BEVERLEY ML 6321 BEVERLEY NORTH ML 6387 EMLs 6048-6392

MINING AND REHABILITATION COMPLIANCE REPORT 2011

HEATHGATE RESOURCES PTY LTD SUITE 1, LEVEL 4, 25 GRENFELL STREET, ADELAIDE, SA 5000 ABN 31 011 018 232 PHONE +61 8 8110-0500 FAX +61 8 8212-5559 Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012

TABLE OF CONTENTS

1 INTRODUCTION ...... 6 1.1 Context for this report ...... 6 1.2 Project Background ...... 6 1.3 Mining Leases and Land Tenure ...... 6 1.4 Heathgate Management Personnel ...... 9 1.5 Heathgate’s Environment Policy ...... 9 2 DESCRIPTION OF ACTIVITIES ...... 10 2.1 Drilling and Mining Activities ...... 10 2.2 Wellfields ...... 10 2.3 Borrow Pits ...... 11 2.4 Changes to Operation ...... 13 2.4.1 Beverley Processing Plant ...... 13 2.4.2 Beverley North Satellite Plants and Wellfields ...... 13 2.4.3 Ore Reserves and Mine Life ...... 13 3 ENVIRONMENTAL AND SOCIAL COMPLIANCE ACTIVITIES ...... 14 3.1 Meteorological ...... 14 3.2 Soil ...... 15 3.3 Vegetation ...... 22 3.3.1 Significant Environmental Benefit ...... 25 3.3.2 Ecosystem Function Analysis ...... 29 3.4 Surface Water ...... 31 3.5 Hydrogeology ...... 32 3.5.1 Great Artesian Basin (GAB) ...... 32 3.5.2 Namba Formation ...... 36 3.5.3 Willawortina Formation ...... 38 3.5.4 Namba Formation ...... 42 3.5.5 Fractured Rock Formation ...... 42 3.6 Fauna ...... 45 3.7 Air Quality ...... 48 3.8 Heritage ...... 50 3.9 Third Party Issues ...... 51 4 ONGOING COMMUNITY ENGAGEMENT PLAN ...... 52 5 ENVIRONMENTAL RADIOLOGICAL MONITORING ...... 53 5.1 Radon Activity Concentration ...... 53 5.2 Radon Decay Product PAEC ...... 54 5.3 Long Lived Alpha Activity in Dusts ...... 55 6 STATUS OF OBLIGATION OF STATE AND FEDERAL CONDITIONS ...... 56 7 RECTIFICATION OF NON-COMPLIANCES ...... 56 8 MANAGEMENT SYSTEM REVIEW ...... 56 9 FITNESS-FOR-PURPOSE REVIEW...... 56 10 NEW ENVIRONMENTAL HAZARDS ...... 56 11 INCIDENTS ...... 57 11.1 Incidents ...... 57 11.2 Corrective Actions ...... 57 12 OTHER ...... 58 12.1 Public Liability Insurance ...... 58

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12.2 MARP Amendments ...... 58 13 BIBLIOGRAPHY ...... 59 APPENDIX A: Beverley ML Monitor Well Level Graphs – Namba Formation ...... 61 APPENDIX B: Beverley ML Monitor Well Chemistry Graphs – Namba Formation ...... 74 APPENDIX C: Beverley ML Monitor Well Level Graphs – Willawortina Formation ...... 84 APPENDIX D: Beverley ML Monitor Well Chemistry Graphs – Willawortina Formation ...... 90 APPENDIX E: Beverley ML Overlying Monitor Well EC Graphs – Willawortina Formation ...... 96 APPENDIX F: Beverley North ML Monitor Well Level Graphs – Eyre Formation ...... 98 APPENDIX G: Beverley North ML Monitor Well Chemistry Graphs – Eyre Formation ...... 108 APPENDIX H: Beverley North ML Monitor Well Level Graphs – Namba Formation ...... 118 APPENDIX I: Beverley North ML Monitor Well Chemistry Graphs – Namba Formation ...... 120 APPENDIX J: Beverley North ML Monitor Well Level Graphs – Fractured Rock Formation ...... 122 APPENDIX K: Beverley North ML Monitor Well Chemistry Graphs – Fractured Rock Formation 124 APPENDIX L: Status of Obligations - Beverley ML 6321 ...... 126 APPENDIX M: Status of Obligations - Beverley North ML 6387 ...... 135 APPENDIX N: Internal Audit ...... 141

Figures Figure 1-1: Location of the Beverley and Beverley North Mining Leases ...... 7 Figure 1-2: Beverley ML 6321, Beverley North ML 6387 and surrounding tenements ...... 8 Figure 1-3: Heathgate’s Environment Policy ...... 9 Figure 2-1: Borrow Pit Location Plan ...... 12 Figure 3-1: Monthly Rainfall and Evaporation ...... 14 Figure 3-2: Comparative Annual Rainfall and Evaporation 2002 to 2011 ...... 14 Figure 3-3: Monthly Average, Maximum and Minimum Temperature and Wind Speed ...... 15 Figure 3-4: Wind Rose 2011 ...... 15 Figure 3-5: Evaporation Pond 5 and PLP water levels ...... 17 Figure 3-6: Chemical parameters for sediment samples on Beverley ML ...... 18 Figure 3-7: Chemical parameters for sediment samples on Beverley North ML...... 19 Figure 3-8: Beverley sediment sampling sites ...... 20 Figure 3-9: Beverley North sediment sampling sites ...... 21 Figure 3-10: Vegetation monitoring sites ...... 24 Figure 3-11: Beverley SEB Reconciliation Map ...... 27 Figure 3-12: Beverley North SEB Reconciliation Map ...... 28 Figure 3-13: EFA transects monitored in 2010 ...... 30 Figure 3-14: Quarterly extraction from the three bores ...... 33 Figure 3-15: Annual total extraction of GAB from 2000 to 2011 ...... 34

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Figure 3-16: Pressure of GAB bores during 2011 ...... 34 Figure 3-17: Conductivity of the three GAB bores ...... 34 Figure 3-18: GAB bores in use are located on Beverley ML 6321 ...... 35 Figure 3-19: Namba Formation monitor well locations ...... 37 Figure 3-20: Dump Monitor Well water ECL and EC chemistry results ...... 39 Figure 3-21: Willawortina Formation monitor well locations ...... 40 Figure 3-22 Pepegoona Monitor Well Locations ...... 43 Figure 3-23 Pannikan Monitor Well Locations ...... 44 Figure 3-24: Fauna monitoring locations ...... 47 Figure 3-25: Employee dose from 2001 to 2011 ...... 49 Figure 4-1: Community Consultations 2011 ...... 52 Figure 5-1: Passive Radon Activity Concentration Monitoring Trends ...... 53 Figure 5-2: Radon Decay Products PAEC Quarterly Monitoring Trends ...... 54 Figure 5-3: High Volume Air Sampling at Accommodation Camp ...... 55

Plates Plate 3-1: Four Mile Creek flowing in March 2011 ...... 18 Plate 3-2: Sturt’s Desert Rose (Gossypium sturtianum) in creek at Beverley North ...... 22 Plate 3-3: North Mulga Dam February 2011 ...... 32 Plate 3-4: Central Netted Dragon (Ctenophorus nuchalis) ...... 45

Tables Table 2-1: Wellfield activity during 2011 ...... 10 Table 2-2: Status of Borrow Pits at end 2011 ...... 11 Table 3-1: Compliance Table – Soil ...... 16 Table 3-2: Compliance Table – Vegetation ...... 23 Table 3-3: Summary of Areas Approved for Clearing (Life-of-Mine) ...... 25 Table 3-4: SEB Calculation (Life-of-Mine) ...... 25 Table 3-5: SEB Reconciliation (to end 2011) ...... 25 Table 3-6: SEB Summary Table ...... 25 Table 3-7: SEB Calculation (Actual cleared in 2011) ...... 26 Table 3-8: Compliance Table – Surface Water ...... 31 Table 3-9: Compliance Table – Hydrogeology - GAB ...... 33 Table 3-10: ECLs for the Namba Formation...... 36 Table 3-11: Namba Formation - Well Classifications ...... 36

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Table 3-12: Compliance Table – Hydrogeology - Namba Formation ...... 36 Table 3-13: Compliance Table – Hydrogeology - Willawortina Formation ...... 38 Table 3-14: Proposed ECLs for the Eyre Formation ...... 41 Table 3-15: Well Classifications ...... 41 Table 3-16: Compliance Table – Hydrogeology – Eyre Formation ...... 42 Table 3-17: Compliance Table – Hydrogeology – Namba Formation ...... 42 Table 3-18: Compliance Table – Hydrogeology – Fractured Rock Formation ...... 42 Table 3-19: Compliance Table – Fauna ...... 46 Table 3-20: Compliance Table – Air Quality ...... 49 Table 3-21: Public dose details ...... 50 Table 3-22: Compliance Table – Heritage ...... 50 Table 3-23: Compliance Table – Public ...... 51 Table 4-1: Quarterly Community Consultations for 2011 ...... 52 Table 5-1: Passive Radon Monitoring Results from Various Locations ...... 53 Table 5-2: Quarterly Radon Decay Products PAEC ...... 54 Table 5-3: High Volume Air Sampling Radiometric Analysis ...... 55 Table 5-4: High Volume Air Sampling Radiometric Analysis ...... 55 Table 11-1: Categorised incidents for 2011...... 57

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1 INTRODUCTION

1.1 Context for this report This Mining and Rehabilitation Compliance Report (MARCR) has been prepared by Heathgate Resources Pty Ltd (Heathgate) for their Beverley Mine Mining Lease (ML 6321), Beverley North Mining Lease (ML 6387) and associated Extractive Mineral Leases (EML) 6048 to 6052 in general accordance with the “Minerals Regulatory Guidelines MG3 Guidelines for Miners: Preparation of a Mining and Rehabilitation Compliance Report (MARCR) Version 1.4 March, 2009” (PIRSA 2009). It focuses on demonstrating that Heathgate has achieved the environmental outcomes for the 2011 calendar year as required by the conditions of: ML 6321 and its 2008 Mining and Rehabilitation Program (MARP) EMLs 6048 to 6052 inclusive ML 6387and its 2011 Mining and Rehabilitation Program (MARP)

1.2 Project Background Beverley Mine Heathgate acquired the Beverley leases in 1990 and undertook further evaluation of historic exploration data. In 1996 the company extended investigations with a view to establishing a mine at Beverley. Programs included baseline environmental studies, geological and uranium resource investigations, hydrogeological investigations and a field leach trial (FLT). The FLT at Beverley operated under approvals given following a Declaration of Environmental Factors in 1997. The trial commenced in January 1998. The first commercial uranium was produced in late 2000 and the mine was officially opened on 21 February 2001 by the then Deputy Premier and Minister for Primary Resources together with the Chairman and CEO of Heathgate’s parent company, General Atomics. Mining is undertaken using the in-situ recovery (ISR) method. The operation involves the mining of radioactive ore (uranium) and is licensed under the South Australian Radiation Protection and Control (RPC) Act 1982 and the action is designated as a “controlled action” under the Commonwealth Environment Protection and Biodiversity Conservation (EPBC) Act 1999. The MARP also constitutes the approved Monitoring Plan, Mine Closure and Completion Plan and Community Engagement Plan. Beverley North Mine Uranium exploration work commenced after September 1990 in the Paralana EL and included core drilling, sampling and metallurgical testing. Heathgate obtained approval for RL 124 for the purposes of a Field Leach Trial (FLT) to assess aquifer performance using the In-Situ Recovery (ISR) method of . The offer of a Mining Lease on Beverley North occurred on 14 December 2010 with conditional approval of the MARP on 23 December 2010. Full approval for the Beverley North Mining Lease ML 6387 was obtained on 28 January 2011 hence this MARCR is the first for demonstrating outcomes pertaining to the full Beverley North ML approvals.

1.3 Mining Leases and Land Tenure Beverley (ML 6321) has an area of 117 km2 and is located entirely within the Wooltana pastoral lease (Wooltana Pastoral Lease Parcel/Plan D42204/A34 Pastoral Lease No 2993 Crown Leasehold Volume 1289 Folio 38) on the arid plains between the Northern Flinders

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Ranges and , approximately 550 km north of Adelaide and 300 km north-east of Port Augusta in (Figure 1-1). Beverley North ML 6387 has an area of 61 km2 and the majority lies on Wooltana, although to the north part of it is located on the Wilderness Sanctuary (Arkaroola Pastoral Lease Hundred 833900 Pastoral Block 1108 Pastoral Lease No 2240, Crown Leasehold Volume 1278 Folio 43). The majority of both these ML areas remain undisturbed by mining activities apart from exploration activities. The closest communities include the tourist resort at Arkaroola and the Aboriginal community at Nepabunna, approximately 30 km and 80 km to the south-west respectively.

Figure 1-1: Location of the Beverley and Beverley North Mining Leases

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Figure 1-2: Beverley ML 6321, Beverley North ML 6387 and surrounding tenements

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1.4 Heathgate Management Personnel During 2011, the following Heathgate personnel were responsible for environmental management at the Beverley site: President – Craig Bartels Operations Manager – Gary Birch Health, Safety & Environment Manager – Sue Carter Production Manager - Chris Every Acting Production Manager – Chris Heinrich

1.5 Heathgate’s Environment Policy Heathgate’s Environment Policy valid during the reporting period is given below in Figure 1-3.

Figure 1-3: Heathgate’s Environment Policy

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2 DESCRIPTION OF ACTIVITIES

2.1 Drilling and Mining Activities Beverley Delineation and production drilling in Beverley and Beverley South areas was conducted on ML 6321 during 2011, none of which significantly affected the reserves or future production. Mining activities occurred in the Beverley orebodies in the North-East, Central, East, South and Deep South wellfields. Beverley North Delineation drilling and production drilling occurred in the Pepegoona East, Pepegoona West and Pannikan areas on ML 6387 during 2011 however discovery of additional resources made no significant affect on reserves or future production. Mining activities occurred in Pepegoona East, Pepegoona West and Pannikan orebodies of the Beverley North ML.

2.2 Wellfields Beverley During 2011, no new wellfields were brought online. Mining operations continued in Central, East, South and Deep South. Eight to eleven wellfields were operated simultaneously. Table 2-1 below shows wellfield activity during 2011 and the dates when wellfields became active, were turned off and which were active throughout the year. Beverley North During 2011 two wellfields were brought online - one at Pepegoona and one at Pannikan. Up to three wellfields were operated simultaneously through two satellite plants. Table 2-1 below shows wellfield activity during 2011 and the dates when wellfields became active. Table 2-1: Wellfield activity during 2011

Wellfield Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Beverley C16 – Central 24-Jul C21 – Central All year C99 - Central 29-Mar S7 – South All year S8 – South 24-Aug E2 – East All year E3 – East 4-Sep DG01 – Deep All year South DG02 – Deep All year South No. of Wellfields 9 9 9 8 8 8 8 7 6 5 5 5 Beverley North PE01 All year PW01 3-Mar

PK01 13-Aug

No. of Wellfields 1 1 2 2 2 2 2 3 3 3 3 3

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2.3 Borrow Pits Heathgate holds a number of Extractive Mineral Licences (EML) for construction minerals, mainly for use as road base. Table 2-1 outlines the EML number, the resource to be extracted and their status and Figure 2-1 shows their location. Table 2-2: Status of Borrow Pits at end 2011 Tenement Type Status EML 6048 Sand and gravel In use – near mined out, used for storage of material and crushing and screening EML 6049 Sand and gravel In use EML 6050 Sand and gravel In use EML 6051 Sand and gravel In use (99% remaining) EML 6052 Sand and gravel Mined out and rehabilitated in 2007 (Calcrete Pit 1)

EML 6385 (MC 3830) Sand and gravel EML granted 2 December 2010, PEPR in (Calcrete Pit 2) progress EML 6384 (MC 4020) Sand and gravel EML granted 10 November 2010, PEPR (Calcrete Pit 3) in progress EML 6392 (MC 4131) Sand and gravel EML granted 3 November 2011, PEPR in (Calcrete Pit 4) progress

EML 6052 was rehabilitated in 2007 and long-lived perennial species including Acacia sp have begun to colonise the disturbed area. External consultants, Outback Ecology, conducted EFA monitoring on this EML in 2011 and the report states that calcrete borrow pit, EML 6052, met all four completion criteria.

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EML 6392

Figure 2-1: Borrow Pit Location Plan

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2.4 Changes to Operation

2.4.1 Beverley Processing Plant Modifications undertaken in the Beverley processing plant include changes to the elution circuits to allow “A” elution column to process resin from the Beverley North satellite plants.

2.4.2 Beverley North Satellite Plants and Wellfields Modifications undertaken at the Pepegoona satellite plant included the installation of an acid storage tank and two additional IX columns including the appropriate bunds for both the tanks and the columns. The Pepegoona West wellfield was brought on line to provide additional flow into the Pepegoona plant. An additional booster pump was also installed and the barren lixiviant tank changed duty to operate as a pregnant lixiviant tank. Installation, commissioning and start up of the Pannikan satellite plant occurred during July and August 2011.

2.4.3 Ore Reserves and Mine Life Beverley Exploration and delineation drilling occurred within ML 6321 during 2011. This drilling had no significant effect on the resource estimate. Limited production drilling occurred within North, Central and Deep South. Mining occurred in North-east, East, Central, South and Deep South orebodies. Beverley North Exploration and delineation drilling was conducted by Heathgate on the Paralana EL 4387 (including RL 124) and the adjacent North Mulga EL 3934 for resource definition in 2010. An order of 3 Mlbs was discovered in the Pepegoona East, Pepegoona West and Pannikan areas. Pepegoona East was brought into production on 28 January 2011 with Pepegoona West and Pannikan orebodies subsequently put into production on 23 June and 15 August 2011 respectively. Subsequent delineation drilling outside of the production areas at Pepegoona East, West and Pannikan did not discover any additional resources which significantly affected reserves or future production for Beverley North. No drilling occurred on the adjacent Arkaroola EL 3666, in the Four Mile East and Four Mile West mineral prospects.

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3 ENVIRONMENTAL AND SOCIAL COMPLIANCE ACTIVITIES

This section discusses the compliance monitoring and management activities for the seven risk areas, – soil, vegetation, surface water, hydrogeology, fauna, air quality and heritage - interpretation of the data and their compliance status for 2011. Both the Beverley and Beverley North MLs are combined in the compliance table for each risk area however if any item relates to only one of the MLs it will be stated so.

3.1 Meteorological Meteorological data is collected continuously at the Beverley site weather tower. Wind speed, wind direction and temperature data are collected at 3 m, 20 m and 28 m and recorded every 10 minutes using a continuous data logging system. Rainfall data is collected using a tipping bucket, tipping at 0.2 mm increments, and recorded every 10 minutes. An automated evaporation pan including precision water level meter and refill tank provide measurements of evaporation. Evaporation is logged at the same time on a daily basis. Faults occurred with the evaporation pan at various times during the year, and a number of results were calculated using averages. The weather station also contains a humidity sensor, with humidity logged every 10 minutes. A 1 in 20 year ARI event occurred on 8 March when 56 mm fell in a 3 hour period. The total rainfall recorded for 2011 was 378.4 mm being above average for the second year running.

Figure 3-1: Monthly Rainfall and Evaporation

Figure 3-2: Comparative Annual Rainfall and Evaporation 2002 to 2011

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Figure 3-3: Monthly Average, Maximum and Minimum Temperature and Wind Speed

Figure 3-4: Wind Rose 2011

3.2 Soil On 19 February, a reportable spill occurred when a filter canister lid came off in the E2 wellhouse filter skid on the Beverley ML during a rainfall event. The spill was contained primarily in a local culvert and surrounding wellfield bunds. The exact spill volume was impossible to determine due to the simultaneous rainfall event. When discovered the wellfield was shut down until the filter canister could be inspected and the lid replaced. No impact on people’s health and no discernible effect to the environment occurred. This spill was reported and investigations were undertaken with interim reports and a final report being sent to the regulators. The SA EPA undertook radiological monitoring including soil sampling confirming there were no impacts to the environment resulting from the spill. Refer to the compliance table being Table 3-1.

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Table 3-1: Compliance Table – Soil

ID Potential Impact Event Outcome(s) Outcome Leading Indicator Compliance Status Measurement Criteria Criteria

1.1 Chemical and radiological Soil affected For a, only Beverley - Leakage from Beverley - No leaks from the ponds contamination of soil and by mining rehabilitation criteria double-lined ponds is were detected in 2011. compared to the Target watercourse sediments activities is apply. Beverley - Water levels in Evaporation that would prevent its suitable for Action Leakage Rate b, c All sites subject (TALR) of 22 mL/m2/day. Pond 5 and the PLP are shown in return to pastoral use return to to spills meet Figure 3-5. arising from: pastoral use. Beverley - water levels in radiological criteria ponds are checked at Soil samples were taken after the spill Beverley - seepage from as defined in the least weekly and after >10 at E2 filter skid that occurred on 19 water management ponds RWMP. mm of rainfall in a day and February as part of the investigation through construction maintained at least into the spill. The SA EPA also took soil defects, wear and tear and 0.20 m below lowest level samples to confirm there was no harm accidental damage. of rim. to the environment. Beverley - pond overflows any leaks detected by Sediment sampling was undertaken of mining solutions and automatic systems or upstream and downstream in local waste disposal solution visual observation are creeks on both MLs in June 2011 as a due to high rainfall events logged as events and result of the 1 in 20 ARI in March (refer or control system failure. rectified. to Meteorology section). All samples Beverley North - water were analysed by a third party the escape of mining levels in bunds and laboratory and the results of this solution due to accidental sumps are checked at analysis averaged over the breakages of piping from least weekly and after classification for Beverley are poor welds, vehicle >10 mm of rainfall in a presented in Figure 3-6 and for damage or pipe defects. day and maintained at Beverley North in Figure 3-7. least 0.20 m below lowest Beverley North - seepage level of rim. Locations of sediment sampling sites from water management are shown in Figure 3-8 for the tanks through construction Beverley ML and Figure 3-9 for the defects, wear and tear and Beverley North ML. accidental damage. Beverley North - Tank or bund overflows of mining solution from high rainfall events or control system failure.

1.2 Spillage of hazardous Soil affected Spills of hazardous Beverley - Number and When spills are identified they are substances during by mining materials are nature of spills and treated soon after, as required. Very transport, storage and activities is assessed and if so cleanups. minor spills are cleaned up immediately handling resulting in suitable for determined cleaned and not all of these are reported due to contamination of soil that return to up: Beverley North - Water immediate action. Larger spills of any levels in bunds and would prevent its return to pastoral use. a) Diesel spills to nature are logged on our Incident pastoral use. sumps are checked at Management Database to enable site-specific criteria to least weekly and after be established using identification of areas to be targeted for >10 mm of rainfall in a corrective actions as appropriate. NEPM Risk day and maintained at Assessment least 0.20 m below Soil affected by hydrocarbon spills was methodology as lowest level of rim. collected and taken to the recommended by SA bioremediation bunds on the Beverley EPA. Beverley North - Any ML. No testing of any of the soils leaks detected by b) Acid or alkali spill within these bunds has occurred as sites returned to automatic systems or yet. within local visual observation are There was a 2,000 L overflow of the logged as events and background range of sulphuric acid tank at the Pannikan pH. rectified. satellite plant during filling of the tank Beverley North - however this was confined to the bund Number and nature of and corrective action to remediate the spills and cleanups and problem has been undertaken. Repairs time taken to complete. to the bund are in progress.

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ID Potential Impact Event Outcome(s) Outcome Leading Indicator Compliance Status Measurement Criteria Criteria

1.3 Soil disturbance due to Soil affected Off-road vehicle Number of non-compliant Nil reports for non-compliant ECPs excessive off-road vehicle by mining movements not ECPs involving off-road involving off road incidents were movement which may activities is approved via an incident. received or logged in the incident compromise rehabilitation suitable for Heathgate’s management database during 2011. for later pastoral use return to Environmental resulting from: pastoral use. Clearance Permit (ECP) are compaction of soil investigated, reported exacerbated erosion. and one of the following actions are undertaken: fenced off to prevent reuse and rehabilitated, or converted to an authorised road subject to SEB.

1.4 Beverley North – Spillage Soil affected All sites subject to Number and nature of See ID 1.2 of resin, chemicals or by mining spills meet spills and cleanups and bleed stream solution activities is radiological criteria time taken to complete. during transport, storage suitable for as defined in the and handling resulting in return to pre- RWMP. contamination of soil that mining use. would prevent its return to pre-mining use.

Figure 3-5: Evaporation Pond 5 and PLP water levels

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Figure 3-6: Chemical parameters for sediment samples on Beverley ML

Plate 3-1: Four Mile Creek flowing in March 2011

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Figure 3-7: Chemical parameters for sediment samples on Beverley North ML Comparisons of the up and down stream concentrations for the mine site show no uncharacteristic results. Thorium (not shown) is also analysed and shows no discernible trends. The Ecosystem Function Analysis (EFA) monitoring program that occurs at Beverley and Beverley North is related to soil monitoring and also includes vegetation measurements as described in Section 3.3.2.

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Figure 3-8: Beverley sediment sampling sites

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Figure 3-9: Beverley North sediment sampling sites

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3.3 Vegetation To ensure minimal disturbance to vegetation and the landscape in general, Heathgate has implemented an Environmental Clearance Permit system where a permit must be obtained prior to work commencing in any undisturbed area or area under rehabilitation. This ensures access networks are planned and sensitive habitat and soaks are retained and outlines specific environmental and rehabilitation requirements. This system enables all new areas of disturbance to be measured by GPS at the end of every year and this information is then plotted on a map to enable calculations using mapping software to determine the total area disturbed for the year. All areas rehabilitated are also measured using a GPS and plotted to a map. These results are used for SEB accounting purposes. The annual vegetation survey was undertaken by EBS Ecology from 10 to 22 September 2011 covering the Beverley and the Beverley North ML areas and some 5 km distant control sites surveying seventy-eight 5 m x 2 m quadrats and four 1 ha quadrats in total. The location of vegetation monitoring sites is shown in Figure 3-10. It is expected that with rainfall over the 2011/12 summer period, perennial cover will be maintained and that annual species cover and species richness will vary dependent on availability of resources. Wellfield areas which have been largely cleared of vegetation are recovering well. It was observed and supported by data, that vegetation within the mine lease away from the development areas are not being adversely impacted and are generally of a better condition than surrounding pastoral areas (EBS Ecology, 2011). The main findings of the 2011 survey were that the Mitchell Grass once dominant in the area no longer plays a significant role in the vegetation of this area, although had recovered somewhat from the previous year following another year of above average rainfall. Other grass species and many chenopods had also shown significant increases. Overall a higher cover was recorded across the entire site and large volumes of seed were observed scattered over the ground. Refer to compliance table being Table 3-2.

Plate 3-2: Sturt’s Desert Rose (Gossypium sturtianum) in creek at Beverley North

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Table 3-2: Compliance Table – Vegetation

ID Potential Outcome(s) Outcome Leading Compliance Impact Event Measurement Indicator Status Criteria Criteria

2.1 Reduction in No loss of abundance or Demonstrate that all Progressive SEB Actual disturbance regional native diversity on or off the clearing undertaken is accounting in the measured by GPS for vegetation species Beverley and Beverley approved in annual MARCR. the purpose of SEB density and diversity North mining leases to accordance with the accounting. due to mining native vegetation through MARP. An aerial photo operations. clearance or any other covering both MLs damage unless prior was taken on 2.2 Loss of local native approval under the relevant 24 February 2011. vegetation (habitat) legislation is obtained. due to clearance for mining operations.

2.3 Introduction of new No introduction of new Flora and fauna Trends noted in Wellfield areas which or increase in weeds, plant pathogens or surveys demonstrate annual vegetation have been largely abundance of pests (including feral no new weeds or feral and fauna cleared of vegetation existing weeds and animals), nor increase in animals (due to surveys are recovering well. pests (feral abundance of existing mining activities) nor It was observed and animals). weed or pest species in the statistically significant supported by data, lease area compared to increase in that vegetation with adjoining pastoral areas. abundance of existing the mine lease away weed or pest species from the development in the lease area areas are not being compared to adjoining adversely impacted pastoral areas. and are generally of a better condition than surrounding pastoral areas (EBS Ecology, 2011)

2.4 Loss of local native Beverley - No uncontrolled Any fires caused by No fires caused by vegetation (habitat) fires caused by mining mining operations are mining or occurred due to mining- operations. controlled within the during 2011. related fires. Beverley North - No loss of ML boundary. abundance or diversity on or off the Beverley North mining lease to native vegetation through fire damage unless prior approval under the relevant legislation is obtained.

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Figure 3-10: Vegetation monitoring sites

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3.3.1 Significant Environmental Benefit There were no new areas of disturbance on the Beverley ML during 2011 that were not previously included in the SEB reconciliation, nor were any areas rehabilitated during the year. Refer to Figure 3-11. On the Beverley North ML however new areas of disturbance occurred to enable the Pepegoona FLT plant to become an operating satellite plant with a small extension to the plant, additional wellfield patterns plus the Pepegoona West wellfield. Construction through to operation of the Pannikan satellite plant and wellfield also occurred. Refer to Figure 3-12. A value of land of $2.66/ha with a management cost of $800/ha has been used to calculate the SEB. The land value is based on the 2009 unimproved value of $672,053 for the Wooltana Lease provided by the Pastoral Land Management Group in April 2010 and an area of 977 square miles (253,042 ha). Table 3-3: Summary of Areas Approved for Clearing (Life-of-Mine)

Reconciliation - Clearing approved Clearing subject to Actual SEB ML pre-SEB (ha) SEB (ha) Clearance during 2011

Beverley 255 264 0

Beverley North N/A 17 19

Table 3-4: SEB Calculation (Life-of-Mine)

Area Cleared Initial Final ML SEB Area (ha) (ha) Ratio Ratio*

Beverley 264 4:1 2:1 528

Beverley North 36 4:1 2:1 72 * Using a 50% discount for areas that will be revegetated.

Table 3-5: SEB Reconciliation (to end 2011)

Area Cleared (ha) Initial Final SEB Area (ha) ML Ratio Ratio*

Beverley 0 4:1 2:1 0

Beverley North 36 4:1 2:1 18* * Using a 50% discount for areas that will be revegetated.

Table 3-6: SEB Summary Table

Pre-2009 (ha) 2009 (ha) 2010 (ha) 2011 (ha)

Disturbed Rehabilitated Disturbed Rehabilitated Disturbed Rehabilitated Disturbed Rehabilitated ML (ha) (ha) (ha) (ha) (ha) (ha) (ha) (ha) Beverley 54 0* 22 11 4 1 0 0

Beverley North N/A N/A N/A N/A 13 0 18 0

Total 54 0 22 11 17 1 18 0

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Table 3-7: SEB Calculation (Actual cleared in 2011)

Management cost SEB value Total Compensation Area SEB Area (based on area (Based on (if SEB area not ML Cleared (ha) (ha) cleared) SEB area provided) $ $ $

Beverley 0 0 0 0 0

Beverley North 19 38 15,200 101 15,301

Total 15 38 15,200 101 15,301

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Figure 3-11: Beverley SEB Reconciliation Map

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Figure 3-12: Beverley North SEB Reconciliation Map

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3.3.2 Ecosystem Function Analysis EFA monitoring, supplementary monitoring committed to in both Beverley and Beverley North MARPs is being used as a tool to assess the progress of areas of rehabilitation The EFA surveys include a vegetation component that compliments the specialised vegetation monitoring. Figure 3-13 shows the location of EFA monitoring sites. In regard to completion criteria seven of thirteen transects monitored in 2011 met all four proposed threshold values, of these, four have now met all completion criteria for three consecutive years. Completion criteria proposed in 2010 for landscape function indices required that rehabilitation indices should reach 80% of the analogue mean for at least three consecutive years. A new rehabilitation transect was established at Beverley North in 2011, EFA35, on a recently rehabilitated drill pad. This transect obviously met none of the completion criteria. Of the other transects monitored in 2011 all achieved completion criteria in relation to the stability index and the infiltration index. The 80% target for nutrient cycling was achieved by nine transects. All sites monitored in 2011, except EFA35 that was only installed this year, had shown improvement from their previous monitoring (Outback Ecology, 2012). The 2011 EFA monitoring program resulted in the highest values ever recorded, of the sites monitored, for the stability, infiltration and nutrient cycling indices. Photo comparison of sites not monitored since 2009 also showed increases in plant cover at all of these sites. This was attributed to the second year of above average rainfall at the sites (Outback Ecology, 2012).

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Figure 3-13: EFA transects monitored in 2010

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3.4 Surface Water Surface water assists in the recharge of the Willawortina Formation. Pastoralists use dams as, often intermittent, stock water supplies. Refer to compliance table being Table 3-8. Table 3-8: Compliance Table – Surface Water

ID Potential Outcome(s) Outcome Measurement Leading Compliance Status Impact Event Criteria Indicator Criteria

3.1 Beverley - Beverley North - Water quality in No watercourse contamination Watercourse No compromise of Beverley - North and South Mulga (including radiological) arising from contamination pastoral use of Dams release of mining solution due to flood (including downstream damage to pipes, ponds and radiological) surface water Beverley North – downstream infrastructure or from high rainfall arising from bodies. water storages (within 5 km of an causing overflow of the Beverley ponds. release of individual mining/spill site, or the mining solution closest accessible significant Grab samples were taken from the due to flood temporary creek waterhole if there North and South Mulga dams after a damage to is no water storage within 5 km). spill occurred at E2 wellhouse on 19 February during a rainfall event. No shall be measured as soon as it is Beverley - anomalous results were recorded. Grab safe to do so following surface pipes, ponds samples were also taken from the other water flow, if there has been any and four dams located on or near the infrastructure, or Beverley - release of mining Beverley and Beverley North MLs, again from high rainfall solution into a flowing stream. returning no anomalous results. causing overflow of Beverley North – immediately No watercourse contamination ponds. reportable release of mining (including radiological) arising from solution. release of mining solution due to flood Beverley North This must show no compromise of damage to pipes, bunds and – pipes, bunds infrastructure or from high rainfall and pastoral use that it is attributable to mine operations. causing overflow of bunds occurred on infrastructure, or the Beverley North ML. from high rainfall Beverley - A mass balance causing calculation using estimated spill overflow of volume and chemical quality and bunds. estimated stream flow shall be undertaken to ascertain if any compromise is plausibly due to the mine. Applicable ANZECC/ARMCANZ stock water guidelines are: • salinity (EC) – 4,000 mg/L (6,000 uS/cm) • sulphate – 1,000 mg/L • uranium – 0.2 mg/L.

3.2 Beverley North - Beverley North - Water quality in No watercourse contamination Watercourse downstream water storages (within (including radiological) as no release of contamination 5 km of an individual mining/spill site, materials into a creek occurred. (including or the closest accessible significant radiological) temporary creek waterhole if there is arising during no water storage within 5 km), will be transport of measured as soon as it is safe to do resin or so following surface water flow, if chemicals, there has been any unremediated resulting from release of resin or chemicals. This an accidents must show no compromise of and release of pastoral use that is attributable to materials into a mine operations. creek. Applicable ANZECC/ARMCANZ stock water guidelines are: • salinity (EC) – 4,000 mg/L (6,000 uS/cm)

• sulphate (SO4)– 1,000 mg/L • uranium – 0.2 mg/L.

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Following a spill on 19 February and an above 1 in 20 ARI event on 8 March, grab samples were taken from the North and South Mulga dams. No anomalous results were recorded. As triggered by the above 1 in 10 year ARI event, grab samples were also taken from the other four dams located on or near the Beverley and Beverley North MLs, again returning no anomalous results.

Plate 3-3: North Mulga Dam February 2011

3.5 Hydrogeology Duplicate sampling of all monitor wells is undertaken on a quarterly basis and duplicates are sent off site to a NATA accredited laboratory. Results from Beverley’s laboratory and the NATA accredited laboratory are compared for quality assurance purposes. Monitoring results are presented in the Quarterly Environment and Radiation Report and distributed to the regulators. No excursions from the mining zone have occurred since operations began. Hydrographs for water levels and chemistry results are given in Appendices A to K. Beverley The hydrogeology in the vicinity of the Beverley Mine consists of three main aquifers: • Willawortina Formation (surface to ~95 m below ground level (bgl)) • Beverley Sands and other minor sands in the Namba Formation (105 – 140 m bgl) • Great Artesian Basin (GAB) – Cadna-Owie Formation (330 – 380 m bgl).

3.5.1 Great Artesian Basin (GAB) Three GAB bores exist on the Beverley ML - Four Mile GAB, Plant GAB 1 and Plant GAB 2 - and monitoring of these bores provides an early warning of possible problems that might occur at pastoral wells in the area and provides assurance that the outcome of ‘no compromise to other existing GAB users within the Beverley Mine region’ will be achieved. Refer to compliance table being Table 3-9. Department for Water granted Heathgate Water Licence No. 162748 on 19 January 2011 with an annual water allocation amount of 140 ML per annum. Extraction from the GAB bores is well within the allocation amount as can be seen in Figure 3-15.

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Table 3-9: Compliance Table – Hydrogeology - GAB

ID Potential Impact Event Outcome(s) Outcome Leading Indicator Compliance Status Measurement Criteria Criteria

4.1 Drawdown and reduced No GAB use not to exceed Volume of water Department for Water granted flow in other pastoral compromise the allocated volume progressively taken Water Licence No. 162748 with a bores that compromise to other specified by license from GAB. total water allocation per annum of their use, due to GAB existing GAB conditions which are Water pressures and 140 ML. water extraction for users within issued according to the pressure trends in Graphs below show the quarterly mining operations. the Beverley requirements of the GAB. extraction of GAB water from the mine region. approved Water three bores and the total annual Allocation Plan, Far GAB water extraction since 2001 North Prescribed Wells including the target annual Area (DWLBC). allocation for 2011 of 140 ML. Pressure trends in the GAB bores are consistent with past years. There was no prolonged decrease in the pressure of the GAB bores.

4.2 Contamination (including No The pressure in the As above. As above. radiological) of the GAB compromise GAB at the extraction Trend of EC. Trends for EC are consistent with aquifer arising from to other bores remains higher previous except for the EC result prolonged pressure drop existing GAB than the maximum for October 2011 which was in the GAB to less than users within pressure in Namba confirmed as anomalous with the Namba aquifer and the Beverley aquifer. results to April 2012 being the creation of a pathway mine region. GAB use not to exceed consistent with previous results. that compromises current the allocated volume and future possible use of specified by license the GAB. conditions which are NOTE: Not a credible risk issued according to the due to small GAB requirements of the extraction rates, pressure approved Water differential between Allocation Plan, Far aquifers and the vertical North Prescribed Wells and lateral seals between Area (DWLBC). credible pathways.

Figure 3-14: Quarterly extraction from the three bores

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Figure 3-15: Annual total extraction of GAB from 2000 to 2011

Figure 3-16: Pressure of GAB bores during 2011

Figure 3-17: Conductivity of the three GAB bores Note: EC result for October 2011 was anomalous and confirmed as further results are consistent with past results up to and including April 2012.

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Figure 3-18: GAB bores in use are located on Beverley ML 6321

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3.5.2 Namba Formation Mining occurs in the uranium-bearing Namba Formation aquifer which is monitored via a network of lateral monitor wells. Excursion Control Limits (ECLs) are set as leading indicators to the migration of mining and disposal solutions and are given in Table 3-10. Table 3-11 outlines the Well Classifications. Refer to compliance table being Table 3-12. During 2011, one Namba monitor well was removed from the regulatory monitor well network and replaced with another for a small wellfield extension. The location of the monitor wells screened in the Namba formation is shown in Figure 3-19.

Table 3-10: ECLs for the Namba Formation

Excursion Control Excursion Control Limits Parameters

pH Minimum of 4.5

SO4 Maximum of 3.6 g/L

U3O8 Maximum of 1 mg/L

Table 3-11: Namba Formation - Well Classifications

Classification Type

1 Well connected across the channel

2 Well connected lateral to the channel

3 Poorly connected

4 Unconnected

Table 3-12: Compliance Table – Hydrogeology - Namba Formation

ID Potential Impact Outcome(s) Outcome Leading Compliance Status Event Measurement Indicator Criteria Criteria

4.5 Contamination No compromise of No migration of mining ECL monitoring Refer to hydrographs: (including potential pastoral and disposal solutions trends APPENDIX A: radiological) of the use (should it outside the ML as Beverley ML Monitor Well Namba aquifer units meet pastoral demonstrated by ECL Level Graphs outside the Beverley water quality monitoring and – Namba Formation, and Mine Lease arising standards) of the response. APPENDIX B: from mining Namba aquifer Beverley ML Monitor Well activities. outside the Chemistry Graphs Beverley mining – Namba Formation. lease.

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Figure 3-19: Namba Formation monitor well locations

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3.5.3 Willawortina Formation The Willawortina Formation is the surficial aquifer that overlies the Namba Formation and is separated by an impervious clay layer. The Willawortina Formation comprises a number of thin aquifers of low water yield, separated by clay layers. Where water is present, the quality may be suitable for general stock use. Pumping tests associated with trials indicate there is no hydraulic connection with the Namba Formation aquifer. Monitor wells screened in the Willawortina Formation are known as overlying monitor wells. Refer to the compliance table being Table 3-13. The location of the overlying monitor well is shown in Figure 3-21. Table 3-13: Compliance Table – Hydrogeology - Willawortina Formation

ID Potential Impact Outcome(s) Outcome Leading Compliance Status Event Measurement Indicator Criteria Criteria

4.3 Contamination No compromise Monitoring of ECL Water pressures Refer to hydrographs: (including to pastoral use of parameters and EC in Namba APPENDIX C: radiological) of the the Willawortina demonstrates that the injection and Beverley ML Monitor Well Willawortina aquifer aquifer. category of pastoral use monitor wells. are Level Graphs by leakage caused by of the Willawortina less than the – Willawortina Formation, over-pressurisation of aquifer does not conservatively the Namba mining change adversely in calculated APPENDIX D: aquifer to the relation to aquitard fracture Beverley ML Monitor Well Willawortina aquifer ANZECC/ARMCANZ pressure of Chemistry Graphs that compromises it categories of water use, 760 kPa – Willawortina Formation, possible future as a result of mining measured at the and pastoral use. operations. wellhead APPENDIX E: Trends of water Beverley ML Overlying level and ECL Monitor Well EC Graphs parameters and – Willawortina Formation. EC.

4.4 Radionuclide Appropriate records Cell sump Refer to Figure 3-20. contamination of the show LLRW facilities monitoring Willawortina aquifer built to design. confirms that no due to seepage from Groundwater quality water has LLRW facilities. monitoring (ECL entered the cell. Note: Not a credible parameters and EC) risk due to design of shows no compromise solid waste facilities, of Willawortina that low rainfall and could be attributed to groundwater the LLRW facilities. discharge, deep water table and presence of extensive clay in unsaturated zone.

Three overlying monitor wells are located immediately surrounding the low level radioactive waste facilities and do not appear to be connected to the main aquifer thus sampling is done via a bailer and results show no uranium concentrations above 1 ppm as do overlying monitor wells nearby the LLRW facilities. Figure 3-20 shows the ECL and EC chemistry for the overlying monitor wells located surrounding the low level radioactive waste facilities. Dump sump bores which are monitored monthly are linked to the base of each waste facility and in general, show no signs of liquid. If a liquid sample is present, it is obtained and sent to a third party NATA accredited laboratory for analysis. To date only low Ra-226 concentrations have resulted. This is consistent with the assertion that radionuclide contamination of the Willawortina aquifer is not a credible risk.

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Figure 3-20: Dump Monitor Well water ECL and EC chemistry results

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Figure 3-21: Willawortina Formation monitor well locations

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Beverley North The hydrogeology in the vicinity of the Beverley North Mine consists of five main aquifers: Willawortina Formation (surface to ~30 m below ground level (bgl)) Namba Formation Sands (30 to ~175 m below ground level (bgl)) Lower Eyre Formation Sands (180 to ~250 m below ground level (bgl)) Bulldog shale (250 to 335 m below ground level (bgl)) Fractured Rock Aquifer (335+m below ground level (bgl). A monitoring well network for the Pepegoona, Pepegoona West and Pannikan ore zones has been established to monitor groundwater in all aquifers above, below and adjacent to the target zone within the Eyre Formation aquifer and comprises three types of wells: Lateral Monitor Wells – These wells monitor the Eyre Formation sands laterally adjacent to the target zone Overlying Monitor Wells – These wells monitor the first permeable sand unit above the ore zone sands Underlying Monitor Wells – These wells monitor the underlying aquifer underlying the ore zone. In the case of the Pepegoona, this is the Fractured Rock Aquifer. The mining zone is within the Eyre Formation at Pepegoona, Pepegoona West and Pannikan. Lateral monitor wells form a network adjacent the target zone. The proposed ECLs for the Eyre Formation, outlined in Table 3-14 are based on baseline sampling of the Eyre Formation lateral monitor wells. Table 3-15 outlines the Well Classifications. Refer to compliance being Table 3-16. The location of the lateral monitor wells and their classifications are shown in Figure 3-22 for Pepegoona and Pepegoona West and Figure 3-23 for Pannikan. Table 3-14: Proposed ECLs for the Eyre Formation

Excursion Control Parameters Excursion Control Limits

pH Minimum of 4.5

SO4 Maximum of 2.0 g/L

U3O8 Maximum of 1 mg/L

Table 3-15: Well Classifications

Classification

A Lateral Monitor Wells close to the ML boundary

B Lateral Monitor Wells (other)

C Overlying Monitor Wells

D Underlying Monitor wells

E Observation wells close to ML boundary

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Table 3-16: Compliance Table – Hydrogeology – Eyre Formation

ID Potential Impact Outcome(s) Outcome Leading Indicator Compliance Status Event Measurement Criteria Criteria

4.1 Groundwater No compromise No migration of mining Water quality and Refer to hydrographs: contamination of to the solutions in the target quality trends in the APPENDIX F: target aquifer(s) environmental aquifers outside the ML mined aquifer Beverley North ML Monitor outside ML values of the as demonstrated by monitoring and Well Level Graphs preventing stock target aquifers Excursion Control Limit observation wells – Eyre Formation, and watering (Eyre or Namba (ECL) and EC (ECL parameters). APPENDIX G: Formations) monitoring and Beverley North ML Monitor outside the ML. response. Well Chemistry Graphs Compliance with the – Eyre Formation. Eyre and Namba Formation outcome will be demonstrated by either no exceedence of ECLs at lateral monitor wells or by demonstration of compliance with the contingency measures.

3.5.4 Namba Formation Overlying monitor wells are located within the Namba formation which is the first permeable sand unit above the ore zone sands. Refer to compliance table being Table 3-17. The location of the overlying monitor wells and their classifications are shown in Figure 3-22 for Pepegoona and Pegegoona West and Figure 3-23 for Pannikan. Table 3-17: Compliance Table – Hydrogeology – Namba Formation

ID Potential Impact Outcome(s) Outcome Leading Compliance Status Event Measurement Criteria Indicator Criteria

4.2 Contamination No compromise Monitoring of ECL Water levels and Refer to hydrographs: (including to the parameters and EC level trends in APPENDIX H: radiological) of non- environmental demonstrates no overlying Beverley North ML Monitor Well target overlying values of the compromise of the monitoring wells Level Graphs aquifer(s) (if locally overlying aquifer environmental values of (ECL – Namba Formation, and existing) units near (Willawortina the overlying aquifer(s), parameters). APPENDIX I: mined Beverley North Formation). should either be Beverley North ML Monitor Well deposits arising from present and saturated, Chemistry Graphs mining activities. as a result of mining – Namba Formation operations.

3.5.5 Fractured Rock Formation Underlying monitor wells are located within the Fractured Rock Aquifer which underlies the orezone. Refer to compliance table being Table 3-18. The location of the underlying monitor wells and their classifications are shown in Figure 3-22 for Pepegoona and Pepegoona West and Figure 3-23 for Pannikan. Table 3-18: Compliance Table – Hydrogeology – Fractured Rock Formation

ID Potential Impact Outcome(s) Outcome Leading Compliance Status Event Measurement Criteria Indicator Criteria

4.3 Contamination No compromise Monitoring of ECL Water quality and Refer to hydrographs: (including to the parameters and EC quality trends in APPENDIX J: radiological) of environmental demonstrates no underlying Beverley North ML Monitor Well underlying aquifer values of the compromise of the aquifer Level Graphs units underlying underlying environmental values of monitoring wells – Fractured Rock Formation and mined Beverley North aquifers the underlying aquifer, (ECL APPENDIX K: deposits arising from (Fractured Rock as a result of mining parameters) Beverley North ML Monitor Well mining activities. or GAB activities. Chemistry Graphs Aquifers). – Fractured Rock Formation

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Figure 3-22 Pepegoona Monitor Well Locations

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Figure 3-23 Pannikan Monitor Well Locations

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 3.6 Fauna The outcomes related to fauna are measured via the results obtained from the annual fauna survey that is undertaken by consultants and by monthly bird and macropod transects, undertaken by Heathgate’s environmental personnel. Refer to compliance table being Table 3-19. Ecological Associates were commissioned to undertake the 2011 annual fauna survey for the Beverley and Beverley North MLs as part of the ongoing annual monitoring program in order to assess the impacts mining operations have, if any, on fauna species composition and population. The survey was carried out over ten days (6 to 15 October 2011) monitoring 24 sites located within the three broad habitat types (major drainage, minor drainage and gibber plans) over both the Beverley and Beverley North MLs (refer Figure 3- 24). The methodology outlined in the Biological Survey of South Australia for sites in the pastoral region of South Australia (Owens 2000) was followed. Comparison between control and mine sites within each of the habitat types for the 2011 surveillance period, showed no apparent negative effect of mining on vertebrate fauna species diversity or abundance when compared with the control sites located outside of the mining area (Ecological Associates, 2011). During the 2011 survey it was noted that mine site faunal diversity and abundance was higher at mine sites compared to control sites. This trend appears to be a direct consequence of destocking the site, which is providing an environmental benefit greater than any localised effects of the mine itself. Heathgate’s Environmental Clearance Permit (ECP) process ensures all disturbances are kept to a minimum and that personnel working in a previously undisturbed area or an area previously under rehabilitation understand any special requirements and their individual responsibility.

Plate 3-4: Central Netted Dragon (Ctenophorus nuchalis)

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Table 3-19: Compliance Table – Fauna

ID Potential Impact Outcome(s) Outcome Measurement Criteria Leading Compliance Status Event Indicator Criteria

5.1 Reduction in No net adverse Results of monitoring program show Trends of the See excerpts from the annual native vertebrate impacts from the site no increase in feral vertebrates, monitoring fauna survey report survey species density operations on native compared with local area program. above conducted by and diversity fauna abundance or background, based on assessment Ecological Associates from caused by diversity in the lease by the appropriately qualified and 6 to 15 October 2011. The wellfield area and in adjacent experienced specialists engaged to survey was conducted in development, areas. undertake and assess the monitoring accordance with the Standard access road program. Biological Monitoring construction and Methodology (DEH Owens operations. 2000) of sites surveyed for 4 days. The Anabat recorder 5.2 Reduction in was placed at Paralana Dam native vertebrate as the dam near CON07 was species density dry and bat activity was and diversity expected to be low. resulting from an increase in feral animals caused by creation of food sources, modified habitat and waste management operations.

5.3 Reduction in No introduction of new Beverley - All complaints from adjacent weeds, plant neighbours regarding feral animal pastoralist pathogens or pests control are investigated and are viability due to (including feral demonstrated to be not due to increase in feral animals), nor increase mining operations. animals due to in abundance of feral Beverley North - Results of mining animals in the lease monitoring program show no operations. area compared to increase in feral vertebrates, adjoining pastoral compared with local area areas. background.

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Figure 3-24: Fauna monitoring locations

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 3.7 Air Quality The estimated radiation doses to both employees and public remained low and within the applicable limits defined under the RPC Act 1982. The average dose received by an employee during 2011 was 0.23 mSv and the maximum was 3.21 mSv, well below the applicable dose limit. Employee average and maximum dose for 2001 to 2011 are shown in Figure 3-25. Refer to compliance table being Table 3-20. The estimated dose to a person living at the accommodation camp is 0.015 mSv (excluding the contribution from natural background radon).

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Table 3-21 shows the separation of dust and radon dose in mSv. The nearest residence occupied by a member of public is the North Mulga Outstation and considering the distance from Beverley Mine area the annual dose received by a person living there will be less than 0.015 mSv, well below the applicable annual dose limit of 1 mSv. Table 3-20: Compliance Table – Air Quality

ID Potential Impact Outcome(s) Outcome Leading Compliance Status Event Measurement Criteria Indicator Criteria

6.1 Beverley - Radon No adverse Estimated radiation Trends from Radiation monitoring was carried release from impacts to doses to the public (and monitoring of out as per the approved processing area and workers, public workers) within radon decay monitoring plan. All the results water management or the applicable limits as products and remained very low. ponds (and other environment due defined under the uranium dust in sources) increasing to radon release, RPC Act. the Estimated doses to members of the public and workers remained radiation doses to the uranium bearing- Beverley - environment or the dust, nor low and well below the annual processing plant, limits. public. radiological ponds and Beverley North - aspects of accommodation Radon and uranium- seepages and camp areas spills. bearing dust release Beverley North - increasing radiation satellite plants doses to the and wellfields environment or the public. remain below the investigation levels

6.2 Beverley - Uranium- Trends from Uranium dust and radon decay bearing dust released monitoring of products -monitored doses are from drier and radon decay calculated and are within packaging area products and applicable limits as defined under increasing radiation uranium dust in the RPC Act 1982. doses to workers or the processing the public. plant, ponds and accommodation camp areas remain below the investigation levels

20

Annual Dose Limit = 20mSv

15

10

5 Total EffectiveTotal Dose (mSv)

0 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

Average Max Figure 3-25: Employee dose from 2001 to 2011

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Table 3-21: Public dose details Dose (mSv) Dust dose (including 0.015 natural background Radon dose (excluding 0.00 background) Total dose for 2010 0.015 Public Dose limit (annual) 1.00

3.8 Heritage All heritage sensitive sites are clearly recorded and a report is generated after every work area clearance survey. Areas are mapped after each survey by Heathgate personnel for internal purposes only. The Native Title Holders wish the locations of these sites remain out of the public domain. Selected locations are protected by flagging (fencing) to avoid disturbance and the relevant flagged areas are checked for disturbance by Heathgate personnel. No disturbance occurred in 2011. Aboriginal Liaison Advisors are included in all routine environmental clearances as part of the Environmental Clearance Permit system to ensure that heritage sensitive areas are not overlooked. Refer to compliance table being Table 3-22. Table 3-22: Compliance Table – Heritage

ID Potential Impact Outcome(s) Outcome Measurement Leading Compliance Status Event Criteria Indicator Criteria

7.1 Impacts on Aboriginal No disturbance Beverley - Documented Near-miss All heritage sensitive areas heritage as a result of to Aboriginal Aboriginal Heritage Clearance incident reports are clearly recorded after mine activity. artefacts or sites surveys of all operational areas. relating to every work area clearance of significance Beverley - Commitments to potential survey and the map was unless prior Traditional Owners reviewed disturbance of updated after each survey. approval under and discussed at the Beverley flagged areas. This map is used for the relevant Advisory Committee to the internal purposes only as legislation is satisfaction of members (as the requested by the Native obtained. agreement is confidential the Title Holders. Beverley - measurement criterion will be There has been no Commitments to the absence of disputes disturbance to flagged Traditional requiring legal action). sensitive areas. Owners as set Beverley North - Demonstration out in Beverley Advisory that documented Aboriginal agreements are Committee meetings Heritage Clearance surveys of all met. have been held to review operational areas. and discuss Audits show flagged areas are commitments to not disturbed. Traditional Owners.

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 3.9 Third Party Issues Beverley North There were no formal third party complaints in 2011 for either the Beverley or the Beverley North ML. Refer to compliance table being Table 3-23. Table 3-23: Compliance Table – Public

ID Potential Impact Outcome(s) Outcome Leading Compliance Status Event Measurement Criteria Indicator Criteria

8.1 Damage to adjacent No unauthorised Any fires caused by No reports of damage (including public or private damage to mining operations are damage by fires caused by property and adjacent public or controlled within the ML mining operations) to public or infrastructure, including private property boundary. private property and that caused by fire, as and infrastructure, infrastructure. One fire on the Any accidental damage a result of mine activity. including that northern end of Wooltana to infrastructure is made caused by fire, as Pastoral Station occurred and good as soon as a result of mine Heathgate personnel responded practicable. activity. and assisted in controlling and extinguishing the fire after being notified by Moolawatana pastoralists. This was most likely the result of a lightning strike.

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 4 ONGOING COMMUNITY ENGAGEMENT PLAN Twenty eight separate community consultations were recorded in Heathgate’s community consultation database for 2011. Heathgate reports community consultations to State regulators each quarter in the Quarterly Environment and Radiation Report and to State and Federal regulators every six months at the Beverley Environmental Consultative Committee meetings. The number of community consultations for each quarter is shown in Table 4-1 while a graph representing the comparative annual community consultations is given as Figure 4-1. Table 4-1: Quarterly Community Consultations for 2011 No. of Community 2011 Consultations 1st Quarter 8 2nd Quarter 7 3rd Quarter 7 4th Quarter 6

Figure 4-1: Community Consultations 2011 Heathgate personnel presented papers or talks at a number of conferences or public meetings during 2011. This included: Environmental Management in Mining Conference, Perth, 22-23 February and Brisbane 8-9 March, 2011 South Australian Chamber of Mines and Energy Breakfast Briefing, 17 March 2011 Paydirt Uranium Conference, Adelaide, 21-22 March 2011 AusIMM International Uranium Conference, Perth, 8-9 June 2011 (3 papers) IAEA Technical Meeting on Uranium Provinces and Mineral Potential Modelling, Vienna, Austria, 20-22 June 2011 Australian Mine Rehabilitation Workshop 2011, Adelaide, Australia, 17-19 August 2011 (2 papers) International Conference 2011: Uranium Mining and Hydrogeology VI, Freiberg, Saxony, Germany, 18-22 September 2011 (2 papers) U2011 Global Uranium Symposium and Trade Show, Casper, Wyoming, USA, 18-21 September 2011 International Conference on Advanced Nuclear Fuel Cycle and Related Nuclear Systems, Tokyo, Japan, December 2011

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 5 ENVIRONMENTAL RADIOLOGICAL MONITORING

Environmental radiation monitoring is undertaken in order to assess the environmental radiological impact due to the operation of the Beverley mines and includes Radon activity concentration in air; Potential alpha energy concentration of radon daughters in air; Long-lived alpha activity of airborne dust.

5.1 Radon Activity Concentration The radon concentration in air is measured using Passive Radon Monitors (PRM) with nuclear track detectors fixed at 20 different locations. The quarterly radon concentration results are given in Table 5-1 and Figure 5-1 shows a graph of monitoring trends since 1999. Table 5-1: Passive Radon Monitoring Results from Various Locations

Radon Concentration 3 Quarter 2011 (Bq/m ) Avg Max First 38.2 73.6 Second 72.1 170.5 Third 39.5 67.1 Fourth 59.1 89.5

500

400

300

200

100 Radon Concentration (Bq/m3) Concentration Radon

0 31-Mar-99 31-Mar-01 31-Mar-03 31-Mar-05 31-Mar-07 31-Mar-09 31-Mar-11

Average Max Figure 5-1: Passive Radon Activity Concentration Monitoring Trends

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 5.2 Radon Decay Product PAEC

The Potential Alpha Energy Concentration (PAEC) of radon decay products is measured continuously at the camp using an Environmental Radon Daughter Monitor (ERDM) which logs every 10 minutes with data downloaded every month. Results of monitoring done in 2011 are presented in Table 5-2 and a summary of monitoring compared with previous years is given in Figure 5-2. Table 5-2: Quarterly Radon Decay Products PAEC

PAEC ( Jm-3) Month Average Maximum January 2011 0.06 0.35 February 2011 0.05 0.39 March 2011 0.02 0.20 April 2011 0.05 0.29 May 2011 0.04 0.22 June 2011 0.05 0.38 July 2011 0.04 0.29 August 2011 0.04 0.21 September 2011 0.01 0.05 October 2011 0.04 0.33 November 2011 0.05 0.35 December 2011 0.01 0.05

The average radon decay products concentrations at camp remained low during the year 2011.

1.0

0.8

0.6

0.4

0.2 RnD Concentration Concentration (uJ/m3) RnD 0.0 06/12/99 05/11/01 06/10/03 05/09/05 06/08/07 06/07/09 06/06/11

Average 10 min Maximum

Figure 5-2: Radon Decay Products PAEC Quarterly Monitoring Trends (Note: Monitoring was incomplete during March and April 2007 and December 2010 because of instrument failure)

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 5.3 Long Lived Alpha Activity in Dusts

Long-lived alpha activity (LLAA) in dust was conducted continually at the camp area using a High Volume Air Sampler. The filter paper was changed monthly and sent to Australian Radiation Services (ARS) for radiometric analysis. Results of this monitoring are given in Table 5-3 and comparison with previous years monitoring is shown in Figure 5-3. Table 5-3: High Volume Air Sampling Radiometric Analysis

Month Radionuclide Concentration (μBqm-3) 238U 226Ra 230Th January 2011 6 1.2 60 February 2011 10 8 100 March 2011 10 6 100 April 2011 8 1.2 80 May 2011 5 10 50 June 2011 8 2 80 July 2011 5 1.6 60 August 2011 10 2.2 90 September 2011 3.9 1.4 60 October 2011 9.6 2.5 130 November 2011 25 11.3 250 December 2011 9.0 3.6 90

Radionuclide concentrations at accommodation camp remained low and comparable with previous years monitoring results.

60

40

20 Concentration (uBq/m3) Concentration 0 13-Feb-02 09-Nov-04 06-Aug-07 02-May-10

Ra226 U238 Figure 5-3: High Volume Air Sampling at Accommodation Camp

Several risk areas involve radiological aspects and Table 5-4 outlines where these are within this document: Table 5-4: High Volume Air Sampling Radiometric Analysis

Risk Areas Sections ID Soil 3.2 1.1 Surface Water 3.4 3.1 Hydrogeology 3.5 4.2, 4.3, 4.4, 4.5 Air Quality 3.7 6.1, 6.2

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 6 STATUS OF OBLIGATION OF STATE AND FEDERAL CONDITIONS The status of obligations with State and Commonwealth approval conditions and reporting requirements including those of the Environmental Protection and Biodiversity Conservation Act for the Beverley ML 6321 and Beverley North ML 6387 are outlined in Appendices L and M respectively.

7 RECTIFICATION OF NON-COMPLIANCES No non-compliances were found to have occurred during 2011.

8 MANAGEMENT SYSTEM REVIEW An internal audit on Heathgate’s compliance with both the Beverley ML and the Beverley North ML MARPs and licence conditions was undertaken during May 2012. This audit was undertaken by our Senior Environment Advisor. The results including recommendations from the audit, non-conformances and areas requiring improvement and recommendations noted are outlined in Appendix N.

9 FITNESS-FOR-PURPOSE REVIEW Beverley Mine Site has a Mex Ops system in place which brings up service requests and dates for rechecking of equipment. An incident report system, InControl, is utilised to action maintenance and repairs that are required to plant equipment at any time other than at regular maintenance checks. The entire Beverley project was subject to a thorough risk assessment prior to the lease extension in 2007 as was the Beverley North Project in 2009/2010. Any new major equipment or facility is subject to a Hazard and Operability Study (HAZOP) analysis.

10 NEW ENVIRONMENTAL HAZARDS No new environmental hazards became evident or apparent during 2011.

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 11 INCIDENTS

11.1 Incidents A total of 179 incidents including 56 hazards were recorded on Heathgate’s internal system, InControl, during the 2011 reporting period. The incidents have been classified into the following categories: Environmental Property Damage Quality/Production Hazard Occupational Health & Safety Injury, First Aid Treatments, Fatality Near Miss Lost Time injury (LTI)

Table 11-1: Categorised incidents for 2011

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec TOTAL

2 4 1 2 1 1 1 2 3 3 20 Environment 4 4 1 1 1 5 4 3 2 3 28 Property damage 1 1 1 1 1 2 1 8 Quality/production 11 3 4 2 3 7 1 1 8 2 9 5 56 Hazard 2 2 OHS Injury, first aid 8 7 10 2 3 1 4 1 1 3 5 7 52 treatments, fatality*

1 2 3 Near Miss 2 2 1 1 1 1 1 1 10 LTI 30 21 19 9 10 15 7 7 14 11 17 19 179 TOTAL * There were no fatalities.

11.2 Corrective Actions All incidents require the generation of an incident report which is logged into Heathgate’s incident and hazard database. Weekly meetings are held to discuss the corrective actions which are put into place when the incidents are logged into the database and to ensure that close out of these is actioned as soon as practicable.

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 12 OTHER

12.1 Public Liability Insurance Public liability insurance for all Heathgate operations is current and a copy of the Certificate of Currency is available to be shown to DMITRE on request.

12.2 MARP Amendments There were no amendments to either ML 6321 or ML 6387 during 2011. A full review of the Beverley ML 6321 MARP occurred in 2011 and this was sent to DMITRE for approval. It is planned that the Beverley and Beverley North MARPs be combined in the near future to form a single Program for Environmental Protection and Rehabilitation (PEPR) as part of the Environmental Management Program (EMP) which will encompass the Radioactive Waste Management Plant (RWMP).

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 13 BIBLIOGRAPHY ANZECC/ARMCANZ 2000. Australian and New Zealand Guidelines for Fresh and Marine Water Quality. Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand. Downloaded July 2006 from http://www.mincos.gov.au/publications/australian_and_new_zealand_guidelines_for_fresh_ and_marine_water_quality Badman FJ 2007. An Assessment of the Significant Environmental Benefit Values of the Beverley East Zone 2 Mine Lease Area. Prepared for Heathgate Resources Pty Ltd Badman FJ 2008. Beverley Uranium Mine, Vegetation Monitoring Observations September 2008. Prepared for Heathgate Resources Pty. Ltd DEWR/PIRSA 2007. Australian Government Department of the Environment and Water Resources/Government of South Australia Primary Industries and Resources SA 2007. Guidelines for Preparation of a Public Environment Report (PER) under the Australian Government Environment Protection and Biodiversity Conservation Act 1999 or a Mining And Rehabilitation Program (MARP) under the South Australian Mining Act 1971 Beverley Uranium Mine Extension, EPBC 2006/3167. BevPER.MARP Guideline V4.6.doc. 12/12/207, http://www.environment.gov.au/epbc/notices/assessments/2006/3167/finalised- guidelines.pdf DWLBC 2005. Guidelines For a Native Vegetation Significant Environmental Benefit Policy For the clearance of native vegetation associated with the minerals and petroleum industry. Prepared for the Native Vegetation Council, Department of Water, Land and Biodiversity Conservation http://www.pir.sa.gov.au/__data/assets/pdf_file/0003/30990/native_veg_policy.pdf EBS Ecology, 2011. Beverley Uranium mine Vegetation Monitoring Observations – September 2011 Ecological Associates, 2011. Beverley Uranium Mine Fauna Monitoring – 2011. Beverley and Beverley North Sites. Groundwater Science, 2011. Determination of Excursion Control Limits for Beverley North. Groundwater Science, 2011. Review of Groundwater Monitoring Approach and Program, Beverley Uranium Mine. Heathgate Resources Pty Ltd 2008a. Response Document - Mining Proposal / draft PER for Proposed Extension of Beverley Mine. Prepared for Heathgate Resources Pty Ltd by URS Australia Pty Ltd, 18 April 2009 http://www.heathgateresources.com.au/contentnewsroom.jsp?xcid=37 Heathgate Resources Pty Ltd, 2008b, Beverley Mine – Mining and Rehabilitation Program – September 2008, Heathgate Resources, Adelaide Heathgate 1998a. Beverley Uranium Mine: Environmental Impact Statement – Main Report. Heathgate Resources Pty Ltd, June 1998, Adelaide Heathgate 1998b. Beverley Uranium Mine: Environmental Impact Statement - Response Document/Supplement. Heathgate Resources Pty Ltd, September 1998, Adelaide Heathgate Resources Pty Ltd 2007. Mining Proposal for Proposed Extension of Beverley Mine. Prepared for Heathgate Resources Pty Ltd by URS Australia Pty Ltd, 21 December 2007 http://www.heathgateresources.com.au/contentnewsroom.jsp?xcid=37 Heathgate 2009a. Beverley Four Mile Project Public Environment Report and Mining Lease Proposal. Prepared for Heathgate Resources Pty Ltd by URS Australia Pty Ltd, ref. 42657105.05002, 7 January 2009.

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 http://www.pir.sa.gov.au/minerals/public_notices/beverley_four_mile_project_mining_propo sal Heathgate 2009b. Response Document - Beverley Four Mile Project PER and Mining Lease Proposal. Prepared for Heathgate Resources Pty Ltd by URS Australia Pty Ltd, 19 March 2009. http://www.pir.sa.gov.au/__data/assets/pdf_file/0009/97083/Mining_Proposal_Response_F our_Mile_FINAL_20090319.pdf Heathgate 2010. Beverley North Mine Mining and Rehabilitation Program January 2011. Heathgate Resources 21 December 2011, Adelaide Kutty, S, Woods, P., Dayal, E & Jagger, A, 2010. Keeping Radiation Management at Beverley Uranium Mine at Best Practice; Plans, Responses and Outcomes. 35th Australasian Radiation Protection Society Conference, Adelaide, 18-20 October 2010 Outback Ecology Services, 2012. Heathgate Resources Pty Ltd, Beverley Uranium Mine and Beverley North Uranium Mine. Ecosystem Function Analysis of Rehabilitated Areas Against Completion Criteria. PIRSA 2007. Guidelines for the Preparation of a Mining Lease Proposal or Mining and Rehabilitation Program (MARP), version 4.8. Primary Industries and Resources SA, July 2007 http://www.pir.sa.gov.au/__data/assets/pdf_file/0003/47514/MARP_Guideline_V4.8.pdf PIRSA 2007. Guidelines for the Preparation of a Mining Lease Proposal or Mining and Rehabilitation Program (MARP), version 4.8. Primary Industries and Resources SA, July 2007 http://www.pir.sa.gov.au/__data/assets/pdf_file/0003/47514/MARP_Guideline_V4.8.pdf PIRSA 2009. Minerals Regulatory Guidelines MG3 Guideline for Miners: Preparation of a Mining and Rehabilitation Compliance Report (MARCR) for Mining Operations Version 1.4. PIRSA, 2009. Waudby, HP and Howe, T 2008. An additional record of the dusky hopping mouse Notomys fuscus in South Australia. Australian Mammalogy 30: 47-49

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APPENDIX A: BEVERLEY ML MONITOR WELL LEVEL GRAPHS – NAMBA FORMATION

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APPENDIX B: BEVERLEY ML MONITOR WELL CHEMISTRY GRAPHS – NAMBA FORMATION

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APPENDIX F: BEVERLEY NORTH ML MONITOR WELL LEVEL GRAPHS – EYRE FORMATION

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APPENDIX G: BEVERLEY NORTH ML MONITOR WELL CHEMISTRY GRAPHS – EYRE FORMATION

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Beverley North Monitor Well Chemistry Graphs – Eyre Well Type A - pH 4.5; SO4 2.0; U3O8 1.0

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Beverley North Monitor Well Chemistry Graphs – Eyre Well Type A - pH 4.5; SO4 2.0; U3O8 1.0

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Beverley North Monitor Well Chemistry Graphs – Eyre Well Type A - pH 4.5; SO4 2.0; U3O8 1.0 Beverley North Monitor Well Chemistry Graphs – Eyre Lateral Well Close to ML Boundary

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Beverley North Monitor Well Chemistry Graphs – Eyre Well Type A - pH 4.5; SO4 2.0; U3O8 1.0

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Beverley North Monitor Well Water Chemistry Graphs – Eyre Well Type B - pH 4.5; SO4 2.0; U3O8 1.0

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Beverley North Monitor Well Water Chemistry Graphs – Eyre Well Type B - pH 4.5; SO4 2.0; U3O8 1.0

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Beverley North Monitor Well Water Chemistry Graphs – Eyre Well Type B - pH 4.5; SO4 2.0; U3O8 1.0

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Beverley North Monitor Well Water Chemistry Graphs – Eyre Well Type B - pH 4.5; SO4 2.0; U3O8 1.0

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Beverley North Monitor Well Water Chemistry Graphs – Eyre Well Type B - pH 4.5; SO4 2.0; U3O8 1.0

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APPENDIX H: BEVERLEY NORTH ML MONITOR WELL LEVEL GRAPHS – NAMBA FORMATION

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Beverley North Monitor Well Water Level Graphs – Namba Overlying Well

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APPENDIX I: BEVERLEY NORTH ML MONITOR WELL CHEMISTRY GRAPHS – NAMBA FORMATION

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APPENDIX J: BEVERLEY NORTH ML MONITOR WELL LEVEL GRAPHS – FRACTURED ROCK FORMATION

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Monitor Well Water Level Graphs – Fractured Rock Underlying Well

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APPENDIX K: BEVERLEY NORTH ML MONITOR WELL CHEMISTRY GRAPHS – FRACTURED ROCK FORMATION

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APPENDIX L: STATUS OF OBLIGATIONS - BEVERLEY ML 6321

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Obligation Origin Condition Status of Obligations

State (PIRSA) Approval: 1 Mining operations authorised by this lease must be only for the recovery of Uranium. Compliant First Schedule

2 The Lessee must keep accurate records of the quantity, value and manner of disposition of all Compliant. No records requested for inspection. minerals mined and, whenever required to do so, submit the records for inspection by any person authorised by the Director of Mines. 3 The Lessee must not conduct any mining operations on the land until a Mining and Rehabilitation 2008 MARP approved by PIRSA on 7 October 2008 Program (MARP) has been approved by the Minister. triggered by ML extension. MARP revision currently with DMITRE for approval. Combined Beverley and Beverly North PEPR to proceed once guidelines received from DMITRE 4 The MARP must comply with the requirements of guidelines approved by the Director of Mines and 2008 MARP approved by PIRSA on 7 October 2008 include environmental outcomes and criteria that are developed in consultation with relevant triggered by ML extension. stakeholders. 5 The Lessee agrees to the approved MARP being made available for public inspection. The 2008 MARP is available to the public on the PIRSA website. Heathgate provides electronic copies on request and is in the process of upgrading its website. 6 The Lessee must demonstrate upon request and to the Director of Mines, the Lessee's capability Heathgate considers its record gives good confidence in and competence to comply with the requirements of the Mining Act, 1971, the conditions of this its ability and competence and will provide further lease and the MARP. demonstration on the appropriate request from the Director of Mines. 7 The Lessee accepts that the Director of Mines may withdraw a MARP approval if, in the Director’s The MARP approved by PIRSA on 7 October 2008 opinion, the Lessee has not complied with the approval, or has not demonstrated satisfactory remains valid. capability to comply with the approval. 8 The Lessee must provide to the Director of Mines, a Mining and Rehabilitation Compliance Report The 2010 MARCR was submitted on 31 May 2011 after a (MARCR) on operations carried out on the lease and compliance with the approved MARP. The two month approved extension. Heathgate provides MARCR must be submitted every year, within 3 months after the anniversary of the date the lease electronic copies on request and is in the process of was granted, or at some other time agreed with the Director of Mines in accordance with guidelines upgrading its website. approved by the Director of Mines. The Lessee agrees to the MARCR being made available for public inspection. 9 The Lessee must, if requested by the Director of Mines, undertake an independent audit of An independent audit was undertaken in March 2011 and achievement of the environmental outcomes in the MARP, by an independent expert approved by the report outlining the findings was included in the 2010 the Director of Mines. The audit will be made available to the public, in a manner and form as MARCR. determined by the Director of Mines. 10 The Lessee must provide to PIRSA a Mine Completion Report prior to lease relinquishment, in Mining not completed. accordance with guidelines approved by the Director of Mines.

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State (PIRSA) Approval: 11 The Lessee must, prior to commencing operations under this lease and for the duration of Compliant. First Schedule (cont) the lease maintain public liability insurance to cover all operations under the lease in the name of the Lessee for a sum not less than $50 million or such greater sum as specified by the Director of Mines and make such amendments to the terms and conditions of the insurance as the Director of Mines may require.

A copy of the cover note of certificate of currency for the insurance must be provided to the Director of Mines upon request.

If requested by the Director of Mines, the Lessee must engage a independent and reputable risk assessor to prepare a risk assessment report detailing the public liability risks arising out of the conduct of mining operations on the lease and recommending the level of amount of public liability cover (in respect of any one occurrence) that should be effected and maintained by the lessee. In preparing the risk assessment report, the assessor must consult with the landowner and the Director of Mines.

In specifying the level of insurance required, the Director of Mines accepts no liability for the completeness, adequacy of the sum insured, the limit of liability, the scoped coverage, the conditions or exclusions of the insurance in respect of how the Lessee may or may not respond to any loss, damage or liability. 12 The Lessee must report any non-compliant criteria that demonstrate a breach of the Compliant environmental outcomes to be achieved (as detailed in the MARP) to the Director of Mines.

A report must be provided after the Lessee becomes aware of the non-compliance, by the close of the next business day or such time period as specified in the MARP. 13 The Lessee must, before commencing operations under this lease, lodge a bond in Financial securities calculations emailed to DMITRE in accordance with the Mining Act, 1971 of such an amount of the surety as determined from August. Awaiting approval of bond amount. time to time by the Minister, to cover the full cost of rehabilitation liability assessed by an independent third party at any time.

In requesting a review of the bond, the Minister may request that written quotes from a third party are obtained by the lessee for the cost of rehabilitating the site to the requirements specified in the approved MARP.

The Lessee must meet all the charges and costs in obtaining and maintaining the Bond. State (PIRSA) Approval: 1 The Lessee must in constructing and operating the lease ensure that soil affected by mining Compliant - fulfilled through MARP obligations. Second Schedule - Soil activities is suitable for a return to pastoral use.

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State (PIRSA) Approval: 2 The Lessee must, in constructing and operating the lease, ensure that there is no Compliant - fulfilled through MARP obligations. Second Schedule - Waste contamination of land and soils either on or off the site caused by waste products and disposal and hazardous hazardous materials used in the mine operations. substances

State (PIRSA) Approval: 3 The Lessee must in constructing and operating the lease ensure that there are no adverse Compliant - fulfilled through MARP obligations. Second Schedule - Waste impacts to the environment due to radon release, uranium-bearing materials, or radiological disposal and hazardous aspects of seepages and spills. substances (cont)

State (PIRSA) Approval: 4 The Lessee must, in constructing and operating the lease ensure no loss of abundance or Compliant - fulfilled through MARP obligations. Second Schedule - diversity on or off the Beverley mining lease to native vegetation through clearance or any Vegetation other damage unless prior approval under the relevant legislation is obtained.

State (PIRSA) Approval: 5 The Lessee must in constructing and operating the lease ensure no introduction of new Compliant - fulfilled through MARP obligations. Second Schedule - Weeds weeds, plant pathogens or pests (including feral animals), nor increase in abundance of and Pests (feral animals) existing weed or pest species in the lease area compared to adjoining pastoral properties.

State (PIRSA) Approval: 6 The Lessee must in constructing and operating the lease ensure no compromise of pastoral Compliant - fulfilled through MARP obligations. Second Schedule - use of downstream surface water bodies. Stormwater

State (PIRSA) Approval: 7 The Lessee must, in constructing and operating the lease ensure that there is no Compliant - fulfilled through MARP obligations. Second Schedule - compromise to other existing Great Artesian Basin users within the Beverley mine region. Groundwater

8 The Lessee must, in constructing and operating the lease ensures that there is no Compliant – fulfilled through MARP obligations - noting compromise to pastoral use of the Willawortina aquifer. that most Willawortina wells on the lease do not meet stock water quality guidelines (Section 6.5.8.4 of the MARP) 9 The Lessee must, in constructing and operating the lease ensure that there is no Compliant - fulfilled through MARP obligations. compromise of potential pastoral use (should it meet pastoral water quality standards) of the Namba aquifer outside the Beverley mining lease. State (PIRSA) Approval: 10 The Lessee must in constructing and operating the lease ensure that there are no net Compliant - fulfilled through MARP obligations. Second Schedule - Native adverse impacts from the site operations on native fauna abundance or diversity in the lease Fauna area and in adjacent areas.

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State (PIRSA) Approval: 11 The Lessee must in constructing and operating the lease, ensure that there is no disturbance Compliant - fulfilled through MARP obligations. Second Schedule - to Aboriginal artefacts or sites of significance unless prior approval under the relevant Aboriginal and European legislation is obtained. Heritage

State (PIRSA) Approval: 12 The Lessee must in constructing and operating the lease ensure that there are no Compliant - fulfilled through MARP obligations. Second Schedule - Fire uncontrolled fires caused by mining operations.

State (PIRSA) Approval: 13 The Lessee must in constructing and operating the lease ensure that there are no public Compliant - fulfilled through MARP obligations. Second Schedule - injuries and or deaths resulting from unauthorised entry to the site that could have been Unauthorised Access reasonably prevented.

State (PIRSA) Approval: 14 Where the pastoral lease holder differs from the mining lease holder, the Lessee must Heathgate is the relevant pastoral lease holder. Second Schedule - ensure that the occupier of the land is fully advised of their program of activities, particularly Landholder Liaison in regard to the impact of operations on the land and rehabilitation progress.

State (PIRSA) Approval: 15 The Lessee must, in constructing and operating the lease, ensure that there is no Compliant Second Schedule - unauthorised damage to adjacent public or private infrastructure. Infrastructure

State (PIRSA) Approval: 16 The Lessee must demonstrate prior to lease expiry or surrender that the following outcomes Mining not completed. Second Schedule - (in so far as they may be affected by mining operations) will be achieved indefinitely post Closure and Rehabilitation mine closure to the satisfaction of the Director of Mines.

16a No change, outside of natural background variation, to the water quality of the GAB. Mining not completed.

16b No change, outside of natural background variation, to the water quality of the Willawortina Mining not completed. Formation. 16c No compromise of potential pastoral use (should it meet pastoral water quality standards) of Mining not completed. the Namba aquifer outside the Beverley mining lease. 16d The external visual amenity of the site is acceptable to relevant stakeholders. Mining not completed.

16e Risks to the health and safety of the public and fauna are as low as reasonably achievable. Note: with respect to radiological risks to fauna, it is deemed that the ALARA protection of the public means that fauna are similarly protected. Mining not completed. 16f Ecosystem and landscape function is resilient, self-sustaining and indicating that the pre- Mining not completed. mining ecosystem and landscape function will ultimately be achieved 16g All waste materials left onsite are chemically and physically stable Mining not completed.

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State (PIRSA) Approval: 17 The MARP must include additional leading indicator criteria for the following outcomes. Second Schedule - Leading Indicators

17a Ensure that soil affected by mining activities is suitable for a return to pastoral use. Compliant – leading indicator criteria included in the approved MARP. 17b Ensure that there is no compromise to other existing Great Artesian Basin users within the Compliant – leading indicator criteria included in the Beverley mine region. approved MARP. 17c Ensure that there is no compromise to pastoral use of the Willawortina aquifer. Compliant – leading indicator criteria included in the approved MARP. 17d Ensure that there is no compromise of potential pastoral use (should it meet pastoral water Compliant – leading indicator criteria included in the quality standards) of the Namba aquifer outside the Beverley mining lease. approved MARP. Federal Approval 1 The person taking the action must ensure that, in undertaking the action, the following Conditions outcomes are achieved (in so far as they may be affected by mining operations):

1(a) No compromise to other existing Great Artesian Basin users within the Beverley mine region Compliant- MARP obligation.

Federal Approval 1(b) No compromise to pastoral use of the Willawortina aquifer. Compliant, noting that most Willawortina wells on the Conditions (cont) lease do not meet stock water quality guidelines (Section 6.5.8.4 of the MARP) – MARP obligation. 1(c) No compromise of potential pastoral use (should it meet pastoral water quality standards) of Compliant – leading indicator criteria included in the the Namba aquifer outside the Beverley mining lease. approved MARP. 1(d) No loss of abundance or diversity on or off the Beverley mining lease to native vegetation Compliant- MARP obligation. through clearance or other damage unless prior approval under relevant legislation is obtained. 1(e) No net adverse impacts from the site operations on native fauna abundance or diversity in Compliant- MARP obligation. the lease area and adjacent areas. 1(f) No introduction of new weeds, plant pathogens or pests (including feral animals), or increase Compliant- MARP obligation. in abundance of existing weed or pest species in the lease area compared to adjoining pastoral areas. 1(g) No uncontrolled fires caused by mining operations. No uncontrolled fires occurred on the MLs.

1(h) No disturbance to Aboriginal artefacts or sites of significance unless prior approval under the No heritage listed sites on ML 6321. relevant legislation is obtained. 1(i) No compromise of pastoral use of downstream surface water bodies. Compliant- MARP obligation.

1(j) Soil affected by mining activities is suitable for return to pastoral use. Bioremediation bays are in use and soil testing for reuse is planned for 2011. Scanning of soils for surface contamination occurs.

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1(k) No adverse impacts to the environment due to radon release, uranium-bearing materials, or Compliant- MARP obligation. radiological aspects of seepages and spills. 1(l) No contamination of land and soils either on or off the site caused by waste products and Compliant- MARP obligation. hazardous materials used in the mine operations that would compromise a return to pastoral use. 2 The person taking the action must develop a Monitoring Plan to measure the achievement of The Monitoring Plan exists as Chapter 6 of the MARP. each outcome in Condition 1. The Monitoring Plan must specify: 2(a) criteria to demonstrate the clear and unambiguous achievement of the outcomes specified Compliant. above 2(b) the parameters to be monitored Compliant.

2(c) how frequency of monitoring will be determined Compliant.

2(d) the responsibility for interpreting the monitoring results Compliant. Results are interpreted by appropriate environmental specialists, either external or internal to Heathgate and documented in the MARCR. The 2010 results are provided in the 2010 MARCR. 2(e) the threshold triggers and the response activities Compliant.

2(f) an outline of control and management strategies that may be used to achieve the Compliant. groundwater outcomes in Condition 1 2(g) reporting arrangements to management, external stakeholders and the public, including Compliant. procedures for reporting non-compliance The action cannot commence until the Monitoring Plan is approved by the Minister. The Compliant. The monitoring plan was integrated into the approved Plan must be implemented. MARP and approved by the Minister on 11 November 2008. 3 The person taking the action must develop a Mine Closure and Completion Plan. The Plan must demonstrate that the following outcomes, in so far as they may be affected by mining operations, will be achieved indefinitely post mine closure: 3(a) No change, outside of natural background variation, to the water quality of the Great Artesian Compliant. The Mine Closure and Completion Plan was Basin. integrated into this MARP and includes this condition (3a). 3(b) No change, outside of natural background variation, to the water quality of the Willawortina Compliant. The Mine Closure and Completion Plan was formation. integrated into this MARP and includes condition 3(b). 3(c) No compromise of potential pastoral use (should it meet pastoral water quality standards) of Compliant. The Mine Closure and Completion Plan was the Namba aquifer outside the Beverley mining lease. integrated into this MARP and includes condition 3(c).

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3(d) Risks to the health and safety of the public and fauna are as low as reasonably achievable. Compliant. The Mine Closure and Completion Plan was integrated into this MARP and includes condition 3(d) with respect to radiological risks to fauna, it is deemed that the ALARA protection of the public means that fauna are similarly protected. 3(e) Ecosystem and landscape function is resilient, self-sustaining and indicating that the pre- Compliant. The Mine Closure and Completion Plan was mining ecosystem and landscape function will ultimately be achieved. integrated into this MARP and includes condition 3(e). 3(f) All waste materials left onsite are chemically and physically stable. Compliant. The Mine Closure and Completion Plan was integrated into this MARP and includes condition 3(f). The action cannot commence until the Mine Closure and Completion Plan is approved by the Progressive rehabilitation will be documented in the Minister. The approved Plan must be implemented. annual MARCR due 31 May. A Mine Closure and Completion Plan was approved by the Minister on 11 November 2008. A formal Closure Plan will require the Minister’s approval. 4 The person taking the action must prepare a Community Engagement Plan to enable open The Community Engagement Plan is integrated into the dialogue with stakeholders on compliance with the approval conditions. The action cannot MARP and approved by the Minister on 11 November commence until the Plan is approved by the Minister. The Plan must be implemented. 2008. 5 Within 14 days of commencement of the action, the person taking the action must advise the Compliant. Department of the actual date of commencement. 6 Within three months of the anniversary of the date of commencement of the action and each Compliant – The 2010 MARCR based on the 2010 year after, the person taking the action must provide a report to the Department addressing calendar years was done by 31 May 2011 after an compliance with the conditions of this approval. Annual reports must be provided until the approved two months extension. Minister is satisfied that the proponent has complied with all conditions of the approval. 7 If at any time after five years from the date of this approval, the Minister notifies the person Compliant. taking the action in writing that the Minister is not satisfied that there has been substantial commencement of the action, the action must not thereafter be commenced without the written agreement of the Minister. 8 Upon the direction of the Minister, the person taking the action must ensure that an Compliant – an external audit was undertaken in March independent audit of compliance with the conditions of approval is conducted and a report 2011 and the report is presented in the 2010 MARCR. No submitted to the Minister. The independent auditor must be approved by the Minister prior to direction to undertake a separate external audit has been the commencement of the audit. Audit criteria must be agreed to by the Minister and the received from the Minister. audit report must address the criteria to the satisfaction of the Minister. 10 If the Minister believes that it is necessary or desirable for the better protection of the Heathgate believes the regular regulator discussions environment to do so, the Minister may request the person taking the action to make (quarterly with State regulators and six-monthly State and specified revisions to the plan approved pursuant to Conditions 2, 3 and 4 and to submit a Federal regulators) will mean any such revisions will be revised plan for the Minister’s approval. The person taking the action must comply with any made progressively with consultation. such request. If the Minister approves the revised plan pursuant to this paragraph, the person taking the action must implement this plan instead of the plan originally approved.

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11 The person taking the action must maintain accurate records substantiating all activities Compliant – all records being maintained. associated with or relevant to the above conditions of approval and make them available upon request to the Department. Such records may be subject to audit by the Department and used to verify compliance with the conditions of approval. Licence to Mine and Mill 1 The Licensee shall comply with the “Code of Practice for Radiation Protection and Radioactive Compliant. Conditions Waste Management in Mining and Mineral Processing (2005)”: Radiation Protection Series No 9; ARPANSA (August 2005), and any amendments thereof or any codes, standards or State EPA – Radiation recommendations substituted therefore. Protection Branch

2 This licensee shall submit to the Environment Protection Authority, together with the application for Compliant. Licence LM4 includes Beverley and Beverley renewal: North MLs and was issued on 4/8/11.

1. A plan showing areas in which new wellfield development is planned in the next licence period; 2. Any significant changes in the plant layout, major equipment or processes introduced during the preceding period; 3. Estimates of the quantities of wastes produced in the previous licence period

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APPENDIX M: Status of Obligations - Beverley North ML 6387

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State (PIRSA) Approval: 1 The term of the lease is for 5 years Accepted Schedule B

2 Lessee must undertake the following program of work in relation to the lease: Compliant Year 1 (or for a term as agreed with the Director of Mines) – Construction and operation of a Uranium In Situ Recovery Field Leach Trial at the Pepegoona deposit, in accordance with the details provided in the Retention Lease Application and subsequent Response Document Undertake progressive rehabilitation of the above Field Leach Trial and closure criteria monitoring to demonstrate achievement of the Closure Outcomes specified in Second Schedule Lease Condition No. 14 3 Pursuant to Section 41F(b) the Lessee has the right to conduct the following mining operations on the Compliant Lease: Undertake a Uranium ISR Field Leach Trial to determine the physical properties of the aquifer, assess pumping design parameters, and assess process and economic performance. 4 The Lessee must not commence or undertake mining operations until a Program, pursuant to Regulation Compliant 42 (b) (ii) has been approved by the Minister (hereafter referred to as a MARP) and a bond has been paid in accordance with Section 62 of the Mining Act, 1971

5 The Lessee must prepare a MARP under clause 4 that complies with the requirements of guidelines Compliant. FLT MARP submitted and approved by the Director of Mines and include environmental outcomes and criteria that are developed in approved. consultation with relevant stakeholders.

6 The criteria included in the MARP must demonstrate clear and unambiguous achievement of the Compliant. environmental outcomes by: • Including the specific parameters to be measured and monitored by the Lessee • Specifying the locations that the parameters will be measured, or how these locations will be determined • Clearly stating the acceptable values for demonstrating achievement of the outcome , with consideration of any inherent errors of measurement • Specifying the frequency of monitoring by the Lessee • Identifying what background or control data are to be used or specify how it will be acquired (if necessary).

7 The Lessee must implement and comply with the approved MARP Compliant.

8 The Lessee must review the MARP on request of the Director of Mines within a time specified in the Compliant. request and submit the revised MARP for approval to the Director of Mines.

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9 The Lessee agrees to the approved MARP being made available for public inspection. The approved MARP is available to the public on the PIRSA website and is available from Heathgate upon request.

10 The Lessee must demonstrate upon request and to the Director of Mines, the Lessee's capability and No request made however Heathgate is competence to comply with the requirements of the Mining Act, 1971, the conditions of this lease, and capable and competent in complying with the MARP. requirements of the Act, lease conditions and MARP.

11 The Lessee must provide to the Director of Mines a Mining and Rehabilitation Compliance Report A combined Beverley and Beverley North (MARCR) on operations carried out on the Lease and compliance with the approved Program and the MARCR was submitted on 31 May 2011 after program of work specified in Clause 2. The MARCR must be submitted every year, within 2 months after an approved two month extension. The the anniversary of the date the Lease was granted, or at some other time agreed with the Director of Mines MARCR will be submitted to PIRSA for in accordance with guidelines approved by the Director of Mines. The Lessee agrees to the MARCR being display to the public. made available for public inspection.

12 The Lessee must, prior to commencing operations under this Lease and for the duration of the lease Compliant maintain public liability insurance to cover all operations under the Lease in the name of the Lessee for a sum not less than $20 million or such greater sum as specified by the Director of Mines, and make such amendments to the terms and conditions of the insurance as the Director of Mines may require. A copy of the cover note of certificate of currency for the insurance must be provided to the Director of Mines upon request. If requested by the Director of Mines, the Lessee must engage an independent and reputable risk assessor to prepare a risk assessment report detailing the public liability risks arising out of the conduct of operations on the lease, and recommending the level of amount of public liability cover (in respect of any one occurrence) that should be effected and maintained by the Lessee. In preparing the risk assessment report, the assessor must consult with the landowner and the Director of Mines. In specifying the level of insurance required, the Director of Mines accepts no liability for the completeness, adequacy of the sum insured the limit of liability, the scoped coverage, the conditions or exclusions of the insurance in respect of how the Lessee may or may not respond to any loss, damage or liability.

13 The Lessee must report any non-compliance with these conditions and approved MARP to the Director of Compliant. Mines. A verbal notification must be provided within 24 hours, after the Lessee becomes aware of the non- compliance. A written report must be provided within 3 calendar days or such time period as approved by the Director of Mines.

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14 In requesting a review of the bond required under the Mining Act,1971, the Minister may request that Compliant. Bond calculations currently with written quotes from a third party are obtained by the Lessee for the cost of rehabilitating the site to the DMITRE for approval. requirements specified in the approved MARP. The Lessee must meet all the charges and costs in obtaining and maintaining the Bond

State (PIRSA) Approval: 1 The Lessee must, in constructing and operating the Lease, ensure that there is no unauthorised Compliant. Schedule C damage (including that caused by fire) to adjacent public or private property and infrastructure.

2 The Lessee must ensure that the occupier of the land is fully advised of their program of activities, Compliant particularly in regard to the impact of operations on the land and rehabilitation progress.

3 The Lessee must, in constructing and operating the Lease, ensure that there is no disturbance to Compliant Aboriginal or European artefacts or sites of significance unless prior approval under the relevant legislation is obtained. 4 The Lessee must, in constructing and operating the Lease ensure that there are no net adverse Compliant - fulfilled through MARP impacts from the site operations (including fire) on native fauna abundance or diversity in the Lease obligations. area and in adjacent areas. 5 The Lessee must, in constructing and operating the Lease ensure no permanent loss of abundance Compliant - fulfilled through MARP or diversity on or off the Lease to native vegetation through: obligations. a. clearance, b. dust/contaminant deposition c. fire or d. other damage to native vegetation unless prior approval under the relevant legislation is obtained. 6 The Lessee must, in constructing and operating the Lease ensure no introduction of new species of Compliant - fulfilled through MARP weeds, plant pathogens or pests (including feral animals), nor increase in abundance of existing obligations. weed or pest species in the Lease area compared to adjoining land. Weeds are defined in this condition as any invasive plant that threatens native vegetation in the local area or any species recognised as invasive in South Australia. 7 The Lessee must, in constructing and operating the Lease ensure that soil affected by mining Compliant - fulfilled through MARP activities is suitable for a return to pre-mining use. obligations. 8 The Lessee must, in constructing and operating the lease ensure that there is no compromise to the Compliant - fulfilled through MARP environmental values of the Eyre Formation aquifer outside the Beverley North Retention Lease. obligations.

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9 The Lessee must, in constructing and operating the lease ensure that there is no compromise to the Compliant - fulfilled through MARP environmental values of the Namba and Willawortina aquifers, should they be present and obligations. saturated. 10 The Lessee must, in constructing and operating the lease ensure that there is no compromise to the Compliant - fulfilled through MARP environmental values of the Fractured Rock aquifer. obligations. 11 The Lessee must in constructing and operating the lease ensure no compromise of pastoral use of Compliant - fulfilled through MARP downstream surface water bodies. obligations.

12 The Lessee must not dispose of any waste within the lease unless prior approval under the relevant Compliant. All waste is being transported for legislation is obtained. disposal at the Beverley mine waste facilities.

13 The Lessee must, in constructing and operating the lease ensure that there are no adverse impacts The RWMP and RMP are the key documents to the environment due to radon release, uranium-bearing materials, or radiological aspects of for management of radiological aspects of the seepages and spills. Beverley North operations and also fulfilled through MARP obligations.

14 The Lessee must demonstrate to the satisfaction of the Director of Mines that the following mine Compliant – fulfilled through MARP closure outcomes (in so far as they may be affected by mining operations) are expected to be obligations. achieved and sustained after mine closure: a. No compromise to the environmental values of the Eyre Formation aquifer b. No compromise to the environmental values of the Namba and Willawortina aquifers, should either be present and saturated c. No compromise to the environmental values of the Fractured Rock aquifer d. The external visual amenity of the site is acceptable to relevant stakeholders e. Risks to the health and safety of the public and fauna are as low as reasonably achievable f. Ecosystem and landscape function is resilient, self-sustaining and indicating that the pre-mining ecosystem and landscape function will ultimately be achieved 15 a. The Lessee must specify closure criteria that will be used to demonstrate the clear and a. Compliant – fulfilled through the MARP unambiguous achievement of the closure outcomes obligations. b. A formal Closure Plan will require the b. Demonstrate that the closure criteria have been met within 5 years of the cessation of mining. Minister’s approval before closure and rehabilitation activities.

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16 The MARP must include additional leading indicator criteria for the following outcomes: Compliant – fulfilled through MARP a) Ensure that soil affected by mining activities is suitable for a return to pre-mining use. obligations. b) Ensure that there is no compromise to the environmental values1 of the Eyre Formation aquifer outside the Retention Lease c) Ensure that there is no compromise to the environmental values13 of the Namba and Willawortina aquifers should either be present and saturated d) Ensure that there is no compromise to the environmental values Fractured Rock aquifer.

17 The above environmental outcomes do not derogate from the operation of any other Acts that may Compliant. be applicable to this operation including (but not limited to): • Aboriginal Heritage Act 1988 • Environment Protection Act 1993

Commonwealth Approval All exploration bores and production and monitoring wells will be cemented to the water table or to the Compliant - fulfilled through MARP Conditions surface to avoid inter-aquifer flow obligations.

All wells will be pressure tested and failing wells either repaired until the test is successful or cemented and Compliant - fulfilled through MARP re-drilled obligations.

Pumping rates will be controlled to ensure a slight excess of extraction over injection Compliant - fulfilled through MARP obligations.

Groundwater levels and water quality will be monitored to track the movement of groundwater and solution, Compliant. and allow early control of any solution movement beyond the planned field leach trial area

At the completion of the trial, the affected aquifer will be remediated by groundwater sweep, as set out in Accepted. the referral EPBC 2010/5446, unless, before that time, the Minister has approved, subject to conditions including remediation of groundwater, the proposed Beverley North extension (EPBC 2009/5138)

1 Environmental Values will be defined according to: The environmental values recognised in ‘ANZEEC & ARMCANZ 2000 Australian and New Zealand guidelines for fresh and marine water quality. National Water Quality Management Strategy Paper No 4, Australian and New Zealand Environment and Conservation Council & Natural Resources Management Ministerial Council, Canberra’.

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APPENDIX N: Internal Audit

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012

Internal Compliance Audit for year 2011

Documents: Beverley MARP, Sept 2008 Beverley North MARP, Jan 2011

Audit date: May 2012 Auditors: Ping Goodwin Scope: To determine whether the requirements of the MARP are completed for Beverley ML and Beverley North ML. Distribution: Sue Carter

A = achieved NCR = non compliance O = observation

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) Bev MARP Sept 2008, Has there been leakage from double-lined O A Longdon interviewed 1 May 12. 6.2.7, 6.2.8 ponds? In the past, leaks are pumped out. But the volume is not How does this compare to the Target Action recorded so the TALR is unable to be calculated. No Leakage Rate (TALR) of 22 mL/m2/day? evidence of past pumping was available to sight. Sighted Bev-Form.209 for leaks and actions but no volume recorded. One form not dated. No leaks from the ponds were detected in 2011. Bev MARP Sept 2008, Are water levels in ponds: A Longdon interviewed 1 May 12. 6.2.7, 6.2.8 1) checked at least weekly, A Bev: Daily Plant and Wellfield Environmental Inspections Bev-Form.115 – daily sheets sighted for 2011. 2) checked after >10 mm of rainfall in a A day, and Level indicators on Ponds 1 – 4 allow visual inspection by operators. Electronic level indicators monitored by control 3) maintained at least 0.20 m below lowest room for PLP and Pond 5. level of rim? A Bev North MARP 2011, A Beverley North – there are no ponds at either the 6.4.8 4) Checked at least weekly? Pepegoona or Pannikan satellite plants. MARP Sept 2008, 6.2.7, Are any leaks detected by automatic O Ponds 1-4 weekly manual check with a pole. Pond 5 and 6.2.8 systems or visual observation PLP electronic monitoring. Recorded on the plant check list. No leaks detected during manual checks. 1) logged as events, and Bev-Form.115 and Bev-Form.209 sighted. 2) rectified? MARP Sept 2008, 6.2.7, Is there documentation showing: Beverley and Beverley north: 6.2.8 1) the number of spills, A All reportable/notifiable incidents have been recorded including nature and clean up actions (Bev-Form.157 – 2) the nature of spills A Notification of Incident).

3) clean up actions? A InControl system used to record incidents, actions and Bev North MARP 2011, follow up. Sighted closed reports: #2091 1 September and 6.4.8 4) Are the spill dimensions and A concentrations documented #2042 22 May. MARP Sept 2008, 6.2.7, Are the number of non-compliant ECPs A ECP not given prior to pegging at Pepegoona on 6.2.8 involving off-road incidents documented? 25 February. Incident report #2033 viewed on InControl. Are corrective actions in place to ensure these do not re-occur?

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.2.7, Are there surface sediment grab samples Sediment samples upstream and downstream taken for 6.2.8 taken up and downstream of local creeks? A Beverley and Beverley North in June 2011– results sighted Bev North MARP 2011, on environment database. 6.4.8 Do the chemical parameters analysed A Radionunlides analysed. include radionuclides? 1 in 20 ARI recorded 8-9 March 2011. Are grab samples taken: A 1) following rainfall events of >10 year ARI, 2) at least once per calendar year. A MARP Sept 2008, 6.3.6, Is all clearing undertaken approved in A ECP are routinely completed Beverley: # 881 and # 865, 6.3.7 accordance to the MARP? Beverley North # 873 and # 878. Bev North MARP 2011, Give 2 recent examples 6.5.8 MARP Sept 2008, 6.3.6, Do the 1) fauna and 2) flora surveys show A O Flora: EBS 2011 report sighted. 5 m x 2 m quadrats 6.3.7; that there is not increase in weed species in assessed in Beverley and Beverley North MLs. No ML 6321 Sch2, 5. the Mine Lease areas when compared to statement indicates that weed species in the Mining Lease pastoral areas? areas are more than the pastoral areas. Bev North MARP 2011, Are 5 m x 2m quadrats surveyed annually A Fauna: Ecological Associates 2011 Fauna report indicates 6.5.8 for flora weed species. while there is not an increase in feral animals in mining areas when compared to control sites, in general the entire region has higher numbers of cats and foxes. MARP Sept 2008, 6.3.6, Have any fires caused by mining operations A A bin fire occurred at the camp on 19/10/11 due to cigarette 6.3.8; been controlled within the ML boundary? butt. Confined to bin. ML 6321 Sch2, 12. Is the extent of any fires mapped, showing On 7/7/11 a small fire in the Bev Plant at the peroxide day Bev North MARP 2011, area burned and distance from boundary? N/a tank started when peroxide contacted some dead insects in 6.5.8 a flushing point. It was put out immediately after being isolated. MARP Sept 2008, 6.3.8, Are control monitoring sites located A Fauna (CON01 to 08) and Vegetation (BE25 to 32) control 6.6.6 approximately 5km from planned sites are located at least 5km from planned disturbances. disturbance areas for Monitoring maps sighted. 1) vegetation, and 2) fauna? These were chosen by EBS (fauna) and Frank Badman (vegetation). Were these sites chosen by a suitably A qualified and experienced specialist? There were no scheduled production activities in these Have vegetation and fauna control sites A areas due to lack of mineralisation. been confirmed that there is no mineralisation?

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.3.8; Is 1) species richness and 2) total cover for A EMS 2011 Vegetation report sighted. Species richness and ML 6321 Sch2, 4. all plant species and perennials only total cover was assessed for all species; perennials at both surveyed annually using 5m x 2m vegetation Bev and Bev North MLs. quadrats for the ML and local area? MARP Sept 2008, 6.3.8 Are weed 1) species and 2) cover surveyed A O 4 quadrats BE05, 09, 15, 16 were assessed for total cover annually using 4 x 1ha quadrats on the ML and species richness. EBS 2011 Vegetation report sighted. and local area? Weed species and cover is not specifically identified in the report. MARP Sept 2008, 6.3.8 Is there evidence showing that the number A 2 emails from P Woods sighted describing sighting of and density of alien vegetation species have Mexican Poppy (14 May 2011), near store, hand pulled) been recorded following rainfall and during and Onion Weed (10 May 2011, at Four Mile tanks) during the Annual survey on the ML? year. MARP Sept 2008, 6.3.8 Is there an aerial photographs taken A Aerial photo completed on 24 Feb 2011. Bev North MARP 2011, biannually (odd years) to assess vegetation 6.5.8 changes on the ML? MARP Sept 2008, 6.3.8 Are there Environmental Clearances issued A Yes. to document planned disturbances on ML? ECP are routinely complete. BN: #873 and #878 Is the actual disturbance on the ML at the Bev: #881 and #865 end of each calendar year 1) Measured by GPS? Actual disturbance logged on GPS and mapped in April 2) Reported as Percent Actual vs 2012. Expected Disturbance area MARP Sept 2008, 6.3.8 Ecosystem Function Analysis transects for A Yes. Outback Ecology Report 2011 sighted. controlled and disturbed areas within the ML and local areas established? Bev North MARP 2011, 6.5.8 Are the landscape units identified on BN eg A bare ground, stony surface, grass?

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.3.8 Is there a measure of: A Yes for Beverley and Beverley North MLs Outback Ecology 1) soil stability, Report 2011 sighted. Bev North MARP 2011, 2) water infiltration and 6.5.8 3) nutrient recycling

by determination of: geographic setting of site; landscape organisation and soil surface assessment (rain splash protection, perennial vegetation cover, litter, cryptogram cover, crust brokenness, soil erosion, deposited materials, surface roughness, surface nature, slake test, texture) MARP Sept 2008, 6.3.8 Are the following measured annually: A ? Quadrat Method has been used for 2010 and 2011 to 1) Plant cover, better reflect cover and density of the sparse vegetation, 2) density and and present more detail in terms of species composition. 3) diversity Plant density and cover and diversity recorded. Outback Ecology Report 2011 sighted. using ‘Point centred quarter’ – sampling points established on EFA transect at regular intervals – at each point distance to nearest perennial plant in each of four sectors measured? A Bev North MARP 2011, 6.5.8 Is the lower story plant assessment for annual and perennial spp, alien spp completed for plant cover, density and diversity? MARP Sept 2008, 6.3.8 Is the upper-storey cover and density in A ? EFA09 has vegetation above 3m. Outback Ecology Report areas with plants over 3 m in height 2011 sighted. measured annually using the ‘Wandering Quarter’ method – in areas with plants over 3 m in height - measuring 25 plants over 3 m in height within a 90 o arc starting at the 0 m post of EFA transect? Bev North MARP 2011, 6.5.8 Is the upper story >2m height measure annually for cover and density?

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.4.8; Are there surface grab samples taken of A Results for water grab samples from Dams 1 to 6, which ML 6321 Sch2, 6. Dams 1 to 6, which include the North and include North and south Mulga Dams completed 1/4/11 South Mulga dam immediately after rainfall if after the 8-9th March rainfall event in 2011. Spreadsheet Bev North MARP 2011, creeks were flowing? containing data sighted on Beverley server. 6.6.8 Are these analysed for pH, EC, SO4 and U? A All analysis completed.

There is no compromise of downstream A 0ppm uranium detected. surface water bodies?

If these results are higher than the A No results exceeded these levels. ANZECC/ARMCANZ 2000 guildelines listed below, has a mass balance been performed to determine if this is directly attributed to mining operations or due to natural variability? Salinity (EC) < 4000mg/L or (6000uS/cm) Sulphate < 1000 mg/L Uranium < 0.2 mg/L MARP Sept 2008, 6.5.6, Volume of GAB does not exceed the O GAB extraction volumes recorded. Noted that GAB Plant 2 6.5.7, 6.5.8; allocated volume specified by DWLBC totaliser stopped working from August to December 2011 ML 6321 Sch2, 7 licence conditions of 140ML? and was replaced in 2012 as reported to DFW. GAB Plant 2 volumes were estimated and reported to regulators as such. Environmental database sighted. MARP Sept 2008, 6.5.6, Does the GAB pressure remain higher than A Production wells are maintained at least 10m below the 6.5.7, 6.5.8; the maximum Namba aquifer? ground surface. The GAB pressures are above 40kPa. ML 6321 Sch2, 7. Are there any trending pressure drops for There are no trending pressure drops for Plant 1, Plant 2 GAB? and Old Camp Bore GAB sites. Environmental database sighted. MARP Sept 2008, 6.5.6, There is no adverse effect as a result of A Data sighted for OMWs show no adverse effect on 6.5.7, 6.5.8; mining, for the water levels, ECL parameters Beverley ML on environment database. ML 6321 Sch2, 8. (pH, SO4, U3O8) and Conductivity in the Willawortina when compared to the ANZECC/ARMCANZ 2000 categories of water use MARP Sept 2008, 6.5.6, Are there appropriate records that show that A The LLRW dumps are construction specifications are 6.5.7 the LLRW facilities are built to design? described in the site’s Radioactive Waste Management Plan. Pho evidence and GPS co-ordinates record the construction to design. Shanky interviewed 3 May 11.

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.5.6, Does groundwater monitoring of the A Data sighted for DMW001, 2, 4 on environment database. 6.5.7; ML 6321 Sch2, Willawortina shows that there is no No contamination trending sighted for Willawortina around 2,3,8. contamination from the LLRW facilities? dumps. MARP Sept 2008, 6.5.6, Does monitoring of groundwater pH, SO4 A Quarterly reports from 2011 indicate there are no 6.5.7; ML 6321 Sch2, 9. and U3O8 show that there is no migration of excursions outside ML boundaries. mining and disposal solutions outside the ML? MARP Sept 2008, 6.5.8 Are all ‘Type 1’ monitor wells monitored for A 3x random monitors selected on environmental database water level and chemistry fortnightly? and shows that the water levels and chemistries are obtained as per requirements. MARP Sept 2008, 6.5.8 Are all ‘Type 2’ monitor wells monitored for A 3x random monitors selected on environmental database water level and chemistry fortnightly? and shows that the water levels and chemistries are obtained as per requirements MARP Sept 2008, 6.5.8 Are all ‘Type 3’ monitor wells monitored for A 3x random monitors selected on environmental database water level and chemistry quarterly? and shows that the water levels and chemistries are obtained as per requirements MARP Sept 2008, 6.5.8 Are all ‘Type 4’ monitor wells monitored for A 3x random monitors selected on environmental database water level quarterly? and shows that the water levels and chemistries are obtained as per requirements MARP Sept 2008, 6.5.8 Are all Willawortina monitor wells measured A 5x random monitors selected on environmental database for water level fortnightly, and sampled for and shows that the water levels and chemistries are ECL parameters and Conductivity at a obtained as per requirements quarterly frequency? Bev North MARP 2011, Are all ‘Type A’ lateral monitor wells close to A 2x Pepe and 2x Pann random monitors on environmental 6.7.8 boundary monitored for water level and database and shows that the water levels and chemistries chemistry monthly? are obtained as per requirements Bev North MARP 2011, Are all ‘Type B’ lateral monitor wells A 2x Pepe and 2x Pann random monitors on environmental 6.7.8 monitored for water level and chemistry database and shows that the water levels and chemistries quarterly? are obtained as per requirements Bev North MARP 2011 Are all ‘Type C’ overlying monitor wells A 2x Pepe and 2x Pann random monitors on environmental monitored for water level and chemistry database and shows that the water levels and chemistries monthly? are obtained as per requirements Bev North MARP 2011 Are all ‘Type D’ underlying monitor wells A 2x Pepe and 2x Pann random monitors on environmental monitored for water level and chemistry database and shows that the water levels and chemistries monthly? are obtained as per requirements Bev North MARP 2011 Are all ‘Type E’ observation monitor wells A 2x Pepe and 2x Pann random monitors on environmental monitored for water level and chemistry database and shows that the water levels and chemistries fortnightly? are obtained as per requirements MARP Sept 2008, 6.6.6 There is no decrease in native vertebrates A 2011 Fauna survey sighted. No decrease detected. compared to local background.

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.6.6 There is no increase in feral animal A Numbers of cats and foxes across entire region are higher. vertebrates compared to local background. Feral animal control is suggested. MARP Sept 2008, 6.6.6 Are all complaints from neighbours A No complaints from neighbours regarding feral animals regarding feral animal control are investigate have been received. Interviewed K Pelgrim 3/5/11. and are proven not to be from mining activities? MARP Sept 2008, 6.6.8 Terrestrial mammal and reptile trapping A Ecological Associates report 2011 sighted. program utilising a line of pitfall traps with Species abundance and number reported Bev North MARP 2011, nearby Elliot and cage traps. Fauna will be Pitfalls, funnel traps, Elliott and cage traps used at each 6.8.8 identified, sexed, marked and released site. unless otherwise required by trapping permit (e.g. voucher specimens for SA Museum).

Undertaken at all fauna sites annually? A

Total species number and abundance at A each site reported? MARP Sept 2008, 6.6.8 Bird transect – walked traverse logging A Ecological Associates report 2011 sighted. Species and species and abundance. abundance at each trapline was performed for 2x 1 hour assessments for Beverley and Beverley North MLs Undertaken at all fauna sites annually. A

Total species number and abundance at each site reported? A Bev North MARP 2011, 6.7.8 BN: Bird transect – walked traverse logging species and abundance each year. A MARP Sept 2008, 6.6.8 Microchiropteran bat trapping - using harp A BU12 6 nights trap each night of the survey is performed BN04 3 nights annually at site BU12. It appears no bats were caught in the harp nets. Total species number and abundance at Ecological Associates report 2011 sighted. each site reported? A Bev North MARP 2011, 6.8.8 Total species number and abundance at each site reported using harp tap net each A night?

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.6.8 At North Mulga Dam the following is Ecological Associates report 2011 sighted. completed: 1) Anabat – record ultrasonic echolocation A Only the total activity can be recorded using anabat, not calls and send to specialist consultant abundance. Species recorded. for analysis. 2) Microchiropteran bat trapping – mist net A Mist nets were set up for 3 nights. set up on evenings when wind conditions allow 3) Total species number and abundance at A site reported? 4) Is done for 3 nights during survey? A Bev North MARP 2011, 6.8.8 At the dam near CON07 the following is completed: The dam near CON07 was dry and the consultants 1) Anabat – record ultrasonic echolocation A considered that the bat activity would be low there. Instead calls and send to specialist consultant testing at Paralana was performed as a substitute. for analysis. 2) Microchiropteran bat trapping – mist net A set up on evenings when wind conditions allow 3) Total species number and abundance at A site reported?

MARP Sept 2008, 6.6.8 Bird transects are logged monthly for species A Environmental database sighted. No data for November and abundance at : 2011. 1) Process ponds 2) Four Mile GAB wetland bore 3) Wellfield MARP Sept 2008, 6.6.8 At the process ponds, Anabat – record A Completed for 5 nights. ultrasonic echolocation calls and send to Ecological Associates report 2011 sighted. specialist consultant for analysis is Again, only total activity can be reported – not abundance. performed 3 evenings during the survey Species is reported.

Total species number and abundance at A each site reported?

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.6.8 Spotlighting traverse – night drive with A Ecological Associates report 2011 sighted. spotlight randomly around site and local Program located on Table 2 and Figure 5 in report. area roads recording number and species of animals annually. Bev North MARP 2011, 6.8.8 Is spotlighting for lease and local area including wellfield at sites CON04 and A CON05. MARP Sept 2008, 6.7.7, Have the radon decay products and uranium A ARS reports for camp dust sighted, Annual Radiation 6.7.8; ML 6321 Sch2, 3. dust in the: Report sighted for 2011. M Jane interviewed on 1 May 2012. Plant, ponds and accommodation areas are within 1) processing plant, levels for uranium dusts and radon decay products. After 2) ponds and permission was granted from regulators, the radon monitor 3) accommodation camp areas at the PLP was removed October 2011.

remained below the investigation levels? MARP Sept 2008, 6.7.8; Are monitored doses of uranium dust and A Yes, according to M Jane interviewed 1 May 2012. ML 6321 Sch2, 3. radon decay products calculated and are within applicable limits as defined under the RPC Act 1982? MARP Sept 2008, 6.8.8, Has the map showing all identified sensitive A Latest areas developed for processing are Pepegoona and 6.8.6 areas been updated after every clearance Pannikan on Beverley North ML. Maps provide by A Hewitt survey? and T Smith on 1 May 2012 show areas cleared by the Heritage Clearance, and also indicates current Is there documentation of the Aboriginal A infrastructure installed. Heritage Clearances for all operational areas? MARP Sept 2008, 6.8.8, Are flagged areas checked for disturbance A While this is not recorded, the fenced site near the Four 6.8.6; ML 6321 Sch2, 11. six-monthly, and after any relevant incident Mile Creek crossing is regularly (monthly) checked for report? disturbance by Environment Advisors. MARP Sept 2008, 6.10 Does the Beverley Advisory Committee Yes four meetings were held in 2011 – 4 March 2011, 29 meet quarterly in Adelaide, Port Augusta May 2011, 21 September 2011, 13 December 11. Minutes Bev North MARP 2011, and Beverley Site for the dissemination of from meetings sighted via R Otte email on 3 May 2012. 6.14 information and for the Aboriginal community to raise issues? MARP Sept 2008, 6.10 Are Aboriginal Heritage Clearances with A Yes. When applicable, an Aboriginal Liaison Offices signs Bev North MARP 2011, Native Title Claimants completed as part of the ECP for planned disturbances. Eg, #870, #856. 6.14 the ongoing exploration and mine development program?

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Beverley ML 6321, Beverley North ML 6387 - 2011 Mining and Rehabilitation Compliance Report – 31 March 2012 Reference (standard, work instruction or Question A NCR O Comments (include interviewees, observations etc) document) MARP Sept 2008, 6.10 Is there an annual NAIDOC Day celebration A Yes. Photos sighted on server. Bev North MARP 2011, at Beverley where Adnyamathanha and non- 6.14 Adnyamathanha staff can interact with visiting Adnyamathanha people and to discuss any issues relating to the mine? MARP Sept 2008, 6.10 Does the Beverley Environmental A BECC 21 July and 15 November. Sighted S Carter Outlook Bev North MARP 2011, Consultative Committee (BECC) meet 6 calendar 2 May 2012. 6.14 monthly? MARP Sept 2008, 6.10 Does the ISR Radiation Review Committee A Yes. The contents of the Quarterly Environment and Bev North MARP 2011, meet quarterly? Radiation Report and the Quarterly Occupational Radiation 6.14 Report are discussed during the ISR Radiation Review Committee meeting on 10 March, 9 June, 8 September and 8 December. Sighted S Carter calendar 2 May 2012. MARP Sept 2008, 6.10 Are there meetings with the pastoralist from A Bev North MARP 2011, every two months to 6.14 exchange information on mining and pastoral practices in the area Peter Maroney (Wooltana) visited randomly. Not logged. MARP Sept 2008, 6.10 Are there ad-hoc meetings with nearby A Bev North MARP 2011, landholders to exchange information? 6.14 MARP Sept 2008, 6.10 Are there ad-hoc meetings with the broader A Opposition Leader Isobel Redmond and various members Bev North MARP 2011, district? of the Liberal Party SA visited 27 April, Friends of the Earth 6.14 26 May 2011, Outback Consultative Committee 26 November, Paydirt Conference site visit 20 March, PIRSA 5 June, plus Kazakhstan and Kazantomprom delegates Jackson Global and Petratherm. MARP Sept 2008, 6.10 Has Heathgate informed the general public A Outback Consultative Committee meeting 26 November at least annually to keep the wider community informed?

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