Australian Graphite Pty Ltd
KOOKABURRA GULLY MINING LEASE PROPOSAL
RESPONSE DOCUMENT
Table of Contents 1 Introduction 4 1.7 General description and location of project ...... 4 1.8 Submissions ...... 6 1.9 Responses ...... 7 2 Legislative Framework 7 3 Description of the Existing Environment 7 3.1 Local Community ...... 7 3.2 Land Use ...... 7 3.3 Proximity to Infrastructure and Housing ...... 7 3.4 Topography and Landscape ...... 7 3.5 Visual Amenity ...... 7 3.6 Noise and Vibration ...... 8 3.7 Air Quality ...... 8 3.8 Climate and Meteorology ...... 8 3.9 Hazards ...... 10 3.10 Hydrology ...... 11 3.11 Groundwater ...... 11 3.12 Flora ...... 13 3.13 Fauna ...... 13 3.14 Soils ...... 13 3.15 Heritage ...... 13 4 Description of Operations 14 4.1 General Description ...... 14 4.2 Project Alternatives ...... 14 4.3 Geology and Mineral Resources ...... 14 4.4 Exploration Activities ...... 15 4.5 Mining Operations ...... 15 4.5.7 Use of Explosives 15 4.5.8 Type of Equipment 19 4.5.9 Mine Dewatering 19 4.6 Underground Workings ...... 25 4.7 Processing Plant, TSF and WRSFs ...... 25 4.8 Wastes ...... 30 4.9 Resource Inputs ...... 30 5 Description of Potential Benefits 30 5.1 Social Benefits ...... 30 5.2 Economic Benefits ...... 31 6 Stakeholder and Community Engagement 34 6.7 Ongoing Community and Stakeholder Engagement ...... 34 7 Environmental Components 36 7.1 Methodology ...... 36 7.2 Flora – Vegetation and Weeds ...... 38 7.3 Fauna ...... 41 7.4 Groundwater ...... 42 7.5 Surface Water ...... 52 7.6 Air Quality ...... 57 7.7 Noise and Vibration ...... 81 7.8 Topsoil and Subsoil ...... 82 7.9 Traffic ...... 83 7.10 Aboriginal and European Heritage ...... 93 7.11 Visual Amenity and Landscape ...... 93 7.12 Asbestiform Minerals ...... 93 8 Mine Closure and Rehabilitation 94 8.6 Closure Strategies ...... 94 8.6.2 Mine Pit (Domain 1) 94 8.6.3 Infrastructure (Domain 2) 95 8.6.4 Tailings Storage Facility, Waste Rock Storage Facility and Low-grade Stockpile (Domain 3) 95 8.7 Environmental Risk Assessment ...... 97
Australian Graphite Pty Ltd 1 MLA RESPONSE DOCUMENT 8.8 Draft Closure Outcomes and Completion Criteria ...... 98 9 Management Systems and Capability 102 9.2 Policies and Objectives ...... 102 Appendix 1. Outcomes of Statutory Consultation on Kookaburra Gully Mining Lease Proposal 103 Appendix 2: Issues raised by the South Australian Government 146
List of Figures Figure 1-1! Site location ...... 5! Figure 1-2! General concept design and locality of the site ...... 6! Figure 4-1! Impact of groundwater drawdown on Eyre Peninsula Blue Gums ...... 22! Figure 4-2! Geological map of the Kookaburra Gully area ...... 23! Figure 4-3! Predictive model with Kh x 10 and higher (> x 10) value of recharge at end of stress period 8 ... 24! Figure 4-4! Steady state SRMS ...... 25! Figure 4-5! Conceptual mounding of groundwater below the TSF due to seepage ...... 28! Figure 5-1! Comparison of graphite grade in global graphite deposits (excluding China and Sri Lanka) ...... 34! Figure 7-1! Location of fence and buffer zone around Eyre Peninsula Blue Gum (Eucalyptus petiolaris) Woodland ...... 40! Figure 7-2! Figure A5 from DEWNR Technical Report 2014/10: Interpolated potentiometric (water level) surface for the basement fractured rock aquifers ...... 44! Figure 7-3! West-east cross section through Borthwick observation wells, MC 4372 ...... 50! Figure 7-4! Potential effect on pools in Pillaworta Creek due to groundwater drawdown ...... 51! Figure 7-5! Cumulative fall in pool water level over 90 days ...... 52! Figure 7-6! Metals analysis of insoluble elements in surface soil material (down to 0.8m depth) at Kookaburra Gully 57! Figure 7-7! Crustal abundance and average metal content in soil and potential mine dust ...... 59! Figure 7-8! Estimated quantity of heavy metal contributions from both mining and existing (baseline) soil contributions at Receptor 1...... 60! Figure 7-9! 1 km and 4 km buffer zones around Kookaburra Gully Mineral Claims ...... 62! Figure 7-10! Incremental and cumulative 24 hour PM10 concentrations (2013) at Receptor 1...... 68!
Figure 7-11! Predicted incremental impacts for 24-hour maximum average PM10 concentrations ...... 70!
Figure 7-12! Predicted cumulative impacts for annual average PM10 concentrations ...... 71! Figure 7-13! Road classifications in DC of Tumby Bay ...... 90! Figure 7-14! Road design guidelines for a Category 2A road in the DC of Tumby Bay ...... 90!
List of Tables Table 3-1! Salinities of dam water and groundwater on the Harris property ...... 12! Table 4-1! Legislation applicable to explosives use in SA ...... 16! Table 4-2! Magazine Separation Distance Estimates ...... 18! Table 4-3! Composition of typical detonators used in SA ...... 18! Table 5-1! Estimated farm income over a 5-year rotation period...... 32! Table 5-2! Estimated mine income over the life-of-mine at kookaburra Gully ...... 32! Table 7-1! Revised MLP Table 7.11 – SEB calculation ...... 41! Table 7-2! Existing heavy metal dust composition based on XRF analysis of surface soil samples from a depth of 0-0.8m ...... 58!
Australian Graphite Pty Ltd 2 MLA RESPONSE DOCUMENT Table 7-3! Total mine-generated analytes for the modelled scenario at Receptor 1 ...... 59! Table 7-4! Predicted impact for maximum 24 hour average PM10 (µg/m3) (by 100th percentile) ...... 67! 3 Table 7-5! Predicted impact for annual average concentrations PM10 (µg/m ) ...... 68! Table 7-6! Operational emission assumptions ...... 73! Table 7-7! Maximum measured air quality baseline concentrations 01 Jan 2013 to 31 Dec 2013 ...... 78! Table 7-8! NPI emission factors for stationary engines ...... 79! 3 Table 7-9! Predicted impact for 24-hour and annual average concentrations NO2 (µg/m ) (diesel generator only) 79! Table 7-10! Predicted impact for 24-hour and annual average concentrations CO (mg/m3) (diesel generator only) 80! 3 Table 7-11! Predicted impact for 24-hour and annual average concentrations PM10 (µg/m ) (diesel generator only) 80! Table 7-12! EPBC Protected Matters Search – transport corridor ...... 86! Table 8-1! Risk Assessment – closure and rehabilitation (revised MLP Table 8.9) ...... 99! Table 8-2! Draft outcomes and completion criteria (revised MLP Table 8.10) ...... 99!
Australian Graphite Pty Ltd 3 MLA RESPONSE DOCUMENT 1 Introduction
In accordance with Regulation 30(04) of the Mining Regulations 2011, I, Dr (Allan) John Parker of Australian Graphite Pty Ltd (AGL), have reviewed this response document to submissions made on AGL’s mining lease proposal dated 7 September 2015 and declare that all information contained in this document is, to the best of my knowledge, accurate.
Signature
Date 2 February 2016
Information in this report that relates to exploration activity and results, Mineral Resources and Exploration Targets was compiled by Dr A John Parker who is a Member of the Australasian Institute of Geoscientists. Dr Parker is Managing Director of Lincoln Minerals Limited and has sufficient experience relevant to the styles of mineralisation and to the activities which are being reported to qualify as a Competent Person as defined by the JORC Code, 2012. Dr Parker consents to the release of the information compiled in this report in the form and context in which it appears Information extracted from previously published reports identified in this report is available to view on the Company’s website www.lincolnminerals.com.au. The company confirms that it is not aware of any new information or data that materially affects the information included in the original market announcements and, in the case of estimates of Mineral Resources and Exploration Targets that all material assumptions and technical parameters underpinning the estimates in the relevant market announcements continue to apply and have not materially changed. The company confirms that the form and context in which the Competent Person’s findings are presented have not been materially modified from the original market announcements. This report contains forward looking statements that involve estimates based on specific assumptions and statements by third parties. Actual events and results may differ materially from those described in these statements as a result of a variety of risks, uncertainties and other factors. Forward looking statements are based on LML’s beliefs, opinions and estimates as of the date the forward looking statements are made and no obligation is assumed to update forward looking statements if these beliefs, opinions and estimates should change or to reflect other future developments.
1.7 General description and location of project Australian Graphite Pty Ltd (AGL), a fully-owned subsidiary of Lincoln Minerals Limited (LML), is proposing the development of the Kookaburra Gully Graphite Project, located approximately 35 km north of Port Lincoln and 20 km west south west of Tumby Bay on the Eyre Peninsula in South Australia (Figure 1-1). AGL owns the graphite rights on the project area. The Kookaburra Gully Graphite Deposit (the deposit) is located on Mineral Claims MC 4372 and MC 4373. Southern Eyre Peninsula is host to numerous historical graphite workings, occurrences and deposits, including the Uley Graphite Mine which is located 17 km south of Port Lincoln. The graphite mineralisation is found in stratigraphically persistent graphitic schists of the Palaeoproterozoic Hutchison Group. Kookaburra Gully is located on Pillaworta Road which can be accessed via Bratten Way, Bailla Hill Road or White Flat Road, all of which can be accessed from the Lincoln Highway. AGL has applied for a Mineral Lease (ML) over the area for an open pit mine and primary infrastructure. Facilities within the ML area will include an open pit, crushing facilities, a mineral processing plant, waste rock storage facilities, a tailings storage facility and other minor infrastructure (Figure 1-2). The mine life based on the current resource is estimated to be approximately eight years based on full production and processing from day one throughout the life-of-mine. The ML application is for the extraction and subsequent processing of 250,000 tonnes of graphite ore each year, with the pit reaching 100 m in depth over the life of the project. Approximately 30,000 tonnes to 40,000 tonnes of high grade graphite concentrate would be produced per annum at grades of 93% to 98% total graphitic carbon (TGC). Subject to approvals and funding, the site works are targeted to commence in late 2016 or early 2017. The project operator is Australian Graphite Pty Ltd (AGL), a fully-owned subsidiary of Lincoln Minerals Limited (LML) of Level 7, 350 Collins Street, MELBOURNE, Victoria 3000 with a technical office at 28 Greenhill Road, WAYVILLE, SA 5034.
Australian Graphite Pty Ltd 4 MLA RESPONSE DOCUMENT
Figure 1-1 Site location
Australian Graphite Pty Ltd 5 MLA RESPONSE DOCUMENT
Figure 1-2 General concept design and locality of the site
1.8 Submissions Twenty five (25) public submissions have been received by AGL from the Department of State Development. These submissions contain over 1,200 issues or comments that require points of clarification and/or additional information to enable a comprehensive assessment of the proposal prior to final consideration by the South Australian Government. However, about 20 of those submissions were very similar and the issues raised were either identical or at least related to the same issue. A large 158-page submission was received from the Tumby Bay Residents and Ratepayers Association, Port Lincoln Residents and Ratepayers Association, Save Our Sustainability Group (SOS), Eyre Peninsula Community Mine to Port Consultative Committee and selected members of the Country Fire Service (CFS). The latter was only represented by small select cross section of members of the CFS and not the CFS as an organisation. Therefore, this submission should not be taken as the view of the CFS as a whole. On the basis that there is a lot of repetition and duplication of issues, even though every issue has been separately numbered, the public submissions have been summarised into a more concise list of approximately 320 issues (Appendix 1) and cross referenced throughout this response document. In addition, AGL received a table of 56 issues raised by a number of SA Government departments that also require points of clarification and/or additional information to enable a comprehensive assessment of the proposal, prior to final consideration by the South Australian Government (Appendix 2).
Australian Graphite Pty Ltd 6 MLA RESPONSE DOCUMENT 1.9 Responses The format of the responses is:
Brief outline of the issue as raised by the various submissions shown in italics within a text box like such.
This is followed by AGL’s response to that issue. The responses have been grouped to correspond to the main chapters or sections of the original Mining Lease Proposal (MLP). In some cases, if the response is only a relatively short statement, that response has been included in the tables in the Appendices.
2 Legislative Framework
Mining in South Australia is governed by the Mining Act 1971 and Regulations, the Offshore Minerals Act 2000 and the South Australian Opal Mining Act 1995. In addition to the primary approval and regulation of mining projects via the Mining Act 1971, there are a number of other South Australian and Commonwealth Acts and regulatory processes that may affect the project.
3 Description of the Existing Environment
3.1 Local Community
Issue #40 – Social License
Demographic data that is four years out of date.
Demographic data were based on Census data. The Census is only conducted every 5 years, 2011 being the most recent – the next scheduled Census is in 2016. Census data is considered the most accurate representation of the demographics since 98.3% of the population participated in the 2011 Census.
3.2 Land Use
Issue #502 – Land Use
Potential existence of Native Title on Road Reserve that is leased to a neighbour
Based on legal advice received by AGL, the road reserve, created as a public or Government road in the 1800's and shown on the Hundred map (Koppio) as a public road, has extinguished native title. Native title, once extinguished, may not revive. The creation of public road rights and entitlements is inconsistent with the continuing use, exercise and enjoyment of native title rights which are inconsistent and extinguished.
3.3 Proximity to Infrastructure and Housing No further information required.
3.4 Topography and Landscape No further information required.
3.5 Visual Amenity Refer to Response 7.11 and SA Govt Issue #52 (Appendix 2).
Australian Graphite Pty Ltd 7 MLA RESPONSE DOCUMENT 3.6 Noise and Vibration Refer to Response 7.7.
3.7 Air Quality
Issue #666 – Dust
Data, especially dust, should be independently monitored
Baseline ambient air quality (dust) monitoring was undertaken by independent consultants Golder Associates Pty Ltd in the fourth quarter of 2012 and in the first 3 quarters of 2013: • February 2013 - Baseline ambient air quality monitoring report for fourth quarter 2012 • June 2013 - Baseline ambient air quality monitoring report for January-March 2013 • October 2013 - Baseline ambient air quality monitoring report for April-June 2013 • December 2013 - Baseline ambient air quality monitoring report for July-September 2013
3.8 Climate and Meteorology
Issue #83 – Eyre Iron Data
Some data has been cut and pasted from information generated by Eyre Iron Pty Ltd for the purpose of mining activities associated with the iron ore Project Fusion….and AGL did not carry out sufficient research to ensure the studies were verifiable for the site of Kookaburra Gully. The data so imported was obtained by another company and not under the care and control of AGL. AGL/LML have no proof and no independent data (using Eyre Iron data which we know has not been independently collected, in sealed, tamper proof containers)
Eyre Iron data were compiled by reputable and independent 3rd party consulting services: • Donata Environmental Services (July 2012) – flora-fauna • Sonus Pty Ltd (Oct 2012) – noise • RPS Aquaterra (Sept 2012, Dec 2012 & May 2013) – groundwater • Golder Associates Pty Ltd (Feb 2013, June 2013, Oct 2013 & Dec 2013) – air quality monitoring The reports were reviewed by AGL’s independent consultants so AGL has no reason to dispute their veracity. As indicated in Issue #56 (Response 7.6) and in Issue #769 below, the data from the Eyre Iron Fusion Project is considered suitable for use on the Kookaburra Gully Project. Monitoring sites were selected to comply with the requirements of Australian Standard AS3580.1.1-2007, “Methods for Sampling and Analysis of Ambient Air – Guide to Siting of Air Monitoring Equipment”. The PM10 monitoring method is based on the requirements of Australian Standard AS 3580.9.8-2008, “Methods for Sampling and Analysis of Ambient Air. Determination of Suspended Particulate Matter – PM10 Continuous Direct Mass Method Using a Tapered Element Oscillating Microbalance Analyser”. AGL has undertaken an extensive suite of independent flora, fauna, hydrogeological, soil testing, metallurgical, analytical and other surveys to support its ML Proposal. These were undertaken by independent expert 3rd party service providers and have been supported by Eyre Iron data.
Australian Graphite Pty Ltd 8 MLA RESPONSE DOCUMENT Issue #769 – Eyre Iron Meteorological Data
Winds in the Koppio hills are different than BoM data of Pt. Lincoln and Cummins airports
As outlined in the Air Quality Report (MLP Appendix C), existing Bureau of Meteorology (BOM) weather monitoring stations were adopted and considered by AGL and its independent consultants to be representative of climate and meteorology in the project region. Baseline data used in the assessment was from the proposed Eyre Iron Fusion Project which extends immediately west and northwest of Pillaworta Road (MC4372 and MC4373) for 6 kilometres to the western end of the Koppio BIF (MLP Figure 3.19). Activities occurring at the time of baseline monitoring included farming activities, public road use and exploration work, which was mainly drilling. The exploration activities for the Fusion Project were similar to those undertaken for the Kookaburra Gully project. Therefore background dust emission would be similar. In addition, as indicated below, the land uses for both Kookaburra Gully and in the area of the baseline monitoring for the Fusion Project are similar. The topography in the vicinity of the Eyre Iron Fusion baseline monitoring site and the Kookaburra Gully project site are similar. The tapered element oscillating microbalance (TEOM) monitoring site for the Fusion Project is located within an area located between two ridges trending south east/northwest ranging between 170m and 220m Australian Height Datum (AHD) but these form part of a regional southwest-northeast trending ridge pattern. The site is near a creek line and a more prominent north trending creek is located within close proximity. Apart from vegetation on the ridge tops the adjacent land is cleared for cropping and grazing. The Kookaburra Gully site is located 6km northeast of the TEOM monitoring site and, while it is characterised by three minor ridge lines trending generally in an east/west direction with an elevation between 200m to 220m AHD, the overall topography represents a valley between two long ridges trending southwest-northeast. Like the Fusion site, apart from the vegetated top of the ridges the adjacent land has been cleared for cropping and grazing. Pillaworta Creek is located in the valley immediately west of the site and the land surface rises to a southwest-northeast trending ridge up to 230m AHD. Both sites also have a road located approximately 200m nearby, which is a source of dust generation. Taking into consideration the similarity of topographical features, vegetation clearing history, land use and surrounding air shed of the Kookaburra Gully project site and the TEOM monitoring site it is considered reasonable to use the data as representative of baseline conditions.
Issue #633 – Rainfall
I live at the headwaters of Kapperna creek which flows into the Pillaworta Creek that flows past the proposed mine site. In 2013 and 2014 we had rainfall of 12 inches (305mm) over a six-week period in both years. The proposed mine site will be a lot wetter than the modelling. AGL/LML stated that the 13th June 2014 was a one in one hundred year event….local records show that this statement is wrong
The figure of 305mm over 6 weeks in 2013 and 2014 is not supported by BOM data nor records from the adjoining Rocky Glenn property. Maximum rainfall figures for the two months (~8 weeks) June + July at the Rocky Glenn property from 1929 to 2011 are 219mm in 1946, 268mm in 1956 and 211mm in 1996. Maximum rainfall for June + July at North Shields is 253mm. BOM data for the Koppio station for June + July 2013 was 243mm and for June + July 2014 was 261mm. BOM data for Yallunda Flat station for June + July 2013 was 265mm and for June + July 2014 was 262mm. BOM data for Yallunda Flat and Koppio on 13 June 2014 were, respectively, 75.0mm and 65.0mm. These were the highest daily maxima for June for ALL years (Yallunda Flat: 1911 to present; Koppio: 1884-present). However, Yallunda Flat did record 113mm on one day, 20 February 1938. That same day Koppio recorded 89mm. Local daily maximum rainfall records maintained by the owner of the adjoining Rocky Glenn property (from 1929 to 2011) show that previous maxima were 70.1mm in June 1994 and 72.4mm in March 1938. Median daily maximum rainfall for Rocky Glenn (from 1929 to 2011) range from 5.1mm in February to 15.5mm in July.
Australian Graphite Pty Ltd 9 MLA RESPONSE DOCUMENT The engineering design of the stormwater control system for the proposed Kookaburra Gully mine will be undertaken to Australian standards. Section 4.9.9 outlines the fact that the drainage and surface water flow system will be designed to accommodate a 100-year Average Recurrence Interval (ARI) event, i.e. the maximum 100-year rainfall depth that might occur over 24 hrs.
3.9 Hazards
Issue #264 – Earthquakes
Earthquakes may be triggered by mining and drilling: Impact of mining induced earthquakes in the Kookaburra Gully area….this may impact the soil, air and water and have detrimental affects, causing a threat to agriculture and fishing, as well as on residents and other businesses of Eyre Peninsula
Section 3.9.1 of the MLP provided information of historical seismic events in the region surrounding the Kookaburra Gully project. No earthquakes (epicentres) have been recorded in the immediate vicinity of Kookaburra Gully. Most significant earthquakes on southern Eyre Peninsula occur within an ENE-SWS trending belt about 10 km north of Cummins. The design of structures in Australia is governed by Australian Standard, AS 1170.4–2007 which provides acceleration coefficients for a 1 in 500 year probability of exceedance. For the Kookaburra Gully area the acceleration coefficient is 0.05 g. For comparison, the published acceleration coefficients for Adelaide and Melbourne are 0.10 g and 0.08 g, respectively, and for Meckering in Western Australia, which has the highest acceleration coefficient in Australia, it is 0.22 g. The building structures will be designed in accordance with the Australian Standard. A ground acceleration of 0.05g has been used in the design of the tailings storage facility, and the slope stability assessment has indicated acceptable factor of safety associated with earthquake loading. It is considered that an appropriate consideration has been given to the potential impact of seismic events on project components. The development of large open pits like Bingham Canyon Mine in the USA can result in mining induced seismicity due to the release of in-situ stresses. Similarly micro-seismic events (magnitude <=2) have been noted as a result of both open pit and underground blasting. The Kookaburra Gully project is proposed to be mined to a depth of 90-110 m over a total area of 18 hectares which in terms of open pit mines would not be classified as large. It is not expected that at the proposed mining depth of the Kookaburra Gully mine that seismic events would be generated. The upper 30 m is expected to be free digging with blasting generally required below this. Blasting will be designed to minimise ground vibrations and external impacts. Given the nature of the rock materials, mica and graphitic schists, biotite gneiss and some dolomite marble the rock breaking forces associated with blasting are not expected to induce seismic events. The size of blasts for this small scale open pit would be similar to existing quarry's in the area, which are quarrying very hard granitic gneiss used for road making (eg. Cave Quarries blasts 100,000 tonnes in a single blast sequence).
Issue #267 – Earthquakes
The 4 main causes of man made induced seismicity are the following: - Injection induced seismicity for oil and gas. - Reservoir induced seismicity because of the filling of water storage reservoirs (holding ponds for dewatering and waste water come into this category and are required for this proposed project). - Mining and quarrying induced seismicity from both open pit and underground mining. - Seismicity induced by nuclear explosions – particularly underground.
The submission has correctly indicated that man-made events could generate seismic events. As indicated above these can be related to the release of stresses in the rock mass due to unloading by development of the open pit and through blasting, either underground or in an open pit. They would be classified as very small or micro seismic events.
Australian Graphite Pty Ltd 10 MLA RESPONSE DOCUMENT Given the size and depth of the proposed open pit and nature of crystalline rock formations at Kookaburra Gully it is very unlikely that mining induced seismic events will occur. If they did occur, they would not be noticed by residents in the area. Reservoir induced seismic events are related to the height of dams (greater than 100m in height). In addition large water storage reservoirs have been known to generate seismic events. The proposed tailings storage facility and process water ponds for the Kookaburra Gully project are not of a size that would result in seismic events. Therefore it is concluded that there are no risks as it is not a viable impact event. Tailings storage facility failures can occur in tailings facilities due to seismicity induced shaking and liquefaction of tailings and overtopping or due to failure associated with up-stream construction using tailings material or building the dam raise components either partially or fully on the tailings surface. Failure could occur if the tailings facility is built on low density, uniformly graded saturated sands. The Kookaburra Gully tailings storage facility will be built using inert waste rock by the downstream construction method for all stages of construction. The foundations do not comprise low density, uniformly graded saturated sands but are hard competent crystalline bedrock. The storage for the tailings has been designed with sufficient freeboard such that overtopping is not feasible during either a 1-in-100 year flood or by wind-generated waves. The facility must be constructed and operated as per design. Therefore the risks of impacts are considered to be acceptably low. Seismic events have occurred as a result of detonation of nuclear bomb testing and by injection associated with the oil and gas industry. These events are not viable impact events for the Kookaburra Gully project.
Issue #269 – Earthquakes
Mining induced earthquakes can vary in nature and be complex, producing liquefaction and landslides. The Lower Eyre Peninsula, including the Kookaburra Gully area has hills 300 metres high.
Refer Issue #264 (Response 3.9). Liquefaction occurs due to ground shaking (primarily as a result of earthquakes). In order for liquefaction to occur either in foundations or natural slopes the material has to have specific material properties consisting of low density, uniformly graded saturated sands and silts. Furthermore, earthquakes that could cause liquefaction cannot be triggered by minor seismic events such as mining-related events. Issues relating to liquefaction of tailings has been included above in Issue #267. The topography of the Koppio Hills is quite mature with rounded hills that have slopes generally less than 12 degrees. The rocks that comprise the hills are hard competent crystalline metamorphic rocks; they are not sand and silt that are susceptible to liquefaction. The risk of liquefaction is considered to be insignificant and likelihood to be very rare.
3.10 Hydrology No further baseline information required at this stage.
3.11 Groundwater
SA Govt Issue #1 – Groundwater – Baseline Quality Assessment
The groundwater quality data presented in the MP is localised to one region of the proposed operations (the southern end of the open pit) and is isolated to a single pump test. There is uncertainty in the description of groundwater quality. A baseline groundwater quality assessment should be undertaken in accordance with the ANZECC prior to any operations occurring (should a lease be granted). The quality of groundwater obtained from the baseline assessment should be used to determine the potential uses of the water.
Section 3.11 of the MLP discusses groundwater data available from a number of sources both within the proposed mine site as well as in other areas around the proposed Kookaburra Gully mine. In addition to this
Australian Graphite Pty Ltd 11 MLA RESPONSE DOCUMENT there are published geological maps to work with, eg. the Lincoln SI5311 geological map (SA Geological Survey). The available data and information provide a sound basis for understanding the hydrogeology of the area not only beneath MC 4373 but also beneath MC 4372. Groundwater modelling by an internationally recognised hydrogeologist has been used to inform the hydrogeological understanding of the area. As indicated in Figure 3.26 of the MLP, the groundwater potentiometric surface at Kookaburra Gully slopes to the west and it is not eliminated at the property boundary. Since writing the MLP, hydrogeological studies have been undertaken on MC 4372, The property owner, C Borthwick, has undertaken peizometer installation on several observation wells drilled on MC 4372 (Unit numbers 6029-1461, 1463 to 1466 and 7229-1) with each of the drillholes found to be dry. This further substantiates the potentiometric surface in the project area. See discussion of ephemeral springs in Response 7.9 below, Issue #878. The assessment of these observation wells was undertaken by P. Howe of CDM Smith Australia Pty Ltd in early August 2015. Additional groundwater surveys will be undertaken prior to the start of mining and these will address the issues raised here in regard to establishing baseline groundwater quality in accordance with ANZECC guidelines. This will include establishing groundwater monitoring wells around the pit and adjacent to Pillaworta Creek.
Issue #320 – Groundwater
As previous owner of Section 196 in Hd of Koppio we have experienced vast difference in quality of water used to supply livestock….2 water supply points within 100 metres of one another where one was saltier than sea water and the other was of quite good quality.
Although the locations of these two water supply points is unknown, the situation described here is likely the result of one water supply point (the good quality one) being replenished by regular surface water inundation, whilst the other (the poor quality one) being a terminal drainage for surface water and groundwater where evaporative concentration of salts has occurred. AGL’s drilling in MC 4373 has shown considerable variability in groundwater quantity and quality. Several drillholes did not intersect any groundwater at all, some recorded dampness or moisture while other drillholes recorded small flows. Salinities (MLP Table 3.11) varied from approximately 4,000 µS/cm to over 13,000 µS/cm. Water points sampled for electrical conductivity (EC) demonstrate that surface water catchments (dams) and groundwater access points (windmills and soaks) are vastly different in EC values (Table 3-1). To highlight the variability in Section 196, the table below highlights the 2015 results of water testing displaying green cells as surface water and blue cells representing groundwater. The results show almost a ten-fold increase in EC when comparing groundwater to surface water EC's (NB sea water EC is ~50,000). Table 3-1 Salinities of dam water and groundwater on the Harris property
Locator EC_2015 (µS/cm) Harris_Main dam 720 Harris Dam Nth 1140 Harris Dam Mid dry Harris_windmill 6810 Harris soak 10030 Harris PVC 11230
Issue #785 – Groundwater
A complex understanding of the hydrogeology of the immediate area is unknown and concern is raised into this determination
Australian Graphite Pty Ltd 12 MLA RESPONSE DOCUMENT The essential elements of the groundwater system in the vicinity of the proposed Kookaburra Gully mine are understood to the level necessary to undertake an adequate analysis of the way the groundwater system will interact with the mining operation, the mine pit in particular. A conceptual hydrogeological model has been developed based on the findings of various hydrogeological studies undertaken in the project area and a numerical groundwater model has been developed to assist in quantifying potential impacts. Details are presented in the MLP Section 4.5.9 and Appendix D.
Issue #792 – Environmental Issues – Groundwater
Eyre Iron identified significant water sources from previous drilling within close proximity to the Kookaburra Gully site that has been ignored by the company
The work undertaken by Eyre Iron was reviewed and incorporated in the studies completed for the proposed Kookaburra Gully mine (see Sections 3.11 and 4.5.9 and report two of Appendix D of the MLP) as appropriate. Detailed investigations conducted for the proposed mine in relation to existing groundwater users are presented as report one of Appendix D of the MLP, and the area covered is much more extensive than the area that will be affected by drawdown induced by the mine pit (see Figure 4.50 of the MLP).
3.12 Flora Refer to Addendum 3 for additional baseline information on MC 4372, Response 7.9 Issue #5 for Pillaworta Road and Addendum 4 for the proposed pipeline route.
3.13 Fauna Refer to Appendix E of the MLP and Addendums 3 and 4.
3.14 Soils Additional baseline soil information will be collected as part of the PEPR process. See also discussions in various responses to tailings storage facility design (Response 4.7) and dust (Response 7.6).
3.15 Heritage
Issue #503 – Cultural Heritage
What consultation did the company have with the local Barngarla community including contact and information from the Barngarla women. Barngarla people advised that reinstatement of the ephemeral creek was the preferred outcome.
A Cultural Heritage Desktop Assessment and Field Survey was conducted by EBS Heritage for AGL (MLP Appendix F). EBS Heritage conducted the cultural heritage site survey on the 10–12 December 2013 with participants from the Barngarla community and their chosen Anthropologist. The cultural heritage team comprised 3 women and 3 men nominated by the Barngarla community. They conducted a surface visual inspection of the proposed project area and did not encounter any sites of cultural or heritage significance. Barngarla representatives consulted with their own anthropologist for the purposes of this project. This involved research and consultation with the Barngarla community in the field and in more detail after the survey. As noted, Barngarla people advised that reinstatement of the ephemeral creek that goes through the site of the proposed TSF was the preferred outcome. At the request of the Barngarla Community, the heritage survey report has been kept confidential.
Australian Graphite Pty Ltd 13 MLA RESPONSE DOCUMENT 4 Description of Operations
4.1 General Description The general description of the project remains unchanged.
4.2 Project Alternatives
Issue #86 – Long Term Processing Options
Local suggestions that this development may also enable some symbiotic arrangement to exist between Australian Graphite Limited and Valance (Uley) Graphite ….part of the relationship may be the establishment of haul routes between the two prospects.
There is no relationship between AGL and Valance Industries Limited and there have been no formal discussions between the two companies relating to such. An independent Option Study undertaken for AGL by a 3rd party consultant (MLP Section 4.2.4) looked at all opportunities for pilot plant processing including building an on-site pilot plant or pilot plant processing at either Uley Graphite Mine, interstate laboratories or overseas processing plants and laboratories. This study did not consider full production plant processing at an alternate site. Pilot plant processing would only involve small quantities of ore (up to 2,000 tonnes).
4.3 Geology and Mineral Resources
Issue #720 – Uranium
AGL has identified the presence of uranium in the proposed site yet have made no mention of monitoring or exclusion zones in relation to rayon gases being released in to the atmosphere or environment (either as gasses or leached into water course in the Tod River catchment through drilling)
As shown in MLP Section 4 the concentration of base metals and uranium within the ore and host rocks are low so the resultant concentrations of these elements in operational depositional dust will also be low. The levels of radioactive materials (uranium and thorium) within the ore and host rocks are below the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) exemption limits of 1 Bq/g2, and are therefore not classified as radioactive materials.
Issue #721 – Uranium
Mamota had a public meeting in Cummins about extraction of uranium in our district and talked about exclusion zones of up to 5km of extraction areas.
As shown in Section 4 the concentration of base metals and uranium within the ore and host rocks are low and the resultant concentrations of these elements in operational depositional dust will also be low. The levels of radioactive materials (uranium and thorium) within the ore and host rocks are below the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) exemption limits of 1 Bq/g2, and are therefore not classified as radioactive materials. On this basis, there is no need for any exclusion zones. Established principles of geological science allows interpretation of geological conditions (eg. mineralogy, structure, resources) observed in drillholes and outcrop on MC 4373 to be extrapolated north into MC 4372. This is supported by very detailed historical geological mapping and trenching by Pancontinental Mining geologists in the 1980s (DSD Open File Envelope 5233).
Australian Graphite Pty Ltd 14 MLA RESPONSE DOCUMENT 4.4 Exploration Activities
Issues #84 & #85 – Long Term Exploration Activities
Kookaburra Gully is potentially not a stand alone development, but a component of the development of the prospect inclusive of Kookaburra Gully extension (for which the Company has received a $3M grant to drill as part of the PACE program) and the original Koppio Graphite Mine area. Is the application an overarching application for the activities not only associated with Kookaburra Gully Mine site but for the holistic view encompassing the original Koppio Mine and Kookaburra Gully extended?
Kookaburra Gully is a stand-alone development and mining lease proposal. AGL has no current plans to develop the historic Koppio Graphite Mine or Kookaburra Gully Extended. The latter, Kookaburra Gully Extended, is purely a long-term Exploration Target which has never been drilled. It appears to be a very good Exploration Target based on its electromagnetic (EM) anomaly but the EM anomaly could also be due to shallow but salty groundwater. It is emphasized that Exploration Target tonnage and grade estimates are entirely conceptual in nature since there has been insufficient or no drilling in the immediate areas of these targets and it is uncertain if further exploration will result in the estimation of a Mineral Resource. While AGL has an Inferred Mineral Resource at Koppio, an Inferred Mineral Resource is the lowest order JORC category and more drilling would be required to convert that to an Indicated Mineral Resource suitable for further mining and scoping studies and maybe ultimate development. AGL has plans to undertake reconnaissance drilling at Kookaburra Gully Extended in 2016 but has not received a $3M PACE drilling grant. The offer to AGL amounts only to a very small fraction of that amount which has been spread between multiple companies who were successful in the grants process run by DSD. The grant is only for Kookaburra Gully Extended and is much less than $100,000. Like the Koppio Graphite Mine deposit, should significant graphite mineralisation be discovered at Kookaburra Gully Extended it and/or Koppio would have to be subjected to detailed resource drilling, metallurgical testing and a full Scoping or Preliminary Feasibility Study before any decision was made to develop or otherwise one, the other or both. Any proposed development(s) would have to be subjected to detailed flora, fauna, groundwater and other environmental surveys, mine planning, stakeholder consultation and preparation of a separate mining lease application and proposal. Any such proposal and development would be at least 5 years away if the project was proven viable and met all the requirements for consideration of a mining project.
4.5 Mining Operations
4.5.7 Use of Explosives
Issue #27 – Explosives Magazine
Community members have been informed there would be limited blasting. However, the lease application document states there will be a huge amount of explosives and dangerous toxic chemicals stored on site. This is a direct conflict to what the mining company had originally informed the community
Whilst it is not specifically envisaged in the upper 30-40 m of the open pit (the first 2-3 years of mining operations in clay-rich rock) that explosives will be used, AGL has sought approval for this activity should it be required. Community Information updates from 2014 distributed to landowners and other interested parties showed the location of the magazine. The magazine facility must comply with the South Australian Explosives Act (1936), the Explosives Regulations (2011) and Australian Standard AS 2187.1–1998, Explosives – Storage, transport and use, Part 1: Storage. Magazines and ammonium nitrate storage facilities will be approved and licenced by SafeWork SA which encompasses all relevant notifications to law enforcement agencies. The expected quantities of explosive to be stored on site determine the appropriate safety distances; both the inside safety distance and the outside safety distance.
Australian Graphite Pty Ltd 15 MLA RESPONSE DOCUMENT The quantity of ammonium nitrate (AN) is of a similar quantity to that which local farmers in the area possess during farming operations in the form of urea. However, by contrast to farming operations, AGL will be strictly governed by the various acts and regulations as listed in the table below (Table 4-1). Table 4-1 Legislation applicable to explosives use in SA
Applicable Legislation
Legislation Australian Standards Codes of Practice
South Australian Work Health and Safety Australian Standard 2187 Australian Explosives Code Act 2012 Storage & Use of Explosives (AEC) (6th Edition)
South Australian Work Health and Safety
Regulations 2012
SA Explosives Act 1936
SA Explosives Regulations 2011
Dangerous Goods Transport Regulations
2008
Dangerous Substances Regulations 2002
Issue #77 – Explosives Magazine
Risk assessment to this facility in the event of a bushfire
Clearly there is a very high risk if fire results in detonation of explosives. This risk can be reduced to a low to moderate risk using the following controls and strategies: • Establishing an accredited and approved Blasting Operations Procedure; • Safe Work Method Statement in relation to Operation of a Mobile Manufacturing Unit; • No smoking signage in place at Magazine/ AN store and enforced; • Ignition sources removed prior to accessing the Magazine or AN store; • Maintain good housekeeping and remove combustibles; • Saline water shall not be used for dust suppression at the AN yard; • Saline water shall not be used for firefighting; • Explosives storage to be located at a location remote from inhabited areas; • Fire break to be maintained around storage areas; • Magazine/ AN store to be protected by locked gates, security fence and surveillance; • Evacuate area if bushfire threat exists to a distance of 600m; and • Storage areas constructed to Australian Standards. In addition to bushfires, there is also an added risk of lightning strikes during thunderstorms. Additional precautions applicable during thunderstorms are: • Establishment of a Site Lightning Procedure • On the approach of a thunderstorm, all work in magazines shall cease, doors closed and locked and all personnel shall withdraw a safe distance of a minimum of 600 metres from the magazine until the storm passes. • Access to the magazine shall be closed using a locked gate or similar at least 600 metres from the magazine/ AN Store. Any areas within the mine that are within 600 metres of the Magazine/ AN Store shall be cleared of all personnel, doors closed and locked.
Australian Graphite Pty Ltd 16 MLA RESPONSE DOCUMENT • No person shall return to the Magazine until the storm has passed and the Shotfirer and the Mine Manager (or delegate) deems it is safe to do so.
Issue #78 – Explosives Magazine
Risk to employee fire fighters or to the CFS as a consequence of a bushfire in the vicinity of the magazine
CFS volunteers would be aware of the risks of firefighting and their mission to protect life, property and the environment from fire and other emergencies whilst protecting and supporting others. AGL (and Lincoln Minerals) has supported CFS activities in the past and made a significant contribution to controlling and extinguishing several bushfires near Port Lincoln and Coomunga over the past 7 years. The Company has provided water carting and fire fighters using the Company's personnel, water truck and firefighting equipment. As part of AGL operations, employees and contractors will be actively encouraged to join such organisations in providing emergency support as the need requires. In addition AGL will develop and implement an emergency response team for all mining and near-by community related incidents that we may reasonably be able to assist. Where Security Sensitive Ammonium Nitrate (SSAN) is a dangerous good, the licence holder must ensure that SSAN is packed, branded, labelled and marked in accordance with the ADG Code (including the requirements for marking, placarding, documentation, segregation and stowage, safety equipment, transport procedures and emergencies) and is carried in a vehicle that complies with the requirements of the ADG Code. The CFS and MFS attend to emergencies involving dangerous goods and are trained in reading ADG placards and understand the emergency procedures associated with them.
If ammonium nitrate is stored in a building it should be a dedicated, single storey building constructed of material that will not burn such as steel, concrete or brick. Ammonium nitrate is stored away from combustible materials by a distance of at least 8 metres or use a barrier of inert material of at least 1.5 metres width and no standing timber within 15 metres.
Issue #79 – Explosives Magazine
Assessment of the impact of a catastrophic explosion of the magazine. In such an event, what would be the blast radius? Being located in a gully would channel the blast over a huge area.
The potential impact of a catastrophic explosion and blast radius would be determined by application of the venerable facilities distances as per below (Table 4-2). The expected quantities of explosive to be stored on site would determine the appropriate safety distances; both the inside safety distance and the outside safety distance. Schedule T of the Explosives Regulations 2011 sets out in table form the minimum mandated safety distances to “protected works” in relation to the storage of Class 1 explosives (HE & IE). Regarding ammonium nitrate (AN), under Regulation 19(2) of the Explosives (Security Sensitive Substances) Regulations 2006, AN or emulsion tonnage is regarded as 50% category ZZ. Therefore, for 20 tonne (equivalent to 10 tonne) the respective distances would range up to 478m based on the following information; • an Heavy Explosive (HE, e.g. Primers) Magazine with a capacity of 5,000kgs - Explosive code 1.1D • an Initiating Explosives (IE, detonators, & surface leads) Magazine with a capacity of 1,000kg - Explosive code 1.1B- 790mg per detonator • an ANFO storage of 20,000kg - Explosive code 1.1D • an ammonium nitrate or emulsion storage of 20,000kg - equivalent to 10,000kg - Explosive code 1.1D
Australian Graphite Pty Ltd 17 MLA RESPONSE DOCUMENT Table 4-2 Magazine Separation Distance Estimates Explosive Type Explosive Volume (kg) - Q Separation Distance (D) Ammonium Nitrate 10,000 478 EMULSION 10,000 478 Primers 5,000 380 Detonators 1,000 150
Further detail would form part of the Blasting Operations Procedure management plan.
Issue #81 – Explosives Magazine
Chemical composition of the detonators. If they contain mercury fulminate, what is the environmental risk of such a large amount of mercury being released during the mining operations (dust and groundwater implications)?
Modern detonators do not contain mercury fulminate. The chemical composition of detonators as per a typical product safety data sheet is (Table 4-3): Table 4-3 Composition of typical detonators used in SA
Issue #82 – Explosives Magazine
There are other issues pertaining to the magazine, particularly in relation to the security of the contents, noting ammonium nitrate is a precursor to many Improvised Explosive Devices. Presumably South Australian Police, Australian Police and ASIO have been informed as to the location and contents of the proposed magazine and the security of its contents.
Ammonium nitrate (AN) is not the precursor, it is a component of the explosive which when combined with other components (EG hydrocarbons) forms the explosive ANFO. AN sold for fertiliser is the same substance as AN sold for use as an explosive. The explosive grade is a lower density prilled material designed to absorb fuel. A magazine and associated AN must comply with:
• The Explosives Act 1936 is the Act and Regulations covering the storing explosives in South Australia. The Regulations lay out the specifics for creating an explosive storage area and incorporates the licensing and permit requirements. • SafeWork SA is the inspecting and controlling authority under the Explosives Act and act as the inspectors under the Act, as do (can) members of the South Australian Police.
Australian Graphite Pty Ltd 18 MLA RESPONSE DOCUMENT • The Explosives (Security Sensitive Substances) Regulations 2006 also apply to the storage and movement of Ammonium Nitrate (which is classed as a security sensitive substance). The regulations lay out a requirement about having a security plan that is approved by the Director and controls the movement of security sensitive substances. • The Critical Infrastructure Section of the Security Intelligence Section of the South Australia Police maintain records of magazine locations and contents. • Only personnel with necessary police security clearance will have access to the magazines and ammonium nitrate storage facility. These nominated personnel will be listed on the “approved persons register” which forms part of the Explosives Security Management plan which is lodged and approved by SafeWork SA.
Issue #194 – Explosives Magazine
What safety precautions for local residents, employees and CFS fire fighters.
Refer Issues #78 to #82 above (Response 4.5.7). The Magazine has been sited on private land about 1.5 kilometres from Pillaworta Road and 700m from the nearest fire track. The Magazine itself will be enclosed by security fencing and will be monitored by surveillance cameras. Defined signage would be displayed and comply with storage and transport of Dangerous Goods. (One can refer to the Dangerous Goods code for further information for placard definitions and emergency procedures). An explosive magazine is constructed and must comply with AS 2187.1:1998 and must cover items such as mounding, earthing and lightning protection, fencing requirements, security and supervision and separation distances with regards to combustibles. A detailed Blasting Operations Procedure management plan would be formulated upon granting of the Mining Lease.
4.5.8 Type of Equipment No changes have been made to proposed types of equipment to be used.
4.5.9 Mine Dewatering
SA Govt Issue #9 – Groundwater Modelling
Identify the limitations, uncertainties and assumptions of the groundwater model in the response document particularly where relevant to the impact assessment for groundwater and GDEs.
The limitations of the Kookaburra Gully groundwater model are those of any Class 1 model based on limited observed data: • Topographic controls are only as good as the published data with surveyed elevations at drillhole collars; • Hydrogeological conceptual modelling is at a basic level to maintain simplicity wherever possible; • Aquifer parameters are universal over the model domain in the absence of any real testing outside the project area; • Initial heads are controlled by a combination of selecting an appropriate Kh, recharge rate and levels and bed properties in the creeks; • The detailed topography of the creek lines is taken from Google Earth images which have a low level of accuracy and stream beds are rarely visible on the images; and • Model calibration is limited due to the lack of transient observation well data leaving a limited pumping test at the project site (in an exploration drillhole) as the sole transient data set. The initial heads represent the result of the Steady State calibration which is largely controlled by the Kh/recharge ratio. The following assumptions apply to the Kookaburra Gully model:
Australian Graphite Pty Ltd 19 MLA RESPONSE DOCUMENT • The aquifer system is semi-unconfined to unconfined and has permeability principally in the form of fractures; • Kh = 0.008m/d and Sy = 0.05 throughout the model domain; • Water is input into the model domain via rainfall recharge at 0.0000125m/d (~4.5mm/year) which is consistent with estimations made by AQUATERRA in the adjacent Eyre Iron Fusion Study. Water is also added to the aquifer via river leakage where the potentiometric surface is higher than the river cells; • All outer boundaries of the model domain are NO FLOW boundaries; and • There is no alluvial aquifer (see further discussion below). Connection to the regional aquifer system from drainage lines is controlled by model input River Stage and Bed Conductance. With reference to the relevance re impact on GDEs, the lack of detailed survey information on the main Pillaworta Creek means that the model is generalised in this area and was not originally designed as an environmental assessment tool. More detailed survey and hydrogeological testing may be required to produce a model capable of reliably predicting environmental changes in the drainage system.
Consider improving the design of the numerical groundwater model to include • Include a layer for the alluvial aquifer, and assign appropriate hydraulic and transmissivity values to reflect the alluvial aquifer’s properties • Include nodes in MODFLOW model to determine drawdown impacts for each individual EP Blue Gum within the model’s existing boundaries. • Calibrate river bed conductance values that considers the alluvial aquifer
The Groundwater modelling report February 2015 Revision 1 states in Section 2 “More recent units include Tertiary age nodular, mottled and pisolitic ferricrete and laterite (Tfe) and Pleistocene age colluvial sands and gravelly clays of the Pooraka Formation or equivalents plus fluvial sands, silts, clays and gravels (Qha1) along watercourses.” However, local and regional geological mapping and geological maps only identify and show Quaternary alluvium to the south of northing 6191500 (MLP Figure 3.33). The ephemeral creeks on the Cullen and Harris property are shallow watercourses that are incised into the in situ Tertiary weathering profile and saprolitic clay developed within the bedrock basement with local outcrops in the channels (see photo below).
Photo 4-1 Graphite schist exposed in Cullen creek Furthermore, site inspections indicate that Tertiary age and younger sands and clays are not present to any large extent along the section of Pillaworta Creek visited as part of the water users survey. The photo below is of the soil profile in Pillaworta Creek on the Cullen property and shows the presence of a thin veneer of sandy clay (topsoil) underlain by black clay. The base of the watercourse occurs on clay regolith. Minor gravels are present in the watercourse but only as isolated (discontinuous) occurrences.
Australian Graphite Pty Ltd 20 MLA RESPONSE DOCUMENT
Photo 4-2 and Photo 4-3 Clay regolith in Pillaworta Creek The modelling report (MLP Appendix D p4) states ‘The subsurface profile encountered during drilling consisted of a thin veneer of surficial sediments (absent in places), underlain by weathered basement rocks, which in turn were underlain by fresher fractured basement rocks (schist, gneiss, graphite). No aquifer was encountered in the shallow surficial sedimentary cover materials’. Consequently, it was concluded that there is no alluvial aquifer present in either the Cullen or Harris ephemeral creeks nor in Pillaworta Creek immediately west of the proposed mining lease. In all areas, the watercourse occurs as an incision into clay and weathered basement rocks (saprolite). The MLP modelling report includes a description of the conceptual hydrogeological model (p5) and includes (among others) the following points: • There is no aquifer in the shallow alluvial sediments on site; • Groundwater occurs in a fractured basement rock aquifer; • The basement rock aquifer is confined to unconfined, with water being stored and transmitted in joints and fractures within the rockmass; and • Discharge occurs to Pillaworta Creek, to the west of the deposit. Whilst (and as stated in the modelling document), river bed conductance was also included in the model, it was not used to simulate the presence of an alluvial aquifer but rather to simulate the behaviour of the creek bed material as a means of recognising the part played by the drainage system as a means of getting water into and out of the basement rock aquifer as configured in the model (IE to enable the steady state water elevations to better approximate those measured in the field). Hence, including an alluvial unconfined aquifer in the model would serve no useful purpose. Drawdowns in model cells that coincide with the positions of Eyre Peninsula Blue Gums could be obtained from the model. However, drawdowns at blue gum locations are clearly discernible in Figures 7.8 and 7.9 of the MLP and the map below (Figure 4-1). In the critical area of Eyre Peninsula Blue Gum TEC, the maximum drawdown, at the end of year 8, ranges from 6.5m to 10m. Scattered blue gums in Pillaworta Creek occur where the maximum drawdown is less than 0.2m and along Pillaworta Road where the maximum modelled drawdown is less than 2m.
Australian Graphite Pty Ltd 21 MLA RESPONSE DOCUMENT
Figure 4-1 Impact of groundwater drawdown on Eyre Peninsula Blue Gums Calibrating river-bed conductance values is not deemed necessary since there is no alluvial aquifer present; the Pillaworta Creek and ephemeral creek watercourses occur as incisions into clay and the weathered basement rocks (saprolite).
SA Govt Issue #10 – Potential Impacts to Groundwater - Groundwater Modelling
Clarify why the input parameters are the most appropriate for the model. The sensitivity analysis indicates there could be an impact on the pools and groundwater users, however this has not been discussed or analysed in the proposal or appendices. Provide in the response document analysis and discussion on the results from alternative case modelled (k = 0.08 m/d)
Model input parameters include potentiometric surface (starting heads), hydraulic conductivity, and Sy. Water elevations were derived from field measured data. Hydraulic conductivity was obtained from the test pumping of a drillhole on site, which produced a very low K value. All other drillholes drilled at the time of the investigation either did not produce water or did so at very low rates, similar to that of the drillhole tested. This was considered to indicate that hydraulic conductivity across the site is uniformly low. Previous exploration drilling by LML also showed very low rates of hydraulic conductivity with many holes either not intersecting any groundwater or only intersecting minor seepages. LML mapping indicates that the main unit (Cook Gap Schist) occurs across the site from the proposed pit and westerly to (at least) Pillaworta Creek. It is therefore likely that the area between the pit and the creek will be of similar hydraulic conductivity. Cook Gap Schist is shown on the LML geological map below (Figure 4-2). The map indicates that areas to the west of Pillaworta Creek are of differing lithology and may have different hydraulic conductivity, so Eyre Iron documentation was reviewed to gain an appreciation of likely values for use in the model. The RPS Aquaterra report for Eyre Iron stated an hydraulic conductivity range in areas to the west of Pillaworta Creek of 0.003 – 0.1m/d. This is considered consistent with the result at Kookaburra Gully and is considered to justify the value used in the model.
Australian Graphite Pty Ltd 22 MLA RESPONSE DOCUMENT
Figure 4-2 Geological map of the Kookaburra Gully area The modelling report states that Specific Storage (Ss) was set to a uniform value of 0.0001/m throughout the model domain to reflect the anticipated small proportion of voids associated with tight fractures in the rocks representative to the area. In the transient mode, Specific Yield (Sy) was set to a global value of 0.05 or 5% reflecting a very small matrix porosity and limited fracture porosity. The RPS Aquaterra report for Eyre Iron also includes similar storativity values. The input parameters, together with the assumptions made in simplifying the geology, produce a good fit to observed groundwater levels in the vicinity of the proposed pit using a Kh (T) value interpreted from the pumping test conducted on site. In a sensitivity model run, only one parameter is altered (usually by a relatively small percentage) to assess the sensitivity of the model response (prediction) at recorded observation points to that variation. The rest of the model parameters, including the initial heads, are not changed and the resulting model cannot be considered to be a valid predictive model as the initial heads are those appropriate to the preferred value of the altered parameter (Kh/T). A predictive model (run that was not a sensitivity run) with Kh x 10 has been run (as part of the development of this response document) and the drawdown contours at the end of stress period 8 are presented below (Figure 4-3). This run used a higher (> x 10) value of recharge and as expected, produces less drawdown than shown in the previously documented sensitivity run with Kh x 10 (MLP Appendix D, Groundwater Modelling Report Addendum, Figure 6). It should be noted that the recharge rate applied in the Kh x 10 run was 45.6mm / year which is considered to be well outside the expected range for the fractured rock environment on the Eyre Peninsula. The drawdown of 0.5m during the original Kh x10 sensitivity run (presented in the modelling addendum cited above), along the creek line and at permanent pools occurring ~2 km SW was a direct outcome of using the initial heads calculated for the preferred Kh and recharge. This is considered to be a valid part of the process of sensitivity analysis.
Australian Graphite Pty Ltd 23 MLA RESPONSE DOCUMENT Figure 4-3 Predictive model with Kh x 10 and higher (> x 10) value of recharge at end of stress period 8 In regard to the impact on the pools and groundwater users based on the sensitivity analysis, the K=0.008 m/d simulation is considered to be the most credible simulation and so our conclusions are based on that parameter value (MLP Figure 7.9). Model runs with K=0.08 m/d are considered to be less credible because that value does not reflect the conditions identified on site.
SA Govt Issue #13 – Groundwater – Steady State SRMS
Provide an update of Figure 4.46 (MLP Figure 4.44) in the response document with the excluded point or provide reasons for its exclusion and how is the overall SRMS affected by the exclusion of the point, 159.88, 164.4, from the calculation.
An updated figure is presented below (Figure 4-4).
Australian Graphite Pty Ltd 24 MLA RESPONSE DOCUMENT Variance = 4.19. RMSE = Sqrt V = 2.047 Figure 4-4 Steady state SRMS
4.6 Underground Workings Not applicable.
4.7 Processing Plant, TSF and WRSFs
Issue #758 – Processing Plant Water Supply
AGL, state they are in discussions with SA Water to supply “20ML per annum (110KL per day) of potable drinking water….Impossible to want that amount of potable water for amenities! Is this excess amount of potable water to be used for mine operations?
NB 20 ML (20,000 m3) per annum is actually about 55 KL (55 m3) per day. In MLP Section 4.7.2.2, it is stated that: “…The pressure filter will be designed to enable washing with potable water equivalent to three filter cake volume displacements to ensure the NaCl content in the filter cake is reduced to meet market expectations.” The filter cake volume is approximately 7ML per annum (0.8 m3/hr) so therefore approximately 21 ML per annum would be required for product washing. With recycling of some of this water, it is estimated that the total quantity of “potable water” required would be less than 20ML.
Australian Graphite Pty Ltd 25 MLA RESPONSE DOCUMENT Issue #70 – Construction of TSF
Limitations of the design of the retaining embankment due to “insufficient geotechnical, geohydrology and hydrology of the site”
Geological investigations were undertaken by AGL to provide an indication of the subsurface profile. This included a soil survey and aircore drilling in the valley area immediately west of the proposed embankment. A typical soil profile in the valley area is: 0-15 cm sandy loam; 15-50 cm dark brown to red-brown clay; 50-90 cm yellow and red mottled brown (locally calcareous) clay. Soil testing at the time didn’t go below 90 cm but geological logs of aircore drillhole under the site of the proposed TSF embankment show mottled clay to ca. 6.9-8.7m and saprolitic clay from there down to 18.2m below ground level. Determination of foundation and embankment material properties can and will be obtained by undertaking site-specific investigations and testing. However, it is common practice to use geotechnical TSF design experience, precedence and geotechnical strength models based on properties of similar rock types and geology to those at Kookaburra Gully for initial conceptual design (Section 4.7.7.4 of the MLA). As indicated in Section 4.2.4 and 5.6.5 of the AMC report (Appendix H), the selection of geotechnical strength parameters for the foundations and the TSF were based on adoption of conservative values as follows: • tailings and clay foundation and liner materials represented using a Mohr-Coulomb constitutive model; • the bedrock utilised the Hoek-Brown constitutive model; • waste rock modelled using the lower bound values from the normal stress-shear stress relationship. As an initial assessment this was considered by AMC to be acceptable and is considered reasonable for the conceptual design. The calculated factors of safety for the TSF exceeded ANCOLD standards. Specific investigations and geotechnical testing and analysis will be undertaken through the PEPR process should a mineral lease be granted. This will include: • Determination of the availability and geotechnical properties of clay borrow sources for use in the low permeability upstream compacted clay liner of the TSF (compaction requirements, Atterberg Limits, particle size distribution, dispersion potential, shear strength and permeability); • Determination of geotechnical properties of waste rock materials (dispersion potential, shear strength, erosion potential (from accelerated weathering tests) and permeability); • Determination of the TSF foundation conditions and shear strength properties (Atterberg Limits, particle size distribution, dispersion potential, shear strength and permeability); • Undertaking of in-situ permeability tests in the foundations for the TSF to be used in additional modelling of potential seepage; • Geotechnical testing of tailings material (Atterberg Limits, particle size distribution, shear strength, permeability). In addition, it will be necessary to undertake air drying tests, drained and undrained settling tests to refine the available tailings storage requirements and deposition cycles; and • Geotechnical specification for construction of the TSF and a Tailings Operational Management Plan. AGL would not be able to commence any site works until such time as further assessment and design was undertaken and verified by an independent expert as required by DSD. This further investigation will enable refinement of the TSF design and confirm the conclusions in the mining lease proposal document that a safe and stable structure can be constructed with minimal potential for adverse environmental impact. The conceptual design of the TSF took into consideration climatic conditions for the area and has allowed for the additional storage within the reservoir of rainfall events equivalent to the 1:100 ARI. On this basis it is considered that the design is consistent with current engineering practice. In addition, upslope and upstream catchment run-off that would normally flow into the TSF storage area will be diverted around the TSF. It is considered that the limitations indicated above (lack of geotechnical and hydrogeological investigation) do not have a significant impact on the risk assessment process and conclusions, given that conservative assumptions for the material properties were adopted in the assessment. This risk will be eliminated by following the recommendations in the design report (MLP Appendix H, Recommendations). Once the studies recommended by the consultant are complete, the design can be updated based on the findings of these studies.
Australian Graphite Pty Ltd 26 MLA RESPONSE DOCUMENT Issue #74 – Construction of TSF
Leaching into the aquifer and also in the Pillaworta Creek environs is of paramount concern, one which is not readily satisfied by the proposed treatment of the TSF. The migration of Chromium, Copper, Manganese, Uranium etc into the groundwater and to the Pillaworta Creek will have significant consequences.
The following design components for the TSF have been included to minimise the potential for seepage from the storage and impact to groundwater: • Construction of a cut-off trench downstream of the TSF and backfilling with compacted low permeability clay; • Placement of a high density polyethylene liner over clay on the upstream face of the TSF; • compaction of the clay in the base of the storage area to produce a low permeability liner; • subaerial deposition of the tailings to ensure consolidation of tailings thereby reducing in-situ permeability and promoting the volatilisation of hydrocarbons; • maintaining a small decant pond thereby reducing the hydraulic head on the tailings; and • implementation of a groundwater monitoring program. Seepage analysis was conducted on the TSF embankment and TSF foundations (refer to MLP Section 4.6.7.2). The analysis indicates that the seepage flow rate will vary over the life of the TSF due to increasing thickness of tailings and any self-weight consolidation that occurs. The total seepage was calculated to be approximate 0.7 L/s which is a low albeit conservative seepage rate for clay. The proposed design measures and presence of a reasonable thickness of clay materials in the foundations would attenuate potential heavy metals present in the tailings and the risk of impacts on groundwater are considered to be low.
SA Govt Issue #4 – Construction of TSF
While the groundwater contours show an east-west gradient (Fig 3.26, based on Fig 3.27 and Appendix H) any mounding under the TSF may alter this regime and seepage may flow radially from the TSF and towards the southern valley and to the east into Rock Valley. It is noted that the TSF is located close to the boundary of Pillaworta and Rocky valleys (a probable groundwater divide) (Figure 3.20). Provide clarification on the likelihood that mounding under the TSF will result in a changed flow regime for seepage from the TSF.
In terms of seepage from the TSF, McWhorter and Nelson described three stages in the development of mounding below a TSF (Figure 4-5): • Stage 1 – seepage from the TSF produces a wetting front that moves vertically downwards toward the water table. The wetting front results in an increase in the moisture content of the foundations and may result in complete saturation as the front moves down. • Stage 2 - characterised by a rising groundwater mound in the underlying aquifer where the rate of rise depends on the seepage rate, the amount of pore space that is available for water storage and lateral spread of the mound. • Stage 3 – the groundwater mound rises to the base of the impoundment, resulting in a saturated hydraulic connection between the tailings deposit and the groundwater. Two additional stages have also being recognised by Vick 1983. • Stage 4 – tailings disposal ends and there is a decline in the mound as the amount of seepage decreases through drainage from the TSF. • Stage 5 – closure and rehabilitation results in little if any infiltration through the surface of the TSF and tailings will drain to its field capacity and the groundwater regime re-establishes its initial configuration.
Australian Graphite Pty Ltd 27 MLA RESPONSE DOCUMENT Figure 4-5 Conceptual mounding of groundwater below the TSF due to seepage The assessment indicated low levels of seepage from the TSF. Seepage rates will be controlled by the generally low permeability of the tailings as consolidation occurs and the re-compacted low permeability of the storage area. If there is seepage it is expected that this would not reach groundwater for a number of years (more than likely not within the 7-8 year mine life) due to low seepage rates and attenuation capacity of the underlying clays. While initially some lateral seepage may occur as indicated by the assessment, the open pit will be a groundwater sink and would capture seepage. The results of numerical groundwater flow modelling, presented in MLP Section 4.5.9 and as Appendix D of the MLP, show the mine pit will effectively act as a long-term groundwater sink (see Figure 4.51 of the MLP, and Section 7 of report two and Section 4 of report four of Appendix D) due to evaporation of water from the closed pit. Any solutes associated with mining and processing that seep to the water table within the cone of drawdown influence will move to the pit where they will be contained under the prevailing hydraulic gradient established by the mine pit after closure. After completion of mining and processing, the TSF would be returned to agricultural use and the only surface water input would be from rainfall directly falling on the ground above the TSF. Since this is the current steady state situation, there is unlikely to be any mounding after rehabilitation. If mounding did occur during mine operations, that mounding would soon dissipate to the current steady state levels following rehabilitation. Groundwater flows across the site in a general westerly direction under an hydraulic gradient of approximately 0.03 (MLP Section 3.11.1.2). On this basis, the estimated groundwater level under the centre of the TSF is about 170m AHD and under the ridge that acts as the surface water drainage divide between Pillaworta Creek and Rock Valley (about 600m east of the TSF centre), the groundwater level would be about 190m AHD. Therefore mounding would have to exceed 20m in vertical elevation to significantly alter the flow regime and flow east instead of west as modelled. This is considered unlikely because the base of the clay under the centre of the TSF is also about 170m AHD and this would restrict mounding. The recommended hydrogeological and hydrological site investigation (MLP Appendix H) would provide and update data for the project’s site wide water balance and groundwater model.
Australian Graphite Pty Ltd 28 MLA RESPONSE DOCUMENT SA Govt Issue #16 – Low-grade Stockpile
Some low-grade ore samples have been identified as PAF (4.3.6.2). In section 4.7.6 it is stated that low- grade ore will be stored on the ROM pad (in between the plant and Pillaworta Road) and in Table 8.5 it is stated that if the low-grade material ‘has not been processed at completion of operation the material will be incorporated into the waste rock storage with appropriate cover material to minimize any potential for AMD’. However the TSF is the only PAF storage facility designated in the MP. There are no design considerations presented for PAF material in the waste rock storage facilities. Management of the low grade stockpile is unclear particularly in relation to AMD given that PAF material could be stored here for a number of years.
As indicated in MLP section 7.5.5.5 and 7.4.6.7 the following control and management strategies will be adopted to mitigate potential impacts to surface water and groundwater: • collection of drainage from or through ore and low grade stockpiles • regular visual inspections and maintenance of surface water control systems will be undertaken during operations immediately after rainfall events and remediated • a surface water quality monitoring program will be developed consistent with the risks and implemented during operations • opportunistic use of water from sediment traps (subject to acceptable quantity/quality) to be used in the process operations or used in other operations, such as dust suppression, to minimise need for off-site release If not processed, the low-grade ore will be placed in a designated area at the southern end of the WRSF West immediately adjacent to the ROM pad (not between the process plant and Pillaworta Road). The conceptual design of the WRSF West (MLP Figure 4.4) has been shown as the final landform after rehabilitation but in an operational sense it would comprise two separate areas; one for waste rock from years 1 and 2 and a second small area at the southern end immediately adjacent to the ROM pad for the low-grade graphite schist which requires storage and is not processed at the time of mining. This latter area would be prepared in the same way as and contiguous with the ROM pad with an engineered compacted clay and rock foundation. Detailed design of the foundation would be included in the PEPR. The pad for ROM ore and low-grade stockpile will be constructed as an engineered compacted clay and rock foundation from clayey oxide waste material with the upper 0.6 m compacted to form a low permeability liner which will retard any seepage and mitigate groundwater impacts. The ROM pad and low-grade stockpile will be sloped and bunded to collect and redirect surface water towards the toe drain. A pond will be provided to trap and collect stormwater runoff from the low-grade stockpile and ROM pad, and, like the bund, will be sized to accommodate runoff from a 100 year ARI storm event. NB only low-grade graphite material mined below 120m AHD (years 5 to 8) is PAF and further grade control and AMD studies will identify and delineate exact volumes. Low-grade ore will be blended with very high-grade ore to maintain consistent feed grades to the process plant and would be processed at opportune times during the life of mine. Potential low-grade ore remaining in the low-grade stockpile after closure would be predominantly non-acid forming low-grade ore with all PAF low- grade ore preferentially fed to the process plant during mine life. In the advent some PAF low-grade material remains at the end of mine life, engineered drainage control in place at the start of mining would capture any runoff from that area and runoff managed until the low-grade PAF material was removed and/or suitably encapsulated in the TSF. Remanent PAF low-grade graphite schist in the low-grade stockpile would be removed and placed in the PAF storage area of the TSF before that area was decommissioned and rehabilitated. Any low-grade material remaining in the pit would be at the bottom of the pit and would therefore by covered by water soon after mining ceases. The maximum amount of PAF low-grade material if none of it was processed and all was mined and stockpiled from the pit is ca. 360,000 tonnes. However, it is very unlikely that such an amount of low-grade PAF material would be left in the stockpile post closure as mine grade ranges are up to 39%TGC and blending with sufficient low grade 2-5%TGC is required to maintain consistent feed grades to the process plant. The cover material for the non-PAF low-grade material if not processed will be similar to that of the store- release cover for the TSF (section 8.6.4.2 of MLP document). The “low grade cell” would be separate from the major portion of the WRSF West.
Australian Graphite Pty Ltd 29 MLA RESPONSE DOCUMENT As indicated in section 8.6.4.6, to finalise the closure strategy it is proposed to undertake a range of studies: • ongoing testing of mine waste rock and soil to determine geotechnical material properties • additional ongoing ARD analysis during both the PEPR stage and mining operations to refine the distribution of PAF and NAF material • conduct trials on site of possible covers • erosion and landform modelling to assess long term performance of the slopes • hydrological modelling of the store release cover to determine optimum thickness to limit the amount of potential infiltration.
4.8 Wastes No further information.
4.9 Resource Inputs
Issue #760 – Water Sources
There is no agreement with DCTB or local landowners for the location of pipeline from Tod Reservoir
The MoU with the DC of Tumby Bay addresses this issue since the proposed route is predominantly along/within public road reserves. The only section not along the road is within SA Water land for which an agreement integrated with the water supply would be required. The route would form a part of the Management Plans foreshadowed in the DCTB MoU. Preliminary discussions have been undertaken with the DCTB Works Manager and also with SA Water regarding the proposed route (Figure 4.71).
5 Description of Potential Benefits
5.1 Social Benefits
Issue #41 – Social License
Reference to 52 mining jobs currently in the town of Tumby Bay noting that the previous mining employer (Centrex Metals/Eyre Iron) has left the area is totally incorrect
The figure of 52 mining jobs currently in Tumby Bay is not correct and was not stated by AGL (refer Issue #28 in Appendix 1). NB in 2012-13, Eyre Iron was actively exploring for iron and employed multiple drill rigs and associated personnel at the time but not all 52 mining personnel are attributed to Eyre Iron. Many DIDO/FIFO workers that work at other State or interstate mines/operations also reside locally or in the nearby region; for example, workers at Olympic Dam, Moomba and Iron Duke.
Issue #28 – Employment and Business Development
RDAWEP estimated the FTE employment for DCTB in 2012/2013 to be 975 with 52 jobs in the mining sector. An additional 30 jobs overall is a small percentage increase and there is a possibility that some of the current 52 jobs are FIFO or DIDO thereby creating the opportunity for skilled mine workers to obtain employment closer to home.
It is important to note that the MLP did not state this fact of 52 mining jobs currently existing in the DCTB region (Refer Issue #42).
Australian Graphite Pty Ltd 30 MLA RESPONSE DOCUMENT It is true that some of the 30 long term jobs may be taken up by locals currently working on a FIFO basis at other mines in South Australia or interstate. However, the opportunity for such people to be able to go home each night is seen as a substantial social/family benefit.
Issue #42 – Social License
The availability of jobs for the local community is based upon what data, given the job profiles of the proposed positions are not identified and the glut of mine employees on the market due to the significant down turn in the mining industry.
AGL has a policy to employ as many locals as possible and employees will be encouraged to reside locally on southern Eyre Peninsula. The direct types of employment are included in MLP Appendix A 5.1.1 Population where it states "During construction and operations there will be potential jobs for plant and vehicle operators, technical, trade and labouring roles, surveyors, engineers, rehabilitation, management, and soil remediation services. It is anticipated that training opportunities undertaken as part of the project will help support the local workforce to develop transferrable skills for future employment." There will be a requirement for on-site training in operation of the process plant and many other proposed job roles as they will site specific. Job descriptions/profiles for the roles will be developed as the project moves from conceptual to actual and if AGL can assist in reducing unemployment rates locally and within the State, this will be a community and State benefit. Like any job application, an applicant needs to possess the skills and temperament required for the role. It is true that there is a glut of skilled mine employees on the market (eg. from the recent closure of Leigh Creek and reductions at Whyalla). While these may not all be local as in, local to Tumby Bay, Cummins and Port Lincoln, they live in regional SA and are very important to the State. If they were to be employed by AGL, it is likely they would move into the district and support the local community.
5.2 Economic Benefits
Issues #452 and #514 – Social License
How much will this beautiful country produce in the next 100 years if it is not mined. At what cost is the proposal to the community (Koppio, Yallunda Flat, Cummins, Port Lincoln, Tumby Bay) that are currently and sustainably relying on agriculture and will continue to do so for 100's years
It has been demonstrated by other mining projects both domestically and internationally that mining operations can coexist with and be beneficial to the agricultural industry (refer to Section 5.2, Section 5.1.4 and Section 7.13). The proposed mine and associated infrastructure occupy an area of 103 Ha (MLP Table 4.2) of which 15.3 Ha is vegetation for which a SEB benefit will apply. Therefore approximately 90 Ha of currently arable/cultivated land will be impacted upon directly by mining operations. The calculated profit from farm income that might be derived from that 90 Ha over a 5-year crop rotation period, based on the figures below (Table 5-1), ranges from $29,100 to $128,250 depending on yield and crop type.
Australian Graphite Pty Ltd 31 MLA RESPONSE DOCUMENT Table 5-1 Estimated farm income over a 5-year rotation period.
5 year rotation period Twice Once Once Once Wheat Barley Canola Fallow Current prices (per tonne) $270 $210 $500 0 Inputs (per Ha) $110.0 $110.0 $150.0 Overheads (per Ha) $180 $180 $180 Yield_Min (tonnes per Ha) 1.5 1.5 0.8 Yield_Max (tonnes per Ha) 2.5 2.5 1.5 Profit_Min (per tonne) $115 $25 $70 $0 Profit_Max (per tonne) $385 $235 $420 $0
On this basis, over the life of the mine (say 10 years including rehabilitation period), the lost profit is $58,200 to $256,500 or, if none of that 90 Ha can be returned to arable land, the lost profit over 100 years is $582,000 to $2.56 million. Based on the published figures (LML Annual Report 2015) for the project based on the conceptual mine plan (Appendix G), the estimated cash flow for Kookaburra Gully over the life of the mine is $63 million to $134 million (see below Table 5-2). On top of this is the employment of about 30 employees for the life of the project and State royalties of the order of $4.5 million. Table 5-2 Estimated mine income over the life-of-mine at kookaburra Gully Operating Cash Total Production Flow (incl. Capital Cost Cost but pre-tax) Scenario Graphite Life Plant feed Feed Concentrate Conc Undisc’d NPV $/t conc Price (yrs) %TGC %TGC $million (10%) FOB (A$/t conc) Low revenue 1,077 6.2 1.55 Mt 15.7 233 kt 94.0 63 35 630 High revenue 1,382 7.2 1.80 Mt 15.4 256 kt 97.0 134 82 704
Therefore, the economic benefit from the proposed mine far outweighs the loss of economic benefit from farming that same small parcel of land. If some of that 90 Ha can be returned to arable land as is planned, then the benefit of mining versus farming is even greater. Further community benefits are detailed throughout the response document.
Issue #43 – Social License
The oft-stated 'benefits' to the community have not been quantified nor have the costs. There is no cost benefit analysis provided.
The benefits of this proposed small mining operation versus farming have been outlined above. The employment of 30 employees over the life of the mine would include wages of the order of $2.5 million to $3.5 million per annum of which approximately $1.6 million to $2.3 million would be net income after tax and go into the local community. This does not include local transport contractors who might transport concentrate to port or the flow-on effect of spending that net income in the community (eg. shop attendants and businesses). During construction, the opportunity exists for local or regional (eg. Whyalla to Port Pirie) contractors and service providers to contribute to site preparation and the construction of plant and equipment. No figure has been placed on the amount that might be spent locally, but if only 10% of the total capital costs went to local contractors that would amount to at least $4 million. However, considerable interest has already been expressed to AGL by regional contractors eager to construct various components of the process plant so it is not unreasonable to expect that as much as 50% of the construction costs or about $20 million could go to local and regional businesses. Again, there would be a flow-on effect to other sectors of the community. Eyre Peninsula is currently supported by a diverse range of industries such as agriculture, aquaculture, tourism and mining. Mining has contributed significantly to Eyre Peninsula’s history and development with the oldest iron ore mine in Australia just west of Tumby Bay, numerous historic copper mines in the Lincoln
Australian Graphite Pty Ltd 32 MLA RESPONSE DOCUMENT Uplands and Cleve Uplands, gypsum from Lake McDonnell, over 115 years of operating iron ore mines in the Middleback Ranges from Iron Knob to Iron Duke, and, more recently, mineral sands at Iluka's Jacinth Ambrosia mine.
Issue #45 – Social License
There are no agreements with the DCTB with respect to costs, inclusive of potential decline in revenue due to the devaluation of properties in the vicinity of the proposed mines and the loss of rate revenue.
The agricultural industry dominates the land use of the area. There are 4 separate agricultural and one vegetated landholdings abutting the proposed ML. The effect of mining on values of adjoining agricultural properties has not been conclusively demonstrated to be either negative or positive, but will be dependent on the nature of the mining operation and its management practices. However, property value impacts may change positively as a result of the proposed Kookaburra Gully Mine. This statement is based on precedence across Australia suggesting that towns and cities near to major mining and resources regions experience a general increase in land values, as demand meets or outstrips supply. AGL does acknowledge that adjoining landholders may perceive that their property is devalued as a result of the Project. However, the scale of the Project is small and the perceived effects are likely to be short lived. Once the mine is operational and the community sees and accepts that the impacts on their properties and livelihoods are minimal to non-existent, there should not be any effect on property values. AGL will implement management strategies including: • Establish clear communication with nearby landowners of activities that may impact on adjacent land use and vice versa. • Minimise areas excluded from agriculture during operation by maintaining agricultural land use on all areas not required for direct mining activity. Refer to Issues #6 & #7 (Response 7.9) regarding DCTB costs.
Issue #788 – Environmental Issues
Economic gain being identified fails to recognize Environmental Diversity and Resilience
The environmental diversity of the proposed mining lease and immediately surrounding area has been described and discussed in the MLP Sections 3.12, 3.13, 7.2 and 7.3 and Appendix E (flora and fauna). Significant habitats have been identified and mapped. The area of the proposed mining lease has been farmed for many years and parts heavily grazed. During the mining operations, these areas would be given an opportunity to recover from grazing and would be monitored for weed infestations and pests. The SEB offset for the small areas of vegetation lost due to the mining operations represents an economic environmental gain and upon completion of mining operations, rehabilitation would restore some areas that are currently being cultivated to native vegetation.
Issue #808 – Economic Viability
Is the graphite grade high enough for a premium price? Once the proposal is refined and quantified is the deposit economically viable? The recent downgrading of operations at the only other graphite mine in South Australia, that recently only reopened, is of significant concern.
Kookaburra Gully Mineral Resource is amongst the top 10 global graphite deposits and almost double the grade at Uley Graphite Mine (Figure 5-1). Laboratory metallurgical studies have shown that a range of high grade coarse flake graphite products can be produced and the average price based on these products is in
Australian Graphite Pty Ltd 33 MLA RESPONSE DOCUMENT the range $1,000 to $1,500 per tonne of concentrate based on 2015 graphite prices and A$/US$ = 0.75 (CF. table in Issue #454 above).
Skaland,#Norway# Nunasvaara,#Sweden#(TLG)# Munglinup,#Western#Australia# Balama#West,#Mozambique#(SYR)# Lac#Gueret#East,#Canada# Balama#East#high#grade,#Mozambique#(SYR)# Kookaburra#Gully,#South#Australia#(LML)# Lac#Knife,#Canada# Raitajarvi,#Sweden#(TLG)# Kringel,#Sweden# Mahenge,#Tanzania#(KNL)# Koppio,#South#Australia#(LML)# Campoona,#South#Australia#(AXE)# Asbury#Graphite,#Quebec# Wilclo#South,#South#Australia#(AXE)# Uley,#South#Australia#(VXL)# Gropabo,#MaDsmyra#&#Mansberg,#Sweden# Molo,#Madagascar# Graphite#Creek,#Alaska# McIntosh,#Western#Australia#(LMB)# Loharano,#Madagascar# Albany,#Canada# 0.0# 5.0# 10.0# 15.0# 20.0# 25.0# Graphite)Grade)(%)TGC))
Figure 5-1 Comparison of graphite grade in global graphite deposits (excluding China and Sri Lanka)
6 Stakeholder and Community Engagement
6.7 Ongoing Community and Stakeholder Engagement
Issues #33 and #39 – Social License
Lack of specific information provided throughout the so called consultation process
The lack of public presentation either by DSD or the Company with respect to the Application
Community information sessions including poster displays, Powerpoint presentations and Q&A were held in: • Tumby Bay and Yallunda Flat – February 2014 • Koppio Museum (SOS Group) – February 2014 • Tumby Bay and Yallunda Flat – July 2014 Community Information Updates were released to coincide with these presentations in February 2014 (#1) and July 2014 (#2) with a further update provided in February 2015 (#3). It is agreed that there was a lost opportunity to engage during the public consultation process but Community Information Update #4 was released by AGL in September 2015 at the start of that process. Efforts were made to consult parties directly affected by the MLP during the consultation period. Ongoing personal meetings have been held with individual landowners, community groups and other key stakeholders including DCTB, the Eyre Peninsula NRM Board, Port Lincoln City Council and DC of Lower Eyre Peninsula throughout the period commencing in 2012 when the Company first released details of its scoping study and flew an airborne EM survey. AGL has been open and transparent in all its discussions regarding the MLP.
Australian Graphite Pty Ltd 34 MLA RESPONSE DOCUMENT Issue #34 – Social License
Lack of availability of hard copy
Hardcopies were made available for public viewing at DCTB and Port Lincoln City Council offices as well as the Company office in Adelaide. USB's of the document were provided to the DCTB and Port Lincoln City Council offices to permit file sharing. In accordance with section 35A(1a), 35A(2) and 53(4) of the Act, DSD provided the owners of land within the application areas and the District Council of Tumby Bay with copies of the application within 14 days of their lodgment.
Issues #35 and #36 – Social License
Lack of knowledge of the inadequacies of internet capabilities on Lower Eyre Peninsula and inability to download a 139Mb file. The fact that some people do not have computers.
The DSD website broke up the complete MLP document (139Mb) into smaller more manageable files ranging from 19.3Mb to 41.4Mb for the main report. The full Mining Lease Proposal including appendices is necessarily very detailed and hence the supporting documentation is quite large when it is put together (154Mb). USB's of the document were provided to the DCTB and Port Lincoln City Council offices to permit file sharing, in addition to the hard copies available for viewing at the councils. In addition directly affected landowners were contacted and offered a USB of the MLP; several landowners took up the offer. Hardcopies were made available for public viewing at DCTB and Port Lincoln City Council offices
Issues #37 and #38 – Social License
The expectation that the recipient of the document of 1169 pages will be able to read, comprehend and formulate a response within the period provided. The complete inflexibility of DSD with respect to an extension of time in which to respond.
The main report was 419 pages and contained the essential information. DSD required a certain level of technical data so unfortunately the company is required to comply with Mining Lease requirements and this made the report quite lengthy. The Act requires the Minister to undertake a minimum two week statutory consultation process on all mining production tenement applications. The Minister commenced a six week public consultation period on 17 September 2015 with a closing date of 29 October 2015. This involved public notices in the Advertiser and Port Lincoln Times, Government Gazette and DSD website, providing copies of the Proposal to all immediate and adjacent landowners, the Council and other relevant stakeholders, making the Proposal document available for viewing on the DSD website, and providing hard copies of the Proposal to the Council for public viewing.
Australian Graphite Pty Ltd 35 MLA RESPONSE DOCUMENT 7 Environmental Components
Issue #207 – Long term Environmental-Operational Issues
Graphite mines are the filthiest, dirtiest of all mines, they must be crazy to be mining in such high rainfall and productive country, No mining should be allowed in that country
Photographs from historic (pre 1950’s) mining of graphite certainly do show miners covered in graphite similar to historic coal miners, copper miners and others. Modern-day graphite mines like modern coal mines are clean and are required to meet strict WH&S standards and hygiene protocols. Mines are very heavily regulated in regards to the environmental, workplace health and safety for employees and general public and must comply with specific Acts and Regulations that govern the mining industry. AGL aims to co-exist with the existing industries on Lower Eyre Peninsula and add to the local community with mutual benefits to support areas of common interest.
7.1 Methodology
UNCERTAINTIES AND LIMITATIONS OF IMPACT ASSESSMENT
Limitations (including uncertainties) deriving from assumptions made in the impact assessment are not clearly provided (as required by 6.3 of MD006). For example groundwater uncertainties should be described in relation to the assumptions in the seepage analysis and groundwater drawdown model. Many of the judgments made about risks to groundwater in this section are dependent on key assumptions.
Trigger for Inclusion of an Outcome. The principle adopted is where Primary Risk has been assessed as higher than low and reliance on control and management measures is required, then that would need an Outcome. In addition, an Outcome has been adopted for issues that were considered by the community to be important.
Vegetation and Weeds On the basis of the detailed flora assessment undertaken it is considered that there is good confidence that the information enabled the risk assessment to be undertaken with negligible if any uncertainties.
Fauna On the basis of the detailed fauna assessment undertaken it is considered that there is high confidence that the information enabled the risk assessment to be undertaken with negligible if any uncertainties.
Groundwater Specific hydrogeological investigations and construction of groundwater monitoring wells are proposed to be undertaken as part of the PEPR process, and during the construction and mining process should a mineral lease be granted. This further investigation will enable refinement of the TSF design and confirm the conclusions in the mining lease proposal document that a safe and stable structure with minimal potential for adverse environmental impact. It is considered that the limitations in regard to hydrogeological investigations do not have a significant impact on the risk assessment process and conclusions, given that conservative assumptions for material and groundwater properties were adopted in the assessment and modelling process. Refer also to Issue #70 (Response 4.7) above.
Australian Graphite Pty Ltd 36 MLA RESPONSE DOCUMENT Surface Water On the basis of the information available, and design assumptions (rainfall events, topography, TSF, and WRSF design) it is considered that there is good confidence that the information enabled the risk assessment to be undertaken with negligible if any uncertainties.
Air Quality As indicated in earlier responses, the air quality assessment was based on baseline data that was derived from Eyre Iron Pty Ltd and collected in close proximity to the site including a dust collector immediately adjacent to the nearest sensitive receptor. On the basis of the similar topographical features, land uses at the time of the survey and climatic conditions it is considered that the data was appropriate to use (Refer Response 3.8 Issue #769). On that basis it is considered that there are limited or no uncertainties that would change the conclusions of the risk assessment.
Noise The noise assessment was based on baseline data that was derived from Eyre Iron Pty Ltd and collected in close proximity to the site. On the basis of the similar topographical features, land uses at the time of the survey and climatic conditions it is considered that the data was appropriate to use. The sources of noise were based on typical mining equipment from various sources as indicated in MLP Appendix B. On that basis it is considered that there are limited or no uncertainties that would change the conclusions of the risk assessment.
Aboriginal, European and geological heritage A survey of the proposed ML was undertaken by a consultant and Barngarla representatives. Review of existing government data bases indicated there were no European or geological heritage sites. On that basis it is considered that there are no uncertainties that would change the conclusions of the risk assessment.
Asbestiform and radioactive substances On the basis of geological investigations and analysis to date and the extensive experience of Dr John Parker who has undertaken numerous petrological studies as part of his PhD studies and subsequent work on Eyre Peninsula over 40 years, it is considered that there are no uncertainties that would change the conclusions of the risk assessment. Further petrological examination will be undertaken on samples from planned geotechnical core drilling and will be ongoing throughout the life of the project.
Acid Rock Drainage The investigations comprised detailed testing and analysis of a selected number of representative samples to develop a site model based on the results of a significant number (1,159 samples) of drill assays for sulphur from which initial prediction of the potential for acid generation was made. The testing of a larger number of samples may have provided additional confidence in the prediction but it is considered that a significant change to the conclusions was unlikely. Additional investigation and testing is proposed as part of the PEPR based on samples from planned geotechnical core drilling and infill resource drilling.
Closure Covers The derivation of closure covers for the TSF and WRSF(s) was based on assumptions of the material properties for drill samples and soil tests undertaken in the area of the proposed pit, the local and regional geological soil profile(s), technical precedence and experience. There was no testing undertaken of materials immediately underlying the TSF and WRSF(s) nor modelling of alternative cap layers which limits a final design to be provided. However, local geological mapping and knowledge across the area of the proposed mining lease shows that the pit area is representative. It is proposed to undertake geotechnical testing and modelling of the TSF and WRSF(s) areas as part of the PEPR and undertake on site trials of the preferred option(s) during the operational phase. It is considered that the limitations indicated above (lack of detailed geotechnical and hydrogeological investigation across the entire proposed ML site) does not have a significant impact on the risk assessment process and conclusions. A revised risk assessment register will be provided in the PEPR.
Australian Graphite Pty Ltd 37 MLA RESPONSE DOCUMENT See also Issue #73 (Response 8.6).
7.2 Flora – Vegetation and Weeds
Issue #126 – Environmental Impacts: Flora
Located on Section 162, Hd of Koppio is 80 ha of natural woodland which has not been stock for 30 years….This area was not burnt out in 2005 bushfires and thus the natural woodland is very healthy. We are extremely concerned for our natural vegetation with the dust and noise contamination due to the mining activity with the extra traffic that will be in our area.
Section 162, Hd of Koppio is located on Bratten Way and the southern boundary of this area of natural woodland is 4.2 kilometres north of the northern boundary of MC 4372. Therefore, it is well beyond the modelled impact zone of any dust (refer Issue #13, Response 7.6). As described in MLP Section 7.2.4.7 dust would be produced as a result of mine operations including traffic movements on site roads and extraction activities. The effects of airborne dust are likely to be localised and occur largely in close proximity to roadways and cleared areas associated with site facilities. Baseline dust deposition at the time of measurement on Pillaworta Road exceeded the recommended limits during some months of the year. Given this existing condition, dust is unlikely to result in death of plants therefore significant impacts from this project are unlikely to occur especially on Section 162 over 4 kilometres away. AGL is not aware of vegetation being impacted by noise. The impacts/effects of noise on animals is generally inconclusive as noted in research papers. There is a lack of fundamental knowledge in this area due to research to date being limited to small, disconnected, anecdotal or correlational studies as opposed to coherent programs of controlled experiments. In general, there is no or little evidence of cause and effect regarding noise and behavioural or physiological effects on domestic animals. It is believed that the relatively low level of infrasonic/infrasound levels from standard mine operations is not likely to affect domestic or wild animals.
Issues #127 and #128 – Environmental Impacts: Flora
It is unjust that our government can give a mining company the approval to destroy our land with a mine with a life span of 8 to 10 years. Our wish is to be able to pass onto our grand children a parcel of land with natural vegetation that has NOT been tarnished with Mining Dust. Our wish is to be able to pass onto our grand children a parcel of land with natural vegetation that has NOT been tarnished with Mining Dust. Please consider our environment.
Approval for the Kookaburra Gully Graphite Project has been sought by AGL via the South Australian Mining Act, 1971. AGL has adhered to the requirements of Mining Act, 1971 and has fulfilled the legislative conditions in the preparation of the Kookaburra Gully Graphite Project - Mining Lease Proposal (MC4372 and MC4373). AGL totally agrees with this wish to be able to proudly say to our children and the community that we are able to pass on a parcel of land that has been properly rehabilitated and returned to agricultural use as far as is practically possible. Every effort will be made to ensure that the Company’s objectives are met and the Government bond system is designed to ensure that rehabilitation objectives are met.
Australian Graphite Pty Ltd 38 MLA RESPONSE DOCUMENT Issues #882 and #883 – EPBC Referral (2015/7470)
Letters dated 11 May 2015 and 28 October 2015 to The Hon G Hunt, MHR, regarding AGL’s EPBC Referral (2015/7470)
On 30 April 2015 AGL submitted a Referral under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act Referral 2015/7470) “to develop, operate and decommission an open cut graphite bearing ore mine with processing facilities, and associated infrastructure, approximately 35 km north of Port Lincoln on the Eyre Peninsula, South Australia.” Following public release and formal assessment of the initial EPBC Referral, additional information was requested on three occasions to enable the Department to consider all relevant issues including those raised by the letters to the Hon G. Hunt cited above. Additional information included: • Further biological survey / assessment within the previously inaccessible portion of the proposed open pit area (viz. parts of MC 4372). This was later extended to include a spring orchid survey; • Issues regarding potential waterlogging of the Eyre Peninsula Blue Gums as well as further information regarding water quality, volumes, timing and duration of flows along relevant watercourses; • An assessment of the activity concentration (Bq/g) of radioactive material within the proposed tailings and waste rock storage facilities. • The status of the water pipeline between the mine site and the Tod Reservoir. • Required road widening along the proposed transport route to the mine site. • The provision of aerial photography-based maps for: • The occurrence of the Eyre Peninsula Blue Gum (Eucalyptus petiolaris) Woodland Threatened Ecological Community (TEC); and • The proposed site layout and clearance areas in relation to the occurrence of this TEC. • Further details regarding AGL’s exploration activities, in particular to the south of the proposal site. • Further details regarding the State assessment process and community responses, as relevant. Further studies / assessments were subsequently organized and submitted to the Commonwealth Department of the Environment. The Commonwealth Department of the Environment has advised AGL (23 December 2015) that the proposed action is “Not a controlled action if undertaken in a particular manner” as set out in this decision. The following measures must be taken to avoid significant impacts on listed threatened species and communities (sections 18 & 18A): • No clearance of Eyre Peninsula Blue Gum (Eucalyptus petiolaris) Woodland occurs as a result of the proposed action; • A fence and signage is to be erected around Eyre Peninsula Blue Gum (Eucalyptus petiolaris) Woodland at a distance of at least 5 metres from the identified Threatened Ecological Community (as illustrated on the attached map at Attachment A) prior to construction; • There is a minimum 20 metre buffer between construction and Eyre Peninsula Blue Gum (Eucalyptus petiolaris) Woodland (as illustrated on the attached map Figure 7-1); and • Clearance on the proposed mine site is consistent with the conceptual mine plan (Figure 1-2). AGL has accepted these measures.
Australian Graphite Pty Ltd 39 MLA RESPONSE DOCUMENT Figure 7-1 Location of fence and buffer zone around Eyre Peninsula Blue Gum (Eucalyptus petiolaris) Woodland
Australian Graphite Pty Ltd 40 MLA RESPONSE DOCUMENT SA Govt Issue #35 – Environmental Impacts: SEB Ratio for Native Vegetation Clearance
Should a lease be granted, it expected that the SEB described in the PEPR will have an appropriate SEB ratio assigned to Association 2 of at least 6:1.
Association 2 SEB is changed from 4:1 to 8:1 due to the presence of threatened species. MLP Table 7.11 has been updated to reflect this change (Table 7-1). Table 7-1 Revised MLP Table 7.11 – SEB calculation Mine Area of Ratio Required Land Set Set Management SEB value Component clearance listed value aside aside cost (ha) (ha) species area with loading % ($/ha) (ha) loading (ha) Open pit 6.54 8:1 50% 2095 52.32 78.48 800 $165,216 2.74 8:1 20% 2095 21.92 26.30 800 $55,907 Waste rock 1 8:1 20% 2095 8 9.60 800 $20,912 storage facility and stockpiles
Tailings storage 2.32 4:1 20% 2095 9.28 11.14 800 $24,130 facility 1.69 7:1 20% 2095 11.83 14.20 800 $30,541
Scattered trees in 0.95 - - 2095 4.12 - 800 $9,431 WRSF South (10 trees)
Total $306,136
7.3 Fauna
Issue #216 – Environmental Impacts: Fauna
What about the kookaburras of Kookaburra Gully
Kookaburras are well represented across the region, state and nationally and are not a threatened species under State or Commonwealth legislation. In addition their habitat is well represented outside the site. On that basis it is considered that there will not be any type of impact on the species.
Issue #273 – Environmental Impacts: Fauna
The Pillaworta Creek joins the Tod River and flows into the sea, Spencer Gulf, at Poonindie and the Port Lincoln harbour is just around a land point to the south. The Southern Right Whales are known to be in the sea at Port Lincoln and Spencer Gulf each year.
The assessment undertaken in MLP Sections 7.5 and 7.6 indicated that the risk of impact to surface water and groundwater due to sediment, chemicals, ARD impact on surface water (including Pillaworta Creek) and groundwater at the site and off-site was low. Therefore the risks of impact further downstream, including Tod River, Spencer Gulf and impacting the marine environment (including whales) is highly unlikely and not considered to be a credible impact.
Australian Graphite Pty Ltd 41 MLA RESPONSE DOCUMENT 7.4 Groundwater
Issue #16 – Groundwater
An analysis of the data provided indicates the existence of a significant number of minerals within the ore body that are potentially harmful to human health and plant health. These include not only the graphite, but Chromium, Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium together with Copper, Magnesium and Zinc. These minerals are potential carcinogens and or neurotoxins in humans and growth inhibitors in plants.
The results of numerical groundwater flow modelling, presented in MLP Section 4.5.9 and as MLP Appendix D show that the mine pit will effectively act as a long-term groundwater sink (see Figure 4.51 of the MLP, and Section 7 of report two and Section 4 of report four of MLP Appendix D) due to evaporation of water from the closed pit. The predicted extent of drawdown surrounding the mine pit extends from Pillaworta Creek (west) to under the proposed location of the tailings storage facility (east), providing an effective capture zone for any solutes associated with mining operation that might seep down to the water table, and as a result there is little potential for these solutes to impact upon the regional groundwater system. Graphite is not a hazardous mineral and is not harmful to human health, plants or animals. For example, it is the “lead” in pencils. As shown in MLP Table 4.5 and Appendix I, the concentrations of base metals and other elements within the ore and host rocks are low and the resultant concentrations of these elements in tailings water (MLP Table 4.41), dust and groundwater will also be low. However, as discussed in MLP Section 7.4.8.8, the majority of rock samples that are enriched (GAI >=3) with respect to metals are either high-grade ore or low-grade ore. Therefore, these metals would be contained within the ore stockpiles and tailings storage facility. The concentrations of elements were compared to the NEPM 1999 (amended in 2013) health investigation levels (HIL) and ecological investigation levels (EIL) where assessment levels are available. A review of the heavy metal concentration included in Appendix I indicated the following: • All arsenic and lead concentrations are below the EILs • Total chromium in one sample (257 ppm) exceeds the EIL (115 ppm) for chromium (III) • Copper (up to 206 ppm) exceeds the EIL (100 ppm) in four samples • Nickel (up to 54.8 ppm) marginally exceeds the EIL (45 ppm) in 3 samples • Zinc (up to 121 ppm) marginally exceeds the EIL (115 ppm) in 2 samples. While there are some exceedences of some EILs, the proposed risk of significant contamination is considered to be low or negligible by implementing the proposed control and management strategies: • installation of a drainage collection system around the perimeter of ore and low grade stockpiles; • re-use of the collected water in processing (subject to acceptable water quality); • implementation of a groundwater monitoring program.
Issue #17 – Groundwater
The nature of the hazardous materials emanating from mining operations inclusive of the processing operations is inadequately described in the application
As well as the response outlined above for Issue #16, the following provides additional information addressing this issue. Section 4.8 of the MLP presents a comprehensive discussion of elements, including metals, that may report to the waste storage facilities (tailings and rock) as part of the mining and processing operations. Section 4.8 of the MLP presents tabulated data for the likely concentrations of different elements and compounds in the tails substrate and water, based on different types of laboratory testing, as well as details concerning industrial and
Australian Graphite Pty Ltd 42 MLA RESPONSE DOCUMENT domestic wastes and sewage. The data presented in Section 4.8 have been tabulated and concentrations compared to relevant health based guidelines sourced from the National Environmental Protection Council. MLP Section 4.3.6 and Appendix I present details of the assessment undertaken regarding the potential for acid and metalliferous drainage, and MLP Section 4.3.7 addresses the issue of asbestos. As outlined for Issue #16 (above), the predicted extent of drawdown surrounding the mine pit after mining ceases extends from Pillaworta Creek to under the location of the tailings storage facility, and this provides an effective capture zone for any solutes associated with the mining operation that might seep down to the water table and, as a result, there is little potential for these solutes to impact upon the regional groundwater system.
Issue #18 – Groundwater
Environmental impact associated with contamination of groundwater with the hazardous materials identified is not fully disclosed neither is the long term health impacts associated with contaminated ground water - damage to be caused to the groundwater on Lower EP
This issue has been addressed in the response to Issues #16 and #17 above. The results of laboratory testing presented in MLP Section 4.3.6 suggests there is little potential for hazardous materials to significantly impact on groundwater quality, and the results of numerical groundwater flow modelling indicate that the predicted extent of drawdown surrounding the mine pit after mining ceases provides an effective capture zone for any solutes associated with mining operations that might seep down to the water table. It is very unlikely that regional groundwater will be adversely affected by the mine operation in either the long or short term.
Issue #19 – Groundwater
There are significant limitations with respect to the geotechnical, hydrogeology and hydrology of the site, especially in regard to the design of the TSF facility (Section 4.7.7.4 pp 198). It is significant concern that the limitations highlighted by the consultant extend beyond the TSF facility to include the known fact that no data exists for MC4372, nor does the geo-hydrology or hydrology exist beyond the boundaries of MC4373 which may impact upon the Prescribed Wells Area to the South, the source of potable water for the lower Eyre Peninsula.
This issue has been partially addressed above in response to Issues #16, #17 and #18, particularly in regard to the effect that groundwater drawdown associated with the mine will effectively isolate the open pit and mine-associated landforms (the waste rock and tailings storage facilities) from the regional groundwater system. To say that ‘the regional hydrogeology is not established’ is not correct. Application of established principles of groundwater science allows interpretation of conditions (eg. groundwater elevations, hydraulic properties of aquifers), and modelling of groundwater response to stresses such as pumping and climate change. There are a number of published and unpublished reports on Eyre Peninsula hydrogeology for the prescribed and non- prescribed groundwater resources, eg. DEWNR Technical Reports 2011/16 and 2014/10, the Eyre Iron Fusion Iron project studies, and presented as Appendix D of the MLA. Hydrogeological studies completed for the Fusion (Koppio) Project, which is located to the west of Pillaworta Creek, do not present results or interpretations that are significantly different to those presented in the MLP. The groundwater system associated with the proposed Kookaburra Gully mine is not connected to the groundwater resources of the Southern Basins PWA (see Figure A5 of DEWNR Technical Report 2014/10; Figure 7-2 below). Regional gradients in groundwater levels in and around the Koppio Hills-Kookaburra Gully area are east-west towards the Spencer Gulf Coast-Wanilla Basin respectively not north to south. Any drawdown that can be attributed to the proposed mine outside of the Pillaworta Creek catchment is extremely unlikely and particularly in regards to aquifers of the Southern Basins PWA, which is located more than 30 km to the south of Kookaburra Gully or the Uley South lens, the main groundwater basin used to supply Eyre Peninsula water, which is over 45km to the southwest.
Australian Graphite Pty Ltd 43 MLA RESPONSE DOCUMENT Figure 7-2 Figure A5 from DEWNR Technical Report 2014/10: Interpolated potentiometric (water level) Figure A5. Interpolated potentiometric (water level) surface for the basement fractured rock aquifers surface for the basement fractured rock aquifers DEWNR Technical Report 2014/10 Hydrogeological studies have been undertaken on the adjoining MC, as well as in other areas around the proposed Kookaburra Gully mine. In addition to this there are published geological maps to work with, eg. the Lincoln SI5311 map (SA Geological Survey). The available data and information provide a sound basis for understanding the hydrogeology of the area beneath MC 4372. Groundwater modelling by an international recognised hydrogeologist has also been used to inform the hydrogeological understanding of the area. As indicated in Figure 3.26 of the MLP, the groundwater potentiometric surface at Kookaburra Gully slopes to the west and it is not eliminated at a property boundary. Since writing of the MLP, the property owner has undertaken peizometer installation upon MC4372 (Unit numbers 6029-1461, 1463 to 1466 and 7229-1) with each of the drillholes found to be dry, and further substantiates the potentiometric surface in the project area (see cross section below in Issue #878). The Eyre Peninsula Demand and Supply Statement outlines the state and condition of all water resources in the region for drinking and non-drinking quality water, lists major demands on these water resources, and identifies likely timeframes when water demand exceeds supply. The original Statement was released in April 2011 and prepared by the Department of Environment, Water and Natural Resources (DEWNR) who are responsible for the preparation of regional demand and supply statements and their reviews in all natural resources management regions of South Australia. New information and assumptions underlying the demand-supply projections are reviewed annually and three annual reviews have been completed for the Eyre Peninsula since the original Statement was released. The reviews found that actual population growth is lower than originally projected and that climate change impacts are expected to be less severe than anticipated in the original Statement. The latest annual review release in July 2014 also found that more groundwater was available due to the ongoing recovery of the groundwater basins in the region. The latest annual review projects that Eyre Peninsula’s drinking water supplies are secure to 2024-25.
Australian Graphite Pty Ltd 44 MLA RESPONSE DOCUMENT Issue 124 – Groundwater
Water that our livestock drink comes from nature soaks, creeks and dams. I am very concerned what will happen to our underground water system if this mining company is allowed to make an open pit mine. In May, June & July 2014 we received 353 mils of rainfall which became extremely wet. I am worried how this mining company is going to cope with their waste water during winter. Is this water going to leak into our natural creek systems and poison our natural vegetation and habitat?
There are two issues to be considered for this submission item – (i) the effect of the mine on livestock water supplies, and (ii) the potential for contact (mine impacted) surface water runoff to impact on creeks, springs and farm dams. It is recognised that the wells, soaks, creeks and dams on which stockwater supplies are located are important. These water sources are maintained by surface water runoff as well as the water table. The results of groundwater flow modelling presented in Section 4.5.9 predicts that drawdowns at local landholder wells will range between 0 and less than 1 m (see Table 4.22 and Figure 4.53 of the MLP), and that only a small number of wells are located within the zone of drawdown. The modelling suggests that a similar sort of drawdown might be experienced at dams that may be supported during dry summer periods by the water table (see Figure 4.53). All of these locations are located within 500 m of the mine pit. It is unlikely water sources located more than 1 km away from the mine pit, or on the western side of Pillaworta Creek, will experience altered water levels that can be attributed to the mine operation. The stormwater control systems have been designed to trap and collect volumes of water corresponding to a once in 100 year ARI storm event. Infrastructure that is included in the MLP will isolate contact (mine- impacted) and non-contact waters from each other. Non-contact water will be diverted around the mine site or into other watercourses using engineered bunds and drains. Contact water will be diverted to on-site storages (such as the process water pond) or sediment ponds and basins, again using engineered bunds and drains. Captured (contact) stormwater will be used in the mine process or monitored and treated if necessary to an appropriate level prior to discharging offsite.
Issue #270 – Groundwater
Dewatering of the area to obtain the graphite may cause earthquakes and subsidence (with reference to land subsidence over 40 years in the Gippsland and Morwell areas of Victoria because of the extraction of underground water for dewatering for mining, and oil and gas activities)
Seismicity associated with dewatering of mines at the scale proposed for the Kookaburra Gully mine (predicted to be around 6 L/sec) in competent crystalline rock would be non-existent or negligible. Subsidence is very different to seismicity. It typically involves the compaction of geological, usually sedimentary, materials as a result of some stress being applied to those materials or the collapse of sediments into voids arising from the dissolution of soluble rocks. Groundwater pumping (eg. for irrigation or mine dewatering) can reduce the volume of water held in pore spaces (depressurization) and contribute to subsidence. The scale of mining operations occurring in the Gippsland Region of Victoria is very different to that proposed for Kookaburra Gully, as too are the hydrogeological settings and the dewatering requirements (Morwell’s dewatering rates were initially almost 30 times larger than that predicted for Kookaburra Gully; Ref. Fraser C.J., 1979, Artesian Dewatering Operations at Morwell Open Cut, IMWA). Subsidence associated with mines like that proposed for Kookaburra Gully, where groundwater drawdown outside the immediate mine pit area is predicted to be generally less than 30 m (see Figure 4.53 of the MLP) and the thickness of sediments is not extensive (generally less than 10 m, see Section 3.11.1 of the MLP) would be expected to be very limited, if at all, and will certainly not extend beyond the zone of drawdown induced by mine dewatering (see Figure 4.53).
Australian Graphite Pty Ltd 45 MLA RESPONSE DOCUMENT Issue #271 – Groundwater
Seawater Intrusion, by the National Centre for Ground Water Research and Training’ states that Eyre Peninsula is highly vulnerable to seawater intrusion.
Seawater intrusion occurs where the discharge of groundwater to the ocean decreases, which can arise due to climate variability and large scale groundwater pumping. The predicted dewatering rate for the proposed Kookaburra Gully mine is around 6 L/sec (see Section 4.5.9 of the MLP) and the zone of drawdown influence is unlikely to extend more than 1,000 m from the open pit (see Figure 4.53 of the MLP). The proposed mine is located more than 15 km from the coast. An NCGRT report (Ivkovic K.M. et al, GeoScience Australia Record 2013/04, GeoCat 74648) identifies the primary threat of seawater intrusion on the Eyre Peninsula is associated with drought and groundwater pumping from aquifers for public water supply along the southern coastline of the Southern Basins Prescribed Wells Area. Sea water intrusion is not a viable risk at Kookaburra Gully.
Issue #272 – Groundwater
Threat to potable ground water in the Lower Eyre Peninsula (Uley South) as the result of overflowing of waste-water holding pond….extreme weather conditions such as a 100 year flood.
The available groundwater quality data for the Kookaburra Gully project area indicates the groundwater is generally not suitable for potable supply without some form of treatment. However, the groundwater quality data do suggest the groundwater is suitable for stock water use and irrigation of some crops (based on salinity concentration, see Table 3.13 and report three of Appendix D of the MLP). However, AGL recognises the importance of protecting groundwater quality, whether it is suitable for potable use, stockwater or other purposes, and has outlined strategies including engineering design and preparation of management plans in the PEPR to ensure this outcome is achieved during and following mining and processing operations. Sections 4.7 and 4.8 in the MLP, in particular, describe these strategies, including designing stormwater control systems to withstand a 100-year ARI. The response to Issue #19 (above) outlines that the predicted extent of drawdown surrounding the mine pit during and after mining will provide an effective capture zone for any solutes associated with the mining operation that might seep to the water table. As described for Issue #16, there is little potential, if any, for these solutes to impact upon the regional groundwater system. Certainly, any drawdown impact associated with the mine outside the Pillaworta Creek catchment (see Figure 3.20) of the MLP will be extremely unlikely.
Issue #274 – Groundwater
Taking a pipeline for potable water from the Uley Basin to the mine site for amenities and the final wash of graphite products. This is putting extra pressure on the requirements of potable water for the lower Eyre Peninsula. The water from the washery has to be dealt with. This may lead to contamination through spillage. Even if this waste water is ‘purified’ the concentrated sludge (heavy metals, brine etc.) is still left behind, and always a problem.
The responses to Issues #16 and #272 (above) describe how the predicted extent of drawdown surrounding the mine pit during and after mining will provide an effective capture zone for any solutes associated with the mining operation (such as may be found in washdown sludge) that might seep down to the water table. The zone of drawdown influence means there is little potential, if any, for potential contaminants arising from the mining and processing operation to impact upon the regional groundwater system. AGL has not proposed taking a pipeline from the Uley Basin to the mine site. However, the MLP does include a requirement for up to 20 ML (20,000 m3) per annum of potable water from the SA Water system for amenities and final washing of the concentrate. SA Water has confirmed that this amount of water can be
Australian Graphite Pty Ltd 46 MLA RESPONSE DOCUMENT readily supplied from a nearby standpipe on Edilillie Road. It would be transported to site on an as-needs basis by water tanker.
Issue #635 – Groundwater
This water, by then including kerosene and other processing agents, will not harm the environment if it overflows into the adjacent areas
Areas on the proposed Mine Lease where hazardous goods are stored or used will be designed to appropriate Australian standards and EPA guidelines to manage and contain any accidental spills. In addition, emergency spill management plans will be in place to assist in the cleanup of any spillages of hazardous goods. The response to Issue #16 (above) outlines that the predicted extent of drawdown surrounding the mine pit during and after mining will provide an effective capture zone for any solutes associated with the mining operation that might seep to the water table. As described for Issue #19, there is little potential, if any, for these solutes to impact upon the regional groundwater system If there is any accidental surface water overflow of the TSF during mining operations, it will be first captured in the water seepage pond immediately below/downstream of the TSF. If that seepage pond overflows, the surface water overflow would go into the open pit. Therefore, surface water could not overflow from the TSF into Pillaworta Creek.
Issue #636 – Groundwater
We use a bore on our property for stock water and this proposed mine is 10kms south of the farm. Not enough is known about the hydrology in the area to be sure this mine will not affect the underground water supplies in the Koppio Hills.
There have be a number of groundwater studies undertaken for the proposed mine area, as well as other locations in the general area of the mine, eg. for the Fusion (Koppio) iron project and by DEWNR, eg. Technical Report 2014/10. Numerical groundwater flow modelling, based on the available data sourced from these studies and testing conducted on the project site, provides a detailed analysis of the way the local to regional groundwater system will respond to mining dewatering during and following mining. The results of the modelling indicate that it is very unlikely that any drawdown impacts associated with the mine will extend more than one kilometre from the mine pit (see Section 4.5.9 of the MLP for discussion). Certainly, any drawdown impact associated with the mine outside the Pillaworta Creek catchment (see Figure 3.20 of the MLP will be extremely unlikely. The results of numerical groundwater flow modelling, presented in Section 4.5.9 and as Appendix D of the MLP, show the predicted zone of drawdown associated with the operating mine might extend to Pillaworta Creek over an approximately 1.5 km stream reach. It is expected that groundwater baseflow from the west side of Pillaworta Creek will continue to support surface water pools and flows. Upstream and downstream of this zone the environmental flow regime of Pillaworta Creek and the riparian zone are unlikely to be measurably impacted. After closure the zone of drawdown influence will be less extensive (see report 4 of MLP Appendix D), and so the potential for impact will be correspondingly less. In addition, only three existing groundwater users are located within the predicted zone of drawdown influence (see Figure 4.51 of the MLP). Drawdown at these locations (around 500 m from the pit) is predicted to range between 0.5 m and 2 m. At distances of more than 1,000 m from the pit, it is unlikely existing users will be adversely effected by drawdown associated with the mine. The groundwater users survey was comprehensive and included inspection of a number of water supply points, historically and still in use.
Australian Graphite Pty Ltd 47 MLA RESPONSE DOCUMENT Issue #789 – Environmental Issues – Groundwater
Concern in relation to the unknown hydrogeological interactions within the 400km2 area that is the Tod River Catchment and Wetland System
The hydrological and hydrogeological systems are well documented in MLP Sections 3.10 and 3.11 respectively. Figure 3.20 in the MLP shows that the Pillaworta subcatchment represents around 10% of the Tod River catchment. The major component of water flows in the Tod catchment is surface water runoff during and following rainfall events. Groundwater baseflow will contribute to year round flows and will be an important component of flow or maintenance of pools during dryer summer months. Numerical modelling (section 4.5.9. of the MLP and report two of Appendix D) predicts that baseflow to Pillaworta Creek will be intercepted over a small reach of the creek (about 1,500 m; see Figure 4.51 of the MLP), and that stream losses over this reach will likely be immeasurable at less than 1 L/sec (see Table 4.24 of the MLP), which represents less than 1 mm/m stream reach. The impact of groundwater drawdown on Pillaworta Creek may affect some pools in the creek during summer (I.E. pools less than 0.5m in depth) but will not affect surface water flows into or along Pillaworta Creek at other times of the year.
Issue #790 – Environmental Issues – Groundwater
Ecological and hydrological functioning of the Tod River Estuary….is not identified in the Mining Lease proposal
Ecosystems of the Eyre Peninsula are adapted to a variable climate as well as seasonal variability, and will also have been impacted by existing landuses. The response to the immediately prior issue to this one (above) describes the interaction of groundwater and surface water and notes the outcome of numerical groundwater modelling that predicts the mine will have little (if measurable) impact on Pillaworta Creek stream flows. It is even more unlikely that the effect of the mine on Tod River stream flows at the estuary will be discernible from other influences, including Tod Reservoir.
Issue #791 – Environmental Issues – Groundwater
Pillaworta Creek Catchment is a major component of the environmental water….baseline data must be determined for both upstream and downstream of the proposed project so that management criteria can be determined for the known impacts and potential risks of the project before mining begins.
Section 3.10.2 presents a description of the Pillaworta Creek flow regime, based on the available records, as well as the environmental condition of the creek, which has been impacted by existing and historical land uses and management. Contact (potentially mine impacted) water will be contained within the mine lease, as described in the response to Issue 124, and other than the predicted loss of flow in response to the mine induced zone of groundwater drawdown (less than 1 L/sec; see Section 4.5.9 of the MLP) it will be unlikely that any other impact will arise to Pillaworta Creek. Water management plans for the mine will consider the issue identified here, and will include response measures. Ongoing groundwater monitoring and data evaluation will be used to further inform the understanding of Pillaworta Creek hydrogeology.
Australian Graphite Pty Ltd 48 MLA RESPONSE DOCUMENT Issue #793 – Environmental Issues – Groundwater
Resupply the creek using pit-water if necessary…. this statement holds limited credibility and should be withdrawn from the proposal if not able to be supported by significant additional information that is site- specific
As outlined in the responses immediately prior to this issue, it is unlikely that the influence of the proposed mine on Pillaworta Creek flows will be measurable since it is predicted to be less than 1 L/sec, which is equivalent to less than 1 mm/m of stream reach adjacent to the proposed mine. As a consequence it is unlikely this management strategy will ever need to be contemplated. Any release of mine-impacted or mine-derived water would need to meet stringent EPA water quality and permitting conditions or would not be released. Any stormwater contaminated as a result of mining operations would not leave the lease area or result in contamination of soil at closure within the lease area.
Issue #878 – Environmental Issues – Groundwater
Hydrogeological assessment of features described on the Borthwick property as ephemeral springs concluded that it is very unlikely the features...are in fact springs. NO drilling or collection of samples was permitted as a condition of entry imposed by the Warden’s Court. The conclusions drawn are not conclusive
An assessment of potential ephemeral springs and groundwater on the Borthwick property (MC 4372) was undertaken by a qualified hydrogeologist from CDM Smith Australia Pty Ltd in early August 2015 under orders of the Warden. The conclusions drawn in regard to the presence or not of ephemeral springs on MC 4372 was based on observations and evidence made on the day in regard to topography, information that could be derived from recent groundwater drilling on the Borthwick property (namely from constructed wells, all of which were dry), and on extensive hydrogeological experience. The groundwater drilling and well construction on the Borthwick property was commissioned by the Borthwicks since writing of the MLP. The property owner has undertaken peizometer installation upon MC 4372 (Unit numbers 6029-1461, 1463 to 1466 and 7229-1) with each of the drillholes found to be dry, and further substantiates the potentiometric surface (water table) in the project area (see geological section below; Figure 7-3).
Australian Graphite Pty Ltd 49 MLA RESPONSE DOCUMENT
Figure 7-3 West-east cross section through Borthwick observation wells, MC 4372
SA Govt Issue 9 – Groundwater Dependent Ecosystems
The numerical model includes assumptions and uncertainties relating to impacts on Pillaworta Creek and associated groundwater dependent ecosystems such as EP Blue Gums. In addition, uncertainty exists in the model outputs such as the potentiometric surface and drawn-down maps (Figures 4.45, 4.50 & 4.51).
Groundwater Dependent Ecosystems (GDE) typically rely on more than one source of water, i.e. they rely on a combination of two or more of surface water, soil water and groundwater. The MLP acknowledges that there will be a reduction in surface water flow along Pillaworta Creek of less than 1 L/sec adjacent to the zone of mine drawdown, and that drawdown will reduce to some extent access to the water table by phreatic vegetation where it occurs within the zone of influence. The proposed mine dewatering may have some level of impact on phreatic vegetation along Pillaworta Creek, where they occur within the zone of groundwater drawdown. However, there are no Blue Gum communities along that section of Pillaworta Creek impacted by significant groundwater drawdown; the modeled drawdown 0.0 m contour runs through the patch of Blue Gums in Pillaworta Creek west of MC 4373 (see MLP Figure 7.9) so modeled drawdown is less than 0.5 m. As outlined in earlier responses, groundwater forms only one component of GDE water requirements, surface water and soil water also contribute. Except for summer, surface water flows along Pillaworta Creek would maintain phreatic vegetation but during summer there is potential for some pools near the Cullen’s residence to become dry and hence vegetation would be dependent on soil water during that period.
Australian Graphite Pty Ltd 50 MLA RESPONSE DOCUMENT SA Govt Issue #40 – Groundwater Impact on Pillaworta Creek
Further information is required regarding potential impacts of proposed mining activities on this section of Pillaworta creek, including: • An indicative range of potential water level changes throughout the year due to proposed mining operations • An assessment of whether there is the potential for complete stream dry out in sections due to proposed mining operations • An assessment of potential impacts on downstream pools and flow due to reduced and interrupted groundwater contribution to stream flow caused by proposed mining operations
Pillaworta Creek already dries out seasonally, although at Cullen’s floodway/ford, it is understood to flow for 9 months or more per year. If a reduction in groundwater levels due to dewatering of 0.5 m occurred beneath the creek, then the reduction in pool levels after 90 days of no flow from upstream and zero rainfall is expected to be in the range 0 – 0.33m (Figure 7-4). This is based on a vertical K of 0.0008 i.e. Kh/10, an initial condition of GW level = pond level and a drawdown in the potentiometric level of 0.5m in the vicinity of the pond. The rate of seepage will vary with the square root of time. The falling level in the pond will result in a slowing of the seepage as vertical gradients are reduced leading to an overall drop in pool level of 275.5mm over 90 days.
Figure 7-4 Potential effect on pools in Pillaworta Creek due to groundwater drawdown
Australian Graphite Pty Ltd 51 MLA RESPONSE DOCUMENT This would be the equivalent of an overall drop in pool level of 275.5mm over 90 days (Figure 7-5).
ASSUMING FALLING POOL HEAD
200 20
180 18
160 16
140 14
120 12 Cumulative Fall (mm) 100 10 Daily Fall (mm/day) 80 8
60 6 (mm/day) DailyFall Cumulative fall in WL(mm) in Cumulativefall 40 4
20 2
0 0 0 20 40 60 80 100
Time (Days)
Figure 7-5 Cumulative fall in pool water level over 90 days Total fall in Pool Level over 90 days = 275.5mm Note this is the worst-case scenario in the seepage scenario in which all flow occurs in the fully saturated condition. The potential impact on downstream pools outside of the drawdown cone is regarded as very low to negligible. These pools have lower elevations (ca. 125m AHD) and have been shown to have highly variable salinities and water depths during summer (MLP Figure 3.22). For example the two large pools approximately 1km southwest of the maximum zero drawdown contour and 2.2km southwest of Cullen’s ford, have salinities of 12700 to 18200 EC units compared to those near to the proposed pit which have salinities of the order of 5500 to 6200 EC units similar to groundwater at the proposed mine site. Therefore, these downstream pools are clearly not directly connected to groundwater flow in the vicinity of the proposed mine.
7.5 Surface Water
Issue #63 – Surface Water
Reference to the northern WRSF and its resultant runoff
It is assumed this item refers to the northwestern WRSF (WRSF West on MLP Figure 4.4) and not an earlier version of the proposed site plan (in 2013) that had a WRSF shown on the northern side of the pit in MC 4372. That proposed WRSF site was abandoned in favour of WRSF South. Key design features of the WRSF's will be further refined as site engineering design is finalised. Aspects for the design of WRSF and site operations will include stripping of topsoil and some subsoil prior to development of the WRSF, leaving a minimum of 2 m clay sub-soil to act as an impervious seal under the waste rock (NB the clay profile is at least 3 m thick in this general area). Internal drainage will be constructed so that any potential leachate is directed toward the pit. Waste rock material is to be dumped in benches approximately 10-15 m high with a maximum height of 60 m. Each batter is to be shaped to an angle of 20-30 degrees. Benches will be formed to allow runoff via regularly spaced drainage channels (spoon drains) of which will be constructed to withstand a 1-in-100 year ARI storm
Australian Graphite Pty Ltd 52 MLA RESPONSE DOCUMENT event. The berms will be sloped inward to reduce the amount of water on the batters. Water collected on the berms and plateau will be channeled to the spoon drains. A perimeter drain is proposed along the western edge of the WRSF West. This would capture any runoff from that facility and divert it to the silt sediment trap for monitoring (and treatment if required) before either site use or release to the environment. As discussed in MLP Section 7.5.4.1 the issues raised were recognised by AGL as an impact event (K31). Control and management measures were discussed in MLP Section 7.5.5.3. On the basis of the risk assessment in MLP Section 7.5.6, the residual risk following implementation of the management measures was assessed as low.
Issue #176 – Surface Water
AGL intends having ponds of kerosene and diesel to float the graphite off
Graphite is separated from other minerals by a flotation process in which the graphite ore is mixed with water and small quantities of reagents in flotation tanks or cells. Flotation reagents include small quantities of kerosene, MIBC frother and sodium silicate binder (MLP Table 4.27 and Figure 4.56). No use of diesel is proposed in the flotation process. All the flotation “ponds” or cells will be fully enclosed within the processing shed (MLP Photo 4.4 and Photo 4.6) and therefore not exposed to the outside elements. As described in MLP Section 4.7.2.6, kerosene is used as a collector reagent. Due to the unique oleophyllic nature of graphite (oil wetting), the small kerosene addition is immediately attracted by the graphite surface and forms an immiscible molecular coating which preferentially attaches to air bubbles during the flotation process allowing separation or “floating off” of the graphite from the non-activated gangue minerals. Therefore, kerosene is floated off with the graphite concentrate. The tails solids assay, refer MLP Table 4.40, was measured as <50 mg/kg, below the limit of reporting, and the tails water assays, MLP Table 4.41, show dissolved organic carbon as 14 mg/l. The Material Safety Data Sheets (MSDS) for kerosene and V80 kerosene indicate that the liquid at 14mg/l (14ppm) does not pose a risk to native fauna.
Issue #177 – Surface Water
The proposed mine site is within the Tod River Catchment…(AGL) have no true understanding of the local rainfall in this area…12 hour rainfall event 15-16 June 2014 over 85mm fell and resulted in creeks and fords overflowing and residents being unable to leave their properties. The DCTB has now erected 2m high flood markers at these crossings. Photos take at approx. 4pm on 16th June 2014, after floodwaters show the road damage on Pillaworta and Bailla Hill Road junctions, and debris caught on the fence up at head height. This debris has since been removed, strangely, and the locals wouldn’t and couldn’t be bothered. The force of this rainfall event was so huge that the pipeline across the Tod River below Reservoir, was such that the pipeline was swept off its’ concrete supports south of the causeway.
As outlined in the Air Quality Report (MLP Appendix C) and Response 3.8, existing Bureau of Meteorology weather monitoring stations were adopted and considered to be representative of climate and meteorology in the project region and for use in design decisions for the project. These stations included White Flat, Koppio and Yallunda Flat rainfall monitoring stations which are all located in the Koppio Hills area close to the proposed mine site and which have recorded rainfall for more than 100 years. They were supported by rainfall records maintained by a neighbour since 1929. As indicated in Section 3.8.2 and Section 7.5 in the MLP, the maximum Average Recurrence Interval (ARI) or annual exceedance probability of rainfall events was used for the tailings storage facility design and process water storages (Appendix H) in terms of additional storage required for rainfall events and ensuing freeboard and therefore no overtopping. This approach is also relevant to the diversion drain upslope of the TSF and other surface water control infrastructure in terms of the likely risks.
Australian Graphite Pty Ltd 53 MLA RESPONSE DOCUMENT The risk assessment in Section 7.5 indicated that implementation of the control and management measures would result in a low residual risk of impact. All stormwater infrastructure will be designed and maintained to withstand the water flows expected for a 100- year ARI storm event. AGL propose to upgrade Pillaworta Road to an all weather road and improve drainage. AGL did not remove any debris caught in fences.
Issue #178 – Surface Water
If a Tailings Dam had been constructed where proposed, would have contaminated the Tod River all the way down to the Tod mouth at the sea, into Fish farming and breeding areas, affecting the Clean, Green Fish farms and our many beautiful beaches
In the very unlikely event of an overflow of the Tailings Storage Facility (TSF), the initial overflow would be captured in the water storage pond immediately west of the TSF embankment wall and then, if that overflows, it would flow into the open pit. The TSF embankment wall is designed to have a minimum 1m “freeboard” above the standing water level to cater for at least a 1:100-year ARI and/or extreme wind-generated waves during any stage of its construction and operation. As discussed in MLP Sections 7.4 and 7.5 the residual risks for all potential impact events on Pillaworta Creek adjacent to the site, following implementation of the management measures were assessed as low. Therefore the potential impacts further downstream to the Tod River and the coast are considered not to be a viable risk.
Issue #275 – Surface Water
A second pipeline is to have water from the Tod Reservoir. The Tod Reservoir use ceased in 2002 because of contamination
As discussed above in Response 7.5, the proposed water for mineral processing will be initially sourced from the Tod Reservoir then supplemented by groundwater derived from mine dewatering. As stated in Section 3.10.1 of the MLP land clearance has increased the salinity of surface water (13 mg/L total dissolved solids (TDS) per year) in the Tod Reservoir since the 1930s, with average salinity in the Tod River reported at over 6,000 mg/L (Goonan et al. 2003). The edges of the rivers have largely been cleared to now support pasture plants, weeds and grasses. The Tod Reservoir previously contributed to Eyre Peninsula’s community water supply although its original intent was for stock supplies only. The Tod Reservoir, with a capacity of 11.3 GL, formed part of the water supply to the Eyre Peninsula until 2002 when it was taken offline due to increasing salinity. AGL is not proposing to use Tod Reservoir water for drinking and does not have to meet the Australian drinking water guidelines (ADWG). The proposed use of Tod Reservoir water is for industrial use (graphite mineral processing) and Tod Reservoir water meets that criteria. In consultation with SA Water they have communicated to AGL that from time to time pesticides exceed the ADWG but the water is fit for purpose with uses that are non drinking. SA Water has detected elevated readings of the chemical Simazine (an agricultural herbicide that is associated with agricultural practices in close proximity to the reservoir) from time to time. Some information in regards to Simazine and the environment are provided below from the MSDS. Breakdown in soil and groundwater: Simazine is moderately persistent with an average field half-life of 60 days. Soil half-lives of 28-149 days have been reported. Residual activity may remain for a year after application (2 to 4 kg/ha) in high pH soils. Simazine is moderately to poorly bound to soils. It is, however, absorbed by clay and mud but its low water solubility makes it less mobile, limiting its leaching potential. Breakdown in water: The average half-life of Simazine in ponds where it has been applied is 30 days, with the actual half-life dependent on the level of algae present, the degree of weed infestation, and other factors. Simazine may undergo hydrolysis at lower pH. It does not readily undergo hydrolysis in water at pH=7. Breakdown in vegetation: Plants absorb Simazine mainly through the roots, with little or no foliar penetration. From the roots, it is translocated upward to the stems, leaves, and growing shoots of the plant. It acts to inhibit photosynthesis. Resistant plants readily metabolize Simazine. Plants that are sensitive to Simazine accumulate it unchanged.
Australian Graphite Pty Ltd 54 MLA RESPONSE DOCUMENT Issue #285 – Surface Water
Method to try to suppress the dust within the mining operation is to spray non potable water onto the road systems and operational areas of the mine, this can lead to contaminated water leaching into the waterways. Which in turn will have a direct effect on the surrounding land.
Refer also to Issue #275 above (Response 7.5). The potential impact of use of saline water from the Tod Reservoir or from groundwater derived from mine dewatering will be mitigated by: • Avoiding over spray with saline water through controlled application • Post operation areas where saline water was applied will be ripped/scarified to assist vegetation establishment and rehabilitation. • Design of roads and trafficable areas with drainage control measures that reduce the potential for salt build up in soil and runoff to vegetated areas. • Haul road surfaces and surfaces around stockpiles will be treated with a bitumen-based polymer to reduce the water needed for dust suppression. • Dust suppression using water carts and sprinklers will be undertaken during construction and operations. • Temporary stockpiles will be hydro-seeded to stabilise soils if the soils will not be re-used within one month. • Progressively revegetating the WRSFs during mining operations; • Monitoring runoff from catch drains around the WRSFs before release to the environment; • Ore stockpiles would be processed so any salinity build-up would go into the process plant; • Conduct bi-annual and/or as-required flora surveys to demonstrate no net adverse effect. The implementation of these mitigation measures would significantly reduce the likelihood to unlikely and the risk to low of salinity buildup and/or contamination of waterways and the surrounding land.
Issue #760 – Surface Water
There is no agreement with DCTB or local land owners for the location of pipeline from Tod Reservoir..
AGL proposes to enter into a MOU and Management Plan with DCTB and SA Water regarding the preferred route for and construction of the pipeline and has discussed placing the pipe in the shoulder of the existing road network to the mine site thus eliminating the impacts on any vegetation and landowners. AGL is investigating various pipeline solutions for the proposed Tod Reservoir pipeline and one option being considered is the NovaLine Spoolable Pipe. NovaLine™ is a flexible, corrosion resistant, high pressure, spoolable pipe system. NovaLine™ has been developed using specific composite materials to meet a range of pressure and application requirements. NovaLine™ has been developed for use in gas or oil gathering, and water or gas injection applications. The unique construction makes it suitable for either burial or laying on the surface. It is long-life (~25 years) UV resistant and will not crush, fracture or burst if driven over by heavy equipment. It can be easily removed following cessation of mining operations.
Photo 7-1 NovaLine™ flexible, corrosion resistant, high pressure, spoolable pipe
Australian Graphite Pty Ltd 55 MLA RESPONSE DOCUMENT Issue #784 – Surface Water
A catch drain/diversion channel to intercept surface water flows will be sized and constructed around the TSF and….redirected to the Pillaworta Creek. What are the water sensitive design and treatment techniques?
Water sensitive design refers to capture and redirection of surface water run-off to maintain environmental flows into Pillaworta Creek rather than discharging directly to downstream areas such as the TSF which would mean that water would be lost to the environment. Water sensitive treatment refers to the implementation of sediment traps to reduce any potential sediment/silt load being transported into Pillaworta Creek. The diversion channel is designed to intercept surface water runoff (not mine impacted) that currently drains into the Cullen creek above the site of the proposed TSF and direct it into the Harris creek immediately to the south. The expanded catchment area was calculated to be 164.63 hectares (an increase of 24.7 hectares above the existing catchment area of the Harris creek). Modelling was undertaken using the DRAINS modelling package by a Parsons Brinkerhoff engineer. The DRAINS model of the proposed diversion network calculated peak flows in the Harris creek would reach 6.44 m3/s in a 100-year 24 hour storm event, and 1.39 m3/s in a 10-year 20 min storm event. This represents a slight increase over the existing modelled peak flows in the Harris creek (5.74 m3/s in the 100-year 24 hour storm event, and 1.16 m3/s in the 10-year 20 min storm event). Based on the above results, at Chainage 396 adjacent to a stand of Eyre Peninsula blue gums in Harris creek, the expected increase in the depth of water is approximately 62mm in the 100-year 24 hour storm or 25 mm in the 10-year ARI 20 min event. The peak flow time period above existing peak flows is 21 minutes. No changes to water quality are anticipated as surface water will be intercepted prior to any mine workings. As outlined above, a small increase in volume will be anticipated down the Harris creek. The timing and duration of these events are weather-dependent (i.e. the present situation). The above assessment indicates a marginal increase in water levels within Harris creek resulting from storm events as a result of the proposed diversion. The flow is then dissipated within a short time frame following the storm. It is considered that there is subsequently a very low to no risk of waterlogging.
Issue #1080 – Surface Water
Reference is made to an arbitrary standard the GAI (Geochemical Abundance Index), which could for convenience be described as a fudging figure
One measure of enrichment of elements in whole rock samples is the Geochemical Abundance Index (GAI). The GAI compares the actual concentration of an element in a sample with the median abundance for that element in the most relevant media (such as crustal abundance, soils, or a particular rock type). The main purpose of the GAI is to provide an indication of any elemental enrichments that may be of environmental importance. The GAI for an element is calculated as follows: • GAI = log2 [ C / (1.5*S) ] where C is the concentration of the element in the sample and S is the median content for that element in the reference material (mean world soil, crustal abundance, etc). The GAI values are truncated to integer increments (0 through to 6, respectively) where a GAI of 0 indicates the element is present at a concentration similar to, or less than, median abundance and a GAI of 6 indicates approximately a 100-fold, or greater, enrichment above median abundance. The actual enrichment ranges for the GAI values are as follow: • GAI=0 represents <3 times median soil content • GAI=1 represents 3 to 6 times median soil content • GAI=2 represents 6 to 12 times median soil content • GAI=3 represents 12 to 24 times median soil content
Australian Graphite Pty Ltd 56 MLA RESPONSE DOCUMENT • GAI=4 represents 24 to 48 times median soil content • GAI=5 represents 48 to 96 times median soil content • GAI=6 represents more than 96 times median soil content As a general guide, a GAI of 3 or above is considered significant and such an enrichment may warrant further examination.
7.6 Air Quality
Issue #8 and #9 – Dust
An analysis of the data provided indicates the existence of a significant number of minerals within the ore body that are potentially harmful to human health and plant health. These include not only the graphite, but Chromium, Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium together with Copper, Magnesium and Zinc. These minerals are potential carcinogens and or neurotoxins in humans and growth inhibitors in plants. The nature and health impacts together with potential agricultural industry impacts of the dust emanating from mining operations
As shown in MLP Table 4.5 the concentrations of base metals and other elements within the ore and host rocks are low hence, since the dust will be derived directly from these rocks, the resultant concentrations of these elements in operational depositional dust will also be low. XRF and ICP analysis of samples of the subsurface materials which will be mined (including waste rock) from the Kookaburra Gully project was undertaken (Table 4.5 of MLP). In addition, for comparative purposes, the heavy metal contents within existing surface soils were also analysed by XRF. The soil geochemical analysis is considered to be a representative presentation of heavy metals within soils of the Kookaburra Gully mining area. The results of the soils analyses are summarised in Figure 7-6 and Table 7-2 below, and are similar to the elemental abundance in crustal matter (Table 4.3 of Appendix I of MLP).
Existing(heavy(metal(content( within(the(surface(soil( Presented(as(percentage( Chromium! ( Copper!! 0.008%! Manganese! Nickel!!
Figure 7-6 Metals analysis of insoluble elements in surface soil material (down to 0.8m depth) at Kookaburra Gully The soils in the Kookaburra Gully area have been developed in-situ and are not wind-blown or regionally transported soils. There has been local transport due to erosion, down-slope runoff and wind-blown dust from cultivated fields but the soils have not been derived from sediments or rocks distal to the area. Therefore, existing soils at Kookaburra Gully are of similar composition to the rocks and exposed regolith in the immediate area and, for example, contain graphite. Consequently, as shown below, dust derived from mining operations will be similar in composition to dust derived from existing soils and agricultural activities.
Australian Graphite Pty Ltd 57 MLA RESPONSE DOCUMENT The baseline maximum monthly dust deposition concentrations were recorded to be, on average, 2200 mg/m2/month across 5 different monitoring stations (Table 5.2 of the Air Quality Impact Assessment (AQIA) report in Appendix C of the MLP). The contribution from mining operations to deposited dust at Receptor 1 was projected to be 300 mg/m2/month (Table 8.4 of the AQIA report), and therefore a maximum cumulative contribution of 2500 mg/m2/month would occur at Receptor 1. As indicated in Section 3.7 of the MLP, the NERDC guideline level of 4000 mg/m2/month (but typically presented as 4 g/m2/month) was adopted as there is no SAEPA level specified in legislation or guidelines. This concentration has been adopted by Victoria and NSW. Therefore in the absence of a South Australia guideline level the 4000mg/m2/month level is considered appropriate and the cumulative dust deposition at Receptor 1 is well within that guideline. To assess the heavy metal composition of the existing pre-mining dust, a conservative approach was adopted by using the average analyte concentrations across the 34 spatially distributed surface soil samples noted above (Figure 7-6 and Table 7-2). The conservative estimate of chemical content of existing dust generating sources is shown in the table below and the estimated baseline was calculated using the following formula (using copper as an example): 0.003% x 2200 = 0.07 Cu mg/m2/mth.
Table 7-2 Existing heavy metal dust composition based on XRF analysis of surface soil samples from a depth of 0-0.8m
Average content Average metal Average found in surface content of baseline percentage of soil (parts per dust (existing) sample composition Element million) (mg/m2/mth) Chromium 101.1 0.01% 0.22 Copper 31.8 0.003% 0.07 Manganese 196.4 0.02% 0.43 Nickel < 50.0 < 0.005% 0.011 Lead 14.9 0.001% 0.033 Strontium 41.0 0.004% 0.09 Thorium 14.9 0.001% 0.033 Uranium < 10.0 <0.001% <0.022 Zinc 84.3 0.008% 0.19 Rare Earths (Sc) < 20.0 <0.002% <0.044
The potential heavy metal content contained within deposited dust as a result of mining activities was calculated based on assay data presented in Table 4.5 of the MLP and is summarised below in Figure 7-7.
1000" Soil" Mining"Dust" Crustal"Abundance" 100"
10" Composi'on)(parts)per)million))
1"
Lead" Zinc" Nickel" Copper" Thorium" Uranium" Stron:um" Scandium" Chromium" Manganese"
Australian Graphite Pty Ltd 58 MLA RESPONSE DOCUMENT Figure 7-7 Crustal abundance and average metal content in soil and potential mine dust
The open pit and waste rock storage facilities were identified as potential sources of heavy metal elements. However as a conservative estimate, all emission sources were considered to contain metals. Based on that criteria, the mining activities will result in dust deposition on adjacent areas (depending on climatic/wind conditions) and using deposited dust modelled simulations from the Air Quality Impact Assessment (AQIA) report in Appendix C of the MLP, deposited dust projections were assessed. Based on the geochemically analysed samples from the Kookaburra Gully drilling program (summarised below in Table 7-3) are representative of the waste rock storage facilities, tailings facility and open pit, the potential levels of chemical analytes were calculated. The concentrations shown in Table 7-3 are a weighted average based on the approximate proportions to be mined of graphite schist to biotite schist, gneiss and marble. Using the predicted incremental annual dust deposition rate attributed from mining activities at Receptor 1 (300 mg/m2/mth) and the percentage metal content in the emissions (EG Cu = 0.004%), the annual average quantity of deposited metal (EG Cu) from mining every month would be: 0.004% x 300 = 0.012 Cu mg/m2/mth. The basis of this calculation is shown below: Table 7-3 Total mine-generated analytes for the modelled scenario at Receptor 1 Weighted average Percentage background Weighted Average contribution of chemical average estimated heavy metal concentrations percentage of metal content loading from Element (from pit and estimated of dust from mining waste rock mine rock mining operations to areas) composition (mg/m2/mth) total dust (parts per content million) Chromium 48.0 0.005% 0.014 6.1% Copper 40.8 0.004% 0.012 14.9% Manganese 296.2 0.03% 0.089 17.1% Nickel 30.6 0.003% 0.009 7.7% Lead 8.0 0.001% 0.002 6.8% Strontium 18.3 0.002% 0.006 5.7% Thorium 15.2 0.015% 0.005 12.2% Uranium 3.6 <0.001% 0.001 4.6% Zinc 59.3 0.006% 0.018 8.7% Rare Earths (Sc) 8.0 0.001% 0.002 6.8%
Based upon this estimate, chemical analytes from mining operations will result in annual quantities ranging from less than 0.001 mg/m2/mth (Uranium) to 0.089 mg/m2/mth (Manganese) at Receptor 1 considering an estimated dust depositional contribution of 300 mg/m2/mth. Considering the existing baseline levels, mining alone contributed to no more than 17.1% of the total quantity of chemical analytes (Manganese), as shown in the summary below (Figure 7-8).
Australian Graphite Pty Ltd 59 MLA RESPONSE DOCUMENT ! Figure 7-8 Estimated quantity of heavy metal contributions from both mining and existing (baseline) soil contributions at Receptor 1. It has been suggested in comments received during the public consultation period for the MLP that dust generated from site operations would result in heavy metal contamination of the crops, potentially harmful to human health and plant health and rainwater tanks. Receptor 1 is representative of the maximum monthly mine-generated dust deposition on cropped farmland immediately outside of the proposed mining lease (MLP Figure 7.15). The modelling undertaken for the project indicates that dust deposition is low and the extent of deposition is within close proximity to the proposed operations. Dust deposition contour plots as shown in Section 7.6.4.3 show that dust impacts will be restricted to the area of the proposed mining lease and are not expected to significantly impact on adjacent cropping land. Incremental and cumulative dust deposition levels were shown to be below the adopted NSW EPA levels. The MLP provides a summary of the proposed control and management measures for the mining operations: • The use of in-pit crushing where possible which will reduce emissions • Clearance of only the land required for operations and progressive rehabilitation • Covering of temporary stockpiles as soon as achievable • A high level of dust suppression would be achieved through the application of water and other water- based inhibitants such as polymers/crusts • Implementation of a dust management plan incorporating real time monitoring of dust emissions, weather forecasting which will enable early identification of potential dust issues, and adoption of management strategies specific to the event (for example a roadside point monitoring of a given particulate size fraction can be used to assess a range of control measures such as vehicle speed restrictions and chemical dust suppressant applications). • Site based tests will be undertaken to reduce and eliminate dust emission sources through the application of dust suppression treatments. Onsite testing during construction of unpaved roads will determine the silt content (material <75µm) and if greater than 10% silt content, gravel applications can be made to reduce the silt fraction. References in the literature (Doley 2006 and Doley and Rosatto 2010) suggest that plants with broad leafs begin to show impacts at levels greater than 7g/m2/month, which is higher than the predicted levels from mining operations. The modelling undertaken in the MLP indicated small increments in dust deposition above the current background levels external to the site. It should also be noted that the crop-growing season occurs when there is a high likelihood of rainfall which would suppress any dust from the project site and also remove dust from plant surfaces. The proposed real time monitoring and weather forecast information will enable modification or suspension of site operations that have the potential to generate dust. It is therefore concluded that there is a low risk that the mine-related dust will have an impact on crop yields beyond that that will be caused by normal farming and public road activities. Similarly the risk of contamination of tank water is considered to be low on the basis of the analysis above and distances to receptors. The target level of 4g/m2/month was adopted by the NSW and Victoria EPAs as the basis for negligible impacts on amenity.
Australian Graphite Pty Ltd 60 MLA RESPONSE DOCUMENT In conclusion the proposed air quality control and management strategies for the site are considered to result in potential impacts and risks that are considered to be “As Low As Reasonably Possible” (ALARP).
Issue #10 – Dust
In the absence of on-site meteorological data, the dispersion pattern modelled from data remote from the site is of concern, given the potential nature of the contaminant within the dust and their impact upon humans and plants alike. There is no consideration given to the impact upon pastures and thence animals whom ingest these contaminants over a period of time.
Refer to issues #8 and #9 in regard to impacts upon humans, pastures and animals, and Response 3.8 regarding meteorological data. Furthermore, recent research by a graphite explorer on Eyre Peninsula (Archer Exploration Limited) has identified that graphite could be used as a soil conditioner/fertilizer and can also improve moisture retention capability of soils. Farming ventures rely on the application of fertilizers to provide macro-nutrients (nitrogen, phosphorus, potassium, calcium, magnesium) and micro-nutrients (trace elements such as copper, iron, manganese, molybdenum, zinc, boron and chlorine) to enhance soils that have been leached of nutrients over the years. Graphite is an inert substance and is NOT toxic. It is the “lead” in our pencils, is used for medical applications and is used in numerous applications where it is subjected to very high temperatures without giving off any fumes or burning.
Issue #11 – Dust
Economic losses attributed to the impact of copper, magnesium and zinc (in excess of trace levels) on grain production
Refer to Issues #8, #9 and #10 above. A deficiency of any trace element in the soil can limit plant growth even when all other essential elements are present in adequate amounts. In South Australian soils, zinc, manganese and copper are often deficient or insufficiently available. In acid soils, molybdenum availability is reduced often resulting in crop deficiency. Copper deficiency in South Australia is most commonly found on highly calcareous or ironstone soils (such as found in the immediate vicinity of the proposed mine) as well as in siliceous sandy soils with low organic matter levels. High soil concentrations of other metals such as iron, magnesium and aluminium can induce copper deficiency. Zinc deficiency in agricultural crops is one of the most common micronutrient deficiencies. It is deficient in a wide range of soil types. Soils with less than 0.3 mg/kg of zinc are likely to require added zinc for optimum crop production (with highly alkaline soils, the critical level may be up to 0.8 mg/kg). Manganese deficiency is most common in alkaline and calcareous soils and is particularly severe in crops and pastures grown on highly calcareous sands (60-85% free lime). It also occurs on slightly acid sandy soils, lateritic soils, peat soils and poorly drained soils. The Kookaburra Gully graphite project is enriched in graphite particularly carbon, not copper, magnesium, lead or zinc. The level of these elements will not be concentrated or significantly elevated by any mining related activity and will remain at their current concentrations and background levels.
Issue #13 – Dust
Potential contamination of rain water, the main source of drinking water for the area
Refer to Issues #8 and #9 above.
Australian Graphite Pty Ltd 61 MLA RESPONSE DOCUMENT AGL proposes to establish a real time dust monitoring system (TBAMS) and will monitor rainwater tanks of any concerned landowners within 4 kms of the ML boundary (Figure 7-9), even though the air quality 3 modelling shows that PM10 concentrations would be well below 50 µg/m at this distance. Predicted 3 cumulative impacts for annual average PM10 concentrations are less than 15 µg/m at all sensitive receptors (houses) except the Cullen’s property immediately over the road from the proposed mine site. At that site it is modelled as 17.4 µg/m3 which is well below the National Environment Protection Measure (NEPM) goal of 30 µg/m3. Should monitoring of rainwater tanks display elevated mine related dust impacts as a result of mining activities and onsite meteorological records confirm dust impact, AGL offers to provide first flush systems for affected rainwater tanks.
Figure 7-9 1 km and 4 km buffer zones around Kookaburra Gully Mineral Claims
Issue #14 – Dust
Impact of the contaminated dust reaching the township of Tumby Bay having regard to the topography (height above sea level of the proposed mine) and the wind direction (and velocity) towards Tumby Bay.
Refer to Issues #8 and #9 above - Tumby Bay is located 17km due east of the Mineral Claim eastern boundary, well beyond any potential dust impacts from the proposed mine site. There will be no dust impact related to the Kookaburra Gully project on the township of Tumby Bay.
Issue #15 – Dust and Surface Water
Impact on surface water contained within the Tod River Water Protection Zone (as per the DCTB Development Plan) or the Tod River Wetland of National Significance.
Australian Graphite Pty Ltd 62 MLA RESPONSE DOCUMENT The project area is within the Tod River Water Protection Zone. Surface water in the project area is not prescribed, however, permits under the NRM Act are required for ‘water affecting activities’, such as the diversion of an ephemeral watercourse, or implementing surface drainage structures for mine haul roads. As described in MLP Section 7.5.7 the impact of proposed mine infrastructure on drainage into Pillaworta Creek will be negligible but may increase slightly due to diversion of water from above (east of) the TSF. In the past most of this water has been captured in a farm dam or has soaked or been absorbed into the soil. Only on occasions of high rainfall does this water flood across Pillaworta Road into Pillaworta Creek. On the basis of the proposed control and management measures for dust control (MLP Section 7.6.5) and surface water management (MLP Section 7.5.7) it is considered that the residual impacts are likely to be very low and acceptable.
Issue #56 – Dust
The nature and health impacts together with potential agricultural industry impacts of the dust emanating from mining operations are inadequately described in the Application. This includes the lack of information in relation to requirements of the National Residue Monitoring Scheme
Impact of contaminants in dust on humans and grains Refer to Issues #8, #9, #10 and #11 above. The discussion in relation to residue levels on crops etc is based on the Maximum Residue Limits (MRLs) in the Commonwealth Department of Agriculture and Water Resources website which reference the National Residue Monitoring Scheme. http://www.agriculture.gov.au/ag-farm-food/food/nrs/about-residues-and-residue-testing Therefore the information provided in the AGL response is considered relevant. The only elements specified are copper mercury, cadmium and lead. The maximum levels set are consistent with the protection of public health and safety. The information in the above web site indicates that where “No limit” is used for environmental contaminants then the as “low as reasonable achievable” principal applies and detection at low levels is allowed. As indicated in the earlier response and in the response above, the concentrations associated with deposited dust from the site indicates that very low chemical concentrations result. Therefore, based on the proposed site management measures, the risk to human health, crops, pasture, water tanks and soils is as “low as reasonably achievable” and consistent with the intent of the Commonwealth guidelines. Impact on pastures and animals through ingestion The impact on animals including stock is related to the uptake through consumption of vegetation, water or soil (consumed in conjunction with grasses). The modelling undertaken for the project indicates that dust deposition is low and the extent of deposition is within close proximity to the proposed operations. As indicated in Section 7 of the MLP the proposed control and management measures that will be adopted are considered to be reasonable and appropriate to mitigate potential impacts. In agriculture, the term ‘residue’ is generally used to describe the small amounts of agricultural and veterinary chemicals, or their breakdown products, that remain in or on an agricultural product. In the broader context of food safety, a substance can be defined as a ‘contaminant’ if it is ‘an impurity which gives consumers health, safety or cleanliness concerns’. Contaminants include residues arising from the use of pesticides and veterinary medicines, heavy metals (e.g. mercury, cadmium, lead), naturally occurring chemicals such as mycotoxins (toxins produced by certain fungi) and microorganisms. All of these may be present in food, either through natural circumstances or as a consequence of industrial or agricultural activities. Chemicals that may be detected as residues include: • antibiotics used to control bacterial diseases in animals • anthelmintics used to control internal parasites in animals • fungicides used to control fungal diseases in plants and plant products • insecticides used to control insect pests in crops, protect stored grain and control external parasites on animals
Australian Graphite Pty Ltd 63 MLA RESPONSE DOCUMENT • herbicides used to control weeds in crops • fumigants used to protect grain and sterilise soil, sheds and bee hives • hormonal growth promotants used as veterinary medicines or to improve growth in livestock. Refer also to Issues #8, #9, #10 and #11.
Issue #180 – Dust
Breathing air with radioactive and heavy metal particles in it.
As shown in MLP Table 4.5 the concentration of base metals and uranium within the ore and host rocks are very low and the resultant concentrations of these elements in operational depositional dust will also be low. The levels of radioactive materials (uranium and thorium) within the ore and host rocks are below the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) exemption limits of 1 Bq/g2. Uranium and thorium concentrations detected in drilling samples cover all aspects of hanging wall to footwall lithologies, and the graphite deposit. The conversion between Bequerel per gram (Bq/g), and parts per million (ppm) varies with each radionuclide. The conversions below may be helpful to interpret data. • For uranium: 1 Bq/g = 80ppm • For thorium: 1Bq/g = 240ppm Both uranium and thorium occur naturally, with worldwide average concentrations being 0.035Bq/g for uranium (3ppm) and 0.030Bq/g for thorium (7ppm). Since all soils and ores contain some uranium and thorium, an exempt concentration limit must be used to prevent unnecessary regulation. Unfortunately this exempt limit varies across Australia’s regulatory jurisdictions. ARPANSA is the national radiation regulatory body, and they define the uranium and thorium activity concentration exempt limit as 1Bq/g2. That is, ore containing less than 80ppm uranium or less than 240ppm thorium is not considered radioactive. Most State and Territory regulatory bodies have either adopted this exempt limit, or plan to adopt it as soon as practicable (Dr Kent Gregory, SA Radiation Pty Ltd, June 2015). As there will be no action taken to concentrate uranium and thorium (or progeny) in the waste rock and tailings, there is no radiological risk posed with this project.
Issue #182 – Dust
Dust contamination of water flowing into Lake Wangary and then Coffin Bay….risk to tourism and aquaculture at Coffin Bay
Section 5.2.1 in Appendix C of the MLP provides information on wind speed and directions. On an annual basis the prevailing wind direction originates from the northern and southern quadrants. During summer the prevailing wind directions are dominated by winds originating from the south quadrant and to a lesser extent the south east. In the autumn winds come from the north quadrant and with contributions from the southeast. The winter winds are from the north and spring shows a transition from winter to summer wind directions, with the inclusion of more winds from the south. The air quality assessment indicates that annual average total suspended particulate concentrations 30 micrograms/m3 within 2 km of the site (and within the Kookaburra Gully water catchment) and well below the NHMRC guideline level of 90 micrograms/m3. In addition the dust deposition levels, adopting the criteria of 4grams/m2/month are wholly within the proposed ML. AGL will ensure that total dust deposition (including both ambient and mine related dust) does not exceed 4g/m2/month averaged over all 12 month periods.
Australian Graphite Pty Ltd 64 MLA RESPONSE DOCUMENT Minor tributaries to water ways that discharge to Lake Wangary and thereafter to Coffin Bay are located about 10 km west of the proposed ML in separate water catchment areas and not along the prevailing wind directions as discussed above. Therefore it is contended that there is no credible risk of site activities impacting water quality in Lake Wangary and Coffin Bay.
Issue #621 – Dust
Potential contaminated dust will travel a lot further than modeling suggests. Predicted cumulative impacts for annual average PM2.5 concentrations do not spread as far as PM10. AGL nearly have the dust confined within their mine site. Impossible with the winds we have in the Koppio hills
The assessment in MLP Appendix C indicates the distribution of PM2.5 and PM10. The concentrations predicted by the modelling do not exceed NEPM criterion for any sensitive receptors. AGL will comply with the Ambient Air Quality National Environmental Protection Measure (NEPM) dust concentration standard for PM2.5 leaving the site, measured over a 24 hour period and will instigate a comprehensive dust monitoring program for the minimum duration of one year once mineral processing commences. AGL will investigate using PM10 measurements as a proxy for PM2.5.
Issue #750 – Dust
Most significant emission of concern is particulate matter, as a result of the development and operation of the open pit, WRSFs and, to a smaller extent, graphite- processing plant…. A small fleet of mobile equipment for loading/dumping of ore and fresh rock waste will also contribute to dust via movement on haul roads causing wheel generated dust and loading and dumping of product. Wind erosion will generate fugitive emissions from the pits, WRSFs and stockpiles.
An assessment of the potential air quality impact was included in Appendix C and a risk assessment of dust emissions in Section 7.6.6. The control and management strategies that will be adopted for the project were provided in Section 7.6.5.1. It was concluded that the risk of health impacts to the community and sensitive receptors was low.
Issue #277 – Air Quality
Impact of diesel fumes and ultra-fine particulate matter on neighbours and animals adjacent to the mine.
As described in Section 7.6.2.2 diesel emissions are not considered to be of significant quantities to affect air quality and will conform to the limits as outlined in the Environment Protection (Air Quality) Policy 1994. A review of the emissions from diesel generators and vehicle emissions was undertaken in Sections 6.2.4 and 6.2.5 of the Air Quality Assessment in Appendix C of the MLP. It was concluded that emissions from both sources would diffuse readily and were not anticipated to impact sensitive receptors.
SA Govt Issue #22 – Air Quality/Background Data
Conduct a sensitivity analysis on the air quality model by varying the background concentration data inputs and reporting on the change in the number of days of exceedances at Receptors.
2013 background contributions assessed in the Air Quality Impact Assessment (AQIA) report in Appendix C of the MLP were from the proposed Fusion Project, located 6km south west of the proposed mine. The monitoring site has similar topographical features, vegetation distribution and land uses to the proposed mine
Australian Graphite Pty Ltd 65 MLA RESPONSE DOCUMENT site. It is therefore reasonable to consider the surrounding air shed of the Kookaburra Gully project site similar to Fusion’s TEOM monitoring site location. It is concluded that the Fusion Project data is representative of baseline conditions. For 2013, although there is a higher than average monthly rainfall for June, July, August, September and November, the rainfall is less than the monthly annual average for January, February and March, as shown in Figure 5.3 of the AQIA report. It should also be considered that during the summer months from January (including March), the subtropical high pressure belt shifts south, and frontal activity results in north to south, and hot, dry easterly wind changes. Along with increasing wind speeds, and a decrease of precipitation, and would not suppress and cause an atypical year of air pollution data. On that basis the 2013 year is not considered to be atypical.
SA Govt Issue #23 – Air Quality/Dust Modelling
Provide a justification for using the 95th percentile in the air quality modelling for PM10.
th In the AQIA report, the 95 percentile PM10 daily average concentration was adopted as the background level th of air quality emissions in the predicted maximum 24-hour average PM10 concentrations. The term “95 percentile” was used by the air quality consultants because there was not a full year of baseline air quality data available. Rather, 346 days of daily average background levels were available for input to the air quality model. 1 US EPA recommendations use the 95th percentile for the 24-hour average PM10 concentration, and it adequately represents the background levels in air quality assessments. The US EPA is used as part of the Approved Methods for the Sampling and Analysis of Air Pollutants in New South Wales (Department of Environment and Conservation, 2005)2. Although South Australia does have its own set of air quality guidelines, it is for analytes only, and is designed for emissions discharged into the atmospheric (predominately from stacks) and centres around air quality when it reaches the ground level3. 1 Environmental Protection Agency (1997) Part II: National Ambient Air Quality Standards for Particulate Matter; Final Rule. 40 CFR Part 50 2: Department of Environment and Conservation (NSW) (2005) Approved methods for the Modelling and Assessment of Air Pollutants in New South Wales. DEC 2005/361 3 Government of South Australia (2006) Air quality impact assessment using design ground level pollutant concentrations EPA Guidelines EPA 386/03.
Provide in the response document a new version of Table 8.1 and Figures 8.1 and B.1 including 100% of the data for PM10.
As noted above, the original Air Quality report (MLP Appendix C) used the 95th percentile for baseline air quality daily average background levels for data!because there was not a full year of baseline air quality data available. To remedy this, the air quality consultants have estimated and added 19 days of data to make up a full year data set. To determine the 100th percentile concentrations, missing data have been replaced with representative 3 maximum PM10 baseline level daily data (36 ug/m ), where dust storms, bushfires and other naturally induced dust events were not occurring. At each receptor, the remaining 5% of data has been added as the estimate of maximum PM10 to the dispersion model daily PM10 predictions to provide the corresponding measured background concentration. The concentrations at each receptor were recalculated to determine the 100th percentile total impact for the relevant averaging, and the annual average adjusted accordingly. The updated results of the dispersion modelling are presented below. The worst case impacts have been predicted for the 24 hour and annual averaging periods at 13 sensitive receivers, using the 100th percentile for baseline air quality measurements.
The predicted maximum 24-hour average PM10 incremental and cumulative impacts for the most impacted day PM10 results are presented in Table 7.4 (replaces MLP Table 8.1 in MLP Appendix C) for particulate emissions. Annual average results are presented in Table 7-5 (replaces MLP Table 8.2 in MLP Appendix C).
Australian Graphite Pty Ltd 66 MLA RESPONSE DOCUMENT th Table 7-4 Predicted impact for maximum 24 hour average PM10 (µg/m3) (by 100 percentile)
PM 24 Project’s PM 24 hour 10 10 hour contribution to incremental Days of predicted cumulative total PM 24 average 10 exceedances at average hour emissions receptor 2013 (µg/m3) (µg/m3) (%) Objective 50 Max 43.8 58.5 75% 2nd 40.7 42.3 96% rd 4 3 29.2 49.0 62% th Refer to Appendix B.1 R1 4 28.3 57.8 49% of MLP Appendix C for 5th 20.5 55.8 38% contemporaneous analysis. 6th 18.9 51.4 36% 7th 18.7 36.8 50% Max 26.6 30.60 87% 2nd 18.3 36.40 50% 3rd 15.9 44.30 36% R2 0 4th 15.9 31.10 51% 5th 15.1 19.10 79%
Max 19.0 29.7 64% R3 0 2nd 11.4 19.3 59% Max 7.1 11.1 64% R4 0 2nd 4.6 22.20 20% Max 8.1 11.6 70% R5 0 2nd 7.7 9.9 77% Max 9.0 10.9 83% R6 0 2nd 7.0 8.8 79% Max 7.6 21.1 36% R7 0 2nd 5.2 7.0 74% Max 2.9 4.7 61% R8 0 2nd 2.5 6.4 40% Max 7.09 14.9 47% R9 0 2nd 6.76 17.5 39% Max 13.4 16.0 84% R10 0 2nd 5.64 22.4 25% Max 5.43 20.2 27% R11 0 2nd 5.09 6.7 76% Max 14.2 18.2 78% R12 0 2nd 5.29 23.4 23% Max 25.9 29.9 87% R13 0 2nd 17.8 33.0 54%
Australian Graphite Pty Ltd 67 MLA RESPONSE DOCUMENT 3 Table 7-5 Predicted impact for annual average concentrations PM10 (µg/m ) ID Incremental Cumulative Annual average Annual average Goal 30 30
R1 4.4 19.40 R2 1.9 16.90 R3 0.7 15.70 R4 0.2 15.20 R5 0.4 15.40 R6 0.4 15.40 R7 0.5 15.50 R8 0.2 15.20 R9 0.3 15.30 R10 0.5 15.50 R11 0.4 15.40 R12 0.3 15.30 R13 1.4 16.40
Cumulative impacts were predicted to be exceeded on 4 days in 2013 at R1 (Table 7.4 and Figure 7-10). This was predicted to occur on the: 16th June (58.5 µg/m3), 24th April (57.8 µg/m3), 13th February (55.8 µg/m3), and 20th December (51.40 µg/m3). On the days of these exceedances, the adopted background Fusion air quality dataset of the 24-hour average PM10 concentration contributed between 25 % and 64 % of the PM10 cumulative concentration predictions, with the project’s activities contributing to the other portion. The third column in Table 7.4 displays the maximum incremental impacts, which is ranked by the highest concentration, and this is to give an indication of the impacts of the mine alone.
Figure 7-10 Incremental and cumulative 24 hour PM10 concentrations (2013) at Receptor 1.
The 24 hour maximum average PM10 concentration is met at all other receptors (R2 to R13), as indicated in Table 7.4.
It should be noted that the cumulative PM10 24 hour average predicted concentrations at R1 were just above 3 the air quality criteria of 50 µg/m . Discounting R1, 24-hour PM10 is compliant with the NEPM goal for this assessment.
Australian Graphite Pty Ltd 68 MLA RESPONSE DOCUMENT The results indicate that maximum incremental and cumulative PM10 annual impacts are predicted to meet air quality goal of 30 µg/m3 annual average (Table 7-5) at all of the sensitive receptors.
Review of the PM10 contour plots indicates that predicted maximum dust concentrations at the private residences surrounding the mine have the potential to exceed ambient air quality goals at nearby sensitive receptors for incremental 24-hour PM10 predicted concentrations (Figure 7.10). Mine management would monitor dust concentrations at these locations to ensure employee exposures to particulates are satisfactory.
Incremental impacts for the maximum 24-hour average and cumulative annual averages for PM10 concentrations are presented below in Figure 7-11 and Figure 7-12 respectively. The National Pollution Inventory (NPI) (Department of Sustainability, Environment, Water, Population and Communities, 2012) was used for calculations to simulate dust being emitted into the ambient atmosphere. The manual contains emission estimation techniques and emission factors for particulate matter PM10 and TSP. The most up to date versions of this manual were used, which have been updated to suit the new USEPA AP-42 emission factors. The operation was modelled on an assumption of control techniques from the manual. An Air Quality management plan will be prepared as part of the PEPR. As indicated in Section 9.3 of the Air Quality report provided in Appendix C of the MLP and summarised in MLP Section 7.6.9, an air quality- monitoring program will be implemented to ensure nearby receptors are not impacted by any PM10 exceedances. The control and management measures indicated in Section 7.6.5 of the MLP and Appendix C are considered appropriate and will be expanded upon in the PEPR.
Australian Graphite Pty Ltd 69 MLA RESPONSE DOCUMENT WRSF West Pit TSF embankment Infrastructure TSF Topsoil stockpile Tailings dam BRATT EN WA Process Y plant
D Subsoil A ROM stockpile O R T Magazine A Cable L area F route A WRSF South D N ENLARGEMENT: PRELIMINARY CONCEPT DESIGN 41 U L L A Y R11 R9 31
AD RO A RT 51 O R3 W A L IL P 61
R12 1 6 91 71 R1 81 1 0 1 1 1 1
1 R13 101 8 ALDERW 101 C O 51 11 OD R2 1 S ROAD 41
SEE ENLARGEMENT KOP R10 PI O R OA D D A O R R4 S 4 3 1 1 L IL H T 5 R7 O 1 4 1 O R5 F 1 4 D A O R 1 Y B 4 E AILLA L 31 L H A IL R8 1 V L 3 K R6 R C O O Y R A A D W H 1 1 6 7 IG 1 H 9 N R1 L O 10 C 1 IN L 11 1
D 21 A 1 O Legend R
R E Sensitive receiver Arterial road V I R Predicted cumulative impacts for Main road D 24 hour maximum O Local road T average PM10 concentration contour (µg/m3) Track Kookaburra Gully 101
8
1 mineral claim 1 6 11 1 OIR DRIVE 101 boundary RESERV MOONLIGHT BAY ROAD
Data source: Lincoln Minerals, Mapland, Map no: 2200002A_GIS_008_E 0 500 1,000 Kookaburra Gully Scoping Study DPTI and Environmental Approvals Author: RP m Figure 8.1 © Parsons Brinckerhoff Australia Pty Ltd ("PB") Copyright in the drawings, information and data recorded ("the information") is the property of PB. This document and the 1:75,000 Predicted cumulative impacts for 24 hour maximum information are solely for the use of the authorised recipient and this document may not Approved by: AST 3 be used, copied or reproduced in whole or part for any purpose other than that which it Scale ratio correct when printed at A4 average PM10 concentrations (µg/m ) was supplied by PB. PB makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document or the information. NCSI Certified Quality System to ISO 9001. © APPROVED FOR AND ON BEHALF OF Date: 29/01/2016 Projection: Transverse Mercator Parsons Brinckerhoff Australia Pty Ltd. Coord sys: GDA 1994 MGA Zone 53 Lincoln Minerals \\APADLFIL01\proj\L\Lincoln_Minerals\2200002A_KOOKABURRA_KOPPIO_ENVIRONMENT\10_GIS\Projects\Maps\2200002A_GIS_008_E.mxd www.pbworld.com
Figure 7-11 Predicted incremental impacts for 24-hour maximum average PM10 concentrations
Australian Graphite Pty Ltd 70 MLA RESPONSE DOCUMENT WRSF West Infrastructure Pit TSF embankment Topsoil Tailings stockpile dam TSF
Process BRATT EN WA plant Y Subsoil
D stockpile A ROM O R T A Cable L Magazine F route area A WRSF South D N ENLARGEMENT: PRELIMINARY CONCEPT DESIGN U L L A Y R11 R9
AD RO A RT O R3 W A L IL 6 P 1
R12 18 R1 2 2 20 2 8 28 R13 32 6 CALDERW 2 OO R2 3 24 DS 0 8 ROAD 2 62
SEE ENLARGEMENT KOP R10 PI O R OA D D A O R S R4 L IL H T O O R7 F R5 D A O R Y B E AILL L A L H IL R8 VA L K R6 R C O O Y R A A D W H R1 IG H N 2 L 2 O 2 C 4 IN L
8
2
D A 2 O 8 Legend R 3 R 0 E Sensitive receiver Arterial road V I R Predicted cumulative impacts for Main road 0 D 26 28 2 annual average PM10 O Local road T 3 30 concentration contour (µg/m ) 3 Track 3 2 2 6 (NEPM goal 30µg/m ) 34 Kookaburra Gully mineral claim
1 R2 8 OIR DRIVE boundary RESERV MOONLIGHT BAY ROAD
Data source: Lincoln Minerals, Mapland, Map no: 2200002A_GIS_009_E 0 500 1,000 Kookaburra Gully Scoping Study DPTI and Environmental Approvals Author: RP m Figure 8.2 © Parsons Brinckerhoff Australia Pty Ltd ("PB") Copyright in the drawings, information and data recorded ("the information") is the property of PB. This document and the 1:75,000 Predicted cumulative impacts for annual average information are solely for the use of the authorised recipient and this document may not Approved by: AST 3 be used, copied or reproduced in whole or part for any purpose other than that which it Scale ratio correct when printed at A4 PM10 concentrations (µg/m ) was supplied by PB. PB makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document or the information. NCSI Certified Quality System to ISO 9001. © APPROVED FOR AND ON BEHALF OF Date: 29/01/2016 Projection: Transverse Mercator Parsons Brinckerhoff Australia Pty Ltd. Coord sys: GDA 1994 MGA Zone 53 Lincoln Minerals \\APADLFIL01\proj\L\Lincoln_Minerals\2200002A_KOOKABURRA_KOPPIO_ENVIRONMENT\10_GIS\Projects\Maps\2200002A_GIS_009_E.mxd www.pbworld.com
Figure 7-12 Predicted cumulative impacts for annual average PM10 concentrations
Australian Graphite Pty Ltd 71 MLA RESPONSE DOCUMENT Provide evidence and justification that the air quality outcomes will be achieved (given that DSD will expect measurement criteria to be 50 µg/m3 over a 24 hour average) and propose new control strategies if they are required to ensure achievement of the outcome.
Sections 9.1 and 9.2 of the AQIA report in MLP Appendix C and Section 7.6.5.1 of the MLP discuss control and management measures for construction (refer 9.1) and operational particulate matter. This offers stringent mitigation techniques, particularly during times of unfavourable meteorological conditions (i.e., dry, windy conditions). Receptor 1 is the only receptor, which will potentially exceed air quality criteria, however this residence is anticipated to be purchased by the client. As indicated in section 9.3 of the AQIA and 7.6.9 of the MLP an air quality monitoring program will be implemented.
Clarify that Figure 8.3 (PM2.5) is for cumulative impacts rather than incremental impacts as indicated in the heading.
MLP Figure 8.3 is for the predicted cumulative impacts. This figure caption for MLP Figure 8.3 should read “Figure 8 3 Predicted incremental cumulative impacts for 24 hour maximum average PM2.5 concentrations”.
SA Govt Issue #24 – Air Quality
Provide more clarity on the emissions factor assumptions for each input to the model. Provide the actual emission factor inputs to the model in grams/ hectare (or equivalent) in a revised Table B1. Emission Factors. Clarify where control measures are contained in the emission factor parameter inputs to the model.
The references for control techniques have been updated in Table 7-6 of this document. This indicates where the information source of control technique assumptions came from, and is an updated version of Table B.1 of the AQIA report. Furthermore, we included total annual emissions source rates in Table 7.1 of the AQIA report (MLP Appendix C).
Australian Graphite Pty Ltd 72 MLA RESPONSE DOCUMENT Table 7-6 Operational emission assumptions
Parameter Assumption Reference
Drilling and blasting
Drilling (holes/year) 8,320 Calculation assumptions from National Pollutant Inventory (2012) Emission Estimation Technique Manual for Mining Version 3.1, Section 1.1.8 Drilling. Department of Sustainability, Environment, Water, Population and Communities. Number of holes, estimate 160 drill holes each time, every 7th working day (ie, once weekly) (Parsons Brinckerhoff assumption)
Blasting (blasts/year) 52 Calculation assumptions from National Pollutant Inventory (2012) Emission Estimation Technique Manual for Mining Version 3.1, Section 1.1.9 Blasting. Department of Sustainability, Environment, Water, Population and Communities. Assume blasting occurs every 7th day (Parsons Brinckerhoff assumption based on information from Kookaburra Gully Graphite Project: Infrastructure scoping study (for Lincoln Minerals Ltd).
Wheel generated dust
Length of haul roads (m) ! 75 m (to WRSF west) Length of roads based on information from Kookaburra Gully Graphite Project: Infrastructure ! 800 m (to WRSF south) scoping study (for Lincoln Minerals Ltd) (Parsons Brinckerhoff 2012) ! 630 m (to processing plant) USEPA (2006) Emission Factor Documentation for AP-42, Section 13.2.2 Unpaved Roads, United ! 4300 m access road (LV) States Environmental Protection Agency, Office of Air Quality Planning and Standards.
VKmT travelled (yearly) ! 51,758 (WRSF west and south) Parsons Brinckerhoff assumption based on information from Kookaburra Gully Graphite Project: ! 2,548 (processing plant) Infrastructure scoping study (for Lincoln Minerals Ltd) (Parsons Brinckerhoff 2012) ! 1533 (LV, access road)
Silt content 8.3% USEPA (2006) Emission Factor Documentation for AP-42, Section 13.2.2 Unpaved Roads, United States Environmental Protection Agency.
Gross mass haul truck (t) 163 http://australia.cat.com/ (777F Off-Highway Truck)
Haul ore capacity 89 (777F Off-Highway Truck) http://australia.cat.com/ (777F Off-Highway Truck)
Level of control for unpaved haul roads 75 75% achieved through watering at >2Litres/m2/hour. (%) USEPA (2006) Emission Factor Documentation for AP-42, Section 13.2.2 Unpaved Roads, United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
Australian Graphite Pty Ltd 73 MLA RESPONSE DOCUMENT
Parameter Assumption Reference
Wind erosion
Area of pit (ha) 13.0 Assumed 70 % of pit mined Based on information from Kookaburra Gully Graphite Project Infrastructure scoping study (for Lincoln Minerals Ltd) (Parsons Brinckerhoff 2012)
Area of WRSF (ha) 3.7 (west) & 25.3 (south) Assumed 70 % of waste rock dump mined Based on information from Kookaburra Gully Graphite Project: Infrastructure scoping study (for Lincoln Minerals Ltd) (Parsons Brinckerhoff 2012)
Area of processing plant (ha) 3.3 Mine design
Area of TSF (ha) 17.0 Assume 70% of the tailings is being used, with wind breaks as a form of control dust factor Control factor assumption from National Pollutant Inventory (2012) Emission Estimation Technique Manual for Mining Version 3.1, Section 5.3 Emissions to air. Department of Sustainability, Environment, Water, Population and Communities. Based on information from Kookaburra Gully Graphite Project: Infrastructure scoping study (for Lincoln Minerals Ltd) (Parsons Brinckerhoff 2012)
Area utilised for topsoil and subsoil 10.4 Assume 70% of collective subsoil and topsoil stockpile allocated area of storage used stockpiles (ha) Based on information from Kookaburra Gully Graphite Project: Infrastructure scoping study (for Lincoln Minerals Ltd) (Parsons Brinckerhoff 2012)
TSP pit retention factor (%) 50 Calculations from National Pollutant Inventory (2012) Emission Estimation Technique Manual for Mining Version 3.1, Section 1.1.17 Wind erosion from active coal stockpiles Department of Sustainability, Environment, Water, Population and Communities. Particle multiplier from USEPA (2006) Emission Factor Documentation for AP-42, Section 3.2.5: Industrial Wind Erosion, United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
PM10 pit retention factor (%) 5 Calculations from National Pollutant Inventory (2012) Emission Estimation Technique Manual for Mining Version 3.1, Section 1.1.17 Wind erosion from active coal stockpiles Department of Sustainability, Environment, Water, Population and Communities. Particle multiplier from USEPA (2006) Emission Factor Documentation for AP-42, Section 3.2.5: Industrial Wind Erosion, United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
Level of control for secondary 60 Calculations from National Pollutant Inventory (2012) Emission Estimation Technique Manual for rehabilitation at WRSF West and South Mining Version 3.1, Section 5.3 Control Technologies. Department of Sustainability, Environment, (%) Water, Population and Communities.
Australian Graphite Pty Ltd 74 MLA RESPONSE DOCUMENT
Parameter Assumption Reference
Level of control for topsoil and subsoil 30 Calculations from National Pollutant Inventory (2012) Emission Estimation Technique Manual for application at WRSF and stockpiles (%) Mining Version 3.1, Section 5.3 Control Technologies. Department of Sustainability, Environment, Water, Population and Communities.
Loading / dumping material
Moisture content in soil (%) 3.5 Based on information from Kookaburra Gully Graphite Project: Infrastructure scoping study (for Lincoln Minerals Ltd) (Parsons Brinckerhoff 2012)
Removal/loading of waste rock at 2.1 Mt Parsons Brinckerhoff communication with client (2015) WRSF West and South
Dumping at WRSF West and South 2.1 Mt Parsons Brinckerhoff communication with client (2015)
Wind speed reduction in pit (%) 50 Calculations from National Pollutant Inventory (2012) Emission Estimation Technique Manual for Mining Version 3.1, Section 1.1.17 Wind erosion from active coal stockpiles Department of Sustainability, Environment, Water, Population and Communities. Particle multiplier from USEPA (2006) Emission Factor Documentation for AP-42, Section 3.2.5: Industrial Wind Erosion, United States Environmental Protection Agency, Office of Air Quality Planning and Standards.
Processing plant
Level of control hooding with fabric 83 Calculations from National Pollutant Inventory (2012) Emission Estimation Technique Manual for filters for jaw crusher, vibrating screens Mining Version 3.1, Section 5.3 Control Technologies. Department of Sustainability, Environment, and crushing circuit conveyor (%) Water, Population and Communities.
Level of control from dust collection 99 Calculations from National Pollutant Inventory (2012) Emission Estimation Technique Manual for system (dust cyclone and dust Mining Version 3.1, Section 5.3 Control Technologies. Department of Sustainability, Environment, collector) (%) Water, Population and Communities.
Diesel generation 2500 kW Calculations from National Pollutant Inventory (2003) Emission Estimation Technique Manual for Combustion Engines Version 3.0, Section 3, Diesel generation. Department of Sustainability, Environment, Water, Population and Communities.
Australian Graphite Pty Ltd 75 MLA RESPONSE DOCUMENT
Clarify if the emissions from the TSF are included in the Air Quality model. If not please justify why.
Two point emission sources were included in the model to represent the tailings storage facility. The source emissions rates are shown in Table 7.1 of the MLP air quality impact assessment (MLP Appendix C), and indicate operational emission assumptions (i.e., area impacted). The source emission rates for wind erosion from the tailings storage facility are 5,960 kg/yr. As indicated in MLP Section 7.4.6.3, it is not expected that there will be dust generation from the tailings storage facility surface during operation. No formal wind breaks would be installed during operation. It should be noted that the embankment design requires the establishment of an additional storage for rainfall that falls on the TSF surface plus additional freeboard to prevent overtopping due to wave run-up (should this occur). This will results in the embankment crest providing a wind break to the tailings surface. It is also considered that the adjacent ridges to which the TSF embankment will be constructed against will also provide for wind protection. Dust generation could occur if the tailings surface dries out prior to installation of the cover material (MLP Section 7.4.6.3). Options were also discussed to mitigate dust emission in between the period of completion of tailings deposition at closure and placement of the cover material. These included use of silt fences or use of polymer dust suppressants. The model assumes that control is provided by rock armour and topsoil (30%) and applied water sprays (40%) to provide collectively 70% of dust control. The control percentages were extracted from Table 4: Estimated control factors for various mining operations NPI’s Emission Estimation Technique Manual (2012). The dust collector system is designed and modelled for hooding with cyclones (65% control) and a dust collector system (83% control with fabric filters), which collectively, was assumed as 99% control in the model.
Based on the outcome of your response to Issue 22, consider conducting a sensitivity analysis on the air quality model by varying relevant emission factor data inputs and reporting on the change in the number of days of exceedances at Receptors.
Please refer to Response 23a for the justification of using 95th percentile. Therefore, it is not considered necessary to revise the maximum PM10 levels and reassess cumulative impacts of PM10.
Based on the modelling, describe the mine dust sources that are the largest contributors to mine generated dust concentrations at the closest human receptors.
The model is unable to project each pollutant’s separate contribution for each receptor. However, we have broken down Table 7.1 of the MLP AQIA report (pollutant emissions rates) from the assessment for the total annual modelling emission, and each source contribution is as follows: • Drilling – 1.1% • Blasting – 0.1% • Light vehicle use along pit access road2 – 0.1% • Hauling rock waste to WRSFs2 – 28.1% • Hauling ore to processing plant – 1.1% • Wind Erosion from pits – 10.1% • Wind Erosion from WRSFs – 28.1% • Wind Erosion from ROM stockpiles – 4.1% • Wind Erosion from TSF – 5.1% • Dragline (ore product and rock waste) from pits – 2.1% • Dumping of waste rock (from pits) to WRSF – 19.1%
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• Dumping ore at processing plant1 – 0.1% • Dumping of tailings at TSF – 0.1% • Loading ore (from stockpile) – 0.1% • Primary crushing (jaw crusher) – 0.1% • Secondary processing (vibrating screens) – 2.1% • Crushing circuit conveying – 0.1% • Bagging to 20kg cement bags – 0.1%
Provide full references for all of the abbreviated references (ie. NPI EET (2012)) given in Table B1 (Appendix B to Appendix C: Air Quality Assessment) so we can review the basis for emission inputs.
A glossary with references is shown in the footnotes of Table 7.1 of the MLP AQIA report. The references are as follows: NPI EET (2012) National Pollutant Inventory (NPI) Emission Estimation Technique Manual (EET) for Mining Version 3.1, Department of Sustainability, Environment, Water, Population and Communities. US EPA (2012) Compilation of Air Pollutant Emission Factors United States Environmental Protection Agency, AP-42, Compilation of Air Pollutant Emission Factors. References have also been updated on Table 1 of this document, which is an updated version of Table B.1 of the MLP AQIA report. SA Govt Issue #26 – Air Quality
Impacts from burning of fuels for the diesel generators, haul trucks and other on-site equipment is not modelled as the report does not consider these emissions to have an impact on air-quality off site. However the diesel generators’ fuel rate of 12,500 litres per day and likely emissions from mobile equipment is not insignificant and therefore the potential impacts from NOx, particulate matter, CO and SO2 should be considered.
As referred to in Section 6.2.3 of the AQIA (MLP Appendix C), diesel generators will have a network capacity of 110 kV. It is not yet certain whether electricity will be supplied from the diesel generator or the network. Therefore we have undertaken a quantitative assessment of emissions from the diesel generator, which supplies 100 % of the electricity onsite. A two-megawatt generator will consume approximately 500 litres/hour under a full load. Collectively, this will amount to 8,400 litres to 12,000 litres of diesel per day. Onsite equipment (haul trucks, grader, light vehicles, dozer and excavator/loaders) were included in the assessment. Refer to Section 6.2.4 of AQIA report for the mine site equipment list and Section 7.4.7 for source emission rates. In this section of the response we have: • Identified local criteria • Identified impacts of the diesel generator to the locality and vicinity of the site • Provided an estimate of quantification of pollutant emissions from the diesel generator • As per the original assessment, predict pollutant concentrations due to generator emissions using AUSPLUME, the air pollutant based dispersion model used for the assessment • Discussed model predictions in relates to impacts (at ground level) • Compared results against regulatory air quality criteria
This assessment considered key air pollutants from the diesel generator, nitrogen dioxide (NO2), carbon monoxide (CO) and particulate matter (PM10). Low levels of sulphur dioxide (SO2), volatile organic compounds (VOCs), and trace levels of polycyclic aromatic hydrocarbons (PAHs) had potential to be emitted. However, emissions from the diesel generators are anticipated to diffuse readily. These three emissions are not anticipated to impact the nearby sensitive receptors. Although this is presented in the response answer questions, it can be considered as part of the air quality impact assessment. The methodology of assessment Australian Graphite Pty Ltd 77 MLA RESPONSE DOCUMENT for these emissions have been compared to the regulatory criteria as referred to in the National Environmental Pollution Measure (1998).
In the case of PM10 background levels were already available for the original air quality impact assessment. For NO2 and CO there was a lack of available nearby data to estimate background air quality pollution levels. A phone conversation on 24 November 2015 with the South Australia Environmental Protection agency (EPA) indicated that the closest air quality monitoring data available within the vicinity of the proposed location was Whyalla for NOx and CO data, and Elizabeth Downs for ozone (O3) (where O3 is used for nitrous oxide conversion). We acknowledge that these monitoring sites are a) a significant distance from the proposed site and b) substantially different in their site classifications, with both of these monitoring locations site being well- established areas. Elizabeth Downs is a residential area on the west side of the Spencer Gulf, and Whyalla is an established urban area which is also likely to be impacted by emissions from the Whyalla steelworks. Therefore the background monitoring data used in this part of the assessment will be an overestimation of pollution. Baseline measurements
The maximum and annual average ground-level criteria for PM10, NO2 and CO are shown below in Table 7-7. th The maximum and annual average ground-level criteria were used for PM10, NO2 and CO. This is the 100 percentile value from Elizabeth Downs (CO), Whyalla EPA monitoring station (NO2) and Project Fusion (PM10). Table 7-7 Maximum measured air quality baseline concentrations 01 Jan 2013 to 31 Dec 2013
Pollutant Criterion Averaging period Baseline Station location measurement
CO 30 mg/m3 1-hour maximum 1.21 mg/m3 Elizabeth Downs EPA 3 3 monitoring station data (2013) 10 mg/m 8-hour maximum 1.22 mg/m
3 3 NO2 246 µg/m 1-hour maximum 88.4 µg/m Whyalla EPA monitoring station 3 3 data (2013) 62 µg/m Annual mean 13.2 µg/m
3 3 PM10 50 µg/m 24-hour maximum 36 µg/m Project Fusion 2013 monitoring 3 3 data 30 µg/m Annual mean 13 µg/m
Dispersion modelling The same dispersion modelling parameters and conditions were used as indicated in Section 7 of the AQIA in Appendix C of the MLP. This includes same upper air predictions from prognostic model, The Air Pollution Model (TAPM) for the wind simulations; stability classes were taken from the 2013 prognostic file used in the AQIA. Assumptions – Estimation of emissions
As discussed above, diesel generator emissions undertaken in this assessment are CO, NO2 and PM10. Assumptions for the diesel generator were: • The requirement for electricity was based on the assumption generators would operate at a 75% loading. • Diesel generator of 2000 kVA to 2500 MWA. • The diesel generator is located at the processing plant. • The burning of diesel fuel could potentially result in emissions in the air basin of the Kookaburra Gully project.
• The most significant emissions produced from diesel generators are oxides of nitrogen (NOx) carbon monoxide (CO) and PM10. Emissions from the diesel power generator were estimated using the National Pollutant Inventory (NPI) Emission Estimate Technique Manual for Combustion Engines4. The NPI has published emissions factor for stationary diesel engines, which are based on the engine power output. Table 7-8 shows the NPI emissions factor for stationary engines. The emission calculations were based on the factors shown in the NPI manual (Department of Sustainability, Environment, Water, Population and Communities, 2012). These emission factors are the same for diesel engines, both less than and greater than 450 kW. Therefore the emission factors still comply with the same rates.
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Based upon the NPI emissions factor, we calculated how much fraction would be released, and how much fuel would be consumed over an hourly rate for a year, which, is shown by the numbers below. Table 7-8 NPI emission factors for stationary engines
Emission (kg/kWh)
Pollutant CO NO2 PM10 Diesel engine location
Operating hr/yr 6500 6500 6500
NPI emission factor 0.015 0.0033 0.00043
Fraction released 100% 100% 80%
Stationary engines > 450kW 1.98 24 0.256 582,985 E 6,192,636 S (processing plant)
4 National Pollutant Inventory (2003) Emission Estimation Technique Manual for Combustion Engines Version 3.0, Section 3, Table 43. Diesel generation. Department of Sustainability, Environment, Water, Population and Communities. As explained above, the figures have been adjusted to the 100th percentile for the air quality monitoring data.
PM10 and PM2.5 are concentrations placed into two different categories due to their size differences. PM2.5 is a subset of PM10, however does not ‘contribute’ to PM10 levels. There is a significant difference between the two pollutants in that PM10 consists of coarse particles, and has a diameter between 10µg and 2.5µg, whereas PM2.5 is any particle size less than 2.5 µg. Predicted Air Quality Impacts – Results
The results of the dispersion modelling are presented in Table 7-9 to Table 7-11 for PM10, NO2, and CO. The worst case impacts have been predicted for either 1 hour, 8 hour, 24 hour or annual averaging periods at 13 sensitive receivers depending on the requirement. 3 Table 7-9 Predicted impact for 24-hour and annual average concentrations NO2 (µg/m ) (diesel generator only)
ID Incremental Cumulative Incremental Cumulative
1 hour maximum 1 hour maximum Annual average Annual average
Goal 246 62 R1 116.1 204.5 2.3 15.5 R2 43.3 131.7 0.3 13.5 R3 46.3 134.7 0.3 13.5 R4 13.0 101.4 0.1 13.3 R5 26.5 114.9 0.2 13.4 R6 27.0 115.4 0.2 13.4 R7 19.6 108.0 0.2 13.4 R8 21.4 109.8 0.1 13.3 R9 34.8 123.2 0.1 13.3 R10 13.7 75.6 0.1 9.4 R11 11.6 20.5 0.2 1.5 R12 17.3 52.7 0.1 5.4 R13 41.1 125.1 0.3 12.9
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Table 7-10 Predicted impact for 24-hour and annual average concentrations CO (mg/m3) (diesel generator only)
ID Incremental Cumulative Incremental Cumulative
1 hour maximum 1 hour maximum 8 hour maximum 8 hour maximum
Goal 30 10
R1 3.2 x10-2 1.2 1.4 x10-2 1.0 R2 1.2 x10-2 1.2 5.3 x10-3 1.0 R3 1.2 x10-2 1.2 3.7 x10-3 1.0 R4 3.6 x10-3 1.2 1.4 x10-3 1.0 R5 7.3 x10-3 1.2 2.0 x10-3 1.0 R6 7.4 x10-3 1.2 2.5 x10-3 1.0 R7 5.4 x10-3 1.2 1.3 x10-3 1.0 R8 5.9 x10-3 1.2 8.8 x10-4 1.0 R9 9.6 x10-3 1.2 1.9 x10-3 1.0 R10 3.8 x10-3 8.6 x10-1 9.4 x10-4 7.1 x10-1 R11 3.2 x10-3 1.3 x10-1 1.4 x10-3 1.1 x10-1 R12 4.8 x10-3 4.9 x10-1 2.1 x10-3 4.1 x10-1 R13 1.1 x10-2 1.17 5.0 x10-3 9.7 x10-1
3 Table 7-11 Predicted impact for 24-hour and annual average concentrations PM10 (µg/m ) (diesel generator only)
ID Incremental Cumulative Incremental Cumulative
24-hour maximum 24-hour maximum Annual average Annual average
Goal 50 30
R1 0.8 36.8 8.07 x10-2 13.1 R2 0.3 36.3 1.19 x10-2 13.0 R3 0.2 36.2 1.15 x10-2 13.0 R4 0.1 36.1 3.05 x10-3 13.0 R5 0.2 36.2 6.13 x10-3 13.0 R6 0.2 36.2 7.09 x10-3 13.0 R7 0.1 36.1 5.67 x10-3 13.0 R8 0.1 36.1 2.46 x10-3 13.0 R9 0.1 36.1 5.02 x10-2 13.1 R10 0.1 25.3 3.97 x10-3 13.0 R11 0.1 3.7 4.76 x10-3 13.0 R12 0.1 14.5 1.13 x10-2 13.0 R13 0.3 34.5 1.13 x10-2 13.0
Summary of results Dispersion modelling has been used to quantify air quality impacts arising from the diesel generator. The conclusions of the study can be summarised as follows:
• Modelling results for NO2 1 hourly emissions indicate that the Project’s operations would comply with NEPM’s maximum 1-hour average goal of 246 µg/m3 at all sensitive receptors. R1 predicted to have the highest cumulative concentration (116 µg/m3) but well below the NEPM guideline level. Australian Graphite Pty Ltd 80 MLA RESPONSE DOCUMENT
• The incremental and cumulative predicted annual average impacts for NO2 did not exceed NEPM’s criterion of 62 µg/m3 for any sensitive receptors, and incrementally results were between 0.1 and 2.3 µg/m3. Cumulatively results ranged between 1.5 to 15.5 µg/m3. • Emissions of CO from the diesel generator is unlikely to cause exceedances for maximum 1-hour and 8-hour average air quality criteria at ground-level locations, with emissions shown in Table 7-11 as minimal from the generator.
• Emissions for PM10 would be minimal from the diesel generator, with the incremental projected concentrations contributing to less than 1 % of cumulative emissions. Based on the modelling from this quantitative assessment emission from the diesel generator, it is not likely to exceed the air quality criteria.
7.7 Noise and Vibration
Issue #68 – Noise
Insufficient data exists in relation to noise generation and dispersion as a consequence of night time operations which not only generate audible noise but also infrasound
As shown in the Noise Report (Appendix B), background noise levels and ambient noise levels were collected in four separate locations adjacent the project site, including adjacent to the Cullens’ House (the closest receptor to the proposed mine site, Receptor R1) and were considered to be representative of the acoustic environment for this locality. As discussed in MLP Section 7, all reasonable and practicable measures will be taken to minimize operational noise. All noise monitoring has been undertaken to meet the requirements of the Environment Protection (Noise) Policy 2007 and AS2187.2-2006.
Issue #69 – Noise
Lack of actual site specific wind dispersion data implies that the noise dispersion patterns having regard to the wind and to the topography are subject to conjecture
As outlined in the Air Quality Report (Appendix C), existing Bureau of Meteorology weather monitoring stations were adopted and considered to be representative of climate and meteorology in the project region. Baseline wind dispersion data was also obtained from the Eyre Iron TEOM monitoring site located 6km southwest of Kookaburra Gully. As discussed in Response 7.6 (Issue #56), the topographical setting and vegetation in the vicinity of the Eyre Iron baseline monitoring site and the Kookaburra Gully project site are similar and therefore are considered to be representative of Kookaburra Gully.
Issue #279 – Noise
Impact of noise on lambing, as well as the quality of the wool, if it is discoloured by the dust
Noise impacts on lambing The noise and vibration report in Appendix B of the MLP included an assessment of the potential impacts of noise and blast vibrations and concluded that impacts were acceptable with the adoption of the proposed control and management measures. The impacts/effects of noise on animals is generally inconclusive as noted in research papers. There is a lack of fundamental knowledge in this area due to research to date being limited to small, disconnected, anecdotal or correlational studies as opposed to coherent programs of controlled experiments. In general, there is no or Australian Graphite Pty Ltd 81 MLA RESPONSE DOCUMENT little evidence of cause and effect regarding noise and behavioural or physiological effects on domestic animals, The relatively low level of Infrasonic/infrasound levels from standard mine operations is not likely to cause effects on domestic or wild animals. Dust impacts on lambing Refer to Response 7.6 (Issue #9).
Issue #280 – Noise
Impact of explosives (blasting) on neighbours and animals
The noise and vibration report in Appendix B included an assessment of the potential impacts of noise and blast vibrations and concluded that impacts were acceptable with the adoption of the proposed control and management measures. An example of typical blasting to occur at Kookaburra Gully is already undertaken at a quarry only 7km to southeast of the Mineral Claims. The quarry blasts hard granitic gneiss of the Lincoln Complex when compared to softer Kookaburra Gully Hutchison Group schists and gneisses. Modern day blasting techniques have improved similar to modern day farming practices (minimum tillage etc) with special timing techniques and the use of electronic initiating systems. Impact would be minimal given planned low powder factors and explosive charge mass of <10kg/m, so blasting vibration and overpressure will not be significant.
Issue #767 – Noise
When the plant is working the noise level rises beyond acceptable level as shown in table 4.26 noise processing plant equipment noise levels.
The predicted noise levels (Appendix B of MLP) indicates that night time operational noise levels at all receptors are below the EPA Noise Policy criteria with the adoption of control and management measures as indicated in Section 7.7.5.1 of the MLP.
Issue #768 – Noise
The national standard for exposure to noise in the occupational environment is an average daily exposure level of 85 decibels.…For peak noise, the national standard is a peak sound pressure level of 140 decibels. (Source: National Occupational Health and Safety Commission, National Strategy for the Prevention of Occupational Noise-induced Hearing Loss [NOHSC: 4004(1989)], Australian Government Publishing Service, Canberra, 1989)
The predicted noise levels (Appendix B of MLP) indicates that night time operational noise levels at all receptors are below the EPA Noise Policy criteria with the adoption of control and management measures as indicated in Section 7.7.5.1 of the MLP. AGL will employ WH&S policies and standards to all employees with regards to hearing protection. AGL commits to conducting a program to assess the potential for the operations to generate noise, the potential radius of impact of any noise from the operations and the potential receptors of such noise with that assessment to be concluded by the end of the first months mineral processing and, to the extent required, to implement programs to attenuate the impact of noise upon identified receptors who are assessed to be negatively impacted by any noise generated by the operations.
7.8 Topsoil and Subsoil Refer to Response 4.7 in regard to additional soil surveys required.
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7.9 Traffic
Issue #1 – Transport Route
The transport route has been determined in the absence of consultation with the community and Elected Members of the District Council of Tumby Bay
At all community information sessions held, poster displays and in Community Information Updates Number 1 February 2014; Number 2 July 2014; Number 3 February 2015 & Number 4 September 2015, and in addition personal meetings held with individual landowners and community groups and other key stakeholders which includes DCTB, AGL made it clear that the preferred route for trucking was north along Pillaworta Road and asked the community for feedback on that selected route. This route was selected based on: • using existing approved heavy-haul roads (Bratten Way and Lincoln Highway); • minimizing use of dirt roads; • minimizing interactions with existing receptors; • road conditions (summer and winter); and • improvements to be made to the existing public road. It should be noted that in late 2014, Council bi-elections were held and new Councilors and Mayor were elected to their prospective new roles and thence a council caretaker position was held over that period. Meetings/discussions with Council have included council presentations, meetings/briefings, and phone calls - • 9 December 2013 • 20 February 2014 • 2 September 2014 • 3 March 2015 (presentation to new Councilors) • 23 September 2015 • 27 October 2015 (Full Council quorum) Minutes from the DCTB council meeting of 13 October are provided below and demonstrate that AGL and the DCTB have been working together on the transport route.
CEO 3/1015 Australian Graphite Limited (AGL) Mining Lease Proposal 10c/10/2015 Moved - Collins Seconded – Stewart That Council note that a response will be forwarded to DSD regarding the AGL Mining Lease proposal for Kookaburra Gully specifically emphasising two major concerns regarding traffic management being; AGL will need to provide the District Council of Tumby Bay with a traffic management plan for the construction period including preferred access routes for vehicles originating from Port Lincoln (or generally south of the site) where the Lincoln Highway/Bratten Way route would not provide the shortest or most direct access. AGL will need to provide the District Council of Tumby Bay, and DPTI (Main Roads) with a traffic management plan for the operational life of the mine including an upgrade/maintenance plan with financial considerations for Pillaworta Road and the Pillaworta Road/Bratten Way intersection. That Council endorse Council officers continuing negotiations with AGL and DPTI (Main Roads) regarding an MOU or other agreement to cover the transport issues identified from the proposal; and That Council endorse the intent of Council officers to pursue the greatest possible economic and community benefit from the proposal for the District Council of Tumby Bay. CARRIED
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Issue #2 – Transport Route
There is no agreement with the DCTB as to the actual transport route
Meetings with the DCTB have consulted, discussed and sought feedback on the transport route. As stated in Section 7.9.1 "The preferred access (and sole access for trucks) to Pillaworta Road will be via Bratten Way and the Lincoln Highway". The Council Works Manager and consultant Road Engineer (Parsons Brinckerhoff) inspected several route options on the 6th February 2014 and agreed that the selected route was the preferred option. Community, DCTB and stakeholder feedback was sought on the preferred route but no alternative was offered. Before an agreement with the DCTB can be made a Mining Lease needs to be granted. Currently a draft Memorandum of Understanding (MoU) has been forwarded to DCTB for consideration and adding to the MOU will be a formal Management Agreement between AGL and the DCTB which will be enacted prior to mine construction. The MOU provides a framework for the Parties to genuinely work together to achieve maximum benefit for the Tumby Bay region and seeks to reinforce the relationship already developed. Through this MOU, the Parties will seek to deliver key outcomes which include, but are not limited to: • The construction or upgrading of Pillaworta Road and Bratten Way intersection and associated slip lane and turning left lane; • Provision of fair maintenance arrangements for Pillaworta Road and other public roads that are identified at risk of having excessive wear and tear that can be specifically attributed toward the Kookaburra Gully project. In principle agreement that the District Council of Tumby Bay (DCTB) will be reimbursed additional costs over and above scheduled maintenance costs associated with upgrading and maintaining Pillaworta Road as required during the construction and operational phases of the mine; • Preparation of a traffic management plan limiting all trucking operations during construction and mine operation, either for supply or export, to access via Bratten Way onto Pillaworta Road to the mine site during daylight hours only unless for emergency. AGL will install appropriate signage to indicate slow moving traffic on Pillaworta Road and trucks entering Bratten Way. The Plan will also provide for mains water carting that will require access along Pillaworta Road from Edillilie Road standpipe; • Preparation of a Company policy to instruct employees/contractors to access the mine site via Bratten Way, however AGL cannot stop employees from using public roads to access the site; • Agreement with respect to the use of the Road Reserve within MC 4373 and continued access to and use of the Council borrow pit in the southeast corner of MC 4373; • Agreement in relation to compliance with the District Council of Tumby Bay Development Plan and Water Protection Zone; • As the project progresses, discussions in relation to Council rates payable by AGL to DCTB for land acquired by AGL for the Kookaburra Gully mine; • AGL continuing its engagement with local community groups to ensure the community remains well informed about Kookaburra Gully and is kept aware of any business or employment opportunities; and • Working together to ensure that opportunities are explored as a means of providing benefits to the wider community and other businesses.
Issue #3 – Transport Route
Assumptions have been made on the part of the Works Manager as to the transport route, but these are not transparent to Elected Members not the Community at large
Meetings with Council have followed on from discussions and route inspection with the Council's Work Manager on 6 February 2014, and feedback was sought from the Council on the access routes selected. No assumptions have been made, there are only 2 exits to Pillaworta Road - north or south and north was the preferred route.
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Refer Issues #1 and #2 above.
Issue #4 – Transport Route
The capability of the ‘Determined route’ appears not to have been subjected to any formal approval process through DPTI
Correct, as the project moves from concept to actual and once a decision has been made to construct the mine, the formal process with DCTB and DPTI will begin. Discussions and formal design of road and/or intersection upgrades will be undertaken with DPTI during development of a Traffic Management Plan with DCTB as part of the PEPR process. Refer Issue #2.
Issues #5 and #742 – Transport Route
Impact upon native vegetation and EPBC listed species is not recognised in the Application. Pillaworta Road upgrade will destroy EP Blue Gums or an alternative route has to be used, namely Bailla Hill Road, in our opinion. This Bailla Hill Road, on the southern side, is more central….Less vegetation to clear for the first half of distance to Lincoln Highway, the second half is already a wider council road and the intersection onto Lincoln Highway is flat with good vision for motorists
A mine access road investigation was undertaken as part of the South Australian Mining Lease Proposal (MLP) process. It has been recommended that Lincoln Highway, Bratten Way and Pillaworta Road should be used as the primary access route to the Kookaburra Gully mine site (based upon safety and comparatively minimal upgrade requirements). It is approximately 22 km from the centre of Tumby Bay to the Kookaburra Gully mine site, which includes a short stretch of 240 metres along the Lincoln Highway. Figure 1-1 (general map of roads between Tumby Bay and proposed mine) shows the proposed transport route for the project. The jurisdictions of these roads are within the District Council of Tumby Bay (Pillaworta Road) and the South Australian Department of Planning, Transport and Infrastructure (DPTI - Lincoln Highway and Bratten Way). The proposed form of transport between Kookaburra Gully and the export destination at Port Adelaide/Port Lincoln will comprise up to seven semi-trailers daily. Semi-trailers are less than 19 metres in length and are classed as a General Access Vehicle (GAV). There are no restrictions placed over their occurrence on South Australian roads. The number of semi-trailers will depend on the total amount of product produced, ranging from 25,000 tonnes per annum up to a maximum of 55,000 tonnes per annum. The most likely scenario will involve approximately 4 to 5 semi-trailers per day. Restricted Access Vehicles (RAV - such as B-doubles and road trains), which are only permitted to use gazetted or permit routes) will not be required. There are also no requirements for rail. No sealing of roads is recommended except for a short distance near the intersection of Bratten Way and Pillaworta Road where trucks heading north will be coming down a relatively steep section to Bratten Way. An upgrade to this intersection (contained and localised widening) may be necessary for safety purposes. Upgrading from a ‘Rural Category 2a’ (Sheeted Collector – High Use) road to ‘Rural Category 3a’ (Sheeted Local Access – Standard Use) road will be required. This may require some vegetation clearance or trimming in sections, however as the roads are fit-for-purpose there is the opportunity to avoid any stands of significant trees or vegetation, if present. Roads will be established within the mine site; however these will be across cleared farmland. The Koppio Hills area is largely defined by Sugar Gum (Eucalyptus cladocalyx) and Eyre Peninsula Blue Gum (Eucalyptus leucoxylon ssp. petiolaris) woodlands. However the largest area within and around the proposed Kookaburra Gully Graphite Project area is cleared farmland (primarily cereal cropping supplemented by stock grazing). Although large areas of the region have been cleared, patches of remnant native vegetation still
Australian Graphite Pty Ltd 85 MLA RESPONSE DOCUMENT occur where there are shallow soils and steep terrain. Riparian areas along watercourses and roadside verges can also retain good examples of remnant native vegetation. A Protected Matters Search was undertaken for the extent of the proposed transport corridor (Table 7-12). Taking into account the geographical location of the project, the following threatened and migratory species were listed as potentially having habitat within the area: Table 7-12 EPBC Protected Matters Search – transport corridor
Species Common name Status
Threatened Peppermint Box (Eucalyptus odorata) Critically Ecological Grassy Woodland of South Australia Endangered Community
Threatened Eyre Peninsula Blue Gum (Eucalyptus Endangered Ecological petiolaris) Woodland Community
Bird Leipoa ocellata Malleefowl Vulnerable
Bird Pedionomus torquatus Plains-wanderer CE
Bird Pezoporus occidentalis Night Parrot E (extinct in region)
Bird Rostratula australis Australian Painted Snipe EN
Bird Stipiturus malachurus parimeda Southern Emu-wren (Eyre Peninsula) VU
Plant Acacia enterocarpa Jumping-jack Wattle EN
Plant Acacia pinguifolia Fat-leaf Wattle EN
Plant Acacia whibleyana Whibley Wattle E
Plant Caladenia macroclavia Large-club Spider-orchid EN
Plant Caladenia tensa Inland Green-comb Spider-orchid EN
Plant Olearia pannosa ssp. pannosa Silver Daisy-bush VU
Plant Ptilotus beckerianus Ironstone Mulla Mulla VU
Plant Pultenaea trichophylla Tufted Bush-pea EN
Plant Tecticornia flabelliformis Bead Glasswort V
Plant Thelymitra epipactoides Metallic Sun-orchid EN
Bird Apus pacificus Fork-tailed Swift Migratory Bird Ardea alba Great Egret, White Egret Migratory Bird Ardea ibis Cattle Egret Migratory Bird Charadrius veredus Oriental Plover, Oriental Dotterel Migratory
Bird Gallinago hardwickii Latham's Snipe, Japanese Snipe Migratory Bird Haliaeetus leucogaster White-bellied Sea-Eagle Migratory Bird Merops ornatus Rainbow Bee-eater Migratory
Bird Motacilla cinerea Grey Wagtail Migratory Bird Motacilla flava Yellow Wagtail Migratory Bird Pandion haliaetus Osprey Migratory Bird Rostratula benghalensis (senso lato) Painted Snipe Migratory
Despite being listed for this area, a general lack of preferred habitat has indicated that the likelihood of occurrence for many of these species in this area is actually quite low (for example, the bead glasswort). For Australian Graphite Pty Ltd 86 MLA RESPONSE DOCUMENT other species (despite their potential presence) due to their nature or habitat use there is not expected to be any form of impact (for example many of the migratory marine or wetland species). The flora and fauna surveys all discuss habitat presence or absence data in line with potential species utilisation and it is not intended to repeat this work here. MNES of interest that may be relevant in this context and include: • Eyre Peninsula Blue Gum (Eucalyptus leucoxylon ssp. petiolaris) Woodland: • Silver Daisy-bush (Olearia pannosa ssp. pannosa) • Tufted Bush-pea (Pultenaea trichophylla) This does not, of course, preclude the presence of the other species. However, the EBS survey for the roadside and proposed pipeline area did not locate any nationally threatened species, including the Silver Daisy-bush and the State rare and nationally endangered Pultenaea trichophylla (Tufted Bush-pea), which were not observed along the roadside. State rare species: Daviesia pectinata (Zig-zag Bitter Pea) and Acacia imbricata (Feathery Wattle) were recorded, the latter being widespread throughout the areas surveyed (in 2013 to 2015 as recorded in EBS’s previous surveys). An additional State rare species, Acacia dodonaeifolia (Hop-bush Wattle) was recorded within the site of Tod Reservoir held land by SA Water. In relation to the proposed transport corridor; the EBS report found that: For Bratten Way: • No EPBC listed species were found along Bratten Way during the assessment. • Species of orchids are unlikely to be found in majority of this area as it is degraded and heavily infested with weeds. • There is a section of the road with Acacia imbricata in the roadside. This was found to be of slightly better quality and it may be possible for orchids to occur here, although none were seen. • Bratten Way is an approved double road train route so no widening is required except at the intersection with Pillaworta Road. • The recommended management response in this section would be to limit widening within the understory of the Acacia imbricata association in the intersection area. For Pillaworta Road north of the mine site: • From the northern end of Pillaworta Road to the entrance to the proposed mine, there are multiple patches of Eucalyptus petiolaris (Eyre Peninsula Blue Gum). The northern 2–3 kilometres of Pillaworta Road through to the intersection with Bratten Way have the Eyre Peninsula Blue Gum TEC areas assessed as category B. • There are patches of good quality Blue Gum along the roadside but also many degraded patches. Some of the degraded roadside patches link to larger areas of Blue Gum and therefore must be considered as part of the larger patch. These are therefore rated as Category B (Category B consists of at least 12 or more species, >50% native cover and patch size is >0.2ha). • Various scattered individual Blue Gums are present along the roadside as well. • No threatened species were located in the roadside. No threatened orchids were located. Some non- conservation rated orchids were seen in the die-off stage. • The current road widths of Pillaworta Road are 7-8m and only minor drainage and vegetation pruning would be required for this limited increase in traffic. For Pillaworta Road south of the mine site (although it should be noted that this section of road will not be used as a transport route for the project and as such no widening or general improvements are required): • About one kilometer south of the entrance to the proposed mine there is a large patch of Blue Gum, which connects through to a patch of roadside vegetation. • In the larger patch away from the road, some of the areas meet the requirements of Category B and A. This means that the entire connecting patch, including the roadside (although it is degraded) has to be classed as Category A. There are known records of EPBC listed species in this vegetated area away from the road. Therefore impacts on this section of roadside would need to be minimised. • It is not proposed to widen or upgrade this section of road as it does not comprise part of the proposed truck route. There will be no impacts to this southern section of Pillaworta Road.
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Traffic management and improvements General improvements are required to the Bratten Way / Pillaworta Road intersection due to poor site distance and visibility of the junction. Potential safety improvements include: • Slow trucks entering Bratten Way. • Seal Pillaworta Road on the approach (for 30 to 50 metres) and flare the left-turn entry. • Flare out/seal shoulder along Bratten Way (northern side) on approach and departure. • Implement ‘Truck Crossing’ warning signs along Bratten Way. • Limit truck movements to daylight hours. With regard to Pillaworta Road, it would be impractical and unnecessary to widen the whole road, alternatively a combination of the following measures could be implemented: • Improve the seal (upgrade from 100mm to 150mm thick road base) and periodically maintain the surface of the road. • Implement warning signage. • Selective localised widening where it doesn’t significantly impact roadside vegetation. • Speed reductions – particularly at bends. • Potential truck communication system (to ensure that only one semitrailer at a time is utilising Pillaworta Road). The proposed transport corridor will extend along roads where there is roadside vegetation present. In some sections, road widening with associated vegetation trimming or tree removal may be required. Despite this, there is flexibility and scope within the existing alignment to avoid significant stands of trees (such as Blue Gums) or patches of vegetation or even individual significant trees by a combination of widening to the other side of the road instead, restricting activities to trimming-only in certain sections, installing guard rails and flagging-off any significant areas. Road widening is not required for the whole extent of the transport route – only sections where safety is a concern due to sight distances. In the event that native vegetation maintenance or clearance is required this will be addressed in line with a Construction Environmental Management Plan and a Roadside Vegetation Management Plan (developed with the Native Vegetation Council of SA). These documents would include the contribution of a Significant Environmental Benefit (SEB), as stipulated under the Native Vegetation Act 1991. Travelling south from the project on Pillaworta Road to Bailla Hill Road was considered in detail when determining the truck route, however, as highlighted above, a higher class of EP Blue Gum exists, the route impacts on more sensitive receptors and the road where it cross the Pillaworta aquaduct requires significant modifications.
Issue #6 – Transport Route
The application includes cost estimates from a private contractor as to upgrading the road, but no Council budget exists for this work to be undertaken and no agreement to cost sharing exists
A Memorandum of Understanding and a future Management Agreement would be enacted in relation to costs incurred for the provision of “fair maintenance” arrangements for Pillaworta Road and other public roads that are identified at risk of having excessive wear and tear that can be specifically attributed to the Kookaburra Gully project. As outlined in the MoU with the DCTB, formal arrangements in regard to costs associated with road upgrades and maintenance will be negotiated and included within the Traffic Management Plan (Refer Issue #2).
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Issue #7 – Transport Route
There is no economic benefit statement to the community pertaining to the proposed road upgrade, only the potential for continued maintenance and repair liabilities for the life of mine and beyond.
The expected economic benefits of the project are described in Section 5.2 of the MLP and have been undertaken as per the requirements of the Ministerial Determination regarding information to be provided in a mining proposal for a mineral lease. AGL accepts that it has a responsibility to assist financially with road/intersection upgrades, maintenance and management to ensure that the local community is not out of pocket. Pillaworta Road would be upgraded to and maintained as an all-weather truck route (single semi-trailer) and the intersection of Pillaworta Road and Bratten Way would be upgraded to make it a much safer intersection. The Pillaworta Road upgrade would be to a standard suitable as a secondary tourist route in accordance with DCTB road service levels.
Issue #20 – Transport Route
The number of heavy vehicles using the road differs in a number of paragraphs
The number of trucks during mine operations is stated to be one (export) truck leaving every one to two hours in daylight hours with the addition of 1-2 trucks per week for supply and fuel. The impact of road use varies depending on the production output and the number of days per week on which product is transported. The product output at the design rate of processing 250,000 tonnes of ore per year varies from about 25,000 tonnes of concentrate per year up to about 40,000 tonnes of concentrate per year. This variation is due to variable grade in the orebody (14% to 17% TGC) and variable recovery (70% to 90%) of graphite from the ore. At 25 tonnes per truck this equates to about 1,000 trucks per year up to 1,600 trucks per year; IE. From 20 trucks per week (~3 per day) up to 32 trucks per week (~7 per day). AGL will actively seek to have empty returning export trucks back-loaded to reduce supply truck deliveries.
Issue #30 – Traffic Management
AGL will need to provide DCTB with a traffic management plan for the construction period including an upgrade/maintenance plan with financial considerations for the preferred access routes including vehicles originating from Port Lincoln (or generally south of the site) where Lincoln Highway/Bratten Way route would not provide the shortest or most direct access.
AGL has prepared a draft Memorandum of Understanding (MoU) with the DCTB which includes preparation of a Traffic Management Plan to address these issues (Refer Issue #2). A traffic management plan is currently being formulated for the construction and operational phases of Kookaburra Gully. The plan will include upgrade/maintenance and financial considerations along with Company policies on traffic movements. Discussions with DCTB have indicated that Pillaworta Road will need to be upgraded from the existing Class 3A road (Figure 7-13) to a Class 2A road. This will require minor widening (ca. 1 m) of the road surface and widening of the safety zones either side of and above the road.
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Category Rural (Cat 1) Sheeted Arterial - High Use Rural (Cat 2a) Sheeted Collector - High Use Rural (Cat 2b) Sheeted Collector - Medium Use Rural (Cat 3a) Sheeted Local Access - Standard Use Rural (Cat 3b) Sheeted Local Access - Low Use Rural (Cat 4a) Natural Formed - Standard Rural (Cat 4b) Natural Formed - Fire Track Sealed Roads DPTI Roads Unclassified Roads
Figure 7-13 Road classifications in DC of Tumby Bay The following provides the desired construction guidelines for Class 2A (WEP Category 5) minor collector unsealed roads (DCTB Ref No. 20130799DR1B) (Figure 7-14). .
© TONKIN CONSULTING Job Number: 2014.0799 District Council of Tumby Bay Filename: Category.wor Revision: B Date: 22/12/2014 Drawn: TJF Road Category
Figure 7-14 Road design guidelines for a Category 2A road in the DC of Tumby Bay It is emphasized here that these are guidelines. The DCTB Works Manager has stated that “it is acknowledged that actuals may differ due to various constraints” and council does not necessarily construct its roads to this specification. It comes back to!efficient use of council resources and road safety. Constraints include native vegetation and driveways into properties.
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Pillaworta Road will be constructed using a base course compacted with roadmaking compaction equipment. The surface course will be rolled with a rubber tyred roller and conditioned with water to ensure a degree of compaction that is similar to that of other unsealed roads in the district. AGL will investigate the use of binding agents/polymers in the construction of the road base to minimise the potential for dust emissions through mine related traffic and an added benefit for public road users. AGL will ensure that dust deposition levels along Pillaworta Road are kept within the environmental air quality criteria. Dust generation along this road is expected to be relatively low due to the low level of heavy vehicle movements (approximately 1 every 1-2 hours in daylight hours). AGL will apply a speed limit of 60 km/hr on straight sections of the road, with a lower speed limit for curves and intersections with other public roads. AGL will negotiate with DCTB regarding the upgrade and maintenance of Pillaworta Road south of the proposed minesite. Although trucks will not use this route, it is accepted that some employees and local contractors from Port Lincoln may choose to use Bailla Hill Road or White Flat Road, Tod River Road and Howards Road to access the site. The latter roads are all Category 1 and 2A roads (see map above) so would not need any upgrading for the stated purpose.
Issue #31 – Traffic Management
AGL will need to provide DCTB, and DPTI (Main Roads) with a traffic management plan for the operational life of the mine including an upgrade/maintenance plan with financial considerations for Pillaworta Road and the Pillaworta Road/Bratten Way intersection.
As noted above (Issues #2 and #30), AGL has prepared a draft Memorandum of Understanding with the DCTB which includes preparation of a Traffic Management Plan to address these issues. Preparation of the Traffic Management Plan will also involve DPTI.
Issue #120 – Transport Route
As a land owner in the Hundred of Koppio, I work in the Tumby Bay Health services. As I frequently travel along the Bratten Way Highway I am very concerned in the traffic load that will be put on the Pillaworta /Bratten Way Intersection. This intersection is on a sweeping bend with double white lines with hills crest on both ends. This road is the responsibility of the Federal Government and NOT our Local Council. It will be very dangerous for loaded semi trailers to enter out into this intersection.
The independent road and traffic consultant’s report prepared for AGL identified this issue as a significant safety issue for these very reasons. AGL will be working with DPTI and the DCTB to develop a Traffic Management Plan (see above) which will incorporate upgrades to this intersection. The improvements planned for the intersection will provide a long-term net benefit to both locals and the greater community that will improve the current ease and safety of grain and livestock trucks (and light vehicles) that exit Pillaworta Road onto Bratten Way not only for the life of mine but also permanently. Traffic warning lights, signs and other safety devices are being considered for traffic entering from Pillaworta Road onto Bratten Way warning Pillaworta traffic of oncoming Bratten Way traffic and vice versa but they would be subject to DPTI and DCTB guidelines, recommendations and approval.
Issue #184 – Transport Route
Pillaworta Road is used mainly by cars and utes and a very small number of trucks (carting stock and grain at harvest time). This road is too narrow for the size and number of trucks proposed by AGL.
Refer also Issue #30 above. Discussions with DCTB have indicated that Pillaworta Road will need to be upgraded from the existing Class 3A road to a Class 2A road. This will require minor widening (ca. 1 m) of the road surface and widening of the safety zones either side of and above the road.
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The road is currently 7 to 8 metres in width and with management policies and procedures and improvements to the pavement and drainage, Pillaworta Road will be improved for all users. Current users which include grain/stock trucks and machinery, transferring grain silos between properties and general light vehicles make up the current users. Only single-trailer semi-trailers are legally permitted on Pillaworta Road.
Photo 7-2 and Photo 7-3 Pillaworta Road during harvest time
Issue #388 – Transport Route
Pillaworta Road follows the valley floor on the eastern side of Pillaworta Creek and run off from rainfall on sloping ground on the east multiplies the water on Pillaworta Road. In the winter time and on occasions in the summer this road can be very wet, slippery and boggy in some places.
AGL is very aware of this issue of water accumulating on Pillaworta Road after heavy rain. The ephemeral creek that runs through the proposed mine site near Cullen’s house does overflow onto the road after heavy rain because the is culvert is located some 35m south along the road edge from where the creek exits the Cullen’s property on the east of Pillaworta Road. AGL would improve this current situation to eliminate the issue and also make Pillaworta Road an all-weather road. On the basis of the proposed control and management measures it is considered that the residual impacts are likely to be very low and acceptable. As part of the Pillaworta Road upgrade which will be prepared in conjunction with DCTB and landowners along the road, culverts will be installed or upgraded to ensure that run-off water from the eastern catchment areas does not flood across the road and that the road is safe in all weather conditions. The road upgrade will require the road base to be increased from 100mm to Photo 7-4 Flooding on Pillaworta Road adjacent to 150mm thick so this will also assist in wet weather to Cullen creek crossing eliminate boggy sections of the existing road.
Issue #397 – Transport Route
Potential impact and risk to CFS crews of a traffic related or product spill incident on public roads (and potential need for Breathing Apparatus)
The Tumby Bay CFS which is two-appliance brigade has currently been refitted with new breathing apparatus should an emergency predicate the wearing of breathing apparatus. The transport of dangerous goods across land is governed by The Australian Dangerous Goods Code Edition 7.3 which lists provisions applicable to the transport of dangerous goods including: Australian Graphite Pty Ltd 92 MLA RESPONSE DOCUMENT
• classification; • packaging and performance testing; • use of bulk containers, IBCs, freight containers and unit loads; • marking and placarding; • vehicle requirements; • segregation and stowage; • transfer of bulk dangerous goods; • documentation; • safety equipment; • procedures during transport emergencies; and • the dangerous goods list with UN numbers. MLP Section 7.13.5.6 indicates that AGL would implement a comprehensive Site Safety and Policy Procedure and the provision of emergency response capability along with consultation with local emergency services. An Emergency response plan would be prepared as part of the PEPR.
7.10 Aboriginal and European Heritage See Response 3.15.
7.11 Visual Amenity and Landscape
Issue #281 – Light Spill
The processing plant which would be operating 24 hours a day would be lit up at night for security measures. Again, this is detrimental to humans and animals.
As described in Table 6.4 of the MLP, only the process plant will use night-time lighting and since that will be fully enclosed there will only be restricted directional external lighting for safety and security on an ‘as needs’ basis to minimise night-time light spill. As indicated in the MLP, lighting will be required to be maintained for safety reasons during the night time operations. Potential impacts will be mitigated by adopting the following control and management strategies: • no open pit mining and waste rock haulage operations at night; • use of public roads by trucks will be restricted to daylight hours; • full enclosure of the process plant within sheds; • location of stockpiles and north west waste rock storage facility to provide a visual barrier from Pillaworta Road; • use of directional lighting targeted to work areas and walkways; and • site design and layout of the topsoil stockpile will also reduce any potential light spill and perimeter fencing will eliminate the impact on animals.
7.12 Asbestiform Minerals See Issues #907 and #1102 in Appendix 1.
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8 Mine Closure and Rehabilitation
8.6 Closure Strategies
8.6.2 Mine Pit (Domain 1)
Issue #286 – Mine Rehabilitation
Once the operation is abandoned the fence surrounding the pit will fall into disarray, the pit will fill with water, wildlife and animals will fall into the pit/s and drown. Worst of all, children could access the area, fall from a great height into the pit and drown.
Modelling indicates that groundwater will recover in the open pit and will result in a slightly saline lake. As noted in Table 8.1, 2m high security fencing would be established around the pit in conjunction with a perimeter bund of inert material to prevent direct access to the open pit. In addition exit points of the open pit will also be bunded to prevent vehicle access. As noted in MLP Section 8.6, the upper level(s) of the pit will be graded and contoured to provide a 20m buffer zone around the pit to provide a bigger catchment zone for rainfall and surface water flows into the pit. This buffer zone would be vegetated and possibly provide a safe haven for any animals that inadvertently enter into the pit domain. The open pit haul road would still remain, however, would be blocked for vehicular access but would provide an access route for any animals that potentially enter and require a path to egress. The risk of significant impact on wildlife and animals was assessed as moderate by implementing the control and management measures. The mine will be located on private property and as such trespassing is illegal. As such, the risks are lower than for natural cliff faces along the coastline of southern Eyre Peninsula.
SA Govt Issue #31a – Closure Domain 1 – Pit Lake Modelling
Identify the uncertainties related to modelling (as a whole) of the rate of pit water recovery and the final pit water level post-closure. This will inform the process to improve future modelling. Identify the uncertainties specific to the model scenario presented in Table 8.1. Clarify the management strategies that are required to achieving this scenario (placement of the abandonment bund, maintaining integrity of diversion drains and dewater diversion bunds etc). These must be relevant and not rely on active management post surrender of the mine lease. Clarify in the response document the pit lake level at which it becomes a flow through system resulting in discharge from the pit towards the creek. This is understood to be at about 150 m AHD. The lowest point of the pit crest should be identified (ie the elevation that will result in surface water discharge from the pit). The fourth model scenario should be provided in the response document. Clarify the potential for seepage from the pit post closure even if the pit remains an evaporative sink. Identify this as an uncertainty in the pit lake closure modelling.
Uncertainties of Model Recovery are: • Rainfall is not regular but likely to be episodic flood/drought; • Runoff coefficients are estimates and hence not measured or site specific. Table 8.1 is a generalized statement applicable to the preferred recovery option. It will involve the diversion of water from uphill areas east of the pit, with only runoff generated from within the bund able to enter the pit. The management of the catchment will involve the construction of permanent diversion channels to feed runoff to the watercourse south of the pit. The pit lake level is designed to remain below 150m AHD, which is the level that could result in through flow.
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The lowest point on the pit crest is designed to be 155 mAHD. 4 scenarios are presented in the modelling report addendum (MLP Appendix D), namely base case (pit only), base case + 20m buffer zone, base case + 20m buffer + catchment west of TSF, and base case + 20m buffer + catchment west of TSF + TSF. The fourth model scenario (base case + 20m buffer + catchment west of TSF + TSF) was not included in the MLP because it was considered an unacceptable option (long term pit water elevation of 155m AHD). Based on the potentiometric surface provided in the groundwater field assessment, the pit lake level at which it becomes a flow through system resulting in discharge from the pit towards the creek is 153mAHD. The base case + 20m buffer modelling produces a long term pit water level of 144m, resulting in a buffer of 6m for throughflow and 11m for pit overtopping.
8.6.3 Infrastructure (Domain 2) No changes to closure plan for this domain.
8.6.4 Tailings Storage Facility, Waste Rock Storage Facility and Low-grade Stockpile (Domain 3)
Issue #73 – Construction of TSF
Rehabilitation of the TSF in the long term
As noted in MLP Table 8.5, a cover of fresh waste rock of 0.5 m-1.0 m thickness will be placed over the entire surface of the TSF when the final surface has dried and consolidated (approximately 3 to 6 months) to enable access for trucks and other equipment. The final surface of the TSF will be covered with subsoil to a depth of approximately 0.5 m-1.0 m then 0.2 m– 0.3 m of topsoil before planting with grasses or a self-sustaining cover suitable for ultimate return to agricultural use. The long-term target use is arable land. More details will be provided in the PEPR based on the existing soil and clay profiles. Trials will be undertaken during operation to determine the optimum thickness and material properties of the subsoil/topsoil cover for rehabilitation.
SA Govt Issue #30 – WRSF Closure Strategies
There is no consideration of the potential for Neutral Metalliferous Drainage (NMD) from the WRSFs post closure. This is relevant considering run-off and seepage from the WRSF will ultimately report to Pillaworta Creek.
AGL is aware of the term Neutral Mine Drainage (NMD) as defined by the GARD Guide and has based its response in accordance with this definition. NMD refers to the condition where metals in solution are present at near neutral to alkaline pH, low to moderate concentration of metals such as zinc, cadmium, manganese, antimony, arsenic or selenium and low to moderate sulphate concentration. Dissolved metals in surface water run-off and in seepage to groundwater could impact environmental receptors. As indicated in the GARD Guide there are no formal guidelines for quantitative definition of NMD. Section 4.3.6.2 provided information on the chemical constituency of a range of typical rock samples that would comprise the waste rock and current assessment criteria. The estimated applicable Ecological Investigation Levels (EILs) are as follows: • Arsenic – 40 mg/kg or ppm • Chromium (III) – 115 mg/kg or ppm • Copper – 100 mg/kg or ppm Australian Graphite Pty Ltd 95 MLA RESPONSE DOCUMENT
• Nickel – 45 mg/kg or ppm • Lead – 200 mg/kg or ppm • Zinc – 115 mg/kg or ppm. A review of the heavy metal concentration included in Sections 4.3.6.2 and 7.4.8.8 indicated the following: • all arsenic and lead concentrations are below the EILs • total chromium in WKG005 (257 mg/kg or ppm) exceeds the EIL for chromium (III) • copper exceed the EIL in WKG002 (107.5 mg/kg or ppm), WKG007 (150 mg/kg or ppm), WKG008 (158.5 mg/kg or ppm) and WKG010 (206 mg/kg or ppm) • nickel marginally exceeds the EIL in WKG006 (54.8 mg/kg or ppm), WKG011 (50.5 mg/kg or ppm) and WKG012 (50.9 mg/kg or ppm) • zinc marginally exceeds the EIL in WKG001 (121 mg/kg or ppm) and WKG018 (118 mg/kg or ppm). Samples WKG005 and WKG010 are graphitic schists and WKG007, WKG008 are high grade graphitic schists. The other samples comprise biotite schists, and biotite gneiss waste rock. To determine potential leachability under neutral conditions testing can involve either the Australian Standard Leaching Procedure (ACLP) test at neutral pH levels of 7 to mimic typical rainfall or the undertaking of “shake flask solubility tests”. While no leachability test were undertaken on the basis of experience with contaminated sites assessment where ACLP test are undertaken to assess impacts, the concentrations detected at the Kookaburra Gully site and presented above are unlikely to result in significant leachate concentrations that would be considered to impact surface water and groundwater. While there are some exceedances of some EILs the proposed groundwater and surface water control and management measures indicated in Section 7.4 and Section 7.5 respectively would mitigate against potential impacts. Section 8.6.4.3 of the MLP provides details of the proposed closure profile and cover for the WRSF’s. On the basis of the conceptual model and risks it was concluded that the risk of impact was low. Therefore it is considered that the risk of NMD is considered to be low. To finalise the closure strategy it is proposed to undertake a range of studies: • testing of mine waste rock and soil to determine geotechnical material properties, leachability testing ACLP testing or “shake flask solubility tests” • additional ARD analysis to refine the distribution of PAF and NAF material • conduct trials on site of possible covers • erosion and landform modelling to assess long term performance of the slopes • hydrological modelling of proposed covers to determine optimum thickness to limit the amount of potential infiltration.
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SA Govt Issue #30 – TSF PAF Cell Closure Strategies
• Figure 4.68 shows PAF exposed at the surface for periods 2 and 3. However the TSF closure strategy does not appear to maintain the PAF cell in a saturated state. How will this be managed during closure? • Will the PAF cell need to be allowed to dry out to achieve consolidation? What is the potential for acid generation during this phase of closure? • Will the store and release cover provide adequate protection to mitigate the potential for PAF seepage? • The slope of the store and release cover is designed to drain inward. Will this promote ponding on the TSF leading to seepage from the TSF/PAF cell and promote continued wetting and drying of the TSF/PAF material? • PAF material is generated mostly late in the life of the pit when less waste rock is being mined and is available for closure and encapsulation without double-handling.
PAF tailings and waste rock would be generated midway during stage 2 (year 5 or when the mine reaches about 120m AHD in depth) and continue through to stage 3 and completion of mining. The PAF cell would need to be allowed to partially dry out over a few months depending on the time of year to achieve enough consolidation so that the store and release cover soil profile can be established. Full consolidation is not required as it will be feasible to produce a working platform from which to dump the inert waste rock and advance it across the final tailings surface. Therefore, while there is some potential for acid generation during that short period, this can be minimised by application of acid neutralizing material to the surface immediately upon cessation of mining/processing operations. Once the store and release cover is established, the PAF cell would be maintained in a moist condition. Further geotechnical studies are required to establish the exact thickness and nature of the store and release cover profile to provide adequate protection to mitigate the potential for PAF acid generation and/or seepage. The initial cover of subsoil and topsoil would be placed to a depth of approximately 0.5 m and 0.2 m-0.3 m respectively before planting with grasses or a self-sustaining cover. There is enough surplus subsoil in the stockpile to enable the thickness of the subsoil to be increased to ca. 1m. The slope of the store and release cover will drain inward which may promote ponding on the rehabilitated TSF after heavy rainfall events but the aim is to establish the store and release cover profile such that continued wetting and drying of the TSF/PAF material will not occur. Some double handling of waste rock may be required for TSF rehabilitation. This would come from the WRSF South. AMC has recommended (MLP Appendix H) that: • Further laboratory testing be undertaken to determine the physical characteristics of the PAF waste material; • An additional study be conducted looking at the possibility of dry-stacking the project’s tailings. This deposition method has advantages in reducing the water needed to transport the tailings as well as increasing the density of the tailings. Both of these reduce the volume required for tailings storage. Note that the use of dry-stack tailings may require a different storage method for the PAF material. Once these studies are completed the design of the TSF and store and release cover would need to be reworked.
8.7 Environmental Risk Assessment No change.
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8.8 Draft Closure Outcomes and Completion Criteria
SA Govt Issue #31b – Closure Domain 1 – Pit Lake Modelling
Clarify the potential for seepage from the pit post closure even if the pit remains an evaporative sink. Identify this as an uncertainty in the pit lake closure modelling.
A groundwater sink is characterised by flow towards the sink in porous media or fractures. Any solutes driven outwards during short term peak water levels, at which times the local hydraulic gradients could be reversed, would be expected to return to the lake with the re-onset of the “sink” as normal levels return. However, if groundwater quality monitoring shows that seepage is ongoing then appropriate remedial action would be implemented. This would primarily be by way of controlling the pit lake level such that it returns to a steady state evaporative sink. This would be achieved by modifying (reducing) the inflows into the pit lake such that the long-term water level is lowered to an appropriate level that ensures that there is little or no seepage from the pit lake or through flow of groundwater. Impact Event K_72 has been revised to include this possible event (see Table 8-1 below).
SA Govt Issue #53 – Additional Closure Outcomes and Completion Criteria
Provide closure outcomes for these environmental aspects, together with a summary of control and management strategies, and draft completion criteria for demonstrating the achievement of this outcome. • public safety (K_82) • visual amenity (landforms) (K_83) • soil quality (K_80) • post mine land use (K_70) • surface water quantity (K_77) Outcome for K_79 is related to surface water (which is appropriate) but the impact event given is related to soil.
Impact Event K_79 is related to soil as indicated in MLP Table 8.9 while Impact Event K_78 is related to surface water. MLP Table 8.10 has been edited as attached below (Table 8-2).
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Table 8-1 Risk Assessment – closure and rehabilitation (revised MLP Table 8.9)
Aspect and impact Primary risk level Control and management measures Residual risk after implementation of control and management measures
Likelihood Consequence Primary Likelihood Consequence Residual risk risk
K_72 Possible Minor Moderate Implementation of groundwater monitoring Unlikely Minor Low program of water levels in monitoring wells. Reduction in quantity of groundwater due to Implementation of remedial action if there is a open pit being a reduction in water supply in wells (e.g. deepen groundwater sink!or! existing wells or provide alternative water supply). seepage from the pit Implementation of remedial action if there is post closure even if the ongoing seepage (e.g. modify catchment regime pit remains an to lower the long-term water level in the pit lake to evaporative sink ensure that the pit remains an evaporative sink)
Table 8-2 Draft outcomes and completion criteria (revised MLP Table 8.10)
Mine closure and rehabilitation
Risk ID Outcome Measurement criteria Criteria
What will be Locations Outcome Frequency Control data measured (and how) achievement
K_67, Ecosystem function Independent expert certifies that EPA/LFA by independent Lease area Target values to Prior to lease Baseline survey K_68, and landscape EPA/LFA is resilient and expert be determined by surrender K_69, function is resilient trending towards sustainability. independent and self-sustaining expert at site closure.
K_70 Audit undertaken by Audit undertaken by an ML area Rehabilitation in Prior to mine Mine Completion Audit undertaken an independent independent suitably qualified accordance with completion Plan by an suitably qualified professional demonstrates that Mine Completion independent professional prior to the site has been rehabilitated Plan suitably qualified mine completion as per the mine completion plan professional prior demonstrates that to mine the site has been completion rehabilitated as per demonstrates that the mine completion the site has been plan developed in rehabilitated as consultation with per the mine Australian Graphite Pty Ltd 99 MLA RESPONSE DOCUMENT
Mine closure and rehabilitation
Risk ID Outcome Measurement criteria Criteria
What will be Locations Outcome Frequency Control data measured (and how) achievement the relevant completion plan stakeholders. developed in consultation with the relevant stakeholders.
K_71, All mine waste An audit prior to completion Chemical and physical Mine lease. All mine waste Prior to Mine Closure and K_72, materials left onsite indicates that: stability of mine waste. chemically and completion. Rehabilitation K_73, are chemically and Audit by a suitably physically stable. Plan ! all mine waste materials, K_75, physically stable qualified and infrastructure and landforms K_79, experienced independent have been established in K_80 expert accordance with the approved design criteria and are geotechnically stable
! prior to surrender of lease all domains have been rehabilitated in accordance with the design and closure strategies
! a site contamination report shows that the lease area is chemically stable
! a report certifies that no hazardous, domestic or industrial waste, other than approved, are left on site.
K_72, No adverse change Groundwater quality (pH, Ec, Groundwater quality (pH, Monitoring wells Within 10% of Annually for a Baseline water K_73, to quality and major ions, TRH and heavy Ec, major ions, TRH and in ML and baseline results period of 3 years quality and K_74, quantity of metals (As, Cd, Cu, Cr, Ni, Pb, heavy metals (As, Cd, immediately or as agreed to groundwater Groundwater K_75, groundwater to Zn)) at monitoring wells in ML Cu, Cr, Ni, Pb, Zn)) adjacent third by DSD levels levels in existing users and and third party wells are within party wells Groundwater levels accordance with groundwater 10% of baseline results. modelling dependent Groundwater levels at third party predictions. ecosystems. wells are in accordance with levels predicted from groundwater modelling.
Australian Graphite Pty Ltd 100 MLA RESPONSE DOCUMENT
Mine closure and rehabilitation
Risk ID Outcome Measurement criteria Criteria
What will be Locations Outcome Frequency Control data measured (and how) achievement
K_77 No adverse change Annual audit of rehabilitation for Quality of surface water Discharge areas No contamination Annually for a Baseline to quality of surface a period of 3 years after mine from lease period of 3 years conditions water in Pillaworta completion (or as agreed with after mine Creek. the Director of Mines) indicates completion (or as run off quality (when runoff agreed with the occurs is within 10% of Director of Mines) background quality
K_78 No adverse change Annual audit of rehabilitation for Quality of surface water Discharge areas No contamination Annually for a Baseline to quality of surface a period of 3 years after mine from lease period of 3 years conditions water due to completion (or as agreed with after mine contamination from the Director of Mines) indicates completion (or as fuel, chemicals and run off quality (when runoff agreed with the waste products left occurs is within 10% of Director of Mines) on site. background quality
K_82 Post mining Post closure audit by a suitably Risk to health and safety Open pit and Stability of open Post mine Mine Completion landforms are qualified and experienced of public and fauna. WRSF(s) pit, and WRSF(s) completion. Plan physically and independent expert indicates: post-mining chemically stable landform. ! open pit and WRSF(s) are and risk the health geotechnically stable long and safety of the term public and fauna are as low as ! the pit abandonment bund reasonably has been constructed in practical. accordance with the approved design warning signage installed
K_83 Integrate and Audit undertaken by an Audit undertaken by an ML area Rehabilitation in Prior to mine Mine Completion harmonise final independent suitably qualified independent suitably accordance with completion Plan rehabilitated professional prior to mine qualified professional Mine Completion landforms with the completion demonstrates that demonstrates that the Plan surrounding the site has been rehabilitated site has been landscape. as per the mine completion plan rehabilitated as per the developed in consultation with mine completion plan the relevant stakeholders.
Australian Graphite Pty Ltd 101 MLA RESPONSE DOCUMENT
9 Management Systems and Capability
9.2 Policies and Objectives
Issue #209 – Long term Environmental-Operational Issues
AGL has no environmental history and no social license in the community to proceed with this proposal. What redress and compensation for the community and the environment is shown in this application.
AGL’s parent company, Lincoln Minerals Limited has been operating on Eyre Peninsula for over 8 years and has a clean slate in regard to environmental management of exploration sites. All previous LML/AGL exploration sites on MC 4373 have been rehabilitated to a standard approved by DSD and the local landowner. They have subsequently been re-cultivated without any detrimental effects in regard to yield. LML and AGL are subject to environmental regulation in respect of the exploration and mining tenements granted to it and the mining legislation of the states in which the mining tenements are held. As reported in LML’s 2015 Annual Report, the Directors are satisfied that no breaches of the environmental conditions of these licences have occurred as they are continually monitoring the Group’s operations. No notices of any such breaches have been received from any authority. AGL is aware of its corporate responsibility to minimise impact on the environment and, as necessary, to undertake mining operations and/or rehabilitate sites in line with detailed procedures and guidelines published by the South Australian Government and exceed these requirements with its own corporate policies and responsibilities. AGL engages and employs best practise policy and procedures to monitor performance and improve operational efficiency to achieve best environmental practice and minimise the impacts of exploration activities wherever possible.
Australian Graphite Pty Ltd 102 MLA RESPONSE DOCUMENT
Appendix 1. Outcomes of Statutory Consultation on Kookaburra Gully Mining Lease Proposal
As per section 35A of the Mining Act 1971 the mining lease application submitted by Australian Graphite Ltd underwent a period of statutory consultation commencing on 17 September 2015. Submissions received from the general public during the formal consultation period raise a broad spectrum of issues regarding the proposed mining operation. Please review each of the issues raised in the public submission and respond to each specific issue using the table format given below as guidance. In relation to common issues within a single submission, the applicant is free to group these issues in the response to prevent duplication. In relation to common issues between different submissions (or a government question), where the issue is identical in nature, the applicant is free to reference a previous response to prevent duplication.
Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response
Submission 1 – MD & SR Sheehan 1 Transport Route Transport route has been determined in the absence of consultation with Response 7.9 (Sect 7.9) the community and Elected Members of the District Council of Tumby Bay 2 Transport Route There is no agreement with the DCTB as to the actual transport route Response 7.9 (Sect 7.9) 3 Transport Route Assumptions have been made on the part of the Works Manager as to the Refer issues #1 & #2 and Response 7.9 (Sect 7.9) transport route, but these are not transparent to Elected Members not the Community at large 4 Transport Route The capability of the ‘Determined route’ appears not to have been Refer issues #1 & #2 and Response 7.9 (Sect 7.9) subjected to any formal approval process through DPTI 5 Transport Route Impact upon native vegetation and EPBC listed species is not recognised Refer issues #742 and Response 7.9 (Sect 7.9) in the Application 6 Transport Route The application includes cost estimates from a private contractor as to Response 7.9 (Sect 7.9) upgrading the road, but no Council budget exists for this work to be undertaken and no agreement to cost sharing exists 7 Transport Route There is no economic benefit statement to the community pertaining to the Response 7.9 (Sect 7.9) proposed road upgrade, only the potential for continued maintenance and repair liabilities for the life of mine and beyond. 8 Dust (Sect 7.6) An analysis of the data provided indicates the existence of a significant Response 7.6 number of minerals within the ore body that are potentially harmful to human health and plant health. These include not only the graphite, but Chromium, Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium together with Copper, Magnesium and Zinc. These minerals are potential carcinogens and or neurotoxins in humans and growth inhibitors
Australian Graphite Pty Ltd 103 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response in plants. () 9 Dust (Sect 7.6) The nature and health impacts together with potential agricultural industry Response 7.6 impacts of the dust emanating from mining operations 10 Dust (Sect 7.6) In the absence of on-site meteorological data, the dispersion pattern Refer to issues #8 & #9 and Response 7.6 modelled from data remote from the site is of concern, given the potential nature of the contaminant within the dust and their impact upon humans and plants alike. There is no consideration given to the impact upon pastures and thence animals whom ingest these contaminants over a period of time.
11 Dust (Sect 7.6) Economic losses attributed to the impact of copper, magnesium and zinc Refer to issues #8 & #9 and Response 7.6 (in excess of trace levels) on grain production 12 Dust (Sect 7.6) Impact upon agricultural businesses within the fallout cloud of Refer to issues #8, #9, #10 & #11 and Response 7.6 contaminated dust through contaminated grain deliveries
13 Dust (Sect 7.6) Potential contamination of rain water, the main source of drinking water for Response 7.6 the area 14 Dust (Sect 7.6) Impact of the contaminated dust reaching the township of Tumby Bay Response 7.6 having regard to the topography (height above sea level of the proposed mine) and the wind direction (and velocity) towards Tumby Bay. 15 Dust (Sect 7.6) Impact on surface water contained within the Tod River Water Protection Response 7.6 Zone (as per the DCTB Development Plan) or the Tod River Wetland of National Significance. 16 Groundwater An analysis of the data provided indicates the existence of a significant Response 7.4 (Sect 7.4) number of minerals within the ore body that are potentially harmful to human health and plant health. These include not only the graphite, but Chromium, Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium together with Copper, Magnesium and Zinc. These minerals are potential carcinogens and or neurotoxins in humans and growth inhibitors in plants. 17 Groundwater The nature of the hazardous materials emanating from mining operations Response 7.4 (Sect 7.4) inclusive of the processing operations is inadequately described in the application 18 Groundwater Environmental impact associated with contamination of groundwater with Response 7.4 (Sect 7.4) the hazardous materials identified is not fully disclosed neither is the long term health impacts associated with contaminated ground water - damage
Australian Graphite Pty Ltd 104 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response to be caused to the groundwater on Lower EP 19 Groundwater There are significant limitations with respect to the geotechnical, Response 7.4 (Sect 7.4) hydrogeology and hydrology of the site, especially in regard to the design of the TSF facility (Section 4.7.7.4 pp 198). It is significant concern that the limitations highlighted by the consultant extend beyond the TSF facility to include the known fact that no data exists for MC4372, nor does the geo- hydrology or hydrology exist beyond the boundaries of MC4373 which may impact upon the Prescribed Wells Area to the South, the source of potable water for the lower Eyre Peninsula.
Submission 2 – Carole Wetherby 20 Transport Route The number of heavy vehicles using the road differs in a number of Response 7.9 (Sect 7.9) paragraphs 21 Transport Route There is no agreement with the District Council of Tumby Bay as to the Refer Issue #2 and Response 7.9 (Sect 7.9) actual transport route 22 Dust (Sect 7.4) This report has nothing mentioned to the major impact upon agricultural Refer Issue #12 and Response 7.6 businesses within the fallout cloud of contaminated dust due to constant very windy conditions that will contaminate Eyre Peninsula’s huge grain deliveries. 23 Dust (Sect 7.4) Potential contamination of rain water which happens to be the Eyre Refer Issue #13 and Response 7.6 Peninsula's main source of drinking water 24 Groundwater Nature of the hazardous materials emanating from mining operations Refer Issue #17 and Response 7.4 (Sect 7.4) inclusive of the processing operations is inadequately described in the application 25 Groundwater Environmental impact associated with contamination of groundwater with Refer Issue #18 and Response 7.4 (Sect 7.4) the hazardous materials is not fully disclosed neither is the long term health impacts of contaminated ground water 26 Groundwater There are significant limitations with respect to the geotechnical, Refer Issue #19 and Response 7.4 (Sect 7.4) hydrogeology and hydrology of the site, especially in regard to the design of the TSF facility. It is significant concern that the limitations highlighted by the consultant extends beyond the TSF facility to include the known fact that no data exists for MC4372, nor does the geo-hydrology or hydrology review exist beyond the boundaries of MC4373 which may impact upon the Prescribed Wells Area to the South, the source of potable water for the Lower Eyre Peninsula 27 Explosives Community members have been informed there would be limited blasting. Refer Issue #268 and Response 4.5.7 However, the lease application document states there will be a huge amount of explosives and dangerous toxic chemicals stored on site. This is a direct conflict to what the mining company had originally informed the
Australian Graphite Pty Ltd 105 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response community
Submission 3 – District Council of Tumby Bay 28 Employment and RDAWEP estimated the FTE employment for DCTB in 2012/2013 to be Noted but it is important to also note that the MLP did not Business 975 with 52 jobs in the mining sector. An additional 30 jobs overall is a state this fact of 52 mining jobs currently existing in the Development small percentage increase and there is a possibility that some of the DCTB region. (Sect 5.1.1, 5.1.2 current 52 jobs are FIFO or DIDO thereby creating the opportunity for and 5.2) skilled mine workers to obtain employment closer to home. 29 Employment and The benefit to the local business economy during construction and then AGL welcomes DCTB’s assistance in this regard and is Business during normal operations is yet to be determined however DCTB would be keen to work with the DCTB to achieve maximum local Development encouraging or facilitating AGL to use local businesses where possible employment at the mine. (Sect 5.1.1, 5.1.2 and 5.2) 30 Traffic AGL will need to provide DCTB with a traffic management plan for the Response 7.9 Management construction period including an upgrade/maintenance plan with financial (Sect.5.1.4 and considerations for the preferred access routes including vehicles originating 7.9) from Port Lincoln (or generally south of the site) where Lincoln Highway/Bratten Way route would not provide the shortest or most direct access. 31 Traffic AGL will need to provide DCTB, and DPTI (Main Roads) with a traffic Refer issues #2 & # 30 and Response 7.9 Management management plan for the operational life of the mine including an (Sect.5.1.4 and upgrade/maintenance plan with financial considerations for Pillaworta Road 7.9) and the Pillaworta Road/Bratten Way intersection. 32 Stakeholder and The extensive consultation undertaken by AGL is noted as is their recent Noted. AGL will continue its commitment to regular Community engagement of a community liaison consultant. The actions of AGL within community updates and meetings with stakeholders Engagement the community, especially those relating to drilling programs, have including DCTB. (Sect 6) generally been an improvement on previous experiences with other companies.
Submission 4 33 Social License Lack of specific information provided throughout the so called consultation Refer issues #39 and Response 6.7 (Sect 5 & 6, process Appendix A) 34 Social License Lack of availability of hard copy Response 6.7 (Sect 5 & 6, Appendix A) 35 Social License Lack of knowledge of the inadequacies of internet capabilities on Lower Response 6.7 (Sect 5 & 6, Eyre Peninsula and inability to download a 139Mb file Appendix A) 36 Social License The fact that some people do not have computers Response 6.7 (Sect 5 & 6,
Australian Graphite Pty Ltd 106 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response Appendix A) 37 Social License The expectation that the recipient of the document of 1169 pages will be Response 6.7 (Sect 5 & 6, able to read, comprehend and formulate a response within the period Appendix A) provided. 38 Social License The complete inflexibility of DSD with respect to an extension of time in Response 6.7 (Sect 5 & 6, which to respond. Appendix A) 39 Social License The lack of public presentation either by DSD or the Company with respect Refer issue #33 and Response 6.7 (Sect 5 & 6, to the Application Appendix A) 40 Social License Demographic data that is four years out of date. Response 3.1 (Sect 5 & 6, Appendix A) 41 Social License Reference to 52 mining jobs currently in the town of Tumby Bay noting that Refer issue #28 and Response 5.1 (Sect 5 & 6, the previous mining employer (Centrex Metals/Eyre Iron) has left the area Appendix A) is totally incorrect 42 Social License The availability of jobs for the local community is based upon what data, Response 5.1 (Sect 5 & 6, given the job profiles of the proposed positions are not identified and the Appendix A) glut of mine employees on the market due to the significant down turn in the mining industry. 43 Social License The oft stated 'benefits' to the community have not been quantified nor Response 5.2 (Sect 5 & 6, have the costs. There is no cost benefit analysis provided. Appendix A) 44 Social License There is no recognition of the costs to the agricultural industry through Refer issues #10, #11, & #12 and Response 7.6 (Sect 5 & 6, contamination dust arising from the mining operations. Appendix A) 45 Social License There are no agreements with the DCTB with respect to costs, inclusive of Refer issue #2 and Response 7.9 (Sect 5 & 6, potential decline in revenue due to the devaluation of properties in the Appendix A) vicinity of the proposed mines and the loss of rate revenue. 46 Social License The significant lack of information in respect to the potential health impacts Refer issues #8, #9 & #10 and Response 7.6 (Sect 5 & 6, of fugitive dust on the community. Appendix A) 47 Transport Route It is noted that the transport route has been determined in the absence of Refer issues #1and Response 7.9 Sect 7.9 consultation with the community and Elected Members of the DCTB. 48 Transport Route There is no agreement with the DCTB as to the actual transport route Refer issue #2 and Response 7.9 Sect 7.9 49 Transport Route Assumptions have been made on the part of the Works Manager as to the Refer issues #1 & #3 and Response 7.9 Sect 7.9 transport route, but these are not transparent to Elected Members nor the Community at large. 50 Transport Route The capability of the 'determined route' appears not to have been subjected Refer issues #4 and Response 7.9
Australian Graphite Pty Ltd 107 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response Sect 7.9 to any formal approval process through DPTI 51 Transport Route The impact upon native vegetation and EPBC listed species is not Refer issue #5 & #742 and Response 7.9 Sect 7.9 recognised in the Application. 52 Transport Route The Application includes cost estimates from a private contractor as to Refer issues #6 and Response 7.9 Sect 7.9 upgrading the road, but no Council budget exists for this work to be undertaken and no agreement to cost sharing exists. 53 Transport Route There is no economic benefit statement to the Community pertaining to the Refer issues #7 and Response 7.9 (Sect 7.9) proposed road upgrade, only the potential for continued maintenance and repair liabilities for the life of the mine and beyond. 54 Transport Route Dependent upon which section of the Application one reads, the impact of Refer issue #20 and Response 7.9 (Sect 7.9) road use in the proposal varies. 55 Dust An analysis of the data provided indicates the existence of a significant Refer issues #8, #9 & #10 and Response 7.6 (Sect 4 pp106-107 number of minerals within the orebody that are potentially harmful to & Sect 7.4) human and plant health. These include not only the graphite, but Chromium, Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium. These minerals are potential carcinogens and or neurotoxins in humans. Also included are Copper, Magnesium and Zinc which are known growth inhibitors in plants. 56 Dust The nature and health impacts together with potential agricultural industry Refer issues #10, #11, & #12 and Response 7.6 (Sect 4 pp106-107 impacts of the dust emanating from mining operations are inadequately & Sect 7.4) described in the Application. This includes the lack of information in relation to requirements of the National Residue Monitoring Scheme 57 Dust In the absence of on-site meteorological data, the dispersion pattern Refer issue #8, #9 & #10 and Response 7.6 (Sect 4 pp106-107 modelled from data remote from the site is of concern. Given the potential & Sect 7.4) nature of the contaminant within the dust and their impact upon humans and plants alike. There is no consideration to the impact upon pastures and thence animals which ingest these contaminates over a period of time 58 Dust Economic losses attributed to the impact of copper, magnesium and zinc Refer issues #8, #9, #10 & #11 and Response 7.6 (Sect 4 pp106-107 (in excess of trace levels) on grain production & Sect 7.4) 59 Dust The impact upon agricultural businesses within the fallout cloud of Refer issues #12 & #56 and Response 7.6 (Sect 4 pp106-107 contaminated dust due to possible contaminated grain deliveries. & Sect 7.4) 60 Dust Potential contamination of rain water, the main source of drinking water for Refer issue #13 and Response 7.6 (Sect 4 pp106-107 the area & Sect 7.4) 61 Dust Impact of contaminated dust reaching the township of Tumby Bay Refer issue #14 and Response 7.6 (Sect 4 pp106-107 & Sect 7.4)
Australian Graphite Pty Ltd 108 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 62 Surface Water Impact on surface water contained within the Tod River Water Protection Refer issue #15 and Response 7.6 Zone (as per the DCTB Development Plan) or the Tod River Wetland of National Significance 63 Surface Water Reference to the northern WRSF and its resultant runoff Response 7.5 64 Surface Water Consideration….over the full course of Pillaworta Creek and Tod River to As discussed in MLP Sections 7.4 and 7.5 the residual the sea. It should be noted that this area of coast also caters for the Marine risks for all potential impact events on Pillaworta Creek Park and Aquaculture Zones adjacent to the site, following implementation of the management measures were assessed as low. Therefore the potential impacts further downstream to the Tod River and the coast are considered not to be a viable risk. Refer issues #15 & #273 and Responses 7.6 & 7.3 respectively 65 Groundwater Nature of the hazardous materials (graphite, Chromium, Copper, Refer issues #16 & #17 and Response 7.4 (Sect 7.4) Manganese, Nickel, Rare Earths, Strontium, Thorium and Uranium) emanating from mining operations inclusive of the processing operations 66 Groundwater Environmental impact associated with contamination of groundwater with Refer issue #18 and Response 7.4 (Sect 7.4) the hazardous materials 67 Groundwater Limitations with respect to the geotechnical, hydrogeology and hydrology of Refer issue #19 and Response 7.4 (Sect 7.4) the site, especially in regard to the design of the TSF facility (Section 4.7.7.4 pp 198). No data exists for MC4372, nor does the geo-hydrology or hydrology exists beyond the boundaries of MC4373 which may impact upon the Prescribed Wells Area to the South the source of potable water for lower Eyre Peninsula 68 Noise Insufficient data exists in relation to noise generation and dispersion as a Response 7.7 (Sect 7.7) consequence of night time operations which not only generate audible noise but also infrasound 69 Noise Lack of actual site specific wind dispersion data implies that the noise Refer issue #56 and Response 7.6 & 7.7 (Sect 7.7) dispersion patterns having regard to the wind and to the topography are subject to conjecture 70 Construction of Limitations of the design of the retaining embankment due to “insufficient Responses 4.7 & 7.1 TSF (Appendix H) geotechnical, geohydrology and hydrology of the site” 71 Construction of Approval should not be granted until all relevant data is available and the This will be part of the PEPR approval. TSF (Appendix H) design reflects this. 72 Construction of Application must contain all relevant information so that the public is well This will be part of the PEPR approval. TSF (Appendix H) informed of the intentions of the applicant 73 Construction of Rehabilitation of the TSF in the long term Response 8.6 TSF (Appendix H)
Australian Graphite Pty Ltd 109 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 74 Construction of Leaching into the aquifer and also in the Pillaworta Creek environs is of Responses 4.7 and 7.1 TSF (Appendix H) paramount concern, one which is not readily satisfied by the proposed treatment of the TSF. The migration of Chromium, Copper, Manganese, Uranium etc into the groundwater and to the Pillaworta Creek will have significant consequences. 75 Environmental Environmental impact of surface water run-off from the activities of mining Refer issues #15 & #273 and Responses 7.6 & 7.3 Impacts operations fails to deal with the fact that this water has a high probability of respectively (Sect 7) being contaminated water (as a consequence of the activities) and whilst a sediment tank is employed, the Application is devoid of information pertaining to the quality of the water (dissolved salts etc) that may (will) reach the confines of Pillaworta Creek and beyond. 76 Environmental Environmental sensitivity of this catchment and its ultimate outflow to the Refer issues #15 & #273 and Responses 7.6 & 7.3 Impacts sea (marine park and aquaculture zones) respectively (Sect 7)
77 Explosives Risk assessment to this facility in the event of a bushfire Response 4.5.7 Magazine (Sect 4.5.7) 78 Explosives Risk to employee fire fighters or to the CFS as a consequence of a bushfire Refer issues #82 & #194 and Response 4.5.7 Magazine in the vicinity of the magazine (Sect 4.5.7) 79 Explosives Assessment of the impact of a catastrophic explosion of the magazine. In Response 4.5.7 Magazine such an event, what would be the blast radius?
(Sect 4.5.7) 80 Explosives Increase in insurance risk to neighbouring properties as a result of the AGL does not subscribe to the belief that there would be an Magazine location of the magazine. Is this potential increase in insurance subject to increased insurance risk to neighbouring properties. (Sect 4.5.7) compensation from the Company? Similar sized blasts are regularly conducted at Cave Quarries in the Tumby Bay foothills and at DK Quarries immediately adjacent to Port Lincoln. 81 Explosives Chemical composition of the detonators. If they contain mercury fulminate, Response 4.5.7 Magazine what is the environmental risk of such a large amount of mercury being
(Sect 4.5.7) released during the mining operations (dust and groundwater implications)? 82 Explosives There are other issues pertaining to the magazine, particularly in relation to Refer issues #78 & #194 and Response 4.5.7 Magazine the security of the contents, noting ammonium nitrate is a precursor to (Sect 4.5.7) many Improvised Explosive Devices. Presumably South Australian Police, Australian Police and ASIO have been informed as to the location and contents of the proposed magazine and the security of its contents. 83 Eyre Iron Data Some data has been cut and pasted from information generated by Eyre Response 3.8 Iron Pty Ltd for the purpose of mining activities associated with the iron ore Project Fusion….and AGL did not carry out sufficient research to ensure the studies were verifiable for the site of Kookaburra Gully. The data so
Australian Graphite Pty Ltd 110 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response imported was obtained by another company and not under the care and control of AGL. 84 Long Term Issues Kookaburra Gully is potentially not a stand alone development, but a Response 4.4 component of the development of the prospect inclusive of Kookaburra Gully extension (for which the Company has received a $3M grant to drill as part of the PACE program) and the original Koppio Graphite Mine area. 85 Long Term Issues Is the application an overarching application for the activities not only Refer Issue #84 and Response 4.4 associated with Kookaburra Gully Mine site but for the holistic view encompassing the original Koppio Mine and Kookaburra Gully extended? 86 Long Term Issues Local suggestions that this development may also enable some symbiotic Response 4.2 arrangement to exist between Australian Graphite Limited and Valance (Uley) Graphite ….part of the relationship may be the establishment of haul routes between the two prospects.
Submission 5 – refer to Submission 4 – additional comments/responses are noted below 111 Explosives I am a CFS volunteer and I WILL NOT be attending any fire at a mining AGL notes your concerns. Refer Issue #78 Magazine company site on Eyre Peninsula. (Sect 4.5.7) Submission 6 – refer to Submission 4 – additional comments/responses are noted below 120 Transport Route As a land owner in the Hundred of Koppio, I work in the Tumby Bay Health Response 7.9 (Sect 7.9) services. As I frequently travel along the Bratten Way Highway I am very concerned in the traffic load that will be put on the Pillaworta /Bratten Way Intersection. This intersection is on a sweeping bend with double white lines with hills crest on both ends. This road is the responsibility of the Federal Government and NOT our Local Council. It will be very dangerous for loaded semi trailers to enter out into this intersection. 124 Groundwater Water that our livestock drink comes from nature soaks, creeks and dams. I Response 7.4 (Sect 7.4) am very concerned what will happen to our underground water system if this mining company is allowed to make an open pit mine. In May, June & July 2014 we received 353 mils of rainfall which became extremely wet. I am worried how this mining company is going to cope with their waste water during winter. Is this water going to leak into our natural creek systems and poison our natural vegetation and habitat? 125 Water Supply We do not have any mains water supply to any of our properties so we rely Refer Issue #13 and Response 7.6 (Sect 7.4) on the rainwater that we catch on our roof tops and dams. This includes our water that we drink, cook in and bath in. Is this going to be contaminated by the dust produced from the graphite mine? 126 Environmental Located on Section 162, Hd of Koppio is 80 ha of natural woodland which Responses 7.2 and 7.6 Impacts has not been stock for 30 years….This area was not burnt out in 2005
Australian Graphite Pty Ltd 111 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response (Sect 7) bushfires and thus the natural woodland is very healthy. We are extremely concerned for our natural vegetation with the dust and noise contamination due to the mining activity with the extra traffic that will be in our area. 127 Environmental It is unjust that our government can give a mining company the approval to Response 7.2 Impacts destroy our land with a mine with a life span of 8 to 10 years. Our wish is to (Sect 7) be able to pass onto our grand children a parcel of land with natural vegetation that has NOT been tarnished with Mining Dust. 128 Environmental Our wish is to be able to pass onto our grand children a parcel of land with Response 7.2 Impacts natural vegetation that has NOT been tarnished with Mining Dust. Please (Sect 7) consider our environment.
Submission 7 – refer to Submission 4 – no additional comments/responses
Submission 8 – refer to Submission 4 – additional comments/responses are noted below 176 Water AGL intends having ponds of kerosene and diesel to float the graphite off Response 7.5 177 Water The proposed mine site is within the Tod River Catchment…(AGL) have no Response 7.5 (see also Response 3.8, Issue #633) true understanding of the local rainfall in this area…12 hour rainfall event 15-16 June 2014 over 85mm fell and resulted in creeks and fords overflowing and residents being unable to leave their properties. The DCTB has now erected 2m high flood markers at these crossings. Photos take at approx. 4pm on 16th June 2014, after floodwaters show the road damage on Pillaworta and Bailla Hill Road junctions, and debris caught on the fence up at head height. This debris has since been removed, strangely, and the locals wouldn’t and couldn’t be bothered. The force of this rainfall event was so huge that the pipeline across the Tod River below Reservoir, was such that the pipeline was swept off its’ concrete supports south of the causeway. 178 Water/TSF If a Tailings Dam had been constructed where proposed, would have Refer issues #15, #64 & #273 and Responses 7.6, 7.5 & contaminated the Tod River all the way down to the Tod mouth at the sea, 7.3 respectively into Fish farming and breeding areas, affecting the Clean, Green Fish farms and our many beautiful beaches 179 Water/Dust Potential contamination “with this potentially deadly dust” of rain water, the Refer Issue #13 and Response 7.6 main source of drinking water for the area 180 Dust Breathing air with radioactive and heavy metal particles in it. Response 7.6 181 Dust Dust contamination of agricultural land, grain and animals (particularly Refer Issues #8, #9, #10, #11 & #56 and Response 7.6 sheep) 182 Dust Dust contamination of water flowing into Lake Wangary and then Coffin Response 7.6 Bay….risk to tourism and aquaculture at Coffin Bay
Australian Graphite Pty Ltd 112 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 183 Dust Sustainable agriculture has existed here for over 100 years and has the Refer issues #8, #9, #56, #452 & #514 and Responses 7.6 potential to continue for over hundreds of years. Even miners have to & 5.2 breather drink and eat! None is this is included in the Mining Lease Application. Our farming land will be worthless and non viable. This MLA is for approx. 7-8 years balance that against thousands of people for over another 100 years. ABS show that 1 Australian farmer feeds 600 people, 150 in Australia and 450 overseas. 184 Roads and Pillaworta Road is used mainly by cars and utes and a very small number Response 7.9 (see also Issue #30) Transport of trucks (carting stock and grain at harvest time). This road is too narrow for the size and number of trucks proposed by AGL. 194 Explosives What safety precautions for local residents, employees and CFS fire Refer Issue #78 and Response 4.5.7 Magazine Site fighters. The Magazine has been sited on private property about 1.5 kilometres from Pillaworta Road and 700 m from the nearest fire track. The Magazine itself will be enclosed by security fencing and will be monitored by surveillance cameras. 207 Long Term Issues Graphite mines are the filthiest, dirtiest of all mines, they must be crazy to Response 7 (Environmental Components) be mining in such high rainfall and productive country, No mining should be allowed in that country 208 Long Term Issues AGL/LML has no proof and no independent data (using Eyre Iron data Refer issues #83 & #666 and Responses 3.8 & 3.7 which we know has not been independently collected, in sealed, tamper respectively proof containers) 209 Long Term Issues AGL has no environmental history and no social license in the community Response 9.2 to proceed with this proposal. What redress and compensation for the community and the environment is shown in this application. 216 Environmental What about the kookaburras of Kookaburra Gully Response 7.3 and MLP 3.13
Submission 9 – Caryll Cabot – refer to Submission 4 – no additional comments/responses
Submission 10 – Anne Daw 264 Earthquakes Impact on mining induced earthquakes in the Kookaburra Gully area….This Response 3.9 and MLP 3.9.1 may impact the soil, air and water and have detrimental affects, causing a threat to agriculture and fishing, as well as on residents and other businesses of Eyre Peninsula 265 Earthquakes Earthquakes may be triggered by mining and drilling Refer Issue #264 and Response 3.9 266 Earthquakes Historically, in USA, earthquake insurance has excluded earth movement Refer issues #264 & #267 and Response 3.9 resulting from human activities such as mining, explosives and oil and gas exploration. How many insurance policies cover mining induced Correct, insurance policies normally exclude natural
Australian Graphite Pty Ltd 113 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response earthquakes in Australia, and does this mean that farmers and residents on earthquakes. Eyre Peninsula have to fork out more for their insurance to cover incidents as the result of mining activities? With unconventional gas activities such as shale or coal seam gas, there are no insurance companies in Australia that want to cover properties where these activities are taking place. 267 Earthquakes The 4 main causes of man made induced seismicity are the following: Response 3.9 - Injection induced seismicity for oil and gas. - Reservoir induced seismicity because of the filling of water storage reservoirs (holding ponds for dewatering and waste water come into this category and are required for this proposed project). - Mining and quarrying induced seismicity from both open pit and underground mining. - Seismicity induced by nuclear explosions – particularly underground. 268 Earthquakes Detonation of explosives are also responsible for triggering seismic activity. Refer Issue #264 (Response 3.9) regarding explosives Australian Graphite Limited is seeking approval to construct and operate an triggering seismic activity and Issue #27 and explosives magazine on site. I understand that 60 tonnes of ammonium Response 4.5.7 regarding risk of magazine nitrate and 1 tonne of detonators will be stored in the complex. This is a risk in itself, of an accidental blast creating toxic dust that may impact the soil, air and water with disastrous consequences. 269 Earthquakes Mining induced earthquakes can vary in nature and be complex, producing Refer Issue #264 and Response 3.9 liquefaction and landslides. The Lower Eyre Peninsula, including the Kookaburra Gully area have hills 300 metres high. 270 Dewatering to Dewatering of the area to obtain the graphite may cause earthquakes and Response 7.4 Access Graphite subsidence (with reference to!land subsidence over 40 years in the Gippsland and Morwell areas of Victoria because of the extraction of underground water for dewatering for mining, and oil and gas activities) 271 Seawater ‘Seawater Intrusion, by the National Centre for Ground Water Research Response 7.4 Intrusion and Training’ states that Eyre Peninsula is highly vulnerable to seawater intrusion. 272 Threat to Potable Threat to potable ground water in the Lower Eyre Peninsula (Uley South) Response 7.4 Groundwater as the result of overflowing of waste-water holding pond….extreme weather conditions such as a 100 year flood. 273 Threat to Potable The Pillaworta Creek joins the Tod River and flows into the sea, Spencer Refer Issue #178 & #272 and Response 7.3 Groundwater Gulf, at Poonindie and the Port Lincoln harbour is just around a land point to the south. The Southern Right Whales are known to be in the sea at Port Lincoln and Spencer Gulf each year.
Australian Graphite Pty Ltd 114 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 274 Threat to Potable Taking a pipeline for potable water from the Uley Basin to the mine site for Response 7.4 Groundwater amenities and the final wash of graphite products. This is putting extra pressure on the requirements of potable water for the lower Eyre Peninsula. The water from the washery has to be dealt with. This may lead to contamination through spillage. Even if this waste water is ‘purified’ the concentrated sludge (heavy metals, brine etc.) is still left behind, and always a problem. 275 Threat to Potable A second pipeline is to have water from the Tod Reservoir. The Tod Refer issues #272 & #273 and Response 7.4 & 7.5 Groundwater Reservoir use ceased in 2002 because of contamination 276 Threat to Potable Impact on the Southern Basins PWA: if!groundwater salinity increases or The groundwater system associated with the proposed Groundwater becomes contaminated (because of impacts of this proposed mining Kookaburra Gully mine is not directly connected to the project), coupled with an increasing demand for water, this would act as a groundwater resources of the Southern Basins PWA, see major risk to the region’s water supply security, development and economic Figure A5 of DEWNR Technical Report 2014/10. Certainly, growth. any drawdown impact associated with the mine outside the Pillaworta Creek catchment (see Figure 3.20 of the MLP) will be extremely unlikely. In addition, refer issues #19, #272 & #273 and Responses 7.4 & 7.3 277 Diesel Impact of diesel fumes and ultra-fine particulate matter on neighbours and Issue #Govt-26 of Response 7.6 animals adjacent to the mine. 278 Dust An analysis of the data provided indicates the existence of a significant Refer issues #8 and Response 7.6 number of minerals within the orebody that are potentially harmful to human and plant health. These include not only the graphite, but Chromium, Manganese, Nickel, Rare Earths, Manganese, Strontium, Thorium and Uranium together with Copper, Magnesium and Zinc. These minerals are potential carcinogens and or neurotoxins in humans and growth inhibitors in plants. 279 Noise (and Dust) Impact of noise on lambing, as well as the quality of the wool, if it is Refer Issue #68 & #56 and Response 7.7 & 7.6 discoloured by the dust 280 Noise Impact of explosives (blasting) on neighbours and animals Response 7.7 & 4.5.7 281 Lighting The processing plant which would be operating 24 hours a day would be lit Response 7.11 up at night for security measures. Again, this is detrimental to humans and animals. 282 Loss of Property Adjoining properties would become devalued or worthless and impossible Refer Issues #6, #7 & #45 and Response 7.9 Valuation to sell.
Submission 11 – J & J Moore (22 Wishart St, Tumby Bay SA 5605) 283 Water Ways Contamination to the fragile water ways and eco system will have a direct As discussed in MLP Section 7.5 the residual risks for all
Australian Graphite Pty Ltd 115 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response impact on the farming community. potential impact events on Pillaworta Creek adjacent to the site, following implementation of the management measures were assessed as low. Refer issues #15, #64 & #273 and Responses 7.6, 7.5 & 7.3 respectively 284 Dust Potential contamination of rain water from graphite dust Refer issue #13 and Response 7.6 285 Dust Suppression Method to try to suppress the dust within the mining operation is to spray Refer issue #275 and Response 7.5 non potable water onto the road systems and operational areas of the mine, this can lead to contaminated water leaching into the waterways. Which in turn will have a direct effect on the surrounding land. 286 Mine Once the operation is abandoned the fence surrounding the pit will fall into Response 8.6 Rehabilitation disarray ,the pit will fill with water , wildlife and animals will fall into the pit/s and drown. Worse of all children could access the area fall from a great height into the pit and drown.
Submission 12 – refer to Submission 4 – additional comments/responses are noted below 320 Groundwater As previous owner of Section 196 in Hd of Koppio we have experienced Response 3.11 vast difference in quality of water used to supply livestock….2 water supply points within 100 metres of one another where one was saltier than sea water and the other was of quite good quality.
Submission 13 – refer to Submission 4 – no additional comments/responses
Submission 14 – refer to Submission 4 – additional comments/responses are noted below 388 Transport Route Pillaworta Road follows the valley floor on the eastern side of Pillaworta Response 7.9 (Sect 7.9) Creek and run off from rainfall on sloping ground on the east multiplies the water on Pillaworta Road. In the winter time and on occasions in the summer this road can be very wet, slippery and boggy in some places.
Submission 15 – refer to Submission 4 – additional comments/responses are noted below 397 Transport Route Potential impact and risk to CFS crews of a traffic related or product spill Response 7.9 and issue #78 in Response 4.5.7 (Sect 7.9) incident on public roads (and potential need for Breathing Apparatus) MLP Section 7.13.5.6 indicates that AGL would implement a comprehensive Site Safety and Policy Procedure and the provision of emergency response capability along with consultation with local emergency services. The Kookaburra Gully Mine will have an emergency response team trained and certified to respond to such
Australian Graphite Pty Ltd 116 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response incidents and compliment Emergency Services in the public arena. Detailed emergency response and traffic management plans will further mitigate potential risks with appropriate controls and management measures employed. The Tumby Bay CFS is fitted out with breathing apparatus and, should an emergency predicate the wearing of breathing apparatus, the CFS is suitably trained and competent. AGL will actively be encouraging employees to join organisations such as the CFS in addition to their site emergency response training.
Submission 16 – refer to Submission 4 – no additional comments/responses
Submission 17 – refer to Submission 4 – additional comments/responses are noted below 450 Introduction Is the short term gain of mining minerals in the Kookaburra Gully worth the Response 5.2 risk of losing productive agricultural land forever. 451 Introduction How much is this beautiful country worth Response 5.2 452 Introduction How much will this beautiful country produce in the next 100 years if it is Response 5.2 not mined 453 Introduction How much will the community of lower Eyre Peninsula benefit Response 5.2 454 Introduction Will mining dust contaminate and condemn our beef, wool, lamb and grain Refer Issue #8, #9 & #56 and Response 7.6 & 5.2
Submission 18 – refer to Submission 4 – additional comments/responses are noted below 502 Native Title Potential existence of Native Title on Road Reserve that is leased to a Response 3.2 (Sect 1.5.3) neighbour 503 Native Title What consultation did the company have with the local Barngarla Response 3.15 (Sect 1.5.3) community. 514 Social License At what cost is the proposal to the community (Koppio, Yallunda Flat, Refer Issues #452, #514 & #43 and Response 5.2 (Sect 5 & 6, Cummins, Port Lincoln, Tumby Bay) that are currently and sustainably
Appendix A) relying on agriculture and will continue to do so for 100's years.
Submission 19 – refer to Submission 4 – no additional comments/responses (NB pages out of order in submission and reordered)
Submission 20 – refer to Submission 4 – additional comments/responses are noted below 621 Dust Potential contaminated dust will travel a lot further than modeling suggests. Response 7.6 & 3.8 and issue #769 (Sect 4 pp106-107 Predicted cumulative impacts for annual average PM2.5 concentrations do & Sect 7.4) not spread as far as PM10. AGL nearly have the dust confined within their The assessment in Appendix C indicates the distribution of mine site. Impossible with the winds we have in the Koppio hills PM 2.5 and PM 10. The concentrations predicted by the modelling do not exceed NEPM criterion for any sensitive
Australian Graphite Pty Ltd 117 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response receptors. 623 Dust We have no main water supply so our stock water could also be Refer Issue #13 and Response 7.6 (Sect 4 pp106-107 contaminated in our dams and creeks Monitoring of rainwater tanks could be extended to include & Sect 7.4) selected dams. 633 Groundwater I live at the headwaters of Kapperna creek which flows into the Pillaworta Refer issue #177 and Response 7.5 (Sect 7.4) Creek that flows past the proposed mine site. In 2013 and 2014 we had The engineering design of the stormwater control system rainfall of 12 inches (305mm) over a six-week period in both years. The proposed mine site will be a lot wetter than the modelling. for the proposed Kookaburra Gully mine will be undertaken to Australian standards. Section 4.9.9 outlines the fact that An AGL/LML re stated that the 13th June 2014 was a one in one hundred the system will be designed to accommodate a 100-year year event….local records show that this statement is wrong. ARI event, i.e. the maximum 100-year rainfall depth that might occur over 24 hrs. 635 Groundwater AGL/LML stated they have spoken to the EPNRM and this water, by then Response 7.4 (Sect 7.4) including kerosene and other processing agents, will not harm the environment if it overflows into the adjacent areas. 636 Groundwater We use a bore on our property for stock water and this proposed mine is Response 7.4 (Sect 7.4) 10kms south of the farm. Not enough is known about the hydrology in the area to be sure this mine will not affect the underground water supplies in the Koppio Hills.
Submission 21 – refer to Submission 4 – additional comments/responses are noted below 666 Social License Data, especially dust, should be independently monitored Response 3.7 (Sect 5 & 6, Appendix A) Submission 22 720 Uranium AGL has identified the presence of uranium in the proposed site yet have Response 4.3 made no mention of monitoring or exclusion zones in relation to rayon gases being released in to the atmosphere or environment (either as gasses or leached into water course in the tod river catchment through drilling) 721 Uranium Mamota had a public meeting in Cummins about extraction of uranium in Response 4.3 our district and talked about exclusion zones of up to 5km of extraction areas.
Submission 24 – Stop Invasive Mining Group (Bronte Gregurke or Keith Coventry) – refer to Submission 4 – additional comments/responses are noted below 742 Transport Route Pillaworta Road upgrade will destroy EP Blue Gums or an alternative route Refer issue #5 and Response 7.9 (Sect 7.9) has to be used, namely Bailla Hill Road, in our opinion. This Bailla Hill Road, on the southern side, is more central….Less vegetation to clear for
Australian Graphite Pty Ltd 118 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response the first half of distance to Lincoln Highway, the second half is already a wider council road and the intersection onto Lincoln Highway is flat with good vision for motorists. 750 Dust Most significant emission of concern is particulate matter, as a result of the Response 7.6 development and operation of the open pit, WRSFs and, to a smaller (Sect 4 pp106-107 extent, graphite- processing plant…. A small fleet of mobile equipment for & Sect 7.4) loading/dumping of ore and fresh rock waste will also contribute to dust via movement on haul roads causing wheel generated dust and loading and dumping of product. Wind erosion will generate fugitive emissions from the pits, WRSFs and stockpiles. 758 Water Supply AGL, state they are in discussions with SA Water to supply “20ML per Response 4.7 annum (110KL per day) of potable drinking water….Impossible to want that amount of potable water for amenities! Is this excess amount of potable water to be used for mine operations? 759 Water Supply Non-potable water from the Tod Reservoir….is reported to be Refer Issue #275 and Response 7.5 contaminated and has not been used for public supply for years. How can AGL construct a pipeline to supply their mine operations with contaminated water, over agricultural land, or along local government roadsides? This contaminated water will be in their holding ponds and used for dust suppression and thereby available to the environment. 760 Water Supply There is no agreement with DCTB or local land owners for the location of Response 7.5 and Response 4.9 pipeline from Tod Reservoir
761 Water Supply Flood of 13th June 2014 was a one in one hundred-year event….local Refer Issue #633 and Response 3.8 records show that this data is wrong. 767 Noise When the plant is working the noise level rises beyond acceptable level as Response 7.7 shown in table 4.26 noise processing plant equipment noise levels. (Sect 7.7) The predicted noise levels (Appendix B of MLP) indicates that night time operational noise levels at all receptors are below the EPA Noise Policy criteria with the adoption of control and management measures as indicated in Section 7.7.5.1 of the MLP. 768 Noise The national standard for exposure to noise in the occupational Response 7.7 environment is an average daily exposure level of 85 decibels.…For peak (Sect 7.7) noise, the national standard is a peak sound pressure level of 140 decibels. The predicted noise levels (Appendix B of MLP) indicates (Source: National Occupational Health and Safety Commission, National that night time operational noise levels at all receptors are Strategy for the Prevention of Occupational Noise-induced Hearing Loss below the EPA Noise Policy criteria with the adoption of [NOHSC: 4004(1989)], Australian Government Publishing Service, control and management measures as indicated in Section 7.7.5.1 of the MLP. Canberra, 1989) 769 Noise Winds in the Koppio hills are different than BoM data of Pt. Lincoln and Responses 3.8 & 7.6
Australian Graphite Pty Ltd 119 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response (Sect 7.7) Cummins airports As outlined in the Air Quality Report (Appendix C) existing Bureau of Meteorology weather monitoring stations and Eyre Iron data were adopted and considered to be representative of climate and meteorology in the project region.
Submission 25 – Emie Borthwick 784 (a) Diversion A catch drain/diversion channel to intercept surface water flows will be Response 7.5 Channel sized and constructed around the TSF and….redirected to the Pillaworta Creek. What are the water sensitive design and treatment techniques? 785 (b) Groundwater A complex understanding of the hydrogeology of the immediate area is Response 3.11 and Response 7.4 unknown and concern is raised into this determination. 786 (c) Surface Water The salinity of the raw water that will be used extensively for dust Refer Issue #275 & #285 and Response 7.5 suppression will accumulate over time within the mineral lease, discharge into the environment will be determined by the ability to meet the regulatory requirements 787 (d) Aboriginal Barngarla people advised that reinstatement of the ephemeral creek was Refer Issue #503 and Response 3.15 Heritage the preferred outcome. Contact and information from the Barngarla women renders this statement false. 788 1. Environmental Economic gain being identified fails to recognize Environmental Diversity Response 5.2 Issues and Resilience 789 2. Environmental Concern in relation to the unknown hydrogeological interactions within the Response 7.4 Issues 400km2 area that is the Tod River Catchment and Wetland System 790 3. Environmental Ecological and hydrological functioning of the Tod River Estuary….is not Response 7.4 Issues identified in the Mining Lease proposal 791 4. Environmental Pillaworta Creek Catchment is a major component of the environmental Response 7.4 Issues water….baseline data must be determined for both upstream and downstream of the proposed project so that management criteria can be determined for the known impacts and potential risks of the project before mining begins. 792 5. Environmental Eyre Iron identified significant water sources from previous drilling within Response 3.11 Issues close proximity to the Kookaburra Gully site that has been ignored by the company 793 6. Environmental Resupply the creek using pit-water if necessary…. this statement holds Response 7.4 Issues limited credibility and should be withdrawn from the proposal if not able to be supported by significant additional information that is site-specific
Australian Graphite Pty Ltd 120 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 794 7. Mine AGL will work with the EPNRM Board in rehabilitation methods….What As the phrase implies AGL will work with the EPNRM Rehabilitation technical and engineering experience does the EPMRN Board have to be Board in rehabilitation methods, this does not imply that the referenced in this way? technical and engineering experience will be sourced from the EPNRM, it is saying that AGL will work with EPNRM as they are involved with many projects and have direct links to environmental improvement. An example of one EPNRM project is: The Eyre Hills project is a large-scale Landcare project that ties in with community, farming enterprises and businesses to achieve ecosystem preservation and function. Ecosystems are important to everyone’s life through the services they provide such as: oxygen production; carbon storage, pollination; pest control; water filtration; animal habitat; inspiring landscapes and more! 795 7. Construction of The concerns of the consultants report, summaries and Refer Issue #70, #71 & Govt #4 and Responses 4.7 & 7.1 TSF conclusions…..there is no scientific evidence and baseline data that supports the concepts and plans the company has submitted in the Mining lease proposal. 796 7. Construction of Low permeability clay within the TSF basin will form a barrier to water Refer Issue #70, #71 & Govt #4 and Responses 4.7 & 7.1 TSF movement….should never been relied upon, especially in light of the enormous lack of data that this company has to support this kind of statement. 797 7. Environmental Acid Sulphate Soil in inland aquatic ecosystems recognised as an As noted in MLP Section 3.14.2.2, soils in the lease area Issues important issue….includes both actual and potential acid sulphate have an average pH of 6.4. PIRSA mapping only identified soils….often found in the same soil profile Pillaworta Creek as having potential for acid sulphate soil formation (1%-10% potential). 798 8. Dust Baseline dust data were collected by Eyre Iron Pty Ltd for the Fusion Refer Issue #666 (Responses 3.8 and 7.6) project over a period of one year on Pillaworta Road adjacent to the proposed mine site, although continuous meteorological, particulate matter Data have been provided to DSD on a confidential basis. and suspended particle data were collected approximately 6 km away.…why did the company not produce any data to support that investment of time which can credibly be concluded as knowledge relevant to this Mining Lease proposal? 799 9. Transport Ephemeral creeks cross the Pillaworta Road in many locations, some have Refer Issues #30, #120 & #388 and Response 7.9 Route simple structures to mitigate flows others have none. After heavy rainfall events this road can become impassable to any traffic apart from a 4wd…..potentially ‘dangerous when wet’ conditions of this road have not been addressed and/or acknowledged 800 9. Transport Traffic predicted for Pillaworta Road.…inaccurate and misleading….School Refer Issue #1 and #803 and Response 7.9 Route bus timetables have been mentioned….how can the company plan for and
Australian Graphite Pty Ltd 121 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response mitigate something that has never been discussed with the affected community members? 801 9. Transport Dangers of the intersection of Pillaworta Road and the Tod Hwy have not We assume that “Tod Hwy” here refers to Bratten Way as Route been identified. the Tod Highway runs through the middle of Eyre Peninsula north-south and not east west as Bratten Way does. The dangers of the Bratten Way-Pillaworta Road intersection were certainly noted and described in the MLP (Section 7.9 and Appendix J). 802 9. Transport How often and what Pillaworta Road is used for has been ignored by the Pillaworta Road is classified by the DC of Tumby Bay as a Route Company and therefore will not be included in the management plans that Class 3A farm access road. The road use is well known are yet to be established. and will form an integral part of the Traffic Management Plan. Local landowners along the road will certainly be consulted as part of this plan. Sometimes on country roads, slow-moving vehicles such as tractors and other agricultural machinery or bicycles may be encountered. Extra care must be taken when approaching them. Safe drivers travel at speeds that enable them to slow or stop their vehicle to avoid a collision in situations where sight distance is limited such as around curves and over crests. When driving in country areas, it is also not uncommon to encounter livestock (e.g. cows or sheep) or native animals, which may have wandered onto the road, or may be being moved across or down a road. Refer issue #30 and Response 7.9 803 9. Transport The company has failed to engage the local community so as to ensure Local landowners along Pillaworta Road were all Route that as affected landowners we will not be impacted individually consulted on several occasions (refer Issue #1 and Response 6.7). In particular, Ms Borthwick was consulted on Wednesday 18 December 2013 by Stephanie Luyks and Luise Michael (Parsons Brinckerhoff) during which issues regarding road use were discussed. Confidential minutes of that meeting including AGL’s response to queries have been recorded. 804 9. Transport Baseline data, which council and EPNRM does not have, that relevantly Response 7.9 Route supports the safety, environmental impacts….suitability and predicted ongoing costs of Pillaworta Road being the most suitable road for the proposal 805 10. SEB An SEB contribution in accordance with legislative requirements will be Refer Issues #Govt-34 to #Govt-37 Contribution made….significant concern as to the Company’s claims for the use of offsets, EPNRM Boards understanding of the process….and ability to not
Australian Graphite Pty Ltd 122 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response create a conflict of interest, DSD delegated authority’s and the lack of transparency and accountability 806 11. Environmental There is little known data and understanding of the existing local and AGL has devoted considerable time and effort into Management regional environment….How do we know that the company is following undertaking local environmental surveys (eg.. flora, fauna, recommendations specified from the departments groundwater) and obtaining more regional survey data from various other sources including from Eyre Iron Pty Ltd and local farmers. The MLP underwent a long review process with Government departments both before and after it was lodged and was subsequently amended in response to those reviews. 807 12. Fauna and No potential impacts on fauna have been raised by DEWNR. What are the Refer to issues raised by Government departments, Flora concerns raised by DEWNR in relation to other aspects of the project? including DEWNR, listed in Appendix 2 808 Economic Viability Is the graphite grade high enough for a premium price? Once the proposal Response 5.2 is refined and quantified is the deposit economically viable? The recent downgrading of operations at the only other graphite mine in South Australia, that recently only reopened, is of significant concern.
Submission 23 – Tumby Bay Residents and Ratepayers Association, Port Lincoln Residents and Ratepayers Association, SOS Group, Eyre Peninsula Community Mine to Port Consultative Committee and selected members of CFS – refer to submissions above – additional comments/responses are noted below 810 1.1. Availability Of Given the local groundwater conditions….where excessive groundwater Noted. Any release of site water would be required to meet Documents conditions are encountered and the water is fresh and uncontaminated, the EPA water quality guidelines. water may be released into local waterways. 811 1.1. Availability Of DENR's Eyre Peninsula Biodiversity Plan (Matthews, et al, 2001) identifies AGL agrees and intends to ensure retention of existing Documents the Koppio Hills as a threatened habitat area. native vegetation where possible (refer mine site layout preserving as much native vegetation as possible), protective measures for threatened species and control and eradication of pest plants and animals. As the biodiversity plan states threats to habitat are caused by:
• Continued isolation of vegetation and wildlife populations • Grazing by stock and rabbits preventing regeneration • Weed invasion • Further clearance of habitat, including roadworks • Predation by cats and foxes • Fragmentation leading to isolated non-viable populations and eventual extinction • Rising saline groundwater due to clearance, causing further loss of vegetation and land degradation.
Australian Graphite Pty Ltd 123 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response With priority actions to include: • Retain all existing remnant native vegetation • Restore degraded remnants through fencing and destocking • Re-establish trees and understorey species to expand existing blocks and create linking corridors or 'stepping stones' • Conduct strategic weed control in and around threatened plant populations, and areas with least weed infestation • Undertake coordinated district level predator control to assist the survival of fauna species. AGL as part of its environmental management plan will establish fencing requirements around native vegetation, monitor flora and fauna within the area, instigate programs of weed and pest animal control, and establish a native nursery. 812 1.1. Availability Of There is potential for artesian conditions in fractured rock environments in No artesian conditions have been encountered on the MCs Documents steeper terrain settings 813 1.1. Availability Of Eyre Iron groundwater records….multiple aquifers (having differing Different standing water levels do not necessarily imply Documents Standing Water Levels) in the immediate region of the proposed multiple aquifers. The basement fractured rock aquifer is Kookaburra Gully Graphite Project. considered as one single aquifer albeit not necessarily homogeneous. As demonstrated by drilling in MC 4373, the water levels are at different depths or elevations across the area (higher in the east and lower in the west) but together they define a uniform potentiometric surface or gradient from east to west. Also, a single angled drill hole may intersect two or more water-filled fractures at different drill depths but those depths of intersection don’t represent different standing water levels or multiple aquifers. 821! 1.3 The Pipeline Construction of the pipeline will, with a high degree of probability, spread Spread of Cape Tulip is by corms and cormils in the known infestation of cape tulip, a noxious toxic weed. contaminated soil and produce, or attached to farm machinery and stock. Pipeline route flora survey and biannual flora and fauna surveys will be undertaken during construction and operations. A weed management plan will be in developed for mining operations to minimise or prevent any increase in weed species within AGL mining leases and associated freehold property due to mining operations.
Australian Graphite Pty Ltd 124 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 823 1.5 Financial Has the Company (AGL) the financial resources to meet the required The company will have the financial resources required to compliance obligations, and in particular those of rehabilitation? meet compliance obligations and a rehabilitation bond will be agreed with DSD prior to mining operations beginning. 824 1.6 Agreement Certification that….the Mineral Claim is a valid claim and thereby the Warden’s Court ruling of 24 June 2015 ruled that the application for a mineral licence upon the Mineral Claim is valid. Notices of Entry are valid and hence the Mineral Claims are valid. 825 1.7 Variations Variations of information between The Proposal, Volume 1, and Volume 2 The main report is Volume 1 and forms the mining lease Supporting Documents proposal. During the process and as a consequence of community consultation, the locations of the various waste rock facilities were moved and some of the reports in the associated Appendices (Volume 2 of the MLP) record those various iterations. The locations shown in Volume 1 are correct. 826 1.8 Risk Risk management is geared to mitigate the liability of the Department to Risk management is the identification, assessment, and Management uphold the interests of the landowner and the environment. prioritization of risks (defined in ISO 31000 as the effect of uncertainty on objectives) followed by coordinated and economical application of resources to minimise, monitor, and control the probability and/or impact of unfortunate events or to maximise the realisation of opportunities. Risk management’s objective is to assure uncertainty does not deflect the endeavour from the business goals. 827 1.9 Agricultural The application is severely lacking in its identification and control of A targeted weed survey has been undertaken along with Land 'declared weeds' in the area. numerous flora surveys by qualified independent ecologists from EBS Ecology. A weed management plan will be in developed for mining operations. The target will be no increase in weed species within AGL mining leases and associated freehold property due to mining operations. 828 1.10 Fugitive Composition of the fugitive dust: no reference has been made to the Refer issue #56 and Response 7.6 Dust National Residue Monitoring Scheme managed by the Commonwealth Department of Agriculture….the Department’s role is in testing these products to ensure they are not contaminated with toxic residues….(and) certification of agricultural products for export. 830 2.1.1 Statement The application has been lodged before final determination by the The MLA was made on the basis that MC 4372 and Warden’s Court of South Australia….in the knowledge that the MC 4373 were valid registered Mineral Claims. The Environmental Impact Assessment had not been undertaken on MC 4372. determination of the Warden dated 24 June 2015 ruled that the Notices of Entry were valid and hence the Mineral Claims were also valid. 831 2.1.2 Relationship The relationship between South Australian Iron Ore Group, Centrex Metals The South Australian Iron Ore Group Pty Ltd is a subsidiary
Australian Graphite Pty Ltd 125 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response Limited, Lincoln Minerals Limited and Australian Graphite Pty Ltd is of Centrex Metals Limited which holds the iron ore rights principally undisclosed jointly with Wuhan Iron and Steel Limited in a JV company, Eyre Iron Pty Ltd. Lincoln Minerals Limited and its wholly- owned subsidiary Australian Graphite Pty Ltd own the rights for all other minerals. Graphite rights for these particular tenements are vested in Australian Graphite Pty Ltd. Agreements signed in 2005, 2006 and 2010, and in particular the 2010 Coordination Agreement, establish Lincoln’s and AGL’s rights to all non-ferrous metals and minerals on Centrex and SAIOG ELs on Eyre Peninsula and set out the framework for exploration and development of resources or co-development of coincident resources as the case may be. The Coordination Agreement is based on a set of co- ordination principles depending on whether a mineral deposit is: • An economic deposit of iron ore minerals without significant other minerals or with uneconomic other minerals;
• An economic deposit of other minerals without significant iron ore mineralisation or with uneconomic iron ore mineralisation; or • An economic deposit of iron ore minerals that co- exists with an economic deposit of other minerals. The second dot point applies to this MLA. The agreements are commercial and confidential. 832 2.1.2 Relationship MC 4372...location listed as Yallunda Flat. MC 4373...location listed as This is correct as per the official Government Land Titles. Koppio…But the two Mineral claims are joined. 835 2.1.2 Relationship The analysis contained on pages 106-7 of Volume 1...(shows) a significant As noted above in Issue #831, the critical words are number of Rare Earth minerals; chromium, copper, manganese, strontium, “without significant other minerals or with uneconomic other thorium and uranium...with concentrations in parts per million (ppm). The minerals”. question now being whether the Company (AGL) has a right of access to these minerals under the terms of the agreements between the parties (South Australian Iron Ore Group, Centrex Metals Limited, Lincoln Minerals Limited and Australian Graphite Limited)? 840 2.2.2 Referring to What are the undisclosed ‘lease conditions’ and what impact do these have These will be determined by DSD as part of their ML offer. MLA 2.1.3.1 upon the project?
Australian Graphite Pty Ltd 126 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 842 2.2.3 EPBC An EPBC referral has been lodged (2015/7470 30th April 2015) but at the The EPBC Referral is not a controlled action if undertaken Referral time of writing of this response, no approval has been granted. The in a particular manner (EPBC referral 2015/7470). Commonwealth Department is aware of the legal action before the Warden’s Court. Response 7.2 848 2.4.1 Referring to Port Lincoln Hospital upgrade is completed, but there is no reference to the A mine site catastrophic event would enact the MLA 3.1.7.1 capacity of the hospital to deal with industrial accidents/emergencies that Australasian Inter-Service Incident Management System might arise from a proposed mine at Kookaburra Gully. The Tumby Bay (AIIMS) which is nationally recognised for the nation’s fire Hospital’s capacity to deal with a similar event is not discussed. No and emergency services agencies. Organisational reference has been made to the evacuation capacity of the Royal Flying principles and structures used to manage bushfires and Doctor Service. other large emergencies (eg floods, storms, plane crash etc) utilise the all-agencies approach. The mine site’s proposed operations are relatively small (up to 30 people) in the scheme of a large emergency involving 100's to 1000's of people. Eyre Peninsula’s emergency services can adequately meet any emergency requirements associated with the proposed mining operations. 849 2.4.2 Referring to What is the educational capacity within the towns of Port Lincoln, Tumby There are numerous secondary and technical and further MLA 3.1.7.2 Bay and Cummins to meet an hitherto undefined educational program education services available on Lower Eyre Peninsula. The sought by the Company Port Lincoln TAFE is capable of holding mine specific training as required. 850 2.4.3 Referring to ‘Exempt land’ pertaining to this Mineral Lease application has not been Following the Wardens Court ruling of 8 September 2015 MLA 3.2.2 subjected to verification by DSD, landowners or the Warden’s Court. all outstanding issues in regard to exempt land were Identified areas of exempt land have not had the required waiver of resolved and were correctly shown in Figure 3.2 of the exemption achieved by the Company…(and) there are no disclosed and/or MLP. Confidential discussions are continuing with confirmed agreements in place at this point in time. landowners in regard to access and compensation agreements or land acquisition. 854 2.4.5 Referring to There is a small benefit to the State through royalties, but….these royalties Royalties are payable from the start of mine production and MLA 3.2.4.2 may not be receive until after the first five years of operation. sales but are reduced by up to 50% for the first 5 years to 2.5% of mine gate value. 855 2.4.5 Referring to What would be the potential cost to Government for the rehabilitation of a There is no cost to government. MLA 3.2.4.2 contaminated water catchment that arose from the mining operations on the proposed site? 856 2.4.6 Referring to Power supply system is already at capacity...use of a 24/7 diesel power Refer to air quality report Appendix C, Issue #277 and MLA 3.3.2 generation system and the pollution arising there from requires Issue #Govt-26 of Response 7.6 consideration from a public (and employee) health aspect. 861 2.4.8 Referring to Mobile phone reception in the area is limited due to the topography...A Noted, AGL will investigate communication strategies as MLA 3.3.4 community benefit would be achieved if the mobile network is upgraded at the project develops. the Company’s cost to wireless broadband capability.
Australian Graphite Pty Ltd 127 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 873 2.4.14 Referring Discrepancy with respect to the concentration of uranium at the Refer issue #720 and Response 4.3 to MLA 3.9.3 site...Irrespective of the standard (200 ppm), the question arises as to the fate of this ore, once mined and thus becoming mobile either in solution or as a component of fugitive dust 876 2.4.15 Referring The "impact of the proposed mine infrastructure on drainage into Pillaworta Refer to Issue #285 and Response 7.5 to MLA 3.10 Creek will be negligible” is clearly contestable given that detailed designs have yet to be provided and the nature of said mining operations, especially in light of the potential chemical hazards 878 2.4.16 Referring Hydrogeological assessment of features described on the Borthwick Response 7.4 to MLA 3.11 property as ephemeral springs concluded that it is very unlikely the features...are in fact springs. NO drilling or collection of samples was permitted as a condition of entry imposed by the Warden’s Court. The conclusions drawn are not conclusive. 879 2.4.17 Referring The information contained in this AGL MLA is devoid of any comprehensive A flora and fauna survey has been undertaken on MC 4372 to MLA 3.12 flora study undertaken over any period of time on the Borthwick properties, and this has also assessed the area for orchids inclusive of the land contained within MC 4372. (Addendum 3 attached to this Response Document). 880 2.4.17 Referring A one day (daylight hours) visit to a designated portion of MC 4372 does The area of the survey was about 10 hectares, which is an to MLA 3.12 not constitute a thorough assessment of the flora on the site...It is area that a qualified ecologist can accurately map and suggested more work is required to verify the conclusion drawn. assess in the duration of a day. Due to the overgrazing of the understory in the sugar gum woodland of MC 4372, much of the understory species were degraded or not represented. 881 2.4.17 Referring Advice has been received that the area contains some 30 listed species of The power line survey area included a much larger area of to MLA 3.12 native orchids as found during the environmental assessment for the the Koppio Hills/Lincoln Uplands specific to upgrading the proposed upgrade to the power line in the area. Such information appears main transmission line to Port Lincoln. Site specific and to be absent from the assessment tendered. transport corridors have been assessed for orchids and their likely habitats also mapped. No threatened or endangered orchid species have been identified. EBS Ecology undertook the powerline survey work for SA Power Networks. 882! 2.4.18 The Hon G Letter dated 11 May 2015 to The Hon G Hunt, MHR, regarding AGL’s The comments and concerns raised by this letter to the Hunt, MHR EPBC Referral (2015/7470) Hon G Hunt have been addressed as part of AGL’s EPBC Referral (2015/7470). Response 7.2 883! 2.4.19 The Hon G Letter dated 28 October 2015 to The Hon G Hunt, MHR, regarding AGL’s The comments and concerns raised by this letter to the Hunt, MHR EPBC Referral (2015/7470) Hon G Hunt have been addressed as part of AGL’s EPBC Referral (2015/7470). Response 7.2
Australian Graphite Pty Ltd 128 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 883! 2.4.20 EPBC and Comments on roadside vegetation with respect to AGL’s EPBC Referral Refer to Response 7.9, Issues #5 and #742 – Transport Roadside (2015/7470) Route Vegetation See also Response 7.2 re EPBC Referral AGL will implement a traffic management plan that will cover roadside vegetation and limit impacts on EPBC listed vegetation. 886 2.4.21 Referring Listed species on the roadways affected by this project have not had due Refer issue #5 and Responses 7.9 & 7.4 to MLA 3.12.3 consideration with respect to any potential groundwater impact of the project. 891 2.4.24 Referring The full extent of the occurrence of sulphides in the deposit appears not to As listed in Table 4.6 of the MLP, sulphur analyses were to MLA 3.14.2.2 be disclosed (especially on MC 4372), so the extent of potential impact of undertaken on over 1150 samples representing ore (~600 acid soils is not fully described. samples) and waste rock (~550 samples). The distribution of S>0.3% in the orebody and waste rock is shown in the accompanying geological cross sections MLP Figures 4.20 to 4.24. Established principles of geological science allow interpretation of conditions (eg. mineralogy, structure) to be continued north into MC 4372. Refer also to Issue # 797 and Response 7.1 897 2.5.3 Waste The final angle of repose for the WRSF and the TSF embankment will be The maximum angle of repose is stated as 20 degrees but Storage Facilities less than 20 degrees...A 20 degree slope would be significant for current it is more likely that it would be closer to 15 degrees which machinery to traverse...the final height of some 50-60 metres above current is consistent with maximum natural slopes in the area. ground level, which would also impact upon the ability to use the area for These slopes would be contoured and vegetated to reduce agricultural (arable) purposes...what happens to the material removed from or eliminate potential for erosion. It is not intended that the embankment, especially if it has been subject to seepage and thus cropping would be undertaken on rehabilitated slopes, but contains the contaminant held with the TSF? rather on the plateaus of the WRSF and TSF. Material on the embankment is not removed but rehabilitated with sub-soil and topsoil and reseeded with native grasses. 901 2.5.5 Site Access Provision of DPTI assessment and approval of the proposed route together Refer issue #5 and Response 7.9 with….approval from EPBC and Native Vegetation Council with respect to impact upon listed species along the road verges 902 2.5.6 Local Section 9 traversing MC 4372 and MC 4373….drill holes featured appear at No. The location of drillhole traces is shown in MLP Geology an angle to the vertical, the question is do the drill holes (or any of) traverse Figure 4.17. The top of that map coincides with the the property boundary? southern boundary of MC 4372 903! Limitations of drill NO drilling has been undertaken on MC 4372; hence the suggested As for groundwater, established principles of geological sampling resource supposedly compliant with JORC Code 2012 is speculative. science allow interpretation of conditions (eg. mineralogy, structure) to be extrapolated over these distances by a
Australian Graphite Pty Ltd 129 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response Competent Person. Historical trenching and sampling on MC 4372 was undertaken in the 1980s by Pancontinental Mining and forms part of the geological model on which Kookaburra Gully Mineral Resource is based. 906 2.5.9 Results The Associations categorically reject the assertion “ while there are some AGL has presented all data openly and transparently with exceedances of some EIL’s the proposed groundwater and surface water control and management measures to mitigate against control and management measures indicated in Section 7.4 and 7.5 potential impacts. respectively would mitigate against potential impacts (not fully disclosed) from the ore and low grade stockpiles and ARD drainage from the PAF storage area”. 907 2.5.10 Minerals The presence or otherwise of asbestos on MC 4372 needs to be As for groundwater, established principles of geological determined, and if found, an acceptable management/control program science allow interpretation of conditions (eg. mineralogy, provided for the community to comment upon structure) to be extrapolated by competent geologists across these short distances. Qualified geologists inspect all drilling and surface exposures of geological formations from not only this small mining lease area but regionally where the existence of asbestos has been found. No asbestos minerals have been found to date, however further petrological studies will be undertaken during the course of the project and if asbestos minerals are found an asbestos management plan would be enacted. 911 2.5.14 Rehabilitat Saline water that will enter the pit post dewatering, will become further This is an essential part of the mine closure strategy, i.e. ion Operations contaminated with the remnants of the mining operations…(and) details in the mine pit acts as the final repository of any potential For Open Pit relation to the locations of the additional pits contaminants that may reach the water table from mine- related contaminant sources. 912 2.5.15 Workforce Will the workforce be subject to zero tolerance with respect to drugs and Yes, like all mine sites, AGL will employ a zero tolerance alcohol? drug and alcohol policy. 913 2.5.15 Workforce Ability of local educational facilities to train prospective employees to the Refer issue #849 in Appendix 1 level envisaged…(and) on-going training and development 920 2.5.17 Type Of Operational risk during mining operations of equipment in use starting a Most if not all mining equipment would be operating in non- Equipment fire...assumed this implies cessation of activities on fire ban days. flammable areas such as within the pit or on haul roads. As such the risk of starting a fire is negligible. However, AGL will develop, in consultation with the CFS, a fire management plan and working conditions that are applicable to a mine site. Mining equipment can be fitted with fire suppression systems in addition to the water cart operating on-site. 921 2.5.18 Mine The assumptions within the modelling lack credibility, especially in relation As noted in the response to Issue #878 and Response 7.4, Dewatering to MC 4372, and non- existent data pertaining to water levels from established principles of geological science allow interpretation of conditions to be extended north into MC
Australian Graphite Pty Ltd 130 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response exploration holes in the vicinity of the pit 4372 by a Competent Person, in this case an experienced hydrogeologist. 922 2.5.18 Mine The assumption based on one hole in the middle of the pit area (one where The modelling has been undertaken by an international Dewatering transmissivity is at the lowest end of the scale), hardly a reliable scientific recognised hydrogeologist. The model has been calibrated quantity as it could well be 100% wrong. to the results of a pumping test as well as observed groundwater head data in the area of the project. The hydraulic properties simulated by the model are consistent with the scientific literature (eg. Anderson & Woesner, 1992, Applied Groundwater Modeling), as well as the results of investigations undertaken in the area of Pillaworta Creek and elsewhere on the EP. 925 2.5.19 Processin The discussion is devoid of consideration of fugitive dust with particulate Refer Govt-23 and Response 7.6 g matter PM2.5 and PM1.0, given that the dust will contain not only the hazardous minerals outlined previously, but graphite and possibly free silica (which to date has not been mentioned). 929 2.5.20 Processin Full disclosure of the chemistry and chemicals used in the process and The process chemicals are described in some detail in g Plant their environmental impact, together with MSDS data is not apparent. MLP Section 4.7.2.6 and Material Safety Data Sheets were included in MLP Appendix L. 930 2.5.20 Processin It is noted that in the cleaning process (page 168) excess sodium chloride The sodium chloride (salt) from the cleaning process would g Plant (salt) is removed from the product….where does all of the sodium chloride be recirculated in the process water tanks to be used in the end up? process plant. 931 2.5.21 Flocculent Magnafloc has known high toxicity to freshwater fish and aquatic As noted in MLP Section 4.7.2.6, Magnafloc contains Dosing System vertebrates. The problem for this site is the close proximity to Pillaworta cationic polymer(s) that may be toxic to aquatic organisms Creek which is also supplied with water from the mine site. when tested in pure (distilled) water. Toxicity is greatly reduced by particles in natural water. All Magnafloc would eventually end up in the TSF where it would be absorbed into the solid soil phase. Refer to Response 7.5 re discussion on surface water and Pillaworta Creek. 932 2.5.22 Product In the event that a bag is ruptured in transit….Curtained semitrailers would Bulka bags or Flexible Intermediate Bulk Containers (FIBC) Storage not provide the security of capture in such an event. have a unique circular and corner channel construction, a high tensile force maximises the strength and stability of FIBC's. AGL will employ correct procedures for handling, storage and transport of FIBC's. 933 2.5.23 Process Whilst there is some discussion concerning the levels of kerosene that may Kerosene is used in the process as a “collector” to attract Chemicals enter the environment, the issue remains, kerosene, once in the system graphite and hence remains with the graphite until drying cannot readily be removed. and only trace amounts of kerosene would enter the TSF which would at least partly volatise with the water.
Australian Graphite Pty Ltd 131 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response Refer to Issue #176 Response 7.5 934 2.5.24 Process Provision of potable water...would this include the supply of permanent It is not proposed to establish a potable water pipeline. Plant And Site potable water to all those in the vicinity of yet another pipeline, this time Water Balance carrying potable water, as opposed to a metered stand pipe located some distance away. 935 2.5.24 Process What is the impact upon the Water Allocation Plan that is apparently soon The groundwater system associated with the proposed Plant And Site to be released by the EPNRM Board….(and) impact the proposal may have Kookaburra Gully mine is not directly connected to the Water Balance upon the local water supply groundwater resources of the Southern Basins PWA (see Figure A5 of DEWNR Technical Report 2014/10). Any drawdown that can be attributed to the proposed mine outside of the Pillaworta Creek catchment is extremely unlikely (see Figure 3.20 of the MLP), and particularly in regards to aquifers of the Southern Basin PWA, which is located more than 30 km to the south of Kookaburra Gully . 939 2.5.26 Slope Given that significant infiltration is not expected to occur under the As indicated in MLP Section 4.6.5.3 a dump stability rating Stability assumed conditions, what is the risk assessment relevant to the actual site (DSR) was used. rainfall, taken over a twelve month period? The DSR scheme includes three alternative provisions for piezometric conditions which can be included in the assessment: • Favourable – low piezometric pressures, no seepage in foundation, development of phreatic surface within dump unlikely, limited precipitation, minimal infiltration into dump • Intermediate - moderate piezometric pressures, some seepage in foundation, limited development of phreatic surface within dump possible, moderate precipitation, high infiltration into dump • Unfavourable - high piezometric pressures, springs in foundation, significant potential for development of phreatic surface within dump or perched water table in dump, high precipitation MLP Table 4.28 indicates that and the Intermediate condition was adopted for the piezometric and climatic conditions. This was considered to be appropriate for the expected conditions at the site. See also additional comments in Response 7.5 & 7.6 940 2.5.26 Slope What is the risk assessment of the structure(s) when subjected to the Structures are designed and engineered for local Stability torrential rainfall that can occasional occur in this region conditions including torrential rain (1:100 year ARI) and
Australian Graphite Pty Ltd 132 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response must comply with the associated Acts, Regulations and building codes. 945 2.5.29 Embankm Management of PAF: what chemical reactions are likely to occur, given the AMD is a specific type of wastewater, which arises in ent Details composition of the TSF and what are the results of such chemical mining of sulphidic ores, ore tailings or overburdens. At reactions. The chemistry should also include potential photochemical sites of moderate-to-high rainfall, AMD can be produced in reactions large quantities, which significantly complicates its treatment. Due to mineralogy, and other environmental factors (especially climate), the potential for AMD formation is highly variable from site to site. Pyrite oxidation takes place when the mineral is exposed to both air and water. AMD involves the oxidation of pyrite and other sulphides, and yields Fe3+ and sulphuric acid. The overall chemical reaction governing pyrite oxidation is:
FeS2 + 15/4 O2 + 7/2 H2O ! Fe(OH)3 + 2SO4 PAF materials are inert as long as they are not exposed to both oxygen and water. Photochemistry is the branch of chemistry concerned with the chemical effects of light. 946 2.5.29 Embankm Diversion Channel: the construction of the open rock lined channel….would Water in the diversion channel would be no different to ent Details allow for absorption of water to occur thereby allowing potentially surface water runoff today because the channel is contaminated water to enter the environment en-route to the aquifer designed to divert runoff above the TSF around all infrastructure. 949 2.5.30 Rehabilitat To what depth has the contaminants contained with the TSF penetrated the It is not proposed to remove tailings from the TSF. The ion Operations substrate and thus to what depth below the surface does the ‘removal of clay liner beneath the tailings will retard the movement of For The TSF tailing’ require? Where will this contaminated material go, once removed? some constituents in tailings seepage (such as heavy metals), and the mine pit will be managed so as to form the ultimate containment for any solutes originating in the TSF that might leach to the water table. 950 2.5.30 Rehabilitat It is noted that the topsoil stockpile will most likely contain seed banks of An environmental management plan will form part of the ion Operations listed species (pp. 197). That being the case, the Company should ensure PEPR. This will include protection of topsoil and seed For The TSF that the seed bank is totally protected. A detailed horticulture...should be banks and establishing a plant nursery for future inclusive in the PEPR. revegetation. 952 2.5.32 Wastes Results published are those applicable to a limited (if not restricted) sample Table 4.39 describes the composition of tailings from a and can be considered to be NOT representative of the complete picture of number of samples, not just one trench sample. Samples the ore body, given that the ‘sample’ was taken from the ‘Kookaburra Gully were collected from Trench 4 at the top of the orebody, trench’ at depth of a few metres beneath surface level. Trench 1 about 35m lower down, a composite suite of samples from 50-65m below the top of the orebody and a composite suite of samples from 65m down to the bottom
Australian Graphite Pty Ltd 133 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response of the orebody 90m below the Trench 4 sample. 953 2.5.33 Oils And It is assumed flocculants will be stored under similar constraints as all other All hazardous chemicals will be stored in the correct Storage Of hazardous materials. manner and as specified by the chemicals MSDS. Chemicals Chemical storage cabinets will be utilised for smaller chemical products required onsite. Emergency spill response stations will located at chemical storage areas. 954 2.5.33 Oils And Will all vehicles leaving the site be washed down and what control Refer MLP Sections 4.8.3.1 and 4.8.3.2. Wash-down water Storage Of measures will be instigated to ensure that the wastes arising from this will be directed to a collection sump where the sediment Chemicals facility do not contribute to the spreading of weeds? will be removed (to the TSF) and the overflow will be directed to the common oil-water separator. A weed management plan will be developed for mining operations. 955 2.5.33 Oils And Have the necessary approvals been sought from the EPA and the District AGL is working with DCTB on these requirements and will Storage Of Council of Tumby Bay with respect to the sewerage system to be work with the EPA for permitting Mineral processing once a Chemicals employed? Mining Lease has been granted.. 959 2.5.33 Supporting It is assumed that the (onsite) laboratory will be capable of monitoring the AGL will undertake monitoring and sampling and submit Surface air and water quality for compliance requirements as well as those activities samples for specialised analysis by an ISO accredited Infrastructure associated with the mining operations. laboratory. 960 2.5.33 Supporting Risks incurred should a breach of the (diesel fuel) tank or pipeline or the Diesel storage tanks will be double walled and Surface involvement of the fuel store in fire and the fire-fighting procedures that constructed/installed on concrete strip slabs that are Infrastructure would prevent diesel from entering the Pillaworta Creek environment (or bunded in accordance with Australian Standards. the ground water system). A Site Emergency Plan would be developed considering all risks associated with the mining operation. 962 2.5.33 Supporting Erosion control measures outlined during the initial construction phase may There will be no release of surface waters that are mine Surface be sufficient to contain particulate matter arising from runoff, but not that impacted without meeting EPA water quality guidelines. Infrastructure which is dissolved. Water diverted from the upper reaches of the Cullen creek and Harris creek would be natural runoff not impacted by mining operations. Drains from around the WRSFs would be channelled into sediment traps for monitoring of both sediment and dissolved matter. 963 2.5.33 Supporting Have discussions been undertaken with DCTB with respect to erection of No. Surface wind turbines in this area noting the requirements under the DCTB Infrastructure Development Plan? 966 2.5.33 Supporting Is this provision (water from Tod Reservoir) contrary to government policy No. Surface in that mining companies are required to provide their own water supplies? Infrastructure
Australian Graphite Pty Ltd 134 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 969 2.6.2 Community ‘sponsorship of the Yallunda Flat and Lipson Horticultural Shows’….is Yallunda Flat Show was sponsored in 2009 and 2010 and Support incorrect. Lipson Show was sponsored from 2010 to 2013 976 2.6.6 Environmen Establishment of an on-site native nursery and planting program This would be part of the PEPR Environmental t immediately the project commences to ensure the replacement of native Management Plan (inclusive of listed species) trees and grasses 982 Water Restriction to an impact zone of 1 kilometre radius of the mine is See above response to issue raised under Reference by Management considered irresponsible, if not environmental vandalism, in the context of submission page 9 and 13-14. The so-called “impact zone the hazardous minerals identified in the rock analysis (pages 106 - 107) of 1 km radius” (see wording used in the adjoining submission) is not a limitation imposed on the model predictions but the result of transient simulation of groundwater system response to mine dewatering. 983 Water Nature of the contaminant in Tod water, apart from the obvious cause of Refer issue #275 and Response 7.5 Management the salinity. 986 Traffic Inconsistencies exist in the application as to the actual heavy vehicle usage Refer issue #20 and Response 7.9 of Pillaworta Road….and total road usage rate. 987 Traffic Expertise of those who undertook the survey for a road that will be required The survey was undertaken by a Parsons Brinckerhoff civil to carry significant tonnages on a 24/7 basis. engineer who has specialist expertise in road design. The survey was undertaken in conjunction with the DCTB Works Manager/Engineer. 994 Air Quality Dust data relates to PM10 but without any analysis of the actual A dust monitoring program would be enacted prior to the contaminant contained within the dust start of mining operations and would be ongoing throughout the project life. See Response 7.6 issues #8 to #13. 995 Air Quality Impact of graphite dust from the mine as well as diesel fumes and Refer to air quality report Appendix C, Issue #277 and particulates from the 24/7 operation of machinery and the power station. Issue #Govt-26 of Response 7.6 996 Air Quality Data relevant to P2.5 and P1.0, considered essential for the monitoring of Refer issue #8, #9, #10 & #11 and Response 7.6 health impacts and contamination of pastures and grain, given the nature of contaminant identified. 1000 Rehabilitation Ability of the Company to fund the rehabilitation Refer issue #823 in Appendix 1. Rehabilitation will be progressively undertaken during the mining operation and hence funded by operating cash flow. The cash flow forecasts for the project (see Response 5.2) indicate that the project is economically viable and that there would be sufficient funds available during and at the conclusion of operations to fund rehabilitation. 1002 Rehabilitation If, as suggested the (pit) lake is an evaporation pond, then concentrations As described in MLP Section 8.6.2, the pit lake will act as of whatever is dissolved increases. If it is salt, then it has the potential to an evaporative sink, with groundwater flowing towards it throughout the modelled interval (500 years). The
Australian Graphite Pty Ltd 135 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response migrate to adjacent soils. modelled pit lake level at 144m AHD is well below the soil level so groundwater would flow from the soil into the lake not vice versa. 1003 Rehabilitation What is the long-term (500 year) prognosis for the mine site and the lake? Refer Section 8.6.2 in MLP. 1014 Economic Impacts Missing is a baseline of property valuations against which any movement Property valuations based on sales of properties in the can be gauged to either support or deny the supposition of decline of immediate district over recent years are quite varied and values….a farmer would not purchase property at market value if a mineral values per hectare vary considerably due to the size of exploration licence, claim of lease were over the land properties, location, farming seasons, grain prices and market conditions. Exploration licenses have been held over most of this region (Koppio Hills) for several decades since at least the 1960s and have not affected property valuations. 1019 Economic Impact Baseline concentration of graphite in surface soils exists and already has The graphite ore body is exposed at the surface for about an identifiable impact upon wool quality half its length (the northern half) and graphite has been continuously eroded from this outcrop for thousands of years. Graphite does not break down or alter to other minerals so remains within both the in situ and transported soils developed immediately above and downslope of the orebody. Therefore, all the soils immediately west of the orebody down to Pillaworta Creek contain graphite as do sediments along Pillaworta Creek itself. Graphite occurs in soil within a belt all the way along the 4.5 km long interpreted extension of the orebody southwest of the proposed minesite. 1022 Risk Register Control criteria and a method of disposal of the ‘collected potentially Refer issues #15 & #273 and Responses 7.6 & 7.3 K_31 contaminated water, inclusive of potentially acid forming materials respectively A more detailed surface and site water management plan will form part of the PEPR. 1023 Risk Register The Acid Rock Drainage Management Plan should have been an integral High-level management of acid rock drainage has been K_33 part of the Application and subject to public scrutiny. described in Section 4.3.6 of the MLP. A more detailed, more technical management plan will form part of the PEPR. 1024 Risk Register The Tailings operation and Management Plan should have been an integral The Tailings Management Plan forms an integral part of the K_34, K_35 & part of the Application and subject to public scrutiny PEPR. K_36 1026 Table 6.7 In the event the Mining Lease is approved, that members of the community Members of the community have already and will be able to be invited to participate in the formulation of the various plans identified in continue to contribute to the formulation of management
Australian Graphite Pty Ltd 136 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response the context of this application. plans. 1030 2.8.2 Referring to “Listed species will not be impacted directly by mine activities” implies Directly impacted refers to physical clearance of vegetation MLA 7.2 - 7.2.1 what? Will not be impacted by machinery, fugitive dust, dewatering, (eg within the confines of the pit or WRSF sites etc). There deprivation of water or contaminated water? will be some dust and water impacts (including potential for overspray of saline water) as described within the MLP Section 7.2.4. 1032 7.2.4.2 There appears to be some confusion as to the location or locations of Yes, there were several sites selected for the proposed WRSF WRSFs. These were presented and discussed at landholder and community stakeholder meetings during the preparation of the MLP. As a consequence, the preferred locations of the WRSFs were moved. Some of the original locations and preliminary designs are still shown in the older independent consultant reports (eg. MLP Appendices G and H). However, the locations and designs shown within the main body of the report (Volume 1) are correct and accurate. 1041 Table 7.9 Does bi-annual monitoring of flora survey sites accommodate the life cycles Targeted flora surveys will be undertaken at varying of all threatened species periods throughout the life cycle of threatened species. 1042 Table 7.9 Conduct of annual flora studies for the purpose of detecting impact arising Continuous monitoring of flora is not feasible in that regard. from high salinity….It is suggested that continuous monitoring is required. Flora and fauna surveys will be conducted as required and biannually to monitor any potential impacts. 1043 Table 7.9 Quantity of salt potentially spread over the ML as a consequence of Water derived from dewatering will be saline (~5000 mg/L) dewatering and ultimately as the ‘lake forms’ as a consequence of and this will be used both for the process plant and also cessation of mining and subsequent “rehabilitation”? dust suppression. Risk K_08 in MLP Table 7.9 addresses the risk of saline water used for dust suppression and methods to be implemented to reduce and minimise that risk. It would be confined to haul roads and areas of exposed WRSF etc. The risk of salt being spread over the ML from the pit lake is considered to be negligible and no different to salt being spread from sections of Pillaworta Creek which is equally saline and which locally dries up over summer. The pit lake level will remain relatively constant due to the groundwater influx so there are unlikely to be large areas of “dry salt flats” that could cause windblown salt to be spread over the surrounding area. 1044 7.2.7.4 No standard exists for the measurement of cumulative dust, but a 'Selected Refer Govt 22-27 and Response 7.6 baseline of 4g/m2/month' has been incorporated….What is the scientific validity of this selection? As indicated in MLP Section 3.7, the NERDC guideline level of 4g/m2/month was adopted as there is no SAEPA
Australian Graphite Pty Ltd 137 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response level specified in legislation or guidelines. This concentration has also been adopted by Victoria and NSW. Therefore this level is considered appropriate. 1045 7.2.9 What negotiations with local land owners has taken place with respect to No discussions have been held with local landowners at the location of monitors (dust, noise, vibration) on their properties? this stage of the MLA. That will form part of the detailed operational design parameters. 1047 7.3.2 Upon what baseline study has DCTB provided advice that there are no DCTB has not provided that advice. DCTB advised that concerns? there were possums in the area. 1048 7.3.2 Pygmy possums and echidnas are known to be in the area. Noted, thank you. The fauna survey found evidence of echidna scratchings on the MC's, however no possums were found. 1049 Table 7.12(?) Water within the tailings dam being contaminated water and the Concentration of process reagents in tailings will not be K_16 consequences of consumption by native fauna (land based or birds) sufficient to result in mortality or injury to native fauna.
Refer MLP Section 4.7.2.6 and Issue #176 Response 7.5.
Tails water assays, MLP Table 4.41, show dissolved organic carbon as 14mg/l. The Material Safety Data Sheets for kerosene and V80 kerosene indicate that the liquid at 14mg/l (14ppm) does not pose a risk to native fauna.
1050 7.3.4.3 & 7.3.5.3 Noise dispersion inclusive of dispersion (air burst) of blasting/explosion and Refer issues #68, #69, #279 & #280 and Response 7.7 vibration (surface and in ground) and infrasound…impact on fauna Impact would be minimal given planned low powder factors and explosive charge mass of <10kg/m, so blasting vibration and overpressure will not be significant. 1051 7.3.7 No night time fauna study has occurred on Section 125 Spotlighting occurred on Section 129 immediately adjacent to Section 125 and is considered to be representative of that area. 1053 7.4.4 The site based drilling program was EXCLUSIVE to MC 4373 and was a Numerical groundwater flow modelling has been single drill hole that only penetrated within the graphite resource body. undertaken. The model has been calibrated to the results of a pumping test as well as observed groundwater head data in the area of the project. The predicted potentiometric contours presented in Figure 7.5 are not hypothetical and result from simulation of the groundwater system. The model has been calibrated to the results of a pumping test as well as observed (and available) groundwater head data in the area of the project.
Australian Graphite Pty Ltd 138 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 1055 7.4.5.3 pit area' outlined in figure 7.9 appears to ignore any impact within the The risk assessment has been informed by field 'designated pit area' within MC 4372 investigations and numerical modelling, as described in a number of responses above. 1056 7.4.5.4 pit will fill with water (to a level stabilized by the Standing Water Table), See response to similar issues above, particularly in regard BUT the problem now being the exposure of water to broken rock and to the mine pit acting as a groundwater sink. thereby chemical contamination by heavy metals, manganese and uranium etc, thus allowing ready contamination of the ground water system inclusive There will be no heavy water associated with the mine process. of contaminated ground water entering the Pillaworta Creek The concentrations of the different elements in weathered rock are similar to that of the unweathered material. See response to similar issues above, particularly in regard to the mine pit acting as a groundwater sink. 1057 7.4.5.7 estimated 4 - 6% of the total volume of waste rock could be potentially acid MLP Section 4.7.5 rock precursors, the question is what tonnage of rock will form the waste rock pile, thus the estimate source of contamination is an unknown Based on MLP Table 4.31, up to 0.5-0.7 million tonnes of waste rock could be potentially ARD (years 5 to 8). 1058 7.4.6.5 compressed clay is not necessarily a low permeably liner, especially in the The compressed clay low permeability liner is up to 3m in context that the processes used in separation of graphite from the ore/clay thickness and is also underlain by a further clay and uses surfactant chemistry, the same chemistry that may take place in the saprolite layer of the order of 10m-15m thick to basement. TSF with a degradation of the so called ‘low permeability layer’ Extensive permeability tests will be undertaken in the design process. 1061 7.4.6.8 Provision of septic system as required by the Tumby Bay Development AGL will employ the most suitable septic system that Plan….better option may be to install biocycle technologies complies with DCTB Development Plan. 1063 7.4.7 (K_22) The flow of contaminants (seepage, etc.) into the pit and then to “use this The need to use of water from the pit to re-establish flows water to re-establish flows in the Pillaworta Creek” in Pillaworta Creek is considered to be highly unlikely and unnecessary but has been suggested as a fallback position if required. However, to do this would require a Water Affecting Permit for which there are very strict conditions and which would include a guarantee that such water was not contaminated. 1064 7.4.8.2 The impact upon native grasses, native orchids and other listed species MLP Section 7.4.8.2 refers to the impact of groundwater on and the habitat in general, is ignored. vegetation. Native grasses and orchids are seasonal and not reliant on groundwater so would not be impacted. The effect on deeper-rooted vegetation such as Eyre Peninsula Blue Gum and other trees is considered as an impact event and would be reduced by implementation of groundwater and GDE monitoring program. See Response 7.4 to Issue #Govt-2
Australian Graphite Pty Ltd 139 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 1065 7.4.8.5 TSF embankment has been constructed and analysis undertaken on its Correct, the proposed design of the TSF embankment “impermeability” states that the entire upstream side of the embankment will be lined with a high density polyethylene (HDPE) liner (MLP Figure 4.65). 1067 7.4.8.5 The pit is below the Standing Water Level; therefore it is within the aquifer. This is not correct. During mining operations groundwater Any water within the pit area has the potential to move into the confines of would flow into the pit and after rehabilitation the pit the aquifer. remains as an evaporative sink as described in MLP Section 8.6.2 and again net groundwater flow is into the pit. See Issue #Govt-31. 1069 7.4.8.8 Samples for analysis were taken from a limited number of drill holes on Detailed geochemical laboratory analysis was undertaken MC 4373 on 38 samples and more restricted sulphur analysis was undertaken on over 1150 samples. In addition, every single 1-metre drill sample was analysed in the field by a field portable XRF. Established principles of geological science allow interpretation of conditions to be extended north into MC 4372 by a Competent Person, in this case an experienced geologist. 1070 7.4.8.8 Cr(VI) needs to be identified specifically. (Exceeds limit: no MSDS) Cr(III) The oxidation of chromium(III) to chromium(VI) → Cr(VI) is the chemistry conducive to oxidation of Cr(III) → Cr(VI)? An excess of sodium hydroxide solution is added to a solution of the hexaaquachromium(III) ions to produce a solution of green hexahydroxochromate(III) ions.
This is then oxidised by warming it with hydrogen peroxide solution. You eventually get a bright yellow solution containing chromate(VI) ions.
Australian Graphite Pty Ltd 140 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response
The key to oxidation of Cr (III) to Cr (VI) is being in solution and the addition of hydrogen peroxide solution. 1071 7.4.9 ACCUMULATIVE impact of the excesses noting, in particular, that the Issues #16 and #17 in Response 7.4, Issue #1080 in mining operation now allows: Response 7.5 and MLP Section 7.4.8.8 discuss the a. These substances mobility (i.e. no longer bound in the ore body). potential contamination of groundwater by heavy metals in b. Subject to weathering due to exposure above ground level. the orebody and associated waste rock. c. Leaching due to the impact of rainfall through the body of the waste rock The waste rock facilities will be progressively rehabilitated dump back into the soil and ultimately the underlying aquifer. and capped by a dry-cover system (see discussion below in Govt Issue #29). They will also have toe drains to capture any surface seepage and divert that into sediment traps where water quality can be monitored. No PAF material will be stored in the WRSFs so the potential for acid generation in the WRSFs is rated as unlikely and risk of groundwater contamination as low. 1072 7.5 AGL MLA uses unsubstantiated evidence from another company (Eyre Iron That is not correct; AGL itself has measured the salinities in Pty. Ltd.) to establish salinity in the Pillaworta Creek Pillaworta Creek and has commenced an ongoing monitoring program. MLP Section 3.10.2 describes typical salinity concentrations in Pillaworta Creek pools and expected variability in stream salinity. 1073 7.5.2 "EPNRM Board expressed a desire that water flows to Pillaworta Creek The EPNRM Board did not specify their concerns, just a and water depended ecosystems were maintained...... ," what are the desire to maintain flows in Pillaworta Creek. environmental impacts which gave rise to the concerns that the Board necessitating this condition 1075 7.5.4.7 & 7.5.4.8 What is the precise nature of these ‘sulphides’ and what is the chemistry of The sulphides are predominantly iron sulphides or the TSF that might impact upon these entities to enhance the production of pyrite/pyrrhotite. Samples with elevated sulphur only have ‘acid rock’ products that give rise to ‘acid soils’? very low background levels of base metals such as copper- lead-zinc. The rate of ARD production depends on a number of
Australian Graphite Pty Ltd 141 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response factors such as: • Surface area of sulphide minerals exposed: Increasing the surface area of sulphide minerals exposed to air and water increases sulphide oxidation and ARD formation. • Type of minerals present: Not all sulphide minerals are oxidized at the same rate, and neutralization by other minerals present may occur, which would slow the production of ARD. • Amount of oxygen present: Sulphide minerals oxidize more quickly where there is more oxygen available. As a result, ARD formation rates are higher where the sulphides are exposed to air than where they are buried under soil or water. • Amount of water available: Cycles of wetting and drying accelerate ARD formation by dissolving and removing oxidation products, leaving a fresh mineral surface for oxidation. In addition, greater volumes of ARD are often produced in wetter areas where there is more water available for reaction for example the Tropics. 1077 7.5.7.3 Whilst there are some exceedance of some EILs, the proposed surface Refer Govt Issue #30 and Response 8.6, water control and management measures would mitigate against potential impacts….would control/management procedures adequately provide the “controls” required. 1078 7.5.7.3 The risk assessment appears devoid of considerations associated with The existing tenements are mineral claims NOT production Cadmium, Manganese, Cobalt, Silver, Gold, Uranium oxide, Vanadium for tenements. They are the precursor to applying for a which ‘production tenement status was granted by DSD as reported in the mineral lease. AGL has applied for a Mineral Lease for MESA Journal 75 4-2014, page 82’. graphite and associated minerals including magnesite. The other minerals listed have not been identified in the ore or associated rocks in significant quantities above background crustal levels. 1079 7.5.7.3 Rare Earth compounds (Ce, Cs, Ga, Hf, In, La, Nb, Rb, Re, Sc, Ta, Th, Te, These elements are not present in any significant quantities Y)….and Strontium, Thorium and Vanadium have not been subjected to above normal crustal background levels in either the ore or any form of risk assessment. waste rock and therefore do not present any risk. 1080 7.5.7.3 Reference is made to an arbitrary standard the GAI (Geochemical Response 7.5 Abundance Index), which could for convenience be described as a fudging figure
Australian Graphite Pty Ltd 142 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 1081 7.5.7.3 The “capping” proposed is inconsistent with the stated objective of the This statement is confusing; the capping process is totally rehabilitation plan to return the WRSF to primary production. consistent with re-establishing the WRSFs to agricultural use by establishing a soil-subsoil profile or “capping” over the WRSF to mimic the regional soil-subsoil profiles. 1085 7.6.4.5 The impact of diesel fumes and particulates arising from the transport Refer issue #Govt-26 and Response 7.6 corridor on the basis of 24 semi-trailer movements per day during daylight hours. 1088 7.6.9 It is noted real time monitoring is envisage. What is the location of the The location of real-time dust monitoring equipment has not receptors? yet been specified but will be decided on the basis of Government and landowner input. 1089 7.7.2 What is not clear is the intention of the applicant to operate the transport AGL has always made it clear that trucking operations fleet outside of the 7 a.m. to 7 p.m. timeframe would be in daylight hours avoiding school bus times. 1090 Figures 7.16, 7.17 Underlying photograph does not have the necessary reference points (road Noted but the aerial photograph can be easily cross & 7.18 way, houses, Mining Claim boundaries) shown. referenced to MLP Figures 7.11 to 7.15, 1091 Figures 7.16, 7.17 ‘modelling’ or predictions for all the other residences previously identified, Modelling has shown that for ALL other residences, the & 7.18 and plotted on an appropriate topographic map. noise levels are well below the following: • 52 dB(A) between the hours of 7 am and 10 pm and • 45 dB(A) between the hours of 10 pm and 7 am. in accordance with the Environment Protection (Noise) Policy. 1093 7.7.5.2 impacts of blasting on fauna, domesticated animals (horses, sheep, cattle, Refer issue #280 and Response 7.7 goats, etc.), residences identified (not just the Cullen house opposite) and concrete troughs and other agricultural industry infrastructures. Impact would be minimal given planned low powder factors and explosive charge mass of <10kg/m, so blasting vibration and overpressure will not be significant. 1094 7.7.8 recommended that continuous noise monitoring be undertaken for a period A noise monitoring plan will be developed for construction of time during which construction and full time production is brought on line and mine operations. to establish an appropriate baseline 1095 7.8.2 Stakeholder views must include advice from local landowners who have Noted. AGL has used the services of EPAnalysis and practical knowledge with respect to soil management in addition to Rural Solutions SA to do soil sampling and analysis in the Government authorities area. EPAnalysis is a local Eyre Peninsula company with extensive local knowledge and experience. 1098 7.8.5.4 Periodic chemical analysis of rock samples to accurately identify sources of A waste rock grade control model will be constructed acid forming rock in the context of a new rock face exposure (through during mining operations and definition/delineation of rock blasting) given that it would appear the extensive drilling and analysis work categories. has not been undertaken over the pit area
Australian Graphite Pty Ltd 143 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 1102! 7.12 Nature of the asbestiform material, the health risks of asbestos….‘control Asbestiform material most commonly occurs as chrysotile, regime’ where asbestiform materials may have been placed within WRSF the asbestiform member of the serpentine group, and five or other locations...compliance requirements minerals of the amphibole group: (1) crocidolite, (2) amosite, (3) anthophyllite asbestos, (4) actinolite asbestos, and (5) tremolite asbestos. While tremolite and actinolite are common accessories in marble within the region, they have not been observed locally in the very fine fibrous asbestiform state. Nevertheless, AGL will maintain an ongoing petrological monitoring program. Note: The American Society for Testing Materials (ASTM) has defined asbestiform minerals as mineral fibre populations generally having the following characteristics when viewed by light microscopy: (1) many particles with aspect ratios ranging from 20:1 to 100:1 or higher (greater than 5µm in length); (2) very thin fibrils generally less than 0.5µm in width; and (3) in addition to the mandatory fibrillar crystal growth, two or more of the following attributes: (a) parallel fibres occurring in bundles, (b) fibres displaying splayed ends, (c) matted masses of individual fibres, and (d) fibres showing curvature. 1103! Table 7.51 Register K_58 has no relevance to the Koppio area Reference to Tarcoola was an error and reference to Tarcoola and pastoralists should be removed. The Environmental Receptor should read “Residents, residents’ vehicles and livestock on the road” The Consequences should also include “Collision with and damage to vehicles and/or injury or death to residents or occupants of the vehicles” 1106 7.13.5.2 Mining Act, what compliance regime exists for entry to mining operations The Mining Act governs entry on private land for the and what compensation regime applies….does the provision of fencing exploration and mining of minerals owned by the crown come under the Fences Act? through the Notice of Entry and Waiver of Exemption regimes. Compensation is applied on a confidential basis with the directly impacted landholders. AGL will fence the perimeter of the Mining Lease. 1108 7.13.5.7 What level of financial support is proposed to be forth coming in order that AGL has not yet considered the level of financial support emergency services can meet the expectations generated by the mining for emergency services. This will be determined in operation? consultation with the DCTB and local emergency service groups.
Australian Graphite Pty Ltd 144 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Issue # Topic Technical Issues Raised in Public Submissions. Kookaburra Gully Response 1109 7.13.6 & Table What level of tangible support is envisaged for the AGL will further develop community support programs and 7.52 community….scholarship fund...critical care unit and staff at the services once mining operations commence. hospital…RFDS…airfield facilities…native nursery. 1112 7.13.9 Complaints register….a scale of incidents may be able to be generated A complaints register will be established by AGL in with appropriate time lines applied. conjunction with community consultation to establish a preferred format, medium and appropriate time lines. 1120 8.7 & Table 8.7 General project closure:...potential for increased weed infestation and pest As previously indicated throughout the MLP and Response incursion to the site...land use has significantly been altered, indicating that Document, it is AGL’s intention to return the land to mining and agriculture cannot co-exist….destruction of agricultural land. agricultural use and farm management. 1121 8.8 & Table 8.9 Rehabilitation time scale is the critical performance It is agreed that the establishment time for Native indicator….establishment time for Native Vegetation is Vegetation is significant as shown by recovery from the significant….monitoring and eradication program for weeds has no time Wangary fire of 2005. Certain plants recover quicker than line….groundwater monitoring….Seepage from the TSP over time, not the others and the revegetation program will focus on life of the operation but 20, 50, 100 years....pit lake introducing those plants first. Revegetation of WRSFs will commence before mining is finished and will be progressive.
Australian Graphite Pty Ltd 145 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) Appendix 2: Issues raised by the South Australian Government
During the consultation period the mining proposal (MP) was circulated to a number of SA Government departments that were deemed relevant based on the information provided. Please find below a table providing issues raised that require points of clarification and/or additional information to enable a comprehensive assessment of the proposal, prior to final consideration by the South Australian government.
# Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document
Description of Environment 1 Groundwater - Section The groundwater quality data presented in the MP is localised to one Please comment on the assumptions and uncertainties of baseline quality 3.11.1.2, Page region of the proposed operations (the southern end of the open pit) and the baseline groundwater quality assessment. assessment 59 is isolated to a single pump test. There is uncertainty in the description Based on the current baseline groundwater assessment of groundwater quality. categorise the existing groundwater in accordance with A baseline groundwater quality assessment should be undertaken in fresh and marine water quality ANZECC guidelines. accordance with the ANZECC prior to any operations occurring (should Response 3.11 a lease be granted). The quality of groundwater obtained from the baseline assessment should be used to determine the potential uses of This is discussed in MLP Section 3.11.1.4 the water. 2 Groundwater 3.12.3, page It is suggested that the following sentence is reviewed. Clarify the uncertainties relating to this assessment. Clarify Dependent 75 whether this will have implications on vegetation not Ecosystems ‘It is likely that the root systems of these species would be accessing identified for clearance. groundwater, however definitive evidence was not clear whether the During field assessment of ponds along Pillaworta Creek, source of this water is from underground, but a proportion of the overall AGL did not observe the ponds to entirely dry out during volume originates as runoff from the surrounding catchment’. summer and could not definitely determine if the vegetation Without evidence to demonstrate that vegetation is not supported by is or is not reliant on groundwater. Until the depth of the groundwater, it should be assumed that some reliance on groundwater root zone is determined and the depth of groundwater is exists. also factored in, it is agreed that there may be some reliance on groundwater during summer months. 3 Groundwater 3.12.3, page It is suggested that the following sentence is reviewed. Clarify the uncertainties relating to this assessment. Clarify Dependent 77 whether this will have implications on vegetation not Ecosystems ‘The Sedgeland communities have mostly rhizomatous root systems that identified for clearance. would probably extend to depths of 400 mm to 500 mm. Given that It is agreed that there may be some reliance on natural groundwater occurs at greater depths it is unlikely that these groundwater by Sedgeland communities along Pillaworta plant communities would be accessing groundwater’. Creek and maybe also Harris creek during summer months. There are no wells with available water level data located near Pillaworta During the PEPR formulation it is proposed to install a creek or the sedgeland communities (Veg association 14, Gahnia filum series of groundwater monitoring wells relating to Pillaworta Sedgeland); so the assumption that groundwater is below the root zone Creek and the proposed mine footprint. Investigations will
Australian Graphite Pty Ltd 146 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document gives rise to uncertainty. At this stage it should be assumed that some also be undertaken to determine the root zones of plants reliance on groundwater exists. along these waterways. 4 Site 3.11.1.2; While the groundwater contours show an east-west gradient (Fig 3.26, Provide clarification on the likelihood that mounding under Hydrogeological Pages 61-63; based on Fig 3.27 and Appendix H) any mounding under the TSF may the TSF will result in a changed flow regime for seepage Assessment Appendix H alter this regime and seepage may flow radially from the TSF and from the TSF. towards the southern valley and to the east into Rock Valley. It is noted Response 7.6 that the TSF is located close to the boundary of Pillaworta and Rocky valleys (a probable groundwater divide) (Figure 3.20).
Description of Operations 5 Construction of 4.10.3.1 It is not clear under what authority the water pipeline is to be AGL – Council and SA Water approval (if we use SA Water water pipeline constructed. Clarify if the pipeline is to be permanent or removed land) from the Tod following completion of the project. Consideration needs to be given to Clarify the authority under which the water pipeline is to be Reservoir to the the process and the timing for obtaining approvals and construction of constructed. Mine site the water pipeline. Since the majority of the pipeline route follows the roads it would be constructed under DC Tumby Bay authority. It forms part of the MoU with the DCTB and has been assessed as part of AGL’s EPBC Referral. There is a short section of the route proposed within SA Water land so that section would be negotiated with them. Clarify whether the pipeline will be permanent or temporary for the life of the project. It is proposed that the pipeline be a temporary structure for the life of the project. It would be removed following completion of the project if there was no benefit to any stakeholders. Issue #760 in Response 7.5 6 Proposed 4.4.2; Page The Response Document should make clear the tenement under which Clarify the intent and timing of exploration activities. Exploration 126-7 exploration activities are to be conducted. The MP refers to exploration Clarify whether exploration activities are to be conducted on Program activities currently approved under exploration lease EL4998 and EL4998 under the authority of EPEPR 2013-038 or under described within E-PEPR2013-038. Based on the work described within the authority of the proposed ML (should a lease be EPEPR 2013-038, one of the objectives of the program is to gather granted), or both. geotechnical and metallurgical information that may be required to complete a Mining PEPR. The MP states that this EPEPR was extended Approved exploration activities proposed at Kookaburra to 25 August 2015 however it has since been extended to 5 May 2016. A Gully Extended under the SA Government PACE program
Australian Graphite Pty Ltd 147 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document new EPEPR will need to be submitted using the new exploration are planned to be undertaken in early 2016. They are templates if this exploration program is not finalised prior to the expiry entirely on EL 5065 and are described within E-PEPR2013- date of the existing EPEPR (5 May 2016). 060. Approved exploration activities proposed at Kookaburra Gully on E-PEPR 2013-038 are related to For activities to be conducted on the EL, a section 80 agreement must EL 4998 whereas planned exploration/mining operations on be in place with all parties (EL holder, Lincoln Minerals, ML Holders) to the mineral claims requires a further E-PEPR. Lincoln allow exploration. Minerals has a Section 80 agreement with the EL holder. The alternative is that the exploration activities are conducted on the ML Geotechnical drilling planned for Kookaburra Gully would (should a lease be granted). If this option is chosen, the Response require a separate E-PEPR because those activities are Document must make this intention clear and the activities can only located on MC 4372 and MC 4373. An E-PEPR 2015-049 commence once the exploration activities are authorized through the has been approved for low-impact activities including soil approval of a Mining PEPR. sampling on those mineral claims and an E-PEPR for geotechnical drilling and trenching is in preparation. A further E-PEPR will need to be prepared for the interim period between granting of the anticipated Mining Lease but before the Mining PEPR is approved. There is an issue of multiple E-PEPR's in this scenario as the Mineral Claim and proposed mining lease area is only 300Ha in size and some exploration and mining related works required for the PEPR (EG groundwater monitoring wells) may cover a much larger area than the proposed mining lease. 7 Proposed 4.4.2; Page It is unclear if additional exploration activities are planned which would Describe any future exploration activities planned to be Exploration 126-7 occur under the authority of the Mining Lease (should a lease be conducted on the proposed ML. Program granted). Ensure that all potential impacts, control strategies and outcomes cover these activities. Refer to the above response (SA Govt Issue #6) 8 Proposed 4.4.2; Page It is expected that aspects of exploration will be rehabilitated (e.g. Clearly articulate within the response document whether all Exploration 126-7 drillhole decommissioning, capping of drillholes, backfilling pits and other exploration activities have been rehabilitated to prevent any Program hazards). If rehabilitation is not to be completed under the authority of future confusion as to what tenement the impacts are the EPEPR (as the activities occur within the footprint of the pit), impacts associated with. must be factored into SEB payments, and bond calculations for the If rehabilitation of all exploration activities is completed, mining PEPR (should a lease be granted). indicate this in the response document and that there is no outstanding exploration liability. There are no outstanding rehabilitation activities required
Australian Graphite Pty Ltd 148 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document other than ongoing annual compliance reporting. ALL drillholes have been rehabilitated and inspected by and to the satisfaction of DSD officers. Refer MLP Photo 3.10 in MLP Section 3.17.3 All exploration works undertaken on the EL, MC or pending ML will have rehabilitation completed within 3 months of the expiry of the E-PEPR (for PEPR's approved for 12 months), or 3 months after the expiry of the program notification (for PEPR's approved for an on-going period) unless otherwise authorised. If a Mining License is granting, exploration works will be rehabilitated under the same conditions. Representative photos from before, during and after exploration works (drilling, excavations etc) will demonstrate all drillholes were permanently or temporarily capped/plugged immediately upon completion. No fauna/livestock can become trapped in drillhole or excavations during the exploration program. Refer to Response to SA Govt Issue #6. 9 Groundwater 4.5.9; Main The numerical groundwater model has only been designed to include Identify the limitations, uncertainties and assumptions of the Modelling document: the fractured rock aquifer, and has not included the alluvial aquifer that groundwater model in the response document particularly exists in creek lines. In addition the model has assumed uniform where relevant to the impact assessment for groundwater Pages 143 to hydraulic and transmissivity values which are unlikely to represent in-situ and GDEs. 160 conditions of the two aquifer types. Consider improving the design of the numerical 7.4.7 & The numerical model includes assumptions and uncertainties relating to groundwater model to include 7.4.8.2; impacts on Pillaworta Creek and associated groundwater dependent Pages: 293 & ecosystems such as EP Blue Gums. In addition, uncertainty exists in the • Include a layer for the alluvial aquifer, and assign 299 model outputs such as the potentiometric surface and drawn-down maps appropriate hydraulic and transmissivity values to reflect the alluvial aquifer’s properties Appendix D – (Figures 4.45, 4.50 & 4.51). Groundwater • Include nodes in MODFLOW model to determine As such the numerical modelling work completed is consistent with a modelling drawdown impacts for each individual EP Blue Gum Class 1 numerical groundwater model as defined by the Australian report pg. 5 to within the model’s existing boundaries. groundwater modelling guidelines. Further work has been completed to 9 • Calibrate river bed conductance values that improve the confidence in the model however it is still considered at best considers the alluvial aquifer a Class 1 model. A Class 1 model is suitable for ‘Developing coarse relationships between Response 4.5.9 groundwater extraction locations and rates and associated impacts’.
Increasing the model classification level to Class 2 would require further
Australian Graphite Pty Ltd 149 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document field work and possible re-conceptualisation of the model. Additional field DSD may require the groundwater model to be updated to a work would include but not be limited to: class 2 model before submission of a PEPR should a lease be granted. • Drilling and pump testing at more than one location Noted and understood. • Collection of regional water levels for model calibration Should the aforementioned modelling be undertaken, it • Improving the understanding of groundwater-surface water suggested that the risk assessment for impacts K19 & K20 interactions should be reviewed. • Understanding variations in river bed conductance, river bed Acknowledged elevation and river stage height Other improvements would include inclusion of TSF seepage into the numerical model. 10 Potential Pages 152-3 Sensitivity/uncertainty analysis was previously requested by Clarify why the input parameters are the most appropriate impacts to Government to provide a range of potential drawdowns impacts that for the model. groundwater - could be expected based on realistic aquifer parameters. The sensitivity analysis indicates there could be an impact Groundwater It is unclear how the sensitivity/uncertainty analysis has been interpreted on the pools and groundwater users, however this has not Modelling to confirm that the input parameters used in the model are the most been discussed or analysed in the proposal or appendices. appropriate for modelling at Kookaburra Gully. Provide in the response document analysis and discussion on the results from alternative case modelled (k = 0.08 The sensitivity analysis included a higher k scenario of 0.08 m/d (10 x m/d). base case). This scenario indicted that drawdown of 0.5 m is possible at the permanent pools located 2 km southwest of the pit (approximate Response 4.5.9 coordinates 581409, 6191263, WGS84 Z53) however under the base case modelling parameters it is not predicted. In your proposal you have committed to conducting groundwater monitoring prior to and during operation to validate the base case modelling predictions. 11 Groundwater Pages 160 Page 160: The text states that the ‘Two large pools about 2 km As above, provide discussion on the results from alternative Modelling and 285 southwest of the proposed pit are sited outside the modelled cone of case modelled (k = 0.08 m/d). depression, which means that groundwater feeding them (if any) will be Response 4.5.9, Govt Issue #10 unaffected by dewatering associated with mining, both during operations and post closure’. There was no predictive model run with Kh = 0.08m/d, only a sensitivity run using initial heads developed for the base Page 285: The modelling indicates there would be no impacts or zero case (as is the situation with sensitivity testing). drawdown at the ponds. These statements are only correct for the model base case.
Australian Graphite Pty Ltd 150 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document 12 Groundwater Page 145 In relation to the groundwater model the following sentence is incorrect: Clarify the inflows to the model. Revised sentence – “Inflow to the model is input as ‘It has been assumed that all inflows to the model are derived from distributed rainfall recharge as well as MODEL rainfall’. CALCULATED river recharge where river reaches are River recharge is the largest contributor to the model. influent.” 13 Groundwater Page 148 Steady state SRMS. Provide an update of Figure 4.46 in the response document Figure 4.44 with the excluded point or provide reasons for its exclusion This does not match the data presented in Figure 4.46 where the range and how is the overall SRMS affected by the exclusion of of modelled heads is 148.64 - 159.88 mAHD and the range for the the point, 159.88, 164.4, from the calculation. observed heads is 145.7 - 164.4. mAHD. It appears that the point An updated figure is presented in Response 4.5.9 159.88, 164.4 is missing from the graph. 14 Groundwater Page 156 It does not appear that the locations of the wells in Figure 4.52 have Provide locations in a map or table. been specified in chapter 4.5.9 or in Appendix D. The locations of the Hudson, Borthwick and Cullen wells are shown in MLP Figures 4.50 and 4.51 (and 3.28) while KK038 (and KK051) is shown in MLP Figures 3.25, 3.26 and 4.46.
Easting Northing Cullen home bore/well 582797 6193134 Hudson Pillaworta Creek well/pump jack 584879 6194819 Historic Bore 583542 6194118 KK038 / KK051 (in pit) 583290 6192649
15 Groundwater Page 156 What is the basis for input (65.5 ML/d) and outputs (66.2 ML/d) values Clarify the basis for the inputs and outputs relating to from river leakage in the transient model runs documented in Table 4.21. leakage from the ephemeral creek in the transient model. The river leakage values in the table (66.5ML/d IN and 66.2 ML/d OUT) were erroneously transferred to the modelling report addendum from an earlier (discarded) version of the model and then subsequently included in the MLP. The correct values are presented below.
Australian Graphite Pty Ltd 151 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document
MLP Table 4.21 Dewatering run water balance, Kh = 0.008 m/d Volumetric budget for entire model at end of time step 10 in stress period 8 3 Rates For This Time Step Cumulative Volumes (m ) 3 (m /d) In: In: Storage = 1253225.5 Storage = 633.3561 Constant Head = 0.0000 Constant Head = 0.0000 Drains = 0.0000 Drains = 0.0000 River Leakage = 3342741.75 River Leakage = 1273.2388 Recharge = 2581850.75 Recharge = 983.1875 Total In = 7177818.0 Total In = 2889.7825 Out: Out: Storage = 25549.4746 Storage = 5.3928 Constant Head = 0.0000 Constant Head = 0.0000 Drains = 1213472.625 Drains = 632.6616 River Leakage = 5937933.5 River Leakage = 2250.7803 Recharge = 0.0000 Recharge = 0.0000 Total Out = 7176955.5 Total Out = 2888.8347 In - Out = 862.5 In - Out = 0.9478 Percent Discrepancy = 0.01 Percent Discre pancy = 0.03
These values reflect the true behaviour of the model and do not change the reported impacts arising out of the model. NB This table also replaces Table 2 in the MLP Appendix D modelling addendum report. Table 3 of the modelling addendum report (MLP Appendix D) also included high river leakage values erroneously copied into it. The appropriate values for this table are presented below.
Australian Graphite Pty Ltd 152 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document
Dewatering run water balance, Kh = 0.08 m/d Volumetric budget for entire model at end of time step 10 in stress period using Kh = 0.08 m/d 3 Rates For This Time Step Cumulative Volumes (m ) 3 (m /d) In: In: Storage = 24629810.0 Storage = 9011.6213 Constant Head = 0.0000 Constant Head = 0.0000 Drains = 0.0000 Drains = 0.0000 River Leakage = 4174400.0 River Leakage = 1737.8146 Recharge = 2581851.25 Recharge = 983.1875 Total In = 31386060.0000 Total In = 11732.6143 Out: Out: Storage = 4999219.0 Storage = 1368.8513 Constant Head = 0.0000 Constant Head = 0.0000 Drains 6053908.5 Drains = 3521.5037 River Leakage = 20332386.0 River Leakage = 6841.4795 Recharge = 0.0000 Recharge = 0.0000 Total Out = 31385514.0 Total Out = 11731.834 In - Out = 546.0 In - Out = 0.7893 Percent Discrepancy = 0.00 Percent Discrepancy = 0.01
16 Low-grade 4.7.6 Some low-grade ore samples have been identified as PAF (4.3.6.2). In Provide strategies to manage the potential for AMD Stockpile section 4.7.6 it is stated that low-grade ore will be stored on the ROM generation from the PAF in the low-grade ore stockpile to pad (in between the plant and Pillaworta Road) and in Table 8.5 it is demonstrate that groundwater and surface water outcomes stated that if the low-grade material ‘has not been processed at are achievable. completion of operation the material will be incorporated into the waste Clarify the management of this material at closure and post rock storage with appropriate cover material to minimize any potential for closure should it not be processed. AMD’. However the TSF is the only PAF storage facility designated in the MP. There are no design considerations presented for PAF material Response 4.7 in the waste rock storage facilities. Management of the low grade stockpile is unclear particularly in relation to AMD given that PAF material could be stored here for a number of years.
Australian Graphite Pty Ltd 153 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document 17 Geotechnical 4.7.7.2; pages Testing of foundation materials (clays) for the TSF is recognised as of a Provide an estimate of the volume of clay material required stability/ 192-3 preliminary nature however no process is provided for ensuring that the for construction of the TSF and where it will be sourced. foundation foundation material will provide a competent liner and adequately Provide strategies for addressing in-situ areas that do not material for the manage seepage from the TSF. have adequate material properties to act as a liner if there TSF No materials balance has been provided for construction of the TSF. It is a shortfall of clay material. has not been identified where additional clay material would be sourced Drilling in the area of the proposed TSF embankment from if required for the liner of the TSF. (KK049 and KK050) shows that clay and saprolitic clay extend to a depth of 9m-18m below the ground surface. Section 5.6.1 of the AMC report (MLP Appendix H) indicates that clay from the embankment footprint will be excavated to bedrock or a depth of 3m. Based on the latter, AMC estimated 238,000 m3 (Table 5.4 in MLP Appendix H) of clay would be excavated from the embankment foundations. Given the size of the ultimate embankment footprint, there will be sufficient material available for the cutoff trench. Surplus material will be used to supplement lining of the upstream storage area. The local geology of the proposed mining lease indicates that saprolitic clay is developed to a depth of at least 1600m AHD in the area of the TSF. This is part of the extensive regional Tertiary weathering profile developed throughout the Lincoln Uplands. Given that most of the TSF is higher in elevation than the embankment foundation (IE above 170m AHD), the thickness/depth of clay throughout the TSF area is expected to be at least 10m so it is highly unlikely that any additional clay would be needed for the construction of the TSF liner. 18 PAF tailings 4.7.7.2; Page It is stated that: “All PAF tailings would be disposed directly into the TSF Provide an estimate of the total volume of PAF tailings. 193 supernatant pond which, combined with the low permeability of the Tailings produced by processing of ore below 120m AHD = unconsolidated tailings material (1.00E-6 m/s for surface tailings) will 0.78 tonnes or 713,000 m3 unconsolidated or 560,000 m3 maintain the tailings in a fully saturated state. Maintaining the tailings in consolidated. a saturated state will generate an oxygen free environment and hence limit the potential for acid to be generated during operations. Management of the supernatant pond will be a high priority during the Clarify how PAF tailings will be deposited directly into the operation of the TSF to ensure that the PAF tailings remain saturated.” supernatant and clarify implications of such a strategy for
Australian Graphite Pty Ltd 154 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document The above statement contradicts the typical method of sub-aerial tailings operation of the TSF. deposition from at or close to the TSF wall which will be required to The location of the supernatant pond is as far away from create tailings beaches. As per Appendix H page 19, creating tailings the engineered embankment as possible which is against beaches is necessary to maximise storage of the TSF. Depositing the northern hill. When the identified PAF tailings are being tailings directly into the supernatant may inhibit the creation of beaches produced the tailings deposition strategy will change from and may not achieve the required consolidation and density of tailings. spigots around the engineered embankment to single point Disposal of PAF tailings directly into the supernatant will require a discharge directly from the northern hill into the supernatant different deposition strategy and is likely to require a different spigoting pond. Consideration at this stage is not maximizing storage system (or other mechanism) to non-PAF tailings. volume but prevention of acid formation thus a sub- aqueous disposal method will be used. Tailings under It is not clear what the anticipated volume of PAF tailings is. water or saturated i.e. all void spaces filled with water not It appears that there is a potential for the supernatant to become oxygen, would be non-acid forming or marginal, so acidified under certain conditions. attenuation would not be a high risk. During mining operations and mineral processing a wet cover will be maintained until a time when operations have been decommissioned and whence a dry cover system can be emplaced (see response to Issue #Govt-28).
Consider implications (if any) of the supernatant becoming acidified for return water to the plant and seepage (to the pit and groundwater). Management of the supernatant pond will be a high priority during operation of the TSF to ensure that the PAF tailings remain saturated and acid formation cannot occur. AMC recommend a risk assessment be completed as part of the detailed design stage. 19 PAF (waste 4.7.7.2; page It is unclear how the TSF PAF cell will operate, for example how the cell Provide clarity in relation to how the PAF cell will operate rock) Cell 193-195 will be accessed to place the waste rock considering no method to inhibit within the TSF. operation the intrusion of the supernatant is proposed. It is not clear how the PAF The PAF waste rock cell will be constructed as a dry stable cell will be kept open until it is required for use (PAF disposal). platform from the northern edge of the TSF. Once Keeping the PAF cell saturated may increase evaporation and therefore production of PAF waste rock has ceased, encapsulation by water use and increase the potential for seepage. Acid generation may tailings will occur. If required, the final design will include an occur unless the PAF cell is saturated in which case it is not clear how embankment surrounding the PAF cell. placement of PAF material would occur. AMC recommended that this design be revisited when more Figure 4.68 shows PAF exposed at the surface during operations. It is details about the characteristics of both the tailings and stated that the PAF cell will be saturated to limit acid generation however PAF material, as well as the PAF waste schedule becomes
Australian Graphite Pty Ltd 155 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document it is not clear how this will occur and it is not reflected in diagrams (ie available. Figure 4.67). Specific tailings management practices would be required It is not anticipated that any significant PAF material will be to avoid acid generation. mined during years 1 to 4 nor during the construction period so it is unlikely that initial construction of the TSF will cause significant acid generation and unlikely that further steps to address this are required. Describe uncertainties and assumptions in the operation of the PAF cell and in the impact assessment relating to the TSF. AMC’s recommendations specified that the encapsulation of the PAF waste is an important component of the TSF operating philosophy and determination of the actual PAF production schedule is required. A laboratory-testing programme is also required to determine the physical (not chemical) characteristics of the PAF waste material. It should be noted that the PAF waste rock disposal concept (PAF cell) was developed by AMC prior to the introduction of PAF tailings. Once the details of the physical characteristics become available, an overall design addressing both the PAF waste rock and PAF tailings would be completed. As noted above, If required, the final design will include an embankment surrounding the PAF cell. 20 Seepage 4.7.7.2; page The scope of the seepage modelling is not clear, ie whether it is for the Clarify if the scope of the seepage analysis is for the entire analysis 192-196 and entire TSF footprint or just the embankment and embankment TSF footprint or just the embankment and embankment 301 foundation. foundation.
The seepage analysis is just for the embankment and
embankment foundation. AMC conducted a steady state seepage analysis on the TSF embankment to provide a preliminary estimate of the amount of seepage that can be expected from the embankment and its foundations. This analysis used AMC estimates since no material permeability values were available. As part of AMC’s recommendations, additional site investigations are required to determine the geotechnical, hydrological and hydrogeological properties of the TSF footprint area.
Australian Graphite Pty Ltd 156 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document 21 Potential for 4.3.6; The risk of AMD is noted and found to be associated with ore deeper Clarify whether the tailings samples are representative of AMD Appendix I, than 120 mAHD (4.3.6.3 Figures 4.20 to 4.24). The location of tailings the tailings from ore in the PAF zone. Pages 107- samples listed in Table 4.9 is not described. Later reading of 4.8.1.1 The tailings analysis details reported in MLP Table 4.9 are 122 (page 201) suggests the tailings are not from the deeper PAF ore. from the shallower NAF ore samples derived from the trenches (representing years 1 to 4). The same trench sample assays are reproduced in MLP Table 4.39 along with calculated tailings assays for samples from the deeper PAF ore (years 5 to 8). The calculated assays are based on laboratory whole rock assays minus TGC as assayed in the concentrates and so are equally representative. 22 Air Quality Appendix C. The background PM10 concentrations used for the air quality model Conduct a sensitivity analysis on the air quality model by Model - Section 5.3.7 contains assumptions and uncertainty because it was collected 6km varying the background concentration data inputs and Background (page 20) from site and was collected in 2013 which is considered an atypical year reporting on the change in the number of days of concentrations (2009 is a more typical year) and are therefore lower than expected. exceedances at Receptors. Response 7.6 23 Air quality/dust Appendix C In Table 8.1 of the Air Quality Assessment report (Appendix C) it is not Provide a justification for using the 95th percentile in the air modelling Table 8.1 clear whether maximum PM10 values provided for each receptor are quality modelling for PM10. 95th percentile values or true maximums. The indication from the Provide in the response document a new version of Table heading of Table 8.1 is that the highest 5% of days (18 days out of 365 8.1 and Figures 8.1 and B.1 including 100% of the data for days) have been removed from the analysis. This is further supported by PM10. . the isopleth figure (Figure 8.1) which shows higher concentrations at the receptors than provided in Table 8.1 and which appears to be based on Provide evidence and justification that the air quality 100% of the data. In Figure 8.1 concentrations at R1, R2 and R13 outcomes will be achieved (given that DSD will expect appear to be higher than presented in Table 8.1. There is no further measurement criteria to be 50 µg/m3 over a 24 hour information provided or justification for removing the highest 5% of average) and propose new control strategies if they are values from the analysis. required to ensure achievement of the outcome. It is not clear in Figure B.1 (Air Quality Assessment Appendix C; Clarify that Figure 8.3 (PM2.5) is for cumulative impacts Appendix B) whether the highest 5% of values in the dataset have been rather than incremental impacts as indicated in the heading. removed from the analysis. Response 7.6
24 Air quality/dust Appendix C; The emissions factors used do not provide enough clarity on what was Provide more clarity on the emissions factor assumptions modelling – B1 modelled. The actual emission value (grams/hectare) is not provided, for for each input to the model. Provide the actual emission emission factors example, what dust generation parameter was used for areas of factor inputs to the model in grams/ hectare (or equivalent) exposed soil or waste rock? Some of the emission factors used contain in a revised Table B1. Emission Factors. Clarify where control measures and some do not appear to. control measures are contained in the emission factor parameter inputs to the model. It is not clear that potential dust generation from the TSF has been
Australian Graphite Pty Ltd 157 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document included as an input to the model. Under some climatic and operational Clarify if the emissions from the TSF are included in the Air scenarios the TSF would be expected to generate dust and it should be Quality model. If not please justify why. included as a source of dust in the air quality model. Based on the outcome of your response to Issue 22, It is not clear which mine dust sources are the largest contributor to dust consider conducting a sensitivity analysis on the air quality concentrations at the closest human receptors. model by varying relevant emission factor data inputs and reporting on the change in the number of days of It is not clear what the Annual Scenario numbers are referring to in Table exceedances at Receptors. B.2. Based on the modelling, describe the mine dust sources that are the largest contributors to mine generated dust concentrations at the closest human receptors. Provide full references for all of the abbreviated references (i.e. NPI EET (2012)) given in Table B1 (Appendix B to Appendix C: Air Quality Assessment) so we can review the basis for emission inputs. Response 7.6 25 Air quality/dust Appendix C; It is stated that that the highest annual incremental concentration Justify that the annual incremental concentration predicted modelling Page 31 predicted for PM10 was 4.4µg/m3 (R1). Does this mean that the for PM10 at R1 is 4.4µg/m3. increase to the background on an annual average basis 300m from the 24-hour PM incremental concentrations are significantly mine is only 4.4µg/m3? 10 lower in comparison to the 24-hour measurements shown in Table 8.2 of the AQIA report (MLP Appendix). This is due to these results being the average across all 365 days of PM10 projected concentrations; whereas Table 8.1 of the AQIA report shows the maximum PM10 24-hour measurements. 26 Air quality/dust Impacts from burning of fuels for the diesel generators, haul trucks and Provide an assessment of potential air quality impacts from modelling other on-site equipment is not modeled as the report does not consider the diesel generators, haul trucks and other on-site these emissions to have an impact on air-quality off site. However the equipment. diesel generators’ fuel rate of 12,500 litres per day and likely emissions Response 7.6 from mobile equipment is not insignificant and therefore the potential impacts from NOx, particulate matter, CO and SO2 should be considered. 27 Air Quality - 7.6.3, page DSD does not apply 5 exceedances to PM10 air quality measurement Provide an update of Table 7.22 in the response document NEPM 321 criteria (Table 7.22) as a result of mining operations. and remove ‘Exceedances allowed per year’ column. Exceedances At present there are no specific guideline limits in South Australia for particulates (only chemical analytes). South Australia has therefore enacted the National Environmental
Australian Graphite Pty Ltd 158 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document Protection (Ambient Air Quality) Measure 1998 as the required air quality standards for air pollution for PM10 and PM2.5 criteria. These standards allow for five (5) PM10 exceedances per year.
Closure/Mine Completion 28 TSF Closure 8.6.4 It is not demonstrated that the strategies for closure will appropriately Clarify how the closure strategies (conceptual cover design Strategies manage potential closure risks for the long term. and final land form design) will achieve the relevant environmental outcomes and the proposed post mining land A post mining land use of grazing or arable land or pasture has been use. proposed. It is not clear if the closure strategies will achieve this post mining land use. The proposed closure strategy is to establish a dry-cover system by placing benign wasterock, subsoil and topsoil over the whole area of the TSF consistent with the existing soil profile that is currently used for cultivation. This strategy has been successfully used in many mine sites throughout Australia (eg sand mining areas) to restore farmland back to cultivated fields equal to if not better than original. Implementing a dry-cover system is a common AMD prevention and control technique. The objectives of a dry cover system are to minimise the influx of water and provide an oxygen barrier. Apart from these functions, dry covers should be resistant to erosion and should provide support to vegetation. A low permeability layer, typically achieved through compaction, is placed directly on the underlying waste. The objective is to provide a hydraulic barrier to percolation of water. A non-compacted layer must overlay the compacted layer. Its objective is to establish a sustainable vegetation cover and at the same time reduce the net percolation. Additional design objectives for dry cover systems placed on reactive tailings and waste rock may consider oxygen consumption (organic cover materials) and reaction- inhibiting materials (e.g. limestone). AMC recommends that the rehabilitation and closure plans continue to be updated for the TSF as the project moves forward. Part of this closure plan would include the necessary monitoring requirements and field trials to
Australian Graphite Pty Ltd 159 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document establish best practice cover systems. 29 TSF – PAF Cell 4.7.4; Table Neither the TSF rehabilitation (4.7.4) section nor the closure section for Provide clarification on all of the issues raised. closure and 4.31; Pages Domain 3, including the TSF, (8.6.4) mentions the PAF cell and no Response 8.6 Rehabilitation 178-179 measures are proposed to close the PAF cell specifically. As stated in the AMC report (MLP Appendix H), further 8.6.4; 8.6.4.1, The lack of information regarding the PAF cell raises a number of study is required regarding closure and rehabilitation as the Table 8.6; queries and issues: project moves forward. This includes developing strategies Pages 398- to maintain the encapsulation of the PAF cell, cover 399 • Figure 4.68 shows PAF exposed at the surface for periods 2 and 3. However the TSF closure strategy does not appear to integrity and slopes. maintain the PAF cell in a saturated state. How will this be
managed during closure? • Will the PAF cell need to be allowed to dry out to achieve Clarify where the materials identified in Tables 4.31 & 8.6 consolidation? What is the potential for acid generation will be sourced from. during this phase of closure? As outlined in Table 4.31 the total estimated volumes of • Will the store and release cover provide adequate topsoil and subsoil generated by pre-stripping the pit, TSF, protection to mitigate the potential for PAF seepage? WRSF, process plant areas prior to construction and • The slope of the store and release cover is designed to development are 235,000 LCM (0.47 Mt) of topsoil and drain inward. Will this promote ponding on the TSF leading 990,000 LCM (1.88 Mt) of subsoil. This material will be to seepage from the TSF/PAF cell and promote continued stockpiled in the topsoil and subsoil stockpiles respectively. wetting and drying of the TSF/PAF material? The volumes required for rehabilitation as identified in Table • PAF material is generated mostly late in the life of the pit 8.6 are 205,000 LCM and 690,000 LCM respectively. This when less waste rock is being mined and is available for indicates that there will be sufficient topsoil and subsoil in closure and encapsulation without double-handling. the respective stockpiles for rehabilitation. • Diagrams and information provided does not identify the source of materials needed for closure. Refer SA Govt Issue #18 for cover discussion. Cover systems will be developed and refined over the life of the project to develop best practice and sustainable future and no legacy issues. Options to eliminate seepage include clay lining, potential limestone rubble course to alleviate PAF with acid consuming material, and then placement of NAF waste rock and subsoil-topsoil profiles. A detailed mine plan and schedule for material movements will be developed as the project moves from conceptual to actual. As with most mine plans they evolve other the life of the project as new advances in mining technology and production efficiencies are implemented. There is sufficient NAF waste rock at Kookaburra Gully.
Australian Graphite Pty Ltd 160 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document 30 WRSF Closure 8.6.4 There is no consideration of the potential for Neutral Metalliferous Provide an assessment of the potential impacts and Strategies Drainage (NMD) from the WRSFs post closure. This is relevant strategies (if required) to manage NMD from the WRSFs considering run-off and seepage from the WRSF will ultimately report to post closure. Pillaworta Creek. In some cases, the acidity produced by sulfide oxidation can be neutralised in the presence of carbonate minerals. The result is neutral metalliferous drainage (NMD) or neutral mine drainage, which has a near-neutral pH but contains elevated dissolved metal sulfate salinity. At Kookaburra Gully, the sulphides are almost exclusively iron sulphides (pyrite) so the NMD would be iron sulphate. Surface drainage and WRSF drainage will be engineered to redirect drains and bunds to sediment traps, where depending on the water quality, water will either be recycled or released from site. Response 8.6.4 31 Closure Domain 8.6.2; Pages The final pit lake water level will determine whether the pit becomes a Identify the uncertainties related to modelling (as a whole) 1 - Open Pit - Pit 392-395; sink for groundwater or a flow-through system with pit water reporting to of the rate of pit water recovery and the final pit water level lake Modelling 8.6.2; Page Pillaworta Creek. This will determine the impacts post closure (if any) to post-closure. This will inform the process to improve future 408 groundwater. modelling. Section 8.6.2 does not identify the modelling uncertainty of pit lake water Identify the uncertainties specific to the model scenario level return post closure. The report describes 4 runoff scenarios for presented in Table 8.1. Clarify the management strategies which the results of only 3 are stated hence it is not clear what happens that are required to achieving this scenario (placement of under the fourth scenario. Is it possible that in the fourth scenario the pit the abandonment bund, maintaining integrity of diversion lake rises above the potentiometric surface and if so what are the drains and dewater diversion bunds etc). These must be implications of this. relevant and not rely on active management post surrender of the mine lease. The pit lake model chosen in the report for the closure strategy (Table 8.1) is for the pit to “remain an evaporative sink with groundwater flowing Clarify in the response document the pit lake level at which towards it throughout the modelled interval.” The modelled pit water level it becomes a flow through system resulting in discharge is about 144 m AHD or higher with increasing salinity over time (through from the pit towards the creek. This is understood to be at evaporation). The identification of a preferred scenario in the report is about 150 m AHD. appropriate however it is not clear what the basis for the chosen model The lowest point of the pit crest should be identified (i.e. the scenario is. Is it because it is the most realistic with the most support elevation that will result in surface water discharge from the from the data or is it the scenario with the least environmental impacts. pit). While it is agreed that a scenario where the pit is a sink (below 144 m AHD) is preferable the most realistic scenario should be presented and The fourth model scenario should be provided in the used as the basis for refining the model. response document.
Australian Graphite Pty Ltd 161 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document A number of specific uncertainties relating to this scenario are evident as Response 8.6.2, SA Govt Issue 31a follows: Clarify the potential for seepage from the pit post closure • Given that groundwater heads west of the pit (Figure 4.46) are even if the pit remains an evaporative sink. Identify this as 145 to 146 mAHD it is conceivable that the pit could easily an uncertainty in the pit lake closure modelling. transition to a flow through system. In light of the requests above, review the closure impact • It is not clear how the modelled pit lake level relates to the events, outcomes and measurement criteria. lowest point of the pit crest (ie the amount of freeboard). • It is not clear what the seasonal variation in the pit lake level is Response 8.8, SA Govt Issue 31b and whether this will be significant or not (i.e. the winter seasonal high will need to be considered). There is a potential for connectivity between the pit and groundwater due to possible fractures in the local pit geology and effects of mining and blasting even if the pit is an evaporative sink through leakage. The model does not recognize the potential for a solute flux between the pit and surrounding groundwater. Contaminants in the pit lake (including salts) may not remain contained in the pit in perpetuity if there is connectivity between the pit lake and groundwater. This should be recognized as a potential impact to groundwater in the closure risk assessment. An understanding of the geology underlying the pit, and an understanding of the likely hydro-geochemistry of the pit and surrounding groundwater will inform the potential for seepage from the pit. 32 Pit lake water 8.6.2 page There is a period of approximately 10 years directly after closure where Consider the potential for acid generation from the pit post quality 397, 7.4; the pit water level will be below 120 m AHD and PAF material may be closure in the period until the water level is consistently Page 289 & exposed to the atmosphere. While most of the sulphide material is to be above the level where most of the sulphide material is Page 35; mined some will remain and a level of acid generation is expected to present in the pit. occur during this period. Appendix D – Most of the sulphide is in the ore (high- and low-grade) Groundwater Consideration may need to be given to expediting the pit lake recovery which will be mined out down to the floor of the pit and so Modelling in the first few years to bring the water level above the 120 m AHD base sulphide will only be exposed on the floor of the pit and not Report, of oxidation. in the walls. Therefore this sulphide will be covered by Section 7 water very soon after mining ceases so the potential for and level of acid generation will be negligible.
Australian Graphite Pty Ltd 162 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document
Impact Assessment and Management Strategies 33 Impact Section 7 Limitations (including uncertainties) deriving from assumptions made in Describe any significant degree of uncertainty pertaining to Assessment the impact assessment are not clearly provided (as required by 6.3 of the evaluation of environmental impacts, including MD006). For example groundwater uncertainties should be described in limitations to modelling and quality of data. relation to the assumptions in the seepage analysis and groundwater Provide a description of the assumptions and uncertainties drawdown model. contained in the groundwater model which informed the Many of the judgments made about risks to groundwater in this section impact assessment. The uncertainties will guide whether are dependent on key assumptions. additional hydrogeological data needs to be collected should a lease be granted. Response 7.1 34 SEB ratio for Page 271 of An SEB ratio has been provided for all of the areas that will be subject to Should a lease be granted, an acceptable SEB must be native vegetation MP disturbance. However, it’s noted that a comprehensive survey of described in the PEPR based on a thorough understanding clearance MC4372 (northern end of the open pit) has not occurred, or not been of all vegetation to be cleared, including that contained on included in this report. Accordingly, the SEB ratio that has been applied MC4372. will need to be reviewed once further survey information has been A flora and fauna survey was undertaken by EBS on the 17 provided. September 2015 on the Borthwick property (refer to attached Addendum 3). The same SEB rating has been applied to both the Cullen and Borthwick Sugar Gum vegetation associations and has been updated in the table in Response 7.2. 35 SEB ratio for Page 271 of Association 2 – Eucalyptus cladocalyx (Sugar Gum) Woodland has been Should a lease be granted, it expected that the SEB native vegetation MP. Page 44 assigned an SEB ratio of 4:1. In particular, this relates to the 6.54 ha of described in the PEPR will have an appropriate SEB ratio clearance and 80 of clearance for the Open Pit as specified in Table 7.11 – SEB calculation. assigned to Association 2 of at least 6:1. Appendix E – The ratio was assigned to the vegetation association due to the Association 2 SEB is changed from 4:1 to 8:1 due to the Flora and ‘moderate to low species diversity’ in the understory which has resulted presence of threatened species. Table 7.11 has been Fauna from a history of stock grazing. However this association contained 22 updated to reflect this change. native plant species within the impact area (including 3 threatened species) which would be considered moderate – moderately high. It also Response 7.2 contained only 5 introduced species, which would be considered low. Additionally, this vegetation community is naturally low in understorey species diversity and is often dominated by leaf litter. Accordingly, this vegetation association is in a condition that would be considered good and it should have a ratio that is reflective of this. Further, as stated in the report from EBS Ecology (Attachment E), the Eucalyptus cladocalyx Woodlands and associated communities provide high habitat values for a range of species by providing valuable habitat
Australian Graphite Pty Ltd 163 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document within a variety of vegetation strata. Accordingly, a ratio of 4:1 is considered insufficient to offset the impacts of clearance on this vegetation. 36 SEB offset for Page 271 of The Mining Lease proposal identifies 10 scattered trees that will be Should a lease be granted, the SEB calculation in the scattered trees MP. Page 66 impacted. The 10 trees are considered to have a combined canopy PEPR should appropriately apply the scattered tree of Appendix E cover of 0.95 ha. Table 7.11 – SEB Calculation, states that the SEB assessment method as discussed. – Flora and requirement for the 10 trees will be 0.95ha or a payment into the fund of The requirement is equivalent to 3.66ha. Table 7.11 SEB Fauna $2,750.25. However, this is not the proper application of the scattered calculation has been updated to a value of $8,467.70. tree assessment method. EBS has undertaken a full assessment of the trees and provides each tree with a corresponding score (Table 34 of The trees are located within 500m of 2ha of native Appendix E). Based in this information, the scattered trees would receive vegetation therefore a landscape rating of Moderate 2.25 is a total combined point score of 2266. If the SEB is to be achieved applied not Low 2.0. However due to AGL potentially paying through a payment into the fund, this would require a payment of a SEB, the landscape rating is automatically classed as $9,391.40 (equivalent to 4.12ha) low. Table 7.11 has been updated to reflect 4.12ha and the $9,391.40 noted. See Response 7.2 (SA Govt Issue #35) 37 SEB Page 223 of It’s stated that the SEB contribution will be achieved by paying into the If Kookaburra Gully chooses to deliver their SEB through a Contribution MP Native Vegetation Fund or equivalent approved fund (e.g. Nature means other than paying into the Native Vegetation Fund, Foundation SA). the proposal should be discussed with the Native Vegetation Management Unit to ensure that it aligns with Please note, an SEB can be achieved on ground by protecting and Native Vegetation Council policies. managing an area of remnant vegetation or re-establishing an area of vegetation. If an on ground SEB cannot be achieved, then the proponent Noted: the SEB contribution will be achieved by paying into may make a payment into the Native Vegetation Fund. However, making the Native Vegetation Fund or by entering into an a payment into a fund of any other kind (other than the Native agreement with a third party provider, such as Nature Vegetation Fund) is not supported. Foundation SA, to achieve an SEB on ground by protecting and managing an area of remnant vegetation or by re- establishing an area of vegetation. 38 Entrapment of 7.3.5.4, Page Control strategies could be strengthened in regards to exploration Control and management measures will be updated in the fauna in 275 operations. PEPR. trenches, dams The following is an acceptable control strategy: and pits ‘All drillholes will be securely capped immediately after completion of drilling.’ Noted: A separate E-PEPR has been prepared for exploration mining operations on MC 4372 and MC 4373 that includes these control and management strategies.
Australian Graphite Pty Ltd 164 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document 39 Potential 7.4.5 Groundwater impacts associated with drilling not included (depends if Where ongoing drilling is proposed, an assessment of these impacts from future drilling is planned). Potential impacts as a result of drilling could particular impacts is to be provided. drilling include: Noted: A separate E-PEPR has been prepared for 1. Groundwater contamination: exploration and drilling operations on MC 4372 and MC 4373 that includes these control and management • contamination of aquifers through entry of pollutants from the strategies. If necessary, a further E-PEPR will be developed surface on the basis of the above E-PEPR for proposed work • interconnection between aquifers (only if multiple aquifers exist) required to be undertaken after the anticipated Mining • degradation of natural hydrostatic conditions (maintain pre- Lease is granted but in the interim period before the Mining drilling pressures). PEPR is approved. 2. Discharge of groundwater into the surrounding environment. The collars for proposed drillholes will remain intact, but would be sealed/capped to prevent entry to any fauna. The decision on whether to partially or completely case the hole will be dependent on ground conditions and whether aquifers are intersected. If multiple and/or confined aquifers (unlikely given drilling to date) are intersected, the hole will be cased according to the relevant guidelines to prevent cross-flow contamination. Maintain documentation that drillholes are decommissioned in accordance with DSD M21 guidelines and/or specific conditions from DEWNR (Drilling Inspector) within 3 months of completion of the program. Drillholes will be restored to controlling geological conditions that existed before the hole was drilled. If multiple aquifers are intersected, the drillhole will be cemented and backfilled accordingly so that all aquifers are isolated to prevent the interaction/movement of groundwater between aquifers. 40 Groundwater – The cone of depression from dewatering will extend beneath Pillaworta Further information is required regarding potential impacts Pillaworta Creek Creek and the modelled losses from the Creek are expected to be less of proposed mining activities on this section of Pillaworta than 1 L/s and therefore applicant concludes that the impact on creek, including: groundwater feeding the Creek, pools and their ecosystems will be minimal. However, the effect is still only quantified in terms of a • An indicative range of potential water level changes volumetric flow reduction and not water level (assumed by applicant that throughout the year due to proposed mining operations water levels will not be affected measurably). Additionally, the applicant • An assessment of whether there is the potential for has not described the potential or likely downstream impacts in sufficient complete stream dry out in sections due to proposed detail. mining operations
Australian Graphite Pty Ltd 165 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document Groundwater is clearly identified as a contributor to water flows in • An assessment of potential impacts on downstream Pillaworta Creek. Consequently an indicative range of potential water pools and flow due to reduced and interrupted level changes throughout the year due to mining operations must be groundwater contribution to stream flow caused by provided (even if it is assumed to be minimal). Given small flows, focus proposed mining operations on extremes i.e. as per original feedback, will groundwater drawdown potentially result in complete stream dry out in sections? And what effect Response 7.4 might this have on downstream pools and flow given a reduced and interrupted groundwater contribution? 41 Groundwater – 7.4.8, pages Control measures proposed for seepage from the TSF embankment Provide information on how the seepage not captured Seepage from 299 - 301 (7.5.5.6) are not sufficient to manage the risks to groundwater. The through the seepage collection system will be managed. TSF seepage analysis in Appendix H (Page 28-29) states that the seepage Monitoring bores will determine whether there is any impact collection system will capture all the seepage through the embankment and if so any seepage not captured by the open pit and but this is only 30% of the seepage modelled. There is currently no dedicated seepage control would be collected by management measures proposed for the remaining 70% of the seepage interception wells. modelled. Appendix H states that it may be necessary to consider groundwater interception wells to capture up to 60% of the seepage. The risk acceptance in relation to management of seepage from the TSF Conduct a sensitivity analysis of the seepage flow rates (0.7 relies in part on the ‘presence of a reasonable thickness of clay l/s) by varying the parameters used in the seepage materials in the TSF foundations’ however no site characterization work assessment described in Appendix H, including sensitivity has been conducted and there is no indication of where clay material will to changes in the assumed permeability of the in situ clay. be sourced from. Permeability values used in the seepage analysis are AMC has indicated that it is not sure that a sensitivity theoretical only and there is no supporting information or validation that analysis in the seepage assessment will address the these rates will be achieved, consequently a sensitivity analysis should comments. The current seepage analysis is preliminary, be conducted on the parameters used in the seepage analysis. only deals with the embankment and is based on assumption. To develop seepage control measures the recommended geotechnical site investigation and hydrogeological study is required for the TSF footprint followed by a detailed seepage analysis using the information gathered. 42 Groundwater Page 297 Impact ID K_25. Residual likelihood requires revision (typo). Provide a statement of the residual likelihood. The residual risk assessment should read as follows: • Likelihood – Possible • Consequence – Minor • Residual Risk – Moderate
Australian Graphite Pty Ltd 166 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document 43 Groundwater Page 298 Impact ID K_27. This impact ID is assessing quality not quantity (water Clarify the statement ‘provide alternative water supply’ is a supply) as indicated. control and management strategy for this impact, given this is not mentioned in Section 7.4.6.5 Correct, the impact event relates to contamination of groundwater (decrease in quality). If this occurs then the water supply for the existing users and GDE would be compromised. AGL would seek to provide an alternative supply if required. 44 Air quality The air quality impact assessment does not include 100% of data for Provide an updated air quality impact assessment, air PM10 with the highest 5% (18 values) removed. quality model and analysis using 100% of the data for PM10. Refer to Response 7.6 – SA Govt Issue #23
45 Impact analysis - 7.4.6.2; Page Please define significant species or communities. Provide a new impact event analysis (source-pathway- Gahnia filum 306 receptor) for the potential impact of mine induced Sedgeland Vegetation association 14 (Gahnia filum Sedgeland) will potentially be groundwater drawdown on vegetation association 14. impacted by 0.5 m of drawdown under the base case scenario. As Risk ID's K_19 and K_20 detail mine dewatering impacts on detailed in the EBS report ‘The community is considered a vulnerable GDE's and in particular Table 7.15 of the MLP identifies ecosystem under the Provisional List of Threatened Ecosystems (DEH, Gahnia Filum and EP Blue Gums with source-pathway- 2005)’. receptor impact analysis. Provide a definition or explanation for what is meant by the term ‘significant species or communities’ The reference used the incorrect wording and should refer to “Impacts to nationally threatened (EPBC) or state listed threatened flora (K_02).” 46 Impact 7.4.58; 7.4.6.7; The impact assessment arrives at a low primary and residual risk of acid Additional information must be provided on how it is Assessment: Appendix M generation from the low grade stockpile and this risk is not covered by proposed to manage the generation of AMD from ore and Low grade (Risk K_26 any proposed outcome. It is identified as PAF with no management low grade stockpiles in order to achieve the relevant stockpile: and K_33), measures proposed to mitigate acid generation from the low grade environmental outcomes. also see stockpile. The low grade stockpile could be exposed to water and Refer to response to SA Govt Issue #16 above. 7.5.5.5 oxygen for a number of years. The measures proposed do not adequately manage the potential to impact surface waters, GDEs, groundwater and adjacent land.
Australian Graphite Pty Ltd 167 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document 47 WRSF run-off It is understood that there will be drains surrounding the WRSFs to Provide clear control and management strategies for waste management capture any drainage, runoff and seepage and divert this into rock placement to address potential impacts of sedimentation ponds. Once settled and following monitoring this will be contaminants entering groundwater, surface water and released off-lease and will report to Pillaworta Creek. The sediment dam water dependent ecosystems during operation and post will reduce sediment loading of runoff however no measures are mine completion. Provide strategies for managing run - off proposed to manage neutral metalliferous drainage (NMD) should it from waste rock dumps should monitoring find it contains occur. NMD may have an impact on stock use of this creek, GDEs and NMD. fauna if it occurs. Monitoring is only relevant if there is a strategy to Provide clarity on the likelihood of NMD occurring in channel this water elsewhere if dissolved metals are present. drainage from the WRSF. Refer to comments to SA Govt Issue #16 above in relation to control and management measures and SA Govt Issue #30 for Neutral Mine Drainage (NMD).
Environmental Outcomes 48 Environmental The trigger for inclusion of an Outcome is not clear, is it the Primary Risk Clarify in the Environmental Components methodology Outcomes: rating? what the trigger is for inclusion of an Outcome. The principle adopted is where Primary Risk was higher than low and reliance on control and management measures was required, then that would need an Outcome. In addition, an Outcome was adopted for issues that were considered by the community to be important. Response 7.1 49 Outcome Page381 Competition for labour is not regulated under the Mining Act. This This comment is for noting relating to K_61 outcome is not necessary. NOTED 50 Outcome for Pages 262-3 Impact events for dust deposition on crops and native vegetation have Include an environmental outcome and draft measurement K_06 and K_07 been identified but have not lead to an environmental outcome. criteria for dust impacts on crops and native vegetation. The Outcome is amended as follows: No loss of abundance or diversity of native vegetation on or off the lease and crops through: • clearance • dust/contaminant deposition • fire or other damage unless prior approval under relevant legislation or through
Australian Graphite Pty Ltd 168 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document agreement with the relevant land owner is obtained 51 Groundwater Page 384 It should reflect no adverse impact to the quality of groundwater Update groundwater quality outcome. Quality Outcome compared to baseline as a result of mining operations. See SA Govt Issue 42 re typo. (K_25) The last point in Control and Management Measures should read: “Implementation of remedial action if there is a reduction in groundwater quality compared to baseline as a result of mining operations.” 52 Visual Amenity Page 365 This outcome only relates to visual amenity impacts to nearby residents. Change Draft Outcomes to: “No adverse visual impact to Outcome (K_53) The public should be included. nearby residents or from Pillaworta Road or other public access points due to mining operations.” Review this outcome to include visual amenity impacts to the general public. Noted. Visual amenity actually includes the general public but the Outcome is amended as follows: “No adverse visual impact to nearby residents or from Pillaworta Road or other public access points due to mining operations.” 53 Closure Pages 411-2 The following closure outcomes are required for mine completion but Provide closure outcomes for these environmental aspects, Outcomes: have not been included: together with a summary of control and management strategies, and draft completion criteria for demonstrating • public safety (K_82) the achievement of this outcome. • visual amenity (landforms) (K_83)
• soil quality (K_80) Response 8.8 and revised Table 8.10 • post mine land use (K_70) • surface water quantity Outcome for K_79 is related to surface water (which is appropriate) but the impact event given is related to soil.
Draft Measurement Criteria – Measurement Criteria are only required to be Draft and will be finalized in the PEPR however guidance is provided to improve these. 54 DRAFT outcome Various The groundwater monitoring program should start at least 1 year prior to These comments should be considered for any future measurement updates to measurement criteria and water monitoring Table 7.18; operation to capture seasonal variations. A similar approach is criteria - programs. Page 320 recommended for the surface water monitoring program. Groundwater NOTED: monitoring of pools in Pillaworta Creek (water
Australian Graphite Pty Ltd 169 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document This is required to differentiate between natural seasonal variations and depths and salinities) and of existing bores (Cullen and potential impacts associated with mining. Harris bores and soak) adjacent to the proposed mine site has already commenced and will continue. Monitoring wells should be considered along Pillaworta creek to demonstrate no impact to the creek outside of the current predicted zone of influence. Monitoring wells should also be considered by the permanent pools southeast of the pit and the significance Blue Gum communities. 55 DRAFT outcome 7.5.9; Page It is recommended that additional criteria be provided for surface water Review the draft measurement criteria and provide measurement 335 flow and quality monitoring upstream and downstream of the pit along clarification in the response document. criteria – Surface Pillaworta creek to demonstrate achievement of the relevant outcomes. NOTED: AGL confirms that appropriate measurement Water It is recommended that surface water that is to be redirected to criteria for measurement of flow and quality of surface water Pillaworta creek is monitored (flow and quality) upstream of the pit and that is to be redirected to Pillaworta creek will be just before it is discharged of lease. undertaken upstream of the pit and just before it is discharged off lease. These criteria will form part of the
Water Management Plan included in the PEPR. As noted above (SA Govt Issue #54), monitoring of water quality and depth of pools in Pillaworta Creek and Cullen and Harris creeks has commenced and will continue. 56 DRAFT outcome Page 382 Annual averaging of PM10 measurements is not an acceptable Review and provide updated draft Measurement and measurement measurement criteria. Leading Indicators which are consistent with NEPM criteria – Air standards. Leading indicator is not adequate. This would require real time data Quality reviewed on an ongoing basis informing a trigger and response plan. One component of the measurement criteria for the air quality human health outcome must be; the background plus mine contribution PM10 concentration is less than 50 µg/m3 as a 24 hour average. As indicated by DSD, updated Measurement Criteria will be provided in the PEPR Management Plans. The total PM10 (including both ambient and mine related dust) leaving the site is less than 50 µ/m3 as a 24-hour average. What will be measured PM10 by mobile real time sampler
Australian Graphite Pty Ltd 170 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables) # Topic MP Section Description of issue raised by SA Government Requirement for applicant in Response Document Locations Nearby residents Outcome achievement <50 µ/m3 a 24-hour average Frequency Real time monitoring Control Data NEPM 1998 On the basis of the amendment no leading indicator will be established.
Australian Graphite Pty Ltd 171 MLA RESPONSE DOCUMENT (DSD Mining Regulation Tables)