Heathgate Resources Pty Ltd's Response to Comments on The
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C:\Documents and Settings\cath_swan\Desktop\VIc\Mining Proposal Response Four Mile FINAL 190309.doc Response Document - Beverley Four Mile Project PER and Mining Lease Proposal Response Document - Beverley Four Mile Project PER and Mining Lease Proposal Mine owner Quasar Resources Pty Ltd and Alliance Craton Explorer Pty Ltd Joint Venture as joint venturers in the Beverley Four Mile Project Proposed Mine operator Heathgate Resources Pty Ltd Contact person Richard Phillips – Managing Director, Operations, Heathgate Resources Pty Ltd Contact details Suite 1, Level 4, 25 Grenfell Street, Adelaide SA 5000 Telephone: 08 8110 0500 Fax: 08 8212 5559 Email: [email protected] Tenement details EL 3666 Name of mining Beverley Mine Four Mile Project operation Commodity to be mined Uranium MLA application date 16th May 2008 Prepared for Heathgate Resources Pty Ltd (as proposed mine operator) Level 4, 25 Grenfell Street, Adelaide 5000 19 March 2009 42657105.05002 RESPONSE DOCUMENT - BEVERLEY FOUR MILE PROJECT PER AND MINING LEASE PROPOSAL Project Manager: URS Australia Pty Ltd Level 4, 70 Light Square ……………………….. Adelaide Vic Farrington SA 5000 Senior Principal Australia Environmental Engineer Tel: 61 8 8366 1000 Fax: 61 8 8366 1001 Project Director: .……………………… Vic Farrington Senior Principal Environmental Engineer Date: 19 March 2009 Reference: 42657105.05002 Status: Final Report Prepared for Heathgate Resources Pty Ltd (as proposed mine operator), 19 March 2009 RESPONSE DOCUMENT - BEVERLEY FOUR MILE PROJECT PER AND MINING LEASE PROPOSAL Table of Contents Table of Contents ES Executive Summary ....................................................................................................... 1 1 Comments and Responses ........................................................................................... 1 2 Errata............................................................................................................................. 45 3 References.................................................................................................................... 47 4 Limitations .................................................................................................................... 48 Tables Table 1-1 Responses to Comments..................................................................................................................2 Prepared for Heathgate Resources Pty Ltd (as proposed mine operator), 19 March 2009 i RESPONSE DOCUMENT - BEVERLEY FOUR MILE PROJECT PER AND MINING LEASE PROPOSAL Executive Summary ES Executive Summary This Response Document follows release by Heathgate Resources Pty Ltd (Heathgate) in its capacity as mine operator on 8 January 2009 of a Public Environment Report (PER) (formally a Draft PER) and Mining Lease Proposal (hereafter called the PER / Proposal), for construction and operation of the Beverley Four Mile Project. The purpose of the Response Document and the PER / Proposal is to satisfy the requirements of the South Australian Government for a Mining Lease Proposal to support an application for a Mining Lease under the SA Mining Act 1971, and the Commonwealth Government’s requirements for a PER under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). The State and Commonwealth requirements for construction and operation of the Beverley Four Mile Project are set out in Guidelines dated 17 September 2008 prepared by the South Australian Department of Primary Industries and Resources SA (PIRSA) and the Commonwealth Department of Environment, Water, Heritage and the Arts (DEWHA) (DEWHA, PIRSA 2008). The Four Mile deposits lie within the boundaries of the Exploration Lease EL 3666. A Mining Lease application covering part of EL 3666 was lodged on 16 May 2008. This MLA is the Project Area for this PER / Proposal. The Beverley Four Mile Project entails construction of a satellite facility close to the Four Mile deposits, and construction of in-situ recovery (ISR) wellfields of the same design as currently used on the Beverley mining lease. This satellite facility would remove the uranium from the ISR liquor by ion exchange, producing uranium bearing resin, which would be trucked to the Beverley processing plant. The resin would then be stripped of uranium, and trucked back to the satellite facility. Minor modifications would be required at the Beverley processing plant to accept the uranium-bearing resin, however there would be no net increase in uranium processing capacity. The uranium stripped from the resin would be processed at Beverley, and the small quantity of liquid waste arising would be disposed of at Beverley. There would be no change to the existing Beverley camps, airstrip and supply bores. An unsealed access road would be constructed between the Beverley processing plant and the Four Mile satellite facility. A separate groundwater water supply may be installed at Four Mile. Some additional internal roads would be necessary within the Four Mile lease to access the wellfields. There would also be some additional fencing along the western boundary of the Four Mile deposits for security purposes, and a minor change to the alignment of the 4WD track from Paralana Springs to Hidden Valley, which runs near this boundary, to divert around the Four Mile West deposit. Read in conjunction with the PER / Proposal, this Response forms the Final PER under the EPBC Act, and supports the conclusion of the PER / Proposal that the construction and operation of the Beverley Four Mile Project can be undertaken to meet applicable South Australian and Commonwealth requirements and with no significant impact on the environment. No comments were received during the public exposure period that required any further evaluation, documentation, figures or tables. A table of the comments received and Heathgate’s responses is provided in Section 1. Errata are listed in Section 2. Prepared for Heathgate Resources Pty Ltd (as proposed mine operator), 19 March 2009 ES-1 RESPONSE DOCUMENT - BEVERLEY FOUR MILE PROJECT PER AND MINING LEASE PROPOSAL Comments and Responses Section 1 1 Comments and Responses The PER / Proposal for the Proposed Beverley Four Mile mine was published on 8 January 2008 in order to allow the public to participate in the approval process. Public comments were collated by the South Australian Government and passed on to Heathgate for response, along with a summary of the issues raised that are within the scope of the assessment process. Table 1-1 below captures all comments received under headings derived from the issues listed in the summary, and provides Heathgate’s responses. Some additional issues raised by the public are also addressed. Some comments that were out of scope (as determined by the regulators) have been omitted. No comments were received that required further evaluation, documentation, figures or tables. Prepared for Heathgate Resources Pty Ltd (as proposed mine operator), 19 March 2009 1 RESPONSE DOCUMENT - BEVERLEY FOUR MILE PROJECT PER AND MINING LEASE PROPOSAL Section 1 Comments and Responses Table 1-1 Responses to Comments Public Comment Response 1 South Australian Department for Environment and Heritage Diversion of Paralana Springs - Hidden Valley 4WD track, and associated impacts The diversion of the Paralana Springs-Hidden Valley 4WD track will not be Diversion of the Paralana Springs–Hidden Valley 4WD track is proposed. Has the required at the beginning of construction and operations. The landform is landform and environment of this area been considered in any of the studies/reports? Paralana High Plains which has been considered in the flora, fauna and other The impacts on flora, fauna, soils and hydrology relevant to this area are not detailed. environmental reports. The track would be relocated closer to the foothills of the Flinders Ranges but still on the High Plains. Details will be confirmed with the owners and managers of Arkaroola Wilderness Sanctuary ahead of its requirement. The area of habitat affected by relocation of this track is very small in the context of the mining plan, and the previous alignment would be rehabilitated when mining finishes, or reinstated and the new alignment rehabilitated depending on the wishes of Arkaroola Wilderness Sanctuary and other stakeholders. It is unclear where resin returned to the Four Mile site from Beverley will be placed and Refer Section 4.5.3 – resin will be taken to a truck loading / unloading bay and how it will be dealt with. returned to one of the five ion exchange vessels. S3.2 states that there will be no impacts to tourism as the operation will be the same The Arkaroola boundary extends eastwards from the Flinders Ranges into the as at Beverley. This does not recognise that the project area for Four Mile West plains area where Four Mile West is located (Figure 2-1). However as noted in overlaps Arkaroola Sanctuary and that proposed road changes, fencing and scenic Section 3.2, the proposed ISR operations on the plains area of Four Mile West impacts closer to the ranges are expected. would not affect the wildlife sanctuary and tourism activities at the Arkaroola Wilderness Sanctuary, which are focussed on the Finders Ranges. It is noted also that the Paralana Springs are outside the proposed Mining Lease area. Prepared for Heathgate Resources Pty Ltd (as proposed mine operator), 19 March 2009 2 RESPONSE DOCUMENT - BEVERLEY FOUR MILE PROJECT PER AND MINING LEASE PROPOSAL Comments and Responses Section 1 Public Comment Response Impacts from the proposed