcan tenement (ML 7024) (held by Rio Tinto Alcan) to avoid the areas of High Ecological Significance (HES) wetlands, small areas of Of-Concern Regional Ecosystems (RE) and the more sensitive marine vegetation. An application for a new transport ML, pursuant to s316 of the MR Act, is in process for the new haul road and will be submitted by Metro Mining for approval in the near future. A transport ML grants the holder the right of transportation through, over or under the land for the purposes of conducting the mining activities on the associated leases, it does not grant any mineral rights. On issue of the new MLA, Metro Mining will seek to have its existing MLA for the haul road proposed in the EIS cancelled. In parallel, Metro Mining submitted an application for a new ML for transport (MLA ) which is located within ML (held by Gulf Alumina). With the acquisition of the SRBP this MLA will be withdrawn. Metro Mining will also withdraw MLA (currently held by Metro Mining) as this haul road is no longer required as a result of the acquisition of the SRBP. An additional ML for transport under s316 of the MR Act was originally required to enable Metro Mining to cross Gulf Alumina s tenements (ML and ML 40069) between BH 6 west and the haul road. The application for this ML will no longer be required due to the acquisition of the SRBP. Mining Lease for Mining Infrastructure Area and Barge Loading Facility Metro Mining currently has MLA for the location of the MIA, RoRo and BLF that were assessed in the original EIS. Given the acquisition of the SRBP and the ability to now utilise the approved SRBP MIA, port and barge loading infrastructure, MLA will become redundant. Metro Mining will withdraw MLA once the Bauxite Hills Project EA is issued by EHP. 3-5

7 3.1.5 Skardon River Port Limits Following the release of the EIS, Metro Mining had detailed discussions and formally wrote to Ports North requesting an extension to the Skardon River port limits (refer to Appendix H) to incorporate the Project s BLF and RoRo facility. The request to extend the port limits was being sought pursuant to s274 of the Transport Infrastructure Act 1994 (TI Act). With the subsequent acquisition of the SRBP and associated MIA, port and barge loading infrastructure, there is no longer a requirement to extend the port limits. Consequently, the request to extend the port limits will be formally withdrawn once the Bauxite Hills Project EA is issued State Consent Cyclone Moorings Metro Mining are progressing necessary operational work approvals under SP Act for infrastructure external to the MLA. This infrastructure consists of a fixed tidal gauge and pile moorings in the Skardon River within an area designated as unallocated State land. Where the development is for land below the high watermark the State is the owner of the resource and must provide consent for applications under the Integrated Development Assessment System (IDAS). The State Land Asset Management (SLAM) unit of DNRM is responsible for assessing and approving State owners consent requests and applications for tenure. Metro Mining will be seeking formal consent from SLAM prior to submitting the IDAS applications for the fixed tidal gauge and cyclone mooring infrastructure. This infrastructure will support the Project needs of the Bauxite Hills Project and potentially the SRBP. 3-6