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Works Approval Application – IBD Project Processing Plant

Attachment 3A – Additional Information relating to the proposed activities.

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1.Background Information

The India Bore Diamond Project (IBD Project) is an alluvial diamond exploration project located adjacent to the closed E9 and E4 diamond mines in the Ellendale diamond field of the West Kimberley region of Western Australia.

India Bore Diamond Holdings Pty Ltd (IBDH) is a private Australian mining company with offices in Derby and Perth in Western Australia and Melbourne in Victoria. The India Bore Diamond Project (IBD Project) consists of 6 contiguous exploration tenements E04/2398, E04/2404, E04/2426, E04/2525, E04/2586, a Mining Lease Application M04/473 and a northern tenement E04/2591.

Figure 1: Map showing the IBD Project Leases (yellow & blue outlines) adjoining the abandoned Ellendale mine lease (brown outline)

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Over 50 lamproite volcanoes have been identified across the Ellendale Diamond Field. The Ellendale 9 (E9) and Ellendale 4 (E4) lamproites were mined between 2004 and 2015 when the project was closed.

Studies completed by IBDH during 2015-2016 identified a canyon (L Canyon) draining the Ellendale Diamond Field into a long wide river channel (L Channel) and a large alluvial fan in the IBD Project Area.

The IBD Project Area has been extensively explored, drilled and trenched with recovered gravels processed across the area for over the past 40 years.

Historical alluvial diamond occurrences southwest of the E4 diamond mine were discovered by earlier explorers that failed to identify the full extent of the L Channel within E04/2398.

IBDH completed its Stage 1 Resource Development Plan in 2016 with a primary goal of confirming a target resource of 16.4Mt of economically minable diamondiferous gravel.

A Heritage Clearance was approved by the Bunuba Native Title holders in April 2017 a PoW approval was granted for drilling by the Department of Mines & Petroleum now DMIRS.

Two Heritage Surveys have now been completed by the Bunuba Native Title Holders.

IBDH drilling programs carried out in 2017 and 2018 have confirmed extensive diamondiferous river gravels along this L Channel target area.

IBDH has obtained the required clearances, approvals and licences for the planned Stage 1 project work to continue through 2019.

IBDH bulk sampling at Trench 1 on the L Channel in May-June 2018 recovered diamonds in 128t of diamondiferous gravel at the average diamond grade of 7.95 carats per hundred tonnes (cpht).

The IBDH Phase 1 drilling, trenching and diamond recovery has resulted in the current diamond target estimate for the L Channel being increased to 1,303,164 carats. Further trenching and processing is required to achieve a JORC compliant resource.

In late 2017 IBDH leased a small mobile DMS plant rated at 20tph and fitted a pre-screening plant rated at 5-10tph for the diamond recovery work. It was expected that the plant would process a maximum of 50t-100t per day for a maximum of 90 days per year. The plant was installed on site and commissioned in November - December 2017. The plant has not been able to process more than 60t per day with a maximum of 500t processed to 26th June 2018 when it was decommissioned.

It was believed by IBDH that due to the small tonnages to be processed and the brief intervals of operation (6weeks – 12 weeks) the plant did not need a DWER Works Approval. IBDH was made aware that this was a breach of the Environment Protection Act and following a warning and further discussions with DWER made an application for Registration of the plant. Registration: R2474/2018/1 was issued to IBDH on 10th October 2018. The plant remains decommissioned and will not be restarted until Works Approval is granted for the upgrade proposed in this Works Approval Application.

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On 3 October 2018 IBDH completed a Mineralisation Report and lodged a Mining Lease (ML) Application with the Department of Mines, Industry Regulation & Safety (DMIRS). The ML application covers the full 9km extent of the L Channel from the northern boundary of E04/2398 adjoining the closed Ellendale mine project area to the bottom of the L Channel Promontory. The ML application has been accepted and is being processed.

A Phase 2 drilling program of 3627m was completed on 6th October 2018. This aircore drilling targeted the diamondiferous gravel beds east of Trench 1 extending both north and south of the trench. Large extensions of gravel ranging in thickness from 4m-10m have been confirmed.

A Program of Work (PoW) for Trench 2 was approved in December 2018. An Excess Tonnage Application for the excavation of 350,000t (total excavation) was approved on the 24th October 2018. A maximum of 300,000t will be excavated for the recovery of a gravel target of 25,000t – 30,000t for processing through an upgraded plant.

IBDH is now seeking a Works Approval for prescribed premises (category 80(3) to upgrade and operate the processing plant. Details of the proposed upgrade are provided later in this report.

If the Works Approval Application is approved IBDH will proceed with the goal of processing a package of gravel up to 30,000t over a 12 weeks period. If this program proves successful two further trench’s will be necessary with up to 30,000t packages of gravel processed.

A licence to use an existing bore on the closed E4 mine adjacent to the IBDH entry gate (within 50m) was granted by the Western Australia Department of Water (GWL200028(1).

Over the past 18 months infrastructure has been developed at the IBD Project site to support ongoing exploration. Key participants in the project including the Bunuba Native Title Holders, Jumbuck Pastoral Company, DMIRS, DWER and the Shire of Derby West Kimberley have been consulted and are updated on the developing project.

While the Mining Lease Application is progressing through the statutory approval process IBDH is continuing to carry out large bulk testing (trenching) of gravels as required under the JORC Code to confirm that an economically viable project exists. If a viable project is confirmed by Trench 2 and subsequent trenches a Mining Proposal will be developed when the Mining Lease is granted.

The exploration program requires further approvals for excavation and processing of large bulk samples.

2. Location of the IBD Project Area

The IBD Project is located 140km east of Derby in WA along the NE margin of an ancient inland ocean referred to as the Canning Basin.

Access to the project area is along the Gibb River Road and Roberts Road through the abandoned Ellendale diamond mining lease M04/372 (Figure 2).

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The tenements are on the pastoral lease held by Jumbuck Pastoral Company and the Native Title land of the Bunuba Traditional Owners.

Figure 2: Location and Access Map for the IBDH Project.

IBDH was granted Exploration Licences E04/2398, E04/2404 and E04/2426 in 2016 following the signing of a Native Title, Heritage Protection and Mineral Exploration Agreement with the Bunuba Native Title Holders. A further tenement has been added and 3 applications are currently being processed.

Figure 3: Aerial Photo of the Project Site in 2018.

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Figure 4: Aerial Photo. IBD Project Area (E04/2398) with Access Road, Drill Lines, Camp Processing and Trench Areas Developed over 3 years.

The total area cleared in the 2017 & 2018 work programs for drill lines, trench and the processing area was 13.5ha. All drill holes have now been rehabilitated. IBDH used existing tracks for access to the process plant & camp area. Re-clearing of the access tracks was undertaken and the total area cleared included in the total area of disturbance.

3.Stakeholder Engagement

Key stakeholders include the Bunuba Native Landowners, Jumbuck Pastoral Company, Shire of Derby-West Kimberley, local Service Providers and the WA Government. IBDH has maintained close liaison with all these stakeholders and provides regular updates of its activities.

3.1 Bunuba Native Title Owners

Much of the Project Area is on granted Native Title Land. IBDH engaged the Bunuba people through their representative body the Bunuba Dawangarri Aboriginal Corporation (BDAC) in early 2015. A Native Title, Heritage Protection and Mineral Exploration Agreement has been

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in place for over 2 years and has provided benchmark arrangements for ongoing participation in the project and cooperation between the parties.

Aboriginal Heritage Surveys were completed on the IBD Project Area in April 2017 and May 2018 to clear exploration areas.

Discussions have commenced to finalise a Mining Agreement between the parties to cover any proposed mining operations.

Regular contact is maintained with BDAC. A Heritage Management Plan is being developed for joint implementation.

Bunuba people have been employed on the project since early 2016.

3.2 Jumbuck Pastoral Company

IBDH has maintained close contact with the Manager of Blina and Ellendale Stations and has engaged in regular meetings to discuss operational issues and management plans. Programs of work to maintain the access roads and fence line fire breaks have been agreed.

Management procedures for protection of the station cattle are being implemented and plans for the control of feral animals will be put in place.

Environmental monitoring and procedures for management of emergencies are to be addressed later in 2019.

4. Project Proposals and Work Programs

The IBD Project remains an exploration project and has no Mining Lease approved. A Prefeasibility Study was completed in 2016 and Stage 1 of the Project was subsequently divided into 2 Phases to permit ongoing evaluation of results, reduce risks and allow for redirection of resources as required. The Phase 1 work program has been completed.

The IBD Project is progressing through 4 stages of development: • Stage 1 Resource Development & Bulk Testing (trenching) – underway; • Stage 2 Feasibility Studies – ongoing; confirmation of a viable project is required; • Stage 3 Project Design & Approval – evaluations commenced; • Stage 4 Implementation of Mining – following design, approval and financing. Studies of key design and cost components for a 1mtpa plant have been progressed. Environmental monitoring and flora and fauna studies have commenced. 4.1 Description and Scope of Prescribed Activities The work proposed in the Phase 2 exploration work program subject to DMIRS and DWER approval comprises: Drilling of up to 4000m of aircore holes to a maximum depth of 25m. This was

approved by DMIRS and completed on 6th October 2018 with 3627m drilled.

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Trenching of up to 300,000t of overburden and river gravels adjacent to the existing Trench 1 with the goal of recovering of up to 30,000t of gravel for processing and recovery of diamonds. This is approved and is planned for completion by 1 July 2019.

Processing would be through the upgraded existing plant following Works Approval. The processing (Figure 10 - Process Flow Diagram) involves:

o screening of oversize through a grizzly when loading the feed bin at the rate of 35t-40t per hour; Oversize returned to the trench.

o removal of +20mm gravel through a trommel (plant upgrade) with -20mm washed through a screen; Pumping -1mm screen wash (plant upgrade) to the sediment settling pond;

o screening +18mm material through a small scrubber with +18mm discarded to the trench; pumping -1mm screen wash to the sediment pond;

o pumping +1mm/-18mm concentrate to the cyclone; lights discarded to trench stockpile;

o processing heavy concentrate through magnetic separator with heavy fractions including diamonds to the diamond Flowsort container; waste to trench stockpile.

All oversize and reject materials are stockpiled for return to the trench. Water is supplied from a small bore to the fresh water pond and pumped to the

process plant as required. The fresh water pond is lined with HDPE. Wash water discharged to the sediment settling pond system is returned to the fresh

water pond for recycling. There is no discharge of water other than small seepage/evaporation losses from the

ponding system. There is no emission of any reagents. Dust is controlled by water truck and spraying. Power is supplied by a slide mounted 350kVa diesel generator. Diesel fuel is stored in a 20,000l self-bunded tank. Ferrosilicon is used in the DMS plant and is recycled. No other hydrometallurgical

reagents are used. There is no discharge of chemical reagents or emissions to air. There is no waste management facility on site. Putrescible and other waste materials

are transported to Derby West Kimberley Shire waste facilities. Very small quantities of solid spares (timber, steel and HDPE pipe) are stored in a laydown area.

The processing plant including loading and removal of waste stock piles is operated by 3 personnel.

The drilling contractors complete the drilling contract work in 3-4 weeks campaigns in the dry season;

The trenching contractors are engaged for 8-12 weeks campaign periods in the dry season.

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Figure 5: Aerial photo of the IBD Project Area south west of the closed Ellendale 4 mine.

4.2 Trenching

The Trench 1 (Phase 1 program) resulted in the recovery of approximately 10,000t of material from a 50,000t trench. The recovered material contained high concentrations of diamond indicator minerals but very little river gravel. Small parcels of the stockpiled ores were processed. An estimated total of 500t were processed and no diamonds were recovered. The material contained high concentrations of clay and silt. The plant was designed to process river gravel and could not effectively treat the clays & silts.

Nearing the end of the trenching program a small volume of river gravel was identified in the eastern wall of the trench. A sample estimated to be around 250t was recovered. The sample was diluted with fine sand and clay at a ratio of approximately 50% gravel:50% sand/silt. The material was processed with 10.17 carats of diamonds recovered from 128t of gravel.

The material excavated from Trench 1 has been returned to the trench with some approved for use in developing roads and pads. Trench I will be backfilled and rehabilitated during the Trench 2 work.

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Figure 6: Aerial Photo of Camp, Processing area and Trench 2 Extending North of Trench 1. The fine black line shows areas to be cleared for the Trench 2 work (approx. 6ha).

The Trench 2 program of work if scheduled to commence when seasonal conditions permit and the IBDH Project Management Plan is approved. It is anticipated that the work will commence in early April 2019 not in October as indicated on Figure 6.

The trenching will be overseen by JDSi Geotechnical Engineers Pty Ltd the company that has designed the DMIRS approved trench and operation. Their report ‘Geotechnical Concept Design and Operation Report Stage 2 – Exploration Trenching and Backfill Project’ – JDSi Ground Engineering – dated 15 October 2018 provides details of the proposed trenching program.

Figure 6 above provides an outline of Trench 2 and detail of the areas to be cleared for the deposition of top soil, ores and waste material. The adjoining Trench 1 will be backfilled during the Trench 2 operations and then rehabilitated. A section of Trench 2 will also be backfilled. It is probable that Trench 2 will be extended to the north if the programs proves successful.

The Trench 2 operation is expected to be completed by 1 July weather permitting.

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4.3 Processing

An area was prepared for gravel and overburden laydown areas, water supply pond, a sediment settling & a water recycle pond and a small processing plant. A small area was also prepared for a temporary accommodation camp.

The process area pads, laydown areas, sediment and the water recycle system were completed in late October 2017. A Dense Media Separation (DMS) plant was leased for a period of 6 months and was delivered to site on 15th November 2017 on one road train.

A ‘Flowsort’ Diamond X-ray Recovery container leased from Diamond Recovery Services was delivered to site in mid-November.

The plant was commissioned in late November-early December and small batches of material (5t-10t) were tested. The plant was shut down in mid-December 2017 and restarted in May 2018 and operated intermittently for a total of 5 weeks.

Figure 7: Processing Plant; DMS in foreground, feed bin at rear and FlowSort X-ray Diamond Recovery Container (white 20ft container).

The plant was not capable of efficiently processing the excavated materials.

There are no emissions from the processing plant. The ferrosilicon is collected in the magnetic separator and recycled.

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4.3.1 Proposed Process Plant Upgrade

The process plants main components are outlined in the flow diagram below (Figure 8). A series of conveyors moves the gravel along the process line. The waste material is removed in separate stages:

Oversize rocks and cobbles (estimated to be 15% of the material) are screened out at the grizzly and are stockpiled for return to the trench;

+20mm stones are removed at the trommel (addition to plant); -1mm clay, silt and sand (estimated 50% of the material) is washed out through the washing screen (addition to plant) and scrubber screens and pumped to the sediment pond for removal to the trench;

+18mm material is removed at the scrubber and stockpiled for return to the trench;

Lights removed in the cyclone are conveyed to the waste stockpile for return to the trench;

Materials removed at the magnetic separator are conveyed to the waste stockpile for return to the trench;

Concentrates are sized into 3 size ranges (-4mm, -8mm & -18mm) and processed through the FlowSort X-ray machine.

Simplified Process Flow Diagram below – Conveyors & Pipelines Transfer the Material

Waste Stream -1mm fines to Sediment Pond Lights/Oversize to Stockpile/Trench

Figure 8: Diagrammatic Process Flow Sheet.

Figure 9: Trommel to be Installed. Figure 10: Washing Screen to be Installed.

A used trommel and washing screen are being refurbished and will be installed when Works Approval is granted. These items were salvaged from the closed Ellendale mine.

Grizzly & Feed Bin Trommel Washing

Screen Scrubber Cyclone Magnetic Separator

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4.3.2 Commissioning Period of Up to 3 Months

The performance of the processing plant will be dependent on the clay, silt and sand concentrations in the material recovered from the trench. The flow rates through the DMS and Flowsort diamond recovery container are expected to be the limiting factors on the rate of processing if the refurbished trommel, washing screen and discharge pump perform efficiently.

The trommel, washing screen and slurry pump have the capacity to process up to 40tph.

It is anticipated that the loading rate will need to be adjusted to effectively process the differing types of gravel material recovered from the trench.

A commissioning period of up to 3 months may be required to permit evaluation of performance and changes to the proposed modifications to the plant if required. There will be no proposal to increase the throughput of the plant above the calculated maximum of 400,000tpa.

5. Water Management

Fresh water is pumped as required to the fresh water pond from the licenced bore. The plant draws water from the fresh water pond (900m3 capacity). Process water is pumped to the sediment pond and returned to the fresh water pond via a settling pond for reuse. It is estimated the processing plant will recycle up to 500m3 of water per day.

Figure 11: The HDPE lined Water Supply Pond Figure 12: Cleaned Sediment & Settling Ponds

Sediments are removed from the sediment pond and returned to the excavated trench. The fresh water pond shown in Figure 11 above has had a new HDPE liner fitted. The sediment and settling pond are constructed of compacted clays and have little water loss through seepage. No seepage areas have been observed and no noticeable water loss has been recorded.

Storm water collected in the trenches will be pumped to the water management system to reduce the need for deep well extraction of fresh water. No seepage into the trench has been recorded. None of the IBD Project exploration drill holes (to depths of 30m) recorded water infiltration. The trenches, processing area and camp are surrounded by strategically placed earth bunds. The following diagram (Figure 13) shows the layout.

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Figure 13: Site Layout showing Bunding and Drainage Pathways

The IBD Project operations area sits on an armoured promontory that is raised between 10m- 15m above the surrounding ground. The access road to the operations travels along the raised promontory except for a small creek crossing on the old Telegraph Line road. A culvert has been installed in this crossing.

Stormwater is shed off the raised promontory along its 9km length. A series of road drains direct stormwater both southwest and southeast off the road along its length. The IBDH access follows previously developed roads and the drains were renewed at the request of Jumbuck Pastoral Company.

Surface water collected in the plant and accommodation areas drains to shallow depressions within the contained bunded areas. The small volumes of water evaporate quickly even following heavy rainfall (120mm/24hrs) in the wet season.

Between 6th-20th December 2017 a series of intense tropical storms resulted in over 300mm of rain. One of these storms produced 120mm within 4.5 hrs. All the bunding and drains proved to be adequate and no damage was recorded.

IBDH has purchased Digital Terrain Modelling (DTM) Generation, Orthorectification, Mosaicking and Pan-sharpening of WorldView-2 Imagery from GEOIMAGE for evaluating a range of applications at the Project.

The high-resolution elevation data allows 1m contour intervals to be overlaid on imagery of the IBD Project Area. High resolution landsat imagery was purchased to provide accurate information on the landforms and position of watercourses.

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Some modifications to the bunding and drainage works will be required before the commencement of the second stage of trenching and processing.

Access to and from the site along the Gibb River road will be cut off for periods during a heavy wet season. Provisions have been made for such events.

The following is a summary of the actions taken on site to control stormwater runoff and manage surface water from intense rainfall events:

Roadside drains and adjacent raised road bunds have been constructed along the access road to redirect stormwater off the roads along raised promontory.

A bund is positioned north of the operations area to redirect stormwater to the southwest and southeast upgradient of the site. (see Figure 13).

A bund surrounds Trench 1. A new bund will be constructed around Trench 2 prior to the commencement of work. Stormwater is collected in a sump in the trench for pumping to the water management pond and recycle system. No water collected in the trench is discharged.

The process plant and ore stockpile areas are surrounded by a bund and all water is collected and directed to the water recycle system.

Gravel washing water is recycled.

Drill holes E-W and N-S through the trench were on average between 20 and 30m depth. No ground water was encountered during drilling operations. All water bores in the E4 area are north of the Oscar fault in what has been interpreted as an uplifted horst block.

The Grant Sandstone host of the L Canyon located to the north of the Oscar fault is a fresh water aquifer. The company has a water extraction permit for the GP4 water bore located 60m north of E04/2398.

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Figure 14: 1m DEM Contours showing Elevation of the IBD Project Area

6.Waste Management

All overburden, waste rock and sediments are returned to the trenches. The sediment pond is periodically cleaned out and the materials returned to the pit. Suitable gravel and rock materials excavated from Trench 1 were approved for surfacing roads and construction of pads.

A small volume of washed river stones has been used to consolidate pad areas near the processing plant and accommodation area.

Waste from the camp mess and accommodation is minimal. The camp is generally occupied by 3-4 personnel with up to 10 personnel for short periods (3 weeks when drilling and trenching are underway). This waste is placed into wheelie bins, transferred to a large waste bin and transported to the waste depot in Derby.

The small volume of waste oil is collected in poly drums and removed from site to the Jenkins Earthmoving and Transport depot in Derby where it is collected by a licenced waste management firm.

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An oil spill kit is kept in a small hydrocarbon bund used for placement of hydrocarbon containers.

A septic tank and absorption trench have been installed to treat sewage form the camp.

The only processing additive to the DMS plant is powdered Ferrosilicon which is recovered in the magnetic separator. The Ferrosilicon powder that contains iron and silica ground up together is lost at a very minor rate to the sediment pond. Additional information can be obtained from: https://www.dmspowders.com

The chemical product safety sheet can be found at the following website and on site.

http://pyrodata.com/sites/default/files/ferro.pdf

There is no waste disposal facility on site.

6.1 Waste, ore and soil characterisation

A rigorous review of the drill hole assays confirmed that there are no elements in concentrations that could represent a threat to the environment particularly in view of the management practices undertaken at the Project. Multi-element assays across the river system have been supplied in the Annual Exploration Report.

The physical and chemical properties of material disturbed are typical alluvial river system clays, sand and gravel.

The physical properties of the excavated materials can be split into 3 categories being topsoil (the top 150mm) stockpiled for rehabilitation, pindan sands and clay-rich alluvial sediments with small 1cm to 15cm wide rounded river pebbles inter-dispersed (at 0.2m -12m depth) and the basal river gravels predominately of quartzite pebbles & boulders in river sands.

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An average thickness of 4.0m has been estimated for the basal river gravel (15m -18m depth). This basal layer has a coarse fraction gravel which contains more quartz river pebbles, river sands and some minor clay. Across the river channel gravel thickness varies from 0.5m up to 9m in some sections.

Full drill logs and geology information was included in the IBDH 2018 Annual Exploration Report.

Hard waste including timber, small steel off cuts and piping is stored in a laydown area for re-use or eventual removal to an approved waste facility.

7. Land Uses and Sensitive Areas.

The tenement is on the Jumbuck Pastoral Company (Jumbuck) pastoral lease. Regular meetings are held with the Manager of the Ellendale and Blina stations owned by Jumbuck. Operational activities are discussed and issues such as road and fence maintenance are agreed. A good working relationship is maintained between the parties.

Regular meetings are held between the company and the Bunuba Dawangarri Aboriginal Corporation (BDAC). Two Heritage surveys have confirmed that there are no sensitive sites on the IBD Project area. Two small sites have been identified in the northeast of the tenements that are currently outside the IBDH operational areas. IBDH and BDAC have agreed processes to manage any sensitive areas that may be identified in the future operations.

IBDH employs a BDAC field assistant to assist with its work programs and has commenced discussions for the development of a Heritage Management Plan.

The abandoned mining lease M04/372 now under the control of the DMIRS adjoins the IBDH tenements to the north.

IBDH uses the pastoral and mine access road (Roberts Road) running through M04/372 to its entry gate adjacent to the disused E4 tailings dam. Locked gates are in place at the intersection of Gibb River Road and Roberts Road, at the entrance to the Ellendale S19 Area (old mine lease) and the entrance to the IBD Project Area.

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Figure 15: Map showing the IBD Project area with historical drilling (red dots), IBDH operational area (red outlined with hatching); Aboriginal heritage sites (squares with blue hatching) and the Tunnel Creek National Park to the northeast.

9. Environmental and Safety Management Programs

Advancing a project from exploration to mining activities requires approval under the Mining Act and Regulations and the Environmental Protection Act and Regulations. Specific requirements include:

• The WA Mines Safety and Inspection Act 1994 requires the development, approval and implementation of a Project Management Plan (PMP) for the safe management of mining construction and operating activities. A PMP is currently being lodged on line for the approval of the State Mining Engineer.

• Approval of a Mining Proposal under the WA Mining Act 1978 – a mining proponent must submit a Mining Proposal in accordance with the 2016 Guidelines for approval of a mining project prior to commencement of mining activities.

• Environmental management of mining operations is approved under the WA Mining Act, WA Environmental Protection Act and where required the Commonwealth Environment Protection and Biodiversity Conservation Act (EPBC Act). These approvals require the gathering of background environmental data for each mine site. This work has commenced at site.

A Flora & Fauna Desktop Study was completed in August 2018 to identify any significant species that may require the implementation of special impact protection measures. An environmental monitoring program commenced on site in December 2018.

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An Annual Environmental Report (AER) must be submitted to the DMIRS in January of each year to report on environmental management activities on site including the progressive rehabilitation of disturbed areas. Recording of the required information is carried out and the first AER was submitted in January 2019.

The WA Environmental Protection Act 1986 and the Environmental Protection Regulations 1987 require Registration of Premises, Works Approval and Licencing of Premises capable of processing 5,000tpa of gravel. The IBD Project processing facilities have been Registered and will require a Works Approval prior to upgrading to potentially process up to 100,000tpa in 3 campaigns of trenching and processing.

9.1 Flora, Fauna and ecosystem management.

IBDH engaged Geotech-enviro to undertake a Flora & Fauna Desktop Study of the project area and surrounding environment. A copy of Geotech-enviro’s report is included.

The IBD Project workings currently cover a small area on the raised promontory.

The area where IBDH is currently drilling and trenching is frequently burnt to provide protection for the conservation areas to the north and northeast of the IBD Project.

IBDH is working with the Jumbuck Pastoral Company to provide fire protection.

The aerial photo (Figure 16) shows the small area of current operations within E04/2398.

The Flora and Fauna Desktop Study refers to significant species in the region that will be monitored carefully by IBDH. Monitoring of fauna has commenced.

The report indicates that the landform habitat suitable for Bilbies is the yeeda land system. This landform does not exist in the current IBD Project Area.

Two sites outside of the area of operations and the proposed Mining Lease have been identified as sites where significant species were sighted.

A procedure for monitoring of rare and endangered species will be implemented for the Project Area.

IBDH has commenced monitoring the fauna and will commission a detailed flora and fauna survey prior to extending the bulk testing program outside of the proposed mining lease area and before any Mining Proposal is prepared for lodgement.

Geology map from Bulletin 145 shows proposed ML, area drainage run off & bores

Dingos and kangaroos have been observed around the camp and processing areas at night. No cattle have been seen near the ponds.

IBDH has committed to the following Environmental Impact Mitigation Measures:

(a) Protection of Conservation Significant Flora and Fauna

(b) Habitat Protection

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as outlined in Attachment 4 Section 5 of the ‘2018 Desktop Flora & Fauna Study – India Bore Diamond Holdings West-Kimberley Diamond Exploration Project’ report dated 21 August 2018.

Figure 16: Google Earth aerial photo of the IBD Project operational area.

A recent google earth aerial photo shows the small area disturbed within E04/2398. The roads and tracks follow previously developed roads.

IBDH has commenced monitoring the fauna and will commission a detailed flora and fauna survey during the Phase 2 exploration program.

9.2 Rehabilitation

Drill holes are placed in the centre of the drill tracks and are rehabilitated within 6 months of the work being completed. All the drill holes have been rehabilitated. It is planned to construct protection barriers around the rehabilitated areas to provide protection in the early stages of stabilisation.

The ongoing trenching and any mining operation to follow will be cut and fill operations. A completed excavation will be used for disposal of the processed gravel and the repository for the overburden or barren material excavated from the following excavation. The mining operation will follow the gravel resources in a planned mining schedule. Completed zones will be rehabilitated progressively. Due to the nature of the overburden materials it is expected that the mined voids will have the capacity to contain all the excavated overburden. There may initially be a slight mound in the rehabilitated excavations and this is expected to settle over time.

The clays and silts captured in the sediment system will be cleaned out as required using an excavator and truck and returned to the trenches and pits.

Some small volumes of sand and river gravel will be collected for hard stand areas and roads and removed in the final closure of the project.

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Topsoil will be removed to a depth of 150mm and stored in stockpiles with a maximum height of 2 metres. All topsoil will be placed in areas away from potential impact of trenching and processing operations.

10. Recommencement of Trenching and Processing on Site

IBDH has now demonstrated that diamondiferous river gravels in the IBD Project target areas contain higher grades of diamonds than previously recovered. The gravels have very distinct characteristics and have been tracked by the Phase 2 drilling north and south of Trench 1. Further drilling and trenching will follow recovery of good grades of diamonds from Trench 2.

It is planned to recommence Trench 2 as soon as dry conditions allow access to the Trench and a date of 1 April has been set as a possible target.

It is planned to recommence processing of recovered gravels following granting of the Works Approval and availability of recovered gravels. A target date of 1 May has been established.