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Hillside Copper Mine

Air Quality Management Plan Program for Environmental Protection and Rehabilitation (PEPR)

AIR QUALITY MANAGEMENT PLAN



Table of Contents

DOCUMENT OWNER .................................................................................................... 4

DOCUMENT APPROVER .............................................................................................. 4

REVISION HISTORY .................................................................................................... 4

DEFINITION OF TERMS ............................................................................................... 5

1. INTRODUCTION .............................................................................................. 6

1.1 ENVIRONMENTAL MANAGEMENT SYSTEM ........................................................................ 6 1.2 OBJECTIVES ............................................................................................................................ 6

2. AIR QUALITY CONDITIONS ............................................................................ 6

3. AIR QUALITY OUTCOMES .............................................................................. 8

4. BASELINE MEASUREMENTS AND MODELLING ........................................... 10

5. UNCERTAINTY ASSESSMENT ...................................................................... 11

6. KEY RISKS .................................................................................................... 12

6.1 DUST.......................................................................................................................................12 6.2 ODOUR ...................................................................................................................................12

7. AIR QUALITY CONTROL MEASURES ........................................................... 13

7.1 PROACTIVE AIR QUALITY CONTROL MEASURES ............................................................13 7.2 REACTIVE AIR QUALITY CONTROL MEASURES ...............................................................13 7.3 MITIGATION MEASURES ......................................................................................................13

8. CONSULTATION ........................................................................................... 19

9. RESPONSE PROCEDURES ............................................................................ 19

9.1 OPERATIONAL RESPONSE PROCESS ...............................................................................19 9.2 EXCEEDANCE PROTOCOL ..................................................................................................19 9.3 COMMUNITY RESPONSE PROCESS ..................................................................................19 9.4 LANDOWNER NOTIFICATION ..............................................................................................20

10. MONITORING PROGRAM .............................................................................. 20

10.1 MONITORING METHODOLOGY ...........................................................................................21 10.2 PM2.5, PM10 AND TSP REAL-TIME MONITORING ................................................................22 10.3 REAL-TIME MONITORING – EARLY WARNING ..................................................................22 10.4 REAL-TIME DUST CONCENTRATION ALERT FUNCTIONS FOR OPERATIONAL

CONTROL ...............................................................................................................................23 10.5 HIGH VOLUME AIR SAMPLER MONITORING (PM10) ..........................................................24 10.6 DUST DEPOSITION MONITORING .......................................................................................24 10.7 METEOROLOGICAL MONITORING ......................................................................................25 10.8 CHEMICAL AND TOXICOLOGICAL COMPOSITION OF DUST EMISSIONS ......................25 10.9 WATER QUALITY TESTING OF RAINWATER TANKS ........................................................25 10.10 MONITORING LOCATIONS ...................................................................................................25



10.11 DATA ANALYSIS ....................................................................................................................27 10.11.1 Data Validation Procedure .......................................................................................27 10.11.2 Real-Time Particulate Monitoring (PM10) .................................................................27 10.11.3 Dust Deposition Monitoring .....................................................................................27 10.11.4 Calibration of Equipment .........................................................................................28

11. REPORTING .................................................................................................. 28

12. PERFORMANCE INDICATORS ...................................................................... 28

13. CONTINUAL IMPROVEMENT ........................................................................ 28

14. REVIEW ......................................................................................................... 29

15. REFERENCES ................................................................................................ 29

16. APPENDICES ................................................................................................ 31



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List of Tables Table 1: Background concentration data ................................................................................................10 Table 2: Major sources of dust in year five .............................................................................................10 Table 3: Major sources of dust in year nine ...........................................................................................11 Table 4: Actions to be taken to check air quality related assumptions during early operations .............11 Table 5: Dust sources, mitigation measures and responsibilities ..........................................................13 Table 6: Summary of air quality compliance criteria ..............................................................................21 Table 7: Trigger levels and description of responses (suggested for commencement of operations)...23 Table 8: Hillside Mine air quality proposed monitoring locations ...........................................................26

List of Figures Figure 1: Sensitive Receptor Locations ..................................................................................................31 Figure 2: Monitoring Locations ...............................................................................................................32 Figure 3: Location Map of year five operations – Predicted Annual Average PM2.5 Concentrations .....33 Figure 4: Location Map of year five operations – Predicted Maximum 24hr PM10 Concentrations .......34 Figure 5: Location Map of year five operations - Predicted Annual Average TSP Concentrations .......35 Figure 6: Location Map of year five operations – Predicted Annual Average Dust Deposition .............36 Figure 7: Location Map of year nine operations - Predicted Annual Average PM 2.5 Concentrations ...37 Figure 8: Location Map of year nine operations – Predicted Maximum 24hr PM10 Concentrations ......38 Figure 9: Location Map of year nine operations – Predicted Annual Average TSP Concentrations .....39 Figure 10: Location Map of year nine operations – Predicted Annual Average Dust Deposition ..........40

List of Appendices Appendix 1: Location Maps Appendix 2: Correspondence Records Appendix 3: Air Quality/Dust Complaints Form Details Example Appendix 4: Hillside Mine Contribution Dust Concentration Calculation Appendix 5: Air Quality Management Plan Requirements Checklist



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Document Owner

Sustainability Manager Document Approver

Project Director Revision History

Version No. Date Published Details 1.0 14/03/2017 First draft – Management review 2.0 08/05/2017 Technical Review - PEL 3.0 01/06/2017 HMCV Draft copy



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Definition of Terms

µg/m3 The concentration of an air pollutant is given in micrograms (one-millionth of a gram) per cubic meter air or µg/m3.

µm Micro metre.

ACR Annual Compliance Report.

Aerodynamic diameter

The aerodynamic diameter of an irregular particle is defined as the diameter of the spherical particle with a density of 1000 kg/m3 and the same settling velocity as the irregular particle.

AQMP Air Quality Management Plan.

Automatic weather station (AWS)

AWS consists of a weather-proof enclosure containing the data logger, rechargeable battery, telemetry (optional) and the meteorological sensors with an attached solar panel or wind turbine and mounted upon a mast.

Beta attenuation monitoring (BAM)

Widely used air monitoring technique employing the absorption of beta radiation by solid particles extracted from air flow. This technique allows for the detection of PM10 and PM2.5, which are monitored as standards by most air pollution regulatory agencies.

DDD Directional Dust Deposition (including both ambient and mine related dust).

DSD Department of State Development, South Australia.

EMS Environmental Management System.

EPA Environment Protection Authority, South Australia.

GHG Greenhouse Gas Emissions.

High volume air sampler (HVAS)

A high volume air sampler is used to collect TSP samples. The high volume air sampler draws a large known volume of air through a pre-weighed filter for 24 hours. The sampler filter traps the TSP particles as air passes through the instrument. After sampling, the filter is re-weighed and the difference in filter weight is the collected particulate matter mass. Dividing the mass by the volume of air sampled gives the concentration of TSP.

HMCV Hillside Mine Community Voice.

IS14001:2004 Environmental management systems – Requirements with guidance for use.

ML Mineral Lease 6438.

Particulate Matter

Refers to a category of airborne particles that range from 0.1 micrometres (µm) to 50 µm in aerodynamic diameter.

PM10 Particulate matter with an equivalent aerodynamic diameter equal to or less than 10 μm.

PM2.5 Particulate matter with an equivalent aerodynamic diameter equal to or less than 2.5 μm.

ROM or ROM Pad

Run of mine pad.

TDD Total Dust Deposition or Average Dust Deposition.

TSF Tailings Storage Facility.

TSP (total suspended particulates)

Including PM10 and all larger particle size fractions which normally stretches to particles of a size of an equivalent aerodynamic diameter of 30 to 50 μm. Due to higher settling velocities for larger particles, these tend to settle out of the atmosphere at closer distances than smaller particles which are carried further from the source.



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1. INTRODUCTION

Rex Minerals Limited plans to develop and operate the Hillside Mine, situated 12 kilometres south of the township of Ardrossan. Conventional open cut mining techniques will be employed using trucks and excavators to deliver ore to a processing plant that will produce a copper concentrate.

Data from the Air Quality monitoring program will be used to determine the air quality impact from the Hillside Mine operations on the surrounding air environment, and the compliance with lease conditions and other statutory requirements.

1.1 ENVIRONMENTAL MANAGEMENT SYSTEM

Rex Minerals is committed to minimising the impact of its operations on the local environment and community, and is developing a comprehensive Environmental Management System (EMS), that will be based on the International Standard 14001:2004. This AQMP is a component of the Hillside Mine EMS. 1.2 OBJECTIVES

The objective of this Plan is to provide the framework for:

• ensuring compliance with all relevant statutory requirements;

• Rex Minerals Policies and Standards;

• implementing applicable practice air quality tools to manage and minimise the impact of dust from mining operations on the environment and nearby residences;

• providing details on air quality management responsibilities;

• identifying and implementing reasonable and feasible measures to minimise the release of, and prevent the emission of, offensive odours;

• maintaining acceptable levels of amenity for surrounding residents; and

• maintaining an effective response mechanism to deal with issues and complaints.

2. AIR QUALITY CONDITIONS

The following Hillside Mine ML conditions (Second Schedule) relate to air quality.

1. The Tenement Holder must ensure that:

1.1. The total PM10 dust concentration (including both ambient and mine related dust) leaving the site is less than 50µg/m3 as a 24 hour (midnight to midnight) average of measurements taken at intervals of not more than 10 minutes; or

1.2. where the total PM10 dust concentration entering the site exceeds 50µg/m3 as a 24 hour (midnight to midnight) average of measurements taken at intervals of not more than 10 minutes, the total PM10 dust leaving the site does not exceed the measured level entering the site during that period.

2. Subject to Condition 3 the Tenement Holder must comply with the Ambient Air Quality National Environmental Protection Measure (NEPM) dust concentration standard for PM2.5 leaving the site, measured on average over a 24 hour period (midnight to midnight) with measurements taken at intervals of not more than 10 minutes.



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3. Condition 2 is applicable unless and until the Director of Mines has notified the Tenement Holder in writing that he is satisfied that the Tenement Holder has:

3.1 Demonstrated compliance with Condition 2 for a period of no less than one consecutive year after the commencement of mineral processing; and

3.2 established that PM10 measurements can be used as a proxy for PM2.5 measurements.

4. The Tenement Holder must ensure that; (i) the TDD leaving the site does not exceed 4g/m2/month averaged over all 12 month periods; and (ii) the mine contribution to TDD leaving the site does not exceed 2g/m2/month for all months.

5. The Tenement Holder must ensure that TSP leaving the site does not exceed an average of 120 µg/m3 for all 24 hour periods (midnight to midnight) and an average of 90 µg/m3 for any 12 month period, unless the tenement holder:

5.1 Provides information (from dust dispersion modelling, operational monitoring or otherwise) that satisfies the Director of Mines that, if the tenement holder exceeds the limits outlined above, there will be no increase in public nuisance from:

5.1.1 air emissions; and/or

5.1.2 dust generated by mining operations; and

5.2 obtains written approval from the Director of Mines to conduct mining operations subject to an alternative TSP limit or limits (on such conditions as the Director of Mines thinks fit and specifies in writing, if any); and

5.3 complies with any alternative TSP limits approved in accordance with Condition 5.2, and any associated conditions.

6. In the event that monitoring shows that Conditions 1, 2, 4 or 5 have been breached, the Tenement Holder must immediately cease the activity which resulted in the breach.

7. The Tenement Holder must measure chemical and toxicological composition of dust emissions generated by mining operations through an ongoing air monitoring program.

8. The Tenement Holder must:

8.1. Within 6 months of the grant of this Lease write to all third parties who have an interest within the Land, or in land within 4 kilometres of the boundary of the Land, and offer to undertake (at least annual) water quality testing of all rainwater tanks owned (or used) by those third parties; and

8.2. where a third party who has an interest within the Land, or in land within 4 kilometres of the boundary of the Land, indicates to the Tenement Holder that they wish to have rainwater tanks that they own or use tested, undertake testing of the relevant tank(s); and

8.3. if testing of a tank is undertaken, provide the third party with those test results (reported against the most recent Australian Drinking Water Guidelines (Australian Government)) within one month of the sampling.

9. The Tenement Holder must ensure that PM2.5 and PM10 dust concentration data and meteorological monitoring data acquired by the Tenement Holder is reported in real time to the public



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on an unrestricted internet site. The monitoring data must be retained and remain accessible on the unrestricted internet site for the life of the mine.

The air quality criteria applicable to the Hillside Mine apply at privately owned residences and privately owned cropping land. Privately owned land is considered dust-affected when dust levels exceed the criteria at any residence on privately owned land.

3. AIR QUALITY OUTCOMES

The following Hillside Mine ML clauses (Sixth Schedule) relate to air quality.

1. The Tenement Holder must ensure that there are no public health and/or public nuisance impacts from air emissions and/or dust generated by mining operations.

2. The Tenement Holder must, in construction, operation and post mine completion, ensure no loss of abundance or diversity of native vegetation on or off the Land through:

2.1. Clearance,

2.2. dust/contaminant deposition,

2.3. fire,

2.4. reduction in water supply, or

2.5. other damage, unless prior approval under the relevant legislation is obtained.

3. The Tenement Holder must, in construction, operation and post mine completion, ensure no impacts to agricultural productivity for third party land users on or off the Land as a result of mining operations, including:

3.1. Reduction in crop yield;

3.2. reduction in grain quality; or

3.3. adverse health impacts to livestock.

4. The Tenement Holder is required to address the following matters for the purposes of Regulation 65(2)(c) of the Regulations in relation to the outcome in Sixth Schedule Clause 1;

4.1. undertake continuous dust and meteorological monitoring to inform decisions for operational response and contingency measures to be implemented to prevent exceedence of compliance criteria.

4.2. Progressive rehabilitation and stabilisation of disturbed areas undertaken throughout the life of mine to control dust emissions generated by wind erosion.

5. The Tenement Holder is required to address the following matters for the purposes of Regulation 65(2)(d) of the Regulations in relation to the outcome in Sixth Schedule Clause 1;

5.1. measure PM10 dust concentration using monitoring methodology, equipment and instruments that are recognised by a relevant International or Australian Standard.

5.2. Measure TDD using monitoring methodology, equipment and instruments that are recognised by a relevant International or Australian Standard.

5.3. Measure TSP using monitoring equipment and instruments that are recognised by a relevant



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International or Australian Standard.

5.4. DDD is to be measured using monitoring equipment and instruments that are recognised by a relevant International or Australian Standard.

5.5. Measure PM2.5 dust concentration including both ambient and mine related dust using monitoring methodology, equipment and instruments that are recognised by a relevant International or Australian Standard.

In accordance with the ML clause 42 and 43 of Sixth Schedule, Rex Minerals must ensure adjacent land use and third party property outcomes the following: 42. The Tenement Holder must during construction, operation and post mine completion, ensure that

there are no adverse impacts to third party land use on property adjacent to and on the Land as a result of mining operations, other than those agreed between the Tenement Holder and the affected user.

43. The Tenement Holder must, in construction, operation and post mine completion, ensure no impacts to agricultural productivity for third party land users on or off the Land as a result of mining operations, including;

43.1 reduction in crop yield;

43.2 reduction in grain quality; or

43.3 adverse health impacts to livestock.

Rex Minerals is required to ensure that no offensive odours exceeding the limits as defined under the Environment Protection (Air Quality) Policy 2016 are emitted from the site.

Health impacts from dust have closer links to smaller, inhalable, particle size fractions such as PM10 and finer particulate matter (PM2.5). TSP (dust) concentrations and dust deposition are considered to be more of a nuisance issue.

The distribution of particle size fractions (between finer and coarser particle size fractions) vary for different dust and particulate matter sources. For instance, higher fractions of finer particulate are generated from chemical/combustion processes compared to mechanical generation of dust, typical of general mining activities.

The air quality will be monitored for PM10, TDD, TSP, DDD, PM2.5 as defined by Standards Australia:

• AS/NZS 3580.9.11:2016 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - PM10 beta attenuation

• AS/NZS 3580.10.1:2016 Methods for sampling and analysis of ambient air - Determination of particulate matter - Deposited matter - Gravimetric method

• AS/NZS 3580.9.3:2015 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - Total suspended particulate matter (TSP) - High volume sampler gravimetric method

• AS/NZS 3580.10.2:2013 Methods for sampling and analysis of ambient air-Determination of particulate matter - Impinged matter - Gravimetric method

• AS/NZS 3580.9.12:2013 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - PM2.5 beta attenuation monitors



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4. BASELINE MEASUREMENTS AND MODELLING

Baseline measurements and assumptions for the Hillside Mine were obtained from the following sources (see Table 1). Table 1: Background concentration data

Substance Background concentration

Averaging period

Notes

PM2.5 7.7 µg/m3 1 Year Annual average of the 2008 Netley monitoring data. Compared to Queensland data 7.7 μg/m3 is likely a very conservative value to apply to Yorke Peninsula as an annual average background concentration for PM2.5. (Department of Science, Information Technology, Innovation and the Arts, 2013).

PM2.5 7.2 µg/m3 24 hour Assumed to be 40% of the background PM10 concentration (18.1 μg/m3) for Schulz Reserve, Whyalla. This ratio is based on typical urban environments and can be considered to be conservative for a rural area.

PM10 18.1 µg/m3 24 hour 70th percentile for Whyalla Schulz Reserve data for the period 2009 – 2012.

TSP 26.9 µg/m3 1 Year Annual average for site data 2012 – 2014.

TSP 27.0 µg/m3 24 hour 70th percentile for site data 2012 – 2014.

Modelling of future air quality at the Hillside Mine was conducted for years five and nine of production because these are the years where maximum mine activity occurs. Modelling has shown that the majority of dust will be generated from haul roads. Table 2 and Table 3 below show the major sources of dust during years five and nine. Year nine shows the contribution of dust emissions during stage five construction of the TSF. Appendix 1 Location Maps shows the modelled levels of dust compared to the receptor locations (Figure 3 to Figure 10 inclusive).

Table 2: Major sources of dust in year five

Activity Annual TSP

Emissions (%) Annual PM10

Emissions (%) Annual PM2.5

Emissions (%) Pit activities including haul roads 30 45 44 Loading and unloading activities 2 3 3 Wind erosion from exposed areas 5 7 10 Haul roads 62 44 42 Crushing activities 0.7 0.8 0.8 Concentrate handling and transport 0.3 0.2 0.2 TSF construction 0 0 0 TOTAL 100 100 100



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Table 3: Major sources of dust in year nine

Activity Annual TSP Emissions (%)

Annual PM10 Emissions (%)

Annual PM2.5

Emissions (%) Pit activities including haul roads 16 28 27 Loading and unloading activities 2 2 2 Wind erosion from exposed areas 3 5 7 Haul roads 50 39 38 Crushing activities 0.4 0.6 0.5 Concentrate handling and transport 0.3 0.2 0.2 TSF construction 28 25 25 TOTAL * 100 100 100

*Rounded up 5. UNCERTAINTY ASSESSMENT

Key assumptions made in predicting dust impacts by the Hillside Mine and in recommending mitigation and management controls are:

• baseline air quality data (refer to Table 4) is representative;

• emission factors for the operations at site assumed wheel generated dust (including surface silt content) and exposed surfaces are representative of site conditions;

• assumed watering frequency is adequate;

• assessment of year five and year nine is accurate;

• salt crusting on the TSF surface is effective in restricting dust generation;

• rehabilitation of overburden landforms can be scheduled to coincide with, or precede, cooler and higher rainfall periods to enable establishment of vegetation.

The following actions (refer to Table 4) will be taken during the early operational phase to check that these assumptions are satisfactory: Table 4: Actions to be taken to check air quality related assumptions during early operations

Assumption Action

Baseline air quality data is representative

Collect sufficient on site PM10 data to establish a more representative air quality baseline for the Hillside Mine (PM10 data from the SA EPA Whyalla Schulz Reserve monitoring station was used to establish baseline conditions).

Emission factors correct

Check that the emission factors for wheel generated dust from haul roads are representative of actual haulage conditions at the Hillside mine. If the assumptions used in the modelling are found to be conservative, then no further action is required. If the modelling assumptions are found to underestimate actual dust generation, then additional controls will be implemented, such as additional watering, speed restrictions and application of dust suppressants.



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Surface silt content on haul road surfaces is representative

Check that the surface silt content on haul roads used in the modelling is representative of actual haul-road construction materials. If the assumptions used in the modelling are found to be conservative, then no further action is required. If the modelling assumptions are found to underestimate actual dust generation, then additional controls will be implemented, such as more targeted selection of road surface construction material.

Assume watering frequency is sufficient

Assess the adequacy of the water truck fleet during operations and make adjustments if necessary.

Salt crusting on the TSF surface is effective

Assess the performance of dry tailings surfaces in windy conditions and apply additional management measures if required, eg. maximise wetted surface during periods if significant dust generation occurs.

Monitoring alerts system

Calibration of trigger alerts system with levels (concentrations) to ensure adequate warning ahead of time to respond to rising dust trends and avoid compliance criteria exceedances.

Rehabilitation of overburden landforms can be scheduled to avoid hot dry conditions

Ensure mine planners understand the air quality requirements for the Hillside Mine and the need to schedule landform rehabilitation activities at the most appropriate times of the year.

6. KEY RISKS

6.1 DUST

Modelling of the dust emissions from the Hillside Mine show the major sources will be from:

• haul roads; • mine activities; and • TSF construction. Modelling has shown that generally dust will be well below the ML compliance limits using standard industry control practices (eg. water trucks on haul roads). A key risk identified in the modelling is the potential for exceedance of the PM2.5 criteria in year nine to receptor 25 (see Figure 1 and Figure 7 in Appendix 1 Location Maps) during the construction of the TSF. This may require additional control measures and will require monitoring to be in place to ensure dust during construction of the TSF will be controlled. 6.2 ODOUR

There are two possible sources of odour:

• blast fumes; and • process reagents.

An odour modelling exercise has been done and results show that this will not be an issue.



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7. AIR QUALITY CONTROL MEASURES

The Hillside Mine AQMP includes a comprehensive set of both proactive (see Section 7.1) and monitoring based reactive control measures (see Section 7.2), as well as planning and practical dust mitigation control measures (see Section 7.3) designed to minimise dust and odour emissions from site. 7.1 PROACTIVE AIR QUALITY CONTROL MEASURES

The proactive air quality control measures are applied based on daily morning reviews of forecast potential air quality risks, considering planned activities, seasonal factors and short-term (up to seven days) weather forecasts. Operations risk reports can be generated by forecast modelling considering site specific conditions. The purpose of forecast based risk reports is for operations to be planned to suit the site conditions and to allow for additional controls to be planned for and put in place ahead of time. 7.2 REACTIVE AIR QUALITY CONTROL MEASURES

Reactive air quality control measures are triggered through air quality monitoring for management purposes and from compliance monitors. There are three levels of action trigger alerts from monitoring based on the dust concentrations and averaging times making up performance trend lines. The actions to be taken following a trigger alert will be staged and include: review and modify operations; apply additional controls; reduce or stop activities. Details on the reactive alerts based air quality control methodology are provided in Section 9. 7.3 MITIGATION MEASURES

Table 5 describes the air quality mitigation measures for sources of wind-blown and activity generated dust due to mining operations and summarises the responsibilities that have been documented within this Plan. A major management tool in all instances will be daily on-site visual inspections of dust generation from operations and alerts of exceedances from the real-time boundary and compliance monitoring. The monitoring based trigger alert system provides notifications that enable operational activities to be adjusted to avoid exceedances of regulatory air quality measurement criteria.

Table 5: Dust sources, mitigation measures and responsibilities

Source Air quality mitigation measures Responsibility Timing

Wind-Blown Dust Sources

Areas disturbed by mining operations

Disturb only the minimum area necessary for mining. Mining Manager Ongoing

Stage the removal of topsoil from mine development areas (mine, waste rock facility, haul roads) to keep the mine disturbance area to a minimum.

Mining Manager, Production Superintendent

Ongoing



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To the extent possible, plan activities in areas close to the mine boundary at times of year when prevailing wind directions are not directly off site.

Mining Manager Ongoing

Dust suppressants to be used where required for temporary dust control of stockpiles and disturbed areas.


Reshape, topsoil and rehabilitate completed overburden emplacement areas as soon as practicable after the completion of an overburden placement stage.

Mining Manager, Sustainability Manager

Ongoing

Overburden emplacement areas

Use of cover crops, other temporary revegetation measures or other surface coating measures to form temporary seals will be used on overburden emplacement areas that remain unused and exposed, where practicable.


Ongoing

Tailings Surfaces

Saline process water will form a salt crust on dry tailings surfaces that prevents dust generation.

If dry tailings surfaces do create dust in windy conditions, maximise wetted surface to minimise dust generation.

Plant Operations Manager

Ongoing

Weather conditions

Predictive models to forecast dust impacts will be evaluated through an assessment and trial period as a potential planning and management tool.


Three year trial period

Activity-Generated Dust Sources

Haul roads Watering of haul roads as required. Mining Manager Ongoing

Design, construct and maintain haul roads and other heavily trafficked areas to ensure good roadway conditions and minimal build-up of roadway silt loading.


Restrict non-essential vehicle access to unsealed areas.


Apply appropriate variable speed limits depending on unsealed surface area conditions.


All haul roads will have edges clearly defined with marker posts or equivalent to control their locations, especially when crossing large overburden emplacement areas.




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Remove dirt and mud from any equipment before it leaves the site using wheel washes.


Promptly remove material that is spilt or tracked-out onto sealed pavements.


Obsolete haul roads will be ripped and revegetated, as soon as practicable.

Mining Manager As required

Keep an adequate number of water trucks on site to allow dust control as required (three are planned).


Speed limit as appropriate considering vehicle size, road and dust generating conditions.


Minor roads Development of minor roads will be limited where possible and locations clearly defined.


Minor roads used regularly for access will be watered using water carts or sprays to minimise the generation of dust and particulate.


Speed limit as appropriate. Speed limits will be enforced to ensure excessive vehicle speeds do not contribute to unacceptable dust generation.

Mining Manager Monthly

The use of suitable dust suppressant will be explored, where practicable, for minor roads.


Obsolete minor roads will be ripped and revegetated as soon as practicable.


Hard stand areas

Speed limit as appropriate. Speed limits will be enforced to ensure excessive vehicle speeds do not contribute to unacceptable dust generation.


Watering of hard stand areas as required to supress dust.


The use of dust suppressant will be explored, where practicable, for hard stand and industrial areas.


Topsoil stripping

Tracks used by topsoil stripping scrapers during their loading and unloading cycle will be watered.

Mining Manager, Development Superintendent

As required

Stripping will occur preferably in damp conditions if practicable and during favourable wind conditions. Stripping operations will be modified or ceased, if


As required



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required, to prevent the generation of unacceptable dust.

Topsoil stockpiling

Long-term topsoil stockpiles that will be used for progressive rehabilitation will be sown with cover crops as required.


Drilling Air pollution control equipment will be operated and maintained on all drilling rigs to prevent fines generated during drilling being discharged to the atmosphere.

Development Superintendent

Ongoing

Apply water to drill patterns post drilling to minimise dust generation from the fine material collected during drilling.


Blasting Blasting will only occur following an assessment of weather conditions to ensure that wind speed and direction will not result in excess dust and fume emissions from the site.

The key mitigation measures to control blast fumes are:

• minimise the potential for delayed firing of shots which have been loaded into wet holes within the constraints of prevailing weather conditions; and

• conduct a pre-blast environmental assessment considering wind speed, direction and shear and the strength of temperature inversions prior to each blast. Whenever practicable, blasts will be fired in suitable weather conditions that minimise the potential for blast generated dust and/or blast fumes to be blown towards neighbouring residential areas.


Overburden dumping

Assess current dumping strategy and utilise alternate, less exposed dumps when meteorological conditions indicate.


Mine planning dump strategy considers prevailing wind speed and direction.

Mine Planning Superintendent

Ongoing

TSF embankment construction

Water trucks used to suppress dust on haul roads and during placement spreading and compaction of fill on embankment.


During embankment construction operations



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Construction at boundaries to the extent possible at time of year with prevailing wind directions away from receptors.


During embankment construction operations

ROM stockpile area

Use water sprays, windbreak fences and/or water trucks on the ROM stockpile traffic area as required.


ROM bin & crusher

Sprays as appropriate. Plant Operations Manager

During tipping operations

Conveyors Sprays will be fitted at transfer points. Plant Operations Manager

During routine maintenance inspections

Hard stand areas around processing area

Use of street sweeps on sealed hard stand areas, as required.


As required

Unsealed roads used regularly for access will be watered using water carts or sprays to minimise the generation of dust and particulate.


As required

All roads are speed limited. Speed limits will be enforced and reduced further, if required, to ensure vehicle speeds do not contribute to unacceptable dust generation.


As required

Concentrate handling facilities

Maintain entrance and interior of the concentrate storage and truck loading facility to ensure there is no concentrate on the floor and adjoining roads.


As required

Prompt clean-up of any concentrate spillage. Plant Operations Manager

As required

Mitigation Measures in Response to Monitoring Triggered Alert Levels

Mining operations

In response to exceedance of monitoring trigger alert levels, operations should be reviewed to determine appropriate responses. Actions to include additional controls, reduction/relocation of activities and when required, cease mining operations. The extent of the trigger level exceedance will determine the level of response.


Haul roads Strategic deployment of water carts to control haul road dust to focused locations/activities.


Speed limit restrictions as relevant. Mining Manager As required

Reduction of haul truck traffic if required. Mining Manager As required



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Relocation of haul truck routes in response to wind direction and speed.


Overburden emplacement areas

Relocation, modification and/or limitation of exposed operations such as topsoil removal or overburden dumping.


Areas disturbed by mining operations

Where relocation is not possible, temporary halting of activities and resuming when weather conditions have improved will be assessed and implemented where required.


Operational Response Processes

AQMP Operate in accordance with this AQMP and implement procedures contained within this management plan.

All employees Ongoing

Ensure the air quality and meteorological monitoring network is maintained and results are routinely analysed, assessed and reported.

Sustainability Manager In accordance with Section 10

Receiving, reporting and responding to any complaints in relation to air quality through the 24-hour community response line.

Sustainability Manager Ongoing

In the event of exceedance of the highest trigger level, the situation should be reported to the Operations Manager.

Operations Manager Ongoing

Report the results of any air quality monitoring in accordance with the ML conditions.

Sustainability Manager As required

Ensure that all employees and contractors are given adequate training in environmental awareness, legal responsibilities, and air quality control methods.

Sustainability Manager Ongoing

Any corrective action as an operational response will be recorded and reported to the Senior Environment Advisor who is to keep a record of all significant proactive and reactive actions. The Community Relations Advisor must be informed of any complaint and details must be recorded in the complaints register in addition to response and actions taken.

Operations Manager, Sustainability Manager

Ongoing

A review to determine whether there is any relationship between short-term dust episodes, and the frequency of dust related community complaints will be ongoing and summarised annually and reported in the ACR.

Senior Environment Advisor, Sustainability Manager

Annual



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8. CONSULTATION

This Plan is being prepared in consultation with the DSD, the EPA, Yorke Peninsula Council, the HMCV consultation group and directly with local landowners. 9. RESPONSE PROCEDURES

9.1 OPERATIONAL RESPONSE PROCESS

Operational response procedures are detailed Section 7.3.

9.2 EXCEEDANCE PROTOCOL

Where dust and/or particulate concentrations consistently approach or exceed the relevant air quality monitoring measurement criteria, active air quality controls for excessive dust events (refer to Table 5) will be implemented and additional dust and particulate control measures investigated. Mining operations will be modified, or may cease if necessary, until air quality levels return to an acceptable range and/or the source of the exceedances can be determined and managed. Any exceedance of the ML criteria will be notified to the DSD and will require an investigation by Hillside Mine personnel including validation of the monitoring data and evaluation of wind conditions and dust concentrations (considering dust concentrations in wind directions over time) during the period to determine the level of mine contribution. In relation to dust deposition monitoring, compliance with air quality criteria will be demonstrated by investigating the spatial representation of wind and operational activities for the monitoring period. Regional dust events are determined from comparative results of the upwind and downwind monitors. 9.3 COMMUNITY RESPONSE PROCESS

All complaints received regarding operational air quality will be responded to in accordance with the Hillside Mine community complaints process. This process details the Hillside Mine’s obligations in regard to receiving, handling, responding to, and recording details of all community complaints. A register of complaints is to be maintained at site by Rex Minerals. Any complaints made to Rex Minerals will be entered in the register (to be maintained for a period of at least seven years) and will also be utilised as a tool to improve the management of the site and its operations. Upon receipt of an air quality related compliant, such as a dust complaint, the following information shall be recorded:

• The date and time of complaint and who received the complaint.

• The method by which the complaint was made (ie. verbal, telephone, written).

• Any personal details of the complainant which were provided by the complainant, or if no such details were provided, a note to that effect.

• Whether the dust was visible (air borne) or deposited.



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• The location of the nuisance observation.

• Wind speed and direction prior to, and at the time the complaint was received.

• Dust monitoring data concentrations at the time of the complaint and the period leading up to the complaint.

• Mining activities on site at the time of the complaint.

• The action taken by Rex Minerals in relation to the complaint, including any follow up contact or correspondence with the complainant.

• If no action was taken, the reason(s) why no action was taken.

The Sustainability and Mining Managers shall be informed immediately of any complaints made. An example of what will be contained on the complaints registration form is provided in Appendix 4 Air Quality/Dust Complaints Form Details Example. When a complaint is received, the following validation process will occur:

• Review of the mining operations, real-time dust monitoring data and wind directions at the time of the complaint and the period leading up to the complaint to review conditions and context of the complaint.

• The Sustainability Manager or other nominated and appropriately trained person will travel to the boundary of the site closest to the complainant’s location (if known) and identify whether visible dust is leaving the site. If visible dust is leaving the site, measures within this Plan will be implemented to reduce emissions to an acceptable level.

• If dust is not observed leaving the site, the manager will drive around the local area to assess if there is any other possible source of the dust complaint.

• The results of the two exercises detailed above will be recorded in the complaints register.

If complaints are historical (eg. event occurred a week ago), this will be recorded in the complaints register.

9.4 LANDOWNER NOTIFICATION

Condition 43 of the Second Schedule of the ML conditions requires the development of a Communication and Operating Protocol with owners of adjacent land. This protocol will include communications and issues management relating to dust as specified in the Social Management Plan.

10. MONITORING PROGRAM

Data from the monitoring program will be used to determine the impact of the Hillside Mine on the surrounding air environment and community.

Table 6 is a summary of the air quality criteria for the Hillside Mine subject to the ML descriptions and compliance conditions listed in Section 2.



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Table 6: Summary of air quality compliance criteria

Substance Criteria Units Averaging Period Reference

TSP 90 µg/m3 12 months Hillside Mine MLe

Air NEPMb

PM10 50 µg/m3 24 hoursa Hillside Mine MLe

Air NEPMb

PM2.5 25 µg/m3 24 hours Hillside Mine MLe

NEPM advisory reporting standardf

PM2.5 8c µg/m3 24 hours NEPM advisory reporting standardf

TSP 120 µg/m3 24 hours Hillside Mine MLe

TSP 90 µg/m3 12 months Hillside Mine MLe

TDDd 2 g/(m2 month) 30 days (for annual average)

Hillside Mine MLe

TDD 4 g/(m2 month) 12 months Hillside Mine MLe

a. 24 hour period is defined as a calendar day (midnight to midnight). b. Air NEPM (Attorney-General’s Department, 2003). c. Compliance with annual average not specifically listed in Hillside Mine ML. d. Compliance requirement that total dust deposition is below 4 g/(m2 month). e. Hillside Mine ML 6438. f. NEPC. (2003). Variation top the National Environment Protection (Ambient Air Quality) Measure for Particles as PM2.5, May 2003. -

It is relevant to note that the Ambient Air Quality NEPM PM2.5 advisory reporting standards were not originally intended as air quality impact assessment criteria. The aim of the reporting standards was to gather sufficient data nationally to facilitate the review of the Air Quality NEPM which is currently underway. However, in the absence of any other relevant assessment criteria for PM2.5 the reporting standards are applied as assessment criteria.

Management of short-term dust episodes will primarily be undertaken using the real-time monitoring system described in the AQMP, supported by a range of controls described in Table 5. An investigation to determine whether there is any relationship between short-term dust episodes and the frequency of dust related community complaints will be ongoing and summarised annually and reported in the ACR. To assist in reviewing cumulative dust impacts around the Hillside Mine, consultation and data sharing arrangements will be explored with neighbouring sources. 10.1 MONITORING METHODOLOGY

The Air Quality Monitoring Program will monitor TSP, PM10, PM2.5, dust deposition, and meteorological conditions. After a period of monitoring, TSP limits may be modified if it can be shown that higher limits do not result in an increase in public nuisance. Such a change will require written approval from the Director of Mines to conduct mining operations subject to an alternative TSP limit or limits.



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PM2.5 measurements are required unless and until the Director of Mines has notified the Tenement Holder in writing that he is satisfied that the Tenement Holder has demonstrated compliance with Condition 2 (ML conditions Second Schedule) for a period of no less than one consecutive year after the commencement of mineral processing; and established that PM10 measurements can be used as a proxy for PM2.5 measurements. All monitoring will be conducted in accordance with the Australian Standards. There will be two categories of real-time monitoring in place:

• Compliance monitoring - for evaluation and assessment against the air quality compliance criteria.

• Boundary monitoring - for dust management purposes. This monitoring is intended to take place within the mine boundary to collect dust data and provide alerts on rising dust trends to avoid air quality exceedances at the nearest receptors.

10.2 PM2.5, PM10 AND TSP REAL-TIME MONITORING

Monitoring of PM10 for compliance purposes is conducted using real-time, continuous air quality monitors, to facilitate good data capture and early identification of increased dust levels at the monitoring site, to allow for reactive air quality management.

Five BAM (US-EPA Federal Equivalent Method approved monitors) are installed to measure PM2.5, PM10 and TSP concentrations to the north, south and west of the mine site (refer to Table 8 and Figure 2 in Appendix 1 Location Maps for monitoring locations). Monitoring locations generally represent the closest privately owned residential areas to the site and aim to provide upwind (including background) and downwind exposure from the mine in prevailing wind directions (especially during the summer months).

Real-time readings will be used for monitoring of current dust conditions and hourly readings will be used for the performance evaluation and compliance reporting.

Monitoring for particulate matter using a BAM must comply with:

AS/NZS 3580.9.11:2016 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - PM10 beta attenuation

AS/NZS 3580.9.12:2013 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - PM2.5 beta attenuation monitors The calculation methodology for dust concentration contribution from the Hillside Mine at a downwind monitoring location is described in Appendix 5 Hillside Mine Contribution Dust Concentration Calculation. 10.3 REAL-TIME MONITORING – EARLY WARNING

In addition to the compliance monitoring at locations targeting the nearest residential receptors, early warning monitoring will use mobile stations which can be moved to consider prevailing wind direction for the time of year and target areas of the mine where operations currently occur. The purpose of the early warning monitoring is to collect data at sufficient resolution for dust that may leave site.

The early warning monitoring does not require a high level of accuracy since the monitoring is aimed at detecting rising dust trends or detection of sustained periods of higher dust concentrations. The



23

monitoring can be done with nephelometer instrumentation with wind sensors, but there is also sensor technology that is under development which may provide a reasonable solution at lower cost.

A total of six mobile stations for early warning monitoring is recommended to cover any daily wind direction changes. 10.4 REAL-TIME DUST CONCENTRATION ALERT FUNCTIONS FOR OPERATIONAL

CONTROL

The real-time air quality monitors (both the compliance and early warning monitoring stations) are to provide data in real-time with alert functions to draw attention to rising dust trends. The primary recipient of alerts is the Mining Manager and it is designed to provide an alert to the rising dust trends and dust episodes that may suddenly pick up with a change in conditions. The alert will be based on a tier system with level 1, 2 and 3 alerts depending on the concentration of dust at the early warning or at the compliance monitoring stations.

Early warning alert concentrations and the averaging period on which they are based need to be calibrated to suit the mine conditions in relation to the compliance criteria and the alerts sensitivity. Proposed initial trigger levels are proposed in Table 7. These should be evaluated and revised throughout mining operations to ensure optimal performance and avoidance of exceedances.

Table 7: Trigger levels and description of responses (suggested for commencement of operations)

Trigger Level Concentration Description response triggered

ATL 1 30 µg/m3

Hourly average

Review current and planned operations considering:

• dust generating sources;

• the current level of dust controls being applied;

• the rolling 24 hourly trend;

• current and forecasted weather conditions.

Revised activities and additional dust controls may be applied or planned as required.

ATL 2 40 µg/m3

Hourly average

The dust trend is either rising and a response to ATL 1 may not be sufficient, or there has been a step in impacts from below ATL 1 to ATL 2. This could be due to an increase in site activity, rising ambient PM10 concentrations or a change in wind direction.

If the ATL 2 level is triggered without previously triggering ATL 1, complete the ATL 1 review bearing in mind that ATL 2 is now also triggered.

If applied dust control measures are not sufficient and additional measures are not available, consider restricting operations. Considering the 24 hourly trend will inform operations if the trend is only just beginning to rise, or whether the trend is at a sustained higher level. This informs the timing of the actions required.

ATL 3 50 µg/m3

Hourly average

This is a prompt that 50 µg/m3 (the daily average compliance limit) is exceeded for an hourly average and that if this is sustained for a 24 hour period, compliance will not be met.

In addition to considering further restrictions to activities as for ATL 2, ceasing work should be considered if conditions and the 24 hourly trend suggest that



24

compliance may not be met. The margin for this decision will need to be evaluated on a case by case basis since the reliability of forecast conditions can vary.

For the compliance monitors, it is proposed that alerts for three concentration levels at 30 µg/m3, 40 µg/m3

and 50 µg/m3 could be set based on one hour and 24 hour rolling averages. A rolling average alert evaluates and monitors performance over time and gives information on when impacts from the operations are approaching or exceeding the compliance criteria. 1 If several alert levels are applied, the required responses need to be defined to enable the Mining Manager to respond appropriately. A decision to cease mining operations, based on the air quality performance conditions, is made by the Operations Manager. The early warning monitoring alert can be set at different levels and should be calibrated against concentrations of concern at nearby downwind compliance monitors. Alerts can also be set to apply to weather conditions that are known to have adverse impacts on the mine dust emissions.

10.5 HIGH VOLUME AIR SAMPLER MONITORING (PM10)

HVAS monitoring is conducted over a 24-hour period every six days. One HVAS is installed to measure TSP concentrations at the northern end of the mine site downwind in the prevailing wind direction from waste rock dumps, the pit, the ROM pad, crushing activities and the processing plant (refer to Table 8 and Figure 2 Appendix 1 Location Maps for monitoring locations). The results from the TSP HVAS sampling will be submitted for metals analysis as a basis for the chemical and toxicological composition of dust monitoring requirement.

Monitoring for particulate matter using a HVAS must comply with AS/NZS 3580.9.3:2015 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - Total suspended particulate matter (TSP) - High volume sampler gravimetric method.

10.6 DUST DEPOSITION MONITORING

Dust deposition gauges capture dust fallout which can be a good indicator of general dust levels in an area. Due to the sampling period over 30 days, the origin of dust deposited in the gauge can often be difficult to determine apart from wind direction frequencies over the monitoring period.

A total network of 10 dust deposition gauges are installed around the mine site and at residential locations (refer to Table 8 and Figure 2 in Appendix 1 Location Maps for monitoring locations). The compliance monitoring locations are representative of privately owned property in the vicinity of the site and have been determined in consultation with DSD and EPA. Data from these gauges enable determination of the compliance status of the mining operations at private properties in the vicinity of the mine site.

1 Single hour of sub-hourly alerts based concentrations can also be applied for instance to give notice that 50 µg/m3 was exceeded on an hourly basis.



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Dust deposition gauges are exposed for 30 days (+/- 2 days) and analysed for insoluble solids and ash residue. Monitoring for depositional dust must comply with AS/NZS 3580.10.1:2016 Methods for sampling and analysis of ambient air - Determination of particulate matter - Deposited matter - Gravimetric method.

10.7 METEOROLOGICAL MONITORING

One on-site AWS is located within the Hillside Mine ML and complies with AS/NZS 3580.14:2014 Methods for sampling and analysis of ambient air - Meteorological monitoring for ambient air quality monitoring. This AWS provides representative weather data for the mine site including wind speed and direction, solar radiation, humidity, rainfall and temperature. The on-site AWS location was cited by an accredited and independent consultant. Real-time data from the on-site station is made available to the Senior Environment Coordinator and Mining Manager to assist in operational monitoring and real-time response.

Four additional weather stations are situated around the mining operations area co-located with the compliance monitoring stations. The purpose of these weather stations is to provide representative wind data for the monitoring locations. Logging of wind data will be for the same time step as set for the real-time data for the compliance stations.

10.8 CHEMICAL AND TOXICOLOGICAL COMPOSITION OF DUST EMISSIONS

The Hillside Mine operation is required to measure chemical and toxicological composition of dust emissions generated by mining operations as per Condition 7 of Second Schedule Hillside Mine ML conditions. Metals analysis of HVAS TSP samples from one in six days monitoring will be applied for this monitoring requirement.

The results will be communicated via the ACR, they will be provided to the HMCV consultation group and also made available for public information on the Rex Minerals website.

10.9 WATER QUALITY TESTING OF RAINWATER TANKS

The Hillside Mine operation will offer to undertake (at least annually) water quality testing of all rainwater tanks owned (or used) by third parties who have an interest in land within the Hillside Mine ML or on land within four kilometres of the boundary of the Hillside Mine ML (as per Condition 8 of Second Schedule of the Hillside Mine ML).

Within six months of the grant of this Lease, written contact was made to all third parties who have an interest within the land, or in land within four kilometres of the boundary of the land, and an offer was made to undertake (at least annually) water quality testing of all rainwater tanks owned (or used) by those third parties.

Results of the testing will be provided to the third party (reported against the most recent Australian Drinking Water Guidelines (Australian Government)) within one month of the sampling.

This monitoring program should commence prior to mining operations to establish a baseline.

10.10 MONITORING LOCATIONS

The AQMP consists of the following:

• five BAMs;

• one HVAS;



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• ten dust deposition gauges;

• one AS3580.14 compliant AWS located at site co-located with HVAS (wind direction and wind speed to also be recorded at each of the four compliance monitoring locations);

• six mobile early warning monitoring stations (with wind sensors).

All statutory/compliance monitoring locations must conform to the requirements of AS/NZS 3580.1.1:2016 Methods for sampling and analysis of ambient air - Guide to siting air monitoring equipment, subject to local site constraints. Monitoring will be conducted in accordance with Australian Standards.

Appendix 1 Location Maps shows the Hillside Mine site with surrounding receptors and established monitoring locations (refer to Table 8 for approximate geographic coordinates for each monitoring location).

Table 8: Hillside Mine air quality proposed monitoring locations Site no.

Location Instrument Frequency Approximate coordinates (MGA)

Reason for location Purpose

M2 Northwest of site

BAM: TSP PM10 PM2.5 (first year)

Continuous 760230E 6178975N

Monitoring of TSP, PM10 and PM2.5 (first year) at nearest receptor in the prevailing downwind direction (especially in summer) location of site. Also covering as an upwind station in reversed conditions.

Compliance

Dust deposition gauge

30 days continuous

Co-located for additional dust levels and type information.

Additional data

M3 Northeast of site after first year

BAM: PM10


Monitoring to expand to this site when monitor from use of PM2.5 becomes available to also cover monitoring in this direction.

Compliance


30 days continuous


Additional data

M5 West of site

BAM: PM10


Targeting of nearest sensitive receptor.

Compliance


30 days continuous


Additional data

M11 South of site

BAM: PM10


Targeting of nearest sensitive receptor.

Compliance


30 days continuous


Additional data

M13 Southeast of site

BAM: PM10 TSP


Monitoring of TSP, PM10 at nearest receptor in the prevailing upwind direction (especially in summer) location of site. Also covering in downwind conditions.

Compliance

M1 North-west of

HVAS: TSP and

1 day in 6 762006E Co-located for boundary conditions and metals analysis

Compliance



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processing plant

weather station

6177264N at exposure location near plant.

M19 North of site


30 days continuous

763956E 6179187N

Target receptor. Additional dust data.

M4 North-eastern corner of site


30 days continuous

764810E 6177388N

Boundary conditions. Compliance

M18 North-west of site


30 days continuous

758678E 6177146N


M12 South-eastern corner of site


30 days continuous

764259E 6171774N


M14 Southeast of site south of pine point


30 days continuous

763830E 6170317N

Target receptor. Additional dust data.

M8 Southwest of site


30 days continuous

759993E 6173413N

Target receptor. Compliance

10.11 DATA ANALYSIS

10.11.1 Data Validation Procedure

Real-time compliance monitoring data to be validated on a monthly basis.

10.11.2 Real-Time Particulate Monitoring (PM10)

• Visual analysis of the raw data is undertaken to reveal any anomalous readings.

• Negative values recorded are not removed unless the data is considered anomalous or below 5 μg/m3. As hourly values are averaged over 24-hours, negative values (due to moisture) will compensate for the over read in the preceding values and should therefore be left in to avoid positive bias in the measurements.

• Zero readings occur when there is a power failure and when a filter is changed and the data recording is stopped for calibration. These readings are removed from the analysis along with the additional following time period as per instrument specification to allow for stabilisation in measurement.

• Extremely high values and other suspect values (for example repetitive readings) should be reviewed on a case by case basis to determine whether the data should be included or excluded.

• Daily averages are calculated from the hourly readings.

• For a valid daily average, at least 75% of hourly data (at least 18 hours) are required.

10.11.3 Dust Deposition Monitoring

• Depositional dust samples are analysed by a National Association of Testing Authorities accredited laboratory and an independent consultant to determine contamination. Typically, contamination may be caused by the presence of bird droppings, vegetation or insects. These samples are excluded from results.



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10.11.4 Calibration of Equipment

• Monitoring equipment is maintained and calibrated in accordance with the manufacturer’s specifications and relevant standards.

• A calibration register and records are to be maintained to ensure the calibration of all equipment is undertaken as per the manufacturer’s schedule.

11. REPORTING

Air quality management reporting is designed to evaluate compliance with the Hillside Mine ML conditions, and to provide stakeholder access to relevant air quality management information and data. Key stakeholders requiring access to this information include Rex Minerals, state and local government agencies, and the local community. Reporting will be undertaken in accordance with the requirements of Condition 9, Second Schedule of the Hillside Mine ML conditions, requiring Rex Minerals to report PM10 and PM2.5 dust concentration data and meteorological monitoring data in real time to the public on an unrestricted internet site. The Hillside Mine will report on the performance of the AQMP in the ACR and provide regular updates to members of the HMCV consultation group. The ACR will be provided to the HMCV and made available for public information on the Rex Minerals website. Hillside Mine will identify and assess opportunities to reduce GHG emissions resulting from mine operations. In accordance with the National Greenhouse and Energy Reporting Act 2007 (NGER Act), the Hillside Mine will regularly quantify GHG emissions attributable to its operations, including emissions from fuel and electricity consumption. 12. PERFORMANCE INDICATORS

The following performance indicators will be measured against the ML conditions:

• Compliance with relevant air quality standards at all compliance monitoring locations.

• Minimisation of air quality complaints as evidenced by trends in the frequency and extent of complaints.

• Compliance with this Plan, as indicated by internal and statutory reporting. 13. CONTINUAL IMPROVEMENT

The Hillside Mine will strive to continually improve on the mine’s environmental performance by applying the principles of best practice to mining operations, including where cost-effective and practicable, the adoption of new best practice technologies and improved air quality control measures. Progress will be monitored using the above noted performance indicators. The Hillside Mine will also review air quality performance in relation to operations and weather conditions to identify improvements in operation practices to achieve improvement in air quality outcomes. In particular, the application of predictive models to forecast dust impacts will be evaluated through an assessment and trial over a three year period as a potential planning and management tool.



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14. REVIEW

This Plan will be reviewed, and if necessary revised, to the satisfaction of the DSD and in consultation with relevant government agencies, in accordance with the requirements relating to PEPR review, update and approval:

• following changes to project approval or licence conditions relating to air quality management or monitoring;

• following any significant air quality related incident;

• when a relevant/significant improvement has been identified;

• for necessary or any unforeseen changes to air quality monitoring locations;

• where a risk assessment identifies the requirement to alter the Plan;

• annually.

15. REFERENCES

Pacific Environment, Rex Minerals Hillside Project: Extended Feasibility Study Dust Impact Assessment, 3 September 2015

Pacific Environment, Update of Rex Minerals Hillside Project Odour Impact Assessment, 26 February 2016

Pacific Environment, Rex Hillside Project: Extended Feasibility Study Dust Impact Assessment, 3 September 2015

EPA - Environmental Protection Licence (application to be submitted for approval prior to project commencement)

Environment Protection (Air Quality) Policy 2016, South Australia

Rex Minerals Ltd, Hillside Mine Mineral Lease Application

Government of South Australia, Mineral Lease 6438, 16 September 2014

Standards Australia (2008), AS 3580.9.8-2008 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - PM10 continuous direct mass method using a tapered element oscillating microbalance analyser

Standards Australia (2007), AS 3580.1.1:2007 Methods for sampling and analysis of ambient air - Guide to siting air monitoring equipment

Standards Australia (1987), AS 2923-1987 Ambient air - Guide for measurement of horizontal wind for air quality applications

Katestone Environmental Pty Ltd (2010), NSW Coal Mining Benchmarking Study: International Best Practice Measures to Prevent and/or Minimise Emissions or Particulate Matter from Coal Mining

Commonwealth of Australia (2001), National Pollutant Inventory Emission Estimation Techniques Manual for Mining, Version 2.3

National Greenhouse and Energy Reporting Act 2007 (NGER Act)

AS/NZS 3580.1.1:2016 Methods for sampling and analysis of ambient air - Guide to siting air monitoring equipment



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National Greenhouse and Energy Reporting Act 2007 (NGER Act)

AS/NZS 3580.9.11:2016 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - PM10 beta attenuation

AS/NZS 3580.9.12:2013 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - PM2.5 beta attenuation monitors

AS/NZS 3580.9.3:2015 Methods for sampling and analysis of ambient air - Determination of suspended particulate matter - Total suspended particulate matter (TSP) - High volume sampler gravimetric method

AS/NZS 3580.10.1:2016 Methods for sampling and analysis of ambient air - Determination of particulate matter - Deposited matter - Gravimetric method

AS/NZS 3580.14:2014 Methods for sampling and analysis of ambient air - Meteorological monitoring for ambient air quality monitoring



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16. APPENDICES

Appendix 1: Location Maps

Figure 1: Sensitive Receptor Locations



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Monitoring locations – preliminary sites have been chosen and will be reviewed following consultation with air quality experts and landowners.

Figure 2: Monitoring Locations



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Figure 3: Location Map of year five operations – Predicted Annual Average PM2.5 Concentrations



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Figure 4: Location Map of year five operations – Predicted Maximum 24hr PM10 Concentrations



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Figure 5: Location Map of year five operations - Predicted Annual Average TSP Concentrations



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Figure 6: Location Map of year five operations – Predicted Annual Average Dust Deposition



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Figure 7: Location Map of year nine operations - Predicted Annual Average PM 2.5 Concentrations



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Figure 8: Location Map of year nine operations – Predicted Maximum 24hr PM10 Concentrations



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Figure 9: Location Map of year nine operations – Predicted Annual Average TSP Concentrations



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Figure 10: Location Map of year nine operations – Predicted Annual Average Dust Deposition



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Appendix 2: Correspondence Records Key relevant communications with DSD, EPA and the community relating to this management plan are detailed below.

Date Communication with Action or Outcomes

3 March 2017 DSD Meeting to update on PEPR progress and initial discussion on Air Quality plan proposed structure.

6 March 2017 HMCV Presentation and outline of initial draft of Air Quality Management and Monitoring Plan covering including objectives, control measures, pictures of examples of monitoring equipment, summary of monitoring options – draft copies of Plan provided.

14 March 2017 HMCV Circulation of PDF draft Air Quality Management Plan and monitoring Plan to HMCV members.

23 March 2017 DSD Update on status of Air Quality plan and consultation with HMCV and landowners.

3 April 2017 HMCV Presentation to HMCV by Johan Meline, Pacific Environment Ltd (Rex Minerals air quality consultant) including sources of dust, controls and management, monitoring and compliance.

13 April 2017 DSD Review of structure of Air Quality Management plan.

1 May 2017 HMCV Updated draft of Air Quality management plan tabled – e-version to be sent with some minor edits.



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Appendix 3: Air Quality/Dust Complaints Form Details - Example

Complaint received by.

Date and time of complaint.

The method by which the complaint was made (ie. verbal, telephone, written).

Any personal details of the complainant which were provided by the complainant, or if no such details were provided, a note to that effect.

Whether the dust was visible (airborne) or deposited.

The location of the nuisance observation.

Wind speed and direction prior to, and at the time the complaint was received.

Dust monitoring data concentrations at the time of the complaint and the period leading up to the complaint.

The action taken by Rex Minerals in relation to the complaint, including any follow up contact with the complainant.

Or

If no action was taken, the reason(s) why no action was taken.

Complaint and follow up correspondence reported as relevant.



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Appendix 4: Hillside Mine Contribution Dust Concentration Calculation Contribution to air borne dust levels at a downwind monitoring location will be calculated by subtracting the dust concentration upwind from the Hillside Mine from the dust concentrations downwind of the Hillside Mine. TSP will be monitored at two locations. PM10 will be monitored at 4 to 5 locations. Mine Contribution Dust Concentration (TSP or PM10) equals Mine Downwind Dust Concentration (TSP or PM10) minus Mine Upwind Dust Concentration (TSP or PM10) (CDC = DDC - UDC) Wind sectors for upwind & downwind monitoring locations (primarily PM10)

Wind direction (blowing from) Upwind monitoring location Downwind monitoring location

SE M13 M2

NW M2 M13

SW M2, M5, M11, M13 M3

NE M3 M5, M11

E M3, M13 M5

N M2, M3 M11, M13

S M11, M13 M2, M3



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Appendix 5: Air Quality Management Plan Requirements Checklist

Condition Requirement Section

Rex Minerals Hillside Mine Mineral Lease Conditions (ML 6438) Second Schedule

Air Quality

1 The Tenement Holder must ensure that:

1.1 The total PM10 dust concentration (including both ambient and mine related dust) leaving the site is less than 50µg/m3 as a 24 hour (midnight to midnight) average of measurements taken at intervals of not more than 10 minutes; or

2 10.2 10.11

1.2 where the total PM10 dust concentration entering the site exceeds 50µg/m3 as a 24 hour (midnight to midnight) average of measurements taken at intervals of not more than 10 minutes, the total PM10 dust leaving the site does not exceed the measured level entering the site during that period.

2 9 10

2 Subject to Condition 3 the Tenement Holder must comply with the Ambient Air Quality National Environmental Protection Measure (NEPM) dust concentration standard for PM2.5 leaving the site, measured on average over a 24 hour period (midnight to midnight) with measurements taken at intervals of not more than 10 minutes.

2 10

3 Condition 2 is applicable unless and until the Director of Mines has notified the Tenement Holder in writing that he is satisfied that the Tenement Holder has:

3.1. Demonstrated compliance with Condition 2 for a period of no less than one consecutive year after the commencement of mineral processing; and

2 10.1 10.2

3.2. established that PM10 measurements can be used as a proxy for PM2.5 measurements.

2 10.11

4. The Tenement Holder must ensure that;

(i) the TDD leaving the site does not exceed 4g/m2/month averaged over all 12 month periods; and

(ii) the mine contribution to TDD leaving the site does not exceed 2g/m2/month for all months.

2 10.6

5. The Tenement Holder must ensure that TSP leaving the site does not exceed an average of 120 µg/m3 for all 24 hour periods (midnight to midnight) and an average of 90 µg/m3 for any 12 month period, unless the tenement holder:

2 10.1 10.2 10.3 10.4 10.10

5.1. Provides information (from dust dispersion modelling, operational monitoring or otherwise) that satisfies the Director of Mines that, if the tenement holder exceeds the limits outlined above, there will be no increase in public nuisance from:

5.1.1. air emissions; and/or

2 9



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5.1.2. dust generated by mining operations; and

5.2. obtains written approval from the Director of Mines to conduct mining operations subject to an alternative TSP limit or limits (on such conditions as the Director of Mines thinks fit and specifies in writing, if any); and

2

5.3. complies with any alternative TSP limits approved in accordance with Condition 5.2, and any associated conditions.

2

6. In the event that monitoring shows that Conditions 1, 2, 4 or 5 have been breached, the Tenement Holder must immediately cease the activity which resulted in the breach.

7.3 9 10.4

7. The Tenement Holder must measure chemical and toxicological composition of dust emissions generated by mining operations through an ongoing air monitoring program.

10.8 10.5

8. The Tenement Holder must:

8.1. Within 6 months of the grant of this Lease write to all third parties who have an interest within the Land, or in land within 4 kilometres of the boundary of the Land, and offer to undertake (at least annual) water quality testing of all rainwater tanks owned (or used) by those third parties; and

10.9

8.2. where a third party who has an interest within the Land, or in land within 4 kilometres of the boundary of the Land, indicates to the Tenement Holder that they wish to have rainwater tanks that they own or use tested, undertake testing of the relevant tank(s); and

10.9

8.3. if testing of a tank is undertaken, provide the third party with those test results (reported against the most recent Australian Drinking Water Guidelines (Australian Government)) within one month of the sampling.

10.9

9. The Tenement Holder must ensure that PM 2.5 and PM10 dust concentration data and meteorological monitoring data acquired by the Tenement Holder is reported in real time to the public on an unrestricted internet site. The monitoring data must be retained and remain accessible on the unrestricted internet site for the life of the mine.

10.2 11 10.7

Meteorological Monitoring

14. The Tenement Holder must undertake meteorological monitoring in accordance with relevant Australian standards to measure and record meteorological data including (but not limited to) wind speed and direction, temperature, humidity, atmospheric pressure, solar radiation, rainfall and evaporation.

10.7

Rex Minerals Hillside Mine Mineral Lease Conditions (ML 6438) Sixth Schedule

Air Quality Outcomes

1. The Tenement Holder must ensure that there are no public health and/or public nuisance impacts from air emissions and/or dust generated by mining operations.

3 9



46

2. The Tenement Holder must, in construction, operation and post mine completion, ensure no loss of abundance or diversity of native vegetation on or off the Land through:

2.1. Clearance,

2.2. dust/contaminant deposition,

2.3. fire,

2.4. reduction in water supply, or

2.5. other damage,

unless prior approval under the relevant legislation is obtained.

3 7.3

3. The Tenement Holder must, in construction, operation and post mine completion, ensure no impacts to agricultural productivity for third party land users on or off the Land as a result of mining operations, including: 3

7.3 10.6 10.8

3.1 Reduction in crop yield;



Air Quality Strategies

4. The Tenement Holder is required to address the following matters for the purposes of Regulation 65(2)(c) of the Regulations in relation to the outcome in Sixth Schedule Clause 1;

4.1 undertake continuous dust and meteorological monitoring to inform decisions for operational response and contingency measures to be implemented to prevent exceedence of compliance criteria.

3 10.1 10.2 10.3 10.4 10.7

4.2 Progressive rehabilitation and stabilisation of disturbed areas undertaken throughout the life of mine to control dust emissions generated by wind erosion.

3 5 7.3

Air Quality Criteria

5. The Tenement Holder is required to address the following matters for the purposes of Regulation 65(2)(d) of the Regulations in relation to the outcome in Sixth Schedule Clause 1;

5.1. measure PM 10 dust concentration using monitoring methodology, equipment and instruments that are recognised by a relevant International or Australian Standard.

2 3 10.1 10.2 10.5

5.2. Measure TDD using monitoring methodology, equipment and instruments that are recognised by a relevant International or Australian Standard.

2 3 10.1 10.6



47

5.3. Measure TSP using monitoring equipment and instruments that are recognised by a relevant International or Australian Standard.

2 3 10.1 10.2 10.5

5.4. DDD is to be measured using monitoring equipment and instruments that are recognised by a relevant International or Australian Standard.

It is proposed that directional dust deposition monitoring will not be included. Real-time TSP data in combination with wind direction data provides alternative and better data. 2 3 10.1 10.2 10.5

5.5. Measure PM 2.5 dust concentration including both ambient and mine related dust using monitoring methodology, equipment and instruments that are recognised by a relevant International or Australian Standard.

2 3 10.1 10.2

Adjacent Land use and Third Party Property Outcomes

42. The Tenement Holder must during construction, operation and post mine completion, ensure that there are no adverse impacts to third party land use on property adjacent to and on the Land as a result of mining operations, other than those agreed between the Tenement Holder and the affected user.

3 7 9

43. The Tenement Holder must, in construction, operation and post mine completion, ensure no impacts to agricultural productivity for third party land users on or off the Land as a result of mining operations, including; 3

7 9 10.6

43.1 reduction in crop yield;



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