Cristal Mining Australia Ltd

Transcription

1 Document No: Reviosion: Department: Process: Document Cat: Operation: AP_ME_ Tech Services Environment Management Plan Murray Basin Cristal Mining Australia Ltd Ginkgo and Snapper Mines Water Environmental Management Plan October 2016

2 Revision History Rev No. Document No. Description Approval Details Date A Revised draft plan for Cristal August 2014 B Final Cristal and GHD October 2014 C Revised due to changed conditions of consent and inclusion of management measures from the Borefield Impact Management Plan D Revised to include details of Ginkgo landfill as required by consent modification Cristal and GHD September 2015 Cristal and GHD August 2016 E Draft Cristal and GHD September 2016 F Final Cristal and GHD October 2016 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336 i

3 Abbreviations Abbreviation AEMR AR Cristal BHCC CE CEMP DA DECC Department DPI Water EIS EMS EPA Full Title Annual Environmental Management Report Annual Return (as required by the EPL) Cristal Murray Basin / Cristal Mining Australia Limited Broken Hill City Council Country Energy Construction Environmental Management Plan Development Application NSW Department of Environment and Climate Change Department of Planning & Environment The Water Division within the NSW Department of Primary Industries (formerly NOW) Environmental Impact Statement Cristal Murray Basin Environmental Management Strategy Environment Protection Authority EP & A Act Environmental Planning and Assessment Act 1979 EPL Environment Protection Licence GHD GHD Pty Ltd HAR HMC MOP MSP NMP NOW Highway Access Road Heavy Mineral Concentrate Mining Operations Plan Mineral Separation Plant (Broken Hill) Noise Management Plan New South Wales Office of Water OEMP Operational Environment Management Plan POEO Act 1997 Protection of the Environment Operations Act 1997 RO Plant RMS Secretary WHIMS Reverse Osmosis Plant Roads and Maritime Services Secretary of the Department of Planning & Environment, or nominee Wet High Intensity Magnetic Separator 3 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

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5 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 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 addresses 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. 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 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. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

6 Table of contents Limitations... iii 1. Introduction Purpose of the management plan Scope of the management plan Document succession Project description Salinity Groundwater Surface water Mining water supply requirements Water balances Summary of relevant activities Summary of potential environmental impacts Environmental management framework Relationship to other Environmental Management Plans Legislative requirements and project environmental approvals Roles and responsibilities Training and inductions Complaint, non-conformance and incident management Environmental reporting and correspondence Audits of the WMP Review and update of WMP Environmental management program Objectives Performance standard Environmental mitigation measures for surface water, erosion and sediment control Environmental mitigation measures for groundwater Reporting References GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

7 Table index Table 1 Ginkgo and Snapper groundwater extraction volume (2014)... 8 Table 2 Approval documents for the Murray Basin Mines Table 3 Regulatory Consent Conditions Applicable to this WESCP Table 4 Surface water, erosion, sediment control and salinity mitigation measures Table 5 Groundwater Monitoring Sites Table 6 Trigger levels for commencement of preventing action Figure index Figure 1 Cristal s environmental management framework Figure 2 Environmental management documents for Cristal s operations in the Murray Basin in NSW Figure 3 Snapper clearance schedule showing bore PW1 to be mined out in Figure 4 Ginkgo Mine drainage structures Figure 5 Ginkgo Landfill (overflow containment area in event of heavy rain north of fence) Figure 6 Snapper Mine drainage structures Appendices Appendix A Figures Appendix B Design criteria GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

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9 1. Introduction 1.1 Purpose of the management plan Cristal Mining Australia Ltd (Cristal) operates a number of mineral sands mines in the Murray Basin and a Mineral Separation Plant (MSP) at Broken Hill in NSW. This Water Management Plan (WMP) has been created for the management of water, erosion, sediment (including salinity management) and groundwater at the Snapper mineral sands mine (Snapper) and the Ginkgo/Crayfish mineral sands mine (Ginkgo) in the Murray Basin in south-west NSW. Cristal s mine sites in the Murray Darling Basin have collectively been referred to as the Murray Basin mines for the purpose of this document. 1.2 Scope of the management plan The WMP provides an overview of the environmental management and performance requirements related to water and groundwater management at the Murray Basin mines. This WMP includes: The requirements for environmental management of surface water, erosion and sediment, bore management and prevention of salinisation for operations at the Murray Basin mines as stipulated by regulatory approvals for the project The responsibilities for implementing this WMP A description of the environmental controls and associated limits to meet objectives, targets and regulatory approval requirements 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 This WMP supersedes the following plans: Murray Basin Mines Water, Erosion and Sediment Control Plan, November 2014 Bemax Resources, Snapper Mineral Sand Mine Borefield Impact Management Plan, March 2011 This WMP supersedes these above documents which are now obsolete. The new WMP (this document) has been prepared on the basis of information contained with the original management plans and advice received from Cristal regarding current activities and management measures. The latest revision is in response to modifications to development consent issued for Ginkgo and Snapper Mines in March 2015 and April The development consent for Ginkgo (refer section 3.2) has been updated to include the Crayfish deposit (a new mine that is an extension of the Ginkgo deposit and the recently constructed landfill). Cristal is committed to updating all affected management plans with details related to operations at the Crayfish mine as the information becomes available. Cristal is required to submit management plans to the Department for approval. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

10 2. Project description The Environmental Management Strategy (EMS, section 3.1) provides details on the current operations at Cristal s mineral sands mines within the Murray Basin in NSW. Water, erosion and sediment control and groundwater management are considered to be environmental aspects that require management to minimise impacts associated with activities for the project. An Environmental Impact Statement (EIS) was completed for the Ginkgo Mineral Sands Mine in 2001 (Bemax 2001b). An Environmental Assessment (EA) was completed for the Snapper Mineral Sands Mine in 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. Stages 1 and 2 of the development involved construction activities related to mine preparation and have now been completed. Cristal is now in the operational mining phase. The water management measures and erosion and sedimentation mitigation measures outlined in this management plan are important at the Murray Basin mines to protect surrounding landscape features and existing site amenity. In particular, mitigation measures are designed to minimise the risks associated with erosion and sedimentation to the following: Clean water supplies on site Surrounding remnant vegetation. The closest watercourses to Ginkgo are Travellers Lake (10 km west) and Darling River (17 km east). The closest watercourses to Snapper are Travellers Lake (10 km northwest) and Darling River (30 km east). The closest watercourses to Crayfish are Travellers Lake (13 km west) and Darling River (14 km east). The risk of mining operations impacting these watercourses is low. 2.1 Salinity Many saline areas in NSW (e.g. inland salt pans, brackish streams, coastal salt marshes and naturally saline soils) are the result of natural processes. Most newly salinised areas however, are often the result of particular land use practices, such as over-clearing, river regulation, irrigation or the cultivation of crops. Salinity is often divided into several different categories including: Dryland salinity Irrigation salinity Urban salinity River salinity Industrial salinity. Irrigation salinity (i.e. due to over-irrigation of farm land, inefficient water use and poor drainage) and urban salinity (i.e. due to dryland salinity processes and over-watering of towns and urban areas) are not relevant to the Project. The three different types of salinity relevant to the Project (i.e. dryland, river and industrial salinity) are described below. 2 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

11 Dryland salinity Dryland salinity is the build-up of salt in the soil, usually as a result of a rising water table. Evaporation of saline water at the soil surface tends to concentrate salts to the point where they affect the environment. In rural areas, dryland salinity associated with rising water tables is often caused by the loss of deep-rooted perennial trees, shrubs and grasses. The loss of vegetation is often caused by factors such as clearing, cropping with shallow rooted annual plants (such as wheat, barley, pasture, etc.) or overgrazing. Secondary to the loss of vegetation and/or poor land management practices are impacts such as soil salinity, sodicity, acidification and erosion. There is no known dryland salinity in the Project area. Industrial salinity Industrial salinity is often related to industrial processes whereby salt is concentrated in the water used. Mine sites often need to manage saline water from groundwater seepage and from rainwater coming into contact with active mining areas or spoil. Abandoned mines are also a major source of salinity in some areas. River salinity Surface water run-off from areas of dryland, irrigation and urban salinity may flow into creeks and rivers, raising the salinity of these waterbodies. 2.2 Groundwater Local hydrogeology and groundwater flows The Murray Basin mines lie within a large aquifer system that extends west of the Great Darling Anabranch, east of the Darling River and south to the Murray River. The main aquifer of interest is the Loxton-Parilla aquifer which overlies the sandy sediments of the Upper Renmark Group. The Loxton-Parilla Sands consists of mainly yellow-brown, weakly-cemented, fine to coarse sands and is considered to have been deposited in various shelf-to-seashore environments (shallow marine, beach and estuarine deposits intersected by younger river systems). At the Murray Basin mine sites, the Loxton-Parilla Sands directly overlie the sandy sediments of the upper Renmark Group. Results of three pumping tests carried out at the Ginkgo Mine site indicate that the two formations are hydraulic connected and act as one aquifer. Deeper saline aquifers at the Murray Basin mines also exist within the underlying Renmark Group. The Renmark Group has been mapped to include sand beds of the Upper, Middle and Lower Olney Formation and the basal Warina Sand. At the mine sites the Upper Olney Formation is indicated by a thin zone of fine sand directly beneath and connected to the Loxton- Parilla Sands. The middle Olney Formation is not well defined in the local mine area but is more significant to the north where it connects with both the Upper and Lower Olney Formations. The Lower Olney Formation and Warina Sand are located at about RL-170 m to RL-260 m beneath the mine site overlaying pre-tertiary bedrock. The Geera Clay Aquitard is approximately 130 m thick at the mine site and separates the saline Upper and Lower Olney Formation units. The regional groundwater flow in all aquifers is from the north margin of the basin and from the east toward the south-west. The Neckarboo Ridge east of the Darling River acts as a groundwater divide. The groundwater levels observed in regional groundwater monitoring bores indicate an upward hydraulic gradient from the deeper Renmark Group and Murray Group aquifers to the Loxton-Parilla aquifer. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

12 The saline groundwater in the Loxton-Parilla aquifer receives minor recharge from the Darling River, Menindee Lakes and intermittently from the Great Darling Anabranch. Losses from this aquifer occur via discharge to the Murray River; at groundwater discharge complexes such as the Coombah-Popiltah-Wilcunda Depression and the Nulla and Scotia Boinka s west of the Silver City Highway; and from evaporative discharge from the shallow water table at The Salt Lakes. Deep drilling at Snapper and re-interpretation of existing government drilling logs has identified the Lower Renmark Aquifer (including the Warina Sand) is thick and has a much higher transmissivity than previously modelled. This aquifer with its higher yields has been selected for the preferred water supply for the Snapper Mine Groundwater Model Predicted Drawdown During 2009 and 2010, Geo-Eng was commissioned to investigate an alternate water supply for the Snapper Mine and also to assess the potential local and regional hydrogeological impacts on this new water supply. The following summarises the assessed impacts of this investigation: Shallow Aquifer Effects The effect of mining on the upper aquifer is significantly reduced as the Snapper mine utilises the lower aquifer for its bore water supply A ground water mound will form in the upper aquifer around the Snapper Mine, offsetting most of the drawdown decline in this aquifer related to the Ginkgo Mine. The net result for the upper aquifer is a smaller groundwater decline around the Ginkgo Mine and a limited groundwater mound centred on the Snapper Mine. In the upper aquifer, the shape of the drawdown contours varies as the mine moves, with a maximum groundwater mounding centred around the middle of the Snapper Mine at the end of Year 4. The maximum groundwater drawdown in the upper aquifer also varies, with a maximum extent of about 4 km located around the Ginkgo Mine at Year 7 of Snapper Mine operations which is Year 12 at the Ginkgo Mine. The nearest fresh water bores known as Chalky Well and Greenvale Well, are located as small fresh water lenses sitting on the Saline Loxton-Parilla Aquifer. These fresh water lenses appear to be related to locations of concentrated infiltration due to topographic depressions. These bores are predicted to experience a drawdown of around 5 cm. The supply at these locations is unlikely to be effected. Deep Aquifer Effects The maximum expected drawdown in the lower aquifer occurs at about Snapper Year 7, as after this time the groundwater pumping requirements decrease. It is predicted that twenty years after mining is completed, there will be no measurable effect in the lower aquifer. The nearest groundwater bore targeting the deeper Lower Olney Formation/Warina Sand aquifer is on the Popio Property about 45 km to the north-west of the Snapper Mine. Government records indicate that this bore may be used for stock as the water quality improves to the north-west. There is expected to be no measurable effect on the Popio Well. 2.3 Surface water Due to relatively low annual rainfall (approximately 270 mm at Pooncarie), the sandy soils, limited topographical relief and high evaporation rates, there are no well-defined drainage 4 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

13 channels within the mining lease area, which limits the potential for fluvial erosion and sedimentation. The water management system has been designed to contain and control waters generated from project development and operational areas, while diverting other runoff water around such areas. The water management system is based on the containment and reuse of mine site waters and on the control of sediment that may be potentially carried with runoff from disturbed areas such as the overburden emplacement area prior to rehabilitation. This also works to prevent clean water runoff entering disturbance zones Ginkgo The Ginkgo mine is in the last phase of mining. The water management system at Ginkgo includes permanent features that will continue to operate at the site post- closure and temporary structures that will only be required until the completion of the rehabilitation works. The water management system at Ginkgo has been progressively developed over time as the mine path progressed and water management requirements changed over time. Operational water management structures that are utilised at Ginkgo include: Slimes dams Process water bore field Dredge pond Site sediment and catchment dams A new landfill was constructed at Ginkgo in The landfill features the following structures to minimize surface water ingress into the landfill and holding dam area: A clay bund at the southern end of the leachate holding dam A clay bund at the crest of the eastern batter An access road at the western side of the landfill graded to promote drainage away from the cell area Snapper Dams have been constructed at the southern end of Snapper to capture fresh water runoff from the overburden storage areas. This fresh water dam is utilised by the topsoil contractors for dust suppression and tree watering. The use of bunds, drains and dams works effectively to keep clean, dirty and contaminated waters separate. 2.4 Mining water supply requirements Ginkgo The operational water management demand requirements for the life of Ginkgo are to supply the following: Dredge pond (evaporation and water for slurry, which is recycled back to dredge pond) Dust suppression (bore water to a dam, fresh water as rainwater in dam in rehabilitation area and front of mine path) Onsite facilities (mine camp 40,000 L of RO water for all uses). The current operational water storages (tanks) for Gingko are: Desalinated process water 600 m 3 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

14 Desalinated potable water 90 m 3 Desalinated water Wash Bay 100 m 3. Crayfish Dry mining of the Crayfish deposit will commence in 2016 (as a satellite to the Ginkgo deposit). No new water storages are planned to be developed at Crayfish and water use (additional to that which already occurs at Ginkgo) to be limited to the supply of the administration block and associated facilities (toilets, tearooms, etc.). It is expected that only ten staff will be based at the Crayfish mine and that no additional water extraction from groundwater (in addition to the licence allocation used to service Ginkgo) will be required for the operation of Crayfish. Snapper The operational water demand requirements for the life of Snapper are to supply the following: Dredge pond Primary gravity concentration unit via the dredge pond Initial Water Dam (decommissioned) RO plant Dust suppression salt washing facility and WHIMS circuit via the RO plant. The main water storage on site was the Initial Water Dam designed to hold up to ML; this dam was required to allow rapid filling of the dredge pit at start up. At the end of 2013, this water dam was de-commissioned and during 2015 will be de-prescribed by the NSW Dam Safety Committee. The current operational water storages for Snapper are: Desalinated process/potable water (tank storages) 135 m 3 Fresh water dams (one with overflow from the RO unit and tanks) 500 m Groundwater extraction Ginkgo Cristal s production bore licences allow for the extraction of up to ML a year. There are six production extraction bores at Ginkgo (P1 P6 inclusive), each with a licence allocation of 812 ML. Crayfish mining operations will also be supplied from the existing production bore licences for Ginkgo. Groundwater processed at the RO Plant is used for the following activities at Ginkgo: Cooling towers Potable water (supplies whole camp) Dust suppression. Non-processed saline groundwater is used for the following activities: Dust suppression for haul roads Overburden removal. 6 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

15 Snapper The groundwater supply at Snapper includes three deep bores in the higher yielding Lower Olney/Warina Sand aquifer. Each of the deep bores is capable of producing approximately L/s. The authorised extraction volume for groundwater at Snapper is set at ML per year. During operation, the average groundwater requirement from the deep bores will be approximately 98 L/s. The maximum rate of dewatering disposal will be 130 L/s. Groundwater processed at the RO Plant is used for the following activities at Snapper: Cooling towers Potable water Dust suppression. Non-processed saline groundwater is used for the following activities: Dust suppression for haul roads Overburden removal. 2.5 Water balances Water balances for each of the Murray Basin mines were created for studies undertaken as part of the Environmental Assessments (Snapper and Crayfish) and Environment Impact Statement (Ginkgo) for the sites. Water balances were categorized into eight separate losses or gains (relative to the mine pond): Water into the ground via the tailings Water flow as groundwater seepage to the mine pond Water lost to the off-path tailings, isolated from the aquifer Water lost to evaporation Water used for dust suppression and potable water (volumes) Pond volume changes (change in area or level) Water from dewatering Water supplied from the bores. The information from water balances was utilised along with predictive groundwater modelling to assess the impact of mining on groundwater levels and quality. The results from these assessments were then used to develop trigger levels for groundwater level and quality against which Cristal must measure its impact on the groundwater environment and implement corrective actions where required (refer to section 4.4). The most recent Annual Environmental Management Reports (AEMRs) show that extraction production bores are significantly less than the current licence allocations for the sites (Table 1). GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

16 Table 1 Ginkgo and Snapper groundwater extraction volume (2014) Bore No. Licence No. Annual Licence allocation Volume extracted (ML) (ML) Bore 1 (P1) 60BL Bore 2 (P2) 60BL Bore 3 (P3) 60BL Bore 4 (P4) 60BL Bore 5 (P5) 60BL Bore 6 (P6) 60BL Total 4,872 2,042 Bore 1 (SB1) 60BL , Bore 2 (SB2) 60BL Bore 3 (SB3) 60BL Total 14,000 1,417* *Data for seven months Jan Jul In the 2013 calendar year, extraction volume for Snapper = 4,063 ML. 2.6 Summary of relevant activities Activities that have the potential to cause soil erosion and generate sediment at the Murray Basin mines are: Use of saline water for dust suppression Vegetation clearing and topsoil stripping Stockpiling of topsoil Construction of roads and infrastructure Construction of overburden emplacements Use of hazardous materials (such as hydrocarbons). Activities that have the potential to impact on regional groundwater levels and quality in the vicinity of the Murray Basin mines are: Extraction of groundwater for water supply for the sites Mining to below the depth of the water table (wet dredging) Dust generating activities in the vicinity of exposed groundwater pits Operation of the Gingko landfill Use of hazardous materials (such as hydrocarbons). 8 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

17 2.7 Summary of potential environmental impacts Significant impacts potentially associated with operations were assessed in the EIS or EA for each of the Murray Basin mines. Mitigation measures that regulatory authorities (for example, the department, EPA, RMS and local councils) deemed required to reduce potential risks to an acceptable level were identified and included in the Conditions of Approval and the EPL (Table 2 and Table 3). A preliminary, high-level risk assessment for the Murray Basin mines 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 the effectiveness of existing controls in reducing risks. Further details on this risk assessment are provided in the EMS. A summary of the main potential environmental impacts for water, erosion, sedimentation, salinity and groundwater at the Murray Basin mines are summarised below: Saline water used for dust suppression impacts surrounding vegetation Saline water used for dust suppression increases salinity levels in soil Run-off from stockpiles impacts surrounding vegetation Spills and leaks of hazardous materials (such as hydrocarbons) enters drainage channels Changes to surface water flow regimes at the mines and surrounding areas and as consequence, potential impacts on vegetation features/landscape Use of groundwater at the mine sites (and exposure of the water table during dredging) results in a drawdown of regional groundwater that impacts other current and potential users of groundwater (i.e. local bores) Alteration of groundwater levels changes hydraulic gradients within the local aquifer and impacts on natural recharge patterns to local rivers and other waterbodies Contamination of groundwater and land from mismanagement of onsite landfill Leachate generation and mismanagement of leachate Groundwater use and contamination by sediment and/or chemicals used on site leads to reduced groundwater quality available for other applicable beneficial users of groundwater in the region. The mitigation measures outlined in this document are based on the requirements of regulatory consent conditions (Table 2 and Table 3). The preliminary risk assessment (as appended to the EMS) identified the residual risk associated with water following the implementation of the mitigation measures in this plan as low. The mitigation measures outlined in this WMP are designed to minimise the potential impact of these above potential environmental impacts. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

18 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 EMPs; and Review and update of the EMPs. This WMP has been designed as a subordinate document to the Environmental Management Strategy (EMS, 2015), which provides the framework for all Cristal s operations at the MSP and at the Murray Basin mines. Each of the main components of the standard has been addressed in detail within the EMS. Information provided within this WMP provides additional, specific details for erosion and sediment management. The Environmental Management Framework in place for Cristal s current operations in the Murray Basin in illustrated in Figure 1. 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 1 Cristal s environmental management framework 10 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

19 3.1 Relationship to other Environmental Management Plans The structure of the environmental management documentation is presented in Figure 1. This WMP makes direct reference to the following environmental management documentation listed in Figure 2: Snapper and Ginkgo Mining Operation Plans. This management plan should be read in conjunction with the above management plans as appropriate. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

20 Companywide Integrated Management System (Environment and Safety) Murray Basin Operations Environmental Management Strategy Aug 2015 Ginkgo & Crayfish 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 Mining Operations Plan Ginkgo Mine Closure Plan Snapper Mining Operations Plan Pollutant Incident Response Management Plan Effluent Management Plan Pollution Incident Response Management Plan Air Quality Management Plan Cultural Heritage Management Plan Water Management Plan Waste and Landfill Management Plan Noise Management Plan Bushfire Management Plan Flora and Fauna Management Plan Land Management Plan Energy Savings Management Plan Borefield Impact Management Plan Offset 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 Figure 2: Environmental Management Documentation for Cristal Operations in the Murray Basin in NSW

21 3.2 Legislative requirements and project environmental approvals Project regulatory requirements Cristal is required to create, maintain and implement EMPs in accordance with the approval conditions for the Murray Basin mines. There are a number of regulatory approval documents that contain conditions for environmental management that Cristal must adhere to for operations at this site. This WMP has been created to address the specific requirements of the regulatory approval documents. The current regulatory approval documents for this project are provided in Table 2. The requirements of these regulatory approvals to be addressed in this WMP are provided in Table 3. With regards to Conditions of Approval granted for the Murray Basin mines under the EP & A Act it is noted that: Development consent for Ginkgo was granted pursuant to section 76(A)9 & 80 (Part 4) in January Development consent for Ginkgo was revised to include the Crayfish deposit in March 2015 Project Approval for Snapper was granted pursuant to section 75J (Part 3A) in August Development Consent Conditions and Environmental Protection Licences issued for Cristal s operations within the Murray Basin have been subject to a number of modifications since regulatory approvals were first granted. The latest revisions to Development Consent Conditions for the mineral sands mines were issued in March 2015 and April 2016 as shown in Table 2 Table 2 Approval documents for the Murray Basin Mines Approval Document Document Number Current revision date Ginkgo Crayfish Development Consent Conditions DA April 2016 Ginkgo Mining Lease ML No March 2002 Ginkgo Mine Environmental Protection Licence EPL December 2015 Snapper Mineral Sands Mine Conditions of Project PA (Mod March 2015 Approval 5) Snapper Mining Lease ML No July 2008 Snapper Mine Environmental Protection Licence EPL July 2012 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

22 Table 3 Regulatory Consent Conditions Applicable to this WESCP Condition number Condition details Section in WMP Ginkgo (DA ) Schedule 3 Soil and Water, Condition 9 Water Supply Schedule 3 Soil & Water, Condition 10 Water Pollution Schedule 3 Soil and Water, Condition 11 Water Management Plan The Applicant shall ensure that it has sufficient water for all stages of the development, and if necessary, adjust the scale of mining operations to match its available water supply and licenced water entitlements, to the satisfaction of the Secretary. Unless an EPL authorises otherwise, the Applicant shall comply with Section 120 of the Protection of the Environment Operations Act 1997 during the carrying out of the development. The Applicant shall prepare and implement a Water Management Plan for the development to the satisfaction of the Secretary. This plan must be prepared in consultation with DPI Water, by suitably qualified and experienced person/s whose appointment has been endorsed by the Secretary, and submitted to the Secretary for approval by 31 March 2016, unless otherwise agreed with the Secretary. This plan must include: (a) A water balance for the development that includes details of: sources and security of water supply; water licences; water make/use; and any water discharges; and (b) management plans for the surface facilities, that include: Sections 2.5, and Section Section 2.5 and 4 a detailed description of water management systems for each site; measures to reuse and recycle water; measures to manage the quality and quantity of surface and ground water; salinity management measures including design 14 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

23 Condition number Condition details Section in WMP measures to minimise any lateral seepage of brackish water from the water dams, emplacements areas and/or sand residue dams; contingency plans to deal with any lateral salt water seepage and/or leachate seepage or breakdown in the dam linings; and monitoring and reporting procedures, including: the volume of pumped leachate; and the holding dam water; and (c) erosion and sediment control measures that must: be consistent with the requirements of Managing Urban Stormwater, Soils and Construction Volume 2E Mines and Quarries, (DECC 2008), or the latest edition; describe measures to minimise soil erosion and the potential for the transport of sediment off site; describe the location, function, and capacity of erosion and sediment control structures; and describe what measures would be implemented to maintain these structures over time, and (d) a Borefield Impact Management Plan that includes: data to benchmark the natural variation in groundwater levels and quality; a detailed program to monitor the groundwater impacts of the development; groundwater impact trigger levels for relevant landholder bores; and a protocol for the investigation, GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

24 Condition number Condition details Section in WMP notification and mitigation of any identified exceedances of the groundwater impact assessment criteria. Snapper (PA ) Schedule 3 Soil & Water Condition 1 Discharges Schedule 3 Soil & Water Condition 2 Water Management Plan Schedule 3 Soil & Water Condition 3 Erosion and Sediment Control Measures Except as may be expressly provided for by an EPL, the Proponent shall not discharge any water from the site. The Proponent shall prepare and implement a Water Management Plan for the project to the satisfaction of the Secretary. This plan must: (a) be prepared in consultation with the EPA and NOW by suitably qualified expert/s whose appointment/s have been approved by the Director-General; (b) be submitted to the Secretary for approval prior to carrying out any development on the site; and (c) include: Erosion and Sediment Control Measures; Surface Water Management Measures; and Borefield Management Measures. The Erosion and Sediment Control Measures must: (a) be consistent with the Managing Urban Stormwater: Soils and Construction manual (Landcom, 2004 or its latest version); (b) identify activities that could cause soil erosion and generate sediment; (c) describe measures to minimise soil erosion and the potential for the transport of sediment; (d) describe the location, function, and capacity of erosion and sediment control structures; and (e) describe what measures would be implemented to monitor and maintain the integrity of the structures over time. No water discharge will occur from the site (not applicable) Section 4 Section GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

25 Condition number Condition details Section in WMP Schedule 3 Soil & Water Condition 3 Erosion and Sediment Control Measures Schedule 3 Soil and Water Condition 5 Borefield Management Measures The Surface Water Management Measures must: (a) describe the salinity management measures on site including the design measures proposed to be used to minimise any lateral seepage of brackish water from the initial water dam, initial emplacement containing the overburden slurry, and initial sand residue dam which could contaminate adjacent soils and cause vegetation dieback; (b) describe measures to manage dust suppression water along the haulage route between the Silver City Highway and the site; (c) include a program to monitor the effectiveness of these measures, with specific reference to vegetation and soil performance criteria; and (d) describe the measures that would be implemented if any exceedances of the performance criteria are detected. The Borefield Management Measures must include: (a) a site water balance; (b) data to benchmark the natural variation in groundwater levels and quality prior to any development on site within the predicted drawdown impact zone (identified in the EA); (c) groundwater impact trigger levels for relevant landholder bores (e.g. Chalky Well); (d) a program to monitor the groundwater impacts of the project; (e) the procedures that would be implemented if the groundwater impact trigger levels are exceeded; and (f) measures to mitigate and/or compensate landholders who are adversely affected by the groundwater impacts of the project, including the provision of alternative water. Section 4.3 Section 2.5 and 4.4 Ginkgo Mine Environmental Protection Licence (EPL 12264) Schedule 2 Discharges to Air and Water and Applications to Land, Condition P 1.2 Schedule 2 Discharges to Air and Water and The following utilisation areas referred to in the table below are identified in this licence for the purposes of the monitoring and/or setting of limits for any application of solids or liquids to the utilisation area. Water and Land Section GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

26 Condition number Condition details Section in WMP Applications to Land, Condition P 1.3 EPA Identification no. Type of monitoring Type of discharge Location description point point 2 Groundwater monitoring 3 Groundwater monitoring 4 Groundwater monitoring Identified as M27 in figure 7 of map Local Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file Identified as M19 in figure 7 of map Local Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file Identified as M21 in figure 7 on map Local Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

27 Condition number Condition details Section in WMP 6 Groundwater monitoring 7 Groundwater monitoring 9 Groundwater monitoring Identified as M26 in Figure 6 on map Regional Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file Identified as Chalky Well in Figure 6 on map Regional Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file Identified as Grenvale Well in Figure 6 on map Regional Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

28 Condition number Condition details Section in WMP 10 Groundwater monitoring 11 Groundwater monitoring 12 Groundwater monitoring Identified as DLWC in Figure 6 of map Regional Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file Identified as DLWC in Figure 6 on map Regional Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file Identified as DLWC in Figure 6 on map Regional Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

29 Condition number Condition details Section in WMP 13 Groundwater monitoring Identified as Trelaga Bore in Figure 6 of map Regional Groundwater Monitoring Sites received by the EPA on 3/5/06 and in EPA file Schedule 3 Limit Conditions, Condition L1 Pollution of Waters L 1.1 Schedule 5 Monitoring and Recording Conditions, Condition M 2.3 Water and Land Monitoring Requirements Except as may be expressly provided in any other condition of this licence, the licensee must comply with section 120 of the Protection of the Environment Operations Act Point 2, 3, 4, 5, 6, 7, 9, 10, 11, 12, 13 Pollutant Units of measure Frequency Sampling Method Standing Water Metres Quarterly Inspection Level Section Total Dissolved Solids Milligrams per litre Quarterly Representative sample Snapper Mine Environmental Protection Licence EPL Schedule 2 Discharges to Air and Water and Applications to Land, Condition P 1.2 The following points referred to in the table are identified in this licence for the purposes of the monitoring and/or setting of limits for discharges of pollutants to water from the point. GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

30 Condition number Condition details Section in WMP Schedule 2 Discharges to Air and Water and Applications to Land, Condition P 1.3 The following utilisation areas referred to in the table below are identified in this licence for the purposes of the monitoring and/or setting of limits for any applications of solids or liquids to the utilisation area. Water and land Section EPA Identification no. Type of monitoring point Type of discharge point Location description 7 Groundwater Identified as SM2 received by EPA on 30 May 2012 and in EPA file as DOC12/ Groundwater Identified as SM3 received by EPA on 30 May 2012 and in EPA file as DOC12/ Groundwater Identified as SM4 received by EPA on 30 May 2012 and in EPA file as DOC12/22510 Schedule 3 Limit Conditions, Condition L1 Pollution of Waters L 1.1 Except as may be expressly provided in any other condition of this licence, the licensee must comply with section 120 of the Protection of the Environment Operations Act GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

31 Condition number Condition details Section in WMP Schedule 3 Limit Conditions, Condition L2 Waste L 2.5 Schedule 3 Limit Condition, Condition O4 Processes and Management Waste Management Plan O4.3 The onsite solid waste landfill must be constructed, managed and rehabilitated in accordance with the Ginkgo Mineral Sands Mine Waste Management Modification Environmental Assessment August 2015 (DA ) and the Environmental Protection Authority Environmental Guidelines: Solid Waste Landfill (2015). The licensee must prepare and implement an Erosion and Sediment Management Plan for the premises. The Erosion and Sediment Management Plan must be prepared and implemented to ensure compliance with the conditions of this Licence and relevant environmental legislation. Details provided in the EA mod (Resource Strategies, 2015) and the landfill construction verification report (GHD 2016). Refer to the Waste and Landfill Management Plan. Section Schedule 5 Monitoring and Recording Conditions, Condition M 2.3 Water and Land Monitoring Requirements Point 2,3,4, 7, 9, 10, 11, 12, 13 Pollutant Units of measure Frequency Sampling Method Standing Water Metres Quarterly Inspection Level Section Total Dissolved Solids Milligrams per litre Quarterly Representative sample GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/

32 3.2.2 Relevant legislation and other requirements This project is subject to the requirements of the New South Wales Protection of the Environment Operations Act 1997 and it subordinate legislation. A full legislative register is provided in the EMS (2015); acts, regulations and policies specific to this WMP are listed below. New South Wales Contaminated Land Management Act 1997 Contaminated Land Management Regulation 2013 Dams and Safety Act 1978 Environmentally Hazardous Chemicals Act 1985 Environmentally Hazardous Chemicals Regulations 2008 Protection of the Environment Operations Act 1997 Protection of the Environment Administration Regulation 2012 Protection of the Environment Operations (General) Regulation 2009 Protection of the Environment Operations (Underground Petroleum Storage Systems) Regulation 2014 Protection of the Environment Operations (Waste) Regulation 2014 Protection of the Environment Legislation Amendment Act 2011 Environmental Planning and Assessment Act 1979 Mining Act 1992 Soil Conservation Act 1984 Waste Avoidance and Resource Recovery Act 2001 Water Act 1912 Water Management Act 2000 Aquifer interference regulation Relevant standards, policies and guidelines Environmental Guidelines: Solid Waste Landfills (NSW EPA 2016) Control of Workplace Hazardous Substances National Model Regulation [NOHSC:2007(1994)]; National Code of Practice [NOHSC:2007(1994)] Storage and Handling of Workplace Dangerous Goods National Standard [NOHSC:1015(2001)]; National Code of Practice [NOHSC:2017(2001)] National Environment Protection (Assessment of Site Contamination) Measure 1999 (Commonwealth) (varied April 2013) National Environment Protection (National Pollutant Inventory) Measure 1998 (Commonwealth) National Environmental Protection (Used Packaging Materials) Measure 2011 (Commonwealth) AS : The Storage and Handling of Flammable and Combustible Liquids AS Guidance on the Design of Sampling Programs, Sampling Techniques and the Preservation and Handling of Samples 24 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

33 AS/NZS :1998 Water Quality Sampling Part 11: Guidance on sampling of groundwaters Australia New Zealand Environment and Conservation Council (ANZECC) Australian and New Zealand Guidelines for Fresh and Marine Water Quality, October 2000 NSW Waste Classification Guidelines 2014 State Environmental Planning Policy No. 55 Remediation of Land Managing Urban Stormwater: Soils and Construction, Volume 2E Mines and Quarries (NSE DECC 2008 or most recent revision) Managing Urban Stormwater: Soils and Construction, Volume 1 (4 th Edition) Landcom 2004 Managing Urban Stormwater: Council Handbook, Draft (NSW EPA 1997) Design Manual for Soil Conservation Works Technical Handbook No. 5 (Soil Conservation Service of NSW 1987) Urban Erosion and Sediment Control Handbook, NSW Department of Conservation and Land Management (J.S. Hunt, 1992) Australian Rainfall and Runoff, Engineers Australia, Current Version Licensing requirements Protection of the Environment Operations Act, 1997 Cristal has obtained an Environmental Protection Licence (EPL) from the NSW EPA pursuant to the Protection of the Environment Operations Act The licence includes conditions for the pollution of waters in order to comply with section 120 of the Protection of the Environment Operations Act Water Act 1912 Ginkgo development consent condition 4.2 (ii) requires Cristal to obtain a licence, under Part II of the Water Act 1912, for the pump and related infrastructure to extract water from the Darling River. It is considered highly unlikely that water will be extracted from the Darling River by Cristal. Ginkgo development consent condition 4.2 (iii) and Snapper development consent Schedule 3 Condition 2 requires Cristal to prepare and implement a (WMP) under Part 5 of the Water Act 1912 that includes erosion and sediment control measures, surface water management measures and borefield management measures. NSW Dams Safety Act, 1978 Where necessary, Cristal will obtain approval from the NSW Dams Safety Committee prior to construction of any dams and embankments, which fall within the provisions of the NSW Dams Safety Act Roles and responsibilities Overall roles and responsibilities for environmental management at the Murray Basin mines are outlined in Cristal s EMS. The responsibility for this WMP lies with the Senior Rehabilitation Advisor. 25 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

34 3.4 Training and inductions Overall training and induction requirements for Cristal s operations at the Murray Basin mines are outlined in Cristal s EMS. 3.5 Complaint, non-conformance and incident management Complaint, non-conformance and incident management for Cristal s operations at the Murray Basin mines is described in Cristal s EMS. 3.6 Environmental reporting and correspondence Annual Environmental Management Report (AEMR) Conditions of Approval for the Murray Basin mines require that Cristal submit an Annual Environmental Management Report (AEMR) to the Secretary of the department. Details of information to be included in the AEMR are provided in Cristal s EMS. For water, erosion and sediment control and groundwater management the AEMR should include but not be limited to details of: The effectiveness of the sediment and erosion control systems and performance against objectives contained in this WMP (section 4) Details of the sediment and erosion control strategies undertaken for the preceding 12 months Any proposed modifications to erosion and sediment control strategies for the upcoming 12 month period Site water management system strategies and the effectiveness of management measures Process water source and supply requirements, site water balance, storage, impact management and monitoring of groundwater in the vicinity of the mining operations A record of all groundwater levels, analysis and volume of water extracted Assessment of impact of operations on groundwater levels and quality compared with expected impacts and environmental factors (such as rainfall) Consultation with EPA, other regulatory authorities and landholders General consultation Consultation processes applied for the Murray Basin mines are provided in detail in the EMS. Complaints and conflict resolution processes for the Murray Basin mines are detailed in Section 5.5 of the EMS (March 2015); the dispute resolution process is also illustrated in Appendix G of the EMS. In the event that Cristal, regulatory authorities or landholders cannot agree on the specifications or requirements of this management plan, the matter shall be referred by either party to an Independent Dispute Facilitator appointed by DPI Water as illustrated in the dispute resolution process within the EMS. Once a matter is referred to the Independent Dispute Facilitator, and if not resolved, the Minister for Planning s determination of the disagreement shall be final and binding on the parties. The independent dispute resolution process is to consider and incorporate in the resulting decision, any relevant DPI Water statutory and natural resource management responsibilities. 26 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

35 Consultation regarding changes to the groundwater bore monitoring network In May 2013, bore M02 was mined out at the Ginkgo Mine and in April 2014, a groundwater bore (PW2) within the mine path at Snapper was mined out as part of the mining schedule. At the time this occurred, there was no formal procedure in place to consult with regulatory authorities on changes to the groundwater monitoring network and the EPA was not notified of the removal of bores located in the middle of the mine paths until after it had occurred. It has been decided that a consultation procedure is needed so that the EPA and other relevant authorities are aware of the pending removal of groundwater monitoring infrastructure before it occurs. It has been identified that monitoring bore PW1 is located at the north end of the Snapper mine path and will be mined out in the process of future mining operations with this bore removal likely to occur in late Cristal will notify EPA of the expected date of the removal of this bore at least three months prior to the scheduled date of removal. EPA will be notified formally by letter with a request that EPA respond with any issues related to this pending removal at least six weeks prior to the scheduled removal. If no response is received from the EPA within this timeline, Cristal will assume acceptance of the letter and continue as planned. Cristal will include details of any new bores proposed to replace the existing bore or other new mitigation measures proposed to compensate for the removal of PW1 in the letter to the EPA. If no new mitigation measures are planned to compensate for the removal of this bore, Cristal will provide details to the EPA to justify this approach (for example, details on how existing control measures and monitoring are considered adequate to meet obligations detailed within section 4 of this WMP). 3.7 Audits of the WMP Conditions of Approval for the Murray Basin mines require that Cristal conduct an Independent Environmental Audit every three years or as otherwise directed by the Secretary of the department. Matters to be covered by the Independent Environmental Audit are described in Cristal s EMS. Further detail of the how audits of EMPs will be conducted (including internal audits) is provided in the EMS. 3.8 Review and update of WMP Conditions of Approval for the Murray Basin mines outline requirements for revision and update of EMPs. EMPs would be reviewed, and if necessary revised to the satisfaction of the Director General, within three months of: (a) The submission of an AEMR (b) The submission of an incident report (c) The submission of an Independent Environmental Audit Report (d) Any modification of the regulatory consent conditions. Further details on the requirements for review and update of EMPs are provided in the EMS. 27 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

36 4. Environmental management program 4.1 Objectives To control soil erosion and sediment generation from areas disturbed by mining activities To minimise the potential for activities to lower the water quality (particularly in terms of total suspended solids content) of downstream watercourses To minimise salinisation caused by mining activities To contain contaminated water (including leachate) onsite in constructed dams to result in zero offsite discharges To conserve water resources throughout all areas of the operation Maximising the reuse/recycling of water to decrease the demand on external water supplies To prevent impacts to regional groundwater (depth to water, quality and hydraulic conductivity and gradients) that will effect current and future potential beneficial uses of groundwater (i.e. stock watering, maintenance of ecosystems). 4.2 Performance standard The following performance outcomes have been identified against the objectives of the WMP. The objectives will be achieved if: Erosion and sediment control structures conform with the NSW Government Managing Urban Stormwater: Soils and Construction (Volume 1, 4 th Edition) The Blue Book Active erosion is not evident along stormwater channels and retention systems To maintain soil salinity at as close as possible to pre-mining levels, no increase in soil salinity due to mine practices resulting in dryland, river, or industrial salinity. Disturbance areas are restricted to operations areas Up-slope stormwater flow is diverted around operational areas Water run-off from operational areas is contained and recycled onsite Water monitoring and response measures are established Exposed areas are stabilised and revegetated Groundwater levels and quality as close as possible to pre-mining levels and maintained within acceptable range (as defined by trigger levels for depth and quality developed for selected bores near the mines). 4.3 Environmental mitigation measures for surface water, erosion and sediment control Ginkgo erosion and sediment control structures The erosion and sediment control structures that will be implemented during the operational phase are described below for the following Project components. These are shown on the figures in Appendix A. Erosion and sediment control structures will be designed in accordance with the criteria in Appendix B with design undertaken by the appointed Cristal engineer. 28 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

37 Initial laydown area The Stage 1 and Stage 2 laydown area have been mined out and form part of the mining area. There is still one laydown area at Ginkgo outside of the mine path between the Wet High Intensity Magnetic Separator (WHIMS) and overburden emplacement No. 1 (OB1). Mining area The mining area effectively acts as its own retention structure. The perimeter of the construction pit has been stripped an additional 20 metres to accommodate an access track. The access track is bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Start-up water dam and tailings dam facility The start-up water dam and tailings dam facility has been decommissioned and has been shaped and prepared for rehabilitation in The catch drain and bunding structure surrounding the start-up water dam and tailings dam facility are maintained. Overburden emplacements Overburden emplacements OB1, OB2 and OB3 have been decommissioned and are in various stages of rehabilitation. The catch drain and bunding structure surrounding the overburden emplacement are maintained. OB4 is a temporary overburden structure and will be mined through and rehabilitated in Slimes Dam The slimes dam has been decommissioned and will be rehabilitated. DMU dam The DMU dam has been has been decommissioned and rehabilitated. The catch drain and bunding structure surrounding the DMU dam are maintained. Wet High Intensity Magnetic Separator (WHIMS) The WHIMS is operational and will be active for the life of the mine. Dirty water is directed to a local retention structure located in the vicinity of the facility. The area is bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Onsite landfill The landfill has been designed and constructed to minimise surface water ingress into the landfill and leachate holding dam. The following surface water controls are maintained: A clay bund at the southern end of the leachate holding dam A clay bund at the crest of the eastern batter The access road at the western side of the landfill area is graded to promote drainage away from the cell area The construction of the landfill cell and associated leachate holding dam was verified by GHD in May 2016 (GHD 2016). Administration office, workshop and accommodation An area was stripped to accommodate the administration office, workshop and accommodation facilities for the life of the mine. Dirty water from these facilities is directed to a local retention 29 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

38 structure located in the vicinity of the administration office, workshop and accommodation area. The area is bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Site access roads Access roads are bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Access roads are watered with saline groundwater for dust suppression purposes. Sediment sumps have been placed at regular intervals alongside all access roads, to contain all dirty water runoff within the sediment sumps for reuse. Groundwater salts collected in these sumps will be periodically removed and deposited with sand residues behind the dredge pond. Erosion of the bed and banks upstream and downstream of road drainage crossings are prevented with suitable scour protection Snapper erosion and sediment control structures Initial laydown area The Stage 1 and Stage 2 laydown area has been mined out and will form part of the mining area. There is still one laydown area at Snapper adjacent to the Snapper administration buildings. Mining area The mining area effectively acts as its own retention structure. The perimeter of the construction pit was stripped an additional 60 m to accommodate bunding, pipelines and the haul road. This area is bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Water dam and off path tails dam (OPTD) The water dam and OPTD were constructed with overburden materials from the construction pit. The storage covers an approximate area of 120 ha with embankments and average of 5-10 m in height. The embankments and floor of the storage have been lined with clay to minimise water losses. The water dam and OPTD were designed with enough excess capacity to accommodate the additional storage requirements associated with a peak rainfall event. The water dam and OPTD are surrounded by a catch drain and bunding structure. This structure retains dirty water that may run-off the embankments, which are directed to the overburden retention structure. The retention structure has been designed to accommodate the storage requirements associated with the entire area of the water dam and off path tails dam. The catch drain and bunding structure will also act to divert clean stormwater away from the disturbed and contaminated land surfaces. The OPTD has been decommissioned and will be capped with overburden from the Snapper earthworks pit and rehabilitated. The water dam is no longer in use and is due for decommissioning in There are no other water storages currently at Snapper mine. Non-slurried overburden emplacement Excess overburden material from the construction pit excavation is placed in a non-slurried overburden emplacement. The non-slurried overburden emplacement covers an area of approximately 250 ha. The non-slurried overburden emplacement is surrounded with a catch drain and bunding structure. This structure retains dirty water that runs off the embankments of 30 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

39 the non-slurried overburden emplacement and diverts it to a site sediment catch dam. The site sediment catch dam has been designed to accommodate the storage requirements associated with the entire area of the non-slurried overburden emplacement. The catch drain and bunding structure also act to divert clean stormwater away from the disturbed and contaminated land surfaces. When the non-slurried overburden emplacement is completed, a retention structure will be constructed on the top of the emplacement. The retention structure will be designed to accommodate the storage requirements associated with the top of the overburden emplacement (the catchment area). This will minimise the potential flow of water down the batters of the overburden emplacement. Heavy Mineral Concentrate (HMC) tower The Heavy Mineral Concentrate (HMC) tower at Snapper is operational and will be active for the life of the mine. Dirty water is directed to a local retention structure located in the vicinity of the facility. The area is bunded to divert clean stormwater away from the disturbed and contaminated land surfaces (Appendix A). Administration office and workshop An area has stripped to accommodate the administration office and workshop facilities for the life of the mine. Dirty water is directed to a local retention structure located in the vicinity of the administration office and workshop. The area is bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Site access roads Access roads are bunded to divert clean stormwater away from the disturbed and contaminated land surfaces. Access roads are watered with saline groundwater for dust suppression purposes. Sediment sumps are placed at regular intervals alongside all access roads, to ensure that all dirty runoff is contained within the sediment sumps for reuse. Groundwater salts collected in these sumps are periodically removed and deposited with sand residues behind the dredge pond. Erosion of the bed and banks upstream and downstream of road drainage crossings are prevented with suitable scour protection Mitigation measures surface water, erosion and sediment control Table 4 outlines environmental mitigation measures for water, erosion and sediment control at the Murray Basin mines. 31 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

40 Potential impact Table 4 Surface water, erosion, sediment control and salinity mitigation measures Mitigation measure Site Responsibility Monitoring Saline water used for dust suppression increases salinity in soil or impacts vegetation (Dryland salinity) Minimise areas disturbed by Project components. Restrict access to non-disturbed areas. Implement, monitor and maintain erosion and sediment control measures as outlined in section Murray Basin mines Senior Rehabilitation Advisor Erosion and sediment control inspections (4.3.4) Salinity monitoring (4.3.4) Saline water used for dust suppression increases Saline water used for the Project mining operations will be pumped directly to the dredge pond to maintain dredge pond water levels during mining. Saline water requirements of the dredge Murray Basin mines Senior Rehabilitation Advisor Erosion and sediment control inspections salinity in soil or impacts vegetation (Industrial salinity and river land salinity) pond are such that make-up water is required during the life of the Project (i.e. at no stage is the Project predicted to operate at a water surplus) (4.3.4) Salinity monitoring (4.3.4) Groundwater bore monitoring (4.4.1) Seepage control measures for the initial water and sand residue dams include moisture Murray Basin Senior Rehabilitation Erosion and sediment conditioned compacted clay floor liners, upstream clay fill zone embankments, seepage cut-off mines Advisor control inspections trenches, moisture conditioned and compacted in situ foundation soils and toe drains. Water collected in the toe drains and cut-off trenches will be recycled back to the dredge pond. (4.3.4) Salinity monitoring (4.3.4) Groundwater bore monitoring (4.4.1)

41 Potential impact Mitigation measure Site Responsibility Monitoring The water management scheme incorporates interception drains (toe drains) and collection storages (temporary sediment basins and contained water storages) around stockpile areas Murray Basin mines Senior Rehabilitation Advisor Erosion and sediment control inspections and overburden emplacements containing saline materials. Groundwater is used as dust suppression water within the Mining Lease Area (MLA) on roads where runoff is controlled and directed to evaporation sumps. Groundwater salts collected in these sumps is periodically removed and deposited with sand residues behind the (4.3.4) Salinity monitoring (4.3.4) dredge pond. Following cessation of mining, areas that have been subject to dust suppression watering will be rehabilitated. Rehabilitation of these areas will Murray Basin mines Senior Rehabilitation Advisor Erosion and sediment control comprise stripping of any salt contaminated materials for disposal under overburden (in the inspections (4.3.4) final depression) followed by chemical testing of foundation soils, contour ripping and, if required, chemical amelioration. Stockpiled soils would then be applied as necessary and stabilised. Salinity monitoring (4.3.4) Revegetation would be undertaken with suitable endemic plant species. Run-off from stockpiles Drainage from disturbance areas around the overburden stripping and overburden Murray Basin Senior Rehabilitation Erosion and sediment enters sensitive vegetated replacement operations will be directed to the evaporation/sediment sumps for containment. Waters collected in evaporation/sediment sumps mines Advisor control inspections (4.3.4) areas Sediment laden run-off during heavy rainfall events Water and wind erosion of soils impacts sensitive vegetated areas may be utilised for dust suppression at the mine site or allowed to evaporate. Upslope diversion drains/bunds will direct runoff from undisturbed catchments upslope of the disturbance areas. Stormwater diversion systems installed at the commencement of the construction period include both permanent and temporary structures. Permanent structures will continue to operate post-closure, while temporary structures will be required until rehabilitated areas are stabilised. Campaign soil stripping of disturbance areas will be undertaken prior to the commencement of construction activities. Where practicable, soil stripping will be undertaken as a two pass operation to separate topsoil (containing higher Murray Basin mines Murray Basin mines Senior Rehabilitation Advisor Senior Rehabilitation Advisor Erosion and sediment control inspections (4.3.4) Erosion and sediment control inspections (4.3.4) 33 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

42 Potential impact Mitigation measure Site Responsibility Monitoring levels of organic matter) from subsoil material which will be stockpiled in separate windrows. Topsoil stripping will be undertaken to a depth of approximately 15 cm within proposed disturbance areas and stockpiled in windrows. Soil sampling indicates that mine disturbance areas occur on a combination of soil types including areas of solonised soils and calcareous red earths which have a layer of calcareous material in the lower soil profile (at depths of greater than 30 cm). Subsoil stripping will be undertaken to a maximum depth of 25 cm to avoid contamination of soil resources with deeper calcareous subsoil materials. Soils will be stripped using a scraper fleet and will be stockpiled along the outside margins of the mine path before being re-spread on rehabilitation areas. When climatic conditions are appropriate, soil stripping and rehabilitation works will be undertaken on a campaign basis and integrated as a single operation. Where soils cannot be used directly in rehabilitation works, they will be stockpiled in windrows constructed with a rough surface condition to reduce erosion hazard, improve drainage and promote revegetation. Stockpiles will be seeded with suitable grass and legume species to maintain soil viability for future rehabilitation works. Leaks and spills of hazardous materials (such as diesel, soil and lubrication fluids) that is washed to drainage Vehicle movements limited to designated areas. Murray Basin mines Mine Operations Manager /All personnel Daily visual inspections 34 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

43 Potential impact Mitigation measure Site Responsibility Monitoring Site staff to respond to minor spills on site. Murray Mine As per External emergency services are contracted in Basin Operations Emergency the event of a major emergency at the site. mines Manager /All Response personnel Procedures and Pollution Incident Response Management Plan. Spill clean-up procedures as outlined in the Murray Mine As per Emergency Response Procedures and Pollution Basin Operations Emergency Incident Response Management Plan. These mines Manager Response outline the steps to be undertaken when cleaning Procedures up spills and responding to emergencies, and Pollution including environmental incidents. Incident Response Management Plan. Spill clean-up kits are located in strategic areas Murray Mine Monthly for use in containing spills of up to 400 litres. Basin Operations inspections mines Manager of spill kits. Contamination With each lift of waste at the landfill, a bund will Murray Mine Erosion and of surface be built along the southern extent of the waste at Basin Operations sediment water from the interface with the leachate holding dam. The mines Manager control leachate from bund is to be constructed with compacted clay inspections the Gingko and inspected regularly with the batter (4.3.4) landfill constructed no steeper than 1(V) in 3(H). Any damage from erosion would be repaired. Regular clean out any accumulation of silt from within the leachate holding dam, with care taken not to damage the geomembrane. Damaged or compromised geotextile materials or sandbags comprising the landfill cell and leachate holding dam will be replaced with like materials as required. Leachate overflow from the leachate holding dam will be contained in the adjacent tails/safety dam and allowed to evaporate. EPA will be notified of overflow from the leachate dam as an environmental incident as per procedures provided in the EMS and Community Consultation Plan 35 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

44 4.3.4 Monitoring surface water, erosion and sediment control Surface water, erosion and sediment control inspections Documented inspections of onsite sediment control structures are undertaken on a monthly basis and/or following major rainfall events. The structures will also be assessed for structural integrity and effectiveness. Inspections will be undertaken to check: There are no low points in retention structures that could overtop in a large storm event Sediment fences are not undercutting, sagging and/or overtopping Design capacity and minimum freeboard of sediment dams, leachate holding dam and drains are maintained Drains, sediment dams and the leachate holding dam are operating as intended The exposed walls of the landfill cell and leachate holding pond The leachate holding dam geomembrane and sandbags, as these may deteriorate over time due to exposure to UV There are no active areas of erosion There are no potential adverse impacts from the use of saline groundwater as indicated by substantial areas of degradation in evaporation sumps. Should these areas show substantial degradation as a result of watering with saline groundwater then alternative methods for dust suppression will be considered. Retention structures will be inspected as part of the monthly inspection and cleaned out, if required, to maintain design storage capacity. Salts and silty material collected will be removed and deposited with the tailings from the mining operation. The inspection will also consider the effectiveness of the retention structure and any required modifications. Following rainfall events, water quality testing may also be undertaken of puddles along the Highway Access Road (HAR). Rehabilitation monitoring The process water borefield would be rehabilitated following mine closure. Rehabilitation would include removal of pumping and electrical infrastructure, plugging and capping of bores and revegetation. Some boreholes may be retained for ongoing monitoring in consultation with NOW. Rehabilitated areas will be monitored to assess the success of rehabilitation techniques and to identify if any remediation work is required. Monitoring will include: Assessing the status of soil erosion and the effectiveness of mitigation measures Confirmatory testing to demonstrate acceptable background radiation levels and soil chemistry Identifying the presence of any weed species or feral animals An assessment of the need for remedial planting or other maintenance works Progress of any required rehabilitation of the site will be summarised in the AEMR. Monitoring of areas where saline water is used for dust suppression A vegetation monitoring programme would be implemented in areas where saline water is used for dust suppression. The rates of occurrence of vegetative die-back in close proximity to areas of saline water application would be monitored. These results would be compared to similar 36 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

45 monitoring to be conducted at control site(s). If monitoring results are indicative of detrimental Project attributable impacts, an investigative process would be implemented. This is detailed in section In addition to the vegetation monitoring programme in areas where saline water is used for dust suppression, soil salinity (i.e. electrical conductivity (EC]) measurements of a soil/water solution) monitoring will be undertaken. Monitoring will be conducted at sites located within the mining lease existing sites, adjacent the highway access road and other major Project roads at varying distances from the road verge (e.g. 10 m, 20 m and 50 m). The trend of monitoring results will be assessed and an investigative process will be implemented if monitoring results are indicative of detrimental Project attributable impacts. This is detailed in section Monitoring leachate No leachate is proposed to be pumped as part of the onsite landfill operations. Leachate generated by the landfill and draining into the leachate holding dam will be disposed of by evaporation to the atmosphere. Refer to the Waste and Landfill Management Plan for monitoring in relation to leachate management at the Gingko landfill Contingency surface water, erosion and sediment control Erosion and sediment control A maintenance program for the sedimentation and erosion control structures has been implemented based on the results of the monitoring program. The following maintenance/remediation works will be undertaken on sediment and erosion control structures as required: Periodically cleaning out sediment dams and diversion drains to maintain design capacity Silt and salts removed from the retention structures servicing access roads that have had dust suppression water applied are disposed with the tailings from the mining operation Replacement or repairing of sediment fences and other such biodegradable products Control of excessive vegetative growth in drains and channels where water flow is impeded through mowing, slashing or biodegradable herbicides. Salinity management If results of monitoring, undertaken in areas where saline water is used for dust suppression, are indicative of detrimental Project attributable impacts, an investigative process will be implemented. The investigative process may include: Baseline soil salinity (EC) levels Vegetation tolerance levels Species-specific considerations Prevailing meteorological considerations Methods and rates of road watering and saline water use Rehabilitation measures to mitigate Project attributable impacts. 37 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

46 Water contamination remediation measures In the event that surface water resources are contaminated as a result of mine operations, contamination remediation measures will be implemented. The remediation measures will involve: Identifying the source of the contaminant Immediately controlling the source of the contaminant (e.g. cease pumping, temporary bunding) Assessing the impact of the contaminant Remediation/ rehabilitation of the affected water source/ area Implementing additional mitigation measures to prevent further and/or future contamination such as: Establishing engineering controls Changing work practices Modifying water management systems Monitoring to ensure the issue has been addressed. Further detail is provided in the Pollution Incident Response Plan Contingency Ginkgo landfill The operation of the landfill is governed by the Waste and Landfill Management Plan. Of relevance to the management of water associated with the operation of the landfill, the following applies: With each lift of waste at the landfill, a bund will be built along the southern extent of the waste at the interface with the leachate holding dam. The bund is to be constructed with compacted clay and inspected regularly and the batter constructed no steeper than 1(V) in 3(H). Any damage from erosion would be repaired. Regular clean out any accumulation of silt from within the leachate holding dam with care taken not to damage the geo-membrane. Damaged or compromised geotextile materials or sandbags comprising the landfill cell and leachate holding dam will be replaced with like materials as required. Leachate over flow from the leachate holding dam will be contained in the adjacent tails/safety dam and allowed to evaporate. EPA will be notified of overflow from the leachate dam as an environmental incident as per procedures provided in the EMS and Community Consultation Plan. Refer to the Waste and Landfill Management Plan for specific management actions in relation to the operation of the landfill. 4.4 Environmental mitigation measures for groundwater Groundwater monitoring Operational Monitoring Program A network of bore sites has been selected for monitoring to effectively assess the potential cumulative groundwater effects of the mines and ancillary activities such as the operation of the onsite landfill at Ginkgo. The monitoring sites consist of existing landholder owned bores/wells, DPI Water regional monitoring bores and Cristal Mine project related monitoring bores. Water 38 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

47 levels and TDS will be monitored on a monthly basis and other listed (Table 5) analytes will be monitored on a quarterly basis. Some bores are monitored for TDS and level on a quarterly basis rather than monthly as indicated in Table 5. The location of the groundwater monitoring sites and analytes are listed in Table 5 and identified in Figure 4. Table 5 Groundwater Monitoring Sites Borehole/Well ID Location Description Analysis M19 Ginkgo North of Mine Path Level, TDS, EC, Chloride, Sulphate, Bicarbonate, K, Na, Ca, Mg, Fe, Pb, Mn, P M21 Ginkgo South of Mine Path Level, TDS, EC, Chloride, Sulphate,, Bicarbonate, K, Na, Ca, Mg, Fe, Pb, Mn, P M26 Ginkgo SE Corner of Mining Lease Level, TDS, EC, Chloride, Sulphate,, Bicarbonate, K, Na, Ca, Mg, Fe, Pb, Mn, P M27 Ginkgo NW Corner of Mining Lease Level, TDS, EC, Chloride, Sulphate,, Bicarbonate, K, Na, Ca, Mg, Fe, Pb, Mn, P PW1 Snapper North End on Mine Path Level, TDS, EC, Chloride, Sulphate,, Bicarbonate, K, Na, Ca, Mg, Fe, Pb, Mn, P SM2-1 Snapper Snapper Administration Level, TDS SM2 2 Snapper Snapper Administration Level, TDS SM3 Snapper South-western boundary fence Level, TDS, EC, Chloride, Sulphate,, Bicarbonate, K, Na, Ca, Mg, Fe, Pb, Mn, P SM4 Snapper Southern corner of lease Level, TDS, EC, Chloride, Sulphate,, Bicarbonate, K, Na, Ca, Mg, Fe, Pb, Mn, P SM5-1 SM5- Snapper 4 km SW of site Level, TDS 2 Snapper 4 km SW of site Level, TDS GW36669 Regional 5 km south of Ginkgo Level, TDS GW36670 Regional 36 km WNW of Ginkgo Level, TDS GW Regional 17 km SE of Snapper Level, TDS (Quarterly) Trelega Bore Regional 5 km SE of Snapper Level, TDS Chalky Well Regional 12 km NNW of Ginkgo Level, TDS Greenvale Well Regional 6 km NNE of Ginkgo Level, TDS Court Nareen Well Regional 13 km ENE of Ginkgo Level, TDS M27-2 Deep Regional Midway between Level, TDS Ginkgo and Chalky Well 39 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

48 South Tank Bore Regional 5 km NW of Snapper Level, TDS Bunnerungi Q Regional Bunnerungi Bridge, Silver City Highway Level, TDS (Quarterly) Coomba Q Regional Coomba Station, Silver City Highway Level, TDS(Quarterly) Karpa Kora Q Regional North East of Pooncarie Level, TDS(Quarterly) WCB04 Q Local Haul Road Level, TDS (Quarterly) WCB05 Q Local Haul Road Level, TDS (Quarterly) WCB06 Q Local Haul Road Level, TDS (Quarterly) Trigger levels for commencement of preventative action Groundwater monitoring data would be utilised to identify variances to anticipated impacts and thereby trigger investigations and/or remedial action. This proactive approach would exceed legislative compliance standards and conditions. The DWE will be contacted immediately if monitoring data indicates that trigger levels may be reached in the foreseeable future. A summary of the trigger levels are provided in Table GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

49 Table 6 Trigger levels for commencement of preventing action Borehole Well ID Initial Levels* 2005 Average Levels* Jan 2005-March 2011 Groundwater Trigger Level* Groundwater Quality Chalky Well 5.10 m 4.74 m 5.20 m TDS mg/l Greenvale Well 5.22 m 4.91 m 5.70 m N/A Trelega Bore^ m m m N/A GW36669^ m m m N/A Static depth below measuring point ^Reference point only (not pumped for water supply) The process for establishing the groundwater level trigger at Chalky Well and Greenvale Well is as follows: Confirm the top and bottom RL of the well screen Obtain available historic groundwater level data Measure the RL of the static water level. If a trigger level is reached, an investigation to assess whether the groundwater level decrease is attributable to the mine operations whilst incorporating seasonal (climatic) trends or other relevant variables (e.g. other groundwater users) would be undertaken. Should drawdown attributable to mining operations at Chalky Well or Greenvale Well significantly exceed the minor impacts anticipated during or immediately following mining operations, remedial actions would be triggered and appropriate remedial measures (developed in consultation with DPI Water formerly NOW and relevant landholders) would be implemented in order to allow groundwater levels to recover. The measurements at both Chalky Well and Greenvale Well are to be taken after 24 hrs from any pumping events for accurate measurements and to account for local redraw. The Salt Lake is a considerable distance from the Project area (located approximately 11.5 km south of Snapper). It would take a significant length of time to observe a change in groundwater levels or flow at the Salt Lake due to Project operations. Therefore, should drawdown at the Salt Lake significantly exceed the minor impacts anticipated during or following mining operations, appropriate remedial measures (developed in consultation with DPI Water and relevant landholders) would be implemented in order to allow groundwater levels to recover. Trelega Bore is located north of the Salt Lakes and south of the Snapper mine. The timeframe within which remedial measures would be implemented will be subject to trends established using monitoring data from observation bores. Groundwater level triggers (i.e. drop in groundwater level) for Trelega Bore and GW36669 are set at 50 cm and 150 cm respectively. If trigger levels are exceeded, an initial investigation would be conducted to assess whether the groundwater level decrease is attributable to the mining operations whilst incorporating seasonal (climatic) trends or other relevant variables (e.g. other groundwater users). In the event that the investigation concludes that the groundwater level drop is attributable to the mine operations, groundwater modelling predictions will be reviewed and impacts to the Salt Lake reassessed. Where necessary, remedial actions would be triggered (section 4.4.3) and appropriate measures implemented in consultation with DPI Water and relevant landholders. 41 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

50 Groundwater Quality Triggers Given the generally poor (i.e. saline) groundwater quality in the vicinity of the mine, remedial actions would only be undertaken should there be a significant change in baseline quality. As indicated in Table 6, groundwater withdrawn from Chalky Well is generally of better water quality (TDS mg/l) than surrounding groundwater bores. The source of groundwater at the stock watering point is considered to be a localised freshwater aquifer perched on the main saline aquifer (Golder, 2001). As a result, a groundwater quality trigger for total dissolved solids (TDS) at Chalky Well would be set at mg/l to meet the Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand (ANZECC & ARMCANZ, 2000) stock watering guideline level for sheep. If the trigger level for Chalky Well is exceeded, an initial investigation will be conducted to assess whether the change in groundwater quality is attributable to the mine operations whilst incorporating seasonal (climatic) trends or other relevant variables (e.g. other groundwater users). In the event that the investigation concludes that the change in groundwater quality is attributable to the mine operations, remedial actions would be triggered (section 4.4.3) and appropriate measures implemented in consultation with DPI Water and relevant landholders Groundwater remedial actions In the event that the mine adversely affects existing or licensed groundwater users, Cristal would initiate the provisions of this WMP and liaise with the users to provide a replacement water supply of similar quantity and quality to that affected, until such time as the development ceases to impact on the users water supply. Given the limited drawdown effects predicted and lack of operating bores within the drawdown area, no specific groundwater impact remedial measures are currently proposed. Should significant changes in groundwater levels and/or quality be identified and trigger remedial action, the appropriate measures identified by DPI Water (e.g. bore reconditioning, lowering) would be implemented to mitigate any impacts. In any impact mitigation process undertaken under this WMP, the quantity, quality and security of the water supplied as a result of that process is to be at least of the same standard as the water supplied from the bore before it was affected, or as otherwise agreed to by the landholder and Cristal. Prior to finalisation of any agreement with respect to any mitigation measures proposed, DPI Water would be consulted for compliance with its statutory and natural resource management responsibilities. 4.5 Reporting The effectiveness of the sediment and erosion control systems and water management and performance against objectives contained in this Water Management Plan will be documented and summarised in the AEMR (section 3.6.1). Any changes to groundwater composition attributed to leachate generated from the Gingko landfill will be reported to the EPA (in accordance with licence requirements) and Cristal will develop suitable contingency measures to address the identified impacts in accordance with section GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

51 5. References Bemax (2001a) Broken Hill Mineral Separation Plant New South Wales, Environmental Impact Assessment, Main Report and Appendices, prepared by Resource Strategies on behalf of Bemax Resources Pty Ltd, November Bemax (2001b) Ginkgo Mineral Sands Project, Environmental Impact Assessment, Main Report and Appendices, prepared by Resource Strategies on behalf of Bemax Resources Pty Ltd, September Bemax (2006) Snapper Mineral Sands Project Environmental Assessment, prepared by Resource Strategies on Behalf of Bemax Resources Pty Ltd, GHD (2016) Gingko Mine Site Landfill Construction Report, GHD Pty Ltd, 16 May 2016 GEOENG (2010) Section 75W Modification Snapper and Ginkgo Mines Hydrogeological Assessment Pooncarie NSW GEOENG (2010) Snapper Mine Tailings Stacking and Groundwater GEOENG (2009) Snapper and Gingko Mines Groundwater Balance Resource Strategies (2015) Ginkgo Mineral Sands Mine Waste Management Modification Environmental Assessment, August GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

52 Appendices

53 Appendix A - Figures 45 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

54 Figure 3 Snapper clearance schedule showing bore PW1 to be mined out in GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

55 Figure 4 Ginkgo Mine drainage structures 47 GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

56 Figure 5 Ginkgo Landfill (overflow containment area in event of heavy rain north of fence) GHD Report for Cristal Mining Australia Ltd - Murray Basin Mineral Sands Mines, 31/34336

57 608000E E E E E N Pole1 Pole2 Pole3 FlowDirection Pole4 Lowlyingareas Pole5 HMCTowerPos2 Highareas Pole6 Pole7 Pole8 Pole9 P40A P N BSL UHF17 Pole10 TF Pole11 P36A Pole12 P36B DustSuppression Dam Pole13 DredgePit Designv21 Pole14 TF Pole16 Pole N Pole20 Pole21 BSL GoLine Boundaryof ApprovedClearing Pole23 BH1 Pole24 Pole25 OP's Laydown Pole26 Yard Pole27 Pole N Pole29 Pole30 earthgrid Pole31 TF Pole32 Pole E E E Boundaryof ApprovedClearing Pole E E RehabilitationArea RehabilitationArea Title: EOMAugustMasterplan Project: DetailContourSurvey Scale Date: 09September2014 Scale: 1:5 VersionRevision: DesignedBy: T.Cross CheckedBy: Signature: Signature: FileLocation: P.Bekker Sheet: 1of1 Co-ordinatesSystem: MGA94(GDA94)Zone54,AHD ReferencePoint: GinkgoBaseE: N: H: Location: GinkgoMineSite,NobRoadviaWentworthNSW 2648 Meters MurrayBasinProjects SnapperMine 200 1:

58 Appendix B Design criteria Erosion and sediment control structures (e.g. sedimentation dams or other siltation control devices) will be constructed to contain or treat surface water runoff from all areas disturbed by mining including overburden dumps, topsoil stockpiles, unsealed roads and areas cleared of vegetation. General design criteria for the erosion and sediment control structures are presented in the following documents (or their current version): Managing Urban Stormwater: Soils and Construction, Volume 2E Mines and Quarries (NSW DECC 2008) Managing Urban Stormwater: Soils and Construction, Volume 1 (4 th Edition) (Landcom 2004b) Managing Urban Stormwater: Council Handbook, Draft (NSW EPA 1997) Design Manual for Soil Conservation Works Technical Handbook No. 5 (Soil Conservation Service of NSW 1986) Urban Erosion and Sediment Control Handbook, Hunt, NSW Department of Conservation and Land Management (J.S. ed, 1992) Australian Rainfall and Runoff, Institute of Engineers Australia, current version. Sedimentation dams will be designed: To provide, to the satisfaction of the DECC (formally DECCW), a minimum dam capacity appropriate to the area draining to each dam So that the maximum flow velocity through the dams meets DECC guidelines To prevent short circuiting If inflow is likely to contain oil or other deleterious floating matter, a baffle will be installed at the outlet to prevent discharge of that matter. Any perimeter bund will be designed for, amongst other things: Toe stability, forces from flooding, hydraulic pressures, seepage, attack from burrowing fauna and revegetation.

59 GHD 57 Orange Avenue Mildura, Victoria 3500 T: (03) F: (03) E: GHD 2016 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\34336\WP\ docx Document Status Revision Author Reviewer Approved for Issue Name Signature Name Signature Date E Jo Stephens Di Kovacs Di Kovacs 06/09/2016 F Jo Stephens Di Kovacs Di Kovacs 05/10/2016

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