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Mining Proposal Page 88 Sorby Management Pty Ltd November 2011 Soil contaminated by incidental hydrocarbon spills will be removed and placed in a purpose built bioremediation facility. The Contaminated Sites Management Series guideline Bioremediation of hydrocarbon-contaminated soils in Western Australia (DEC, 2004) will be used to guide the construction and operation of this facility. Clean soil, once validated, will be reused on site. To ensure the impacts from hydrocarbon use are minimised, management measures will be incorporated into the Sorby Hills Construction and Operational EMPs. The specific strategies that will be implemented are shown in Table 4-11: Specific Management Strategies in relation to Hydrocarbons to be adopted at the Sorby Hills. Table 4-11: Specific Management Strategies in relation to Hydrocarbons to be adopted at the Sorby Hills Project Aspect Management Strategy Procedures and Training Incorporate hydrocarbon use procedure into the Sorby Hills CEMP and OEMP as required. Provide a suitable level of training to staff and contractors identified to be involved in hydrocarbon management to ensure they are aware of KBL’s requirements for use, storage and disposal. Ensure spill response equipment is available and procedures are communicated effectively to staff involved with hydrocarbon use in their work areas. Development of an incident management system, with corrective action processes, to facilitate continuous improvement of hydrocarbon storage, handling and disposal. Refuelling Ensure diesel generators are bunded. Install bund and collection sump at the vehicle refuelling area Develop procedures for refuelling of mobile equipment. Storage Storage of hydrocarbons to be in accordance with AS/NZS 1940:2004 Self bunded fuel storage tank to be installed. Oils and lubricants to be installed in weatherproof sea container. An inventory of hydrocarbons and quantities will be maintained and reported to the appropriate authority, as required. Regular inspections of storage areas will be conducted to identify any leaks or issues with hydrocarbon storage areas. MSDSs will be located at storage areas and will be regularly maintained. Disposal Recycle waste oil and oily rags wherever possible. Develop a bioremediation facility to treat contaminated soil in situ 4.10 Dangerous Goods and Hazardous Substances Management The use of dangerous goods and hazardous substances is required for the operation of the Sorby Hills Mine Site. Appropriate licences and requirements of the Dangerous Goods Safety Act 2004 (WA) (Dangerous Goods Safety Act) will be implemented wherever necessary. SMPL and all its contractors responsible for handling and storing concentrate will be required to obtain a Dangerous Goods Licence under the Dangerous Goods Safety (Storage and Handling of Non Explosives) Regulations 2007. Drivers of any vehicles transporting containers carrying SMPL concentrate will be required to obtain a Dangerous Goods Drivers Licence under the Dangerous Goods Safety (Road and Rail Transport of Non-explosives) Regulations 2007. All relevant actions undertaken at Wyndham Port must comply with the Dangerous Goods Safety Act, specifically the Dangerous Goods Safety (Goods in Ports) Regulations 2007. Port operators are currently guided by the International Maritime Dangerous Goods Code (IMDG Code) administered by the United Nations International Maritime Organisation (IMO). The Goods in Port Regulations

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Soil contaminated by incidental hydrocarbon spills will be removed and placed in a purpose builtbioremediation facility. The Contaminated Sites Management Series guideline Bioremediation ofhydrocarbon-contaminated soils in Western Australia (DEC, 2004) will be used to guide theconstruction and operation of this facility. Clean soil, once validated, will be reused on site.

To ensure the impacts from hydrocarbon use are minimised, management measures will beincorporated into the Sorby Hills Construction and Operational EMPs. The specific strategies thatwill be implemented are shown in Table 4-11: Specific Management Strategies in relation toHydrocarbons to be adopted at the Sorby Hills.

Table 4-11: Specific Management Strategies in relation to Hydrocarbons to be adopted at the SorbyHills Project

Aspect Management Strategy

Procedures and Training Incorporate hydrocarbon use procedure into the Sorby Hills CEMP andOEMP as required.

Provide a suitable level of training to staff and contractors identified to beinvolved in hydrocarbon management to ensure they are aware of KBL’srequirements for use, storage and disposal.

Ensure spill response equipment is available and procedures arecommunicated effectively to staff involved with hydrocarbon use in theirwork areas.

Development of an incident management system, with corrective actionprocesses, to facilitate continuous improvement of hydrocarbon storage,handling and disposal.

Refuelling Ensure diesel generators are bunded.

Install bund and collection sump at the vehicle refuelling area

Develop procedures for refuelling of mobile equipment.

Storage Storage of hydrocarbons to be in accordance with AS/NZS 1940:2004

Self bunded fuel storage tank to be installed.

Oils and lubricants to be installed in weatherproof sea container.

An inventory of hydrocarbons and quantities will be maintained andreported to the appropriate authority, as required.

Regular inspections of storage areas will be conducted to identify any leaksor issues with hydrocarbon storage areas.

MSDSs will be located at storage areas and will be regularly maintained.

Disposal Recycle waste oil and oily rags wherever possible.

Develop a bioremediation facility to treat contaminated soil in situ

4.10 Dangerous Goods and Hazardous Substances Management

The use of dangerous goods and hazardous substances is required for the operation of the SorbyHills Mine Site. Appropriate licences and requirements of the Dangerous Goods Safety Act 2004(WA) (Dangerous Goods Safety Act) will be implemented wherever necessary.

SMPL and all its contractors responsible for handling and storing concentrate will be required toobtain a Dangerous Goods Licence under the Dangerous Goods Safety (Storage and Handling ofNon Explosives) Regulations 2007. Drivers of any vehicles transporting containers carrying SMPLconcentrate will be required to obtain a Dangerous Goods Drivers Licence under the DangerousGoods Safety (Road and Rail Transport of Non-explosives) Regulations 2007.

All relevant actions undertaken at Wyndham Port must comply with the Dangerous Goods SafetyAct, specifically the Dangerous Goods Safety (Goods in Ports) Regulations 2007. Port operators arecurrently guided by the International Maritime Dangerous Goods Code (IMDG Code) administeredby the United Nations International Maritime Organisation (IMO). The Goods in Port Regulations

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require Port operators to comply with Australian Standard AS 3846-2005 (which is based on theIMDG Code).

The Australian Dangerous Goods Code (ADGC) and other international dangerous goods codes(such as the IMDG Code) require that goods be assigned a dangerous goods class according to themost significant risk presented by the goods, as determined by the criteria set out in the code.The dangerous goods classification applicable to the concentrate produced at the Sorby Hills MineSite has been determined by Toxikos Toxicology Consultants. The concentrate was analysed forboth freshwater and seawater effects. As a result of the analysis the following dangerous goodsclassifications have been determined:

Class 6.1 lead compound, soluble, N.O.S (UN 2291, packaging group III) for the purpose ofroad and rail transport; and

Class 9 miscellaneous dangerous good, environmentally hazardous substance (chroniccategory II) for the purpose of marine transport.

Using the freshwater LC50 (lethal concentration) of 138µg/L for Daphnia magna the Sorby Hillconcentrate is not classifiable as an Environmentally Hazardous Substance for the purpose of roador rail transport. However, using the EC50 (effective concentration) of 105µg/L for Chaetoceros sp.,the concentrate has a subsidiary environmental hazard classification for marine environments.Further detail on the dangerous goods classification of the Sorby Hills concentrate is included asAppendix 26.

The use of reagents and process chemicals will be managed to mitigate contamination. Bunded,purpose built storage and reagent handling facilities will be incorporated into the Process Plantand specific handling and storage procedures for developed, which include spill response. Aproposed design has been undertaken by BGRIMM and is included as Appendix 19.

Fireproof Dangerous Goods cabinets will be installed in the workshop, laboratory and processplant; they will be clearly signposted and be noted on site emergency plans. There will be aninventory system in place to record stocks of hazardous material and up-to-date MSDSs kept forall hazardous substances that will possibly be used on the site. Segregation requirements will beconsidered when storing dangerous good and hazardous materials.

Gas cylinders will be stored in appropriate dedicated areas and procedures will be in place for thehandling and storage of gas cylinders.

Explosives will be stored in an explosives magazine in compliance with the Explosives andDangerous Goods Act, the Dangerous Goods Safety (Explosives) Regulations 2007 and AustralianStandard AS 2187.1:1998, Explosives – Storage, transport and use, Part 1. Explosives will be storedremote from the mine site and process plant.

All personnel who will handle dangerous goods, hazardous substances, gas cylinders or explosiveswill all be adequately trained.

Specific measures to reduce the impacts of dangerous goods on site are included in

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Table 4-12: Specific Management Strategies in relation to Dangerous Goods and HazardousSubstances to be adopted at the Sorby Hills.

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Table 4-12: Specific Management Strategies in relation to Dangerous Goods and HazardousSubstances to be adopted at the Sorby Hills Project

Aspect Management Strategy

Use Develop procedures on the handling and storage of dangerous goods onsite, incorporating spill response requirements.

Provide a suitable level of training to staff and contractors identified to beinvolved in dangerous goods use, storage and disposal to ensure they areaware of SMPL’s requirements and procedures.

Storage Specifically designed, labelled storage areas will be identified and installed,with consideration to segregation requirements.

A stock inventory will be maintained.

Appropriate fire response equipment will be located near storage areas.

Regular inspections of storage areas will be conducted.

Transport “Rotabox” containers to be individually inspected prior to transport off site

Unforseen concentrate spill during transport should be included in the SiteEmergency Plan.

Disposal Disposal of dangerous goods and hazardous materials will be in accordancewith MSDSs and any requirements from DEC.

4.11 Atmospheric Pollution and Noise

As there are no neighbouring receptors to the Sorby Hills Project site, dust and noise impacts areexpected to be low. Atmospheric pollutants such as odours and gas emissions will also benegligible. Some aspects of the Sorby Hills Project, such as crushing and processing, will operateon a 24hr basis and as such lighting will be required which may be visible from the Weaber PlainRoad. To ensure light impacts do not pose a safety issue for traffic travelling within the vicinity,SMPL will ensure that all lighting is directed inwards at the site. This will most likely result in a“glow” being visible from the Weaber Plain Road rather than direct light; therefore no lightemission impacts are expected.

Although the Sorby Hills Project is a drill and blast operation, blasting will only be conducted atdesignated blast times during dayshift and will not be undertaken in unfavourable conditions (e.g.high wind speed) or unfavourable wind directions relative to sensitive premises such asadministration buildings therefore reducing dust and noise impacts.

As the mining fleet is relatively small, consisting of an excavator and four haul trucks, along withauxiliary equipment the noise generated from the mining fleet is expected to be negligible.

The site power plant will consist of five fixed 500kW diesel generator sets running the plant,workshops and offices. There will also be two mobile generators for dewatering requirements.These generators will have modern noise suppression devices attached, thus minimising the noiseemissions.

The key noise impact for the operation will be from concentrate haulage through the Kununurraand Wyndham townships. Noise will be mitigated through the application of speed restrictionsand a ban on exhaust braking within the towns and ensuring vehicles are regularly maintained toreduce noise generation. In addition, concentrate haulage trucks will only operate during daylighthours. Dust generation resulting from concentrate haulage is expected to be minimal; all loadswill be carried in fully sealed containers and speed restrictions will be applied through Kununurraand Wyndham.

Dust generation on site will predominantly be associated with blasting, extraction, haulage,stockpiling and crushing activities. Management measures for dust will significantly reduce any

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potential impacts to the surrounding environment. Dust suppression will be carried out on siteutilising a water truck; any areas that have mobile equipment operating and have the potential tocreate dust will be adequately watered to minimise dust generation. The water truck will alsospray the ROM and stockpiles as required. Dust suppression systems will exist on the crusher andprocess conveyors to minimise dust. Concentrate will also fall straight from the filter press intotransport containers and will not be stored in stockpiles, thus mitigating excessive dustgeneration.

An onsite dust sampling program has been established for the Sorby Hills Project, utilising dustdeposition gauges. Analysis is undertaken monthly in the dry season; dust monitoring locationsare presented in Figure 4-5: Sorby Hills Project Dust Monitoring Sites. In addition, visualmonitoring of dust will be regularly conducted and activities will be halted if adverse conditionslead to excessive dust generation.

To minimise generation of other atmospheric pollutants, plant and equipment will be regularlymaintained to ensure they operate at maximum achievable efficiency. The rural landfill site will beregularly covered in accordance with requirements of the Environmental Protection (RuralLandfill) Regulations 2002 to ensure excessive odours are not produced.

Specific measures to reduce the impacts from atmospheric pollution and noise on site areincluded in Table 4-13: Specific Management Strategies in relation to Atmospheric Pollution andNoise to be adopted at the Sorby Hills Project.

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Auth: T.Smith Project: SMPL Sorby Hills Figure 4-5: SMPL Sorby Hills dust monitoring

sites

Date: October 2011 Datum: GDA94

MGA Zone 52

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Table 4-13: Specific Management Strategies in relation to Atmospheric Pollution and Noise to beadopted at the Sorby Hills Project

Aspect Management Strategy

Noise Ensure vehicles, plant and equipment are serviced and maintained tosystem requirements to avoid unnecessary noise and implement noisemitigation measures where appropriate.

Ensure generators are serviced and maintained to system requirements.

Apply speed restrictions and a ban on exhaust braking for concentratehaulage trucks whilst travelling through the Kununurra and Wyndhamtownships to reduce noise impacts.

Concentrate haulage trucks to operate only during daylightHrs.

Dust Incorporate dust management into the Sorby Hills CEMP and OEMP,including inspection and notification requirements and suppressiontechniques to be employed (primarily water spray).

Dust generating activities (such as blasting) will not be undertaken duringunfavourable weather conditions.

Ensure stockpiles, roads, laydown areas, tipping areas and car parks areadequately dampened to reduce dust impacts.

Establish a system of regular visual monitoring for dust, halt activities ifdust exceeds acceptable levels until conditions alter.

Personal dust monitoring of staff members in higher risk work areas to beundertaken as part of the Health Surveillance Program.

Establish photographic monitoring points of vegetation adjacent to highdust generating sources.

Continue dust sampling program.

Apply speed restrictions for concentrate haulage trucks whilst travellingthrough Kununurra and Wyndham to reduce dispersion of roadside dust.

All concentrate loads to be carried in fully sealed and locked containers.

Odour Waste material will be covered in accordance with the schedule identifiedin Section 6 of the Environmental Protection (Rural Landfill) Regulations2002. For the Sorby Hills Mine Site it is anticipated that waste pits will becovered monthly.

Light Ensure lighting is directed inwards to avoid visual impacts to surroundingtraffic.

Consultation Continue stakeholder consultation throughout the life of the project

All complaints regarding excessive noise generation will be investigated andmitigating measures implemented where required.

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5 SOCIAL IMPACTS

5.1 Heritage

The Sorby Hills project site lies within the traditional lands of the Miriuwung Gajerrong people.Although the Sorby Hills tenements pre-date the Native Title Act 1993 (Native Title Act), aHeritage Protection Agreement was developed between the previous owners of the Sorby Hillstenements and the MG Corporation, as part of this agreement SMPL will develop an IndigenousLand Use Agreement (ILUA) with the MG Corporation. SMPL is committed to providing contractingopportunities, employment and training for Traditional Owners.

Ethnographic and archaeological surveys have been conducted of the proposed infrastructure andmining areas that will be disturbed during the development of the project. These surveys wereconducted with the full participation of the Miriuwung Gajerrong people. It was identified duringthese surveys that no impacts to any heritage sites should occur, as no sites were identified withinthe survey areas.

A register of stakeholder consultation, including indigenous stakeholders, is incorporated intoAppendix 17.

The Sorby Hills Mine Site has no National or World Heritage significance.

5.2 Land Use and Community

The Sorby Hills Mine Site is located on unallocated crown land and was previously part of apastoral lease.

The town of Kununurra is the closest township to the Sorby Hills project, being 50km south-westof the site by road; another significant community in the region is Wyndham which isapproximately 160km north-west of Sorby Hills. There are a further 42 small Indigenouscommunities in the region (Strategen, 2011). SMPL will contribute to these communities byproviding employment and contracting opportunities. SMPL is also a generous contributor tocommunity fundraising initiatives.

5.3 Workforce Induction and Training

SMPL will have a complete Induction & Training program that is endorsed by management andcoordinated on site by the Safety, Health Environmental and Community (SHEC) Coordinator. TheSHEC program will incorporate all induction and training policies, procedures and competencies,along with the environmental controls on site. Training requirements of specific roles will beperiodically reassessed and training packages will be regularly reviewed and updated to maintainrelevance.

Training will be incorporated into the Sorby Hills SHECMS.

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6 MINE CLOSURE

Mine closure planning is an essential aspect of the Sorby Hills Project. The key objective of SMPLis to leave the community with a site that is stable, non-polluting and able to support pastoralactivities. The intended final land use is pastoral.

SMPL has identified the following five domains within the Sorby Hills project area:

Plant Site

TSF

Pit area

Haul and access roads

Landfill.

Upon closure the Plant Site will be decommissioned, infrastructure removed and reshaped toblend with the adjacent topography, the TSF will be capped to provide a Store and Release cover,pits will remain open with the flood bund being extended to provide an abandonment bundaround the voids, the landfill with be covered and haul roads and other disturbed areas will beripped and re-contoured. Soil will be respread over disturbed areas and vegetation debris placedon top to provide microhabitats and reduce erosion effects.

Further details of mine closure concepts are included in the Sorby Hills Project Mine Closure Plan,included as Appendix 27.

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7 REFERENCES

Australian Government (2011). Australian Natural Resources Atlashttp://www.anra.gov.au/topics/vegetation/extent/wa/ibra-pilbara.html accessed March 2011.

Beard, J.S. (1975) Pilbara – The Vegetation of the Pilbara Area 1: 100,000 Vegetation Series.University of W.A. Press, Perth.

Canadian Council of Ministers of the Environment (1999) Canadian environmental qualityguidelines - Canadian soil quality guidelines for the protection of environmental and humanhealth: Thallium. Canadian Council of Ministers of the Environment, Winnipeg.

DEC, 2004. Contaminated Sites Management Series – Bioremediation of HydrocarbonContaminated Soils in WA.

Department of Agriculture and Food (2009). Rangeland Land System Mapping for WesternAustralia dataset.

Department of Agriculture and Food (2011) Declared Plants List.http://agspsrv95.agric.wa.gov.au/dps/version02/01_plantsearch.asp (accessed August 2011).

Fox, I. D., Neldner, V. J., Wilson. G.W. and Bannink, P.J. (2001) The Vegetation of the AustralianTropical Savannas. Environmental Protection Agency, Brisbane.

Keighery, B.J. (1994). Bushland Plant Survey. A guide to plant community survey for thecommunity. Wildflower Society (Inc.), Western Australia.

McKenzie, N.L., Start, A.N., Burbidge, A.A., Kenneally, K.F. and Burrows, N.D. (2009). Protectingthe Kimberley; a synthesis of scientific knowledge to support conservation management in theKimberley region of Western Australia. Part B: Terrestrial environments. Department ofEnvironment and Conservation.

Moro, D. (2001) Evaluation and cost-benefits of controlling house mice (Mus domesticus) onislands: an example from Thevenard Island, Western Australia. Biological Conservation 99(3): 355– 364.

Stratagen (2011). Ord River Irrigation Area Weaber Plain Development Project Draft;Environmental Impact Statement. Landcorp.www.dsd.wa.gov.au/documents/ORIA_Weaber_Plain_EIS.pdf

Strategic Design + Development Pty Ltd (2010). “Freight and Logistics Services in the EastKimberley Region” (unpublished report).

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8 APPENDICES

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Appendix 1: Certificate of Incorporation and Joint Venture Agreement

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Appendix 2: Crown Land Lot 373 on Deposited Plan 51355

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Appendix 3: Geological Cross Section for D Pod and E Pod

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Appendix 4: Geochemical Characterisation Report

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Appendix 5: The Sorby Hills Pre-Mine Soils Characterisation Report

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Appendix 6: Surface Water and Flood Assessment

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Appendix 7: Hydrogeological Assessment for the Sorby Hills Project Ore Bodies

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Appendix 8: Flora Survey Report

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Appendix 9: Terrestrial Fauna Assessment describing Non-Volant Vertebrate Fauna

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Appendix 10: Ornithological Assessment describing all Avifauna Species

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Appendix 11: Echolocation Survey to describe Bat Species Present

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Appendix 12: Subterranean Fauna Assessment Data

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Appendix 13: Aboriginal Heritage Desktop Analysis

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Appendix 14: DIA Heritage Register search results

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Appendix 15: Archaeological and Ethnographic Surveys

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Appendix 16: Written Correspondence from MG Corporation

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Appendix 17: Stakeholder Consultation Register and Public Communication

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Appendix 18: Monthly Mine Schedule for D pod for the First 2 Years of Operation

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Appendix 19: Proposed Design of Purpose Built storage and Reagent HandlingFacilities (BGRIMM)

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Appendix 20: Rock Mechanics Analysis (Mount Isa Mines Ltd; 1979)

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Appendix 21: MSDS data for Processing Reagents and Chemicals

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Appendix 22: Planned use of “Rotabox” Containers

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Appendix 23: Proposed Sorby Hills Project Organisational Structure

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Appendix 24: KBL Environmental Policy

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Appendix 25: Construction Environmental Management Plan

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Appendix 26: Dangerous Goods Classification – Sorby Hills Project Concentrate

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Appendix 27: Sorby Hills Project Mine Closure Plan