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Rasp MineZinc – Lead – Silver Project

Project Approval No. 07-0018

January 2011

Environment Management Strategy V2

June 2012

DISTRIBUTION: CONTROLLED

REV DATEREVISION PREPARED REVIEWED APPROVED

SCOPE/PURPOSE INIT SIGN INIT SIGN INIT SIGN

1 30/3/2012 Original PB Peter Boyle

(ENVIRON) BB Brendan Barker BB Brendan Barker

2 26/4/2012

Updated for TSF2, incident reporting, removal of use of septic tanks and salt recovery investigations, and other minor modifications.

GW Gwen Wilson BJ Ben Jones TD Tony Davis

Document Owner

Environment & Community Officer Signature Ben

Jones Department SHE Date Apr 2012

Uncontrolled Document When Printed

Broken Hill Operations Pty Ltd – Rasp MineEnvironment Management Strategy

BHO-ENV-SYS-001

Table of Contents

1. Overview.....................................................................................................................................4

1.1. Purpose.............................................................................................................................4

1.2. Scope.................................................................................................................................4

1.3. Referenced Documents....................................................................................................4

1.4. Definitions........................................................................................................................4

2. Commitment and Responsibilities.............................................................................................5

3. Description of Operations..........................................................................................................9

3.1. Rasp Mine Activities.........................................................................................................9

3.2. Rasp Mine Location and Surrounding Environment........................................................9

4. Consents, Leases and Licences.................................................................................................12

4.1. Consents.........................................................................................................................12

4.2. Leases..............................................................................................................................13

4.3. Licences...........................................................................................................................13

5. Statutory Requirements...........................................................................................................14

5.1. Legislative Obligations....................................................................................................14

5.2. Project Approval Conditions...........................................................................................14

5.3. Environment Protection Licence....................................................................................16

6. Environmental Goals and Objections.......................................................................................18

7. Management of Key Environmental Risks...............................................................................19

7.1. Air Quality Control Measures.........................................................................................19

7.2. Community Lead Measures............................................................................................20

7.3. Noise Measures – Blasting Control Measures................................................................21

7.4. Noise Measures – Operations Control Measures..........................................................21

7.5. Cultural/Indigenous Heritage Control Measures...........................................................22

7.6. Water Management, Sediment and Erosion Control Measures....................................23

7.7. Traffic Management Control Measures.........................................................................23

7.8. Environmental Monitoring.............................................................................................24

8. Community Consultation, Complaints and Dispute Resolution...............................................27

8.1. Consultation....................................................................................................................27

8.2. Communication..............................................................................................................27

8.3. Community Complaints and Dispute Resolution...........................................................28



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9. Environmental Emergency Response.......................................................................................29

10. Compliance and Auditing..........................................................................................................29

11. Review......................................................................................................................................30

List of Tables

Table 1 - Major Environment ResponsibilitiesTable 2 - Key Features of the Rasp MineTable 3 - Major EquipmentTable 4 - Development ConsentsTable 5 - Mineral AuthoritiesTable 6 - Licences Held/RequiredTable 7 - Environmental ObjectivesTable 8 - Summary of Key Environmental Aspects and ImpactsTable 9 - Air Quality MeasuresTable 10 - Summary of Noise Mitigation MeasuresTable 11 - Summary of Environment Monitoring Program

List of Figures

Figure 1 - CBH Model for Environmental Management SystemsFigure 2 - Facility Organisation ChartFigure 3 - Project Site and Surrounding Area

Appendices

Appendix A – Project ApprovalAppendix B – Revised Statement of CommitmentsAppendix C – Summary of Environmental Monitoring



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1. Overview

1.1. Purpose

This environment management strategy (EMS) provides the strategic framework for environmental management at the Rasp Mine. The EMS identifies the statutory approvals that apply to the Rasp Mine, describes the role, responsibility, authority and accountability of all key personnel involved in the environmental management at the Rasp Mine, outlines the major environmental management plans and procedures to keep the local community and relevant agencies informed about the operation and its environmental performance. The EMS summarises the management of community concerns and complaints and how disputes are to be resolved. The EMS outlines BHOP response to any non-compliance and environmental emergency situation and lists the monitoring required to be carried out under the conditions of the Project Approval 07_0018.

1.2. Scope

This EMS applies to any employee or contractor engaged by BHOP and undertaking activities for the Rasp Mine, or any other agent acting on behalf of the BHOP.

1.3. Referenced Documents

Project Approval No 07_0018, granted by the Minister for the Department of Planning on the 31st January 2011 pursuant to Part 3A of the Environment Planning and Assessment Act 1979.

Environment Protection Licence 12559, Office of Environment and Heritage. Environment Assessment Report, BHOP, June 2010 and response to submissions. Preferred Project Report, BHOP, September 2010 and response to submissions. Revised Statement of Commitments, BHOP, January 2011.

1.4. Definitions

Environment Surrounding in which BHOP operates including air, water, noise, land, flora, fauna, natural resources, humans and their interactions.

Environmental Impact Any change to the environment, whether adverse or beneficial, wholly or partially resulting from BHOP activities, products or services.

Serious Potential Incident Incident, or their potential incident, that has a risk ranking greater than an 18, CBH – Incident Reporting.

JSA Job Safety Analysis, reviews the potential safety and environmental hazards and risks for a task and identifies actions to prevent injury and damage.

SOP Safe Operating Procedure, a standard work procedure determined by the outcomes of the JSA.



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2. Commitment and Responsibilities

BHOP is committed to the protection of the natural environment and achieving a high level of performance at its Rasp Mine and will manage its operations to limit the potential for adverse impacts to the environment.

As set out in the Environment Policy BHOP will to:

Comply with relevant legislation and licensing requirements Identify, assess and manage environmental risks arising from activities Set and review objectives and targets to achieve continuous improvement Prevent pollution and promote efficient use of resources Manage and dispose of waste responsibly Progressively rehabilitate, where possible, and maintain closure plans Protect natural, historic and culturally significant sites Monitor the effectiveness of environmental management systems Provide information, training and supervision to enable employees and

contractors to meet their responsibilities Hold managers, supervisors, employees and contractors accountable for their

environmental performance Communicate with the workforce, Government and local community about

environmental performance

In addition BHOP requires all persons in the workplace to: Meet their environmental obligations and responsibilities Adhere to safe work practices, instructions, rules and statutory requirements Promptly report hazards and incidents and take action to protect the

environment

BHOP is a wholly owned subsidiary of CBH Resources Pty Ltd (CBH) and as such endorses and follows the CBH corporate environment management system which is based on the following model:



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Figure 1 - CBH Model for Environmental Management Systems

The General Manager is the most senior person on site and takes overall responsibility for the EMS, its implementation, maintenance and review. Site activities – underground mining, minerals processing, concentrate despatch and maintenance are undertaken at the site.

BHOP has appointed a SHE Superintendent and an Environment & Community Officer who are responsible for day to day environmental management at the Rasp Mine.

Table 1 outlines the major environmental responsibilities of key environmental management personnel.



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Table 1 - Major Environment Responsibilities

Title Responsibility

General Manager Overall site responsibility for environmental performance and legal compliance.

Provide required resources and support to implement the EMS and associated plans, standards and procedures.

Authorise the implementation of the EMS.

Participate in annual reviews of the EMS.

Provide presentations to the Community Consultative Group.

Resolve community environmental issues (with CBH senior management where required).

Department Managers Set environmental objectives and targets

Provide resources required to implement the actions from the EMS and associated plans, standards and procedures.

Allocate responsibilities within their department for the implementation of the EMS.

Arrange and/or authorise training, including competency assessments, for personnel undertaking works in relation to the EMS.

Implement environmental control measures as required.

Investigate incidents within their department and implement corrective actions as required

Participate in annual reviews of the EMS.

Environment & Community Officer (ECO)

Prepare and maintain the EMS.

Assist in the monitoring and review of the plans, standards and procedures required to implement the EMS.

Consult with regulatory authorities as required.

Undertake or arrange environmental monitoring as required.

Maintain monitoring records.

Assist in the investigation of environmental incidents.

Provide recommendations for continual improvement of the EMS and associated procedures.

Report environmental performance via site meetings and reports, the Rasp Mine website, the AEMR, Annual Return and annual environmental reviews required by government agencies.

Report incidents to government agencies and prepare and submit written incident reports.

Provide employees and contractors with updates on environmental requirements.



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Title Responsibility

Monitoring Officer (ECO) Check monitoring equipment is correctly installed and used. Arrange maintenance and calibration of equipment as required to ensure

equipment reliability. Undertake monitoring and record results. File all electronic results from monitoring and store information on file for

a period of not less than 4 years. Report monitoring results to the Environment Coordinator.

Community Liaison Officer (ECO)

Follow up on community enquires and complaints, and close out.

Liaise with community members and provide monitoring data to the Community Consultation Group meetings, Rasp Mine newsletters and website.

BHOP Personnel and Contractors

Participate in training to implement the standards and procedures for noise and vibration management as required to maintain competency levels.

Follow the procedures to implement the EMS in your area.

Figure 2 - Facility Organisation Chart

Commercial Superintendent

Senior Environment &

Community Officer

SHE Manager

Senior Mining Engineer

Mine Maintenance

Superintendent

Operations Manager

Mining Superintendent

Technical Services Superintendent

Safety Officers

Emergency Service Officers

Manager Metallurgy

Electrical Superintendent Electrical Engineer

Senior Plant Metallurgist

Mill Maintenance Superintendent

MillSuperintendent

Mechanical Engineer

Senior HR Officer

Health Coordinator

EnvironmentOfficer

General Manager



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3. Description of Operations

3.1. Rasp Mine Activities

The Rasp Mine undertakes the following activities on CML7:

mining of 8,450,000 tonnes (t) of ore:- 7,200,000 t from underground mining in the Western Mineralisation and Centenary Mineralisation; and- 1,250,000 t from underground mining of Main Lode Pillars off the Rasp Decline;

transport of ore to the surface in haul trucks;

ore processing using crushing, milling and flotation to produce zinc and lead concentrates;

tailings management, including emplacement at Blackwood Pit (TSF2) as well as providing back fill for underground mining voids; and

operation of a rail spur to transport concentrate in lidded containers by rail to a port / smelter.

3.2. Rasp Mine Location and Surrounding Environment

The Rasp Mine is located within Consolidated Mine Lease 7 (CML7) which includes underground and surface lease areas. Surface exclusion areas within CML7 do not from part of the Rasp Mine. CML7 occupies a central region of the Broken Hill Line of Lode orebody, approximately 3.8 km long and 1.2 km wide (Figure 4) CML7 incorporates the original mine areas that commenced operations in the 1880s, including Broken Hill Pty Ltd (BHP).

The Rasp Mine is located centrally within the City of Broken Hill and is surrounded by transport infrastructure, areas of commercial and industrial development and some residential housing. The CML7 is bounded by Eyre Street and Holten Drive to the south and east, Menindee Road (MR 66) to the northeast, Crystal and Argent Streets to the north, and South Road (Silver City Highway SH 22) to the west. These roads form part of the existing trucking route through Broken Hill. The Broken Hill railway station is located directly to the north of the mine and lies on the main Sydney – Perth railway line. Residential and commercial areas are located to the west, north and south of the Rasp Mine, Perilya mine developments to the east (North Mine) and west (Southern Operations) and the Mawsons Quarry to the east. These features are shown on Figure 4.

Broken Hill is renowned as one of Australia’s foremost mining cities and is the largest regional centre in the western half of NSW. In general, the region is dominated by urban development within the City of Broken Hill, cattle and sheep grazing beyond the city limits and extractive industries including mines and quarrying. With the exception of the Line of Lode and its associated waste dumps the surrounding landform is a rejuvenated undulating peneplain.



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Figure 3– Project Site and Surrounding Area



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Table 2 – Key Features of the Rasp Mine

Perilya MineLease Area

Rail Loadout

Processing Plant

ROM

TSF2

Kintore Pit

WorkshopsOffices

MawsonsQuarry

Western Mineralisation

Main Lode Pillars

Portal

Railway Station

Perilya MineLease Area

CML7 Boundary



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Item Description

Mine life 15 years (includes construction and closure)

Tenement status CML7 – Incorporates the Rasp Mine.

Approval period 15 years comprising construction, underground mining, processing operations and closure.

Approval granted 31st January 2011 to 31st December 2026.

Mining methodology Underground mining using various methods including long hole, benching, modified Avoca, room and pillar or uphole retreat.

Mining rate and total production

750 000 tpa ore.

Total production over life of Project: Approximately 8,450,000 t

Waste rock disposal Underground: Backfill

Surface: Inert material to be used for road repair and bunding and rehabilitation at closure

Processing methodology Crushing, grinding, flotation, thickening and filtration at on-site processing facilities.

Processing rates 250 tph in crushing plant and 93.8 tph in grinding plant.

Concentrate production Lead: 44,000 tpa (concentrate 73% Pb and 985 g/t Ag)

Zinc: 87,000 tpa (concentrate 50% Zn)

Tailings disposal Fine tailings disposal (approximately 320,000 tpa) TSF2 Blackwood Pit

Coarse tailings disposal (approximately 320,000 tpa) as underground stope back fill.

Services Extensions to existing substations, water lines and phone lines.

22kV overhead powerlines.

Table 3 -Indicative Major Equipment

3 Mine trucks 50 t

2 Prime movers 64 t

2 forklifts 35 t

2 front end loaders 6 m3

2 diesel tanks 70,000 l

2 substations 11 kVA

In addition there will be one primary crusher, 1 SAG and 1 ball mill, 2 underground mine ventilation fans, 23 light vehicles and 1 locomotive.



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4. Consents, Leases and Licences

4.1. Consents

Table 4 presents the consents held by BHOP.

Table 4 - Development Consents

Approval Number Date Issued Duration Purpose

DA 125/2001

5 Sept 2002 Work completed

Surface drilling on CML7 in surface exclusion zone (near rail), supported by a SEE.

MOP 06/6463

26 Oct 2006 31 Aug 2008 Construct exploration decline, conduct drilling and obtain bulk sample, supported by a REF.

MOP Amendment 06/6436

5 May 2008 31 Oct 2009 Extend the exploration decline.

MOP 06/6463

16 Dec 2009 31 Dec 2010Extended to 31

March 2011

For underground mining and stockpiling 120,000 tpa, supported by a REF.

MOP 06/6463

1 April 2011 31 Mar 2014 For underground mining, construction and processing of ore and despatch of concentrate by rail, supported by an EAR and PPR.

DA 101/2007 26 April 2007 Work completed

Undertake temporary mining in the Kintore Pit, supported by a SEE.

DA 264/2009

19 Jan 2010 2 Feb 2011Works not

undertaken

For ancillary surface mining activities including crushing, stockpiling and transport of ore, supported by a SEE.

Part 3A Application

07_0018

31 Jan 2011 31 Dec 2026 Mining production of 750,000 tpa from Western Mineralisation, Centenary Mineralisation and Main Lode Pillars. Construction and operation of a minerals processing plant and rail loadout facility.Supported by an EAR.

MOP

06/6483

1 April 2011 31 March 2014 Mining production of 750,000 tpa from Western Mineralisation, Centenary Mineralisation and Main Lode Pillars. Construction and operation of a minerals processing plant and rail loadout facility.

Supported by an EAR prepared for DoPI Part 3A Project Approval.

Part 3A Project Approval

Amendment

March 2012 31 Dec 2026 Relocation of ventilation shaft. Supported by an environment assessment.

MOP

06/6463

March 2012 31 March 2014 Relocation of ventilation shaft. Supported by an environment assessment.

4.2. Leases



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Table 5 summarises the mineral authorities held by BHOP in the vicinity of the Rasp Mine. For the purposes of this document, the area covered by CML7 and MPLs 183, 184, 185 and 186 within the surface area rights of BHOP, is referred to as the “Rasp Mine”.

Table 5 - Mineral Authorities

MineralAuthority Grant Date Last Renewed Renewal Date Holder Purpose

CML7 8 Oct 1987 17 Jan 2007 31 Dec 2026 BHOP

As per Schedule 2 of the Lease Open cutting, shaft sinking, stoping, tunnelling, building of dams, extraction and obtaining minerals, generation of electricity, erecting dwellings, storage of fuels, dumping of ore, treatment and dumping of tailing, development of roads (Annexure 1)

MPL 183 4 Feb 1981 24 Apr 2007 31 Dec 2026 BHOP Dumping of ore and mine residues, treatment of tailing




EL 5818 8 Mar 2001 7 Mar 2011 7 Mar 2013 BHOP Surface disturbing works such as drilling and soil sampling

4.3. Licences

Table 6 presents the licences held and proposed by BHOP in relation to the Rasp Mine.

Table 6 - Licences Held/Required

Licence / Permit Issued By Relevant Date Purpose

EPL 12559 DECCW2 Nov

Anniversary date

Mining and processing up to 500,000tpa.This Licence has been varied to incorporate construction activities.

Dangerous Goodsand Explosives

NotificationWork Cover 23 Feb 2012

Expiry

Storage and use of dangerous goods.

Water extraction NOW 29 March 2017

Water extraction from Shaft 7 and underground mine dewatering for site use and use by Perilya – CML5.

Radiation DECCW 18 July 2014Sell and/or possess radiation apparatus

Sell and/or possess radioactive or items containing radioactive substances.

TSF1 Dam Safety Committee

May 2011Approved

As TSF1 will not be used for tailings deposition DSC approval was not



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Licence / Permit Issued By Relevant Date Purpose

progressed.

5. Statutory Requirements

5.1. Legislative Obligations

The key reference documents for environmental legal obligations related to the Rasp Mine include the following Acts and their respective regulations:

Mining Act 1992 Protection of the Environment Operations Act 1997 Protection of the Environment Legislation Amendment Act 2011. Environment Planning and Assessment Act 1979 Protection of the Environment Administration Act 1991 Water Act 1912 Water Management Act 2000 Contaminated Land Management Amendment Act 2008 Soil Conservation Act 1938 Local Government Act 1993 Explosives Act 2003 OHS Amendment (Dangerous Goods) Act 2003 Dams Safety Act 1978 Broken Hill Local Environment Plan 1996 Broken Hill Development Control Plan No 11 Management of Lead Contamination

5.2. Project Approval Conditions

The Rasp Mine project approval was granted by the Minister for the Department of Planning and Infrastructure (DoPI) under Part 3A of the Environment Planning and Assessment Act 1979. The Project Approval 07_0018 permits the construction and operation of a processing plant, underground mining and for these operations to continue until 31 December 2026 (Appendix A). It allows for a maximum of 750,000 tonnes of ore to be extracted per annum, or more than 8,450,000 tonnes of ore over the life of the mine. It requires BHOP to undertake these mining activities in line with the Environment Assessment (June 2010), the subsequent Preferred Project Report (September 2010) the response to submissions and the BHOP Statement of Commitments.

The following summarises the major requirements of Project Approval:

No offensive odours to be emitted from the site (as defined under the Protection of the Environment Operations Act 1997 (POEO Act)).

BHOP to take all reasonable and feasible measures to minimise the release of greenhouse gas emissions from the site.



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BHOP to take all reasonable and feasible avoidance and mitigation measures so that particulate matter emissions generated by the project do not cause an exceedance of listed criteria.

That certain roads be sealed. Ore crushing to be undertaken in a fully-enclosed structure that is designed, operated

and maintained to ensure internal negative internal air pressure relative to ambient (external) conditions, minimising fugitive emissions from the structure.

Application of a chemical dust suppressant on ‘free areas’ of the site. Enclosure of all above ground conveyors and transfer points prior to the grinding

circuit. Video equipment to be installed on TSF1 to monitor for dust generation. A reasonable contribution towards the cost of public health monitoring, particularly in

relation to child blood lead levels; and public education campaigns about the health risks associated with lead.

Updated human health risk assessment within one year of the commencement of operations and every five years thereafter.

Operational restrictions - Construction activities to be undertaken only between 7:00am and 7:00pm on any day;- Crushing shall only occur between 7:00am and 7:00pm on any day;- Shunting of concentrate wagons shall only occur between 7:00am and 6:00pm on any day; and- Production rock blasting shall only occur between 6:45am and 7:15pm on any day.

BHOP to undertake noise control measures so as not to cause an exceedence of the listed criteria.

BHOP to undertake blasting control measures so as not to cause an exceedence of the listed criteria.

BHOP to comply with Section 120 of the POEO Act prohibiting the pollution of waters. BHOP shall ensure sufficient water for all stages of the project, and if necessary, adjust

the scale of mining operations to match its water supply. Maintain at least 66 car parking spaces on site. BHOP to consult with BHCC and RTA in regards to modifications to Eyre Street

footpath access, heavy vehicle entry and parking, and use of Holten Drive for site access.

BHOP to commission dilapidation reports for roads likely to be affected by the construction.

From the end of June 2012 and annually thereafter, environmental reviews to be completed and submitted to the DoP.

Undertake revisions of strategies, plans and programs and submit to the DoP within 3 months of an Annual Review, Incident Report, Audit Reports and any Project Approval modifications.

Report incidents to the DoP with a written report within 7 days.



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Provide regular reporting of performance and provide other information as listed on the Rasp Mine website.

Conduct an independent environmental audit by the end of December 2011 and every three years thereafter.

In addition the Project Approval requires the following environmental management plans:

This Environment Management Strategy (EMS), this document An Air Quality Management Plan (AQMP), including air quality monitoring. A Community Lead Management Plan (CLMP) A Noise and Blasting Management Plan (NBMP), including noise and blasting

monitoring A Site Water Management Plan (SWMP), including surface and ground water

monitoring A Traffic Management Plan (TMP) A Conservation Management Plan (CMP) A Waste Management Plan (WMP) A Rehabilitation Environment Management Plan (REMP)

Broken Hill Operations Pty Ltd has made a number of commitments for managing potential environmental impacts of the Rasp Project. The draft Statement of Commitments originally provided in Section 18 of the EAR and amended in the Preferred Project Report (PPR) has been revised to address the issues raised in the responses to submissions.

The revised Statement of Commitments details the measures proposed by BHOP for environmental mitigation, management and monitoring of the Rasp Project.

This revised Statement of Commitments forms part of the Project Approval granted 31 January 2011 by the Department of Planning and is included at Appendix B.

5.3. Environment Protection Licence

Broken Hill Operations Pty Ltd holds a current Environment Protection Licence 12559 from the Office of Environment and Heritage. The Licence provides for crushing, grinding or separating to 2Mt and mining to a maximum of 2Mt.

The following provides a summary of Licence conditions:

Undertake monitoring for dust, surface and ground water at listed locations for listed parameters and meet listed criteria.

Prevent pollution of waters in compliance with section 120 of the Protection of the Environment Operations Act 1997.

Not to take waste from outside the premises or allow waste generated at the premises to be disposed at the premises except as permitted by the Licence.

Undertake crushing activities only during the period 7.00am to 7.00pm on any day.



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Only allow shunting of wagons to occur between 7.00am and 6.00pm on any day. Undertake production rock blasting only between 6.45am and 7.15pm on any day. Undertake construction activities only between 7 am and 7 pm on any day. Meet noise criteria as listed. Meet blasting and overpressure criteria as listed. Not to cause any offensive odour from the premises. Carry out activities in a competent manner. Maintain and operate plant and equipment in a proper and efficient manner Prevent dust emission from the premises. Cover the loads of any ore trucks entering or leaving the premises. Immediately suppress any visible dust emissions from the TSF by water or chemical

suppressant. Operate the crusher enclosure under negative pressure at all times when in operation

and minimise any fugitive emissions. Include dust management practices in the air Quality Management Plan that

effectively minimise dust emissions. Maintain water storage ponds to ensure sedimentation does not reduce capacity by

more than 10% of the design capacity. Undertake weather monitoring at the listed location for listed parameters. Maintain monitoring records for 4 years and provide to an EPA officer upon request. Record pollution complaints and maintain these records for 4 years and provide to an

EPA officer upon request. Establish and maintain a complaints line for the public, providing notification of the

number and its purpose. Provide (and retain) an annual return to the EPA including a summary of monitoring

results, statement of compliance and any public complaints made during the period. Notify the EPA of incidents causing or threatening to cause environmental harm (131

555) and provide written reports as required. Keep a copy of the Licence on the premises and make available to an EPA officer

and/or employee on request.



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6. Environmental Goals and Objections

The overall objectives for environmental management are outlined in the Environment Policy. Table 7 provides a summary of objectives for a number of key environmental areas.

Table 7 - Environmental Objectives

Issue Goal Objectives

Air To maintain current air quality standards.

To comply with air quality criteria as listed in the Project Approval and EP Licence, as verified by monitoring.

To implement air quality control measures as outlined in the Air Quality Management Plan.

To receive minimal community complaints, which are addressed promptly and satisfactorily, and reported as required.

To report and address any non-compliances.

Lead To have no adverse impact on blood lead levels of the community.

To assist the community in raising awareness about managing lead in the environment.

To use measures to minimise dust emissions.

To support community blood lead level monitoring programs.

Noise To maintain an acceptable noise amenity for surrounding neighbours.

To use measures to minimise noise emissions.

To monitor and meet noise emission criteria and EP Licence conditions.

To promptly address any complaints relating to noise from the general public and report as required.

To report and address any non-compliances.

Water To prevent pollution and contamination to surrounding lands.

To use measures to prevent water discharge.

To reduce the risk of oil or chemical contamination of surface / groundwater.

To reduce sediment runoff.

Emergency response

To quickly and effectively minimise adverse impacts to the environment associated with an emergency situation.

To provide training and equipment to enable a quick and effective response to environmental emergencies including spillages.

Heritage To retain the maximum possible value of cultural mining heritage located on CML7.

To prevent demolition wherever possible of listed heritage buildings and structures.

To adaptively reuse heritage buildings where possible.

To conserve heritage buildings and structures where possible.



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7. Management of Key Environmental Risks

Table 8 lists the key environmental risks and references the section of the EAR where the risks are assessed and control measures outlined. A summary of measures to control these risks is also provided below.

Table 8 - Summary of Key Environmental Aspects and Impacts

Potential key Environmental Risks Plan Reference

Deterioration of air quality from the generation of airborne dust AQMP, REMP

Loss of containment of airborne dust from TSF1 and TSF2 AQMP

Increase in greenhouse gas emissions AQMP

Community health impacts related to exposure to lead bearing dust CLMP

Noise from operations NBMP

Vibration impacts to local buildings from blasting and rail activities NBMP

Disturbance of significant heritage sites CMP, REMP

Surface water runoff leads to off-site contamination SWMP, REMP

Decrease in the water supply to the City of Broken Hill SWMP

Reduction in groundwater flow and availability affecting other groundwater users SWMP

Seepage from TSF impacts on local residents SWMP

Increase in traffic volume CTMP

7.1. Air Quality Control Measures

The activities that have the potential to generate dust or impact on air quality are listed in Table 9 together with a general description of the environmental management measures.

Table 9–Summary of Air Quality Control Measures

Operation Control

Earthworks Water sprays / sprinklers, water truck and managing potentially dust generating activities during windy conditions.

Waste and ore stockpiles

Sprinkler systems are used to regulate water content and aid dust suppression. Chemical dust suppressants will also be used in traffic areas.Restricted height of ROM stockpile.Installation of static wind breaks (oriented perpendicular to the dominant wind direction) along with top-mounted water sprays.

Crushing Enclosed structure vented to a baghouse.

Haulage operations Haul roads will be sealed.

Traffic movement Main roads will be sealed and other roads coarse rolled gravel. Water



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sprinklers have been installed on all haul roads from the workshop to the Kintore Pit and down the Pit ramp. Chemical suppressant1 to be used on unsealed roads.Service roads and tip points around the ROM stockpile will be laid with compacted road base.Installation of vehicle wash facilities for all vehicles that have entered the mine site.Limitation of vehicles in exposed ‘free’ areas.Undertaking sampling to quantify road surface silt loadings on an ongoing basis.Use of street sweeper.

Concentrate Maintaining a moisture content level around 9 percent.

Concentrate loading operations

Installation of vehicle wash facilities for all vehicle and container prior to delivery to rail loading/storage area.

Conveyors Full enclosure of all conveyors and transfer points prior to the milling circuit.

Tailing storage There will be a number of levels of dust management at the tailing storage facilities including:

- embankments to be constructed with waste rock which is moisture conditioned prior to placement and water sprays during placement

- water sprays to be installed along the roadway during the movement of waste rock

- the moisture content of the tailing and cycling frequency between cells

- the use of chemical dust suppressants1

- water sprinkler system- water truck

Video equipment will be installed at TSF2 when the tailing level increases to a level where there is potential dust generation from the Pit. This provide continuous surveillance in the control room for operators.

‘Free areas’ The use of chemical dust suppressants1.Maintenance of surface crust to minimise potential for wind erosion.Limitation of work access to ‘free’ areas.Removal of fine material, particularly in water storage basins, or capping with waste rock.

Greenhouse gases Complete energy audit to compare predicted and actual energy consumption by 31 December 2011.

Note1 Where a different chemical dust suppressant is used than those included in the EAR BHOP will conduct a new health assessment and forward this to Greater Western Area Health Service and NSW Health for approval prior to its use.

7.2. Community Lead Measures

Consistent with the Project Approval BHOP will continue to contribute to a Lead Awareness and Impact Management Strategy developed in consultation with the Lead Reference Group, including the NSW Department of Health (Greater Western Area Health Service) and BHCC.

BHOP has prepared a Community Lead Management Plan for the Project which outlines measures to prevent adverse health impacts to the local community. The Plan also outlines BHOP contribution to the public health monitoring program, particularly in relation to child blood



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lead levels, and tracking of this data over time; and to public education campaigns about the health risks associated with lead, including lead hygiene, lead and children, tank water lead risks and soil lead contamination risks.

This Plan also identifies additional reasonable and feasible measures that could be implemented either on site or in the areas adjoining the site to minimise the potential lead impacts of the project and “free areas”; includes a program for the staged implementation of the measures identified in the event that dust emissions are higher than predicted or the public health monitoring suggests further action is required to reduce blood lead levels in the environment surrounding the site; and includes a detailed communication strategy, that outlines how the relevant dust and blood level monitoring data will be reported on the Rasp Mine website.

BHOP will engage a suitably qualified expert to update the human health risk assessment within 1 year of commencement of operations and subsequently every 5 years of operations thereafter.

7.3. Noise Measures – Blasting Control Measures

A Noise Blasting Management Plan and a Monitoring Protocol - Vibration and Overpressure have been developed to provide employees with an understanding of their responsibilities and requirements for noise control on site.

Blast management is optimised through the following measures:

The use of blast noise and overpressure absorption barriers to minimize noise and blast overpressure at lease boundaries.

Stemming of development blast holes to minimize noise and blast overpressure.

Provision of a contact telephone number via which the public may seek information or make a complaint, and

Maintenance of a log of complaints, to be acted upon by the site environmental manager in a responsive manner.

Maintaining the Blasting Vibration and Overpressure Log.

Continuation of the blasting vibration and overpressure monitoring program.

Blasts will be monitored for ground vibration to establish more appropriate and specific data. Monitoring will include the time, date, charge mass, location and blasting technique used.

7.4. Noise Measures – Operations Control Measures

The activities that have the potential to generate noise impacts are listed in Table 10 together with a general description of the environmental management measures.



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Table 10 - Summary of Noise Mitigation Measures

Operation Control

Earthworks Restricted to between 7am and 7pm, any day.

Blasting Smaller stope designs to reduce blast vibrations.Designing blasts and arranging firing times to minimise potential community impacts.Prohibiting production rock blasting between 7.15pm and 6.00am

Ventilation fans Relocated underground.

Waste and ore stockpiles

4 m high bunding along the southern perimeter of the ROM pad

Crushing circuit Limiting operations to between 7.00am and 7.00pm, on any day.Enclosing the crusher and installing noise abatement bunding to the north and south of the crusher.

Haulage operations Installation of noise abatement bunding along roadways.

Traffic movement 4 m high bunding along the southern side of the haul road.Silencers to be installed on haul trucks.Noise suppression kits to be installed on the front end loaders.

Processing plant Re-located to the north-eastern end of the site, away from residentialdwellings to the south.

Grinding circuit Locating the SAG and ball mills behind the flotation building, shielding the noise generated.

Flotation Locating the flotation circuit within a building.

Concentrate Filters will be housed in a clad building.

Concentrate loading Limiting rail shunting of rail wagons to between 7.00am and 6.00pm, on any day.Installation of overlapping 4 m bunds at the northern side of the rail wagon container storage area to shield Crystal Street residences.

Conveyors Full enclosure of all conveyors and transfer points prior to the milling circuit.

7.5. Cultural/Indigenous Heritage Control Measures

The development of a Conservation Management Plan will provide a strategic framework for all heritage items located on CML7 and under the control of BHOP. The Plan will be based on the principles of the Burra Charter, and developed in consultation with the Office of Environment and Heritage and the BHCC.

Other control measures adopted include:

The remnant timber square-set stopes in the northern section of the western wall of the Kintore Pit will be retained in situ where possible.

The remnant timber stopes in the lower portion of the Kintore Pit access way will be retained and protected in situ if possible.



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Works will cease immediately upon the discovery of any indigenous or non-indigenous relics and the OEH and the NSW Heritage Office will be notified. Work will only re-commence following clearance by appropriate authorities.

7.6. Water Management, Sediment and Erosion Control Measures

BHOP has a Stormwater Management Plan (SWMP) which addresses surface water and erosion control. The goal of the SWMP is to retain stormwater runoff from a 100 year ARI rainfall event from all active mine areas. The primary water control feature of the SWMP is the provision of small ponds / storages spread throughout the Rasp Mine that temporarily hold surface water runoff. Due to high evaporation rates this runoff evaporates in a relatively short period following storm events. This arrangement prevents runoff from leaving the active mine site and allows the suspended particles to settle in the ponds /storages allowing better management of contaminated sediment on site. This Plan will:

Outline the site’s water balance detailing water sources, use and management. Provide water storage areas designed to prevent discharges of surface waters from the

new active mine areas including the processing plant and rail siding. Minimise disruption to mining activities and provide a safe working environment. Identify erosion and sediment control measures. Outline a water monitoring program, including parameters to be monitored, for:

- water from mine dewatering- groundwater locations to the east of TSF1- surface water represented by Horwood Dam- water captured by the toe drains of the tailings storage facility- water seepage from the tailings storage facility and- the background local groundwater system

Detailed design for the relocated processing plant and rail siding have recently been completed and will now be incorporated into the updated Water Management Plan.

7.7. Traffic Management Control Measures

A Traffic Management Plan has been prepared in consultation with the RTA and BHCC. Consistent with the Project Approval the Plan focuses on traffic management during construction of the Project, particularly in relation to access and egress from the site. The Plan forms part of the Construction Environment Management Plan. This Plan has now been updated for operations.

BHOP will maintain at least 66 car parking spaces on site at all times.

BHOP has consulted with the RTA and BHCC in regards to modifications required at Eyre Street for site access and has established spaces for B-Doubles and semitrailers to park on site and avoid parking in Eyre Street.

Where access is required to Holten Drive BHOP will consult with RTA and BHCC over its use.



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BHOP prepared a Dilapidation Report for roads that may be impact during the construction period and submitted to BHCC. A subsequent report will be repeated following construction and any repairs undertaken, at BHOP cost, and following consultation with the RTA and BHCC.

7.8. Environmental Monitoring

The environmental monitoring program at the Rasp Mine includes noise and blast monitoring, air monitoring for dust and lead bearing dust, and groundwater monitoring around the tailings storage facilities.

Monitoring protocols have been established describing the roles, responsibilities, procedures, recording and reporting requirements for this monitoring.

Monitoring results are provided to department managers assisting in identifying areas for improvement, included in annual environment reports to government agencies and are summarised on the Rasp Mine website.

Monitoring records will be kept for a minimum of 4 years.

Appendix C provides a summary of the monitoring program.

8. Community Consultation, Complaints and Dispute Resolution

8.1. Consultation

BHOP has established a communication forum with local major stakeholders. This forum assists in developing constructive relationships and promoting a higher level of understanding between the parties.

The aims of this forum are to:

Keep stakeholders informed of the Project and its progress; Maximise the level of accurate information provided to stakeholders; Engage in meaningful dialogue to source ideas and opinions; Identify potential issues and collect stakeholder views; Obtain and provide feedback; Listen to and acknowledge stakeholder concerns; and Broaden a higher level of knowledge about the Project with stakeholders.

Members of this Community Consultative Group include representatives from:

Greater Western Area Health Service; Chamber of Commerce; local union organisations; Outback Area Consultative Committee; Flying Doctor Service; Broken Hill City Council Aboriginal community; and



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South Broken Hill residents.

The Consultative Group meets at least twice per year, or as required and when members are available. Presentations are provided outlining current and proposed activities at the Rasp Mine and environmental performance, including monitoring results. Feedback is sought from members and the groups they represent.

8.2. Communication

In addition to the Community Consultative Group BHOP provides advice of activities through a newsletter which is distributed by a letter box drop to local neighbours.

BHOP has also established a website for the Rasp Mine and consistent with the Project Approval conditions makes copies of the following publicly available:

BHOP Environment Policy; EAR and accompanying studies; Response to submissions received for the EAR; PPR and accompanying studies; Response to submissions received for the PPR; Project Approval; BHOP Statement of Commitments; Complaints register; Monitoring data required under the Project Approval conditions, and when approved Environment management strategies, plans and programs required under the Project

Approval conditions.

Annual environmental reviews of the Rasp Mine and independent audits together with BHOP’s response to any recommendations made will also be posted on this website.

8.3. Community Complaints and Dispute Resolution

A complaint may be made in writing or by telephone.

All complaints are to be immediately passed to the Community Liaison Officer who shall record the complaint on the Complaints Form and in the Complaints Register.

Where this person is not on site, complaints shall be passed to the most senior manager of the Rasp Mine who shall:

(i) Record the complaint on the Complaints Form,(ii) Notify the Community Liaison Officer as soon as possible, and (iii) Forward the Complaints Form to the Community Liaison Officer to record in the

Complaints Register and follow up actions and feedback.

Where Rasp Mine personnel are not on site, the Site Duty Supervisor shall be responsible for recording information and determining:



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(i) If the environmental issue can be the result of any activities carried on at the Rasp Mine or on behalf of BHOP

(ii) The seriousness of the complaint,(iii) If the complaint can be easily resolved,(iv) The action to be taken, and(v) The need to immediately notify the Community Liaison Officer.

Where action is taken by the Site Duty Supervisor notification must be made to the Community Complaints Officer as soon as possible on the next working day. In these cases the Site Duty Supervisor will be responsible for collecting information from the complainant and completing the Complaints Form and forwarding this form to the Community Liaison Officer.

Information about the environmental issue and the complaint are recorded in the Complaints Register and reported internally to senior management (BHOP and CBH) and to external government agencies (OEH, DRE, BHCC and/or DoPI) and when required.

In the event of a disagreement between BHOP and a member of the community, the Community Liaison Officer and Environmental Coordinator, and as necessary the BHOP Operations Manager and / or CBH Chief Operations Manager and Managing Director, will work to resolve the issue. Where necessary external assistance may be sought to resolve the issue, this may include the Community Consultative Group, technical expertise and/or local government agencies.

9. Environmental Emergency Response

BHOP has an Emergency Response Plan that was developed primarily for safety and extends to environmental emergencies. This Plan outlines organisational responsibilities, actions, reporting requirements (both internal and external) and resources available to enable an effective and timely response to emergency situations.

The emergency situations have been identified through a risk assessment process.

Rasp Mine personnel are trained in emergency response procedures which are reinforced through tool box talks and participation in emergency training scenarios.

Site procedures also address spill response to ore, concentrate and hydrocarbon spills.

10. Compliance and Auditing

Compliance with all approvals, plans and procedures is the responsibility of all personnel and contractors employed on or in association with the Rasp Mine with the Operations Manager holding overall accountability.



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Departments are responsible for undertaking regular audits and inspections which are verified by the Environment Coordinator. The Environment Coordinator assists in identifying any remediation / rectification work required, and areas of actual or potential non-compliance.

Any non-compliance or potential non-compliance with regulations, licences or approvals are reported to the relevant authority, together with details of the corrective actions taken to avoid future occurrences.

Non-compliances with the requirements of the Rasp Mine EP Licence are reported each year via the Annual Return.

A review the Rasp Mine’s compliance with all conditions of the Project Approval, mining lease and all other approvals and licences is undertaken yearly as part of the Annual Environment Management Report (AEMR) submitted to Mineral Resources. The AEMR is also provided to BHCC, relevant government agencies, and will be provided to the Director General – Department of Planning and Infrastructure as a condition of approval to provide an annual environment performance report.

Additionally, an independent environmental audit will be undertaken by the end of December 2011 and then once every three years and the report submitted to the Director-General – Department of Planning and Infrastructure. The independent audit will be undertaken by an appropriately certified auditor in accordance with ISO 19011:2002 “Guidelines for Quality and/or Environmental Systems Auditing” and ISO 14011 or equivalent updated versions of these guidelines. This report and BHOP’s response to any recommendations shall also be posted on the Rasp Mine website.

11. Review

The EMS will be reviewed biennially or where there are significant changes to the site’s operations. The annual review will reconsider the risks presented by waste, options to reduce the waste generated, changes in reuse and recycling local opportunities.



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Appendix A - Project Approval

Appendix B - Revised Statement of Commitments

Appendix C- Summary of Environment Monitoring Program

EPA ID BHOP ID Environment Factor

Parameter Frequency Location

1 Vent Shaft Dust - Oxides of Nitrogen (as NO2)-Total solid particles (TSP)- Volatile organic compounds- Sb, As, Cd, Pb, Hg, Be, Cr, Co, Mn, Ni, Se, V

Real time Ventilation Shaft

2 Process Enclosure/ Baghouse

Stack

Dust - Total solid particles (TSP)- Total - Sb, As, Cd, Pb, Hg, Be, Cr, Co, Mn, Ni, Se, V

Real time Process Plant Enclosure

3 D1 Dust Insoluble solids, Lead Monthly St Johns Enclosure

4 D2 Dust Insoluble solids, Lead Monthly Block 10 Hill5 D3 Dust Insoluble solids, Lead Monthly Thompsons

Shaft6 D4 Dust Insoluble solids, Lead Monthly Brown’s No 1

Residence7 D5 Dust Insoluble solids, Lead Monthly Silver Tank8 D6 Dust Insoluble solids, Lead Monthly Casuarina

Ave9 D7 Dust Insoluble solids

LeadMonthly Blackwood

Pit10 TSP-HVAS Dust Total Suspended Particulate,

Lead on filter paperEvery 6 days Silver Tank

11 PM10-HVAS1

Dust PM10, Lead on filter paper Every 6 days Silver Tank

12 PM10-HVAS2

Dust PM10, Lead on filter paper Every 6 days Blackwood Pit

13 TEOM 1 Dust PM10, Wind Speed/Direction Continuous Essential Water Enclosure

14 TEOM 2 Dust PM10, Wind Speed/Direction Continuous Blackwood Pit

29 SW2, SW3 Surface Water

pH, EC, TDS, SO4, Cl, Na, Cd, Pb, Mn, Zn

When contain water (at least 2 per 12 mths)

S31-1, S31-2

30 SW4 Surface Water



S44




S49



When contain water (at least

S1-A



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2 per 12 mths)33 SW6, SW7 Surface

WaterpH, EC, TDS, SO4, Cl, Na, Cd, Pb, Mn, Zn


S9B-1, S9B-2




Horwood Dam

35 Upstream Monitoring Location 1

Surface Water


When flowing (at least 2 per 12 mths)

Creek near airport

36 Downstream Monitoring Location 2

Surface Water


When flowing (at least 2 per 12 mths)

Creek crossing on Menindee Rd

37 GW01 Groundwater pH, EC, TDS, SO4, Cl, Ca, Mg, Na, Fe, Cd, Pb, Mn, Zn

Quarterly Mt Hebbard


Quarterly Mt Hebbard


Quarterly Roadside to Horwood Dam






Quarterly Roadside to HorwoodDam




Quarterly Eyre Street Dam


Quarterly Eyre Street Dam


Quarterly Adjacent to Eyre Street Dam


Quarterly Adjacent to Blackwood Pit


Quarterly Adjacent to Blackwood Pit


Quarterly Near existing slag heap


Quarterly Near existing slag heap


Quarterly Near rail load out facility


Quarterly Near Ryan Street/ S49



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53 Shaft 7 discharge

Groundwater pH, EC, TDS, SO4, Cl, Ca, Mg, Na, Fe, Cd, Pb, Mn, Zn

Quarterly From Shaft 7 collected in S22

54 Kintore Pit discharge

Groundwater pH, EC, TDS, SO4, Cl, Ca, Mg, Na, Fe, Cd, Pb, Mn, Zn

Quarterly From mine dewatering collected in S22

- R1 Noise Leq, 15min/Lperiod Continuous Blackwood Pit

A1 N1 Noise Leq, 15min/DayLeq, 15min/EveningLeq, 15min&Lmax/Night

Quarterly Piper Street North


Quarterly Adjacent to 322 Eyre St


Quarterly 500 Crystal St


Quarterly West of Quarry entrance


Quarterly Resident 18

V1 V1 Airblast Overpressure & Ground Vibration

dBmm/ second

Continuous Silver Tank


dBmm/ second

Continuous Scrap metal yard Crystal Street


dBmm/ second

Continuous Air Express yard