Government of Western Australia Office of the Environmental Protection Authority Mulga Rock Uranium Project PUBLIC ENVIRONMENTAL REVIEW ASSESSMENT NO. 1979 SUMMARY OF PUBLIC SUBMISSIONS – 27 June 2016 This document forms a summary of public submissions and advice received regarding the Public Environmental Review (PER) for the Mulga Rock Uranium Project (MRUP) proposed by Vimy Resources Limited. The public review period for the proposal commenced on 14 December 2015 for a period of 12 weeks, ending on 8 March 2016. A total of 1192 submissions were received. The principal issues raised in the submissions and advice received included environmental and social issues as well as issues focussed on questions of fact and technical aspects of the proposal. Although not all of the issues raised in the submissions are environmental, the proponent is asked to address all issues, comments and questions, as they are relevant to the proposal. Page 1 Table of Contents 1. The Proposal – General comments ...................................................................... 3 2. Flora and Vegetation .......................................................................................... 20 3. Terrestrial Fauna ................................................................................................ 42 4. Subterranean Fauna ........................................................................................... 60 5. Hydrological Processes ...................................................................................... 62 6. Inland Waters Environmental Quality ............................................................... 100 7. Air Quality and Atmospheric Gases .................................................................. 137 8. Human Health .................................................................................................. 154 9. Heritage ............................................................................................................182 10. Rehabilitation and Decommissioning ................................................................ 191 11. Offsets .............................................................................................................. 221 12. Consultation ..................................................................................................... 224 13. Other ................................................................................................................ 225 Page 2 1. The Proposal – General comments Submitter Submission and/or issue Response to comment Department Public Health Scoping Tool - Mine Sites and Construction Villages Public health and safety is the highest priority for Vimy. The public health factors of Health listed in the Department of Health (DoH) Scoping Tool include air quality, water Although previously raised during the scoping exercise, it is prudent to (DoH) quality, land and hazard management, radiation safety, workforce health and reiterate the potential public health issues that may arise with such a communities. These have all been addressed in the PER and will continue to be development. The proponent has been provided with a scoping tool that considered in the development of the Mining Proposal, Mine Closure Plan, highlights public health issues that should be addressed and Project Management Plan and Radiation Management Plan. incorporated into the proposal. The proponents can use the scoping tool as a checklist of public health issues. DoH The proponent should consider developing a Disaster Management and Vimy Resources have prepared an Emergency Response Plan (ERP) for the Emergency Response Plan (DMERP) addressing potential disasters site as part of the conditions for undertaking the geotechnical investigative within the plant (e.g. facility fire) and external threats (e.g. bush fire, trenching program. This ERP addresses bush fires, storms, including cyclones, cyclone). vehicle crashes and evacuation of personnel from site. The existing ERP will be further developed (and possibly renamed the Disaster Management and The DMERP should consider specific regional requirements and Emergency Response Plan) as the project evolves and will be submitted to the integrate with appropriate authorities (e.g. local governments) and Department of Mines and Petroleum (DMP) for approval prior to mining to services. ensure all relevant health and safety aspects are covered. Department There has not been a Radiation Management Plan (RMP) presented as Vimy Resources has prepared a Radiation Management Plan (RMP) for the site of the part of this submission. as part of the conditions for undertaking the geotechnical investigative trenching Environment program. This RMP addresses the health and safety issues, and the Information Required – A RMP will need to be included with any license (DoE) management of exposing, handling and utilising radioactive material, such as application. It would be useful if a provisional plan were presented in this the orebody. The existing RMP will be updated as the project develops to include Public Environmental Review (PER). tailings management, processing and transport of this material. The RMP for the larger proposal will be developed in accordance with the Radiological Council of WA and DMP Resources Safety to ensure all relevant health and safety aspects are covered. Page 3 Submitter Submission and/or issue Response to comment DoE General comments on readability of entire document Vimy agrees that the existing PER is large and at times cumbersome. This document attempts to compile over two years’ worth of work that has been The document is made up of 58 files (corresponding to distinct sections undertaken by numerous consultants / authors. Simple formatting of such a or appendices). Many of these have been produced independently by large document (427 pages, excluding Appendices) is technically challenging, several authors. A table of contents is not included. with most word processing programs likely to struggle with such a complex Some cross-referencing is provided, however in some cases this does document, particularly when it comes to cross-referencing. However, this format not correspond to the released version of the document. is set by the EPA and Vimy have adhered to the requirements. Information Required – A more integrated document with accurate referencing and table of contents would make the reviewing process much easier. DoE Executive Summary- - Table E.4 (p ix, x and xvii) In Table E-4 of the Executive Summary there is a statement that relates to potential impacts on Subterranean Fauna which states “Groundwater extraction Internal inconsistency. from the proposed borefield may potentially impact on subterranean fauna Information Required – ‘Subterranean Fauna’ highlights some potential present”. This is not a statement about actual outcomes but effectively impacts on stygofauna in the extraction borefield. However, 'Hydrological represents a review of the risks to Subterranean Fauna. Processes' states 'No flora or fauna of any sort will be impacted', and Later in Table E-4, there is a statement that relates to Hydrological Processes 'Offsets' states 'no subterranean fauna will be threatened as a result of and in particular what the potential impact of the proposed extraction of water water extraction or water reinjection in borefields. - Clarify which is would be upon terrestrial flora and fauna. The term ‘terrestrial’ was not present correct. but should be evident from the context. Terrestrial fauna is different from subterranean fauna. Again in Table E-4, in the section dealing with Offsets the statement is made that “No subterranean fauna will be threatened as a result of water extraction or water reinjection in borefields”. This is a statement about whether water extraction or water reinjection threatens subterranean fauna in a manner that would be relevant to any offset assessment. All three statements are correct in their context. Page 4 Submitter Submission and/or issue Response to comment DoE 5.3 Project Description Overburden Landforms (Resulting non This issue appears to relate to a height differential between the overburden mineralised landforms) (Pg. 43) landforms being constructed and the height of immediately proximate dunes (which were described as local) which are not as high – with the concern being Inadequate coverage: Scale of the landforms created exceeds that of the that excessively high dunes may be subject to wind erosion. However, it is existing landscape incorrect to assume that there are not dunes of the same height or higher within Information Required – The PER (pg. 43) discusses the possible impact the same area, because dunes equal in height to the highest overburden of wind erosion and whether the final design should be altered depending landforms exist about 1.5 kilometres to the south and dunes 10 metres higher upon the results of trials undertaken. The submitter notes that erosion of exist about 5 kilometres further south. the overburden landforms could be exacerbated by the elevation Moreover, Vimy is committed to rehabilitating the overburden landforms and differential resulting from the height of the landforms created in excess once rehabilitated the vegetation would give an element of protection against of the existing landscape (30m high, so 16m above existing dunes). wind erosion. Given that other higher dunes exist in the area, there is no reason to suppose that the overburden landforms, once rehabilitated, would be subject to excessive