2019 mining management plan beatrice project els 24291 ... · the beatrice project, comprising...

Alligator Energy Ltd ACN 140575604

2019 MINING MANAGEMENT PLAN BEATRICE PROJECT

ELs 24291 & 26796 Authorisation 0853.01

June 2019, Rev 0

2019 Mining Management Plan Beatrice Project ELs 24291 & 26796 Authorisation 0853.01 Alligator Energy Ltd

Document Control

June 2019, Rev 0 ALLIGATOR ENERGY LTD

Page i

Job Details

Document Title:

2019 Mining Management Plan Beatrice Project ELs 24291 & 26796 Authorisation 0853.01

Operator:

Alligator Energy Ltd

Document Status

Revision Description Date Reviewer

0 2019 MMP Beatrice Project June 2019 AJ/PM

Distribution Record

Destination

Rev0 Rev1 Rev2 Rev3

Department of Primary Industry and Resources, NT

1 hard copy & 1 Digital copy -

Northern Land Council, NT 1 hard copy & 1 Digital copy -

Office of Supervising Scientist, NT 1 hard copy & 1 Digital copy -

Alligator Energy website (www.alligatorenergy.com.au

-

All copies provided to DPIR for distribution to NLC and OSS

Document Approval

Approved By

Name

Pete Moorhouse

Date

21 June 2019

Signature

signed

Copyright © These materials or parts of them may not be reproduced in any form, by any method, for any purpose except with written permission from Alligator Energy Ltd.


Table of Contents


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1. Operator Details 1 1.1 Name and Contacts 1 1.2 Organisational Structure 1 1.3 Workforce 2 2. Identified Stakeholders and Consultation 2 2.1 Stakeholders 2 2.2 Consultation 2 3. Project Details 3 3.1 Project Name and Location 3 3.2 Mining Interests 3 3.3 Previous Activities and Current Status 3 3.3.1 History of Exploration 3 3.3.2 Previous 12 Months Exploration 6 3.4 Proposed Activities 2019 Field Season 7 4. Current Project Site Conditions 8 4.1 Land Area Type 8 4.2 Hydrology 8 4.3 Flora & Fauna 9 4.4 Current Land Use 9 4.5 Historical, Aboriginal and Heritage Sites 10 5. Environmental Management System 10 5.1 Environmental Policy and Responsibilities 10 5.1.1 Environmental Policy 10 5.2 Statutory and Non-Statutory Requirements 12 5.2.1 Statutory Requirements 12 5.2.1.1 Northern Territory 12 5.2.1.2 Commonwealth 12 5.2.1.3 Other 12 5.2.2 Non Statutory Requirements 13 5.3 Induction and Training 13 5.4 Identification of Environmental Aspects and Impacts 13 5.4.1 Environmental Aspects and Impacts 13 5.4.2 Environmental Management Plan 16 5.4.2.1 Overview 16 5.4.2.2 Water Management 17 5.4.2.3 Weed Management Plan 17 5.4.2.4 Flora & Fauna Management 18 5.4.2.5 Waste Management 20 5.4.2.6 Noise & Air Quality Management 20 5.4.2.7 Cultural & Heritage Management 21 5.4.2.8 Hazardous Material & Hydrocarbons Management (not Radiation) 21 5.4.2.9 Radiation Management 22 5.5 Environmental Audits, Inspections and Monitoring 25 5.5.1 Audits and Inspections 25 5.5.2 Monitoring 26 5.6 Environmental Performance 29 5.6.1 Objective and Targets 29 5.6.2 Performance Reporting 31 5.6.2.1 Radiation Monitoring Results Summary 2018 31 5.6.2.2 Water Monitoring Results 29 5.6.2.3 Rehabilitation Monitoring Results 30 5.6.2.4 Hydrocarbon Monitoring Results 33


Table of Contents


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5.6.2.5 Waste Monitoring Results 33 5.6.2.6 Weed Monitoring Results 33 5.6.2.7 Internal Alligator Energy Audits 31 5.6.2.8 Annual OSS Environmental Audit 31 5.7 Emergency Procedures and Incident Reporting 34 6.0 Exploration Rehabilitation 35 6.1 Exploration Rehabilitation Register 35 6.1.1 Rehabilitation Methods 35 6.1.2 Rehabilitation Status 38

FIGURES

Figure 1 Project Location Plan Figure 3 Myra Camp Layout TABLES

Table 1: Alligator Energy Contact Details Table 2: Anticipated Work Schedule 2019 Table 3: Environmental Aspects and Impacts Table 4: Radiation Risk and Mitigation Matrix Table 5: Monitoring Program Table 6: Radiation Monitoring Schedule Table 7: Description of Rehabilitation Methods APPENDICES

Appendix 2 Environmental and other Company Policies Appendix 3 Extract from the Northern Territory Parks and Conservation Master Plan 2005 and NR Maps Appendix 4 Radiation Management Plan


Ammendments


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The following table summarises the content changes between the approved 2018 Rev 0 MMP and this 2019 MMP.

Section Amendment

General Update of MMP version and date in footers and title page

Document Control Update to Document Status, Distribution Record and Document Approval (Page i)

Table of Contents Update page numbering (Pages ii & iii)

Amendments Insert Amendments table (Page iv)

Section 1.3 Workforce Delete reference to drilling program & updated anticipated workforce/staff numbers (Page 2)

Section 2.2 Consultation Update Work Program meeting date (Page 2)

Section 3..3.1 History of Exploration Added 2017-2018 work completed (Page 6)

Section 3.3.2 Previous 12 Months Exploration Replaces details 2017 field season exploration with details of 2018 field season (Page 6)

Section 3.4 Proposed Activities 2019 Field Season

Replaces proposed 2018 activities with proposed 2019 activities including Figure 2 – 2019 Proposed Work Areas and Table 2 – Anticipated Work Schedule (Pages 6-7)

Section 5.4.2.3 Weed Management Plan Note in final paragraph that weed management not required at BT during 2019 but was conducted on TCC tenements in April 2019 (Page 17)

Section 5.4.2.7 Cultural & Heritage Management

Note in final paragraph that training will be provided in 2019 as necessary (Page 19)

Section 5.5.1 Audits and Inspections Note in a limited external audit was conducted by DPIR and OSS in 2018 (Page 24)

Section 5.6.2.1 Radiation Monitoring Results Summary 2018

Note that Monitoring specific to TCC during 2018 and amended summary (Page 29)

Section 5.6.2.2 Water Monitoring Results Replaces results for 2017 for results for 2018. (Page 29)

Section 5.6.2.3 Rehabilitation Monitoring Note added highlighting no ground disturbance during 2018 (Page 30)

Section 5.6.2.4 Hydrocarbon Monitoring Results

Note added highlighting no requirement during 2018 (Page 30)

Section 5.6.2.5 Waste Monitoring Results Provides updated information for 2018 (Page 30)

Section 5.6.2.6 Weed Monitoring Results Update to provide relevance to 2018 (Page 31)

Section 5.6.2.7 Internal Alligator Energy Audits

Update to provide relevance to 2018 (Page 31)

Section 5.6.2.8 Annual OSS Environmental Audit

Update to provide relevance to 2018 (Pages 31)

Section 6.1.2 Rehabilitation Status Update to include reference to 2018 activities


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1. Operator Details

1.1 Name and Contacts

The operator of the Beatrice Project is Alligator Energy Limited (Alligator Energy) ACN 140575604. Alligator Energy is an ASX listed company focussed on exploration for world class uranium deposits in the Alligator Rivers Terrane. The company is based in Brisbane and is Australian owned and controlled.

Key contact details for Alligator Energy personnel managing the Beatrice Project are provided in Table 1 below:

Table 1: Alligator Energy Contact Details

Street Address Brisbane Office:

Suite 3, 36 Agnes Street, Fortitude Valley QLD 4006

Postal Address Brisbane Office: PO Box 338, Spring Hill QLD 4004

Phone:

Brisbane office: (07) 3852 4712 (Business Hours)

Peter Moorhouse (07) 3852 4712 (Business Hours)

Fax and Email: Brisbane office: (07) 3852 5684 [email protected] Key Personnel Peter Moorhouse – Exploration Manager - [email protected]

Robert Lightfoot – Senior Project Geologist – [email protected]

1.2 Organisational Structure

An Organisational Chart for Alligator Energy is provided below:

mailto:[email protected]


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1.3 Workforce

The average number of personnel within the project area at any one time during busiest period of the field season is expected to be between 6 and 12 assuming a full work program can be financed. Initially, a workforce of up to 6 Alligator Energy field personal will be deployed during Phase 1 of the 2019 program. If Phase 2 progresses, personnel numbers will increase. Contractor numbers will vary but could average 6-10 people, typically geophysical and helicopter contractors during the later phase. For work items during different phases, refer to the work program in section 3.4.

Alligator Energy has a policy to employ local Traditional Owners where possible. Employment arrangements will be flexible so that local employees can attend to their community and cultural obligations. Employment opportunities will include Cultural and Environment Monitors (CEMs) and Exploration Field Assistants. Training will be provided as required.

2. Identified Stakeholders and Consultation

2.1 Stakeholders

The following people and organisations have an interest in, or may be affected by the project and its activities:

Aboriginal Traditional Owners

DEMED Association, Gunbalanya, and regional ranger groups;

Northern Land Council, including Caring for Country branch;

Department of Land Resource Management (Weeds and Bushfires NT);

Bush Fires Council

Department of Primary Industry and Resources;

Office of the Supervising Scientist Division (OSS).

Warddeken Land Management

NT WorkSafe.

Alligator Energy Ltd (current holder & operator of project ELs)

2.2 Consultation

The primary stakeholders are the Aboriginal Traditional Owners. In accordance with the requirements of the Aboriginal Land Rights Act, Alligator Energy is required to enter into a Deed with the Traditional Owners prior to an Exploration Licence being granted. As a component of this process, thorough anthropological surveys are conducted prior to grant of title with identified no-go zones excised from the licence area upon grant. In the case of the Beatrice tenements, Alligator Energy, as signatory to the JV and operator of the tenements, is obliged to meet the obligations contained in the Exploration Agreement between Cameco Australia and the NLC.

Prior to field work commencing, Work Area Clearance meetings are held with Traditional Owners a n d representatives o f the NLC. At these meetings, Traditional Owners are presented with the proposed exploration program and their permission is sought for Alligator Energy to proceed. The Work Program for the 2019 field is to be proposed at a work program meeting with relevant Traditional Owners and the NLC on 19th June 2019. The work program proposed was approved at that meeting. Additional anthropological and archaeological clearances of work areas are conducted as necessary prior to work commencing. There are no current requirements for any additional surveys for the approved work program.

Ongoing consultation with Traditional Owners is undertaken with guidance from NLC field officers and with local


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organisations such as Warddeken Land Management or similar relevant agencies. For example, Alligator Energy liaises with Warddeken Land Management in relation to weed management programs in the region and the implementation of programs.

3. Project Details

3.1 Project Name and Location

The Beatrice Project, comprising Exploration Licences (ELs) 24291 and 26796, is operated by Alligator Energy Ltd.

Cameco entered a Joint Venture agreement with Alligator Energy Limited (Alligator Energy) on 18 December 2014 for

uranium exploration on the Beatrice tenements. As of April 2018 Alligator has acquired Cameco’s remaining interest in the

venture to hold project 100% outright.

Alligator Energy is an ASX listed company focussed on exploration for world class uranium deposits in the Alligator Rivers

Terrane. The company is based in Brisbane and is Australian owned and controlled. Alligator Energy Ltd is the operator. A nomination of operator form has been previously lodged with DPIR.

The project area is about 260 km east of Darwin and 45 km east of Jabiru.(refer Map Sheets: 1:250,000: Alligator River (SD-5301), 1:100,000: Howship (SD-5572), 1:50,000: Mount Howship (5572-4) and attached Figure 1: Project Location Plan).

The project area is managed from the Alligator Energy operated Myra Camp which is located approximately 20 kilometres to the north of EL 24292. The camp was established in the late 1980’s on the Tin Camp Project EL 24922 and has served as an exploration base camp for a number of explorers, most recently Cameco Australia Pty Ltd. The location of the camp and the camp layout is shown on Figure 1: Project Location Plan and Figure 3: Myra Camp Layout respectively.

3.2 Mining Interests

The Beatrice Project area comprises ELs 24291 and 26796 which were originally granted on 04 July 2008 for a tenure period of six years. At the time of grant, the total area covered by the two licences was 356.99 km2 (131 sub-blocks), comprising 337.21 km2 (121 sub-blocks) on EL 24291 and 19.78 km2 (10 sub-blocks) on EL 26796. Renewal applications for both ELs were lodged in 2014, 2016 and 2018, and subsequently granted for two additional two (2) year periods to 3 July 2020 over the same areas. The ELs are entirely within Aboriginal land.

The project area is shown on Figure 2: 2019 Proposed Work Areas

Apart from the Beatrice JV tenements, Alligator Energy is the holder of a number of other tenements in western Arnhem Land including ELs 24921, 24922 and 25002 (TCC Project). The company also has a number of ELs under application in western Arnhem Land.

This MMP is in respect of the Beatrice Project ELs 24291 and 26796.

3.3 Previous Activities and Current Status

3.3.1 History of Exploration

Queensland Mines Limited

Limited exploration work was conducted by Queensland Mines Limited (QML) between 1970 and 1973 before the


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cessation of exploration in Arnhem Land with the introduction of the Aboriginal Land Rights Act in 1973. Mapping, airborne and ground radiometric and magnetic surveys in 1970 and 1971 led to the identification of the Beatrice prospect

In 1971 radiometric surveying and costeaning of the most anomalous zones at the Beatrice prospect was conducted, followed by topographic and surface geological mapping. Trenches at the prospect were bulldozed for mapping. A track was bulldozed from the west along the East Alligator River valley into the Beatrice Inlier to permit truck-mounted drill rig access. Diamond drilling in 1971 comprised eight drillholes for a total of 490.7 m. Low-grade secondary sooty pitchblende was intersected below the surface anomalies. Despite intersecting 7 m at 3.3% U3O8, at the completion of the program it was suggested that all prospective sites had been tested and there was no further exploration potential.

In 1973, a grid-based mapping, radiometric and soil-sampling survey was conducted over the Beatrice prospect. Lockhart noted that the mineralisation is restricted to an area of chloritised gneiss, spatially associated with a series of northeast trending quartz stockwork breccias. QML’s exploration was curtailed in early 1973 by the Federal Government imposed moratorium on exploration pending a resolution of the issue of Aboriginal Land Rights, and no further on-ground exploration work was conducted by QML.

Reinterpretation of results by QML geologists in 1982 concluded that potential remained within the prospect area based on the intersections from the 1971 drilling. As a result, further drilling and surface investigations were recommended.

Cameco Exploration

Afmeco Mining and Exploration Pty Ltd (AFMEX) acquired the exploration licence application from QML in 1998 and formed part of the joint venture partnership between AFMEX (25% operating partner), Cameco (50%) and SAE Australia Pty Ltd (25%).

Following the dissolution of the joint venture agreement in 2003, the exploration licence application was transferred to Cameco. The original exploration licence application area (EL 24291) was split by non-consent areas as determined by an anthropological survey conducted prior to grant, forming the two non-contiguous licences EL 24291 and EL 26796. Grant of licence was given on 04 July 2008, for a period of six years.

2008 – 2009

The 2008 exploration program consisted of airborne geophysical surveys and helicopter-supported ground activities, comprising geological mapping, reconnaissance, and outcrop sampling.

Air photography over the Beatrice project area produced a digital image which was geometrically corrected to create an ortho-photograph and digital elevation model. Two airborne geophysics surveys were flown over the Beatrice project area. These were a helicopter-borne VTEM (time domain electromagnetic system) and magnetic data, and fixed-wing radiometric and total field magnetic surveys.

Ground investigations consisted of reconnaissance and sampling of the identified airborne radiometric anomalies, geological reconnaissance across the tenement, with focus given to the Beatrice prospect. Outcrop sampling returned a best assay result of 0.15% U3O8 in a strongly chlorite altered and sheared granite from the Beatrice prospect.

A large radiometric anomaly identified in the northwest of EL 24291, sited within a shallow gully to the south of and parallel to the Beatrice Fault near the intersection with the Bulman Fault Zone returned elevated uranium results within sandstone, with a best assay result of 8.8 ppm U3O8 in hematite altered, fine-medium grained sandstone. This anomaly was named the Violet prospect.

The exploration work was conducted by Cameco.

2009 – 2010

Work conducted in 2009 consisted of an airborne radiometric and magnetic survey, an airborne hyperspectral survey, a ground-based sub-audio magnetic (SAM) survey over the Beatrice prospect, five diamond core drillholes and 272 auger holes at the Beatrice prospect, and rock outcrop sampling in conjunction with reconnaissance mapping over the two


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licences.

Helicopter-supported drilling and other work were conducted at the Beatrice prospect from 27 May to 23 July 2009. Five diamond drillholes for a total of 730.5 m and 272 auger holes were completed. The diamond drillholes were completed at variable azimuths and dips as conditions and targeting warranted. All auger holes were completed adjacent to the Beatrice prospect, with a portable track-mounted machine and a detachable auger bit. Auger holes penetrated the top 1.2 m of the soil horizon, and samples were collected of the bottom of hole from the auger flyte.

In addition, during the 2009 – 2010 field season 105 ground stations were recorded, including 10 mapping points and 95 rock sample sites. On EL 24291, 98 sites were recorded with 9 mapping stations and 89 rock samples collected. Lastly, on EL 26796, 7 sites were recorded with 1 mapping station and 6 rock samples collected for geochemical analysis.

The exploration work was conducted by Cameco.

2010 – 2011

Work conducted in 2010 consisted of a ground-based resistivity survey, airborne electromagnetic (TEMPEST) survey and helicopter-supported activities that included diamond core drilling, geological mapping and outcrop sampling. In total, 6 diamond core drillholes were completed at the Violet prospect for a total of 1,836.7 m. The most significant uranium intersection was intersected in BTD0278 with 20.6 m at an average grade of 850.6 ppm U3O8 from 30.1 to 50.7 m.

Outcrop sampling in conjunction with reconnaissance mapping were conducted across EL 24291 and EL 26796 with 234 sites recorded in total. On EL 24291, 217 sites were recorded with 164 mapping stations and 53 rock sample sites. Lastly, on EL 26796, 17 sites were recorded with 3 mapping stations and 14 samples collected for geochemical analysis. The exploration work was conducted by Cameco.

2011 – 2012

Helicopter-supported tree leaf vegetation sampling was conducted over the Beatrice prospect to test this surface sampling technique over known uranium mineralisation. In total 18 samples were collected at a nominal spacing of 50 m in a northwest trending line. The exploration work was conducted by Cameco.

2012 - 2013

Diamond drilling was the focus of exploration activities for the reporting period and additional desktop studies were completed after the field season. During July – August 2012, one diamond core drillhole, BTDD0001, was drilled to 206.8 m. The drillhole targeted an interpreted steep north-trending structure in a previously untested area ~500 m north of the Beatrice prospect. Nearby surface sandstone samples returned U values up to 21.4 ppm. BTDD0001 was collared at 8604657 N, 304317 E (MGA94-53) at an azimuth of 270° and a dip of -60°. Radioactivity is background throughout the drillhole. The exploration work was conducted by Cameco.

2013 – 2014

No exploration was conducted by Cameco during this period

2014 – 2015

Work undertaken was confined to the 6 month period from 18 December 2014 when Cameco entered a Joint Venture agreement with Alligator Energy Limited (Alligator Energy) for uranium exploration on the Beatrice tenements. Work included the collection of 295 surface samples inclusive of 28 soil samples and 267 rock chip samples. Additionally 3 water samples were collected for radionuclide analysis. Field work also included the collection of 696 ground based radiometric point readings by hand held scintillometers, and 91 lithological mapping points. Ground based exploration was preceded by the resampling of historic drill core totalling 93 core samples.

The exploration work was conducted by Alligator Energy.

2015 – 2016

Exploration conducted under the current Authorisation by Alligator Energy during the period from 4 July 2015 comprised:


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Geochemical analysis of historic drill core totalling 181 samples by Bureau Veritas.

Radionuclide testing of 14 groundwater samples.

Geochemical and Lead (Pb) isotope analysis of 1,133 surface rock chip samples.

Geochemical analysis of 116 soil samples.

Geophysical HeliSAM survey over 3 regional areas (743 line kms).

Prospect and regional mapping of the Beatrice anomaly and nearby targets.

Ground based radiometric survey totalling 2,050 hand held scintillometer points.

Air Core drilling 87 holes for 2,257 metres

Initial validation of historical data and database amalgamation.

Independent geological review of the Alligator Rivers and Pine Creek mineral provinces. (HINMAN GeoSOLUTIONs). 2016 – 2017

Exploration conducted under the current Authorisation by Alligator Energy during the period from 4 July 2016 comprised: Work on the Beatrice Project for this reporting period consisted of:

Geochemical analysis of historic drill core totalling 269 whole metre samples.

Re-logging of 2 historic drill holes at the Violet prospect for a total of 706.6m.

Geochemical and Lead (Pb) isotope analysis of 374 surface rock chip samples.

Prospect scale geological mapping and reconnaissance, with 36 recorded mapping points.

Ground based hand-held scintillometer radiometric survey at the BT2 prospect totalling 13 recorded stations.

Continued validation of historical data and database amalgamation.

Ongoing geological interpretation, modelling and reviews with relation to regional settings and neighbouring tenements.

2017 – 2018


Geochemical and Lead (Pb) isotope analysis of 262 surface rock chip samples.

Project scale geophysics review.

Regional geological interpretation of sub-Kombolgie geology.

Geophysics reprocessing of magnetics at BT12.



3.3.2 Previous 12 Months Exploration


Commission of geophysics remodelling for sub-Kombolgie features. (ongoing)

Project scale geophysics review.

Regional geological interpretation of sub-Kombolgie geology.



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In addition to this field work there has also been continued work in re-establishing Myra Camp, from which fieldwork is based, to meet modern standards and preparing various compliance documentation. There was no ground disturbance on the project area and no infrastructure requirements during the 2018 field season.

3.4 Proposed Activities 2019 Field Season

A systematic surface sampling program is proposed across 2 areas of the Beatrice tenement during the 2019 field season. Approximately 150 samples are planned between the BT6 and BT7 regions utilising helicopter support for access purposes. Additionally in conjunction with this proposed sampling program geological mapping will be conducted escarpment edges within the proposed areas where possible. A second phase of exploration contingent on mid-season fundraising could include a small helicopter supported geophysical survey at BT12 with the potential for follow up drilling. The exploration proposed for the 2019 program will consist of: Phase 1

Approximately 50 surface geochemistry rock chip samples in area shown in Figure 2 as BT7 on EL26796;

Approximately 100 surface geochemistry rock chip samples in area shown in Figure 2 as BT6 on EL24291;

Geological mapping and geochemical sampling within proposed work areas.

Phase 2 If fundraising is successful during the field season, phase 2 exploration may be conducted comprising:

Sub Audio Magnetic (SAM) or similar geophysical technique at BT12; Refer attached Figure 2: 2019 Proposed Work Areas for general location of work areas. There is no current infrastructure on the Beatrice tenements. The only current infrastructure in the general area is at Myra Camp on TCC Project EL 24922 and comprises transportable bunk houses, ablution units, septic system, transportable offices, kitchen, cool room, zinc aluminium sheds, core shed and racks, fuel storages, generators, refuse tip and a helipad. All operations conducted on the Beatrice tenements will be based from Myra Camp with access by helicopter. No tracks will need establishment during Phase 1 of the program. An ATV may be heli lifted into the tenement area to assist access throughout the area. Previous experience with use of ATVs (Polaris 4WD and 6WD) during the past few years confirms that they have negligible potential for any significant disturbance when used in an appropriate manner. No tracks will need establishment if Phase 2 of the program proceeds. Should a geophysical survey be conducted, it is likely that GAP Geophysics from Brisbane would be contracted to do the survey work. GAP have worked out of Myra camp in recent years for Alligator over both the Beatrice and Tin Camp Creek project areas. The schedule for the proposed exploration campaign is shown in following Table 2 however it must be noted that the timing of activities may change as a result of a number of factors including:

The outcomes of work program meetings;

The findings of any archaeological surveys which may need to be conducted with the assistance of Traditional Owners;

The ability to safely access the work areas


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Weather

The availability and timing of equipment.

Table 2 - Anticipated Work Schedule 2019

Activity Duration of

Activity Timing Amount Location

Initial field reconnaissance visit

5 days April N/A Voilet

Outcrop sampling, mapping

At various times

July to September Estimated 150 samples Project wide

*Geophysical Survey 3 weeks August to

September Up to 400 line km TBA

*Contingent on funding, **Contingent on geophysics

4. Current Project Site Conditions

4.1 Land Area Type

The topography underlying the project area is a diverse combination of Arnhem Land plateau country consisting of escarpments and undulating savannah woodlands. The major watercourse in the area is the East Alligator River.

Soils consist of thin sandy types and some black loams covering (in part) the plateau country. Gorges and valleys within the plateau contain alluvium and localised soil development. Elsewhere, thick clay rich or sandy soils predominate; there are a variety of transported materials such as outwash sand, gravel and ferricrete and in situ weathered rock. This material is collectively termed’ regolith’, which covers most of the lowland country. The depth of weathering in the latter is commonly up to 40 – 50m but varies.

4.2 Hydrology

The Arnhem Plateau is the watershed for most of the region’s main watercourses including the East Alligator, Goomadeer, Liverpool and Mann Rivers, which all flow northwards into the Arafura Sea. There is also an extensive development of major secondary drainages, which have their origins in the plateau. These are either tributaries of main rivers, such as Tin Camp, Birraduk, Cooper and Jungle Creeks, or flow directly to the coast. Many other lesser creeks and streams are present throughout the region.

Many of the watercourses, both major and minor, maintain their flows throughout year, while others dry out completely or contain pools until late in the dry season.

During the field season, water is sourced on a regular basis from Tin Camp Creek for domestic purposes at the Myra Camp.

Water is required for diamond drilling and this is obtained where possible from flowing creeks in the vicinity of the drilling site. Water is preferably pumped to the site via removable poly lines but where that is not practicable it is carted to the sites. In order to supplement surface water supplies if necessary, a water bore or bores may be drilled in the project area to service drilling activities.

All water will be sourced with the permission of the Traditional Owners.

The present level of exploration activities will have little impact on the water resources of the area.


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4.3 Flora & Fauna

The Beatrice tenements are located in north western Arnhem Land. The project area occurs within the Arnhem Plateau (ARP) bioregion as described in the Northern Territory Parks and Conservation Master plan (2005). The bioregions provide a division of the NT based on areas of broadly similar landform, geology and planning. There are 13 bioregions wholly within the NT and another 13 shared with neighbouring states.

The main vegetation types of the ARP are sandstone heath lands, rainforests (characteristically dominated by the endemic tree Allosyncarpia ternata), hummock grasslands and eucalypt open woodlands (with a range of dominants including Eucalyptus phoenicea, Eucalyptus kombolgiensis, Eucalyptus miniata and Eucalyptus dichromophloia).

Lists of significant plant and animal species in NT bioregions are included in the Northern Territory Parks and Conservation Master Plan 2005. The project area is within the Arnhem Plateau (ARP) bioregion. A complete listing of significant species in the ARP is attached (Attachment 3 – Extracts from the Northern Territory Parks and Conservation Master Plan 2005 and NR Maps)

A search of NR Maps database does not identify any threatened or significant fauna within the Beatrice tenement area. This may be due at least in part to the remote nature of the area and lack of vehicular access for a number of decades. The database identifies the following fauna recorded in close proximity to the north western boundaries of EL 24291:

• Litoria australis (Giant Frog); • Acrochordus arafurae (Arafura File Snake); • Heteronotia binoei (Bynoe’s Gecko); • Oedura rhombifer (Zigzag Velvet Gecko); • Proablepharus tenuis (Northern Soil Crevice Skink); • Carlia amax (Two Spined Rainbow Skink); • Little Egret and Pied Heron None of these species are listed as vulnerable or endangered in the ARP bioregion in the Northern Territory Parks and Conservation Master Plan 2005 although the NR Maps database lists the Two Spined Rainbow Skink as threatened (refer NR Maps printout for significant fauna in Attachment 3). A search of NR Maps database does not identify any threatened flora within the Beatrice tenement area. Significant flora species noted were:

• Borona laxa • Acacia sp. Jim Jim falls

• Temstroemia cherryl • Tephrosia humifusa

• Dichapetalum timoriense • Spermacoce pessima

• Dubouzetia australiensis • Hibbertia circularis

• Hibbertia sp. Mount Howship • Hibbertia fractiflexa subsp. Filicauli

• Podocarpus grayae • Atalaya salicifolia

• Acacia armitil

Borona laxa and Temstroemia cherryl are noted as vulnerable and Dichapetalum timoriense is noted as endandered in the ARP bioregion in the Northern Territory Parks and Conservation Master Plan 2005. The latter five species (Tephrosia humifusa, Spermacoce pessima, Hibbertia circularis, Hibbertia fractiflexa subsp. Filicauli and Atalaya salicifolia) are not listed as significant in the ARP bioregion in the Northern Territory Parks and Conservation Master Plan 2005 but do have significant flora status in the NR Maps database (refer NR Maps printout for significant flora in Attachment 3). None of the listed species are shown to occur within proximity of BT12 and Violet prospects. One significant (but not vulnerable or endangered) species, Podocarpus grayae, may be present east of BT12 in the BT1 prospect area however no activities are proposed on BT1 during 2019. Habitat modification and loss as a result of altered burning regimes and weed invasion are listed in the Northern Territory


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Parks and Conservation Master Plan 2005 as key threatening processes for many species. Alligator Energy has specific procedures in place both to ensure weeds are not spread as a result of our activities and to ensure that wildfires are not started. Early season burning may be conducted in combination with local ranger groups around the camp area (Myra Camp) and proposed drill sites (if applicable) to minimise the chance of wildfire resulting from Alligator Energy’s activities.

There are possibly a variety of exotic plants and animals in the project area. Exotic plant species recognised by WONS (Weeds of National Significance) are Alligator Weed (Alternanthera philoxeroides) and Olive Hymenachne (Hymenachne amplexicaulis). These species are serious aquatic weeds that have the potential to cause grave damage to waterways and floodplains. Grassy weeds are also of particular importance due to their role in increasing the severity and impact of wildfire.

The presence of weeds and other non-native vegetation in Arnhem Land is currently being investigated by personnel attached to the NLC (Caring for Country team). DEMED, based at Gunbalanya, have been active in weed eradication in recent years and have also been advising on weed-related issues. The Weed Management Branch of the Department of Land Resource Management also has information relating to weeds in the area. Warddeken Land Management was established to service the Warddeken Indigenous Protection Area which incorporates the Tin Camp Creek and Beatrice Project areas and is coordinating efforts in the region to control the spread of weeds.

Of particular concern in the region is Mission Grass. The NLC on behalf of the Traditional Owners have indicated that the spread of weeds is of particular concern due to past activities by previous explorers. Alligator will implement a weed management program in consultation with the NLC and the local community.

There are a range of flora and fauna protection management practices noted in Section 5.4.2.4 of the MMP and these will be applied to minimize the likelihood of adverse effect to all species, not just significant or threatened species. Additionally and to the extent possible and practicable, Alligator personnel will be trained to observe and recognize significant species and associated habitat so that application of management measures can be more focused in more critical areas.

Exotic animal species include buffalo, cane toad, feral cat, cattle, crazy ant, feral dogs, goat, honeybees, feral pig, and Sambar deer. Alligator Energy personnel are not permitted to carry firearms and there is no specific plan to control feral animals except by discouraging their presence by implementation of appropriate waste and other practices particularly in and around Myra Camp and other work areas. However, assistance may be provided to Traditional Owners if requested and licenced personnel eg; Warddeken Land Management, may be employed in eradication programs if necessary.

4.4 Current Land Use

The primary land use is traditional aboriginal ownership. Outstations are scattered throughout the region. Traditional Owner visitations to the Beatrice tenement areas are tempered by current limited vehicular access. Exploration has been conducted intermittently in the project regional area since the early 1970s.

4.5 Historical, Aboriginal and Heritage Sites

Alligator Energy meets with the NLC and Traditional Owners each year prior to commencing exploration activities. Traditional Owners are advised of the proposed work program as required under the ALRA. Prior to the grant of the exploration licence a Heritage Survey is conducted by a qualified anthropologist to identify any sites of cultural significance. Designated no-go zones are excised from the licence by DPIR at grant. Smaller no-go zones as determined by archaeological surveys may be identified within the licence area.

5. Environmental Management System

5.1 Environmental Policy and Responsibilities

Alligator Energy considers environmental management as core business to its operations. The company’s business is


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focused on uranium exploration in Western Arnhem Land. Its management policies are therefore focused specifically on these activities. Environmental management is based on a risk management approach combined with a strong focus on indigenous community consultation and involvement with implementing operational plans and procedures to protect the environment.

Alligator Energy’s Environmental, Safety and Social policies are built on the following principles:

Leadership – commitment and active involvement from management.

Experience - experienced personnel are required in the field to supervise and mentor staff and contractors.

Vigilance – Constant awareness of potential risks and prompt attention to mitigate risks.

Accountability – Clear responsibilities and accountabilities are defined for all personnel. Accountability to indigenous

landowners is emphasised by openness and direct involvement.

Training and mentorship – All field personnel must be provided with appropriate guidance and training to undertake

their duties safely and professionally.

Well defined work procedures - incorporate risk management controls for environment, health and safety, technical

and social risks into work procedures in an integrated manner.

Resources – Appropriate resources and equipment will be supplied to operate professionally.

Environmental control protocols/procedures have been developed from Hazard Identification processes and in consultation with local stakeholders. Control Measures are incorporated into planning of each field program based on the Risk Control Hierarchy of:

Elimination of hazard

Substitution of hazardous processes or materials

Engineering controls

Procedural controls

PPE

Finally the control measures are implemented by inclusion into operational procedures for each field activity which form the basis for staff and contractor induction, training and supervision. Traditional Owners are preferentially engaged as Field Assistants following discussions with the NLC, however they also provide advice on cultural and environmental matters and assist in the monitoring of the day to day implementation of control measures as an independent community based accountability and audit process.

Contractors are required to comply with all Alligator Energy’s management policies and operating procedures. These requirements are included in contract documentation as necessary and are reinforced during the site induction process and regular inspections and audits.

5.1.1 Environmental Policy

Alligator Energy’s commitment to the environment is defined in its Environmental Policy.

Operationally, Alligator Energy’s objectives will be achieved by:

Open and Accountable communication with regulators and local communities

Compliance with environmental laws, regulations and conditions as a minimum standard.

Consultation with Traditional Owners to ensure control measures meet local community and cultural standards.

Incorporating risk assessment and hazard Identification into operational and business planning.

Incorporating Cleaner Production and Risk Control Hierarchy principles into control measures.

Ensuring experienced personnel are involved with all aspects of operations and that all personnel have appropriate

training and guidance.

Minimizing waste streams.

Undertaking progressive rehabilitation of exploration disturbance to best practice industry and community standards.


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A copy of the Alligator Energy Environmental Policy is attached as Appendix 2

5.2 Statutory and Non-Statutory Requirements

5.2.1 Statutory Requirements

The following list all relevant legislation, codes and other statutory obligations related to the tenements detailed in section 3.2.

5.2.1.1 Northern Territory

Current Northern Territory legalisation which may be applicable includes:

Aboriginal Land Act Aboriginal Sacred Sites Act 2006; Bushfires Act 2004 and Regulations; Dangerous Goods Act 1998 and Regulations; Environmental Offences and Penalties Act 1999; Heritage Conservation Act 1991 and Regulations; Mineral Titles Act 2011 and Regulations; Mining Management Act 2008 and Regulations; Northern Territory Aboriginal Sacred Sites Act 1989 and Regulations; Radiation Protection Act 2004 and Regulation Radioactive Ores and Concentrates (Packaging and Transport) Act 2007 and Regulations; Territory Parks and Wildlife Conservation Act 2006 and by-Laws and Regulations; Water Act 2004; Waste Management and Pollution Control Act 2003; Weeds Management Act 2001; and Work Health and Safety (National Uniform Legislation) Act 2011 and Regulations

5.2.1.2 Commonwealth

Commonwealth legislation which may be applicable includes;

Aboriginal Land Rights (NT) Act 1976 Environmental Protection (Alligator Rivers Region) Act 1978 Native Title Act 1993; Atomic Energy Act 1953; and Environment Protection and Biodiversity Conservation Act 1999.

5.2.1.3 Other

Other statutory requirements, Codes, Guides and so on relevant to the Arnhem Land Project include the following;

Code of Practice for Safe Transport of Radioactive Materials 2008, ARPANSA.

Code of Practice for Radiation Protection and Radioactive Waste Management in Mining and Mineral Processing 2005, ARPANSA.

Safety Guide for the Safe Transport of Radioactive Material, 2008, ARPANSA

Safety Guide for the Management of Naturally Occurring Radioactive Material (NORM), 2008, ARPANSA

Reporting of employment/injury and safety statistics to NT WorkSafe. Alligator Energy has a Risk Management Plan lodged with, and approved by, NT WorkSafe. All reportable incidents will be notified to NT


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Worksafe as required under Sections 64 and 65 of the Workplace Health and Safety Act 2007 and Regulation 46 of the Workplace Health and Safety Regulations 2008. The NT WorkSafe Incident Notification Form FM 137 will be used for reportable notifications to NT WorkSafe.

Environmental incidents will be reported to the Department of Primary Industry and Resources (DPIR) on Form CF7-001 – Notification of a Serious Accident or Critical Incident (Environmental).

5.2.2 Non Statutory Requirements

The Beatrice Project is subject to Exploration Agreements between the traditional land owners and the Northern Land Council (NLC) to enable exploration within the Beatrice tenements listed in section 3.2. These agreements contain certain provisions relating to the protection of sacred sites, employment and training of traditional owners, cross cultural training, environmental protection, rehabilitation and occupational health safety and environmental requirements specific to uranium exploration. Alligator Energy will abide by the requirements of these agreements.

No other non-statutory agreements have currently been proposed or entered into.

5.3 Induction and Training

Prior to undertaking any field activities all staff and contractors are required to undertake field inductions, which includes environmental, cultural and safety issues relevant to the Project. A general induction includes all aspects of the Environmental Management Plan (refer Section 5.4.2). More detailed training and induction is provided for the following:

Weed Identification and Management, Radiation Management, Cultural Awareness and Rehabilitation Requirements and Procedures Safety (emergency response, search and rescue, medical emergency, environmental/safety incidents et al)

In addition to the inductions, daily briefings are held during drilling programs to discuss specific issues pertaining to the day’s operations and specific problems encountered during the day. ES&H meetings will also be carried out where environmental aspects of the operation will be discussed. These meetings will be generally in the form of a “toolbox” meeting and held on an “as needed” basis to discuss particular environmental and safety issues as they arise. Over the duration of the field season these meetings generally average one meeting every one to two weeks.

All training, induction, ES&H and daily meeting records relevant to the specific field season will be maintained in electronic and hard copy format at the Myra Camp site office and subsequently transferred to the Alligator Energy Brisbane Head Office at the conclusion of the season.

5.4 Identification of Environmental Aspects and Impacts

5.4.1 Environmental Aspects and Impacts

The key environmental aspects considered to be of primary importance in the assessment of environmental impacts for the Alligator Energy Arnhem Land Projects, are outlined in Table 3 - Environmental Aspects and Impacts. As noted in section 5.6.1, risk assessment and hazard identification of operational and business planning forms an integral part of Alligator Energy’s activities. The company employs a detailed Risk Management Plan approved by NT Worksafe in planning and implementation of its activities. The Plan includes Risk Matrices for health and safety, radiation exposure, environmental risk and incident reporting. The Plan also includes a detailed Risk Register which identifies a comprehensive range of activities. For each activity, the aspect/hazard, impact consequences, likelihood and consequences, risk rating, control measures, control measure effectiveness assessment and accountability is documented. Success of the risk assessment and hazard strategy is predominately judged by the company’s performance in all its operations. Protocols/procedures define requirements and inspections/audits assess performance and require rectification of underperformance. Due to the nature of exploration activities, a qualitative risk assessment has been undertaken on the various aspects of work to be undertaken and is based on the extensive experience of


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Alligator Energy management. Risk assessments will be reviewed regularly in consultation with local stakeholders once field work commences.

Table 3: Environmental Aspects and Impacts

Aspect Rating Impact Management Measure Rehabilitation

Access Tracks

M Erosion risks, particularly on sloping terrain, sediment runoff from roads into creeks

- Minimise tracks. -Ensure tracks properly formed. Utilise proper track alignment and gradient in sloping areas. -Blade up grading. -Erosion controls including diversion drains and “whoa boys” - In sensitive areas or sites that require excessive excavation and disturbance, utilise heli-drilling. - implement Ground Disturbance Protocol

-Closure of roads at end of dry season that are to be used the following year. -Erosion controls established to minimise erosion over wet season. -Permanent rehabilitation of roads when no further use required

L Dust generation -Blade up track clearing -Speed limits <50km/hr

-Closure of roads and rehabilitation.

M Damage to habitat, Roadkill

-Divert tracks around trees and dense stands of vegetation. -Supervision by Traditional Owners (CEMs). -Limit speed <50kph. -Warning signage of crossings and blind bends.

-Closure of roads and rehabilitation.

M Damage to Cultural sites

-Supervision by CEMs and planning of tracks with Traditional owners input. -Reference to cultural heritage maps.

-Avoid cultural sites. -Consultation with Traditional Owners.

H Weed Invasion -See Weed management Plan. -Mapping of weed areas along tracks for seasonal treatment.

-Ongoing monitoring of treated areas and follow up spraying

H Safety on Tracks -Limit speed <50km. -Warning signage of crossings and blind bends.

-Close off roads when programs are finished

Fire Management

H -Uncontrolled “hot” fires. -Damage to property, camps and equipment. -Damage to cultural sites or food sources.

-Conduct controlled burns around camp sites and drilling areas as firebreaks. - Burning to be undertaken with approval and/or supervision of Bushfires Council and Traditional owners.

-Use emergency back burning if feasible contact and liaise with Bushfire council. - Notify local communities. -Monitor fire.

Drill Pads and Sumps

M -Erosion risks. -Damage to habitat. -Risks to fauna (drill sumps). -Overflow of sludge into watercourses.

-Construct sumps properly with sufficient volume. -Bund down slope side of sumps. -Construct sumps with sloping entrance to allow fauna to escape. In problematic areas use above ground tanks with bunded plastic underlay. -Remove sludge to a safe disposal site. -in summary, prepare drill pads in accordance with AGE Drill Pad Protocol

-All sumps to be rehabilitated prior to wet season .

Aspect Rating Impact Management Measure Rehabilitation

Drilling M Fuel and fluid spills -Fuel lines, valves checked daily. -Containment or plastic sheeting/spill matting to be placed under fill points - spill trays or similar protection under stationary engines.

-Absorbent matting and “kitty litter” kept with rig at all times. - All spills cleaned up.

M -Drill return water and sludge overflows.

-Contain flows with bunding. -Ensure sumps constructed properly. -Cease drilling if fluid escapes containment areas until control measures are in place.

-Leaks and spills to be dealt with immediately and remediated.

H -Uncapped drill holes risk to small fauna

-Backfill and Cap holes asap on completion and concrete collar.

-Backfill and Cap holes on completion and concrete collar.


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M -Contamination of groundwater.

-Use biodegradeable and/or benign drilling fluids. -Avoid hydrocarbon spills.

-Backfill and if necessary grout drillholes on completion.

M-H -Water supply -Pumping water from sensitive sites. -Pumping water holes dry.

-Source water from substantial or flowing water courses in consultation with Traditional owners - consider groundwater use if necessary to avoid excessive depletion of surface water sources. -Monitoring by CEMs.

M-H -Exposure of drill sludge to rainfall run-off and fauna. -Radionuclide runoff and radiation safety.

-For in ground sumps, allow drilling water to evaporate then in fill sump with 1 metre of compacted soil. -For above ground tanks, remove sludge in suitable container to appropriate burial pit and cover with 1m of compacted soil

-Check progress of rehabilitated sites. -Radiation monitoring checks of backfilled sumps and burial pits.

M -Rubbish left on site -Ensure all rubbish is removed from site at the completion of each drill hole. -Include requirement in drill contract.

-Remove any rubbish found on project area.

H Fire Management – potential fire/bushfire risk due to general drilling machinery operation and maintenance, in particular due to hot work

-Ensure drill sites are clear of vegetation which could contact with drilling machinery -As necessary, conduct controlled burns or appropriate clearing of vegetation around drilling areas as fire breaks (burning to be undertaken with approval of and/or supervision by the Bushfires Council and Traditional owners) -Ensure all hot work is undertaken in an appropriately controlled manner using shielding etc -Ensure safe storage and handling of fuels and other flammable materials. Conduct regular rig maintenance to check for leaking fuel lines and other potential fire risk areas -Provide all necessary fire fighting equipment eg; fire extinguishers of appropriate type -Provide necessary training to drill operators stressing the importance of fire prevention and control

-Use emergency back burning if feasible. Contact and liaise with Bushfire Council and Traditional Owners -Notify local communities -Monitor fire

L Artesian flows from exploration drill holes (note that the potential for artesian flows in proposed drilling areas is negligible. There are no known artesian areas and the anticipated lithologies are tight metamorphic rocks with low potential hydraulic conductivities).

-In the unlikely event that artesian flows are encountered, the holes will be plugged and capped in accordance with statutory requirements and DPIR Advisory Note AA7-008

-Refer management measure note

H -Spread of weeds -See Weed Management Plan Section of MMP -Weed Spraying in consultation with local community and DPIR

H -Injury to people and fauna

-Limit speed to 50km/hr. -Proper signage. -Induction.

-Rehabilitate and close roads after use is completed.

M -Erosion from tracks. -Proper road alignment and drainage -Rehabilitate and close roads after use is completed.

L -Dust -Limit Speed. -Blade up grading.

-Rehabilitate and close roads after use is completed.

Mapping M -Interference with significant or restricted

-Avoid sites by reference to updated Cultural Heritage Maps and liaison with Traditional

-Ongoing consultation with traditional owners


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access sites. Owners.

H -Spread of weeds -See Weed management Plan -Weed Spraying in consultation with local community and DPIR

L -Rubbish -Bring all rubbish back to camp -Remove any rubbish found on site.

M -Uncontrolled fires -No fires to be lit outside of controlled burns. -Inform local community of uncontrolled or accidental fires

Airborne Geophysics

L -Noise nuisance and disturbance of people and wildlife

-Inform community of dates, times and area of survey. -Liaise with local community.

-Respond to complaints promptly.

Camp Management

Fuel Storage M-H -Fuel Spills -Fuel store within bunded areas or in self bunded tanks. -Fill points and valves to be checked and kept in good order. -Absorbent matting kept on hand. -Reporting and remediation of spills.

-Fuel spills to be remediated asap following spill - conduct investigation of spill causes and implement additional controls as necessary in accordance with spill management protocol .

Septic Systems

M -Flow of Septic into watercourses

-Septic systems to be properly installed and checked regularly -monitor upstream downstream water quality to ensure efficient operation of septic system.

-Check for leaks and remediate as required.

Greywater L -Flow of waste water into watercourses.

-Greywater Drains constructed. -Monitor greywater drains and remediate leaks.

Rubbish M -Littering -Maintain rubbish pits and cover rubbish properly. -Dispose of all litter.

Fire breaks M -Uncontrolled fires -Fire breaks and back burning to be established around camp early in dry season.

-Use back burning where possible to limit fire. - Contact and liaise with NT Bushfire Council. -Notify local community.

Core and Sample Storage.

M-H -Radiation safety and contaminated run-off

-Regular radiation monitoring. -Appropriate storage of samples. -Check integrity of core racks and ensure they are secure . -Store in well ventilated areas.

-Remove spilled samples ore core to appropriate storage facility or bury in pits with at least 1 metre of compacted soil above.

L = Low; M = Medium; H = High

5.4.2 Environmental Management Plan

5.4.2.1 Overview

This Environmental Management Plan (EMP) is specific to the Beatrice Project and Myra Camp operations, however it is identical in almost all respects to the EMP for the Tin Camp Creek Project with only minor project specific issues in variance.

Where contracting organisations have an EMP, this will be evaluated and audited prior to, or immediately following, mobilisation to the field. Where a contractor does not have an EMP, or the system is deemed deficient, contractors will be required to comply with Alligator Energy systems. The majority of issues are dealt with during the induction process and all inductees are provided with a hard copy of the induction booklet which includes a range of relevant procedures and protocols.

Alligator Energy’s CEO is responsible for ensuring that the Environmental Management Plan is implemented and adhered to by employees and contractors. Senior site personnel provide day to day management and implementation of procedures to ensure a high level of environmental performance on the tenements.


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5.4.2.2 Water Management

The objective of water management is to ensure that exploration activities do not cause contamination of ground and surface water.

There is no groundwater extraction planned during the exploration program unless surface water supplies for drilling activities become untenable. Groundwater that comes to the surface as a result of exploration drilling will be contained and left to evaporate. Any resulting sediment will be buried during drill site rehabilitation in accordance with relevant protocols.

Spillages of hydrocarbons or radioactive material may also impact on groundwater and surface water resources. Measures are in place to ensure that the potential for spillage of hydrocarbons and other hazardous materials is minimised and any spillage is cleaned up and the area rehabilitated. A hydrocarbon and chemical spill protocol has been prepared manage hydrocarbons and to guide any necessary clean up operations.

Impacts to surface water on the project would normally result from vegetation clearing and drilling activities including:

impacts to the shape, location and profiles of water courses from clearing; increased sediment load resulting in alteration of depositional pattern of the watercourses; pollution potential from erosion of disturbed areas, and spillages from exploration activities; and, dust emissions from drill rigs and vehicles.

Surface water management includes minimising any impacts on natural surface drainage patterns by:

rehabilitation of access tracks crossing drainage lines after significant/erosive flood flow; best practice drill rig pad management, including topsoil and vegetation management, and construction of small

bunds to divert surface runoff around disturbed areas and access tracks; ensuring spillages are cleaned up and rehabilitated; reducing dust emissions (see section 5.4.2.6); containment of drilling water returns within drill sumps and /or tanks and rehabilitation of the drill sites prior to the

onset of the wet season.

Water for reticulation to toilets and showers and other areas of non-human consumption at Myra Camp will be sourced from Tin Camp Creek. No testing will be necessary.

Drinking water will also be sourced from Tin Camp Creek but will be appropriately treated via a filtration and ultra violet system to ensure it is fit for human consumption. Treated water, together with water from Tin Camp Creek will be sampled on a regular basis (initially at the start of the field season then at least every 2 months until the end of the field season) and sent to the DPI Bacteriological Laboratory for total coliform, E. coli and total viable bacteria analysis to confirm compliance with drinking water standards. A new water treatment system was installed at Myra Camp in September 2011 and, apart from replacement of filter casings in 2013 and 2015 and regular replacement of filters, has operated without failure since that time.

Water for drilling operations will be sourced from waterholes and creeks in consultation with Traditional Owners. Abstraction of groundwater to supplement surface water supplies for drilling purposes particularly towards the end of the field season may be necessary to maintain adequate surface water availability for wildlife in the area.

5.4.2.3 Weed Management Plan

Alligator Energy recognises that the spread of weeds is of particular concern to the NLC, Traditional Owners and local landcare groups. Weed outbreaks are known to occur in the area due to the activities of previous explorers. Protection of the area from weed invasion will continue to focus on the prevention of spreading weed seeds, and the control of weeds that may be accidentally introduced.

Procedures include:

Training of all Alligator Energy personnel in weed identification and control procedures. Training comprises awareness of NT Advisory Note AA7-017; posting of enlarged colour posters of weeds around Myra Camp; practical


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field training by assisting Warddeken Land Management during weed control programs. Alligator personnel attending the weed control campaigns pass on their knowledge to other Alligator personnel during the field season

Provision of designated wash down areas for all vehicles and equipment in the project area. All vehicles and equipment are washed down before entering Arnhem Land, moving between sites in Arnhem Land and before leaving Arnhem Land.

Wash downs can also be conducted using a mobile water trailer during track and drill pad construction as necessary where it is impossible to put a detour around an infestation and the infestation must be traversed; The designated wash down area at Myra Camp was previously within the rubbish dump which was monitored and

any emergent weeds destroyed. Since Alligator Energy purchased the camp in 2011, a dedicated concrete wash down slab has been constructed with runoff directed to an in ground sump. Wash downs are effected with a high pressure “gurney”. An additional wash down area, sump and “gurney” facility will be established if necessary close to the main drilling areas thus enabling heavy equipment “pre-wash” to be carried out prior to travelling the track into Myra Camp.

A Vehicle Clearance Form is filled out when vehicles are washed down at Myra Camp prior to leaving the TCC project area (from the Beatrice tenements). The form provides a dual purpose confirming the cleanliness of the vehicle from both weeds and radiation. Both weed and radiation clearance inspections are conducted by designated Alligator personnel trained in that capacity. Copies of the clearances are kept in the vehicle and at Myra Camp.

Consultation with the DNRETAS Weed Management Branch, Warddeken Land Management and Traditional Owners prior to commencing work in new areas to obtain most up to date information and maps on areas of weed infestation in work areas and appropriate measures to avoid further spread of weeds.

The weed control measures will be reviewed and updated on an ongoing basis in consultation with the NLC, the local community and Warddeken Land Management.

Regional weed control programs in the area generally are co-ordinated by Warddeken Land Management which has been established by Traditional Owners to assist in environmental management of their country. Alligator Energy is assisting the Warddeken with these programs including Mission Grass spraying and eradication programs in the Tin Camp Creek area.

Major collaborative weed management programs were conducted by Warddeken Land Management in conjunction with Alligator Energy personnel in April 2011 and February 2012 with follow up programs later in the field seasons.

Alligator Energy personal conducted a weed management control program in early April 2013 with follow up programs later in the field season. Warddeken personal were unavailable due to other work commitments, however, all Alligator personal conducting the 2013 programs were experienced and had previous training with Warddeken in 2011 and 2012. A number of local traditional owners were part of the control program teams.

A helicopter supported weed management program was conducted by Alligator Energy personnel between 25 February and 4 March 2014. Particular attention was paid to known “hot spots on the TCC tenements.

Alligator assisted Warddeken with weed spraying in the Mekinj Valley and Beatrice areas in early April 2015 and contributed significantly to the overall cost of the program. The helicopter assisted program was based from Myra Camp which was opened on a temporary basis for the duration of the work.

Alligator and Warddeken conducted an inspection, weed spraying and seed head removal program at selected areas on the TCC and Beatrice tenements in April 2016, April 2017, April 2018 and April 2019. In addition, a major collaboration between Alligator, Warddeken, Njanjma Rangers and CSIRO commenced to review alternative additional weed control methods for Mimosa infestations in western Arnhem Land. No known weed occurences exist within the Beatrice tenement and as such no inspections or work were merited during 2018 field season due to no on-ground exploration in the previous 12 months.

5.4.2.4 Flora & Fauna Management

Flora Management

Effective management of flora aims to minimise disturbance, avoid known priority flora locations and to ensure effective progressive rehabilitation. Management practices to be employed are:


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Minimising the area cleared for access tracks; Use old and existing tracks where possible; Minimise the number of new tracks constructed; Avoid clearing established trees and dense stands of vegetation; Limiting the size of the drill pad; Use of blade up techniques when clearing access tracks and drill pads; Stockpile cleared vegetation and topsoil/soil separately for later rehabilitation; Rehabilitate disturbed areas as soon as practicable; and Ensure all staff are inducted in relation to rehabilitation and fire management.

To minimise accidental fires as a result of Alligator Energy’s activities, controlled burns are undertaken by Alligator Energy personnel, Bushfires Council, Caring for Country and local aboriginal groups. Caring for Country and Indigenous Rangers are supplied with Alligator Energy’s proposed work locations and may burn these areas as a component of their annual burning program.

Controlled fires are set within the fire breaks around the camp site. This is conducted early in the season, at a time when the vegetation surrounding the campsite is still green and therefore a ‘cool burn’ is generated. This process has protected the camp from wildfires that threaten later in the season. There are backpack water pumps and a water trailer located at the camp-site for fire fighting.

Other fire management procedures involve drill contractor management to minimise the risk of wildfire. Alligator Energy will ensure:

fire extinguishers are present and in date in adequate quantity (Alligator Energy and contractors); drillers are instructed to ensure fire fighting equipment is set up on arrival at site hot-work is conducted in areas clear of vegetation and employing appropriate prevention controls. induction for all personnel in use of water pumps and water trailer at camp and work sites, provision of vehicle mounted fire fighting units for use during loader operations; and, sufficient staff have undertaken appropriate fire fighting training with appropriately qualified and experienced

instructors Fauna Management The objective of fauna management is to minimise disturbance to fauna though exploration activities. Potential impact of exploration activities on native fauna is the displacement or loss of species or habitat during vegetation clearing operations. Other potential impacts could be: hydrological changes and changes to surface water quality; disturbance at important areas, such as waterholes, by personnel; road kill; drill holes or sumps not being capped or backfilled; fire.

Key actions for fauna management include: minimising disturbance to vegetation and potential fauna habitats; prohibiting firearms and domestic pets on site; educating people on the importance of not disturbing wildlife; limiting vehicle speeds to reduce the potential for road kills; capping open drill holes upon completion of drilling; Management of sludge disposal sumps to minimise potential for injury to fauna (perimeter bunding or fencing (3

sides) and sloping entry); backfilling and rehabilitation of sumps as soon as practicable after use; managing refuse to prevent attraction of feral animals; training in fire prevention and management (see above); and, Implementing feral animal control programs as necessary. Programs will be conducted in consultation with relevant

agencies. Control programs were conducted by Warddeken Land Management during 2011 and 2012 for feral pig


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eradication. No controls were required during the 2013 field season. Any program conducted during 2019 will be on an “as needed” basis.

5.4.2.5 Waste Management

Waste is produced by many exploration activities. The exploration program will generate a number of different types of wastes including:

organic debris (i.e. food scraps);

general refuse including scrap metal, cardboard and plastics;

small quantities of Naturally Occurring Radioactive Material (NORM) from drilling;

hydrocarbon wastes, such as oil filters; and

sewage..

Any ‘industrial waste’ including tyres, oils, plastic drums, steel and hydrocarbon contaminated material is transported to Darwin for disposal. Most waste that can be re-cycled is transported to Darwin; all domestic refuse (putrescible waste from messing activities and paper, cardboard and similar material from the kitchen, office amenities and maintenance areas) is disposed of in a pit nearby Myra Camp. The area is fenced to inhibit access by feral animals, principally pigs. Windblown litter is prevented by a range of measures including mesh fencing, burning the waste following tipping (in safe fire conditions) and covering with earth following burning if necessary. The pit is backfilled fully at the end of each season. The GPS location of the pit is documented. All wastes generated by exploration activies on the Beatrice tenements will be transported back to Myra Camp for disposal.

The Myra campsite has a septic and transpiration facility for collection of black and grey wastewaters respectively. Septic tanks are emptied and transpiration trenches serviced by a specialist contractor as required. To ensure any contamination of the local creek systems is detected, periodic water quality monitoring is conducted both upstream and downstream of the camp site.

Sludge from helicopter supported drilling will be collected in above ground tanks and then transported by helicopter for disposal in purpose dug sumps at selected locations. At land-based drill sites, sludge will be collected in above ground tanks and then carted by 4WD vehicles to purpose dug sumps for disposal. Domestic waste from drilling personnel is returned to the camp and managed as detailed above.

Alligator Energy has a Waste Management Plan summarising waste management issues, performance targets, operational practices, monitoring, record keeping and training. This plan forms part of the induction process pack for all personnel working on the tenements.

Radioactive material wastes are discussed in section 5.4.2.9

5.4.2.6 Noise & Air Quality Management

Noise generated from exploration activities may impact on fauna and people in the vicinity of the project. Impact on the local community is expected to be minimal due to the remoteness of proposed exploration operations.

Noise management measures to ensure occupational safety include:

Provision and use of correct protective equipment (PPE) that meets Australian Standards. Training in the proper use of PPE is provided as necessary;

Signs indicating areas where PPE is mandatory.

Dust controls are employed to ensure that dust generated from exploration activities does not cause contamination of water and soil.

Management measures to ensure environmental dust emissions are minimised include:

Use of equipment to suppress dust from drill rigs (cyclones, dust collectors), Limiting vehicle speeds whilst driving on site; Minimisation of vegetation clearing.


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Progressive rehabilitation of drill pads

5.4.2.7 Cultural & Heritage Management

Cultural and heritage management aims to minimise the impacts to cultural and heritage sites. This is achieved through effective education of personnel working on the project and continuous liaison with the Northern Land Council and Traditional Owners.

Aboriginal heritage and cultural site management is included in the field inductions for all personnel.

Cultural Awareness Training is provided to employees and contractors and Alligator Energy ensures that all new staff and on-site contractors receive this training.

Eight (8) Alligator Energy staff and two (2) Gap Geophysics staff attended a cultural awareness training session at Myra Camp with Don Christopherson on 2 July 2014. This training session was again conducted in Darwin by Don Christopherson on 21 July 2014 for five (5) Alligator Energy directors including the Chairman and CEO. Alligator provided ongoing training to contractors and new Alligator field personnel in 2015. No new field staff have been employed from outside local communities since this phase of training. Training will be provided as needed throughout 2019.

5.4.2.8 Hazardous Material & Hydrocarbons Management (not Radiation)

Hydrocarbons eg, diesel fuel and oils/greases, are used for all exploration activities. Alligator Energy will ensure the following controls are in place:

Transportation and storage in accordance with applicable regulations and codes; Use of (portable) bunds and/or spill pallets at drill sites to store hydrocarbons; Ensuring that spill kits are available at drill sites during drilling operations; Ensuring use of suitable techniques and ensuring availability of appropriate equipment for refuelling operations to

prevent spillage; Use of plastic sheeting and spill matting (if necessary) under drill rigs during drilling; Use of plastic sheeting/trays under small stationary motors to catch spillage; Disposal of hazardous waste in a manner that minimises any potential impacts; Disposal to registered disposal sites where required; Prompt cleanup of any spills and the remediation of contaminated areas. Ensuring absorbent matting is on site for spill clean-up. Ensuring emergency spill kits consisting of absorbent materials, a waste cleanup container, clean rags, plastic

bags, a shovel and gloves are available in drilling support and other relevant vehicles

Fuel Storage Bulk distillate is stored at Myra Camp in secure self bunded Trans tanks which comply with the requirements of AS1940 and AS1692. A permanent T13 Transtank (safe fill 10,000 litres) was purchased and installed in November 2011 to replace old above ground storage facilities. An additional T30 Transtank (safe fill 28,000 litres approximately) was purchased in 2014 and installed adjacent to the T13 Transtank. These tanks adequately serviced drilling activities and ancillary distillate requirements during the past field season. It is unlikely that additional storage capacity will be required during the 2019 field season. Minor quantities (up to 6 to 8 x 200 litre drums at any one time) of drummed fuel (Opal ULP) are also stored at Myra Camp on self bunded spill pallets and/or within a high density polyethylene (HDPE) lined pit adjacent to the distillate storage tanks to prevent spillage to the ground or waters. The HDPE lining in this pit was replaced during 2014. Also, due to the potential heli drilling programs and the heli supported geophysics survey, up to about 50 x 200 litre drums at any one time of Jet A1 fuel for helicopter use may be required on site. Storage will be adjacent to the Helipad in an HDPE) lined pit. A limited number of JetA1 drums may also be securely located near the heli drill sites as an emergency measure. No significant quantities of fuel will be stored at any of the exploration/drilling sites during the 2019 field season (except fuel in fuel tanks on the drill rigs and support vehicles). Minor quantities of distillate and ULP will be stored at drill sites in 20 litre drums on spill pallets for re-fuelling stationary engines. Fuel for the rigs will be sourced from the Trans tank at Myra


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Camp and carted in purpose built pods or drums on the back of company or contractor 4WD vehicles to refuel the 4WD accessible rigs. Fuel for the heli rigs will be flown in by helicopter. Minor quantities of distillate (up to 2 x 200 litre drums on a spill pallet) may be located elsewhere on the tenements to provide fuel to the front end loader/backhoe being used for track and drill pad preparation and rehabilitation activities. Control Measures Alligator Energy has appropriate operational procedures in place for the management and control of hydrocarbons used on the tenements. A Hydrocarbon/Chemical Spill Management Protocol forms part of the induction pack provided to all site personnel. The protocol includes requirements for provision and use of spill cleanup kits and materials; implementing accidental spill containment and cleanup and reporting requirements.

5.4.2.9 Radiation Management

The objective of radiation management is to ensure that all activities conform to the “As Low As Reasonably Achievable” (ALARA) principle.

Much of the material encountered during uranium exploration activities is not mineralised and does not contain radioactive materials in quantities significant enough to present a risk to workers or the environment. When mineralised zones are discovered, the main radioactive materials encountered may include naturally occurring uranium, thorium and radon and their decay products.

To ensure all radiation risks are effectively managed, Alligator Energy implements a Radiation Management Plan (refer Attachment 4).

The Radiation Management Plan includes requirements for:

Monitoring Dose assessment Waste management and controls Worker Inductions and training Personal Hygiene Control Transport Requirements Storage and Signage Sample Handling Recordkeeping and Reporting

A Radiation Induction is mandatory for all relevant Alligator Energy personnel and contractors working on or visiting any Alligator Energy held or managed tenements.

Radiation Sources

The principal sources of ionising radiation during exploration include:

inhalation of dust containing uranium mineralisation (the effective dose equivalent being largely due to the presence of long-lived alpha-emitting radionuclides in the uranium decay series);

direct exposure to gamma radiation; inhalation of the decay products of radon gas; and, ingestion (principally associated with contamination).

Of these sources, the inhalation of dust is likely to be the greatest source of effective dose equivalent (i.e. ‘dose’). Gamma flux from cores and drill chips grading 0.1 % U3O8 is a minor, secondary contributor to dose. Radon decay products (variously called ‘radon daughters’ or ‘radon progeny’) will contribute insignificantly to dose, since in unconfined atmospheres, they dilute and disperse rapidly. Ingestion of uranium- bearing mineralised contamination is a trivial source of dose, not only because ingestion is unlikely but also because uranium in its native form is almost wholly insoluble in the body and will pass through the gut without transferring to internal organs. Experience at other e xploration sites over many years would indicate that individual doses to exploration personnel are unlikely to exceed one or two milli Sievert per year (1-2 mSv/y).


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It is anticipated that the exploration activities likely to expose individuals and the environment to ionising radiation will include:

drilling activities core handling and transport; core cutting and examination; sample handling and transport; rehabilitation of drill pads and sumps; disposal of drilling cuttings and sludge; core storage; use of portable XRF equipment, and environmental and occupational monitoring

Table 4 shows major risks associated with uranium exploration and mitigation matrix for these activities.

Storage

The storage of radioactive material in the Northern Territory is governed by Radiation Protection Act 2009; however mining and related activities are exempt from this Act. Core from drilling will ma in ly be stored in open air core racks and on s tee l pa l le ts at Myra camp. Bulk samples from RC drilling and laboratory returned sample butts will be mainly stored in securely capped 200 litre drums and/or temporarily in covered bags on pallets. Sample pulps returned from laboratory analysis are stored in an appropriately signed and locked bottom vented shipping container fitted with ceiling wind driven ventilators. This storage container was established at Myra Camp in 2014.

Transport

Mineralised samples sent off-site for testing will be packed and transported in accordance with Northern Territory and Commonwealth Legislation. Samples sent to external laboratories will be accompanied by “chain-of-custody” records, and will be returned to the site for disposal or storage after they are no longer needed for laboratory tests.

Table 4: Radiation Risk and Mitigation Matrix

Activity Principal Dose Pathway Mitigation Measures Monitoring

Drilling

Inhalation of LLADA

Direct gamma

Dust collection device Respiratory protection (dust mask)

Time management

Use of dustless core drilling as a priority

Personal dust sampling Alpha-counting, calculation of

EDEB

TLDC

Core handling and transport

Direct gamma Time management Shielding

TLD

Core-cutting and exam

Inhalation of LLAD Direct gamma

Irrigated core saws Time management

Personal dust sampling TLD

Sample handle and transport

Direct gamma Time management Shielding

TLD


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Rehabilitation Inhalation of LLAD

Direct gamma

Dust suppression (water spray)

Time management

Environmental dust sampling TLD

Disposal of drilling cuttings and sludge

Inhalation of LLAD

Direct gamma

Dust suppression (water spray)

Time management

Burial

Environmental dust sampling

TLD

Core storage Inhalation of RDPE

Ventilation Radon sampling with pump

Portable XRF Use

Direct gamma Time: optimise number of exposures and the exposure time Distance: keep as far away as practicable from the FPXRF apparatus during an exposure Shielding: stay behind the FPXRF

N/A (refer XRF RSPP)

Monitoring Inhalation of LLAD Direct gamma

Time management Time management

Personal dust sampling Instant Read Dosimeters

TLD

A Long-Lived Alpha-emitters in Dust B Effective dose equivalent C Thermo-Luminescent Dosimeter D Time management simply means not spending time near the activity if not actually working. Thus breaks

should be taken away from the activity area E Radon Decay Products

Contamination

Mobile equipment used in the exploration program may become contaminated with uranium-bearing material. A radiation clearance will be conducted prior to any mobile equipment leaving Arnhem Land. At the end of the drilling program, all items of mobile equipment will be checked for contamination using alpha and gamma radiation detectors. Contaminated items will be cleaned and re-tested until they pass inspection. A record of all equipment inspected will be maintained.

Areas where drill-rigs and sumps are established will first be surveyed using gamma dose-rate meters. Following rehabilitation, these areas will again be surveyed to detect any change in gamma dose-rate. These measurements will be used to monitor rehabilitation measures.

Wastes

All wastes generated by the drilling program will be classified into categories which reflect the likelihood of contamination.

Radioactive wastes may consist of soil, core samples, diamond core drill cuttings, and core sample saw cuttings, and RC cuttings. Alligator Energy proposes the following management of these wastes:

diamond drilling sludge, core saw cuttings and other collected materials will be disposed and buried beneath no less than 1 m of soil;

Unwanted core samples will be disposed of onsite and buried beneath no less than 1 m of soil; Drilling sludge generated during heli drilling activities will be collected at each drill site and lifted and flown to one of

the above disposal sites and covered beneath no less than 1 m of soil Following disposal, monitoring will be undertaken to ensure the area does not exceed measured baseline levels; and The location of all disposal sites will be recorded and inspected to ensure rehabilitation success.

Accidents and Incidents

Radiological accidents and incidents that deliver a significant dose to an individual are unlikely at an exploration site; however there may be a perception of risk. A radiation induction strives to alleviate this perceived risk.

All accidents and incidents will be recorded and an explanation given to any personnel involved. If possible, an


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assessment will be made of the likely magnitude of any effective dose equivalent delivered.

All incidents will be reported to DPIR (Form CF7-001) and other relevant authority.

Record Keeping and Reporting

Alligator Energy maintains records of all personnel working on or visiting the exploration site. Alligator Energy will retain an ionising radiation history of Alligator Energy staff and drilling contractors who have worked on Alligator Energy projects.

Radiation inductions are provided to all workers on entry to Alligator tenements. The inductions are conducted by an accredited Radiation Safety Officer. A digital spreadsheet is maintained at Myra Camp and also on Alligators server in its Brisbane office of the names of all inductees. Each inductee is required to complete and sign an Acknowledgement of Radiation Safety Instructions and Briefing form at the completion of the induction. The form includes name of worker, date of birth, postal address and details of any previous uranium or mineral sands working history and dates.

The form is maintained in hard copy and digital format at Myra Camp. A digital copy is also maintained on Alligators server in Brisbane and all hard copies are re-located to the Brisbane office for filing at the conclusion of each field season.

A three month and annual accumulated dose report is provided by ARPANSA of radiological dose rates collected from the TLD badges worn by on site personnel. These assessments are undertaken by qualified and experienced health physicists at ARPANSA. Information from these assessments can be provided to all employees and contractors on request.

Training

All employees and contractors working in Arnhem Land will receive a general radiation induction.

Radiation Safety Officer (RSO) training has been provided for some Alligator Energy staff. In house training will be provided to staff that will operate radiation monitoring equipment.

Currently accredited RSO personnel are Peter Moorhouse and Allen Jermyn.

5.5 Environmental Audits, Inspections and Monitoring

5.5.1 Audits and Inspections

Alligator Energy undertakes internal auditing to ensure compliance with management system requirements and to facilitate continuous improvement. A minimum of three (3) scheduled internal environmental audits will be conducted during each field season if significant work activities are being undertaken e.g; drilling. This number could be reduced to two (2) audits if minimum work activities are conducted or, as was the case for the 2018 field season, exploration activities commenced later than usual. One of these audits will be at the conclusion of the field season drilling activities to identify any outstanding rehabilitation requirements. The audits test all aspects of the MMP, in particular, radiation management, weed management, hydrocarbon management, waste management, cultural and heritage site protection, flora and fauna protection, surface and groundwater management, erosion and sediment control and rehabilitation success. In addition to these audits, Alligator Energy site personnel are required to conduct regular inspections of all operational sites to identify any environmental concerns and to ensure remedial actions are undertaken promptly as necessary. These inspections will form part of the daily work load of Alligator personnel.

As part of its field operations, Alligator Energy will employ local indigenous people as field assistants. These employees will act as Cultural and Environment Monitors as a continuous community auditing and accountability process. The internal audits will encompass all of Alligator Energy’s projects generally in combined reports.

Further audits/inspections may be conducted from time to time by: Traditional Owners; Regulatory authorities


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Key stakeholders ES&H Consultant

The scheduling of these latter audits/inspections would be generally be out of Alligator Energy’s immediate control but would be fully supported by the company. The DPIR, OSS and NLC conduct an annual audit of Alligators exploration activities. The 2015 audit was conducted on 30 September and 1 October 2015.The subject of the audit was the 2015 Alligator Energy Mining Management Plans for Tin Camp Creek and Beatrice projects. No audit was conducted by these authorities in 2016 or 2017, however a site inspection and review of procedures, practice and current MMPs was conducted in September 2018 by DPIR and OSS personnel, although not deemed an official audit..

5.5.2 Monitoring

Monitoring on the Alligator Energy tenements in western Arnhem Land are focussed principally on the following issues: Community, cultural and heritage management, radiation management, land management, with particular emphasis on erosion and sediment control, vegetation protection, weed control, rehabilitation of disturbed land, and fire control, water management, hydrocarbon/chemical management and waste management. Regular general surveillance/inspection and documentation is the principal monitoring tool which triggers any necessary corrective actions. Sample collection and analysis is carried out as necessary to verify general surveillance. Monitoring methods and schedule for implementation are shown in Table 5 – Monitoring Program. A separate schedule for radiation monitoring is shown in Table 6 – Radiation Monitoring Program. Any non-conformances detected by the monitoring programs are actioned as soon as practicable. The Senior Project Geologist is responsible to ensure that corrective and preventative actions are implemented to remedy any non-conformances. Regular reviews and surveillance of control measures, practices and implementation are conducted to ensure satisfactory safety and environmental performance. Timely directives to correct underperformance are issued as necessary. Monitoring results are documented and maintained in as hard copy at Myra Camp during the field season and subsequently in digital format at the Alligator Energy Brisbane office. Table 5: Monitoring Program

ITEM AIM METHOD RESPONSIBLE PERSON

SCHEDULE

COMMUNITY

Community Relations Maintain community relations Community liaison Senior Project Geologist

As necessary

Complaints Action and resolve complaints Prompt investigation and resolution of all complaints

Community Assistance Assist local community works Provision of resources as appropriate and available

Senior Project Geologist

As available

CULTURAL/HERITAGE

Anthropological and archaeological surveys

To minimise potential impacts to cultural and heritage sites

Anthropological and archaeological surveys

NLC officers, external consultants, traditional owners

As directed by NLC

Field personnel training Cultural awareness training, induction

NLC approved trainer, Senior Project Geologist

Annual induction, additional training when necessary

RADIATION MANAGEMENT

Radiation Protection Minimise radiation exposure to workers and members of the public

Implement Radiation Management Plan

Radiation Safety Officers

As per Radiation Monitoring Schedule

LAND MANAGEMENT

Vegetation Protection Ensure clearing contained within Implement Ground Disturbance Senior Project As necessary prior to


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SCHEDULE

authorised areas and done in accordance with procedures/protocols

Protocol, conduct Drill Site Analyses & inspections,

Geologist / Env. Advisor

vegetation clearing

Weed Control Prevent spread of weeds Inspection, weed control programs in collaboration with Ranger groups


Post wet season, continuous field season surveillance

Vehicle/machinery washdown, inspection, clearance issue prior to leaving Myra Camp

Appropriately trained field personnel

Immediately prior all vehicles/machinery leaving Myra Camp

Rehabilitation/ Revegetation

To minimise distributed areas and ensure rehabilitation works are progressive

Schedule rehab. works as soon as possible following disturbance, follow up inspections, maintain records

Senior Project Geologist / Env. Advisor

As soon as possible following disturbance and prior to field season close out

To confirm successful vegetation re-establishment

Inspection, records, photography Env. Advisor Biannually (minimum)

Fire Controls Prevent wildfires, protect infrastructure and equipment

Inspection, maintain fire- fighting equipment, control programs in collaboration with Ranger groups


Equipment inspections (Weekly Camp Inspection), other as necessary

Animal Pests Control feral pests Surveillance, advise Ranger groups for control campaigns / implementation


As necessary during field season

WATER MANAGEMENT

Overall water management system

To ensure exploration activities do not cause contamination of ground and surface water

Implement procedures and protocols (ground disturbance, drill site analysis, drilling contractor, hydrocarbons, waste), surveillance

Senior Project Geologist / Env. Advisor

Daily, weekly and/or event depending upon issue

Erosion & sediment Control

Minimise potential for erosion and sediment transportation post field season (wet season)

Implement procedures and protocols for field season closeout (particularly for access tracks)

Senior Project Geologist / Env. Advisor/machinery operator

Immediately prior to close out

Water Quality Confirm quality of any water release from drilling activities

Surveillance / Measurement Senior site person / Env. Advisor

Event

Confirm effective operation of water control procedures during drilling operations

Surveillance Senior site person / Env. Advisor/ drilling supervisor

Regular surveillance during operations

Drinking Water Myra Camp

Confirm water quality to potable standard

Measurement (DPI lab bacteriological water analysis)

Senior site person / Env. Advisor

Every 2 months (min) during field season

WASTE MANAGEMENT

Regulated Waste Record regulated wastes removed and disposed off –site at licenced facility/recycling facility

Recording /waste tracking/disposal receipts

Senior site person Event

General Waste Confirm adequacy and use of on-site storage facilities/regular removal to off site waste facility

Inspection/ Implement Waste Management Plan

Senior Site Person/all site personnel

Weekly Camp Inspection

Putrescible Waste Effective management of Myra Camp rubbish tip

Implement Waste Management Plan/Surveillance

Senior Site Person/all site personnel

Weekly Camp Inspection/ event usage

HYDROCARBON / CHEMICAL MANAGEMENT

Integrity of Containment Facilities

Confirm compliance with AS 1940 Inspection & ensure implementation of Hydrocarbon/Chemical Spill Management Protocol and procedures, machinery checks, daily pre starts

Senior Site Person, drilling

supervisor, drilling crews, field crew

Weekly Camp Inspection

Spill Kits and Procedures

Confirm spill kits intact and procedures current

Weekly (min)

Drilling Activities Minimise potential for hydrocarbon spills to water/land

Weekly (min) during drilling operations

DUST MANAGEMENT

Dust Control Minimise dust generation which could affect the environment and personal health during drilling and earthmoving operations

Surveillance of visible dust; ensure appropriate drilling control measures in place, measurement of respirable dust (personal air sampler)

Senior Project Geologist / Radiation Safety Officers

Regular surveillance during drilling activities, respirable dust measurements as necessary

Minimise dust on access tracks, camp surrounds

Surveillance, enforce speed limits Senior Site Person Regular surveillance


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SCHEDULE

NOISE MANAGEMENT

Noise Control Minimise noise generation which could affect native fauna and personal health during drilling and earthmoving operations

Surveillance, inspections of fixed and mobile plant and equipment

Senior Site Person, drilling supervisor, machinery operator

Regular surveillance, daily machinery pre starts

Table 6 - Radiation Monitoring Schedule

Airborne dust monitoring

Area

Method

Frequency

June July Aug Sept Oct Comment

Drill Rigs Personal dust sampler Weekly When operating in potentially

mineralized ground.

Core Shed Personal dust sampler Weekly

When cutting core

Surface contamination monitoring

Area

Method

Frequency


Drill Rigs Alpha scintillometer Weekly

When operating

Core Shed (including core

saws) Alpha scintillometer Weekly

When in use

Camp (offices, kitchen, laundry

etc) Alpha scintillometer Monthly

When drilling

Vehicles Alpha scintillometer Monthly Monitor when leaving site. Limit for

release = 20 c/m

Gamma radiation monitoring

Area

Method

Frequency


All Relevant personnel

TLD badges Quarterly Results to be sent to personnel if

requested

Drill Rigs Gamma counter Weekly

When operating & when leaving site

Core Shed (including core

saws) Gamma counter Weekly

When operating

Vehicles Gamma counter As reqd Monitor when leaving site.

Limit 0.5µS/hr

Sample drums Gamma counter As reqd

Monitor when leaving site

Core storage area Gamma counter Monthly

When change

Waste sumps Gamma counter Monthly

When saws operating

Camp (offices, kitchen, laundry

etc) Gamma counter Monthly

When drilling


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5.6 Environmental Performance

5.6.1 Objective and Targets

Alligator Energy has a range of procedures/protocols identifying quantitative and measurable targets to meet objectives and mechanisms to ensure performance is being met. Objectives, and how they will be met, are as follows:

Open and accountable communication with regulators and local communities Alligator Energy, through close involvement of senior management, maintains regular communications with regulators and consultation/interaction with local communities. The success of the strategy employed by company executives is measured by the cooperative relationships which have developed since the company initiated its exploration activities in Arnhem Land. It is the company’s policy to continue to develop and maintain strong relationships with all stakeholders.

Minimize impact to the environment and heritage in accordance with community and regulatory standards

Minimising impact to the environment and heritage is one of Alligator Energy’s primary exploration requirements. The company has established various procedures/protocols and mechanisms for assessment of performance as generally described in following paragraphs.

Compliance with environmental laws, regulations and conditions as a minimum standard. Alligator Energy is committed to achieving full compliance with environmental laws, regulations and conditions beyond minimum standards. This is achieved by employment of appropriately qualified and experienced senior managers to design, develop, document and implement procedures/protocols for environmental issues on the exploration tenements. The success of environmental management and performance is measured by continual surveillance and monitoring of site activities and regular detailed internal environmental audits (minimum of 2 to 3 per field season depending on the level of exploration activity). Furthermore, an annual external audit conducted by DPIR, NLC and OSS provides an additional measure of compliance. Underperformance is rectified; procedures/protocols reviewed/amended and additional personnel training provided as necessary to ensure targets and objectives are met in the future. The DPIR/OSS/NLC audits conducted for the TCC Project tenements in September 2012, 2013 and 2014 had no findings of Conditional Grade or above thus indicating a high level of compliance. The audit for the Beatrice/Tin Camp Creek Projects for 2015 had two conditional findings – one relating to non smoking signs and one relating to drill hole plugging technique. Both conditional findings were immediately actioned. Alligator is committed to maintaining a high level of compliance across all its tenements.

Consultation with Traditional Owners to ensure control measures meet local community and cultural standards.

Alligator Energy meets with the NLC and Traditional Owners each year prior to commencing exploration activities. Traditional Owners are advised of the proposed work program as required under the ALRA. Designated no-go zones are excised from the licence by DPIR at grant and work program areas are reviewed by archaeological surveys prior to commencement of field activities. Local traditional owners are employed as field assistants during the field season and these personnel are thoroughly apprised of work procedures/protocols and continuing advice is sought to ensure that the procedures/protocols conform to local community and cultural standards and expectations. Success is measured predominately by feedback from the Traditional Owners.

Incorporating risk assessment and hazard Identification into operational and business planning. Risk assessment and hazard identification of operational and business planning forms an integral part of Alligator Energy’s activities. The company employs a detailed Risk Management Plan approved by NT Worksafe in planning and implementation of its activities. The Plan includes Risk Matrices for health and


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safety, radiation exposure, environmental risk and incident reporting. The Plan also includes a detailed Risk Register which identifies a comprehensive range of activities. For each activity, the aspect/hazard, impact consequences, likelihood and consequences, risk rating, control measures, control measure effectiveness assessment and accountability is documented. Success of the risk assessment and hazard strategy is predominately judged by the company’s performance in all its operations. Protocols/procedures define requirements and inspections/audits assess performance and require rectification of underperformance.

Incorporating Cleaner Production and Risk Control Hierarchy principles into control measures. Protocols/procedures implemented on Alligator Energy tenements have been developed with due regard to cleaner production and risk control hierarchy principles. Emphasis is placed on environmental and safety issues including ground disturbance procedures/protocols for establishment of access tracks, drill pads, sumps and the like. An example is the Drill Pad Protocol which requires the following initial steps:

“A drill site analysis is to be completed by the site geologist and field supervisor to identify potential risks and determine risk controls and logistical requirements. Risk controls should consider the risk management hierarchy”.

Preference Control Example

1. Eliminate Removing the hazard

2. Substitute Replacing a hazardous substance or process with a less hazardous substance or process

3. Isolation Restricting access to plant and equipment

4. Engineering Redesign a process or site, may involve using barriers

5. Administrative Adopting standard operating procedures (SOPs) or safe work practices.

6. PPE The provision and use of personal protective equipment.

Subsequent review of the performance of the pad will determine if the objectives/targets nominated in the particular procedure/protocol have been successful in meeting objectives/targets or additional review is necessary.

Ensuring experienced personnel are involved with all aspects of operations and that all personnel have

appropriate training and guidance. Alligator employs appropriately qualified and experienced senior managers to design, develop, document and apply procedures/protocols to all relevant aspects of its operations. Procedures/protocols are documented. All personnel are trained in the practical implementation of the requirements of the procedures/protocols including demonstrations by personnel experienced in each aspect/issue. Ongoing training and guidance is provided as necessary to ensure compliance with performance targets. Management carries out regular ongoing checks/audits of compliance with performance targets and ongoing training/guidance is provided as necessary to maintain a high level of compliance.

Minimizing waste streams. Alligator has in place a Waste Management Plan. The performance target for waste management is application of the waste management hierarchy contained in accepted protocols and legislation as follows:

Waste avoidance

Waste re-use

Waste recycling

Energy recovery from waste

Waste disposal The plan contains operational practices to be observed on all Alligator held or operated tenements under the hierarchy and also includes a procedure for landfill management. Training is provided to all Alligator personnel and all site personnel, including contractors, are inducted in relation to requirements. Regular monitoring/surveillance is


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carried out by senior site management and waste management is included in the internal environmental audits conducted during the field season (a minimum of 3 audits per field season). Ongoing training/guidance is provided as necessary to site personnel to maintain a high level of waste management compliance.

Undertaking progressive rehabilitation of exploration disturbance to best practice industry and community standards. Alligator is very aware of the requirement for best practice in conducting its rehabilitation activities on its tenements. The MMP provides details of issues, targets and operational practices. Alligator has developed, documented and implemented a number of procedures/protocols which detail requirements for minimising exploration disturbance and rehabilitation requirements. Rehabilitation is programmed on a progressive basis whenever possible with all necessary rehabilitation actions completed prior to the end of each field season. All disturbance will be documented with photographs and location prior to disturbance and following rehabilitation works. Follow up inspection and photography will be conducted as soon as practicable at the start of the subsequent field season. Rehabilitation works will be regularly monitored during the field season by senior site management to ensure the program is being effectively implemented. Rehabilitation progress will be included in the internal environmental audits conducted during the field season (a minimum of 3 audits per field season). An annual audit is also conducted by DPIR/OSS/NLC personnel.

Rehabilitation progress reports will be prepared to document rehabilitation success and identify any follow up actions required to achieve required outcomes. An interim rehabilitation report may be prepared at the conclusion of the field season if considered necessary with a final report following an inspection at the start of the subsequent field season. The final report will include reference to inspections/outcomes/required actions of past years rehabilitation as applicable. The annual DPIR/OSS/NLC audit will also provide feedback on rehabilitation success, as was the case in 2011, 2012, 2013 and 2014 for the TCC Project tenements and in 2015 and 2018 for the combined TCC Project and Beatrice Project tenements. Such feedback can be applied across all Alligator held or operated tenements.

Work and Camp sites will be inspected routinely and their condition recorded, photographed and documented.

Where water quality monitoring is undertaken these results will be recorded and stored.

Continued monitoring of all land disturbance areas (tracks, drill sites) indicates that natural revegetation has been successful in the majority of instances. Traditional Owner representatives will be invited on a regular basis to inspect work areas and ongoing rehabilitation and will provided with all monitoring information on request.

5.6.2 Performance Reporting

5.6.2.1 Radiation Monitoring Results Summary 2018

Radiation Monitoring Radiation monitoring during 2018 was specific to the Tin Camp Creek Project. No ground disturbing work was

conducted on the Beatrice tenements during 2018. Radiation monitoring on the TCC tenements during the 2018 field season was limited due to the shorter field season

and fewer activities carried out which included geological reconnaissance, RC-DD drilling sampling and logging. Monitoring included initial alpha and gamma monitoring around Myra Camp (at core shed, sample drums and camp generally), drill sites and drilling equipment combined with continual monitoring of RC chips and core along with regular follow up monitoring. Results were consistent with results from previous years.

Monitoring equipment used included a Ludlum model 44-38 Beta-Gamma detector, a Ludlum model 43-65 Alpha Scintillometer and a Ludlum Model 2241-3 Survey Meter.

Personal Gamma dose monitoring (personal TLD badges) was conducted. No airborne dust monitoring was conducted due to limited and intermittent RC drilling capacity. Radiation monitoring of road vehicles leaving Myra Camp was conducted as necessary with all vehicles having

accessed site past Myra onto active exploration grounds surveyed for Gamma and Alpha before being allowed to depart.

Monitoring was overseen by Alligator Energy personal holding appropriate licences under the SA Radiation


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Protection and Control Act to act as a Radiation Safety Officer.

5.6.2.2 Water Monitoring Results

Drinking Water Quality

Drinking water for Myra Camp is sourced from Tin Camp Creek. The water is treated through two particulate filters and an ultra violet tube. At the start of the 2018 field season, filters were replaced and the ultra violet tube was confirmed as operational. Sampling and bacteriological testing (total coliform, E. coli and total viable bacteria) to

confirm compliance with drinking water standards was conducted twice during the limited field season in August shortly after the opening of camp and commencement of operations and approximately 6 weeks later during early October. Microbiological results from these tests confirmed successful operation of the system since 2011 (100% compliance from 16 separate tests of drinking water between 2011 and 2018).

Environmental Water Quality

Sampling and testing of water from Tin Camp Creek upstream and downstream of Myra Camp has been conducted generally on a monthly schedule during all the field seasons since the start of Alligators operation in 2011 to monitor any potential influence on creek water quality due to the septic and grey water system installed at the camp. The results of bacteriological testing by DPI have showed no particular discernible adverse effects since 2011 indicating that the system has performed in an acceptable manner even when camp personnel numbers were in excess of 25. During the limited duration 2018 field season, personnel numbers at Myra Camp at any one time averaged 6 to 12 placing minimal load on the septic and grey water system. Monitoring was conducted twice throughout the 2018 field season as a consequence.

No environmental water quality monitoring was considered necessary elsewhere on the Beatrice tenements due to no ground disturbing work being conducted during the 2018 field season.

5.6.2.3 Rehabilitation Monitoring Results

There was no ground disturbance on the BT tenements during the 2018 field season. Ground disturbance during the 2015 field season comprised establishment of 17.2 kms of low impact access tracks, 87 minor disturbance drill pads, 5 sumps for the disposal of drill cuttings and 3 helicopter landing / equipment laydown areas. Very minor ancillary disturbance was associated with accessing and transfer of water for drilling activities.

Drilling (aircore) was facilitated by a compact helicopter transportable rig, a small compressor and two Polaris ATVs. The drill rig was mobilised by a small excavator which was heli lifted in various component parts to the project area from Myra Camp and then reassembled.

Rehabilitation activities of the majority of areas disturbed during the 2015 exploration program were initiated on a progressive basis during the program. All rehabilitation activity was concluded shortly following the completion of the final drill hole and drill rig demobilisation in early November 2015.

The status of rehabilitation of drill pads was tracked during the rehabilitation process by maintaining a spreadsheet of progressive activities conducted on all the pads. Items recorded included drill hole/pad ID, co-ordinates, equipment removed including waterlines, litter removal, hole plugging, sump backfilling, site re-contouring, final radiation monitoring, photography at the completion of works and any pertinent comments.


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The status of the rehabilitation was inspected in April 2016. Photographs were taken of all drill pads and a number of representative access track sections and heli landing/equipment laydown areas. The status of rehabilitation after a single wet season was extremely good. An interim Rehabilitation Report for the 2015 field season works was prepared and attached as Appendix 8 to the 2016 MMP for the Beatrice Project.

In April 2017, an additional comprehensive inspection of the 2015 field season rehabilitation works was carried out. This involved walking the entire track system and photographing drill sites, sumps and other areas disturbed during 2015. A rehabilitation report for the 2015 field season works was prepared and submitted as an attachment to the 2017 MMP titled Final Rehabilitation Report 2015 Field Season Works.

5.6.2.4 Hydrocarbon Monitoring Results

Hydrocarbon monitoring at Myra Camp was conducted as part of a weekly camp inspection during 2018. The results of the inspections were recorded on an inspection sheet. Items inspected included bulk storage facilities, drummed storage facilities, stored quantities, integrity of bunds, hoses, leakages, ground contamination, status of spill kits, fire extinguishers and so on. Hydrocarbon monitoring on the Beatrice exploration areas during 2018 was not necessary considering the type of exploration conducted although Alligator Energy conducted vehicle pre starts on its front end loader and ATVs at Myra Camp. These pre starts included checks on any oil/fuel leakages, condition of fuel/hydraulic lines and other relevant components. Monitoring during the field season revealed no hydrocarbon spillages

5.6.2.5 Waste Monitoring Results

Monitoring of waste management at Myra Camp was conducted as part of a weekly camp inspection during 2018. The results of the inspections were recorded on an inspection sheet. Items inspected included general refuse bins, waste in correct bins, putrescible waste burned on a regular basis, camp dump fencing integrity, absence of windblown litter, septic tank maintenance and proper storage of regulated wastes, in particular hydrocarbon wastes. The inspections noted any requirements for action. Waste generated on a daily basis by field crews was removed the same day.

There were no recorded incidents involving waste during the 2018 field season. No regulated wastes (mainly waste hydrocarbons, hydrocarbon contaminated wastes) required delivery NTRS at Darwin. General wastes (not regulated or putrescible) were removed from the project area on a regular basis to council landfills. Management of putrescible wastes in the Myra Camp rubbish tip continued to be a challenge due to feral pigs.

5.6.2.6 Weed Monitoring Results

Alligator Energy recognises that the spread of weeds is of particular concern to the NLC, Traditional Owners and local landcare groups and particular attention is paid to monitoring and control to assist the prevention of spreading of weed seeds. Alligator conducted an inspection, weed spraying and seed head removal program for mission grass at selected areas on the TCC tenements, along the access road to Myra Camp and in the Mikginj Valley between 4 and 12 April 2019. Collaboration was planned with Warddeken rangers as in previous years however they were unable to access site due to recent rainfall. During the 2015 field season, areas the subject of exploration activities were inspected for the presence of mission grass. There were no observations of infestations. The tracks, drill pads and heli landing/laydown areas utilised during 2015 were inspected between 16 and 17 April 2016 and 6 and 7 April 2017 and again no infestations were observed. Monitoring and control will continue during the 2019 field season in conjunction with any on-ground activities carried out.

5.6.2.7 Internal Alligator Energy Audits As noted in section 5.5.1, Alligator Energy undertakes internal auditing to ensure compliance with management system requirements and to facilitate continuous improvement. The audits test all aspects of the MMP, in particular, radiation management, weed management, hydrocarbon management, waste management, cultural and heritage site protection, flora and fauna protection, surface and groundwater management, erosion and sediment control and rehabilitation success.


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Due to a short field program during the 2018 season and timings of an external departmental audit, only one internal audit was conducted and deemed necessary. This was conducted part way through the season and complemented other inspections conducted on camp opening and closure. The audit conclusions noted that all procedures/protocols had been reviewed and found to be adequate. This audit and previous audits had confirmed application of work controls including monitoring and record keeping and maintenance of an acceptable level of compliance.

5.6.2.8 Annual OSS Environment Audit No official external audit was conducted by the DPIR, OSS and NLC during 2018 however a site inspection and review of procedures, practice and current MMPs was conducted in September 2018 by DPIR and OSS personnel, though not deemed an official audit.

5.7 Emergency Procedures and Incident Reporting

As part of Alligator Energy’s operating management system all environmental incidents, near misses and hazards are to be reported. Alligator Energy will notify relevant authorities of any environmental incident that results in non-compliance with regulatory conditions within 24 hours of the event occurring. In particular, notifiable environmental incidents will be reported to the Chief Executive Officer of the Department of Primary Industry and Resources (DPIR) on Form CF7-001 – Notification of a Serious Accident or Critical Incident (Environmental). The DPIR Advisory Note – Environmental incident reporting under Section 29 of the Mining Management Act will provide guidance in relation to assessing the severity of an incident and reporting requirements. Internally, all environmental and safety incidents are reported to the company CEO.

The company Risk Management Plan requires safety and environmental emergency procedures be tested on a regular basis.

Alligator Energy will implement the following steps in the event of an environmental incident:

Undertake immediate inspection, temporary control and internal notification to management and outside authorities if relevant;

Notification to Traditional Owners’ representative (Monitor or employed TO) Identify corrective actions to be undertaken to mitigate any adverse consequences; Follow up to ensure corrective actions are implemented; Identify changes to work procedures to ensure the incident does not reoccur; Emergency response is supported by SAT phones and UHF receivers in vehicles and the camp, first aid kits,

adequate provision of drinking water and fire extinguishers in all vehicles. Portable spill kits are carried in operational vehicles or are available at drill and other operational sites

All employees and contractors are briefed at site inductions on the procedures and documentation required in case of an emergency and the requirement to report and record all environmental and safety incidents. Reporting forms will be readily available to all personnel. Incident reporting forms allow staff to review and take corrective and preventative action for the future.

Hydrocarbon spillage is one of the principal causes for an environmental incident during exploration activities. Earthmoving machinery, drill rigs and support vehicles, stationary and mobile equipment and vehicles have potential to release hydrocarbons by refuelling and transportation spillage, engine and hydraulic oil spillage by leakage and/or hose and coupling failure and so on. Drilling activities have the potential to release drilling fluids and drill cuttings and sludge to land and waters, earthmoving activities (access tracks, drill pads) have the potential to cause significant land disturbance and result in reduced land capability and weed infestation, stormwater runoff from disturbed areas has the potential erode, mobilise and transport sediment and turbid water and sediment discharge can alter the characteristics of receiving waters and may impact downstream ecosystems. Alligator Energy has developed a number of procedures/protocols focussed on prevention of environmental incidents including protocols for ground disturbance, drill site analysis and drill pad establishment and procedures for drilling contractors. These have been particularly effective in operational management and the prevention of environmental


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incidents. The principal environmental incident procedure relates to hydrocarbon spill prevention and management and recording and reporting. All incidents are reported on the Alligator Energy Incident Report Form – Environmental. (refer Appendix 9 – Protocols and Reporting Forms included in the 2016 MMP for the Beatrice Project.).

6.0 Exploration Rehabilitation

6.1 Exploration Rehabilitation Register

6.1.1 Rehabilitation Methods

Alligator Energy recognises that rehabilitation is an essential component of exploration planning and execution.

The nature and scale of rehabilitation works carried out at on the tenements and techniques used depend upon the type of exploration activities conducted. Generally rehabilitation will be progressive during the field season and responsive to changing conditions and requirements. Timing and extent of rehabilitation works will depend on equipment availability, weather conditions and the design and staging of exploration activity during a particular field season and proposed activities in subsequent field seasons. A description of general rehabilitation methods employed for a typical exploration program carried out during a four to six month field season is shown in Table 7. Table 7: Description of Rehabilitation Methods

Disturbance Rehabilitation Methods Schedule (Timing)

Closure Objectives / Targets

Monitoring and Remediation

Drill pads/Drill Holes

Drill pads will be rehabilitated following completion or subsequent down hole probing:

All sample bags and other rubbish to be removed prior to rehabilitation works;

Drill chips, if any, remaining at the site will be returned to the hole if practicable or to an in-ground purpose dug sump ;

Any other potentially uranium mineralised material will be disposed of to the purpose dug in-ground sump;

Drill holes will be capped/plugged in accordance with DPIR guidelines as soon as practicable following drilling;

Pads will be re-shaped to a condition similar to the original contours with appropriate drainage ;

Pads will be ripped if necessary to break up compacted areas;

Previously stripped sub soil and top soil will be spread over the pad prior to ripping;

Any vegetation previously cleared to establish the pad will be re-spread over the pad

Seeding will be carried out as necessary using direct seed techniques with local provenance seed if natural regeneration has not occurred within a reasonable time period;

Collars to be temporary capped at the completion of each hole prior to permanent plugging

Drill pads will be rehabilitated following completion or subsequent down hole probing:

Rehabilitation work will be completed within 6 months after drill hole completion or prior to the onset of the wet season whichever comes first;

The aim for rehabilitation works will be as soon as possible

All holes plugged/capped and stable/safe prior to end of field season program

Drill sites to be returned to original contour and to blend with surrounding environment to the extent practicable

Revegetation to be established to conform as close as possible to adjacent vegetation in density and species mix

Inspection of drill sites to be undertaken at end of subsequent wet season or within six months to monitor site stability, erosion, weeds and natural vegetation regrowth.

Ongoing monitoring to be undertaken in subsequent years to monitor rehabilitation success.

Monitoring to encompass 2 wet season as a minimum

Remediation of any unsuccessful objectives to be initiated at the inspection

Before, immediately after, and subsequent year photos to be taken to confirm plug and rehabilitation success


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Drill collars may be capped and left accessible for future down hole probing. Upon completion of work in the area, these collars will be removed and the site closed out. If this is not required, the holes will be finally rehabilitated and collars will be permanently plugged and buried.

following completion of drill hole

Sumps (drillhole)

In ground sumps for diamond drilling have not been used by Alligator Energy since 2012. Alligator Energy now requires diamond drilling contractors to use above ground tanks to contain drilling fluids/drill cuttings. As necessary during drilling and at the conclusion of each drill hole, sludge is pumped from the above ground tanks into a mobile tank which is then emptied into a large purpose dug sump or sumps in proximity to the drilling area.

The locations of the sludge disposal sumps are carefully selected to ensure nil or minimal potential for environmental impact, both surface and sub surface.

Sumps will be rehabilitated as soon as practicable following drilling:

Drilling fluid in the sumps will left to settle and evaporate to the extent possible;

Following settling and evaporation, any remaining clear water/liquids remaining in the sumps may be pumped into surrounding bushland away from natural drainages if this poses no environmental hazard;

Sumps will then be back filled (at least 1 metre depth of fill) and left with slight mound to allow for subsidence;

Topsoil and vegetation will then be spread over the area.

Sumps will be rehabilitated as soon as practicable following drilling completion (completion within 6 months after drill program or prior to the onset of the wet season whichever comes first);

All sumps backfilled and stable/safe prior to end of field season program

Sump area to be returned to original contour and to blend with surrounding environment to the extent practicable

Sumps will then be back filled (at least 1 metre depth of fill) and left with slight mound to allow for subsidence;


Inspection of sump sites to be undertaken at end of subsequent wet season or within six months to monitor site stability, erosion, weeds and natural vegetation regrowth.





Costeans There have been no costeans excavated by Alligator Energy on the Beatrice Tenements to date and none are proposed in the foreseeable future

Bulk sample pits

There have been no bulk sample pits excavated by Alligator Energy on the Beatrice Tenements to date and none are proposed in the foreseeable future


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Tracks / Gridlines

Vegetation and any removed topsoil (if any) will be respread;

Windrows and cleared vegetation to be smoothed back over the track

Culverts (if any) placed at creek/gully crossings will be removed prior to the wet season to ensure re-establishment of natural drainage pathways;

Tracks will be ripped or scarified if necessary where soil is compacted;

Whoa boys will be placed at appropriate intervals along the tracks to assist in the control of erosion;

If seeding is required, direct seed using local provenance seed; and

Rehabilitated tracks will be demarcated and/or blocked by appropriate means eg; logs, rocks as required to limit access.

Access tracks will be rehabilitated annually at the completion of exploration program and prior to the wet season;

On final closure, the local Traditional Owners will be consulted as to which tracks they wish to retain for permanent land access.

The main access tracks generally will be ripped and seeded, with erosion control structures placed as required.

Sample bags

Sample bags to be removed and drill cuttings to be backfilled in the drillhole, or buried in the central sump; Radioactive or acidic drill cuttings to be backfilled in the drillhole or buried in the central sump beneath a minimum of 1 m clean fill.

Empty sample bags are to be removed to Myra Camp for temporary secure storage prior to disposal to licenced landfill off tenement

Bags are to be emptied and removed from drill sites as soon as practicable after completion of drill hole and prior to the end of the field season/wet season at the latest

No bags are to remain at drill sites.

Bags are to be removed from tenement (and Myra Camp) as soon as practicable

Monitor to ensure no bags remaining at drill sites and tenement

Camps Camps (cont)

No camp sites are proposed for the Beatrice tenements.

Closure criteria have not been fully developed for the rehabilitation of the Myra camp as it is expected that field activities will be ongoing for many years.

The following outlines the general process which would be followed in order to rehabilitate these sites.

Upon cessation of exploration activities in western Arnhem Land an experienced contractor will be commissioned to remove all infrastructure from the field camp.

Once all infrastructure has been removed, the camp area will require a contaminated site survey and possible remediation in some areas.

The camp area will then be re-

Temporary /short term camp sites are to be rehabilitated as soon as practicable after demobilisation of camp infrastructure

Permanent camp sites eg Myra Camp will be subjected to progressive rehabilitation following removal of infrastructure and any

Camp sites to be returned to original contour and to blend with surrounding environment to the extent practicable


Inspection of rehabilitated camp sites to be undertaken at end of subsequent wet season or within six months to monitor site stability, erosion, weeds and natural vegetation regrowth.




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contoured to prevent water ponding or the formation of preferential flow paths leading to soil erosion.

Finally, the camp area will be ripped and revegetated using local providence seed with ongoing monitoring and management required to control weed invasion or fire.

necessary site investigations

Rehabilitation will generally not be necessary if the camp is taken over by other interests eg; exploration companies, ranger groups, indigenous groups



6.1.2 Rehabilitation Status

The status of rehabilitation activities on the Beatrice tenements was provided in Appendix 5: Rehabilitation Register attached to the 2017 MMP for the Beatrice Project. In particular, the following relevant tables were included with Appendix 5:

Exploration Activities Rehabilitation Summary (Cumulative)

Drill Hole/Pad Rehabilitation Status

Access Track/Drill Line Rehabilitation Status

Bulk Sample (Drill Cuttings) Disposal Status Note that for the Beatrice Project tenements, the rehabilitation status data only refers to Alligator Energy exploration activities which commenced during the 2015 field season. Details of rehabilitation activities conducted by previous explorers, most recently Cameco Australia, are not known. Cameco advised Alligator Energy in April 2015 that they were preparing a closure report for outstanding disturbance prior to 2015. As noted in Section 5.6.2.3, an interim Rehabilitation Report for the 2015 field season works was attached as Appendix 8 to the 2016 MMP for the Beatrice Project. Included in the interim report is the 2015 Rehabilitation Status Spreadsheet as at 17 April 2016. The report included a range of representative before and after rehabilitation photographs and photographs from the initial post wet season inspection conducted in April 2016. On 6 and 7 April 2017, an additional comprehensive inspection of the 2015 field season rehabilitation works was carried out. This involved walking the entire track system and photographing drill sites, sumps and other areas disturbed during 2015. A rehabilitation report for the 2015 field season works has been prepared and is attached as a separate document to the MMP titled Final Rehabilitation Report 2015 Field Season Works. The report concludes: “Inspections following two wet seasons have confirmed the success of rehabilitation works conducted on the project area during the 2015 field season. Comprehensive inspections of the rehabilitation works areas were conducted following completion in 2015 and on 16 and 17 April 2016 and, almost without exception, showed a high level of rehabilitation success after only 6 months and a single wet season. A final inspection during April 2017 confirmed the expected successful outcome of rehabilitation. It is concluded that disturbance as a result of the 2015 field season work has been satisfactorily rehabilitated and can be excluded as a cost item for security calculation purposes for the Beatrice Project”.


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As a consequence, the security of $25,240 was reduced to $5,000 in 2017 and was maintained at that level in 2018. No on ground activities were conducted on the Beatrice tenements during the 2018 field season.


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figures

Figure 1 – Location Map

Appendix 2

Appendix 3

Appendix 4

2019 mining management plan beatrice project els 24291 ... · the beatrice project, comprising...

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