P-PRCP-100723747 · NORANDA PACIFIC PTY LIMITED

item 2 3.2 Post Mining Land Use

Department foundIn accordance with s126C(1)(d) of the EP Act, the PRC plan must state the extent to which each PMLU is consistent with any strategies or plans for the land of a local government, the State or Commonwealth. To ensure the proposed PRC plan adequately addresses this requirement, further information is required.

Asked forProvide an updated PRC plan including discussion regarding the extent to which each proposed PMLU is consistent with any strategies or plans for the land of a local government, the State or Commonwealth.

Applicant repliedWorks confirm proposed PMLU of Low Intensity Cattle Grazing and Native Habitat are consistent with government plans and policy. Additional content included in PRC Plan.

Where addressedSection 3.2.4

item 3 .6.1 General rehabilitation practices

Department foundThe Rehabilitation Planning Part relies on the results and conclusions from several technical reports, which in some instances have not been provided to support the application. It is recommended that these are provided as they are necessary to justify the proposed rehabilitation and management methodologies.

Asked forProvide a copy of the following technical reports: - Waste Rock and Spoil Management Plan (WRSMP) - ATCW report referenced in section 3.6.2.1.1 - RGS Environmental Consultants Pty Ltd referenced in section 3.6.1.1 - Engeny 2020 Lady Loretta Mine – Leachate Management Dam Construction Report referenced.

Applicant repliedTechnical reports provided as Appendix to PRCP. The exception is the WRSMP—recently revised, this site management plan is currently being certified by an RPEQ and could be provided upon completion and request.

Where addressedAppended to PRCP

item 4 3.6.1 General Practices. PRCP Guideline, Section 3.6.1 General rehabilitation practices, Landform design and Waste characterisation · 3.6.1 General Practices. PRCP Guideline, Section 3.6.1 General rehabilitation practices, Landform design a

Department foundLimited information is presented to demonstrate the erosion stability associated with the final landform. For example, 25% (maximum) slopes are proposed for a number of batters such as the ROM pad side-hill landform and the re-profiled batters of decommissioned dams, and specific slope gradients are proposed for the WRE crest and batters. Erosional stability is referred to in the Lady Loretta PMLUP (2018) based upon the recommendations drawn from supporting technical studies which employed the WEPP model. It is further assumed that the options assessments and closure design studies completed by ATCW referred to in Section 3.6.2.1.1 of the Rehabilitation Planning Part may contain conclusions regarding the erosional stability of the proposed final landform. To further satisfy the requirements of the PRCP Guideline and to demonstrate the land will be stable, the conclusions and assumptions of previous modelling and investigations regarding the stability of proposed slopes and the suitability of materials (including waste characterisation studies) used to construct the final landform must be provided in the Rehabilitation Planning Part.

Asked forProvide an updated PRC plan that presents the conclusions and assumptions of previous modelling and investigations regarding the stability of proposed slopes and the suitability of materials (including waste characterisation studies) used to construct the final landform.

Applicant repliedStability analysis and erosion modelling included in PRCP. Long term modelling of Waste Rock Emplacement (WRE) plateau and hydraulic calculations for WRE batters carried out. Assessment indicated material for cover suitable and stable conditions expected.

Where addressedSection 3.6.2 Section 3.6.2.12 Appendix A Appendix F Appendix G

item 5 3.6.1.1 Soil and Capping Material Assessment

Department foundThis section does not provide enough information as to the inventory of borrow and topsoil materials. The amount of topsoil and non-mineralised material required for remaining rehabilitation activities are documented, and some information as to the quantity topsoil is available However. There is no information regarding the quality of the material and whether ameliorants are required. To clarify rehabilitation strategies proposed by the PRC plan, it is recommended that additional information is included in Table 13 regarding: - A description of what material ‘General Backfill’ is and where this material will be sourced from. - Clarification as to which Rehabilitation Areas the topsoil and subsoil materials will be applied. - Clarification regarding the depth of Rock Mulch to be applied as the NAF protection layer on the WRE Batter (assumed to be 3m based on information provided in the table). - Clarification regarding the depth of Rock Armour to be applied as a protection layer to the WRE

Asked forProvide an updated PRC plan that includes further information regarding: - The quantity of topsoil material required to complete rehabilitation at each site, - A description of what material ‘General Backfill’ is and where this material will be sourced from. - Clarification as to which Rehabilitation Areas the topsoil and subsoil materials will be applied. - Clarification regarding the depth of Rock Mulch to be applied as the NAF protection layer on the WRE Batter. - Clarification regarding the depth of Rock Armour to be applied as a protection layer to the WRE.

Applicant repliedFurther detail on material balance and quality of material has been completed. Additional detail on optional borrow sites and re-design have been included in PRCP. Clarification on which rehabilitation areas growth media will be applied as well as WRE cover depths is included in PRCP. The additional works confirm rocky soil mulch with fertiliser and/or ameliorants will provide similar outcomes as growth media application.

Where addressedSection 3.6.1.1 Section 3.6.2 Appendix A

Notice, page 4

item 14 Rehabilitation Milestone Criteria - General

Department foundThe intent of milestone criteria is that they provide measurable parameters to demonstrate achievement of the relevant Rehabilitation Milestone. There are a number of opportunities where additional criteria can be drawn from the Rehabilitation Planning Part into the proposed PRCP schedule, with the intent of providing a clear demonstration that the milestone has been achieved. For example: • Drawing from information provided at section 3.6.2.8 of the Rehabilitation Planning Part, a criterion regarding the volume and quality of seepage from the WRE could be added at RM11a) to further demonstrate achievement of the design objectives of the cover system. Table 7 of the Rehabilitation Planning Part clearly articulates a number of elements and the design intent necessary to achieve the objective of chemically stable. It is recommended milestone criteria are proposed to demonstrate the design intent for these elements are achieved. • Revision to RM3c to include more specific backfill criteria e.g., Section 3.2.1.5 of the Rehabilitation Planning Part indicates backfill of the upper 460m of the mine decline. • Addition of a criterion at RM2 to demonstrate mineralised waste, soils and subsoils contaminated with heavy metals and salts have been encapsulated within the upper benches of the WRE.

Asked forConsider the matter raised and provide an updated PRC plan (including the PRCP Schedule) where revisions have been made to Rehabilitation Milestone Criteria.

Applicant repliedAdditional milestone criteria included for WRE. PRCP Schedule RM2 and RM12 updated including PRCP monitoring and maintenance program. PRCP Schedule for RM4 remains unchanged due to conceptual nature of the geotechnical study.

Where addressedSection 4.4 Section 3.14 Section 3.10.1 Appendix J

Notice, page 8

item 15 RM5

Department foundCriterion RM5 relates to the decommissioning of Regulated Structures and Erosion and Sediment Control facilities

Asked forProvide an amended PRC Schedule and consider additional criteria to demonstrate that the potential for land and water contamination during the decommissioning of the regulated structures will be appropriately managed.

Applicant repliedAdditional milestone criteria included for erosion and sediment control systems. PRCP Schedule RM5 updated.

Where addressedAppendix J

Notice, page 8

item 16 RM6

Department foundCriterion RM6 d) proposes the placement of “maximum thickness of 100 mm of growth media at ROM, Paste Plant and Batch Plant Area (RA7), subject to recommendations by suitably qualified person”. Justify how this value has been chosen and how it is suitable for the establishment of the PMLU or consider updating criterion RM6 accordingly.

Asked forProvide an updated PRC Plan that demonstrates that a growth media less 100mm would be suitable for revegetation planned and minimising erosion or amend relevant criterion in the PRC Schedule.

Applicant repliedPRC Plan updates for matters relating to stockpiled soils. Minimum 150 mm thickness of growth media proposed for RA7 and borrow sites within RA9. Glencore also note that 150 mm is consistent with the Departments Estimated Rehabilitation Cost Guidelines.

Where addressedSection 3.6.1.1 Section 4.4 Appendix J

item 17 RM7

Department foundAs proposed, criterion RM7a) does not appear to reflect the intended areas of disturbance (i.e., all areas excluding the WRE).

Asked forProvide an updated PRCP Schedule to ensure criterion RM7 a) correctly refers to the relevant areas of disturbance.

Applicant repliedUpdates to PRCP Schedule made.

Where addressedSection 4.4 Appendix J

item 18 RM11 Section 7, Appendix B Flood Assessment; (WRM Flood Assessment report)

Department foundThe WRM Flood Assessment report models peak velocities along the proposed final landform drain west of the WRE of up to 2.7 m/s, and velocities in the steep drain into the former sediment dam at CDB of up to 3 m/s. Considering the velocities predicted and the runoff potential from the outer slopes of the WRE, consider reviewing the wording of milestone criteria RM11, specifically “No rill/gully erosion > 500 mm”, to ensure the erosion trends from-long term monitoring are an input into assessing whether the final landform will meet the design objectives of negligible erosion (Section 3.6.2.1)

Asked forProvide an updated PRC plan and the PRCP Schedule with a criterion RM11 that ensures that the erosion onsite is negligible.

Applicant repliedNo rill/gully erosion > 500mm is considered appropriate based on proposed concept cover design and depth to underlying liner. Glencore also notes the LOD states ‘>1m deep’. Long term erosion modelling undertaken and presented.

Where addressedSection 3.6.2 Section 4.4 Appendix F

Response, page 4

item 19 RM12 and RM13 Proposed PRC plan, Section 3 Rehabilitation Planning PRCP Guideline, Section 4.1 Steps for developing a PRCP schedule, Step 5 Develop site-specific milestone criteria, and Appendix 3 Reference Milestones · RM12 and RM13 Propos

Department foundThresholds for the various Ecological Function Analysis (EFA) indices are proposed as milestone criteria (e.g., “Vegetation Dynamics >40% of reference”). The Rehabilitation Planning Part does not currently justify the choice of thresholds. It is necessary to justify how the milestone criteria will demonstrate achievement of the relevant Rehabilitation Milestone which in turn achieves the required outcome of land in a stable condition. Both RM12 and RM13 propose the following criterion – “Contaminated land assessment completed by suitably qualified person”. Throughout the Rehabilitation Planning Part there are references to instances where contaminated land investigations and any necessary remediation activities will be completed early in rehabilitation activities. For example, Section 3.6.7.3 Contamination from Mineralised Streams discusses the initial investigation and remediation efforts focussed on excavation of contaminated soil and sediments and disposal by placement in the crest of the WRE. Appendix 3 of the PRCP guideline provides an example of a Rehabilitation Milestone for “Remediation of contaminated land” which should be included where relevant in a PRCP schedule and scheduled to occur at the relevant moment in rehabilitation activities. That is, prior to final landform surface preparation and revegetation works. It is recommended that a definition for ‘Low intensity grazing’ (or a framework against which this can be measured) is provided as a footnote at RM13 to ensure RM13a) can be demonstrated as achieved.

Asked forProvide an updated PRC plan (including the PRCP Schedule) that: - Justifies the choice of thresholds for EFA indices as sufficient to achieve the final outcome of land in a stable condition and discuss why these thresholds were chosen. - Considers the matter raised regarding earlier demonstration that contaminated land activities are completed and updates the Rehabilitation Planning Part and Schedule where necessary. - Provides a definition for Low Intensity Grazing, sufficient to measure achievement of criterions RM13a)

Applicant repliedPRC Plan includes further rationale and justification for EFA thresholds—with consideration to site and regional climatic conditions. The approach within the PRCP adopts averaged scores for representative reference, noting that arid environments may experience periods of regression. Contaminated land remediation milestone has been updated based on suitability for PMLU. Glencore note that surrender of the EA will require demonstration of compliance with the EA and completion of contaminated lands assessment works. Definition for ‘Low intensity grazing’, and a framework against which this can be measured, included in PRCP and appended technical study.

Where addressedSection 3.14 Section 4.4 Section 3.2.3 Appendix C Appendix J

Response, page 4

item 20 RM12 Groundwater Criteria

Department foundCriterion RM12 f) describes the “Assessment and validation by suitably qualified person that the long-term risks presented byground water contamination do not preclude the PMLU”. As proposed, this milestone criterion is unclear and inconsistent with the other proposed criterion RM13)h).

Asked forProvide an updated PRCP Schedule that includes clear contaminant limits applicable to the WRE, such as “Groundwater quality to meet contaminant limits defined in the current EA##”

Applicant repliedGroundwater success criteria, consistent with requirements of the EP Act, has been proposed. While monitoring in accordance with the EA is appropriate for collecting a dataset and identifying rehabilitation performance during the post closure period prior to relinquishment, the architecture of this monitoring regime, specifically the contaminant limits, are inappropriate for use as success criteria.

Where addressedSection 3.6.2 Section 3.14.14.2 Section 4.4 Appendix J

Response, page 4

Notice, page 10

Replies to requests not published on the register: 8

item 6

Request, as quoted by the applicantSection : 3.6.1 General rehabilitation practices, Soil and capping material assessment; 3.6.1.1.3 Rock Mulch. Matter: Based on information provided in the Rehabilitation Planning Part and the proposed PRCP schedule, it appears that in several Rehabilitation Areas the Rock Mulch will be utilised as the growth media (without the application of topsoil). Limited information is provided to demonstrate the suitability of this material to act as a growth media... Request: Provide an updated PRC plan with further discussion to demonstrate the suitability of the Rock Mulch to act as a growth media for the proposed PMLUs. As above, provide a copy of the technical report by RGS Environmental Consultants Pty Ltd which is referred to in this section.

Applicant repliedAdditional works confirm rocky soil mulch with fertiliser and/or ameliorants expected to provide similar outcomes as growth media application. Technical reports provided as Appendix to PRCP. Demonstration sites of similar methodologies included in PRCP.

Where addressedSection 3.6.1.1 Appendix A

item 7

Request, as quoted by the applicantSection : 3.6.2 Final Landform Design – WRE; 3.6.2.2 WRE Crest; 3.6.8.4 Application of Seed; 3.6.2.7 Sustain the PMLU of Native Habitat. Matter: It is noted that much of the waste rock generated from the operations was Potentially Acid Forming (PAF) material, which is proposed to be permanently stored within the WRE. Hence the cover system is critical to minimising the potential release of contaminants from the WRE. he proposed Store and Release cover system includes the Infiltration Storage Layer which will be comprised of a 1.5m deep application of Rock Mulch intended to act as a growth medium for vegetation… … which is different to the cover design presented by the Land Outcome Document. Further justification is required as to whether the depth of rock mulch layer and the vegetation community to be established on the WRE crest will ensure the ongoing structural integrity of the cover system is not impacted by the influence of plant roots and adequately mitigates against vertical movement of moisture into the encapsulated waste rock. Request: Include further supporting information to justify the changes to the previously proposed cover system design in the PLMUP; Provide information regarding how the proposed cover design mitigates the impacts of all contaminants of concern; Provide permeability testing at locations that are representative of the surface of the WRD and provide modelling based on those tests; Provide a risk assessment of the cover not achieving a stable cond

Applicant repliedMultiple Accounts Analysis for the WRE and cover design has been completed with the approach/outcomes included in the PRCP. Permeability testing results waste rock and borrow material within appended technical study. Further assessment of seed mix and consideration of shrub layer, structural integrity and root depths provided in PRCP and appended technical study. WRE cover design also includes a root barrier layer specifically designed to prevent root penetration. Risk Assessment updated to address the Departments query on stable conditions.

Where addressedSection 3.6.2 Section 3.12.4 Section 3.13.1 Appendix A Appendix C Appendix F

item 8

Request, as quoted by the applicantSection : 3.7 Risk assessment – General. Matter: For most identified risks, limited information has been provided regarding the selection of the relevant treatment options and limited information has been provided regarding the resourcing requirements (both internally and externally) necessary for completing the nominated treatment action/s. Request: Provide additional justification regarding the reasoning for selection of the relevant treatment options. Provide additional information regarding any resourcing requirements (both internally and externally) necessary for completing the nominated treatment action/s.

Applicant repliedRisk Assessment section of PRCP updated and information on treatment options and resourcing requirements

Where addressedSection 3.13

item 9

Request, as quoted by the applicantSection : 3.7 Risk assessment. Matter: The provided risk assessment in Table 17 does not appear to consider risks associated with failure of rehabilitation due to natural events such as drought, floods, storms, fire etc. Request: Ensure the risk assessment includes relevant factors that may impact on the success of rehabilitation. Note that the Monitoring Management Plan will also require updating accordingly to the additional identified risks.

Applicant repliedAdditional risks considered for rehabilitation failure due to natural events included in PRCP—Risk Assessment section including consideration of monitoring and maintenance requirements.

Where addressedSection 3.13 Section 3.14

item 10

Request, as quoted by the applicantSection : 3.7 Risk assessment. Matter: The risk assessment acknowledges a risk that the cover system may not perform as required, however additional information is required to better understand the proposed controls and relevant treatment options that would be implemented to address the potential for the WRE cover to fail or in the event that it does not perform adequately. Request: Provide additional information regarding remedial measures in the risk treatment plan with regards to the potential for the WRE cover to fail.

Applicant repliedAdditional risk and proposed actions for WRE included in PRCP —with specific emphasis on items related to erosion and water flux entering waste.

Where addressedSection 3.13

item 11

Request, as quoted by the applicantSection : 3.8 Monitoring and maintenance Matter: The Monitoring and Maintenance Plan provided is general in nature and does not directly correlate to the RMs included in the proposed PRCP schedule. Request: Provide additional information to explain the relationships between Table 18 and the monitoring and maintenance activities. For example, a comparison of monitoring activities and how they directly relate to the RMs and criteria could be included in the proposed PRC plan.

Applicant repliedMonitoring and Maintenance Plan linkage with milestones provided in PRCPP.

Where addressedSection 3.14

item 12

Request, as quoted by the applicantSection : RA8 – Exploration, Roads and Tracks Native Habitat PMLU (15.7ha); RA9 – Exploration, Roads, tracks and Haul Road Grazing PMLU (24.7ha). Matter: Confirm if the entirety of RA8 and RA9 (as indicated by Figure 017 Lady Loretta Rehabilitation Areas) will be disturbed… Request: Provide an updated PRC plan (including the PRCP Schedule) that - Confirms if the entirety of RA8 and RA9 as presented by the Rehabilitation Area map will be disturbed and require rehabilitation. - Assigns the relevant Rehabilitation Milestone and criteria against RA8 and RA9 to demonstrate rehabilitation of areas disturbed by exploration.

Applicant repliedMapping and PRCP Schedule updated. Rehabilitation Map and areas nominated against Rehabilitation Milestones reflect areas of disturbance.

Where addressedSection 4 Appendix J

item 13

Request, as quoted by the applicantSection : RA10 – Underground Openings – Shafts, decline, portal. Matter: It is acknowledged that RA10 only involves a small area of disturbance (0.6Ha). RM12 applies to this Rehabilitation Area and includes several criteria relevant to vegetation and erosion characteristics. Confirm if any revegetation activities are necessary for RA10 to ensure achievement of RM12 and update the PRCP schedule accordingly Request: Provide an updated PRC plan (including the PRCP Schedule) to confirm if revegetation activities are necessary within RA10 to ensure achievement of RM12.

Applicant repliedConfirmed revegetation activities are necessary within RA10 to ensure achievement of RM12. PRCP Schedule updated.

Where addressedSection 3.10.1 Appendix J