Mining Proposal for Proposed Extension of Beverley Mine
Mine owner Heathgate Resources Pty Ltd Mine operator Heathgate Resources Pty Ltd Contact person Richard Phillips – Managing Director, Operations Contact details Level 9, 45 Grenfell Street, Adelaide SA 5000 Telephone: 08 8110 0500 Fax: 08 8212 5559 Email: [email protected] Tenement details MC 3679-3739 inclusive incorporating ML 6036 and MPL 57, 58 and 59 Name of mining Beverley Mine operation Commodity to be Uranium mined MLA application 23 November 2006 date
Prepared for:
Heathgate Resources Pty Ltd
Level 9 45 Grenfell Street Adelaide SA 5000
21 December 2007
42213777
J:\J obs \42213777\R eporti ng\Final D ecember 07\Fi nal Report\H eathg ate Mini ng Pr opos al 20071221 F INA L. doc Mining Pr opos al for Proposed E xt ension of Beverl ey Mine
MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Project Manager:
URS Australia Pty Ltd
Level 4 …………………………… 70 Light Square Tim Jarvis Adelaide SA 5000 Associate Scientist
Tel: 61 8 8366 1000 Project Director: Fax: 61 8 8366 1001
…………………………… Vic Farrington Senior Principal Environmental Engineer
Prepared for Heathgate Resources Pty Ltd, 23 November 2007
MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Contents
Contents 1 Introduction ...... 1-1 1.1 A General Description of the Project or Mine ...... 1-1 1.2 Background to the Proposal...... 1-1 1.3 Summary of the Land and Environment Description...... 1-1 1.4 Summary of Existing Operations ...... 1-3 1.5 Summary of Proposed Operations ...... 1-5 1.6 Key Environment Impacts and Management Strategies...... 1-5 1.7 Updated Baseline Studies...... 1-7 1.8 Proposed Post Mine Land Use ...... 1-7 1.9 Mine Closure and Rehabilitation Strategies...... 1-7 2 Detail of Mining Proposal ...... 2-1 2.1 Tenement Name and Number of the Mine ...... 2-1 2.2 Name of the Mining Operation...... 2-1 2.3 Commodity to be Mined ...... 2-1 2.4 Summary of Program ...... 2-1 2.5 Location of the Operation; Direction and Distance from the nearest town...... 2-1 2.6 Land Tenure...... 2-1 2.7 Certificate of Title...... 2-2 2.8 Type of Operation and Other Associated Tenements and Operations ...... 2-2 2.9 Contact Details of Mine Owner and Operator ...... 2-2 2.10 District Council or Corporation ...... 2-2 3 Description of Environment ...... 3-3 3.1 Land Use ...... 3-3 3.2 Amenity...... 3-3 3.3 Noise, Dust and Air Quality...... 3-3 3.4 Local Community...... 3-4 3.5 Climate ...... 3-6 3.6 Geohazards...... 3-6 3.7 Proximity to Housing and Infrastructure...... 3-6 3.8 Topography and Landscape...... 3-7 3.9 Hydrology ...... 3-7 3.10 Geology and Hydrogeology...... 3-8
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Contents
3.11 Vegetation, Weeds and Plant Pathogens ...... 3-10 3.12 Fauna...... 3-13 3.13 Topsoil and Subsoil...... 3-14 3.14 Heritage...... 3-14 3.14.1 Aboriginal Heritage ...... 3-14 3.14.2 European Heritage ...... 3-15 3.14.3 Heritage Management ...... 3-15 3.14.4 National Estate Listings ...... 3-16 3.15 Proximity to Conservation Areas ...... 3-16 3.16 Pre-existing Site Contamination and Disturbance ...... 3-16 3.17 Natural Radioactivity ...... 3-16 3.17.1 Introduction to radioactivity in the Beverley context ...... 3-16 3.17.2 Background and current radiation levels ...... 3-17 4 Description of the Operation...... 4-1 4.1 General Description...... 4-1 4.2 Ore Reserves and Market...... 4-1 4.2.1 Geological Environment ...... 4-1 4.2.2 Reserves and Resources ...... 4-3 4.2.3 Market...... 4-3 4.2.4 Radioactive Substances and Ores ...... 4-4 4.3 Mining Operations ...... 4-4 4.3.1 Type or Types of Mining Operation to be Carried Out ...... 4-4 4.3.2 Sequence of Operation...... 4-5 4.3.3 Modes and Hours of Operation ...... 4-5 4.3.4 Field Equipment...... 4-6 4.3.5 Processing ...... 4-6 4.3.6 Early Mining in the Extended Lease...... 4-6 4.4 Wastes...... 4-10 4.4.1 Drill Cuttings ...... 4-10 4.4.2 Mine Solid Wastes...... 4-11 4.4.3 Low-level Radioactive Wastes...... 4-11 4.4.4 Process Wastes - General...... 4-12 4.4.5 Updated Liquid Waste Disposal Procedure...... 4-14
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Contents
4.4.6 Silt Control and Drainage ...... 4-16 4.4.7 Airborne wastes...... 4-16 4.5 Supporting Infrastructure ...... 4-17 4.5.1 Road Access...... 4-17 4.5.2 Airstrip...... 4-17 4.5.3 Camp Accommodation ...... 4-19 4.5.4 Minesite Support Facilities...... 4-19 4.5.5 Services and Utilities ...... 4-19 4.5.6 Mobile Equipment...... 4-19 4.5.7 Water Supply ...... 4-19 4.5.8 Communications...... 4-19 4.5.9 Visual Screening and Site Security ...... 4-20 4.5.10 Emergency...... 4-20 4.6 Resource Inputs...... 4-20 4.6.1 Workforce ...... 4-20 4.6.2 Energy Sources ...... 4-21 4.6.3 Water Sources...... 4-21 5 Description of Potential Benefits...... 5-1 5.1 Social...... 5-1 5.2 Economic ...... 5-1 5.3 Environmental ...... 5-2 6 Results of Stakeholder Consultation...... 6-1 6.1 EIS stakeholder consultation process...... 6-1 6.2 Extension ML stakeholder consultation process...... 6-1 7 Environmental, Social and Economic Aspects ...... 7-1 7.1 Context and Stakeholder Views ...... 7-1 7.2 Potential Impact Events ...... 7-1 7.3 Applicable Legislation or standards...... 7-1 7.4 Likelihood and Severity of Consequence, Risk...... 7-3 7.5 Control and Management Strategies ...... 7-4 7.6 Desired Outcomes ...... 7-4 7.7 Risks to Achieving Outcomes ...... 7-4 7.7.1 Soil Aspects...... 7-4
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Contents
7.7.2 Vegetation Aspects...... 7-7 7.7.3 Surface Water Aspects...... 7-8 7.7.4 Hydrogeological Aspects ...... 7-9 7.7.5 Fauna Aspects...... 7-10 7.7.6 Radiation Aspects...... 7-12 7.7.7 Heritage Aspects ...... 7-14 7.8 Risk Acceptance ...... 7-15 7.9 Outcomes...... 7-15 7.10 Outcome Measurement Criteria ...... 7-15 7.11 Leading Indicator Criteria ...... 7-15 7.12 Ongoing Community Engagement Plan ...... 7-15 7.13 Native Vegetation...... 7-16 7.13.1 Native Vegetation Management ...... 7-16 7.13.2 Significant Environmental Benefit Compensation ...... 7-16 8 Monitoring Program...... 8-1 8.1 Overview ...... 8-1 8.2 Meteorology...... 8-1 8.3 Landscape (Soils and Vegetation) ...... 8-1 8.4 Fauna...... 8-2 8.5 Surface hydrology ...... 8-4 8.6 Hydrogeology...... 8-5 8.7 Wastes...... 8-6 8.8 Restricted Release Zone ...... 8-9 9 Mine Closure and Rehabilitation Plan ...... 9-11 9.1 Preamble ...... 9-11 9.2 Context...... 9-11 9.3 Stakeholder Involvement and Issues...... 9-12 9.4 Scope and description of closure domain ...... 9-13 9.5 Potential environmental, economic and social impacts of mine closure ...... 9-13 9.6 Desired outcomes...... 9-14 9.6.1 General Outcomes ...... 9-14 9.6.2 Specific Outcomes...... 9-14 9.7 Risks to Achieving Outcomes ...... 9-15
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Contents
9.7.1 Failure of revegetation...... 9-15 9.7.2 Disturbance of waste pits ...... 9-1 9.7.3 Willawortina and Great Artesian Basin aquifers...... 9-1 9.8 Closure strategies (control measures) ...... 9-2 9.9 Closure plan maps and sections...... 9-3 9.10 Residual Risk Assessment ...... 9-3 9.11 Closure Cost Estimate...... 9-3 9.12 Mine Closure Schedule ...... 9-3 10 Management Systems ...... 10-1 10.1 Environmental Management System ...... 10-1 10.1.1 Background...... 10-1 10.1.2 Introduction ...... 10-1 10.2 Environment Policy ...... 10-2 10.3 Planning ...... 10-4 10.3.1 Environmental Aspects and Impacts ...... 10-4 10.3.2 Legal and Other Requirements ...... 10-4 10.3.3 Objectives and Targets...... 10-4 10.3.4 The Environmental Management Program ...... 10-5 10.3.5 Implementation and Operation ...... 10-5 10.3.6 Structure and Responsibility...... 10-5 10.3.7 Training, Awareness and Competence ...... 10-5 10.3.8 Communication...... 10-6 10.3.9 EMS Documentation...... 10-6 10.3.10 Document Control...... 10-7 10.3.11 Operational Control ...... 10-7 10.3.12 Emergency Preparedness and Response...... 10-8 10.3.13 Checking and Corrective Action ...... 10-8 10.3.14 Monitoring and Measurement...... 10-8 10.3.15 Non-conformance and Preventative and Corrective Action ...... 10-9 10.3.16 Records ...... 10-9 10.3.17 EMS Audit...... 10-10 10.3.18 Management Review...... 10-10 10.4 Previous Experience of Operator...... 10-11
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Contents
10.5 Lease Conditions ...... 10-11 10.6 SA EPA 2004 Review ...... 10-11 11 References...... 11-1 12 Limitations...... 12-1
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Tables, Figures, Plates, Drawings Appendices
Tabl es, Figures , Plat es , Drawi ngs A ppendices Appendices
Appendix A: Wooltana Lease
Appendix B: Environmental Studies Summary Report
Appendix C: Oct 2006 Native Vegetation Application
Appendix D: SEB Assessment Report April 2007
Appendix E: Supporting Reports A to F
Supporting Reports
Supporting Report A: Geology of the proposed ML Extension area Supporting Report B: Hydrology of the proposed ML Extension area Supporting Report C: Hydrogeology of the proposed ML Extension area Supporting Report D: Flora of the proposed ML Extension area Supporting Report E: Fauna of the proposed ML Extension area Supporting Report F: Heritage of the proposed ML Extension area
Tables
Table 3-1 Summary of radiation dose statistics for 1st quarter 2007 ...... 3-18 Table 4-1 Expected typical mining solution composition ...... 4-10 Table 4-2 Typical waste water concentrations (2006) ...... 4-16 Table 6-1 Results of Stakeholder Consultation...... 6-3 Table 7-1 Relevant State and Commonwealth Legislation and Codes of Practice ...... 7-2 Table 7-2 Definitions of Likelihood and Severity and or Consequence ...... 7-3 Table 7-3 Risk Assessment Matrix...... 7-3 Table 7-4 Potential Impact Events & Management...... 7-18 Table 8-1 Meteorology Monitoring Program...... 8-1 Table 8-2 Landscape Monitoring Program...... 8-1 Table 8-3 Fauna Monitoring Program ...... 8-2 Table 8-4 Surface Hydrology Monitoring Program...... 8-4 Table 8-5 Great Artesian Basin Well Sampling Program...... 8-5 Table 8-6 Environmental Liquid Waste Monitoring Program ...... 8-6 Table 8-7 Environmental Solid Waste Monitoring Program...... 8-7 Table 8-8 Environmental Airborne Monitoring Program...... 8-8
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Tables, Figures, Plates, Drawings Appendices
Table 8-9 Environmental RRZ Monitoring Program...... 8-9 Table 9-1 Potential Impact Events & Management – Rehabilitation and Closure ...... 9-16 Table 9-2 Conceptual Mine Closure Schedule – Subject to Amendment...... 9-4
Figures
Figure 1-1 Beverley Uranium Mine - location...... 1-2 Figure 1-2 General Arrangement of Beverley Operations...... 1-4 Figure 1-3 Proposed Mineral Lease ...... 1-6 Figure 3-1 Beverley and Surrounds ...... 3-5 Figure 3-2 Regional Geology / Hydrogeology ...... 3-9 Figure 3-3 Vegetation Associations...... 3-11 Figure 4-1 Conceptual geological / hydrogeological model, Beverley ...... 4-2 Figure 4-2 Beverley Process Diagram ...... 4-7 Figure 4-3 ML Extension Orebodies and Prospects ...... 4-8 Figure 4-4 Site Infrastructure...... 4-18 Figure 5-1 Greenhouse Gas Emissions from Electricity Generation ...... 5-3 Figure 8-1 Ecological Monitoring Locations ...... 8-3 Figure 8-2 Hydrology Monitoring Locations...... 8-4 Figure 8-3 GAB bore locations ...... 8-5 Figure 8-4 Current Restricted Release Zone ...... 8-10 Figure 10-1 ISO 14001 Continual Improvement Cycle ...... 10-2 Figure 10-2 Heathgate Resources Environment Policy ...... 10-3
Plates
Plate 3-1 Dust Storm at Beverley...... 3-4 Plate 3-2 Mitchell grass plains at Beverley ...... 3-12 Plate 3-3 Major drainage line vegetation at Beverley (Four-Mile Creek) ...... 3-12 Plate 3-4 Minor drainage line vegetation at Beverley Extension...... 3-13 Plate 4-1 Typical wellhouse and mining area at Beverley...... 4-9 Plate 4-2 Typical trunkline at Beverley...... 4-9
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Executive Summary
E xecuti ve S ummar y This Mining Proposal has been prepared by Heathgate Resources Pty Ltd (Heathgate) to satisfy the requirements of the South Australian Government for assessing the application by Heathgate for an extension to the current Beverley Mineral Lease (ML 6036), and the Commonwealth Government’s requirements for a Public Environmental Report under the Environment Protection and Biodiversity Conservation Act 1999. The intention is to replace ML 6036 with a larger Mineral Lease, which subsumes the existing ML 6036, three existing Miscellaneous Purposes Licences (MPL 57, 58 and 59) and two Retention Leases (RL 18, RL 19). The extended ML will include the existing camps, airstrip, camp bore and associated internal access roads which are now on MPLs. There are no proposed changes to the existing operations at the Beverley processing plant, and no increased production above the existing approved level is sought. The document has been designed to meet the requirements of the process of granting a new Mineral Lease (ML) under the Mining Act 1971, in accordance with PIRSA’s consultation draft advisory document Preparation of a Mining Lease Proposal (Proposal) or Mining and Rehabilitation Program (MARP), Version 4.8 (June 2007), and the guidelines for the Public Environmental Report published by the Commonwealth. This Proposal demonstrates that the proposed ML extension can be undertaken to meet applicable South Australian and Commonwealth requirements, and with no significant impact on the environment.
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
ES-1
MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction
1 Introduction 1.1 A General Description of the Project or Mine Heathgate Resources Pty Ltd (Heathgate) operates the Beverley Uranium Mine in northern South Australia. Mining is by in-situ leach (ISL) methods, and currently produces about 1,000 tonnes (licensed for up to 1,500 tonnes) of uranium (expressed as U3O8) per annum, in the form of uranium oxide concentrate (UOC). A description of the current ISL mining operations at Beverley is provided in Section 1.4. Beverley is located on the arid plains between the North Flinders Ranges and Lake Frome, approximately 600 km north of Adelaide and 300 km north-east of Port Augusta (Figure 1-1). The uranium mineralisation is present in and around an existing 8 km2 Mineral Lease (ML), ML 6036, which is located entirely within the Wooltana pastoral lease (Appendix A). An Environmental Impact Statement (EIS) was prepared in 1998 to satisfy both Commonwealth and South Australian Government requirements, resulting in approval of the ML, an Export Permit, and other related requirements. The proposed development outlined in this Mining Proposal is an extension of the area outside the existing Mineral Lease (ML 6036) in which wellfields may be installed. The intention is to replace ML 6036 with a larger ML, comprising part of Exploration Lease EL 3251, which subsumes the existing ML 6036 and three existing Miscellaneous Purposes Licences (MPL 57, 58 and 59), and also incorporates two Retention Leases (RL 18 and 19). The extended ML will include the existing camps, airstrip, camp bore and associated internal access roads, which are now on MPLs, as well as the existing Beverley processing plant and wellfields on ML 6036. There are no proposed changes to the existing operations at the Beverley processing plant, and no increased production above the existing approved level is sought. The granting of the ML extension will extend the life of the Beverley mine, and allow for continued production of UOC at Beverley. Without the ML extension, the Beverley mine could close within a few years. Based on present resource knowledge, the granting of the ML extension would allow the Beverley mine to continue for many more years.
1.2 Background to the Proposal In accordance with Mining Regulations 42(b), all Mining Leases are subject to a requirement that operations are carried out in an orderly and skilful manner in accordance with an approved Mining Proposal and Mining and Rehabilitation Program (MARP). Heathgate is pleased to present this document to PIRSA to satisfy the Mining Proposal component of the approval process for the proposed extension of the existing uranium mining operations at the Beverley Mine. Since the proposed extension will involve the mining of radioactive ore (uranium), licencing or registration under the Radiation Protection and Control Act 1982 will also apply. As the proposed action is a “controlled action” under the Commonwealth Environment Protection and Biodiversity Conservation (EPBC) Act 1999 (because of the Sections 21 and 22A - nuclear actions), approval is also required from the Australian Government Minister for the Environment and Water Resources.
1.3 Summary of the Land and Environment Description Beverley Mine is located in an arid region of South Australia, on the western boundary of a broad, almost featureless plain approximately 45 km wide lying between the eastern margin of the Flinders Ranges and Lake Frome. The area is characterised by low average, but highly variable rainfall. A series of water courses, rising in the Flinders Ranges, flow in a generally easterly direction (including across the Heathgate site), eventually discharging into Lake Frome.
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction
Figure 1-1 Beverley Uranium Mine - location
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction
Between the Ranges and the Lake, many small flow channels are cut into the topography, rising in the low foothills of the area, at about elevation 100 m AHD, and which also flow in an easterly direction toward Lake Frome. No species presently listed under the EPBC Act are known to occur at Beverley or on the proposed extension area to which this proposal relates. One threatened species, Swainsona oligophylla, which is listed as rare under the National Parks and Wildlife Act, 1972 (NPWA), is known to occur at Beverley. Two previously reported species, Frankenia subteres and Swainsona murrayana, are now considered to be based on misidentifications. Most of the threatened species that are known to occur in the general area are restricted to the Flinders Ranges and are not known to exist on the plains. One proclaimed plant, Tribulus terrestris, has been recorded at Beverley. It is fairly common in the general area but is not recorded in all years. Twenty alien plant species have been recorded at Beverley and a further 10 are known to occur in the general area. None of these occurrences can be directly attributed to exploration or mining activities. The dominant habitat types within the project area are a mixture of gibber plains, very open eucalyptus woodland, tall shrubland and tall shrubland over chenopods. Fauna surveys conducted as part of the Beverley Mine EIS in 1998 identified no species of state or national conservation significance. One notable capture was a Pseudomys hermannsburgensis (Sandy Inland Mouse), which is listed as rare in the NPWA. This represents a range extension for this species of over 80 km. The annual fauna monitoring survey that occurs at the Beverley Mine site has recorded an additional two bird and three reptile species, none which are considered to be of conservation significance. Hydrogeologically, the mine and proposed extension area are located within the western Frome Embayment region where groundwater occurs in several aquifer systems separated by aquitards. Water use for the Beverley mine comes from two sources: groundwater from the Namba Formation aquifer, which is largely recycled throughout the ISL process; and groundwater from the Great Artesian Basin (GAB), which is utilised for potable, plant and camp use. Groundwater from the Namba Formation aquifer within the Beverley mineralised zone is saline, with Total Dissolved Solids up to 15,000 mg/L, and contains naturally occurring radioactive uranium and radium at many times drinking water limits. It is therefore entirely unsuitable as potable water, and the radioactivity renders it unsuitable, now and in the future, for agriculture or stock watering purposes. Higher quality groundwater is found in both the underlying GAB and in part of the overlying Willawortina Formation, which is and will remain both suitable and available for stock and other uses.
1.4 Summary of Existing Operations The Beverley Uranium Mine is capable of producing about 1,1000 t/a uranium as UOC by the ISL method, however the current production is approximately 800 t/a. The current production target for Heathgate is 800-1000 t/a UOC (approximately 1.8 – 2.4 million pounds of uranium per annum). The export authority is for 1,500 t/a (as U3O8), and it is possible that the production from the new ML may be increased to that in the future. ISL is a mining method that is applicable to uranium ore-bodies that present in aquifers and have suitable geological and other conditions. ISL mining removes uranium from the host ore without the physical removal of ore and covering soils and rocks. It requires installation of multiple close-spaced wells into the aquifer, pipelines to and from the wells and a surface treatment plant, and does not require either underground mine workings or open cut pits. In the ISL process, natural groundwater from the mineralised zone of the aquifer is conditioned by adding an oxidant (e.g. hydrogen peroxide or ferric chloride) and dilute sulphuric acid, which after conditioning is called mining solution. This mining solution is then pumped via multiple injection wells back into the aquifer, where it dissolves the uranium contained in the aquifer. The resulting uranium-rich solution is pumped back to the surface via multiple extraction wells, to a uranium recovery plant. The general arrangement of the Beverley operations is shown in Figure 1-2.
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction
At the plant, uranium is stripped from the uranium-rich mining solution using ion exchange resin beads and held for later precipitation, drying and packaging. The barren solution is reconditioned (back to mining solution specification) and recycled back to the injection wells. Within any given area, this cycle continues until the uranium remaining in the aquifer is depleted to uneconomic levels. A group of multiple injection and extraction wells is called a wellfield. Control of the flow of mining solution through the aquifer is maintained through careful design and operation of the wellfield, adjusting the pressures in each extraction well to direct the fluid to required areas. This ensures continuous recycling within the active mining area, and minimises potential for leakage of mining solutions outside the active mining area (excursions). A small amount of liquid waste is produced through this process which is reinjected in unused or mined out sections of the Namba Formation aquifer. A small amount of solid waste (radioactive and non- radioactive) is also produced and is buried in purpose-built near surface facilities that meet the requirements of the Radiation Protection and Control Act 1982 (SA), in particular as set out in the ARPANSA Code Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing (2005). Other relevant legislation and Codes of Practice are listed in Table 7-1. Figure 1-2 General Arrangement of Beverley Operations
Extraction of uranium may be conducted over a number of phases to maximise the total amount extracted (only about 70% is extracted in the first phase). After the final phase has been completed, the wellfield will be closed and rehabilitated. ISL mining is a relatively low impact mining method, since ore is not mined in the conventional sense. There is minimal surface disturbance, no overburden removal, no ore treatment facility, no tailings generation nor disposal requirements. It requires a simple recovery plant that can be removed on completion of mining, and simple surface rehabilitation once a wellfield has completed its final operational phase. No rehabilitation of wellfields is being undertaken at this time, as further ISL mining may be undertaken in future phases, subject to the price of uranium, and also to meet operational needs of desired minimum
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction average uranium grade in process liquors. However, owing to the low disturbance impact of ISL mining, the final rehabilitation of wellfields is not a major exercise. The existing mine is operated 24 hours per day, 365 days per year on a fly in-fly out basis. There is a camp that accommodates about 150 people, an airstrip and other associated infrastructure located in three Miscellaneous Purposes Licences (MPL 57, 58 and 59 respectively), to the west of ML 6036 (refer Figure 1-3; also Figure 4-4). 1.5 Summary of Proposed Operations The development proposed is an extension of the area (outside the existing ML 6036) in which wellfields may be installed. No changes to existing infrastructure or processes at the Beverley operations within ML 6036 are proposed, with the exception of the location and length of trunklines that transport fluids between the plant and the wellfields. The proposed extended ML area is shown in Figure 1-3. The proposed extended ML comprises part of the Paralana Exploration Lease EL 3251, plus two adjoining Retention Leases (RL 18 and RL 19) on the southern boundary of EL 3251, and incorporates the existing Beverley ML 6036. The new ML will also incorporate three existing Miscellaneous Purposes Licences (MPL 57, 58 and 59), which include the camp, airstrip, camp bore and associated internal access roads. However, there are no proposed changes to the existing operations at the Beverley processing plant, and no increased production above the existing approved level is sought. The proposed actions in the areas outside the existing approved ML 6036 will include:
• Work area clearance surveys (Aboriginal heritage surveys);
• Drilling and logging;
• Well installation;
• Wellhouse construction;
• Installation of power communications and pipe work to wells and wellhouses;
• Rehabilitation of delineation holes; and
• Ancillary related activities. 1.6 Key Environment Impacts and Management Strategies The following environmental topics have been identified as requiring assessment with respect to the proposed ML extension.
1. Surface hydrology 2. Hydrogeology 3. Landscape (soil and vegetation) 4. Landscape (amenity) 5. Flora, including weeds and plant pathogens 6. Fauna 7. Radiation Management 8. Non-radioactive Waste 9. Chemical Management 10. Heritage Management and Community Liaison 11. Rehabilitation. 12. Air Quality 13. Noise and Vibration.
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction
Figure 1-3 Proposed Mineral Lease
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction
The risk assessment criteria outlined in the Guidelines for the Preparation of a MARP document (PIRSA 2007) have been applied to the proposed ML extension activities, in relation to these topics. A description of this risk assessment methodology, and the proposed control and management strategies to reduce the potential identified environmental impact events, has been set out in Section 7. The strategies for managing issues involve the implementation of technically and economically achievable best practice mining and environmental management techniques, including progressive rehabilitation where applicable and practicable. Control and management strategies detail one or more of the following:
• A change in design or procedures to avoid or reduce the likelihood of the impact occurring.
• A change in design or procedures to avoid or reduce the consequences of an event, should it happen.
1.7 Updated Baseline Studies To accompany this application, Heathgate undertook priority environmental impact assessment studies of the proposed extended ML area during 2006. The objective of these studies was to document the environmental characteristics of the extended ML area, to compare environmental conditions to the current Beverley operational area and to note updated information since the development of the original mine EIS (Heathgate Resources 1998). The following six environmental impact assessment studies, deemed to be of key priority to support the ML application, were undertaken during the period of March to November 2006: A Geology;
B Hydrology;
C Hydrogeology;
D Flora;
E Fauna; and
F Heritage.
These six reports are provided with this submission as Supporting Reports A to F. A Summary Report is also attached, as Appendix B to this application. The other key environmental aspects addressed in the 1998 EIS were in relation to visual amenity, socio- economic impacts, radiation, transport and climate. It is considered that the issues in relation to these aspects would be essentially unchanged for the proposed wellfields operations in the extended ML area. 1.8 Proposed Post Mine Land Use The long-term objective for rehabilitation is the return the landscape at the Beverley site to pastoral activity.
1.9 Mine Closure and Rehabilitation Strategies The long-term objective for closure and rehabilitation of the proposed ML extension is the return the landscape to a moderately stable soil surface carrying a self-maintaining set of plant communities dominated by grasslands, with no major surface hydrological alterations, and minimal acceleration of natural erosion processes, and which is suitable for pastoral activity.
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
1-7
MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 1 Introduction
The primary outcomes for the proposed ML extension closure and rehabilitation are: the closure of wells; the removal/disposal of trunklines and supporting infrastructure such as fences and tracks and the return of the landscape as described above. Heathgate intends to undertake the decommissioning and rehabilitation of the existing and the proposed ML areas. As surety, a bond that is adequate to cover the cost of decommissioning and rehabilitation has been provided to the South Australian government, and this bond will be maintained in accordance with PIRSA requirements. As noted above, extraction of uranium may be conducted over a number of phases to maximise the total amount extracted. After the final phase has been completed, the wellfield will be closed and rehabilitated. The timing of future phases is subject to the price of uranium, and also to meet operational needs. At the conclusion of mining operations, any remaining ponded process solutions would be treated and disposed of in accordance with the relevant regulations. Once this is accomplished, all remaining wells and the processing plant will be decommissioned. Heathgate proposes an initial period of five years from the conclusion of commercial operations to complete the decommissioning of facilities. A monitoring and maintenance program is proposed to run for a further two years, for a total of seven years from the final conclusion of mining activities. Facilities will therefore be fully decommissioned within seven years from the conclusion of the commercial operation. This period includes a post-completion monitoring period for vegetation maintenance, groundwater sampling, drainage repairs, and other activities to ensure the long-term permanent rehabilitation of the site. Rehabilitation of temporary access tracks and other temporary infrastructure will therefore be completed as soon as possible after the conclusion of mining operations. Details of the rehabilitation requirements in these instances are included as part of the environmental clearance permits issued prior to commencement. No active remediation of the Namba Formation aquifer is proposed. Monitoring results trending towards a pH of 4.5 or higher is considered to have demonstrated that attenuation is occurring as expected and is satisfactory in terms of mine closure. It is noted that owing to the salinity and presence of metals and radionuclides, the only potential beneficial use for the Namba Formation water, without treatment, is for mining purposes1.
1 The minutes of Technical Working Group Meeting Strategic Review Of Liquid Waste Disposal For Beverley Uranium Mining meeting 26 September 2006 record “that there are ‘no environmental values related to the Beverley Aquifer’. However short term impacts must be controlled for both mining efficiency and for minimising long-term impacts.”
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 2 Detail of Mining Proposal
2 Detail of Mining Proposal 2.1 Tenement Name and Number of the Mine The uranium mineralisation is present within an existing 8 km2 Mining Lease (ML 6036), Retention Leases (RL 18, RL 19) and the Paralana Exploration Lease (EL 3251) (Figure 1-3), and is located entirely within the Wooltana pastoral lease (Appendix A). The intention is to replace ML 6036 with a larger ML, comprising part of EL 3251, which subsumes the existing ML 6036 and three existing Miscellaneous Purposes Licences (MPL 57, 58 and 59), and also incorporates two Retention Leases (RL 18 and 19). The proposed extended ML is shown in Figure 1-3; the coordinates and boundaries are in conformance with the existing Mineral Claim. 2.2 Name of the Mining Operation Beverley Uranium Mine. 2.3 Commodity to be Mined Uranium.
2.4 Summary of Program The proposed development outlined in this Mining Proposal is an extension of the area outside the existing ML 6036 in which wellfields may be installed. No changes to existing infrastructure or processes at the Beverley operations within the area of the existing ML 6036 are proposed, with the exception of the location and length of trunklines that transport fluids between the plant and the wellfields. Heathgate intend to undertake ISL mining in the proposed area as soon as is practicable after approval is granted to commence mining. The granting of the ML extension will extend the life of the Beverley mine, and allow for continued production of UOC at Beverley. Without the ML extension, the Beverley mine could close in 2009. The granting of the ML extension would allow the Beverley mine to continue for some 15 additional years, based on present resource knowledge; however, with continued exploration and ore resource definition this could be extended.
2.5 Location of the Operation; Direction and Distance from the nearest town The Beverley Uranium Mine is located between the Northern Flinders Ranges and Lake Frome, approximately 600 km north of Adelaide and 300 km north-east of Port Augusta. The closest communities include the tourist resort village at Arkaroola (some 30 km to the South-West) and the Aboriginal community at Nepabunna (approximately 80 km South-West) (refer Figure 3-1). 2.6 Land Tenure The existing Mining Lease (ML 6036) and the Paralana Exploration Lease (EL 3251) is located entirely within the Wooltana pastoral lease. The Wooltana pastoral lease is owned by Heathgate. The surveys of Adnyamathanha cultural heritage matters pertaining to the present ML 6036, and the proposed extended ML, are undertaken by Adnyamathanha representatives who have been selected by named Native Title applicants. The applicants are generally considered by their peers to be most closely associated with the Wooltana Pastoral Lease and knowledgeable about its cultural amenity. This is the preferred approach of the body representing the Native Title claimants for the area.
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Section 2 Detail of Mining Proposal
2.7 Certificate of Title Wooltana Crown Lease Volume 1289 Folio 38 (Appendix A). 2.8 Type of Operation and Other Associated Tenements and Operations The Beverley Mine is an in-situ leach (ISL) uranium mining operation. Heathgate and its sister company, Quasar Resources Pty Ltd, are also conducting uranium exploration operations on the Paralana EL and on surrounding ELs that are held in joint venture with various other companies.
2.9 Contact Details of Mine Owner and Operator Owner and operator: Heathgate Resources Pty Ltd Address: Level 9, 45 Grenfell Street, Adelaide SA 5000 Contact person: Richard Phillips - Managing Director, Operations Phone: (08) 8110 0500 Fax: (08) 8212 5559 Mobile: 0419 866 862
2.10 District Council or Corporation The Wooltana pastoral lease is out of Hundreds, and is not within a District Council or Corporation area. The Outback Areas Community Development Trust provides services to the region that may otherwise be undertaken by a Council.
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Section 3 Description of Environment
3 Description of Environment 3.1 Land Use The proposed ML is situated entirely within the Wooltana pastoral lease (Wooltana Station) which is owned by Heathgate (Figure 3-1). The primary land use is pastoral, currently cattle grazing for beef production but previously sheep grazing for wool production. The land has been used for pastoral purposes continuously since the 1870s. ML 6036 and the associated MPLs have been fenced to prevent access by stock to mining and accommodation areas. Wooltana lease areas that are not involved with mining are sub-leased to another party for pastoral use. Issues related to water supply, fencing, stock control and roads are discussed with the lessees on a co-operative and ongoing basis. The Flinders and Outback Region is a key tourist area within South Australia with potential to expand its tourism industry. A significant element in tourist attraction to the Flinders Region is the sense of wilderness conveyed by open and largely uninhabited spaces. The incremental development of the Beverley operation will have negligible impact on tourism. The operations are effectively unchanged from those being undertaken at present. Over the life of the mine, the modest size of the overall project (for instance compared with the Leigh Creek coalfields, located at a similar latitude but on the western side of the Flinders Ranges) plus the modest scale of plant and buildings, and the small numbers of traffic movements associated with it, will produce a very minor overall surface impact. It is anticipated that the future land use (post-rehabilitation) of the current and proposed ML areas will be for pastoral activity, in particular cattle grazing. Accordingly, appropriate measures are taken not to adversely impact on the integrity of the Willawortina aquifer, which has been used for stock watering. 3.2 Amenity The main opportunity for viewing the mine site by tourists and visitors to the region arises when travelling the Balcanoona-Moolawatana Road, which is some 5 km distance at the closest point (Figure 3-1). Despite the small probability of adverse visual impact, buildings and infrastructure are designed to blend in with the surrounding landscape. From the Flinders Ranges (Sillers Lookout), the mine is barely detectable to the naked eye. At night, lights can be seen from both the Balcanoona-Moolawatana Road and Sillers Lookout. Given that the beauty of the Flinders Ranges is appreciated during daylight hours, the use of lights at night at Beverley is not regarded as a significant negative impact. In any event, the overall visual impact is no more significant than structures normally associated with a pastoral station. It is anticipated that the proposed developments will have negligible additional impact on the visual aesthetics of the area.
3.3 Noise, Dust and Air Quality No specific noise monitoring has been collected for the project area. However, no significant, permanent man-made noise sources are located near the project area. Wind blowing over vegetation is the only noise source. The nearest sensitive noise receptor to the mining operation is North Mulga outstation which is located 10 km east of the project area. This outstation is occupied approximately 6 months per year. Particulate matter (dust), as the result of wind is likely to be the most significant natural impact on air quality. For example, Oodnadatta, an arid site north-west of Beverley, experiences on average five dust storms annually (Arid Areas Catchment Water Management Board 2006). This frequency is related to lack of ground cover and major dust storms have been recorded after periods of drought. High wind levels are likely to exacerbate dust generation and lead to an increase in the concentration of airborne dust. An example of a dust storm at Beverley is shown in Plate 3-1.
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Section 3 Description of Environment
Plate 3-1 Dust Storm at Beverley
High-volume dust sampling to check radionuclide content is undertaken at the Beverley camp as part of the Radiation Management Plan. The weighted average of four years of data (June 2003 to August 2003 was 0.13 mg/m3 (range 0.02 to 0.40 mg/m3). This includes the effects of the mining operations, including the movement of vehicles (note that the radiological impact is not significant). Similarly, dust deposition has been measured at four compass points near the boundary of the current ML since 2005. The average, maximum and minimum daily dust deposition rates (from quarterly composites) are 118, 319 and 22 mg/m2/d respectively. These compare to rates of 49 mg/m²/d and 46 mg/m²/d attributed to background measurements near Olympic Dam during the 1 January to 31 December 2004 reporting period by Termite Resources (2007). Vehicles and the existing Beverley operations are the only anthropological sources of other emissions to air in the area. These emissions would include minor amounts of nitrogen oxides, carbon monoxide and particulates.
3.4 Local Community The closest communities include the tourist resort at Arkaroola and the Aboriginal community at Nepabunna (Figure 3.1). A total of some 50 permanent residents live within a 50 km radius of the Beverley Uranium Mine site. This figure includes staff at the Arkaroola tourist facilities and Wooltana Station, each some 30 km distant. The actual population at Arkaroola varies with tourist demand. The North Mulga outstation of Wooltana Station is located 10 km east of Beverley and but is only occupied for approximately 6 months per year. Small numbers of people reside the former homestead of Balcanoona that is now the Vulkathunha- Gammon Ranges National Park headquarters (45 km south-west).
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The Aboriginal communities of Nepabunna and Iga Warta are approximately 80 km from the Beverley site, on the western side of the Gammon Ranges (Figure 3-1). These communities are within Aboriginal Lands and operate as self-contained settlements. The population is currently estimated to be about 120 persons, but it fluctuates with the movement of residents to and from the townships. Leigh Creek, some 150 km to the west, is the nearest significant township and service centre. Beverley employees are generally flown to the site from Adelaide and Port Augusta on a regular company aircraft service, and flown back for rest-days. All employees are housed at the camp on the Beverley site. Emphasis is placed on hiring local personnel, with most operational staff coming from Nepabunna, Iga Warta, Leigh Creek, the Iron Triangle region and Adelaide. Beverley contributes over $1.5m/year in Aboriginal Royalties, Administration & Community payments, $2.2m/year in State Royalties, Taxes, Fees & Licenses, and about $25m/year to regional and state businesses/suppliers. Heathgate strives to achieve 20% Aboriginal employment at the mine site by providing employment opportunities for Aboriginal people from the Flinders Ranges. At the end of December 2006 the percentage of local area Aboriginal employment was at 22.2%2, however this figure may vary from month to month. Figure 3-1 Beverley and Surrounds
2 With respect to non-professional site-based positions.
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3.5 Climate The proposed ML extension is located in an arid region of South Australia, adjacent to the Northern Flinders Ranges and in their rain shadow. The area is characterised by low, but highly variable, average rainfall. Meteorological data is collected continuously at the Beverley weather tower. Wind speed and wind direction are collected at heights of 3 m, 20 m and 28 m, and are recorded every 30 minutes using a continuous data logging system. Using data from the weather station at Beverley, the most common winds in the area are from the south-south west and the south. These two directions account for nearly 31% of wind direction time. The predominance of southerly and south westerly winds persists though the year, regardless of season. Wooltana station homestead and Arkaroola are the closest rainfall recording stations to the Beverley site (Figure 3-1). Mean annual rainfall at Wooltana at the foot of the Ranges is 192 mm ( median is only 164 mm) and at Arkaroola within in the Ranges the mean and median rainfall are 251 mm and 212 mm respectively. There is a one-year-in-ten expectation of an annual total less than 80 mm. Rainfall data is collected at the Beverley meteorological station using a tipping bucket, and recorded every hour. Five full years of rainfall data are available (2002 – 2006). The average of these five years is 93 mm; however, the length of record is not sufficient to consider this the average rainfall of the site. Based on its location in the rain shadow of the Ranges the average rainfall of the proposed mining lease can be estimated at approximately 150 – 200 mm/yr.
For November to March, mean maximum temperatures exceed 30°C, and daily temperatures may exceed 40°C. Summer mean minima are around 20°C. Mean maximum temperatures are lowest for June and July, around 15°C. Mean minimum temperatures are <10°C, with <0°C daily minima recorded. Frosts are frequent, although actual white frosts appear less frequently because of the dryness of the air. Average annual evaporation for the region ranges from around 2500 mm near Yunta to the south, to over 3700 mm to the north east at Moomba. Evaporation is measured at Beverley using an evaporation pan located adjacent to the weather tower, with a precision level meter linked to the weather station that logs every 24 hours. The five-year average (2002-2006) is 3,645 mm/yr, but this has occurred during below- average rainfall. The estimated average evaporation for the Beverley site, based on regional trends, is likely to be above 3000 mm. 3.6 Geohazards Since the June 1998 EIS, the Australian Standard (AS1170.4 – 1993) Minimum design loads on structures Part 4: Earthquake Loads has been updated in draft form (by David Love, PIRSA Senior Seismologist). URS sighted this draft standard and confirmed that the statements made in the June 1998 EIS remain valid. Seismic risk is addressed in detail in the 1998 EIS (EIS Section 6.4 and EIS Appendix 3). An overview is also presented in a report on the geology of the proposed ML extension area, which is provided in Supporting Report A. The possibility of an earthquake destabilising the mine site has been quantified based on data from AGSO. The Beverley area has a similar (but lower) seismic risk to Adelaide and appropriate design criteria are being utilised. The risk of serious disruption to Beverley project operations is very low, for the expected additional 15 year period of operations. The low relief on the project area and the depth of the natural free-standing water table at 16 m AHD means infrastructure foundation conditions will be stable. 3.7 Proximity to Housing and Infrastructure The area is remote and sparsely populated. Section 3.4 describes the nearest communities. Other infrastructure within the proposed mining lease is owned by Heathgate Resources as part of Wooltana Station, including fencing, grids, water supply bores and water tanks.
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Section 3 Description of Environment
Due to the nature of ISL mining, it is anticipated that the proposed development will have negligible additional impact in terms of dust, noise and damage to flora and fauna. 3.8 Topography and Landscape Beverley lies towards the western boundary of a broad, almost featureless plain approximately 45 km wide lying between the eastern margin of the Flinders Ranges and Lake Frome. The Ranges rise abruptly on the western margin of the plain to about 600 m above sea level, falling to between 100 m to 60 m over the proposed Mining Lease, then to the lowest elevation of +0.5 to -3.0 m above seas level at Lake Frome some 35 km south east. The terrain consists of four main landforms:
• Level to moderately steeply sloping stream channels rising on the High Plain and discharging on to the Low Plain,
• Flat to very gently sloping slightly elevated areas adjacent to drainage,
• Gently to steeply sloping dissection slopes of the High Plain, and
• Gently sloping, broadly rounded foot slopes and interfluves of the second-order and streams forming the lower margins of the High Plain.
Additional information on topography (including elevation contours) and landscape is provided in Supporting Reports A (geology) and B (hydrology) and the original 1998 Beverley Environmental lmpact Statement. 3.9 Hydrology The proposed ML lies adjacent to and is crossed by a number of watercourses, the majority of which carry water very rarely but are subject to occasional high volume flows. The area is characterised by highly variable but low average rainfall (Section 3.5). These watercourses flow in a general west to east direction, receiving runoff either from catchments on the western portion of the High Plains or, in the case of the major streams, from the Flinders Ranges, and drain to Lake Frome. The following information is summarised from Supporting Report B (Paralana and Mulga Creeks) and the 1998 EIS (4-Mile and Jenny Creeks; Tonkin and Associates 1998). Figure 3.3 (Vegetation Associations) in Section 3.11 shows the local drainage and creeks. The largest of these watercourses is Four Mile Creek, which has a catchment area of approximately 100 km2. The main creek bed skirts the northern boundary of the existing ML 6036. An outwash fan is present on the southern side of Four Mile Creek indicating high water level during flooding. The unofficially named Jenny Creek is formed from three watercourses (or washes) that cross the site. Jenny Creek has a catchment of approximately 8.6 km2. To the south, beyond the proposed ML boundary, Paralana Creek drains a significant catchment which rises in the Ranges. As it travels generally beyond the southern boundary of the proposed ML, it branches at a point near the Paralana Outstation, with one branch flowing to the southeast, and a second to the northeast. This branch enters the proposed ML near the south-eastern corner, joining with Mulga Creek, prior to discharging across the eastern boundary of the proposed ML and flowing toward Lake Frome. Within the proposed ML, Mulga Creek rises along the western boundary in a series of small channels spread from south to north across the area. These various branches gradually join together in a series of increasingly larger streams, which become wider as they reach the flatter land toward the eastern side of the proposed ML. The two main drainage systems in the southern portion of the proposed ML, Paralana Creek and Mulga Creek, were determined to have catchments of 208 km2 and 47 km2 respectively. It should be noted
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Section 3 Description of Environment however that these catchments have many tributaries and smaller drainage lines that combine to form the larger system. In assessing the impact of predicted flood risk on potential operations within the floodplain, recognition must be made of the likelihood of a flood event occurring. For example, if activities are to be located within a floodplain for a relatively short period (up to a few years), such as is the case for piping and extraction equipment associated with individual wellfields for the ISL process, a lower flood standard may be considered to be appropriate. Over a 12–month period, the probability of operations within the 100 year floodplain being inundated is 1%, while within a 1 in 10 year ARI floodplain it is 10%. Operational facilities that are to remain in one place for a much longer period, however, would be exposed to a higher level of probability of inundation if located within a floodplain. This could be the case for main connecting pipelines or other infrastructure that may stay in place for some years. Within a 1 in 100 year floodplain, a facility with a 15 year life would have a probability of 14% of being inundated, which although still unlikely, is clearly higher. Consideration of risk should also be tempered with consequence of inundation. Flow velocities within the floodplain, be it either the 1 in 10 year or 1 in 100 year ARI floodplain, are relatively low - generally 1 m/sec or less. Provided the design of equipment is able to sustain flow of such a velocity, location of certain equipment within the 1 in 10 year floodplain for relatively short periods (up to a few years) could be considered appropriate, with more long-term equipment located beyond the 1 in 10 year ARI floodplain. All infrastructure will be installed above the 1 in 100 year flood level, where possible. Additional information on hydrology is provided in Supporting Report B and in Tonkin and Associates (1998). 3.10 Geology and Hydrogeology The Beverley Uranium Deposit consists of mineralisation within the upper portion of the Namba Formation (Figure 3-2). The Namba Formation comprises uncemented sand, clay and silt. The overlying Willawortina Formation comprises uncemented inter-laminated clays, sands and gravels. Thin surficial beds of younger Quaternary sediments overlie the Willawortina Formation. The Alpha mudstone, the lower part of the Namba sequence, is a thick, hard and continuous black clay capable of preventing the escape of water or mining fluids downwards. The Eyre Formation, which is below the Namba and is discontinuous in the region, comprises clayey sands. The Bulldog Shale, below the Eyre Formation, regionally confines the Cadna-Owie aquifer. The hydrogeology in the vicinity of the Beverley Mine consists of three main aquifers (see Figure 3-2):
• Willawortina Formation (surface to ~95 m below ground level (bgl))
• Beverley Sands in the Namba Formation (105 – 140 m bgl)
• Great Artesian Basin (GAB) – Cadna-Owie Formation (330 – 380 m bgl).
The Willawortina Formation comprises a number of thin aquifers of low water yield, separated by clay layers. Where water is present, the quality is suitable for general stock use. At Beverley, pumping tests associated with trials indicate there is no connection with the Namba Formation aquifer. The Namba Formation comprises the Beverley Clay, the Beverley Sands and the Alpha Mudstone (Clay). The Beverley Sands are sealed between the two clay units.
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Section 3 Description of Environment
Figure 3-2 Regional Geology / Hydrogeology
The Cadna-Owie Formation is the only GAB aquifer present in the area to the west of Lake Frome. The Cadna-Owie Formation is capped regionally by the Bulldog Shale (Marree Subgroup). The vertical separation between the GAB and the Beverley Namba Formation aquifer horizon exceeds 100 m at Camp Bore. Water use for the Beverley mine comes from two sources: groundwater from the Namba Formation aquifer, which is largely recycled throughout the ISL process; and groundwater from the GAB, which is utilised for potable, plant and camp use. Groundwater in the Beverley mineralised zone is saline, with Total Dissolved Solids up to 15,000 mg/L, and contains naturally occurring radioactive uranium and radium at many times drinking water limits. It is therefore entirely unsuitable as potable water, and the radioactivity renders it unsuitable, now and in the future, for agriculture or stock watering purposes. The much higher quality groundwater in both the underlying GAB and in part of the overlying Willawortina Formation is and will remain both suitable and available for stock and other uses. The interpreted water flows are shown in Figure 3-2. The principal natural loss mechanism for the high pressure aquifer, the Cadna-Owie unit of the GAB, is by seepage through the confining Bulldog Shale to overlying aquifers. Seepage plus upward leakages along faults into the overlying Eyre Formation and Namba sands pass upwards into shallower aquifers and, eventually, to evaporation. The Flinders Ranges fractured rock aquifers discharge into the Ranges creek system, and may leak across the Paralana fault zone, where they discharge into either the Eyre Formation sedimentary aquifer or into deeper basement fractured rock zones. Additional information on hydrogeology is provided in Supporting Report C.
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Section 3 Description of Environment
3.11 Vegetation, Weeds and Plant Pathogens There are three principal vegetation associations on the existing and proposed Beverley mining leases:
• Mitchell grass plain
• Major drainage lines
• Minor drainage lines. The distribution of the identified vegetation associations across site are shown in Figure 3.3. Plates 3.2 to 3.4 illustrate the vegetation associations of the area. The main site land cover (Mitchell grass plains) is perennial Mitchell grassland (Astrebla pectinata) with a very high component of Bassias and Sclerolaena species. Slopes and shallow drainage lines (minor drainage line association, such as Jenny Creek) have a tall shrubland cover of Eremophila or Acacia species. It should be noted that the series of dry years experienced at Beverley leading to 2006 have lead to the natural demise of much of the Mitchell grass on the plains; as described in the surveys given in Supporting Report D, Astrebla pectinata cover values reached a maximum of 13.2% cover in 2000 declining to 1.8% in 2005 (Table 3 of Supporting Report D, for historic monitoring at the existing Beverley operations). Small Chenopods such as Sclerolaena are currently the most common plants on the plains. Four Mile Creek is an example of the major drainage line association with a fringing woodland of red gum Eucalyptus camaldulensis and Teatree Melaleuca along major channels. A very open tall shrubland of Acacia victoriae is present on the lower levels of floodplains. Higher levels of floodplains, as well as outwash areas, have a low very open shrubland of cottonbush Maireana aphylla or other similar chenopod shrubs, interspersed with Mitchell grass. A further vegetation survey was conducted in 2006. A copy of this report is provided in Supporting Report C. This survey found that no species listed under the EPBC Act are known to occur at Beverley or on the proposed ML area. One threatened species, Swainsona oligophylla, which is listed as rare under the National Parks and Wildlife Act, is known to occur at Beverley. Two previously reported species, Frankenia subteres and Swainsona murrayana, are now considered to be based on misidentifications. Most of the threatened species that are known to occur in the general area are restricted to the Flinders Ranges and are not known to exist on the plains. One proclaimed plant, Tribulus terrestris (common names include Caltrop, Cat-head, Catshead), has been recorded at Beverley. It is fairly common in the general area and is not recorded in all years. Twenty alien plant species have been recorded at Beverley and a further 10 are known to occur in the general area. None of these occurrences can be directly attributed to exploration or mining activities. It is proposed that the current procedures at Beverley will be extended to the proposed ML area to prevent any adverse vegetation impacts from new wellfield development. No changes to the approach of the Environment Management and Monitoring Plan are considered necessary for vegetation management in the proposed ML. The EMMP will be updated as part of the Mining and Rehabilitation Program (MARP) update that must be approved before operation can commence on the extension to the ML and will document all routine monitoring sites on ML 6036 (existing EMMP) and the extension area (as set out in Supporting Report D).
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Figure 3-3 Vegetation Associations
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Plate 3-2 Mitchell grass plains at Beverley
Plate 3-3 Major drainage line vegetation at Beverley (Four-Mile Creek)
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Plate 3-4 Minor drainage line vegetation at Beverley Extension
3.12 Fauna Prior to mining operations commencing, fauna surveys for small terrestrial mammals, reptiles, amphibians, larger mammals, feral animals and birds were conducted. Results of these were presented as part of the 1998 EIS process. These surveys found that no species presently listed under the EPBC Act are known to occur at Beverley or on the proposed ML area. A further fauna survey was conducted in the southern half of EL 3251 in March 2006. A copy of this report is provided in Supporting Report D. A total of nine sites representing four different habitat types were surveyed for fauna species following a standard biological survey methodology developed by the Department for Environment and Heritage (Owens 2000). The major findings of the survey were:
• Mammals - a total of 147 observations of 20 mammal species were made, of which only four are considered to be introduced.
• Reptiles - a total of 84 observations of 24 reptile species were made, all of which were native species. No amphibian species were observed however little suitable habitat was observed within the project area.
• Birds - a total of 892 observations of 48 bird species were made, with only one of these an introduced species.
• No species of state or national conservation significance were observed during the survey. However, one notable capture was a Pseudomys hermannsburgensis (Sandy Inland Mouse). This record (voucher specimen lodged with the South Australian Museum) is a range extension for this species of over 80 km.
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The annual fauna monitoring at the Beverley Mine site, which resurveys the trapping has recorded an additional two bird species and three reptile species which were not recorded by Gunninah or during the current fauna survey. None of the additional species are considered to be of conservation significance. The habitats and environmental features on the Beverley site and those in the general vicinity are neither unique nor restricted in extent. Those habitats present are represented in regional conservation reserves. It is proposed that the current measures at the Beverley site would be applied to the proposed ML area to prevent any adverse fauna impacts from new wellfield development. No changes to the Environment Management and Monitoring Plan are considered necessary for the proposed ML.
3.13 Topsoil and Subsoil Soil surface material varies from boulders and cobbles in a sandy matrix, through gravels and sands to silts and clays. The quartz, quartzite and granite gibbers found on many of the flatter surfaces occur mainly on scald areas with little vegetation. In these areas much of the surface soil has been removed by deflation. The resulting hardpan surface has a low permeability, but is quite resistant to water erosion. Generally, the soils are of relatively high strength throughout the area. They are however susceptible to loss of strength when wet. This particularly applies in the soils with surficial Gilgai structures. Further information is provided in Supporting Report A. 3.14 Heritage
3.14.1 Aboriginal Heritage As part of the 1998 EIS process, anthropological and archaeological investigations in conjunction with the Native Title claimants were undertaken in 1997 within the Mining Lease and Miscellaneous Purpose Lease areas. No areas requiring specific avoidance or behavioural restrictions were identified at this time on the current ML with the exception of a small depression with comparatively larger vegetation than the surrounding area near Four Mile Creek that was considered to be of significance. This is located mostly within the current ML but also partially within the proposed lease area. On the plain lands covering most of the proposed lease area, artefacts were found to be very scarce. One artifact was however found near Jenny Creek. No sites on the proposed development area were however identified as requiring entry on the South Australia Register of Aboriginal Sites. A further Aboriginal Cultural Heritage Study of the proposed extended ML area was undertaken by Bob Ellis in 2006 (Ellis B, 2006). The resultant report identifies and addresses the Aboriginal Cultural Heritage matters which arise in the study area. A copy of this report is provided in Supporting Report E. The Ellis 2006 Aboriginal Cultural Heritage Study relied upon information collated as a result of a series of separate Cultural Heritage inspections and reports produced since 1999; and the application of a methodology for continuing assessment of activities proposed by Heathgate in the area of their leases and licences. As a result, the proposed development area has been the subject of more than ten Work Area Clearance inspections by teams of Adnyamathanha researchers (Ellis B, 1999-2006, Fitzpatrick P, 2002). Maps have been produced by Heathgate in association with the researchers, which detail areas where approval has been granted for exploration or related activities. While not shown on those maps, an area applies 30 m either side of the major channels of Four Mile Creek along its entire length has not been sought for approval. Elsewhere, approvals may have been granted for specific activities, but those approvals may be subject to conditions imposed by the research teams which are specified in the reports of the inspections.
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Team members have been reluctant to approve any physical intervention within 30m of the banks of other major watercourses. This is because most sensitivity associated with Aboriginal occupation in this area is associated with such watercourses and due to the fact that Mr Artie Wilton, the last Adnyamathanha wilyaru man, expressed a desire that drilling and other physical activities should not occur in the bed of Four Mile Creek. A Work Area Clearance methodology adopted by the company in association with the Native Title applicants, has been developed to minimise potential deleterious impact upon Aboriginal cultural values at all stages of exploration and development within the area (refer Section 3.14.3).
3.14.2 European Heritage The Flinders Ranges is of significance to European heritage. From the start of European use of the Flinders Ranges and immediate surrounds in the 1850s, the historical land use of the region has been primarily pastoral. Mining has been historically a secondary land use. Apart from coal mining post-World War 2 at Leigh Creek, other minerals have been successfully mined, particularly copper, gold, talc, and barite. The Beverley site itself contains no artefacts of European occupation of historical value. The operation of the existing Beverley mine and its associated facilities has had no impact upon the European heritage of the area, and an extension of the area on which wellfields could be developed would also have no impact.
3.14.3 Heritage Management Inspections (Ellis B, 1999-2006, Fitzpatrick P, 2002) have arisen from the application of the Heathgate Work Area Clearance methodology, adopted by the company in association with the Native Title applicants, to minimise potential deleterious impact upon Aboriginal cultural values at all stages of exploration and development within the mining leases and licences held. This methodology and the inspections it has generated have resulted in detailed and in most cases, on-foot investigation, of areas embraced by the proposed extended ML area. The Work Area Clearance methodology was developed in the Northern Territory to permit Aboriginal traditional owners, in company with cultural heritage professionals or advisors, (but not those professionals or advisors alone), to assess activities proposed on Aboriginal land, without the necessity for them to divulge information on the cultural amenity of the area within which work is proposed. The Aboriginal Cultural Heritage Study of the present ML and the proposed extended ML area undertaken by Bob Ellis in 2006 did not seek to provide an “expert” assessment of, or approval for, future activities likely to be undertaken within those tenements or future tenements. Rather, it further developed this methodology for work clearance that has been employed for continuing assessment of such activities by Adnyamathanha representatives selected by named Native Title applicants. The applicants are generally considered by their peers to be most closely associated with the Wooltana Pastoral Lease and knowledgeable about its cultural amenity. This is the preferred approach of the body representing the Native Title claimants for the area under review and the one that most closely replicates the traditional decision-making responsibilities that previously applied in this area. Such an approach is recommended as one most likely to ensure continuing protection for the cultural heritage values and places associated with the areas under consideration. It is also considered to have the benefit of promising opportunity for Heathgate to negotiate reasonable and speedy resolution of matters essential for future mine development within such tenements as they may be granted in this location. Heathgate recognises the importance of information regarding the environment, heritage management and Aboriginal issues in the region. In order to aid in community liaison, a Visitor and Heritage Centre has been constructed at the mine site. Different community groups require different specific mechanisms for consultation. The level and type of consultation varies between these groups (refer Section 6).
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3.14.4 National Estate Listings The site is not subject to any National Estate or similar listings.
3.15 Proximity to Conservation Areas The nearest conservation areas are the Arkaroola Wilderness Sanctuary (a private reserve) and the Vulkathunha- Gammon Ranges National Park (Figure 3-1). The closest boundaries of these areas are located approximately 9 km west and 30 km south-west of the proposed ML. The Vulkathuna – Gammon Ranges National Park includes a section of plain between the Flinders Ranges and Lake Frome of similar character to the proposed mining lease. Paralana Hot Springs (Figure 3-1) is simultaneously of major significance to Aboriginal people, a tourist attraction, a site of particular geological interest, and albeit radioactive the closest permanent natural surface water to the site. The springs are located outside the proposed ML over 10 km to the west of the Beverley, within the Arkaroola Wilderness Sanctuary. The proposed project will not impinge on the springs. There are some areas within the proposed ML that are considered as environmentally sensitive for reasons such as unusual vegetation, good faunal habitat, gibber/gilgai landforms posing erosion hazards or because they are flood prone areas. Thus care and environmental sensitivity is taken in surface activities throughout the mining process. Clearance of native vegetation is subject to the issuing of individual clearance permits under Heathgate’s Environment Management System (see Section 10). 3.16 Pre-existing Site Contamination and Disturbance There is a pre-existing mine with approved low level radioactive waste and burial sites at the main Beverley mine site. No site disturbance or pre-existing contamination is known to exist on the proposed ML extension. The Lake Frome Plains area has however been subject to some mining and pastoral activity since European settlement. This is evident by ruins in the vicinity of the ML, such as the old Paralana Homestead (13 km west of Beverley), and a number of small mines and associated structures. Pastoral activity in the region since the late 1850s has also resulted in substantial modification to natural vegetation. The ML extension would result in the removal of livestock from the ML allowing regeneration of this vegetation. 3.17 Natural Radioactivity
3.17.1 Introduction to radioactivity in the Beverley context Radiation management is integral to the operation of the Beverley Uranium Mine. A brief background to radiation is provided below (Department of Education, Science and Training, 2002), to give context to the management of radiation at Beverley. Radiation management and monitoring is set out in detail in Heathgate’s Radiation Management Plan, which is approved by the South Australian Environment Protection Authority Radiation Protection Branch. Radioactivity is the term used to describe the breakdown of unstable atoms and the associated release of energy, which is in the form of sub-atomic particles or electromagnetic waves. Over time, radioactive material is completely broken down, stable atoms are formed and there is no further release of energy or radiation. The time taken for this decay process is measured in terms of an atom’s half-life. One half-life is the time for half of the radioactive atoms to decay to either stable atoms or the next element in a decay chain leading to stable atoms.
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Section 3 Description of Environment
In uranium mining, radiation arises as uranium decays via a decay chain of other isotopes to a stable form of lead. During this decay process, radiation may be released in three forms: alpha (α) particles, beta (β) particles and gamma (γ) radiation. Alpha particles are atomic nuclei, and can only travel a few centimetres in air; a sheet of paper or a layer of skin can stop them. Beta particles, which are electrons or positrons, can travel metres in the air and several millimetres into the human body, and can be stopped by a small thickness of light material such as aluminium or plastic sheeting. Gamma rays are very energetic electromagnetic radiation and can pass through the human body. A radiation dose is the measure of how much energy is absorbed when radiation hits body tissue. The different types of radiation (alpha, beta and gamma) have different penetrating powers and carry different levels of energy, and therefore have different effects on humans. The energy that radiation deposits in the body has the ability to break the bonds between atoms. In most cases, these bond breaks do not matter to the functioning of the body, and are either repaired or occur in places where they do no harm. If the break occurs in molecules that control the way a cell works, the cell can stop working, start working in a destructive way that can lead to cancer, or die. Alpha radiation cannot penetrate skin; beta radiation will penetrate skin but will not penetrate far into human tissue (it is often referred to as a ‘skin dose’). Thus the effects of alpha and beta radiation are of most significance if radioactive material is taken into the body by inhalation of contaminated dust, or by ingestion of contaminated food or drink. Gamma radiation penetrates most matter and so may be of health significance for both internal and external radiation sources. The National Health and Medical Research Council (NHMRC) and National Occupational Health and Safety Commission (NOHSC) have set a National standard for limiting occupational exposure to ionizing radiation (1995). For members of the public, the dose limit in this national standard is an annual effective dose of 1 mSv above the ambient background dose rate, excluding exposure from medical procedures. For occupationally exposed workers, the dose limit is 20 mSv/yr, averaged over a five-year period. The nature of the ISL process (see Section 1.4) significantly reduces the sources of radiation exposure compared with traditional mining operations.
3.17.2 Background and current radiation levels Radioactivity in groundwater at Beverley is discussed in Supporting Report C. Due to the general presence of uranium in the geological environment, and the natural high concentration of uranium in the orebodies with the Beverley Sands, uranium and associated radionuclides are elevated in many of the groundwaters of the area. The range of uranium content exhibited by the "shallow aquifer" water samples in the regional database, which includes both Proterozoic rocks of the Flinders Ranges and the shallow aquifers of the foothills and plains is illustrated in Figure 22 of Supporting Report C. Concentrations extend from below detection limit to in excess of 300 ug/L. The spatial distribution of these values is given in Figure 23 of Supporting Report C, showing uranium concentration tending to increase towards the west reaching a maximum of 310 ug/L. Radium reaches a maximum value in this sample set of 16.4 Bq/L (excluding a single higher measurement considered anomalous) with values to the west dropping to below 1 Bq/L. Radon distribution shows one high value at Paralana Springs, which is well known as a radon anomaly. Surface soils have typical background gamma activity. Recent readings from the Deep South area of the proposed Mining Lease are considered typical; the average of 102 readings taken in 2007 was 0.143 uSv/h (range 0.10 to 0.20 uSv/h). These measurements were undertaken as part of exploration drilling activities and are used to check the radiation status of rehabilitated areas. Such measurements will continue to be taken during the planned operations on the proposed ML.
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Table 3-1 presents a summary of the most recent radiation dose data including both background and current mine activity. The radiation doses are low compared with statutory limits. Table 3-1 Summary of radiation dose statistics for 1st quarter 2007
Number of employees 206 Average employee dose (mSv) 1 0.10 Maximum employee dose (mSv) 1 1.16 Member of the public dose 3 Indistinguishable from natural background Notes: 1. Average annual limit for radiation workers = 20 mSv (NHMRC/NOHSC 1995) 2. Worldwide background Radon concentration range = 1 Bq/m3 - 100 Bq/m3 (UNSCEAR 2000a) 3. Worldwide average background radiation dose = 2.4 mSv (UNSCEAR 2000b)
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Section 4 Description of the Operation
4 Description of th e Operatio n 4.1 General Description Heathgate operates the Beverley Uranium Mine by in-situ leach (ISL) methods, described in Section 1.4, and illustrated in Figure1-2. Further information on the process is also provided in Section 4.3.1. ISL mining removes uranium from the host ore without the physical removal of ore and covering soils and rocks. It requires installation of multiple close-spaced wells into the aquifer, pipelines to and from the wells and a surface treatment plant, but does not require either underground mine workings or open cut pits. The proposed development outlined in this Mining Proposal is a request to extend the existing approved ML 6036 for the purpose of installing additional wellfields to extract uranium using ISL methods and the existing infrastructure to produce uranium (refer Sections 4.3 to 4.5, and Figures 1-3 and 4-4). The proposed lease will include existing operations in ML 6036 and the associated Miscellaneous Purposes Licences MPL57, MPL58 and MPL 59 (Figure 1-3). Supporting infrastructure is described in Section 4.5 and includes an airstrip, accommodation camp and processing plant with associated ponds. 4.2 Ore Reserves and Market Heathgate has systematically recalculated the Beverley Resource as the orebodies are developed. This new assessment takes account of parameters that directly affect the effectiveness of the ISL process, including porosity and permeability so far as is possible with the available historical data-set and the recently acquired core data. A description of specific aspects, as set out in the joint State-Commonwealth guidelines (DEWR/PIRSA 2007), follows.
4.2.1 Geological Environment A description of the geology of the ML extension area is provided in Supporting Report A. A brief summary follows. The Beverley Uranium Deposit lies in the western part of the Frome Embayment between Lake Frome and the Flinders Ranges. Geological information specific to the project area consists of open hole drilling, and downhole geophysical logs to 180 m from the surface; Four Mile Flowing Bore (Camp Bore) of 302m depth; and limited seismic data. Uranium mineralisation occurs within a sequence of sands/silts/clays (of the Namba Formation) deposited within an elongated, channel-like depression on the surface of the highly impermeable Alpha Mudstone some 100 m above the GAB. The Beverley sequence is made up of a complex series of lenticular sands with silt/clay interbeds. A schematic cross section of the Beverley Sequence is presented as Figure 3-2. The Beverley Sand aquifer within the Namba Formation is considered to be a confined system, completely bounded on all sides by very low permeability units. The Beverley Sand aquifer sequence can be vertically subdivided into four broad aquifer units:
• Top Silt unit typically ranging from around 90 m to 100 m depth, comprising fine-grained silts, sandy silts and clays of low permeability.
• Upper Sand unit typically ranging from around 100 m to 120 m depth, comprising silty sands of moderate transmissivity (the main mineralised zone in the Upper Sand). There are numerous areas of facies changes from the Upper Sand into thicker sequences of the Top Silt.
• Lower Sand unit typically at 120 m to 130 m depth, comprising an upper sub-unit of medium to fine grained sands (with some clays) of high transmissivity (the main mineralised zone in the Lower Sand), grading into coarser, un-mineralised Basal Sands with higher permeability.
• Basal Sand unit typically at 130 m to 140 m depth, comprising “pods” of medium to fine grained sands of high permeability, less extensive than the Lower Sand unit.
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Section 4 Description of the Operation
In the Beverley area, the Beverley Sand aquifer is overlain by the Beverley Clay unit providing an impermeable barrier hydraulically isolating the Beverley Sand aquifer from the overlying Willawortina Formation aquifer. This clay unit comprises a widespread, predominantly clayey sequence. The clay is plastic in nature and experience accumulated by Heathgate through its various drilling programs has shown this clay to be self sealing within minutes to hours. The plastic nature of this clay serves to continuously isolate the disposal target aquifer from the overlying Willawortina Formation aquifer. The Beverley Sand aquifer is underlain by the next lower units of the Namba Formation, the Alpha, Beta and Gamma Mudstones. The uppermost of these, the Alpha Mudstone, forms an impermeable confining base to the Beverley Sand aquifer. The other mudstones are additional low permeability units below the Beverley Sand, and act as impermeable bases (and where applicable covers) to the thin Alpha, Beta and Gamma sands that have been identified in some area within the mudstone sequence. Laterally, there are abrupt boundaries in some areas, particularly where the “channel” structure of the Lower and Basal Sand sediments are effectively pinched out by the Alpha Mudstone. The Upper Sand also has a “channel” structure, but this is characterised by lateral facies changes into the low permeability silts, sandy silts and clays of the Top Silt. To the north and south, the “channel” structure of the Beverley Sand generally ends in low permeability clays and silts. Within the Alpha, Beta and Gamma Mudstones are some sandy units, which are similarly considered to constitute isolated aquifers (Figure 4-1, from Supporting Report C). These are also prospective for uranium mineralisation and are being explored within both the existing ML 6036 and the proposed extended ML. One orebody has been identified in the Alpha sand in Beverley East Zone 3 (see Section 4.3.6). Figure 4-1 Conceptual geological / hydrogeological model, Beverley
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Section 4 Description of the Operation
4.2.2 Reserves and Resources
The Beverley Uranium Mine has an export authority for 1,500 t/a uranium (as U3O8). The existing plant is capable of producing about 1,000 t/a uranium as UOC by the ISL method, although the current production is approximately 800 t/a. The current production target for Heathgate is 800-1000 t/a UOC (approximately 1.8 – 2.4 million pounds of uranium per annum) (Section 1.4). It is anticipated that this production target will not change once the proposed ML is operational, rather, it will simply extend the life of the mine. Heathgate’s target exploration drilling is aimed to be approximately nine months ahead of mine planning. Orebodies identified to date are east and south of the existing ML 6036 (see Section 4.3.6). Targets close to these identified orebodies will be further investigated first as they are near the proposed early infrastructure. This will be followed by investigation of other orebodies depending on exploration results. Sedimentary uranium deposits as present at Beverley do not readily lend themselves to ore characterisation under the JORC code3 as requested by the State-Commonwealth guidelines (DEWR/PIRSA 2007- see McKay et al. 2007). Uranium concentration is quantified using the in-situ PFN (prompt fission neutron) geophysical method and reconciled against mined uranium in existing wellfields. As noted by McKay, there is on-going discussion on the issue of resource estimation for ISL uranium projects, where new wellfields for an existing deposit such as Beverley are planned with a high level of confidence using a lesser drillhole spacing than would be required under the JORC code, but based on what is an extensive experience dataset. A further issue is the recoverability of the uranium from the deposit using ISL, and this can be confirmed only in a field leach trial (FLT). In the extended ML, Heathgate has identified over 12 months of production to the full internal level of confidences required for planning, and will be undertaking ongoing delineation drilling to maintain the nine-month lead on mine planning. Heathgate expect that additional ore will be delineated within the existing ML 6036 as well as the extension area applied for. The progressive development of orebodies in addition to those in Deep South and Beverley East described here will be subject to applications to amend the MARP for the extended lease, as has been the practice within ML 6036, where several orebodies have been found and mined since the lease was initially granted and the first MARP approved.
4.2.3 Market Global population is predicted to double from 5 billion between early and the middle of the 21st century and consumer demand for electricity (particularly in eastern Europe and Asia) is set to more than double. The current world population at October 2007 is estimated to be 6.6 billion4. This will lead to increasing dependence on electricity and thus nuclear power stations. About 17 per cent of the world’s energy is generated by nuclear power. The Uranium Institute in London says uranium production in 2006 was insufficient to meet demand, a condition that has persisted for over a decade. Australian exports are now approaching 9000 tonnes per year of uranium oxide concentrate - about 25 percent of world uranium supply.
3 Joint Ore Reserves Committee (JORC), sponsored by the Australian mining industry and its professional organisations. The Code for Reporting of Mineral Resources and Ore Reserves (the JORC Code ) is widely accepted as a standard for professional reporting purposes. However, as noted in the text, the suitability of the JORC Code for uranium ISL projects is under discussion. http://www.jorc.org/main.php
4 http://www.census.gov/ipc/www/popclockworld.html
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Section 4 Description of the Operation
Uranium prices vary as the balance between supply and demand fluctuates. Over the past couple of years, prices have increased 10 times or more from historic lows. Most recent prices have retreated from a peak in mid 2007 but are still well above those of two years ago. All Beverley contracts are subject to Australian Government safeguards requirements. The main customers are in:
• Japan
• Europe (presently only France)
• United States. All ongoing sales from the extended ML will continue to be subject to the safeguard requirements. Sales may be made to other approved countries in the future.
4.2.4 Radioactive Substances and Ores Where radioactive ores are to be mined, preoperational monitoring is required to determine background radiation levels in the environment. These measurements are required to ensure that the mining operation does not significantly increase exposure of the environment to radiation as a result of mining activities. Heathgate has prepared a Radiation Management Plan and Radioactive Waste Management Plan to satisfy the monitoring and reporting requirements under relevant regulations and Codes of Practice (particularly the ARPANSA Code Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing (2005)). These plans have been submitted to, and approved, by the SA EPA. Heathgate conducts all operations in a safe and responsible manner, and places the safety of workforce (employees and contractors) and protection of the environment ahead of commercial considerations. Therefore, the Radiation Management Plan and Radioactive Waste Management Plan have been designed to enable Heathgate to critically review the radiological impact of the Beverley processing plant and associated wellfields. The Radiation Management Plan and Radioactive Waste Management Plan give details of the issues related to the occupational and environmental radiation at the Beverley Uranium Mine respectively. Stakeholders who would be consulted include the Radiation Protection Division of the EPA. Other potential stakeholders include the landholders using bores in the areas, DWLBC, immediate and adjacent landholders, special interest community groups and the general public. ISL mining is a relatively low impact mining method for extraction of uranium, since ore is not mined in the conventional sense. There is minimal surface disturbance, no overburden removal, no ore treatment facility, no tailings generation or disposal requirements, and rehabilitation is relatively simple. Sections 4.3 and 4.4 provide further information on the process and wastes generated, and Section 4.5 provides information on the operations infrastructure.
4.3 Mining Operations
4.3.1 Type or Types of Mining Operation to be Carried Out This Mining Proposal involves an extension to the area in which ISL mining would be undertaken at Beverley. ISL mines have many advantages when compared with traditional mines since they have:
• Minimal surface disturbance;
• No ore surface exposure;
• No waste rock dumps;
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Section 4 Description of the Operation
• No tailings dams; and
• Greatly reduced radiation exposure to workers and the community at large. ISL mining removes economic mineralisation from the host ore without the physical removal of ore and overburden. It requires multiple close-spaced wells into the ore, pipelines to and from the wells and a surface treatment plant, but does not require either underground mine workings or open cut pits, or waste rock dumps and tailings management facilities. The general arrangement of ISL facilities at Beverley is shown in Figure 1-2. In the ISL process, natural groundwater from the mineralised zone has added to it oxidising and complexing reagents. Oxidising reagents are commonly oxygen or hydrogen peroxide, though other alternatives may be used. Complexing reagents may be acidic or alkaline: the present operation is an acidic leach using dilute sulphuric acid. The mining solution (lixiviant) is pumped via multiple injection wells into a permeable orebody where it mobilises the uranium contained in the ore. In this process, some of the reagents are consumed. The resulting uranium-rich solution is pumped back to the surface via multiple extraction wells to a uranium recovery plant. At the plant, uranium is stripped from the solution and held for later precipitation, drying and packaging. The barren solution is refortified to replace used reagents, and recycled back to the injection wells. Within any given area, this cycle continues until the uranium remaining in the ore is depleted to uneconomic levels. ISL mining is feasible where the geological and hydrological characteristics of the orebody are favourable. This is the case with the Beverley uranium deposit, where the uranium is easily mobilised, the mineralised zone occurs in highly permeable sediments that are confined by largely impermeable strata above and below the ore body, and the mineralised zone is saturated with groundwater. The design and operation of the wellfield controls the flow of mining solution through the mineralisation. Operations are generally limited to only parts of wellfields at any one time, although the whole of each wellfield will eventually be mined during the life of a mine. Injection and extraction wells are closely spaced, at present between 12 m to 40 m apart. Within the active mining area, the volume of solutions extracted is slightly more than the volume injected. This ensures a slight continuous inflow from the surrounding formation into the active mining area, and minimises leakage of mining solutions away from the active mining area (excursions).
4.3.2 Sequence of Operation Heathgate anticipate commencing operations as soon as possible after the proposed development is approved. There will be no developments or infrastructure on the extended ML area (beyond the existing ML and MPLs) except for the temporary presence of wellfields, which will be connected to the existing infrastructure at the existing ML site (with booster stations for trunklines if necessary). As is current practice, when a wellfield is no longer viable, it will be relocated elsewhere within the extended ML for further use. The operations at the Beverley processing plant, described in Section 1.4 and in this section, including a process diagram (Figure 4-2), will remain unchanged.
4.3.3 Modes and Hours of Operation The extended mine area will operate the same as the current mine area, namely 24 hours a day, 365 days a year, on a fly-in fly-out basis.
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Section 4 Description of the Operation
4.3.4 Field Equipment Field activities on the extended ML will be wellfield construction and operation, and rehabilitation following closure. All drilling will be undertaken using wet-mud techniques. All operational processing will occur at the existing Beverley processing plant. Field equipment to be used on the proposed extended ML will be the same as that used at the existing Beverley operations, and includes the following (Heathgate and contractors):
• up to six drill rigs and support vehicles including water tankers; • two to four geophysical logging vans; • one airlift truck; • one water recovery truck; • one water sampling truck • two backhoes; • one low-loader and prime mover; • one crane; • one grader; • five forklift trucks; • two water trucks; • 4-WD ambulance; • one fire truck (ordered); and • assorted light vehicles (4WD utilities and wagons). There are also truck movements associated with reagent and diesel fuel delivery and produce transport. The only operations likely to generate minor noise or dust are traffic on unsealed roads, wellfield construction activities, and wellfield rehabilitation. Water trucks are used on roads for dust suppression and distance from any sensitive receptors or neighbours precludes any off-site noise or air quality issues.
4.3.5 Processing Processing will continue to be undertaken at the existing Beverley processing facility. No changes to the facilities are envisaged. The general arrangement of the Beverley operations is shown in Figure 1-2; a process diagram is provided in Figure 4-2. A process description is provided in Section 1.4, with additional information in Section 4.3.1.
4.3.6 Early Mining in the Extended Lease A map showing current target areas and identified orebodies in the ML extension area is shown as Figure 4-3. These are the mining areas that will be included in the MARP, which will be submitted for approval following the grant of the extended ML. Mining of additional orebodies, as they are identified, will be subject to MARP amendments, as has been done within ML 6036. Orebodies for immediate development in the months following the grant of the extended ML and associated MARP and other approvals are in the areas immediately east and south of the existing ML 6036 known as Beverley East and Deep South respectively. The development of a small orebody largely within the existing ML 6036 but extending into the ‘Falcon’ target on the extended ML will be also pursued in the short term. The (currently) small orebody adjacent to ‘Falcon’ and Zone 1 of Beverley East will be incorporated into existing mining on ML 6036 with simple extensions of existing wellfields. A typical wellhouse which mines a section of orebody is shown in Plate 4-1, and a trunkline is shown in Plate 4-2.
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Section 4 Description of the Operation
Figure 4-2 Beverley Process Diagram
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 4 Description of the Operation
Figure 4-3 ML Extension Orebodies and Prospects
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Section 4 Description of the Operation
Plate 4-1 Typical wellhouse and mining area at Beverley
Plate 4-2 Typical trunkline at Beverley
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 4 Description of the Operation
The proposed routes of the trunklines (two 560 mm external diameter poly pipes, painted white) for the proposed early orebody developments are shown in Figure 4-3. The locations of other piping are still in the design stage. All piping will be above ground in conformance with current practice. Only one minor ephemeral water course crossing (Mulga Creek) is required, for the Deep South trunk line. Similar techniques to ephemeral creek crossings within ML 6036 will be used. Further details will be provided in the MARP application which must be approved before construction can commence. Deep South and Beverley East Zone 1 and 2 orebodies occur in the same geological and hydrogeological settings as the existing Beverley orebodies. Beverley East Zone 3 is located in the Alpha sand. Pumping tests are scheduled for the orebody aquifers at Beverley East Zone 3 and Deep South Dragon and Gecko orebodies. Results will be provided to state and commonwealth authorities when available. These will be used to finalise the design of wellhouses and injection-extraction well patterns and the number and location of monitor wells. The current Beverley regulatory guidelines for the installation and monitoring of monitor wells will be applied to the new wellfields. Final wellfield outlines will be provided in the MARP and (as required) later MARP amendments. The quality of mining solution that will be introduced into the new mining areas is expected to have a similar composition to that used in current operations (as all mining solution comes from the same plant and is influenced by all active and recently active wellfields). Typical concentrations of elevated constituents expected are shown in Table 4.1. Table 4-1 Expected typical mining solution composition
Constituent Expected Constituent Expected Concentration Range Concentration Range
Sulphate mg/L 8,500 – 9,500 pH 1.7-1.9
Uranium (as U3O8) 20 - 60 Electrical conductivity 18-32 mg/L mS/cm
4.4 Wastes
4.4.1 Drill Cuttings Mud pits are excavated adjacent to the rig at each drill hole collar, to allow the circulation of drilling fluid and for capture of drill cuttings. At the completion of the drill hole or well development, the mud pits are rehabilitated as follows:
• The mud pit is allowed to dry out;
• The drill cuttings in the pit are covered with material excavated from the pit; and
• The surface is compacted to ensure that the surface of the capping is levelled with the surrounding terrain. The final capping will be approximately 0.6 m thick. Radiation monitoring and modelling of the above procedure has been undertaken and has demonstrated that the method conforms with best practice, and ensure that radiation doses to employees and members of the public are below applicable limits and as low as reasonable achievable.
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Section 4 Description of the Operation
4.4.2 Mine Solid Wastes The Beverley Uranium Mine produces a certain amount of non-radioactive solid waste associated with both its mining operation and accommodation facilities, including:
• Normal ‘household’ putrescible wastes (food scraps, plastic wrapping etc);
• Packaging and containers (cans, bottles etc);
• Commercial wastes (papers, documents etc); and
• Industrial wastes (oils, chemicals etc). All wastes that are deemed to have no further use are disposed of in an approved landfill facility. The objectives for managing the landfill comprise:
• Minimise waste requiring disposal in approved refuse facility;
• Maximise recycling and reuse;
• Minimise the impact on the environment by waste handling and disposal methods; and
• Ensure that the integrity of the waste management facilities is maintained. The strategies for managing the landfill operations are:
• Identification of waste streams;
• Segregation of radioactive wastes from the general waste stream (see Section 4.4.3);
• Implementation of management systems to minimise waste generation, including: – Recycling and re-use; – Pre-burial environmentally friendly burning; – Composting; – Shredding; and – Baling or other form of compaction.
• Periodic review of waste management technology with a view to adoption of cost-effective waste management methods;
• Fencing and locking of refuse facilities to prevent inappropriate use (and access by feral goats); and
• Waste facilities are constructed according to engineering specifications. The location of the landfill is shown in Figure 4-4.
4.4.3 Low-level Radioactive Wastes An appropriately designed and approved disposal method is required for disposal of low-level radioactive (LLR) waste solids arising from the project operations. The current arrangement is for purpose-built near surface facilities, which are established on site as needs arise. These facilities are filled, closed and rehabilitated from time to time as required, in compliance with regulatory requirements of the South Australian Environmental Protection Authority (SA EPA). The management of solid radioactive waste involves:
• Segregation from general waste stream:
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• Temporary storage; and
• Eventual final disposal in an approved facility. Solid radioactive waste is restricted from leaving the site via the use of a contaminated items clearance procedure. Any items leaving the Beverley Site are accompanied by a clearance certificate showing that the surface radioactive contamination is below the limits determined by the appropriate authority. The typical items of LLR waste include items such as piping, valves and filters. To ensure timely collection and segregation of this waste from the non-radioactive waste stream, LLR waste collection points are situated throughout the plant and wellfield. This typically comprises 205 L steel drums with lids, labelled ‘Low Level Radioactive Waste’, which when full are transferred to the temporary LLR waste holding facility. Any larger LLR waste item that cannot be placed in these bins (typically piping) is transferred separately to the temporary holding facility. Note that piping is re-used as much as is practicable, when closing down spent wellfield areas and opening new wellfields. Any soils recovered from contaminated areas of the plant and wellfield are also temporarily stockpiled adjacent to the temporary LLR waste holding facility, on a low bunded containment pad. During storage, these materials are covered with a weatherproof material. The LLR waste disposal cells have dimensions of approximately 10 m wide by either 10 m or 30 m long, and 5 m deep, with a 3 m capping. The maximum holding capacity of each cell is 200 m3 (10 m long x 10 m wide x 2 m deep), or 600 m3 (10 m long x 30 m wide x 2 m deep). An access ramp of gradient approximately 15%, which is gravelled, is provided for access to the cell. The battered walls of the cell are lined with a 2 mm thick HDPE synthetic liner. A 0.3 m clay base is also provided over the liner. The base has a slope of approximately 5% to a front corner of the cell, which is equipped with a sump for the monitoring of any leachate. The placement of the LLR waste within the cells is as follows:
• Steel drums will be positioned on the base of the cell from the edges to the centre;
• LLR waste not contained in steel drums (e.g. piping) is placed in the centre of the cell, and surrounded by drums;
• Two layers of drums only are allowed to be placed onto the base of the cell; and
• Where possible, contaminated soils or drill cuttings will be used to fill the voids between the drums, otherwise clean soil will be used. Wastes are inspected prior to the transfer from the holding area and prior to being covered by soil. Any items that can be decontaminated, re-cycled or re-used are removed, and an inventory of waste material permanently contained in the cell is maintained. When a disposal cell has reached its maximum capacity, it is closed, and another cell commenced.
4.4.4 Process Wastes - General The primary waste streams from the mining operation are spent solutions from the uranium precipitation process, washdown water and filter cleaning water. These fluids are initially collected in the plant water management ponds. The management and disposal of the fluids reporting to the water management ponds is via one of the following processes:
• Evaporation is maximised by maintaining full coverage of the current evaporation pond;
• Recycling water to the plant for re-use in the process;
• Pumping of water between the ponds around site; and
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• Disposal of excess volumes by re-injection to the Namba Aquifer in the North Beverley Wellfield5, as directed by the conditions of ML 6036. Currently one evaporation pond is in use. Whilst Heathgate has no immediate plans for an additional evaporation pond, should a pond be required in the future it would be subject to the approvals process with EPA and PIRSA before it could be built. A neutral water balance is maintained in the ore zone aquifers throughout the mining and disposal operations. This is reported quarterly to the EPA and PIRSA (and Commonwealth authorities). The fluids disposed of into the Namba Formation (mining) aquifer are re-injected in areas of the mined aquifer already mined6, and which are preferably remote from potential future mining areas. The injection rates, total volumes and aquifer pressures are managed to avoid the migration of waste water from the target aquifer to surrounding aquifers. At a special Technical Group Meeting of the Beverley Environmental Consultative Committee in 2006 (more details in Section 9.7.2), the Beverley aquifer was determined to be saline and radioactive and thus has no environmental value other than for mining. The GAB and Willawortina, however, do have environmental values and are to be protected. Note that the GAB aquifer has a hydraulic head such that any potential for leakage between aquifers is towards the Namba Formation, and not from the Namba formation to the GAB (refer Sections 3.10, 4.2.1). Presently the liquid wastes are disposed of by injection into the Namba mining aquifer in the Northern Wellfield area. The intention is that the injection activity will be moved to the Central Wellfield area following the cessation of ISL mining activities in that area, extending later into the South Wellfield area. Heathgate report quarterly to PIRSA and the EPA with relevant details of liquid waste disposal, and will notify of this proposed change at the appropriate time. Any sediment that accumulates in the process plant holding ponds will remain within the ponds until decommissioning. If the uranium content is sufficient, sediment may be reslurried and some of this uranium recovered, as has occurred in 2006 and 2007. The disposal of liquid wastes as outlined above is subject to the conditions of ML 6036. These conditions are expected to also apply to the extended ML. Disposal of liquid waste is carried out under an approved procedure. This procedure is prepared in accordance with the:
• Beverley Mine Environmental Management and Monitoring Plan;
• Beverley Mine Radiation Management Plan;
• Beverley Mine Radioactive Waste Management Plan;
• Beverley Mine Procedure for Liquid Waste Disposal; and
• Beverley Mine Uranium Export Licence conditions.
5 Heathgate is in the process of gaining approval for the injection of liquid wastes into the Central and South Wellfield areas and in the future other mined-out wellfields may be used, with appropriate approvals. As mining fluids will be mixed between existing operations and wellfields in the extended part of the new Mining Lease, effectively waste attributable to the extended parts of the lease will be injected initially into the currently approved disposal area in the North Wellfield then into Central and South once approvals are received and disposal starts in those areas.
6 This includes both mined-out areas and adjacent parts of the same aquifer that may not have been mined due to insufficient contained uranium (i.e. below cut-off grade).
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The historic procedure has been successful in demonstrating disposal of liquid wastes to the target mined-out aquifer only, without excursions into surrounding areas including the overlying Willawortina Aquifer. To date all injection of waste water has been in the North Beverley orebody aquifer, as required. In September 2007 Heathgate applied to update the waste disposal procedure to identify additional areas of mined aquifer as they are required, and to incorporate quarterly monitoring of the plume of injected water, as well as monitoring a network of monitor wells surrounding and overlying the mined-out aquifer being used for waste disposal. Waste disposal will continue under existing approvals until the new arrangements are accepted. The updated procedure for disposal of liquid waste developed by Heathgate has been agreed ‘in principle’ with the State and Commonwealth regulators and is summarised below. It is expected to be formally adopted in December 2007 or early 2008.
4.4.5 Updated Liquid Waste Disposal Procedure The updated methodology developed by Heathgate entails a number of steps: 1. Feasibility study prediction of sustainable disposal volumes through review of hydrogeological data and numerical modelling of the aquifer system. An initial feasibility study examining sustainable liquid waste disposal volumes will be undertaken at each disposal site. This feasibility study will incorporate: a. Collating and reporting all available hydrogeological information regarding aquifer geometry, aquifer boundaries and aquifer properties of the aquifer targeted to host liquid waste; b. Identifying the available aquifer extent targeted for liquid waste disposal – both vertical and lateral extents; c. Determining the capacity of the aquifer to accept and transmit the liquid waste within the aquifer at the proposed rates of injection (presented as a volume per time unit). d. Reporting of the pH, conductivity, concentrations and chemical compositions of the liquid wastes, the natural groundwater and residual mining fluids in the aquifer. This data is presented to the State Government regulators on a quarterly basis, and is also passed on to the Commonwealth; and e. Preparing a numerical hydrogeological model calibrated to observed groundwater level trends using the hydrogeological data collated during step (a) above. This model will be utilised to plan predicted sustainable disposal volumes and any groundwater management strategies required to manage the disposal plume extent. This model will be used to provide an estimate of sustainable disposal rates (expressed as volume per unit time) and total volumes. A predicted maximum plume extent map will be produced. Heathgate will provide a target for maximum daily injection and extraction rates as part of the feasibility study for each new liquid waste disposal location. These rates will be based on the outcome of numerical modelling and the requirement that modelled aquifer pressures do not exceed the safe aquifer pressure limits. 2. Quarterly determination of the plume extent through groundwater monitoring and chemical analysis and prediction of future disposal plume extent. Following the implementation of liquid waste disposal, a quarterly monitoring program will be implemented, which will entail: a. Determination of the actual plume extent through monitoring of groundwater chemical composition at a comprehensive set of monitor wells to identify monitor wells contacted by the disposal solution plume; b. Quarterly prediction of remaining sustainable disposal volumes based on observed rates of plume expansion in response to disposal volumes and on volumetric estimates of
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disposal rates and available aquifer volume. A piston flow assumption will be used for the prediction using best available aquifer geometry and porosity information; and c. Annual numerical modelling will be undertaken using the actual injected volumes of waste water to allow updating of the predicted plume extent in the following years. A quarterly report will be provided to the government regulators as a component of the regular quarterly environmental reporting undertaken by Heathgate. This report will contain the following information: 1. Monthly liquid waste disposal volumes for the quarter. 2. Water balance information for the quarter. 3. Disposal solution chemistry (average EC, pH, sulphate, chloride and uranium concentrations) for the quarter. 4. Details of monitor wells within the Namba Formation sampled to determine disposal plume extent (coordinates, depth, screened interval and aquifer accessed). 5. Interpreted chemical composition of groundwater samples from monitor wells. 6. Scatter plots of sulphate versus chloride and hydrographs of sulphate concentration used to determine chemical composition and water type. 7. A map showing aquifer extents, monitor wells, interpreted groundwater composition, inferred disposal plume extent. 8. Predicted disposal volumes for the following quarter. 9. Predicted disposal plume extent for the following quarter (presented on a map) including volumetric calculations of the aquifer capacity over the predicted plume extent. 10. A comparison of the measured plume extent against the results of numerical groundwater modelling used to predict plume extent through the Feasibility Study and the annual updated disposal modelling. In addition to an annual re-run of the hydrogeological numerical model, the model itself shall be recalibrated if there is a significant difference between predicted an actual disposal plume movement. Specifically, the numerical model shall be recalibrated (and re-run) if:
1. The lateral extent of the predicted disposal plume differs from the actual by 20% or more; or 2. The direction of the modelled plume migration differs from the actual by 45 degrees of more. These criteria recognize that there may be inherent complexities in the real aquifer system (for instance preferential flow paths and plume dilution) that are not incorporated in a numerical model and particle tracking methodology, whilst ensuring that the numerical model is sufficiently robust to predict aquifer response to a degree of accuracy that allows effective planning disposal fluid management. In the future any changes to the arrangements will be subject to a similar scrutiny and approval process. As stated above, Heathgate has also applied to commence waste injection in the Central and South Beverley orebodies, in anticipation of completion of mining in parts of those orebodies. There is enough volume in these orebody aquifers to accept several years of waste water. The procedure (or its approved successor) will be used to support any possible future applications to inject waste into additional orebodies, which may include parts or all the ‘Deep South’ and ‘Beverley East’ orebodies described in Section 4.3.6. Currently Heathgate injects waste water at a rate of up to 5 L/s. Injection rates are higher in winter when evaporation rates (from the evaporation pond) are relatively low, and are lower in summer when evaporation rates are relatively high. The total disposal volume for the 12 months to end June 2006 was 81.9 ML (annualised mean rate 2.6 L/s).
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As the production rates will remain similar to current practice, the rate of injection of waste water will remain similar as mining extends on to the extended ML (subject to approvals). Injection water is saline with the following average composition (significantly elevated constituents only, average of the 12 months to June 2006, rounded to two significant figures; Table 4-2). Table 4-2 Typical waste water concentrations (2006)
Constituent Average Constituent Average Concentration Concentration
Sulphate mg/L 17,000 pH 2.9
Chloride mg/L 29,000 Electrical conductivity 58 mS/cm
Uranium (as U3O8) 68 Ra-226 Bq/L 540 mg/L
4.4.6 Silt Control and Drainage Operations in drainage channels and creeks are avoided wherever possible. However, some silt control measures are employed on roads, particularly creek crossings.
4.4.7 Airborne wastes The ISL mining process generates very small quantities of airborne radioactive wastes. The management of the individual airborne waste streams is discussed below.
Exhaust stacks on drying and packaging dust extraction systems The drying system installed at the Beverley Uranium Mine is categorised as a low emissions dryer. A dust extraction system is installed on the drier, which draws air and dusts from the drier through a fabric filter. The filtered air is then passed though a wet scrubbing system, followed by a High Efficiency Particulate Air (HEPA) filter prior to exiting via a stack in the roof of the packaging warehouse. The dryer and packaging enclosure are both also equipped with dust extraction systems for collection of any fugitive dust that may be emitted from the dryer or packaging operations. These systems both consist of fabric filters, equipped with secondary filters, prior to exiting though the stacks on the roof of the packaging warehouse. The management practices comprise good maintenance, air sampling conducted in the dryer and packing areas, and sampling of exhaust stack particles.
Radon dispersion Radon may be emitted from areas of the plant where processing streams are open to the atmosphere, including the water management ponds and mixing tanks, and also during airlifting of new wells for removal of drilling fluids. During the 1998 EIS process, radon dispersion models were developed; these clearly showed the emissions potential for radon to be released from the plant and ponds was low. The management practices include controls on tank ventilation, and radon monitoring and review. Modelling of the airlift process has also shown that radon releases are low.
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Dust dispersion As the ISL process is essentially a wet process (other than the dryer and packaging plant), the sources of radioactive dust in the ISL process are minimal. There is no dust (or other air quality emission) associated with the wellfield operations, apart from dust from access roads and tracks, which is controlled by the use of water trucks.
4.5 Supporting Infrastructure Site infrastructure is shown generally in Figure 4-4, and is discussed below.
4.5.1 Road Access Beverley may be accessed by road from the west via Copley, near Leigh Creek, and from the south from the Barrier Highway via Yunta, through either public roads or the (private) Epic Pipeline road that parallels the Moomba to Adelaide gas and liquids pipelines (Figure 3-1). A permit is required to use the Epic Pipeline road. Product UOC (in sealed drums, weight approximately 280-300 kg, containerized 63 drums to a container) is trucked to Port Adelaide via the Epic Pipeline Road, which is a gravelled, well maintained road. The present production is about 11 drums per day, corresponding to about one container per week. The full containers are held on site until a ship is scheduled, when transport of the containers is arranged by semi -trailers. Shipments are made out of Port Adelaide and Darwin. For shipping from Darwin, containers are railed from Port Adelaide to Darwin. The alternative route, through Leigh Creek (via the Arkaroola Road) is on a mix of gravel and sealed roads, and is used primarily for incoming raw materials, the largest items of incoming freight being sulphuric acid from Port Pirie, and salt. The traffic in the area relates primarily to tourism and pastoral activity – and to the few isolated mining and exploration operations, and oil and gas pipelines. The main tourist traffic in the area is to Arkaroola village, and along the Strzelecki track (Figure 3-1).
The site (field) roads are formed, and gravelled where required, and are well maintained, and provide ready access to all operating facilities. No new access roads will be developed as a result of the proposed ML extension, other than site (field) roads for wellfields access.
4.5.2 Airstrip The normal mode of travel by personnel between Adelaide and Beverley is by air. The airstrip is 1.5 km long and unsealed, and complies with DCA standards for jet aircraft, and is located about 2 km to the west of the accommodation complex. The travel time to Adelaide (from Parafield airport) is approximately one hour. The location of the airstrip relative to the processing plant and camp accommodation is shown in Figure 4.4. The frequency of airstrip use corresponds to the shift roster in place for the wellfield and for process plant operations, and apart from specific staff travel is routinely used only on one or two days per fortnight. The airstrip is equipped with navigation aids to Department of Civil Aviation (DCA) requirements. No modifications to the airstrip will be developed as a result of the proposed ML extension although Heathgate is considering sealing of the airstrip with bitumen for the future.
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Figure 4-4 Site Infrastructure
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4.5.3 Camp Accommodation Accommodation is provided for the workforce in conventional re-locatable accommodation units with single rooms and shared (between two rooms) ‘en-suite’ facilities. Presently the camp (Figure 4-4) can accommodate 152 persons. The camp is operated by a catering contractor, and is geared to the shift rosters of the Beverley workforce. Rooms are vacated (with some exceptions) on rostered days off, in order to maximise the utilisation of the accommodation units. Meals are provided in a fully-equipped mess, with recreational facilities including a gymnasium, at the disposal of the workforce. In addition, a satellite Exploration and Drilling Camp, which can accommodate 32 persons, has been established for use by contractor drilling crews. This camp comprises trailer mounted units, which can be re-located at short notice. No new accommodation will be required as a result of the proposed ML extension. Heathgate and its affiliate Quasar Resources may choose to shift the Exploration and Drilling Camp in the future.
4.5.4 Minesite Support Facilities The minesite support facilities include an administration centre, control rooms, offices and amenities, workshops and workshop equipment, laboratory and miscellaneous buildings (core sheds etc). No new minesite support facilities will be required as a result of the proposed ML extension.
4.5.5 Services and Utilities The Beverley Mine is approximately 15 km west of the Epic gas pipeline from Moomba to Adelaide (Figure 3-1). An 89 mm diameter spur line provides natural gas to drive gas engine-driven generators, which provide power for the site. The power generation capacity on site comprises four 1 MW units and one 2 MW unit. No new power generation facilities will be required as a result of the proposed ML extension. Investigations are underway evaluating a prospective geothermal energy source midway between the minesite and the Epic gas pipeline, in a pilot test facility, which is being installed by an independent operator. If this proceeds, an alternative source of power (externally supplied) will exist. Heathgate has no commercial interest in this activity, but is cooperating with the developer. The geothermal pilot plant has no impact on the Beverley operations.
4.5.6 Mobile Equipment There is no heavy mining equipment as used for open cut operations. The mobile equipment on site is small in number (refer Section 4.3.4), and also 4WD units for personnel and light goods transportation. No additional mobile equipment will be required as a result of the proposed ML extension.
4.5.7 Water Supply Water sources are discussed in Section 4.6.3 of this report. Potable water for camp and process use is sourced from the GAB; a reverse osmosis water treatment plant is used to meet potable standards. The locations of the three GAB bores on site are shown in Figure 8-3. No change in the water supply arrangements is required as a result of the proposed ML extension.
4.5.8 Communications Beverley is connected into the national telephone (dial-up) network. Beverley is not (presently) within mobile phone range. In addition, CB radio is used for contact with and between vehicles on site, and for contact with Arkaroola village. Two satellite phones are also available on site.
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Computer systems at Beverley and Adelaide are compatible and each is able to access the other. Other than dial-up telephone contact, email transmissions are the most frequent form of communication between the Beverley operations and the Adelaide office.
4.5.9 Visual Screening and Site Security The mine site is remote with one main access gate, and an airstrip. Road access is either from the west, via Leigh Creek and Copley, or from the south via Yunta (Figures 1-1 and 3-1). Most personnel, contractors and visitors arrive by the company aircraft and are subject to the new CASA security requirements including luggage checks and metal detector screening. The main access gate is locked and monitored from the plant. The existing mining operations, including the camp and processing areas are fenced. Furthermore, access to the processing plant is by security card only. The product area is subject to an additional level of security, with restricted access. As per Australian Nuclear Safeguards Office requirements, the processing area fence is checked weekly and a 2 m-gap maintained between buildings and the fence. The remoteness of the site and single entry access assists in ensuring that site visitors are identified, logged in and provided with the necessary safety and other briefings prior to gaining plant access. Any new wellfields in the ML extension would be fenced prior to operation. Due to the nature of ISL mining, it is anticipated that the proposed additional development will have negligible additional visual impact on the visual aesthetics of the area. Buildings and infrastructure are furthermore designed to blend in with the surrounding landscape (refer Section 3.2).
4.5.10 Emergency Emergency procedures are in place to cope with unanticipated incidents, and nominated emergency personnel are on call at all times. Heathgate maintains emergency protocols which are periodically updated to ensure currency. In event of a medical evacuation being required, the airstrip is available for Royal Flying Doctor Service use. For lesser situations, casualties may be taken to Leigh Creek hospital by ambulance or other vehicle.
4.6 Resource Inputs
4.6.1 Workforce Beverley currently provides over 150 full time jobs, with production crews working on a roster basis, flying in and out of the site. Heathgate strives to achieve high Aboriginal employment by proactive recruitment of Aboriginal people from the Flinders Ranges region (refer Section 5.1). Heathgate also employ a number of labour hire personnel, recruited on an ad hoc basis from Port Pirie- and Port Augusta-based employment agencies, creating further opportunities for the workforce of the region. Heathgate’s Adelaide based workforce undertook significant growth during 2005 with the implementation of an aggressive exploration program. As of late 2007, this exploration program workforce stands at 25 full-time, 3 casual and 2 part-time personnel. Maintaining this existing workforce relies upon an ongoing exploration program to discover additional resources. The proposed ML extension is central to this.
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4.6.2 Energy Sources The existing mine utilises gas, sourced from a spur from the main gas (Epic) pipeline, from Moomba to Adelaide. Similarly, the site has access to locally-generated electricity and telecommunication lines. The proposed development will also utilise these services. This may result in extended cabling from the existing to new operations.
4.6.3 Water Sources As noted in Section 3.10, there are three main aquifers in the vicinity of the Beverley Mine:
• Willawortina Formation (surface to ~95 m below ground level (bgl))
• Beverley Sands in the Namba Formation (105 – 140 m bgl)
• Great Artesian Basin (GAB) – Cadna-Owie Formation (330 – 380 m bgl).
The hydrogeology of the area, including the interpreted water flows, is shown diagrammatically in Figure 3-2. Water use for the Beverley mine comes from two sources: groundwater from the Namba Formation aquifer, which is largely recycled throughout the ISL process; and groundwater from the GAB, which is utilised for potable, plant and camp use. As noted in Section 4.5.7, reverse osmosis water treatment plants are used on the GAB water to meet potable standards. The locations of the three GAB bores on site are shown in Figure 8-3. Groundwater in the Beverley mineralised zone (the Namba) is saline, with Total Dissolved Solids up to 15,000 mg/L, and contains naturally occurring radioactive uranium and radium at many times drinking water limits. It is therefore entirely unsuitable as potable water, and the radioactivity renders it unsuitable, now and in the future, for agriculture or stock watering purposes. The much higher quality groundwater in both the underlying GAB and in part of the overlying Willawortina Formation is and will remain both suitable and available for stock and other uses. Additional information on hydrogeology is provided in Supporting Report C. An indicative current water balance for the South Australian part of the GAB has recently been updated, using the GABFLOW model (Armstrong 2005, reported in Arid Areas Catchment Management Board. 2006). The overall GAB usage by bores in South Australia was estimated to be an average of 128 ML/day. The GAB usage by the Beverley project for the period July 2006 to June 2007 varied from approximately 0.25-0.5 ML/day (averaged on a per monthly basis), which is a very small proportion of the overall GAB usage in South Australia. The flows to and from the Namba aquifer, as part of the ISL uranium extraction process, are also monitored. For the quarter ending March 2007, the extraction and injection rates averaged 20 ML/day; the water balance of extraction and injection was within 0.2%, i.e. the balance is essentially neutral.
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5 Description of Potent ial B enefit s 5.1 Social Beverley contributes over $2 m/year in Aboriginal Royalties, Administration & Community payments, $2.2 m/year in State Royalties, Taxes, Fees & Licenses, and about $30 m/year to regional and state businesses/suppliers. In association with Flinders Personnel of Port Pirie – and in line with commitments made in mining agreements with Adnyamathanha and Kuyani Native Title claimants – Heathgate strives to achieve 20 percent Aboriginal employment at the Beverley site7. Significant non-economic benefits can be expected to flow from increased employment, particularly in the Iron Triangle (Pt Pirie – Pt Augusta – Whyalla region), from which a major portion of direct employment is drawn. Heathgate have a pro-active employment policy directed to the Aboriginal community, and compensation flows to Native Title claimants. The social benefits include:
• Increased social wellbeing in the region as a flow-on from direct and indirect employment;
• Increased opportunity and independence in the Aboriginal community as a flow-on from influence of mining development and operation via advisory committees, and from royalties;
• From employment opportunities as well as associated skills training; and
• Proactive assistance for Aboriginal businesses. 5.2 Economic Beverley is a significant contributor to the South Australian economy through a number of avenues, including:
• Employment;
• Royalties; and
• Construction contracts. Accepting mining industry multipliers, it is estimated that Beverley has created up to 450 permanent jobs off site. This has led to additional wage income in the vicinity of $6 million a year, with associated payroll tax revenue to the State Government. Employees are drawn from the northern South Australia regional areas whenever possible. Further, with the approval of the proposed development, the Government will benefit through continuing annual royalty payments. Beverley's annual export income is currently a positive contributor to the national balance of payments. The current operations at Beverley are a $120 million investment, with an export income of about $100 million per annum and rising. Royalties to the state and Aboriginal communities are in the order of $6 million per annum.
7 With respect to non-professional site-based positions.
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5.3 Environmental There are a number of environmental benefits associated with development of the ML extension. These include:
• Removing introduced grazing animals from the active mining areas of the ML. Pastoral activity has resulted in substantial modification to natural vegetation. The ML extension would result in the removal of livestock from the active mining areas of the ML, allowing regeneration of vegetation in these areas.
• Heathgate operates a program of feral species management on the mine site. This would be extended to the proposed ML extension.
• Heathgate has been responsible for closing off free flowing bores in the area of the Beverley Mine Site. This work would continue with respect to the proposed ML extension.
• High net energy yields and low greenhouse gases using Heathgate’s uranium in nuclear power plants, compared with other methods of electricity generation. Using Life Cycle Analysis, nuclear power shows up very well as a net provider of energy and as an emitter of greenhouse gases (UIC 2006). In regard to the final point above, the Standing Committee on Industry and Resources, in the Inquiry on use of Australia’s uranium (Parliament of the Commonwealth of Australia 2006), made the following comments in the Foreword of their Report: ‘There is now a growing recognition that nuclear power makes a significant contribution to the mitigation of greenhouse gas emissions. Worldwide, nuclear power plants currently save some 10 per cent of total carbon dioxide (CO2) emissions from world energy use. This represents an immense saving of greenhouse gas emissions that would otherwise be contributing to global warming. If the world were not using nuclear power, emissions of CO2 would be some 2.5 billion tonnes higher per year. Nuclear power plants emit no greenhouse gas emissions at point of generation and very small quantities over the whole nuclear fuel cycle, from uranium mining through to waste disposal. Indeed, the Committee reports that nuclear power emits only 2 to 6 grams of carbon per kilowatt hour of electricity produced. This is two orders of magnitude less than coal, oil and natural gas, and is comparable to emissions from wind and solar power. A single nuclear power plant of one gigawatt capacity offsets the emission of some 7–8 million tonnes of CO2 each year, if it displaces use of coal. Nuclear power also avoids the emission of sulphur dioxide, nitrous oxide and particulates, thereby significantly contributing to air quality.
Australia’s uranium exports displace some 395 million tonnes of CO2 each year, relative to black coal electricity generation, and this represents some 70 per cent of Australia’s total greenhouse gas emissions for 2003.’ The Committee’s report quoted a comparison of greenhouse gas emissions, based on a study by Spadaro et al (2000); also reported by McDonald and Rogner (IAEA, 2002). This comparison is provided in Figure 5-1. The data from these various studies indicates that clear cash terms nuclear energy incurs about one tenth of the costs of coal. Also, the external costs for coal-fired power are a very high proportion (50-70%) of the internal costs, while the external costs for nuclear energy are a very small proportion of internal costs, even after factoring in hypothetical nuclear catastrophes. It is noted that all of the waste management costs in the nuclear fuel cycle are already internalised. The external costs of nuclear energy averages 0.4 euro cents/kWh, much the same as hydro, whereas coal is over 4.0 cents (4.1 - 7.3 cent averages in different countries), gas ranges from 1.3-2.3 cents and only wind shows up better than nuclear, at 0.1-0.2 cents/kWh average (UIC 2006). However wind (and
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Section 5 Description of Potential Benefits also solar) provide intermittent inputs of primary energy, with inevitably low capacity utilisation and relatively high energy costs in the plant (for silicon manufacture in the case of solar cells, or steel & concrete for wind turbines) (UIC 2006). In terms of greenhouse gas emissions, nuclear compares favourably with hydro, solar and wind, in the study by Spadaro (2002), as reported in McDonald and Rogner (IAEA, 2002) and the Parliament of the Commonwealth of Australia (2006) (Figure 5-1). Figure 5-1 Greenhouse Gas Emissions from Electricity Generation
Source: Spadaro et al (2000); also reported by McDonald and Rogner (IAEA, 2002), and Parliament of the Commonwealth of Australia 2006.
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6 Results of St akeholder Consultation 6.1 EIS stakeholder consultation process Many of the concerns raised by the public during the Beverley EIS process, undertaken in 1998, focussed on issues relating to general opposition to uranium mining and the use of nuclear material in the nuclear fuel cycle and nuclear weapons. A number of submissions were critical of the EIS process itself. The Guidelines for the EIS specified that these issues were outside the scope of this assessment. The major issues associated with the construction and operation of the Beverley Uranium Mine, as raised in the EIS process, are reflected in the contents of the EIS Assessment Report (Minister for Primary Industries, Natural Resources and Regional Development, South Australia, 1998):
• Hydrogeology and Water Use.
• Radiation Effects.
• Transport.
• Fauna and Flora.
• Aboriginal Heritage & Native Title.
• Environmental Monitoring & Rehabilitation.
• Issues Outside of the Scope of the EIS Process. The consultation process undertaken during the 1998 EIS set the framework for the ongoing consultation process undertaken since. For the proposed ML extension, more recent consultation has been undertaken. This is discussed below. 6.2 Extension ML stakeholder consultation process Heathgate has undertaken a widespread consultation process as part of the proposed Beverley ML extension. Heathgate furthermore acknowledges the benefits associated with undertaking stakeholder consultation. As part of this ongoing commitment to consultation and transparency, and recognising the importance of information dissemination on the environment, heritage management and Aboriginal issues in the region, a Visitor and Heritage Centre has been constructed at the mine site. Heathgate has also established different mechanisms for consultation with various stakeholder groups. The level and type of consultation varies between these groups. In preparation for formal negotiating meetings to develop a new Production Agreement, two workshops were held during 2005/2006 in order to achieve a mutual understanding of the needs and desires of both Heathgate and the Adnymathanha people. The focus of these workshops was to explore ways of working together to achieve sustainable outcomes for the Adnymathanha community. A key outcome of the workshops was the development of a partnership-based vision statement (developed by both Adnymathanha and Heathgate representatives) that is to guide the new agreement. The Native Title Claimants not only represent the whole Adnymathanha/Kuyani community, they also represent most of the major regional settlements such as Nepabunna, Iga Warta, etc. Formal negotiating meetings were held on 12 April 2007 and 24 July 2007 regarding the proposed ML extension. The key issues discussed included:
• The extension will not change anything at the current site – it will only change where the wellfields will be located;
• Reserves on the existing ML are being depleted and if the new ML is not granted, Beverley will run out of ore and close within a few years;
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• Heathgate has been successful in achieving high employment levels for Adnymathanha people and in protecting Aboriginal heritage and the environment; and
• Heathgate would like to work with the Adnymathanha people to produce sustainable benefits from the new agreement. The main outcome from the meetings is general agreement that the Adnymathanha people want the mine to continue, they want the benefits to be fairly distributed, and they want more employment and business opportunities. Heathgate has modified the draft production agreement to accommodate these outcomes, and a full community meeting will be held to consider the final draft of the agreement. A summary of the main elements of the consultation process, including ongoing arrangements and consultation undertaken specifically for the ML Extension, are summarised in Table 6-1.
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Section 6 Results of Stakeholder Consultation
Table 6-1 Results of Stakeholder Consultation
Stakeholder Type of Issues raised Response group stakeholder
Adnymathanha Regional Aboriginal Aboriginal employment There is general agreement by the Adnymathanha negotiating team that the mine should communities Communities continue. Aboriginal businesses More emphasis is needed on employment and business opportunities, issues that have been Environmental performance addressed in the new draft agreement.
Cross cultural matters Environmental performance is considered satisfactory.
Community benefits Additional cross cultural training will be given to supervising staff at Beverley.
Continuity of benefits Community benefits will continue and benefits will be more sustainable if the new ML is approved and the new agreement is implemented.
The new agreement has not yet been considered by a full community meeting.
Beverley Regional Aboriginal Environmental performance The Beverley advisory committee meet quarterly. In addition to providing a forum for Advisory Communities dissemination of information, the advisory committee presents an opportunity for the Aboriginal Committee Aboriginal employment community of the Northern Flinders Ranges to raise any issues of concern it may have.
Cross cultural matters Meetings are held in Adelaide, Port Augusta and at the Beverley site. The most recent was held at Beverley on 20 September 2007. Coming events The minutes of the meetings over the last few years show that the Adnymathanha community is satisfied with Heathgate’s employment and environmental performance.
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Adnymathanha Regional Aboriginal Protection of Aboriginal Throughout the life of the Beverley mine, Heathgate has conducted a number of Aboriginal Heritage Survey Communities heritage Clearances with Native Title Claimants as part of their extensive Exploration program. These teams clearances ensure that future activities will not interfere with Aboriginal heritage, and that past Environmental activities have been conducted in accordance with previous clearance reports. They also provide performance further consultation and ensure the local Aboriginal people are up to date with any mine developments.
The survey reports show that Heathgate takes its responsibilities seriously and has performed well in this area.
Adnymathanha Regional Aboriginal NAIDOC day Each year, Heathgate hosts NAIDOC Day celebrations at Beverley. The day consists of communities Communities speeches, flag raising, a mine tour and a BBQ in the creek featuring traditional camp oven cooked Aboriginal employment kangaroo and damper. The feedback from these events consistently shows that participants are satisfied with the performance at the mine. Cultural awareness Each year, Heathgate sends representatives to the Croc Festival to inform Adnymathanha school age children of career options.
Heathgate also has a recruitment drive each year at Quorn, Hawker, Leigh Creek, Iga Warta, Nepabunna and Port Augusta to inform Adnymathanha people of potential employment opportunities. The feedback shows that there is a lot of interest in working at Beverley, and the very high retention rate indicates that Aboriginal employees are happy to stay with Heathgate.
A range of other consultative mechanisms are used to ensure that the local Aboriginal communities are informed of progress at the mine. These include the following:
• regular contact with the aboriginal communities regarding Heathgate’s community payments to Nepabunna and Iga Warta (as the nearest Aboriginal communities to the mine). These funds are used for projects that benefit the communities, such as a school bus and a cultural centre.
• Heathgate operates a cross-cultural training program in partnership with representatives of the Adnyamathanha community, ensuring that all Beverley personnel have an understanding and appreciation of Aboriginal interests in the area. The most recent cross-cultural sessions were held at Iga Warta on 3 and 10 October 2007.
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Section 6 Results of Stakeholder Consultation
Pastoralists Farming Fencing and access to Heathgate is committed to maintaining a good working relationship with pastoralists. An active communities stock water at Wooltana program of consultation is in place. This includes: • Regular telephone contact and visits to various pastoral properties in the area – in particular Wooltana and Wertaloona to the south and Moolawatana and Murnpeowie to the north.
• Further, other pastoral properties ranging further north, south and east are recipients of the regular project newsletter, In Situ.
• Significant developments within the area are brought to the attention of the surrounding pastoral leaseholders or managers, by way of written and verbal communications, as required.
Heathgate will ensure that fencing changes at Wooltana will be discussed fully before implementation and that restrictions to access to water will be minimised.
The most recent meeting with the Wooltana station manager was held at site on 4 September 2007, which included discussion on Heathgate’s plans for mining in Deep South and Beverley East and the issue of stock access, as well as suggested changes to the stock watering network.
Individual Tourism Industry No issues of concern Heathgate has established close links with local tourism operators – in particular the Arkaroola Tourism were raised Wildlife Sanctuary, where Heathgate has hosted site tours to a range of visitors from Arkaroola. operators Feedback has been very supportive. The presence of the Beverley mine has assisted the sustainability of the Arkaroola Wildlife Sanctuary, particularly during the low tourist periods of the seasons.
Anti-uranium NGOs Radiation safety NGOs and others have access to environmental information by way of the Annual Environment Non- Report, as well as via Heathgate website www.heathgateresources.com.au Government Aquifer protection Organisations Where practicable Heathgate addresses environmental concerns through relevant forums, and Aboriginal heritage always endeavours to foster good relations with NGOs. (NGOs) The “Radioactive Exposure Tour” has been hosted by Heathgate. Approximately 50 members from Friends of the Earth toured the mine in their second annual tour. The return of this group has verified our rating of the success and once again positive feedback was received from this tour.
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Heathgate has detailed plans and procedures in place, and has a good record in the areas of concern to NGOs. It is fair to say, however, that information on this record is not accepted by most.
General Public Wider community Various Heathgate has continued with an active program to keep the wider community informed of the benefits the Beverley mine delivers for South Australia, the nation and the world, by contributing to the delivery of greenhouse friendly energy to the world. Several tours of the mine were conducted for the wider community during the past year.
The information program includes:
• updating and enhancing the Heathgate web site;
• an “open doors” policy to community inquiries;
• active involvement with all branches of the media, including news, current affairs and talkback radio;
• wide circulation of the project newsletter, In Situ;
• participation in industry forums;
• involvement with organisation such as the Northern Region Development Board and SA Great;
• involvement in the SA Chamber of Mines education program, including funding for educational packages for South Australian schools and the dedicated web site – www.uraniumsa.org
• a range of sponsorships focussed primarily in the north of the State.
Leigh Creek Service provider Ongoing demands on HGR participated in the Health Service Planning meeting held at Leigh Creek on 19 September Health Service Leigh Creek Health 2007, at which it was discussed that the planned ongoing presence of the Beverley mine be taken Service into consideration in the review of health services at Leigh Creek.
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Government Regulatory Environmental and safety issues Throughout the year Heathgate attended formal meetings with various government regulatory agencies regulatory bodies including the ISL Radiation Review Committee and the Beverley bodies Environment Consultative Committee (BECC). The most recent ISL Radiation Review Committee meeting was held at the SA EPA on 6 September 2007, and BECC last met on 31 May 2007, both in Adelaide.
In accordance with various licences and approvals held, formal reporting was also undertaken to a variety of State and Commonwealth Departments including: PIRSA; SA Water Resources; SA – EPA; Commonwealth Industry Tourism and Resources; and the Australian Safeguards and Non Proliferation Office.
A specific meeting was held with PIRSA regarding a preliminary draft of this Mining Lease Application document on 27 July 2007, at which the most recent Heathgate plans for the proposed extended ML were discussed.
Similarly, regular site inspections were undertaken by officers of various government regulatory bodies. Less formal communications also were conducted as required for the daily operation of the mine.
The record shows that regulatory agencies are satisfied with the performance at Beverley.
Heathgate Employees Continuity of employment An active social club is supported by management and all personnel receive copies of In- workforce Situ delivered to their home addresses. An internal staff newsletter is produced on an ad- hoc basis to facilitate communications and all employees are also kept informed via monthly meetings.
Heathgate has appointed two Aboriginal Liaison Officers. These part-time positions are intended to provide for direct Aboriginal contact with senior management, and mentoring and assistance to other Aboriginal employees.
The workforce clearly supports the ML extension and the continuation of employment.
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Section 7 Environmental, Social and Economic Aspects
7 Environm ent al, So ci al and E conom ic Asp ects 7.1 Context and Stakeholder Views The Beverley mine is located in a remote part of the State, between the eastern edge of the Northern Flinders Ranges and Lake Frome. There are few communities within proximity of the mine – notably (Figure 3-1):
• Arkaroola;
• Nepabunna; and
• Iga Warta. Heathgate recognises the importance of information regarding the environment, heritage management and Aboriginal issues in the region. In order to aid in community liaison, a Visitor and Heritage Centre has been constructed at the mine site. The mine furthermore has an extensive OH&S system and risk assessment process. Different community groups require different specific mechanisms for consultation. The level and type of consultation varies between these groups, as described in Section 6, Table 6-1. 7.2 Potential Impact Events A listing of all potential impact events associated with activities relating to the proposed ML extension, including construction and operational activities, has been developed. This includes any potential impacts relating to the following:
• Natural environment (including air quality, surface and underground water supplies, flora, fauna, landform stability etc.)
• Social environment (including public health, amenity, nuisance, fires, heritage, use of public resources etc.)
• Economic environment (including regional economy, individual landholder incomes, land values etc.) The basis for the determination of these issues involves application of a risk assessment methodology, which is set out in Section 7.4. The potential impact events include any major negative public perceptions (even if not technically justified). Such events will be considered as a social impact event and appropriately managed. The listing of potential impact events is provided at the end of this chapter (Table 7-4). The table includes reference to legislation, the assigned risk level, the control and management strategy, outcomes and outcome measurement criteria, which are discussed in the following sub-sections. 7.3 Applicable Legislation or standards A listing of legislation and standards relevant to the proposed Beverley mine extension is provided in Table 7-1. As noted above, reference is made to relevant legislation and standards in the potential impact events table at the end of this chapter (Table 7-1).
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Table 7-1 Relevant State and Commonwealth Legislation and Codes of Practice
State Legislation Commonwealth Legislation Commonwealth CoP SA State Codes of Practice
Aboriginal Heritage Act 1988 Aboriginal and Torrens Strait Islander Australian Code for the Transport Assessment of Underground Storage Systems (EPA Commission Act 1989 of Dangerous Goods by Road Guidelines, Feb 2005) Controlled Substances Act 1984 and Rail 1993 Aboriginal and Torrens Strait Island Bunding and Spill Management (EPA Guidelines, Re- Country Fires Act 1989 Heritage Act 1984 Code of Practice and Safety issued January 2004) Dangerous Substances Act 1979 Guide, Radiation Protection and Civil Aviation Act and Regulations Radioactive Waste Management Compliance and Enforcement (EPA Guidelines, 2005) Development Act 1993 Customs Tariff (Uranium Concentrate in Mining and Mineral processing, Disposal of Used Hydrocarbon Absorbent Materials Environment Protection Act 1993 Export Duty) Act 1980 ARPANSA, 2005 (EPA Guidelines, March 2004) and Regulations Customs (Prohibited Exports) Code of Practice, Safe Transport Draft Environment Protection (Site Contamination) Heritage Act 1993 Amendment Regulations 2000 (No. of Radioactive Material, Amendment Bill 2005 1), under the Customs (Prohibited ARPANSA, 2001 Mines and Works Inspection Act Exports) Act 1901 Environment Protection Authority Guidelines for 1920 and Regulations Department of Industry Tourism Responsible Pesticide Use, 2004 Environment Protection & Biodiversity and Resources documents Mine Mining Act 1971 and Regulations Conservation Act 1999 Closure and Completion (2006a), Environment Protection (Industrial Noise) Policy 1994 and Mine Rehabilitation (2006b). National Parks and Wildlife Act Environment Protection (Nuclear Environment Protection (Machine Noise) Policy 1994 1972 Codes) Act 1978 National Health and Medical Environment Protection (Waste Management) Policy Research Council (NHMRC) and Native Vegetation Act 1991 1994 Foreign Acquisitions and Takeovers National Occupational Health and Natural Resources Management Act 1975 Safety Commission (NOHSC) Environment Protection (Water Quality) Policy 2003 National standard for limiting Act 2004 Industrial Chemicals (Notification and Environment Protection Act 1993 (including the occupational exposure to ionizing Assessment) Act 1989 Environment Protection (Miscellaneous) Amendment Occupational Health Safety and radiation 1995. Welfare Act 1986 and Regulations Native Title Act 1993 Bill 2005) Pastoral Land Management and Nuclear Non-Proliferation Environmental Noise (EPA Information, Oct 2004) Conservation Act 1989 (Safeguards) Act 1987 Fire protection services pipework systems (EPA Public and Environmental Health Nuclear Safeguards (Producers of Guidelines, Re-issued Sept 2003) Act 1987 Uranium Ore Concentrates) Charge Waste tracking form (EPA Guidelines, 2003) Act 1993 Radiation Protection and Control Waste transport certificate (EPA Guidelines, Re-issued Act 1989 and Regulations Sept 2003)
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7.4 Likelihood and Severity of Consequence, Risk The risk assessment has been carried out based on Australian Standard AS/NZS 4360:2004 Risk Management. The methodology conforms generally with the criteria outlined in the Guidelines for the Preparation of a Mining Lease Proposal or Mining and Rehabilitation Program (MARP), version 4.8, (PIRSA June 2007) and the State-Commonwealth guidelines (DEWR/PIRSA 2007). The assessment has been prepared by URS Australia and Heathgate Resources taking into account the history of environmental management, regulation and reporting undertaken including during and since the production of the EIS in 1998. For clarification, the definitions and risk assessment matrix are outlined in Tables 7-2 and 7-3.
Table 77---22 Definitions of Likelihood and Severity and or Consequence
Ranking criteria Definition
LikLikelihoodelihood Almost certain Will occur, or is of a continuous nature, or the likelihood is unknown. Likely Likely to occur during mine lifetime. Possible Not likely to occur during mine lifetime, but may occur in some mines. Unlikely May occur in some mines. Rare Has almost never occurred in similar mines but conceivably could. Severity Insignificant Possible impacts but without noticeable consequence. Minor Some limited consequence but no significant long-term changes, and / or may be simply rehabilitated, not of significant concern to wider consequence community. Moderate Significant changes, may be rehabilitated with difficulty. Major Substantial and significant changes, will attract public concern, only able to be partially rehabilitated or uncertain if it can be successfully rehabilitated. Catastrophic Extreme permanent change to environment(not able to be practically rehabilitated), major public outrage or the consequences are unknown.
Table 77---33 Risk Assessment Matrix
Likelihood of Consequences
E D C B A
Rare Unlikely Possible Likely Almost certain
5 Insignificant Low Low Low Moderate High
4 Minor Low Low Moderate High High
3 Moderate Moderate Moderate High High Extreme
2 Major High High Extreme Extreme Extreme Severity of of Severity of Severity Severity of of Severity of Severity Consequence Consequence Consequence Consequence 1 Catastrophic High Extreme Extreme Extreme Extreme
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7.5 Control and Management Strategies Table 7-4 (at the end of this section) includes a description of all proposed control and management strategies to reduce the environmental impacts associated with the ML Extension. These strategies are set out opposite the potential impact event. The strategies for managing issues involve the implementation of technically and economically achievable best practice mining and environmental management techniques, including progressive rehabilitation where applicable and practicable. Control and management strategies detail one or more of the following:
• A change in design or procedures to avoid or reduce the likelihood of the impact occurring.
• A change in design or procedures to avoid or reduce the consequences of an event, should it happen. 7.6 Desired Outcomes The desired environmental outcomes for the establishment of additional wellfields and the ongoing operation of the Beverley Mine, can be expressed in the words of the environment policy (see Section 10:
• Waste minimisation;
• Zero pollution events;
• Compliance with all applicable laws and regulations concerning the environment;
• Environmental awareness training; and
• Minimum site disturbance. Desired outcomes for different aspects of.operations that affect the environment are discussed in the following sections and set out in Table 7-4. 7.7 Risks to Achieving Outcomes The main risks associated with potentially not meeting the desired outcomes are discussed below, and are later summarised in Table 7-4. The seven key risk areas are:
• Soils;
• Vegetation;
• Surface Water;
• Hydrogeology;
• Fauna;
• Radiation; and
• Heritage.
7.7.1 Soil Aspects
Context The soils of the Beverley area are described in Section 3.13. The nature of mining at Beverley requires the disturbance and in some cases removal and stockpiling of soil. It is not the disturbance of soil per se that could cause environmental impacts at Beverley; rather, it is the potential for soil disturbance to lead to other problems.
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Nevertheless, as the measures to avoid or minimise these effects are to do with soil stabilisation and the like, soil is considered as an aspect with risks to be assessed and ameliorated.
Potential Impacts - Soil Mine operations may degrade soil or allow additional erosion that could affect infrastructure (e.g. road washouts); cause vegetation death by exacerbated dust deposition; or delay final revegetation of the site and the return to the pastoral use, e.g. by compaction or other degradation including spills of mining solution, fuel or chemicals. The potential impacts considered in Table 7-4 are:
• Disturbance during planned development of wellfields. This includes road clearing; construction and maintenance; drilling of delineation, production and monitoring wells; and the installation of wellhouses, piping and electrical supply.
• Disturbance above the planned development, e.g. by installation of facilities without following the appropriate clearance procedures to minimise disturbance, or by off-road driving.
• Exacerbated erosion by wind or runoff that may damage infrastructure (repaired during operations) or jeopardise final revegetation by exposing subsoil less suitable for vegetation establishment and growth.
• Contamination of soil due to spills or overflows of mining solutions, waste water, fuel (diesel) or chemical contaminants. The inherent risks of these events are assessed as high to low without management. With management the risks are reduced to moderate to low.
Management Strategies - Soil The management strategies to minimise the risks of soil degradation and erosion have been used and progressively reviewed and improved at Beverley over the seven years of operations. These are summarised as follows:
• Actively manage activities to minimise disturbance areas.
• Prior to any planned disturbance issue an Environmental Clearance Permit and document any expected disturbance.
• Measure actual disturbance at completion of planned activity.
• Rehabilitate disturbed areas post closure of the wellfield, for suitability for later pastoral use (refer to Section 9).
• Lay main plant trunk lines on ground surface to minimise unnecessary soil disturbance.
• Provide regular stormwater turn-outs along roadways, to reduce water velocities.
• Provide and maintain stabilised tracks for areas with frequent traffic, reduce potential erosion, runoff and sedimentation issues.
• Use stone (gibber) or environmental matting cover to protect cut slopes from erosion during major rainfall events.
• Restrict down slope movement of soil from bared ground by stabilising soil surfaces.
• Establish silt fences or similar management tools to minimise the amounts of sediment entering creeks.
• Train all site employees and contractors on the importance of remaining on existing tracks.
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• Provide stabilised tracks for areas with frequent traffic.
• Require personnel to drive vehicles only on existing tracks (where possible).
• Where possible, install ponds, piping and associated infrastructure above the known 1 in 100 year ARI flood level.
• Visual assessment of infrastructure as part of routine maintenance, and following all major rainfall events of greater than 1-in-10 year ARI.
• Sufficient freeboard in ponds to ensure that a high rainfall event does not result in over-topping.
• Burial or installation of mechanical protection for piping that crosses creeks.
• Wellfield and trunk line shut down procedures for significant rainfall events.
• Use of visual assessment of infrastructure as part of routine maintenance.
• Staff adherence to procedures – no reversing in wellfields areas to avoid backing into wellheads or running over pipes, and keeping to defined tracks.
• Chemicals storage and processing areas appropriately bunded to contain potential spills.
• Undertake routine inspection of tanks and equipment used to store and transfer chemicals and process materials. Any deficiency in the integrity of any equipment discovered by the inspection is brought to the attention of the Senior Site Supervisor for appropriate corrective action.
• Implement and regularly update spill and emergency response procedures.
• Implement and regularly update standard operating procedures for handling of chemicals.
• Regular training of emergency response personnel.
Specific Outcomes - Soil Specific outcomes to be achieved by these management measures are:
• Ground disturbance occurs only for planned area of any new wellfield and associated access roads.
• All soil disturbance is undertaken using internal clearance procedure.
• No increase in erosion from rainfall runoff as a result of activities conducted at the Beverley Mine, which would compromise rehabilitation for later pastoral use.
• No unauthorised off-road driving.
• 6-monthly audit of authorised roads checking for unauthorised off-road tracks.
• No remaining soil contamination resulting from spill of mining fluids due to flood damage of mine infrastructure.
• No remaining soil contamination resulting from overtopping of ponds.
• No spill of mining fluids resulting from piping breakages.
• No serious harm to the environment (as defined in the Environment Protection [EP] Act 1993 [SA]) as a result of hazardous substances storage and handling.
• Should a spill occur, no residual spillage remains after clean-up that could cause serious harm to the environment (as defined in the EP Act).
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7.7.2 Vegetation Aspects
Context The soils of the Beverley area are described in Section 3.11. The nature of mining at Beverley requires the disturbance and removal of vegetation. The vegetation associations affected are widespread in the area and the proportion of vegetation removal is very small compared to the surrounding area, such that no species or vegetation associations are threatened by the Beverley operations. Nevertheless, because of the arid climate, establishment and growth of native vegetation after clearing is slow, and so it is important to minimise the removal of vegetation. This is the aim of the management strategies described below. It is noted that Heathgate have well established procedures for determination of Native Vegetation Significant Environmental Benefit (SEB) ratio and compensation for proposed wellfields and infrastructure development areas, in accordance with South Australian legislation and policy. This is detailed separately in Section 7.13.2.
Potential Impacts - Vegetation Disturbance and clearing of vegetation closely mirrors that of soil described above. The proportion of vegetation removal is very small compared to the surrounding area, such that no species or vegetation associations are threatened by the Beverley operations. However, locally the removal or degradation of vegetation has follow-on effects by the local temporary reduction in habitat for fauna (see Section 7.7.5) and can exacerbate erosion discussed in Section 7.7.1 above. The potential impacts considered in Table 7-4 are:
• Temporary loss of habitat reduction in vegetation species density and diversity compared to control sites.
• Disturbance causing increase in weed species.
• Importation of weed species by vehicle movement into the Mining Lease.
• Additional disturbance caused by off-road driving. These are assessed as having an inherent risk level of moderate to high without management. . With management the risks are reduced to moderate to low.
Management Strategies - Vegetation The management strategies to miminise the risks of vegetation disturbance and clearing have been used and progressively reviewed and improved at Beverley over the seven years of operations. All of the soil protection management strategies also apply to vegetation. The additional management strategies specific to vegetation alone are summarised as follows:
• Aerial Photography – comparisons with previous photographs to assess site wide vegetation cover changes
• Measure actual vegetation clearance at completion of activity.
• Prior to planned vegetation clearance identify and protect any vulnerable vegetation (fencing off).
• Determination of Native Vegetation Significant Environmental Benefit (SEB) ratio and compensation for proposed wellfields and infrastructure development areas (refer Section 7.13.2).
• Use of landscape function analysis / ecosystem function analysis (LFA / EFA) in planned new disturbed areas, to assess long-term rehabilitation and re-vegetation success
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• Prevent the establishment of additional non provenance species (other than naturalised species) within disturbed areas by spraying or removal.
• Train personnel to identify and report any alien species.
• Annual vegetation cover and weed species monitoring.
• Inspection of any mining equipment or vehicles for seeds prior to bringing onto Mining Lease, and cleaning if necessary.
Specific Outcomes - Vegetation All of the soil protection management strategies also apply to vegetation. Additional specific outcomes to be achieved by the combined soil and vegetation management measures are:
• Vegetation clearance occurs only for planned area of any new wellfield and associated access roads.
• Vegetation species density and diversity post closure is similar to control sites.
• No new non-provenance species establish in the Mining Lease.
7.7.3 Surface Water Aspects
Context The hydrology of the Beverley area is described in Section 3.9. The nature of mining at Beverley requires very little disturbance to the hydrology of the area, as there are no creek diversions or significant catchment area reductions or alterations required. However, road and pipelines do cross creeks of various sizes and flow potential, and the protection of these creeks and their associated ecology (mainly terrestrial vegetation, as there are no aquatic ecosystems involved) needs to be considered. These have parallels to soil protection discussed above.
Potential Impacts – Surface Water Potential impacts considered in Table 7-4 are:
• Watercourse contamination arising from release of mining solution due to flood damage to pipes, ponds and infrastructure, or from high rainfall causing overflow of ponds.
• Watercourse contamination arising from release of mining solution due to breakages of piping from poor welds or vehicle damage. These are assessed as having an inherent risk level of moderate to low without management. With management the risks are reduced to low.
Management Strategies – Surface Water The management strategies to minimise the risks associated with surface water have been used and progressively reviewed and improved at Beverley over the seven years of operations. Some of the soil protection management strategies also apply to surface water. No historic spills have affected surface water, rather the limited and short-lived nature of spills affect soil only. The management strategies listed in Table 7-4 are summarised as follows:
• Visual Inspection around site and review of Flood Management Plan as appropriate.
• Use of 1-in-100 year ARI flood level map in design of pipe routes and flood protection to minimise creek crossings.
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• Visual assessment of infrastructure as part of routine maintenance, and following all major rainfall events of greater than 1-in-10 year ARI.
• Sufficient freeboard in ponds to ensure that a high rainfall event does not result in over-topping.
• Visual assessment of infrastructure as part of routine maintenance.
• Staff adherence to procedures – no reversing in wellfields areas to avoid backing into wellheads or running over pipes, keeping to defined tracks.
Specific Outcomes – Surface Water Specific outcomes to be achieved by the above management measures are:
• No water contamination resulting from spill of mining fluids resulting from flood damage to mine infrastructure.
• No water contamination resulting from overtopping of ponds.
• No spill of mining fluids resulting from piping breakages.
7.7.4 Hydrogeological Aspects
Context The hydrogeology of the Beverley area is described in Section 3.8, and Supporting Documents A (Geology) and B (Hydrogeology) apply to the extension area. It is the uranium-bearing aquifers of the Beverley Sands (and in the case of Beverley East Zone 3, the Alpha Sands) that are mined and impacted by mining solution and in some cases disposal of waste water. As is discussed in Section 9.4.2, it is accepted by the regulators that there are no environmental values for the Beverley Aquifer, and no potential beneficial use of the Beverley Sand at the Beverley mine other than mining; Heathgate asserts the same for the Alpha Sands at Beverley East Zone 3. Therefore, it is the protection of the overlying Willawortina aquifer and underlying GAB Aquifer that is important, and this is the focus of this risk assessment and the management measures that have been adopted since the commencement of mining at Beverley. These have been refined over the seven years of mining with regular and intense interaction with stakeholders (including consultation specifically for the extension lease) and will be applied with the same review and improvement to future operations on the extended lease. Because the GAB in the Beverley area is a prescribed water course under the Natural Resources Management Act 2004 (SA), a water allocation and licence will be required (currently in preparation by the State government). When the licence is issued Heathgate will abide by its conditions.
Potential Impacts – Hydrogeology Potential impacts considered in Table 7-4 are:
• GAB water abstraction causing reduced pressure and water flow from other (pastoral) bores.
• Current and future possible use of the GAB is compromised by contamination of the GAB aquifer, arising from prolonged pressure drop in the GAB aquifer to less than the Namba aquifer, allowing potential contamination by the Namba aquifer.
• Future possible pastoral use of the Willawortina aquifer is compromised by leakage from the Namba mining aquifer to the Willawortina aquifer. These are assessed as having an inherent risk level of low without management. With management the risks are remain low but the likelihood is further reduced.
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Management Strategies – Hydrogeology The management strategies to minimise the risks associated with groundwater have been used and progressively reviewed and improved at Beverley over the seven years of operations. No historic excursions of mining solution or injected waste water into the official monitor well network have been recorded. The management strategies listed in Table 7-4 are summarised as follows:
• Reduce the demand for GAB water (and therefore maintain the hydrostatic pressure) via various strategies (summarised in Table 7-4).
• Monitor GAB water use, pressures and quality at Beverley and nearby pastoral bores
• Ensure bores are properly cased to ensure no leakage from the Namba mining aquifer to the Willawortina.
• Monitor Willawortina water quality and water levels.
Specific Outcomes – Hydrogeology Specific outcomes to be achieved by the above management measures are:
• No drawdown of the GAB that adversely affects other GAB users.
• No change, outside of natural background fluctuations, in the water quality of the GAB.
• Water licence conditions are met.
• No contamination of the Willawortina aquifer, which would compromise future possible pastoral use.
7.7.5 Fauna Aspects
Context The fauna of the Beverley area are described in Section 3.12, with recent survey information in supporting report E. The nature of mining at Beverley requires the disturbance and removal of vegetation and disturbance of other fauna habitat. The all fauna affected are widespread in the area and the proportion of habitat removal is very small compared to the surrounding area, such that no species are threatened by the Beverley operations. Nevertheless, it is considered important to minimise the impact on fauna, which is the aim of the management strategies described shortly. Small fauna may be killed during vegetation and soil clearing, but the main effect on fauna is displacement into surrounding habitat. Some additional fauna deaths occur accidentally due to traffic, falling into drilling pits or drill holes, or contact with mining solutions. Local populations of house mice have become established at the camp and plant, and it would be possible for feral predators such as cats and wild dogs, or herbivores such as goats to increase and put additional pressure on native fauna.
Potential Impacts - Fauna Potential impacts considered in Table 7-4 are:
• Disturbance due to wellfield development and access road construction, and operations, causing reduction in species density and diversity, and /or increase in feral animals.
• Fauna killed or injured by vehicles, causing reduction in abundance.
• Ingestion of water from water management ponds by birds or animals, causing reduction in abundance.
• Animals falling into drilling mud pits or drill holes, causing reduction in abundance.
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• General wastes attracting birds or feral animals. These are assessed as having an inherent risk level of moderate to low without management. With management the risks are remain low but the likelihood is further reduced for some aspects.
Management Strategies – Fauna The management strategies to minimise the risks associated with fauna have been used and progressively reviewed and improved at Beverley over the seven years of operations. Historic monitoring shows no mine-related decrease in fauna. The management strategies listed in Table 7-4 are summarised as follows:
• Assess and control the risk from direct hazards on fauna associated with development.
• Establishment and maintenance of clean water sources as an alternative to process water and ponds.
• Fencing of process and pond areas to exclude larger fauna.
• Backfilling of exploration and delineation drill holes.
• Replace stockpiled vegetation as habitat.
• Prohibition on pets within the lease area.
• Trap and destroy feral species at harbouring sites four times per year.
• Recreational hunting and firearms will be banned within the lease area.
• Terrestrial mammal and reptile trapping program utilising pitfall, Elliot and cat traps. Fauna will be identified, sexed, marked and re-released, and feral fauna destroyed.
• Speed limits within Mining Lease.
• Increase personnel awareness via inductions and notices.
• Fencing of ponds and process area to exclude larger fauna.
• Use of bird scaring devices, and physical chasing away of birds.
• Rapid backfilling and rehabilitation of mud pits, presence of drilling crews, and rescue of any trapped fauna.
• Identification of waste streams, and implementation of management systems to minimise waste generation.
• Periodic review of waste management technology with a view to adoption of cost-effective waste management methods.
• Fencing and locking of refuse facilities to prevent access by feral animals.
• Waste facilities constructed and maintained according to engineering specifications.
Specific Outcomes – Fauna Specific outcomes to be achieved by the above management measures are:
• No reduction of species density and diversity in the undisturbed part of the lease area when compared to the control areas.
• No increase in feral animals above local control areas.
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• No increase in feral animals or birds in the vicinity of the waste management facilities above local control areas.
7.7.6 Radiation Aspects
Context Natural radiation in the Beverley context is discussed in Section 3.17. The Radiation Management Plan and Radioactive Waste Management Plan (separately approved under the Radiation Protection and Control Act 1989) have been designed to enable Heathgate to critically review the radiological impact of the Beverley Mine site, and to demonstrate compliance with the requirements of the Licence issued under the Radiation Protection and Control Act (1982), administered by the Environment Protection Authority (EPA). The Plans provide details of any potential issues related to the occupational and environmental radiation at the Beverley Uranium Mine, and satisfy the monitoring and reporting requirements under relevant regulations and Codes of Practice for the commercial mining and milling of radioactive ores at Beverley. Operations are conducted in accordance with the Radiation Management Plan and Radioactive Waste Management Plan, the ARPANSA 2005 Code Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing, and the NHMRC / NOHSC (1995) National standard for limiting occupational exposure to ionizing radiation. Other key points are: • The Radiation Protection Division of the EPA was consulted before the background monitoring program was established.
• The ALARA principle (As Low As Reasonably Practicable) is applied to minimise the radiation dose to personnel and the public.
• Operations covered by the ARPANSA 2005 Code need to demonstrate use of Best Practical Technology (BPT). Heathgate does and will conduct all operations in a safe and responsible manner, and places the safety of workforce (employees and contractors) and protection of the environment ahead of commercial considerations. The radiation plans will be updated to include operations on the extended mining lease. For completeness, the risks, management measures and outcomes associated with the environment and public (i.e. not including mine workers) are outlined here and in Table 7-4, but full details are in the respective Plans, which are not part of the MLA/PER process. No specific environmental radiation guidelines exist for the general environment. Human protection guidelines and limits only are used. Regarding radon, modelling and monitoring was undertaken during the 1998 EIS, which established that the risk of radon exposure from the processing area and ponds is low. This has been confirmed by operational monitoring for the last seven years. Monitoring of other radiological measures has similarly confirmed low radiation exposure. For the lined ponds on site, experience in Australia and elsewhere has shown that whilst leakage rates from appropriately designed and constructed plastic lined ponds is very small, in practice a small number of defects are possible even with best practice. Historically there have been some minor pond leaks at Beverley, which have been repaired as soon as practicable. If an absolute zero tolerance is enforced, more damage may be done searching for small inconsequential leaks than leaving the very small leaks in place. Heathgate proposes to adopt an industry standard ‘Target Action Leakage Rate’ (TALR) above which leaks must be found and repaired. The rate chosen of 22 mL/m2/day is based on the paper by Peggs (2006). In practice leakage rates are normally undetectable, but the adoption of the TALR will avoid unnecessary and potentially counterproductive repair attempts for inconsequential leaks. It is noted that the thick unsaturated zone beneath the ponds to the Willawortina aquifer some 50 m beneath provides an effective additional barrier against potential impacts of leaks below the TALR.
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Potential Impacts - Radiation Potential impacts considered in Table 7-4 are: • Radon release from processing area and water management ponds increasing radiation doses to the environment or the public.
• Uranium-bearing dust released from drier and packaging area increasing radiation doses to workers or the public.
• Seepage from water management ponds causing soil contamination.
• Seepage from low level radioactive (LLR) Waste Facilities causing contamination of the Willawortina aquifer. These are assessed as having moderate to low inherent risk, which are reduced to low with management in place.
Management Strategies – Radiation The measures listed in Table 7-4 are a summary only of the radiation management arrangements at Beverley. Those listed are:
• Controls on tank ventilation, and radon monitoring and review.
• A dust extraction system is installed on the drier, which draws air and dusts from the drier through a fabric filter. The filtered air is then passed though a wet scrubbing system, followed by a High Efficiency Particulate Air (HEPA) filter prior to exiting via a stack in the roof of the packaging warehouse.
• The drier and packaging enclosure are both also equipped with dust extraction systems for collection of any fugitive dust that may be emitted from the drier or packaging operations. These systems both consist of fabric filters, equipped with secondary filters, prior to exiting though the stacks on the roof of the packaging warehouse
• Management practices include good maintenance, air sampling conducted in the drier and packing areas, and sampling of exhaust stack particles
• Water management ponds are lined with 1.5 or 2 mm HDPE, with 0.3 m compacted clay under. Slotted PVC pipes are installed within the compacted clay layer, which are used to detect and intercept any seepage that may occur from the ponds.
• Adoption of an industry standard ‘Target Action Leakage Rate’ (TALR) above which leaks must be found and repaired.
• LLR Waste Facility cells are fully lined on the sides and top with 2 mm HDPE, with 0.3 m compacted clay under, 0.5 m domed soil over, capped with 0.3 m clay and backfilled with compacted soil domed 0.3 m high to accommodate soil settlement. The base is sloped to one corner, and a slotted PVC pipe is installed within the compacted clay layer in this corner, which is used to detect any seepage that may occur from the ponds.
• Monitor wells are installed and monitored in the underlying Willawortina Aquifer (some 50 m below the surface, in the vicinity of the LLR facilities).
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Specific Outcomes – Radiation Specific outcomes to be achieved by the above management measures are:
• Radon levels are measured around the processing area and ponds.
• Monitored radiation doses to the public (and workers) are within applicable limits.
• Uranium emissions measured in stacks from drier and packaging area meet Radiation Management Plan commitments.
• No seepage is detected above the TALR.
• Monitoring of Willawortina water quality shows contamination is not occurring.
7.7.7 Heritage Aspects
Context The Heritage context of the Beverley area is described in Section 3.14 and Supporting Report E, and an Aboriginal Clearance will be provided in confidence to PIRSA before mining commences on the extension area (clearances are in place for other infrastructure and mining on ML6036). The maintenance of a good and mutually beneficial relationship with the Native Title Claimants is a high priority for Heathgate. Information here is a summary only.
Potential Impacts - Heritage Potential impacts considered in Table 7-4 are: • Maintain and improve the use of Aboriginal Heritage Clearance surveys.
• Protection of heritage sites in accordance with State and Commonwealth legislation (there are currently no listed heritage sites within the proposed ML extension).
• Check flagged areas for disturbance. The inherent risks associated with these impacts is considered high, reduced to moderate by the application of the management measures summarised below.
Management Strategies – Heritage The measures listed in Table 7-4 are:
• Maintain and improve the use of Aboriginal Heritage Clearance surveys.
• Protection of heritage sites in accordance with State and Commonwealth legislation (noting that there are currently no listed heritage sites within the proposed ML extension).
• Checking of flagged areas for disturbance.
Specific Outcomes – Heritage Specific outcomes to be achieved by the above management measures are:
• Compliance with legislative requirements.
• Adherence to commitments in agreements with Traditional Owners.
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7.8 Risk Acceptance Table 7-4 includes a description of the Potential Impact Events, associated Risk, and Control & Management Strategies devised to ensure that the risks (after control measures have been implemented) are managed to "As low as reasonably practicable" (ALARP) levels. The only instances where control & management strategies, outcomes and outcome measurement criteria for an event are not set out in Table 7-4 are where:
• The risk level for an event is deemed so low, that further specific control measures are not warranted. If this is case, no outcome, criteria or further monitoring may be warranted;
• The risk is considered acceptable in context of the mining industry and surrounding environment such that there are no control measures available;
• The cost of implementing further control measures is grossly excessive compared to the benefit obtained; or
• The risk is acceptable, given the other benefits that will arise from the mining operation, which will outweigh the risk. There are no events identified where further control measures are possible, but are not planned to be implemented. 7.9 Outcomes Table 7-4 includes a list of outcomes associated with those identified environmental, social and economic impacts and events and associated risks. Each outcome includes measurable assessment criteria developed in accordance with the risk acceptance methodology outlined in Section 7.4. 7.10 Outcome Measurement Criteria Table 7-4 provides criteria established to demonstrate the achievement of outcomes. All criteria developed are clear and measurable in accordance with the Guidelines for the Preparation of a Mining Lease Proposal or Mining and Rehabilitation Program (MARP), version 4.8, (PIRSA June 2007). In accordance with these guidelines, measurement criteria are outlined in more conceptual terms where background data are still to be acquired. These measurement criteria have however been incorporated into the monitoring plan, and will be presented in the MARP submission for the proposed ML Extension,at a later date. 7.11 Leading Indicator Criteria Table 7-4 includes a listing of all aspects with a high consequence event. Where an aspect/event relies significantly on a control strategy to reduce the risk, a leading indicator criteria has been developed. These are designed to give early warning that the control measure may be failing, and the outcome is potentially at risk of not being achieved. These are set out together with outcome measurement criteria in the column ‘Outcome Measurement Criteria’ in Table 7-4.
7.12 Ongoing Community Engagement Plan Heathgate is committed to ongoing consultation and transparency, and recognises the importance of information dissemination on any environment, heritage management and Aboriginal issues that might potentially be associated with the proposed Beverley Mine Extension. Different mechanisms for consultation with various stakeholder groups have been established (refer Table 6-1).
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7.13 Native Vegetation
7.13.1 Native Vegetation Management Heathgate will continue with its current operational practices for Native Vegetation and general ecosystem management, which includes:
• Identification of native vegetation and sensitive ecosystems as part of the Environmental Clearance Permit system. Site practices ensure no surface disturbances occur before an environmental clearance permit is issued;
• Fencing of identified sensitive vegetation and ecosystems;
• Re-location, wherever possible, of disturbance areas, drill sites and wellfield infrastructure to avoid sensitive vegetation and ecosystems;
• Determination of an approved road network to avoid sensitive areas wherever possible;
• Agreement on maximum disturbance area; this is recorded and tracked as a key performance indicator;
• Photographing and specimen collection to ensure correct identification of species and to assist with rehabilitation;
• Training and education of all site personnel;
• Details of rehabilitation requirements included on Environmental Clearance Certificate; and
• Rapid rehabilitation of completed areas (e.g. drilling sites are generally rehabilitated within weeks of completion). No native vegetation clearance will occur unless in accordance with the Native Vegetation Act, Regulations and the Significant Environmental Benefit (SEB) policy. Heathgate believes that with its current, proven management practices, disturbance of significant native vegetation within the extended ML area will be minimal. At the completion of mining in any particular area, it is expected that rehabilitation outcomes will be achieved rapidly, by having surrounding and interwoven vegetation throughout the area to assist with these processes. Heathgate’s Native Vegetation Plan will be translated into the current format in PIRSA’s guidelines in the MARP. However, the principles above will be maintained.
7.13.2 Significant Environmental Benefit Compensation As required under the South Australian Native Vegetation Regulations (2003) and according to PIRSA’s Guidelines for a Native Vegetation Significant Environmental Benefit Policy for the clearance of native vegetation associated with the minerals and petroleum industry, Heathgate has undertaken an assessment of flora in the extended ML area. This is provided in Section 3.11, with the latest information provided as Supporting Report D (earlier information comes from the EIS combined with routine annual monitoring of vegetation reported in Heathgate’s Annual Environmental reports). Supporting Report D has a final section that outlines the calculation of the Significant Environmental Benefit (SEB) ratios needed to calculate compensation for vegetation cleared, and the report as a whole provides general vegetation survey information for that part of the proposed ML. Actual SEB compensation ratios and areas cannot be calculated until the design of wellfields has been prepared, and the area has been surveyed by a suitably qualified botanist. Applications are thus made prior to the proposed development of any new wellfields area.
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Appendix C provides a recent example (covering letter only) for such an application, on 31 October 2006. Appendix D (Badman 2007) provides a more current example of a report and SEB calculation applicable to the eastern extension of the current Central Wellfield (expected to be one of the earliest areas of the extended ML in which a wellfield would be developed). It follows the method adopted and accepted for recent minor extensions of wellfields within ML 6036, for which SEB was required. Based on the assessment by Badman (2007), Heathgate proposes to adopt an SEB ratio of 4:1 for the area of potential disturbance for the eastern extension of the Current Central Wellfield (Beverley East Zones 1 and 2). Heathgate intends to fulfil its Native Vegetation SEB commitments for this area by allocating an area four times (in this case) the actual disturbance in a section of its pastoral lease, Wooltana Station, under suitable native vegetation management. However, the final calculations for this area and the equivalent assessment and calculations will be provided in the MARP application to be provided and approved ahead of mining. Heathgate may opt to fulfil part of its SEB compensation obligations by other means acceptable to PIRSA, such as monetary and in-kind contributions to suitable conservation projects in the district or payment into the Native Vegetation Fund administered by the South Australian Department for Environment and Heritage (DEH). SEB compensation is not required for clearing authorised prior to the implementation of the current rules. In the MARP, an account of pre- and post-SEB clearing authorisations for the extended lease (incorporating existing operations on ML 6036) will be provided. Currently, a compensation area of 4.6 ha has been calculated for recent clearing within ML 6036 for which SEB compensation was required8. It is intended that this management will be outsourced to the local Aboriginal communities, in an area adjacent to the Balcanoona Plains section of the existing Vulkathunha /Gammon Ranges National Parks for maximum benefit of contiguous conservation areas. The Native Vegetation Management Plan for the SEB compensation area is still being prepared and negotiated, and final locations will be confirmed following consultation with local Aboriginal groups. The area set aside will be sufficient to provide foreseeable SEB requirements for the new ML, with scope for future expansion if required for this ML or other possible future MLs in the district. The same procedure will be adopted to calculate SEB requirements for additional wellfields in the extended ML. Further information will be provided in the consolidated MARP for the extended ML. Heathgate Resources will keep an ongoing account of expected and actual clearing, and also the SEB compensation areas allocated, and report in the Beverley mine’s Annual Environment Reports.
8 Clearing of the original wellfields and plant is not subject to SEB compensation as clearing was approved prior to the SEB compensation provisions coming into effect.
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Table 7-4 Potential Impact Events & Management
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy SOILS
Soil disturbance due Likelihood: Possible Likelihood: Unlikely Ground disturbance occurs only Percent actual vs expected Actively manage activities to to a planned wellfield for planned area of any new disturbance area for each Consequence: Moderate minimise disturbance areas. Consequence: Moderate development and wellfield and associated access planned disturbance is less Risk: HIGH Risk: MODERATE associated access Prior to any planned disturbance roads. than 10% different. road construction, issue Environmental Clearance All disturbance undertaken using All required clearance resulting in land Permit and document expected internal clearance procedure. permits completed. becoming unsuitable disturbance. for return to pastoral use post closure. Measure actual disturbance at completion of planned activity.
Rehabilitation of disturbed areas post closure of the wellfield, for suitability for later pastoral use.
Increase in soil Likelihood: Possible Likelihood: Unlikely No ground disturbance occurs Percent actual vs expected Actively manage activities to disturbance areas beyond the planned area of any disturbance area for each Consequence: Moderate minimise disturbance areas. Consequence: Moderate due to a wellfield new wellfield and associated planned disturbance is less Risk: HIGH Risk: MODERATE development and Prior to any planned disturbance access roads. than 10% different. associated access issue Environmental Clearance All disturbance undertaken using All required clearance road construction, Permit and document expected internal clearance procedure. permits completed. beyond that planned, disturbance. resulting in land becoming unsuitable Measure actual disturbance at for return to pastoral completion of planned activity. use post closure. Rehabilitation of disturbed unplanned areas post closure of the wellfield, or before if possible, for suitability for later pastoral use.
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Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Erosion arising from Likelihood: Unlikely Prior to any planned disturbance Likelihood: Rare Number of incident reports of No increase in erosion from rainfall wellfield development issue Environmental Clearance erosion or sedimentation is Consequence: Minor Consequence: Minor runoff as a result of activities and access road Permit and document control less than 6 per annum as conducted at the Beverley Mine construction, causing Risk: LOW measures. Risk: LOW shown by summary of that would compromise gullying and inspections and outcomes rehabilitation for later pastoral use. sedimentation in Actively manage activities to nearby areas and in minimise disturbance areas. creeks, which may compromise Lay main plant trunk lines on ground rehabilitation for later surface to minimise unnecessary pastoral use. soil disturbance. Provide regular stormwater turn- outs along roadways, to reduce water velocities.
Provide and maintain stabilised tracks for areas with frequent traffic, reduce potential erosion, runoff and sedimentation issues. Use stone (gibber) or environmental matting cover to protect cut slopes from erosion due to major rainfall events. Restrict down slope movement of soil from bared ground by stabilising soil surfaces.
Establish silt fences or similar management tools to minimise the amounts of sediment entering creeks.
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Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Soil disturbance due Likelihood: Possible Train all site employees and Likelihood: Unlikely Number of reported incidents No unauthorised off-road driving. to off-road driving, Consequence: Minor contractors on the importance of Consequence: Minor of unauthorised off-road which may remaining on existing tracks. driving is less than 1 per Risk: MODERATE Risk: LOW compromise Provide stabilised tracks for areas week, averaged over the rehabilitation for later with frequent traffic. year. pastoral use. Require personnel to drive vehicles only on existing tracks where possible.
6-monthly audit of authorised roads checking for unauthorised off-road tracks
Soil contamination Likelihood: Possible Where possible, install ponds, Likelihood: Rare No remaining soil contamination No reported incidents of arising during high Consequence: Minor piping and associated infrastructure Consequence: Minor resulting from spill of mining fluids mining solution loss arising rainfall events, from above the known 1-in-100 year ARI due to flood damage of mine from flood damage causing release of mining Risk: MODERATE flood level. Risk: LOW infrastructure. soil contamination, for rainfall solution due to flood Visual assessment of infrastructure No remaining soil contamination events less than 1-in-100 damage to pipes and as part of routine maintenance, and resulting from overtopping of year ARI. ponds, or from following all major rainfall events of ponds. Records show no overflow of ponds. greater than 1-in-10 year ARI. overtopping of ponds. Sufficient freeboard in ponds to All soil contamination ensure that a high rainfall event requiring cleanup has bee does not result in over-topping. dealt with. Burial or installation of mechanical protection for piping that crosses creeks.
Wellfield and trunk line shut down procedures for significant rainfall events.
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Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Soil contamination Likelihood: Possible Visual assessment of infrastructure Likelihood: Unlikely No spill of mining fluids resulting Number of reported incidents arising from release Consequence: Minor as part of routine maintenance. Consequence: Minor from piping breakages. of mining solution loss from of mining solution due piping breakages causing Risk: MODERATE Staff adherence to procedures – no Risk: LOW to breakages of reversing in wellfields areas to avoid soil contamination is less piping, during backing into wellheads or running than 6 per annum. wellfields operation. over pipes, and keeping to defined tracks.
Spillage of hazardous Likelihood: Possible Chemicals storage and processing Likelihood: Rare No serious harm to the Spill incident reports substances (diesel, Consequence: Minor areas appropriately bunded to Consequence: Minor environment (as defined in the demonstrate that serious chemicals during contain potential spills. Environment Protection [EP] Act) harm to the environment (as Risk: MODERATE Risk: LOW transport, storage and Undertake routine inspection of as a result of hazardous defined in the EP Act) has handling) resulting in tanks and equipment used to store substances storage and handling. not occurred. contamination of soil. and transfer chemicals and process Should a spill occur, no residual materials. Any deficiencies in the spillage remains after clean-up integrity of any equipment that could cause serious harm to discovered by the inspection will be the environment (as defined in the brought to the attention of the EP Act). Senior Site Supervisor for appropriate corrective action. Implement and regularly update spill and emergency response procedures. Implement and regularly update standard operating procedures for handling of chemicals. Regular training of emergency response personnel.
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Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
VEGETATION
Disturbance arising Likelihood: Possible Aerial Photography – comparisons Likelihood: Unlikely Vegetation clearance occurs only Percent actual vs expected from planned wellfield Consequence: Moderate with previous photographs to assess Consequence: Moderate for planned area of any new disturbance area for each development and site wide vegetation cover changes wellfield and associated access planned disturbance is less Risk: HIGH Risk: MODERATE access road Prior to any vegetation clearance roads. than 10% different. construction resulting issue an Environmental Clearance Vegetation species density and Vegetation clearance is in in temporary loss of Permit and document expected diversity post closure is similar to accordance with approved habitat reduction in clearance. control sites. Native Vegetation vegetation species Measure actual vegetation Management Plan and SEB density and diversity provision. compared to control clearance at completion of activity. sites, following Prior to planned vegetation Vegetation species density rehabilitation. clearance identify and protect any and diversity post closure is vulnerable vegetation. similar to control sites. Laying of main plant trunk lines on ground surface to minimise unnecessary vegetation clearances. Determination of Native Vegetation Significant Environmental Benefit (SEB) ratio and compensation for proposed wellfields and infrastructure development areas (refer Section 7.13.2). Use of LFA / EFA in planned new disturbed areas, to assess long-term rehabilitation and re-vegetation success.
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Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Disturbance arising Likelihood: Unlikely Aerial Photography – comparisons Likelihood: Rare Vegetation clearance occurs only Percent actual vs expected from unplanned Consequence: Moderate with previous photographs to assess Consequence: Moderate for planned area of any new disturbance area for each wellfield development site wide vegetation cover changes wellfield and associated access planned disturbance is less Risk: MODERATE Risk: MODERATE and access road Prior to any vegetation clearance, roads. than 10% different. construction causing issue an Environmental Clearance Vegetation species density and Vegetation clearance is in reduction in Permit and document expected diversity post closure is similar to accordance with approved vegetation species clearance. control sites. Native Vegetation density and diversity Measure actual vegetation Management Plan and SEB compared to control provision. sites, following clearance at completion of activity. rehabilitation. Prior to planned vegetation Vegetation species density clearance identify and protect any and diversity post closure is vulnerable vegetation. similar to control sites . Laying of main plant trunk lines on ground surface to minimise unnecessary vegetation clearances. Determination of Native Vegetation Significant Environmental Benefit (SEB) ratio and compensation for proposed wellfields and infrastructure development areas (refer Section 7.13.2). Use of LFA / EFA in planned new disturbed areas, to assess long-term rehabilitation and re-vegetation success.
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Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Disturbance causing Likelihood: Possible Prevent the establishment of Likelihood: Unlikely No new non-provenance species Annual vegetation cover and increase in weed Consequence: Minor additional non provenance species Consequence: Minor establish in the Mining Lease. weed species monitoring species. (other than naturalised species) shows no increase in weed Risk: MODERATE within disturbed areas by spraying Risk: LOW species compared with or removal. control areas.
Train personnel to identify and report any alien species.
Annual vegetation cover and weed species monitoring.
Importation of weed Likelihood: Possible Inspection of any mining equipment Likelihood: Unlikely No new non-provenance species Annual vegetation cover and species by vehicle Consequence: Minor or vehicles for seeds prior to Consequence: Minor establish in the Mining lease. weed species monitoring movement into the bringing onto Mining Lease, and shows no increase in weed Mining Lease. Risk: MODERATE cleaning if necessary. Risk: LOW species compared with Prevent the establishment of control areas. additional non provenance species (other than naturalised species) within disturbed areas by spraying or removal. Train personnel to identify and report any alien species.
Annual vegetation cover and weed species monitoring.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Vegetation Likelihood: Possible Training of all site employees and Likelihood: Unlikely No unauthorised off-road driving. Number of reported incidents disturbance due to Consequence: Minor contractors on the importance of Consequence: Minor of unauthorised off-road off-road driving. remaining on existing tracks. driving is less than 2 per Risk: MODERATE Risk: LOW Provision of stabilised tracks for month, averaged over the areas with frequent traffic. year.
Personnel are required to drive vehicles only on existing tracks where possible.
6-monthly audit of authorised roads checking for unauthorised off-road tracks
SURFACE WATER
Watercourse Likelihood: Unlikely Visual Inspection around site and Likelihood: Rare No water contamination resulting No reported incidents of contamination arising Consequence: Minor review of Flood Management Plan Consequence: Minor from spill of mining fluids resulting mining solution loss arising from release of as appropriate. from flood damage to mine from flood damage causing Risk: LOW Risk: LOW mining solution due to Use of 1-in-100 year ARI flood level infrastructure. water contamination, for flood damage to map in design of pipe routes and No water contamination resulting rainfall events less than 1-in- pipes, ponds and flood protection to minimise creek from overtopping of ponds. 10 year ARI. infrastructure, or from crossings. No overtopping of ponds. high rainfall causing overflow of ponds. Visual assessment of infrastructure as part of routine maintenance, and following all major rainfall events of greater than 1-in-10 year ARI. Sufficient freeboard in ponds to ensure that a high rainfall event does not result in over-topping.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Watercourse Likelihood: Possible Visual assessment of infrastructure Likelihood: Unlikely No spill of mining fluids resulting Number of reported incidents contamination arising Consequence: Minor as part of routine maintenance. Consequence: Minor from piping breakages. of mining solution loss from from release of piping breakages causing Risk: MODERATE Staff adherence to procedures – no Risk: LOW mining solution due to reversing in wellfields areas to avoid watercourse contamination breakages of piping backing into wellheads or running does not exceed 1 per from poor welds or over pipes, keeping to defined annum. vehicle damage. tracks. HYDROGEOLOGY
GAB water Likelihood: Unlikely Reduce Beverley’s demand for GAB Likelihood: Rare No drawdown of the GAB that Analysis of pressure trend abstraction causing Consequence: Minor water via the strategies outlined in Consequence: Minor adversely affects other GAB users. data for nearby pastoral reduced pressure and the Beverley Mine Water bores shows no effect arising water flow from other Risk: LOW Management Plan, including: Risk: LOW from Beverley’s GAB water (pastoral) bores. • Increase employee awareness usage that affects pastoral of the worth of the GAB as a GAB use in the area. water resource; • Implement water saving equipment, procedures and programs; • GAB use not to exceed that specified by license conditions; and • Involvement in and assistance with the GAB bore rehabilitation program in the local area, specifically converting free flowing pastoral bores and open bore drains into capped and piped systems, which maintains pressures and also minimises the ecological and soil impacts of open bore drains.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Current and future Likelihood: Rare Maintain GAB pressures by recycle Likelihood: Rare No change, outside of natural The relative pressure possible use of the Consequence: Minor and re-use of various water streams Consequence: Minor background fluctuations, in the difference between the GAB GAB is compromised and the implementation of a water water quality of the GAB. and Namba aquifers remains Overall Risk: LOW Overall Risk: LOW by contamination of treatment system to best manage Water licence conditions met. positive. the GAB aquifer, ionic concentrations. Monitoring demonstrates no arising from Monitor GAB water use and contamination of the GAB prolonged pressure pressures in Beverley and nearby aquifer. drop in the GAB pastoral GAB bores. aquifer to less than the Namba aquifer, allowing potential contamination by the Namba aquifer..
Future possible Likelihood: Unlikely Ensure bores are properly cased to Likelihood: Unlikely No contamination of the Monitoring demonstrates no pastoral use of the Consequence: Minor ensure no leakage from the Namba Consequence: Minor Willawortina that would contamination of the Willawortina aquifer is mining aquifer to the Willawortina. compromise it future possible Willawortina aquifer that Risk: LOW Risk: LOW compromised by Monitor Willawortina water levels pastoral use. would compromise it future leakage from the and quality. possible pastoral use. Namba mining aquifer to the Willawortina aquifer.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy FAUNA
Disturbance due to Likelihood: Possible Assess and control the risk from Likelihood: Unlikely No reduction of species density Results of monitoring wellfield development Consequence: Minor direct hazards on fauna associated Consequence: Minor and diversity in the undisturbed program, as set out in control and access road with development. part of the lease area when and management strategy, Risk: MODERATE Risk: LOW construction, and Establishment and maintenance of compared to the local area. show no reduction of species operations, causing: clean water sources as an No increase in feral animals above density and diversity, and no • reduction in alternative to process water and local area background. increase in feral animals, species density ponds. compared with local area background. and diversity, and Fencing of process and pond areas /or to exclude larger fauna. • increase in feral Backfilling of exploration and animals delineation drill holes. Replace stockpiled vegetation as habitat. Prohibition on pets within the lease area. Trap and destroy feral species at harbouring sites 4 times per year. Recreational hunting and firearms will be banned within the lease area. • Terrestrial mammal and reptile trapping program utilising pitfall, Elliot and cat traps. Fauna will be identified, sexed, marked and re-released, and feral fauna destroyed.
Fauna killed or Likelihood: Unlikely Speed limits within Mining Lease. Likelihood: Rare No significant decrease in animal Results of monitoring injured by vehicles Consequence: Minor Increase personnel awareness via Consequence: Minor or bird abundance compared to program show no decrease causing reduction in inductions and notices. control areas arising from vehicle in feral animals or birds, abundance Risk: LOW Risk: LOW impact. compared with local area background
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Ingestion of water Likelihood: Unlikely Fencing of ponds and process area Likelihood: Rare No significant decrease in animal Results of monitoring from water Consequence: Minor to exclude larger fauna. Consequence: Minor or bird abundance compared to program show no decrease management ponds Use of bird scaring devices. control areas arising from water in feral animals or birds, by birds or animals Risk: LOW Risk: LOW ingestion compared with local area causing reduction in Physical chasing away of birds. background abundance.
Animals falling into Likelihood: Unlikely Rapid backfilling and rehabilitation Likelihood: Rare No significant decrease in animal Results of monitoring drilling mud pits or Consequence: Minor of mud pits; Consequence: Minor or bird abundance compared to program show no decrease drill holes causing Presence of drilling crews. control areas arising from water in feral animals or birds, reduction in Risk: LOW Risk: LOW ingestion compared with local area abundance Rescue of trapped fauna. background
General wastes Likelihood: Rare Identification of waste streams, and Likelihood: Rare No increase in animals or birds in Results of monitoring attracting birds or Consequence: Minor implementation of management Consequence: Minor the vicinity of the waste program show no increase in animals. systems to minimise waste management facilities. animals or birds, compared Risk: LOW Risk: LOW generation. with local area background Periodic review of waste management technology with a view to adoption of cost-effective waste management methods. Fencing and locking of refuse facilities to prevent access by feral animals. Use of bird scaring devices. Waste facilities constructed and maintained according to engineering specifications.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy RADIATION MANAGEMENT
Radon release from Likelihood: Rare The management practices include Likelihood: Rare Radiation doses to the public (and Radon levels measured processing area and Consequence: Minor controls on tank ventilation, and Consequence: Minor workers) are within applicable around the processing area water management radon monitoring and review. limits. and ponds. Risk: LOW Risk: LOW ponds increasing Monitored radiation doses to radiation doses to the the public (and workers) are environment or the within applicable limits. public.
Uranium-bearing dust Likelihood: Rare The drying system installed at the Likelihood: Rare Radiation doses to the public (and Uranium emissions released from drier Consequence: Moderate Beverley Uranium Mine is Consequence: Minor workers) are within applicable measured in stacks from and packaging area categorised as a low emissions limits. drier and packaging area increasing radiation Risk: MODERATE drier. A dust extraction system is Risk: LOW meet Radiation Management doses to workers or installed on the drier, which draws Plan commitments. the public. air and dusts from the drier through Monitored radiation doses to a fabric filter. The filtered air is then the public (and workers) are passed though a wet scrubbing within applicable limits. system, followed by a High Efficiency Particulate Air (HEPA) filter prior to exiting via a stack in the roof of the packaging warehouse. The drier and packaging enclosure are both also equipped with dust extraction systems for collection of any fugitive dust that may be emitted from the drier or packaging operations. These systems both consist of fabric filters, equipped with secondary filters, prior to exiting though the stacks on the roof of the packaging warehouse. The management practices comprise good maintenance, air sampling conducted in the drier and packing areas, and sampling of exhaust stack particles.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Seepage from water Likelihood: Possible Water management ponds 1-4 are Likelihood: Rare No seepage from the primary No seepage from the primary management ponds Consequence: Minor double lined with a primary 1.5 or Consequence: Minor HDPE liner of water management HDPE liners detected above causing soil 2 mm HDPE liner, and a secondary ponds 4 and 5 greater than a the TALR level (ponds 4 and contamination. Risk: MODERATE 0.3 m compacted clay liner under. Risk: LOW TALR for properly constructed 5). Slotted PVC pipes are installed geomembrane liners of 2 No seepage from the primary within the secondary compacted 22 mL/m /day (reference: Peggs HDPE liners of ponds 1-4 clay layer, which are used to detect 2006). greater than that which can and intercept any seepage that may fill the leak detector pipes in No seepage to the secondary clay occur from the primary liner. less than 24 hours. liner of ponds 1-4 greater than that The larger ponds 4 and 5 are double which can fill the leak detector lined with HDPE above compacted pipes in less than 24 hours. clay with leak detection between the HDPE liners.
Adopt an industry standard ‘Target Action Leakage Rate’ (TALR) for the primary liner, above which leaks must be found and repaired (Ponds 4 and 5). Leaks from the primary liner above the TALR level will be repaired (Ponds 4 and 5). Ponds 1-4 will be periodically cleaned and inspected, and any damage to the liner will be repaired.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 7 Environmental, Social and Economic Aspects
Potential Impact Inherent Risk LevelLevel Control & Management Residual Risk Level Outcome Measurement Criteria Event Strategy
Seepage from low Likelihood: Rare LLR Waste Facility Pits are fully Likelihood: Rare No seepage from the LLR Waste Monitoring of Willawortina level radioactive Consequence: Minor lined on the sides and top with Consequence: Insignificant Facility Pits. water quality shows (LLR) Waste Facility 2 mm HDPE, with 0.3 m compacted contamination is not Risk: LOW Risk: LOW Beneficial use of underlying Pits (used for solid clay under, 0.5 m domed soil over, Willawortina (stock water) not occurring. waste disposal), capped with 0.3 m clay and compromised. causing backfilled with compacted soil contamination of the domed 0.3 m high to accommodate Willawortina aquifer. soil settlement. The base is sloped to one corner, and a slotted PVC pipe is installed within the compacted clay layer in this corner, which is used to detect any seepage that may occur from the ponds. Monitor wells are installed and monitored in the underlying Willawortina Aquifer (some 50 m below the surface in the vicinity of the LLR facilities). HERITAGE
Impacts on Aboriginal Likelihood: Rare Maintain and improve the use of Likelihood: Rare Compliance with legislative Documented Aboriginal heritage as a result of Consequence: Major Aboriginal Heritage Clearance Consequence: Moderate requirements and commitments in Heritage Clearance surveys mine activity. surveys. agreements with Traditional of all disturbed areas Risk: HIGH Risk: MODERATE Protection of heritage sites in Owners. Audits show flagged areas accordance with State and are not disturbed. Commonwealth legislation (there are currently no listed heritage sites within the proposed ML extension). Check flagged areas for disturbance.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
8 Monitoring Program 8.1 Overview To determine the impact on the environment from operations at Beverley, and measure the effectiveness of the management strategies, a comprehensive monitoring program has been implemented. The tables in this section summarise the Beverley monitoring program. 8.2 Meteorology Table 8-1 Meteorology Monitoring Program
Locations Method Parameter Frequency
Anemometer Wind Speed 10 minute averages Weather Tower – 3 m, Wind Vane Wind Direction 10 minute averages 10 m & 28 m Probe Temperature 10 minute averages Pluviometer – Continuous Rainfall 10 min totals during meter, Tipping Bucket type. Logged Rainfall rainfall event signal every 0.2 mm. Weather Tower – Evaporation Pan – Decrease or Ground Level Increase in Pan level measured then adjusted to set point. Evaporation Evaporation Daily measured in millimetres following adjustment for any rainfall.
Note: - All instrument loggers are sent for calibration once every two years, as per the manufacturers’ recommendations. 8.3 Landscape (Soils and Vegetation) Landscape function analysis (LFA) (Tongway and Hindley 2004) is used by Heathgate Resources to measure the rehabilitation performance of the Beverley site, and is undertaken by a qualified environmental officer. This technique is less prone to climatic variations than other commonly used parameters, and provides information on the landscape, flora and fauna. Table 8-2 Landscape Monitoring Program
Location Method Parameter Frequency
Determination of: geographic setting of site; landscape organisation and Landscape Function soil surface assessment (rain splash Analysis (LFA) Soil stability, water protection, perennial vegetation cover, traverses at both infiltration and nutrient Annually litter, cryptogram cover, crust analogue (control) and recycling brokenness, soil erosion, deposited disturbed areas materials, surface roughness, surface nature, slake test, texture) Point centred quarter – sampling Lease and Local Area points established on LFA transect at Species Richness and regular intervals – at each point structure of grasses, Annually
distance to nearest plant in each of shrubs and trees four sectors measured Opportunistic watch –look for and Number of each alien Following rainfall and record any alien species. species during Annual Survey
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
Aerial photograph – comparisons with previous photographs to assess site Vegetation cover Annually wide vegetation cover changes Prior to any planned disturbance issue Environmental Clearance Permit and Percent Actual vs For each planned Lease Area document expected disturbance. Expected Disturbance disturbance Measure actual disturbance at Area completion of activity Prior to any planned disturbance issue Environmental Clearance Permit and Percent Actual vs For each planned Lease Area document expected disturbance. Expected Disturbance disturbance Measure actual disturbance at Area completion of activity
The LFA monitoring program would be extended into the ML extension area, as new areas are disturbed. 8.4 Fauna Table 8-3 Fauna Monitoring Program
Location Method Parameter Frequency
Terrestrial mammal and reptile trapping program utilising a line of pitfall traps with nearby Elliot and cat traps. Fauna will be Annually – 6 day identified, sexed, marked and re-released Lease and Local survey Area at established unless otherwise required by trapping permit points. See map in (e.g. tissue samples taken for SA Museum). Appendix 1 Undertaken at all sites 500 m Bird Transect – Walked traverse logging species and abundance. Undertaken Annually at all sties Microchiropteran bat trapping - Using harp net Annually – 6 day BU-12 each night. survey 3 evenings during Anabat – Recorded data and send to North Mulga Dam annual 6 day specialist consultant for analysis Total number of fauna survey Bird Transect - Walked traverse logging species and Monthly species and abundance. abundance at each site Microchiropteran bat trapping - Mist Net set Process Ponds up for evenings that wind conditions allow. 3 evenings during annual 6 day Anabat – Record data and send to specialist fauna survey consultant for analysis. Macropod Count – Drive in vehicle on set path Wooltana Cross and count number of macropods (native and Monthly Roads to Airstrip feral) for each species. Bird Transect - Walked traverse logging Monthly 4-mile bore wetland species and abundance. Opportunistic sighting Annually Spotlight traverse – Drive at night with Lease and Local spotlight randomly around site and local area Annually Area roads recording number and species of feral animals.
The fauna monitoring locations are shown in Figure 8-1.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
Figure 8-1 Ecological Monitoring Locations
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
8.5 Surface hydrology Table 8-4 Surface Hydrology Monitoring Program
Locations Method Parameter Frequency (refer Figure 8-2)
Visual Inspection around site and review of Flood Management Plan as appropriate Jenny Creek and Following rainfall N/A associated flood plain events of >10 year ARI Review, assess and update (if necessary) modelled 1-in-100 year ARI flood level map.
Surface sediment grab up and Chemical parameters downstream of local creeks including radionuclides Following Rainfall Mine Site Events that result in Visual Inspection around site and surface water runoff review of Erosion Management N/A Plan as appropriate
Figure 8-2 Hydrology Monitoring Locations
Camp
Wellfield
Plant
Airstrip
1. Locations for estimation of stream flow following 10 year ARI – Green lines 2. Soil Sampling Locations – red star in circle
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
8.6 Hydrogeology Table 8-5 Great Artesian Basin Well Sampling Program
Location Method Parameter Frequency
Draw down – Analysis of pressure data for Continual logged Pressure any trending artesian pressure drops. data Flow rate totaliser – Continuous flow meter Volume Continual when flow Plant GAB Bores (2) and with data logger. 4-Mile Bore (refer Figure Major ions, 8-3) selected heavy Water sample – Grab sample from GAB tank metals, pH, Annually Electrical conductivity Figure 8-3 GAB bore locations
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
8.7 Wastes The current waste monitoring programs as required by Heathgate’s authorities to operate (PIRSA MARP and EMMP, Radiation Waste Management Plan etc) are set out in Tables 8.6 to 8.8. The monitoring programs set out in these tables will be continued on approval of the new ML, with ongoing review and revision under the current (and future) regulatory arrangements. Table 8-6 Environmental Liquid Waste Monitoring Program
Location Method Parameter Frequency
Monitor Well Ring Tape and probe Standing Water Level Fortnightly
Collection of water sample pH Fortnightly site lab Conductivity Sulphate Quarterly NATA lab
U(total)
Willawortina Monitor Wells Tape and probe Standing Water Level Fortnightly
Data logging piezometer Standing Water Level Continuous
Collection of water sample pH Fortnightly site lab Conductivity Sulphate Quarterly NATA lab
U(total)
Disposal Well Monitor Tape and probe Standing Water Level Fortnightly Wells
Disposal Well re-injection Grab sample pH Quarterly liquids Conductivity Sulphate
U(total) Ra-226
Pumped volume totaliser Volume Continuous when flow
Holding Ponds Grab sample pH Quarterly Conductivity Sulphate
U(total) Ra - 226
Leak detection system Check for moisture Weekly
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
Table 8-7 Environmental Solid Waste Monitoring Program
Location Method Parameter Frequency
Each Wellfield Survey Gamma dose rate at 1m Prior to new Wellfield Development
After closure of Wellfield
LLR waste temporary Estimate quantity Cubic metres Annually storage compound
Evaporation ponds Estimate sludge Volume Cubic metres Annually
Grab Sample Ra-226 Annually U-Total Th-230 Pb-210
LLR disposal Facility Inspection If water present, sample Quarterly Inspection well Ra-226 U-238 Th-230
Survey Gamma dose rate at 1m Prior to installation
On closure
TLD Personal Gamma Dose All personnel during transfer
Person Air Sampler Long Lived Alpha Activity During transfer in Dusts
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
Table 8-8 Environmental Airborne Monitoring Program
Location Method Parameter Frequency
North Project Area Passive monitor Rn Continuous - Quarterly
North Project Area Passive monitor Dust - Ra-226, U-238, Th- Continuous - Quarterly 230, Pb-210
East Project Area Passive monitor Rn Continuous - Quarterly
East Project Area Passive monitor Dust - Ra-226, U-238, Th- Continuous - Quarterly 230, Pb-210
South Project Area Passive monitor Rn Continuous - Quarterly
South Project Area Passive monitor Dust - Ra-226, U-238, Th- Continuous - Quarterly 230, Pb-210
West Project Area Passive monitor Rn Continuous - Quarterly
West Project Area Passive monitor Dust - Ra-226, U-238, Th- Continuous - Quarterly 230, Pb-210
Accommodation Area Passive Monitor Rn Continuous - Quarterly
Continuous Monitor Rn Decay Products - Continuous 2 months per PAEC quarter
High Volume Sampler Ra-226 Continuous 2 months per quarter U-238 Th-230
Plant Area Passive Monitor Rn Continuous - Quarterly
Wellfield Area Passive Monitor Rn Continuous - Quarterly
Dryer and Packaging Grab sample U-total in particulates Quarterly System Exhausts
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
8.8 Restricted Release Zone An approved Restricted Release Zone (RRZ) is in place at the Beverley operations. The RRZ has been implemented in accordance with the ARPANSA 2005 Code, Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing. The current RRZ was approved on 6 October 2000; the plan of this area is shown in Figure 8-4. The RRZ currently includes the production plant with associated ponds, the North, Central and South Beverley wellfields, the trunkline and the LLR Waste Disposal Facility. The Code requires that procedures be developed to restrict infiltration of leach solutions beyond the RRZ, and that a monitoring program be established to detect and give the earliest possible warning of excursions in the wellfield. This monitoring program is described in Table 8-9. It is proposed that as new wellfield areas and trunklines are developed in the extended ML, application would be made to the SA EPA for approval to update the RRZ. The RRZ would be kept to the minimum required area, as has been the past practice. Table 8-9 Environmental RRZ Monitoring Program
Location Method Parameter Frequency
Any equipment or Survey Alpha Surface Contamination Prior to leaving site. materials that come in <0.4Bqcm2. contact with radioactive items
Up and down stream of Surface sediment grab Ra-226 Annually local creeks U-Total Th-total
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 8 Monitoring Program
Figure 8-4 Current Restricted Release Zone
NORTH
PROPOSED LLR WASTE DISPOSAL
HEATHGATE RESOURCES PTY LTD
Restricted Release Zone (hatched areas)
Waste Code Adelaide Office September 2000
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 9 Mine Closure and Rehabilitation Plan
9 Mine C losu re and Rehab ilit ation Plan 9.1 Preamble The mine closure and rehabilitation plan will ensure that the following standards are taken into account:
• General economic standards: – That the community are left with no residual liability for site rehabilitation or maintenance; – That any adverse economic effects are minimised; and – That provision is made for reasonable access for future mining (or reprocessing) of any remaining resource.
• General social standards: – Effective ongoing community engagement; and – Closure minimises the disruption/impact on the community. Rehabilitation and mine closure and completion will be undertaken with reference to the recently released Department of Industry Tourism and Resources documents Mine Closure and Completion (2006a), and Mine Rehabilitation (2006b). Applicable legislation is listed in Table 7-2. Rehabilitation and mine closure will involve the return of disturbed land to “a stable, productive and self- sustaining condition, after taking into account the beneficial uses [in this case, pastoral] of the site and the surrounding land.” This includes:
• Physical, geochemical and ecological stability;
• The protection of the quality of the surrounding water resources; and
• A condition where the risk of adverse effects to people, livestock, other fauna and the environment in general has been reduced to a level acceptable to stakeholders. The establishment of monitoring and reporting criteria for successful final rehabilitation may include reference to:
• Appropriate mechanisms for formal “sign-off” of rehabilitation as completed.
• Australian Standards as they apply at the time the rehabilitation is “signed-off”.
• Comparative measures for example reference photographs.
• Agreed times for the proving of rehabilitation actions.
• Requirements under other legislation e.g. the Environmental Protection Act 1993 (SA) and the Radiation Protection and Control Act 1982 (SA), in particular as set out in the ARPANSA Code Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing (2005).
9.2 Context Beverley is located in the pastoral zone of South Australia and was developed as a greenfields site, i.e. there was no prior mining in the areas now occupied by or proposed for the Beverley mine. The long- term objective for rehabilitation is the return of the landscape at the Beverley site to pastoral use. However, it is possible that some facilities may be handed over for other activities on the cessation of mining, subject to appropriate approvals and handover arrangements. Any change to the full return to pastoral use will be subject to future stakeholder involvement and planning.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 9 Mine Closure and Rehabilitation Plan
The objective of return to pastoral use is attainable given that:
• ISL mining leaves the soil profile largely intact, and major soil changes through the construction of pads (for footings, hardstands, roads etc.) are limited in area;
• The largely Mitchell grass / chenopod plain vegetation has been shown to be highly resilient, under both past excessive grazing pressures and intensive drilling activities;
• General drainage will be unaltered by the development and only minor changes in surface hydrology would occur; and
• The current and proposed construction and eventual rehabilitation of waste sites, including low-level radioactive wastes, pose no long-term hazards to biological communities, or to any user of the land surface. The requirements for pastoral use, of a land condition similar to the present, are also likely to be the requirements for other land uses, dependent on the natural landscape, such as expanded conservation reservation or recreational usage. Mining may be ongoing in the area after the Beverley orebodies are exhausted. It is possible that the plant, camp and airstrip at Beverley may be retained as a central facility for other deposits within economic distance. In this scenario the Beverley wellfields may be closed and rehabilitated in advance of other infrastructure. The appropriate tenure will be maintained for infrastructure maintained after the exhaustion of the Beverley orebodies. It is possible that some facilities (e.g. camp, airstrip, power station) may be handed over for other activities on the cessation of mining, subject to appropriate approvals and handover arrangements. These possibilities will continue to be discussed with Government and other stakeholders over the coming years. A staged mine closure and rehabilitation will occur for the proposed extended ML, as with the current Beverley ML 6036. This involves commencement of rehabilitation as soon as practical after the completion of mining. Hence, at the final closure of mining operations, rehabilitation to be carried out will largely be limited to the most recently active mining area and the dismantling of surface facilities. 9.3 Stakeholder Involvement and Issues The proposed extended ML is a continuation of existing mining at Beverley, and as such there has been the extensive stakeholder involvement of two Environmental Impact Statements, a number of government inquiries and regular scheduled meetings with State (quarterly) and State and Federal authorities (six- monthly), as well as many other discussions (please refer Section 6). The more recent EIS (Heathgate Resources Pty Ltd 1998a,b) included extensive consideration of decommissioning and rehabilitation, which is reflected in the existing Mining and Rehabilitation Program (MARP). The South Australian EPA-commissioned CSIRO review (CSIRO 2004) also considered rehabilitation issues. The proposed rehabilitation measures have evolved since mining commenced with a number of undocumented small surface rehabilitation trials undertaken. More recently, and as recommended by CSIRO (2004), Ecosystem Function Analysis (EFA) was undertaken at some early rehabilitation sites (including a drillers’ laydown and the former exploration camp) in 2006, and is being repeated in 2007. The trends established by EFA will allow further refinement of surface rehabilitation techniques as progressive rehabilitation begins in earnest. As these results are interpreted and provided to the stakeholders, closure and rehabilitation of the proposed ML extension and existing Beverley operations will be further reviewed and determined in consultation with the appropriate regulatory authorities, the pastoralist, indigenous peoples, and other direct stakeholders via the consultation processes set out in Section 6. Note that Heathgate owns the lease of Wooltana Station on which the Beverley mine is located.
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Section 9 Mine Closure and Rehabilitation Plan
Heathgate’s detailed closure plan, which will include a listing of individual or grouped infrastructure and specific treatments, will be initially provided to stakeholders three years prior to the anticipated final completion of commercial mining, to allow sufficient time for negotiation. This will include detailed plans of areas for rehabilitation and any infrastructure that will be left (subject to appropriate approvals). Note that currently Heathgate assumes that all infrastructure will be removed.
9.4 Scope and description of closure domain All of the ML is proposed to be returned to pastoral use, i.e. there is a single ‘domain’. However, more effort will be required at the plant, whereas rehabilitation of the wellfields, camp and airstrip will be straightforward. Maps and specific procedures will be required for the decommissioning of the processing plant and associated holding ponds, located on the existing ML 6036, to meet the requirements of the Radiation Protection and Control Act 1982 (SA), in particular as set out in the ARPANSA Code Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing (2005). This will be set out in appropriate detail in the detailed closure plan to be prepared closer to the completion of commercial mining at Beverley.
9.5 Potential environmental, economic and social impacts of mine closure Heathgate’s current planning associated with the current Beverley ML assumes that it will remove all facilities on decommissioning. In the case of the proposed ML extension, this will consist only of trunklines, wells, access roads and fencing. Some access roads and fencing may be left, at the request of the pastoralist. On the existing ML 6036 and associated MPLs, which will be subsumed by the new ML, the plant, ponds, camp and airstrip will be rehabilitated. It is expected that all environmental effects from the Beverley Uranium Mine and proposed Extension ML will have been mitigated at the conclusion of the long-term program, with the exception of the mine zone aquifer, which will be more saline than prior to mining and with respect to pH and radionuclide content may take some time to attenuate to near pre-mining conditions (CSIRO Land and Water 2004). Note that the mined aquifers will be more saline than their pre-mining state due to the addition of sulphate, chloride and balancing cations during the mining process, but will contain less uranium. Any requirements for activities beyond the long-term program will be determined and addressed with the concurrence of the appropriate regulatory authorities. The closure of the Beverley operation, in the absence of other operations taking its place, will significantly reduce employment in the region. The economic contributions described in Section 3.4 will cease. However, in the case of the local Aboriginal communities at Nepabunna and Iga Warta, a proportion of Aboriginal royalties, administration and community payments have been invested in long-term projects and investments, which will continue to benefit those peoples after final closure of Beverley. There will also be the positive legacy of improved skills and employability of staff and contractors who have worked at the mine both in the local region and the main other areas workers have been drawn from Adelaide and the Iron Triangle region of mid north South Australia. As discussed earlier, it is possible that some facilities (e.g. camp, airstrip, power station) may be handed over for other activities on the cessation of mining, subject to appropriate approvals and handover arrangements.
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9.6 Desired outcomes
9.6.1 General Outcomes The general outcomes for closure of the Beverley Mine, as adapted from the Department of Industry Tourism and Resources (2006a), are to ensure that:
• The interests of stakeholders are considered in the mine closure process;
• The closure process can occur in an orderly, cost-effective and timely manner;
• The cost of closure is properly provided for, and that the community is not left with an on-going liability;
• There are clear accountabilities and resources available to implement the closure plan; and
• A point can be reached where Heathgate has met the closure criteria. The general criteria for rehabilitation and closure of the Beverley Mine, as adapted from the Department of Industry Tourism and Resources (2006a), are that:
• The post-mined landscape is safe and stable;
• The post-mining land use (pastoral) is able to continue; and
• The rehabilitation monitoring demonstrates that the land is suitable for relinquishment. The principal aims of the planning for closure of the Beverley Mine are:
• Non-mining aquifers are maintained with existing potential beneficial uses
• That the landforms are rehabilitated to ensure conformity with the surrounding natural landforms and ecosystems;
• That rehabilitation is carried out progressively, where possible; and
• For relinquishment, the rehabilitation monitoring demonstrates that the land is suitable for relinquishment. Heathgate intends to undertake the decommissioning and rehabilitation of the existing and the proposed ML areas. As surety, a bond that is adequate to cover the cost of decommissioning and rehabilitation has been provided to the South Australian government. This will be reassessed and adjusted as required during the finalisation of the ML conditions when offered by the South Australian Government.
9.6.2 Specific Outcomes The Technical Group of the Beverley Environmental Consultative Committee met at PIRSA’s offices on 26 September 2006, to discuss environmental values for the Beverley project. The following Environmental Values were determined:
• Great Artesian Basin - Protection of the GAB, which is suitable for multiple purposes, by ensuring no incursion of water from overlying aquifers. Maintenance of the integrity of GAB is most important. Issues include ensuring that quality, quantity and pressure of the GAB is maintained.
• Willawortina Aquifer - Protection of the Willawortina Aquifer, which has marginal use (brackish to saline water) and currently and potentially used for stock watering. The Namba Formation contains the uranium deposits and also the Beverley Aquifer, which is used for the disposal of the liquid waste stream. Thus the internal integrity of the Namba Formation is the key to protecting the GAB and Willawortina. It is noted that the Namba Formation will be altered as a result of ISL mining. The
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Namba is a confined system with little or no flow, with connections between the northern, central and southern portions.
• Beverley Aquifer - It was agreed that there are no ‘environmental values related to the Beverley Aquifer’. However, short term impacts must be controlled for both mining efficiency and to minimise long-term impacts.
• Land surface – the aim is to return the land surface to its pre-mining condition, including in relation to surface hydrology, soil, air, flora and fauna. If waters were to escape from aquifers to the surface, there would be potential for impacts to soil, vegetation and to Four Mile Creek. Evaporation ponds pose a potential hazard to fauna, particularly birds. In summary, it is essential that the GAB is not degraded in terms of quality, pressure, and quantity, and that the Willawortina Aquifer’s quality should be maintained. The Namba Formation will be changed, however there was agreement that this Formation has no environmental values. Potential surface impacts include changes to vegetation and habitat. The evaporation ponds have the potential for impact on fauna including birds and mammals. Specifics are given in Table 9.1. For the land surface, achievement criteria in regard to the rehabilitation outcome of “suitable for pastoral use” are:
• Rehabilitation earthworks have been completed and are stable; and
• Vegetation has been successfully established and is progressing towards local standards as demonstrated by LFA monitoring. With respect to groundwater, the desired outcome of no compromise of the protected beneficial uses of the GAB and Willawortina aquifers would be demonstrated by use of time-series monitoring, which shows:
• Sustained maintenance of pressure gradient and that water quality in GAB and Willawortina aquifers is within natural background variation; or
• Any changes are not trending such that the potential beneficial use is likely to be compromised. 9.7 Risks to Achieving Outcomes There are three main risks associated with potentially not meeting the desired rehabilitation outcomes. These are discussed below and later summarised in Table 9-1.
9.7.1 Failure of revegetation Growth of vegetation including establishment from seeds and other propagules is closely related to the erratic and low rainfall received in the area. Re-establishment of vegetation is key to the outcome of suitable for pastoral use, but if no significant rain falls for some months or years after physical rehabilitation works are complete, the success or otherwise of revegetation may not be apparent for some time. Natural re-colonisation of disturbed and cleared areas has already been observed at Beverley, notably in the North wellfield, which was cleared of remnant vegetation and top soil in 1999/2000. Due to the nature of mining and other disturbance at Beverley, it can be reasonably expected that the area would return to suitability for pastoral use without active intervention following the removal of infrastructure. Nevertheless, both as a good corporate citizen and to meet the rehabilitation requirements of the existing and expected lease conditions, Heathgate will intervene as described later to facilitate the return of vegetation to the disturbed areas.
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Table 9-1 Potential Impact Events & Management – Rehabilitation and Closure
Potential Inherent Risk Control & Management Strategy Residual Risk Outcome Outcome Impact Event Level Level Measurement Criteria REHABILITATION
Failure of Likelihood: Possible Both passive and active methods of Likelihood: Unlikely Land suitable for pastoral Demonstrated achievement of revegetation to meet Consequence: Minor rehabilitation will be used. Passive methods Consequence: Minor activities. rehabilitation outcomes, pastoral use in a will be used in small areas of disturbance, specifically Risk: MODERATE Risk: LOW reasonable where nearby plants provide some shelter and • rehabilitation earthworks timeframe due to seed for the area being rehabilitated. have been completed and insufficient Active methods will be used where the are stable; and rehabilitation. rehabilitation area is larger and needs to have an additional source of seed. • vegetation has been As a contingency, additional physical works successfully established (e.g. re-ripping, erosion repair) will be and is progressing undertaken if monitoring shows vegetation is towards conditions in not established and is not progressing towards control sites demonstrated conditions in control sites. by LFA monitoring.
Disturbance of waste Likelihood: Unlikely Location of pits is accurately surveyed and Likelihood: Rare No unauthorised opening Record of pit locations is added pits exposing low- Consequence: Minor recorded on land title. Consequence: Minor of waste pits. to land title. level radioactive waste or other Risk: LOW Risk: LOW contaminants
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Potential Inherent Risk Control & Management Strategy Residual Risk Outcome Outcome Impact Event Level Level Measurement Criteria
Compromise of Likelihood: Unlikely Pressure gradient from GAB and Willawortina Likelihood: Rare No compromise of the Time series monitoring shows protected potential Consequence: Minor Aquifers to mined aquifer is re-established. Consequence: Minor protected beneficial uses pressure gradient and water beneficial uses of of the aquifers. The quality in the GAB and Risk: LOW All wells (not retained for long-term monitoring, Risk: LOW the overlying pastoral supply or other approved purposes) targets for each aquifer Willawortina aquifers is within (Willawortina) or will be appropriately decommissioned by are: natural background variation, underlying (GAB) cement grouting and removal of top 0.5 m • No change, outside OR any changes are not aquifers. (approximately) of casing. of natural trending such that the potential background beneficial use is likely to be All waste repositories are appropriately compromised. capped. variation, to the water quality of the GAB. • No change, outside of natural background variation, to the water quality of the Willawortina Formation.
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The main events that may cause failure of revegetation are:
• Soil is too compacted for retention/protection of seeds, infiltration of rain or seedling establishment;
• Removal of suitably natural or prepared soil by wind or water erosion; and
• Death or over-predation of seed stock due to time delays of rain. Local vegetation is adapted to the low and erratic rainfall of the area. The longevity of seed is illustrated by the absence of some species of local plants for some years in vegetation surveys, then their reappearance when suitable conditions occur. The passive and active control and management strategies are expected to reduce the risk of failure of revegetation from Moderate to Low. The use of Ecosystem Function Analysis will allow early recognition of slow progress of revegetation. The mine closure schedule allows for annual review of rehabilitation monitoring. During these reviews, the need to implement additional measures or undertake repairs will be discussed. Contingency measures to be considered include:
• Selected re-ripping (or initial ripping) of areas where compaction is considered to be inhibiting revegetation;
• Repair of wind or water erosion features where they are considered to be inhibiting revegetation, including the installation of erosion-resistant treatments (e.g. installation of silt traps, spreading of gibber stones); and
• Additional spreading of seed.
9.7.2 Disturbance of waste pits It is possible that waste pits (general waste or low-level radioactive waste) might be disturbed after rehabilitation, exposing low-level radioactive or general waste. This may have health and amenity implications. To reduce the risk of this, the locations of all waste pits will be accurately recorded and attached to the land title to make the information available to all future owners of the lease and land. Note that the risk is low under both scenarios.
9.7.3 Willawortina and Great Artesian Basin aquifers The Beverley Sands are hydraulically isolated from the overlying Willawortina aquifer and the underlying GAB aquifer. Although the isolating clay layers tend to be self-healing, i.e. they expand to block any open holes drilled through them and prevent inter-aquifer flow, current best-practice and DWLBC and PIRSA guidelines require the filling of open holes with cement grout to (further) reduce the risk of inter-aquifer flow. For cased holes (wells), the annulus between casing and the surrounding sand, clay and gravel layers is filled with cement grout during construction and the casing is pressure tested to check the integrity of the seal. For abandonment, all wells will be grouted internally. This will eliminate the possible pathway for inter- aquifer flow, should future ground movement or casing weaknesses cause cracking of the casing. Further, the natural hydraulic gradient is from the Willawortina and GAB towards the Beverley Sands. This means if groundwater moves at all, it would move very slowly from the other aquifers to the Beverley Sands. To maintain this natural protection, the gradient will be re-established prior to the removal of all of the wells that can be used to pump water from the mined aquifer, in order to re-establish this gradient. The other potential impact event that could impact the Willawortina aquifer only is seepage of contaminated water (leachate) from the waste repositories. The risk of this is naturally low, because of:
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Section 9 Mine Closure and Rehabilitation Plan
• The thick unsaturated zone with high clay content between the repositories and the Willawortina aquifer;
• Naturally low rainfall;
• Naturally very low groundwater recharge rates on the water-shedding area selected for the waste repositories; and
• The capping (and in the case of low-level radioactive waste, plastic liner) of the pits with a final water-shedding profile. Note that the risk is low under all scenarios, but the precautions further reduce the likelihood of any compromise. 9.8 Closure strategies (control measures) Both passive and active methods of rehabilitation will be used. Passive methods will be used in small areas of disturbance, where nearby plants provide some shelter and seed for the area being rehabilitated. Active methods will be used where the rehabilitation area is larger and needs to have an additional source of seed. Specifics are given in Table 9.1. For the land surface, closure strategies are:
• Site cleanup and removal of saleable buildings, equipment and scrap metal/plastic subject to suitable radiation clearances;
• Suitable burial of steelwork, used fencing, piping etc than cannot be removed from site for sale or re- use, as standard landfill or low-level contaminated waste;
• Removal of (the surface parts of) wells to avoid leaving hazards to wildlife/stock;
• Radiation survey to define any areas of contaminated soils requiring clean-up;
• Break-up of foundations and burial, or covering with at least 0.5 m of erosion-resistant inert covering suitable for (eventual) vegetation growth;
• Respreading of stockpiled soil and gibbers where relevant;
• Surface ripping of compacted areas including unwanted roads; and
• Seeding with local provenance species in disturbed areas (to supplement respread topsoil and future wind-borne natural seeding). With respect to groundwater:
• The pressure gradient from GAB and Willawortina Aquifers to mined aquifer will be re-established by appropriate pumping prior to the removal of pumping equipment.
• All wells (not retained for long-term monitoring, pastoral supply or other approved purposes) will be appropriately decommissioned by cement grouting and removal of top 0.5 m (approximately) of casing, then covering with soil. This is consistent with State Government guidelines for well decommissioning and is designed to prevent any possible cross-aquifer groundwater flow through abandoned wells
• All waste repositories will appropriately capped to minimise potential seepage of leachate to groundwater.
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9.9 Closure plan maps and sections At this time all infrastructure is proposed to be removed and rehabilitated. Should some infrastructure be retained (subject to appropriate approvals and handover arrangements) plans clearly showing infrastructure to be kept and areas to be rehabilitated will be provided in the detailed closure plan foreshadowed in Sections 9.1 and 9.3. All areas will be returned to the approximate pre-mining contours. As such no cross sections are provided. 9.10 Residual Risk Assessment Residual risks are considered in Table 9.1, and are considered low and acceptable.
9.11 Closure Cost Estimate This information is considered Commercial in Confidence and will be provided separately to PIRSA during discussions of an appropriate bond for the extended ML. 9.12 Mine Closure Schedule The mine closure schedule cannot be determined in any detail as there remain many exploration targets on the extended ML that may allow mining to continue beyond the currently identified resources. The use of the Beverley plant and supporting infrastructure for possible nearby future mining may mean a gap of some years between the completion of mining at Beverley, with wellfield rehabilitation, and the closure and rehabilitation of the plant and other infrastructure. There is also the possibility as mentioned above that some infrastructure may be handed over for other uses at the end of mining, as described in Section 9.2, subject to appropriate approvals and handover arrangements. It is also possible that facilities may be kept on a standby or care-and-maintenance status after the first cessation of active mining at Beverley, pending improved market conditions or technology improvements that would allow additional uranium to be extracted from existing wellfields, or while feasibility investigations or approvals of nearby deposits are undertaken, the mining of which may rely on the use of Beverley infrastructure. A conceptual mine closure schedule is given in Table 9-2, assuming no standby or care-and- maintenance.
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Section 9 Mine Closure and Rehabilitation Plan
Table 9-2 Conceptual Mine Closure Schedule – Subject to Amendment
Time from official Milestone/Activity Notes closure
-3 years Draft Formal Closure Provided to stakeholders for Plan discussion/negotiation. Wellfields no longer required on standby or for production are progressively rehabilitated.
-1 year Closure plan formally Tenders let for salvageable items etc. Some adopted unwanted items may be removed prior to official closure
0 Official closure Commencement of post-closure environmental monitoring. Size of leases reduced to disturbed areas only. Final rehabilitation commences.
6 months Salvage of suitable Rehabilitation activities and post-closure items, demolition and environmental monitoring. burial of unsuitable items
1 year Majority of physical First annual review of post-closure rehabilitation complete. environmental monitoring. Recalculation of Return of part of bond. bond.
2 years Physical rehabilitation Findings assessed and discussed with complete. Return of regulators to set additional requirements and majority of bond. confirm relinquishment conditions. Recalculation of bond. End of minimum post- closure environmental monitoring.
3-7 years Confirmation post- Annual post-closure monitoring reviews. closure environmental monitoring. Relinquishment conditions met, post-closure environmental monitoring ceases. Leases relinquished to PIRSA and return of remainder of bond.
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Section 10 Management Systems
10 Management Systems 10.1 Environmental Management System
10.1.1 Background Heathgate maintains a computer-based Environmental Management System as part of its broader Environmental, Safety and Health Management System (ESHMS) for its Beverley operation that will cover operations on the extended lease. The ESHMS is designed to enable organisations to address the balance between economic imperatives, worker safety, and environmental concerns by creating a system of processes and procedures that:
• bring focus to important safety and environmental goals; and
• establish and implement plans to achieve those goals. The Beverley ESHMS seeks to satisfy the fundamental human values of ensuring: the safety of ourselves and our workmates, contractors and visitors; and the protection of the environment in which we work. These values need to be satisfied in the context of meeting production needs to ensure that we have a sustainable business to provide our livelihood. The ESHMS also seeks to satisfy legal requirements, and the requirements of the AS 4801 and ISO 14001 Standards on which the system is based (although certification under these standards is not sought). Heathgate Resources demonstrates and improves its safety and environmental performance through the implementation of this ESHMS.
10.1.2 Introduction Environmental Management Systems (EMS) are designed to enable organisations to address environmental values, economic imperatives and public expectations. An EMS creates a system of processes and procedures to examine performance against environmental goals, and to continually achieve higher levels of performance. The ISO 14001 Standard emphasises the need for continual improvement in the organisation's environmental performance (Figure 10.1). Further, a systematic approach to environmental performance fosters a more efficient use of resources, so the EMS should provide benefits to the organisation's bottom line. Heathgate believes that sound environmental management is an important component of its overall management responsibility. Heathgate demonstrates its environmental performance through implementation of this EMS which is based on the ISO 14001 Standard, and which addresses all of Heathgate’s operations. The Standard will also be used in ongoing development and improvement of this EMS. The cornerstones of the EMS are:
• The Environment Policy;
• The development and implementation of Environmental Objectives and Targets;
• The ongoing monitoring and reviewing of environmental performance; and
• Continual improvement of Heathgate's environmental performance. As part of its commitment to minimise the environmental impacts of its operations, Heathgate has developed this EMS, and has established an Environment Safety and Health Committee to oversee its implementation and ongoing operation.
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The Environment Policy, EMS Procedures Manual and the Procedures Registers are the key EMS documents. Figure 10-1 ISO 14001 Continual Improvement Cycle
10.2 Environment Policy Heathgate’s Environment Policy was last updated in April 2007. It states: Heathgate Resources Pty Ltd (Heathgate) is committed to conducting all of its mine operation activities in an environmentally responsible and prudent manner with the objective of minimising any adverse impacts to the air, land and water resources, to the lowest reasonably achievable level. Heathgate utilizes environmental objectives, targets and plans in an endeavour to continually improve its overall environmental performance. Integral to the Environment Policy are goals focused on:
• Waste minimisation;
• Zero pollution events;
• Compliance with all applicable laws and regulations concerning the environment;
• Environmental awareness training; and
• Minimum site disturbance.
Heathgate insists that its employees, contractors and agents conduct all business activities in a manner that is protective of the environment. The Environment Policy, as displayed in Heathgate’s offices and at Beverley, is shown in Figure 10.2.
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Section 10 Management Systems
Figure 10-2 Heathgate Resources Environment Policy
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Section 10 Management Systems
10.3 Planning
10.3.1 Environmental Aspects and Impacts ISO 140001 requires an organisation to establish and maintain a set of procedures to identify environmental impacts of its activities, products or services that it can control and over which it can be expected to have an influence, in order to determine those which have, or can have, significant impacts on the environment. To meet the requirements of the Standard, Heathgate has conducted a comprehensive HAZID (Hazard Identification process) and developed a Risk Register. Heathgate's risk assessment process, using the AS 4360/1996 Risk Management Standard, has been used to rank the identified impacts in terms of significance (refer Section 7.4, and Table 7-4). The assessment criteria are based on a consideration of business, safety and environmental factors. This risk assessment allows Heathgate to prioritise the relative risks of its current activities, determine the significance of each environmental impact identified, and nominate how the issue will be addressed. Table 7.4 includes the potential identified events, reference to legislation, the assigned risk levels, the control and management strategies, outcomes and outcome measurement criteria. The procedure for identifying and evaluating the environmental aspects and impacts of Heathgate's operations is documented in the Risk Management Procedure. Reassessment of the environmental aspects and impacts is required annually or when there are significant changes to operations. Note that the internal risk management procedure takes a different format to that required by the guidelines for this document. The Risk Assessment presented in Section 7 has drawn from Heathgate’s internal documentation but presented in the guideline format.
10.3.2 Legal and Other Requirements ISO 14001 requires an organisation to 'establish and maintain a procedure to identify and have access to legal and other requirements that are applicable to the environmental aspects of its activities, products or services’. Heathgate understands the importance of meeting, and where practicable, exceeding, its regulatory obligations. Heathgate has developed a procedure and a Legal and Other Requirements Register. The Legal Register provides a summary of applicable Commonwealth and State Laws, Codes of Practice, Heathgate Resources Policies, Initiatives, Licensing and Permits.
10.3.3 Objectives and Targets ISO 14001 requires an organisation to 'establish and maintain documented environmental objectives and targets. In accordance with the Standard, Heathgate has established objectives and targets by considering:
• legal and other requirements,
• environmental goals arising from its environmental policy, and
• significant environmental impacts. As required by the Standard, technological options, views of interested parties and financial, operational and business requirements were also considered. The ESH Manager will coordinate an annual review of the objectives and targets. A review is also required to assess the impacts from changes to Heathgate's operations, the results of management reviews as well as environmental audit findings and recommendations. The revision of objectives and targets will form the basis for continual improvement in Heathgate's environmental performance.
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Procedures relating to the establishment, progress and review of objectives and targets can be found in the Objectives and Targets Procedure.
10.3.4 The Environmental Management Program ISO 14001 requires that an organisation establishes and maintains an Environmental Management Program to achieve its objectives and targets. The Program includes the:
• designation of responsibility for achieving objectives and targets at each relevant function and level of organisation; and
• the means and time-frame by which they are to be achieved. In meeting these requirements and those of the regulators, Heathgate has developed an Environmental Management and Monitoring Plan (EMMP) that addresses those aspects assessed as having environmental impacts of relatively high significance, assigns tasks and responsibility for meeting environmental targets and specifies a framework for their achievement. The EMMP will be revised by the ESH Manager every three years9.
10.3.5 Implementation and Operation Effective implementation and operation of the EMS requires Heathgate to develop capabilities and support mechanisms necessary to achieve the EMS objectives and targets. Heathgate recognises that environmental improvements will require the continued allocation of resources, especially human and financial. Heathgate has committed to ongoing human resources and will seek additional funding as required through its budgetary process.
10.3.6 Structure and Responsibility ISO 14001 requires roles, responsibilities and authorities to be defined, documented and communicated to facilitate effective environmental management. The Standard requires that senior management will provide human, technological and financial resources and appoint a management representative who will:
• ensure the EMS requirements are established, implemented and maintained; and
• report on the performance of the EMS to top management for review and as a basis for improvement. Heathgate has appointed an ESH (Environment, Safety and Health) Manager to oversee the development and implementation of the EMS and established an ESH Committee. These appointed personnel work together to implement and maintain the EMS. The ESH Manager has the authority to ensure compliance, identify and implement solutions, and act upon incidents. The ESH Manager assists Management and Supervisors to inform and educate staff and contractors of their roles and responsibilities with respect to the Heathgate EMS. The ESH Manager also coordinates audits and management reviews.
10.3.7 Training, Awareness and Competence ISO 14001 requires that an organisation establish and maintain a program to identify and address environmental training and awareness for all its stakeholders. Heathgate's stakeholders include clients, management, employees, contractors, suppliers and visitors to the building. The standard requires that all staff, whose work may create a significant environmental impact, receive appropriate training.
9 The EMMP will be reviewed as part of the MARP application in late 2007/early 2008 as part of this cycle.
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Heathgate has developed a Training, Awareness and Competence Procedure to ensure that:
• The importance of compliance with the environmental policy, EMS procedures and requirements is communicated to stakeholders;
• Stakeholders are aware of the significant environmental impacts (actual and potential) of their work activities and of the environmental benefits of improved personal performance;
• Stakeholders are aware of their individual roles and responsibilities, and are aware of the potential consequences of departure from specified operating procedures; and
• Stakeholders are adequately trained to successfully perform their designated roles and responsibilities. Documentation for the Training and Awareness Program and Register is maintained by the HR Coordinator. Records are kept in accordance with the Records Procedure.
10.3.8 Communication ISO 14001 requires that an organisation establish and maintain procedures for internal communication between various levels and functions of the organisation regarding its environmental aspects and the EMS. The Standard also requires an organisation to consider processes for external communication on its significant environmental aspects, together with a mechanism to record these communications. Heathgate recognises that communicating its environmental objectives, targets and performance to all stakeholders is an essential component of the EMS. It provides for a greater understanding of Heathgate's environmental impacts and an acceptance of the organisation's effort to improve its environmental performance. Heathgate encourages the use of electronic communication to reaffirm its commitment to the protection of the environment by avoiding excess paper use. Through effective internal communication, particularly results of EMS monitoring, audits and management reviews, employees will be well informed and thereby generate greater ownership of the environmental process. This will result in a higher level of motivation for continuing environmental improvement. In accordance with the requirements of the standard, Heathgate has established an Environmental Communications Procedure. The ESH Manager is responsible for documenting and maintaining records of communications as amended and updated onto the intranet site. Heathgate will encourage two- way communications and information for both internal and external stakeholders.
10.3.9 EMS Documentation ISO 14001 requires that an organisation will establish and maintain information, in paper or electronic form, to:
• describe the core elements of the EMS and their interaction; and
• provide direction to related documentation. Heathgate satisfies these requirements by maintaining its EMS in electronic form located at the Heathgate Intranet site. The core elements of this environmental management system are:
• The Environment Policy demonstrating Heathgate's commitment to and providing direction for continual improvement in environmental performance.
• The EMS Procedures Manual, consisting of general procedures to enable implementation and reviewing of the EMS to ultimately achieve continued improvement in environmental performance.
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The EMS Procedures Manual refers to other documents that register and record the processes and outcomes of these procedures.
• The EMS Registers are the working documents of the EMS. Typically, performance of the procedures requires the recording of information within these registers. All EMS documents contained within and related to the above core elements will be clearly named and sufficiently referenced to be accessible to interested parties.
10.3.10 Document Control In accordance with ISO 14001, Heathgate has established a Document Control Procedure to control all ESHMS documentation such as manuals, forms, records and registers. The ESH Manager is responsible for the original copy of the EMS to ensure that its documents are controlled. The standard states that this documentation will be kept legible, dated, identifiable and retained for a specified period. The Document Control Procedure is required to include provisions for the creation and modification of various types of document. A Document Control Register has been established by Heathgate to ensure that in accordance with the standard:
• All relevant environmental documents can be easily located within Heathgate's offices;
• Documents are periodically reviewed and revised as necessary under the authorisation of the ESH Manager;
• Up to date versions of relevant documents are available at locations where operations essential to the effective functioning of the environmental management system are performed;
• Obsolete documents are immediately removed to prevent their inadvertent use; and
• Obsolete documents retained for legal or other purposes are held and are suitably identified in the Document Control Register. The ESH Manager is responsible for implementing the Environmental Document Control Procedure, and maintaining and updating all EMS manuals and associated documents.
10.3.11 Operational Control ISO 14001 requires that when actual or potential significant impacts have been identified the activities associated with these impacts are identified and control measures are implemented. Control and planning measures must:
• document procedures to prevent deviations from the system;
• establish operational criteria within the procedures;
• identify procedures that have significant environmental aspects; and
• establish procedures to ensure suppliers and subcontractors are aware of the requirements of the EMS. Operational Control is required to ensure that activities associated with potential significant environmental impacts are conducted under controlled conditions. Standard Operating Procedures (SOPs) have been developed for the more significant impacts of Heathgate's activities. Each SOP identifies the environmental impact associated with an aspect of Heathgate's operations, and specifies management measures that could reduce these impacts.
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Section 10 Management Systems
The ESH Manager is responsible for ensuring that all SOPs are maintained in accordance with the Operational Control Procedure and are documented in the Operational Control Manual (SOP Manual). The ESH Manager is also responsible for communicating the requirements of the SOP to stakeholders.
10.3.12 Emergency Preparedness and Response ISO 14001 requires that an organisation shall establish and maintain procedures to identify the potential for and to respond to accidents and emergencies, and for preventing and mitigating the environmental impacts that may be associated with them. The standard also requires that these procedures will be reviewed and revised when necessary, in particular after the occurrence of accidents, and that they will be periodically tested where practicable. Heathgate has developed a compliant Environmental Emergency Preparedness and Response Procedure that, in conjunction with the Safety emergency procedures, will ensure accidents and emergency situations will be adequately managed to minimise potential adverse environmental impacts. It is the responsibility of the ESH Manager to identify, with the assistance of qualified staff, the potential environmental impacts of accidents and emergency situations and to ensure that section leaders and contract managers understand their responsibilities to make sure services are performed in accordance with the EMS. The Environmental Emergency Preparedness and Response Procedure will be reviewed annually and revised to reflect Heathgate’s current operations. This review process will be coordinated by the ESH Manager, who may seek external professional advice. The ESH Manager will carry out an investigation and review of the procedure following any emergency incident where a significant environmental impact has, or potentially may have occurred.
10.3.13 Checking and Corrective Action In order to facilitate continual improvement, Heathgate recognises the importance of ongoing monitoring and implementing any required adjustments. Heathgate has established and maintains procedures for the measurement and evaluation of its environmental management and performance. Procedures are also in place for the ESH Manager to undertake investigations of situations where the EMS was not conformed with, and to recommend any necessary corrective and preventative actions.
10.3.14 Monitoring and Measurement ISO 14001 requires that an organisation establish and maintain procedures to enable ongoing monitoring and measuring (for the evaluation) of environmental performance of activities that can have a significant environmental impact. These procedures must address the recording of information to track performance, relevant operational controls and conformance with objectives and targets. Records must be kept detailing the calibration and maintenance of monitoring equipment used and a documented procedure established for reviewing compliance with relevant environmental legislation and regulations. The SOPs address those activities that have been determined to have significant environmental impacts. They include monitoring and measurement instructions to be followed by all staff and contractors. When the monitoring and measurement data has been recorded, it is stored in the Monitoring Database. The ESH Manager is responsible for assessing the effectiveness of the EMS through periodic reviews of the monitoring data that are reported annually in the Annual Environment Report. This will enable the identification of those functions requiring corrective actions, and those being successfully implemented. Monitoring and measurement functions will be audited to assist in evaluating the effectiveness of the EMS.
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Section 10 Management Systems
10.3.15 Non-conformance and Preventative and Corrective Action ISO 14001 requires that in the case of non-compliance with an element of the EMS:
• the responsibility and authority for initiating investigation, taking action to mitigate any impacts caused and corrective action will be defined; and,
• procedures will be established and maintained for investigating and correcting non-conformance to: – determine the cause; – identify and implement corrective action; – initiate preventative actions; – apply controls to ensure that preventative actions taken are effective; and – record any changes in written procedure resulting from the corrective action. Heathgate has a compliant Non-conformance and Corrective and Preventative Action Procedure. Effective and prompt action must be initiated should an activity or function result in an unforeseen environmental impact or fails to comply with the EMS. The ESH Manager has been assigned responsibility and authority to initiate an investigation into a non- conformance event. The Non-conformance and Corrective Action Procedure details a protocol that enables a non- conformance to be identified and addressed (via a Corrective Action Request). It also details actions to prevent further non-conformances, including the alteration of procedures. Following implementation, the procedure assesses and verifies the effectiveness of the corrective or preventative action.
10.3.16 Records ISO 14001 requires that procedures for the identification, maintenance and disposition of environmental records should be established and maintained. These records, including training records and the results of audits and reviews are required to be legible, identifiable and traceable to the activity, product or service involved. They must be stored and maintained, be readily retrievable and protected against damage, deterioration or loss. Heathgate has met the requirements of the standard by incorporating the following records in this EMS:
• The Training and Awareness Program and Register records training sessions conducted to addresses training and awareness needs and equip Heathgate stakeholders with the knowledge and skills required to undertake their individual EMS roles and responsibilities.
• The EMS Communications Register contains records of all environmental communication.
• The Document Control Register records all EMS and records and their location.
• The Non-conformance and Corrective Action Register is a record of EMS Non-conformances. The Environmental Records Procedure has been combined with the Document Control Procedure for management of all EMS documents and environmental records.
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Section 10 Management Systems
10.3.17 EMS Audit ISO 14001 requires that programs and procedures for periodic EMS audits be established and maintained in order to determine:
• whether or not the EMS: – conforms to the requirements of the standard and the planned arrangements set out in this document, the EMMP, procedures and work instructions; and – has been properly implemented and maintained; and
• that Heathgate's environmental performance is improving. The standard requires that the audit program also covers the audit scope, frequency and methodologies, as well as the responsibilities and requirements for conducting audits. Heathgate has developed a compliant EMS Audit Procedure that addresses:
• The activities and areas to be audited;
• The frequency of audits;
• The responsibility associated with conducting an audit;
• Communication of the audit findings; and
• Auditor competence. The ESH Manager will appoint appropriately trained persons from Heathgate or external to the Agency to undertake audits of the Heathgate EMS. Auditors will be required to provide an audit report within 2 months of completing an audit. The audit report, which will be presented to senior management, will detail all audit activities, functions, and elements of the EMS, and provide details of any non- conformances and corrective or preventative actions to be undertaken within a specified time frame.
10.3.18 Management Review ISO 14001 requires that at specified intervals, senior management will review the EMS to determine continued suitability and effectiveness. This review should include results of audits, a review of performance against objectives and targets, procedures, incidents, concerns of interested parties, the suitability of the policy, and the suitability of the EMS in view of changing conditions. The Standard also requires the management review process to ensure that necessary information is gathered for management evaluation and that the review is documented. Heathgate established a Management Review Procedure, which is implemented and maintained by the ESH Manager, to meet these requirements. The procedure enables senior management to undertake a complete review of the ongoing suitability and effectiveness of the EMS. The review process, which includes a review of internal and external audits, public and customer comments, and legislative requirements, is coordinated by the ESH Committee. The ESH Manager ensures the results of the review are documented and distributed to stakeholders. The ESH Manager will initiate and participate in a review of the EMS at least once per year to consider the impact of changes in the Agency's operations, legislative requirements and technology. The ESH Committee will initiate corrective action in accordance with the Non-conformance, Corrective and Preventative Action Procedure where improvements to the EMS are identified during reviews. The ESH Manager will maintain records demonstrating the implementation of the corrective actions.
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Section 10 Management Systems
10.4 Previous Experience of Operator Heathgate Resources has owned the Beverley deposit since 1990 and operated the mine since 2000. The staff and long-term contractors comprise a mixture of personnel with up to 7 years site experience (some of whom worked on the original Field Leach Trial) and senior staff have experience at other mine sites as operators, contractors, consultants and regulators. This experience is directly applicable to the planned operations on the proposed extended ML, which will be a continuation of mining currently undertaken on ML 6036. 10.5 Lease Conditions The conditions in ML 6036 were imposed after rigorous consultation. It is expected that similar conditions will be imposed for the extended ML when granted. The prime requirements of the Lease Conditions for ML 6036 include:
• Mining to be undertaken in general accord with the EIS (draft and supplement).
• Ensure that land disturbed by mining and exploration activity is rehabilitated to achieve a stable and regular land formation and to return the area to grassland, suitable for a grazing after-use.
• Preparation, approval and implementation of an Environmental Management and Monitoring Plan (EMMP).
• Preparation of an annual environmental report based on the EMMP, to be made public.
• Appropriate bore construction and testing to protect the other aquifers.
• Waste water to be held in ponds before disposal to the northern ore zone aquifer of the upper Namba formation10.
• Progressive rehabilitation of areas as they become available.
• Effective plugging of redundant boreholes and removal of surface infrastructure at the end of mining, unless otherwise agreed in consultation with the Pastoral lessee, native title claimants and the Chief Inspector of Mines. Heathgate’s original EMMP to satisfy many of these conditions was approved prior to mining, and an update was approved in 2005. As previously discussed, the EMMP will be updated again as part of the MARP for the extended ML applied for here. A detailed list of lease conditions and the mechanism for their fulfilment will be provided in the next MARP when the conditions of the new lease have been issued. 10.6 SA EPA 2004 Review In 2004 the SA EPA released its report “Review of environmental impacts of the acid in-situ leach uranium mining process” undertaken on its behalf by CSIRO (CSIRO 2004). The review was in response to claims that acid in-situ leach (ISL) mining and disposal of waste would contaminate groundwater. It was a valuable opportunity for the EPA to re-examine the impacts of this mining process used in South Australia (EPA 2007).
10 As discussed earlier Heathgate is currently applying to extend water disposal to the Central and Southern Beverley orebody aquifers, after several months of discussion with regulators.
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Section 10 Management Systems
The CSIRO review resulted in 13 recommendations, the majority of which related to groundwater monitoring and the impact of natural attenuation processes on the presence of mining and disposal fluids. The South Australian Cabinet accepted the report and committed to fully implement the recommendations of the review. The existing mechanisms of EPA approvals (Radiation Management Plan and Radioactive Waste Management Plan) and PIRSA MARP/EMMP amendments were used to implement the recommendations. In June 2007 the SA EPA released its report “Review of environmental impacts of the acid in-situ leach uranium mining process – Implementation of recommendations” (EPA 2007). The abstract of that report is reproduced below. The recommendations from the Review of Environmental Impacts of the Acid In-situ Leach Uranium Mining Process (2004) have now been implemented into the appropriate regulatory programs of the South Australian Environment Protection Authority (EPA) and Department of Primary Industry and Resources, South Australia (PIRSA). Details of how the recommendations have been actioned are provided in the summary (see Page 8). Some outcomes from the recommendations require ongoing monitoring and assessment. Such requirements have also been included in the relevant monitoring programs. This report has been developed with the agreement from PIRSA and Department for Water, Land and Biodiversity Conservation (DWLBC.) The interested reader is referred to the 2007 EPA report, which tabulates the recommendations and how they were individually implemented.
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Section 11 References
11 Refer en ces Arid Areas Catchment Management Board. 2006. State of the Catchment Report. Report prepared for the South Australian Arid Lands Natural Resources Management Board, January 2006. Armstrong D. 2005. Report to Arid Areas Catchment Water Management Board on Review and Application of BRS Numerical Model – GABFLOW. (Not published, reported in Arid Areas Catchment Management Board, 2006). ARPANSA. 2005. Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing. Radiation Protection Series Publication No. 9 AS/NZS ISO 14001:2004 : Environmental management systems - Requirements with guidance for use. Badman FJ. 2006. Beverley Uranium Mine Additional Mineral Leases - Flora Survey. Prepared for Heathgate Resources Pty Ltd. Badman FJ. 2007. An Assessment of the Significant Environmental Benefit Values of the Beverley East Zone 2 Mine Lease Area. Prepared for Heathgate Resources Pty Ltd. Brandle R. 1998. A Biological Survey of the North West Flinders Ranges, South Australia, Dec 1997 (Biological Survey and Research, Department for Environment, Heritage and Aboriginal Affairs, South Australia) CSIRO Land and Water. 2004. Review of Environmental Impacts of the Acid In-situ Leach Uranium Mining Process. Authors Graham Taylor, Vic Farrington, Peter Woods, Robert Ring and Robert Molloy. Report for the South Australian Environment Protection Authority. Department of Industry Tourism and Resources, 2006a. Mine Closure and Completion. Department of Industry Tourism and Resources, 2006b. Mine Rehabilitation. Department of Education, Science and Training. 2002. National Radioactive Waste Repository Draft EIS. Prepared by PPK Environment and Infrastructure. DEWR/PIRSA 2007 DRAFT Guidelines for Preparation of a Public Environment Report (PER) under the Australian Government Environment Protection and Biodiversity Conservation Act 1999 or a Mining And Rehabilitation Program (MARP) under the South Australian Mining Act 1971 Beverley Uranium Mine Extension, EPBC 2006/3167. Regulatory Guideline No. 2 Version: 4.6. Australian Government Department of the Environment and Water Resources / Government of South Australia Primary Industries and Resources SA, 28/06/2007. http://www.environment.gov.au/epbc/notices/assessments/2006/3167/draft-guidelines.pdf EBS Services. 2006. Beverley Uranium Mine Additional Mineral Leases - Fauna Survey. Prepared for Heathgate Resources Pty Ltd. Environment Protection Authority (SA). 2007. Review of environmental impacts of the acid in-situ leach uranium mining process – Implementation of recommendations, 26 September 2006. ISBN 978-1- 921125-38-6, June 2007. http://www.epa.sa.gov.au/pdfs/acid_leach.pdf Heathgate Resources Pty Ltd. 1998. Beverley Uranium Mine: Environmental Impact Statement – Main Report. Heathgate Resources, June 1998, Adelaide. Heathgate Resources Pty Ltd. 1998. Beverley Uranium Mine: Environmental Impact Statement - Response Document/Supplement. Heathgate Resources, September 1998, Adelaide. Institution of Engineers Australia. 1987. Australian Rainfall and Runoff. McKay, A, Stoker, P & Lambert, I 2007. Resource Estimation for In Situ Leach Uranium Projects andreporting under JORC Code. Presentations, Australia’s Uranium Conference 2007, 15-16 May 2007, Darwin, Australia. Australasian Institute of Mining and Metallurgy (Melbourne) Publication Series No 3/2007.
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Section 11 References
McDonald A and Rogner H-H. 2002. Nuclear power: status and outlook. International Atomic Energy Agency. McLaren N., Wiltshire D., and Alexander L., 1992, Arid Zone Field, Environmental Handbook, Santos Ltd and Delhi Petroleum Pty Ltd.100pp. Minister for Primary Industries, Natural Resources and Regional Development, South Australia. 1998. Assessment Report on the Environmental Impact Statement for the proposed Beverley Uranium Mine. South Australian Government. Native Vegetation Council, Department of Water, Land and Biodiversity Conservation. October 2005. Guidelines for a Native Vegetation Significant Benefit Policy for the Clearance of Native Vegetation Associated with the Minerals and Petroleum Industry. National Health and Medical Research Council (NHMRC) and National Occupational Health and Safety Commission (NOHSC). 1995. National standard for limiting occupational exposure to ionizing radiation. Owens, H. 2000. Guidelines for Vertebrate Surveys in South Australia Using the Biological Survey Of South Australia. (National Parks & Wildlife South Australia). Parliament of the Commonwealth of Australia. 2006. Australia’s uranium - Greenhouse friendly fuel for an energy hungry world. House of Representatives Standing Committee on Industry and Resources. November 2006. Canberra. Peggs, I. D. 2006. Geomembrane Liners in Wastewater Treatment Ponds: Whales, and their Prevention. Land and Water 50(4). http://www.landandwater.com./features/vol50no4/vol50no4_1.php PIRSA. 1998. Field guide for the environmental assessment of abandoned petroleum wellsites in the Cooper Basin, South Australia. Primary Industries and Resources SA PIRSA. March 2007. Mining Approvals in South Australia, version 1.4. Primary Industries and Resources SA PIRSA. July 2007. Guidelines for the Preparation of a Mining Lease Proposal or Mining and Rehabilitation Program (MARP), version 4.8. Primary Industries and Resources SA Spadaro, Joseph V., Lucille Langlois, and Bruce Hamilton, 2000: “Assessing the Difference: Greenhouse Gas Emissions of Electricity Generating Chains,” IAEA Bulletin,Vol. 42, No. 2,Vienna, Austria. Termite Resources 2007 Cairn Hill Magnetite- Copper-Gold Mining Proposal Supporting Document for Mining Lease Application. http://www.pir.sa.gov.au/__data/assets/pdf_file/0008/50777/2007-06-28- Mining_Proposal.pdf Tonkin, B. C. and Associates. 1998. Surface water hydrology study for the Beverley Retention Lease site South Australia. Supporting document to the Beverley Uranium Mine Environmental Impact Statement, Heathgate 1998. Tongway, D. J. and Hindley, N. L. 2004. Landscape function analysis: Procedures for monitoring and assessing landscapes. CSIRO Sustainable Ecosystems. 82 pp. Uranium Information Centre. 2006. Energy Analysis of Power Systems. UIC Nuclear Issues Briefing Paper # 57, March 2006
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Section 12 Limitations
12 Limit ations URS Australia Pty Ltd (URS) has prepared this report in accordance with the usual care and thoroughness of the consulting profession for the use of Heathgate Resources Pty Ltd. Only Heathgate Resources Pty Ltd and the South Australian and Commonwealth government departments or authorities to whom this report is to be submitted may rely this report. No other third party may rely on this report unless the third party has been authorised in writing by URS to rely on the report. This report is based on generally accepted practices and standards at the time it was prepared. No other warranty, expressed or implied, is made as to the professional advice included in this report. It is prepared in accordance with the scope of work and for the purpose outlined in the Proposal dated 21 December 2005, and subsequent documentation. The methodology adopted and sources of information used by URS are outlined in this report. URS has made no independent verification of this information beyond the agreed scope of works and URS assumes no responsibility for any inaccuracies or omissions. No indications were found during our investigations that information contained in this report as provided to URS was false. This report was prepared between February and December 2007 and is based on the information reviewed at the time of preparation. URS disclaims responsibility for any changes that may have occurred after this time. This report should be read in full. No responsibility is accepted for use of any part of this report in any other context or for any other purpose or by third parties. This report does not purport to give legal advice. Legal advice can only be given by qualified legal practitioners.
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Appendix A Wooltana Lease
A. Wooltana Lease
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MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Appendix B Environmental Studies Summary Report
B. Environmental Studies Summary Report
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
SUMMARY REPORT:
EL3251 Environmental Studies
Heathgate Resources Pty Ltd Level 9, 45 Grenfell Street Adelaide SA 5000
25 North Terrace Hackney SA 5069
01 December 2006
42656422.05011
Contents
1 Introduction------2
1.1 Background 3 1.2 Report Objectives 4
2 Environmental Studies - Summary Details ------5
3 Hydrogeology ------6
3.1 Hydrogeology - Background 6 3.2 Hydrogeological Setting 6
4 Geology ------11
4.1 Geology - Background 11 4.2 Geology Setting 11
5 Hydrology ------15
5.1 Hydrology - Background 15 5.2 Hydrology Setting 15
6 Heritage ------19
6.1 Heritage - Background 19 6.2 Heritage Description 19
7 Flora------21
7.1 Flora - Background 21 7.2 Flora Description 21
8 Fauna ------24
8.1 Fauna - Background 24 8.2 Habitat Description 24 8.3 Fauna Survey Findings 24
9 Conclusions ------26
10 References------27
J:\JOBS\42656422\6000\FINAL STUDY REPORTS\EL3251 STUDIES SUMMARY REPORT NOV06.DOC\1-DEC-06 i List of Tables and Figures
1 Introduction
Tables
Table 1 – Summary of Environmental Studies
Table 2: Abbreviated Regional Stratigraphy
Table 3 – Significant Environmental Benefit Ratio Scores
Figures
Figure 1 – Study Area
Figure 2 – Monitoring Well Locations
Figure 3 – Conceptual Model in Vicinity of Beverley Channels
Figure 4 – Regional Geology
Figure 5 – 10 Year and 100 Year ARI Flood Plain (Mulga Creek and Paralana Creek Catchments)
Figure 6 – Flora Monitoring Sites
Figure 7 – Fauna Monitoring Sites
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1.1 Background
Heathgate Resources Pty Ltd (Heathgate) seeks a Mineral Lease (ML) for their Acid In-situ Leach Uranium Mine at Beverley, South Australia. Beverley Mine is located to the east of the Northern Flinders Ranges, approximately 550 km north of Adelaide and 35 km west of the northern end of Lake Frome.
A Mineral Lease is necessary to allow additional in-situ leach well fields for the southern portion of Exploration Lease (EL) 3251, as shown by the dashed line in Figure 1 below.
Figure 1 – Study Area
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The extended ML area is needed to extend the life of the current mine operation. Additional wellfields in the extended ML area would link to the current processing plant via temporary pipelines. Wellfields would be established for periods of 12 months, until uranium levels are depleted, whereupon a new wellfield would be developed and the previous wellfield area would be rehabilitated.
The proposed operations in the extended ML area would be the same as previously undertaken. No additional permanent processing plant or change to operations is proposed for the new ML area.
To accompany this ML application, Heathgate undertook priority environmental impact assessment studies of the proposed ML area (as shown in Figure 1). These studies detail the environmental characteristics of the ML area, compare environmental conditions to the current mine operational area and note updated information since the development of the original mine Environmental Impact Statement (EIS) (Heathgate Resources, 1998).
The following environmental impact assessment studies, deemed to be of key priority to support the ML application, were undertaken during the period of March to July 2006:
• Hydrogeology
• Geology
• Hydrology
• Flora
• Fauna
• Aboriginal Heritage
The other key environmental aspects addressed in the 1998 EIS were in relation to visual amenity, socio- economic impacts, radiation, transport and climate. It is considered that the issues in relation to these aspects would be essentially unchanged for the proposed wellfields operations in the extended ML area.
1.2 Report Objectives
This report provides an overview of the findings of the priority environmental studies undertaken of the proposed ML area during March to July 2006. Key findings, including any significant differences from the EIS, as well as considerations for environmental management for the ML area, are highlighted.
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2 Env ironmenta l St udies - Summary Details
Table 1 summarises the priority environmental impact assessment studies undertaken of the proposed ML area. Overall coordination and project management of these studies was undertaken by URS Australia Pty Ltd (URS).
Table 1 – Summary of Environmental Studies
Study Consultant/s Study Period Reference
Hydrogeology Flow Environmental Management April – September Flow Environmental Management (Alexandra Dimos, Hydrologist) 2006 Pty Ltd (2006). EL3251 Don Armstrong, Hydrologist. Hydrogeology Study Beverley Uranium Mine. Draft Report. Geology URS Australia Pty Ltd (John Slade , March – May URS Australia Pty Ltd (2006). Geological Engineer and Peter 2006 Beverley Uranium Mine EL 3251 Mitchell, Senior Principal Geological Geology Study Part 1. Engineer) Hydrology URS Australia Pty Ltd (Jerome Argue, March – May URS Australia Pty Ltd (2006). Senior Principal Engineer) 2006 Beverley Uranium Mine EL 3251 Hydrological Study Part 1. Flora Badman Environmental (Frank March – May Badman Environmental (2006). Badman, Botanist) 2006 Southern EL 3251 Flora Survey. Fauna Environmental and Biodiversity March – May EBS (2006). Southern EL 3251 Services (Dr Travis How, Director and 2006 Fauna Survey. Project Team) Aboriginal Bob Ellis (Aboriginal Cultural Heritage March – May Ellis, B (2006). Aboriginal Cultural Heritage Consultant) 2006 Heritage. A Report on the Heathgate Resources Pty Ltd Mineral Lease Extension Area (ML6036).
A summary of the scope, key findings and conclusions of the above studies is provided in Sections 3 to 8.
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3 Hydrogeology 3.1 Hydrogeology - Background
Flow Environmental Management was engaged to undertake a desktop study of the local and regional hydrogeology of the southern portion of EL 3251 (refer to Figure 1 – Study Area).
The study involved a desktop review of the hydrogeological characteristics of the study area, and updating the hydrogeological assessment of the June 1998 EIS for the current mine operation.
A large part of the regional geological discussion in the 1998 EIS remains valid for the study area. Therefore, the hydrogeological setting discussion is primarily sourced from the EIS, but also includes revisions of the conceptual understanding and detailed evaluation of water level observations that have been collected since the commencement of monitoring in 2001.
3.2 Hydrogeological Setting
The Beverley uranium deposit is located within the western Frome Embayment region where groundwater occurs in several separate aquifer systems (from deepest to shallowest):
• Mt Painter Complex and other fractured rock aquifers (Proterozoic);
• Great Artesian Basin (GAB) aquifer - the Cadna-Owie Sandstones (Mesozoic);
• Eyre Formation - blanket and palaeochannel sands, which are not thought to be extensively developed at Beverley (Tertiary);
• Namba Formation aquifers - Beverley and Alpha, Beta and Gamma Sands (Tertiary); and,
• Willawortina Formation and younger aquifers - conglomerates and poorly sorted sands in clays, and those aquifers in the younger stream sediments, which have been incised into the Willawortina Formation (Tertiary and Quaternary).
• Between and within each of these aquifers are aquitards.
New exploration drilling and re-interpretation of old drilling data have led to the recognition of a more complex pattern of channel sands than that outlined in the current EIS.
In plan view, several new mineralised zones, referred to as “trends” have been described:
• Northeast sands lying immediately to the east of the North Beverley Orezone and trending towards the east. This sand body has been tested for continuity with Beverley North and found to be essentially a separate sand lens surrounded by sits and clays.
• Beverley East trend, which extends from the eastern side of the Central Beverley Orezone in a position, which approximately coincides with the projected Central Channel shown in EIS Figure 6.4.
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• Deep South area with two essentially north-south trending mineralised sands, including:
– Russell trend, which lies to the east of a southerly extrapolation of the Beverley South Orezone (roughly coinciding with the South channel shown on EIS Figure 6.4); and
– Poontanna trend, which lies approximately one km west of the Russell trend and over three km south of the current ML boundary.
In vertical profile, drilling below the Alpha Mudstone (which lies below the Beverley Sand) has revealed a series of mineralised sequences of sand, separated by mudstones and grading laterally into silts/clays. These sands have been designated Alpha, Beta and Gamma sands and the intervening mudstones bear the name of the underlying sand zone. Thus the stratigraphic sequence, where fully developed, consists from top downwards of:
• Beverley Sand;
• Alpha Mudstone;
• Alpha Sand;
• Beta Mudstone;
• Beta Sand;
• Gamma Mudstone;
• Gamma Sand;
• Lower Namba Carbonate; and
• Eyre Formation.
Since the commencement of mining operations, a series of monitoring wells have been installed within and near the boundaries of the channel sand deposits, predominately within the current mining lease boundary. The majority of these wells intersect the Beverley Sand aquifer, providing a very good spatial distribution for understanding the water level responses in this aquifer. These wells are either screened within the sand body of the orezone or within low permeability silty-clay sediments at the margins of the channel sands, both laterally and vertically.
A total of eight wells have been screened across the Alpha Sand aquifer. In addition, a number of wells intersect the overlying Willawortina Formation. Gauging information pertaining to these wells is available from 2001. Three monitoring wells have been installed within the southern portion of the EL3251. For two of these wells, gauging records since early 2005 are available for the assessment of temporal trends. Apart from these three monitoring wells, the hydrogeological setting for the study area is primarily sourced from the EIS.
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Water levels measured in the Namba Formation, prior to the commencement of the 1997 round of groundwater pumping activities at Beverley (the method of mining), were approximately 60 m below ground level, at elevation levels of 17.74 m (+/-0.16 m) AHD. These levels may be taken to represent the undisturbed groundwater levels within the palaeochannel sands.
The recorded levels within the aquifer infer a very low hydraulic gradient, indicative of a low potential for groundwater flow. More recent water level data observed at monitoring wells outside the boundaries of the orezones and the current ML area, indicate static water levels, which are not considered to be influenced by mining activities. A detailed review of the temporal water level trends within the current ML area and in the vicinity of the mining zones has identified the following key findings:
• Water levels of wells intersecting the low permeability sediments show a slow water level recovery back to pre-mine baseline levels following well development and routine groundwater sampling. This slow recovery process has been observed within the wells intersecting the low permeability silt- clay sediments of the aquitards within the different mineralised sand aquifers.
• Wells intersecting the Beverley sand aquifer respond rapidly to changes in on-going mining activities.
• Pumping tests and groundwater level observations have been used to determine the hydraulic connection between North, Central and South Orezones. Based on these observations, the North Beverley Orezone is considered to be hydraulically separated from the Central and South Beverly Orezones but a hydraulic connection exists between the South and Central Beverley Orezones.
• Water level responses to mining operations correlate with the inferred geological boundaries of the channel sand deposits and can be used to confirm these boundaries.
The existing mine Environmental Monitoring and Management Plan (EMMP) was based on the known extent of the Beverley Channel Sands at the time of the commencement of mining. The EMMP (and other relevant planning documentation for the site) would need to be updated to reflect the updated hydrogeological setting for the area (as new mineralised zones have been discovered and developed) and changes to the monitoring well layout, which have been progressively approved for the site.
Groundwater monitoring well locations, as of September 2006, are shown in Figure 2.
A conceptual model of the Beverley aquifer system (for the immediate environs of the Beverley Channel Aquifers) is illustrated in Figure 3.
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Figure 2 – Monitoring Well Locations
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Figure 3 – Conceptual Model in Vicinity of Beverley Channels
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4 Geology 4.1 Geology - Background
A desk-top study of the regional geology and geology of the study area was undertaken by URS. The geology assessment was based on documented information, and additional information from the progression of the exploration for resources for the Beverley Uranium Mine, to the period ending February 2006. The Geology Study report updates Section 6 ‘Existing Physical Environment– Regional Geology’ of the June 1998 EIS (Heathgate Resources, 1998) and updates relevant figures.
It needs to be noted that exploration to date has been to the south and eastern sections of the study area. This exploration has been broad (i.e. large drill patterns of 200m x 200m) and therefore the definition of geological controls upon depositional environments, mineralization and structural settings are to within the accuracy of this exploration work.
4.2 Geology Setting
The Geology Study report provides details of the regional structural, lithological and depositional factors controlling the mineralisation of the Beverley Uranium Mine resource. This information is based on reports from Heathgate Resources and publicly available maps and other information.
The Beverley Uranium Deposit lies in the western part of the Frome Embayment between Lake Frome and the Flinders Ranges. The regional geology of the Frome Embayment is illustrated in Figure 4. The stratigraphy of the region is summarised in Table 2.
A large part of the regional geological discussion in the June 1998 EIS statement remains valid for the study area. Therefore, the regional geology discussion is consistent with sections of the June 1998 EIS that are of relevance to the study area. Updated figures to illustrate the regional geology in context of the study area and the current mine operation have been incorporated into the Geology Study report.
A revised assessment was undertaken of the seismic activity in the region, soil and terrain classifications and the geotechnical characteristics of the sediments of the Beverley resource contained within the study area.
Key findings of the URS geological assessment in relation to the extended ML area that have changed or progressed since the description in the 1998 EIS are detailed below.
• Geology and Mineralisation
Recent drilling to the south of the Beverley Deposit confirms repeated stratigraphic units and the presence of mineralised sands deeper than currently mined at the Beverley Deposit. Mineralisation has been intersected at depth of 200 to 240m. This mineralization is contained with a coarse-grained thick sand sequences below the Alpha Mudstone unit (called the Deep Sands). It is unclear whether the Deep Sands are part of the Namba Formation or Eyre Formation. Exploration models indicate the Russell Structure is a primary control in the location of the mineralisation.
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Since 1994, exploration has identified, to the south and east of the existing mine, additional structural trends. Further exploration is required to define these trends and the existence of structures in the structural trends.
At the time of the URS study there was no further geotechnical or geochemical data available.
• Seismicity
Since the June 1998 EIS, the Australian Standard (AS1170.4 – 1993) ‘Minimum design loads on structures Part 4: Earthquake Loads’ has been updated in draft form (by David Love, PIRSA Senior Seismologist). URS sighted this draft standard and confirmed that the statements made in the June 1998 EIS remain valid. This draft standard would need to be considered in relevant documentation for the extended ML area.
As stated in the June 1998 EIS response document/supplement, seismic risk is addressed in detail in EIS Section 6.4 and EIS Appendix 3. The possibility of an earthquake destabilising the mine site has been quantified based on data from AGSO. The Beverley area has a similar seismic risk to Adelaide and appropriate design criteria are being utilised.
In relation to major earthquakes being accompanied by small movements along existing fault planes, the EIS Supplement stated that there were no identified faults in direct contact with mining solutions, and movements of the order of a few millimetres along a distant fault, such as the Poontana Fault, would be unlikely to alter the groundwater regime.
However, URS has noted that recent magnetic surveys have identified new fault systems in the region and have provided better definition of previously known fault systems.
• Soils and Terrain
Similar climate, topography, basement rocks and geomorphologic processes are active in the study area as has previously been described for the existing ML areas.
Whilst the general terrain patterns detailed in Section 6 of the EIS also apply to the study area, an additional field study would be necessary to map the terrain units.
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Figure 4 – Regional Geology
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Table 2: Abbreviated Regional Stratigraphy
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5 Hydrology 5.1 Hydrology - Background
URS has investigated and reported on the surface hydrology associated with the study area.
In undertaking this investigation, URS relied on both topographic information derived from satellite photographs, as well as a site assessment. Reference was also made to earlier hydrology studies undertaken as part of the 1998 EIS (B.C Tonkin & Associates, 1998).
A previous study (B.C Tonkin & Associates, 1998) investigated the two Creeks; 4-Mile Creek and Jenny Creek, in the northern part of the study area. URS’ study therefore focussed on Mulga Creek (which runs through the centre of the study area) and Paralana Creek (which enters the study area for a short distance near the south-eastern corner).
A flood-routing model and backwater curve analysis model were established for the creeks, defining extent of flooding during both a 1 in 10 year Average Recurrence Interval (ARI) and a 1 in 100 year ARI event.
Rainfall information was derived using the procedure outlined in Australian Rainfall and Runoff (1987), and catchment analysis, using available topographic information, was undertaken for input into the rainfall runoff routing model (RORB). Output from this model was then translated into the HEC-RAS model, using cross-sections derived from topographic data, to predict the extent of flooding during the two analysed events.
5.2 Hydrology Setting
Beverley Mine is located in an arid region of South Australia, in the Northern Flinders Ranges. The area is characterised by low average, but highly variable rainfall. Rainfall events of varying duration and recurrence interval were derived using the procedure outlined in Australian Rainfall and Runoff (ARR 1987), for use in predictive modelling.
Catchment Analysis
A series of water courses, rising in the Flinders Ranges, flow is a generally easterly direction (including across the Heathgate site), eventually discharging into Lake Frome. Between the Ranges and the Lake, many small flow channels are cut into the topography, rising in the low foothills of the area, at about elevation 100 m AHD, and which also flow in an easterly direction toward Lake Frome.
As these channels merge and join, increasing catchment areas result in larger flows being experienced during major storm events. The study area is crossed by many such ephemeral streams, whose channels vary in size from shallow depressions at their source, to large, flat expanses of braided channels, flowing across the flat topography.
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To the south, beyond the study area boundary, Paralana Creek drains a significant catchment which rises in the Ranges. As it travels generally beyond the southern boundary of the study area, it branches at a point near the Paralana Outstation, with one branch flowing to the south-east, and a second to the north- east. This branch enters the study area near the south-eastern corner, joining with Mulga Creek, prior to discharging across the eastern boundary of the study area and flowing toward Lake Frome.
Within the study area, Mulga Creek rises along the western boundary in a series of small channels spread from south to north across the area. These various branches gradually join together in a series of increasingly larger streams, which become wider as they reach the flatter land toward the eastern side of the study area.
The two main drainage systems assessed through this study, Paralana Creek and Mulga Creek, were determined to have catchments of 208km2 (Paralana Catchment) and 47km2 (Mulga Creek Catchment) respectively. It should be noted however that these catchments have many tributaries and smaller drainage lines that combine to form the larger system.
The flood plains for both catchments are shown in Figure 5.
The study concludes that the extent of flooding during both ARI events (1in 10 year and 1 in 100 year) is quite similar, with relatively low velocities associated with flood flows (generally 1 m/sec or less).
In assessing the impact of predicted flood risk on potential operations within the floodplain, recognition must be made of the likelihood of a flood event occurring. For example, if activities are to be located within a floodplain for a period of 12 months only, such as is the case for piping and extraction equipment associated with individual wellfields for the ISL process, a lower flood standard may be considered to be appropriate. Over a 12–month period, the probability of operations within the 100 year floodplain being inundated is 1%, while within a 1 in 10 year ARI floodplain it is 10%.
However operational facilities that are to remain in one place for a much longer period, for example 15 years, would be exposed to a higher level of probability of inundation if located within a floodplain. This could be the case for main connecting pipelines or other infrastructure that may stay in place for some years. Within a 1 in 100 year floodplain, a facility with a 15 year life would have a probability of 14% of being inundated, which although still unlikely, is clearly higher.
Consideration of risk should also be tempered with consequence of inundation. As has been discussed, flow velocities within the floodplain, be it either the 1 in 10 year or 1 in 100 year ARI floodplain, are relatively low; generally 1 m/sec or less. Provided design of equipment was able to sustain flow of such a velocity, location of equipment within the 1 in 10 year floodplain for 12 month periods could be considered appropriate, with more long-term equipment located beyond the 1 in 10 year ARI floodplain.
It is proposed that a risk-based approach is appropriate in determining the location of facilities within floodplains, recognising both the risk of inundation as well as the consequences of inundation, given considerations of velocity of flow. Such an approach would be adopted in design planning for the extended ML area.
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Figure 5 – 10 Year and 100 Year ARI Flood Plain (Mulga Creek and Paralana Creek Catchments)
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6 Heritage 6.1 Heritage - Background
An Aboriginal Cultural Heritage Study of the area was undertaken by Bob Ellis (Ellis B, 2006). The report identifies and addresses the Aboriginal Cultural Heritage matters which arise in the study area (Figure 1).
The Aboriginal Cultural Heritage Study relies upon:
• information collated as a result of ten (10) separate Cultural Heritage inspections and reports which have been produced since 1999; and
• application of a methodology for continuing assessment of activities proposed by Heathgate Resources Pty Ltd (and its sister company Quasar Resources Pty Ltd) in the area of their leases and licences.
Previous inspections (Ellis B, 1999-2006, Fitzpatrick P, 2002) have arisen from the application of a Work Area Clearance methodology, adopted by the company in association with the Native Title applicants, to minimise potential deleterious impact upon Aboriginal cultural values at all stages of exploration and development within the mining leases and licences held. This methodology and the inspections it has generated have resulted in detailed and in most cases, on-foot investigation, of areas embraced by the proposed extended ML area.
The Work Area Clearance methodology was developed in the Northern Territory to permit Aboriginal traditional owners, in company with cultural heritage professionals or advisors, (but not those professionals or advisors alone), to assess activities proposed on Aboriginal land, without the necessity for them to divulge information on the cultural amenity of the area within which work is proposed (see Toyne and Vachon, 1984, p. 111).
6.2 Heritage Description
The study area has been the subject of at least ten Work Area Clearance inspections by teams of Adnyamathanha researchers. As a consequence of those inspections, maps have been produced by Heathgate Resources Pty Ltd, in association with the researchers, which detail areas where approval has not yet been granted for exploration or related activities.
While not shown on those maps, an area applies 30m either side of Four Mile Creek along its entire length. Elsewhere, approvals may have been granted for specific activities, but those approvals may be subject to conditions imposed by the research teams which are specified in the reports of the inspections.
As mentioned above, team members have been reluctant to approve any physical intervention within 30m of the banks of Four Mile Creek or of other major watercourses
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There are two reasons for this reluctance: in the first instance, most evidence of prehistoric or historic Aboriginal occupation in this area is associated with such watercourses (Kinhill, 1997). Further, as a consequence of the general association of significant traditions in this area with Four Mile Creek, Mr Artie Wilton, the last Adnyamathanha wilyaru man, expressed a desire to ensure that drilling and other physical activities should be precluded from the bed of that watercourse.
In the area to the east of the Beverley Mine exclusion area has been established along the shores of a presumed flood line. Inspection of this area confirmed the presence of numerous artefacts, predominantly grindstones and ilda (stone ovens employed in the preparation of vegetable foods).
The survey of Adnyamathanha cultural heritage matters pertaining to the present ML 6036, and the proposed extended ML, does not seek to provide an “expert” assessment of, or approval for, future activities likely to be undertaken within those tenements or future tenements. Rather, it is the intention of this report to outline a method for work clearance that has been employed for continuing assessment of such activities by Adnyamathanha representatives who have been selected by named Native Title applicants.
The applicants are generally considered by their peers to be most closely associated with the Wooltana Pastoral Lease and knowledgeable about its cultural amenity. This is the preferred approach of the body representing the Native Title claimants for the area under review and the one that most closely replicates the traditional decision-making responsibilities that previously applied in this area.
Such an approach is recommended as one most likely to ensure continuing protection for the cultural heritage values and places associated with the areas under consideration. It is also considered to have the benefit of promising opportunity for Heathgate to negotiate reasonable and speedy resolution of matters essential for future mine development within such tenements as they may be granted in this location.
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7 Flora 7.1 Flora - Background
Badman Environmental was engaged to undertake a flora assessment of the proposed extended ML area (Figure 1). The study was undertaken in March 2006 and included a baseline survey and assessment of the vegetation communities and flora species within the study area, including the two supplementary areas on the southern boundary of the extended ML area (shown shaded in Figure 1).
The survey design was planned so as to be compatible with other South Australian Department for Environment and Heritage (SA DEH) biological surveys. A field survey was carried out using the methodology of the Biological Survey of South Australia, with permanent numbered vegetation monitoring sites that conform to the standards of the SA DEH Biological Survey. Monitoring sites covered one hectare and a 100m x 4m Jessup Transect was also set up at each site to gather quantitative data on shrub densities. These sites will form the basis of an ongoing monitoring programme (refer to Figure 6). The location and extent of any threatened or significant species was recorded and assessed, as well as the distribution of any alien species.
7.2 Flora Description
Data from these sites was examined by means of the multivariate analysis techniques of ordination and classification. These analyses resulted in the description of three main vegetation groups which are consistent with the main groups described for the mine area in the 1998 EIS (Heathgate Resources, 1998). These groups are the Mitchell Grass plains (with Astrebla pectinata and Sclerolaena spp.), the minor watercourses (with Rhagodia spinescens and several tall shrubs or low trees) and the major creek lines (with Eucalyptus camaldulensis and Melaleuca spp).
Quantitative data from this survey were compared to other data collected during the routine annual monitoring events at Beverley, but were found in most cases to be incompatible because of different survey techniques. The only previous data that were found to be compatible are those from the one hectare quadrat at monitoring site BU15 and this site was found to fit well with the Mitchell Grass plains group.
No species listed under the EPBC Act are known to occur at Beverley or on the study area. One threatened species, Swainsona oligophylla, which is listed as rare under the National Parks and Wildlife Act, 1972, is known to occur at Beverley. Two previously reported species, Frankenia subteres and Swainsona murrayana, are now considered to be based on misidentifications. Most of the threatened species that are known to occur in the general area are restricted to the Flinders Ranges and are not known to exist on the plains.
One proclaimed plant, Tribulus terrestris, has been recorded at Beverley. It is fairly common in the general area and is not recorded in all years. Nineteen alien plant species have been recorded at Beverley and a further 10 are known to occur in the general area. None of these occurrences can be directly attributed to exploration or mining activities.
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Two alien species have been recorded at the Four Mile Bore since the 1998 EIS survey. This bore and its wetland pre-date any exploration and mining activities and it is not known whether the presence of these species is connected to these activities.
Under the proposed revised methodology for determining Significant Environmental Benefit (SEB) ratios (DWLBC (2005b) the vegetation impact scoring system would give a score of 12 (Table 3 below) out of a possible total of 36. This would give a ratio of 3:1, taking into consideration that arid zone areas can be heavily disturbed without the introduction of sufficient weed species to form a dominant part of the vegetation (Badman 1995).
Table 3 – Significant Environmental Benefit Ratio Scores (under the proposed revised methodology)
Rate of regeneration 2 Remnancy 1 Disturbance 1 (except that very few dead and no live weeds present) Surface Water and Drainage Effects 1 Soil Erosion 1 Wetland 0 Threatened Species and Communities 1 Biodiversity 2 Connectivity 2 Habitat 1 Total 12
It is proposed that the current measures in the Beverley site EMMP would need to be extended to the proposed extended ML area to prevent any adverse vegetation impacts from new wellfield development.
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Figure 6 – Flora Monitoring Sites
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8 Fauna 8.1 Fauna - Background
A fauna survey was conducted in the southern half of the Exploration Lease 3251 (an area surrounding the existing Beverley Uranium Mine), north east of Arkaroola, South Australia in March 2006.
A total of nine sites representing four different habitat types were surveyed for fauna species following a standard biological survey methodology developed by the Department for Environment and Heritage (Owens 2000) (refer to Figure 7).
8.2 Habitat Description
The dominant habitat types within the project area were:
• Sclerolaena spp - Herbland on high and low gibber plains (would be a Mitchell Grass (Astrebla pectinata) plain in better years)
• Eucalyptus camaldulensis - Very Open Woodland
• Eremophila spp. / Acacia spp. / Santalum lanceolatum - Tall Shrubland
• Acacia victoriae - Tall Shrubland over chenopods
8.3 Fauna Survey Findings
Major findings of the survey were:
• Mammals - A total of 147 observations of 20 mammal species were made, of which only four are considered to be introduced.
• Reptiles - A total of 84 observations of 24 reptile species were made, all of which were native species. No amphibian species were observed however little suitable habitat was observed within the project area.
• Birds - A total of 892 observations of 48 bird species were made, with only one of these an introduced species.
• No species of state or national conservation significance were observed during the survey. However, one notable capture was a Pseudomys hermannsburgensis (Sandy Inland Mouse). This record (voucher specimen lodged with the South Australian Museum) is a range extension for this species of over 80km.
Gunninah Environmental Consultants completed a fauna survey at the Beverley Mine site as part of the EIS in 1998. A total of six sites were implemented and the survey was undertaken over a six night period. A similar list of fauna species was recorded compared to the current survey. The Gunninah 1998 survey
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recorded four reptile species, four mammal species and 20 bird species which were not recorded in the current survey. The current survey recorded three reptile species, two mammal species and ten bird species which were not recorded in the Gunninah 1998 survey. None of the additional species recorded by Gunninah in 1998 were of conservation significance.
The annual fauna monitoring at the Beverley Mine site, which re-surveys the trapping site put in by Gunninah Environmental Consultants, has recorded an additional two bird species and three reptile species which were not recorded by Gunninah or during the current fauna survey. None of the additional species are considered to be of conservation significance.
It is proposed that the current measures in the Beverley site EMMP would be extended to the proposed extended ML area to prevent any adverse fauna impacts from new wellfield development.
Figure 7 – Fauna Monitoring Sites
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9 Conclusio ns It is proposed that the findings of this environmental review, including environmental information that has become available since the 1998 EIS, will be utilised in updating the documents that govern environmental management at the extended Beverley mine site (incorporating the proposed extended ML area). These documents comprise:
• Environmental Management and Monitoring Plan
• Radioactive Waste Management Program
• Mining and Rehabilitation Program
• Transport Management Plan – Uranium Ore Concentrate
• Transport Management Plan – General Dangerous Goods
It is considered that the existing environmental management measures are an appropriate basis for application to the establishment of additional wellfields in the proposed extended ML area.
However, arising from this environmental review, Heathgate propose that that the following key points would be incorporated into the management measures detailed in the above Plans and Programs:
• Changes to groundwater information and monitoring well layout;
• Changes in key geological findings (including updated design planning to incorporate revised seismic standards and accommodating any different terrain units);
• Consideration of 1in 10 year flood management standards for short-term wellfields (typically 12 months) based on the hydrology assessment recommendations;
• Use of advanced methodologies for Aboriginal Heritage Assessment and Work Clearance processes at the site; and
• Continued implementation of environmental management measures for flora and fauna, including a review of monitoring sites.
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10 References
1. B. C. Tonkin and Associates (1998), Surface water hydrology study for the Beverley Mineral Lease Site in South Australia, June, 1998
2. Badman Environmental (2006). Southern EL 3251 Flora Survey.
3. EBS (2006). Southern EL 3251 Fauna Survey.
4. Ellis, B (2006). Aboriginal Cultural Heritage. A Report on the Heathgate Resources Pty Ltd Mineral Lease Extension Area (ML6036).
5. Flow Environmental Management Pty Ltd (2006). EL3251 Hydrogeology Study Beverley Uranium Mine. Draft Report.
6. Heathgate Resources (1998). ‘Heathgate Resources Pty Ltd Beverley Uranium Mine Environmental Impact Statement – Main Report, June 1998.
7. Heathgate Resources (1998). ‘Heathgate Resources Pty Ltd Beverley Uranium Mine Environmental Impact Statement – Response Document/Supplement, September 1998.
8. URS Australia Pty Ltd (2006). Beverley Uranium Mine EL 3251 Hydrological Study Part 1.
9. URS Australia Pty Ltd (2006). Beverley Uranium Mine EL 3251 Geology Study Part 1.
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Appendix C Oct 2006 Native Vegetation Application
C. Oct 2006 Nati ve Veg etation Applic ation
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
31 October 2006
Mr. Greg Marshall Chief Inspector of Mines Regulation and Rehabilitation Branch Primary Industries and Energy GPO Box 1671 Adelaide SA 5001
Dear Mr. Marshall,
NATIVE VEGETATION MANAGEMENT – NORTH-EAST
I refer to correspondence dated 23 May 2006 where approval was granted for an amendment to Mining and Rehabilitation Plan 99/26 to conduct mining operations in the Beverley North East area. In this correspondence you referred to possible further requirements under the Native Vegetation Act 1991 and associated regulations.
The majority of mining surface area that will be disturbed has little to no native vegetation, consisting mainly of gibber plains as detailed in the existing MARP, EIS and EMMP. However mining within the North East zone will progress through a section of vegetation highlighted on figure 6.57 of the EIS, under the section “Environmentally sensitive locations in the project area”.
As required under the South Australian Native Vegetation Regulations (2003), and according to the PIRSA guideline, “Guidelines for a Native Vegetation Significant Environmental Benefit Policy For the clearance of native vegetation associated with the minerals and petroleum industry”, Heathgate has undertaken an assessment of this vegetation. This assessment was undertaken by the consultant Frank Badman of Badman Environmental; his full report entitled “An assessment of the Significant Environmental Benefit Values of the North East Creeklet at the Beverley Uranium Mine” has been provided as Attachment 1.
Based in this consultant’s assessment, Heathgate proposes to adopt a SEB ratio of 4:1 for the area of potential disturbance in the North East Creeklet. This area will be a maximum of 100m x 115m, see figure 1.
Heathgate intends to fulfill its Native Vegetation SEB commitments for this area by 2 allocating a 46,000m section of its pastoral lease Wooltana Station as an offset area to have native vegetation management. This section of the pastoral lease is adjacent to existing National Parks; the approximate location is shown in figure 2. The final location will be confirmed following consultation with local Aboriginal groups. The management of the offset area will be outsourced to the local Aboriginal communities and Heathgate will submit a SEB Offset Area Management Plan by 30th June 2007; this will provide details regarding the long-term management of the offset area.
HEATHGATE RESOURCES PTY. LTD. 45 GRENFELL STREET, LEVEL 9, ADELAIDE, S.A. 5000 AUSTRALIA ABN 31 011 018 232 PHONE +61 8 8110-0500 FAX +61 8 8212-5559 061031_PIRSA_NE creeklet_NativeVegSEB.doc Native Vegetation Management – North-East Page 2
Additional to this commitment Heathgate will continue with it current operational practices of Native Vegetation and general ecosystem management which includes:
x Identification of Native Vegetation and sensitive ecosystems as part of an Environmental Clearance Permit system. Site practices ensure no surface disturbances occur before an environmental clearance permit is issued;
x Fencing of identified sensitive vegetation and ecosystems;
x Re-location, wherever possible, of disturbance areas, drill sites and wellfield infrastructure to avoid sensitive vegetation and ecosystems;
x Determination of an approved road network;
x Agreement on maximum disturbance area, this is recorded and tracked as a key performance indicator;
x Photographing and specimen collection to ensure correct identification of species and to assist with rehabilitation;
x Training and Education of all site personnel;
x Details of rehabilitation requirements included on Environmental Clearance Certificate; and
x Rapid rehabilitation of completed areas (eg: delineation drilling sites generally rehabilitated within weeks of completion).
Heathgate believes that with its current, proven, management practices, disturbance of significant Native Vegetation within the North East Creeklet will be minimal. At the completion of mining in this area it is expected that rehabilitation outcomes will be achieved rapidly having surrounding and interwoven vegetation throughout the area to assist with these processes.
If you have additional queries please do not hesitate to contact me.
Sincerely,
Patrick Mutz Managing Director, Operations
HEATHGATE RESOURCES PTY. LTD. 45 GRENFELL STREET, LEVEL 9, ADELAIDE, S.A. 5000 AUSTRALIA ABN 31 011 018 232 PHONE +61 8 8110-0500 FAX +61 8 8212-5559 061031_PIRSA_NE creeklet_NativeVegSEB.doc MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Appendix D SEB Assessment Report April 2007
D. SEB Assessment Report April 2007 SEB: Significant Environmental Benefit
Prepared for Heathgate Resources Pty Ltd, 21 December 2007
AN ASSESSMENT OF THE SIGNIFICANT ENVIRONMENTAL BENEFIT VALUES OF THE BEVERLEY EAST ZONE 2 MINE LEASE AREA
Prepared for Heathgate Resources Limited
By F.J. Badman Badman Environmental
Adelaide April 2007
Badman Environmental 6 Griggs Drive Athelstone SA 5076 Tel/Fax: (08) 8365 7784 E-mail: [email protected] Beverley East Zone 2
LIST OF CONTENTS
Introduction...... 1 Methods...... 1 Results...... 1 Vegetation Groups ...... 1 Introduced Species...... 2 Threatened species and communities...... 5 Calculating the Significant Environmental Benefit Ratio ...... 7 References...... 8 Appendix A: Site photographs...... 9
Badman Environmental 2 Beverley East Zone 2
Introduction This report examines the vegetation of a section of country known as Beverley East Zone 2. This area lies to the east of the Beverley Mine Lease and measures approximately 450 m from north to south and approximately 300 m from east to west, an area of approximately 13.5 hectares. It is directly to the east of the existing Mine Lease fence and its location is shown on the drawing in Figure 1. The area contains two vegetation communities: chenopod low shrubland along the minor watercourse that diagonally crosses the south-west corner of the survey area and herbland dominated by chenopod forbs across the remainder. The latter area and vegetation type covers more than two thirds of the surveyed area. Methods The vegetation of two temporary and unmarked one hectare quadrats in the survey area was sampled using the methodology of the Biological Survey of South Australia (Heard and Channon 1997). One of these quadrats was placed within each of the vegetation types mentioned above, with site SEB01 in the gibber tableland association (Plate 1) and site SEB02 in the minor watercourse (Plate 2). These data were added to recently collected data from the Beverley Mine Southern EL 3251 vegetation survey (Badman 2006) and the recently completed Four Mile vegetation survey (Badman in prep.) The ensuing matrix was analysed and an ordination plot produced with the PC-Ord computer software package (McCune and Mefford 1999). Results
Vegetation Groups A list of the species recorded in the one hectare quadrats and others recorded in the survey area but outside the quadrats is given in Table 1. The ordination plot from the analysis of these data together with the Beverley Mine Southern EL 3251 vegetation survey data (Badman 2006) and the recently completed Four Mile baseline vegetation survey (Badman in prep.) is shown in Figure 2. The ordination plot (Figure 2) shows the same three vegetation groups as the two previous survey reports (Badman 2006, in prep.). The Beverley East Zone 2 sites lie within Vegetation Group 3 in this ordination. This group contains sites that are dominated by low shrubland or herbland vegetation on tablelands. The Beverley East Zone 2 SEB study sites, marked “SEB01” and “SEB02” in the ordination plot, fit in with sites from similar habitats surrounding the present Beverley Mine Lease. SEB01, which contains almost no tall shrubs, fits within the cluster of the majority of tableland sites. However, vegetation of site SEB02, which is the low shrubland site along a minor watercourse, is somewhat closer to the Group 2 sites, which are mostly tall shrubland sites along minor watercourses, than vegetation of site SEB01. SEB02 could possibly be included with Group 2 sites, but it has here been included in Group 3 because it is closer in the ordination to a Group 3 site (BE22) than to any of the Group 2 sites and because it contains far fewer tall shrubs than the majority of Group 2 sites.
Badman Environmental 1 Beverley East Zone 2
A comparison of species richness shows that the Beverley East Zone 2 temporary survey site SEB01 has very similar species richness to that of all other Group 3 (tableland) sites (14 compared to a mean value of 13.1 for all sites in this group). The temporary site SEB02 has a higher species richness (20) which is closer to the mean for all Group 2 sites (23.2) than it is to the Group 1 mean, so this part of the SEB area could be seen as either a species poor Group 2 site or a species rich Group 3 site. The species richness of both 2007 SEB sites is well within the range recorded for both groups, which is 9-40 for the minor watercourse Group 2 sites and 9-20 for tableland Group 3 sites. Vegetation Group 2 contains all but one of the Beverley sites situated along minor watercourses, plus two of the plains sites (Badman 2006). These plains sites are atypical in that they both contain significant numbers of low shrubs even though they are not associated with watercourses. These minor watercourses begin on the plain, rather than in the Flinders Ranges. The single watercourse site from the Southern EL 3251 survey that does not fit into Group 2 is atypical in that it does not contain any shrubs. There are many species that are common to both of the vegetation groups identified for the Beverley East Zone 2 area (Table 1), but the tableland areas have a much lower species richness than the minor watercourse area. Data from the 2007 survey of the Four Mile area have yet to be fully analysed, but are thought unlikely to be dissimilar to the 2006 findings.
Introduced Species No introduced species were recorded in the Beverley East Zone 2 survey area in April 2007. Past work has found that the majority of introduced species occur in Group 1 vegetation, which occurs along the Four Mile Creek and its tributaries. These have been introduced into the area by stream flows from the Flinders Ranges (Badman 2006). These species are far less common in Group 2 and Group 3 vegetation (Badman 2006). The recorded occurrence of introduced species in the Beverley area is much lower than in surrounding areas (Badman 1995, 2006). This may be partly due to the very dry seasons experienced in this area since 2001. During the 2006 Southern EL 3251 survey and the 2007 Four Mile survey, seven introduced species were recorded at Group 1 (major watercourse) sites, three species at Group 2 (minor watercourse) sites and one species at Group 3 (tableland sites). The only introduced species so far recorded at Beverley tableland sites is Sisymbrium erysimoides (Hedge Mustard), which was recorded once at a single site. This species is listed as an “aggressive weed” by DWLBC (2005), but although this is the case in its preferred habitat, which at Beverley has been found to be the Four Mile Creek and its tributaries (Badman 2006) it is not the case on the tablelands.
Badman Environmental 2 Beverley East Zone 2
Table 1: Species recorded in the Beverley East Zone 2 survey area Association 1: Gibber tableland with Astrebla pectinata grassland and chenopod forbs (Site SEB01) Association 2: Minor watercourses with chenopod low shrubland (Site SEB02) O: dominant/co-dominant overstorey species U: dominant/co-dominant understorey species : species present in surveyed one hectare quadrats †: other species recorded in the vegetation association but outside the surveyed quadrat Species Common Name Assn. Assn. 1 2 Abutilon halophilum Plains Lantern-bush Acacia victoriae Elegant Wattle Astrebla pectinata Barley Mitchell-grass O U Atriplex lindleyi Baldoo U Boerhavia dominii Tar-vine Calotis hispidula Hairy Burr-daisy Einadia nutans Climbing Saltbush Eragrostis setifolia Bristly Love-grass † Eremophila freelingii Rock Emubush Gnephosis arachnoidea Spidery Button-flower † Hakea leucoptera ssp. leucoptera Silver Needlewood † Lepidium phlebopetalum Veined Peppercress Maireana aphylla Cotton-bush Malacocera albolanata Woolly Soft-horns Malvastrum americanum var. americanum Malvastrum Neobassia proceriflora Desert Glasswort Pimelea simplex ssp. simplex Desert Riceflower Plantago drummondii Dark Plantain Rhagodia spinescens Spiny Saltbush O Rhodanthe floribunda White Everlasting Salsola kali Buckbush Santalum lanceolatum Plumbush Sclerolaena brachyptera Short-wing Bindyi U † Sclerolaena divaricata Tangled Bindyi U Sclerolaena longicuspis Long-spine Bindyi Sclerolaena ventricosa Salt Bindyi U Senna artemisioides ssp. coriacea Broad-leaf Desert Senna Senna artemisioides ssp. petiolaris † Senna phyllodinea Teucrium racemosum Grey Germander † Tripogon loliiformis Five-minute Grass †
Badman Environmental 3 Beverley East Zone 2
Figure 1: Aerial photograph showing location of Beverley East Zone 2 Extension
Badman Environmental 4 Beverley East Zone 2
Threatened species and communities No species were recorded in the Beverley East Zone 2 area, or at any similar sites during the current or recent baseline vegetation surveys (Badman 2006, in prep.), that are listed under the EPBC Act. No species were recorded in the Beverley East Zone 2 area that is listed as threatened under the National Parks and Wildlife Act 1972. No species listed as threatened under this Act were recorded in similar habitat during the Beverley Southern EL 3251 survey (Badman 2006). The Beverley Southern EL 3251 survey included the area of the Beverley East Zone 2 The Beverley East Zone 2 area is not part of a threatened vegetation community as listed by Davies (1982) or Neagle (1995).
Badman Environmental 5 Beverley East Zone 2
BE10 Group 2: Minor watercourses
BE12
BE07 80
BE13
BE06
FM02 BE08 FM17 SEB02 BE24 BE22 BE21 BE11 FM20 BE19 Axis 2 BE23 FM19 BE09 FM05 BE16 BE14 BE17SEB01 FM21 FM22 FM07 FM01 BE15 FM16 BE18 BE20 BE25 FM06 FM08 FM03 FM04FM14 FM15 FM12
40 FM18 FM13 FM11 Group 3: Tableland sites
FM10 FM09 BE02
BE03 BE04
BE05 Group 1: Major creeklines
BE01 0
0 40 80 Axis 1
Figure 2: Ordination plot of data from Beverley 1 Ha quadrats collected in 2006 and 2007 Sites prefixed BE are from Badman (2006) and those prefixed FM are from Badman (in prep). Sites from the current survey are SEB0107 (Association 1) and SEB0207 (Association 2)
Badman Environmental 6 Beverley East Zone 2
Calculating the Significant Environmental Benefit Ratio Based on the information presented in the previous section, the vegetation of the Beverley East Zone 2 area is typical of other tablelands in the region. The 13.5 hectares covered by this report is a very small part of the total area of this type of country in this region. Clearance of this area will have no impact on flora of listed conservation significance at the local, regional or state level. Vegetation clearance associated with the proposed development will affect only vegetation types that are common in the general area and over broader areas of the north of South Australia. Existing impacts on native vegetation are mainly those associated with domestic grazing and grazing by kangaroos. These cannot be quantified, although Badman (2004) demonstrated that the grazing effects of kangaroos inside the Beverley Mine Lease fence was equivalent to the grazing pressure of cattle outside the fence. Badman (2002) also found that total grazing pressure remains the same when domestic stock are removed from a mine lease because kangaroos and perhaps rabbits move in to take advantage of the extra vegetation provided by the removal of domestic stock. The report “Draft Guidelines for a Native Vegetation Significant Environmental Benefit Policy for the Mineral and Petroleum Resources Industry” does not adequately address the condition of vegetation in arid areas such as the Beverley Mine site. The Guidelines place considerable emphasis on clearance of trees and the number and frequency of introduced species and are more appropriate where the native vegetation is remnant rather than intact but disturbed. No trees have been cleared in the Beverley Mine site area, other than perhaps where they may have been cleared during past pastoral fence construction, and only a few tall shrubs are present in the Beverley East Zone 2 area. Practically no introduced species are present in the general area in dry years and only a few species in good seasons. Even during wet years, the alien species present are mostly winter-growing annuals rather than perennial species and are restricted to the major watercourses that originate in the Flinders Ranges. Vegetation has been modified by domestic grazing, but this modification cannot be quantified. When calculating the SEB ratio using the guidelines provided in Table 1 of DWLBC (2005), the Beverley East Zone 2 survey area should probably be treated as having a 6:1 ratio. However, this does not take into consideration past grazing practices. These guidelines are largely based on the findings of work in southern parts of the state and place too much emphasis on the incidence of, and domination by, alien species. Arid zone areas can be heavily disturbed without the introduction of sufficient weed species to form a dominant part of the vegetation (Badman 1995). The Beverley East Zone 2 area probably has been cleared of 10-50% of its original vegetation, including most of the original understorey, by cattle grazing, which, under the DWLBC guidelines, would give it a 4:1 SEB ratio except that the vegetation is not dominated by weeds.
Badman Environmental 7 Beverley East Zone 2
References Badman, F.J. 1995. Changes in the Incidence of Alien Plant Species at Olympic Dam Between 1986 and 1994. Qualifying Masters Thesis, Botany Department, University of Adelaide, Adelaide. Badman, F.J. (2002). A comparison of the effects of grazing and mining on vegetation in selected parts of northern South Australia. PhD Thesis, Department of Environmental Biology, University of Adelaide, Adelaide. Badman, F.J. (2004). Beverley Uranium Mine Vegetation Monitoring Observations, December 2003. Report prepared for Heathgate Resources Pty Ltd, Adelaide. Badman, F.J. (2006). Southern EL 3251 Flora Survey. Report prepared for Heathgate Resources Pty Ltd, Adelaide. Badman, F.J. (in prep.). Beverley Uranium Mine, Four Mile Baseline Vegetation Survey. Report being prepared for Heathgate Resources Pty Ltd, Adelaide. Davies, R.J-P. (1982). The Conservation of Major Plant Associations in South Australia. Conservation Council of South Australia, Inc. Adelaide. DWLBC 2005. Draft Guidelines for a Native Vegetation Significant Environmental Benefit Policy for the clearance of native vegetation associated with the Mineral and Petroleum Resources Industry, For Consultation. Guidelines prepared for the Native Vegetation Council by the Department of Water, Land and Biodiversity Conservation, Government of South Australia, Adelaide. Heard, L. and Channon, B. (1997). Guide to a Native Vegetation Survey (Agricultural Region) Using the Biological Survey of South Australia Methodology. Geographic Analysis and Research Unit, Information and Data Analysis Branch, Department of Housing and Urban Development, Adelaide. McCune, B. and Mefford, M.J. (1999). PC-Ord. Multivariate Analysis of Ecological Data, Version 4. MjM Software Design, Gleneden Beach, Oregon, USA. Neagle, N. (1995). An Update of the Conservation Status of the Major Plant Associations of South Australia. Native Vegetation Conservation Section, Department of Environment and Natural Resources, South Australia.
Badman Environmental 8 Beverley East Zone 2 Appendix A: Site photographs
Plate 1: Vegetation Association 1
Plate 2: Vegetation Association 2
Badman Environmental 9 MINING PROPOSAL FOR PROPOSED EXTENSION OF BEVERLEY MINE
Appendix E Supporting Reports A to F
E. Supporti ng Reports A t o F
The following Supporting Reports are provided in a separate volume: Supporting Report A Geology of the proposed ML Extension area Supporting Report B Hydrology of the proposed ML Extension area Supporting Report C Hydrogeology of the proposed ML Extension area Supporting Report D Flora of the proposed ML Extension area Supporting Report E Fauna of the proposed ML Extension area Supporting Report F Heritage of the proposed ML Extension area
Prepared for Heathgate Resources Pty Ltd, 21 December 2007