_________________________________________________________________________________________________________ Aughinish Island, Askeaton, Co Limerick – Ireland – Tel. +353 (0)61 604000 – Fax +353(0)61 604242 – www.rusal.com

DIRECTORS: K Bezzubov, D A Clancy, I Firyukov, D Goldberg, D Makarenko, A Shmalenko, K Strunnikov Reg. in Ireland No.59982. Reg. Office: Aughinish Island, Askeaton, Co Limerick, Ireland

6th March 2012

Environmental Protection Agency

Office of Climate, Licensing & Resource Use

EPA Regional Inspectorate P.O. Box 3000

Inniscarra, Johnstown Castle Estate

Co. Cork Co. Wexford

Attn: Ms Sonja Smith Mr.Michael Owens

Ref: IPPC P0035-05 Review of existing IPPC License.

Ms Smith,

Further to Agency letter dated 24th November 2011 from your Mr. Owens to our Mr.Fleming re.

classification of the Bauxite Residue Disposal Area (BRDA) and further to Agency letter dated 28th March

2011 from your Mr. Owens to our Mr. Fleming re. BRDA stability monitoring and compliance with BREF

Management of Tailings 2009, Rusal Aughinish (RA) submit the following

Attachment 1. Describes particular BRDA Design and Operation and particular applicability of some

but not all aspects of the BREF to our BRDA here to emphasise that the BREF cannot prescribe a

one size fits all residue storage regulation.

Attachment 2. Summarises and updates with revised data and information the Aughinish rationale

that the BRDA should be categorised as “NOT Category A”

Attachment 3. Lists the Aughinish BRDA Stability Monitoring Programme and shows why it

complies with BAT as outlined in the BREF.

RA has since the commencement of its operation in 1983 adopted BAT in the form of thickened tailings

technology. Since 2008 we have further enhanced the BRDA operation (over and above any technique

described in the BREF) with the introduction of mud farming using amphirolls, an Australian alumina

industry developed technology. This has significantly enhanced the physical stability of the BRDA by

making the residue denser and stronger and thereby increasing its physical stability.

~ RUSAL...... AnallNI:-i1l

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RA has since July 2011 at a test scale and since January 2012 at a pilot scale introduced atmospheric

carbonation of the bauxite residue. The effect of this carbonation is to reduce the liquid phase alkalinity in

the red mud to ensure that both leachate and runoff from the BRDA pose less chemical risk to the external

environment.

RA has organised recently specific corrosivity testing of bauxite residue and its leachate and the results

indicate that neither bauxite residue nor its leachate is corrosive as defined in the Dangerous Substances

Directive.

In addition in order to enhance the physical stability of the overall BRDA structure and to reduce the risk of

any structural failure, RA has decided not to construct the Upper Level Interceptor Channel (ULIC) at Stage

6 originally designed to facilitate landscaping (see Figure 6.4 of original Breakout Study submitted in 2011).

Golder Associates recently revised the containment failure probability assessment to take account of

eliminating the ULIC and reported that the risk of BRDA containment failure reduces very significantly from

1 in 8,700 years to less than 1 in 400,000 years because the potential for blockage of spillways, overflow

pipes and channels has been consequently removed. As this ULIC feature has not been constructed to date,

that risk does not exist in 2012 but that risk had been accounted for in the 2006 Break-Out Study and

associated Risk Assessment.

Furthermore RA indicates in Appendix 3 the extensive stability monitoring and visual inspections

undertaken in the existing BRDA. The particular instrument monitoring is undertaken on a quarterly basis by

Golder Associates as their recommended frequency. Golder Associates have proposed to Aughinish the

extent and frequency of stability instrument monitoring and site investigation frequency as adequate for

facility management given that the stability risk and in particular that the Aughinish BRDA is a stacked

thickened tailings facility and not a conventional tailings pond.

Please note that the monitoring schedule listed in Table 4.15 page 400 of the BREF was adapted, (not

transcribed) by the original BREF drafting team from ICOLD Bulletin No. 104 “Monitoring of Tailings

Dams”. There is an extensive 14 page description in that bulletin of monitoring parameters for upstream

raised tailings (ponds) dams but lists none for stacked thickened tailings with no water storage. That original

bulletin does not mention or prescribe at all the monitoring frequencies. The BREF Table 4.15 description

also uses the term “typical” and “examples” and should not be regarded as prescriptive.

In conclusion, RusalAughinish contends that:

The proposed categorisation of the BRDA should be “NOT Category A”. The decision to remove the

upper level interceptor channel from the design re-enforces this.

The recommended type and frequency of BRDA stability monitoring tasks and visual inspections is

BAT and in compliance with BREF and is best defined by the judgement of competent independent

geotechnical experts because BREF Table 14.5 should not be interpreted as a one size fits all tailings

stability monitoring schedule.

Yours truly

Thomas Hartney

Consultant Engineer for Aughinish Alumina Ltd.

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Submission regarding Classification& Licensing of the Aughinish BRDA under the

Extractive Waste Directive (2006/21/EC)& EU Decision 2009/337.

Attachments

1. Description of Aughinish residue containment system & relationship toBAT

2. Updates with revised data forRusal Aughinish rationale that „NOT Category A‟ should apply

3. Summary of Aughinish stability monitoring and compliancewith BAT as defined in BREF.

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1.1 Description of Aughinish residue containment system in relation to BREF

In summary the bauxite residue (tailings) containment at Aughinish uses a permeable upstreamstage raise method of construction to retain the residue and has an

interior (rather than perimeter) system of stacked residue deposition. Therefore the 2% sloping surface of the residue from the interior to the perimeter ensures that

water flows off the surface of the residue, drains through the permeable upstream walls and flows downwards into an external surface water collection drain.

Therefore the leachate and rainfall are collected in a ground-level perimeter drainage channel; see Figure 1.1 which is outside the structural containment perimeter of

the residue. There is no storage of water on the existing BRDA. Currently 9 of the 10 permitted stages have been constructed on the Phase 1 BRDA.

Figure 1 .1Aughinish BRDA with structural containment of residue (tailings) shown in yellow.

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Table 1.1 Containment system described in BREF and contrast with scheme at Aughinish

BREF

Section

Heading Description Contrast at Aughinish

2.4.2 Tailings

Dams

Describes tailings ponds with

percent solids 20 to 40%

Thickened tailings consolidated to 70 to

74% solids. Figure 2.26 does not

describe Aughinish‟s thickened tailings.

2.4.2.2 Confining

dam

Permeable Dam (applicable) Retains (confines) the bauxite residue

but facilitates unimpeded drainage of

storm-water and leachate.

2.4.2.4 Removal of

free water

3 systems described in

figures well as overflow

systems

In contrast Aughinish uses totally

permeable stage raised walls to drain all

surface water away.

2.4.2.5 Seepage Flow Figure 2.46 on flat ground Seepage can be removed though the

permeable stage walls. Prevention of

seepage through/near the toe of the inner

wall (that could potentially undermine

conventional tailings dams) is not a

feature of the Aughinish design as the

wall is deliberately highly porous.

2.4.3 Thickened

tailings.

Figure 2.47 represents a

tailings in Australia with

impermeable dams and

decant tower

At Aughinish both walls are porous and

decants are not used as these have the

potential for blocking.

3.1.1.3.1

page 100

Under Figure

3.3 the text

reads

“ In both cases, the tailings

mature to 70% solids”

Since 2002 when that information

transmitted to EU for the BREF, the

residue solids has increased to 74% due

to introduction of mud farming using

“amphirolls”, so therefore it is more

solidified and more stable.

3.1.1.3.3

page 107

Safety and

accident

prevention

Sardinian alumina plant

tailings pond which has an

impermeable upstream wall

(page 105) has monthly

piezometer monitoring and

stability checks twice yearly.

As Aughinish has more stable thickened

tailings which is solidified and hardened

by mud farming, Aughinish has quarterly

monitoring, quarterly stability reviews

and annual stability inspection audit.

4.4.10 Design Flood

for tailings

ponds

These are based on “ponds”

and a low hazard pond would

have a 1 in 100 year flood

design

Aughinish by contrast is a thickened

tailings with no water storage and has a 1

in 200 year flood resistant design.

4.4.14 Monitoring of

Tailings

Extensive description of

types and frequency of

monitoring and inspections

See Attachment 3 below.

4.4.16 Dewatering

of tailings

Describes tailings ponds with

percent solids 20 to 40% and

indicates concerns with

regard to mobility if tailings

structures collapses

Thickened tailings consolidated to 70 to

74% solids; therefore risk of tailings

mobility is significantly reduced.

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Table 1.1 (Continued) Containment system in BREF and contrast with scheme at Aughinish

BREF

Section

Heading Description Contrast at Aughinish

4.4.16.2 Thickened

tailings

Recommended as safer

option compared to slurry

disposal in conventional

tailings ponds.

Aughinish utilises thickened tailings disposal

but has enhanced this with the practise of

mud farming using amphirolls to consolidate

and increase the density of the residue.

4.6.1 Mitigation of

Accidents

Emergency Planning and

Response

Aughinish is accredited to the International

Safety Rating System (ISRS) and to ISO

14001 which addresses this issue and

Aughinish undertakes extensive emergency

planning to deal with such emergencies.

4.6.2 Evaluation

and follow

up of

incidents

Describes requirements Aughinish employs an extensive system of

reporting, investigation and corrective action

follow-up system for both safety related and

environmental related incidents. Causes and

effects of accidents are clearly documented,

the learning outcomes are locked into our

information systems, and that there is follow

up to ensure that future incidents are

prevented.

4.6.3 Tailings pipe

line burst

Detection systems

required

Aughinish employs online pressure

monitoring, flow rate meter and density

monitoring and all report directly to the

relevant control room, so any pipeline failure

would be automatically detected by the

control room operator. However as the

scaling rate and wear rate of critical parts of

the pipe line is also monitored as part of the

Non Destructive Examination system at

Aughinish, pipe-line failure through rupture

would be a highly improbable event.

4.7 EMS tools Aughinish EMS is certified to ISO 140001.

5.2 BAT

Generic

Implementation of BAT

for Residue Disposal at

Aughinish was listed in

Appendix C of original

submission to Agency in

February 2011.

In addition to the original submission,

Aughinish has since July 2011 on a trial scale

and since January 2011 on a pilot scale

implemented atmospheric carbonation of

bauxite residue.

Residue carbonation will ensure that the

leachate and runoff generated will be more

benign than the un-treated leachate and

runoff.

BAT page 429 of BREF “is to neutralise

alkaline effluents with carbon dioxide.”

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Attachment 2.0 Update of Rusal Aughinish rationale for classification as ‘NOT Category A’

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2.0 Update on why ‘Not Category A should apply to Aughinish BRDA

The previous submission to the Agency in February 2011 in relation to classification of the BRDA facility listed every relevant article and sub-article with EU

Decision 2009/337 and listed the Aughinish BRDA performance in relation to the classification criteria. The submission listed issues in relation to the risk and

consequences of containment failure as well as characterising the residue in relation to the Hazardous Waste Directive and Dangerous Substances Directives. The

original Aughinish Assessment is still valid but particular aspects will be updated (see Table 2.1) and the previous 2011 Summary Table submitted is now updated,

see Table 2.2 below.

RA respond as follows to Agency letter dated 24th November 2011 which listed as an event “containment failure” that could cause a major accident leading to

1. non-negligible potential for loss of life OR

2. serious danger to human health OR

3. serious danger to the environment

Issue Factor determining Aughinish revised response

Containment

failure Risk of that event

In light of the Agencies intention expressed in the letter of 24th November last, Aughinish and Golder

Associates have reviewed aspects of the Phase 1 and 2 BRDA which could lead to increased risk of

“containment failure”. RA has decided not to construct the Upper Level Interceptor Channel (ULIC) described

in the 2004 Design Report and in the related Breakout Study and Risk Assessment. This has removed the risk of

water storage at height due to blockages of the culverts. The presence of water would increase the risk of mud

mobility. By removing the ULIC the risk of red mud release reduces from 1.14 E-04 to 2.46 E-06. Therefore the

risk of failure has reduced from „Highly Unlikely‟ to less than „Highly Improbable‟. See attached Event Tree

Figures 2.1 & 2.2 replacing original Figures 8.1 & 8.2 in the original 2006 Breakout Study. The risk of failure

in Sector D near the Water Treatment Plant has reduced to 2.90 E-08.

non-negligible

potential for

loss of life

Human lives are threatened

where slurry levels exceed 0.7

metres

The thickened tailings that are pumped to the BRDA are quickly consolidated and strengthened using the mud

farming “amphiroll”, see figure 2.1 attached. Therefore over the majority of the BRDA, the cross sectional

depth does not contain slurry but compacted and strengthened solid residue. The compacted residue is capable

of supporting all common types of excavation plant as well as 4 wheel drive vehicles. Therefore the well farmed

residue is no longer slurry and will not readily flow out of the BRDA. Currently there is no public or third party

access to land outside the BRDA perimeter where any mud slurry from containment failure could flow to and

impact on human life.

non-negligible

potential for

loss of life

Human lives are threatened

where water levels exceed 0.7

metres

The decision not to construct the Upper Level Interceptor Channel described above will also remove the risk of

water levels exceeding 0.7 metres. This risk previously existed in the event that a culvert or spillway became

blocked. That original risk was assessed as 6.28 E-05 and is now reduced to zero by eliminating that ULIC from

the design. Currently there is no public or third party access to land outside the BRDA perimeter where runoff

water from the BRDA by containment failure could flow to and impact on human life.

serious danger

to the

environment

Intensity of the potential

contaminant source strength is

(NOT) decreasing significantly

within a short time

The bauxite residue and red mud leachate has been recently classified as Not Corrosive following specialist

laboratory testing in compliance with the Dangerous Substances Directive, see Table 2.3. In addition, Rusal

Aughinish has commenced atmospheric carbonation of the bauxite residue and therefore the risk of alkaline

contamination in both runoff and leachate will significantly decrease.

Table 2.1 Particular Response on Highly Improbable “containment failure” scenario”

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Issue Comment Conclusion

Risk of Structural

Integrity Failure

The annualised risk has been calculated at 2.46E-06 which is in

the „Highly Improbable‟ range especially given that the

remaining life of the BRDA is estimated to be just another 20

years until 2032.

This would not

trigger Category A

classification.

Potential for loss of

life or danger to

health

No members of the public are exposed to the residue as the

current BRDA is lower than either the public road, local

authority water treatment plant or the nature trails?

This would not

trigger Category A

classification.

Potential for serious

danger to the

environment

BRDA complies with all relevant aspects of BAT. Atmospheric

Carbonation reduces the liquid phase alkalinity. In the „Highly

Improbable‟ event of a failure, any remaining caustic leachate

from Bauxite Residue released to the environment would be

neutralised and buffered by the saline tidal estuary and the

brackish groundwater.

This would not

trigger Category A

classification.

Water and slurry

levels exceeding 0.7

metres above ground.

There is no water stored on the tailings because RA thickens

and stacks mud at a slope in contrast to the conventional

tailings ponds. Therefore there is no risk of water storage at

high levels.

Mud layers are constantly consolidated, dried and strengthened

by the mud farming technology. The strengthened and

hardened residue is capable of supporting all common types of

excavation plant as well as 4 wheel drive vehicles. Therefore

the well farmed residue is no longer slurry and will not readily

flow out of the BRDA. Currently there is no public or third

party access to land outside the BRDA perimeter where any

mud slurry from containment failure could flow to and impact

on human life.

Category A

classification not

triggered

Water and slurry

velocities exceed

0.5m/s

There is no water stored on the residue and therefore no water

velocity is generated. The absence of water on the residue

makes it extremely difficult for consolidated and hardened

residue to be mobilised. Currently there is no public or third

party access to land outside the BRDA perimeter where runoff

water from the BRDA by containment failure could flow to and

impact on human life

Category A

classification not

triggered

Hazardous Waste

content at end life

exceeding 5%.

The current hazardous waste salt cake 010307 represents just

over 1.5% of the total residue.

Red mud code 010309 is classified as Non Hazardous within

the EWC. And the recent laboratory analysis of bauxite residue

as Non Corrosive confirms that Aughinish‟s red mud is NOT

classified as Hazardous Waste

This would not

trigger Category A

classification.

Dangerous

Substances content

aqueous phase

during operation of

Facility

Recent testing has confirmed that bauxite residue and

associated leachate is Non Corrosive and therefore it will not

be classified within the Dangerous Substances Directives., see

extracts listed in Table 2.3

This would not

trigger Category A

classification.

Table 2.2 Update of Previous 2011 Submission Summary

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Figure 2.1 Amphiroll faming and subsequent Bulldozer Operations on solid residue at Aughinish

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Table 2.3(1) Recent Corrosivity Testing indicates bauxite residue after amphirolling as Non Corrosive

COMP CTED RED MUD AFTER..MPHIROLLI G

Stld °20110252TC I CS MMARY

The aim of the study was to assess the skin corrosion potential of COMPACTED RED MUD AFTERAMPHIROLLING using an if! vitro skin corrosion model based on reconstructe{j human skin.Firstly, a preliminary study was performed to identitY the possible interference between MTT and testitem. In a second phase, the main study involved 15 reconstruc.ted epidermis units (3 per group) asdescribe{j below:

In Vh.ro Skin Corrosion: HU111an SkinModel Test

(OCDE 431

BlllJ.gy, ;'j.-farch ':"'0, 01-

Table t Treatment design

Groups l'.umbco< DrreeD 5tlucte:d

~pidermis. unilSTe:stitemlest item

Negative comml

N~ti\"econuol

Positive control

ConcmtratlCln lO be[~5ted

undiluted

undilDted0.9%0.9%

undih.ned

Ex:P05U~ nme

.3 minute.sI hour

3 minutesI hour

.3 minute.s

SPO SOR:Rus:3l1 ALlghinish AluminaAughinish .A.lumina LimitedAughinish ]slandAsk.~-aton

Co. LimerickIRELAND

Test item and negati\'e control were applied topically for 3 minutes and I hour and positive control wasapplied for 3 minutes to a three-dimensional human skin model. After rinsing of tissues, assay mediumwas replaced by MTT-medium. Following 3 hours incubation. the formed blue fomlazan sa.lt wasextracted with isopropanol and the optical density was determined spectrophotometrically at 550nm ±10 nm. The optic.al density values obtained for each group were used to calculate the percentage of cellviability and consequently to classify the test item as corrosive or non-corrosive.

RemIts:Preliminar~' study:Since MTT solution, did not tum blueJpurple when in contact with the test item for I hour (step I),no interference between \iTT and test item was concluded. For this reason, the. second step of thepreliminary study was not undertaken.. bin .tudy:After 3 minutes of treatment, the positive control item showed a cell viability percentage 12.4%. Asexpected and according to the OECD Guideline No.431, the positive control item was c1assitie{j ascorrosive. This result validated the ongoing sensitivit}' of the method used.After 3 minutes and I hour of treatment with the undiluted test item, the percentage of cell viabilitywas 100% in both cases.

Under the experimental conditions adopted, COMPACTED RED MUD AFTERA.\tPHIROLLI[liG was classified as non-curro.h·e on the Skin Ethic human reconstructedepidermis.

HI:SH 'G FACIUCentre de Recherches. Biologiques CERB)Chemin de ~ontifault

18800 B:3ILlgyFlianc.e AUDITED DRAFT RELEASE I GLP Primed date: lIt/arch 20, 2012

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Table 2.3(2) Recent Corrosivity Testing indicates red mud leachate & carbonated red mud as Non Corrosive

CERB REPORT 20110254TClX

SUMMARY

Page 8 on CERB REPORT 20110250TCUC

SUMMARY

Page 8 of2

The aim or the study wa, 10 assei' the 'kin corrosion potential or RED MUD LEACIIATE FROMBRDA PERIMETER using an in "llro skin corrosion model ba'ed on reconstructed human 'kin.Fimly, • preliminary 'tudy wa, performed to iden,ify Il,e pOiSible interference between MIT .nd teititem. In a 'econd phase, Il,e main 'tudy in\'olved 15 rec.an'truc,ed epidermis unit> (3 per group) asdeseri bed below,

The aim of ,he stud)' was to assess Ihe skin corrosion pOlential of COMPACTED RED M DAFTER

FARMING/CARBONATION using an In vitro skin corrosion model based on reconstructed humanskin.Firstly, a preliminary study was performed to identify the possible interference between MTT and testi'em. In a second phase, the main study involved 15 leconstructed epidemtis unil< (3 per group) asdescribed in Table 1.1, page 14.

Tahle I Treatment design

;)\un.lber 0:~COllSlruCled

eflbdemlisu"ttsT.estit.cmTest jl~rn

l'\egl1l:i\'c oontrOlPOilti\'~ conool

Concemration tLJ. bemood

t1ndnut.ed

0.9%0.9%

t1ndi ted

EXpOrufi! time

I hour

I hour

Table I

Groups

Treatment design

~umtxrof

rec()nstruc:tedepidermis units

Trc:a.tment

TCSlitcm

TCSlitcm

Nceativc controlNegative control

Positive control

Concenrration [0 be:le5(~d

undilutedundiluted

0.9%0.9%

undiluted

E:x:po.5ure time:

3 minutes

1 hour3 minutes

1 hour

3 minutes

Te;t item .and negative conU'OI were applied topiCally for 3 minme; and I hour and posjt~\"e conU'OI wasapplied for 3 minmes to a three-dimensional human ;kin modeL After rinsing ofti;sues, ass.ay medjumwas ,"placed by MTT-medium. Following 3 hours incubation, the blue formazan <alt fom'ed waseXU'acled with isopropanol .nd the op,ical densi,y was detennined spectrophotometrically a, 550nm ±10 nm. The optical densi'y values obtained for Mch g'oup we,e used '0 calcul.,e the perc"ntage of cellviab.lity and c.onsequently to cla;sify the I.e;t item as corrosive or non-corrosive.

Results:Prellmlna,")" study:Since MTT solUlion did nOl turn blue/purple when in contac, with Ille teS! ilem fo' I hour ('tep I),no interference between MTT and le;t item was concluded_ For this re-3son., the second Sltep of theprelimin.ry <ludy w", not undertaken.

~lajll study:After 3 minu,e, of "eatment, the positive control item showed a c,,11 viability percentage of 1204%.A' expected and .cc.arding to the OECD Guideline, 0.431, Il,e positive control i,em was classified ascorrosive. This result \ lidated the ongoing sensiti iry of the method u;ed.After J minute,; and I hour of treatment with the undiluted teSI item, the percentage of ceU viabilityw'as 100% i.n both cases.

Test item and negative control we," applied topically for 3 minutes and I hour and positive control wasapplied for 3 minutes 10 a three-dimensional human skin model. After rinsing of tissues, assay mediumwas replaced by },1TT-medium. Following 3 hours incubation, the blue ormazan salt formed wasextracted with isopropanol and the optical density was determined spectrophotometrically at 550nm =10 nm. The. optical density values obtained for each group were used to calculate the percentage ofcellviability and consequeml)f to classify the lest ilem as corrosive or non·corrosive.

Re.ults:Preliminary stUd)':Since MTT solution did not tum blue/purple when in contact with the te<l item for I hour (step I),

no interference between ~ITT and test item was concluded. For this reason, the second step of 'hepreliminary study was not undertaken.i\lain study:After 3 minutes of trealmem, the positive control item sho\ved a cell viabiliry percentage of 12.4%.

As expected and according to 'he OECD Guideline No.43 I, the positive control item was classified ascorrosive. This result validated the ongoing sensitivity o"'lhe method used.Afler 3 minutes and I hour of treatment with the undiluted tesl item, the percentage of cell viabilitywas 100% in both cases.

Under the experimental eondltJeH15 adopted, RED ~'IUD LEACIIATE FRO'. ORDAPERnlETER was classified as non-eorroslw on tlle SkJnEthle human reconstrueled eplderml'.

AUDITED DRAFT RELEASE I GLP PrlnlM dat": Marrh 20. 2012

Under the e.perimental condition. adopted, CO IPACTED RED MUD AFTERFAR)II 'G/CARBONATIO:-; was classified as non-corro''''e on the SkinEthic human re­

constructed epidermis.

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Figure 2.1 Revisions to original Breakout Study Figure 8.1 with Upper Level Interceptor Channel Removed.

UOE-ollSo,..

~.

~,

1 E_'::,O'"",, I--~I...,,« ~,.,

~, '"

1':::=1 E""'''''OI1.. 11 St.tlQ 1-•.- 1..• l ......act""

U$E-03 UIOE~t .48E~ $.OOE~3

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FIGURE 8.1

BRDA FAULT TREE: SECTORS A, B, C & F

UPPER PERIMETER INTERCEPTOR CHANNEL REMOVED

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Figure 2.2 Revisions to original Breakout Study Figure 8.2 with Upper Level Interceptor Channel Removed Sector D adjacent to Limerick County Council

Water Treatment Plant

--­"""''''''''BROA

FIGURE 8.2

BRDA FAULT TREE: SECTORS 0 & E

UPPER PERIMETER INTERCEPTOR CHANNEL REMOVED

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Attachment 3 BRDA Stability Monitoring.

3.1 Aughinish BRDA Stability Monitoring.

The stability monitoring function for the Aughinish BRDA has been contracted out to Golder Associates.

The function is implemented by the following

Quarterly (3 monthly) monitoring of existing instruments Table 3.1 installed in the BRDA

Periodic site investigation using a mobile rig comprising Cone Penetration Testing (CPT) , and

residue sampling, see typical schedule of tests in Table 3.2

Quarterly review of that instrument monitoring data

Annual inspection of the BRDA , see Table 3.3

Compilation and assessment of all relevant stability data on an annual basis

Table 3.1 Existing Stability Monitoring Instruments in the Phase1 BRDA.

Site Investigation Tasks Laboratory Analysis

Cone Penetration Test (CPT) cone penetration

resistance with depth of the red mud

Mostap undisturbed sampling of red mud; and

Installation of push in standpipe piezometers.

Natural Moisture Content

Plasticity Index

Density

Undrained Triaxial Tests

Table 3.2 Planned Site Investigation & Laboratory Analysis of BRDA residue.

Inclinometers

Magnetic

Extensometers

Vibrating Wire

Piezometers

Cassegrande

Standpipes

Push -in CPT

Standpipes

1 1AIL 1AIL FGPZ 3c 1APL APT 11A

2 1AIU 1AIU FGPZ 7a 1APU AAT12A

3 1BIL 2AIL FGPZ 7c 2APL AAT 14A

4 1BIU 2AIU FGPZ 8d 2APU CPT 1

5 2AIL 3AIL FGPZ 12a 3APL APT 1A

6 2AIU 3AIU FGPZ 13a 3APU APT 3A

7 2BIL 4AIL 4APL CPT 4A

8 2BIU 4AIU 4APU

9 3AIL 5AIL 5APL

10 3AIU 5AIU 5APU

11 3BIL 6AIL 6APL

12 3BIU 6AIU 6APU

13 4AIL 7AIL 7APL

14 4AIU 8AIL 8APL

15 4BIL 1BIU

16 4BIU 2BIU

17 5AIL

18 5AIU

19 5BI

20 6AIL

21 6AIU

22 6BIL

23 6BIU

24 7AIL

25 7BI

26 8AIL

27 8BI

28 9BIL

29 9BIU

Total 29 16 6 14 7

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Task Frequency

Stability Instrument Monitoring Quarterly

Data Review Quarterly

Annual Inspection & Review Annually

CPT rig Site Investigation Phase 1 BRDA prior to Stage 10 During 2013

First CPT Site Investigation in Phase 2 BRDA to avoid probe

penetration damage to the composite liner. At Stage 3 raise residue filling

Subsequent CPT Site Investigations in Phase 2 BRDA (as all static

stability parameters already derived from Phase 1 BRDA)

Every Second stage raise i.e.

Stage 5

Stage 7

Stage 9

Table 3.3 Golder Associates frequency of stability monitoring and assessments

Task Frequency

Daily inspection by BRDA Supervisor Daily

Weekly inspections of BRDA equipment by operators Weekly

General conditions inspections by Aughinish engineer Monthly

Environmental monitoring around perimeter of BRDA , dust deposition

, ground water and surface water sampling Monthly

Table 3.4 Rusal Aughinish frequency of Logged Visual Inspections & Environmental Sampling

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BAT requirement Section 5.2

page 432

Apply Reason for Aughinish position

BAT is to monitor in a tailings

pond/dam (Section 4.4.14.2) YES

BRDA is a thickened tailings stack and is not a pond. The Inner Wall and the current 9 upstream stages raise walls to date

comprise the overall Dam Walls

The water level NO Water level cannot be measured as water not stored on or inside the dam

Quality and quantity of seepage

flow through the dam (also

section 4.4.12) NO Seepage through the dam cannot be measured or sampled as dam wall design is totally porous, and does not retain seepage

position of the phreatic surface YES Position of Phreatic Surface in the bauxite residue is measured

Pore pressure YES Static pore pressures are measured

Movement of the dam crest and

tailings YES Movement of tailings is measured using inclinometers and extensometers

Seismicity to ensure stability of

the dam and the supporting

strata NO

Seismicity is not measured by active instruments but issue has been assessed in the Breakout Study and annual risk of

trigger earthquake listed as 1 in 95,000 years

Dynamic pore pressure and

liquefaction NO

Dynamic pore pressures and liquefaction are not considered relevant because of the low incidence and magnitude of

earthquakes at the site as stated above. The design report comprehensively evaluates the potential for residue bauxite to

liquefy and CPT testing is undertaken to assess the increase in strength and density of the material with time and stress

level. The probability of both dynamic and static liquefaction has been calculated in the Breakout Study

Soil mechanics YES Soil Mechanics Penetrometers ,i.e. the Cone Penetration Testing Rig are used periodically at Aughinish prior to

construction of upstream raise walls

Tailings placement procedures YES Tailings Placement Procedures are applied but Aughinish are specifically drafted for thickened tailings, upstream

construction and mud farming and not for the tailings “ponds” as outlined in the text of the ICOLD bulletin 104

undertake for tailings pond/dam

Visual inspections

YES

Visual Inspections are undertaken and Aughinish uses a system of daily, weekly and monthly check sheets on our

computerised Business Performance Improvement System & inputted by the relevant operators, supervisor and engineer.

Annual reviews YES Golder Associates undertake both quarterly and annual reviews

Independent audits YES Golder Associates are independent specialists & undertake the audits, their analysis are internally peer reviewed. Golder

and the BRDA design has also been peer reviewed by SLR on behalf of the Agency in 2004/05 and 2008

Safety evaluations of existing

dams (SEED) YES

SEED In 2004 the Golder Associates design and geotechnical assessment of the BRDA was peer reviewed by SLR on

behalf of the Agency (Licensing). Again in 2008, the Agency (Enforcement) asked SLR to review the Golder Design in the

context of Condition 8.3.5 Essentially SLR have peer reviewed Golder‟s Design and also the Breakout Study and that

accounts as SEED

BREF table 4.15 page 400 & Section 5.2 Monitoring Stability page 432 is adapted (not transcribed) from ICOLD BULLETIN No. 104 “Monitoring of Tailings Dams “1996 and between

pages 21 and 49 for upstream raised tailings ponds and not for thickened tailings with porous dam design. There are no monitoring frequencies prescribed in this ICOLD documents

even for tailings ponds. Monitoring tasks and frequencies should be based on the judgement of the competent independent geotechnical experts. BREF cannot be prescriptive.

Table 3.5 Aughinish performance versus BREF BAT Section 5.2 page 432

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Assessment

Type

Aughinish

Frequency

Personnel Aughinish Justification

Visual

Inspections

Daily, weekly and

monthly

Aughinish

personnel with

BRDA related

responsibilities &

experience.

Aughinish use a system of daily and weekly

check sheets on our computerised Business

Performance Improvement System which are

filled in by the relevant operators,

supervisors (facilitators) and engineers.

Instrument

Monitoring

Quarterly Golder Associates Quarterly frequency is justified because

Aughinish BRDA is a compacted thickened

tailings and not a tailings pond.

Soil Mechanics

Penetrometers

using CPT rig

Only before every

second upstream

stage raise

constructed from

filled Stage 3 Raise

onwards in Phase 2

BRDA

Golder Associates

supervising CPT

rig sub-contractor.

Comprehensive data already collected in

Phase 1 BRDA and CPT rig cannot

commence below stage 3 in Phase 2 BRDA

to avoid damaging composite lining. The

frequency reflects Golder Associates

judgement based on the consolidated and

strengthened red mud data already assessed

in the Phase 1 BRDA and because no

dynamic pore pressures is observed in

consolidated red mud.

Data review Quarterly Golder Associates Quarterly frequency is justified because

Aughinish BRDA is a consolidated thickened

tailings and not a tailings pond.

Annual

Inspection and

Review

Yearly Golder Associates Aughinish have contracted service to Golder

Associates to undertake annual inspection

and review which involves detailed site

inspection and collation of all quarterly

monitoring and site investigation data.

Independent

Audit

Bi-annual Golder Associates Golder Associates stability reports are peer

reviewed by appropriate experts within that

organization which is equivalent to

independent audits.

In addition SLR on behalf of the Agency

have peer reviewed the Aughinish design on

at least two occasions.

(SEED) Safety

Evaluation of

Existing Dams

15 to 20 years Team of

Independent

experts

In 2004 the Golder Associates design and

geotechnical assessment of the BRDA was

peer reviewed by SLR on behalf of the

Agency (Licensing). Again in 2008, the

Agency (Enforcement) contracted SLR to

review the Golder Design in the context of

Condition 8.3.5. Essentially SLR have peer

reviewed Golders Design and Breakout

Study and that should provide the assurance

required by the Agency. As indicated above

all major Golder assessments are peer

reviewed. In addition GolderAssociates have

submitted in 2006 a Breakout Study for the

BRDA. Therefore Aughinish contend that the

proposed frequency of 20 years is adequate.

Table 3.6 BREF Table 4.15 & 4.17 & justification Aughinish frequency monitoring, inspections and

audits.

In conclusion Rusal Aughnish practice already complies extensively with BAT requirement in relation to

stability monitoring of the BRDA.

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