Cristal Mining Australia Ltd. Ginkgo and Snapper Bushfire Management Plan

Transcription

1 Cristal Mining Australia Ltd Ginkgo and Snapper Bushfire Management Plan

2 Abbreviations Rev No. Document No. Description Approval Details Date A Draft for Cristal Approval May 2013 B Draft for submission to Wentworth Shire Council and the Rural Fire Service October Final GHD to Cristal October Annual Review Cristal October 2015 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166 i

3 Abbreviations Abbreviation AEMR Cristal BFMP DA DECC DECCW DLWC DOP EIS EMS EPA Full Title Annual Environmental Management Report Cristal Mining Australia Ltd Bushfire Management Plan Development Application NSW Department of Environment and Climate Change (formerly DECCW) NSW Department of Environment, Climate Change and Water (now DECC as part of the OEH) Department of Land Water and Conservation NSW (now part of OEH) NSW Department of Planning and Infrastructure Environmental Impact Statement Cristal Murray Basin Environmental Management Strategy NSW Environment Protection Authority (part of the OEH) EP & A Act Environmental Planning and Assessment Act 1979 EPL ERP ESCA ETL GHD HAR HMC MOP MSP NOW NPWS NSW NSWRFS OEH WSC Environmental Protection Licence Emergency Response Plan Emergency Services Cooperation Agreement Electricity Transmission Lines GHD Pty Ltd Highway Access Road Heavy Mineral Concentrate Mining Operations Plan Mineral Separation Plant (Broken Hill) New South Wales Office of Water National Parks and Wildlife Service New South Wales New South Wales Rural Fire Service NSW Office of Environment and Heritage Wentworth Shire Council ii GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

4 Glossary Assets: anything valued by the community which includes houses, crops, heritage buildings and places, infrastructure, the environment, businesses, and forests, that may be at risk from bush fire. Bushfire: a general term used to describe fire in vegetation, includes grass fire. Bushfire danger zone: the area under immediate threat from an uncontrolled bushfire. Bushfire Hazard: the potential severity of a bush fire, which is determined by fuel load, fuel arrangement and topography under a given climatic condition. Bushfire Risk: the chance of a bush fire igniting, spreading and causing damage to the community or the assets they value. Fire Potential: is a general assessment referring to the flammability of the community and the likelihood for fire to spread through the community given suitable weather conditions. Likelihood: the chance of a bush fire igniting and spreading. Vulnerability: the susceptibility of an asset to the impacts of bush fire. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166 iii

5 Limitations This report: has been prepared by GHD Pty Ltd (GHD) for Cristal Mining Australia Ltd (Cristal) and may only be used and relied on by Cristal for the purpose agreed between GHD and Cristal as provided section 1.1 and 1.2 of this report. GHD otherwise disclaims responsibility to any person other than Cristal arising in connection with this report. GHD also excludes implied warranties and conditions, to the extent legally permissible. The services undertaken by GHD in connection with preparing this report were limited to those specifically detailed in the report and are subject to the scope limitations provided in the report. GHD s scope of works was limited to updating Cristal s environmental documentation into standardised templates that are consistent with ISO and addresses Cristal s most recent approval requirements. GHD has relied on information provided in existing plans, the specific requirements stated within licences, permits and approval conditions provided to GHD and advice provided by Cristal on the status of works and implementation of management measures for the pre-construction and construction phase works. GHD has updated documents based on advice from Cristal relating to their current operations and management practices. As Cristal s existing documentation has previously been approved by government agencies, GHD has not proposed new mitigation or management measures. Where GHD has identified deficiencies or anomalies in the existing plans, these have been updated based on additional information provided by Cristal. It is not within GHD s scope of works to undertake a detailed risk assessment for environmental aspects or to provide specialist advice on the suitability of mitigation measures or to devise new mitigation measures. The opinions, conclusions and any recommendations in this report are based on conditions encountered and information reviewed at the date of preparation of the report. GHD has no responsibility or obligation to update this report to account for events or changes occurring subsequent to the date that the report was prepared. GHD has prepared this report on the basis of information provided by Cristal which GHD has not independently verified or checked beyond the agreed scope of work. GHD does not accept liability in connection with such unverified information, including errors and omissions in the report which were caused by errors or omissions in that information. iv GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

6 Development consent(s) & project approval modification On 20 March 2015, the Secretary for the Minister for Planning issued Cristal with the following Notice of Modification(s) for Cristal s operations in the Murray Darling Basin: Ginkgo Mineral Sands Project (DA ), Modification 9. Snapper Mineral Sands Project (PA 06_0168), Modification 5. Mineral Separation Plant (DA ), Modification 3. In relation to these modifications, Cristal acknowledges the following: Minor changes will be required to the Environmental Management Strategy (EMS, ) and subordinate management plans to reflect the changes required to department names, acronyms and abbreviations. Specific changes will be required to individual documents to reflect changes to consent conditions which affect future operational management requirements. The Notice(s) of Modification are appended to the EMS and Environmental Management Plans affected by specific condition changes prescribed in the above modification notices. Cristal is committed to amending the EMS and affected management plans in general accordance with Section 6.1 of the EMS in such that minor changes (not affecting operations) will be completed within 3 years of the date of the issue of the above Modifications. Plans impacted by changes to specific conditions effecting operations will be updated within 3 months of the completion of internal audits of these plans (Feb 2016). GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166 v

7 Table of contents Limitations... iv Development consent(s) & project approval modification... v 1. Introduction Purpose of the management plan Scope of the management plan Document succession Project description Summary of potential impacts Environmental management framework Relationship to other Environmental Management Plans Legislative requirements and project environmental approvals Roles and responsibilities Training and inductions Complaint, non-conformance and incident management Environmental reporting and correspondence Audits of the BFMP Review and update of BFMP Environmental management program Objective Performance standards Fire preparedness Fuel management Monitoring Reporting References Table index Table 1 Assessed maximum fuel load for the classification of vegetation communities within ML 1504 and Table 2 Approval documents for Ginkgo and Snapper Table 3 Regulatory consent conditions applicable to this BFMP Table 4 Responsibility for bushfire management at Ginkgo and Snapper Table 5 Bushfire Preparedness Table 6 National Bushfire Warning System alert levels Table 7 Bushfire mitigation works schedule GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

8 Figure index Figure 1 Ginkgo and Snapper regional location and main features... 3 Figure 2 Cristal s environmental management framework... 8 Figure 3 Environmental management documents for Cristal s operations in the Murray Basin in NSW Figure 4 Location of fire fighting resources and ancillary infrastructure (regional) Figure 5 Location of fire fighting resources and ancillary infrastructure for Ginkgo Figure 6 Location of fire fighting resources and ancillary infrastructure for Snapper GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

9 1. Introduction 1.1 Purpose of the management plan This Bushfire Management Plan (BFMP) identifies strategies to mitigate the risks of bushfires starting at or impacting on Ginkgo mineral sands mine (Ginkgo) and Snapper mineral sands mine (Snapper) in south-west NSW. Cristal s mine sites in the Murray Darling Basin have collectively been referred to as the Murray Basin mines for the purpose of this document. 1.2 Scope of the management plan The BFMP provides an overview of the environmental management and performance requirements related to bushfire management of the Murray Basin mines. This BFMP includes: Strategies to mitigate the risk of bushfire at mine sites as stipulated by regulatory approvals for the project; Responsibilities for implementing this BFMP; Preparedness, detection, response and coordination objectives, to mitigate the potential for impacts on life and property, and meet regulatory approval requirements; and An overview of the fuel management plan including the monitoring and control of fuel loads. Further details on the Environmental Management Framework for Cristal s operations at this site are provided in Section Document succession This BFMP supersedes the following EMP (Environmental Management Plan): Ginkgo Mineral Sands Mine Bushfire Management Plan, Document No: MP011-GM, October The document listed above is now obsolete. The new BFMP (this document) incorporates specific requirements of the superseded plan, and amended to reflect the specific management measures applicable to the current operational stage of the project (see Section 2.1). Cristal will submit this updated plan to the Wentworth Shire Council (WSC) and the NSW Rural Fire Service (NSWRFS) (as required by Ginkgo Condition of Approval, Schedule 2, Condition 3.8(b), Table 3) for review following its review by the DOP. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

10 2. Project description Ginkgo and Snapper Ginkgo and Snapper (Mining Lease [ML] 1504 and 1621 respectively) are located approximately 85 km north of Mildura and 40 km west of the township of Pooncarie in western New South Wales (NSW). Ginkgo and Snapper are located within an area of pastoral leases and isolated homesteads. The greater mining leases (ML 1504 and 1621) cover an area of approximately 5,700 hectares. A site location map of Ginkgo and Snapper is provided in Figure 1. Cristal has two offset areas in the general region that cover an approximate area of 6,920 hectares (Ha). These offset areas are described in detail in the Offset Management Plan (Cristal, 2012). A brief summary of the existing (i.e. pre-mining) environment of the Ginkgo and Snapper project area and surrounds, along with further details of the sites environmental values are provided in the Ginkgo and Snapper Flora and Fauna Environmental Management Plan (GHD 2012). The project area includes the Ginkgo and Snapper mining lease areas, highway access road (HAR) and electricity transmission line (ETL) (Figure 2). The mining areas are comprised of the following components: Dredge and floating plant for heavy mineral mining and primary mineral separation; Heavy Mineral Concentration (HMC) facility; Administration, maintenance and accommodation camp buildings; Potable water pipeline and treatment and a sewage treatment plant; A borefield supplying make-up water to the dredge pond and floating plant; An overburden stripping program with truck and shovel operations; Initial sand residue and water supply dams; An initial overburden emplacements; Project roads; Overburden, soil and mineral concentration stockpiles; and Fuel and combustibles storage facilities. 2 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

11 "Popiltah" E E E E Popio Lake Popiltah Lake "Polia" "Moorara" "Heatherbloom" "Court Nareen" "Woodlands" N Hill Pine Lake "Greenvale" "Kinross" Travellers Lake Rotten Lake Binjie Lake Blue Lake "Ringwood" Access Road Extensions "Willow Point" "Mullingar" "Roo Roo" Nialia Lake Yelta Lake Ginkgo Mine "Menincourt" "Manilla" Pooncarie "Windamingle" Nearie Lake LEGEND Snapper Mine MLA Boundary "Nindethana" Dwelling Cadastral Boundary Ginkgo Mine Potable Water Pipeline Track Main Roads v Existing Electricity Transmission Line v N Proposed Electricity Transmission Line Lake Milkengay "Waukeroo" "Trelega" "Carstairs" "Kelleen" "Lethero" N Source: BEMAX, 2001; and Wentworth Shire Council, 2001 SNAPPER FLORA AND FAUNA MANAGEMENT PLAN "Twelve MMiil ee FIGURE 2 Snapper Mine Location Figure 1 Ginkgo and Snapper regional location and main features E E E 10 Kilometres BMX F&F_002A "Reedy Point" "Minda" The Salt Lakes Mineral Concentrate Transport Route Existing Highway Access Road N "Tarcoola" "Akuna" "Mallara" Nitchie Lake Warrawenia Lake 0 Snapper Mine "Wyndham" N "Lelma 000E 640 B

12 2.1.2 Climate and fuel factors The climate across the study area is arid, with hot dry summers and cold dry winters. Maximum summer temperatures often exceed forty degrees Celsius while winters regularly experience frosts. The mean maximum summer temperature is 33 degrees, with an approximate winter average maximum of 16 degrees. Annual mean rainfall for Wentworth is 287 mm (BoM 2012). Significant annual climatic variation is a feature of the landscape. The area has experienced prolonged drought conditions over most of the last ten years, followed by two years of sustained high rainfall in 2010 and 2011, resulting in increased growth of understory shrubs and grasses, elevating bushfire hazard. The offset area is considered to be the area that presents the highest bushfire risk due to the density of the vegetation and isolation of these areas, which means more time could pass before a fire is detected in these areas. Historically, climatic conditions associated with major bushfires in the arid and semi-arid zone occur when there is a return to dry conditions following seasons of heavy inland rainfall. Such conditions occur on an inter-decadal basis, and result in prolific regeneration of grass and shrub fuels, providing a continuous fuel cover across the landscape, conducive to large landscape level fires (see Section 2.1.2). Fuel includes perennial and ephemeral species of various grasses and herbs, but particularly the highly flammable speargrass (Austrostipa species) which dominates in the Mallee-sandplain, open Belah woodland and open grassland/herbland communities, after effective rainfall. Under normal climatic conditions rainfall is insufficient to promote grasses and shrub growth, with fuels patchy and isolated, and consisting of Mallee trees and litter, shrubs and spinifex. Fires that occur during these conditions are unlikely to grow to landscape level proportions, vary in size and intensity and are mainly restricted to the Mallee-spinifex community and to a lesser extent the Mallee-sandplain community (DEC 2006). Bushfires in the region generally occur between November and March. Prevailing weather conditions associated with the bushfire season in south western NSW are strong westerly to northerly winds in spring and summer, with high temperatures occurring throughout spring, summer and extending into autumn. High temperatures combined with thunderstorm activity through the bushfire season can initiate significant fire events. Cristal s Murray Basin mines are located in a landscape of low rolling sand plain, with very limited topographical relief, and characterised by vegetation of low-open woodlands and shrublands. The vegetation immediately surrounding the mine sites consists almost entirely of very open Belah woodland and chenopod shrubland. Mallee shrubland and woodland, and black box woodland also is present within the lease boundary. In summary, fire frequency is relatively low, and linked with drier seasons that immediately follow unseasonal wet years, that generally occur on an inter-decadal basis. In such seasons fuels are continuous with ephemeral fuels linking the usually isolated patches of perennial fuels, and able to support fast moving landscape scale fires. In normal years fires are generally restricted to patches of vegetation, with the higher fuel loads in Mallee communities of the vegetation types present supporting the fires of greatest intensity Fire history and ignition factors The arid nature of south-western NSW means the availability of fuel is a highly variable and significant factor influencing the frequency and severity of bushfires. There is a history of severe bushfires across the region in the following years: 1917/1918 (Lake Victoria), 1931(Tapio), 1950 (Kulkurna and Euston), 1956 (Manilla), 1969/1970 (Wilkurra), 1974/1975 (Gol Gol fire, Wentworth and Balranald Shires), 1984/1985 (Pooncarie fire, Wentworth Shire). All of these fires have been preceded by seasons of good rainfall, this is particularly evident in the 1974/1975 fires when prolific growth in the previous two seasons led to almost complete ground 4 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

13 coverage of spear grass and other understory fuels (NSW BFCC, 1997). Therefore, while high intensity fires may occur infrequently, it is likely during the life of the development, the mines will be impacted by a high intensity fire. Because the landscape surrounding the mine lease area is sparsely populated with limited fire suppression resources, any ignitions that occur are likely to have sufficient time to develop into large fires undetected, with long response times once detected. The main sources of bushfire ignition in south-western NSW include: Natural ignition, through lighting strikes during dry electrical storms, are the most common cause of bushfire ignition in western NSW Ignition by lightning strikes are more likely during late spring and early summer when electrical storm activity is at its peak; Roadside ignitions are a common cause of fire in the area. They are often caused by vehicle accidents or malfunctions such as blown tyres, seized bearings or electrical faults, and from discarded cigarette butts; Accidental ignitions or escaped burns from agricultural or mining activities; and Escapes from camp fires or accidental ignitions from tourist activities along the Darling River and Anabranch Consequence factors Values and assets at the Murray Basin mines that have the potential to be impacted by a bushfire may be broken into the following: Human life including staff, contractors, visitors and residents on and off site; Human settlement, including accommodation, administration, maintenance and camp buildings; Agricultural assets such as cropping/grazing land, saleyards; Other human infrastructure areas including mine areas; Infrastructure such as roads, power lines, gas pipelines, railway lines, electricity substations and communication facilities; Environmental values including populations of threatened species and ecological communities sensitive to fire; and Cultural values including areas of aboriginal significance, aboriginal places and items of significance. The main bushfire threats (fuel loads) and specific assets at risk are detailed below. Pasture areas Table 1 provides a summary of indicative maximum fuel loads for the classified vegetation communities within ML 1504 and 1621, as calculated in the guidelines for Planning for Bushfire Protection 2001 (NSW Rural Fire Service and Planning NSW 2001). GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

14 Table 1 Assessed maximum fuel load for the classification of vegetation communities within ML 1504 and 1621 Vegetation Classification Approximate % area within ML 1504 and 1621 Vegetation Group Blackbox Woodlands (Woodland) Belah Woodlands (Woodland) Belah-Bluebush Woodlands and Mallee-Belah Woodlands (Open Woodland) Chenopod Shrubland Mallee Shrubland Grassland Maximum Indicative Fuel Load (t/ha) Mine buildings and infrastructure All buildings are constructed in accordance with the Building Code of Australia and relevant Australian Standards. The buildings are steel frames and metal clad. All buildings are surrounded by a 10 m asset protection zone. The potential for fire beginning within the mining leases is considered limited as major equipment would be electrically powered and the dredge and plant will be floating within the dredge pond. All equipment is regularly (monthly inspection register) checked and maintained (maintenance department). Additional fire suppression measures have recently been installed on site equipment to further reduce fire risk including: Gas suppression in high risk rooms such as Motor Control Centres on the dredge, concentrators and WHIMS; Aqueous Film Forming Foam (AFFF) systems on heavy earthmoving and similar equipment; and Other control measures such as sprinkler systems in and around spirals, transformers, hydraulic rooms and other flammable material are also being scoped for implementation. A site procedure for managing and controlling impairments to the onsite fire systems has also been implemented in conjunction with Insurer (FM Global) requirements. The aim of the procedure is to minimise the down time and control site activities to mitigate fire risks when fire systems are not active due to either planned or unplanned maintenance. Electricity ransmission Line A 66 kv ETL runs from an existing transmission line easement adjacent to the Pooncarie- Wentworth Road to the mine site and comprises a standard three conductor configuration 66 kv transmission line. The initiation of a bushfire from a line fall accident was risk rated as low in a Preliminary Hazard Analysis undertaken as part of the Environmental Impact Statement (Bemax, 2001c). This was given that a line failure could be rapidly identified with immediate mobilisation of a repair crew and/or emergency response team if required. Diesel Storage Facilities Diesel is stored at Murray Basin mine sites in bunded storage facilities in accordance with Australian Standards AS 1940: The storage and Handling of Flammable and Combustible Liquids. The storage facilities will be well maintained with vegetation kept clear from diesel 6 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

15 storage tanks. The Murray Basin Mine Site Emergency Response Plan (internal version, 2012) provides details of all the diesel fuel storages. This plan notes the following diesel stores: Ginkgo 90,000 L at the Ginkgo administration, 1 x 55,000 L and 2 x 52,000 L in the contractor s yard; and Snapper 2 x 80,000 L at the BSL contractor yard and 9,000 L at the Chisholm contractor yard. 2.2 Summary of potential impacts A hazard analysis (risk assessment) for Ginkgo and Snapper was created as part of the update of the EMS and are appended to this revised EMS (October 2012). The purpose of this risk assessment was to apply quantitative risk ratings to significant impacts (identified in the EIS and regulatory consent conditions) as requiring management after the implementation of mitigation measures. This high-level assessment was a subjective assessment based on Cristal s knowledge of site operations to-date and the effectiveness of existing controls in reducing risks. Further details on this risk assessment are provided in the EMS. Bushfire related issues identified in this document are based on the requirements of regulatory consent conditions (Table 2 and Table 3). The preliminary risk assessment (as appended to the EMS) identified the residual risk associated with bushfire following the implementation of the mitigation measures in this plan as Low. Mitigation measures for the management of bushfires are provided in Section 4. It should be noted that this plan does not prescribe measures to prevent bushfires occurring bushfires are often a natural occurrence and can occur independently of human influences. This plan outlines measures to reduce risks to personal safety, assets, and ecological values from bushfires impacts. The following potential impacts from bushfires have been identified for the mines: Threat to personal safety of staff and visitors at the mine sites, farmers of surrounding properties and users of the surrounding public roads; Damage to mine infrastructure; and Damage to surrounding assets including farm houses, crops, and the ecological values of the surrounding environment. Mitigation measures to reduce risks of these bushfire impacts are provided in Section 4 of this document. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

16 3. Environmental management framework The environmental management framework for Cristal s operations in the Murray Basin is based on the requirements of AS/ISO 14001:2004 (the standard). Major elements of the environmental management framework include: Project risk identification and assessment; Environmental objectives and measurable performance targets; Legal and other requirements; Roles and responsibilities for environmental management; Staff training and induction processes; Responding to and managing complaints, non-compliances and incidents; Environmental reports and correspondence for the project; Audits of the BFMP; and Review and update of the BFMP. This BFMP has been designed as a subordinate document to the Environmental Management Strategy (EMS, 2012), which provides the framework for all Cristal s operations at the MSP and at the Murray Basin mines. Each of the main components of the standard has been addressed in detail within the EMS. Information provided within this BFMP provides additional, specific details for bushfire management. The Environmental Management Framework in place for Cristal s current operations in the Murray Basin in illustrated in Figure 2. Policy Provides overall direction for management actions, decisions and environmental commitments. Environmental Strategy Provides a framework for the delivery of environmental objectives, targets, programs and plans Procedures Step by step guides to implement environmental management Environmental Management Plans Details requirements to meet environmental performance objectives for key environmental aspects Registers, Forms & Data Databases Registers of incidents, plans & supporting documents & legal requirements Forms monitoring forms, inspection forms, incident & complaint forms etc Databases internal mechanisms for recording, tracking & managing key components of the EMS (incidents, monitoring, non-conformances, etc.) Figure 2 Cristal s environmental management framework 8 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

17 3.1 Relationship to other Environmental Management Plans The structure of the environmental management documentation is presented in Figure 3. This BFMP makes direct reference to the following environmental management documentation listed in Figure 3: Murray Basin Mines Flora and Fauna Management Plan; Murray Basin Operations Community Consultation Plan; and Offset Management Plan. The following plans not listed in Figure 2 (as managed by Cristal s safety department) are also relevant to this plan: Murray Basin Mine Site Emergency Response Plan; and Murray Basin Operations Safety Management Plan. This management plan should be read in conjunction with the above management plans. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

18 Companywide Integrated Management System (Environment and Safety) Murray Basin Operations Environmental Management Strategy Ginkgo Snapper Mineral Separation Plant Murray Basin Operations Community Consultation Plan Murray Basin Operations Traffic Management Plan & Code of Conduct Murray Basin Operations Radiation Management Plan Murray Basin Operations Environmental Monitoring Program Ginkgo Painted Burrowing Frog Management Plan Ginkgo Mining Operations Plan Ginkgo Mine Closure Plan Ginkgo DMU Salinity and Rehabilitation Management Plan Ginkgo Integrated Mining Rehabilitation Environmental Management Plan Pollution Incident Res ponse Management Plan Air Quality Management Plan Cultural Heritage Management Plan Water Erosion and Sediment Control Management Plan Waste and Landfill Management Plan Noise Management Plan Bushfire Management Plan Flora and Fauna Management Plan Land Management Plan Snapper Mining Operations Plan Pollutant Incident Response Management Plan Effluent Management Plan Operational Environment Management Plan Air Quality Management Plan Energy Savings Management Plan Water Management Plan Emergency Response Management Plan Safety Management Plan Noise Management Plan Waste Management Plan Cultural Heritage Management Plan Construction Environment Management Plan Noise Management Protocol Erosion and Sediment Control Plan Safety Study Fire Study Risk Hazard Analysis Energy Savings Management Plan Borefield Impact Management Plan Offset Management Plan Figure 3 Environmental management documentats for Cristal operations in the Murray Basin in NSW

19 3.2 Legislative requirements and project environmental approvals Project regulatory approvals Cristal is required to create, maintain and implement EMPs in accordance with the approval conditions for the Murray Basin mines. There are a number of regulatory approval documents that contain conditions for environmental management that Cristal must adhere to for operations at these sites. This BFMP has been created to address the specific requirements of the regulatory approval documents. The current regulatory approval documents for this project are provided in Table 2 below. The requirements of these regulatory approvals to be addressed in this BFMP are provided in Table 3. With regards to Conditions of Approval granted for the Murray Basin mines under the EP & A Act it is noted that: Development consent for Ginkgo was granted pursuant to Section 76(A)9 & 80 (Part 4) in January 2002; and Project Approval for Snapper was granted pursuant to Section 75J (Part 3A) in August Table 2 Approval documents for Ginkgo and Snapper Approval Document Document Number Current revision date Ginkgo Mineral Sands Mine Development Consent Conditions DA March 2015 Ginkgo Mining Lease ML No March 2002 Ginkgo Mine Environmental Protection Licence EPL July 2012 Snapper Mineral Sands Mine Conditions of Project Approval DA March 2015 Snapper Mining Lease ML No July 2008 Snapper Mine Environmental Protection Licence EPL July 2012 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

20 Table 3 Regulatory consent conditions applicable to this BFMP Condition number Condition details Section in EMP Ginkgo (DA ) Schedule 2, Condition 3.2 Environmental Management Strategies and Plans (d) The Applicant shall prepare the following environmental management plans: (v) Bushfire Management Plan (Condition 3.8(b)) Schedule 2, Condition 3.8 Bushfire and other Fire Controls Schedule 2, Condition 3.10 Adjoining Properties Schedule 2, Condition Emergency Services Cooperation Agreement The Applicant shall: (a) Provide adequate fire protection works on site, including the availability of trained personnel, water tankers and fire fighting equipment and annual hazard reduction measures with particular attention to boundaries of adjoining landholdings; (b) Prior to the commencement of mining operations prepare a Bushfire Management Plan for all its holdings contained in the DA to the satisfaction of the WSC and Rural Fire Service. The applicant shall regularly consult with adjoining property owners to ensure property management issues including maintenance of common fences, site weed control and bushfire management are coordinated. Details of consultation are to be provided in the Annual Review. (a) Prior to the commencement of construction, the Applicant shall develop an Emergency Services Cooperation Agreement in consultation with State Emergency Services and bushfire fighting services in the area. The Agreement shall provide, but not necessarily be limited to: (i) Policies and procedures for the ongoing supply of hazards information related to the Project to the state emergency services and bushfire fighting services (including quantities and locations of dangerous goods inventories and possible hazardous events at or associated with the development); (ii) Policies and procedures for communication with the state emergency services and bushfire fighting services and notifications in the event of an emergency; (iii) Details of any agreement for the provision of fire fighting/emergency response equipment from the Project in the event of a bushfire emergency; (iv) Details of any agreement for access to water stores at the development in the event of a bushfire; and (v) Details of any agreement for the provision of suitability qualified employees from the Project in the event of a bushfire or emergency. (c) The Applicant shall supply a copy of the Emergency Services Cooperation Agreement to the Director-General within 14 days of the agreement being reached. Section and Section 1.3 Murray Basin Operations Community Consultation Plan Section GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

21 Snapper (DA ) Schedule 3, Specific Environmental Conditions, Condition 16, Flora and Fauna Schedule 3, Specific Environmental Conditions, Condition 17, Offset Management Plan Appendix 4, Statement of Commitments SOC 1 Emergency Response Plan (ERP) The Proponent shall prepare and implement a Flora and Fauna Management Plan for the project to the satisfaction of the Director- General. This plan must:.. (d) include a:.. description of the detailed measures that would be implemented to: - manage grazing, fauna entrapment in the dredge pond, bushfires, and remnant vegetation on site; The proponent must prepare and implement an Offset Management Plan to the satisfaction of the Director-General. The plan must: (c) Describe the measures to implement the flora and fauna offset (see statement of commitment 4 in Appendix 5 and the detailed description of this offset in the EA), including: a description of short, medium and long term measures that would be implemented, including appropriate fencing to exclude grazing, incrementally de-stocking the offset area over three years, removal of unnecessary existing fences, erosion control, signage of the offset, revegetation of unnecessary access tracks, animal and pest control, weed management, fire management and threatened species management;. An Emergency Response Plan will be prepared for the construction and operation of the Snapper Mine to detail responsibilities in the event of emergencies in and around the Snapper Mine area. Snapper Mine fire response will be coordinated with the local fire brigade. Ginkgo and Snapper Flora and Fauna Management Plan Ginkgo and Snapper Offset Management Plan Murray Basin Mine Site Emergency Response Plan GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

22 3.2.2 Relevant legislation and other requirements This project is subject to the requirements of the New South Wales Protection of the Environment Operations Act 1997 and it subordinate legislation. A full legislative register is provided in the EMS (2012); acts, regulations and policies specific to this BFMP are listed below. Commonwealth Acts Environment Protection and Biodiversity Conservation Act 1999; State (NSW) Acts Environmental Planning and Assessment Act 1979; Mining Act 1992; National Parks and Wildlife Act 1974 (Aboriginal sites); Threatened Species Conservation Act 1995 (Threatened Species); Rural Fires Act Regulations Rural Fires Regulation Relevant Standards, Codes of Practice and Guidelines Bush Fire Environmental Assessment Code for NSW, February 2006; 3.3 Roles and responsibilities Overall roles and responsibilities for environmental management at the Murray Basin mines are outlined in Cristal s EMS. Cristal also has an Emergency Response Plan (ERP) that defines the roles and responsibilities for their emergency control organisation for responding to emergencies at the mines. The roles and responsibilities below are based on those provided in Cristal s ERP Chief Warden The role of Chief Warden is filled by the Shift Supervisor both during and after hours. Separate Chief Wardens exist for each of the Ginkgo and Snapper mines. The responsibilities of the Chief Warden are: Receive notification of the bushfire from the staff and/or public via the processes documented in the Detection and Reporting section of this plan (Section 4.6); Immediately proceed to the Emergency Control Position (See Section 4.3.6). Assess the emergency situation, determine and implement appropriate action. For bushfires the Chief Warden is responsible for the first response to fires, which is detailed in Section The Chief Warden remains responsible for first response procedures until handover to emergency services including the NSWRFS. Communicate details of the bushfire to Area Wardens by telephone, two-way, public address system or runner. 14 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

23 Contact the Shift Supervisor from the other mine site for assistance with extra personnel needed as required (i.e., nurse, senior first aid personnel). In the event of a bushfire that poses a risk to both sites, Shift Supervisors from both mines may be involved in executing the duties of Chief Warden. Briefing of emergency services as required and implementing directives made by emergency services for the safety of mine staff, visitors and neighbours. Contact and inform the Head of Department, Mine Manager and Operations Manager of the emergency situation and provide relevant updates as required. Advice Area Wardens of process and muster points for evacuation if required. Delegate responsibilities for emergency response as appropriate to the situation (for example, direct incoming traffic, keep access roads clear, meet emergency services on arrival and direct them to the Emergency Control Position) Communications Officer The role of the Communications Officer may be assumed by the Chief Warden (Shift Supervisor) or delegated to an appropriate person. The Communications Officer receives information from the person whom initially reports the emergency and may also assume the role in the event in an emergency, such as notifying the Chief Warden to initiate first response procedures and communicating with Area Wardens and emergency services Deputy Chief Warden The role of Deputy Chief Warden is filled by appointment from the Senior Production Coordinator in the event of an emergency. The Deputy Chief Warden assumes responsibilities of the Chief Warden if the Chief Warden is absent or unavailable. The Chief Warden may request assistance from the Deputy Chief Warden and delegate tasks as required Area Wardens Area Wardens are in place for main areas at each of Snapper and Ginkgo (administration, workshop/store, wet plant, dredge, laboratories and mine camp). The ERP states that after hours the responsibilities held for these areas fall back to the Shift Supervisor Emergency response team An emergency response team is trained to respond to and assist with fire outbreaks within the mining lease areas and surrounds (as per their training plan). The emergency response team is required to attend and assist, within their training and competency, an emergency situation as instructed by the Chief Warden. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

24 Table 4 Responsibility for bushfire management at Ginkgo and Snapper Mitigation measure Section in BFMP Responsibility Detection and reporting All Staff and visitors First response arrangements Chief Warden Bushfire coordination Chief Warden (as directed by emergency services after handover to the NSWRFS). Emergency Response Plan (ERP) Fire fighting infrastructure and ancillary equipment Safety department Emergency response team Fuel management 4.4 Environmental Department Identification of bushfire threat and assets at risk Implementation of fuel management plan Annual Hazard Reduction Program Development Chief Warden Environmental Department 4.5 Environmental Department 3.4 Training and inductions Overall training and induction requirements for Cristal s operations at the Murray Basin mines are outlined in Cristal s EMS. National competency based fire training is required by all staff and contractors in relation to the role they may fill in fire suppression during an incident on the emergency response team or part of mine rescue. 3.5 Complaint, non-conformance and incident management Complaint, non-conformance and incident management for Cristal s operations at the Murray Basin mines is described in Cristal s EMS. 3.6 Environmental reporting and correspondence Conditions of Approval (see Table 2), require that Cristal submit an Annual Environmental Management Report to the Director-General of the Department of Planning. Details of information to be included in the Annual Environmental Management Report (AEMR) are provided in Cristal s EMS. For bushfire management, the AEMR should include but not be limited to details of: Current cooperative agreements and communication with the NSWRFS and other emergency services; Summary of mitigation measures applied during the previous year to manage fuel loads, maintain fire breaks and otherwise the reduce risks associated with bushfires to health, environmental values and site infrastructure; and 16 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

25 Details of any incidents or complaints related to bushfire management, including management of these incidents, reporting to required agencies and the involvement of emergency services. The Environmental Protection Licences (EPLs, Table 2) for the Murray Basin mines stipulate that a monitoring and complaints summary in Cristal s Annual Return that must be completed for each site and supplied to the EPA not later than 60 days after the end of each reporting period (see the EMS for further details). Monitoring related to bushfire is not specifically required by the EPA as part of the Annual Return. 3.7 Audits of the BFMP Conditions of Approval for the Murray Basin mines (see Table 2) require that Cristal conduct an Independent Environmental Audit every three years or as otherwise directed by the Director- General of the Department of Planning. Matters to be covered by the Independent Environmental Audit are described in Cristal s EMS. Further detail of the how audits of EMPs will be conducted (including internal audits) is provided in the EMS. 3.8 Review and update of BFMP Conditions of Approval for the Murray Basin mines (see Table 2) outline requirements for revision and update of EMPs. EMPs would be reviewed, and if necessary revised to the satisfaction of the Director General, within three months of: (a) the submission of an AEMR; (b) the submission of an incident report; (c) the submission of an Independent Environmental Audit Report and; (d) any modification of the regulatory consent conditions. Further details on the requirements for review and update of EMPs are provided in the EMS. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

26 4. Environmental management program 4.1 Objective The primary objective of this BFMP is to establish a bushfire management strategy to mitigate the risk and subsequent impacts of bushfire on life and property in and around the Murray Basin mines, and to establish emergency response procedures that comply with the Development Consent Conditions, by: Developing and implementing a fuel management plan; Establishing operational arrangements for detecting, responding and coordinating bushfire events; and Establishment of emergency response evacuation procedures; This BFMP has been prepared as a requirement of the Conditions of Approval for the Murray Basin mines, as outlined in Table 3. The BFMP details procedures and programs for managing bushfire risk associated with the Murray Basin mines. Ginkgo and Snapper include the Mining Leases (ML) 1504 and 1621, mineral concentrate transport route and electricity transmission line as shown in Figure Performance standards All requirements of this BFMP are complied with; and No bushfire damage to life and property of the mine sites, mining lease areas or the surrounding area occurs as a result of actions of Cristal and its employees. 4.3 Fire preparedness Fire preparedness includes all activities undertaken in advance of bushfire occurrence to decrease bushfire area and severity and to facilitate more effective fire suppression. Fire preparedness covers the following aspects: preparing an ERP for responding to bushfires; identifying resources required and available for fire suppression; competency and training of personnel to required levels; serviceability and strategic location of fire fighting equipment; maintaining key roads, tracks and strategically located water points; monitoring fire danger; satisfactory bushfire detection; maintaining records; conducting fuel management in certain areas; designating strategic areas as firebreaks; and community and interest group have access to information matters such as flora and fauna values, fuel management implementation, etc. 18 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

27 4.3.1 Pre-season briefing Prior to the bushfire season an agenda item at the September monthly site meetings should include site bushfire preparedness, including: Understanding of personnel of preparedness and response actions (Section 4.3.2); Detection and reporting arrangements (Section 4.3.3); First response and coordination arrangements (Sections ); Response actions (Section 4.3.6); and Confirmation that equipment and suppression resources are prepared (Section 4.3.7). This pre-season briefing is complimented by discussion of bushfire risk as an agenda item at daily production meetings throughout the fire season. Area supervisors and contractor supervisors attend the daily production meetings and are responsible for communicating information on bushfire risks with personnel under their supervision as appropriate. Bushfire risk and management is also discussed at toolbox meetings. The safety department is responsible for collating and distributing relevant information related to current bushfire risks at these meetings. Information communicated throughout the season should include (but not be limited to) details on the roles and responsibilities for bushfire reporting and management and activity restrictions that are in place on days of higher bushfire risk Fire preparedness in response to forecast fire danger This aspect of fire preparedness refers to site arrangements in response to forecasted periods of elevated fire danger. Current and forecasted fire danger ratings are issued by the NSWRFS ( with the Murray Basin mines located near the northern border of Fire Area 20 (South-Western Fire Area) and mine leases in Fire Area 21 (Far Western Fire Area). The Safety Department is responsible for checking the fire danger issued for the South Western and Far Western Fire Areas daily throughout the fire danger season. The Safety Department will notify appropriate personnel/shift supervisors of a total fire ban and when the fire danger rating reaches a level that site activities need to be restricted. Table 5 outlines the site restrictions and fire preparedness measures that will be enacted in response to fire danger ratings. This table is communicated to site staff through toolbox meetings and noticeboards. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

28 Table 5 Bushfire preparedness Fire Danger Rating Cristal working restrictions and emergency actions General site readiness in event of a bushfire /access restrictions/site closure Low / Moderate High Very High Severe / Total Fire Ban (TOBAN) No restrictions No restrictions No remote area work outside of the main mining areas (for example, fencing of boundary areas or works in the offset areas). Supervisors to maintain a listening brief on ABC local radio for official fire warnings. No remote area work outside of the main mining areas (for example, fencing of boundary areas or works in the offset areas). Supervisors to maintain a listening brief on ABC local radio for official fire warnings. No hot works, except for those specially permitted under the Rural Fires Act. Under the Rural Fires Act lighting of fire is prohibited during a TOBAN except for: Fire lit, maintained or used in association with the cutting, welding and/or grinding apparatus used for the purpose of the urgent and essential maintenance and repair of mining equipment provided that: (a) the cutting, welding and/or grinding apparatus is used in a manner which will prevent the escape of fire, sparks or incandescent or burning material from the site of the works; and (b) adequate fire fighting equipment is provided at the site of the works to prevent the escape or spread of the fire. Water carts active on site and crew on standby, graders on standby and water tankers. 20 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

29 Extreme / TOBAN Code Red / Catastrophic / TOBAN No remote area work (as for Severe / TOBAN above) No hot works except in special circumstances as permitted under the Rural Fires Act (see Severe / TOBAN above) No external access to the mine site (road closures), may include no new shifts/personnel to come onto site (next shift suspended, remaining staff to stay within designated areas until safe to leave site where active fires are likely. Supervisors to maintain a listening brief on ABC local radio for official fire warnings. All measures required for Extreme / TOBAN above apply. Mine management to liaise with NSWRFS to assess need to evacuate site the previous evening or early in the morning. Decision enacted for site staff as appropriate. Supervisors to maintain a listening brief on ABC local radio for official fire warnings. Water carts active on site and crew on standby, graders on standby and water tankers. Contact with NSWRFS Water carts active on site and crew on standby, graders on standby and water tankers. Contact with NSWRFS GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

30 4.3.3 Detection and reporting Any fires detected by employees within the Murray Basin mine areas are to be reported immediately by employees and contractors via the emergency radio channel (for response by the site shift supervisor and for notification of the site office and camp). As incidents, bushfires and related events are also reported through the incident reporting system (ACCSTAT, as described in the EMS, 2012). Members of the public can immediately report any fires detected within the vicinity of the Murray Basin mines via 000 and also via the 24-hour a day/7 days a week telephone hotline, which is published on the company website. The telephone hotline number will be provided to local landholders and advertised regularly in the local newspaper. During high fire danger seasons, fact sheets may be provided to local landholders on the procedures for reporting fires to the mines. The following information is to be provided when reporting the outbreak of a fire: A description of the location of the fire; Details of the extent/status of the fire ; and Direction the fire is heading (If known). The fire is reported to the NSWRFS who then takes control of the situation (on-site emergency control team working under the direction of the NSWRFS for work within the lease area) First response arrangements In the event of a fire being reported within the mine lease or surrounds, the first response will be as follows: Identify the extent/status of the fire, (i.e. spot fire versus bushfire); Identify what resources are required to control the fire: If determined to be a spot surface fire burning under mild conditions, then Cristal fire fighting equipment is to be deployed including mine water truck and/or trailers, emergency response team and other such Cristal fire fighting equipment; If determined the fire is or has the potential to become a bushfire, emergency 000 is to be contacted and the Cristal Emergency Response Procedures are to be implemented. Access to the fire area or those areas deemed to be at high risk from the bushfire will be restricted to authorised appropriately competent persons only. Mine roadways, including the HAR within the fire danger zone or in the line of direction of the fire are to be closed off to prevent unauthorised persons including landholders or visitors from entering the fire danger zone. The shift supervisor acting as the Chief Warden (Section 3.3.1) is responsible for coordinating the first response to site fires, until handover to local emergency services occurs including the NSWRFS. Any further actions undertaken with regards to bushfire response after NSWRFS resume control will be under the direction of the NSWRFS Bushfire coordination An effective and coordinated approach to fire protection planning and bushfire control demands close liaison with fire emergency services. Cristal will develop and implement an Emergency Services Cooperation Agreement (ESCA) in accordance with Development Consent Condition The agreement will provide details of: 22 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

31 The procedures for providing information on hazards of the operation to Emergency Services; The procedures for communicating with Emergency Services; An agreement for the provision of fire fighting / emergency response equipment from Ginkgo and Snapper in emergency situations; An agreement for access of water stores at Ginkgo and Snapper in the event of a bushfire; An agreement for Cristal to regularly conduct site visits so that local external emergency response personnel are aware of the potential for fire at Ginkgo and Snapper; An agreement for Cristal to regularly supply plans and updated information to the local external emergency response personnel so that in the event of emergency the groups are aware of the layout and access restrictions of the mine site; and An agreement for the provision of suitably trained personnel to assist in emergency situations. An arrangement with local fire fighting authorities has been established as part of the ESCA for responding to bushfires within the mining lease. This arrangement will involve the deployment of local fire fighting equipment and teams in response to bushfires. In the event of a bushfire, an Incident Control Centre (also known as an emergency control position) will be assigned the responsibility for coordinating the action to be undertaken by the local fire fighting authorities and Cristal. The Incident Control Centre will be established as per the government hierarchy of responsibilities in emergency situations. Cristal s ERP lists the emergency control positions as follows: Ginkgo mine site Mine site administration conference room 1, after hours the wet plant control room/whims office. Snapper mine site Mine site administration office, after hours the wet plant control room. Village/mine camp Camp managers office or if inaccessible the Ginkgo mine site administration conference room. An Emergency Response Coordinator (the Chief Warden or delegate) will be responsible for communicating with the Incident Control Centre (on behalf of Cristal) as detailed in the section below Emergency Response Plan An ERP has been developed as part of the Safety Management System for Ginkgo and Snapper. The ERP provides procedures for responding to a range of potential emergencies including safety incidents, traffic accidents, natural disasters, environmental incidents and fire outbreaks excluding bushfires, which are covered in this plan. Bushfire emergency response procedures In the event of a bushfire, Cristal will assign an Emergency Response Coordinator (this role is usually filled by the Chief Warden or delegate, Section 3.3) who will be responsible for the roles and activities related to bushfire response that are outlined in Section GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

32 Evacuation Cristal s ERP provides details of emergency evacuation procedures applicable to most emergency situations. Cristal will develop emergency evacuation procedures to be used in the event of a bushfire in accordance with the template presented in Appendix A. The evacuation procedure highlights: Immediate evacuation routes and muster points/shelters; The sounding of an emergency evacuation siren to notify employees of the actions they need to implement in response to a bushfire warning; Contact details and communication processes with the NSWRFS and local fire brigade; and Further evacuation procedures for evacuation to Wentworth or Broken Hill in consultation with the fire fighting authorities. Self-evacuation under adverse fire conditions can be fatal and all evacuations must be conducted in consultation with emergency service authorities. Evacuation point requirements Cristal s emergency evacuation procedures will detail emergency evacuation points. The following summarises key requirements for emergency evacuation points. Immediate evacuation routes and muster points/shelters must be located at a pre-assigned location in an area cleared of woody vegetation and fine fuels within the mine site and preferably a building with the suitable setbacks established. Due to smoke, ember and heat impacts the best place to shelter from a bushfire is within a suitably prepared and designated building. This building should be separated by a physical break from the nearest vegetation hazard by a distance of 25 m (as determined using guidance within AS , FDR 80, 5-10 degree land scope, Mallee/Mulga vegetation classification) and the fuel load within the vegetation hazard reduced to a total distance of 100 m. The designated building should have water and facilities available (i.e., toilets) and resistance improved where possible that meets the design measures identified in AS for a BAL 12.4 construction for the sections of the building facing the fire hazard, such as: Walls lower than 400 mm above ground non-combustible, 6 mm fibre cement or bushfire resistant timber; Windows with a bushfire shutter/drop down eave, metal screen or 4 mm safety glass; Windows of a non-combustible material, such metal reinforced PVC-U or bushfire resistant timber; Outward facing doors non-combustible (solid core) with weather strip at base or where hollow core includes metal framed tight fitting metal screen door; Non-combustible roof covering, with roof/wall junction sealed, openings fitted with noncombustible ember guards and roof fully soaked; and External verandas enclosed where < 400 mm of ground and decking non-combustible or bushfire resistant timber. 24 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

33 If evacuation is to an open space it should be located at a 310 m radius from vegetation. All evacuation points must have safe access and exit routes and be of a suitable capacity to accommodate the persons on site in adverse conditions. Fuel loads around designated evacuation points should be managed in accordance with the fuel management plan (Section 4.4.1). Evacuation points should be located as close as possible to fire fighting equipment and amenities. National Bushfire Warning System All personnel must be aware of actions to prepare for and respond to a formal bushfire emergency alert that may be issued for the site. There are three levels of alert under the national bushfire warning system (see below). These alerts are broadcast where there is a known potential bushfire risk to a locality, via the media (ABC local radio, television, social media applications and internet) and potentially by text message (to all mobile phone users at a locality). Bushfires can threaten suddenly and without warning. You should always be ready to act on the basis you may not receive an official warning and respond to signals that a bushfire may be in the area. The National Bushfire Warning System has three phases which align well with the Prepare, Act, Survive framework with responses identified for the site as follows. These will be documented in the Bushfire ERP for the site (to be developed in accordance with the template provided in Appendix A). GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

34 Table 6 National bushfire warning system alert levels BUSHFIRE WARNING ADVICE WATCH AND ACT EMERGENCY WARNING Meaning An advice will provide information on where the fire is and provide general information in relation to that fire. There is no immediate danger. A fire is approaching. There is a threat to life and property. You need to take action to protect yourself and others. An Emergency Warning is the highest level of alert and advises you of immediate danger. It may start with a siren sound. You are in danger and you need to take immediate action. Action Personnel should be aware of bushfire indicators in the area (smoke, ash), report fire outbreaks in the area, and make themselves familiar with the emergency response plan for the site (Appendix A). Fire suppression equipment should be prepared for use. Maintain a listening brief of ABC local radio and prepare to respond. There is a heightened level of threat. Personnel should assemble in on-site evacuation areas, or if advised by emergency services prepare to leave the site. You must start taking action now. The site may be in immediate danger of impact by bushfire and action needs to be taken immediately. Personnel should assemble in the predetermined evacuation building and follow the advice of fire authorities Fire fighting infrastructure and ancillary equipment For effective bushfire control, the Murray Basin mines will rely on the response of fire fighting authorities such as the NSWRFS, as well as use of suitable heavy equipment owned by Cristal and other private individuals within the area. Fire authorities have access to fire fighting equipment including, fire tankers, slip-on fire fighting units, mobile retardant mixers, pumps and hand tools. A map for Ginkgo and Snapper that shows the location of major fire fighting resources and infrastructure is provided as Figure 4. An emergency response team is trained to respond to and assist with fire outbreaks within the mining lease areas and surrounds. Cristal s ERP provides further information on the emergency response team. The team will be supported by a dedicated emergency response vehicle, which would be equipped to provide equipment for fire control and/or first aid capability as required. It is noted that in the event of a bushfire, Cristal will hand control of the situation to emergency services. The emergency response team may be required to act under the direction of the NSWRFS if appropriate. Fire trail register A detailed fire trail register is maintained and outlines the following within the Mining Leases: The location of fire trails, roadways and firebreaks across the mine leases; 26 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

35 Records of maintenance works undertaken on fire trails and the dates the work was undertaken; The location of all water sources across the mine leases; Records of any fuel reduction measures undertaken and the dates the works were undertaken; and Details of the fire history of the area. Water sources The Murray Basin mines have a fully functional fire water supply designated to protect the mine offices, workshops, accommodation camp and ancillary infrastructure from bushfire. This system draws water from the potable water reticulation system (Figure 4). A diesel powered pump station is located at the 100,000 L potable water tank located within the Ginkgo mining lease area. Water is automatically drawn down from this system when required into a ring main. The ring main will feed at least six hydrants and four hose reels. 6 x 20,000 L water tanks with diesel pump are also located at Snapper and a further 100,000 L is stored at the mine camp (Ginkgo mining lease area) as back-up supply for the camp fire hoses. In addition there is access to contractors water carts (up to six) to cart water as required in an emergency, some of these water carts have hose reels and capability to act as bulk containers for the two on-site water trailers (fire fighting trailers fitted with foam induction). In the event of an outbreak of fire the water truck would be deployed to give additional resources as required. Ancillary equipment The Murray Basin Mines has a 1 X 3000 litre 4WD Fire Tanker (Diesel driven pump with A Class Foam Proportion system) and a 2 X 1200 litre Fire Trailer (Diesel driven pump with A Class Foam Proportion system). The following fire fighting equipment is available in the 4WD Fire Tanker: Five 38 mm x 30 mt Duraline firefighting hoses; Two 64 mm x 30 mt Duraline firefighting hoses; Three 50 mm x 3 mt Hard suction lines; One 64 mm 3TPI Male to Storz adaptor; One 64 mm Camlock Male to Storz adaptor; One 64 mm Camlock Female to Storz adaptor; Two A Class Foam Branch; Two 361 Protek firefighting branch; Two 366 Protek firefighting branch; One Suction Strainer; Two Hose Spanners; and 40 litre A Class Foam Concentrate. The following fire fighting equipment is available in the 2 X 1200 litre Fire Trailer Two 38 mm x 30 mt Duraline fire fighting hose; One 64 mm x 10 mt Duraline fire fighting hose; Two 50 mm x 3 mt Hard suction lines; GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

36 One 64 mm Stortz to 38 mm Wayjax reducer; One 360 Protek firefighting branch; One 64 mm Camlock Male to Stortz adaptor; and One A Class Foam Branch. 28 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

37 LEGEND Road Track Cristal Fence Water Point Figure 4 Cristal Mining Australia Ltd Location of fire fighting resources and ancillary infrastructure Bushfire Management Plan Scale: 1:90000 Projection: Custom Projection kilometres Figure 4 Location of fire fighting resources and ancillary infrastructure (regional)

38 Cristal Mining Australia Ltd Figure 5 Location of fire fighting resources and ancillary infrastructure for Ginkgo Bushfire Management Plan Scale: 1: Projection: Custom Projection metres Figure 5 Location of fire fighting resources and ancillary infrastructure for Ginkgo 1,000

39 Cristal Mining Australia Ltd Figure 6 Location of fire fighting resources and ancillary infrastructure for Snapper Bushfire Management Plan Scale: 1:25000 Projection: Custom Projection ,000 metres Figure 6 Location of fire fighting resources and ancillary infrastructure for Snapper

40 4.4 Fuel management Environmental considerations Vegetation clearance protocols and threatened species management protocols have been developed for Murray Basin mines and are included in the Flora and Fauna Management Plan (2013). The clearance protocols outline measures to be undertaken prior to clearing of any vegetation within the Mining Leases. Measures include: Delineation of areas to be disturbed with remnant vegetation to be clearly marked or fenced; Pre-clearance survey for flora, including a targeted survey for Swainsona adenophylla; Preliminary and secondary fauna habitat assessments; and Trigger for threatened species management protocols; Prior to undertaking any fuel reduction measures, vegetation clearance and threatened species management protocols will be employed Fuel Management Plan The fuel management plan aims to identify appropriate strategies for reducing fire hazards and related risks and impacts to life, property and the environment. The manipulation of fuel loads in strategic areas can allow bushfire damage to be moderated, reduce the potential for spotting from an advancing bushfire, and facilitate bushfire control activities. The effectiveness of a fuel reduced area on a subsequent bushfire depends on: Fuel type, distribution and levels of fuels, which in turn depend on the coverage and the time that has elapsed since fuel reduction measures were undertaken; Width of the fuel reduced area in relation to the direction of bushfire travel; and The intensity of the bushfire. Appropriate strategies to be implemented (by the environmental department as required) for fuel management include: fuel reduction in directly around assets and at strategic locations in the landscape by targeted grazing, slashing, pruning, mulching, ploughing, herbicide application, grading/dozing and/or rolling; Fuel burning in strategic locations (dependant on conditions) within the lease/offset areas where conventional fuel management strategies are impracticable or not successful (undertaken in consultation with relevant fire authorities); and Maintaining strategic areas designated as firebreaks. Generally on days of elevated fire danger winds are from the north through to west, and in the event of a wind change from the south west. Therefore strategic fuel free breaks of minimum 20 metres width should be established and maintained to the south-west to north-east of the asset clusters. Areas for fuel reduction will be selected annually after considering the recent fire history, fuel hazards present and environmental considerations of the area. A combination of fuel reduction strategies will be implemented prior to high danger fire seasons. Grazing Grazing will be considered as a localised fuel management option where it is consistent with the management objectives of the area concerned. The location, type, level and period of grazing will be determined in consultation with local landholders. The progress of grazing for fuel 32 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

41 management will be monitored and stock removed when fuel management objectives have been achieved. Grazing should seek to reduce grass fuels to a low overall fuel hazard rating. Crash grazing could be an option for strategic areas prior to the fire season in those areas carrying above average fuel loads. Firebreaks Firebreaks act as control lines for low-intensity fires, assist with safer access for moderate to high-intensity fires and providing a defence line for back burning. A network of firebreaks will be maintained along power easements, mine access roads and along the immediate Mining Lease boundary. The width of these breaks will be equivalent to the adjoining tree height, to account for the majority of short-distance spotting for low and moderate fires. Firebreaks will be maintained by slashing and grading. Additional firebreaks may be constructed during a bushfire event to assist in controlling the bushfire if directed by fire fighting authorities. All fence lines and roads within the Mining Lease areas and for land under Cristal control are maintained as fire breaks (excluding grazing lease areas). The Offset Management Plan (2012) also allows for controlled burns to be undertaken in offset areas if needed to reduce fuel loads. Slashing Slashing is used to reduce the fire hazard around the immediate Mining Lease and within firebreaks. Timing will accommodate requirements of flora or fauna on slashed areas provided fire protection objectives are still satisfied. Slashed areas will be maintained in a condition which satisfies fire suppression objectives and fire fighter safety considerations. Bulldozing and Grading Bulldozing and grading are used in constructing some firebreaks and in removing specific fire hazards. Bulldozer or grader lines will be constructed as control lines around the perimeter of the majority of bushfires, and also provide appropriate vehicle access for firefighters. As far as practicable, bulldozer or grader lines will be located to minimise impacts on the environment. Lines not required after bushfire events will be rehabilitated in accordance with rehabilitation techniques outlined in the Flora and Fauna Management Report and the Mining Operations Plan. Pruning, Ploughing and other operations Additional management measures such as ploughing, herbicide application or rolling may be used to reduce fuels where other conventional methods are inappropriate, impracticable or unsuccessful. Pruning of trees will be undertaken along electricity transmission lines when necessary in accordance with Tree Pruning - Typical Clearances (Planning for Bushfire Protection, Rural Fire Service and Planning NSW, 2001). The guidelines state that for a 66 kv line, typical clearance of vegetation to the nearest conductor in rest position is 2.25 m, and the typical clearance of vegetation along the middle 2/3 of span to the nearest conductor in rest position is 2.25 m or sag at 50 C plus 1.0 m (whichever is greatest). Species with a maximum growth height of 3 m do not need to be pruned. This is the responsibility of Essential Energy (pruning near power infrastructure) and Cristal would liaise with Essential Energy on the need for the pruning (as described above) as required. GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

42 Fuel reduction burning Burning as a fuel reduction measure will only be undertaken in strategic areas if other conventional fuel reduction measures are unsuccessful and/or inappropriate. Planning for fuel management burning will be done in close consultation with fire fighting authorities. Burning for fuel management will be, as far as is practical, fully integrated at the local planning level, to maximise possible mutual benefits. So that fuel management burning operations are conducted in a responsible manner the following strategies will apply: Each burning operation will be the subject of an approved Burn Plan; Each Burn Plan will comply with the planning requirements, operational standards and guidelines from the NSWRFS and other governing authorities; Each burning operation will be undertaken so that the fire will be, as far as possible, contained within pre-defined control limits; Fuel hazard levels will be assessed prior to burning and will be monitored following burning; The results of each burn will be mapped and recorded in the Fire Trail Register; and Significant environmental or other values identified in the burn planning process will be monitored following burning. 34 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

43 4.5 Monitoring Table 7 below outlines the schedule that Cristal will implement for bushfire mitigation works detailed in the sections above. Fuel reduction strategies will be reviewed annually to assess the success of the program and any impacts to the environment as identified through pre and post assessments. The findings of such assessments will be considered when conducting future fuel reduction strategies. Table 7 Bushfire mitigation works schedule Mitigation Work Type Location Standard Timing Responsibility Monitoring Pre-season briefing All sites at toolbox meetings and production meetings during fire season n/a Monthly Safety department none Grading fire trails Ginkgo/Snapper Offsets Lease boundaries Approximately 3-5 m each side of fence line) Twice annually Environmental department Environmental department visual inspection on completion. Grazing Agricultural areas adjacent mining lease and offsets As per western lands lease conditions Ongoing Occupational Lessee none Slashing Near mine site infrastructure (i.e., power lines) As required Prior to fire season Environmental department Visual prior to the commencement of fire season Fuel reduction burning As identified (strategic based on anticipated high-risk conditions). As per NSWRFS guidelines for hazard reduction burns. As required Environmental department Environmental department 35 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

44 4.5.1 Pre-season monitoring Before the fire season begins, checks should be undertaken to test that mitigation actions have been put in place such as: Implementation of the bushfire mitigation works schedule fully implemented including: Asset protection zones established and maintained (grading mine lease boundaries); Fire management zones established and fuel reduced; Slashing and fuel reduction works completed if required; Fire trails inspected; Fire trails trafficable; Water points checked and accessible; Identified fire control room suitable prepared for use; Identified bushfire awareness actions completed (for new and existing site users); Bushfire contact numbers checked and correct; Pre-season site bushfire awareness briefing completed / scheduled if required; and Site based fire suppression equipment checked and operating. 4.6 Reporting Annual Environmental Management Reports (AEMR) are produced for Cristal. The effectiveness of proposed mitigation measures and monitoring will be documented and summarised in the AEMR, along with details of fuel reduction strategies undertaken during the preceding 12 months will be reported in the AEMR. The AEMR will also include any proposed modifications to fuel reduction strategies for the following 12-month period. The AEMR will be distributed to DOP, WSC, OEH, and local landholders in close proximity to the operations. The report will also be made available for public information at WSC. Any wildfire that occurs at the Murray Basin mines, or in the surrounding area, once controlled, should be accurately mapped and reported to the NSWRFS, WSC and OEH. 36 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

45 5. References Bemax (2001a) Broken Hill Mineral Separation Plant New South Wales, Environmental Impact Assessment, Main Report and Appendices, prepared by Resource Strategies on behalf of Bemax Resources Pty Ltd, November Bemax (2001b) Ginkgo Mineral Sands Project, Environmental Impact Assessment, Main Report and Appendices, prepared by Resource Strategies on behalf of Bemax Resources Pty Ltd, September Bemax (2007) Snapper Mineral Sands Project Environmental Assessment, prepared by Resource Strategies on Behalf of Bemax Resources Pty Ltd, Bureau of Meteorology (2012) Monthly Climate Statistics for Wentworth ( DEC (2006) Fire Management Plan - Mallee Cliffs National Park - Feb Feb 2011, Department of Environment and Conservation (NSW) Lower Darling Area GHD (2012) Ginkgo and Snapper Flora and Fauna Environmental Management Plan. Report prepared for Cristal Resources, November NSW BFCC (2010) Lower Western Zone Bush Fire Management Committee Bush Fire Risk Management Plan, Lower Western Zone Bush Fire Management Committee GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

46 38 GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166 Appendices

47 Appendix A Bushfire Emergency Response Plan (Template) GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

48 Bushfire Emergency Response Plan Template Section 1: Risk Assessment and Management Strategies Property Name Location Locality Map Area Bushfire Prone Summary of Bushfire Risk Factors [Name of the property] [Street address of property (if you ring 000 they ask for an address this must be provided), and distance from nearest highway to emergency meeting point. Include the lat/long of a helicopter landing spot and the lat long of the nearest airstrip] [Locality map showing the location of site, boundary, major roads and nearest towns] [Total area in hectares] [Details of why the site is bushfire prone, and the likelihood and consequence factors associated with this vegetation] [Summary of the key bushfire risk factors, strategies and risk control measures across the site] Section Two: Bushfire Mitigation Works Program to be completed prior to fire season Work Type Location Timing Responsibility Procedures Monitoring [e.g. slashed break] [Preparation of evacuation points, etc.] [Preparing equipment] [Ploughing, etc.] GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/29166

49 Section Three: Bushfire Awareness Program [Insert pre-season and daily briefing requirements] Section Four: Preparedness and Response Strategy Preparedness Bushfire Detection and Reporting Bushfire Warnings Fire Suppression Resources Command and Control Contacts [Insert Table 5 (Bushfire Preparedness table from Bushfire Management Plan)] [Identify the process to follow when a bushfire ignition is detected on or adjacent to the property This could be prepared as a flow chart.] [Insert a site response action when a bushfire warning is issued (Table 6, Bushfire Management Plan) including directions /distance to nearest evacuation point and bushfire emergency refuge of last resort)] [Identify the nearest fire suppression resources and approximate distance ] [Identify command and control arrangements for the site ] [Contacts, phone numbers and radio call signs /channels of the site point of contact and stakeholders including neighbours] [Insert site map should show the full site extent with zoom in windows where greater detail is required. Incident Control System (ICS) symbology 1 should be used to show site features and it should show the location of buildings in which people should evacuate to and distances to major roads, helicopter landing point, nearest airstrip and ambulance meeting point] 1 data/assets/pdf_file/0006/41838/emsina_all_hazards_symbology_report_final_july10.pdf GHD Report for Cristal Mining Australia Ltd - Ginkgo and Snapper Bushfire Management, 31/

50 GHD 57 Orange Avenue Mildura, Victoria 3500 T: (03) F: (03) E: GHD 2013 This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited. G:\31\29166\WP\ docx Document Status Rev No. Author Reviewer Approved for Issue Name Signature Name Signature Date Geoff Nyssen Geoff Nyssen 4/10/ D Adshead J Stephens C Evans 1 D Adshead J Stephens C Evans D Kovacs D Kovacs 05/11/2014

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