ASX:ABX Development Plan and Environmental Management Plan Bald Hill Bauxite Project Campbell Town Supplement Response 18th November 2014 AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 Australian Bauxite Limited – Bald Hill Bauxite mine, Macquarie Road, Campbell Town Summary of public representations, Agency & Council comments Plus ABx Responses Details of comments on the project are provided in following tables: Table A, a summary of comments made in the representation. Table B, a summary of comments, including requests for further information from State Government agencies. Table C, a summary of comments, including requests for further information from Northern Midlands Council. In the following tables, DPEMP means the Development Proposal and Environmental Management Plan, Bald Hill Bauxite Project, dated 23 September 2014. A. Public representations Representation No. 1 2 Comment Further info required by EPA Representor resides less than 1 km from the proposed JB1 mine pit. Representor was concerned about hours of work, noise and lighting if work was to be undertaken at night. Consultation between the representor and proponent provided assurance that the mining operations would only be undertaken during daylight hours. The representor noted that the proposal should benefit the local community and supports the proposal. Dust has the potential to impact Tasmanian Networks Pty Ltd’s assets. The nearest transmission line (Palmerston-Avoca 110kV Transmission Line (TL429)) is approximately 4.8 km north of the proposal. Given the prevailing winds are from the north, the life of the mine is short, and the proponent has undertaken to employ dust suppression measures (e.g. wet spraying on site), a dust monitoring regime for impact on transmission assets is not considered necessary. No No A local power supply runs along Macquarie Road which may be tapped into if the need arises. This can be assessed in the event a connection application is made. B. Agency comments DPIPWE, EPA Transport noise EPA: It is noted in the DPEMP that haulage will occur between 0600 hours and 2000 hours, 6 to 7 days per week, with modelling indicating several residences are likely to be impacted. The DPEMP acknowledges that the level of noise increase at one property is AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 Describe measures to mitigate noise from heavy vehicles which may enter likely to be very noticeable and significant. The EPA considers the movement of trucks along West Street and onto the Midlands Highway in Campbell Town, particularly before 0700 hours and after 1900 hours and on Sundays is likely to result in environmental nuisance to residences in close proximity. ABx Response: Agreed. TasRail has been appointed as the transport provider. Their proposal is to have a shuttle service of half height containers on normal container skeleton trucks or “skels” between the mine site on Macquarie Road and Conara siding. Preferred Scenario Traffic Generation Production Years Year 1, 4 & 5 (300,000 T) Year 2 & 3 (550,000 T) Overall Daily Trips 23 40 Total Hourly Peak Traffic 2* 3.5 + * 1 Hour Round trip (mine to Conara and back to mine) per truck with two trucks operating + 1 Hour Round trip (mine to Conara and back to mine) per truck with 3.5 trucks operating The above Preferred Scenario assumes that operations are utilizing B Doubles with 49 tonne payload (Payload is assumed to be 44t of Ore inside two 20' Half height containers) operating 13 hours per day 6 days a week 52 weeks per year. Additionally, TasRail has been consulted regarding this issue and are agreeable to operate the shuttle truck service 6 days per week (Monday to Saturday) for 13 hours per day.(Start Conara @ 6.30am through to End Conara @ 7.30pm) Trucks will start their day at Conara siding, an existing transport hub and travel to mine site. Operational instructions will include: West Street, Campbell Town (To minimise impact on the 4 houses affected) 1/ No trucks before 7.00am 2/ No use of exhaust brakes 3/ Speed to be under 60 KPH EPA: It is further noted that the proponent intends to keep the transport vehicles well maintained and include the fitment of manufacturers silencing equipment. This is supported. AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 and leave the Land. Proposed mitigation should be considered within the context of potential environmental nuisance caused by heavy vehicles traveling along West Street. ABx Response: TasRail has agreed that all trucks will be well maintained and will ensure all exhaust and silencing equipment will be to Australian & Manufacturers standard. Dust EPA: It is noted in Commitment 5 that haul roads, ore dumps, screening drop points, and earth stockpiles will be kept watered in dry windy conditions. All cleared areas on the mine site, including the mined out areas and areas receiving returned material are also likely to generate dust during windy conditions. These areas should be incorporated into commitment 5. ABx Response: Cleared areas are to be kept to a minimum at all times and Stornoways, the highly experienced mine contractor, uses simple procedures to achieve this. Actively used areas will be kept dust-free by periodic watering. Permanently abandoned cleared areas will be revegetated at the first opportunity, subject to the farmer's requirements for future farm road access. Fortunately, once wetted and allowed to dry in hot sunlight, the bauxite minerals naturally cement together. Therefore, any temporarily unused cleared areas containing bauxite minerals will quickly form a thin cemented crust and prevent wind-blown dust generation - one of the reasons bauxite is useful for road verge construction throughout Tasmania. If a temporarily unused cleared area has formed this dust-free crust, disturbance by vehicle traffic is to be minimised. EPA: It is noted in the DPEMP (page 26) that if sufficient water for dust suppression is not available from the main sedimentation dam adjacent to Macquarie Road, it will be piped from a landholder’s dam. This is considered to be an important management measure given the local climate. The landholder’s dam referred to needs to be clearly stated and or marked on a map. ABx Response: ABx4 has a land access agreement with the Rosedale landholder, Mr Foster to take water by pump and pipeline from his large irrigation dam and to construct a sedimentation dam along the ML boundary, if needed as shown in Figure 18 in the DPEMP. An updated version of Figure 18 showing the Agreed Water Supply is attached. For emergency firefighting in the district, this Rosedale dam is available as a water source and the mine will naturally coordinate with fire authorities and make any AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 Describe appropriate dust suppression measures for all areas on the mine site where dust generation is likely to occur. Clarify where water for dust suppression will be acquired from if not available from the main sedimentation dam adjacent to Macquarie Road. Clarify whether dry or wet screening will take place. If dry screening is to take place, state under what equipment available. For added security, a farm road from Macquarie Road past JB1 pit to Elizabeth River is to be upgraded to provide a second permanent access to emergency water. Other than emergency such as bushfire, no water will be taken from Elizabeth River or any streams that discharge into Elizabeth River. EPA: It is noted in the DPEMP that dust will be generated from the screening and returning of fines if dry screening is used, as opposed to wet. ABx Response: Dry screening is considered the optimum method to upgrade most of the bauxite and will be used whenever practical. The screen equipment is to be shrouded and dust suppressed using a natural citrus spray that has proven highly effective. Stockpiles are to be built in the leeward side of hills and will be water-sprayed if any dust problems arise (not expected). Fines may be sold for construction aggregates and other domestic purposes, possibly including cement and fertiliser manufacture. This should minimise the return of dry fines to exhausted pit areas but in places where dry fines are returned to the pits, they will be dust suppressed by water-sprays as required and quickly covered with soil as part of the rapid rehabilitation process. Note; These two points have been added to Commitments Summary as Commitments 73 & 74. Bauxite that requires wet screening is expected to be a smaller proportion of the total and will be wet-screened in campaigns using simple vibrating wet screens sited adjacent to a sedimentation dam that will be cleaned-out periodically and the wet fines returned to the pits or sold domestically - it may be valuable clay for brick making. DPIPWE, Heritage Tasmania Historic heritage sites EPA: Clarify which historic heritage site is to be impacted. If it is any of ADM 2, 3, 7 or 8, it is recommended that additional commitments are made in line with the CHMA report, such as photographic recording, mapping and reporting (see page 71 of Appendix F). Commitment 40 states that a plan for unanticipated discoveries is to be followed. This is generally in accordance with Heritage Tasmania’s ‘Pre-Development Assessment Guidelines’ and is supported. ABx Response: Agreed. The single Aboriginal heritage site will be left untouched and protected from accidental incursion by low-visibility barriers such as a temporary line of AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 The proponent may wish to address this issue. rocks. Operators are to avoid the area at all times and to maintain confidentiality. DPIPWE, Policy and Conservation Assessment Branch Threatened flora No significant European historic heritage site exists within the pit areas but ABM 6 is a row of old Pine Trees classified by CHMA as being heritage and will be removed during mining of the northern end of the deposit, possibly in Years 2 or 3. The landowner is agreeable to the removal of these pine trees when that bauxite is mined and does not want pine trees replanted. ABx will carefully photograph these few trees but it is noted that the DPEMP is already a fine and expensive historical tribute to their heritage value. EPA: Any disturbance of Scleranthus fasiculatus will require a permit to take issued under the Threatened Species Protection Act 1995. The processing of permit applications may take up to 4 weeks. The proponent may wish to address this issue. ABx Response: Agreed. A “permit to take” will be applied for if Scleranthus fasiculatus is identified by ECOtas or ABx’s Flora & Fauna consultant in any areas of development. Geoconservation EPA: In order to minimise potential impacts on the Tasmanian Geoconservation Database (TGD) listed site Macquarie River Valley Sandsheets, it is recommended soil be replaced post-mining within the TGD site in its original profile and as close to pre-mining conditions as feasible. ABx Response: Agreed, If any disturbance of that site is considered then care will be taken to return the soil profile to original, however the TGD listed site has been identified and will be segregated from any mine development activity, thereby ensuring no disturbance. Department of State Growth, Mineral Resources Tasmania Sedimentation dam Department of State Midlands Highway EPA: Discharge from the main sedimentation dam may need to be controlled to mitigate any potential damage to Macquarie Road. Potentially any discharge could be directed to the landowner’s dam directly south of the sedimentation dam. ABx Response: Agreed. All potential waterflows from the main sedimentation dam discharge into the landowner’s major irrigation dam via an existing culvert beneath Macquarie Road. However, because wet screening will not be a continuous process nor a major activity, ABx anticipates no discharge from the main sedimentation dam which is meant to be an facility to allow fines to dry before removal. EPA: The Transport Infrastructure Division does not object to the proposal in principle. As mentioned in the TIA and in consultation with the proponents’ representatives, the AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 Describe measures to minimise the potential impact on the TGD listed Macquarie River Valley Sandsheets. Provide detail on the size of the sedimentation dam adjacent to Macquarie Road, including a map showing its extent, and how overflow will be directed to the landholder’s dam south of the road. The proponent may wish to address this issue. Growth, Transport Infrastructure Division junction(s) transport route is yet to be finalised. The Department will need to receive confirmation of the proposed route before being able to provide a definite position. In the event that the product is to be transported via the West Street (Campbell Town) / Midland Highway intersection, a channelised right turn lane would need to be fitted on the highway at the West Street intersection. This facility must be designed to Ausroads’ Guidelines and provide storage for two heavy vehicles. ABx Response: Agreed. TasRail has been appointed as the transport provider. Their proposal is to have a shuttle service of half height containers on normal container skeleton trucks or “skels” between the mine site on Macquarie Road and Conara siding. Preferred Scenario Traffic Generation Production Years Year 1, 4 & 5 (300,000 T) Year 2 & 3 (550,000 T) Overall Daily Trips 23 40 Total Hourly Peak Traffic 2* 3.5 + * 1 Hour Round trip (mine to Conara and back to mine) per truck with two trucks operating + 1 Hour Round trip (mine to Conara and back to mine) per truck with 3.5 trucks operating The above Preferred Scenario assumes that operations are utilizing B Doubles with 49 tonne payload (Payload is assumed to be 44t of Ore inside two 20' Half height containers) operating 13 hours per day 6 days a week 52 weeks per year. EPA: In the event that the rail option north of Campbell Town is to be used, a channelised right turn lane would also need to be fitted on the highway at the entrance to the private road accessing the rail facility. ABx Response: This option is no longer being considered. C. Northern Midlands Council comments Building and Bushfire Code Council: Advice from a Building Surveyor on the class of the proposed buildings under the Building Code is required. Code E1.0 Bushfire Prone Areas Code of the Interim Scheme needs to be addressed for any buildings that are Class 1-9. AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 ABx Response: Agreed. All buildings will be temporary and comply with relevant building codes Sedimentation dam Council: Detail on the size of the sedimentation dam adjacent to Macquarie Road, and the proposed measures to ensure that overflow from the dam does not impact on Macquarie Road is required. ABx Response: Wet screening is to apply to a small proportion of the ore, in short campaigns and usually utilise water temporarily pumped from the landowner’s nearby large irrigation dam or utilise harvested rainwater. The dam is to be built by experienced road construction professionals (Stornoway’s), low-profile (say, less than 1.2 metres high) and comprising a stable bank of clay-rich fill material inside the landholders fence line to ensure all impounded water is kept at a safe distance off the road embankment. Should the dam ever overflow, the discharge will be in the same location as the existing natural fall line so that water flows are not diverted from their natural course towards the existing, generally dry culvert beneath Macquarie Road. Once the intermittent wet screening is concluded, the dam is to dry out to allow recovery of clays and fines for sale or return to the pits. Note; As the sedimentation dam is put into Drying cycle, water for dust control will be sourced from the landowner’s nearby large irrigation dam shown in Figure 18. In net terms, the small and infrequent quantity of water flowing beneath Macquarie Road will probably decrease due to evaporation losses in the main sedimentation dam. Barring heavy rain events, the main sedimentation dam may have zero discharge until end of operations. The overflow system will be built from rocks with energy dissipation traps to ensure zero erosion potential. Water settling characteristics of bauxite rinse-water are good to excellent as outlined in the Appendix K of the DPEMP – see extracted images of settling tests below. Dam Size, Figure 18 showing: 1. Main sedimentation dam covering approximately 50 m x 150m in area ~7,500 sq metres or 0.75Ha 2. Maximum water containment extent in periods of exceptionally heavy rainfall covering approximately 90m x 250m ~ 22,500 sq m or 2.2Ha. At its maximum capacity the dam will be very shallow and have a volume of significantly less than 50 KLtrs. This design was selected to comply with our Mining Lease s6 (j) of "Lessee's Further Conditions" which require that we provide drains and settling ponds : (i) to allow for 10-year storm events. (ii) stable spillways and add energy traps in spillways. (iii) stable and vegetated dam walls. AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500 (iv) cleaned-out regularly so that no more than 2/3rds of dam depth contains sediment; and (v) Sediment removed and secured so it will not run-off the ML. Traffic Impact Assessment Council: The Traffic Impact Assessment must include a road pavement analysis for Macquarie Road and West Street, and address: Traffic load effects on Macquarie Road and West Street; The standard of Macquarie Road and West Street to accommodate the proposed truck movements and the likelihood of pavement failures due to the heavy vehicle; and The suitability of the existing access ways to accommodate the heavy vehicles and the likelihood of pavement damage due to turning trucks. ABx Response: Pavement analysis is being done through Pitt & Sherry and Stornoway using ground penetrating radar and in consultation with Midlands Council road engineer. This report will be used to identify the current state of Macquarie Road and West Street and any design and maintenance requirements for the TIA. Bauxite Settling Tests – from Appendix K, DPEMP After 40 minutes (left) Overnight (right) Water clarity is excellent. pH neutral. Ideal for release into natural wetland watercourse leading into landholders large irrigation water dam. AUSTRALIAN BAUXITE LIMITED www.australianbauxite.com.au e: [email protected] ABN 14 139 494 885 ASX : ABZ Level 2 Hudson House 131 Macquarie St Sydney NSW 2000 Australia P: +61 2 9251 7177 F: +61 2 9251 7500
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