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CHAPTER 1 - INTRODUCTION GULF ALUMINA LTD – SKARDON RIVER BAUXITE PROJECT

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Page 1: HAPTER 1 INTRODU TION - Metro Mining...HAPTER 1 - INTRODU TION GULF ALUMINA LTD – SKARDON RIVER AUXITE PROJE T Skardon River Bauxite Project Chapter 1 - Introduction Page 1-i Page

CHAPTER 1 - INTRODUCTION

GULF ALUMINA LTD – SKARDON RIVER BAUXITE PROJECT

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TABLE OF CONTENTS

1.1 Purpose .............................................................................................................1-1 1.2 Project Proponent ..............................................................................................1-1 1.3 Proponents Environmental Record and Environmental Policy ..............................1-1 1.4 Project Overview ................................................................................................1-2 1.5 Legislative Framework ........................................................................................1-2 1.6 Project Location and Mining Leases ....................................................................1-3 1.7 Project Description .............................................................................................1-6 1.8 Rehabilitation ....................................................................................................1-9 1.9 Social and Economic Benefits ..............................................................................1-9 1.10 Project Alternatives .......................................................................................... 1-10 1.11 Environmental Impact Assessment ................................................................... 1-11 1.12 Environmental Authority Process ...................................................................... 1-11 1.13 Assessment Methodology................................................................................. 1-12 1.14 Risk Based Assessment ..................................................................................... 1-12 1.15 Environmental Management ............................................................................ 1-16 1.15.1 Environmental Management Plan ........................................................................... 1-16 1.15.2 Monitoring and Measurement ................................................................................. 1-16 1.15.3 Records Management .............................................................................................. 1-16 1.15.4 Reporting, Corrective and Preventive Action ........................................................... 1-16 1.15.5 Audits ....................................................................................................................... 1-16 1.15.6 Management Review ............................................................................................... 1-17 1.16 EIS Document Structure .................................................................................... 1-17 1.17 Environmental Objectives and Performance Outcomes ..................................... 1-19

Tables

Table 1-1 Consequence of Impacts .......................................................................................... 1-13 Table 1-2 Risk Analysis Matrix (Consequence and Likelihood) ................................................ 1-15 Table 1-3 Chapters Structure ................................................................................................... 1-18 Table 1-4 Appendix List ............................................................................................................ 1-19 Table 1-5 Environmental Objectives and Performance Outcomes .......................................... 1-21

Figures

Figure 1-1 Regional Project Location ........................................................................................... 1-4 Figure 1-2 Project Area, Skardon River and Offshore Activity Areas and Cadastral

Boundaries ................................................................................................................. 1-5 Figure 1-3 Proposed Project Layout ............................................................................................ 1-8

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1. INTRODUCTION

1.1 Purpose

The purpose of this Environmental Impact Statement (EIS) document is to provide information to support the Skardon River Bauxite Project (the Project) environmental authority (EA) amendment application and Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) Referral.

The State and Commonwealth administering authorities must consider the environmental values of the area of the mining leases (MLs) and Project activities when it decides an application for an EA amendment in accordance with the Environmental Protection Act 1994 (EP Act) or a controlled action under the EPBC Act.

This document provides an assessment of the Project’s impact on the environmental values of the Project area and surrounds, including emissions and wastes from the Project. It assesses the risks to environmental values and proposes measures to mitigate impacts.

The EA process commenced on lodgement of the EA amendment application in March 2014. The Department of Environment and Heritage Protection (EHP) commence the decision stage for the grant of the EA once the EIS assessment report has been finalised. As the mining leases have already been granted, the EA will take effect on the day the EA is issued.

The approvals process for the Project is detailed in Chapter 2.

1.2 Project Proponent

The proponent, Gulf Alumina Ltd (Gulf Alumina) is a public company registered on 23 February 2004 in Sydney, NSW to explore and develop bauxite deposits in and around Australia. Gulf gained full ownership of the three Skardon River mining leases from ACC Ecominerals in January 2012. Gulf is currently the sole holder of the EA (EPML 00967013) for the Project’s three mining leases (MLs) - ML 40082, ML 40069 and ML 6025.

Gulf Alumina’s head office is located in Sydney at the following address:

Gulf Alumina Limited Suite 503, Level 5, 37 Bligh St, Sydney, NSW 2000 Telephone: (02) 9221 4689 Fax: (02) 9221 4686 Email: [email protected] Website address: www.gulfalumina.com.au ACN: 108 086 377

1.3 Proponents Environmental Record and Environmental Policy

The proponent has not been subject to proceedings under a law of the Commonwealth or State for the protection of the environment or the conservation and sustainable use of natural resources (and environmental law). Gulf Alumina’s environmental policy is provided in Appendix 11.

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1.4 Project Overview

The proposed Project involves mining of a bauxite ore body of 50 million tonnes (Mt). The planned mine production rate would initially be 3 million tonnes per annum (Mtpa) initially and would rise to 5 Mtpa subject to market conditions. The operational Project life is expected to be 10 years, with a construction period of approximately 1 year and post mining decommissioning and final rehabilitation period.

The total disturbance area for the bauxite mine across all three mining leases is approximately 1,453 ha - of which 138 ha has already been disturbed as part of the historical kaolin mining. Therefore the proposed bauxite mine will create an additional 1,315 ha of new disturbance.

Bauxite products would be transported via the existing and new haul roads to the Port of Skardon River and transhipped by barge to bulk carriers in deep water beyond the mouth of the river for export.

Construction is planned to commence in 2016 and bauxite mining and shipping would commence in 2017.

1.5 Legislative Framework

The existing mining leases are subject to an existing environmental authority (EA), number EPML 00967013 (formerly MIN104486212). This EA relates to mining of kaolin on the mining leases, which has ceased. On 20 January 2014, the Department of Natural Resources and Mines (DNRM) approved the existing mining leases to include mining bauxite. Gulf applied for an amendment for bauxite mining within the existing mining leases in March 2014 as the current EA only allows for mining kaolin and operating an associated kaolin plant. Environment and Heritage Protection (EHP) decided that the proposed amendment was a major amendment under sections 228 and 229 of the EP Act. On 19 May 2014, EHP notified Gulf that the amendment application required assessment by environmental impact statement (EIS).

In May 2015, Gulf proposed a change to the EA amendment application under Sections 236 – 238 of the EP Act to include additional bauxite resources. In May 2015, EHP determined that the proposed changes would be assessed as part of this EIS.

The proposed Project was referred on 14 August 2014 to the Commonwealth Department of the Environment (DoE) (EPBC 2014/7305). On 11 September 2014, the Minister for the Environment determined the proposed Project to be a controlled action under the Commonwealth EPBC Act. The controlling provisions are sections 18 and 18A (listed threatened species and communities), 20 and 20A (listed migratory species) and 23 and 24A (Commonwealth marine areas). On 18 February 2015 DoE approved an application to vary the original Referral to include resource extraction within ML 6025 south of Namaleta Creek. On 22 April 2015, DoE approved an application to vary the original Referral to increase the depth of bed levelling and the volume of material to be transferred by bed levelling.

Gulf submitted an Initial Advice Statement (IAS) and the draft Terms of Reference (ToR) for the Project’s EIS in September 2014. Following Gulf’s responses to the comments received on the draft ToR (under Section 45 of the EP Act), the final ToR was approved on 15 January 2015.

The Project will be assessed under the bilateral agreement between the Commonwealth and the State of Queensland using the EIS prepared under the EP Act.

The Project approvals process, including approvals required under other legislation, is described in Chapter 2.

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1.6 Project Location and Mining Leases

The Project will be located on Cape York Peninsula, approximately 90 km north of Weipa, in the Parish of Skardon within the Cook Shire. The regional Project location is shown in Figure 1-1. The relevant mining tenures are granted ML 6025 (1922ha), ML 40069 (260ha) and ML 40082 (1,743ha). The Port of Skardon River is within the Project’s mining leases. Some Project activities will occur outside of the mining leases such as barging of bauxite on the Skardon River and offshore transhipment.

The Project area (Project mining leases), Skardon River and offshore activity areas, and underlying and adjacent cadastral boundaries are shown in Figure 1-2. The lots intersected by the Project’s mining leases are owned by the Old Mapoon Aboriginal Corporation - Trustee for the benefit of Aboriginal people particularly concerned with the land and their ancestors and descendants, and under the Aboriginal Land Act 1991.

A detailed description of the Project location is provided in Chapter 4.

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G:\CLIENTS\E-TO-M\Gulf Alumina\GIS\Maps\EIS\Ch01_Intro\FIG_1_1_Project_Location_160311.mxd

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Date: 11/03/2016 Author: malcolm.nunn1:3,500,000Map Scale:

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Regional Project Location

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No warranty is given in relation to the data (including accuracy, reliability, completeness or suitability) and accept no liability (including without limitation, liability in negligence) for any loss, damage or costs (including consequential damage) relating to any use of or reliance upon the data. Data must not be used for direct marketing or be used in breach of privacy laws. Tenures © Geos Mining (2015). State Boundaries, Towns, Railways and Roads © Geoscience Australia (2015). Towns and LGA boundaries © State of Queensland (Department of Natural Resources and Mines) 2015.

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1.7 Project Description

A detailed description of the Project activities is provided in Chapter 5.

The Project involves the construction and operation of an open cut bauxite mine in Western Cape York Peninsula. The Project involves mining a bauxite ore body of around 50 million tonnes (Mt) and is anticipated to initially produce 3 million tons per annum (Mtpa) bauxite suitable as direct shipping ore (DSO), which is expected to rise to 5 Mtpa subject to market conditions.

The DSO bauxite mining method involves vegetation clearing and grubbing, harvesting topsoil and subsoil, mining bauxite, placing mined subsoil on mined pit floor, placing harvested topsoil on subsoil and rehabilitating mined areas. The bauxite within the mining leases is less than 3 m thick, with an average DSO thickness of 1.7 m, and does not extend more than 6 m below the surface. Conventional open cut mining will be carried out after removing the topsoil and subsoil. Mining will occur 24 hours per day, 7 days per week. Mining of DSO bauxite is planned to occur during the dry season with shut down during heavy rain periods of the wet season, approximately 3 months from January to March.

DSO does not require beneficiation of the bauxite and hence beneficiation and associated tailings management are not part of the Project. The option for DSO bauxite therefore results in lower environmental impact than beneficiation of bauxite by avoiding tailings management and associated additional water and energy requirements.

The bauxite ore will be mined and transported via existing, upgraded haul roads to a crushing and stock pile facility at the Port of Skardon River. The bauxite product will be barged to bulk carrier vessels in deep water approximately 15 km beyond the mouth of the river for export. Construction is planned to commence in 2016 with bauxite mining and shipping in 2017 after the wet season period. For the purpose of feasibility study mine planning, it is assumed that mining commences in April 2017.

Life of Project activities and infrastructure that form part of the EIS assessment for the Project include:

A new wharf / barge loading facility within the Project’s existing mining leases and the gazetted Port

of Skardon River, constructed using piles and dolphins.

Barging of bauxite to the offshore transhipment location in deep water approximately 15 km

offshore from the Skardon River mouth, and transfer from barges to bulk carriers.

Bulk carrier movements with Australian waters.

Bed-levelling at the mouth of Skardon River to a depth of approximately 2.2 m below lowest

astronomical tide (LAT). Bed levelling would involve underwater reprofiling of shallow areas at the

seaward extent of the Skardon River mouth by pushing the crests of sand banks into deeper gutters.

No dredging is proposed; however, annual maintenance bed levelling is likely to be required.

Upgrade of the existing boat ramp and jetty infrastructure at the Port to improve access for vessel

supply of fuel, consumables, materials and site equipment.

New bauxite ore dump facility, crushers, conveyor belt system and bauxite product stockpile facility,

all adjacent to the Port of Skardon River landing.

New workshop, warehouse, administration and crib room at the Port of Skardon River.

Upgrade of the existing bulk fuel storage, new fuel transfer pipeline, diesel transfer tanks and export

waste storage at the Port of Skardon River.

Use of existing landfill and a new landfill with leachate management, for limited waste disposal.

Upgrade of the existing 15 km north-south haul road from the Port to the former wet plant area; a

new haul road system surrounding the kaolin mine overburden piles, upgrade of the crossing of

Namaleta Creek and an additional 1.5 km of haul roads south of Namaleta Creek.

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Temporary branch haul roads would be used to link with the existing haul road.

Upgrade of the existing accommodation camp from 50 beds to 150 beds for the construction

workforce and maintained for mining operation, and upgrade of the sewage treatment system.

Use of the existing airstrip and relocated airstrip later in mine life, primarily for transport of workers.

A process water pumping station at the existing kaolin mine water storage pits with existing pipeline

to transfer water to water storage tanks at the Port of Skardon River. This pipeline will run adjacent

to the existing north- south haul road.

Installation of a new sediment pond, and retention of the existing sediment pond for stormwater

run-off from infrastructure and stockpile areas at the Port of Skardon River.

Power will be supplied by three 1MW generators fitted on semi-trucks.

The proposed Project layout, with all mining areas and the Port infrastructure area is shown in Figure 1-3.

Water supply and mine site water management is described in Chapter 6. The annual water requirements for dust suppression, watering haul roads and plant and equipment washdown would be sourced from the existing kaolin mine water storages and shallow groundwater aquifers.

The offshore transhipment would occur in a defined area where bulk carriers (e.g. Panamax ships) will anchor. Barges will anchor adjacent to the bulk carriers for loading of bauxite ore.

Two barges, with a capacity of about 4,000 to 7,000 t per barge, will transfer bauxite ore to the bulk carriers, which will have an approximate capacity of 75,000 deadweight tonnes (dwt). Barges would work 24 hours (although crossing of the Skardon River mouth would be limited to approximately 18 hours of the day to avoid low tide), 7 days a week with a loading rate up to 2,000 tonnes/hour, for approximately 40 weeks per annum (i.e. excluding the wet season). At a bauxite production rate of 5 Mtpa, this will result in approximately 1.5 bulk carrier shipping movements per week, or 65 to 70 bulk vessel movements per annum.

It is expected that an average of 100 people will need to be accommodated during the bauxite infrastructure construction period of 30 weeks with a maximum workforce of 120 people. The Project would require approximately 160 employees during operation. Employees will be on a shift roster and hence not all employees will be at site at any one time. Employees would be accommodated in the upgraded accommodation camp during the construction and the mining operation phases. The Project workforce will be transported to the site by air and will be accommodated in camp on the Project area. The workforce will be 100% fly in fly out (FIFO), including from nearby areas such as Weipa and Mapoon, as it is not practical for the workforce to access the Project by road.

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LegendMining Lease Boundaries

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No warranty is given in relation to the data (including accuracy, reliability, completeness or suitability) and accept no liability (including without limitation, liability in negligence) for any loss, damage or costs (including consequential damage) relating to any use of or reliance upon the data. Data must not be used for direct marketing or be used in breach of privacy laws. Imagery sourced from Gulf Alumina (2014). Tenures © Geos Mining (2015). State Boundaries and Towns © Geoscience Australia (2006).

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*Port/Wharf infrastructure are indicative layouts only and adapted from plans created by Sedgman Ltd.*Haul Road/Crossing layouts are indicative only and based on centrelines in plans created by Sedgman Ltd.

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1.8 Rehabilitation

Project rehabilitation and decommissioning is detailed in Chapter 7.

A Rehabilitation Management Plan (RMP) will be developed to ensure that land disturbed by mining operations is effectively rehabilitated such that:

the agreed post-mining land use (native vegetation, except for infrastructure retained for

Traditional Owners) is achieved

the site is stable, non-polluting and safe to humans and animals

stable environmental conditions are established which are able to be sustained

all relevant statutory requirements are complied with.

Progressive rehabilitation will occur throughout the life of the Project. Decommissioning and final rehabilitation of areas used for mining will be outlined in a Mine Closure Plan (MCP) and specific rehabilitation completion criteria, indicators and monitoring methods, will be provided in the RMP.

On the completion of mining, the following treatments will be undertaken:

Infrastructure will be removed and dismantled where required unless the landholder (Traditional

Owners) requests otherwise.

Vegetation cover will be restored and land will be returned to its agreed post-mining land use.

Erosion and sediment control structures will be constructed to maintain topsoil cover, landform

stability and prevent sedimentation of waterways.

Contaminated land will be remediated and assessed for any potential future contamination issues.

1.9 Social and Economic Benefits

The social and economic benefits and impacts of the Project are described in Chapter 25. In summary:

Capital expenditure of approximately $61 million will be invested into the economy.

Operational expenditure of approximately $134 million per annum will be invested into the

economy.

Approximately 160 direct jobs and many more indirect jobs will be created during operations.

Approximately 100 direct jobs and many more indirect jobs will be created during construction.

Royalties of approximately $325 million over the life of the Project will be generated.

Taxes of approximately $434 million over the life of the Project will be generated.

Indigenous groups will receive benefits under the current traditional owner agreement.

Indigenous landowners will receive a share of mining lease royalty payments.

The Port of Skardon River (as operated by Ports North) will be further developed.

Infrastructure (airstrip, accommodation, dams, roads and Port) will be upgraded or developed. In

agreement with the landowners (traditional owners), these may be retained to improve the

functionality of the land.

Commitments by the proponent to assist with land management type activities (e.g. weed and pest

management and fire management) will be implemented.

Economic stimulation generated as a result of wages and additional demand for goods and services is expected to have beneficial effects at the local level. Revenue generated for the state and federal

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government in the form of taxes and royalties will assist in the funding of a wide range of services to the benefit of the community. The Project is expected to have a beneficial impact on Indigenous people residing in the local area and Cape York region through the provision of increased business opportunities, employment, education and training opportunities.

1.10 Project Alternatives

Project alternatives are considered in terms of location of activities, design of infrastructure and types of activities proposed.

The location of mining is dictated by the location of the bauxite resource. However where the bauxite resource encroaches on sensitive areas (e.g. low lying areas such as wetlands or tidal areas) buffer areas have been proposed that will limit encroachment. Bauxite mining is proposed using conventional open cut methods, with various options for the type of excavation and haulage equipment.

The proponent has elected to direct ship ore. This means that no beneficiation of the bauxite ore and resulting tailings management is required. As a consequence significantly less water is required for the Project, thereby minimising impacts on water sources, and there are no impacts associated with tailings management.

The proponent has taken advantage of existing infrastructure in the Project area, associated with the former kaolin mine, to minimise the Project disturbance area. This includes using the existing Port area, airstrip, camp and haul roads. Two options were considered for the haul road crossing of Namaleta Creek. The preferred option involves upgrading the existing crossing of Namaleta Creek. The second option involved extending the haul road along the eastern and southern boundary of the mining leases, with a crossing of Namaleta Creek upriver from the existing crossing. The preferred option was selected as it minimises the ecological and hydrological impacts in comparison to the second option, minimises haul distance and potentially improves hydrological flows compared to the current crossing design.

The Project area is located in a remote area that is not feasibly accessible by public road by the workforce or for the supply of equipment, fuels and material. Therefore, the proponent intends to transport workers by air, and equipment, fuels and material by sea. No off tenement road upgrades are proposed, thereby avoiding disturbance activities off tenement.

The options considered for water supply to the Project have focussed on supply from existing dams associated with the former kaolin mine and, when required, extraction from shallow aquifers. This avoids the need to construct additional surface water collection dams or target water from deep aquifers associated with the Great Artesian Basin, thereby minimising hydrological impacts from sourcing water for the Project.

The Port of Skardon River (and its associated disturbance area and infrastructure) already exists and hence the proposal to upgrade the infrastructure at the Port for the Project will result in the least amount of additional impact. Various options were considered for the exact location of additional or upgraded Port infrastructure, but these are all centred on the existing Port location. The wharf upgrade at the Port will be designed and located to avoid the need for dredging, thereby minimising impacts on the marine environment. The wharf construction method (piles and dolphins) minimises impacts to the marine environment in comparison to other construction methods.

Due to the shallow depth of the mouth of the Skardon River, some bed levelling is required so that barge movements between the Port and the offshore transhipment area are economic. Having barges with a draft shallow enough to cross the mouth of the Skardon River would result in inefficiencies and increased vessel movements. In order to minimise impacts, dredging, involving removal, transport and disposal of subsurface materials at an alternative location, is not proposed. The proponent has balanced the minimum depth of bed levelling required with the need to operate barges efficiently. An assessment of the operability and environmental impacts of bed levelling compared to dredging has been

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undertaken (refer to Chapter 17) which identifies that bed levelling and dredging options are feasible although there are potential operability issues as a trailer suction hopper dredger will likely have to combine with a bed leveller and a cutter suction dredger requires stable sea conditions. Neither bed levelling or dredging are expected to have a significant impact on the environment. Bed levelling is expected to result in similar, or lesser, environmental impacts than dredging due to lower suspended sediment concentrations and smaller plume extent during the activity. Bed levelling is the preferred option and has been assessed.

In order to minimise the offshore transhipment impact, no fixed infrastructure is proposed offshore, other than cyclone moorings.

Should the Project not proceed, the economic and social benefits summarised in Section 1.9 and Chapter 25 will not be realised. This EIS describes the potential social, economic and environmental impacts of the Project and measures to manage and mitigate those impacts. On balance the socio-economic benefits of the Project outweigh the residual social, economic and environmental impacts of the Project.

1.11 Environmental Impact Assessment

The purposes of an environmental impact assessment and production of an EIS, as addressed in this EIS are as follows:

to assess the potential adverse and beneficial environmental, economic and social impacts of the

Project; and management, monitoring, planning and other measures proposed to minimise any

adverse environmental impacts of the Project

to consider feasible alternative ways to carry out the Project

to give enough information about the above matters to the Commonwealth and State authorities

and the public

to prepare or propose environmental management plans for the Project to inform the

environmental authority application

to give information to other Commonwealth and State authorities to help them make informed

decisions

to meet any assessment requirements under the EPBC Act as the Project is a controlled action under

a bilateral agreement

to allow the State to meet its obligations under a bilateral agreement.

1.12 Environmental Authority Process

The EA process commenced on lodgement of the EA amendment application. EHP will commence the decision stage for the grant of the EA once the EIS assessment report has been finalised.

As the mining leases are granted, the EA will take effect on the day the EA is issued.

Chapter 4 of the EP Regulation prescribes the regulatory requirements with which the administering authority is required to comply for making environmental management decisions — including the issuing of an EA. To facilitate this, EHP has developed a set of model conditions for resource projects, which form the basis for proposed EA conditions and general environmental protection commitments in the EIS. The EIS describes impact mitigation measures in the context of these model conditions.

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Environmentally relevant activities (ERAs) are prescribed activities for which approval is required. The ERAs potentially triggered by the Project are described in Chapter 2. Under Schedule 2A of the EP Act, the Project is for ‘mining bauxite’ which has an aggregate environmental score (AES) of 97.

1.13 Assessment Methodology

The methods used to obtain and present the information in this EIS include:

desktop review of regulatory requirements and relevant government policies and guidelines

desktop review of available data from local, state and federal government data sets (including EIS

material from nearby mine projects)

baseline environmental studies, including fieldwork (undertaken as denoted in chapters)

identification and assessment of potential impacts requiring assessment through specialist studies

including baseline studies

community consultation

compilation of relevant information in the EIS documents.

The impact assessment examines the existing environmental values of the Project area for each element of assessment and then determines the potential impacts associated with the Project’s construction, operation, decommissioning and rehabilitation phases. Where required, baseline studies were undertaken to establish environmental values.

1.14 Risk Based Assessment

A risk framework has been adopted to assess the risk to the environment, people, land use / property and the community from Project activities. The risk framework combines the consequence and likelihood of a particular impact, after consideration of proposed mitigation measures (i.e. residual risk), and assigns a risk level of low, medium, high or extreme.

The consequence (incorporating duration, magnitude and intensity) of the impacts to the environment, people, land use / property and the community is described in Table 1-1 for consequences that are insignificant, minor, moderate, major and severe. Consequence is considered in relation to the existing environmental conditions and sensitivity of the value, receptor or resource.

Table 1-2 describes the likelihood of a particular impact and combines this with consequence to determine a risk ranking.

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Table 1-1 Consequence of Impacts

Type of Loss Consequence

1 (Insignificant) 2 (Minor) 3 (Moderate) 4 (Major) 5 (Severe)

Impact to People

Minor injury.

Slight negative impact on individual health.

Significant reportable injury

Major impact on health of several people.

Major injury to one or more persons.

Severe health impacts on a number of people.

Single fatality

Severe irreversible disability or impairment.

Multiple fatalities.

Major permanent negative health impacts on a large number of people

Impact to Property / Land Use

Could cause minor damage <$10K

Could cause moderate damage $10K to $100K

Could cause major damage $100K to $1M

Could cause severe damage $1M to $10M

Unplanned mine closure damage >$10M

<1% of property directly impacted

1 – 5 % of property directly impacted

5 - 20% of property directly impacted

20 - 50% of property directly impacted

>50% of property directly impacted

Insignificant change to water availability

Minor, temporary change to water availability with alternative supplies readily available

Major, temporary change to water availability with alternative supplies available

Severe, long term change to water availability with alternative supplies difficult to obtain

Permanent change to water availability, no alternative supplies

Insignificant indirect impacts, land productivity unchanged

Moderate indirect impacts with isolated changes to land productivity, easily mitigated

Moderate indirect impacts with broad changes to land productivity, requiring standard mitigations

Severe indirect impacts with large scale changes to land productivity, requiring complex mitigations

Catastrophic indirect impacts with permanent changes to land productivity that cannot be mitigated

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Type of Loss Consequence

1 (Insignificant) 2 (Minor) 3 (Moderate) 4 (Major) 5 (Severe)

Impact to Environment

Negligible reversible environmental impact requiring very minor or no remediation. Alteration or disturbance to ecosystem within natural variability.

Minor reversible environmental impact requiring minor remediation. Measurable changes to ecosystem components.

May result in small decreases to a local population that would be resolved without further mitigation. Any population changes resulting from minor impacts would fall within natural fluctuations of a local population, that is, within the normal carrying capacity of the area.

Moderate reversible environmental impact with short term effect requiring moderate remediation. Measurable changes to ecosystem components without major change in function. Recovery in 1 - 2 years following the event.

May result in a substantial change to a local population, which would not lead to extinction at any level.

Major environmental impact with medium term effect requiring significant remediation. Measurable changes to ecosystem components with major change in function. Recovery in 3 - 10 years following the event.

May be detrimental or to the species or community at a population scale. High negative impacts may result in local extinction or declines and a consequent substantial decrease in abundance and population viability at larger scales. High negative impacts may also be qualified by the conservation status of the value being affected.

Extreme environmental impact with long term effect requiring major remediation regulatory intervention or premature closure of the operation. Long term and possibly irreversible damage to 1 or more ecosystem functions. Recovery, if at all, >10 years following the event.

Would result in the regional extinction of a species or community or in catastrophic declines and a consequent substantial decrease in abundance and population viability at the National or State scale.

Impact to Community

Slight negative

impact on

individuals in local

community.

Flare up of issues in

affected communities.

Media criticism.

Significant public

criticism, e.g.

community complaints.

Media or NGO ‘take up

the issue’.

Major negative impact

on economic viability.

Loss of community’s

economic viability. Significant

damage to reputation of the

operations.

Public international

condemnation. Major

breakdown of social order

in affected community.

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Table 1-2 Risk Analysis Matrix (Consequence and Likelihood)

Consequence

Type of Loss 1 (Insignificant)

2 (Minor)

3 (Moderate)

4 (Major)

5 (Severe)

Like

liho

od

A

(Almost Certain)

The event has occurred frequently: occurs one or more times per year and is likely to re-occur within 1 year

>90% chance

Medium (M) High (H) H Extreme (E)

E

B

(Likely)

The event has occurred but is not frequent: occurs less than once per year and is likely to re-occur within 5 years

50-90% chance

M M H H E

C

(Possible)

The event has happened in the business in the past 10 years or could happen within the next 10 years

30-50% chance

Low (L) M H H H

D

(Unlikely)

The event has happened in the business in the past 20 years or could happen within the next 20 years

10-30% chance

L L M M H

E

(Rare)

The event has never been known to occur in the business and it is highly unlikely that it will occur within less than the next 20 years

<10% chance

L L M M M

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1.15 Environmental Management

1.15.1 Environmental Management Plan

Gulf Alumina has prepared an environmental management plan (EM Plan) for the Project based on the information provided in this EIS, which is provided in Appendix 13. The EIS covers all aspects of environmental management for the Skardon River Bauxite Project, as required by the Project’s ToR.

Gulf Alumina manages the decommissioned kaolin mine (in care and maintenance) under a Plan of Operations and Rehabilitation Plan, with the current plan covering the period from February 2016 to February 2017. Financial assurance has been provided to the State, based on the expected rehabilitation of the kaolin mine. Much of the infrastructure (e.g. wet plant) has been decommissioned and removed from the site. In addition, the existing EA for the mining leases conditions environmental management of the kaolin mine whilst in care and maintenance.

The EM Plan and Chapter 7 covers the proposed Project and rehabilitation of the decommissioned kaolin mine that formerly operated on the Project’s mining leases (MLs), previously owned and operated by ACC Ecominerals and Skardon River Kaolin (SRK). The EM Plan provides the framework for environmental management of kaolin mine and Project activities during construction and operation. Where required, plans for environmental management during construction and operation activities will be developed prior to those activities commencing, and will be based on the EM Plan. A Construction Environmental Management Plan will be developed 3 months prior to commencement of construction activities. An Operations Environmental Management Plan will be developed 3 months prior to commencement of mining activities.

1.15.2 Monitoring and Measurement

The proposed monitoring plan for each environmental value is contained within the chapters of this EIS. Environmental monitoring will address meeting any EA conditions and environmental legal obligations, implementation of the operational controls developed, as well as progress towards objectives and targets. Monitoring plans have and will be developed that outline the environmental monitoring to be undertaken, including monitoring sites, parameters, frequency, procedures or methods, and records to be kept. Monitoring records will be kept and results reviewed on an as required basis to determine ongoing compliance.

1.15.3 Records Management

Records will be kept to demonstrate compliance with the EA and other identified environmental legal obligations.

1.15.4 Reporting, Corrective and Preventive Action

Statutory reporting requirements will be identified as part of the environmental legal obligations and undertaken as per the reporting requirements. To ensure continual improvement, any non-conformance with the EA conditions will be investigated and reported as per the EA requirements, including corrective and/or preventative actions. Where identified, amendments will be made to environmental management plans, EA or operational procedures or plans, based on the outcomes of investigations.

1.15.5 Audits

An audit schedule will be developed to ensure the effective implementation of environmental management and compliance with the EA and other legal obligations. Internal audits will be conducted at regular intervals to cover the scope of all environmental requirements and will be planned based on environmental risk and previous performance.

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1.15.6 Management Review

A management review will occur on an annual basis to determine the suitability, adequacy and effectiveness of environmental management. Audit results, evaluations of environmental legal compliance and compliance with the environmental objectives will be taken into consideration. The output of the management review will include changes to environmental objectives and targets and the environmental policy consistent with the commitment to continual improvement.

1.16 EIS Document Structure

The structure of this EIS is provided in Table 1-3 and Table 1-4 below comprising:

chapters describing the approvals process, the Project and, for each identified environmental

aspect, the environmental values, potential impacts, risk assessment and mitigation measures

appendices supporting the chapters, including management plans, draft environmental authority

conditions (as proposed by the proponent) and specialist technical reports on identified

environmental aspects.

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Table 1-3 Chapters Structure

Chapter Chapter Title

Executive Summary

1 Introduction

2 Approvals

3 Public Consultation

4 Location

5 Construction and Operations

6 Water Management

7 Rehabilitation and Decommissioning

8 Non-mining Waste

9 Climate

10 Geology, Topography and Soils

11 Land Use and Land Contamination

12 Water Values and Quality

13 Hydrology and Hydrogeology

14 Flooding

15 Terrestrial Ecology

16 Aquatic Ecology

17 Coastal Processes

18 Marine Ecology

19 Air Quality and Greenhouse Gas

20 Noise and Vibration

21 Landscape and Visual Amenity

22 Transport and Maritime Operations

23 Hazards and Safety

24 Cultural Heritage

25 Social and Economic Impacts

26 Matters of National Environmental Significance

27 References

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Table 1-4 Appendix List

Appendix Appendix Name

1 Commitments Register

2 Acronyms and Abbreviations

3 Terms of Reference cross-reference table

4 Water Management

5 Terrestrial Ecology

6 Aquatic Ecology

7 Stygofauna

8 Marine Ecology and Coastal Processes

9 Air Quality

10 Noise and Vibration

11 Gulf Alumina Ltd Environmental Policy

12 EPBC Act Protected Matters Search

13 Environmental Management Plan

14 Draft Environmental Authority Conditions

15 Surface Water and Groundwater Monitoring Plan

16 Vegetation and Aquatic Ecology Monitoring Plan

17 Coastal Processes Supplementary Report

1.17 Environmental Objectives and Performance Outcomes

As stated in Schedule 5 of the Environmental Protection Regulations 2008 (EP Regulation), in assessing whether an application achieves the relevant environmental objective the assessor is satisfied if the activity the subject of the application achieves—

(a) item 1 of the performance outcome for the relevant environmental objective; or

(b) item 2 of the performance outcomes for the relevant environmental objective.

In developing the environmental objectives and performance outcomes for the Project, Gulf Alumina does not consider that the performance outcomes for item 1 of the relevant environmental objective to be achievable as they effectively require no impact and no change in environmental values. Hence Gulf Alumina has adopted the performance outcomes for item 2 for each environmental objective. The only exception to this is for ‘Waste’ where the performance outcomes for item 1 have been adopted.

Table 1-5 demonstrates that all environmental objectives and performance outcomes from the EP Regulation have been adopted by Gulf Alumina. Gulf Alumina has proposed additional environmental objectives and performance outcomes to those in the EP Regulation in order to provide a comprehensive set of environmental objectives and performance outcomes for the Project. These additional environmental objectives and performance outcomes are identified in Table 1-5 using the notation ‘Gulf’ rather than a ‘ ’ for environmental objectives and performance outcomes provided in the EP Regulation.

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Table 1-5 provides the EIS chapter and section of the EM Plan where each of the environmental objectives and performance outcomes has been adopted. Due to the structure of the EIS chapters and EM Plan sections it is not practical to follow the exact order in which environmental objectives and performance outcomes are listed in the EP Regulation. Therefore Table 1-5 has been included in Chapter 1 of the EIS to demonstrate that all environmental objectives and performance outcomes have been considered in the EIS chapters and EM Plan.

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Table 1-5 Environmental Objectives and Performance Outcomes

Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

Air

Environmental Objectives

The activity will be operated in a way that protects the environmental values of air. 19 18

Performance Outcomes

Fugitive emissions of contaminants from storage, handling and processing of materials and transporting materials within the site are prevented or minimised.

19 18

Contingency measures will prevent or minimise adverse effects on the environment from unplanned emissions and shut down and start up emissions of contaminants to air.

19 18

Releases of contaminants to the atmosphere for dispersion will be managed to prevent or minimise adverse effects on environmental values.

19 18

No complaints about dust or odour from the Project. Gulf 19 18

Water

Environmental Objectives

The activity will be operated in a way that protects environmental values of waters. 6, 8, 10, 11, 12, 13, 14, 16

6, 7, 8, 9, 13, 15

The activity will be operated in a way that protects environmental values of marine waters. Gulf 17 14

The activity is operated in a way that protects the environmental values of marine sediments. Gulf 17, 22 14

The activity is operated in a way that protects the environmental values of marine flora and fauna. Gulf 18 16

Minimise direct and indirect impacts on marine fauna and flora. Gulf 18 16

Biodiversity offsets are provided for significant residual impacts on marine fauna and flora. Gulf 18 16

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

To prevent or reduce the risk of release of introduced marine organisms into the marine environment from shipping traffic generated by the Project.

Gulf 22 17

Performance Outcomes

The storage and handling of contaminants will include effective means of secondary containment to prevent or minimise releases to the environment from spillage or leaks.

8, 11 9

Storage and handling of potential contaminants will minimise release to the marine environment. Gulf 17, 22 14

Contingency measures will prevent or minimise adverse effects on the environment due to unplanned releases or discharges of contaminants to water.

6, 8, 11, 12, 14

7, 8, 9

Contingency measures will prevent or minimise adverse effects on marine water quality or sediment quality due to unplanned releases of contaminants to the marine environment.

Gulf 17, 22 14

The activity will be managed so that stormwater contaminated by the activity that may cause an adverse effect on an environmental value will not leave the site without prior treatment.

6, 12 7

The disturbance of any acid sulphate soil, or potential acid sulphate soil, will be managed to prevent or minimise adverse effects on environmental values.

10, 17 6, 14, 15

Acid producing rock, if any, will be managed to ensure that production and release of acidic waste is prevented or minimised, including impacts during operation and after the environmental authority has been surrendered.

10 6

Any discharge to water or a watercourse or wetland will be managed so that there will be no adverse effects due to the altering of existing flow regimes for water or a watercourse or wetland.

6, 12, 13, 16 7, 13

Any discharge to marine waters will be managed so that there will be no adverse effects due to the altering of existing flow regimes for marine waters.

Gulf 17, 22 14

For a petroleum activity, the activity will be managed in a way that is consistent with the coal seam gas water management policy, including the prioritisation hierarchy for managing and using coal seam gas water and the prioritisation hierarchy for managing saline waste.

n/a – the Project is not a petroleum activity

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

The activity will be managed so that adverse effects on environmental values are prevented or minimised. 6, 12, 13 7

Any changes in the hydrology of wetlands or watercourses as a result of mining activities will be prevented or minimised.

Gulf 13, 16 7, 13

Activities that disturb marine sediments will be managed in a way that prevents or minimises adverse effects on environmental values.

Gulf 17, 22 14

Prevent or minimise the release of ship-sourced pollutants. Gulf 17 14

Implement emergency response plans for any hydrocarbon contaminant release. Gulf 17 14

Prevent mortality or permanent hearing damage to marine megafauna, and mitigate temporary hearing loss and behavioural modifications by maintaining exclusion zones around piling operations.

Gulf 18 16

Conduct operations so that seagrass meadows remain viable within the Project area. Gulf 18 16

Prevent establishment of marine pest species. Gulf 18 16

Minimise the incidence of vessel strike and minimise light spill. Gulf 18, 22 16

Biodiversity offset plans will be developed for any significant residual impacts on marine fauna and flora in accordance with relevant Commonwealth and State policies.

Gulf 18 16

Management measures are implemented to avoid or limit releases of exotic organisms into the marine environment to the greatest extent practicable.

Gulf 22 17

Wetlands

Environmental Objectives

The activity will be operated in a way that protects the environmental values of wetlands. 6, 12, 13 7

The activity will be operated in a way that protects the environmental values of wetlands and associated flora and fauna.

Gulf 16 13

Minimise direct and indirect impacts on fauna and flora. Gulf 16 13

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

Biodiversity offsets are provided for significant residual impacts on fauna and flora. Gulf 16 13

Performance Outcomes

The activity will be managed in a way that prevents or minimises adverse effects on wetlands. 6, 12, 13, 16 7, 13

Biodiversity offset plans will be developed for any significant residual impacts on fauna and flora in accordance with relevant Commonwealth and State policies.

Gulf 16 13

Buffer zones are created around sensitive ecological areas (i.e. wetlands and watercourses) where mining activities are restricted.

Gulf 16 13

Areas of connectivity between mining areas, including wetlands and watercourses are retained. Gulf 16 13

Weeds and pests are managed to prevent increase in abundance or diversity. Gulf 16 13

Groundwater

Environmental Objectives

The activity will be operated in a way that protects the environmental values of groundwater and any associated surface ecological systems.

6, 8, 11, 12, 13, 16 7, 9, 13

Performance Outcomes

The activity will be managed to prevent or minimise adverse effects on groundwater or any associated surface ecological systems.

6, 8, 11, 12, 13, 16 7, 9, 13

Noise

Environmental Objectives

The activity will be operated in a way that protects the environmental values of the acoustic environment. 20 19

Performance Outcomes

The release of sound to the environment from the activity is managed so that adverse effects on environmental values including health and wellbeing of sensitive receptors are prevented or minimised.

20 19

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

Project noise emissions comply with the proposed noise criteria at sensitive receptors during all phases of the Project.

Gulf 20 19

No complaints about noise or vibration from the Project. Gulf 20 19

Waste

Environmental Objectives

Any waste generated, transported, or received as part of carrying out the activity is managed in a way that protects all environmental values.

8, 11, 22, 23 9

To reduce the potential for prohibited releases of ballast water to occur. Gulf 22 17

To reduce the potential for environmental harm to marine environments, as a result of release from shipping, through implementation of appropriate contingency measures.

Gulf 22 17

To emolliate the impacts of any unauthorised ballast water release. Gulf 22 17

To prevent or reduce the release of shipping waste from Project shipping traffic into the marine environment. Gulf 22 17

To reduce spill of any substance into the marine environment from shipping traffic. Gulf 22 17

Prevent impacts to the marine environment as a result of pollution from shipping. Gulf 22 17

Identify potential hazards to people and property from abnormal hazardous events and conditions. Gulf 23 21

Determine the residual risk levels (i.e. risks after proposed mitigations measures) and propose new risk treatment measures if risk are not tolerable.

Gulf 23 21

Performance Outcomes

Waste generated, transported or received is managed in accordance with the waste and resource management hierarchy in the Waste Reduction and Recycling Act 2011.

8, 11 9

If waste is disposed of, it is disposed of in a way that prevents or minimises adverse effects on environmental values.

8, 11 9

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

No contamination of land or waters from waste management beyond the footprint of waste management facilities.

Gulf 8, 11, 22, 23 9

If land or groundwater contamination as a result of waste management activities has occurred, an investigation will be undertaken, with management or remediation as required. This may involve engaging a suitably qualified person approved by DEHP as a contaminated land specialist, where required, and will fully depend on the nature and extent of contamination.

Gulf 8, 11, 22, 23 9

Waste monitoring data demonstrates reduction in waste produced (per tonne of production). Gulf 8, 11, 22 9

Adherence to waste management plan indicating minimisation of waste generated, maximise reuse and recycling, and the safe treatment and disposal of all non-reusable and non-recyclable materials in compliance with legislation.

Gulf 8, 11, 22 9

No incidents of environmental harm involving ballast water releases. Gulf 22 17

Waste releases into the marine environment are in accordance with relevant laws and standards. Gulf 22 17

No complaints from public or government agencies regarding noticeable waste or spills, as a result of shipping activities.

Gulf 22 17

Accidental releases of any substance into the marine environment are avoided or promptly managed to avoid material impacts.

Gulf 22 17

Pollution as a result of Project related shipping activities are avoided or managed in accordance with relevant legislation and guidelines.

Gulf 22 17

Following risk treatment measures, there are no residual risks which are determined as high or extreme and all other risks are as low as reasonably practicable (ALARP).

Gulf 23 21

Prepare a Risk Management Plan and Emergency Management Plan. Gulf 23 21

Land

Environmental Objectives

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

The activity will be operated in a way that protects environmental values of land including soils, subsoils, landforms and associated flora and fauna.

7, 8, 10, 11 6, 9, 10, 11, 12

Salvage soils resources for use in progressive rehabilitation. Gulf 10 6

Minimise impacts to the quality of soils, including soils to be used in rehabilitation. Gulf 10 6

Minimise soil stockpiling duration and volume. Gulf 10 6

Minimise direct and indirect impacts on fauna and flora. Gulf 15 12

Progressively rehabilitate of mined areas with native vegetation. Gulf 15 12

Biodiversity offsets are provided for significant residual impacts on fauna and flora. Gulf 15 12

The activity is operated in a way that protects the landscape character of the area. Gulf 21 20

Allow for ongoing land use following final rehabilitation and decommissioning. Gulf 11 5

Minimise the extent and degree of disturbance on land as mining is occurring. Gulf 11 5

Performance Outcomes

Activities that disturb land, soils, subsoils and landforms will be managed in a way that prevents or minimises adverse effects on the environmental values of land.

10, 15 6, 12

Areas disturbed will be rehabilitated or restored to achieve sites that are—

(i) safe to humans and wildlife; and

(ii) non-polluting; and

(iii) stable; and

(iv) able to sustain an appropriate land use after rehabilitation or restoration

7* 10, 11

The activity will be managed to prevent or minimise adverse effects on the environmental values of land due to unplanned releases or discharges, including spills and leaks of contaminants.

8, 11 9

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

The application of water or waste to the land is sustainable and is managed to prevent or minimise adverse effects on the composition or structure of soils and subsoils.

8, 11 9

Activities that disturb the landscape will be managed in a way that prevents or minimises adverse effects on landscape character, including progressive rehabilitation and decommissioning.

Gulf 21 20

Conserve carbon content at pre-mining level, or replenish through vegetation regeneration process post mining.

Gulf 10 6

Conserve mineral content at pre mining level, or replenish during vegetation regeneration process. Gulf 10 6

Soil stockpiling is preferentially undertaken during a single dry season. Gulf 10 6

Comply with rehabilitation and decommissioning performance criteria. Gulf 11 5

Biodiversity offset plans will be developed for any significant residual impacts on fauna and flora in accordance with relevant Commonwealth and State policies.

Gulf 15 12

Buffer zones are created around sensitive ecological areas (i.e. wetlands and watercourses) where mining activities are restricted.

Gulf 15 12

Vegetation clearing is minimised both temporally and spatially. Gulf 15 12

Revegetation with native species occurs progressively after mining. Gulf 15 12

Habitat and fauna management practices are implemented prior to and during clearing activities. Gulf 15 12

Areas of connectivity between mining areas are retained. Gulf 15 12

Weeds and pests are managed to prevent increase in abundance or diversity. Gulf 15 12

Fire is managed to prevent impacts on rehabilitation areas. Gulf 15 12

Site Suitability

Environmental Objectives

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

The choice of the site, at which the activity is to be carried out, minimises serious environmental harm on areas of high conservation value and special significance and sensitive land uses at adjacent places.

6, 12, 13, 15, 16, 19 7, 12, 13, 18

The choice of the site, at which the activity is to be carried out, minimises serious environmental harm on areas of high conservation value and special significance in the marine environment.

Gulf 17, 18, 22 14, 16

Performance Outcomes

Areas of high conservation value and special significance likely to be affected by the proposal are identified and evaluated and any adverse effects on the areas are minimised, including any edge effects on the areas.

6, 12, 13, 15, 16, 18 7, 12, 13, 16

Critical design requirements will prevent emissions having an irreversible or widespread impact on adjacent areas.

6, 12, 13, 17, 19 7, 14, 18

Activities in the marine environment are carried out in a way that prevents or minimises adverse effects on the use of surrounding waters and allows for effective management of the environmental impacts of the activity.

Gulf 17, 22 14

Location on Site

Environmental Objectives

The location for activities on a site protects environmental values relevant to adjacent sensitive uses. 11, 14 5, 8

The location for activities on a site with the potential to cause contamination protects environmental values relevant to adjacent sensitive uses.

Gulf 8, 11 9

The location of activities in the marine environment protects environmental values of adjacent sensitive uses. Gulf 17, 18 14, 16

The location for the activities protects visual amenity of sensitive receptors. Gulf 21 20

Performance Outcomes

The activity will be carried out on the site in a way that prevents or minimises adverse effects on the use of surrounding land and allows for effective management of the environmental impacts of the activity.

8, 11 5

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

Areas used for storing environmentally hazardous materials in bulk are located taking into consideration the likelihood of flooding.

14 8

Mining activities and Port infrastructure will be located above the 1:100 year flood level. Gulf 14 8

Shipping activities will be managed to minimise bank erosion potential and habitat impact. Gulf 17 14

Activities that disturb the marine environment and associated flora and fauna will be managed in a way that prevents or minimises adverse effects on the environmental values.

Gulf 18 16

Minimise interaction with marine species and habitats on the Skardon River. Gulf 18 16

The activities will carried out in a way that prevents or minimises adverse visual amenity impacts for sensitive receptors and surrounding land uses.

Gulf 21 20

Critical Design Requirements

Environmental Objectives

The design of the facility (water management infrastructure) permits the operation of the site at which the activity is to be carried out, in accordance with best practice environmental management.

6, 14 7, 8

The design of the facility (waste management facilities) permits the operation of the site at which the activity is to be carried out, in accordance with best practice environmental management.

8, 11 9

Performance Outcomes

All storage provided for hazardous contaminants includes secondary containment to prevent or minimise releases to the environment from spillage or leaks.

8, 11 9

Regulated structures comply with the ‘Manual for Assessing Consequence Categories and Hydraulic Performance of Structures’ (EHP, 2013).

6 7

Containers used for the storage of hazardous contaminants are secured to prevent the removal of the containers from the site by a flood event.

14 8

The design of the facility prevents or minimises the production of hazardous contaminants and waste. 8, 11 9

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Environmental Objective / Performance Outcome EP Regs or Gulf

EIS Chapter EM Plan Section

If the production of hazardous contaminants and waste is not prevented or minimised, then the design of the facility contains and treats hazardous contaminants rather than releasing them.

8, 11 9

Creek and drainage feature crossing structures will minimise change to existing flow regimes and flood behaviour.

Gulf 14 8

* The performance outcomes listed in the EP Regulation provide a summary of the rehabilitation objectives provided in Chapter 7.