mt jackson j1 deposit mine closure plan -...

Cliffs Asia Pacific Iron Ore Pty Ltd

Yilgarn Operations MT JACKSON J1 DEPOSIT MINE CLOSURE PLAN Yilgarn Mineral Field 77 Tenements M77/993, M77/994, M77/1248, M77/1249, L77/216 Revision 1 November 2012

Cliffs Asia Pacific Iron Ore Pty Ltd Level 12, 1 William Street PERTH WA 6000

GPO Box W2017 PERTH WA 6846

Yilgarn Operations Cliffs Asia Pacific Iron Ore Pty Ltd Mt Jackson J1 Mine Closure Plan November 2012 (Revision 1)

Page i

Revision Author Distribution Date Status

Revision A M. Barendrecht J. Nielsen 16 Nov 2010 Draft for

internal review

Revision B J. Nielsen P. West, R. Howard, J. Shepherdson

S. Hawkins 7 Jun 2011

Draft for

internal review

Revision C J. Nielsen P. West, J. Shepherdson, D Wright 26 Jul 2011 Draft for

internal review

Revision 0 J. Nielsen Environmental Protection Authority Department of Mines and Petroleum

5 Oct 2011 Public Release

Revision 1 N. Harry Environmental Protection Authority 1 Nov 2012 Public Release


Page ii

DMP MINE CLOSURE PLAN CHECKLIST

Q No Mine Closure Plan Checklist Y/N/NA Page No Comments

Contact Details

1 Has the Checklist been endorsed by a senior representative within the tenement holder / operating company?

Y iv Refer to endorsement at the bottom of this checklist

2 How many copies were submitted to the DMP? Hard copies = Two

Electronic copies = Two

Cover Page, Table of Contents

3

Does the cover page include:

Project Title;

Company Name;

Contact Details;

Document ID and version number;

Date of submission?

Y Cover page

Contact details are also provided in Section 2.4

4 Has a Table of Contents been provided? Y v

Scope and Project Summary

5 Why is the MCP submitted? Y 4 Section 1.4

6

Does the project summary include:

Land ownership details;

Location of the project;

Comprehensive site plans;

Background information on the history and status of the project?

Y

Y

Y

Y

5

5

9-10

7

Section 2.3

Section 2.2

Figures 2.1 and 2.2

Section 2.1

Legal Compliance

7 Has a consolidated summary or register of closure obligations and commitments been included?

Y 12 Section 3

Table 3.1

Data Collection and Analysis

8

Has information relevant to mine closure been collected for each domain or feature (including pre-mining baseline studies, environmental and other data)?

Y 17

67

Section 4;

Attachment 1

9 Has a gap analysis been conducted to determine if further information is required in relation to closure of each domain or feature?

Y 20 Section 4.4

Stakeholder Consultation

10 Have all stakeholders involved in closure been identified?

Y 21 External stakeholders listed in Table 5.1

11

Have a summary or register of stakeholder consultation been provided, with details as to who has been consulted and the outcomes?

Y 22

75

Section 5.3

Attachment 2


Page iii


Final Land Use(s) and Closure Objectives

12 Does the Mine Closure Plan include proposed end land-use(s), closure objectives and conceptual landform design diagram?

Y 23

27-29

Section 6

Figures 6.1 to 6.3

13

Does the Mine Closure Plan identify all potential (or pre-existing) environmental legacies, which may restrict the post-closure land use (including contaminated sites)?

Y 79 Attachment 3 assesses closure-related risks.

Identification and Management of Closure Issues

14 Does the Mine Closure Plan identify all potential issues impacting mine closure objectives and outcomes?


15 Does the Mine Closure Plan include proposed management or mitigation options to deal with these issues?


16 Have the process, methodology and rationale been provided to justify identification and management of the issues?

Y 30 Section 7

Attachment 3

Closure Criteria

17 Does the Mine Closure Plan include a set of specific closure and closure performance indicators?

Y

31

34-55

Section 8 outlines Cliffs’ iterative process for developing realistic closure criteria.

Sections 10.3 to 10.6 provide interim closure criteria for each mine site Management Unit.

Closure Financial Provision

18

Does the Mine Closure Plan include costing methodology, assumptions and financial provision to resource closure implementation and monitoring?

Y 33 Summary presented in Section 9.2.

19 Does the Mine Closure Plan include a process for regular review of the financial provision?

Y 33 Section 9.1

Closure Implementation Programs

20

Does the reviewed Mine Closure Plan include a summary of closure implementation strategies for the proposed operations or for the whole site?

Y 34

34-55

Section 10.1 summarises the Closure Implementation program and Sections 10.3 to 10.6 provide a Closure Implementation Plan for each mine site Management Unit.

21 Does the Mine Closure Plan include a closure work program for each domain or feature?

Y 38-55

Sections 10.3 to 10.6 provide a closure implementation program for each mine site Management Unit.

22 Have site layout plans been provided to clearly show each type of disturbance?

Y 38-55

Sections 10.3 to 10.6 provide site layout plans for each mine site Management Unit.


Page iv


23 Does the Mine Closure Plan contain a schedule of research and trial activities?

Y 34-55 Incorporated into the Closure Implementation Program in Section 10.

24 Does the Mine Closure Plan contain a schedule of progressive rehabilitation activities?


25 Does the Mine Closure Plan include details of how unexpected closure (including care and maintenance) will be handled?

Y 57 Section 10.7

26 Does the Mine Closure Plan contain a schedule of decommissioning activities?


27 Does the Mine Closure Plan contain a schedule of closure performance monitoring and maintenance activities?


Closure Monitoring and Maintenance

28

Does the Mine Closure Plan contain a framework, including methodology, quality control and remedial strategy for closure performance monitoring including post-closure monitoring and maintenance?

Y 58

58-60

Section 11

Tables 11.1 and 11.2

Closure Information and Data Management

29

Does the Mine Closure Plan contain a description of management strategies including systems and processes for the retention of mine records?

Y 61 Section 12

30 Confidentiality Y 33 Section 9

Table 9.1

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

Signed:

Name: Paul West

Position: Manager Environmental Services

Date: 1st November 2012


Page v

TABLE OF CONTENTS

DMP MINE CLOSURE PLAN CHECKLIST ............................................................................... II

1. INTRODUCTION ........................................................................................................... 1

1.1 YILGARN OPERATIONS ......................................................................................................... 1

1.2 REHABILITATION AND CLOSURE SYSTEM ............................................................................. 3

1.3 SCOPE ................................................................................................................................. 4

1.4 PURPOSE ............................................................................................................................. 4

2. PROJECT SUMMARY ..................................................................................................... 5

2.1 LOCATION ........................................................................................................................... 5

2.2 OWNERSHIP ........................................................................................................................ 5

2.3 CONTACT DETAILS ............................................................................................................... 6

2.4 PROJECT DESCRIPTION ........................................................................................................ 7

2.5 MINE CLOSURE MANAGEMENT UNITS ................................................................................. 11

3. CLOSURE OBLIGATIONS AND COMMITMENTS .......................................................... 12

4. REHABILITATION AND CLOSURE DATA ..................................................................... 17

4.1 SUMMARY OF ENVIRONMENTAL CHARACTERISTICS ............................................................ 17

4.2 MINING DATA .................................................................................................................... 19

4.3 POST-MINING DATA ........................................................................................................... 19

4.4 KNOWLEDGE GAPS ............................................................................................................. 20

5. STAKEHOLDER CONSULTATION ................................................................................. 21

5.1 STAKEHOLDER IDENTIFICATION ........................................................................................ 21

5.2 CONSULTATION PROCESS .................................................................................................. 22

5.3 CONSULTATION TO DATE ................................................................................................... 22

6. POST-MINING LAND-USE AND CLOSURE OBJECTIVES ............................................. 23

6.1 POST-MINING LAND-USE .................................................................................................... 23

6.2 CLOSURE OBJECTIVES ........................................................................................................ 23

6.3 FINAL LANDFORM DESIGN CONCEPT .................................................................................. 24

7. IDENTIFICATION AND MANAGEMENT OF CLOSURE ISSUES ..................................... 30

8. COMPLETION CRITERIA ............................................................................................. 31

8.1 DEVELOPMENT OF COMPLETION CRITERIA ......................................................................... 31

8.2 INTERIM COMPLETION CRITERIA ....................................................................................... 31

8.3 REFERENCE SITES .............................................................................................................. 32

9. FINANCIAL PROVISION FOR CLOSURE ..................................................................... 33

9.1 METHODOLOGY FOR MAINTAINING FINANCIAL PROVISIONS .............................................. 33

9.2 MT JACKSON J1 DEPOSIT FINANCIAL PROVISIONS .............................................................. 33

10. CLOSURE IMPLEMENTATION ..................................................................................... 34

10.1 CLOSURE IMPLEMENTATION PROGRAM .............................................................................. 34


Page vi

10.2 CLOSURE IMPLEMENTATION PLANS .................................................................................... 34

10.3 MINE PITS MANAGEMENT UNIT .......................................................................................... 38

10.4 WASTE ROCK LANDFORM MANAGEMENT UNIT .................................................................... 41

10.5 INFRASTRUCURE AREA MANAGEMENT UNIT ....................................................................... 46

10.6 HAUL ROAD MANAGEMENT UNIT ........................................................................................ 51

10.7 GENERAL REHABILITATION AND CLOSURE ACTIVITIES ....................................................... 56

10.8 UNPLANNED CLOSURE ........................................................................................................ 57

11. MONITORING AND MAINTENANCE ............................................................................ 58

12. INFORMATION MANAGEMENT ................................................................................... 61

13. REFERENCES .............................................................................................................. 62

14. ABBREVIATIONS ........................................................................................................ 64

ATTACHMENTS .................................................................................................................... 65

ATTACHMENT 1 BIBLIOGRAPHY RELEVANT TO REHABILITATION AND

CLOSURE OF MT JACKSON J1 DEPOSIT MINING OPERATIONS ................................ 67

ATTACHMENT 2 STAKEHOLDER CONSULTATION REGISTER RELATING TO

REHABILITATION AND CLOSURE OF THE MT JACKSON J1 PROJECT ........................ 75

ATTACHMENT 3 ENVIRONMENTAL ASPECTS REGISTER - MT JACKSON J1

MINE CLOSURE RISK AND OPPORTUNITY ASSESSMENT .......................................... 79


Page vii

FIGURES

Figure 1.1 Location of Cliffs’ Yilgarn Operations ........................................................................ 1 Figure 1.2 Location of the Mt Jackson J1 Deposit in relation to Cliffs’ Yilgarn

Operations ............................................................................................................. 2 Figure 1.3 Overview of Cliffs Rehabilitation and Closure System ................................................ 3 Figure 2.1 Layout of the Mt Jackson J1 Deposit mining and infrastructure areas......................... 9 Figure 2.2 Location of the Mt Jackson J1 Deposit mine and haul road ...................................... 10 Figure 6.1 Mt Jackson J1 Deposit conceptual post-mining landform design (looking

towards the north-west) ....................................................................................... 27 Figure 6.2 Mt Jackson J1 Deposit conceptual post-mining landform design (looking

towards the south-west) ....................................................................................... 28 Figure 6.3 J1 Waste Rock Landform construction design ......................................................... 29 Figure 8.1 Cliffs’ process for developing site-specific completion criteria (adopted

from Nichols 2010) ............................................................................................... 32 Figure 10.1 J1 Mine Pits Management Unit .............................................................................. 38 Figure 10.2 J1 Waste Rock Landform Management Unit ........................................................... 41 Figure 10.3 J1 Infrastructure Area Management Unit ................................................................ 47 Figure 10.4 J1 Haul Road Management Unit ............................................................................ 51

TABLES

Table 2.1 Mt Jackson J1 Deposit management units for rehabilitation and closure planning and implementation ................................................................................ 11

Table 3.1 Obligations and commitments pertaining to rehabilitation and closure of

the Mt Jackson J1 Deposit mining operations ......................................................... 12 Table 4.1 Summary of Mt Jackson J1 Deposit pertinent environmental

characteristics ...................................................................................................... 17 Table 5.1 Cliffs’ external stakeholders ................................................................................... 21 Table 6.1 Cliffs’ mine closure objectives ................................................................................ 24 Table 6.2 Waste rock classification ....................................................................................... 25 Table 9.1 Mt Jackson J1 Project Closure Provisions................................................................ 33 Table 10.1 Summary of Mt Jackson J1 Project Closure Implementation Program ....................... 36 Table 10.2 Mt Jackson J1 Project Mine Pits Management Unit Completion Criteria ..................... 40 Table 10.3 Mt Jackson J1 Project Waste Rock Landform Management Unit

Completion Criteria ............................................................................................... 44 Table 10.4 Mt Jackson J1 Project Infrastructure Area Management Unit Completion

Criteria ................................................................................................................ 49 Table 10.5 Mt Jackson J1 Project Haul Road Management Unit Completion Criteria ................... 53 Table 10.6 General rehabilitation and closure activities applicable to the Mt Jackson

J1 Deposit mining operations ................................................................................ 56 Table 11.1 Overview of rehabilitation and closure monitoring .................................................. 58 Table 11.2 Closure objectives, completion criteria and related monitoring

methodology ........................................................................................................ 59


Page 1

1. INTRODUCTION

1.1 YILGARN OPERATIONS

Cliffs Asia Pacific Iron Ore Pty Ltd’s (Cliffs) Yilgarn Operations includes mine operations at

the Koolyanobbing Range, Mt Jackson Range, Windarling Range and the Deception Deposit,

ore processing at Koolyanobbing, and road and rail transport between these operations and

the Port of Esperance where the processed ore is exported to international customers. The

regional location of Cliffs’ Yilgarn Operations is shown in Figure 1.1. The location of the Mt

Jackson J1 Deposit in relation to other parts of Cliffs’ Yilgarn Operations is shown in

Figure 1.2.

Figure 1.1 Location of Cliffs’ Yilgarn Operations


Page 2

Figure 1.2 Location of the Mt Jackson J1 Deposit in relation to Cliffs’ Yilgarn

Operations


Page 3

1.2 REHABILITATION AND CLOSURE SYSTEM

Cliffs’ Rehabilitation and Closure System (RCS) (Cliffs 2010a) (Figure 1.3) provides the

framework for planning and implementing progressive rehabilitation and mine closure across

its entire Yilgarn Operations. This Mine Closure Plan (MCP) is one of a series of plans that

outlines how Cliffs manages the rehabilitation and closure aspects of its Yilgarn Operations.

It details the management actions that Cliffs will implement in relation to rehabilitation and

closure of the Mt Jackson J1 Deposit mining operations. The Koolyanobbing, Mt Jackson

(J2/J3), Windarling and Deception Closure Plans are separate documents, which detail the

specific aspects to closure relating to these operations separately.

Figure 1.3 Overview of Cliffs Rehabilitation and Closure System

The Mining Act 1978 was amended in 2010 with regards to the submission of MCPs, stating

that Closure Plans must be submitted with the initial mining proposal for new projects, or at

a time directed by the Department of Mines and Petroleum (DMP) for existing projects. The

Mt Jackson J1 MCP has been prepared in accordance with these amendments and also the

Guidelines for Preparing Mine Closure Plans (DMP/EPA 2011) issued jointly by the DMP and

the Environmental Protection Authority (EPA) in 2011. It is also consistent with the

Strategic Framework for Mine Closure (ANZMEC/MCA 2000).

The Strategic Framework for Mine Closure (ANZMEC/MCA 2000) emphasises that mine

closure planning is not an “end of mine life process” but is integral to the “whole of mine

life” plan. With this in view, this MCP describes Cliffs’ current approach for the

decommissioning, rehabilitation and closure of the Mt Jackson J1 mining operations. It will

be amended throughout the life of the mine to reflect changes in:

mining operations;

rehabilitation techniques and technologies;

legislative requirements;

stakeholder expectations; or


Page 4

advances in knowledge arising from environmental surveys, rehabilitation trials and

site investigations.

At a minimum it will be revised and amended every three years.

1.3 SCOPE

This MCP applies to all landforms and infrastructure associated with the Mt Jackson J1

Deposit mining operations as described in Cliffs’ Mt Jackson J1 Deposit Mining Proposal

(Cliffs 2010b). This MCP provides the mine closure framework throughout all aspects of the

project from design, construction and operation through to decommissioning and closure.

This MCP excludes rehabilitation and closure of exploration areas occurring outside of the

footprint of the Mt Jackson J1 Deposit mining operations. Exploration activities are

regulated under a Program of Works and rehabilitation activities are expected to be carried

out as prescribed by DMP in its guidance document Guidelines for Mineral

Exploration/Rehabilitation Activities (DMP 2007). Monitoring of and reporting on

rehabilitation activities is a requirement of the Program of Works approval. Thus, to avoid

duplicating processes, the rehabilitation and closure of such exploration areas associated

with the Mt Jackson J1 Deposit has been excluded from this MCP.

1.4 PURPOSE

This MCP has been prepared to fulfil the following objectives:

To enable Cliffs’ to rehabilitate the Mt Jackson J1 Deposit mining operations to an

agreed standard such that Cliffs can relinquish the site and be released from further

liability.

To satisfy the requirements of a “Conceptual Closure Strategy” required under

Condition 9 of Cliffs’ Environmental Protection Act 1986 approval (Statement 843)

issued for the Mt Jackson J1 Deposit mining operations by the Western Australian

Minister for Environment on 28 October 2010.

To satisfy the requirements of a “Decommissioning and Rehabilitation Plan” required

under Condition 2(d) of Cliffs’ Environmental Protection and Biodiversity Conservation

Act 1999 (EPBC Act 1999) approval (EPBC 2008/4449) issued for the Mt Jackson J1

Deposit mining operations by the Commonwealth Minister for Environment on 5

October 2009. To satisfy the requirements of DMP/EPA’s Guidelines for Preparing

Mine Closure Plans (DMP/EPA 2011).


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2. PROJECT SUMMARY

2.1 LOCATION

The Mt Jackson J1 Deposit mining operations are located within Tenements M77/993,

M77/994, M77/1248, M77/1249 and L77/216 granted to Cliffs under the Mining Act 1978.

Figure 2.1 shows the layout of the Mt Jackson J1 Deposit mines and associated

infrastructure. Figure 2.2 shows the layout of the Mt Jackson J1 Deposit mines and haul

road, which links to the Mt Jackson J2 and J3 mining operations.

2.2 OWNERSHIP

The Proponent for the Mt Jackson J1 Deposit mining operations is Cliffs Asia Pacific Iron Ore

Pty Ltd (Cliffs). Cliffs is the holder of all tenements. There are no joint venture

arrangements, management companies or contracting companies relevant to the Mt Jackson

J1 Deposit mining operations.


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2.3 CONTACT DETAILS

Cliffs’ contact details are:

Cliffs Asia Pacific Iron Ore Pty Ltd (ACN 001 892 995)

Level 12, The Quadrant

1 William Street, PERTH WA 6000

GPO Box W2017, PERTH WA 6846

Telephone: (08) 9426 3333

Fax: (08) 9426 3390

Website: www.CliffsNR.com

Corporate Enquiries:

Mr Paul West

Manager Environmental Services


Telephone: (08) 9426 3309

Email: [email protected]

Technical Enquiries:

Ms Nicole Harry

Senior Environmental Advisor - Closure


Telephone: (08) 9049 4066


Tenement Enquiries:

Mr Peter Brammall

Senior Tenement Advisor


Telephone: (08) 9426 3341


mailto:[email protected]




Page 7

2.4 PROJECT DESCRIPTION

2.4.1 Overview

Cliffs obtained environmental approval under the Commonwealth EPBC Act 1999 for its Mt

Jackson J1 Deposit mining operations in 2009 and under the Western Australian EP Act 1986

and Mining Act 1978 in 2010. Cliffs commenced implementation of the project in Quarter 1

of 2011 and has an estimated mine life of 10 years, with mining expected to be completed

in 2021.

Cliffs’ Mt Jackson J1 Deposit mining operations comprise the following components:

two mine pits;

one waste rock landform;

ore stockpiles;

internal mine roads;

administration and operations buildings; and

a haul road and gravel pit.

Ore is mined from two pits and transported by road to Koolyanobbing for processing.

2.4.2 Mine pits

The Mt Jackson J1 Deposit comprises approximately 30.1Mt of iron ore. Mining operations

involve mining from two pits: “J1 West Pit” and “J1 East Pit”. The J1 West Pit will be mined

to approximately 170m depth and the J1 East Pit mined to approximately 95m depth. The

J1 West Pit will involve mining to approximately 75m below the 417mAHD natural

groundwater level. The J1 East Pit will not involve mining below the groundwater table.

The pits will join though not at full depth; a saddle will join the two pits. The combined area

of the two pits is approximately 114ha.

2.4.3 Waste Rock Landform

Waste rock (excavated un-mineralised rock and soil material) from the mine pits will be

disposed of by construction of a waste rock landform (WRL). The volume of waste rock to

be excavated is approximately 57.8 million loose cubic metres. The WRL will be constructed

with a footprint of 170ha and to a height of nominally 520mAHD. Accounting for topsoil

storage, the total area of disturbance will be approximately 211ha.

The size and height of the overburden landform is based on a 15o slope with 10m, back-

sloping berms. The WRL will be subject to an engineering design catering for a 1:100 year

Annual Recurrence Interval (ARI) for rainfall, which is consistent with the engineering design

of Cliffs’ existing waste rock landforms. Waste rock geochemistry has been characterised to

facilitate the management of potentially acid forming (PAF) waste rock.


Page 8

2.4.4 Infrastructure

Support infrastructure will require an area of approximately 225ha. The support

infrastructure will include the following components:

ore stockpiles

workshops and maintenance areas

vehicle parking areas

wash bay

hydrocarbon storage

power plant

administration offices

water treatment plant

explosives Storage

water storages and catchment dams

drainage and diversion channels

internal and access roads

topsoil, vegetation and gravel stockpiles adjacent to the mining infrastructure

2.4.5 Haul Road

The haul road is approximately 10.7km long, 40m wide (44ha in area) and connects to Cliffs’

Mt Jackson J2 Deposit haul road. The haul road is constructed of gravel and designed to

cater for a 1:100 year ARI for rainfall, consistent with the engineering design of Cliffs’

existing haul road network. Gravel for the construction of the haul road was sourced from a

10.6ha gravel pit located adjacent to the haul road.


Page 9

Figure 2.1 Layout of the Mt Jackson J1 Deposit mining and infrastructure areas


Page 10

Figure 2.2 Location of the Mt Jackson J1 Deposit mine and haul road


Page 11

2.5 MINE CLOSURE MANAGEMENT UNITS

To facilitate the implementation of progressive rehabilitation and closure activities, the Mt

Jackson J1 Deposit mining operations were divided into discreet areas or “management

units” (Table 2.1). Each management unit comprises landforms or features that have similar

rehabilitation needs for their intended post-mining land use. This approach is consistent

with the “domain” model proposed by ICMM (2008) as advocated in DMP/EPA’s Guidelines

for Preparing Mine Closure Plans (DMP/EPA 2011). Thus, reference to management units

throughout this MCP, particularly in relation to completion criteria (Section 8), financial

provisions for closure (Section 9) and the Closure Implementation Program (Section 10), is

based on the management units listed in Table 2.1. The geographical boundary of each

management unit is detailed in the Closure Implementation Program presented in

Section 10.

Table 2.1 Mt Jackson J1 Deposit management units for rehabilitation and closure

planning and implementation

Management Unit Feature(s) Tenements

Mine Pits J1 Pit West

J1 Pit East

Mine pit dewatering pipeline and infrastructure

M77/994

Waste Rock Landform

J1 Waste Rock Landform

Topsoil, vegetation and gravel stockpiles adjacent to the

WRL

Explosives storage (adjacent to WRL)

M77/993

M77/994

Infrastructure Ore stockpiles

Workshops and maintenance areas

Vehicle parking areas

Wash bay

Hydrocarbon storage

Power plant

Mine administration offices

Water treatment plant

Explosives Storage (adjacent to topsoil stockpile)

Water storages and catchment dams

Drainage and diversion channels

Internal and access roads

Topsoil, vegetation and gravel stockpiles adjacent to the

mining infrastructure

M77/994

M77/1249

Haul Road J1 Haul Road connecting to Mt Jackson J2/J3 mine haul

road

Gravel Pit

L77/216

M77/1248

M77/997


Page 12

3. CLOSURE OBLIGATIONS AND COMMITMENTS

Cliffs’ obligations and commitments for rehabilitation and mine closure of the Mt Jackson J1

Deposit mining operations were identified through a review of relevant:

legislation;

tenement conditions;

ministerial Statements;

mining Proposal commitments; and

Management Plan commitments.

Cliffs’ obligations and commitments for rehabilitation and mine closure across its Yilgarn

Operations are maintained in its Legal Obligations Register. Those obligations pertaining to

rehabilitation and closure of the Mount Jackson J1 Deposit mining operations is presented in

Table 3.1.

Table 3.1 Obligations and commitments pertaining to rehabilitation and closure of the Mt Jackson J1 Deposit mining operations

Tenement

No.

Condition

No.

Condition / Commitment

EP Act 1986: Ministerial Statement 843

All:

M77/993; M77/994;

M77/1248;

M77/1249; and

L77/216

8-1(1) The waste dump shall be non-polluting and shall be constructed so that

their final shape, stability, surface drainage, resistance to erosion and ability to support local native vegetation are comparable to natural

landforms within 100km of the proposal.

8-1(2) Subject to the Final Closure and Decommissioning Plan with regard to the haul road and an internal access road (Condition 10-4(1)), the

waste dump and other areas disturbed through the implementation of

the proposal (excluding mine pits) shall be progressively rehabilitated with vegetation composed of native plant species of local provenance

(as agreed by the CEO in consultation with the DEC and the DMP).

8-1(3) The percentage of living vegetation in all rehabilitation areas shall be

comparable to non-disturbed natural vegetation within 100km of the

proposal.

8-1(4) For rehabilitation areas where a similar geological profile to the pre-

mining condition can be re-established, such as areas cleared for

infrastructure, the species diversity and abundance shall be comparable with reference sites representative of the pre-disturbance condition of

those areas, to be chosen in consultation with the DEC prior to ground disturbing activities.

8-1(5) To improve the likelihood of rehabilitation success for the flora species

Bossiaea sp. Jackson Range, Spartothamnella sp. Helena and Aurora Range and Calytrix sp. Paynes Find, the proponent shall:

(a) Within 12 months after commencing proposal implementation, submit a proposed scope of work for a rehabilitation investigation

including seed germination trials, seedling trials and propagation

trials, to the approval of the CEO on advice from the DEC;


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Tenement

No.

Condition

No.


(b) Undertake the rehabilitation investigation as determined under Condition 8-1(5a) during the Mt Jackson J1 Deposit mine

operations; and

(c) Report the findings of the rehabilitation investigation to the CEO as

part of annual compliance reporting required by Condition 4-6.

8-1(6) Any new species of weeds (including both declared weeds and environmental weeds) introduced into the proposal area as a result of

implementation of the proposal shall be managed to the approval of the DEC.

8-1(7) The coverage of weeds (including both declared weeds and

environmental weeds) within the rehabilitation areas shall be no greater than the average of three suitable reference sites on nearby

land, with the reference sites to be chosen in consultation with the DEC.

8-2 Rehabilitation activities shall continue until such time as the

requirements of Condition 8-1 and are demonstrated by inspections and reports to be met, for a minimum of five years to the satisfaction

of the CEO on advice of DEC and DMP.

9-1 Within 12 months after commencing proposal implementation, the proponent shall submit a detailed and project-specific Conceptual

Closure Strategy to the requirements of the CEO on advice of the Department of Environment and Conservation and the Department of

Mines and Petroleum.

9-2 The Conceptual Closure Strategy shall include:

1. a detailed risk assessment to identify any acidity and metal

contamination hazards associated with mining related activities in

the area of this proposal;

2. details of a monitoring program to ensure that materials with

potential to cause acid and/or metalliferous drainage are identified prior to excavation; and

3. actions to be taken in the event that materials with the potential to

cause acid and/or metalliferous drainage are identified through the monitoring program required by Condition 9-2(2).

9-3 The Conceptual Closure Strategy shall provide detailed technical information on proposed management measures to prevent pollution,

environmental harm or human health impacts during the

implementation of the proposal and after mine completion and closure.

9-4 The Conceptual Closure Strategy shall include maps and diagrams

showing the proposed placement, dimensions, design and proposed

methods of construction and closure of waste disposal facilities and mine pits.

9-5 The Conceptual Closure Strategy shall demonstrate that waste dumps can be located, designed and constructed to ensure that they are non-

polluting and so that their final shape, height, stability, surface

drainage, resistance to erosion and ability to support native vegetation are comparable to natural landforms in the area.

9-6 The Conceptual Closure Strategy shall include specific practicable

procedures to ensure the protection of the environment in the event of unplanned or temporary mine closure.


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Tenement

No.

Condition

No.


9-7 The proponent shall implement the proposal consistent with the Conceptual Closure Strategy referred to in Conditions 9-1 to 9-6.

10-1 At least two years prior to mine completion, the proponent shall prepare and submit a Final Closure and Decommissioning Plan to the

requirements of the CEO on advice of the DEC and DMP.

10-2 The Final Closure and Decommissioning Plan shall be prepared consistent with:

1. ANZMEC/MCA 2000, Strategic Framework for Mine Closure

Planning; and

2. Department of Industry, Tourism and Resources 2006 Mine Closure

and Completion (Leading Practice Sustainable Development Program for the Mining Industry), Commonwealth Government,

Canberra

10-3 The Final Closure and Decommissioning Plan shall provide detailed technical information on the following:

1 Final closure of all areas disturbed through the implementation of the proposal so that they are safe, stable and non-polluting;

2 Decommissioning of all plant and equipment;

3 Disposal of waste materials;

4 Final rehabilitation of the waste dump facilities and other areas

(outside the mine pits);

5 Management and monitoring following mine completion; and

6 Inventory of all contaminated sites and proposed management.

10-4 The Final Closure and Decommissioning Plan shall also include the following proposal specific requirements:

1. Retention, closure or rehabilitation of the haul road and an internal access road to the approval of the DEC;

2. Details of the monitoring program to be carried out to inform final

closure procedures for the pit void such that the standing water body does not cause environmental harm by:

(a) Attracting native fauna which may be subsequently harmed; or

(b) Attracting fauna which may harm native fauna populations

and/or surrounding native vegetation.

3. Management actions to be undertaken based on the findings under Condition 10-4(2).

10-5 The proponent shall close, decommission and rehabilitate the proposal consistent with the approved Final Closure and Decommissioning Plan.

10-6 The proponent shall make the Final Closure and Decommissioning Plan required by Conditions 10-1 to 10-4 publicly available in a manner

acceptable to the CEO.

EPBC Act 1999: EPBC 2008/4449

All:

M77/993;

M77/994; M77/1248;

2(d) For the restoration of the threatened Malleefowl (Leipoa ocellata)

habitat post-mining, the person taking the action must implement a

Decommissioning and Rehabilitation Plan.


Page 15

Tenement

No.

Condition

No.


M77/1249; and

L77/216

Mining Act 1978 Tenement conditions

M77/993

M77/994

M77/1248

M77/1249

6 Unless the written approval of the Environmental Officer, DMP is first

obtained, the use of 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 and/or completion of operations.

M77/994 14 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.

L77/216 5 All topsoil that may be removed ahead of pipe-laying operations to be

stockpiled for replacement in accordance with the directions of the

Environmental Officer, Department of Mines and Petroleum.

7 On the completion of the life of mining operations in connection with

this licence the holder shall:

remove all installations constructed pursuant to this licence; 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 Mines and Petroleum 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.

Mt Jackson J1 Project Mining Proposal – Proponent Commitments

All:

M77/993;

M77/994; M77/1248;

M77/1249; and

L77/216

Table 1-3

Commitment

7-1

Prior to land clearing and periodically during mine operations, Cliffs will collect seed (for subsequent use in rehabilitation) from areas of:

Bossiaea sp. Jackson Range;

Spartothamnella sp. Helena & Aurora Range; and

Community EeWH1 Eucalyptus ebbanoensis Woodland over Heath

with Calytrix sp. Paynes Find.

Table 1-3

Commitment

7-2

During initial mine development, Cliffs will collect and separately

stockpile/store topsoil (for subsequent use in rehabilitation) from areas

of:

Bossiaea sp. Jackson Range;

Spartothamnella sp. Helena & Aurora Range; and




Page 16

Tenement

No.

Condition

No.


Table 1-3

Commitment

7-3

During rehabilitation, Cliffs will undertake actions that seek to establish:

Populations of Bossiaea sp. Jackson Range;

Populations of Spartothamnella sp. Helena & Aurora Range; and

20ha of native vegetation containing representative species of




Page 17

4. REHABILITATION AND CLOSURE DATA

4.1 SUMMARY OF ENVIRONMENTAL CHARACTERISTICS

The environmental characteristics of the Mt Jackson J1 Project area were described in Cliffs’

Public Environmental Review (Cliffs 2009) and Mining Proposal (Cliffs 2010b). Table 4.1

summarises the key aspects of the Mt Jackson J1 Deposit environment that are relevant to

rehabilitation and mine closure planning and implementation. Attachment 1 provides a

bibliography of technical reports for the Mt Jackson J1 deposit that provide data relevant to

mine rehabilitation and closure planning.

Table 4.1 Summary of Mt Jackson J1 Deposit pertinent environmental characteristics

Aspect Description

Climate

Characterised by hot, dry summers and mild, wet winters. Main climatic

features are:

Maximum temperature peaks (>30oC) occur between December and

March.

Rainfall occurs throughout the year with approximately 70 days of

rainfall and an annual average of 294.5mm/y. Wettest months (>30mm) occur between May and August. Driest months (<20mm)

occur between October and January.

Winds between January and April are generally from north-east, east or

south-east directions during both mornings and afternoons. During July to October, wind direction is predominantly north-west, west or south-

west during the mornings, and variable in the afternoons. Periods of calm (no wind and wind <10km/hr) occur during the mornings between

May to July. Strongest winds occurring in the afternoons between July

to November.

In relation to climate change, the region may be expected to become hotter

and drier as a function of El Nino / Southern Oscillation (ENSO) variations.

Topography

Majority of the region is gently undulating at approximately 335mAHD to

400mAHD. The pre-mining elevation of the Mt Jackson J1 Deposit ranges

between 510mAHD and 550mAHD.

Soil characteristics

Three soil types (soil management units (SMU)) can be differentiated across

the Mt Jackson J1 Deposit operational area (SWC 2011a):

Skeletal Soil over Ironstone (SMU 1): Corresponding to the ridge and

upper slopes of the Mt Jackson J1 mine pit footprints. This soil is typically shallow (10-20cm), gravelly, non-saline, potentially dispersive

and acidic (pH 4 – 5).

Shallow-deep loamy gravels (SMU 2): Corresponding to the lower slopes

and plains of the waste rock landform and mining infrastructure area.

This soil typically occurs to depths of 1m, has a high gravel and loam content, is non-saline, potentially dispersive and acidic (pH 4 – 7).

Deep clay loam (SMU 3): Found in the northern and south-eastern parts

of the waste rock landform footprint. This soil typically occurs to a depth

of <1m, has a high clay content, low permeability and is saline, alkaline (ph 8 – 10) and highly dispersive.

SMUs 1 and 2 are suitable for stock-piling for use in rehabilitation whereas SMU 3 is not (SWC 2011a). However, during stripping of the surface soils,

the relatively low volume of SMU 3 does not warrant stripping separately.


Page 18

Aspect Description

Waste Rock

Geochemistry

Approximately 6.6% (3,920,000m3) of the waste rock sulphur content

exceeding 0.3% (based on 9,314 samples (Cliffs 2008 unpublished data)). As this volume includes both reactive sulphur (potentially acid forming) and

non-reactive sulphur (non-acid forming), this estimate is regarded as conservative.

Independent testing of representative overburden samples (EGI 2009) identified that:

84% of samples tested contained little sulphur and were classified as

either barren or non-acid forming (NAF);

16% of samples were classified as PAF (10%) or uncertain (6%);

the greatest risk for acid generation was the massive pyrite which is

expected to constitute approximately 5% to 6% of waste rock generated and occurs at depth;

the acid neutralising capacity of the waste rock was low.

Saline waste rock of low to moderate salinity is expected at depth, reflecting the surrounding groundwater salinity (2,000mg/L to 6,000mg/L).

Testing by SWC (2011b) indicated that:

The top 20-30m of J1 waste rock is not acidic (pH ~ 8), not acid forming

(NAF) and has a high acid neutralising capacity (ANC). This waste rock would be unlikely to inhibit plant growth;

Below 20-30m and above the groundwater level (~417mAHD), waste

rock is generally acidic (pH ~ 4), representing already-oxidised sulphides and has low ANC. This waste rock would be likely to be inhibitory to

plant growth;

Below the groundwater level (~417mAHD), waste rock is generally

neutral (pH ~ 6 – 8), comprising a heterogeneous mix of PAF and NAF.

Sulphur occurs in an unoxidised form (is therefore PAF). The ANC is

low. This waste rock would be likely to be inhibitory to plant growth;

Above the groundwater level, salinity is low, whereas below the

groundwater level, salinity increases to levels that could inhibit plant

growth.

The potential for non-acidic metalliferous drainage to occur is low,

indicating that metals and metalloids are bound tightly in the rock

matrix.

Vegetation and Flora

The predominant vegetation assemblages occurring over the J1 deposit were Acacia sp. Mt Jackson Shrubland and Dryandra arborea Shrubland

(WB 2009).

The significant flora species and vegetation communities identified by

Western Botanical (2009) in the vicinity of the Mt Jackson J1 Deposit were:

Tetratheca harperi (DRF); Beyeria rostellata (P1); Bossiaea sp. Jackson Range (P1); Lepidosperma ferricola (P1); Lepidosperma jacksonense

(P1); Leptospermum macgillivrayi (P1); Jacksonia jackson (P1); Austrostipa blackii (P3); Spartothamnella sp. Helena & Aurora Range

(P3); Stenanthemum newbeyi (P3); Daviesia purpurescens (P4);

Eucalyptus formanii (P4); Dryandra arborea (P4); Mt Jackson Range Priority Ecological Community (PEC).

Fauna

Species of conservation significance recorded on the Mt Jackson Range include the Malleefowl Leipoa ocellata, Peregrine Falcon Falco peregrinus, Rainbow Bee–eater Merops ornatus and Carpet Python Morelia spilota imbricata (BCE 2009).


Page 19

Aspect Description

Groundwater

Groundwater occurs at approximately 417mAHD (Rockwater 2007a).

Groundwater salinity is low (2,000mg/L to 6,000mg/L) when compared to regional salinities recorded at the Windarling Range (20,000mg/L to

29,000mg/L) and towards Koolyanobbing (18,000mg/L to 39,000mg/L) (Rockwater 2003; Rockwater 2007b).

Groundwater modelling (Rockwater 2009) predicts that, depending on the permeability of the country rocks, the pit may either remain dry, or recover

with the water level stabilising at about 370mAHD (28 m pit water depth)

after about 250 years. If the latter occurs, the salinity of the void water will rise, reaching about 73,000 mg/L total dissolved solids (TDS) after 250

years and then stabilising at about 77,000 mg/L TDS after 400 years since the end of dewatering.

Surface Water There are no nearby natural surface water features (lakes or streams) in the

vicinity of the Mt Jackson J1 Deposit.

Conservation Reserves The Mt Jackson J1 Deposit is not located within any conservation reserve.

Pastoral Leases

The Mt Jackson J1 Deposit is wholly located within the Mt Jackson Pastoral Lease. The current land uses occurring on the Mt Jackson Pastoral Lease

include pastoral and mining activities. Cliffs is the holder of the Mt Jackson Pastoral lease.

Aboriginal Heritage Nine registered Aboriginal Heritage sites occur in the vicinity of the Mt

Jackson J1 Deposit (DIA 2009).

Native Title

The Mt Jackson J1 Project area coincides with two separate Native Title

applications, being the Central West Goldfields People and the Kalamaia

Kabu(d)n People. Native Title has yet to be determined by the Federal Court of Australia (NNTT 2008a; NNTT 2008b).

European Heritage

Two European heritage sites, the Mt Jackson Homestead and the Mt

Jackson Graves and Cemetery, occur in the vicinity of the Mt Jackson J1 Project. These are located approximately 3km and 3.5km (respectively)

west of the Mt Jackson J1 Project.

4.2 MINING DATA

A range of data will be collected during mine operations that will assist in informing mine

closure (e.g. monitoring results from progressive land rehabilitation). Records of this mining

data will be will be updated in periodic review of this MCP.

4.3 POST-MINING DATA

Data collected following the completion of mine operations will further inform mine closure

(e.g. monitoring results from progressive land rehabilitation). Records of this post-mining

data will be will be updated in periodic review of this MCP.


Page 20

4.4 KNOWLEDGE GAPS

At this early stage of the Mt Jackson J1 Deposit mining operations, the knowledge gaps are

considered to be:

The selection and characterisation of suitable reference sites in order to develop

appropriate completion criteria for landform stability and revegetation; and

Appropriate seed mix, seed treatments to promote germination and seeding rate to

apply to promote the establishment of self-sustaining native vegetation compatible

with surrounding assemblages.

Cliffs proposes to address these knowledge gaps within the first three years of the Mt

Jackson J1 Project (refer to the Closure Implementation Program in Section 10). Cliffs will

continue to assess its knowledge gaps throughout the life of the project during MCP reviews.


Page 21

5. STAKEHOLDER CONSULTATION

5.1 STAKEHOLDER IDENTIFICATION

Cliffs identified its stakeholders during the planning of its Mt Jackson J1 Deposit mining

operations. The external stakeholders identified are presented in Table 5.1.

Table 5.1 Cliffs’ external stakeholders

Category Stakeholders

Commonwealth Government Department of Sustainability, Environment, Water, Population and

Communities (DoSEWPC)

State Government

Department of Mines and Petroleum (DMP)

Department of Environment and Conservation (DEC)

Department of Indigenous Affairs (DIA)

Department of Water (DoW)

Department for Planning and Infrastructure (DPI)

Department of Agriculture and Food (DAF)

Conservation Commission

Heritage Council of WA

Local Government Shire of Yilgarn1

Indigenous Groups

The Central West Goldfields People

The Gubrun People

The Kelamaia Kabu(d)n People

The Ballardong People

Non-Government Organisations

Conservation Council of Western Australia

The Wilderness Society Australia

Wildflower Society of Western Australia1

Yilgarn Land Conservation District Committee1

Local communities Residents of Southern Cross1

Pastoral leaseholders1

Special Interest Groups

Toodyay Naturalists Club1

Malleefowl Preservation Group1

Windarling Preservation Group1

1 Members of the Yilgarn Operations Community Reference Group


Page 22

5.2 CONSULTATION PROCESS

Stakeholder engagement and consultation on mine rehabilitation and closure of the Mt

Jackson J1 Deposit mining operations will be carried out as a part of Cliffs’ overall

stakeholder engagement activities. Of particular note is the Yilgarn Operations Community

Reference Group (CRG). Table 5.1 identifies members of the CRG.

The CRG meets every 6 months, and Cliffs provides project updates to members

approximately every three months between meetings. Mine rehabilitation and closure is

discussed as an agenda item during CRG meetings. Outside of CRG meetings, Cliffs will

undertake regular consultation with stakeholders as required throughout the life of Cliffs’

mining operations.

5.3 CONSULTATION TO DATE

Cliffs engaged with its stakeholders during the planning of the Mt Jackson J1 Deposit mining

operations, through meetings and written correspondence. The topics discussed were

primarily related to describing the suite of environmental studies undertaken, various

aspects of project design and measures implemented to minimise environmental

disturbance. Cliffs’ ongoing stakeholder engagement will focus increasingly on mine

rehabilitation and closure as mining of the Mt Jackson J1 Deposit advances.

Cliffs’ maintains a Stakeholder Consultation Register that is used to record consultations

relating to mine closure. The Stakeholder Consultation Register records the stakeholder

consulted, the method of consultation, issues discussed and any conclusions reached. An

excerpt from Cliffs’ Stakeholder Consultation Register focussing on the Mt Jackson J1

Deposit mining operations is presented in Attachment 2.


Page 23

6. POST-MINING LAND-USE AND CLOSURE OBJECTIVES

6.1 POST-MINING LAND-USE

The Shire of Yilgarn contains a number of large pastoral leases, including the Mt Jackson

Pastoral Lease (covering Cliffs’ Mt Jackson Range mines), and the Brontie Pastoral Lease

(covering Cliffs’ Koolyanobbing Range mines). The Windarling Range mining operations

were covered by the Diemals Pastoral lease however the lease was cancelled in October

2011 and is now covered by unallocated crown land (UCL). The Mt Jackson J1 Deposit

mining operations is wholly located within the Mt Jackson Pastoral Lease. Pastoral activities

on pastoral leases in the Shire of Yilgarn have occurred for more than 50 years.

In 2010, the Western Australian Government announced a proposal to create a

“Conservation and Mining Reserve” overlapping with Cliffs’ Mt Jackson mining operations.

Key aspects of the proposal were:

The establishment of a reserve for conservation and mining purposes in the main area

of Cliffs’ operations upon the expiry of the Mt Jackson and Diemals Pastoral Leases.

The proposed reserve to carry the designation Section 5(1)(h) Reserve under the

Conservation and Land Management Act 1984. This is a multi-use category equivalent

to International Union for Conservation of Nature (IUCN) category IV.

Although it is a “conservation” reserve in terms of its statutory vesting, mining within

the reserve is established as a legitimate purpose.

Accordingly, Cliffs’ proposed end land-use for Mt Jackson J1 Deposit mine is as a multi-use

conservation reserve. The Conservation and Mining Reserve has yet to be established under

the Land Administration Act 1997. Cliffs will undertake further stakeholder consultation

through its CRG meetings and the relevant government agencies to ensure that the

proposed post-mining land-use is aligned with stakeholder expectations.

6.2 CLOSURE OBJECTIVES

Cliffs’ overarching objective for mine closure is to achieve stable, non-polluting landforms

with self-sustaining native vegetation that is compatible with the post-mining land-use of the

surrounding environment. Cliffs’ objectives relating to specific aspects that support the

over-arching objective are presented in Table 6.1. Cliffs will undertake further stakeholder

consultation through its CRG meetings to ensure its mine closure objectives are aligned with

stakeholder expectations.


Page 24

Table 6.1 Cliffs’ mine closure objectives

Aspect Cliffs’ Closure Objectives

Landform stability Ensure that final landforms are stable and erosion is controlled to an

acceptable level, comparable to that of the surrounding landscape within 100km.

Public safety Ensure that the land is physically safe for people to access and does not pose

a human health risk.

Soils (cover

systems)

Ensure that reconstructed soil profiles are stable and capable of supporting

resilient and self-sustaining native vegetation.

Vegetation Re-establish native vegetation (within the limits of leading-practice

rehabilitation techniques and the capability of the post-mining soil/waste rock

cover system) comparable to undisturbed natural vegetation within 100km.

Ensure that weeds are effectively controlled.

Ensure that grazing by introduced animal species is effectively controlled.

Sustainability Establish resilient and self-sustaining vegetation.

Establish rehabilitated landforms that are capable of providing habitat for a

variety of vertebrate and invertebrate species.

Ensure that rehabilitated landforms are safe, stable, non-polluting and

compatible with surrounding land-uses and stakeholder expectations.

Ensure that post-mining land management requirements are comparable to

that of the surrounding, undisturbed landscape.

6.3 FINAL LANDFORM DESIGN CONCEPT

6.3.1 Mine pits

The Mt Jackson J1 West Pit will form a pit lake after the completion of mining and

associated dewatering. The J1 East Pit, which will remain joined to the J1 West Pit by a low

saddle, will not form a pit lake. A representation of the post-mining, rehabilitated landscape

showing the mine pits is presented in Figure 6.1.

6.3.2 Waste Rock Landform

Landform Design Concept

To support successful post-mining rehabilitations, the WRL is to be constructed in

accordance with the following design criteria:

10m lifts to a height ranging from 440mAHD to 550mAHD;

batters with slope angles of 15º and 10m back-sloping berms between lifts;


Page 25

water control baffles installed at intervals along berms to control surface water

following intense rainfall events;

0.5m high bund installed around the crest of the WRL to control surface water

movement;

bunded cells installed on the top of the final lift of the WRL to contain run-off,

minimise surface flow volumes and velocities and promote infiltration;

PAF waste rock blended with non-PAF waste rock and selectively placed at least five

metres from batter surfaces.

The conceptual, rehabilitated, post-mining WRL is shown in Figures 6.1 and 6.2. Figure 6.3

illustrates the WRL design to promote land stability and successful rehabilitation.

Waste Rock Geochemical Characterisation

In order to manage waste rock appropriately, Cliffs has undertaken geochemical

characterisation prior to mining (SWC 2011b) and identified zones of waste rock that are

likely to be inhibitory to plant growth. Further testing of waste rock is carried out during

blast-hole drilling or reactive ground testing to verify areas predicted to comprise hostile

waste rock.

Criteria used to define waste rock that is either benign or inhibitory to plant growth are

shown in Table 6.2. Waste rock with any combination of pH<4.5, EC>100mS/m or

TS>0.3% is regarded as inhibitory to plant growth and commingled with benign waste and

buried within the WRL as shown in Figure 6.3.

Table 6.2 Waste rock classification

Parameter Benign Inhibitory

pH pH > 4.5

(non-acidic)

pH < 4.5

(acidic)

pHox (pH after reaction with

peroxide)

pHox > 4.5

(Not Acid Forming (NAF))

pHox < 4.5

(Potentially Acid Forming (PAF))

Electrical Conductivity EC < 100 mS/m

(non-saline)

EC > 100 mS/m

(saline)

Total Sulphur TS < 0.3%

(Not Acid Forming (NAF))

TS > 0.3%

(Potentially Acid Forming (PAF))


Page 26

6.3.3 Mining Infrastructure

Rehabilitation and closure of mining infrastructure would generally entail:

decommissioning and removal of all infrastructure;

reshaping disturbed land-surfaces, so that they are compatible with surrounding

areas;

installing drainage structures as required to manage surface water flow and potential

erosion;

conducting a contaminated soil investigation and remediating contaminated soil if

required;

spreading available growth medium (topsoil and or vegetation mulch) as required;

deep ripping to loosen traffic-compacted soils;

seeding with local native flora species, appropriate for the soil conditions; and

monitoring to determine the status of rehabilitation in relation to stated completion

criteria.

A representation of the post-mining, rehabilitated landscape showing the mining

infrastructure area is presented in Figure 6.2.


Page 27

Figure 6.1 Mt Jackson J1 Deposit conceptual post-mining landform design (looking towards the north-west)


Page 28

Figure 6.2 Mt Jackson J1 Deposit conceptual post-mining landform design (looking towards the south-west)


Page 29

Figure 6.3 J1 Waste Rock Landform construction design


Page 30

7. IDENTIFICATION AND MANAGEMENT OF CLOSURE ISSUES

Issues relevant to rehabilitation and closure of the Mt Jackson J1 Project were identified

through:

baseline environmental surveys carried out during the environmental approvals phase;

soil, waste rock and landform characterisation and investigations; and

a structured risk assessment carried out in 2011.

Cliffs’ risk assessment methodology follows AS/NZS 4360:2004 Risk Management (AS/NZS

2004) as advocated by the International Council on Mining and Metals (ICMM) in its Planning

for Integrated Mine Closure Toolkit (ICMM 2008). Cliffs’ risk assessment process considers

both risks and opportunities associated with rehabilitation and mine closure of the J1 mining

operation and is presented in Attachment 3. This risk and opportunity assessment for the

Mt Jackson J1 Project will be periodically reviewed throughout the life of the mine to take

account of changes in:

mining operations;

rehabilitation techniques and technologies; and

advances in knowledge arising from environmental surveys, rehabilitation trials and

site investigations.

At a minimum, the risk assessment will be reviewed every three years during triennial

revisions of the MCP.


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8. COMPLETION CRITERIA

8.1 DEVELOPMENT OF COMPLETION CRITERIA

Completion criteria are the basis on which successful rehabilitation is determined

ANZMEC/MCA 2000). The purpose of completion criteria is to establish a set of

rehabilitation standards or end-points that, when achieved, will enable the mining company

to relinquish the mine site and be released from further liability. Stakeholder consultation is

critical during the development of completion criteria to ensure that:

a) there is a common understanding of the constraints posed by post-mining

environmental conditions; and

b) agreement is reached on rehabilitation standards with recognition of those constraints.

Cliffs’ process for developing its completion criteria, illustrated in Figure 8.1, comprises:

implementation of leading practice mining and rehabilitation methods during the

operations phase;

monitoring of rehabilitated landforms and comparable ‘Reference Sites’; and

reviewing the completion criteria in light of monitoring data, in consultation with

stakeholders, to establish achievable criteria that, when achieved, will allow Cliffs to

relinquish the site and future liability.

Post-mining landforms have different characteristics to undisturbed areas so the attainment

of pre-mining (undisturbed) conditions may not be a practical expectation of rehabilitation.

Therefore, completion criteria are required in order to define the end-point for rehabilitation

that, whilst may not resemble pre-mining conditions, is nevertheless acceptable to all parties

i.e. the State, the community and the mining company. Completion criteria should reflect

what can be achieved when current leading practice rehabilitation methods are used, whilst

recognising the limitations that may be imposed by the inherent physical and geochemical

properties of the post-mining soil and waste rock materials.

8.2 INTERIM COMPLETION CRITERIA

Interim completion criteria have been developed for each closure management unit of the

Mt Jackson J1 Deposit mining operations (refer to Section 10 of this MCP). These interim

completion criteria will continue to be reviewed throughout the life of the Mt Jackson J1

Deposit mining operations and refined in light of rehabilitation trials and monitoring data

(following the process outlined in Figure 8.1) to develop achievable criteria relevant to each

landform and mine feature.

The interim completion criteria are referenced to the DMP’s criteria for bond reduction and

retirement (refer to Section 10 of this MCP). Through monitoring, Cliffs’ proposes to

measure the progress of its rehabilitation and apply to the DMP for bond discounts or

retirement upon the attainment of the applicable completion criteria.


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Figure 8.1 Cliffs’ process for developing site-specific completion criteria (adopted

from Nichols 2010)

8.3 REFERENCE SITES

Reference sites comprising undisturbed landforms around the Mt Jackson J1 Deposit mining

operations will be selected to assist the development of completion criteria. Examples of

rehabilitation that appear to be progressing satisfactorily may also be selected as reference

sites. Reference sites will be selected and completion criteria refined accordingly within the

first three years of the Mt Jackson J1 Deposit mining operations.


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9. FINANCIAL PROVISION FOR CLOSURE

9.1 METHODOLOGY FOR MAINTAINING FINANCIAL PROVISIONS

Cliffs’ maintains financial provisions for rehabilitation and closure as a contingent liability in

accordance with its procedure FIN056 Financial Processes Iron Ore Rehabilitation Provisions

(Cliffs 2010c). Under this procedure, the cost-estimate is updated biannually accounting for

changes in land disturbance as mining projects advance and a comprehensive review is also

conducted triennially. Cliffs’ financial provisions are audited annually by an independent

financial auditor. The Financial Operations Controller is responsible for maintaining the

financial provisions in the company accounts.

Financial provisions are estimated based on current areas of land disturbance and unit rates

for rehabilitation activities e.g. earth moving, topsoil spreading, contour ripping and seeding.

Financial provisions are estimated separately for each management unit and mine feature.

Thus, the costs for rehabilitation, decommissioning and closure of each management unit or

individual feature can be tracked and updated during biannual reviews. The financial

provisions for any given area of disturbed land remain as a liability on the company accounts

until such time as the rehabilitation completion criteria are achieved and signed off by the

relevant regulatory authorities.

9.2 MT JACKSON J1 DEPOSIT FINANCIAL PROVISIONS

The financial provisions required for the rehabilitation and closure of Cliffs’ Mt Jackson J1

Deposit mining operations is estimated to be, in today’s dollars, $11.7M Australian Dollars

(AUD). This estimate assumes that the Mt Jackson J1 Deposit mining operations are fully

implemented in accordance with the Mt Jackson J1 Deposit Mining Proposal (Cliffs 2010b).

Table 9.1 Mt Jackson J1 Project Closure Provisions

Management Unit Closure Provision

Mine Pits

Confidential

Waste Rock Landforms

Infrastructure Area

Haul Road

General Support Activities (relevant to all management units)


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10. CLOSURE IMPLEMENTATION

10.1 CLOSURE IMPLEMENTATION PROGRAM

Cliffs’ mine rehabilitation and closure program for the entire Mt Jackson J1 Deposit mining

operations is summarised in Table 10.1. The table assumes that surfaces of the WRL will

not become available for progressive rehabilitation to commence until 2014. Consequently,

progressive rehabilitation, revegetation trials and monitoring would commence from 2014

onwards, with the outcomes being used to refine the completion criteria for this

management unit.

With mining currently projected to occur until 2021, decommissioning works for the mine

pits, infrastructure area and haul road would commence after the completion of mining i.e.

from 2022 onwards. Table 10.1 assumes that it will take nominally up to ten years to

achieve the completion criteria for each management unit so includes a post-mining period

of monitoring and management extending to 2031. In practice, progress towards achieving

the completion criteria will be monitored throughout the post-mining period with a view to

relinquishing the site earlier if possible.

10.2 CLOSURE IMPLEMENTATION PLANS

Cliffs’ Closure Implementation Program for the Mt Jackson J1 Project is underpinned by

Closure Implementation Plans that have been prepared for each management unit to

address their specific rehabilitation and closure issues and requirements. Sections 10.3 to

10.6 present the detailed Closure Implementation Plans for each management unit.

The Closure Implementation Plan for each management unit comprises the following:

Description and Setting: description of the management unit, including a map

showing its geographical boundary and relationship with other management units.

Management History: discussion of any events during mining that may have

implications for rehabilitation and closure.

Risk Assessment: description of the key risks and opportunities related to

rehabilitation and closure of the management unit.

Closure Assumptions: identification of current assumptions regarding rehabilitation

and closure e.g. estimated life-of mine, retention of infrastructure.

Knowledge Gaps: identification of any knowledge gaps specific to the management

unit.

Rehabilitation and Closure Activities: outline of rehabilitation and closure activities

including a “Task Register” summarising the key tasks and their expected timing..

Rehabilitation Materials: identification of the volumes and sources of materials

required for rehabilitation e.g. topsoil quantities.


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Bond Retirement and Relinquishment Strategy: identification of Cliffs’ closure

objectives and completion criteria specific to the management unit, with reference to

DMP’s criteria for bond reduction and relinquishment.

Section 10.7 summarises rehabilitation and closure activities that apply across all

management units. Section 10.8 describes Cliffs’ contingencies in the unlikely event of

unplanned closure.


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Table 10.1 Summary of Mt Jackson J1 Project Closure Implementation Program

Activity

Timing

20

11

20

12

20

13

20

14

20

15

20

16

20

17

20

18

20

19

20

20

20

21

20

22

20

23

20

24

20

25

20

26

20

27

20

28

20

29

20

30

20

31

Mining Activities

J1 Deposit Mining

WRL Construction

Pre-Closure Planning Activities

Reference Site selection

Revegetation Trials and Monitoring

Refinement of completion criteria

Stakeholder Consultation

Implementation of Rehabilitation and Closure Activities

Mine Pit Management Unit: Decommissioning and Closure

Waste Rock Landform Management Unit: Progressive

Rehabilitation


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Activity

Timing

20

11

20

12

20

13

20

14

20

15

20

16

20

17

20

18

20

19

20

20

20

21

20

22

20

23

20

24

20

25

20

26

20

27

20

28

20

29

20

30

20

31

Infrastructure Area Management Unit: Decommissioning and Rehabilitation

Haul Road Management Unit: Decommissioning and Rehabilitation

Post-mining Monitoring and Management

Post-mining monitoring and evaluation against completion criteria

Post-mining Stakeholder

Engagement

Progressive Bond Reduction and Relinquishment


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10.3 MINE PITS MANAGEMENT UNIT

MINE PITS CLOSURE IMPLEMENTATION PLAN

Scope:

J1 Pit West.

J1 Pit East.

Mine pit dewatering pipeline and infrastructure.

1. Description and setting

Location Tenement M77/994 (Figure 10.1).

Area of disturbance J1 Pit West 98.5ha.

J1 Pit East 15.7ha.

Total 114.2ha.

Current Status Active – mining commenced in Q3 2011.

Closure date Mining is expected to be completed in 2021.

Relationship with other plans This Mine Pit Closure Implementation Plan should be coordinated with the Waste Rock Landform Closure Implementation Plan integrate installation of the pit abandonment bunds and manage surface water.

Figure 10.1 J1 Mine Pits Management Unit

2. Management History

Mining commenced in Q3 2011 and to be completed in 2021. Soil and waste rock properties have been characterised to facilitate (a) retention of surface materials for rehabilitation, and (b) management of potentially acid forming (PAF) materials, respectively.


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3. Risk Assessment

The main risks associated with the mine pits were identified as being:

Public safety / inadvertent entry to the abandoned pits; and

A permanent water source that potentially attracts and stimulates populations of feral fauna.

Refer to risk assessment presented in Attachment 3.

4. Closure Assumptions

Cliffs Closure Implementation Plan for the J1 Mine Pits Management Unit is based on the following assumptions:

Mining will be completed in 2021 to final design (i.e. no further pit expansions occur).

A mine pit lake will form in the J1 West Pit that will be nominally between 10m and 30m deep.

The mine pit lake will form a groundwater sink due to the low inflows relative to the high evaporation rate characteristic of the region.

No infrastructure related to the mine pits is to be retained post-mining.

5. Knowledge Gaps

Current knowledge gaps relating to the J1 WRL Management Unit relate to:

The presence of exposed PAF materials, metals and metalloids in the mine pit walls and potential risks to the surrounding environment.

6. Rehabilitation and Closure Activities

Prior to mining

Prior to mining the following activities will be implemented in support of mine rehabilitation and closure:

Where possible, retain recoverable surface soils and associated vegetation debris from within the boundary of the proposed pits prior to mining.

Retain surface soils and associated vegetation debris from the association Eucalyptus ebbanoensis Woodland over Heath with Calytrix sp. Paynes Find and stockpile separately.

Post-mining

Upon the completion of mining, the following rehabilitation and closure activities will be implemented:

A continuous abandonment bund approximately 2m in height and 5m at the base constructed of benign waste rock material is to be installed at a distance of 80m from the J1 West Pit and 60m from the J1 East Pit (in accordance with DMP 1997), except where the constructed J1 WRL serves the function of an

exclusion bund.

Dewatering infrastructure (generators, pumps, and pipelines) will be decommissioned and removed.

Monitoring to determine: (a) the potential for the mine pit lake to attract native and feral fauna; and (b) the environmental impacts of these fauna if found to be attracted to the mine pit lake.

In the event that native and feral fauna are found to be attracted to the mine pit lake and are subsequently causing detrimental environmental effects, implement appropriate management actions, in consultation with the DEC.

Pit lake depth and water quality (pH and salinity) will be monitored for a nominal 10 year post-mining period.

The presence of exposed PAF materials, metals and metalloids in the mine pit walls and potential risks to the surrounding environment will be investigated after the completion mining.

7. Task Register

No. Description Timing Status

1 Retain surface soil and associated vegetation debris (where recoverable soil occurs).

Prior to ground disturbance.

Implemented during pioneering works.

2

Retain surface soil and associated vegetation debris from the association Eucalyptus ebbanoensis Woodland over Heath with Calytrix sp. Paynes Find and stockpile separately (where recoverable soil occurs).


Implemented during pioneering works.

3 Decommission and remove dewatering Post-mining (2022). Not yet required.


Page 40

infrastructure.

4 Install abandonment bunding. Post-mining (2022). Not yet required.

5 Post-mining monitoring of native and feral fauna.

Annually post-mining (2022).

Not yet required.

6 Post-mining monitoring of pit lake depth and water quality (pH and salinity).

Post-mining (2022-2031). Not yet required.

7

The presence of exposed PAF materials, metals and metalloids in the mine pit walls and potential risks to the surrounding environment will be investigated after the completion mining.

Post-mining (2022). Not yet required.

8 Apply for relinquishment.

Post-mining (2022 – 2031, when evidence is available of the achievement of completion criteria).

Not yet required.

8. Rehabilitation Materials

The following materials will be required for rehabilitation and closure of the J1 mine pits:

Approximately 32,000bcm of insert waste rock for construction of the pit abandonment bund.

9. Bond Retirement and Relinquishment Strategy

Bond retirement is not applicable to mine pits as pits are not bonded by the DMP. Cliffs will apply to relinquish the J1 mine pits upon the attainment of the closure objectives and completion criteria shown in Table 10.2.

Table 10.2 Mt Jackson J1 Project Mine Pits Management Unit Completion Criteria

Aspect Closure Objective Interim Completion Criteria

Public safety. Ensure that the land is physically safe for people to access.

Appropriate safety and abandonment structures are in place (based on DMP (1997) guidelines).


Page 41

10.4 WASTE ROCK LANDFORM MANAGEMENT UNIT

WASTE ROCK LANDFORM CLOSURE IMPLEMENTATION PLAN

Scope:

J1 Waste Rock Landform.

Topsoil, vegetation and gravel stockpiles adjacent to the WRL.

Explosives storage.


Location Tenements M77/993 and M77/994 (Figure 10.3).

Area of disturbance The Waste Rock Landform Management Unit comprises one WRL.

Total 211ha.

Current Status Active – construction commenced in Q3 2011.

Closure date Mining is expected to be completed in 2021.

Relationship with other plans This Waste Rock Landform Management Unit Closure Implementation Plan should be coordinated with the Mine Pit Management Unit Closure Implementation Plan with respect to surface water management.

Figure 10.2 J1 Waste Rock Landform Management Unit


Mining commenced in Q3 2011, with construction of the WRL coinciding with the commencement of mining. Construction of the WRL will occur throughout the life of the mining project, to be completed in 2021 upon the cessation of mining.


Page 42

3. Risk Assessment

The main risks associated with the WRL were identified as being:

• Landform stability and the control of water runoff and erosion.

• Placement of saline or PAF waste rock near the surface of the WRL, thereby potentially compromising revegetation outcomes.



Cliffs Closure Implementation Plan for the J1 WRL Management Unit is based on the following assumptions:

Surfaces for implementing rehabilitation and conducting trials will not become available until 2014.

Mining will be completed in 2021 to final design (i.e. no further pit expansions are planned).

Waste rock above 505mAHD is considered to be non-saline, non-PAF and suitable for placement on the outer surface of the WRL.

Waste rock between 505mAHD and the groundwater level (417mAHD) is considered to be acidic, inhibitory to plant growth and unsuitable for the outer surfaces of the WRL.

Waste rock below the groundwater level (417mAHD) is considered to be saline and PAF, inhibitory to plant

growth and unsuitable for the outer surfaces of the WRL.

No infrastructure related to the WRL is to be retained post-mining.

5. Knowledge Gaps

Current knowledge gaps relating to the J1 WRL Management Unit relate to:

The selection and characterisation of suitable reference sites in order to develop appropriate completion criteria for landform stability and revegetation; and

Appropriate seed mix, seed treatments and seeding rate to apply to promote Conditions and treatments required to promote the re-establishment of native vegetation and in particular populations of Bossiaea sp. Jackson Range, Spartothamnella sp. Helena & Aurora Range, and Calytrix sp. Paynes Find.

Reference sites will be selected and characterised with respect to aspect, gradient, soil, vegetation and flora during the first three years of the Mt Jackson J1 Deposit mining operations.

A research program will be implemented to investigate factors influencing the rehabilitation success native vegetation including Bossiaea sp. Jackson Range, Spartothamnella sp. Helena & Aurora Range, and Calytrix sp. Paynes Find, as required by Condition 8-1(5) of EP Act 1986 Statement 843, within the first three years of the Mt Jackson J1 Deposit mining operations.


Prior to mining

Prior to mining the following activities will be implemented in support of mine rehabilitation and closure:

Prior to land clearing, collect seed from the disturbance area for use in rehabilitation.

Retain recoverable surface soils and associated vegetation debris from within the boundary of the proposed pits prior to mining.

During mining

During mining the following activities will be implemented in support of mine rehabilitation and closure:

Reference Sites will be selected and characterised with respect to aspect, gradient, soil, vegetation and flora during the first three years of the Mt Jackson J1 Deposit mining operations.

Development of a monitoring program for the WRL that addresses the potential for seepage and metalliferous drainage both during operations and the post-mining period.

Progressive rehabilitation of the WRL will be carried out throughout the life of the mine as each lift of the

WRL is completed.

Progressive rehabilitation comprises:

Spreading retained topsoil to a depth of approximately 0.2m.

Deep-ripping on contour.

Seeding with a broad mix of native species of local provenance.

Conducting trials on the re-establishment of native vegetation, including Bossiaea sp. Jackson Range, Spartothamnella sp. Helena & Aurora Range and Calytrix sp. Paynes Find.

Monitoring of rehabilitated sites and relevant reference sites to verify and refine completion criteria.


Page 43

Post-mining


Investigate WRL as-built characteristics with respect to geotechnical stability, surface water management, soil/subsoil physical and chemical properties and implications for long-term stability and vegetation growth.

Annual monitoring of landform stability and revegetation until agreed completion criteria are met.

7. Task Register


1 Collect seed from mining areas for use in rehabilitation.


Seed not collected in 2011. There is currently little seed available for collection due to low rainfall conditions experienced in recent years.

2 Retain surface soils and associated vegetation debris (where recoverable surface soil occurs).


Stripping and stockpiling of surface soils and associated vegetation debris commenced in Q1 2011.

3 Select and characterise Reference Sites. Within first three years of mining.

Not yet undertaken.

4

Prepare a scope of work to investigate rehabilitation of Bossiaea sp. Jackson Range, Spartothamnella sp. Helena & Aurora Range and Calytrix sp. Paynes Find.

2011. Submitted to EPA (17 February 2011).

5

Develop a monitoring program for the WRL that addresses the potential for seepage and metalliferous drainage both during operations and the post-mining period.

2013 Not yet undertaken.

6 Earthworks to shape, spread topsoil and deep rip.

Progressively throughout

mining. WRL areas become available for rehabilitation from 2014 onwards.

Not yet required.

7 Seeding.

Progressively throughout mining. WRL areas become available for rehabilitation from 2014 onwards.

Not yet required.

8 Conducting revegetation trials.

Progressively throughout mining. WRL areas become available for rehabilitation from 2014 onwards.

Not yet required.

9 Monitoring of progressive rehabilitation and development of final completion criteria.

Progressively throughout mining. Monitoring would commence 12 months after the implementation of rehabilitation works.

Not yet required.

10 Investigate as-built WRL characteristics. Post-mining (2021). Not yet required

11 Post-mining monitoring of rehabilitation against final completion criteria.

Post-mining (2021 - 2031).

Not yet required


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12 Apply for relinquishment

Progressively throughout

post-mining period (2022 - 2031 i.e. when evidence is available of the achievement of completion criteria).

Not yet required


The following materials will be required for rehabilitation and closure of the J1 WRL:

A minimum of 422,000bcm of surface soils is required for surfacing the WRL (to a depth of approximately 0.2m).

A minimum of 10.6 million bcm of benign waste rock is required for surfacing the WRL to a depth of 5m over commingled benign/hostile waste rock.

Approximately 1700kg of seed is required to seed the WRL at a nominal seeding rate of 8kg/ha.


Cliffs will apply to retire the bond and relinquish the J1 WRL according to the completion criteria shown in

Table 10.3.

Table 10.3 Mt Jackson J1 Project Waste Rock Landform Management Unit Completion Criteria

DMP bond reduction and

retirement criteria

Aspect Closure Objectives Interim Completion Criteria

Stage 1: Primary earthworks (50% bond reduction):

Structure stable

Erosion controlled

Water run-off managed

effectively

Landform stability Ensure that final landforms are stable and erosion is controlled to an acceptable level, comparable to that of the surrounding landscape within 100km.

WRL slopes constructed to design criteria (nominally 15o).

WRL berms minimum of 5m width and backward sloping (between 5o and 10o).

Surface water drainage is effectively controlled.

Stage 2: Finishing earthworks (30% bond reduction):

Appropriate soil cover

Adequate contour ripping

Demonstrated stability and erosion control

Soils (cover systems)

Ensure that reconstructed soil profiles are stable and capable of supporting resilient and self-sustaining native vegetation.

Surface cover comprises a combination of 0.2m soil; erosion protection by rock/gravel; and vegetation debris.

Sub-surface material comprises a minimum 5m layer of benign waste rock.

Stage 3: Revegetation (20% bond reduction):

Vegetation established (but not demonstrated to be self-sustaining)

Vegetation Re-establish native vegetation (within the limits of leading-practice rehabilitation techniques and the capability of the post-mining soil/waste rock cover system) comparable to undisturbed natural vegetation within 100km.

Foliar cover of perennial native species 20% — 70% of the average of three

reference sites.

Species richness of perennial native flora 20% — 70% of the average of three reference sites.

Plant density of perennial native species 20% — 70% of the average of three reference sites.


Page 45

Weed control program

commenced

Grazing control commenced

Ensure that weeds are

effectively controlled.

Coverage of weed species

is less than the average of three reference sites on nearby land.


Grazing by introduced animal species is managed such that it does not significantly impact on rehabilitation ecology.

Stage 4: Relinquishment:

All criteria met

Sustainability Establish resilient and self-sustaining native vegetation.

Foliar cover of perennial native species remains 20% — 70% of the average of three reference sites for five consecutive years post-mining.

Species richness of perennial native flora

remains 20% — 70% of the average of three reference sites for five consecutive years post-mining.

Plant density of perennial native species remains 20% — 70% of the average of three reference sites for five consecutive years post-mining.

Establish rehabilitated landforms that are capable of providing habitat for a variety of vertebrate and invertebrate species.

Rehabilitated landforms provide habitat and food resources for a variety of vertebrate and invertebrate species.

Ensure that rehabilitated landforms are safe, stable, non-polluting and compatible with surrounding land-uses and stakeholder expectations.

Abandonment safety and water management structures remain in place and effective.

Emissions and discharges from rehabilitated lands (e.g. sediment, leachate) do not result in off-site impacts to soil, water or vegetation.

Ensure that post-mining land management requirements are comparable to that of the surrounding, undisturbed landscape.

Rehabilitated landforms do not require ongoing management of stability, erosion, drainage, and soil or water contamination.


Page 46

10.5 INFRASTRUCURE AREA MANAGEMENT UNIT

INFRASTRUCTURE AREA CLOSURE IMPLEMENTATION PLAN

Scope:

Ore stockpiles.

Workshops and maintenance areas.

Vehicle parking areas.

Wash bay.

Hydrocarbon storage.

Power plant.

Mine administration offices.

Water treatment plant.

Explosives Storage.

Water storages.

Drainage and diversion channels.

Roads.

Topsoil, vegetation and gravel stockpiles adjacent to the mining infrastructure.


Location Tenements M77/994 and M77/1249 (Figure 10.3)

Area of disturbance 225ha

Current Status Active – construction is expected to commence in Q3 2011.

Closure date Mining is expected to be completed in 2021. These facilities and infrastructure will be required at least until the completion of mining and will be progressively decommissioned during the post-mining phase when they are no longer required to support for rehabilitation and closure activities.

Relationship with other plans Nil.


Page 47

Figure 10.3 J1 Infrastructure Area Management Unit


Construction commenced in 2011. Mining infrastructure will be require throughout the life of the Mt Jackson J1 Deposit mining operations so decommissioning and rehabilitation are not expected to be required until 2021 at the earliest.

3. Risk Assessment

The main potential risks associated with the infrastructure area were identified as being:

Soil contamination;

Salinisation of roads from dust suppression using saline groundwater; and

Removal and disposal of man-made structures and materials.



Cliffs Closure Implementation Plan for the J1 Infrastructure Area Management Unit is based on the following assumptions:

No infrastructure related to the Infrastructure Area is to be retained post-mining for transfer to third parties for beneficial uses.

Any soil identified as contaminated will be excavated and disposed of by burial into the WRL where it will

be capped and isolated.

5. Knowledge Gaps

The current knowledge gaps relating to the J1 Infrastructure Area Management Unit relates to the selection and characterisation of suitable reference sites in order to develop appropriate completion criteria for landform stability and revegetation.


Page 48


Prior to mining

Prior to mining, the following activities will be implemented in support of mine rehabilitation and closure:



During mining

Reference Sites will be selected and characterised with respect to aspect, gradient, soil, vegetation and flora during the first three years of the Mt Jackson J1 Deposit mining operations.

Post-mining


Above-ground infrastructure that has no further foreseeable use will be dismantled and removed from the mine site for re-use, recycling or disposal as appropriate. Water storages would be backfilled and graded.

Buried infrastructure (such as telecommunications cabling) will be left in situ. Groundwater bores will be capped or plugged.

Mining equipment and supplies (such as mechanical equipment and parts) will be removed from site for re-use, recycling or disposal as appropriate.

Site contamination will be investigated and remediated (as appropriate). Contaminated materials will be excavated and disposed of to the WRL where it will be capped and isolated.

Disturbed areas will be shaped to blend with the contours of the surrounding landscape.

Disturbed areas will be topsoiled to a depth of 0.2m, deep ripped and seeded with a broad mix of native species of local provenance.

Monitoring of landform stability and revegetation will be carried out annually until agreed completion criteria are met.

7. Task Register



Prior to ground disturbance

Not yet implemented. There is currently little seed available for collection due to low rainfall conditions experienced in recent years.


Prior to ground disturbance


3 Select and characterise reference sites. Within first three years of mining.

Not yet undertaken.

4 Investigate site contamination Post-mining (2022)

Not yet required

5 Decommission, dismantle and remove above-ground infrastructure

Post-mining (2022 onwards; when no longer required for other purposes)

Not yet required

6 Earthworks to shape, spread topsoil and deep rip

Post-mining (2022 onwards)

Not yet required

7 Seeding Post-mining (2022 onwards)

Not yet required

8 Monitoring of rehabilitation, development of final completion criteria and further monitoring against final completion criteria

Post-mining (2022 - 2031)

Not yet required


Page 49

9 Apply for relinquishment

Post-mining (2022

– 2031, when evidence is available of the achievement of completion criteria).

Not yet required


The following materials will be required for rehabilitation and closure of the J1 Infrastructure Area:

450,000bcm of topsoil required for surfacing the Infrastructure Area to a depth of 0.2m.

Approximately 1800kg of seed is required to seed the Infrastructure Area at a nominal seeding rate of 8kg/ha.


Cliffs will apply to retire the bond and relinquish the J1 Infrastructure Area according to the completion criteria shown in Table 10.4.

Table 10.4 Mt Jackson J1 Project Infrastructure Area Management Unit Completion Criteria


retirement criteria



Structure stable

Erosion controlled

Water run-off managed effectively


Reinstatement of pre-disturbance contours.








Surface cover comprises a combination of 0.2m soil;

erosion protection by rock/gravel; and vegetation debris.

Stage 3: Revegetation (20% bond reduction):


Vegetation Re-establish native vegetation (within the limits of leading-practice rehabilitation techniques and the capability of

the post-mining soil/waste rock cover system) comparable to undisturbed natural vegetation within 100km.

Foliar cover of perennial native species ≥20% — 70% of the average of three reference sites.

Species richness of perennial native flora ≥20% — 70% of the average of three reference sites.

Plant density of perennial native species ≥20% — 70% of the average of three reference sites.


Page 50

Weed control program

commenced


Ensure that weeds are

effectively controlled.

Coverage of weed species

is less than the average of three reference sites on nearby land.




All criteria met


Foliar cover of perennial native species remains ≥20% — 70% of the average of three reference sites for five consecutive years post-mining.


remains ≥20% — 70% of the average of three reference sites for five consecutive years post-mining.

Plant density of perennial native species remains ≥20% — 70% of the average of three reference sites for five consecutive years post-mining.



Ensure that rehabilitated landforms are safe, stable, non-polluting and compatible with surrounding land-uses and stakeholder expectations.

Abandonment safety and water management structures remain in place and effective.

Man-made structures and materials are removed (unless otherwise approved)

Contaminated soil is managed





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10.6 HAUL ROAD MANAGEMENT UNIT

HAUL ROAD CLOSURE IMPLEMENTATION PLAN

Scope:

J1 Haul Road connecting to Mt Jackson J2/J3 mine haul road.

Gravel Pit.


Location Tenements M77/1248 and L77/216 (Figure 10.4).

The haul road intersects with the Bullfinch-Evanston Road, which is a public road.

Area of disturbance J1 Haul Road connecting to Mt Jackson J2/J3 mine haul road up to 44ha.

Gravel Pit 11ha.

Total 55ha.

Current Status Active.

Closure date Mining is expected to be completed in 2021. The haul road will be required at least until the completion of mining and will be rehabilitated during the post-mining phase if no longer required.

Relationship with other plans Nil.

Figure 10.4 J1 Haul Road Management Unit


The haul road commenced construction in Q1 2011. The gravel pit was created during 2011 in conjunction with construction of the haul road.

3. Risk Assessment


Page 52

The main risk associated with the haul road was identified as being:

Salinisation of roads from dust suppression using saline groundwater.



Cliffs Closure Implementation Plan for the J1 Haul Road Management Unit is based on the following assumptions:

Although Cliffs’ EP Act 1986 conditions permit the retention of the haul road post-mining, this MCP currently assumes that the haul road not be retained. The Closure Task Register includes activities for the rehabilitation and closure of the haul road. The closure financial provisions in Section 9 include provisions for rehabilitation of the haul road.

The gravel pit would be rehabilitated at the same time as the haul road.

5. Knowledge Gaps

The current knowledge gaps relating to the J1 Haul Road Management Unit relates to the selection and characterisation of suitable reference sites in order to develop appropriate completion criteria for landform stability and revegetation.


Prior to mining

Prior to mining, the following activities will be implemented in support of mine rehabilitation and closure:



During mining

Reference sites will be selected and characterised with respect to aspect, gradient, soil, vegetation and flora during the first three years of the Mt Jackson J1 Deposit mining operations.

Post-mining


The haul road and gravel pit will be shaped to blend with the contours of the surrounding landscape.

Topsoil will be spread to a depth of 0.2m, deep ripped and seeded with a broad mix of native species of local provenance.

Monitoring of landform stability and revegetation will be carried out annually until agreed completion criteria are met.

7. Task Register




Seed not collected in 2011. There is currently little seed available for collection due to low rainfall conditions experienced in recent years.




3 Select and characterise reference sites. Within first three years of mining.

Not yet undertaken.

4 Earthworks to shape, spread topsoil and deep rip.

Post-mining (2022 onwards; when no haul road longer required for other purposes).

Not yet required.

5 Seeding. Post-mining (2022 onwards).

Not yet required.


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6

Monitoring of rehabilitation, development of

final completion criteria and further monitoring against final completion criteria.

Post-mining (2022

- 2031) Not yet required.

7 Apply for relinquishment.

Post-mining (2022 – 2031, when evidence is available of the achievement of completion criteria).

Not yet required.


The following materials will be required for rehabilitation and closure of the J1 haul road and gravel pit:

110,000bcm of topsoil required for surfacing the rehabilitation areas to a depth of 0.2m.

Approximately 440kg of seed is required to seed the rehabilitation areas at a nominal seeding rate of

8kg/ha.


Cliffs will apply to retire the bond and relinquish the J1 haul road and gravel pit according to the completion criteria shown in Table 10.5.

Table 10.5 Mt Jackson J1 Project Haul Road Management Unit Completion Criteria


retirement criteria



Structure stable

Erosion controlled

Water run-off managed effectively










Surface cover comprises a combination of 0.2m soil;

erosion protection by rock/gravel; and vegetation debris.


Page 54

Stage 3:

Revegetation (20% bond reduction):


Weed control program commenced


Vegetation Re-establish native vegetation

(within the limits of leading-practice rehabilitation techniques and the capability of the post-mining soil/waste rock cover system) comparable to undisturbed natural vegetation within 100km.

Foliar cover of perennial

native species ≥20% — 70% of the average of three reference sites.

Species richness of perennial native flora ≥20% — 70% of the average of three reference sites.

Plant density of perennial native species ≥20% — 70% of the average of three reference sites.

Ensure that weeds are effectively controlled.

Coverage of weed species is less than the average of three reference sites on nearby land.




All criteria met


Foliar cover of perennial native species remains ≥20% — 70% of the average of three reference sites for five consecutive years post-mining.

Species richness of perennial native flora remains ≥20% — 70% of the average of three reference sites for five

consecutive years post-mining.

Plant density of perennial native species remains ≥20% — 70% of the average of three reference sites for five consecutive years post-mining.




Page 55

Ensure that rehabilitated

landforms are safe, stable, non-polluting and compatible with surrounding land-uses and stakeholder expectations.

Abandonment safety and

water management structures remain in place and effective.

Man-made structures and materials are removed (unless otherwise approved)

Contaminated soil is managed


Ensure that post-mining land

management requirements are comparable to that of the surrounding, undisturbed landscape.

Rehabilitated landforms do

not require ongoing management of stability, erosion, drainage, and soil or water contamination.


Page 56

10.7 GENERAL REHABILITATION AND CLOSURE ACTIVITIES

In addition to the rehabilitation and closure activities specified for each management unit in

Sections 10.3 to 10.6, there are several activities that apply to the Mt Jackson J1 Project as

a whole (Table 10.6).

Table 10.6 General rehabilitation and closure activities applicable to the Mt Jackson J1 Deposit mining operations

No. Description Timing

1 Maintenance of Mine Closure Plan. Every three years at a minimum throughout mining and post-mining period (2011 – 2031)

2 Project Management, Engineering and Survey.

Annually post-mining for an estimated period of 10 years

(2021 – 2031)

3 Post-mining environmental monitoring and reporting.

Annually post-mining for an estimated period of 10 years

(2021 – 2031)

4 Post-mining stakeholder engagement. Annually post-mining for an estimated period of 10 years

(2021 – 2031)

5 Weed control. Annually post-mining for an estimated period of 10 years

(2021 – 2031)

6 Post-mining maintenance earthworks. During post-mining period (2021 – 2031)

7 Equipment mobilisation and de-mobilisation.

During post-mining period (2021 – 2031)


Page 57

10.8 UNPLANNED CLOSURE

Care and maintenance procedures will be implemented in the event mining operations are

suspended. The extent and detail of procedures will be dependent in part on the nature and

duration of any suspension of mining operations. An overall objective of measures

undertaken in any care and maintenance phase will be to reduce safety and environmental

risk.

Rehabilitation activities during unplanned closure would generally include:

maintenance of environmental monitoring and reporting programmes;

removal of hazardous materials and fuel from site (other than to maintain essential

services and subject to the duration of any suspension);

dewatering saline water storage dams and any other water points;

earthworks to stabilise/contain any works in progress that constitute an unacceptable

erosion risk;

covering landfill sites;

installation of additional safety measures (signage, fencing, bunding) as may be

necessary to ensure safety in the absence of an active mining operation;

retention of a site caretaker to ensure essential maintenance and that safety

precautions such as barriers and signage are kept in good order; and

removal or storage of equipment/infrastructure to protect from fire.

The full scope of a care and maintenance programme will be agreed with relevant

authorities in the event of a decision to suspend mining operations.


Page 58

11. MONITORING AND MAINTENANCE

The objectives of rehabilitation monitoring are to:

evaluate the progress of rehabilitated areas towards achieving the completion criteria

for each Management Unit;

reveal the need for any remedial actions in the event that rehabilitation is failing;

determine whether rehabilitation is likely to achieve the stated completion criteria;

review and refine the effectiveness of the rehabilitation methods used; and

demonstrate to stakeholders the attainment of rehabilitation completion criteria for the

purposes of bond recovery and land relinquishment.

Monitoring of rehabilitated landforms will facilitate the quantitative and objective evaluation

of rehabilitation progress against the stated completion criteria. Table 11.1 provides an

overview of the monitoring that would be carried out for different rehabilitated landforms.

Table 11.2 provides further detail of specific monitoring programs related to Cliffs’ closure

objectives and completion criteria. Monitoring will be conducted during operations and for a

post mining 10 year period. Reference sites would be monitored at the same time, using

the same survey parameters and methods, to compare and contrast temporal trends

observed at rehabilitated sites.

Table 11.1 Overview of rehabilitation and closure monitoring

Rehabilitated

Landforms

Aspect

Public

Safety

Landform

stability Soil Vegetation Water Fauna Contamination

J1 East Pit

(dry)

J1 West Pit (Post-mining Pit Lake)

Waste Rock Landform

Infrastructure Area

Haul Road


Page 59

Table 11.2 Closure objectives, completion criteria and related monitoring methodology

Aspect Cliffs’ Closure Objectives Interim Completion Criteria Monitoring Methodology


Waste Rock Landform constructed to design criteria.


Audit of rehabilitated landforms against design criteria.


Qualitative assessment of erosion (e.g. rills, gullies, piping) and sedimentation in water management structures (e.g. rip lines, berms).

Public safety Ensure that the land is physically safe for people to access and does not pose a human health risk.

Appropriate safety and abandonment structures are in place.

Audit of rehabilitated landforms against relevant standards and guidelines.

Soils (cover systems) Ensure that reconstructed soil profiles are stable and capable of supporting a resilient and self-sustaining native vegetation community.

Surface cover comprises a combination of 0.2m soil; erosion protection by rock/gravel; and vegetation debris.


Sub-surface material comprises a minimum 5m layer of benign waste rock (applicable only to Waste Rock Landform Management Unit).


Vegetation Re-establish native vegetation (within the limits of leading-practice rehabilitation techniques and the capability of the post-mining soil/waste rock cover system).

Foliar cover of perennial native species ≥20% of the average of three reference sites.

Quantitative assessment of foliar cover of perennial native vegetation at rehabilitated landforms and Reference Sites

Species richness of perennial native flora ≥20% of the average of three reference sites.

Quantitative assessment of perennial native vegetation species richness at rehabilitated landforms and Reference Sites

Plant density of perennial native species ≥20% of the average of three reference sites.

Quantitative assessment of perennial native vegetation plant density at rehabilitated landforms and Reference Sites

Ensure that weeds are effectively controlled. Coverage of weed species is less than the average of three reference sites on nearby land.

Quantitative assessment of weed foliar cover.


Page 60

Aspect Cliffs’ Closure Objectives Interim Completion Criteria Monitoring Methodology



Qualitative assessment of grazing impacts on perennial native vegetation at rehabilitated landforms.

Sustainability Establish resilient and self-sustaining vegetation assemblages.

Foliar cover of perennial native species remains ≥20% of the average of three reference sites for five consecutive years post-mining.

Quantitative assessment of foliar cover of perennial native vegetation at rehabilitated landforms and Reference Sites.


remains ≥20% of the average of three reference sites for five consecutive years post-mining.

Quantitative assessment of perennial native

vegetation species richness at rehabilitated landforms and Reference Sites.

Plant density of perennial native species remains ≥20% of the average of three reference sites for five consecutive years post-mining.

Quantitative assessment of perennial native vegetation plant density at rehabilitated landforms and Reference Sites.

Establish rehabilitated landforms that are capable of providing habitat for fauna.


Qualitative observation (or evidence) of native vertebrate and invertebrate fauna occurring on rehabilitated landforms.

Ensure that rehabilitated landforms are safe,

stable, non-polluting and compatible with surrounding land-uses and stakeholder expectations.

Abandonment safety and water

management structures remain in place and effective.

Assessment of erosion, sedimentation and

physical condition of rehabilitated landform.

Man-made structures and materials are removed (unless otherwise approved).

Audit of decommissioning and rehabilitation actions carried out against Mine Closure Plan.

Contaminated soil is managed. Quantitative assessment of contaminants at contaminated sites (e.g. hydrocarbons).

Emissions and discharges from rehabilitated lands (e.g. sediment and leachate) do not result in off-site impacts to

soil, water or vegetation.

Quantitative assessment of groundwater quality and vegetation downstream of WRL and identified contaminated areas.



Identified as an outcome of the monitoring programs described above.


Page 61

12. INFORMATION MANAGEMENT

Information relevant to mine rehabilitation and closure includes:

approvals documentation (e.g. Mining Proposals, Environmental Impact Statements);

geological and geotechnical data;

operational records (e.g. mining and production records, sulphidic waste rock handling

records, soil stripping and stockpiling records, Annual Environmental Reports);

design and construction documentation (e.g. design and construction reports for

WRLs, pits);

types, locations, and quantities of stored wastes (e.g. landfill records, bioremediation

records, contaminated soil records);

environmental baseline studies, surveys and monitoring reports and data;

rehabilitation data (e.g. design and specifications for final landform construction and

rehabilitation, survey records of as-built landforms, rehabilitation treatments

implemented at specific landforms); and

minutes of stakeholder consultation meetings.

Cliffs’ spatial data is held in its Geographical Information System (GIS) in Surpac® and

MapINFO®. Relevant documents are catalogued electronically and accessed via Sharepoint®

and Compass®. Technical reports supporting rehabilitation and mine closure planning of the

Mt Jackson J1 Deposit mining operations are not appended to this MCP due to the size and

number of these documents. A bibliography of existing documents relevant to rehabilitation

and closure of the Mt Jackson J1 Deposit mining operations is presented in Attachment 1.

This suite of documents relevant to rehabilitation and mine closure will continue to expand

as the project advances and further studies and monitoring activities are carried out.


Page 62

13. REFERENCES

ANZMEC / MCA. 2000. Strategic Framework for Mine Closure. Australian and New Zealand

Minerals and Energy Council / Minerals Council of Australia.

AS/NZS. 2004. AS/NZS 4360:2004 Risk Management. Standards Australia / Standards New

Zealand.

BCE. 2009. Fauna Surveys of the Mt Jackson Range, Western Australia, 2000 to 2008.

Report prepared by Bamford Consulting Ecologists for Cliffs Asia Pacific Iron Ore Pty

Ltd (formerly as Portman Iron Ore Limited), April 2009.

Cliffs. 2009. Koolyanobbing Iron Ore Project - Mt Jackson J1 Deposit Environmental Impact

Assessment (Public Environmental Review). Prepared by Globe Environments Australia

Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd, Perth, Western Australia. Revision H,

July 2009.

Cliffs. 2010a. Yilgarn Operations – Rehabilitation and Closure System Manual. Cliffs Asia

Pacific Iron Ore Pty Ltd, Perth, Western Australia.

Cliffs. 2010b. Koolyanobbing Iron Ore Project Mt Jackson J1 Deposit – Mining Act 1978

Mining Proposal. Prepared by Globe Environments Australia Pty Ltd for Cliffs Asia

Pacific Iron Ore Pty Ltd, Perth, Western Australia. Revision F, August 2010.

Cliffs. 2010c. FIN056 Financial Processes Iron Ore Rehabilitation Provisions. Cliffs Asia


DIA. 2009. Aboriginal Heritage Inquiry System Search: Local Government Area Yilgarn.

Department of Indigenous Affairs website http://www.dia.wa.gov.au. Accessed 13

July 2009.

DMP. 2007. Mineral Exploration/Rehabilitation Activities Guidelines. Department of Mines

and Petroleum, Perth, Western Australia.

DMP/EPA. 2011. Guidelines for Preparing Mine Closure Plans. Department of Mines and

Petroleum / Environmental Protection Authority, Perth, Western Australia.

EGI. 2009. Exploratory Assessment of Drill Core Samples from the Mt Jackson J1 Deposit,

WA. Unpublished report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd by

Environmental Geochemistry International Pty Ltd, August 2009.

ICMM. 2008. Planning for Integrated Mine Closure: Toolkit. International Council on

Mining and Metals, London, United Kingdom.

Nichols, O. 2010. Development of Completion Criteria for Different Regions. Workshop on

Integrating Sustainability into Life-of-Mine Planning held by the Sustainable Minerals

Institute, 19-23 April 2010, Fremantle, Western Australia.


Page 63

NNTT. 2008a. Native Title Determinations Search - Western Australia. National Native Title

Tribunal webpage http://www.nntt.gov.au. Accessed 4 August 2008.

NNTT. 2008b. Native Title Applications Search – Shire of Yilgarn. National Native Title

Tribunal webpage http://www.nntt.gov.au. Accessed 12 August 2008.

Rockwater. 2003. Groundwater Supplies for Koolyanobbing-Windarling Haul Road –

Completion Report for Drilling, Bore Construction and Test-Pumping. Report

Unpublished report prepared by Rockwater Pty Ltd for Cliffs Asia Pacific Iron Ore Pty

Ltd, Perth, Western Australia.

Rockwater. 2007a. Koolyanobbing Iron Ore Project Mt Jackson J1 Deposit - Numerical

Modelling of Groundwater Dewatering. Unpublished report prepared by Rockwater Pty

Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd, Perth, Western Australia.

Rockwater. 2007b. Mt Jackson J1 Deposit Bore Completion Report. Unpublished report

prepared by Rockwater Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd, Perth, Western

Australia.

Rockwater. 2009. Mt Jackson J1 Deposit: J1 West Pit, Assessment of Final Void Water

Level and Salinity. Unpublished report prepared by Rockwater Pty Ltd for Cliffs Asia


SWC. 2011a. Soil Characterisation for the Mt Jackson J1 Deposit. Unpublished report

prepared by Soil Water Consultants Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd,

Perth, Western Australia.

SWC. 2011b. Mt Jackson Range J1 Deposit Geochemical Characterisation. Unpublished

report prepared by Soil Water Consultants Pty Ltd for Cliffs Asia Pacific Iron Ore Pty

Ltd, Perth, Western Australia.

WB. 2009. Flora and Vegetation of the Western Jackson Range (Mt Jackson Range)

Western Australia. Unpublished report prepared by Rockwater Pty Ltd for Cliffs Asia



Page 64

14. ABBREVIATIONS

AHD Australian Height Datum

ANC Acid Neutralising Capacity

ARI Annual Recurrence Interval

AUD Australian Dollars

Cliffs Cliffs Asia Pacific Iron Ore

CRG Community Reference Group

DAF Department of Agriculture and

Food

DEC Department of Environment and

Conservation

DIA Department of Indigenous Affairs

DMP Department of Mines and

Petroleum

DPI Department for Planning and

Infrastructure

DoW Department of Water

DoSEWPC Department of

Sustainability, Environment, Water,

Population and Communities

ENSO El Nino Southern Oscillation

EP Act Environmental Protection Act 1986

EPA Environmental Protection Authority

EPBC Environmental Protection and

Biodiversity Conservation Act 1999

GIS IUCN International Union for the

Conservation of Nature

MCP Mine Closure Plan

NAF Not Acid Forming

PAF Potentially Acid Forming

RCS Rehabilitation and Closure System

SMU Soil Management Unit

TDS Total Dissolved Solids

UCL Unallocated Crown Land

WRL Waste Rock Landform


Page 65

ATTACHMENTS


Page 66


Page 67

ATTACHMENT 1 BIBLIOGRAPHY RELEVANT TO REHABILITATION AND CLOSURE OF MT JACKSON J1 DEPOSIT MINING OPERATIONS


Page 68

Table A1 Bibliography relevant to rehabilitation and closure of the Mt Jackson J1

Deposit mining operations

Artefaxion. 2007. Archaeological Survey of the J1 Project Area and Proposed Haul Road

Corridor. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman

Iron Ore Limited), March 2007.

Artefaxion. 2009. Archaeological Test Pitting of the Curragibbin Hill Rockshelter. Report

prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore

Limited), February 2009.

Bamford Consulting Ecologists. 2006. Fauna Assessment of the J1 Mining Area. Report


Limited), March 2006.

Bamford Consulting Ecologists. 2007. Field Survey for Trapdoor Spiders (Mygalomorphae)

at the J1 Project Area, Mt Jackson. Report prepared for Cliffs Asia Pacific Iron Ore Pty

Ltd (formerly as Portman Iron Ore Limited), May 2007.

Bamford Consulting Ecologists. 2009. Fauna Surveys of the Mt Jackson Range, Western

Australia, 2000 to 2008. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd

(formerly as Portman Iron Ore Limited), April 2009.Bennelongia Pty Ltd. 2008.

Troglofauna survey of the Mt Jackson Range, Western Australia. Report prepared for

Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore Limited), December

2008.

Biota Environmental Sciences. 2009. Targeted Survey for Short Range Endemic Fauna

Invertebrates at Mt Jackson Range, Western Australia. Report prepared for Cliffs Asia

Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore Limited), February 2009.

Biota Environmental Sciences. 2009. Mt Jackson J1 Deposit – Preliminary Summary of

Additional Millipede Sampling, August 2009. Report prepared for Cliffs Asia Pacific

Iron Ore Pty Ltd, September 2009.

Biota Environmental Sciences. 2009. Mt Jackson J1 Deposit – Summary of Atelomastix

Sampling, August 2009. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd,

November 2009.

Cliffs Asia Pacific Iron Ore Pty Ltd. 2003. Koolyanobbing Expansion Project – Agreement

with the Department of Conservation and Land Management. September 2003.

Cliffs Asia Pacific Iron Ore Pty Ltd. 2008. Operating Strategy for Water Supply Borefield -

Koolyanobbing Project Northern Haul Road Network and Minesite Facilities. January

2008.


Page 69

Cliffs Asia Pacific Iron Ore Pty Ltd. 2009. Koolyanobbing Iron Ore Project – Mt Jackson J1

Deposit: Environmental Protection Act 1986 Environmental Impact Assessment (Public

Environmental Review). Report prepared by Globe Environments Australia Pty Ltd for

Cliffs Asia Pacific Iron Ore Pty Ltd, Revision H, July 2009.


Deposit: Environment Protection and Biodiversity Conservation Act 1999

Environmental Impact Assessment. Report prepared by Globe Environments Australia

Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd, Revision C, June 2009.

Cliffs Asia Pacific Iron Ore Pty Ltd. 2019. Koolyanobbing Iron Ore Project Mt Jackson J1

Deposit – Shire of Yilgarn Town Planning Scheme No 2: Application for Planning

Approval – Supporting Documentation. Report prepared by Globe Environments

Australia Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd, Revision C, December 2009.


Deposit Decommissioning and Rehabilitation Plan. Report prepared by Globe

Environments Australia Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd, Revision G,

January 2010.


Deposit – Mining Act 1978 Mining Proposal – Tenements M77/993, M77/994,

M77/1248, M77/1249 and L77/216. Report prepared by Globe Environments Australia

Pty Ltd for Cliffs Asia Pacific Iron Ore Pty Ltd, Revision F, August 2010.


Deposit – Implementation Statement 843, Condition 8, Rehabilitation Investigation

Scope of Works. Report prepared by Globe Environments Australia Pty Ltd for Cliffs

Asia Pacific Iron Ore Pty Ltd, Revision E, February 2011.

Department of Environment and Conservation. 2010. Environmental Protection Act 1986

Licence 5058/9. Issued to Cliffs Asia Pacific Iron Ore Pty Ltd on 17 September 2010.

Department of Environment, Water, Heritage and the Arts. 2009. Approval: Koolyanobbing

Iron Ore Project – Mt Jackson J1 Deposit, WA (EPBC 2008/4449). Approval to Cliffs

Asia Pacific Iron Ore Pty Ltd under s133 of the Environment Protection and Biodiversity

Conservation Act 1999 (C’th) dated 30 September 2009.

Department of Environment, Water, Heritage and the Arts. 2009. EPBC Protected Matters

Report. Protected Matters Search Tool report for the Mt Jackson J1 Deposit project

area of 25 March 2009.

Department of Indigenous Affairs. 2009. Aboriginal Heritage Inquiry System Search: Local

Government Area Yilgarn. Department of Indigenous Affairs website

http://www.dia.wa.gov.au. Accessed 13 July 2009.

Department of Water. 2009. Groundwater Licence GWL154459. Issued to Cliffs Asia

Pacific Iron Ore Pty Ltd under the Rights in Water and Irrigation Act 1914 (WA).


Page 70

DumpSolver Pty Ltd. 2009. Mt Jackson J1 Deposit Abandonment Bunding Requirements.

Report for Cliffs Asia Pacific Iron Ore Pty Ltd, February 2009.

Ecologia Environmental Consultants. 2001. Koolyanobbing Expansion Project: Fauna

Assessment Survey. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly

as Portman Iron Ore Limited).

Ecologia Environmental Consultants. 2002. Koolyanobbing Iron Ore Expansion Project:

Public Environmental Review. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd

(formerly as Portman Iron Ore Ltd) by Ecologia Environmental Consultants. March

2002.

Ecologia Environmental Consultants. 2003. Koolyanobbing Expansion Project – Northern

Tenements Mining Notice of Intent. Notice of Intent No. 4450. Report prepared for

Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore Ltd) by Ecologia

Environmental Consultants. Revision 1, November 2003.

Environmental Geochemistry International Pty Ltd. 2009. Exploratory ARD Assessment of

Drill Core Samples from the Mt Jackson J1 Deposit Western Australia. Report

prepared for Cliffs Asia Pacific Iron Ore Pty Ltd, August 2009.

Environmental Protection Authority. 2010. Koolyanobbing Iron Ore Project – Mt Jackson J1

Deposit: Report and recommendations of the Environmental Protection Authority.

Report 1347, February 2010.

Framenau, V.W. and Harvey, M.S. 2009. The Short-Range Endemic Invertebrate Fauna of

Mt Jackson (Western Australia). Report prepared for Biota Environmental Sciences.

January 2009.

Graeme Campbell and Associates. 2002. Geochemical Characterisation of Waste-rock and

Low-grade ore samples (‘static-testwork’): Implications for Mine-Waste Management.

Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore

Limited).

Government of Western Australia. 2010. Minister for Environment; Youth. Statement No.

843: Koolyanobbing Iron Ore Project – Mt Jackson J1 Deposit. 28 October 2010.

Harvey, M.S. 2006. The Short-Range Endemic Invertebrate Fauna from the Mount Jackson

Region, Western Australia. Report prepared for Bamford Consulting Ecologists.

September 2006.

Heritage Council of Western Australia. 2008. Heritage Enquiry: Mine Project in Shire of

Yilgarn. Letter to Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore

Limited) of 7 August 2008.

Malleefowl Preservation Group. 2007. Mt Jackson Malleefowl Survey 20-26th May 2007.


Limited). May 2007.


Page 71

Malleefowl Preservation Group. 2008. Mt Jackson Malleefowl Survey 1-7th June 2008.


Limited). June 2008.

Malleefowl Preservation Group. 2009. Mt Jackson Malleefowl Survey 10-15th May 2009.

Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd. June 2009.

Malleefowl Preservation Group. 2010. Mt Jackson Malleefowl Survey 23rd-28th May 2010.

Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd. June 2010.

National Native Title Tribunal. 2008a. Native Title Determinations Search - Western

Australia. National Native Title Tribunal webpage http://www.nntt.gov.au. Accessed

4 August 2008.

National Native Title Tribunal. 2008. Native Title Applications Search – Shire of Yilgarn.

National Native Title Tribunal webpage http://www.nntt.gov.au. Accessed 12 August

2008.

National Native Title Tribunal. 2009. Claimant Application Summary – Central West

Goldfields People. Produced by the National Native Title Tribunal, January 2009.

National Native Title Tribunal. 2009. Claimant Application Summary – Kalamaia Kabu(d)n

People. Produced by the National Native Title Tribunal, January 2009.

Rockwater Pty Ltd. 2003. Groundwater Supplies for Koolyanobbing-Windarling Haul Road –

Completion Report for Drilling, Bore Construction and Test-Pumping. Report for Cliffs

Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore Limited), December 2003.

Rockwater Pty Ltd. 2007. Koolyanobbing Iron Ore Project Mt Jackson J1 Deposit -

Numerical Modelling of Groundwater Dewatering. Report for Cliffs Asia Pacific Iron

Ore Pty Ltd (formerly as Portman Iron Ore Limited), December 2007.

Rockwater Pty Ltd. 2007. Mt Jackson J1 Deposit Bore Completion Report. Report for Cliffs

Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore Limited), September 2007.

Rockwater Pty Ltd. 2009. Mt Jackson J1 Deposit: J1 West Pit, Assessment of Final Void

Water Level and Salinity. Report for Cliffs Asia Pacific Iron Ore Pty Ltd, August 2009.

Shire of Yilgarn. 1997. Municipal Heritage Inventory. Inventory for the Shire of Yilgarn by

O’Brien Planning Consultants, August 1997.

Soil Water Consultants. 2011. Soil Characterisation for the Mt Jackson J1 Deposit. Report

prepared for Cliffs Asia Pacific Iron Ore Pty Ltd, June 2011.

Soil Water Consultants. 2011. Mt Jackson Range J1 Deposit Geochemical Characterisation.

Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd, June 2011.


Page 72

Western Australian Herbarium. 2009. Taxonomic notes on Bossiaea sp. Jackson Range (G.

Cockerton & S. McNee LCS 13614). Prepared by Wege J (Dr.) for the Western

Australian Herbarium of the Department of Environment and Conservation. January

2009.

Western Botanical. 2004. Vegetation Clearances for Drill Pads Jackson Ranges (J1) July

2004. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as Portman

Iron Ore Limited). WB 236, August 2004.

Western Botanical. 2004. Vegetation Clearances for Drill Pads Jackson Ranges (J1)

September 2004. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as

Portman Iron Ore Limited). WB 244, October 2004.

Western Botanical. 2005. J1 Drill Holes Vegetation Clearance. Report prepared for Cliffs

Asia Pacific Iron Ore Pty Ltd (formerly as Portman Iron Ore Limited). WB 313, August

2005.

Western Botanical. 2005. Vegetation Clearance for Drill Pads Jackson Range J4 and J1

Deposits September/October 2004. Report prepared for Cliffs Asia Pacific Iron Ore Pty

Ltd (formerly as Portman Iron Ore Limited). WB 258, May 2005.

Western Botanical. 2006. J1 Water Bore Flora and Vegetation Clearances October 2006.


Limited). October 2006.

Western Botanical. 2007. Flora Survey of Proposed Drill Lines at Jackson Range April 2007.


Limited). WB 437, May 2007.

Western Botanical. 2007. Flora Survey of Proposed Drill Lines at Western Jackson Range –

J1 Phase 2 June 2007. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd

(formerly as Portman Iron Ore Limited). WB 440, June 2007.

Western Botanical. 2007. Flora Survey for Proposed clearing for extension of sump at J1.


Limited). WB 447, July 2007.

Western Botanical. 2007. Flora Survey of RAB Lines at J1 Jackson Range for Sterilisation

July 2007. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as

Portman Iron Ore Limited). WB 457, August 2007.

Western Botanical. 2009. Seed Collection of Spartothamnella sp. Helena & Aurora Range at

the Jackson Ranges. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd.

September 2009.

Western Botanical. 2009. EeWH1 Eucalyptus ebbanoensis Woodland with Calytrix sp.

Paynes Find Heath. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd. November

2009.


Page 73

Western Botanical. 2009. Mt Jackson J1 Deposit – Results of surveys for Bossiaea sp.

Jackson Range. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd. November

2009.

Western Botanical. 2009. Flora and Vegetation of the Western Jackson Range (Mt Jackson

Range) Western Australia. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd

(formerly as Portman Iron Ore Limited). WB 359, April 2009.

Wetland Research and Management. 2008. Stygofauna sampling at J1 Deposit. Report


Limited). May 2008.

Wetland Research and Management. 2009. Stygofauna sampling at Mt Jackson J1 Deposit,

Western Australia. Report prepared for Cliffs Asia Pacific Iron Ore Pty Ltd (formerly as

Portman Iron Ore Limited). January 2009.


Page 74


Page 75

ATTACHMENT 2 STAKEHOLDER CONSULTATION REGISTER RELATING TO REHABILITATION AND CLOSURE OF THE MT JACKSON J1 PROJECT


Page 76

Table A2 Stakeholder Consultation Register relevant to rehabilitation and closure of the Mt Jackson J1 Project

Date Stakeholder Consultation method Issues discussed Decisions related to rehabilitation and closure

Various during 2008/09

Department of Environment and Conservation (WA)

Meetings Discussion of environmental baseline (flora and fauna) studies carried out.

Nil at this stage.

Consultation will be ongoing throughout the life of the project.

Various during 2008/09

Department of Mines and Petroleum (WA)

Meetings

Discussion of environmental baseline (flora and fauna) studies carried out.

Discussion of mine planning processes.

Nil at this stage.


Various during 2008

Shire of Yilgarn Meetings Discussed detailed mine planning issues in relation to flora, fauna, conservation reserves, groundwater and heritage.

Nil at this stage.


Ongoing Community Reference Group

Biannual meetings

Discussion of environmental baseline (flora and fauna) studies carried out.

Discussion of mine planning processes.

Nil at this stage.


Various during 2007 and 2009

Central West Goldfields People

Meetings Identification of significant Indigenous Heritage sites to be left undisturbed by mining.

Nil at this stage.


Various during 2007

Kalamaia Kabu(d)n People Meetings Identification of significant Indigenous Heritage sites to be left undisturbed by mining.

Nil at this stage.


Various during 2007 and 2009

Ballardong People Meetings Identification of significant Indigenous Heritage sites to be left undisturbed by mining.

Nil at this stage.



Page 77

Date Stakeholder Consultation method Issues discussed Decisions related to rehabilitation and closure

3 Nov 2008

The Wilderness Society Australia Inc

Meeting

Discussed details of mine planning and design, flora and fauna survey results, Aboriginal Heritage surveys and conservation reserves.

The Wilderness Society expressed its views regarding the potential for mining companies to become involved in management of the entire landscape (beyond Cliffs’ tenement boundaries), opportunities for indigenous employment during post-mining land use activities (e.g.

long-term management of the pastoral lease).

Nil at this stage.


3 Nov 2008

Conservation Council of Western Australia

Meeting Discussed details of mine planning and design, flora and fauna survey results, Aboriginal Heritage surveys and conservation reserves.

Nil at this stage.


Various during 2008

Wildflower Society of WA Meeting

Discussed details of mine planning and design, flora and fauna survey results, Aboriginal Heritage surveys and conservation reserves.

The Wildflower Society expressed its concerns regarding the quality of rehabilitation of Cliffs’ existing overburden landform at the Windarling Range mine operations.

Nil at this stage.



Page 78


Page 79

ATTACHMENT 3 ENVIRONMENTAL ASPECTS REGISTER - MT JACKSON J1 MINE CLOSURE RISK AND OPPORTUNITY ASSESSMENT


Page 80

Table A3.1 Mt Jackson J1 Project Mine Closure Risk and Opportunity Assessment

Ref. No.

Aspect Issue Context Consequence Categories

Proposed Management Residual Risk Rating

Likelihood Consequence Risk

1.0 Mine Pits

1.1 Public safety

Inadvertent entry to the mine pits after the

completion of mining leading to injury or death

The pit will be bordered to the north by the waste rock landform, which will act as a barrier to inadvertent entry. The southern boundary would require the installation of an abandonment bund.

Safety

Installation of abandonment bunding in accordance with DMP (1997) guidelines.

The DMP would be consulted during the planning of the abandonment bund installation.

E 4 M10

1.2 Mine pit lake

Potential post-mining water source that could attract and sustain feral fauna populations, with subsequent potential for

sustained fauna populations to impact native flora and native fauna.

Groundwater salinity is about 2,000mg/L to 6,000mg/L (TDS). Modelling indicates that the pit may either remain dry or create a lake at about 370mAHD (28m pit water depth). The lake

would gradually increase in salinity to between 73,000 mg/L and 77,000 mg/L.

Environmental

Contingencies in place to exclude feral fauna from mine pit lake as part of adaptive management approach.

D 2 L5

1.3 Water quality

Potential detrimental impact on groundwater quality and beneficial uses / groundwater dependent ecosystems

Groundwater is below 70m from the natural land surface and there are no groundwater dependent ecosystems or beneficial users in the vicinity

Environmental

No management proposed due to changes in water quality within mine pit will be confined to the mine pit itself with no impacts to surrounding groundwater

E 1 L1


Page 81

Ref. No.




2.0 Waste Rock Landforms

2.1 Geotechnical Stability

Potential for instability of structure resulting in partial failure

WRL design engineered to manage surface water and promote stability. Experience gained at Cliffs’ other Yilgarn Operations indicates that the WRL design is effective for creating stable landforms.

Environmental

15º batter gradient (10.5o overall WRL slope).

5º-10º back-sloped berms with baffles constructed across berms at 100m intervals.

Cells created on top of WRL to reduce water volumes, velocities and risks of overtopping.

Deep ripping to provide rock-armouring of surface soils.

Survey control of WRL construction.

D 2 L5

2.2 Surface Water Drainage

Potential erosion and loss of soil if surface water drainage not adequately controlled.

WRL design engineered to manage surface water and promote stability. Experience gained at Cliffs’ other Yilgarn Operations indicates that the WRL design is effective in minimising surface erosion.

Environmental

15º batter gradient (10.5o overall WRL slope).

5º-10º back-sloped berms with

baffles constructed across berms at 100m intervals.

Cells created on top of WRL to reduce water volumes, velocities and risks of overtopping.

Deep ripping to provide rock-armouring of surface soils.

Survey control of WRL construction.

Implementation of remedial measures if required to reduce erosion.

C 2 M8


Page 82

Ref. No.




2.3 Acidic

Drainage

Placement of Potentially Acid Forming (PAF) material near WRL surface potentially

generating acidic drainage that compromises mine closure objectives.

Pre-mining waste rock characterisation indicated that 84% of waste rock is not acid forming (16% of waste rock identified either as PAF or uncertain). The

Acid Neutralising Capacity of non-PAF material is low. The WRL has been designed to enable comingling of PAF with non-PAF and encapsulation.

Environmental

Pre-mining characterisation of PAF material incorporated into block model.

Identification of PAF materials during mining.

PAF comingled with non-PAF and placed >10m from WRL batter surface.

Characterisation of “as-built” WRL and monitoring of vegetation and groundwater leachate to identify issues and facilitate adaptive management actions.

C 2 M8

2.4 Saline waste rock

Placement of saline waste rock near WRL surface

potentially creating saline conditions that compromises mine closure objectives.

Saline waste rock of low to moderate salinity is expected at depth, reflecting the surrounding groundwater salinity (2,000mg/L to

6,000mg/L) (SWC 2011b)

Above the groundwater level, salinity is low, whereas below the groundwater level, salinity increases to levels that could inhibit plant growth.

Environmental

Pre-mining characterisation of saline material incorporated into block model.

Characterisation of “as-built” WRL soils during mine closure studies and seeding with local seed mix suitable for the soil conditions.

C 2 M8


Page 83

Ref. No.




2.5 Metalliferous Drainage

Potential generation of metalliferous drainage from WRL resulting in metal toxicity to revegetated areas and surrounding

naturally-occurring vegetation.

The potential for non-acidic metalliferous drainage to occur is low, indicating that metals and metalloids are bound tightly in the rock matrix. Only likely to occur under acidic conditions

although the potential is low (SWC 2011b).

Environmental

If found to be an issue of concern, adaptive management strategies to be developed relating to the handling and placement of waste rock during

WRL construction.

E 2 L3

2.5

Dust emissions from post-mining landscape

Dust emissions from post-mining landscape impacting on surrounding native vegetation

Experience gained at Cliffs’ other Yilgarn Operations indicates that dust emissions from constructed WRLs are low.

Environmental

Measures to promote revegetation of disturbed land will also reduce the probability of dust emissions occurring.

E 1 L1

2.6 Native vegetation

Potential failure to achieve stakeholder-agreed completion criteria for native vegetation on rehabilitated landforms

Appropriate reference sites are yet to be selected and characterised.

Rehabilitation trials are required in order to test and refine methodologies and define what can reasonably be achieved in context with the nature of J1 Deposit waste rock and soil properties.

Environmental

Reputation

Implementation of progressive rehabilitation throughout the

operating life of the mine and monitoring of progress in relation to reference sites.

Refinement of completion criteria in light of monitoring results.

Implementation of remedial measures if required to promote revegetation.

B 2 H12

2.7 Weeds

Potential weed infestations on

disturbed land compromise ability to achieve mine closure objectives.

Experience gained at Cliffs’ other Yilgarn Operations indicates that the potential for rehabilitation to be impacted by weeds is low.

Environmental

Weed monitoring and distribution mapping during

operations and post-mining period.

Implementation of weed control program during operations and post-mining period.

D 2 L5


Page 84

Ref. No.




2.8 Topsoil availability

Insufficient topsoil available to adequately cover disturbed ground to a sufficient depth to provide a growth medium.

Experience gained at Cliffs’ other Yilgarn Operations indicates that there should be adequate topsoil available if it is stripped and retained during pre-mining ground disturbance.

Environmental

Retention of topsoil during clearing.

Management of topsoil inventories and reconciliation against rehabilitation requirements.

E 1 L1

2.9 Topsoil viability

Topsoil structure and seed bank viability degraded, resulting in reduced capacity to achieve mine closure outcomes.

The effect of long term stockpiling of topsoil on soil structure and seed viability has not been investigated.

Environmental

Schedule topsoil stripping and rehabilitation works to permit direct placement wherever possible.

Where direct placement is not possible, use topsoil for rehabilitation within 12 months wherever possible.

C 2 M8

3.0 Infrastructure

3.1 Soil contamination

Potential

contamination from wash bay, refuelling, storage and workshop facilities that compromises mine closure objectives.

Experience gained at Cliffs’

other Yilgarn Operations indicates that soil contamination probably will occur at some time during the mining operation and is the affected area is highly localised as contaminated soil is removed immediately.

Environmental

Cliffs’ standard storage, handling and spill response measures to be implemented during mining.

Contaminated sites investigation at the completion of mining and implementation of soil remediation if required.

C 1 L4

3.2

Dust emissions from post-mining

landscape

Dust emissions from post-mining landscape impacting on

surrounding native vegetation

Experience gained at Cliffs’ other Yilgarn Operations indicates that dust emissions

from bare areas are low.

Environmental

Measures to promote revegetation of disturbed land will also reduce the probability

of dust emissions occurring.

E 1 L1


Page 85

Ref. No.




3.3 Native fauna

Entrapment and mortality of native fauna in man-made structures post-decommissioning.

Entrapment of fauna would not be expected to occur if infrastructure is dismantled and removed, and subsurface structures back-filled and contoured.

Environmental

Reputation

Decommissioning and removal of infrastructure that could entrap fauna (e.g. turkeys nest dams, drainage lines, bores, septic tanks, sumps) and reinstatement of natural land contours.

E 1 L1


Potential failure to achieve stakeholder-agreed completion criteria for native vegetation on rehabilitated landforms


Rehabilitation of infrastructure areas is not expected to be as problematic as WRLs. Compaction is likely to be the main post-mining soil condition requiring remediation.

Environmental

Reputation

Implementation of progressive rehabilitation throughout the operating life of the mine and monitoring of progress in relation to reference sites.



C 2 M8

3.5 Weeds

Potential weed infestations on disturbed land compromise ability to achieve mine closure objectives.


Environmental

Weed monitoring and distribution mapping during operations and post-mining period.


D 2 L5


Insufficient topsoil available to adequately cover disturbed ground to a sufficient

depth to provide a growth medium.

Experience gained at Cliffs’ other Yilgarn Operations indicates that there should be adequate topsoil available if it is stripped and retained

during pre-mining ground disturbance.

Environmental



E 1 L1


Topsoil structure and seed bank

The effect of long term stockpiling of topsoil on soil

Environmental Schedule topsoil stripping and rehabilitation works to permit

C 2 M8


Page 86

Ref. No.




viability degraded, resulting in reduced capacity to achieve mine closure objectives.

structure and seed viability has not been investigated.

direct placement wherever possible.


4.0 Haul Road

4.1

Salinisation of roads from dust suppression using saline groundwater

Creation of salinised soil that compromises ability to achieve mine closure objectives.

Groundwater is not hypersaline – salinity is typically about 2,000mg/L to 6,000mg/L (TDS). Use of saline groundwater for dust suppression is not expected to create hypersaline soils.

Environmental

Soil characterisation during mine closure studies and seeding with local seed mix suitable for the soil conditions.

C 2 M8

4.2

Dust emissions from post-

mining landscape

Dust emissions from post-mining landscape

impacting on surrounding native vegetation

Experience gained at Cliffs’ other Yilgarn Operations indicates that dust emissions

from constructed WRLs are low.

Environmental

Measures to promote revegetation of disturbed land

will also reduce the probability of dust emissions occurring.

E 1 L1


Potential failure to achieve stakeholder-agreed completion criteria for native vegetation on rehabilitated

landforms


Rehabilitation of roads is not expected to be as problematic as WRLs. Salinisation and compaction is likely to be the main post-mining soil condition requiring remediation.

Environmental

Reputation

Implementation of progressive rehabilitation throughout the operating life of the mine and monitoring of progress in relation to reference sites.



C 2 M8


Page 87

Ref. No.




4.4 Weeds

Potential weed infestations on disturbed land compromise ability to achieve mine closure objectives.


Environmental

Weed monitoring and distribution mapping during operations and post-mining period.


D 2 L5


Insufficient topsoil available to adequately cover disturbed ground to a sufficient depth to provide a growth medium.

Experience gained at Cliffs’ other Yilgarn Operations indicates that there should be adequate topsoil available if it is stripped and retained during pre-mining ground disturbance.

Environmental



E 1 L1


Topsoil structure and seed bank viability degraded, resulting in reduced capacity to achieve mine closure outcomes.

The effect of long term stockpiling of topsoil on soil structure and seed viability has not been investigated.

Environmental

Schedule topsoil stripping and rehabilitation works to permit direct placement wherever possible.


C 2 M8

5.0 Heritage

5.1 Indigenous heritage

values

Rehabilitation and closure plans not consistent with Indigenous

Heritage values of the post-mining landscape.

The locations of registered Aboriginal Heritage sites are known (DIA 2009).

The Mt Jackson J1 Deposit area coincides with two separate Native Title applications. Cliffs has identified the claimants as stakeholders.

Reputation

Consultation with Indigenous stakeholders to ensure that rehabilitation and closure

objectives are consistent with Indigenous Heritage values.

E 2 L3


Page 88

Ref. No.




6.0 Stakeholder engagement

6.1 Stakeholder concerns

Rehabilitation and closure plans do not adequately address stakeholder concerns

Cliffs has identified its stakeholders and established a Community Reference Group, which meets biannually.

A

Pro-active stakeholder engagement on rehabilitation and closure planning and implementation throughout the life of the Mt Jackson J1 Project.

E 2 L3

6.2 Post-mining land use opportunities

Opportunities to add value to the post-mining land use potential not realised (e.g. retention of infrastructure or access tracks for beneficial uses)

Cliffs has identified its stakeholders and established a Community Reference Group, which meets biannually.

A

Pro-active stakeholder engagement on rehabilitation and closure planning and implementation throughout the life of the Mt Jackson J1 Project.

E 1 L1


Page 89

Table A4.2 Consequence criteria

Consequence Level

Business Impact

(F)

Health (H)

Safety (S)

Environment (E)

Reputation, Community and Public Relations

(R)

Compliance (C)

Employee Development / Organizational Effectiveness

(OE)

5 > US $20 million.

Long term chronic health effects to workers or public with potential for

death

Fatality

(Including multiple fatalities,

permanent

disability)

Large scale long-term environmental damage

offsite and/or a compliance breach

that threatens

continued operation.

International adverse media coverage.

Severe, prolonged local community

resistance.

Operations suspended or

severely reduced by authorities.

Prolonged strike. Unavailability or loss of multiple key skills

or personnel.

4 US $5 to US $20 million

Long term chronic health effects to workers or public with major impact

on body function or lifestyle

Serious injury. (Serious injury and

hospitalization, temporary disability.)

Large scale short-term environmental damage

offsite and/or a compliance breach

sanction.

National adverse media coverage;

reduction in credibility with major

stakeholders; persistent community

problems.

Major breach of regulation.

Potential for severe fines and/or

litigation.

Strike. Unavailability or loss of a few key skills or personnel.

3 US $1 to US

$5 million

Chronic health effects causing

partial impact on body function(s).

Moderate injury. (Minor or short-

term loss of body

function. Loss time incident.)

Small scale environmental damage

offsite and/or a reportable compliance

breach; major environmental damage

onsite.

Local adverse media coverage; repeated

community complaints.

Serious breach of internal policy;

breach of

regulation; potential for fines and/or litigation.

Arbitration; occasional shortage

of key skills or personnel.

2 US $100,000

to US $1 million

Health treatment requiring medical

treatment or intervention; but not permanent.

Medical treatment. (Treatment that must be given by

a doctor.)

Significant environmental damage

onsite; minor offsite impact; and/or

technical compliance breach.

Low level community dissatisfaction.

Internal non-compliance; minor

breach of regulation; no fines

or litigation.

Grievance activity by group.

1 Less than

US$100,000 Transitory health

impact.

Minor impact.

(First Aid Treatment)

Minor environmental impact and/or

technical compliance breach.

Isolated local community incident.

Insignificant

internal non-compliance.

Isolated employee dissatisfaction.


Page 90

Table A4.3 Likelihood criteria for classifying the probability of an incident occurring and resulting in defined consequence, and resulting

risk ranking

LIKELIHOOD SCALE

(Likelihood of defined consequences) CONSEQUENCE SCALE

For Ongoing

Activities

For defined time

activities 1 2 3 4 5

A

Many times per

annum,

continuous

99%

Chance

Medium

11

High

16

Critical

20

Critical

23

Critical

25

B Once or twice

per annum

50%

Chance

Medium

7

High

12

High

17

Critical

21

Critical

24

C Once in 5 years 10%

Chance

Low

4

Medium

8

High

13

Critical

18

Critical

23

D Once in 15 years 1%

Chance

Low

2

Low

5

Medium

9

High

14

Critical

19

E Unlikely in life of

mine

0.1%

Chance

Low

1

Low

3

Medium

6

Medium

10

High

15


Page 91

Table A4.5 Management Response

Risk Rating Management Response

C CRITICAL RISK: requires changes to project design or operating procedures.

H HIGH RISK: requires detailed research or planning to develop appropriate risk

reduction controls.

M MODERATE RISK: can be managed using existing information by developing and implementing an appropriate management plan.

L LOW RISK: can be managed using routine procedures

(implement continual improvement measures where cost-effective).

mt jackson j1 deposit mine closure plan -...

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