Mount Dromedary Graphite Project Site-specific Environmental … · 2019-09-23 · on (07) 4034...

Mount Dromedary GraphiteProject Site-specificEnvironmental AuthorityApplication - Responseto Information Request Novonix Ltd

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F:\AAA\408_NVX\408002_EA\408002.01_Env Apps\Rpt\Add info response\Mt Dromedary add info response_cov lett L01.docx

NRA Reference: Mt Dromedary add info response_cov lett L01

31 January 2018

Department of Environment and Science PO Box 7230 Cairns QLD 4870

Attention: Kerwin Swanson, Environmental Officer

Dear Kerwin

RE: Mount Dromedary Site-specific EA application (AR096425), Response to Information Request– final report

On behalf of Novonix Ltd, please find enclosed the response to the Information Request for a site-specific Environmental Authority (EA) application for the Mount Dromedary graphite project in north-west Queensland (application reference number AR096425). The Information Request items were detailed in a Notice from the Department of Environment and Science (DES), dated 2 March 2017.

The enclosed information provides a response to each of the items in the Information Request. The response considers the request in the Notice and the outcomes of meetings held with DES officers in 2017.

Please proceed with the assessment of the application using the additional information enclosed, which complements the information provided in the EA application (December 2016).

If you have any questions regarding the enclosed information, please do not hesitate to contact me on (07) 4034 5300 or [email protected].

Yours sincerely NRA Environmental Consultants

Shannon Wetherall Senior Environmental Scientist

Encl: Mount Dromedary Graphite Project, Site-specific Environmental Authority Application – Response to Information Request (31 January 2018), including technical reports provided as Appendices.

CC: Steve Hadwen (Novonix Ltd) Phil St Baker (Novonix Ltd)

© Natural Resource Assessments Pty Ltd This document is the property of Natural Resource Assessments Pty Ltd. Apart from any use as permitted under the Copyright Act 1968, all other rights are reserved. Unauthorised use of this document in any form whatsoever is prohibited.

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NRA Filepath: F:\AAA\408_NVX\408002_EA\408002.01_Env Apps\Rpt\Add info response\Mt Dromedary EA application - Response to Info Req R02.docx

Status: R02 (Final) Date of Issue: 31 January 2018 Project Manager: Shannon Wetherall

Title: Mount Dromedary Graphite Project Site-specific Environmental Authority Application - Response to Information Request

Client: Novonix Ltd Client Contact: Steve Hadwen (Project Manager)

Copies Dispatched: 1 PDF Other Info or

Requirements: Final report supersedes and replaces all previous documentation prepared.

Report Summary

Key Words

Novonix, NVX, Graphitecorp, Mount Dromedary Graphite Project, Environmental Authority application, Information Response, Cloncurry, Burke Developmental Road, Gleeson Station, Coolullah Station.

Abstract Novonix Ltd (previously Graphitecorp Ltd) has applied to the Queensland Government for a site-specific Environmental Authority (EA) under the Environmental Protection Act 1994. This report provides the response to the Department of Environment and Science request for information and should be read in conjunction with the supporting information documents for the application.

Citation

This report should be cited as: NRA 2018, Mount Dromedary Graphite Project Site-specific Environmental Authority Application - Response to Information Request, R02 (Final), prepared by NRA Environmental Consultants for Novonix Ltd, 31 January 2018.

Quality Assurance

Author Technical Review Editor Document

Version

Approved for Issue by QA Manager

Date Signature

Shannon Wetherall

BAppSc(Hons)

- - R01 - - Tim Anderson

MAgrSc, BSc(Hons)

Kirsty Anderson BA(Hons)

R02 31/1/18

© Natural Resource Assessments Pty Ltd This document is the property of Natural Resource Assessments Pty Ltd. Apart from any use as permitted under the Copyright Act 1968 all other rights are reserved. Unauthorised use of this document in any form whatsoever is prohibited.

Certified Integrated Management System AS/NZS ISO 9001:2015 (Quality) AS/NZS ISO 14001:2015 (Environment) AS/NZS 4801:2001 (Safety)

Limitations of this Report

The information in this report is for the exclusive use of Novonix Ltd, the only intended beneficiary of our work. NRA cannot be held liable for third party reliance on this document. This disclaimer brings the limitations of the investigations to the attention of the reader. The information herein could be different if the information upon which it is based is determined to be inaccurate or incomplete. The results of work carried out by others may have been used in the preparation of this report. These results have been used in good faith, and we are not responsible for their accuracy. The information herein is a professionally accurate account of the site conditions at the time of investigations; it is prepared in the context of inherent limitations associated with any investigation of this type. It has been formulated in the context of published guidelines, legislation in force at the date of this report, field observations, discussions with site personnel, and results of laboratory analyses. Any change to published guidelines or legislation may change the opinions of NRA expressed in this document. NRA’s opinions in this document are subject to modification if additional information is obtained through further investigation, observations or analysis. They relate solely and exclusively to environmental management matters, and are based on the technical and practical experience of environmental practitioners. They are not presented as legal advice, nor do they represent decisions from the regulatory agencies charged with the administration of the relevant Acts. Any advice, opinions or recommendations contained in this document should be read and relied upon only in the context of the document as a whole and are considered current as of the date of this document.

Table of Contents 1. Introduction .............................................................................................. 1

2. Groundwater ............................................................................................. 2

3. Surface Water ......................................................................................... 10

4. Waste Rock/Ore/Tailings Characterisation and Management ............. 17

5. Air ............................................................................................................ 21

6. Mine Planning and Design ..................................................................... 23

7. Significant Residual Impacts ................................................................. 25

8. Regulated Structures ............................................................................. 26

9. Rehabilitation ......................................................................................... 27

10. Ground-truthing ..................................................................................... 28

11. References .............................................................................................. 29

Tables

Table 1: Mount Dromedary baseline groundwater monitoring data ............. v

Table 2: Proposed receiving water monitoring sites ................................... vi

Table 3: Mount Dromedary baseline surface water quality data ................. vi

Table 4: Mount Dromedary baseline metal and metalloid stream sediment quality data ....................................................................................... ix

Table 5: Receiving surface water trigger values and contaminant limits for consideration in the EA .................................................................... x

Table 6: Stream sediment trigger values and contaminant limits for consideration in the EA ................................................................... xi

Table 7: Geochemical abundance index results for mine waste weathered zone (Regolith Profile) samples ..................................................... xii

Table 8: Geochemical abundance index results for mine waste fresh zone (Bedrock Profile) samples ............................................................. xiii

Table 9: Geochemical abundance index results for low-grade ore Samples ......................................................................................................... xiv

Table 10: Summary of PAF and NAF materials balance for waste rock and low-grade ore ................................................................................... xv

Figures

Figure 1: Project location .................................................................................. i

Figure 2: Groundwater monitoring bores ........................................................ ii

Figure 3: Proposed water management infrastructure, release points and receiving water monitoring locations ............................................. iii

Figure 4: Surface water monitoring sites ....................................................... iv

Plates

Plate 1: Vegetation along the central watercourse, potentially a terrestrial GDE .................................................................................................... 5

Plate 2: Aerial photograph of potential terrestrial GDE along the central watercourse, indicated by the green vegetation ............................. 5

Appendices

Appendix A: Information Request

Appendix B: Mt Dromedary Underground Water Impact Report and Dewatering Assessment

Appendix C: Mt Dromedary GDE Indicators

Appendix D: Concept Design Study for Mine Waste and Water Management

Appendix E: Site Structural Geology

Appendix F: Geochemical Assessment of Mine Waste and Low Grade Ore

Appendix G: Geochemical Assessment of Tailings Slurry Water

Appendix H: Revised Significant Residual Impact Assessment

Appendix I: Consequence Category Assessment

Novonix Ltd Mount Dromedary Graphite Project Site-specific Environmental Authority Application - Response to Information Request

NRA Environmental Consultants 1 31 January 2018

1. Introduction

The Mount Dromedary Graphite Project (the Project), located in north-west Queensland, is owned by Novonix Ltd (NVX) (ACN: 157 690 830)1. An application for a site-specific Environmental Authority (EA) under the Queensland Environmental Protection Act 1994 has been lodged with the Queensland Department of Environment and Science (DES)2 and is being assessed as application number AR096425. The application applies to mining lease application (MLA) 100121 and 100126 (Figure 1). As part of the application process, DES requested that further information be provided to assess the application3. This report provides the response to the request for further information (ie information request) and should be read in conjunction with the supporting information provided as part of the site-specific EA application (received by DES on 16 December 2016).

Information requested by DES has been prepared by technical specialists and is collated in this report. Each of the items in the information request has been responded to in separate sections in this report, with the information request details in grey text boxes. A copy of the information request is provided in Appendix A.

Since the site-specific EA application was submitted in 2016, the following additional studies have been undertaken for the project, and the information has been provided in this report. • Surface water monitoring. • Groundwater monitoring (monthly water levels, quarterly water quality). • Identification of groundwater dependent ecosystem (GDE) indicators (NRA 2018a). • Groundwater model and associated reporting in an Underground Water Impact Report

(UWIR) and Groundwater Assessment (RLA 2018). • Structural geological mapping at the Project scale (Tedman-Jones 2017). • Geochemical assessment of waste rock and low-grade ore samples, describing acid-

forming characteristics and multi-element enrichment (GCA 2018a). • Geochemical assessment of tailings slurry from samples generated in a pilot plant

program in 2017 (GCA 2018b). • Further detail in the concept design study for mine waste and water management

(ATCW 2018a). • Consequence category assessment of water management structures (ATCW 2018b). • Revision of the significant residual impact (SRI) assessment (NRA 2018b).

Figures and Tables All figures and tables referred to in this report are collated after the references and before the appendices.

1 Previously Graphitecorp Ltd. The company number has not changed. 2 Previously the Queensland Department of Environment and Heritage Protection (EHP). 3 Letter dated 2 March 2017, DES reference 101/0021264; AR096425.


2 NRA Environmental Consultants 31 January 2018

2. Groundwater

Further information is required to assess the potential impacts to groundwater environmental values and to meet the requirements of s126A of the Environmental Protection Act 1994 (EP Act) and the Departments Guideline Requirements for site-specific and amendment applications – underground water rights (ESR/2016/3275).

The proposed open pit will exercise ‘underground water rights’4, and further information regarding potential impacts associated with interfering with underground water is provided in this report. These rights will be exercised on MLA 100121 during development and operation of the proposed open pit.

Hydrogeologist, Rob Lait & Associates (RLA), prepared a report addressing the information request items for groundwater, ie Mt Dromedary Underground Water Impact Report and Dewatering Assessment (RLA 2018) (Appendix B).

Information request: 1(a). For each aquifer affected, or likely to be affected, by the proposed mining activities and the exercise of underground water rights:

i) a description of each aquifer, including: - hydrogeological properties - aquifer type, number and flow rates (confined, unconfined, fractured, etc) - geology/stratigraphy (such as alluvium, volcanic, metamorphic) - depth to and thickness of the aquifers - a description of the physical integrity of the aquifer, fluvial processes and morphology of groundwater resources - depth to water level and seasonal changes in level/elevation; and - hydrogeological cross sections, including: affected or potentially affected aquifers; the elevations and relative positions of each of these aquifers; the location of water bores screened within these aquifers (if known); the location of any significant faults and/or structural geological features that intersect each potentially affected aquifer; and available data on current underground water levels.

1(b). An analysis of the movement of underground water to and from the aquifer, including how the aquifer interacts with other aquifers and surface water, including:

i) inputs (recharge from rainfall or other aquifers) and outputs (discharge to springs, base flow to watercourses and extraction from water bores)

ii) contours of underground water elevations to analyse groundwater movements iii) the connectivity between aquifers iv) natural and anthropogenic preferential flow paths such as faults and abandoned water

bores and exploration bores.

The aquifer(s) relevant to the Project, and the movement of underground water associated with the aquifer(s), is described in section 5 of RLA (2018) (Appendix B). Information paraphrased here has been sourced from RLA (2018).

The main aquifer at the Project, and the only one to be considered of any significance, occurs in fractured calc-silicates of the Corella Formation. Four dedicated groundwater monitoring bores are installed in this formation (to the north, south, east and west of the proposed open pit). Data from these bores indicates that the general depth to groundwater near the pit occurs between 15 m and 25 m below ground level (BGL). Close to the central watercourse, to the south of the proposed open pit, the depth to the water table may be as shallow as approximately 5-7 m BGL.

4 As defined in the Queensland Water Act 2000.



The groundwater monitoring bores recorded very low hydraulic conductivity, in the order of 10-6 and 10-7 m/s, and this was observed in the low airlift yields and discharges of these bores in the Corella Formation.

It has been assumed in the groundwater assessment that hydraulic connectivity exists across the Project site within the Corella Formation. Correlation of monthly groundwater level data (from the four monitoring bores at the Project) and monthly rainfall nearby shows that the water level in the bores responded to rainfall recharge and that water levels fluctuated seasonally between 1 m and 4 m. Using potentiometric surface contours, the located groundwater flow direction is from north to south, towards the central watercourse.

Other aquifers in the area, considered to not be of significance to the project, include calcite deposit lenses in hard calc-silicate rock, and the Gilbert River and Wallumbilla Formations in the Mesozoic sequence (part of the Great Artesian Basin). None of these aquifers is considered to be hydraulically connected with the Corella Formation at the Project.

Information request: 1 (c). A description of the area of the aquifer where the water level is predicted to decline because of the proposed mining activities and the exercise of underground water rights, which includes:

i) predictions for the life of the project and post-closure ii) the timing, spatial extent and magnitude of maximum water level declines in affected

aquifers iii) the timing and magnitude of groundwater level equilibrium in affected aquifers iv) detailed information about the groundwater model, including:

- model type (eg numerical or analytical) - modelling platform - model inputs (eg aquifer hydraulic properties, the extraction regime and locations of the bores/wells) - model boundary conditions - model assumptions and limitations (including those related to connectivity between aquifers and water balance components); and - details of any sensitivity analysis and/or calibration that was performed.

Potential impacts of the proposed exercise of underground water rights on the aquifer at the Project are described in section 6 of RLA (2018) (Appendix B). A numerical model was used to simulate impacts from the proposed mining operations. The finite-element simulation package FEFLOW was used, and details on the model inputs, boundary conditions, assumptions, limitations, calibration and sensitivity analysis are provided in Appendix B. The model outputs show the predicted drawdown in years 2, 3 and life of the mine.

Information request: 1(d). The predicted quantities of water to be taken or interfered with because of the proposed mining activities and the exercise of underground water rights during the period in which activities are carried out, which includes:

i) an estimate of the groundwater that will be extracted during the period in which the mining activities are carried out based on the projected production or extraction schedule.

Section 4 of RLA (2018) (Appendix B) describes the predicted quantities of water to be taken or interfered with by the proposed exercise of underground water rights. It is expected that approximately 1,463 ML of groundwater will be extracted from the open pit over the life of the mine. This volume includes a recharge rate of 0.1% rainfall in the model. During the first 12 months of mining, approximately 5 ML of water is expected to be taken from the open pit, followed by 26 ML by year 2 and 58 ML by year 3. The volumes do not include incidental rainfall or surface runoff that may enter the open pit. The predicted annual dewatering volume for each year of operation is presented in Table 4.1 of Appendix B.



Information request: 1(e). The environmental values that will, or may, be affected by the proposed mining activities and the exercise of underground water rights and the nature and extent of the impacts on the environmental values, including an assessment of the following aspects:

i) the magnitude, relative size or actual extent of any impact in relation to the environmental value being affected by groundwater level changes, particularly a decline in water level or change in water quality

ii) the vulnerability or resilience of the environmental value to the predicted impacts considering; and - the severity of any adverse effect; and - the duration of the effect, for example the impact may be seasonal, or it may end with the activity or extend beyond the cessation of the activity.

iii) An indication of the level of uncertainty of impacts and any assumptions used to address the uncertainty in any of the data or proposed commitments to protect the environmental values.

Taking, or interfering with, groundwater by development of the open pit is predicted to reduce groundwater levels in the area surrounding the open pit. The predicted drawdown contours are provided in RLA (2018) (Appendix B). Reduced groundwater levels have the potential to negatively impact on environmental values (EVs). The EVs that may be affected by the exercise of underground water rights of the Project are described in section 7 of RLA (2018) (Appendix B). All EVs listed in the Queensland Environmental Protection (Water) Policy 2009 have been considered, and the EVs that may be affected by the exercise of underground water rights are considered in more detail, ie aquatic ecosystem (biological integrity of ecosystems), stock watering, and industrial use.

The existing land use at the Project is cattle grazing, and landholders commonly use groundwater for livestock (beef cattle) watering. No landholder bores are located within the predicted groundwater drawdown area, and no impact is predicted for nearby groundwater users (section 7.5 in RLA 2018 (Appendix B)).

The only industrial activities in the area are those proposed as part of the Project. Groundwater extracted at the Project will be via passive in-pit dewatering, and the extracted water will be used on-site. The groundwater quality at the Project is considered suitable for the proposed operation.

The Guidelines for Groundwater Quality Protection in Australia (Australian Government 2013)5 note that, in the context of water quality guidelines (ie ANZECC/ARMCANZ 2000 and NHMRC & NRMMC 2011), “the ‘aquatic ecosystem’ category of EV refers to the groundwater quality that supports GDEs, such as groundwater discharge to rivers and wetlands, and to aquatic organisms that solely inhabit groundwater” (eg stygofauna). Aquatic Groundwater Dependent Ecosystems (GDEs) (ie where groundwater discharges to rivers and wetlands) and subterranean GDEs (ie caves) are considered not present in the Project area. Therefore, the ‘aquatic ecosystem’ EV is considered not present. Wetlands also are not present in the Project area (NRA 2018a (Appendix C)), and therefore the EVs of wetlands (as listed in EHP 2016a) do not apply.

GDEs also include vegetation, and a potential terrestrial GDE has been identified within the predicted groundwater drawdown area in the Corella Formation aquifer. The potential terrestrial GDE was identified by Wetland Indicator Species (WIS) occurring on the banks of the central watercourse (eg Melaleuca bracteata) and by the approximate depth to the water

5 Refer to the guideline Requirements for site-specific and amendment application – underground water rights (EHP 2016a) for further guidance on deriving EVs for groundwater.



table (conservative estimate 5.5 m BGL). Roots from M. bracteata and other plants along the watercourse may rely on the subsurface availability of groundwater to maintain their viability and ecosystem services. Plate 1 shows the M. bracteata vegetation along the central watercourse within the predicted groundwater drawdown area. In Plate 2, the potential terrestrial GDE is indicated by the greener vegetation along the central watercourse.

Plate 1: Vegetation along the central watercourse, potentially a terrestrial GDE

Plate 2: Aerial photograph of potential terrestrial GDE along the central watercourse,

indicated by the green vegetation

The vegetation along the central watercourse also receives surface water flows during the wet season, and the reliance of this ecosystem on subsurface sources of groundwater for survival is unquantified. Consequently, the contribution of groundwater to the ecosystem along the central watercourse has not been determined, and a cautionary approach has been taken when considering potential impacts from groundwater drawdown. The impact assessment is described in section 7.4 of RLA (2018) (Appendix B). In a worst-case



scenario, there may be mortality to some plants along the riparian zone within the predicted groundwater drawdown area. The low hydraulic conductivities of the fractured rock aquifer in the Corella Formation suggest that groundwater level recovery would be extremely slow and that the effects of groundwater drawdown from the exercise of underground water rights will occur beyond mine closure. The rate of recovery is dependent on several factors, including the amount of rainfall received. Although some species of plants may be cleared due to groundwater drawdown during mining operations and post closure, it is likely that vegetation will remain on the banks of the watercourse. This vegetation is likely to comprise grasses, sedges, shrubs and trees that do not require groundwater for survival6, thus retaining the ecosystem services of the vegetation along the central watercourse.

It is proposed that during mining operations the potential impacts of groundwater drawdown on vegetation along the central watercourse will be monitored to quantify and confirm if the potential impact occurs or is likely to occur. The monitoring will include groundwater levels at bore site GWMB01 and observational surveys on vegetation condition (eg indications of dieback/stress). The monitoring will be developed and incorporated into the Project’s Receiving Environment Monitoring Program (REMP), which will be required as a condition in the EA.

RLA (2018) determined that the exercise of underground water rights was not likely to affect groundwater quality within the predicted drawdown area, and if any moderate changes occurred, they would not have a significant impact on EVs or beneficial uses identified for the Project.

Some of the predicted drawdown area occurs within the life of mine extent of the open pit, and vegetation associated with the watercourse along these sections will be removed as part of pit development. For the remaining sections of watercourse outside of the open pit, the vegetation is mapped as ‘regulated vegetation associated with a watercourse’ by the Queensland Government, and therefore potential impacts require assessment under the using the Significant Residual Impact (SRI) guideline (EHP 2014). This assessment has been completed, and the outcomes are reported in Section 7.

Information request: 1(f). Any impacts on the quality of groundwater that will, or may, happen because of the proposed mining activities and the exercise of underground water rights during or after the period in which mining activities are carried out; including:

i) in order to determine a baseline that predicted impacts are compared to the following parameters should be measured in accordance with the requirements of the Queensland Water Quality Guidelines 2009, version 3 (relating to sampling intensity and frequency): - pH - electrical conductivity - turbidity - total dissolved solids - temperature - dissolved oxygen - alkalinity (bicarbonate, carbonate, hydroxide and total as CaCO3) - anions (bicarbonate, carbonate, hydroxide, chloride, sulphate) - cations (aluminium, calcium, magnesium, potassium, sodium) - silica - dissolved and total metals and metalloids (including but not necessarily being limited to: aluminium, arsenic, barium, borate (boron), cadmium, chromium III, cobalt, copper,

6 As indicated by vegetation along the watercourse outside the terrestrial GDE (observations by NRA during baseline surveys).



iron, fluoride, lead, manganese, mercury, molybdenum, nickel, selenium, silver, strontium, tin, uranium, vanadium and zinc) - total phosphorus - ammonia, nitrate, nitrite as nitrogen - gross alpha + gross beta or radionuclides by gamma spectroscopy.

ii) An explanation of the variation of chemical concentrations as a result of chemical reactions over the life of the project including an evaluation of the following contributing factors: - magnitude of the water level decline - differences in water quality in aquifers overlying and/or underlying this aquifer; and - the connectivity between the target aquifer for resource activities and the underlying and overlying aquifer.

Four groundwater monitoring bores have been installed at the Project to collect baseline data (water levels and water quality) for potential impacts from the pit development and the associated exercise of underground water rights. The bores are labelled GWMB01, GWMB02, GWMB03 and GWMB04, and their locations are shown on Figure 2.

Baseline groundwater quality data is collated in Table 1. The analytes measured included pH, electrical conductivity (EC), major ions, alkalinity, nutrients and metals/metalloids. Some analytes listed in the information request have not been included in the baseline monitoring as they are not relevant to the Project. For example, silica is relevant for coal seam gas projects because of the potential changes in this analyte during water treatment process (eg desalination); desalination is not proposed for the Project. Turbidity, temperature and dissolved oxygen were not measured in groundwater because these analytes are not likely to be affected by the Project; if they are needed for investigation to interpret other analytes in the future, they can be included in the analyte suite at the appropriate time. Radionuclides may naturally occur in the groundwater; the proposed mining activity is not likely to increase or concentrate these analytes (increases in radionuclides may occur as a waste product from water treatment, such as reverse osmosis of coal seam gas water or drinking water). Barium, boron, silver, tin, vanadium and uranium were not included in baseline monitoring. Geochemistry analysis and comparison to the Geochemical Abundance Index (GAI) show that these analytes are not significantly enriched at the Project (further information on geochemical analysis is provided in Section 4). Future monitoring will include these analytes to confirm they are not needed for compliance monitoring.

In Table 1, the baseline water quality data was compared to default guideline values for livestock (beef cattle) drinking water (noting that other EVs are not present for the Project, as described above). The only exceedance of the default guideline values was sulfate on one occasion. The data shows that the groundwater in the Corella Formation at the Project site is generally neutral (pH 6.8-8.4), fresh to slightly brackish (EC 810-2920 µS/cm), with variable major ion concentrations. The metal/metalloid concentrations were mostly below or close to the laboratory limit of reporting, with the exception of arsenic, which was detected in all bores (up to 113 µg/L in GWMB02). Zinc was recorded in GWMB04 above the laboratory limit of reporting on each sample occasion (6-33 µg/L), and it was below the limit of reporting for most sample occasions in the other bores. Arsenic and zinc were far below the livestock drinking water guideline values (500 µg/L and 20,000 µg/L respectively).

Baseline water quality, and potential impacts of the exercise of underground water rights, was considered in the UWIR and groundwater assessment report (RLA 2018, Appendix B). According to the hydrogeologist, ‘there are no changes expected in water quality as a result of the exercise of underground water rights, and a moderate change in quality would not have a significant impact on environmental values or beneficial use’ (section 8.1 of RLA 2018).



Information request: 1(g). Strategies for avoiding, mitigating or managing the predicted impacts on the environmental values stated for paragraph (1)(e) or the impacts on the quality of groundwater mentioned in paragraph (1)(f). These are presented in the text boxes in the sections above.

The exercise of underground water rights for the Project may reduce the groundwater level in a potential terrestrial GDE area to the point where vegetation along the central watercourse may be adversely affected. In a worst case scenario, dieback or mortality may occur to some plants, such as M. bracteata shrubs along the watercourse. As stated above, the reliance of plants along the central watercourse to subsurface groundwater is not known, and therefore a conservative approach is taken and assumes that the interaction exists.

The environmental objective is for the exercise of underground water rights to have a minimal impact on vegetation along the central watercourse and for ecosystem services to remain intact.

To achieve the objective, the following strategies will be implemented to minimise impacts on the potential terrestrial GDE. • Surface area and depth of the open pit will be minimised to the extent needed for the

mining operation, thus reducing the volume of groundwater interfered with. • Surface water flows to the central watercourse will be retained to continue alternative

water sources to the riparian vegetation. • Existing disturbances to riparian vegetation, ie from cattle grazing, will be reduced by

fencing cattle away from the Project area. This will reduce sources of impact to the vegetation.

• Annual monitoring of vegetation condition along the central watercourse will be undertaken to identify if degradation to the vegetation occurs during mining operations (eg dieback/stress or mortality). The monitoring will be interpreted with groundwater level data for the nearby bore GWMB01 to correlate groundwater drawdown with effects on the vegetation.

• It is expected that if GDE plants are removed from the watercourse, other plants will colonise the banks, thus retaining ecosystem services (eg bank stability). However, the density of shrubs along the watercourse may reduce. This assumption is based on the vegetation observed on sections of the central watercourse downstream of the potential terrestrial GDE (pers. obs., Shannon Wetherall, Senior Environmental Scientist, NRA, February 2016).

The monitoring program will be defined as part of the REMP, and will be reviewed according to the REMP review schedule. The review will incorporate the findings of the groundwater model update, which is required for the UWIR, to clarify if the monitoring area and predicted drawdown area remains relevant. The monitoring program will consider the guidance in Australian Government (2013) and EHP (2016a).

Potential impacts on groundwater at the Project, other than those associated with the exercise of underground water rights, may occur from seepage of mine-affected water on-site. It is expected that the quality of water stored in the Integrated Waste-Tailings Landform (IWTL), Mine Water Dam (MWD) and Process Water Pond (PWP) may be poor quality, and may be not suitable for release to groundwater. Drainage water from the low-grade ore stockpile may be of poor quality. Therefore, it is proposed that these structures will be designed, constructed and operated to minimise seepage. In the unplanned event that poor quality seepage is not contained, drainage from the IWTL and MWD would be expected to migrate towards the surface water drainage features/watercourses to the north, south and west of the



structures. An appropriate monitoring strategy will be developed, implemented and reviewed to assess potential impacts associated with unplanned seepage risk. The PWP and low-grade ore stockpile are adjacent to the open pit and within the predicted groundwater drawdown contours. It is expected that in the unplanned event of seepage from the PWP or low-grade ore stockpile, contaminants would report to the open pit.

Prior to commissioning the IWTL and MWD, monitoring bores will be installed to collect baseline data. The proposed monitoring bore locations are shown on Figure 2, and are labelled GWMB05, GWMB06 and GWMB07. These bores will be a combination of deep and shallow bores for the purpose of monitoring water levels and quality to inform potential impacts associated with the IWTL. Once the bores have been installed, their location can be included in the EA.

GWMB03 is located within the footprint of the proposed low-grade ore stockpile. The monitoring bore will be suitable until the stockpile reaches the bore (or until groundwater dewatering reduces the water level and quantity in the bore), at which point the bore will need to be decommissioned. Prior to decommissioning GWMB03, a new monitoring bore will be installed outside of infrastructure disturbance. This location will be determined during the mining activities in consultation with a hydrogeologist, as and when needed. Based on the mine plan proposed for the EA application, a monitoring bore between the eastern edge of the open pit and the low-grade ore stockpile would be suitable (pers. comm. Rob Lait, RLA, 28 January 2018). The administering authority will be notified of any changes to bore locations. Details for the existing monitoring bores are presented in the EA application (refer to Table 1 in Appendix C of NRA 2016).

The environmental objective and water management strategies associated with unplanned seepage risks at the Project are described in Section 3.

For groundwater monitoring compliance in the EA, intra-bore comparison (as opposed to inter-bore comparison) will be necessary due to the groundwater system at the project (ie fractured and low yielding aquifers). The intra-bore comparison method should follow the contemporary guidance and approach from DES7.

7 As discussed with DES officers, Luke Johnstone and Jacob Toe, and NRA scientists, Shannon Wetherall and John Broughton, in 2017, and subsequently applied to metalliferous mining EAs in north Queensland.



3. Surface Water

Information request: 2. Provide a water monitoring and management plan including but not limited to: • A water balance model for the entire project including the pit and waste disposal facilities. • Water management infrastructure locations, specifications and designs by a suitably qualified

person. • The details and locations of any water release points and the character of potentially contaminated

water that may be released during the life of the project. • Receiving water monitoring locations, including the rationale for each point. • Management measures for minimising and preventing contaminated water releases to the receiving

environment. • Provide details of the project’s erosion and sediment control strategy, including an erosion hazard

assessment.

The environmental objective for surface water is that the Project will be operated in a way that protects the EVs of waters (EVs were identified in section 6.2.2 of the EA application report (NRA 2016)).

To achieve the objective, surface water management for the Project will involve minimising disturbance, segregating ‘clean’ water from mine-affected water, seepage interception, and monitoring. During the proposed operations, water will be stored in the IWTL, Raw Water Dam (RWD), MWD and PWP. Pipework and tanks will be used in the mine water infrastructure to store and transfer water, where required.

A water management plan has been prepared by engineers ATC Williams Pty Ltd (ATCW) (refer to ATCW (2018a) in Appendix D). The plan is based on the concepts developed for the Project’s water management infrastructure, and it will be reviewed when detailed designs are prepared for the Project. The water management plan includes a water balance model, which considers the storage available in the IWTL, MWD, RWD and open pit. Overall, the water balance is considered to be in deficit, and is therefore dependent on the make-up water supply for the Project. No regulated structures are modelled to spill, and water volumes in the pit sump are expected to be minor, with the exception of extreme rainfall years. A raise on the IWTL starter embankment is expected after 3 years.

Structural geology for the Project site, in the areas proposed for infrastructure development, has been described by Senior Geologist Chris Tedman-Jones (2017) (Appendix E). The local geology has been described by Tedman-Jones as follows, and key features pertinent to mine planning are shown on Figure 6 in Appendix E. • Proterozoic Corella Formation, which is tightly folded into steeply, mainly steeply west

dipping, metasediments in the northern sector (ie open pit, low-grade stockpile, process plant, administration area). No large regional scale faults were identified in the low-grade ore stockpile, processing plant and administration areas.

• Alluvium and colluvium in most of the southern section (ie IWTL, MWD, RWD, landfill area), which masks large areas from structure observations.

• One prominent sheared fault structure (‘Creek Fault’), aligned with a north-south trending creek bed and indicating displacement of local lithology, is mapped on the eastern side of the southern sector at the RWD.

• ‘Middle Fault’ is west of ‘Creek Fault’. This is a north-south structure interpreted from regional magnetics and not located/confirmed in outcrop. The feature occurs on the eastern margin of the IWTL structure.



• The major north-south trending Coolullah Fault occurs in the western margin of the Project area and does not intersect any proposed infrastructure.

• The mapped structures in the northern and southern sectors represent relatively tight structural formation and should be minimally pervious and not significantly impact infrastructure planning. Structures described as ‘Middle Fault’ and ‘Creek Fault’ are not considered to be regionally significant, but relatively limited scale local structures. Mine infrastructure planning should consider these features.

The location and design specifications (concept) for the water management structures are included in ATCW (2018a), and the locations are shown on Figure 3. The designs and specifications have been prepared by a suitably qualified person. A compacted low permeability basal zone is proposed for the base of the IWTL, with grading west away from the ‘Middle Fault’ and towards the MWD. This will minimise downward migration of contaminants from the IWTL. The presence of ‘Creek Fault’ below the RWD is not considered an environmental risk because the RWD will be used to store clean make-up water for the Project, not mine-affected water. Therefore, the migration of contaminants from the RWD to the receiving environment is unlikely. Surface water monitoring site SW7 may be used to monitor potential impacts of seepage from the RWD and IWTL along the ‘Creek Fault’ and ‘Middle Fault’ respectively.

Proposed release points on the water management structures (IWTL, MWD, RWD) are the emergency spillways shown on the design drawings in ATCW (2018a) (Appendix D). Figure 3 shows the location of the proposed release points (ie RP1, RP2, RP3). The RWD will contain make-up water sourced from Lake Julius and rainfall water. Water stored in the RWD will not be mine-affected water, and it is assumed to be suitable for release to the receiving environment. Water quality monitoring during operations, when water is stored in the RWD, will be undertaken to confirm this assumption. The IWTL will store potentially acid forming (PAF) waste rock and thickened tailings. Based on the geochemistry of the waste rock (GCA 2018a), preliminary geochemical analysis of tailings-solids test samples (GCA 2016b), and tailings slurry water analysis (GCA 2018b), it is expected that the water stored in the IWTL will be enriched with sulfate, fluoride, and some metals/metalloids, and may be acidic and brackish, depending on the sulfide-oxidation reactions and pH balancing in the processing plant. The water in the IWTL may also contain traces of hydrocarbons as a residue from the processing circuit.

Proposed receiving water monitoring sites are shown on Figure 3 and are located on watercourses downstream of the proposed mining activities and water storages. Table 2 lists the proposed receiving water sites, their co-ordinate, and rationale for the monitoring site. The site locations have been selected based on field observations by NRA personnel in February 2016 and February 2017, within 24 hours of rainfall. The majority of the watercourses in the receiving environment were dry, and small isolated pools were observed. As the central and southern watercourses flow westwards, they drain as overland flow across the floodplain towards the Leichhardt River. Therefore, the extent of the receiving environment, for reliable and meaningful surface water monitoring, does not appear to extend beyond the mining lease (MLA 100121).

Management measures to minimise and prevent contaminated water releases to the receiving environment are identified in ATCW (2018a) (Appendix D), and include the following principles. • Preference to contain acid producing mine waste material in one area, ie co-disposal of

PAF waste rock with thickened tailings. • Simplified water management (single mine-affected water dam).



• Minimising the amount of make-up water brought to the site by recovering and recycling mine-affected water in the process circuit. This will include recovering of water from tailings by a paste thickener, and decant pond on the IWTL.

• Reduced land disturbance. • Location of mine waste disposal away from core habitat and corridors of the Purple-

necked Rock Wallaby (Petrogale purpureicollis)8. • Landform stability and erosion management. • Segregation of clean water from mine-affected water and mine waste. • Diversion of clean water around mine-affected areas (open pit and low-grade ore

stockpile) to natural drainage pathways. • Recovery of water from tailings by a paste thickener, to reduce the volume of water

reporting to the IWTL. • Use of the open pit for storage of low-grade ore stockpiling, when the development of

the open pit allows. • Design configuration of the structures has allowed contingency (eg total disposal volume

to IWTL calculated as 10.7 million m3, and the total design volume adopted is 12.5 million m3).

• The IWTL and low-grade ore stockpile will have a compacted low permeability basal zone. The basal zone will be graded to the MWD for the IWTL, and to the open pit for the low-grade ore stockpile.

• Operation of the IWTL will be staged, in a cell approach, allowing for progressive cover and rehabilitation throughout the project life. This will reduce the footprint exposed to rainfall, thus reducing mine-impacted runoff and drainage water, and is expected to reduce capital expenditure costs and rehabilitation liability (currently calculated as financial assurance).

• The water balance for the site is considered to be in deficit. • The Design Storage Allowance (DSA) and Mandatory Reporting Level (MRL) of

regulated structures, ie the IWTL and MWD, will be determined and monitored on-site. • Storages and mine wastes will be decommissioned and rehabilitated as soon as

practicable.

Mitigation measures to protect the EVs of water have also been described in the EA application (section 6.2.3 of NRA 2016).

Erosion and sediment control approaches for the mine water management infrastructure are described in section 8.3 of ATCW (2018a) (Appendix D). Detailed erosion and sediment control plans (ESCPs) will be prepared as part of the construction documentation for the structures. A site wide ESCP will be developed prior to earthworks on-site, and will include permanent and temporary (for construction) ESC measures. The ESCP will be prepared by an appropriately experienced person cognisant of Best Practice Erosion and Sediment Control (IECA 2008).

8 Listed as Vulnerable under the Queensland Nature Conservation Act 1992.



Information request: 2. Provide the baseline water quality of the receiving waters in accordance with the requirements of the Queensland Water Quality Guidelines 2009.

Baseline surface water and stream sediment quality monitoring was undertaken in 2016 and 2017. Surface water monitoring sites are located on the four drainages within the Project area (Figure 4). The baseline surface water quality results are provided in Table 3, and the stream sediment results are in Table 4. The sampling was undertaken in accordance with the Queensland Water Quality Guidelines (QWQG) (EHP 2013), and laboratory analysis was conducted to limits of reporting sufficiently low to allow comparison with published guideline values.

The water quality monitoring measured physico-chemical parameters including pH, electrical conductivity (EC), turbidity, major ions, alkalinity, nutrients, metals and metalloids. Metal/metalloid analysis was conducted on unfiltered and field filtered samples. Stream sediment were analysed for metal/metalloid concentrations in the <2 mm and <63 µm fractions for total recoverable metals (TRM), and in the <2 mm fraction for dilute acid extractable (DAE) concentrations.

Water quality was neutral to slightly alkaline (pH 6.1-9.3), fresh (EC 40-403 µS/cm), turbid (25-2,600 NTU), and contained negligible ions and organic forms of nutrients, and negligible metal/metalloid concentrations (most were below the laboratory limit of reporting). Copper concentrations were consistently detected above the laboratory limit of reporting for each site (2-7 µg/L), and the concentrations were above the default guideline values for the protection of slightly-to-moderately disturbed aquatic ecosystems (1.4 µg/L).

Considering the limited dataset available to date, major ion and pH records for sites SW3 and SW6 indicate that the water quality in this eastern draining watercourse are different to the waters at the other Project monitoring sites. Although the sites on the eastern draining watercourse will be in an undisturbed catchment for the proposed mining activity, the water quality differences with sites SW3 and SW6, compared to sites downstream of the proposed mining activity, may not be suitable for use as reference sites to derive site-specific guideline values for the project at this time. This should be re-considered in the future when more data has been collected and the site-specific guideline values are derived.

Stream sediment results (Table 4) recorded all metal/metalloid concentrations below default sediment quality guideline values (SQGV) for all sites (where guideline values were present), with the exception of chromium at site SW8 (104 mg/kg compared to SQGV 80 mg/kg) and nickel, which was recorded above the guideline value (21 mg/kg) at most sites (up to 38.4 mg/kg). Arsenic and copper concentrations in the <2 mm TRM results were close to, but did not exceed, the SQGV for some sites. The DAE concentrations for all metals/metalloids were well below the default SQGV, indicating low risk to the slightly-to-moderately disturbed aquatic ecosystems.

Information request: 2. Propose locally derived surface water contaminant limit and trigger values, that are developed in accordance with the Queensland Water Quality Guidelines.

Watercourses at the Project are ephemeral, and water is present in small pools immediately following rainfall events. The watercourses and pools dry out within a day or two of storm events (field survey observation records). This episodic nature of the surface water makes it challenging to collect water samples, and it is expected that it will take many years (4 to 5 at



a minimum) for sufficient data to be collected to calculate interim site-specific guideline values in accordance with the QWQG (EHP 2013)9.

In the absence of site-specific guideline values, default guideline values for the protection of EVs relevant to the Project have been presented in Tables 3 and 4 and compared with the baseline surface water and stream sediment monitoring data, respectively. Sample values that are bold and underlined in the tables exceeded at least one of the default guideline values.

Baseline monitoring covered a broad sweep of analytes in the surface water and stream sediment samples, and some of the analytes presented in Tables 3 and 4 are considered not necessary for compliance monitoring. For example, mercury was consistently below the laboratory limit of reporting in surface water and stream sediment samples, thus indicating its absence (at the relevant concentration) in the Project area. Further, mercury is not proposed to be introduced to the Project area during operations, and the geochemistry analysis on waste rock and low-grade ore samples (GCA 2018a) shows that mercury is not present in significant abundance, therefore mercury is not considered a risk and should not be included in the EA for compliance reporting.

Major ions and nutrients should be included as part of the REMP, but not in the EA (ie analytes for compliance with trigger values and contaminant limits are nominated). For nutrients, the effects of cattle in the catchment are likely to influence the phosphorus and nitrogen concentrations (as shown by the elevated concentrations recorded in baseline monitoring). The exception to this is nitrate, which may occur on-site from explosive residue on waste rock and ore, and hence nitrate has been included. Major ions (with the exception of sulfate) are useful during investigations, but not for compliance reporting.

Considering the baseline data collected for the project, guidance in the QWQG (EHP 2013) and associated guidelines (eg ANZECC/ARMCANZ 2000), and contemporary approaches to surface water compliance monitoring, the analytes, trigger values and contaminant limits in Table 5 are suggested for the EA.

For stream sediment, nickel and chromium exceeded the default SQGV on at least one occasion in the <2 mm sediment fraction using the TRM method, and arsenic and copper concentrations were close to the SQGV on two occasions. Following the decision framework in Simpson et al. (2013), the DAE concentrations were compared to the default SQGV and showed no exceedances. Considering the baseline concentrations of some metals/metalloids, site-specific guideline values will be important for assessing potential impacts on the receiving environment from the proposed mining activity. In the absence of sufficient data to calculate site-specific guideline values, the decision tree framework in Figure 1 of Simpson et al. (2013), which is a revision of the method in ANZECC/ARMCANZ (2000), should be applied.

The default SQGVs (Table 2 in Simpson et al. 2013) list concentrations that are considered ‘low risk’ and ‘high risk’ to aquatic ecosystems. For analytes without guideline values, Simpson et al. (2013) and ANZECC/ARMCANZ (2000) suggest using the median natural background (reference) concentrations multiplied by an appropriate factor. A factor of two is recommended for slightly-to-moderately disturbed ecosystems; although, in some highly disturbed ecosystems, a factor up to three may be more appropriate. Considering this advice,

9 A minimum of eight sample values per reference site is required to calculate interim site-specific guideline values.



and in the absence of site-specific guideline values at this time, the trigger values and contaminant limits in Table 6 are suggested for the EA.

Information request: 2. Provide details of how the operation will ensure that contaminated water, which has been proposed to be used in the processing plant and dust suppression on haul roads, will not have an impact on groundwater.

Mine-affected water will be used on-site for dust suppression and for use in the processing plant, where suitable. The water balance for the Project (ATCW 2018a) identifies a deficit; consequently, make-up water will need to be sourced. It is proposed that the make-up water will come from nearby Lake Julius. If required, the make-up water may be blended with mine-affected water to improve the water quality prior to use in dust suppression or the processing plant.

To minimise impacts on groundwater from the use of contaminated water in the processing plant, it is proposed that, with the exception of the IWTL, the water supply in the processing plant will be contained in pipes, tanks and the lined PWP. Further, the processing plant is located adjacent to the open pit and will be within the predicted long-term affected area of groundwater drawdown associated with the pit development.

Water used in dust suppression will depend on the quality of the water, and the location of the dust suppression activity. For example, very poor water quality will be applied to haul roads and surfaces requiring dust suppression within the containment of mine-affected water management (eg within the pit, low-grade ore stockpile, IWTL). All water applied to haul roads for dust suppression will be done so in a manner that is sufficient to dampen the surface, but not result in runoff. Further, the haul roads will be compacted and, combined with high evaporation for the Project, will minimise infiltration of contaminated water to groundwater. Monitoring bores located on-site will also monitor for potential contaminants (eg proposed GWMB05 and existing GWMB01 (Figure 2).

Information request: 2. Provide appropriate modelling, such as, the Model for Effluent Disposal Using Land Irrigation (MEDLI) software, for the proposed method of treating and releasing sewage.

The Project is located in a semi-arid climate, where annual evaporation far exceeds annual rainfall10 (refer to Table 1 in Appendix D (ATCW 2018a)). The proposed treatment of sewage and release of effluent meets the eligibility criteria in the Eligibility criteria and standard conditions for sewage treatment works (ERA 63) (EHP 2015), as follows. • Sewage treatment will have a peak design capacity of 21 to 100 equivalent persons, and

treated effluent will be discharged through an irrigation scheme, ie irrigation to naturally vegetated areas, allowing evaporation of irrigated waters.

• Treated effluent will not be discharged to an infiltration trench. • The treated effluent disposal area is not located within 250 m of a bore used for domestic

water supply, or within 1,000 m of a bore used for town water supply. • The activity will not be carried out in a designated precinct in a strategic environmental

area.

10 Long-term average yearly rainfall in Cloncurry: 490.2 mm; long-term average yearly evaporation in Mt Isa: 3,068 mm; long-term average yearly evaporation in Julia Creek: 2,885 mm (sourced from the Bureau of Meteorology and reported in ATCW 2018a).



• The sewage treatment plant and treated effluent disposal area will be located more than 100 m away from any watercourse, wetland or spring.

• The sewage treatment plant will not release aqueous waste to waters.

In addition to meeting the eligibility criteria, the proposed activity will also comply with the standard conditions for environmentally relevant activity (ERA) 63 (in EHP 2015). This includes the irrigation area requirements for areas of <600 mm of rainfall per year (Table 1 in EHP 2015), contaminant release limits to land (Table 2 in EHP 2015), and monitoring requirements (condition D5 in EHP 2015). Other standard conditions for ERA 63 can also be complied with, but are likely to be superseded by the site-specific conditions relevant to other ERAs proposed for the Project.



4. Waste Rock/Ore/Tailings Characterisation and Management

Information request: 3. Provide detailed characterisation of the waste rock, waste ore and tailings material, including but not limited to kinetic tests, advanced static tests and multi-element analysis, in accordance with the Global Acid Rock Drainage (GARD) Guide requirements. Provide a material balance of NAF, PAF and Uncertain material based on the testing required above.

The preliminary geochemical analysis reported in the EA application (GCA 2016a in NRA 2016) has been updated with further geochemical characterisation of waste rock and low-grade ore samples by geochemist Graeme Campbell & Associates Pty Ltd (GCA 2018a, provided in Appendix F).

The following analyses were conducted on samples from the weathered zone and fresh zone representative of waste rock and low-grade ore. • Acid forming characteristics – results used to classify samples as non-acid forming

(NAF) or potentially acid forming (PAF). The already acidic conditions of some samples further classified these as PAF-short lag.

• Multi-element composition – results used to identify element enrichments, which may be a concern for environmental management.

• Water-extraction test work – results show the interaction of crushed samples with water, and describe the geochemistry of ‘contact waters’ with the waste rock and low-grade ore samples.

The multi-element analysis results from GCA (2018a) were compared to the element average crustal abundances (from Smith & Huyck 1999) to provide an indication of element enrichment using the Geochemical Abundance Index (GAI), as per the Global Acid Rock Drainage (GARD) Guide (INAP 2017). The results are summarised in Table 6 and show: • mine waste, weathered zone – no significant enrichment of assessed elements • mine waste, fresh zone – no significant enrichment of assessed elements • low-grade oxide ore – no significant enrichment of assessed elements • low-grade primary ore – arsenic, molybdenum and selenium significantly enriched.

Tailings samples are characterised as either graphite-schist weathered ore (GSW) or graphite-schist primary ore (GSP). Preliminary studies on the tailings described the GSW tailings as NAF due to negligible sulfides in a calcareous gangue, and the GSP as PAF due to accessory sulfides in a gangue devoid of calcite (GCA 2016b). In 2017, a pilot plant study was undertaken in Brazil, and tailings samples generated from this work are being analysed by Graeme Campbell & Associates (GCA). Tailings slurry water for GSW and GSP samples has been analysed and reported (GCA 2018b) (Appendix G), and static testing of the GSW and GSP tailings solids is underway. Kinetic testing is not proposed for the tailings samples, and is considered not necessary at this stage, because the tailings management at the Project assumes that the IWTL will be managed as problematic waste (ie PAF with enriched metal/metalloid concentrations).

GCA (2018b) (Appendix G) describes the GSW tailings slurry water as circum-neutral (pH 7.3) with abundant bicarbonate-alkalinity (88 mg/L as CaCO3) and minor element



concentrations (below or close to the detection limits). For the GSP tailings slurry water, the pH was acidic (3.7) and some element concentrations were elevated, reflecting the acidification from sulfide-oxidation as a result of the samples being stored for some time during the pilot plant trials, and prior to laboratory analysis (GCA 2018b). During operations, pH control during flotation should produce circum-neutral GSP tailings slurry water with minor element concentration (GCA 2018b). Hydrocarbons are proposed to be used during ore processing. The tailings slurry waters detected recoverable hydrocarbons (for C10-C14 and C15-C28) above the detection limit; all other hydrocarbons (volatile and polycyclic aromatic hydrocarbons) were below laboratory reporting limits (GCA 2018b, Appendix G). These results, combined with the preliminary geochemical assessment (GCA 2016b) identify potential contaminants that are expected to be generated from the processing of the graphite schist ore (ie GSP and GSW) at the Project. As a conservative approach, it is assumed that tailings will be acid generating from sulfide-oxidation reactions, which is likely to result in low pH, elevated EC and sulfate, and elevated concentration of metals (such as aluminium, copper, nickel, zinc, cobalt, manganese, iron). The concept design for the IWTL, and the proposed surface water and groundwater monitoring programs, have taken this into consideration.

Based on the work by GCA (2016a, 2018a), a materials balance of NAF and PAF units has been determined and is summarised in Table 10 for waste rock and low-grade ore. The materials balance shows that 68% of the waste rock volume, and 80% of the low-grade ore volume, have been determined as PAF. All of the tailings material will be treated as PAF.

Information request: 3. Provide a statistical analysis that demonstrates the sampling intensity and regime is sufficient to determine the character of mine waste (rock, ore and tailings) as either PAF or NAF.

The sampling intensity and regime applied to the Project are considered sufficient to appropriately determine the mineral waste/ore as PAF or NAF, as follows (pers. comm. Graeme Campbell, geochemist, GCA, 28 January 2018). • The geological database has sulfur (S) and carbonate (CO3-C) assays, typically for 1 m

intervals, for every exploration hole drilled. • The GCA (2016a) report assessed 911 of the 1 m intervals within waste rock and low-

grade ore zones. This assessment gave a spatially comprehensive representation of acid forming tendency (with various assumptions subsequently confirmed).

• Based on the above, for sections/transects stepping along 50-100 m steps along strike (south to north of elongate pit), 33 samples were subjected to conventional static testing in GCA (2018a).

• Table A1, in conjunction with Figure 1, in GCA (2018a) shows the representativeness of the 33 samples tested in the geochemical assessment.

Information request: 3. Provide a conceptual site model that describes the release, transport and fate of contaminants from waste disposal facilities, in accordance with the GARD Guide requirements. Provide a detailed assessment of the predicted volumes and quality of seepage from the proposed waste disposal facilities. Provide detailed designs, by a suitably qualified person, of the proposed waste disposal facilities, supported by a land use assessment in accordance with Table 2, Schedule 5 of the Environmental Protection Regulation 2008. Provide a waste rock, ore and tailings management plans for the life of the mine based on the information required above.



Provide details of the proposed capping and cover systems for the closure of the waste disposal facilities.

Waste disposal facilities at the Project include the IWTL (combination of waste rock and thickened tailings), MWD (mine-affected water) and open pit (combination of low-grade ore and/or PAF waste rock). The low-grade ore stockpile is not a waste disposal facility, but will store mineralised material with NAF and PAF characteristics. Therefore, the low-grade ore stockpile has been considered here as a conservative measure.

To minimise potential impacts of waste disposal facilities on the receiving environment, the IWTL and MWD have been placed together, at the upstream extent of a small drainage feature. The low-grade ore stockpile is adjacent to the open pit to minimise the distribution of contamination sources across the site. Contaminants from the proposed waste disposal facilities have the potential to enter the receiving environment via overland flow pathways, or via seepage. Windblown dust may also be a transport pathway of contaminants.

For the IWTL and MWD, overland flow pathways would occur as discharge via the emergency spillway. The IWTL overflows to the MWD, and the MWD discharges to land adjacent to an ephemeral unnamed drainage feature. Potential environmental harm associated with discharge from the IWTL and MWD were assessed as part of the consequence category assessment for the structures (NRA 2017, in Appendix I). Drainage water from the low-grade stockpile will be captured by stormwater management controls and contained as part of the mine-affected water management.

Contaminants from the waste disposal facilities may also migrate downwards, or laterally, through the soil profile towards surface water drainages or groundwater. The IWTL and low-grade ore stockpile will be constructed with low permeability basal layers to minimise the downward migration of contaminants. A clay fill (or similar) layer and cut-off key will be incorporated into the embankment of the IWTL and MWD to minimise migration of contaminants from these facilities. A seepage interception trench will be installed on the IWTL, and a seepage collection sump will be in place for the MWD. More details on seepage fate and control for the IWTL are provided in ATCW (2018a) (Appendix D).

Designs for the waste disposal facilities (ie IWTL and MWD) have been prepared by suitably qualified persons and are included in ATCW (2018a) (Appendix D). Detailed design plans will be prepared for construction, and will be provided to the administering authority as per the requirements expected for the EA (ie model conditions).

A land use assessment, in accordance with Table 2 in Schedule 5 of the Queensland Environmental Protection Regulation 2008 has been completed, and the outcomes are provided in ATCW (2018a) (Appendix D). This assessment should be read in conjunction with the land use assessment provided in section 6.6 of the EA application (NRA 2016).

Management plans for waste rock and tailings disposal are included in section 10 of ATCW (2018a) (Appendix D). Operational and management plans will also be prepared for the facility during the detailed design phase, prior to construction and operation of the facility.

Management measures for the low-grade ore stockpile have been described in GCA (2018a) (Appendix F), and these recommend a similar approach to waste rock management at the Project. This includes the following. • Segregation of NAF rock from PAF rock.



• Placement of low-grade ore from the weathered zone as a basal blanket, and around the edge of the fresh (ie primary) zone low-grade ore.

• Active compaction (where practicable) of placed rock. • Clean water diversions around the stockpile. • Capture of drainage water in the mine-affected water circuit. • Minimising the footprint and exposed rock surfaces of the low-grade ore material. • Placement of low-grade ore (primary) in the open pit as soon as practicable, thus

reducing the volume of low-grade ore (primary) stored outside of the pit. • Rapid closure of the stockpile with a suitable cover, if the material will not be used in

processing.

A closure, decommissioning and rehabilitation plan will be provided for the IWTL as part of detailed design. The approach to closure and rehabilitation will consider capping trial outcomes. The objectives and conceptual approach to rehabilitation of the waste disposal facility is described in section 11 of ATCW (2018a) (Appendix D). The conceptual capping arrangement for the IWTL includes capillary break, sealing layer and surface protection layer.



5. Air

Information request: 4. Further information is required to determine the potential impacts to air. Specifically, please provide: - Information consistent with the requirements detailed in section 3 to 5 of the Department’s guideline Application requirements for activities with impacts to air ESR/2015/1840. - An emissions inventory for the project, consistent with section 4 of the Department’s guideline Application requirements for activities with impacts to air ESR/2015/1840, in conjunction with information about existing sources/air quality to predict cumulative ground-level impacts on sensitive receptors. - An assessment that the operation will meet the air quality objectives specified within the Environmental Protection Policy for Air (EPP Air) for all identified sensitive receptors.

Information required by sections 3 to 5 of the EHP guideline Application requirements for activities with impacts to air (ESR/2015/1840) is provided in section 6.1 of the EA application (NRA 2016), ie identification and description of EVs for air at the Project site and surrounding area (including sensitive receptors11), sources of Project impacts on the EVs for air, and proposed management practices to minimise impacts to EVs for air. Emissions from the Project are likely to include particulate matter (ie dust), odour, and exhaust fumes.

Existing sources of air pollutants for the Project are described in NRA (2016), and are particulate matter (dust) and vehicle emissions. As the project area is remote, ambient dust and vehicle emissions are expected to be conducive to a rural environment, which can include more intense sources such as dust storms or bushfires.

The greatest non-point source of particulate matter (dust) at the Project will be vehicle movements along haul roads and access tracks. Where possible, roads on-site will be constructed from compacted in situ material. If the haul roads require additional material, waste rock from the weathered zone will be used. The GAI assessment (Table 9) shows that the waste rock from the weathered zone does not contain enriched elements at significant levels; therefore, it is not expected that dust generated from vehicle movements will cause a significant impact on sensitive receptors. As a precautionary measure, to reduce dust emissions from vehicle movements, the haul road surface will be compacted, and water trucks with sprays will be used to dampen the road surface. Other dust generating activities, such as blasting, loading and unloading vehicles, stockpiles, and crushing, will be undertaken at point sources and are not likely to cause cumulative ground-level impacts on sensitive receptors.

The air quality objectives prescribed in the Queensland Environmental Protection (Air) Policy 2008 (EPP (Air)) apply to specific EVs for air. The EVs for air that may be affected by the Project are: • health and biodiversity of ecosystems (other than protected areas) (ie natural vegetation

in the Project area) • aesthetics of the environment (ie proximity of the project to the Burke Developmental

Road) • agricultural use of the environment (ie extensive cattle grazing by the landholder).

11 Sensitive receptors for the Project is the Gleeson Homestead, approximately 16 km north-west of the project (Figure 2 in NRA 2016).



Health and wellbeing of humans is also an EV; however, it is not considered present for the Project. The nearest sensitive receptor is Gleeson Homestead, approximately 16 km north-west of the Project. Given the distance between the Project and the EV, particulate matter, odour and fumes from the Project are not likely to impact on the health and wellbeing of humans.

Air quality objectives are nominated in Schedule 1 of the EPP (Air), and relevant EVs have been assigned to each of the objectives. Most of the air quality objectives apply to the health and wellbeing of humans EV. Given the scale of the proposed works and location of the Project, significant impacts on EVs for air are considered not likely to occur.



6. Mine Planning and Design

Information request: 5. Provide further information relating to the diversion of any watercourse, in accordance with section 98 of the Water Act 2000, specifically: - Details of the watercourse diversion(s) planned throughout the life of the project. - Information required by the Department of Natural Resource and Mines Guideline Works that interfere with water in a watercourse—watercourse diversions (2014) for proponents seeking approval to divert a watercourse. - An assessment of the potential impacts on downstream environmental values as a result of the watercourse diversion(s) and any associated management measures to prevent or minimise the potential impacts.

As part of the water management infrastructure at the Project, clean water diversions are proposed for upslope of the open pit to divert clean water away from mine disturbance and provide a safe work environment within the pit. ATCW (2018a) shows the location of the proposed diversions. Water captured in the clean water diversions will remain in the same catchment and will be directed in a controlled manner to the watercourse that flows from the open pit area in a southerly direction before flowing west. The clean water diversions will be installed in stages as the Project progresses, and as the open pit is developed from south to north, thus retaining flows in the area for as long a period as possible.

In accordance with the Department of Natural Resources and Mines guideline Works that interfere with water in a watercourse—watercourse diversions (2014), only features that are defined as watercourses under sections 5 and 5A of the Queensland Water Act 2000 (Water Act) and Section 3 of the Water Regulation 2002 require approval under the EA for a watercourse diversion. Since the guideline was prepared (2014), the Water Act and subordinate legislation, including the Water Regulation 2002, have been updated. Therefore, some of the definitions and their location in legislation may have changed. To determine if the Project will trigger ‘diversion of a watercourse’, the definition of a watercourse in the Water Act (current as at 7 December 2017) was considered. The definition of a ‘drainage feature’ was also considered because section 5(3) of the Water Act states that ‘a watercourse is not a drainage feature’12.

The watercourse identification map by the Queensland Government is one way of determining watercourses and drainage features under the Water Act. The mapping (last updated 1 December 2017) does not identify any ‘watercourse’, ‘drainage feature’ or ‘unmapped’ features for the Project site. The closest feature on the watercourse identification map is a tributary of the Leichhardt River, approximately 10 km west of the Project, and is mapped as a ‘watercourse’. Therefore, clarification on watercourses, for the purpose of determining the regulatory process associated with clean water diversions for the Project, was obtained from officers at the Department of Natural Resources Mines and Energy (DNRME).

12 A drainage feature is defined in the Water Act as a drainage feature identified on the watercourse identification map; or a natural landscape feature, including a gully, drain, drainage depression or other erosion feature that: (i) is formed by the concentration of, or operates to confine or concentrate, overland flow water during and immediately after rainfall events; and (ii) flows for only a short duration after a rainfall event, regardless of the frequency of flow events; and (iii) commonly, does not have enough continuing flow to create a riverine environment. Example for b)(iii) – there is commonly an absence of water favouring riparian vegetation.



Photographs and descriptions of the channel through the proposed open pit, and downstream of the open pit, were provided to DNRME for consideration in determining if the feature within the proposed open pit is a ‘watercourse’. Preliminary feedback from DNRME was that the feature within the open pit area did not meet the definition of a watercourse under the Water Act (pers. comm. Roger Timm, DNRME, 29 January 2018). Further information has been provided to DNRME, and feedback is yet to be received. Once received, DES will be updated accordingly.

The clean water diversions, which are part of the proposed stormwater management for the Project, have been designed by an appropriately qualified person (Figure 006 in ATCW (2018a) (Appendix D)). Detailed construction designs will be prepared prior to construction. The clean water diversions will adopt best practice erosion and sediment control measures (eg from IECA (2008)) to convey water in a controlled manner and minimise erosion. For example, the outlet of the diversion drain will be stabilised and on an angle that does not result in scouring. An appropriate measure would be a level spreader to overland flow prior to the water entering the channel downstream of the open pit.



7. Significant Residual Impacts

Information request: 6. Please provide further information in relation to the potential for significant residual impacts to occur to prescribed matters, including: - In accordance with the Departments Significant Residual Impact Guideline (2014), conduct an assessment of the likelihood of a significant residual impact occurring and provide information to demonstrate how an appropriate environmental offset will be delivered in accordance with the Environmental Offsets Act 2014 and Environmental Offsets Regulation 2014.

Significant Residual Impacts (SRI) were considered and reported in the EA application (section 6.5.2 of NRA 2016). Since the application was submitted, liaison with DES officers confirmed that the Regional Ecosystem (RE) structural category ‘very sparse’ should be treated the same as ‘sparse’ in the SRI guideline (EHP 2014); therefore, the SRI assessment has been revised. Further, based on the outcomes of the dewatering assessment, taking ‘associated water’ during open pit development may affect Regulated Vegetation within the predicted groundwater drawdown area (RLA 2018). Subsequently, the SRI assessment has been revised to include prescribed vegetation within the predicted drawdown area.

The open pit will permanently clear approximately 4.8 ha of Regulated Vegetation, as per the Queensland Vegetation Management Act 1999 (VM Act) mapping and definition of prescribed vegetation. A baseline field survey in 2016 (NRA) identified that the upstream extent of the VM Act watercourse was poorly defined and was more conducive to a drainage feature or gully. Taking this into account, the vegetation associated with a watercourse within the open pit would reduce by at least 2.4 ha. The area of vegetation clearing using the VM Act mapping exceeds the SRI guideline of 2 ha for ‘sparse’ structural category vegetation by at least double. The field verified information, however, significantly reduces the area of prescribed vegetation clearing. The revised SRI assessment (NRA 2018b) is included in Appendix H and, as a conservative approach, identified that a SRI was likely for Regulated Vegetation using the VM Act mapping.

Extraction of groundwater for the open pit development is predicted to reduce groundwater levels around the pit; this may have a detrimental impact on Regulated Vegetation along a watercourse (eg dieback or mortality). Using the VM Act mapping, the area of Regulated Vegetation clearing within the predicted groundwater drawdown area is approximately 0.1 ha (excluding the Regulated Vegetation accounted for in the open pit clearing above). In isolation, the groundwater drawdown activity is not likely to trigger SRI, due to the small area. Also, it is not known if the extent of impact of groundwater drawdown will cause clearing of vegetation along the watercourse. Therefore, 0.1 ha is conservative.

In combination, and assuming a worst case scenario for the groundwater drawdown, a SRI to some 4.9 ha of VM Act mapped Regulated Vegetation associated with a watercourse is likely to occur. Therefore, provisions for Environmental Offsets in accordance with the Queensland Environmental Offsets Act 2014 will be investigated, and the appropriate offset strategy will be developed and implemented for the Project. As per the guidance in EHP (2014), the requirement for offsets will be discussed with the administering authority, considering the information provided in the assessment and the intended offset objectives.

Additional information on why a SRI is considered not likely to occur from the Project on habitat for the Purple-necked Rock Wallaby is provided in NRA (2018b) (Appendix H).



8. Regulated Structures

Information request: 7. In accordance with the Manual for assessing hazard consequence and hydraulic performance structures ESR/2016/1933, please provide a consequence category assessment of any structure that is anticipated to be a ‘regulated structure’.

The following structures are proposed for the Project and will be used for water management. • Integrated Waste-Tailings Landform (IWTL). • Raw Water Dam (RWD). • Mine Water Dam (MWD). • Process Water Pond (PWP).

In accordance with the Manual for assessing consequence categories and hydraulic performance of structures (ESR/2016/1933) (EHP 2016b), a consequence category assessment for the IWTL, RWD, MWD and PWP was completed by consulting engineers ATC Williams Pty Ltd (ATCW). The Mount Dromedary Graphite Project Consequence Assessment (ATCW 2018b) report is provided in Appendix I. The general environmental harm criteria was assessed by NRA (NRA 2017) and is included in the ATCW (2018b) report.

Based on the outcomes of the assessment (ATCW 2018b): the IWTL and MWD will be regulated structures and have ‘significant’ consequence category ratings; and the RWD and PWP will have ‘low’ consequence category ratings and will not be regulated structures (as defined in EHP 2016b).



9. Rehabilitation

Information request: 8. Provide detailed rehabilitation planning, including; objectives, indicators, completion criteria, methods of rehabilitation, the rehabilitation strategy such as progressive rehabilitation and trials and any relevant reference sites that may be used.

Rehabilitation for the Project was identified in section 4.6 and throughout the EA application (NRA 2016) where rehabilitation was nominated as a proposed mitigation/management measure. This included developing a Post Mine Land Use Plan (PMLUP) to achieve the following outcomes for the final land use identified in the EA application (NRA 2016). • Areas disturbed during mining are to be progressively rehabilitated as soon as possible

following disturbance. • Rehabilitation to establish vegetation communities of an acceptable rehabilitation target. • Decommission and remediate water bodies that are part of the process circuit. • Where possible, create or enhance habitats in the post-mine landscape that are suitable

for identified threatened species (eg retain large boulders during excavation and place on the final landform as habitat for the Purple-necked Rock Wallaby).

Rehabilitation goals, consistent with the model mining conditions (EHP 2017), were nominated in section 4.6 of the EA application (NRA 2016), as follows. • Safe to humans and wildlife. • Non-polluting. • Stable. • Able to sustain an appropriate land use after rehabilitation or restoration.

Detailed rehabilitation planning will be provided during the Project, in accordance with EA conditions. Some rehabilitation strategies will be developed as part of design and operational plans for site facilities such as the IWTL, and other strategies will be developed as part of the whole Project rehabilitation. These strategies will refine the concepts described in NRA (2016) and ATCW (2018a). Progressive rehabilitation will be identified in the Plan of Operations and associated Financial Assurance calculations13.

13 It is noted that the Queensland Government approach to rehabilitation liability identification and management is being reviewed, and alternative documents may be required in the future.



10. Ground-truthing

Information request: 9. Departmental mapping has identified a prescribed matter identified as, Category B Endangered Regional Ecosystems (ERE) under the Environmental Protection Act 1994. The application states that this area has been ground-truthed and is not consistent with online mapping. Please contact the Department of Natural Resources and Mines to amend the mapping. Departmental mapping has identified a prescribed regional ecosystem within the proposed disturbance footprint of the pit. A prescribed regional ecosystem is a Matter of State Environmental Significance to the extent that the ecosystem is located within a defined distance from the defining banks of the relevant watercourse. Relevant watercourses are identified on the vegetation management watercourse and drainage feature map under the Vegetation Management Act 1999. Please contact the Department of Natural Resources and Mines to amend the vegetation management watercourse and drainage feature map. Should the mapping not be accepted, information must be provided to demonstrate how an appropriate environmental offsets will be delivered in accordance with the Environmental Offsets Act 2014 and Environmental Offsets Regulation 2014.

As per discussion with DES officers14 on 31 May 2017, the application by the proponent is for a site-specific EA. In the meeting, DES officers confirmed that it is not a requirement for Queensland Government mapping to be updated by the proponent, and site-specific information provided in the application will be used to determine and assess potential impacts on environmental values.

The VM Act mapping for Regulated Vegetation associated with a watercourse has been used in the SRI assessment for this application, and alterations to the Queensland Government mapping by NVX are not proposed at this stage.

14 Meeting with the DES project team for the EA application, as well as DES technical advisors Mike Trennery and Matt Bogart.



11. References

ANZECC/ARMCANZ 2000, Australian and New Zealand Guidelines for Fresh and Marine Water Quality, National Water Quality Management Strategy, Paper No. 4, Vol 1, Australian and New Zealand Environment and Conservation Council & Agriculture and Resource Management Council of Australia and New Zealand, Canberra, October 2000.

ANZGFMWQ 2017, Australian and New Zealand Guidelines for Fresh and Marine Water Quality – Default guideline values for toxicants: fluoride – freshwater (DRAFT), Australian Department of Agriculture and Water Resources, Canberra.

ATCW 2018a, Mount Dromedary Graphite Project Concept Design Study for Mine Waste and Water Management, prepared by ATC Williams Pty Ltd for Novonix Ltd, January 2018.

ATCW 2018b, Mount Dromedary Graphite Project Consequence Assessment, prepared by ATC Williams Pty Ltd for Novonix Ltd, January 2018.

Australian Government 2013, Guidelines for Groundwater Quality Protection in Australia, National Water Quality Management Strategy, Australian Government.

EHP 2013, Queensland Water Quality Guidelines 2009, Version 3, Department of Environment and Heritage Protection, Brisbane, July 2013.

EHP 2014, Queensland Environmental Offsets Policy Significant Residual Impact Guideline – Nature Conservation Act 1992, Environmental Protection Act 1994, Marine Parks Act 2004, Department of Environment and Heritage Protection, Queensland Government, December 2014.

EHP 2015, Eligibility criteria and standard conditions for sewage treatment works (ERA 63), ESR/2015/1710, version 2, Department of Environment and Heritage Protection, Queensland Government, effective 30 September 2015.

EHP 2016a, Requirements for site-specific and amendment application – underground water rights, ESR/2016/3275, version 1.00, Department of Environment and Heritage Protection, Queensland Government, effective 6 December 2016.

EHP 2016b, Manual for assessing consequence categories and hydraulic performance of structures, ESR/2016/1933, version 5.00, Department of Environment and Heritage Protection, Queensland Government, effective 29 March 2016.

EHP 2017, Guideline – Model Mining Conditions, ESR/2016/1936, version 6.01, Department of Environment and Heritage Protection, Queensland Government, effective 7 March 2017.

GCA 2016a, Mount Dromedary Project: Assessment of Assay Results in Context of Environmental Geochemistry of Low-Grade-Ore and Mine-Waste Samples and Implications for Material Management, prepared by Graeme Campbell & Associates Pty Ltd for Graphitecorp Ltd, 23 November 2016.

GCA 2016b, Mount Dromedary Project: Assessment of Assay Results for Tailings-Solids Samples Derived from Preliminary Bench-Scale Metallurgical Studies and Implications for Process-Tailings Management, prepared by Graeme Campbell & Associates Pty Ltd for Graphitecorp Ltd, 7 December 2016.

GCA 2018a, Mount Dromedary Project: Geochemical Assessment of Mine-Waste and Low-Grade-Ore (LG-Ore) Samples – Implications for Mine-Waste and LG-Ore Management, prepared by Graeme Campbell & Associates Pty Ltd for Novonix Ltd, 24 January 2018.



GCA 2018b, Mount Dromedary Project: Geochemical Assessment of GSW-Tailings-Slurry and GSP-Tailings-Slurry Samples Generated in 2017 Pilot-Plant Programme in Brazil, prepared by Graeme Campbell & Associates Pty Ltd for Novonix Ltd, 28 January 2018

Hickey C 2002, Nitrate Guideline Values in ANZECC 2000, Memorandum from the National Institute of Water and Atmospheric Research (NIWA) NZ, 30 September 2002.

Hogan AC, Butler AR, Butler F & Batley GE 2016, Derivation of High Reliability Water Quality Guideline Values for Cobalt in Freshwaters – Improving Water Quality Guidelines for Better Water Quality Compliance Management in Mining, Life-of-Mine 2016 Conference, Brisbane, Queensland 28-30 September 2016, Proceedings published by the Australasian Institute of Mining and Metallurgy.

IECA 2008, Best Practice Erosion and Sediment Control, International Erosion Control Association (Australasian Chapter), Picton, NSW, Australia, November 2008.

INAP 2017, Global Acid Rock Drainage Guide (GARD Guide), International Network for Acid Prevention, ‘http://www.gardguide.com'.

NHMRC & NRMMC 2011, Australian Drinking Water Guidelines Paper 6 National Water Quality Management Strategy, Version 3.3 (updated November 2016), National Health and Medical Research Council, Natural Resource Management Ministerial Council, Commonwealth of Australia, Canberra.

NHMRC 2008, Guideline for Managing Risks in Recreational Water, National Health and Medical Research Council, Commonwealth of Australia, Canberra.

NRA 2016, Mount Dromedary Graphite Project Site-specific Environmental Authority Application, prepared by NRA Environmental Consultants for Graphitecorp Ltd, 15 December 2016.

NRA 2017, Consequence Category Assessment (General Environmental Harm) for Structures at the Mount Dromedary Graphite Project, prepared by NRA Environmental Consultants for Novonix Ltd, 15 December 2017.

NRA 2018a, Mt Dromedary Groundwater Dependent Ecosystem Indicators, technical note prepared by NRA Environmental Consultants for Novonix Ltd, 25 January 2018.

NRA 2018b, Mount Dromedary Graphite Project, Site-specific EA application, DES Information Request 101/0021264; AR096425: Response to Flora and Fauna Items, prepared by NRA Environmental Consultants for Novonix Ltd, 31 January 2018.

RLA 2018, Mt Dromedary Underground Water Impact Report and Dewatering Assessment, prepared by Rob Lait & Associates for Novonix Ltd, January 2018.

Simpson SL, Batley GE & Chariton AA 2013, Revision of the ANZECC/ARMCANZ Sediment Quality Guidelines, CSIRO Land and Water Science Report 08/07, Report prepared for the Department of Sustainability, Environment, Water, Population and Communities, May 2013.

Smith KS & Huyck HLO, 1999, An overview of the abundance, relative mobility, bioavailability, and human toxicity of metals, in Plumlee, GS & Logson, MJ (eds), The environmental geochemistry of mineral deposits, Part A: Processes, techniques, and health issues, Littleton, Colorado, USA, Society of Economic Geologists.

Tedman-Jones C, 2017, Synopsis: Structural mapping covering the infrastructure planned for the mine construction at the, Mount Dromedary Graphite Project, Cloncurry, NW Queensland, prepared by Chris Tedman-Jones (Senior Geologist) for Novonix Ltd, September 2017.

Figures and Tables


NRA Environmental Consultants Figures and Tables v 31 January 2018

Table 1: Mount Dromedary baseline groundwater monitoring data

Analyte Unit Groundwater Quality Monitoring Bores

Livestock drinking water quality guideline value1 GWMB01 GWMB02 GWMB03 GWMB04

12/7/16 17/8/16 10/5/17 16/8/17 14/11/17 16/8/16 10/5/17 16/8/17 14/11/17 12/7/16 16/8/16 10/5/17 16/8/17 14/11/17 12/7/16 16/8/16 10/5/17 16/8/17 14/11/17 pH pH Units 7.7 7.9 7.2 7.2 8.0 7.9 7.1 7.2 7.2 8.4 8.0 7.1 7.1 7.1 7.6 7.8 6.8 7.8 7.3 6.0 – 8.5a Electrical Conductivity μS/cm 870 1100 2920 2430 1080 970 1070 1030 1020 950 950 970 940 940 1000 960 810 920 850 5970 Chloride mg/L 27 38 178 93b 31 21 15 12b 13 21 23 16 14b 10 26 23 24 15b 24 - Sulfate mg/L 28 120 1400 745b 89 52 106 109b 92 82 86 15 9b 23 130 100 48 58b 62 1000 Fluoride mg/L 1.1 1.0 0.5 0.8 1.1 1.1 1.2 1.3 1.3 1.6 1.7 1.4 1.6 1.8 0.3 0.3 0.4 0.3 0.2 2 Hydroxide Alkalinity (CaCO3) mg/L <5 <5 <1 <1 <1 <5 <1 <1 <1 <5 <5 <1 <1 <1 <5 <5 <1 <1 <1 - Carbonate Alkalinity (CaCO3) mg/L <5 <5 <1 <1 <1 <5 4 <1 <1 <5 <5 8 <1 <1 <5 <5 <1 <1 <1 - Bicarbonate Alkalinity (CaCO3) mg/L 420 450 262 369 439 480 508 373 473 420 440 541 484 513 360 400 331 537 508 - Total Alkalinity (CaCO3) mg/L 420 450 262 369 439 480 513 373 473 420 440 549 484 513 360 400 331 537 508 - Calcium mg/L 84 100 324 191 100 67 74 73 76 44 44 66 70 80 55 54 37 53 59 1000 Magnesium mg/L 46 57 167 106 60 69 86 73 80 58 60 57 52 60 52 52 24 48 55 - Sodium mg/L 45 54 263 158 60 43 61 54 58 65 65 77 65 76 70 67 96 77 83 - Potassium mg/L 4 4 8 4 3 6 6 5 6 7 7 6 4 5 5 5 5 3 3 - Hardness (CaCO3) mg/L 400 490 1500 913 519 450 539 483 519 350 370 400 389 447 350 360 191 330 374 - Sodium Adsorption Ratio - 0.98 1.07 2.96 2.27 1.17 0.88 1.14 1.07 1.11 1.51 1.50 1.68 1.43 1.56 1.62 1.56 3.02 1.84 1.87 - Total Phosphorus (as P) mg/L 0.07 0.06 0.06 0.09 0.06 0.03 0.06 0.07 0.05 0.05 0.03 0.23 0.21 0.14 <0.02 <0.02 0.08 0.03 0.02 - Reactive Phosphorus (as P) mg/L - - 0.01 0.07 0.04 - 0.04 0.05 0.03 - - 0.02 0.01 <0.01 - - 0.07 <0.01 <0.01 - Nitrite (as N) mg/L 0.019 <0.005 <0.01 <0.01 <0.01 <0.005 <0.01 <0.01 <0.01 <0.005 <0.005 <0.01 <0.01 <0.01 0.047 0.18 <0.01 0.06 <0.01 9.12 Nitrate (as N) mg/L 0.29 <0.005 <0.01 0.47 0.76 0.079 0.01 0.03 0.03 <0.005 0.075 <0.01 <0.01 <0.01 0.87 0.055 0.29 1.01 <0.01 90.29 Total Oxidised Nitrogen (as N) mg/L 0.31 <0.005 <0.01 0.47 0.76 0.079 0.01 0.03 0.03 <0.005 0.075 <0.01 <0.01 <0.01 0.92 0.24 0.29 1.07 <0.01 - Total Kjeldahl Nitrogen (as N) mg/L 0.61 0.19 0.2 0.3 <0.1 0.18 <0.1 <0.1 <0.1 0.17 0.11 <0.1 0.1 <0.1 0.16 0.07 <0.1 0.1 <0.1 - Ammonia (as N) mg/L 0.041 0.071 0.33 0.18 <0.01 <0.005 0.02 <0.01 <0.01 <0.005 0.015 0.12 0.09 0.04 <0.005 0.006 0.12 0.10 <0.01 - Total Nitrogen mg/L 0.91 0.19 0.2 0.8 0.8 0.26 <0.1 <0.1 <0.1 0.17 0.19 <0.1 0.1 <0.01 1.1 0.3 0.3 1.2 <0.01 - Aluminium - filtered µg/L 6 10 <10 <10 <10 11 10 10 <10 8 <5 <10 <10 <10 <5 27 <10 <10 <10 - Aluminium - total µg/L 1,800 36 20 <10 <10 69 <10 <10 <10 7 42 50 <10 <10 520 80 12 <10 <10 5,000 Antimony - filtered µg/L <3 <3 <1 <1 <1 <3 <1 <1 <1 <3 <3 <1 <1 <1 <3 <3 <1 <1 <1 - Antimony - total µg/L <3 <3 <1 <1 <1 <3 <1 <1 <1 <3 <3 <1 <1 <1 <3 <3 <1 <1 <1 - Arsenic - filtered µg/L 14 6 6 5 7 29 113 95 94 17 14 11 15 8 4 <3 8 4 2 - Arsenic - total µg/L 13 8 6 5 7 33 111 99 93 16 15 13 15 8 4 <3 10 5 1 500 Cadmium - filtered µg/L <0.1 0.1 <0.1 <0.1 <0.1 0.2 <0.1 <0.1 <0.1 <0.1 0.2 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 - Cadmium - total µg/L <0.1 0.1 <0.1 <0.1 <0.1 0.2 <0.1 <0.1 <0.1 <0.1 0.2 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 10 Chromium - filtered µg/L <1.0 <1.0 <1 <1 <1 <1.0 <1 <1 <1 1.2 <1.0 <1 <1 <1 <1.0 <1.0 <1 <1 <1 - Chromium - total µg/L 2.0 <1.0 <1 <1 <1 <1.0 <1 <1 <1 2.0 2.0 <1 <1 <1 <1.0 <1.0 <1 <1 <1 1,000 Cobalt - filtered µg/L <1 <1 6 2 2 1 <1 <1 <1 <1 <1 <1 <1 <1 3 3 <1 2 2 - Cobalt - total µg/L 2 <1 6 2 1 2 <1 <1 <1 <1 <1 <1 <1 <1 3 3 <1 2 2 1,000 Copper - filtered µg/L 1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 - Copper - total µg/L 31 <1 2 <1 <1 <1 1 <1 <1 <1 <1 <1 <1 <1 1 <1 <1 <1 <1 1,000 Lead - filtered µg/L 1 1 <1 <1 <1 2 <1 <1 <1 1 1 <1 <1 <1 <1 1 <1 <1 <1 - Lead - total µg/L 3 2 <1 <1 <1 2 <1 <1 <1 2 2 <1 <1 <1 3 2 <1 <1 <1 100 Mercury - filtered µg/L <0.05 <0.05 <0.04 <0.04 <0.04 <0.05 <0.04 <0.04 <0.04 <0.05 <0.05 <0.04 <0.04 <0.04 <0.05 <0.05 <0.04 <0.04 <0.04 - Mercury - total µg/L <0.05 <0.05 <0.04 <0.04 <0.04 <0.05 <0.04 <0.04 <0.04 <0.05 <0.05 <0.04 <0.04 <0.04 <0.05 <0.05 <0.04 <0.04 <0.04 2 Molybdenum - filtered µg/L 4 10 12 12 15 20 19 16 18 4 5 2 2 2 2 2 1 2 2 - Molybdenum - total µg/L 5 10 13 15 13 19 20 22 20 4 7 2 1 1 1 2 2 2 2 150 Nickel - filtered µg/L <1 <1 2 <1 <1 1 <1 <1 <1 3 2 <1 <1 <1 4 3 2 2 2 - Nickel - total µg/L 5 <1 3 <1 <1 1 <1 <1 <1 3 3 1 <1 <1 5 3 2 <1 2 1,000


vi Figures and Tables NRA Environmental Consultants 31 January 2018

Analyte Unit Groundwater Quality Monitoring Bores

Livestock drinking water quality guideline value1 GWMB01 GWMB02 GWMB03 GWMB04

12/7/16 17/8/16 10/5/17 16/8/17 14/11/17 16/8/16 10/5/17 16/8/17 14/11/17 12/7/16 16/8/16 10/5/17 16/8/17 14/11/17 12/7/16 16/8/16 10/5/17 16/8/17 14/11/17 Selenium - filtered µg/L <1 <1 <0.2 0.9 1.6 <1 <0.2 <0.2 <0.2 <1 <1 <0.2 <0.2 <0.2 <1 <1 <0.2 <0.2 <0.2 - Selenium - total µg/L <1 <1 <0.2 0.8 1.1 <1 <0.2 <0.2 <0.2 <1 <1 <0.2 <0.2 <0.2 <1 <1 <0.2 <0.2 <0.2 20 Strontium - filtered µg/L - - 992 392 226 - 60 53 50 - - 248 222 214 - - 161 238 266 - Strontium - total µg/L - - 937 424 242 - 64 57 55 - - 244 215 210 - - 142 249 271 - Tellurium - filtered µg/L <1 <1 <5 <5 <5 <1 <5 <5 <5 <1 <1 <5 <5 <5 <1 <1 <5 <5 <5 - Tellurium - total µg/L <1 <1 <5 <5 <5 <1 <5 <5 <5 <1 <1 <5 <5 <5 <1 <1 <5 <5 <5 - Zinc - filtered µg/L 9 <5 <5 <5 <5 <5 <5 7 <5 7 <5 <5 <5 <5 10 33 14 6 12 - Zinc - total µg/L 66 60 <5 <5 <5 12 <5 <5 <5 8 6 <5 <5 <5 17 38 9 <5 8 20,000

Values bold and underlined indicate exceedance of the default guideline value. 1 Guideline values for the protection of livestock drinking water (for beef cattle) were derived from ANZECC/ARMCANZ (2000) section 4.3. a The pH range (6.0 – 8.5) has been selected to limit corrosion and fouling of pumping and stock watering systems, noting that the quality of water for soil and animal health will not generally be affected by water with pH in the range of 4 – 9 (section 4.2.10.1 of ANZECC/ARMCANZ

(2000)). b Duplicate chloride and sulfate samples on 16/8/2017 returned results outside of normal quality control limits. The data interpretation herein is cognisant of the limitations created by this anomaly.

Table 2: Proposed receiving water monitoring sites

Site name Co-ordinate (GDA94, zone 54K) Rationale Easting Northing SW4 417668 7830393 On the central watercourse, downstream of the open pit, low-grade ore stockpile, processing plant, and clean water diversions around the pit.

SW5 416310 7829964 On the central watercourse, approximately 1.8 km downstream of site SW4, and the next location with pooled water. The site is also located to the north-north-west of the proposed IWTL, and would be useful as a point to detect seepage from the IWTL or MWD, in the event it occurred.

SW7 417012 7828819 On a tributary of the southern watercourse, approximately 650 m downstream of the RWD. The site is located to the south of the IWTL, and may detect seepage from this structure, if it occurred.

SW8 416268 7829452 On a tributary of the southern watercourse, immediately downstream of the MWD embankment and emergency spillway (ie receives water from RP1). SW9 415623 7829359 On the southern watercourse, approximately 700 m downstream of site SW8. Receives water from RP1 and RP2.

SW10 416328 7828979 On the southern watercourse to the south-west of the IWTL and MWD. Receives water from RP2 on the RWD, and potential seepage from the IWTL or MWD, if it occurred. This site is expected to hold water longer than site SW7 (pers. obs. Iain Goodrick, Environmental Scientist, NRA, February 2017).

IWTL – Integrated Waste-Tailings Landform. MWD – Mine Water Dam. RWD – Raw Water Dam. RP1, RP2 – release point on the MWD and RWD, respectively.

Table 3: Mount Dromedary baseline surface water quality data

Analyte Unit

Monitoring sites Default guideline values for Environmental Values SW1 SW2 SW3 SW4 SW5 SW6 SW8

Aquatic Ecosystem1 Livestock

drinking water2

Recreation - primary, secondary and visual

appreciation3

Drinking water – human

consumption4 2 Feb 2016

13 Jan 2017

2 Feb 2016

12 Jan 2017

2 Feb 2016

13 Jan 2017

15 Feb 2017

2 Feb 2016

12 Jan 2017

2 Feb 2016

12 Jan 2017

2 Feb 2016

13 Jan 2017

22-Feb 2017

pH pH Units 6.9 7.4 6.1 7.3 7.1 7.6 8.3 7.4 7.6 7.8 7.9 9.3 8.1 8.0 6.0-8.0 4.0 – 9.0a 6.5 – 8.5 6.5-8.5 Electrical Conductivity μS/cm 107 49 68 40 300 86 403 153 80 101 70 262 186 124 500b 5970 - - Temperature °C 31 - 32 - 32 - - 31 - 32 - 38 - - - - - Turbidityg NTU 152 - 109 - 32 - 25 53 - 117 - 74 - 2600 15 - 50 5 Chloride mg/L 1 <1 1 <1 7 2 31 2 1 2 1 26 13 11 - - - - Sulfate mg/L <5 <1 <5 <1 <5 <1 <1 <5 <1 <5 <1 <5 <1 <1 - 1000 2500 250 Fluoride mg/L <0.1 <0.1 <0.1 <0.1 0.1 <0.1 0.2 <0.1 <0.1 <0.1 <0.1 0.2 0.1 <0.1 2.4e 2 15 1.5 Hydroxide Alk. (CaCO3) mg/L <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 - - - - Carbonate Alk. (CaCO3) mg/L <1 <1 <1 <1 <1 <1 3 <1 <1 <1 <1 21 <1 <1 - - - -


NRA Environmental Consultants Figures and Tables vii 31 January 2018

Analyte Unit

Monitoring sites Default guideline values for Environmental Values SW1 SW2 SW3 SW4 SW5 SW6 SW8

Aquatic Ecosystem1 Livestock

drinking water2

Recreation - primary, secondary and visual

appreciation3

Drinking water – human

consumption4 2 Feb 2016

13 Jan 2017

2 Feb 2016

12 Jan 2017

2 Feb 2016

13 Jan 2017

15 Feb 2017

2 Feb 2016

12 Jan 2017

2 Feb 2016

12 Jan 2017

2 Feb 2016

13 Jan 2017

22-Feb 2017

Bicarbonate Alk. (CaCO3) mg/L 52g 26 32g 24 53g 41 161 74g 42 48g 38 54g 76 48 - - - - Total Alkalinity (CaCO3) mg/L 52g 26 32g 24 53g 41 164 74g 42 48g 38 75g 76 48 - - - - Calcium mg/L 6h 7 8h 5 22h 10 26 11h 10 12h 10 13h 14 <1 - 1000 - - Magnesium mg/L <1 <1 1 <1 3 1 4 <1 1 1 1 1 1 <1 - - - - Sodium mg/L <1 1 <1 <1 15 4 56 1 2 2 1 36 21 25 - - - - Potassium mg/L 2 2 3 2 4 2 7 2 3 4 2 3 2 <1 - - - - Hardness (CaCO3) mg/L 15h 17 24h 12 67h 29 81 27h 29 34h 29 36 h 39 <1 - - 2000 200 Total Phosphorus (P) mg/L 0.136 0.128 0.079 0.049 0.056 0.117 0.076 0.302 0.176 0.126 0.188 0.062 0.065 0.414 0.01 - - - Filt. React. Phosphorus (P) mg/L 0.017g 0.029 0.002g 0.005 <0.001g 0.014 0.003 0.174g 0.089 0.009g 0.021 0.002g 0.002 0.161 0.004 - - - Nitrite (as N) mg/L 0.010 0.004 0.004 <0.002 0.005 <0.002 0.009 0.008 <0.002 0.005 <0.002 0.010 <0.002 0.004 - 9.12 9.12 0.912 Nitrate (as N) mg/L 0.021 0.022 0.006 <0.002 <0.002 <0.002 0.009 0.003 <0.002 <0.002 <0.002 0.003 <0.002 0.006 7.2c 90.29 112.9 11.29 Tot. Oxidised Nitrogen (N) mg/L 0.031 0.026 0.010 <0.002 0.005 <0.002 0.018 0.011 <0.002 0.005 <0.002 0.013 <0.002 0.01 0.01 - - - Tot. Kjeldahl Nitrogen (N)g mg/L 0.41 0.28 0.42 0.24 0.54 0.26 2.17 0.90 0.4 0.48 0.48 0.49 0.43 0.45 - - - - Ammonia (as N) mg/L 0.096 0.016 0.028 0.021 0.018 0.013 0.544 0.021 0.01 0.032 0.012 0.027 <0.005 0.044 0.9 - 5 0.5 Total Nitrogen mg/L 0.44g 0.31 0.44g 0.24 0.55g 0.26 2.19 0.91g 0.40 0.48g 0.48 0.50g 0.43 0.46 0.3 - - - Antimony - filtered µg/L <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 9d - - - Antimony - total µg/L <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 - - 30 3 Arsenic - filtered µg/L <1 <1 <1 <1 <1 <1 <1 1 1 <1 <1 1 <1 <1 13 - - - Arsenic - total µg/L 1 <1 <1 <1 <1 1 1 2 2 <1 <1 1 <1 2 - 500 100 10 Cadmium - filtered µg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.2 - - - Cadmium - total µg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 - 10 20 2 Chromium - filtered µg/L <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 1 - - - Chromium - total µg/L 5 <1 2 2 <1 6 <1 2 2 2 4 2 2 35 - 1,000 500 50 Cobalt - filtered µg/L <1 2 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 4.3f - - - Cobalt - total µg/L 4 <1 2 4 2 5 1 2 1 2 2 2 2 29 - 1,000 - - Copper - filtered µg/L 2 5 4 2 2 2 3 4 2 3 2 7 3 4 1.4 - - - Copper - total µg/L 10 3 7 8 3 12 5 10 5 6 9 12 6 73 - 1,000 20,000 2,000 Lead - filtered µg/L 2 1 <1 <1 2 1 <1 1 <1 <1 <1 <1 <1 <1 3.4 - - - Lead - total µg/L 7 <1 1 1 3 2 <1 2 <1 <1 <1 10 <1 5 - 100 100 10 Mercury - filtered µg/L <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 0.06 - - - Mercury - total µg/L <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 <0.04 - 2 10 1 Molybdenum - filtered µg/L <1 <1 <1 <1 2 <1 4 <1 <1 <1 <1 3 1 <1 34d - - - Molybdenum - total µg/L <1 <1 <1 <1 2 <1 5 <1 <1 <1 <1 <1 <1 <1 - 150 500 50 Nickel - filtered µg/L <1 1 2 <1 2 <1 2 2 <1 1 <1 1 <1 <1 11 - - - Nickel - total µg/L 4 <1 4 4 3 7 3 2 2 2 3 3 2 28 - 1,000 200 20 Selenium - filtered µg/L <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 0.2 <0.2 <0.2 <0.2 <0.2 0.2 <0.2 0.3 5 - - - Selenium - total µg/L <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 0.2 <0.2 0.3 - 20 100 10 Tellurium - filtered µg/L <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 - - - - Tellurium - total µg/L <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 - - - - Zinc - filtered µg/L <5 <5 5 <5 <5 <5 <5 <5 8 <5 <5 <5 <5 <5 8 - - - Zinc - total µg/L 8 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 <5 35 - 20,000 30,000 3,000

Values bold and underlined indicate exceedance of at least one of the default guideline values. 1 Guideline values for the protection of slightly-to-moderately disturbed freshwater aquatic ecosystems were derived from ANZECC/ARMCANZ (2000) Table 3.3.4 - Default trigger values for physical and chemical stressors for tropical Australia for slightly disturbed ecosystems

(lowland river), Table 3.3.5 – Ranges of default values for conductivity (EC, salinity), turbidity and suspended particulate matter (SPM) indicative of slightly disturbed ecosystems in tropical Australia, and Table 3.4.1 – Trigger values for toxicants at alternative levels of protection (using the shaded values for slightly-moderately disturbed systems). Where alternative guideline values have been used, these have been footnoted.

2 Guideline values for the protection of livestock drinking water (for beef cattle) were derived from ANZECC/ARMCANZ (2000) section 4.3.


viii Figures and Tables NRA Environmental Consultants 31 January 2018

3 Guideline values for the protection of water for secondary recreational use were derived from NHMRC 2008. For chemical hazards, the values were 10 times the concentrations stipulated in the Australian Drinking Water Guidelines (NHMRC & NRMMC 2011). 4 Guideline values for the protection of drinking water for human consumption were derived from NHMRC and NRMMC (2011). It is noted that the water quality guidelines in NHRMC and NRMMC (2011) apply to point of use (ie after appropriate treatment if required), and not

mandatory standards. a Section 4.2.10.1 Guideline value derived from ANZECC/ARMCANZ (2000) Section 4.2.10.1 "Soil and animal health will not generally be affected by water with a pH in the range 4-9". b Queensland Water Quality Guidelines (EHP 2013) Table G.1, 75th percentile for the Gulf zone. c Nitrate guideline value has been amended (Hickey 2002). d Low reliability guideline value from section 8.3.7.1 of ANZECC/ARMCANZ (2000). e Revised default guideline value for fluoride (draft) for aquatic ecosystems (ANZGFMWQ 2017). This guideline value is under review and has not been formally adopted. NRA has permission to use this guideline value (pers. comm. Chris Hepplewhite, Assistant Director, National

Water Policy Section, Australian Government Department of Agriculture and Water Resources, 19 June 2017). The final guideline value is subject to change following review. f Revised default guideline value for cobalt (draft) for slightly-to-moderately disturbed aquatic ecosystems (Hogan et al. 2016). This revised guideline value has been developed by NRA and reviewed by Graeme Batley. The final guideline value is subject to change following review. g Results obtained for field duplicates of bicarbonate (and associated total alkalinity), reactive phosphorus, total Kjeldahl nitrogen (and associated total nitrogen) in February 2016 were outside of quality control limits. This is reflective of the very shallow nature of the site at the time of

sampling and the inherent difficulty in physical collection of representative duplicate samples. The discussion herein is cognisant of the limitations placed on the interpretation of this data. h Results obtained for field duplicates of calcium (and associated total hardness) in February 2016 were outside of quality control limits. This is reflective of the very shallow nature of the site at the time of sampling and the inherent difficulty in physical collection of representative

duplicate samples. The discussion herein is cognisant of the limitations placed on the interpretation of this data. It is noted that none of the metals species assessed during this period were present in concentrations that require hardness correction.


NRA Environmental Consultants Figures and Tables ix 31 January 2018

Table 4: Mount Dromedary baseline metal and metalloid stream sediment quality data

Analyte Unit Specification

Monitoring sites Sediment Quality Guideline Value SW1 SW1 SW2 SW2 SW3 SW3 SW4 SW4 SW5 SW5 SW6 SW6 SW7 SW8 SW9 Sed1 Sed 1

2 Feb 2016

15 Feb 2017

2 Feb 2016

15 Feb 2017

2 Feb 2016

15 Feb 2017

2 Feb 2016

15 Feb 2017

2 Feb 2016

15 Feb 2017

2 Feb 2016

15 Feb 2017

15 Feb 2017

15 Feb 2017

15 Feb 2017

3 Feb 2016

15 Feb 2017 Aquatic Ecosystems1

Antimony mg/kg <2 mm (TRM) 0.2 0.1 0.2 <0.1 0.2 0.2 0.2 <0.1 <0.1 <0.1 0.2 0.1 <0.1 <0.1 <0.1 <0.1 <0.1 2 <2 mm (DAE) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 2 <63 µm (TRM) 0.1 0.2 <0.1 0.1 0.2 0.2 0.1 0.1 <0.1 0.1 0.1 0.2 0.1 <0.1 <0.1 <0.1 0.1 -

Arsenic mg/kg <2 mm (TRM) 6.5 7.6 12.4 4.0 14.0 9.8 17.0 8.5 9.1 12.4 2.7 2.4 3.5 1.2 1.5 7.1 18.1 20 <2 mm (DAE) 0.35 0.72 0.20 0.38 0.29 0.62 2.15 1.56 0.69 0.60 0.35 0.46 0.31 0.17 0.24 1.38 1.57 20 <63 µm (TRM) 7.0 8.6 7.3 - 8.5 9.2 13.7 9.6 7.2 8.2 5.5 - 4.9 1.7 3.0 12.5 - -

Cadmium mg/kg <2 mm (TRM) <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.1 1.5 <2 mm (DAE) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 0.06 1.5 <63 µm (TRM) <0.1 0.2 <0.1 <0.1 0.2 0.2 0.1 <0.1 <0.1 <0.1 0.1 0.1 0.1 1.0 <0.1 0.1 0.2 -

Chromium mg/kg <2 mm (TRM) 30.4 28.6 25.5 19.5 25.6 26.3 25.2 19.1 20.2 12.0 31.2 17.2 23.5 104 14.3 13.5 52.2 80 <2 mm (DAE) 0.63 1.28 0.44 1.25 0.60 1.33 1.15 0.59 0.50 0.46 0.58 0.93 0.60 76.9 0.56 0.52 37.8 80 <63 µm (TRM) 48.7 49.4 42.0 39.5 52.6 43.6 49.2 47.7 41.3 48.4 40.8 43.0 44.9 33.7 37.0 21.0 21.1 -

Cobalt mg/kg <2 mm (TRM) 19.6 22.5 13.6 10.6 16.7 29.3 14.9 18.3 15.4 14.6 19.6 24.5 21.0 12.2 12.0 11.5 14.7 - <2 mm (DAE) 3.32 4.49 2.21 3.97 3.57 5.88 5.73 4.08 3.05 2.62 4.90 3.78 2.88 5.31 2.98 6.66 7.08 - <63 µm (TRM) 25.2 24.8 28.1 28.8 33.2 26.8 25.9 21.4 19.6 27.5 27.2 22.9 29.1 24.2 24.2 20.1 19.6 -

Copper mg/kg <2 mm (TRM) 36.5 32 33.0 24.3 42.3 47.0 64.6 53.7 54.1 43.4 29.7 34.7 64.2 20.4 26.1 40.6 49.0 65 <2 mm (DAE) 4.39 4.98 3.02 3.62 2.72 5.33 13.00 10.4 5.98 5.83 3.00 3.11 8.15 4.15 5.34 8.87 7.93 65 <63 µm (TRM) 78.8 94.3 80.0 87.4 111.0 113 116.0 105 109.0 116 88.8 128 181 79.8 82.2 88.3 132 -

Lead mg/kg <2 mm (TRM) 15.4 16.4 7.0 5.0 6.1 6.6 16.6 12.9 5.2 7.8 4.0 2.8 3.2 1.8 3.0 12.8 15.8 50 <2 mm (DAE) 6.35 7.29 1.25 1.96 1.83 2.18 4.97 4.68 2.15 1.88 1.39 1.18 0.75 0.66 1.04 7.60 5.02 50 <63 µm (TRM) 25.4 31.4 11.8 12.2 15.1 13.7 17.8 15.0 13.4 14.3 11.3 12.6 9.5 6.3 8.3 30.6 31.9 -

Mercury mg/kg <2 mm (TRM) <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.15 <2 mm (DAE) <0.10 <0.01 <0.10 <0.01 <0.10 <0.01 <0.10 <0.01 <0.10 <0.01 <0.10 <0.01 <0.01 <0.01 <0.01 <0.10 <0.10 0.15 <63 µm (TRM) <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.2 <0.1 <0.1 <0.1 -

Molybdenum mg/kg <2 mm (TRM) 0.8 0.9 2.5 1.2 2.2 2.3 1.8 1.2 1.3 0.9 0.3 0.4 0.3 0.4 0.2 1.8 3.4 - <2 mm (DAE) <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.09 <0.05 <0.05 0.1 - <63 µm (TRM) 0.6 0.9 1.3 1.5 1.5 1.8 1.7 1.8 1.1 1.1 1.0 1.3 0.7 0.3 0.5 2.5 3.8 -

Nickel mg/kg <2 mm (TRM) 21.9 20.2 23.9 17.3 22.0 38.4 26.3 25.0 33.7 23.9 21.0 15.9 25.4 12.4 13.5 26.0 31.6 21 <2 mm (DAE) 1.39 2.05 1.22 1.75 1.81 2.89 2.60 1.85 1.61 1.43 2.01 1.49 0.92 2.64 1.73 4.09 4.62 21 <63 µm (TRM) 30.3 33.1 41.8 38.7 44.9 39.9 39.2 40.7 34.8 41.4 34.6 35.3 36.4 23.0 30.4 43.1 42.2 -

Selenium mg/kg <2 mm (total) <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 - <2 mm (DAE) <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 - <63 µm (total) <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 -

Tellurium mg/kg <2 mm (TRM) <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 - <2 mm (DAE) <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 - <63 µm (TRM) <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 -

Zinc mg/kg <2 mm (TRM) 24.4 20.6 12.7 17.1 22.5 30.3 45.7 19.6 13.5 11.3 8.8 10.5 12.8 7.5 9.5 19.2 21.9 200 <2 mm (DAE) 1.87 1.48 1.27 1.97 1.66 2.78 4.15 2.38 2.06 1.28 1.10 1.56 1.16 2.37 1.39 1.92 3.01 200 <63 µm (TRM) 52.8 69.2 39.1 43.9 57.4 59.2 50.2 35.9 35.5 40.9 34.7 73.0 55.2 29.0 32.2 40.6 73.3 -

Values bold and underlined indicate exceedance of the default sediment quality guideline value. TRM – Total Recoverable Metals; DAE – Dilute Acid Extractable. 1 Guideline values for sediment for the protection of aquatic ecosystem were derived from Simpson et al. (2013). No guideline values applicable to <63 µm sediment fraction.


x Figures and Tables NRA Environmental Consultants 31 January 2018

Table 5: Receiving surface water trigger values and contaminant limits for consideration in the EA

Analyte Unit Trigger Value1 Contaminant Limit1 pH pH unit 6.0-8.0a 4-9b Electrical conductivity µS/cm 500a 5,970b Turbidity NTU 80th percentile of

background^ N/A

Sulfate mg/L 80th percentile of background

1,000b

Fluoride mg/L 2b 2.4c Nitrate mg/L (as N) 7.2a 90b Arsenic µg/L 13a,d 500b,e Cadmium µg/L 0.2a,d 10b,e Cobalt µg/L 4.3c,d, or 80th percentile of

background, whichever is higher#

1,000b,e

Copper µg/L 80th percentile of background^

1,000b,e

Lead µg/L 3.4a,d, or 80th percentile of background, whichever is

higher#

100b,e

Molybdenum µg/L 34a,d 150b,e Nickel µg/L 11a,d 1,000b,e Selenium µg/L 5a,d 20b,e Zinc µg/L 8a,d 20,000b,e Total petroleum hydrocarbons (TPH)

mg/L Film/odour by observation N/A

1 Trigger values and contaminant limits may be revised (subject to discussion with the administering authority and the EA holder) once sufficient data has been collected to derive site-specific guideline values.

a Default guideline value for the protection of slightly-to-moderately disturbed aquatic ecosystems (EHP 2013, ANZECC/ARMCANZ 2000).

b Default guideline value for the protection of livestock (beef cattle) drinking water (ANZECC/ARMCANZ 2000).

c Revised default guideline value for slightly-to-moderately disturbed aquatic ecosystems for fluoride (draft) (ANZGFMWQ 2017) and cobalt (Hogan et al. 2016).

d Concentration applies to filtered sample. e Concentration applies to unfiltered sample. ^ Baseline water quality data shows that site conditions consistently exceeded the published guideline value;

therefore, only a site-specific guideline value is appropriate. # Baseline water quality data shows that on at least one occasion, the concentration on-site was greater than

the published guideline value, and/or the level of detection is very close to the guideline value; therefore, consideration of site-specific guideline values is required.


NRA Environmental Consultants Figures and Tables xi 31 January 2018

Table 6: Stream sediment trigger values and contaminant limits for consideration in the EA

Analyte Unit Trigger Value1 Contaminant Limit2 Arsenic mg/kg 20, or 2 x background3,

whichever is higher. 70, or 3 x background3,

whichever is higher. Cadmium mg/kg 1.5, or 2 x background3,


whichever is higher. Cobalt mg/kg 2 x background3. 3 x background3. Copper mg/kg 65, or 2 x background3,


whichever is higher. Lead mg/kg 50, or 2 x background3,


whichever is higher. Molybdenum mg/kg 2 x background3. 3 x background3. Nickel mg/kg 21, or 2 x background3,


whichever is higher. Selenium mg/kg 2 x background3. 3 x background3. Zinc mg/kg 200, or 2 x background3,


whichever is higher. Total petroleum hydrocarbons (TPH)

mg/kg Observation by film/odour -

1 Trigger value derived from Simpson et al. (2013) (Table 2 – guideline value, and section 2.3.4) and follows the decision tree framework in Figure 1 of Simpson et al. (2013). Where the TRM (<2 mm fraction) concentration exceeds the trigger value, the DAE (<2 mm fraction) concentration should be compared to the trigger value. An exceedance of the trigger value only occurs if both the TRM and the DAE concentrations are greater than the trigger value.

2 Contaminant limit derived from Simpson et al. (2013) (Table 2 – SQG-High, and section 2.3.4) and follows the decision tree framework in Figure 1 of Simpson et al. (2013). Where the TRM (<2 mm fraction) concentration exceeds the contaminant limit, the DAE (<2 mm fraction) concentration should be compared to the contaminant limit. An exceedance of the trigger value only occurs if both the TRM and the DAE concentrations are greater than the contaminant limit.

3 The background value is the median value of background (reference) concentrations, as per Simpson et al. (2013). Background concentrations may be sourced from unaffected receiving sites, eg sites located downstream of the mining operations with data collected prior to mine related disturbance in the catchment reporting to the site.


xii Figures and Tables NRA Environmental Consultants 31 January 2018

Table 7: Geochemical abundance index results for mine waste weathered zone (Regolith Profile) samples

Element GCA11790 GCA11791 GCA11807 GCA11815 GCA11811 GCA11798 GCA11817 GCA11810 GCA11795 GCA11792 GCA11799 GCA11793 GCA11797 Median Maximum Minimum

Ag 0 - 3 - - 1 - 0 - - 0 0 0 0 3 0 Al 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 As 1 - 4 - - 4 - 0 - - 1 4 2 2 4 0 B 2 - 3 - - 2 - 2 - - 2 2 2 2 3 2 Ba 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Bi 0 - 1 - - 3 - 0 - - 0 3 0 0 3 0 Ca 1 - 0 - - 0 - 1 - - 0 0 0 0 1 0 Cd 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Co 1 - 0 - - 0 - 0 - - 0 0 0 0 1 0 Cr 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Cu 1 4 4 3 3 0 3 0 2 2 1 0 1 2 4 0 Fe 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Hg 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 K 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0

Mg 1 - 0 - - 0 - 1 - - 0 0 0 0 1 0 Mn 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Mo 3 - 2 - - 0 - 0 - - 1 2 0 1 3 0 Na 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Ni 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 P 0 0 0 0 0 1 0 0 0 0 0 1 0 0 1 0

Pb 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Sb 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Se 1 - 3 - - 0 - 0 - - 1 0 2 1 3 0 Sr 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Th 0 - 1 - - 0 - 0 - - 0 0 1 0 1 0 Tl 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 U 1 - 1 - - 1 - 0 - - 2 2 2 1 2 0 V 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 Zn 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 F 1 - 0 - - 0 - 0 - - 0 1 0 0 1 0

Sn 0 - 0 - - 0 - 0 - - 0 0 0 0 0 0 A GAI of 3 or greater is considered significant, based on the median value.


NRA Environmental Consultants Figures and Tables xiii 31 January 2018

Table 8: Geochemical abundance index results for mine waste fresh zone (Bedrock Profile) samples

Element GCA11789 GCA11803 GCA11786 GCA11806 GCA11812 GCA11813 GCA11787 GCA11804 GCA11808 GCA11794 GCA11805 GCA11809 GCA11816 Median Maximum Minimum

Ag 3 - - - 0 0 - - - - 0 0 0 0 3 0 Al 0 - - - 0 0 - - - - 0 0 0 0 0 0 As 3 - - - 1 0 - - - - 2 2 2 2 3 0 B 2 - - - 2 2 - - - - 2 2 2 2 2 2 Ba 0 - - - 0 0 - - - - 0 0 0 0 0 0 Bi 1 - - - 0 0 - - - - 0 0 1 0 1 0 Ca 0 - - - 0 1 - - - - 2 2 2 1.5 2 0 Cd 0 - - - 0 0 - - - - 0 0 0 0 0 0 Co 4 - - - 0 0 - - - - 0 0 0 0 4 0 Cr 0 - - - 1 0 - - - - 0 0 0 0 1 0 Cu 5 3 3 3 0 1 2 4 3 3 0 0 0 3 5 0 Fe 2 - - - 0 0 - - - - 0 0 0 0 2 0 Hg 0 - - - 0 0 - - - - 0 0 0 0 0 0 K 0 - - - 0 0 - - - - 0 0 0 0 0 0

Mg 0 - - - 1 0 - - - - 2 2 2 1.5 2 0 Mn 0 - - - 0 0 - - - - 1 0 1 0 1 0 Mo 2 - - - 0 0 - - - - 0 1 0 0 2 0 Na 0 - - - 0 0 - - - - 0 0 0 0 0 0 Ni 0 - - - 1 0 - - - - 0 0 0 0 1 0 P 1 0 0 0 0 0 0 0 0 0 1 0 0 0 1 0

Pb 0 - - - 0 0 - - - - 0 0 0 0 0 0 Sb 1 - - - 0 0 - - - - 0 0 0 0 1 0 Se 5 - - - 0 1 - - - - 0 1 1 1 5 0 Sr 0 - - - 0 0 - - - - 0 0 0 0 0 0 Th 0 - - - 0 0 - - - - 0 0 0 0 0 0 Tl 0 - - - 0 0 - - - - 0 0 0 0 0 0 U 0 - - - 0 0 - - - - 0 0 0 0 0 0 V 0 - - - 0 0 - - - - 0 0 0 0 0 0 Zn 0 - - - 0 0 - - - - 0 0 0 0 0 0 F 1 - - - 0 0 - - - - 0 0 0 0 1 0

Sn 0 - - - 0 0 - - - - 0 0 0 0 0 0 A GAI of 3 or greater is considered significant, based on the median value.


xiv Figures and Tables NRA Environmental Consultants 31 January 2018

Table 9: Geochemical abundance index results for low-grade ore Samples

Element Low-grade Oxide Ore Low-grade Primary Ore

GCA11788 GCA11800 GCA11796 Median Maximum Minimum GCA11802 GCA11801 GCA11814 GCA11818 Median Maximum Minimum

Ag 0 2 1 1 2 0 0 0 2 1 1 2 0 Al 0 0 0 0 0 0 0 0 0 0 0 0 0 As 2 3 2 2 3 2 2 2 5 4 4 5 2 B 2 4 2 2 4 2 2 3 2 2 2 3 2 Ba 0 0 0 0 0 0 0 0 0 0 0 0 0 Bi 0 1 2 1 2 0 0 1 2 1 1 2 1 Ca 0 0 2 0 2 0 0 0 0 0 0 0 0 Cd 0 0 0 0 0 0 0 0 0 0 0 0 0 Co 0 0 0 0 0 0 0 0 0 0 0 0 0 Cr 0 0 0 0 0 0 0 0 0 0 0 0 0 Cu 0 2 0 0 2 0 0 0 0 1 0 1 0 Fe 0 1 0 0 1 0 0 0 0 0 0 0 0 Hg 0 0 0 0 0 0 0 0 0 0 0 0 0 K 0 0 0 0 0 0 0 0 0 0 0 0 0

Mg 0 0 0 0 0 0 0 0 0 0 0 0 0 Mn 0 0 0 0 0 0 0 0 0 0 0 0 0 Mo 2 2 0 2 2 0 2 2 4 4 4 4 2 Na 0 0 0 0 0 0 0 0 0 0 0 0 0 Ni 0 0 0 0 0 0 0 0 0 0 0 0 0 P 0 0 0 0 0 0 0 0 0 1 0 1 0

Pb 0 0 0 0 0 0 0 0 0 0 0 0 0 Sb 0 1 0 0 1 0 0 0 0 0 0 0 0 Se 2 3 0 2 3 0 4 4 3 2 3 4 2 Sr 0 0 0 0 0 0 0 0 0 0 0 0 0 Th 0 0 0 0 0 0 0 0 0 0 0 0 0 Tl 0 0 0 0 0 0 0 0 0 0 0 0 0 U 0 1 0 0 1 0 1 1 3 2 2 3 1 V 0 0 0 0 0 0 0 0 0 0 0 0 0 Zn 0 0 0 0 0 0 0 0 0 0 0 0 0 F 0 0 0 0 0 0 0 0 0 0 0 0 0

Sn 0 0 0 0 0 0 0 0 0 0 0 0 0 A GAI of 3 or greater is considered significant, based on the median value. Significant results are shown by shaded cells.


NRA Environmental Consultants Figures and Tables xv 31 January 2018

Table 10: Summary of PAF and NAF materials balance for waste rock and low-grade ore

Rock management unit

Tonnage (million tonnes) PAF NAF Total

Waste Rock Mica-schist, MS 4.5 2.1 6.6 Siltstone, ST 2.8 1.2 4.0 Dolerite, DOL 3.9 1.5 5.4 Dolomite, LSD 0.0 0.5 0.5 Low-grade Ore Mica-schist, MS 1.6 0.4 2.0 Siltstone, ST 0.4 0.1 0.5 TOTAL 13.2 5.8 19.0

Source: volumes from GCA (2018a)

Appendix A: Information Request

Appendix B: Mt Dromedary Underground Water

Impact Report and Dewatering Assessment

(RLA 2018)

(Included separately)

Appendix C: Mt Dromedary GDE Indicators

(NRA 2018a)


Appendix D: Concept Design Study for Mine Waste and Water Management

(ATCW 2018a)


Appendix E: Site Structural Geology

(Tedman-Jones 2017)


Appendix F: Geochemical Assessment of Mine

Waste and Low Grade Ore (GCA 2018a)


Appendix G: Geochemical Assessment of

Tailings Slurry Water (GCA 2018b)


Appendix H: Revised Significant Residual

Impact Assessment (NRA 2018b)


Appendix I: Consequence Category

Assessment (ATCW 2018b)


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