Conceptual Mine closure plan final - Amazon S3 › torofiles › ... · 2015-11-13 · Processed Waste – Waste that has been used in pilot plant trials and/or has had some physical

CONCEPTUAL MINE CLOSURE PLAN for Tenements M53/224, L53/184a, L53/175a, L53/150, L53/158,L53/152, L53/167, L53/183a,

M53/1095, M53/336, M53/1090a and M53/1089

Toro Energy Limited

ABN 48 117 127 590

Level 3, 33 Richardson Street, West Perth, WA, 6005.

DOCUMENT REF

REVISION DATE PREPARED BY

CHECKED AUTHORIZED AUTHORIZED FOR USE

MCP‐001 0 27 October 2015

Alan Tandy Lisa Chandler Andrew Worland

Conceptual Mine Closure Plan

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EXECUTIVE SUMMARY

The Wiluna Uranium Project (the Project) is a combination of four uranium deposits located between Wiluna and Lake Maitland in the north eastern goldfields region of Western Australia. The Lake Way deposit is located the closest to the town of Wiluna, approximately 15km to the south. The Lake Maitland deposit is located the furthest away from Wiluna, approximately 105km to the south east. The Centipede and Millipede deposits are located approximately 30km to the south of Wiluna, and it is at this location where the processing facilities and primary mine operations would be located. The Project is wholly owned by Toro Energy Limited (Toro). To date the Centipede and Lake Way deposits have been assessed under the Environmental Protection Act 1986 (WA) and the Environmental Protection and Biodiversity Act 2000 (Cwlth) (EPA Assessment 1819 and EPBC 2009/5174) and Federal and State approvals have been granted. The Lake Maitland and Millipede deposits are currently under assessment (EPA ASSESSMENT NO CMS 14025).

This Mine Closure Plan (MCP) has been prepared specifically to:

Address the closure and rehabilitation requirements of the Wiluna Uranium Project

Comply with the Western Australian Department of Mines and Petroleum (DMP) Guidelines for the Preparation of Mine Closure Plans

The goal of the Project is to undertake mining and then progressively rehabilitate areas mined, returning them to as close to pre‐mining conditions as possible. The proposed mining areas are on land used by Aboriginal People for traditional purposes including law activities, ceremonies, hunting and collection of bush foods. It is also used for pastoral purposes. At the close of mining, Toro proposes to return the land to a state safe and suitable for a continuation of these activities. Toro has consulted Aboriginal People and pastoralists about its Project plans, including for closure and rehabilitation, and will continue to do so.

Significant baseline studies have been undertaken to support the government assessment of the Project. Further data gathered during progressive rehabilitation of the mining areas would be used to assess and refine the rehabilitation process and evaluate its success.

Further feedback from stakeholders will be sought during implementation of the Project and in reviews of this MCP.

A model for mine closure costs (inclusive of progressive rehabilitation costs) has been developed in accordance with government guidelines and will be reviewed periodically in line with those guidelines.


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TABLE OF CONTENTS

EXECUTIVE SUMMARY ............................................................................................................................................ 3 1 INTRODUCTION .......................................................................................................................................... 1‐1

1.1 Purpose ............................................................................................................................................... 1‐1 1.2 Scope .................................................................................................................................................. 1‐1 1.3 Key Project Details .............................................................................................................................. 1‐1 1.4 Project Setting .................................................................................................................................... 1‐2

1.4.1 Lake Way .................................................................................................................................... 1‐2 1.4.2 Lake Maitland ............................................................................................................................ 1‐3

2 PROJECT OVERVIEW ................................................................................................................................... 2‐1 2.1 Mining ................................................................................................................................................. 2‐2 2.2 Processing ........................................................................................................................................... 2‐3 2.3 Waste Rock ......................................................................................................................................... 2‐3 2.4 Water Supply ...................................................................................................................................... 2‐3 2.5 Energy Supply ..................................................................................................................................... 2‐4 2.6 Workforce Accommodation ............................................................................................................... 2‐4 2.7 Transport ............................................................................................................................................ 2‐4 2.8 Decommissioning and Mine Rehabilitation ........................................................................................ 2‐4

3 IDENTIFICATION OF CLOSURE OBJECTIVES AND COMMITMENTS ............................................................. 3‐1 3.1 Statutory Requirements ..................................................................................................................... 3‐1 3.2 Government and Industry Guidelines, Policies and Standards .......................................................... 3‐1 3.3 Toro Corporate Requirements ............................................................................................................ 3‐1

4 COLLECTION AND ANALYSIS OF CLOSURE DATA ........................................................................................ 4‐1 4.1 Leachability of Ore .............................................................................................................................. 4‐3 4.2 Physical and Geochemical Characterisation of Waste Rock Material ................................................ 4‐4 4.3 Mining Waste Generation .................................................................................................................. 4‐4 4.4 Acid and Neutral Rock Drainage ......................................................................................................... 4‐5 4.5 Timing of Land Disturbance .............................................................................................................. 4‐11 4.6 Mine Closure ..................................................................................................................................... 4‐15 4.7 Landform Evolution Modelling ......................................................................................................... 4‐16 4.8 Fate of Contaminant and Transport Modelling ................................................................................ 4‐16 4.9 Tailings Characterisation .................................................................................................................. 4‐18

5 STAKEHOLDER ENGAGEMENT .................................................................................................................... 5‐1 5.1 Overview of Stakeholders ................................................................................................................... 5‐1 5.2 Consultation Process .......................................................................................................................... 5‐2 5.3 Stakeholder Engagement Strategy ..................................................................................................... 5‐4

6 POST‐MINING LAND USE AND CLOSURE OBJECTIVES ................................................................................ 6‐1 6.1 Post‐closure Land Uses ....................................................................................................................... 6‐1 6.2 Closure Goals and Objectives ............................................................................................................. 6‐1

7 IDENTIFICATION AND MANAGEMENT OF CLOSURE ISSUES ....................................................................... 7‐1 8 DEVELOPMENT OF COMPLETION CRITERIA ............................................................................................... 8‐1 9 FINANCIAL PROVISIONS FOR CLOSURE ...................................................................................................... 9‐1 10 CLOSURE IMPLEMENTATION .................................................................................................................... 10‐1

10.1 Key Strategies and Closure Actions .................................................................................................. 10‐1 10.2 Management Accountabilities .......................................................................................................... 10‐1

11 CLOSURE MONITORING AND MAINTENANCE .......................................................................................... 11‐1 12 MANAGEMENT OF INFORMATION AND DATA ......................................................................................... 12‐1 13 REFERENCES ............................................................................................................................................. 13‐1


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TABLE OF FIGURES

Figure 2.1: Schematic of Tailings Storage Facility (cross‐section) ........................................................................ 2‐6 Figure 2.2: Schematic of Tailings Storage Facility (plan view) .............................................................................. 2‐7 Figure 2.3: Schematic showing mining near Uramurdah Creek and temporary diversion .................................. 2‐8 Figure 4.1: Mining waste generation and rehabilitation ...................................................................................... 4‐5 Figure 4.2: Geological cross‐section – Millipede .................................................................................................. 4‐6 Figure 4.3: Geological cross‐section – Lake Maitland .......................................................................................... 4‐7 Figure 4.4: Sonic drill core analysis to compare Total Sulphur (S) and Total Sulphate (SO4) ............................... 4‐8 Figure 4.5: Major and trace element concentrations in waste and low grade ore lithologies ............................ 4‐9 Figure 4.6: Land disturbance timing – Years 1–6 ............................................................................................... 4‐12 Figure 4.7: Land disturbance timing – Years 7–12 ............................................................................................. 4‐13 Figure 4.8: Land disturbance timing – Years 13–16 ........................................................................................... 4‐14 Figure 4.9: Predicted U transport from tailings over a 1000 Year period with a flow velocity of 0.5 m/a ........ 4‐17 Figure 4.10: Predicted U transport from tailings over a 10,000 Year period ..................................................... 4‐17

TABLE OF TABLES

Table 2.1: Toro Energy Wiluna Uranium Project Tenement Holdings ................................................................. 2‐1 Table 4.1: Summary of Key Closure Data ............................................................................................................. 4‐1 Table 4.2: Results of ore leachability tests ........................................................................................................... 4‐3 Table 4.3: Final materials and waste management – Lake Maitland ................................................................. 4‐16 Table 5.1: Key Stakeholders ................................................................................................................................. 5‐1 Table 5.2: Stakeholder Engagement Register ...................................................................................................... 5‐2 Table 7.1 Environmental Risk Assessment for Tailings and Mine Closure ........................................................... 7‐2 Table 8.1: Provisional Completion Criterial and Indicators .................................................................................. 8‐2 Table 10.1: Mine Closure and Rehabilitation Accountabilities .......................................................................... 10‐2 Table 11.1: Preliminary Monitoring Schedule (Mine Rehabilitation)................................................................. 11‐1

TABLE OF APPENDICES

Appendix A: Legal Obligations Register Appendix B: Closure Task Register


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Definitions

Actions – Defined activities aimed at achieving a given objective. May be outcome‐based (prevent groundwater pollution by hydrocarbons) or process‐based (implement Surface Water Management Plan). A given action may support more than one objective.

Care and Maintenance – Period following temporary cessation of operations when infrastructure remains largely intact and the site continues to be managed.

Closure – The point at which operations cease and plant and infrastructure are removed. It includes decommissioning, rehabilitation and monitoring and typically culminates in tenement relinquishment.

Closure Planning – A process that extends over the mine life cycle and continues until final tenement relinquishment.

Completion Criteria – Qualitative or quantitative standards of performance used to measure the success or otherwise of rehabilitation actions required for closure of a site.

Controlled Area – An area to which access is subject to control and in which employees are required to follow specific procedures aimed at controlling exposure to radiation.

Criterion – A measure or standard by which attainment of objectives may be assessed. A criterion may be used to assess conformance with specified actions or to evaluate the effectiveness of those actions in achieving objectives (or both).

Decommissioning – The process that begins near or at the cessation of mineral production and ends with the removal of all unwanted infrastructure and services.

Disturbance – Any process resulting in substantial damage to the biotic and abiotic properties of ecosystems. Disturbance results in reduction in biodiversity and/or alteration to soils, landforms and hydrology.

Domain– A group of landform(s) or infrastructure that have similar rehabilitation and closure requirements and objectives.

Ecosystem Processes – Interconnected processes that sustain the biodiversity of ecosystems, and drive the self‐directed development of that ecosystem. Such processes involve all components of ecosystems, biotic and abiotic and include nutrient cycling/conservation, maintenance of appropriate hydrological regimes, soil quality, etc.

Ecosystem Services – Particular dynamic aspects of ecosystems that provide requirements for biotic and abiotic components. In a narrow sense, ecosystem services are defined ‘as goods and services that are provided by or are attributes of ecosystems which benefit humans’ (Eamus et al., 2005).

Environment – Means living things, their physical, biological and social surroundings, and interactions between all of these. The social component of the environment includes the aesthetic, cultural, economic and social aspects that may directly affect or be affected by changes to the physical or biological environment.

Goal – an overall outcome towards which rehabilitation and closure effort is directed.

Indicator – An attribute which can be measured or described and used to evaluate if a criterion has been met (performance indicator, trend indicator) or whether agreed actions are being implemented (milestone indicators).

Keystone Species – Species with a major role supporting other species by providing food, shelter or habitat.


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Local Provenance – Material used to propagate plants (most often seed) collected from a narrowly defined geographic area, which closely matches the plant community types and physical environment where it is to be used (see provenance).

Measure – A qualitative or quantitative aspect of an indicator; a variable which can be measured (quantified) or described. Used for tracking completion of actions, assessing performance or showing trends.

Objective – A specific outcome which, if achieved, will contribute to the attainment of one or more closure goals. An objective can serve as the basis or focal point for a regime of closure activities.

Processed Waste – Waste that has been used in pilot plant trials and/or has had some physical treatment to liberate uranium

Non‐processed Waste – drill core, rock chips and other mineralised material that has not be subject to any testing that alters the physical characteristics of the material.

Reference Ecosystem – Ecosystem or landscape units used to provide a model for planning a restoration project. Measurements from reference systems (fixed reference points or plots where biodiversity is measured) are normally used to set appropriate levels for rehabilitation projects.

Rehabilitation – In restoration ecology rehabilitation (reclamation) is normally defined as a process where disturbed land is returned to a stable, productive and self‐sustaining condition, taking future land use into account. This process differs from the narrower definition of restoration by not aspiring to fully replace all of the original components of an ecosystem.

Relinquishment – Formal approval by the relevant regulating authority indicating that the completion criteria for the mine have been met to the satisfaction of the authority.

Remediation – To clean up or manage the effects of contamination of soil or water.

Restoration – Ecological restoration is distinguished from rehabilitation as the process of fully repairing the composition, structure, function and dynamics of pre‐existing indigenous ecosystems.

Revegetation – Return vegetation (indigenous or otherwise) to an area.

Stakeholder – A person, group or organisation with the potential to affect or be affected by the process or outcome of mine closure.

Standard – A rule established by authority. Environmental standards may take the form of prescribed numerical values set through approvals, legislation, policy or codes of practice. Assessments against standards are used to assess regulatory compliance.

Supervised area – an area in which working conditions are kept under review but in which special procedures to control exposure to radiation are not normally necessary.


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Q No

Mine Closure Plan (MCP) checklist

Y/N NA

Reference Comments Changes from Previous Version (Y/N)

Summary

1 Has the Checklist been endorsed by a senior representative within the tenement holder/operating company? (See bottom of Checklist.)

Y N/A

2 Are you aware that from 2015 all MCPs will be made publicly available?

Y N/A

3 Is there any information in this MCP that should not be publicly available?

N N/A

4 If ‘Yes’ to Q3, has confidential information been submitted in a separate document/section?

N/A N/A

5 Does the MCP cover page include;

Project Title Company Name

Contact Details (including telephone numbers and email addresses)

Document ID and version number

Date of submission (needs to match the date of this checklist)

Y See also quality tracking information inside cover page

N/A

6 State why the MCP is submitted (as part of a Mining Proposal or a reviewed MCP or to fulfil other legal requirements)

Provided as part of documentation submitted to EPA for assessment under Part IV of EP Act (EPA assessment number 2002 (CMS14025))

N/A


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Q No


Y/N NA


Summary

7 Does the project summary include;

Land ownership details (include any land management agency responsible for the land/reserve and the purpose for which the land/reserve (including surrounding land) is being managed)

Location of the project; Comprehensive site plan(s);

Background information on the history and status of the project.

Y Section 2

Table 2.1

Site plans are provided in the PER, to which this closure plan is appended

N/A

8 Does the MCP include a consolidated summary or register of closure obligations and commitments?

Y Refer Appendix A – Obligations Register

N/A

9 Have all stakeholders involved in closure been identified?

Y Section 5 N/A

10 Does the MCP include a summary or register of historic stakeholder engagement been provided, with details on who has been consulted and the outcomes?

N N/A

11 Does the MCP include a stakeholder consultation strategy to be implemented in the future?

Y Section 5.3 N/A

12 Does the MCP include agreed post‐mining land use(s), closure objectives and conceptual landform design diagram?

Y Section 6.1 N/A


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Q No


Y/N NA


Summary

13 Does the MCP identify all potential (or pre‐existing) environmental legacies, which may restrict the post mining land use (including contaminated sites)?

N/A N/A

14 Does the MCP include an appropriate set of specific completion criteria and/closure performance indicators?

Y Section 8

Table 8.1

N/A

15 Does the MCP include baseline data (including pre‐mining studies and environmental data)?

Y Section 1.4

See also PER, to which this plan is appended

N/A

16 Has materials characterisation been carried out consistent with applicable standards and guidelines (e.g. GARD Guide)?

N/A N/A

17 Does the MCP identify applicable closure learnings from benchmarking against other comparable mine sites?

N/A N/A

18 Does the MCP include a gap analysis/risk assessment to determine if further information is required in relation to closure of each domain or feature?

Y Table 7.1,

Appendix C

N/A

19 Does the MCP identify all key issues impacting mine closure objectives and outcomes including potential contamination impacts?

Y Section 7 N/A


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Q No


Y/N NA


Summary

20 Does the MCP include information relevant to mine closure for each domain or feature?

NA Domain by domain closure information will be generated during operational life of project.

N/A

21 Does the MCP identify any potential environmental legacies, which may restrict the post mining land use (including contaminated sites)?

N/A N/A

22 Does the MCP include proposed management or mitigation options to deal with these issues?

NA No legacy issues; risk based assessment of closure issues provided in Section 7

N/A

23 Does the MCP include the process, methodology, and rationale been provided to justify identification and management of the issues?

NA N/A

24 Does the MCP include a summary of closure implementation strategies and activities for the proposed operations or for the whole site?

Y Section 10 N/A

25 Does the MCP include a closure work program for each domain or feature?

Y Appendix C N/A

26 Does the MCP contain site layout plans to clearly show each type of disturbance as defined in Schedule 1 of the MRF Regulations?

N To be included in updated MCP provided with mining proposal

N/A


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Q No


Y/N NA


Summary

27 Does the MCP contain a schedule of research and trial activities?

N/A N/A

28 Does the MCP contain a schedule of progressive rehabilitation activities?

Y Appendix C N/A

29 Does the MCP include details of how unexpected closure and care and maintenance) will be handled?

N/A N/A

30 Does the MCP contain a schedule of decommissioning activities?

N/A Refer description in Section 2.1.8

N/A

31 Does the MCP contain a schedule of closure performance monitoring and maintenance activities?

Y Table 4.1 identifies closure‐related monitoring activities

N/A

32 Does the MCP contain a framework, including methodology, quality control and remedial strategy for closure performance monitoring including post‐closure monitoring and maintenance?

Y Section 11 N/A

33 Does the MCP include costing methodology, assumptions and financial provision to resource closure implementation and monitoring?

Y Section 9 N/A

34 Does the MCP include a process for regular review of the financial provision?

Y Section 9 N/A

35 Does the MCP contain a description of management strategies including systems, and processes for the retention of mine records?

Y Section 12 N/A


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Corporate Endorsement:

I hereby certify that to the best of my knowledge, the information within this Mine Closure Plan and checklist is true and correct and addresses all the requirements of the Guidelines for the Preparation of a Mine Closure Plan approved by the Director General of Mines.

Name: Andrew Worland Signed:

Position: General Manager Date: 27 October 2015

(NB: The corporate endorsement must be given by a senior representative from the tenement holder/operating company, for example the Registered Mine Manager or higher).


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1 INTRODUCTION

The Wiluna Uranium Project (the Project) comprises a proposed open pit uranium mine, processing plant and associated infrastructure approximately 960km north‐east of Perth, near the town of Wiluna, in Western Australia.

1.1 Purpose

This Conceptual Mine Closure and Rehabilitation Plan (Plan) has been prepared to guide Toro Energy Limited (Toro) in aspects of the Project which may affect the attainment of mine rehabilitation and closure outcomes. The Plan identifies strategies to reduce impacts to the post‐mining environment through the application of appropriate and effective planning, design and risk management. This plan is preliminary in nature and, accordingly, does not provide detailed prescriptions of how the rehabilitation and closure outcomes would be achieved.

This Plan is being submitted to the Office of the Environmental Protection Authority (OEPA) and to the Department of Mines and Petroleum (DMP) as part of the pre‐mining assessment process for the proposed Extension to the Wiluna Uranium Project (EPA Assessment No: 2002 (CMS14025)).

The aims of the document are to:

Describe Toro’s vision for the post‐mining environment in the Project area, including a set of closure and rehabilitation objectives;

Stimulate discussion amongst stakeholders who may wish to contribute to Toro’s closure and rehabilitation planning;

Identify key environmental and social risks associated with planned or unplanned closure of the Project;

Describe how key closure risks will be avoided or managed;

Identify measures by which Toro proposes to track its progress towards its closure and rehabilitation targets;

Propose a schedule for the further development of mine rehabilitation and closure planning beyond this initial phase; and

Satisfy government requirements for formally documenting Toro’s mine closure framework in a manner consistent with EPA/DMP guidelines (EPA/DMP, 2015).

1.2 Scope

This Plan applies to the activities of Toro and its contractors throughout the life of the Wiluna Uranium Project (including the post‐mining phase). The closure and rehabilitation objectives and strategies described in the Plan address both planned and unplanned closure events, including temporary closure (‘care and maintenance’), other than planned maintenance shut down events.

1.3 Key Project Details

Toro (ABN 48 117 127 590) is an Australian uranium explorer and project developer. The key contact for this proposal is:

Mr Andrew Worland, General Manager – Wiluna Project Phone: +61 8 9214 2100 Fax: + 61 8 9226 2958 Email: [email protected]


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1.4 Project Setting

1.4.1 Lake Way

The land in the area where mining of the Millipede, Centipede and Lake Way deposits would occur is characterised by gently sloping sand plains, dunes and alluvial flats. Lake Way is the most significant geomorphic feature in the locality. Most of the Lake Way playa is extremely flat‐lying, with elevations varying between 490 and 491 mRL. There are a number of gypsiferous dunes, which appear as small islands within the playa. The islands are generally elliptical in plan, and predominantly oriented along a north‐easterly to south‐westerly axis. The dimensions of the islands typically do not exceed 3 km long x 1 km wide. The maximum elevation of the island landforms above the surrounding surface of the playa generally does not exceed about 8m and slopes are in the order of 0.005 to 0.01 m/m.

There are no permanent watercourses in the Project area. Intermittent surface water flows occur after heavy falls normally associated with cyclonic rains, which typically occur between January and March.

In the proposed mining areas groundwater occurs at shallow depth – typically at a depth of about 2 m below ground level. The quality of water in shallow, unconfined alluvial and calcrete aquifers is variable, ranging from brackish (TDS ~3000 mg/L) to hypersaline (TDS >100,000 mg/L). The salinity of the groundwater in the Project area generally increases down gradient (that is, salinity increases the closer one gets to Lake Way). Groundwater salinities also tend to increase with depth. No large‐scale abstraction takes place in close proximity to the Project area, although there are pastoral, municipal and industrial groundwater users in the wider region.

The Project area is located over three land systems, of which the Carnegie and the Cunya land systems are the most common. The Carnegie land system represents the Lake Way salt lake and fringing saline alluvial plains and surrounding sand dunes. The Cunya land system represents the calcrete earths and platforms adjacent to Lake Way, which support halophytic shrublands and open Mulga woodlands further from the lake’s edge. The Violet land system represents the plains and low rises adjacent to Lake Way, located in the areas to the west of the Millipede/Centipede deposit, in the general locality of the proposed processing plant site.

Soil textures in the Project area range from clayey sand to clay. However, the majority of soils are clayey sands, sandy loams or sandy clay loams. Soils underlain by calcrete at shallow depth typically contain a high proportion of gravel‐sized (or coarser) rock fragments. Most soils tested during baseline characterisation were non‐dispersive, although some showed a tendency to hard‐setting or formation of crusts.

The soils in the Project area show a wide range of permeabilities, with estimated values of saturated hydraulic conductivity spanning three orders of magnitude (from about 3 mm/h to over 300 mm/h). The range of plant‐available water (per cent volume) values measured in soils from the Project area is considered to be low to moderate (in the range of 15 per cent to about 25 per cent), which is typical of the soils of the region.

Soil pH values were predominantly alkaline, but ranged between pH 5.4 (acidic) to 9.4 (strongly alkaline). Soil salinity ranged from non‐saline to extremely saline. Soil salinity tended to increase with depth. The majority of the soils assessed within the area of the Millipede/Centipede deposit were classified as non‐sodic. The majority of soils sampled were very low in organic carbon and had low to moderate levels of plant‐available nutrients. Soil concentrations of trace metals were typically low, although background vanadium concentrations are high (exceeding DER ‘environmental investigation levels’) in some parts of the Project area. The baseline soil investigations did not identify any ‘legacy’ sites within the Project footprint that are likely to constrain the post‐mining use of land in the Project area. However, increases in sediment arsenic levels were noted in a mine dewatering discharge area


Page 1‐3

associated with past mining operations (by others) at a location to the north of the proposed Project area.

Vegetation is dominated by mulga woodlands, hummock grasslands, salt bush and samphire shrublands. Minor areas of potentially groundwater dependent vegetation have been identified along drainage lines. Some of the lake fringe vegetation (Tecticornia species) has also been provisionally classified as groundwater dependent.

The vegetation provides fauna habitat for a range of terrestrial vertebrates. Surveys in the Project area have identified 31 mammal species of which 20 are native, 105 bird species, 75 reptiles, and five amphibians. No threatened or priority vertebrate fauna species have been observed in the Millipede/Centipede/Lake Way mining areas. Local calcretes are an important habitat for stygofauna and troglofauna.

1.4.2 Lake Maitland

The Lake Maitland deposit is located in the eastern goldfields region of Western Australia approximately 95 km to the north west of the town of Leinster. It is situated within the Murchison bioregion of Australia and sits specifically within the Eastern Murchison. The Project area at Lake Maitland has an arid climate, with an average annual rainfall of 225 millimetres (mm). The mean monthly temperature range is 37.9°C (Jan) to 19.3°C (Jul).

Lake Maitland is located within an ephemeral drainage system. Regionally, the surface topographies range from 465m AHD in the southernmost part of the palaeovalley, to 590m AHD between Mt Keith and Mt Phillipson.

The Project is situated across six land systems: Ararak, Bullimore, Darlot: Desdemona; Melaleuca and Mileura. The Bullimore and Darlot Land systems are the most widespread across the Project area. Vegetation of the Project area is dominated by Mulga Woodlands that are frequently rich in ephemerals, hummock grasslands, saltbush shrublands and Tecticornia shrublands.

This vegetation provides fauna habitat for a wide range of terrestrial vertebrates. Surveys conducted across the area have identified 18 species of mammal, 94 bird and 53 reptile species. The studies found that the Project area could potentially host 14 species of conservation significance. However field studies found only three vertebrate species of conservation significance: the brush tailed mulgara, the rainbow bee‐eater and the Australian bustard. The Barwidgee calcrete, which lies in close proximity to the deposit, is a listed priority ecological community and hosts a range of stygofauna species.

The dominant land use within the Project area is unimproved pasture grazing, accounting for 85.5% of the land use. Other significant land uses include crown reserves, unallocated crown land and gold and nickel mining (Cowan, 2001). The Lake Maitland deposit is located 55 km to the east of the Wanjarri Reserve. This reserve is a destocked pastoral lease, which is now classified as an A class reserve. The reserve covers an area of some 53,000 ha (CALM, 1996). Proposed mining at Lake Maitland would have no direct or indirect impact on the reserve.


Page 2‐1

2 PROJECT OVERVIEW

The Project is located across four uranium deposits which are contained within mining leases M53/224, M53/1090a, M53/336, M53/1095, M53/1089 and M53/1092a (Table 2.1). All the mining leases, with the exception of M53/1089 are located on the Lake Way Pastoral Lease. M53/1089 is located on the Barwidgee Pastoral Lease. Toro is the holder of both of these leases.

In 2013 the Wiluna People were granted Native Title over an area that includes M53/224, M53/1092a, M53/1090 and M53/336. There is currently no native title claim over the area in which M53/1089 is located. Toro has engaged with the Barwidgee People who assert an interest in the land about assisting with their native title application.

Table 2.1: Toro Energy Wiluna Uranium Project Tenement Holdings

Tenement Status

M53/1090A Application

M53/1095 Granted

M53/224 Granted

M53/336 Granted

M53/1089 Granted

L53/184a Application



L53/150 Granted

L53/158 Granted

L53/152 Granted

L53/167 Granted

At all four deposits the ore is shallow and occurs between 1–10 m below ground level. For this reason Toro would use surface miners and conventional excavators to mine the deposits. Processing would be carried out using a conventional agitated leach method. The process would include a grinding mill, mechanically agitated leach tanks and solution thickeners and would produce up to 1200 tonnes per annum of uranium oxide concentrate (UOC) over a mine life of up to 20 years. Tailings produced as part of processing would be stored in pit voids at Millipede and Centipede. No tailings would be returned to either the Lake Way or Lake Maitland deposits.

In mine development, land disturbance would be staged and both clearing and rehabilitation will occur progressively over the life of the mine. At Millipede and Centipede, once the tailings had consolidated, the pits would be rehabilitated and revegetated.

The principal activities planned for the Project are:

Development and operation of an open pit uranium mine encompassing the Centipede, Millipede, Lake Way and Lake Maitland deposits.

Construction and operation of a uranium ore processing facility adjacent to the Centipede/Millipede deposits.


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The redevelopment of the existing West Creek borefield and the installation of the Lake Maitland borefield to supply fresh to brackish water to the Project.

Establishment and use of support facilities including an accommodation village, mine administration buildings and workshops, haul roads, power generation and transmission facilities, water supply pipeline, communications systems and water and waste management;

Transport of uranium product within Australia for export; and

Rehabilitation and closure of the mine and other areas disturbed by the Project.

In order to plan and monitor its environmental management and rehabilitation activities Toro has designated nine management domains that broadly align with the key Project activities. Each domain is described below;

Lake Way pit void and stockpiles (overburden and topsoil);

Centipede/Millipede pit void, in pit tailings storage area and stockpiles;

Lake Maitland pit void and stockpiles;

Access roads, haul roads, laydown areas (not including ROM pad or any mineralised stockpiles);

‘Controlled’ areas of plant, including PLS evaporation pond, ROM and mineralised material stockpiles;

‘Supervised’ areas of plant;

Accommodation villages at Centipede and Lake Maitland;

Borefields and water distribution pipelines; and

Evaporation ponds not in the mine path.

2.1 Mining

The mineralisation across the four deposits is typically shallow, occurring between 1 m to 15 m below natural ground surface. The shallow nature of the deposits means they are amenable to surface mining and would require no drill or blast. Surface miners and tracked vehicles with cutting drums would be used to break up thin layers of material which would then be picked up and trucked to the processing plant. Because much of the uranium resource occurs at or below the water table in all deposits, dewatering of the open pits would be required. Water barriers would be installed to minimise the amount of water that would have to be pumped from the pits. Water from pit dewatering would be used in ore processing or in other mining applications, such as dust control. At Lake Maitland excess water would be reinjected back into a reinjection borefield located downstream of the mining area. Ore would be transported in trucks via dedicated haulage roads to the processing plant close to the Millipede/Centipede deposits.

The waste rock arising from mining is non‐acid forming. Waste material above the ore zones (overburden) would be mined either by scrapers, surface miners or excavators. The Project intends to produce up to 1200 tonnes of uranium ore concentrate (UOC) per annum, and depending on local ore grades the amount of material moved in a given year would reflect this. Mining would commence at Centipede and Millipede before moving to Lake Maitland and then finish at Lake Way.

Storage areas for topsoil and waste rock would be cleared adjacent to the mining areas. Non‐mineralised overburden and waste rock would be stockpiled next to the pit until there was sufficient mined out void to allow direct backfill. Stockpiled waste would be separated into several categories to allow for selective placement during rehabilitation earthworks. Detailed engineering studies to be completed prior to the implementation of the Project will identify a final mining sequence and schedule for the Project, which will be included in the next revision of this MCP.


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2.2 Processing

At the processing plant a Semi‐Autogenous Grinding mill (SAG) would reduce the ore particles to a P80 of about 400 µm (i.e. 80 per cent of the feedstock is of a particle size smaller than 400 µm). Following grinding, a hydrocyclone would be used to sort the ore, prior to it being fed into the leach thickener.

Leaching of the thickened slurry would be performed at normal atmospheric pressure or at a low pressure in a series of mechanically agitated leach tanks. Steam would be injected into the insulated tanks to heat and maintain the slurry at the required operating temperatures, which may range from 90 to 120 degrees Celsius. Leaching would be undertaken in alkaline conditions by the addition of sodium carbonate. The leached slurry would then report to the counter current decantation (CCD) thickeners for recovery of leach solution. Underflow from the final stage of the CCD would be pumped to the Tailings Storage Facility (TSF) at either Millipede or Centipede.

The CCD overflow or filtrate, pregnant leach solution (PLS), containing the recovered uranium in solution, would be pumped to the plant via a lined evaporation pond. PLS would be recovered from the evaporation pond and pumped to a Pin Bed Clarifier. The clarified solution would be heated to approximately 85oC and uranium would be recovered as uranium oxide via a process that would begin with the precipitation of sodium diuranate (SDU) using sodium hydroxide.

The SDU precipitate would be re‐dissolved using sulphuric acid. Any remaining vanadium in the solution would be removed by adjusting the solution pH to precipitate the aqueous vanadium and then separate the vanadium from the uranium rich solution by filtration. Uranium would be precipitated from the solution by the addition first of hydrogen peroxide and then sodium hydroxide to precipitate uranyl peroxide. The barren solution would be returned to the leach circuit.

The product slurry would be dewatered, centrifuged, dried and cooled before packaging in 205 L plastic lined, steel drums. The drums would be weighed, labelled, loaded onto pallets, wrapped and placed into a shipping container for despatch from site by road transport. The details of each drum would be documented in accordance with regulatory requirements prior to despatch.

2.3 Waste Rock

Waste rock material would be generated across the four deposits. The hierarchy for disposal of this material would be to first return it to the area from which it came, or if there was insufficient pit void available, return it to another pit void. Across the four deposits, Toro has undertaken waste rock characterisation and has concluded that the geology across the deposits is similar enough that the movement of waste rock between deposits poses no long term post closure issues (Outback Ecology 2008a and 2011d).

2.4 Water Supply

The total water demand or the project is estimated at up to 2.5 GLpa. Toro proposes to secure the low salinity (brackish) component of the makeup water demand (in the order of 1 GLpa) from a newly established borefield at Lake Maitland, connected to the processing plant at Centipede/Millipede via a pipeline. Studies undertaken by Toro at the site of the proposed borefield have confirmed that the borefield is capable of supplying up to 1.3 GLpa for a 20 year period. A secondary source of brackish water is available at the currently unused West Creek Borefield, which would be refurbished at Project implementation. This borefield was included in the assessment of mining at Centipede and Lake Way (EPA Assessment 1819) and was found to be capable of supplying up to 0.7 GLpa for a period of seven years. Higher salinity water requirements would be met by recycling water from the tailings storage facility and by using hypersaline water from mine dewatering operations.


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2.5 Energy Supply

The Dampier to Kalgoorlie Goldfields Gas Transmission (GGT) pipeline runs a short distance to the east of Lake Way and within 28 km of the proposed plant location. The GGT has sufficient capacity and existing gas suppliers have sufficient quantities of gas to meet the energy demands of the Project. Toro is currently conducting investigations into options for supply of gas to its plant. The current preferred option is to truck gas from a compression station south‐east of Wiluna to the plant, although pipeline options have also been evaluated. The trucking option would involve approximately four truck movements per day. Backup diesel power generation would be maintained to cater for emergency power generation and to ensure security of production in the event that gas supply was interrupted.

2.6 Workforce Accommodation

Approximately 200 employees would be required during the operational phase of the Project. It is anticipated that management and professional roles would be staffed by Toro personnel and mining will be carried out by a contractor. Employees and contractors would be accommodated at one of two camps. One camp would be located approximately 5 km to the south of the processing plant to accommodate the bulk of the workforce, while a second camp would be established for the much smaller number of employees working at Lake Maitland.

2.7 Transport

During the construction phase, some pre‐assembled modules would be partly or fully constructed off‐site and transported to site for final assembly. Movement of these items would likely occur along the transport route between Perth and Wiluna, via Kalgoorlie.

Processing reagents and other materials required for the operational phase are also likely to be transported along this route.

Toro proposes to transport finished product by road to Adelaide for shipment from Port Adelaide or transfer to rail for movement to the Port of Darwin. The trucks would travel the Goldfields Highway to Kalgoorlie before moving east on the Eyre and Princess highways. Some product may be railed from Adelaide to the Port of Darwin depending on the availability of shipping.

2.8 Decommissioning and Mine Rehabilitation

The Project is expected to have an operating life of up to 20 years (not including the construction and post‐closure phases). At the end of its useful life, the processing plant would be decommissioned, dismantled and either buried in mined out voids or removed. Mined areas would be recontoured and rehabilitated. Rehabilitation works would include demonstrating that areas disturbed by mining met agreed safety and environmental quality standards.

In the lead up to closure, reuse and recycling opportunities for fixed and mobile plant and infrastructure would be considered. This could include removal of selected equipment for use by a third party, or leaving some equipment or infrastructure (for example, water supply bores, power transmission infrastructure or access roads) in situ for alternative uses such as for pastoral or community purposes. Where no feasible or practicable alternatives were identified, the Project components would be decommissioned.

Typically, decommissioning activities could include –

Decommissioning mining and processing facilities;

Decommissioning water and power supply infrastructure; and

Removal of accommodation and site office infrastructure.


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All waste would either be returned to mine voids or be used to cover completed in‐pit tailings storage facilities. At closure the surface topography would be similar to the pre‐mining landscape. All mineralised wastes, including tailings, would ultimately be deposited below the natural grade of the land. Experience with backfilling waste rock in approved resource test pits indicates that there is minimal increase in the volume of mined material following excavation. This is likely due to the reduction in void space that occurs during mechanical handling of the vuggy calcrete that hosts the ore.

At Centipede and Millipede the mined out pit would be used for tailings storage. Mining operations would start up to a year ahead of processing to allow for construction of tailings storage cells within the pit (Figure 2.1 and Figure 2.2). Internal walls also would be constructed to allow for better water and settling management. These walls would be constructed in compacted layers from waste material. Tailings would be deposited into the cells from multiple points around the perimeter. Excess water would either be returned to the process plant or evaporated. Once the tailings had dried sufficiently to operate machinery on them safely, they would be capped with waste rock material and rehabilitated to a form similar to the surrounding landforms.

Small portions of the ore body encroach into the southern branch of Abercromby Creek. When possible, sections of ore underlying the creek bed would be mined out in the dry season and backfilled immediately to re‐establish the original profile of the creek bed. Flood protection bunds would be established to prevent water ingress into the pit and to eliminate the potential for entrainment of backfilled materials or water from the pit void, should a flood occur during active mining or backfilling. The bund that would form the external walls of the tailings cell would be constructed along the perimeter of the creek to protect the mining and tailings operations from potential flooding and to preserve the capacity of the creek to handle a large rainfall event. The wall would be reinforced with rock armour to protect it from erosion.

Once the tailings cell had been filled and capped with non‐mineralised waste, the shoreline of the creek would be rehabilitated to a form similar to the original creek bed so that there would be no lasting impact on the upstream environment.

At the Lake Way and Lake Maitland operations areas, waste rock would be placed back into the pit voids at similar elevations and slopes to the original topography. Backfilling would commence and continue through to the end of mining, minimising the rehandling of waste and the time that the mining area was open. No tailings would be placed in the Lake Way or Lake Maitland pit voids. Non ore grade waste rock from Centipede and Millipede may be backfilled into the Lake Way or Lake Maitland pits. As no tailings are deposited back into the Lake Way or Lake Maitland pit voids, the waste materials are required to reinstate natural ground levels.

As a portion of the Lake Way orebody is on the Uramurdah Creek floodplain, provision would be made to prevent flooding of the mine workings if a significant rainfall event should occur. As mining approached the creek, bunding would be constructed along the banks to prevent any inrush of water into the mining area. Following the completion of mining and backfilling adjacent to the creek, a temporary creek diversion, with bunding, would be established over the backfill to allow mining of the rest of the orebody. At completion of mining, the pit would be backfilled and the creek diversion works would be removed, restoring the original drainage path.


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Figure 2.1: Schematic of Tailings Storage Facility (cross‐section)


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Figure 2.2: Schematic of Tailings Storage Facility (plan view)

Surface disturbances would be rehabilitated and no stockpiles or elevated landforms would remain. Figure 2.3 illustrates how the expected land forms would be contoured and shows that similar profiles and slope angles to the original profiles would be created.


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Figure 2.3: Schematic showing mining near Uramurdah Creek and temporary diversion


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3 IDENTIFICATION OF CLOSURE OBJECTIVES AND COMMITMENTS

3.1 Statutory Requirements

Closure and rehabilitation of the Wiluna Uranium Project would, as a minimum, satisfy general requirements set out in the following legislation:

Environmental Protection Act 1986;

Contaminated Sites Act 2003;

Mining Act 1978;

Mines Safety and Inspection Act 1994;

Mining Rehabilitation Fund Act 2012;

Dangerous Goods Safety Act 2004; and

Radiation Safety Act 1975.

In addition Toro has specific closure and rehabilitation obligations arising out of approvals issued under State and Commonwealth Legislation. The closure obligations are listed in the Legal Obligations Register (Appendix A).

3.2 Government and Industry Guidelines, Policies and Standards

The methods by which closure and rehabilitation outcomes may be achieved and the standards by which closure planning, design and implementation will be assessed are described in a range of guidelines and related publications including:

Mine Closure Guideline for Mineral Operations in Western Australia (CME 2000)

Strategic Framework for Mine Closure (Australian and New Zealand Minerals and Energy Council and Minerals Council of Australia 2000)

Mine Closure and Completion, Leading Practice Sustainable Development Program for the Mining Industry (Department of Industry Tourism and Resources, 2006a)

Mine Rehabilitation, Leading Practice Sustainable Development Program for the Mining Industry (Department of Industry Tourism and Resources, 2006b)

Guidance Statement No 6 – Rehabilitation of Terrestrial Ecosystems (EPA, 2006)

Planning for Integrated Mine Closure: Toolkit (International Council on Mining & Metals, 2008).

Guideline 18: Rehabilitation requirements for mining projects (Queensland Department of Environment and Resource Management, 2008)

Environmental Assessment Guideline No 4 ‐Towards Outcome Based Conditions (EPA, 2009)

Guidelines for Preparing Mine Closure Plans (EPA/DMP, 2015)

This Plan has been prepared in accordance with the draft Guidelines for Preparing Mine Closure Plans (DMP, 2015) and also reflects the approaches recommended in the other guidelines listed above.

3.3 Toro Corporate Requirements

Toro is committed to good governance principles, including the recognition and management of risk (Toro corporate governance statement: http://www.toroenergy.com.au/governance.html, 2013). The company has established the following policies, which are relevant to the planning and implementation of mine closure:

Health & Safety Policy;

Environment Policy;

Community Policy; and

Indigenous Relations Policy.


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This MCP is one of a suite of inter‐related plans and procedures that together support Toro’s Health, Safety and Environment Management System. The following documents may also contain information relevant to mine closure design, planning and implementation:

Radioactive Waste Management Strategy;

Tailings Operating Manual;

Water Management Strategy;

Vegetation Clearing and Soil Management Strategy;

Waste Management Strategy;

Erosion Monitoring Procedure;

Soil and Overburden Classification Procedure; and

Closure Provisioning Calculation Method.

Toro has established an obligations register to enable it to monitor its compliance with all legal obligations and commitments arising from the Wiluna Project. At the time of preparing this conceptual closure plan, Toro’s legal obligations and commitments relating to mine closure and rehabilitation were chiefly those arising from:

Programmes of Works submitted for exploration activities at tenements L53/150, E53/1132, E53/1287, E52/1288, M53/113, M53/121, M53/124, M53/1089, L53/152 P53/1355, P53/1356, P53/1357, P53/1370, and P53/1396;

Mining proposal (Reg ID 21674) and addenda (Reg ID 24204, Reg ID 28041) approved in relation to pre‐mining works carried out at Tenement M53/224;

Tenement conditions for tenements on which exploration activities (Programmes of Works) have been approved; and

DEC (now DER) works approval and draft licence conditions for a dewatering trial carried out in June 2011.

The legal obligations register (Appendix A) would be reviewed and updated by Toro on an annual basis.


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4 COLLECTION AND ANALYSIS OF CLOSURE DATA

The key physical and biological information required for mine closure implementation and to evaluate Toro’s success in attaining closure objectives is summarised in Table 4.1.

Table 4.1: Summary of Key Closure Data

Parameter Why required How acquired How held/reviewed/reported

Topography To demonstrate that landforms will be compatible with pre‐mining environment

To show that surface flow paths closely match pre‐mining hydrology

Lidar survey and ground‐based surveys

CAD files

Data to be reviewed at least 3‐yearly as part of mine closure plan review

Erosion To refine cover design Ground‐based surveys of transects

Annual and event‐based surveys

Results to be reviewed at least 3‐yearly as part of mine closure plan review

Extent of ground disturbance and rehabilitation

To demonstrate compliance with approval conditions

To provide basis for closure cost estimates

Ground‐based and aerial surveys

Reviewed and reported annually in Annual Environment Report (AER)

Soil chemistry and radiochemistry

To demonstrate that concentrations of trace elements, radionuclides and salts in soils affected by mining activities are compatible with the proposed post‐mining land uses.

Site contamination assessment conducted as part of decommissioning and closure activities

Incident response and follow up reports (in case of spills)

Hard copy and electronic reports

Access database (backed up in Toro head office)

Results (contamination incidents) to be reviewed at least 3‐yearly as part of mine closure plan review

Soil and mine waste chemical (ESP, EC, pH) and physical characteristics and quantities

Provides basis for identifying soil groupings requiring separate storage and management

Allows estimation of quantities available for constructing tailings cover systems

Provides records of quantities and age of topsoil to be used in mine rehabilitation

6‐monthly soil and mine waste testing and quantity inventory

Hard copy and electronic reports

Reviewed annually during preparation of AER


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Groundwater elevation, piezometric heads

To assess groundwater levels in proximity to waste storages including evidence of effectiveness of perimeter barriers and evidence of integrity of tailings containment system

Monthly monitoring of groundwater levels and piezometric pressures

Reviewed at least annually as part of AER and annual aquifer review

Groundwater quality

To verify performance of waste disposal facilities

Quarterly groundwater monitoring


Climate data, especially rainfall, wind speed and direction and evaporation

Information required for interpretation of erosion monitoring (wind or water erosion) and groundwater monitoring

To provide context for evaluation of vegetation monitoring data

To provide input to periodic reviews of the site water balance.

BoM data from Wiluna

Site‐based records of rainfall, wind speed and direction, temperature and evaporation.


Vegetation density and diversity

To evaluate progress towards ecosystem restoration

biennial monitoring of quadrats

Reviewed annually during preparation of AER

Vegetation condition

To assess response of vegetation in rehabilitated areas to environmental stressors.

Review of seasonal multi‐spectral satellite data and/or ground‐based surveillance.

Reviewed and reported annually in AER

Weed occurrence To assess ecosystem health

Annual weed surveys Reviewed and reported annually in AER

Tailings quantities and density

To check capacity of mine voids to contain wastes

Daily log of tailings discharge

Annual and event‐based testing of in situ tailings density

Reviewed and reported annually in tailings review report.

Quantity and quality of seepage from underdrainage systems (PLS storages)

To confirm integrity of containment systems

Continuous recording of quantities

If seepage present, event‐based testing of quality

Reviewed weekly

Reported annually

Tailings pore fluid quality

To enable refinement of solute transport model.

Quarterly and event‐based sampling and testing.

Review annually

Update seepage model 3‐yearly as part of closure plan review


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Radiation To confirm effectiveness of cover system

To enable updating of dose estimates

As described in the Radiation Management Plan

As described in the Radiation Management Plan

To support its mine closure planning, Toro has undertaken a series of studies.

4.1 Leachability of Ore

In order to assess any potential impact arising from an unplanned closure of operations that would result in the stockpiling of unprocessed ore, Toro commissioned ore leachability tests. The results are in Table 4.2. They confirm that the ore is relatively benign.

Table 4.2: Results of ore leachability tests

Ore Constituent ASLP 1, mg/L CL1, mg/kg Wiluna ore, water leachable metal, mg/L

Wiluna ore, total metals, mg/kg

Wiluna ore, leachable metal as a percentage of total metal, %

Aluminum ‐‐ 50,000 <0.1 23,110 ‐‐

Arsenic 0.5 500 0.002 20 0.2

Barium ‐‐ 50,000 0.06 370 0.38

Beryllium 0.1 100 <0.01 <0.5 ‐‐

Cadmium 0.1 100 <0.002 <0.5 ‐‐

Chromium (VI) 0.5 500 <0.01* 50* <0.004*

Cobalt ‐‐ 50,000 <0.01 <5 ‐‐

Copper ‐‐ 50,000 0.02 20 0.4

Lead 0.1 1500 <0.01 10 ‐‐

Manganese ‐‐ 50,000 <0.01 215 ‐‐

Mercury 0.01 75 <0.0002 Not tested ‐‐

Molybdenum 0.5 1000 <0.01 <5 ‐‐

Nickel 0.2 3000 <0.01 15 ‐‐

Selenium 0.5 50 <0.001 Not tested ‐‐

Silver 1 180 <0.01 <1 ‐‐

Thorium ‐‐ ‐‐ 0.002 4.0 1

Uranium ‐‐ ‐‐ 0.001 537.5 0.004

Vanadium ‐‐ 50,000 0.01 200 0.1

Zinc ‐‐ 50,000 0.05 25 4

Note: The ore was characterised using the DER waste classification (DER 2009). Chromium concentrations are for total, not hexavalent chromium. A dash (‐‐) means no value has been defined or no percentage could be calculated because the concentrations of metals were less than the analytical limit of reporting.


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4.2 Physical and Geochemical Characterisation of Waste Rock Material

Millipede, Centipede, Lake Maitland and Lake Way are all classified as surficial calcrete associated uranium deposits due to their equivalent geological/geomorphological setting, mineralogy and theory (or theories) of genesis as outlined by Brunt (1990). In the Yilgarn of Western Australia, these four deposits are not unique. Yeelirrie, Lake Raeside, Lake Mason, Nowthanna, Thatcher Soak and Dawson Hinkler are all of the same uranium deposit classification. All these deposits have an ore mineralogy of almost 100% carnotite (K2(UO2)2(VO4)2∙3H2O) and are associated with calcium and magnesium carbonates in an oxidised setting near the surface (within 1–2 m depth) with valley fill sediments (sands, silts and clays) in broad palaeovalleys, trunk drainage systems and playas (Brunt, 1990).

Given these fundamental similarities, the mineralogical and chemical composition of bulk material excavated from any of these deposits, whether in the form of ore or waste rock, will be for all intents and purposes, the same.

The only lithological changes that would occur within waste stockpiles, or any stockpile for that matter (ore on the ROM or low grade ore), would be due to changing dominances within different parts of the deposits. For example, some areas have more clay than calcrete and some more calcrete than clay. This is evidenced in the representative sampling that has occurred for waste characterisation whereby whilst the calcium and magnesium carbonates dominate the system, there can be considerable differences in the abundances of particular clay species or lithology, such as silcrete (portrayed by quartz content), depending on the exact locations the samples have been collected from within the deposits. Whatever the case, however, mineralogical and geochemical analyses show that bulk material from all deposits, whether ore or waste, will be relatively benign oxidised sands, silts and clays with calcrete (often dolomitic).

4.3 Mining Waste Generation

Over the course of the operation and across all four deposits, the generation of wastes would remain fairly consistent. This is due to similarities in all four deposits including their grades, depths and geographical extents. Figure 4.1 demonstrates how mining wastes would be generated by the Project.

The orange line shows the cumulative tonnages of waste mined over the duration of the Project (including mining at Centipede and Lake Way). After waste is taken from an area being mined, it is stockpiled and later returned as backfill when a suitable void is available. As mining progresses, the void space available for waste keeps up with the volume of waste generated as shown by the orange and green lines remaining almost in parallel. The green line, representing waste rehabilitation through return of waste as backfill, remains lower than the cumulative waste generation line during the life of mining, but by the end of operations the entire quantity of waste has been rehabilitated. The brown polygon at the base of the graph shows the annual total tonnage of waste in stockpiles at the end of each year.


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Figure 4.1: Mining waste generation and rehabilitation

4.4 Acid and Neutral Rock Drainage

There are four key fundamentals to understanding the potential chemistry of drainage from any stockpile or long term final landform at the Wiluna Uranium Project. They are:

1. All the deposits forming the Wiluna Uranium Project (Millipede, Centipede, Lake Maitland and

Lake Way) are located within a completely oxidised setting only 1–2 m from the surface (Toro

geological observations (Figure 4.2 and Figure 4.3) and Brunt, 1990);

2. All of the deposits are hosted by relatively benign oxidised sands, silts and clays within deltas and

playas in broad palaeovalleys (Toro geological observations (Figure 4.2 and Figure 4.3) and Brunt,

1990);

3. Whilst varying amounts of different clay species are present as well as gypsum (the latter mostly

above the ore body in the waste) the geochemical environment is dominated by calcium and

magnesium carbonate precipitates and concretions ( Toro geological observations (Figure 4.2

and Figure 4.3) and Brunt, 1990); and

4. The ore mineral in all calcrete associated uranium deposits is almost entirely the potassium

uranyl vanadate, carnotite (K2(UO2)2(VO4)2∙3H2O (Brunt, 1990, Cameron, 1990, Bastrakov et al.,

2010), a relatively stable mineral within the chemical conditions and timescales relevant to the

Wiluna Uranium Project.


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Figure 4.2: Geological cross‐section – Millipede


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Figure 4.3: Geological cross‐section – Lake Maitland

The first of the above fundamentals means that there are no potential acid forming minerals present in the geological host, such as iron sulphides, since such minerals need reducing conditions to form. Toro analysed for both Total Sulphur and Total Sulphate in sonic drill core from the 2012 resource drilling program at Centipede; a comparison of the results shows that all sulphur present is in the form of sulphates (dominantly gypsum), not sulphides (Figure 4.4). Thus, there is no potential for


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direct acid rock drainage (ARD) nor neutral drainage from acid forming reactions occurring inside the stockpiles or final landforms.

In effect, unlike deeper deposits hosted in hard rock (fresh rock), there is very little difference between the oxidation‐reduction conditional balance (commonly known as redox) between the setting of the deposit, at 1–2 m from the surface, to a stockpile at the surface. Changes in redox and the chemistry associated with the main redox chemical reactions are the main controls on weathering, ARD and neutral drainage issues.

Figure 4.4: Sonic drill core analysis to compare Total Sulphur (S) and Total Sulphate (SO4)

Note: Chart shows that for all intents and purposes, all S is present as SO4, mostly in the form of Gypsum (CaSO4∙2H2O), meaning a complete lack of any sulphides and therefore potential production of free hydrogen ions and thus acid rock drainage from the oxidation of them.

In addition to the absence of potential acid forming minerals, the second and third fundamentals above mean that there is very little of most elements available to be leached from the host material if presented to stockpiles. In other words, it is relatively benign material. Table 4.2 in this section provides results of ore leachability tests. Figure 4.5, again from samples of sonic drill core from the 2012 resource drilling, shows major and trace element concentrations in the different lithologies of waste and low grade ore to be extremely low, apart from those related to calcrete and dolocrete (calcium [Ca], magnesium [Mg], barium [Ba] and strontium [Sr]), gypsum (sulphur [S]), some of the more resistate minerals in the sands (iron in iron nodules [Fe], boron, [B], chromium [Cr], barium [Ba], zirconium [Zr] and rubidium [Rb]) and the aluminium (Al) in the clays.


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Figure 4.5: Major and trace element concentrations in waste and low grade ore lithologies


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Note: Boxplots showing the range of concentrations of major and trace elements in the main lithological units of the Centipede Deposit, Wiluna Uranium Project for waste and very low grade ore (approximately less than 105 ppm U). Samples are from sonic drill core from the 2012 resource drilling program over the Centipede Deposit. The lithologies are the same lithological units used by Toro geologists across all of the Wiluna Uranium Project calcrete associated deposits, including Millipede and Lake Maitland.

The fourth fundamental outlined above relating to the ore mineral in all calcrete associated uranium deposits being carnotite is important because, again, carnotite as a mineral that has precipitated in an oxidised environment and will not be introduced to chemical conditions of any vast difference in the stockpiles or final landforms. Uranium solubility modelling work by Bastrakov et al. (2010) has shown that carnotite is a relatively stable solid phase in the environments and timeframes relevant to the Wiluna Uranium Project.

Calcrete/dolocrete

Sands

Silts

Clays

Silcrete

LEGEND for Figure 4.5


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4.5 Timing of Land Disturbance

Toro has estimated the timing of land disturbance based on its current mining schedule (Figure 4.6, Figure 4.7 and Figure 4.8). Mining is scheduled to commence at Centipede as shown in Year 1 of Figure 4.6. Mining at Centipede would start away from the lake and gradually progress north. By Year 2 tailings are being deposited into the first mining area. In Year 3 mining would move west and also commence at the Millipede deposit. By this stage, significant void space has been opened up for tailings. Rehabilitation commences in Year 4 to allow tailings time to consolidate sufficiently to allow material to be backfilled over the tailings.

The mining at Centipede and Millipede would continue until Year 5, at which time mining would commence at Lake Maitland. At Millipede, sufficient pit void space needs to be left to take tailings generated from the processing of ore mined at Lake Maitland, and at Centipede the same is the case for Lake Way tailings.

At Lake Maitland, as mining progresses rehabilitation would be quicker as there is no need to allow time for tailings to settle. The pits at Lake Maitland would be backfilled with suitable material and rehabilitated immediately. By the end of Year 12, mining has ceased at Lake Maitland and the entire mining area is being rehabilitated. Toro would ensure that no mine pits are left at Lake Maitland at the end of operations there to ensure no pit lakes are created.

Between Years 13 to 18, the Lake Way deposit would be mined. This is not shown on the figures below as mining at Lake Way has already been the subject of EPA Assessment 1819 and mining there would follow the sequence assessed (Toro, 2011a, Section 2.5.6). During mining at Lake Way, tailings are still being deposited at Centipede and the consolidated TSF is still being rehabilitated. By the end of Year 18, all of Centipede and Millipede has been rehabilitated, as has Lake Way and Lake Maitland.


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Figure 4.6: Land disturbance timing – Years 1–6


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4.6 Mine Closure

As part of the rehabilitation of the mine pits, space would be allowed to contain any materials that cannot be taken off site.

In the lead up to closure, reuse and recycling opportunities for fixed and mobile plant and infrastructure would be considered. This could include removal of selected equipment for use by a third party, or leaving some equipment or infrastructure (for example, water supply bores, power transmission infrastructure or access roads) in situ for alternative beneficial uses such as for pastoral or community purposes. Where no feasible or practicable alternatives were identified, the Project components would be decommissioned.

Total estimates of concrete, steel, pipelines and other materials available for salvage or to be disposed of at decommissioning following mining at Millipede, Centipede, Lake Maitland and Lake Way will be provided in the Mining Proposal.

At the end of its useful life, the processing plant would be decommissioned, dismantled and either buried in mined‐out voids or removed. Decommissioning of the processing plant and the accommodation camp which would support mining at Millipede/Centipede was included in EPA Assessment 1819.

The infrastructure to support mining at Millipede would be the same as that required for Centipede. There are no additional installations apart from internal haul roads needed to facilitate mining at Millipede. For this reason, there are no waste materials (such as concrete and steel) that would need to be removed from Millipede that are additional to those to be removed from Centipede. The roads put in place to connect the two deposits would be ripped up and re‐spread with topsoil and revegetation, where required.

The underground pipeline connecting the processing plant with the Lake Maitland borefield would likely be left in place. The advantage of this is that after installation the area cleared for the pipeline would be rehabilitated and have had almost 20 years to recover. Removal of the pipeline at that stage could interrupt ecosystems and spread weeds. Accordingly, the environmental benefits of leaving the pipeline in place outweigh any benefits of its removal. Infrastructure at each end of the pipeline would be removed.

The haul road connecting Lake Maitland to the processing plant would be rehabilitated by ripping, spreading with topsoil and revegetated, if required. As this haul road would not be required beyond Year 13 of the operation, it is likely that this rehabilitation would take place well in advance of Project closure.

At the Lake Maitland site, all above ground installations such as workshops, the accommodation camp and any office buildings would be removed. It is likely that the office buildings and camp would be sold and taken off site. Similarly, workshops are also likely to be removed from site as they would not be contaminated beyond the point of remediation. Fuel tanks and other hydrocarbon storage containers would be taken back to the workshop at Centipede where they would be used for the remainder of the Project’s life. During operations at Lake Maitland, all rubbish and waste hydrocarbons would be sent to the Centipede site for disposal and/or remediation.

It is likely that concrete footings at Lake Maitland would need to be disposed of inside the mine pit. The volume of concrete to be removed has been estimated based on the approximate footprint of the mine buildings and is presented in Table 4.3. The engineered pads on which the stockpiles would sit are likely to be compacted clay and are not included within the calculation. These are also likely to be disposed of within the pit.


Page 4‐16

Table 4.3: Final materials and waste management – Lake Maitland

Installation Footprint Approximate Volume of Concrete to be Removed

Mine workshops 2 ha area allowed for workshop floors 2000 m3

Mine camp and offices 20 dongas, plus footpaths, parking and associated infrastructure

520 m3

4.7 Landform Evolution Modelling

Modelling was undertaken by Landloch to assess the long‐term stability of the post‐closure landforms, particularly over the rehabilitated tailings storage facility (Landloch, 2015 – Appendix 10‐10 of PER). Samples were taken of the three most common soil types found across the Project area. The clay pan material was found to be hypersaline, as expected, and was only suitable for use in rehabilitating reconstructed clay pan areas.

The two other soil types, the lake playa sand and the dune sand, were found to have indistinguishable properties and were considered to be the same material. To model the erosion potential of reformed structures, a 20 m high dune with an 18° batter configuration was chosen. This structure represents a reformed dune constructed with considerably steep walls. Landloch’s erosion model found that material across the Project area was not susceptible to erosion.

4.8 Fate of Contaminant and Transport Modelling

At the Millipede and Centipede deposits, Toro is planning to backfill mine voids with tailings. Mine voids would be prepared for tailings with a layer of compacted clay to serve as a trap to capture mobilised uranium and other contaminants, and to also slow the movement of water into and out of the TSF. Tailings would then be deposited into the void to a depth of 3 m below the top of the pit. The tailings cap would be a minimum 2 m thick and comprise a compacted multi‐layer cover with a radiation control layer at the base. Further details of the TSF design are given below.

To demonstrate that in‐ground tailings is a safe and viable option for the long‐term storage of tailings, Toro has previously undertaken geochemical and solute transport modelling of seepage into the surrounding groundwater environment using independent consultants (Knight Piésold Consulting, 2011). This was completed as part of the assessment of mining at Centipede and Lake Way (EPA Assessment 1819 and EPBC 2009/5174). The same management method is proposed for tailings produced from ore mined at Millipede and Lake Maitland.

Toro’s fate of contaminant modelling assessed how far from the TSF contaminates would flow after 10,000 years. It adopted conservative assumptions, including no clay barrier in the TSF.

The results showed that there would be an initial pulse of uranium resulting in a peak in concentration (40.8 mg/L) in the aquifer in close proximity to the mine pit (<10 m). With time, the uranium plume would disperse due to the movement of the groundwater. After 1000 years, the released uranium (38.5 mg/L) would drop appreciably to concentrations of less than 0.5 mg/L at distances of up to 45 m from the mine pit, and to below 0.4 mg/L at distances greater than 45 m. This significant drop in uranium concentrations is likely due to adsorption on to the calcite and associated iron oxide surfaces (Knight Piésold Consulting, 2011).

The model prediction for a 10,000 year period is shown in Figure 4.9 and Figure 4.10. It is predicted that the groundwater uranium concentration would remain below 0.40 mg/L across all distances from the mine pit, and that the majority of uranium released in the leachate would be adsorbed or precipitated out of solution at distances greater than 250 m.


Page 4‐17

Figure 4.9: Predicted U transport from tailings over a 1000 Year period with a flow velocity of 0.5 m/a

Source: Soilwater (2012)

Figure 4.10: Predicted U transport from tailings over a 10,000 Year period

Source: Soilwater (2012)


Page 4‐18

At the request of the Department of Environment Regulation, Toro commissioned Dr Henning Prommer, a Principal Research Scientist at CSIRO and Winthrop Research Professor at the University of Western Australia, to update the original model to ensure all chemical speciation/complexing, and therefore uranium solubility/sorption, is in line with the most recent international research on uranium hydro‐geochemistry and contaminant transport (Prommer et al., 2015 – Appendix 10‐29 of the PER).

The updated model used the same conservative assumptions as the previous model in initial scenarios, such as no barriers, no dilution and no lateral flows of water. Later modelling went further to include a worst case scenario whereby tailings water was allowed to release into the surrounding groundwater unabated for 200 years at a constant rate and volume.

So far the modelling has shown that updating the speciation/complexing database results in an increase in the solubility of uranium, but that including carnotite saturation, the ore mineral of the deposits proposed to be mined by Toro, places a control on maximum solubility. Importantly, when introducing reduction and therefore iron sulphide formation into the geochemical model, something that is currently observed in the shallow lake sediments directly adjacent to the proposed TSF at Millipede/Centipede and therefore within the assumed flow path of any solute release, uranium is precipitated out of solution to significantly reduced levels. In other words, a natural trap for uranium seems to already exist in the current groundwater regime (Prommer et al., 2015 – Appendix 10‐29 ).

This PHREEQC geochemical transport model will now be used by CSIRO as a base to test the effect of likely natural physical and chemical scenarios arising from implementation of this Proposal.

Toro is committed to the necessary research to further an understanding of the physical and chemical conditions within and surrounding the TSF so that a full 3D model can be established for contaminant fate transport modelling. Toro has already committed to this under condition 17(d) of the federal approval for mining at Centipede and Lake Way (EPBC 2009/5174). Under this condition, prior to the commencement of development, Toro will submit for approval a mine closure plan with a comprehensive and conservative safety assessment that includes modelling to determine the long‐term risk to the public and the environment from operation of the TSF and demonstrates that the closure outcome can continue to be achieved.

4.9 Tailings Characterisation

Tailings characteristics are typically heavily influenced by the ore mineralogy, together with the physical and chemical processes used to extract the ore. The tailings characteristics have to be understood in order to establish appropriate control measures to manage the short‐, medium‐ and long‐term physical, radiological and geochemical behaviour of the tailings. Characterisation of the tailings facilitates identification of the preferred consistency, transport, deposition, placement and storage methods.

The long‐term performance of the tailings is influenced by the method of deposition. It is therefore essential that the tailings characterisation process allows for the identification of key physical characteristics and the establishment of the material parameters. This facilitates estimation of the tailings settling and drying behaviour, short‐ and long‐term densities, beach slope angles, segregation and other factors than can arise as a result of differing deposition techniques.

As the selection and refinement of the ore processing method for the Proposal has progressed, tailings samples generated at several stages have been subjected to test work to establish parameters and indications of behaviour for design purposes. This test work was conducted as an iterative process with samples subjected to a continually modified program. Each iteration was adjusted to account for information gathered from the previous round of work. The information


Page 4‐19

gathered was used to develop design parameters for the tailings to be generated following ore processing by direct precipitation (DP).

The DP tailings samples consisted of ore that had undergone a bench‐scale uranium extraction process intended to replicate full‐scale processing. The laboratory test work program was developed to assess properties of the tailings solids including:

Mineralogy;

Geotechnical parameters for use in design;

Geochemical properties of the tailings; and

Radiological properties of the tailings.

Additional test work was conducted to assess the tailings supernatant properties including:

Mineralogy of suspended solids;

Suspended solids content;

Dissolved metals content; and

Water chemistry and pH.

Information obtained from the analysis of the tailings supernatant properties was evaluated in conjunction with the properties of the tailings solids to assist in developing an appropriate tailings management plan.

The results of the laboratory test work program identified that the inherent characteristics of the tailings would necessitate some form of intervention to achieve the tailings management objectives established for the Proposal. Without further intervention, the characteristics of the tailings arising from the extraction process exhibited specific behaviours that needed to be addressed as part of the tailings management strategy. These behaviours included:

A short‐term resistance to settling (release of supernatant water);

A slow rate of consolidation subsequent to releasing supernatant water; and

A subsequent low bearing capacity and shear strength that inhibited rehabilitation.

Improvement of these tailings characteristics resulted in substantial benefits in meeting tailings management and environmental objectives. These benefits included:

Reducing the required footprint area for the TSF;

Minimising the pond size required to manage decanted water; and

Increased use of decanted (supernatant) water for return to the processing plant.

Consideration was given to improving the tailings characteristics through mechanical dewatering of the tailings, flocculation of the tailings near the point of discharge and a combination of these two methods. A final average tailings dry density in the range of 1.0 tonnes per cubic metre (t/m3) to 1.2 t/m3 has been identified as a design objective, based on desiccation and consolidation test work. Achieving the design density of tailings allows for in‐pit storage of tailings that would:

Achieve a shear strength that will allow for progressive rehabilitation; and Minimise the extent of any above‐ground landforms required to store surplus waste materials arising from bulking during mining and processing operations.


Page 5‐1

5 STAKEHOLDER ENGAGEMENT

Toro initiated its stakeholder consultation programme immediately after it acquired its interest in the Wiluna Uranium Project in 2007 and there has been comprehensive stakeholder consultation since proposed mining at Centipede and Lake Way was referred for government assessment in October 2009. The purpose of the consultation so far has been to identify issues that could be considered as part of the process of investigating Project alternatives and to assist in design and assessment of Project options. Since acquiring the Lake Maitland Project Toro has continued the consultation initiated by the former owner. The consultation has included extensive discussion about Toro’s proposals for mine closure and rehabilitation.

5.1 Overview of Stakeholders

Toro’s consultation has included state, federal and local government agencies, Aboriginal people and organisations, the residents of Wiluna, Leonora, Laverton, Menzies and Kalgoorlie, non‐government organisations, and people and organisations with wider interests. Toro has undertaken its own consultation specific to this Proposal in Wiluna and the wider region and also participated in industry initiatives to provide information about the Proposal and more general issues associated with uranium mining to local and regional communities. This has included participation in community forums in Kalgoorlie, Wiluna, Leonora, Laverton and Menzies.

Toro has consulted Traditional Owners and Native Title Holders through community meetings and their representative body, Central Desert Native Title Services (CDNTS). Toro is negotiating a mining agreement with the Wiluna Native Title Holders who were granted Native Title to their lands in July 2013 by the Federal Court. Those lands include the Millipede, Centipede and Lake Way deposits and part of the southern ore haul road that connects the Lake Maitland deposit to the previously assessed processing facility at Millipede/Centipede. Toro has also continued consultation with the Barwidgee and other Aboriginal people who claim an interest in Lake Maitland, the descendants of the Tjupan People. Lake Maitland is on the ancestral lands of the Tjupan.

A table of the key stakeholders for the Project is presented in Table 5.1.

Table 5.1: Key Stakeholders

Category Group

Government Western Australian and Commonwealth Ministers and senior advisers

State and Commonwealth Government Departments and Agencies (Departmental and Agency heads and their senior reports)

Local Government representatives (Shires of Wiluna, Leonora, Laverton and Menzies and City of Kalgoorlie)

Non‐government organisations and service providers

Community groups

Environmental groups

Private service providers

Industry and business Local and regional industries and businesses (including mining companies)

Regional economic development boards

Industry organisations

Aboriginal groups Native Title Holders and Claimants

Other Aboriginal people claiming an interest in the Project


Page 5‐2

Category Group

Landholders Pastoral lease holders and managers

General public Local

Regional

State

Non‐government organisations

Relevant communities Wiluna

Leonora

Laverton

Menzies

Kalgoorlie

5.2 Consultation Process

A member of Toro’s management group has specific responsibilities to manage day‐to‐day contact with the Wiluna community. The company representative also manages Toro’s engagement with Aboriginal people and communities.

Consultation on mine closure and rehabilitation matters is an important element of Toro’s Community and Stakeholder Consultation Program.

On‐going consultation with the Wiluna People has identified in particular, their view that post‐mining, no artificial above‐ground structures should remain. This has been an important consideration for Toro in its proposal to undertake in‐pit tailings storage at Millipede and Centipede.

Table 5.2: Stakeholder Engagement Register

Date Engagement Stakeholders Comments/

Issues

Proponent

Response

Stakeholder

Response

2009 ‐ ongoing

Half‐yearly meetings and site visits

Traditional owners

Avoidance of any above‐ground artificial structures post‐mining;

Radiation protection; employment opportunities

Matter continuing to be discussed during mining agreement negotiation – proposal for involvement of Traditional Owners in mine closure work

Satisfied with level of engagement

2009 –on‐going

Periodic meetings including on‐lease consultations

Pastoral lease‐holders

Extent to which on‐going pastoral activities may be affected by post‐mining activities

Some areas may be permanently off‐limits but a relatively very small part of leases

Acceptable


Page 5‐3

Date Engagement Stakeholders Comments/

Issues

Proponent

Response

Stakeholder

Response

2009 ‐ ongoing

Periodic meetings Wiluna and Leonora Shires and local and regional businesses

Benefits to region post‐mining

Seeking to build capacity in local community which may be applicable to opportunities post‐mining – also considering what mine‐related infrastructure could be left as a legacy to the local community

Acceptable

2009 ‐ ongoing

Periodic meetings and site visits

Western Australian and Federal Government agencies

Discussions about preparation of environmental assessment documentation

Reviews to environmental assessment documentation to meet requirements of government assessors

Acceptable

2009 ‐ ongoing

Periodic meetings and site visits

Non‐government Organizations (environmental)

Opposition to uranium mining and other stages of the nuclear cycle including generation of nuclear power and radioactive waste management

Toro seeks to ensure that environmental impacts (including to workers, contractors and members of the public) arising from uranium mining are minimized

Unacceptable – continuing opposition to uranium mining

Mining of the Millipede, Centipede and Lake Way deposits would occur on land held in native title by the Wiluna People. In a mining agreement negotiation with the Wiluna People, Toro has proposed that it help build the capacity of the Wiluna People in work associated with mine closure and rehabilitation including radiation and groundwater monitoring, the on‐going collection and storage of topsoil and seeds, seed germination and banking. Toro has also proposed that during the operational phase of the mine there would be continuing consultation about mine closure through a Liaison Committee which would meet quarterly.

Toro would take the same approach in its negotiation of a mining agreement with the Barwidgee People who claim an interest in the land on which mining at Lake Maitland would occur.


Page 5‐4

5.3 Stakeholder Engagement Strategy

Following a Final Investment Decision to proceed with the Project, Toro would commit to the following specific methods to keep communities and stakeholders informed on mine closure and rehabilitation issues (in addition to any reporting obligations to government):

The establishment of a Toro office in Wiluna at which a Community Relations Manager would be readily accessible;

The appointment of an Aboriginal Liaison and Development Officer and an Aboriginal Liaison Committee comprising representatives of Traditional Owners and Toro management;

Establishment and maintenance of a register of contact with the communities and stakeholders most likely to be affected by operations and mine closure, to be available for government review;

All those on the contact register to be informed of planned milestones including start to commissioning, start to regular production and subsequent major operational schedules including implementation of closure and rehabilitation plans;

A quarterly newsletter;

A half yearly briefing of members of the Wiluna Shire Council by senior Toro management;

A half yearly briefing of representatives of the Traditional Owners by senior Toro management;

A Community Issues Procedure to ensure prompt and documented responses to all issues (including those related to closure) raised with Toro, available for government review;

An annual open day at site for the local community;

An annual site visit for Non‐government Organisation representatives;

An annual report posted on Toro’s web site on operational, environmental and social performance – such report to be externally audited every three years; and

Regular provision of information to the local and regional press and media.

Toro would involve representatives of the local community in the monitoring of predicted operational impacts, as a means of transparently demonstrating the outcomes of mine rehabilitation practices.


Page 6‐1

6 POST‐MINING LAND USE AND CLOSURE OBJECTIVES

6.1 Post‐closure Land Uses

Mine closure and rehabilitation objectives must be defined in the context of proposed or likely land uses in the post‐mining period. Apart from mining, the current land uses in the Shire of Wiluna include pastoral activities, law activities, ceremonies, hunting and food gathering by traditional owners and some tourism. The Project lies within the Lake Way, Millbillillie and Barwidgee pastoral leases.

In preparing this Conceptual Mine Closure Plan, Toro has assumed that after cessation of mining, land within the Project area would revert to current uses. This would be finally determined in consultation with relevant stakeholders including Native Title Holders and Claimants, pastoralists, and state and local government authorities. Toro would reinstate the land to a condition compatible with the agreed post‐mining use.

6.2 Closure Goals and Objectives

Toro’s overall goals in relation to mine closure and rehabilitation are to ensure that land disturbed by Toro’s activities is:

Safe to both humans and wildlife;

Non‐polluting;

Geotechnically and erosionally stable ; and

Suitable for agreed post‐mining land uses.

Toro would conduct its closure and rehabilitation activities in a way that is socially responsible and which demonstrates respect for the community in which it operates. Through consultation with stakeholders, Toro has identified the following specific objectives for mine closure and rehabilitation:

‘No surprises’ in mine closure timing and process;

Local stakeholders to be encouraged to take an active role in monitoring rehabilitation outcomes in the post‐closure period on a fee‐for‐service basis;

Post‐mining concentrations of metals, salts and radionuclides in soils and groundwater outside any engineered waste containment structures would be within the range of naturally occurring levels that existed in the Project area pre‐mining;

Vegetation communities in areas disturbed by mining would be demonstrably similar to natural ecosystems in the Lake Way and Lake Maitland areas (especially where native vegetation is the proposed land use);

Surface water flow patterns would be returned to a condition that closely approximated pre‐mining conditions where there has been a temporary surface water diversion;

Rehabilitated land would blend with the surrounding undisturbed land; and

Toro would aim to complete relinquishment of tenure within 10 years after cessation of mining.

The management actions required to achieve environmental and social objectives may vary for areas that are used for different purposes during the active life of the mine. Although the overall goals are the same (safe, non‐polluting, stable), the work required to achieve those goals would be different for each of the management domains defined in Section 2.


Page 7‐1

7 IDENTIFICATION AND MANAGEMENT OF CLOSURE ISSUES

Toro commissioned Knight Piésold Consulting to assess alternative tailings disposal options. This assessment confirmed that the in‐pit tailings disposal option provides the lowest risk and hazard rating, consistent with current best practice (Knight Piésold Consulting, 2011).

Toro also completed a series of risk assessment workshops to identify and prioritise potential risks associated with implementation of the Proposal, including a specific risk assessment process for tailings disposal and mine closure (Table 7.1).

The closure risk assessment considered a range of risks (likelihood and consequence), impacts and mitigating controls associated with the long‐term integrity of the TSF post‐closure. This has particular relevance to the groundwater environment and the tailings cover integrity.

The analysis of likelihood and consequence was carried out after developing specific impact criteria for each environmental value or factor. Impact criteria were defined in consultation with a wide range of technical specialists and took into account current government policy and established environmental standards.

Many potentially significant risks were eliminated through design decisions taken during development of the Proposal, such as:

Using in‐pit tailings disposal into mine voids as the preferred disposal method;

Placing all mineralised materials below the land surface at closure;

Constructing a multi‐layered tailings cover thickness of greater than 2 m to attenuate radon emanation, limit salt upwelling and divert rainwater from the surface;

Including water barriers and an engineered clay liner in the TSF design; and

Incorporating flood diversion structures and erosion protection into the TSF design.

The outcome indicated that of the seven events rated, none was an extreme risk, one rated as high risk and the remainder as medium risk (Table 7.1). For all events, the identified risk mitigation controls have been included in Toro’s TSF design and mine closure plans and effectively reduce each of these risks to low.

In 2012, as part of Toro’s commitment to best practice, Toro funded the preparation of a university thesis which studied the physical suitability of mined waste materials for use in the capillary layer of the TSF. The study concluded that inclusion of the capillary layer would ‘ensure that current best practice is incorporated in Toro’s tailings cover design, limiting the risk of tailings release through groundwater or evaporative forcing’ (Dunne, 2012 – Appendix 10‐48 of the PER). The study also made recommendations for grain sorting of the materials to be used in the capillary layer. Toro will include these recommendations into the final engineering design of the mine plan.


Page 7‐2

Table 7.1 Environmental Risk Assessment for Tailings and Mine Closure

Risk Assessment ‐ Closure Plan

Aspect/

Activity

Event Event Cause Event Impact Likelihood Consequence Risk

Rating

Control

Domain: Centipede / Millipede pit void, tailings storage area and stockpiles

Aspect ‐

Groundwater

Seepage of

metals or

radionuclides

into

groundwater

Increased mobility of

elements in waste

rock as a result of

mechanical

disturbance.

Contamination

of groundwater

(reduction in

beneficial use)

1 4 Medium Include clay liner and water barriers in TSF

design; Conduct routine groundwater

monitoring to assess against closure criteria;

periodically review solute transport model.

Seepage of

metals or

radionuclides

into

groundwater

Underestimation of

contaminants

mobility/interactions

Reduction in

beneficial use of

groundwater;

accumulation of

contaminants in

biota





Seepage of

metals or

radionuclides

into

groundwater

Breach or bypassing

of containment

system

Reduction in

beneficial use of

groundwater;

accumulation of

contaminants in

biota





Seepage of

metals or

radionuclides

into

groundwater

Loss of containment

or contaminant

behaviour not

conforming to

model.

Reduction in

beneficial use of

groundwater;

accumulation of

contaminants in

biota






Page 7‐3

Risk Assessment ‐ Closure Plan

Aspect/

Activity

Event Event Cause Event Impact Likelihood Consequence Risk

Rating

Control

Domain: Centipede / Millipede pit void, tailings storage area and stockpiles

Aspect‐

Surface water

Discharge of

water and/or

sediment

from area of

breached

tailings cover

Erosion of tailings

cap and site flooding

due to extreme

rainfall

Contamination

outside Project

footprint

2 3 Medium Construct tailings cover to be multi layer and

ensure depth of cover and substrates used are

adequate for containment

Activity:

Tailings

storage

Upward

migration of

metals or

radionuclides

through

cover system

Inappropriate design

or construction of

cover system

Bioaccumulation

of contaminants

in soil and

vegetation

3 4 High Construct tailings cover to be multi layer and

include barrier to salt upward migration.

Conduct trials of cover system before finalising

design.

Release of

radioactivity

to the

atmosphere

Insufficient depth of

cover over the

tailings

Localised

radiation levels

above

background

2 3 Medium Construct tailings cover to be multi layer and

include barrier to radon emanation. Ensure

depth of cover and substrates used are

adequate for containment.


Page 7‐4

Risk Assessment Matrix

Likelihood

Consequence

Almost certain 5

Likely 4 Possible 3 Unlikely

2 Extremely unlikely 1

Very serious to

catastrophic 5 Extreme Extreme High High High

Major 4 Extreme High High Medium Medium

Moderate 3 High High Medium Medium Low

Minor 2 Medium Medium Medium Low Low

Negligible 1 Low Low Low Low Low


Page 8‐1

8 DEVELOPMENT OF COMPLETION CRITERIA

The main effect of implementing the Wiluna project arises from the direct disturbance of approximately 3121 ha of land. Other potentially significant impacts (described in the PER) include:

Temporary changes in groundwater levels in areas from which groundwater is abstracted for water supply and pit dewatering;

Changes in groundwater levels associated with groundwater reinjection at Lake Maitland;

Alteration in soil quality as a result of mechanical disturbance or release of salts, radionuclides or trace elements from mining activities;

Alteration to surface water flow;

Reshaping of the land surface in mining operations areas;

On‐site disposal of tailings and other wastes from mining activities; and

Socio‐economic changes in the Wiluna community.

At cessation of mining and processing it would be necessary to demonstrate that the biophysical environment has been restored to a safe, stable, non‐polluting condition which supports the target post‐closure land uses. Toro has defined a preliminary list of closure criteria and indicators that would be used to monitor and evaluate the effectiveness of its closure and rehabilitation activities. These are summarised in Table 8.1.


Page 8‐2

Table 8.1: Provisional Completion Criterial and Indicators

Factor Closure Objective Indicators Preliminary Completion Criteria

Measurement

Flora and Vegetation Vegetation and vegetation communities are restored across disturbed areas

No increase in weed species present

Species present in monitoring plots are the same as in analogous plots outside the disturbed area

Weed surveys and inspections undertaken by Toro show no new infestations of known weeds, or new infestations of unknown species

50% of pre mining taxa are re‐established in disturbed areas within 5 years of Project closure

Vegetation density is similar to pre mining density

Weed occurrence (type of weed and population density) is the same as at analogue sites within 5 years of mine closure

Annual flora surveys across disturbed areas

Landform Stability Backfilled mine voids are stable and non‐eroding

All above ground installations are removed

Removed access tracks and haul roads are not eroding

Visual signs of erosion or subsidence

Drainage lines installed along roads show no signs of erosion

Location and hydrological attributes of drainage features

No above ground storage of mineralised materials

Maximum height and scale to built landforms to resemble existing islands in Lake Way

Ground based topographic surveys

Lidar data

Occurrence of rills, gullies, sheetwash or subsidence features in disturbed areas.

Surface water Turbidity and chemical characteristics of run off from rehabilitated areas are similar to runoff from agreed analog sites (To be established)

Turbidity, EC Surface water quality to be consistent with regional surface water quality

Event based monitoring at agreed monitoring locations


Page 8‐3


Measurement

Groundwater Aquifer water levels required for the protection of water‐dependent biota are maintained

Groundwater quality surrounding the in‐pit tailings storages is maintained post‐closure

Drawdown at or below modelled levels

Monitor tailings pore water fluid and groundwater

Periodically update seepage model

No changes in plant health when impact areas are compared to non‐impact sites

Groundwater chemistry outside the 0.5m drawdown contour remains consistent with pre‐mining data

Monitoring at agreed locations

Soil quality Contamination status of soils in mined areas does not differ to pre‐mining status

Soils are compatible with agreed post‐mining land uses

Concentrations of trace elements, radionuclides, hydrocarbons and total salts

Mean concentration of radionuclides, metals and salts in upper 1 metre of soil does not exceed pre‐mining mean plus 1 standard deviation from the mean

Soil characterisation in accordance with sampling and analysis plan to be agreed with the DER, DPaW and DMP

Fauna Natural recolonization of disturbed areas by vertebrate and invertebrate fauna

No evidence of accumulation of trace elements or radionuclides in invertebrates

Biomass and diversity of soil meso‐ and macro‐fauna

Concentrations of radionuclides and trace elements in invertebrate fauna

Demonstrable increase in biomass and diversity of soil meso‐ and macro‐fauna over time

Annual sampling and annual review of soil invertebrates


Page 8‐4


Measurement

Radiation Post mining radiation levels will be compatible with agreed post‐mining land uses

Post closure radiation levels in environmental media

Annual radiation doses to members of the public do not exceed 1mS/a

Radiation dose to non‐human biota do not trigger any requirement for intervention based on ERICA modelling

Ground based radiation surveys

Sampling, testing and analysing of environmental medial media such as soils, vegetation and bush foods.


Page 9‐1

9 FINANCIAL PROVISIONS FOR CLOSURE

Toro has prepared a preliminary closure cost estimate for the Proposal using the New South Wales Department of Primary Industry rehabilitation and closure cost spreadsheet (www.dpi.nsw.gov.au./Rehabilitation‐Cost‐Calculation‐Tool‐V1.7.xls). In preparing its preliminary closure cost estimate, Toro took into account volumes, areas and quantities developed by mining and other studies. Unit prices for each of the closure activities were calculated from the spreadsheet base cost and escalated for time. Recent local cost information was used where available.

In addition to the capital and operating costs arising from site decommissioning, clean up and rehabilitation, the preliminary closure cost estimate makes provision for third party management. The closure cost estimate includes a provision for post‐closure environmental monitoring in all domains. An allowance of 5% of the cost of closure at each domain has been assumed for the cost of environmental monitoring in at least the first 10 years of the post‐closure period. That is, if the cost to rehabilitate a domain is estimated at $1 million, a provision of $50,000 has been made for monitoring of the domain subsequent to closure.

Toro would review its closure cost provisioning prior to ground disturbing works, as part of documentation supplied in a mining proposal to be submitted to the DMP. The closure cost estimate would be reviewed and audited at least 3‐yearly, as part of Toro’s regular review of its mine closure plan.


Page 10‐1

10 CLOSURE IMPLEMENTATION

10.1 Key Strategies and Closure Actions

Through the risk‐based assessment of mine closure and rehabilitation risks, Toro has identified seven key strategies to support its attainment of closure objectives. The strategies are mainly preventative, rather than restorative: they aim to avoid impacts which would add to the cost, complexity or duration of site decommissioning and rehabilitation works. The key closure strategies are:

1. Minimisation of disturbance: temporary disturbance to be located on mine path to the extent practicable; use of existing disturbed areas for access roads and lay down areas. Rehabilitation to be carried out progressively.

2. Appropriate storage of hazardous materials: ensure that fuels, reagents and process liquids are stored and transferred in accordance with best practice. Carry out routine checks to ensure integrity of containment systems. Conduct periodic contamination assessments.

3. Below ground waste disposal: at closure mineralised materials are to be disposed of below ground level. Land surface to resemble pre‐mining topography. Focus on materials quantities and volume control throughout life of Project.

4. Minimisation of water abstraction, use and storage: Water abstraction is to be minimised through use of perimeter barriers and recovery of pit de‐watering water in ore treatment process.

5. Segregation of materials: Careful segregation of saline and less saline materials and mineralised/non‐mineralised wastes to be a key focus of mine planning.

6. Development and practical demonstration of local capability in land restoration and protection. Implement weed hygiene practices, collection and storage of local provenance propagules, field trials of barrier systems and rehabilitation methods throughout the life of mine to demonstrate the effectiveness of rehabilitation prescriptions.

7. Encourage local stakeholder participation: Seek the views and input of local stakeholders to develop meaningful completion criteria. Invite local participation in monitoring activities aimed at testing the effectiveness of mine rehabilitation practices.

The specific management actions required to implement these strategies have been documented in a Closure Task Register (Appendix C).

10.2 Management Accountabilities

Management accountabilities for mine closure and rehabilitation are summarised in Table 10.1. Role descriptions and organisational charts reflecting key rehabilitation and closure accountabilities would be prepared prior to the commencement of ground disturbing works.


Page 10‐2

Table 10.1: Mine Closure and Rehabilitation Accountabilities

Role Responsibility

Toro senior management Allocate resources for mine closure and rehabilitation design, implementation and monitoring

Annual review of closure provisioning

Participate in and respond to periodic independent environment audits (including closure liability review)

Sign off on annual compliance reports to DMP, OEPA, DER

Authorise adoption or revision of closure criteria

Mine Manager On‐site management and responsibility of the Project, Toro employees and contractors

Incorporate key closure strategies in mine planning and design

Community Relations Manager

Continuing community consultation and communication of information

Coordinate and support local community involvement in monitoring

OHS&E Manager Onsite responsibility for implementation of environmental policies, procedures and systems

Ensure Obligations Register is implemented and maintained

Periodically review and update closure standards to ensure compatibility with legislation and corporate requirements

Ensure compliance with all environmental policies, procedures and systems by contractors, Toro staff and visitors to site

Liaise with stakeholders

Schedule and participate in periodic internal and third party audits (site contamination, closure liability, etc)

Conduct three yearly review of Mine Closure and Rehabilitation Plan

Environmental Superintendent and Officers

Induct staff, contractors and visitors to site about the requirements of this MCP

Annually review and update Closure Task Register

Maintain and update materials inventories and environmental databases

Record non‐conformances, incidents and complaints on the Compliance Register and document how issues raised have been resolved

Schedule and prepare progress reports on mine rehabilitation trials and other research

Coordinate environmental audits and ongoing monitoring to verify compliance

Contractors Carry out work in accordance with this Closure Plan

Acquire data and maintain records needed to support implementation of this Plan

Train staff (as required) so that work is carried out to comply with requirements of the MCP

All Other Toro Personnel and Site Visitors

Comply with all relevant site procedures and policies


Page 11‐1

11 CLOSURE MONITORING AND MAINTENANCE

Closure monitoring would build on information collected during baseline environmental surveys and routine operational monitoring (Table 11.1). Details of routine operational monitoring conducted for the purpose of on‐going assessment of Project impacts on radiation hazard, air quality, vegetation, groundwater, surface water and other environmental aspects of the Project are presented in the relevant Toro environmental management plans and are not described in detail in this MCP.

Table 11.1: Preliminary Monitoring Schedule (Mine Rehabilitation)

Factor Monitored parameters Monitoring method Monitoring frequency

Flora and vegetation

Species diversity

Vegetation density

Weed occurrence

Vegetation health

Transect and quadrat‐based ground surveys

Ground‐based photographic records

Satellite imagery (multi‐spectral)

Annual surveys (quadrats/transects)

Annual weed surveys

Periodic review of multi‐spectral data, timed to capture significant climatic events

Landform stability

Frequency and size of rills and gullies

Quantity of sediment collected in settling ponds and other drainage structures.

Occurrence of soil crusts

Surface stability measures (as described Landform Function Analysis)

Ground‐based surveys of rill frequency, form and size.

Annual and event based erosion surveys (transects)

Soil quality Concentrations of trace elements, radionuclides, total salts

Bulk density and plant available water

Other parameters (e.g. hydrocarbons) for targeted contamination assessment

Sample collection and analysis in accordance with DER guidelines (2001), Australian Soil and Land Survey Handbook (McDonald et al. 1998), McKenzie et al (2002) and relevant Australian Standards.

Minimum three‐yearly

Event‐based monitoring in the event of spills or loss of containment.

Disturbance Disturbance footprints

Waste/soils quantities

Lidar data (for regional scale topographic and drainage information)

Ground‐based topographic surveys (for footprint and volume estimation)

Quarterly data acquisition; annual review

Fauna Biomass and diversity of soil meso‐ and macro‐fauna.

Concentrations of trace elements and radionuclides in invertebrate fauna.

Project specific method to be developed based on Andre et al (2009), Andrés and Mateos (2005), Greenslade (2007), Hancock et al (2006), Majer et al (2007a & b), Majer (2009), Gongalsky (2003)

Six‐monthly sampling and annual review


Page 11‐2

Factor Monitored parameters Monitoring method Monitoring frequency

Groundwater Aquifer water levels

Tailings pore water fluid

All monitoring systems installed in tailings deposition areas to continue for suitable length of time after facility is shutdown with monitoring to include ongoing measurements of water quality around the facility. (Knight Piésold Consulting, 2013. Updated Monitoring Maintenance and Contingency Response Planning. A report to Toro Energy Limited, 12 February 2013.)

Quarterly data acquisition; annual review

During the operating life of the mine routine rehabilitation monitoring would be carried out by Toro staff and selected specialist contractors. All environmental and safety monitoring would be conducted in accordance with procedures documented in Toro’s ISO9001/ISO14001‐ consistent management system. Regular internal audits of the quality system would be scheduled by the Manager OHSE and monitored by senior Toro management. Independent external audit of mine closure performance and provisioning would be conducted no less than two‐yearly and would be completed in a timeframe aligned with Toro’s biennial review of its Mine Closure Plan.

Annual assessment of closure outcomes, including trends in rehabilitation performance, would be conducted by the Manager, OHSE as part of Toro’s reporting obligations under the Environmental Protection Act 1986 and the Mining Act 1978. Where required, technical assessments, which form the basis of closure performance evaluation would be certified by appropriately qualified engineers or scientists.

Toro has committed to involving local stakeholders in environmental monitoring activities. To that end, Toro has actively sought to build capacity in areas that would support on‐going monitoring and maintenance of environmental and safety aspects of Toro’s operations. By developing local skills and resources, Toro envisages that local stakeholders would continue to take an active role in mine rehabilitation and related land care activities into the post‐closure period. This would help to extend the social and economic benefits of the Project beyond the active life of the mine. Use of local skills would also help to maintain a consistent approach to land management.


Page 12‐1

12 MANAGEMENT OF INFORMATION AND DATA

Information and data required for implementing and evaluating mine rehabilitation and closure would be held in electronic format at the Wiluna operations site, with daily back‐up of records in Toro’s Perth office. Annual environmental reports and statutory compliance reports would be provided in the formats stipulated by the relevant agencies. Summaries of monitoring results required for annual compliance reporting would be supplied to regulatory agencies and made publicly available through Toro’s website.

As part of its stakeholder consultation, Toro would develop a plain‐language format ‘environmental report card’ to provide information on mine rehabilitation and other environmental results in an accessible format.

Toro would encourage the Wiluna community and other stakeholders to take advantage of opportunities to inspect rehabilitation works and other land management activities during annual open days.


Page 13‐1

13 REFERENCES

Anderson AN, 1993. ‘Ants as indicators of restoration success at a uranium mine in tropical Australia’. Restoration Ecology, V 1, Issue 3: 156 – 167.

André A, Antunes SCa, Gonçalves Fa and Pereira R, 2009. ‘Bait‐lamina assay as a tool to assess the effects of metal contamination in the feeding activity of soil invertebrates within a uranium mine area’, Environmental Pollution, V 157, Issues 8‐9: 2368 – 2377.

Andrés P and Mateos E, 2006. ‘Soil mesofaunal responses to post‐mining restoration treatments’, Applied Soil Ecology, V 33, Issue 1: 67 – 78.

Australian and New Zealand Minerals and Energy Council and Minerals Council of Australia, 2000. Strategic Framework for Mine Closure.

Bastrakov EN, Jaireth S and Mernagh TP, 2010. Solubility of uranium in hydrothermal fluids at 25o to 300oC: Implications for the formation of uranium deposits, Geoscience Australia Record 2010/29, 91p.

Brunt DA, 1990. Miscellaneous uranium deposits in Western Australia, in Geology of the Mineral Deposits of Australia and Papua New Guinea (ed., FE Hughes), the Australian Institute of Mining and Metallurgy, Melbourne, Australia, pp 1615‐1620.

Cameron E, 1990. Yeelirrie Uranium Deposit, in Geology of the Mineral Deposits of Australia and Papua New Guinea (ed., FE Hughes), The Australian Institute of Mining and Metallurgy, Melbourne, Australia, pp 1625‐1629.

Department of Environmental Protection, 2001. Development of Sampling and Analysis Programs, Contaminated Sites Management Series, December 2001.

Department of Industry Tourism and Resources, 2006a. Mine Closure and Completion, Leading Practice Sustainable Development Program for the mining industry.

Department of Industry Tourism and Resources, 2006b. Mine Rehabilitation, Leading Practice Sustainable Development Program for the Mining Industry.

Dunger W, Wanner M, Hauser H, Hohberg K, Schula H‐J, Schwalbe T, Seifert B, Vogel J, Voigtländer K, Zimdars B and Zulka KP, 2001. ‘Development of soil fauna at mine sites during 46 years after afforestation’, Pedobiologia, V 45, Issue 3: 243‐ 271.

Dunne P, 2012. ‘Physical suitability of mined waste materials near Wiluna, Western Australia, for use in a capillary barrier as part of a radioactive tailings storage cover system’. Thesis for Bachelor of Engineering (Environmental), University of Western Australia, 2012.

Environmental Protection Authority (EPA), 2006. Guidance Statement No 6 – Rehabilitation of Terrestrial Ecosystems

EPA 2009. Environmental Assessment Guideline No 4 ‐Towards Outcome Based Conditions

Environmental Protection Authority/Department of Mines and Petroleum (2015). Guidelines for Preparing Mine Closure Plans.

Greenslade P, 2007. ‘The potential of Collembola to act as indicators of landscape stress in Australia’. Australian Journal of Experimental Agriculture 47(4): 424–434 .

Gongalsky KB, 2003. ‘Impact of pollution caused by uranium production on soil macrofauna’, Environmental Monitoring and Assessment, V89: 197 – 219.


Page 13‐2

Hancock GR, Grabham MK, Martin P, Evans KG and Bollhöfer A, 2006. ‘A methodology for the assessment of rehabilitation success of post mining landscapes—sediment and radionuclide transport at the former Nabarlek uranium mine, Northern Territory, Australia’. Science of the Total Environment, V 354, Issues 2‐3: 103 – 119.

International Council on Mining & Metals, 2008. Planning for Integrated Mine Closure: Toolkit.

Knight Piésold Consulting, 2011. ‘Tailings Testing and Storage Facility Design/Operation’. A report to Toro Energy Limited, 28 November 2011.

Knight Piésold Consulting, 2013. Updated Monitoring Maintenance and Contingency Response Planning. A report to Toro Energy Limited, 12 February 2013.

Landloch, 2015. Millipede and Centipede Landform Stability Assessment. Unpublished Report for Toro Energy Limited. (Appendix 10‐10 of PER)

Majer JD, Brennan KEC and Moir ML, 2007a. ‘Invertebrates in ecosystem restoration: Thirty years of research in land rehabilitation following mining’. Restoration Ecology 15: 103‐114.

Majer JD, Orabi G and Bisevac L, 2007b. ‘Ants (Hymenoptera: Formicidae) pass the bioindicator scorecard’. Myrmecological News 10:69‐76.

Majer JD, 2009. ‘Animals in the restoration process – Progressing the trends’. Restoration Ecology 17: 315‐319.

McDonald R, Isbell C, Speight RF, Walker JG, Walker J and Hopkins MS, 1998. Australian soil and land survey field handbook, CSIRO Publishing, Collingwood, 190pp.

McKenzie N, Couglin K and Cresswell H, 2002. Soil physical measurement and interpretation for land evaluation. CSIRO Publishing, Collingwood.

Pereira R, Marques CR, Silva‐Ferreira MJ, Neves MFJV, Caetano AL, Antunes SC, Mendo S and Conçalves F, 2009. ‘Phytotoxicity and genotoxicity of soils from an abandoned uranium mine area’, Applied Soil Ecology, V 42, Issue 3: 209 – 220.

Prommer H, Davis JA and Douglas GD, 2015. Wiluna Uranium Project: Long Term Fate of Uranium and Vanadium – Supplementary Reactive Transport Simulations and Recommended Future Investigations. CSIRO Mineral Resources Flagship, Australia. (Appendix 10‐29 of the PER)

Queensland Department of Environment and Resource Management, 2008. Guideline 18: Rehabilitation requirements for mining projects.

Soilwater Consultants, 2012. Wiluna Uranium Project – Supplementary Modelling.

Toro Energy Limited, 2011. Environmental Review and Management Program, 21 February 2011.

Toro Energy Limited, 2015. Public Environmental Review for the Wiluna Uranium Project Extension, June 2015.

WA Chamber of Minerals and Energy, 2000. Mine Closure Guideline for Mineral Operations in Western Australia.

APPENDIX A

LEGAL OBLIGATIONS REGISTER

Condition/Commitment Source

All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas

Controlled areas of plant,

including PLS evaporation

pond, R

OM, and

mineralised m

aterial

stockpiles

Supervised areas of plant

Accommodation village at

Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap

oration ponds not in

the m

ine path

The Licensee notifying the holder of any underlying pastoral or grazing lease by telephone or in person, or by registered post if contact cannot be made, prior to undertaking airborne geophysical surveys or any ground disturbing activities utilising equipment such as scrapers, graders, bulldozers, backhoes, drilling rigs; water carting equipment or other mechanised equipment.

DMP Tenement Condition

X

The Licensee or transferee, as the case may be, shall within thirty (30) days of receiving written notification of:‐ the grant of the Licence; or registration of a transfer introducing a new Licensee; advise, by registered post, the holder of any underlying pastoral or grazing lease details of the grant or transfer.


X

No interference with Geodetic Survey Stations (various ‐ see key) and mining within 15 metres thereof being confined to below a depth of 15 metres from the natural surface


X

No excavation, excepting shafts, approaching closer to the Goldfields Highway, Highway verge or the road reserve than a distance equal to twice the depth of the excavation and mining on the Goldfields Highway or Highway verge being confined to below a depth of 30 metres from the natural surface.


X X

The Licensee submitting a plan of proposed operations and measures to safeguard the environment to the Director, Environment, DoIR for assessment and written approval prior to commencing any development or construction.


X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

The rights of ingress to and egress from Miscellaneous Licence 53/21, 22, 23, 24, 51, 62, 140 (and others) being at all times preserved to the licensee and no interference with the purpose or installations connected to the licence.


X

On the completion of the life of mining operations in relation to this licence the holder shall: remove all installations constructed pursuant to this licence; cover over all wells and holes in the ground to such degree of safety as shall be determined by the District Inspector of Mines; and on such areas cleared of natural growth by the holder or any of its agents, the holder shall plant trees and/or shrubs and/or any other plant as shall conform to the general pattern and type of growth in the area and as directed by the Environmental Officer, Department of Industry and Resources and properly maintain same until the Environmental Officer advises regrowth is self‐supporting; unless the Minister responsible for the Mining Act 1978 orders or consents otherwise.


X

All surface holes drilled for the purpose of exploration are to be capped, filled or otherwise made safe immediately after completion.


X X X X X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

All costeans and other disturbances to the surface of the land made as a result of exploration, including drill pads, grid lines and access tracks, being backfilled and rehabilitated to the satisfaction of the Environmental Officer, Department of Industry and Resources (DoIR). Backfilling and rehabilitation being required no later than 6 months after excavation unless otherwise approved in writing by the Environmental Officer, DoIR.


X

All waste materials, rubbish, plastic sample bags, abandoned equipment and temporary buildings being removed from the mining tenement prior to or at the termination of exploration programme.


X

Unless the written approval of the Director, Environment Division, DoIR is first obtained, the use of drilling rigs, scrapers, graders, bulldozers, backhoes or other mechanised equipment for surface disturbance or the excavation of costeans is prohibited. Following approval, all topsoil being removed ahead of mining operations and separately stockpiled for replacement after backfilling


X

No interference with the drainage pattern, and no parking, storage or movement of equipment or vehicles used in the course of mining within the Safety Zone established by Condition 9 hereof without the prior approval of the operators of the Gas pipeline.


X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

Compliance with the provisions of the Aboriginal Heritage Act, 1972 to ensure that no action is taken which is likely to interfere with or damage any Aboriginal site.


X

No developmental or productive mining or construction activity being commenced until the tenement holder has submitted a plan of the proposed operations and measures to safeguard the environment to the Director, Environment, DoIR for assessment; and until his written approval has been obtained.


X

Licence subject to the following conditions:1) the well must be constructed by a driller having a current class 1 water well drillers certificate issued by the WA branch of the Australian Drilling Industry Association or other certification approved by the DoW as equivalent; 2) that should the bore/s be abandoned it/they shall be sealed off to the satisfaction of DoW; 3) that the depth of the well/s shall be limited to the Fractured Rock aquifer; 4) that the bore is adequately capped and if it flows to the surface, equipped with a valve to control the flow; 5) that the bore is not permitted to run to waste; 6) that no well shall be sunk within 500m of an existing well without the written permission of the owner of that well; 7) that water drawn from the bore shall be limited to well development, test pumping and sampling.


X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

General licence commitments. Main condition 3) this licence does not authorise the sale of plant material from the following species unless specifically endorsed: Banksia hookeriana, Boronia megastigma, Corynanthera flava, Eucalyptus species taken for didgeridoos and wood products of Santalam spicatum (sandalwood).


The development and operation of the Project being carried out in such a manner so as to create the minimum practicable disturbance to the existing vegetation and natural landform.


X

At the completion of operations, or progressively where possible, all access roads and other disturbed areas being covered with topsoil, deep ripped and revegetated with local native grasses, shrubs and trees to the satisfaction of the Director, Environment Division, DoIR.


X X X X X X X

The lessee submitting to the Director, Environment Division, DoIR, a brief annual report outlining the Project operations, minesite environmental management and rehabilitation work undertaken in the previous 12 months and the proposed operations, environmental management plans and rehabilitation programmes for the next 12 months. This report to be submitted each year in March


X

At the completion of operations, all buildings and structures being removed from site or demolished and buried to the satisfaction of the Environmental Officer, DOIR, State Mining Engineer


X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

All rubbish and scrap is to be progressively disposed of in a suitable manner.


X

Causeways are to be removed upon cessation of use. DMP Tenement Condition

X

All waste materials, rubbish, plastic sample bags, abandoned equipment and temporary buildings being removed from the mining tenement prior to or at the termination of exploration programme.


X

All topsoil being removed ahead of all mining operations from sites such as pit areas, waste disposal areas, ore stockpile areas, pipeline, haul roads and new access roads and being stockpiled for later respreading or immediately respread as rehabilitation progresses.


X

All topsoil being removed ahead of mining operations and stockpiled for replacement in accordance with the directions of the District Mining Engineer.


X X X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

Licence is subject to: 1) that should the licensee's draw adversely affect the aquifer or other users in the area, the DoW may reduce the amount that may be drawn; 2) that should the drawing of water during dewatering operations adversely affect the aquifer and/or other users the DoW shall direct the licensee to take necessary action to make good the supply to the affected users; 3) in this licence the quantity of water that may be taken for authorised activities is limited to 100,000KL per water year; 4) the annual water year for water taken under this licence is defined as 12:00pm at 30 June to 12: pm 30 June 12 months later; 5) approval by DoW is to be obtained prior to the construction of additional and replacement wells and the modification or refurbishment of existing wells.


X

Rehabilitation report required. Report to include: baseline and post‐drilling radiation levels; before and after drilling photographs; samples buried in sumps (>1.5m) or down drill hole; drill holes securely plugged >400mm deep; tracks rehabilitated and access blocked; all rubbish and markers removed.


X

Ground disturbance to be minimised to reduce the risk of erosion and maximise natural rehabilitation. Comply with all tenement conditions and to securely plug and backfill to surface all drill holes and remove all sample bags within 6 months of drilling. Recommended to implement internal compliance audit programme.

Toro Documented Commitment

X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

Use of waste material from the mine immediately in backfilling operations.


X X X

Conduct prompt and progressive rehabilitation including revegetation.


X

Maintain monitoring results in an electronic data management system.


X

Provide environmental indicators, objectives and targets. Toro Documented Commitment

X

Undertake progressive rehabilitation Toro Documented Commitment

X

Project facilities strategically located to avoid disturbance where practicable.


X X X X

Ongoing water quality monitoring programmes will be established to provide a quantitative assessment of possible environmental impacts due to drainage discharge and to provide baseline data to assist in the review and improvement of operations


X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

Monitor potential impacts of altered groundwater levels and maintain acceptable levels by altering the pumping regime and/or developing alternative supplementary water supplies.


X

Establishment of drawdown trigger levels for impact on surrounding users and environmental values (i.e. Lake Way and GDEs).


X

Ongoing water quality monitoring programmes will be established to provide a quantitative assessment of possible environmental impacts due to any discharges or seepage


X X

The nominal one metre cover will be placed as rapidly as possible. Toro Documented Commitment

X X X

Monitoring of rate of rise of tailings in each TSF cell annually. Toro Documented Commitment

X

Accumulated low level waste to be disposed in tailings facility at end of mine life


X

Policy to decontaminate where practicable rather than disposal Toro Documented Commitment

X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

Establishment of an identification process to determine waste material suitable for decontamination.


X

Contaminated soils to be treated or disposed in tailings facility. Toro Documented Commitment

X

Topsoil stockpile locations to be maintained on maps and registers.


X

Potential other uses for topsoil to be investigated to avoid long term stockpiling.


X X X X X

Consultation with traditional owners. Toro Documented Commitment

X

Direct return of topsoil where possible. Toro Documented Commitment

X X X

Monitoring program implemented which should include a number of undisturbed analogue sites.


X X X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

Closure and rehabilitation plan strategies implemented. Toro Documented Commitment

X

Identify potential direct and indirect environmental impacts from waste management to the environment.


X X X

Provide environmental indicators, objectives and targets. Toro Documented Commitment

X

Implement management measures, methods and reporting and auditing and review systems.


X

Short‐term operation monitoring – this includes items such as offtake location, whether pipe joints are leaking.


X

Compliance monitoring – this includes items such as checking survey pins for movement and monitoring bores for contamination.


X

Long‐term performance monitoring – this includes such items as residue and water level surveys and water flow measurements, etc., which are used to monitor the long term performance of the facility and refine future embankment lift levels and final residue extent.


X


All

Lake

Way Pit void and

Stockpiles

Centipede / M

illipede pit

void, in pit tailin

gs storage

and stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s, Hau

l Road

s

and Lay Down Areas



pond, R

OM, and

mineralised m

aterial

stockpiles



Centipede and Lake

Maitlan

d

Borefields an

d water

pipelin

es

Evap


the m

ine path

Through negotiation of a mining agreement with Traditional Owners, provision of funding for agreed community development interests.


An annual report posted on Toro’s web site on operational, environmental and social performance – such report to be externally audited every three years.


X

APPENDIX B

CLOSURE TASK REGISTER

All Domains

Lake

Way Pit Void and

Stockpiles

Centipede/ Millipede pit

void, in pit TSF and

stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s Hau

l road

and Laydown Areas

Controlled' sections fo the

plant

Supervised

' Areas of the

Plant

Accomodation Villages

Borefield and water

distribution pipelin

es

Evap

oration Ponds if not in

mine path

Current Status and Information Gaps

Estimated Closure Date 2036 2036 2036* 2036 2036 2036 2036 2036 2036 2036

Define management domains X COMPLETED

Define impact criteria X COMPLETED

Conduct closure risk assessment X COMPLETED

Document and Maintain obligations register X COMPLETED

Collect baseline meteorological data for use in water balance, seepage and erosion assessment, air modelling

X ON GOING

Baseline soils and vegetation mapping, including weeds

X COMPLETED

Baseline soils and waste rock characterisation and physical properties

X COMPLETED

Topographic survey X TO BE COMPLETED OVER BOREFIELD AND HAUL ROAD AREAS. COMPLETED OVER MINNG AREAS

Baseline radiation monitoring X ONGOING

Establish baseline dust monitoring network X ONGOING

Baseline groundwater monitoring X X X X ONGOING

All Domains

Lake

Way Pit Void and

Stockpiles



stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s Hau

l road

and Laydown Areas


plant

Supervised

' Areas of the

Plant


Borefield and water


es

Evap


mine path



Preliminary drainage design and flood analysis

X X X COMPLETED

Preliminary closure cost estimate X COMPLETED

Stakeholder consultation X ONGOING

Training of staff X UP TO DATE FOR NOW, ONGOING IN THE FUTURE

Stakeholder capacity building X ONGOING

Review and document organisational accountabilities for rehabilitation. Communicate with staff and contractors

X INDUCTIONS TO STAFF AND CONTRACTORS ARE OCCURING

Develop rehabilitation specification for construction works and include in contract

X PRIOR TO THE ISSUE OF CONTRACTS

Finalise layout of controlled and supervised areas of plant

X TO BE COMPLETED AS PART OF DFS

Design any rehabilitation trials, icluding tecticornia trials

X X X X X TO BE FINALISED WITH CONSULTANT INPUT CLOSER TO PROJECT IMPLEMENTATION

Collect seeds for use in rehabiLiation trials X X X X X IMPLEMENTED PRIOR TO GROUND DISTRUBANCE

All Domains

Lake

Way Pit Void and

Stockpiles



stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s Hau

l road

and Laydown Areas


plant

Supervised

' Areas of the

Plant


Borefield and water


es

Evap


mine path



Train staff to recognise Project weeds X IN CURRENT INDUCTIONS

Implement weed control procedures X ONGOING

Include weed control in earthworks contracts

X TO BE FINALISED WITH CONTRACTS

Document seed lists for rehabilitation of various areas

X TO BE DONE PRIOR TO GROUND DISTURBANCE

Establish materials inventory X AT DFS

Physical characterisation of tailings X COMPLETED

Finalise tailings cover and containment strategy to meet mining proposal specifications

X DURING MINING PROPOSAL STAGE

Field testing of perimeter barriers X COMPLETED

Identify sites for use in closure (analog) X PRIOR TO GROUND DISTURBANCE

Define soil monitoring programme for stability, soil fauna and vegetation re‐establishment in rehab areas.

PRIOR TO GROUND DISTRUBANCE

Consult with stakeholders to agree on measurs of rehabilitation success

XX ONGOING

All Domains

Lake

Way Pit Void and

Stockpiles



stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s Hau

l road

and Laydown Areas


plant

Supervised

' Areas of the

Plant


Borefield and water


es

Evap


mine path



Prepare annual reporting templetes X ONGOING

Develop monitoring and reporting procedures

X ONGOING

Schedule site surveys X TO BE FINALISED CLOSER TO THE TIME

Annual survey of disturbed and rehabilitated areas

X DONE WHEN IN OPERATION

Annual complaince report to OEPA, DER and DMP

X ONGOING

Annual tailings review X DONE ONCE IN OPERATION

Annual aquifer reivew X DONE ONCE IN OPERATION

Review closure cost estimate X AT BIENNIEL PLAN REVIEW

Review materials quantities database X DONE DURING DFS

Undertaken further geochemical testing as mentioned by CSIRO

X PRIOR TO MINING PROPOSAL SUBMISSION

All Domains

Lake

Way Pit Void and

Stockpiles



stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s Hau

l road

and Laydown Areas


plant

Supervised

' Areas of the

Plant


Borefield and water


es

Evap


mine path



Review routine radiation, groundwater & air quality data and incorporate in compliance reports (as defined in relevant management strategies)

X ANNUALLY POST GROUND DISTRUBANCE

Review specialist survey schedule X TO BE COMMENCED

Schedule annual open days X TO BE COMMENCED

Schedule regulatory inspections X TO BE COMMENCED

Two year plan review X Jun‐17

Communicate closure programme to internal and external stakeholders

X TO BE COMMENCED

Prepare assests list X TO BE DONE PRIOR TO GROUND DISTURBANCE

Check status of closure taks list X ONGOING

Review disturbance and rehabilitation areas and material inventory

X ONGOING

Update closure accountabilities X TO BE DONE IN NEXT REVIEW

Conduct site contamination survey and prepare clean up schedule

X TO BE DONE DURING OPERATION

All Domains

Lake

Way Pit Void and

Stockpiles



stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s Hau

l road

and Laydown Areas


plant

Supervised

' Areas of the

Plant


Borefield and water


es

Evap


mine path



Review closure costs X IN NEXT PLAN REVIEW

Annual inspection of tailings cover integrity X TO COMMENCE ONCE IN OPERATION

Groundwater quality and level monitoring X X X X ONGOING

Reinjection recovery monitoring X TO COMMENCE AT THE CESSATION OF REINJECTION

Annual monitoring and review of radiation, vegetation, fauna and soil stability

X TO COMMENCE WHEN GROUND DISTURBANCE STARTS

Review site safety and security X TO COMMENCE WHEN GROUND DISTURBRECE STARTS

Review closure costings X BIENNIALLY

Review disturbance and rehabilitation areas and material inentory

X ONGOING

Implement employee / contractor communications strategy

X PRIOR TO PROJECT CLOSURE

Review monitoring and reporting requirements

X PRIOR TO PROJECT CLOSURE

All Domains

Lake

Way Pit Void and

Stockpiles



stockpiles

Lake

Maitlan

d Pit void and

stockpiles

Access Road

s Hau

l road

and Laydown Areas


plant

Supervised

' Areas of the

Plant


Borefield and water


es

Evap


mine path



Conduct closure environmental liability audit.

X POST PROJECT CLOSURE

Documents

Conceptual Mine closure plan final - Amazon S3 › torofiles › ... · 2015-11-13 · Processed Waste – Waste that has been used in pilot plant trials and/or has had some physical