Item
Description
Information Requested
Response
Corresponding Sections
Off lease dist.
Provide advice on this off-lease discrepancy identified and detail how this will be rectified via this amendment.
The application, including figures and associated spatial files, has been updated to ensure that the Red Ox and Q Dump areas/polygons are contained within ML boundaries. This change to disturbance areas has resulted in a reduction of the approved areas for mining in the revised Table A1. Additionally, the portion of the haul road that exists off tenure has been removed from this application.
Section 2.3.2
The proposed revision of figure 1 (Mine Area Location) of environmental authority (EA) EPML00433013 is depicted in figure 9 of the application material (Wulguru, 2025)[1]. It appears disturbance footprints extend outside of tenure boundaries. Specifically, the Red Oxide Tails, Q Dump and a section of haul road northeast of the mining/contractor yard. Mining related disturbance subject of the EA is not authorised outside of tenure boundaries.
1
Regional interest development approval
Clarify if there is an intention to include a mine equipment park up and workshop area to the EA. If so, provide all necessary information for its inclusion. For example, description of the infrastructure, location, footprint size, identification of environmental values and the associated risks, impacts and management measures, and rehabilitation information for this feature.
The equipment park up and workshop from the approved RIDA is no longer going ahead as would impact on the amenity of the lookout. A new laydown area inclusive of the heavy vehicle maintenance area has been identified and included in the application, as stated in response to Item #3. An application to amend the current RIDA will be conducted following EA amendment approval but before proposed EA activities are undertaken
Not applicable (NA)
It is identified that regional interest development approval RPI17/001 is approved for the project. Upon review of the documents publicly available related to RPI17/001, it is acknowledged that a ‘mine equipment park up and workshop’ is proposed downstream of the proposed Upper Mundic Gully Tailings Storage Facility (UGM TSF), however, this is not reflected in this application.
2
Ancillary infrastructure
Provide revised application material which describes all ancillary infrastructure required for the construction and operation of the UGM TSF. If ancillary infrastructure is proposed provide: a) A description of each feature proposed including an assessment against the environmental values, impacts and risks to environmental values and the management and monitoring measures, and rehabilitation information. b) A description of the location, including maps, GPS co-ordinates and total disturbance area in hectares (ha) for each feature. Information should be provided in the same format as Schedule A1 (Authorised mining activities and locations) of the EA.
a) The Application has been updated to describe each new proposed feature, assessment of EVs, impacts and the rehabilitation strategy for the following new features: - New topsoil stockpile - New pipe corridor from process plant to UMG - New nursery - Haul road extension into UMG TSF footprint - New laydown area inclusive of heavy vehicle maintenance b) The description of location, maps, coordinates, total disturbance area for each feature identified above has been included in the proposed replacement Table A1 of the revised application a) The design basis for the UMG TSF embankment is intended to match that of Sandstone Gully TSF whereby the use of selected rock fill, borrowed from the western dump, will be used as zone 3A material used in embankment construction. This design basis is pending further detailed design works and RPEQ confirmation. Placing selected rock from western dump into the UMG is a similar concept to placing PAF material within NAF material to reduce potential for contaminant migration. The use of selected rock from Western Dump within the embankment, where it will be enclosed by verified clean material, is a better environmental outcome than the status quo whereby uncontrolled discharge of ARD into surface water features is occurring as evidenced by the surface water results described in Section Error! Reference source not found. . The application has been updated to include management measures to be implemented to prevent ARD mobilisation from the TSF to any receiving environment during operation and construction b) The Western Dump, which is not a feature authorised for disturbance in the EA, is seeping contaminants into the adjacent ephemeral dam as demonstrated through surface water quality sampling results. The reshaping of the western dump and selective placement of some material into the UMG TSF embankment is expected to improve the environmental outcome of the site by containing some of the acid generating material. The operation of the UMG TSF is not expected to exacerbate ongoing ARD leaching from the Western Dump. The UMG TSF embankment will reduce ARD generation and some waste rock material will be encapsulated in the development of the embankment. The UMG TSF design basis includes the installation of a liner on the upstream batter of the embankment to mitigate potential seepage through the embankment. As described in section 5.15.1 of the supporting information report, the tailings to be discharged into UMG TSF will not be acidic. The pH of the tailings material is moderately alkaline, whilst the
a) Section 5.2 describes the ancillary infrastructure features and environmental values, whilst the rehabilitation strategy is provided in Section 7.5.3 b) Section 2.3.2
Limited information is presented regarding if ancillary infrastructure is required to support the construction and operation of the UGM TSF. For example, this may include laydown areas potentially for pump systems, haul roads, access tracks, tailings pipeline and topsoil stockpiles. Further, as indicated in information request item 2, this may also involve a mine equipment park up and workshop area.
3
Western dump
Provide revised application material which:
a) Embankment design basis and management measures to avoid environmental harm are described in Section 5.9. b) Section 5.15.1. Water quality of the ephemeral dam is provided in Section 4.3. Seepage management plan is provided in Appendix H c) Proposed conditioning related to conducting geotechnical investigations is provided in Section 2.3. A forward works plan is provided in Section 9.
The UGM TSF is proposed to be built over a portion of the existing western dump. It is acknowledged in the application that the western dump is likely contributing to acid rock drainage (ARD), however, this has not been confirmed via submission of site data or investigations. It is stated the exposed face of the western dump will be sealed, further reducing potential ARD seepage. However, no information is presented regarding the material or methods to be utilised to support the assertion this will reduce potential ARD. there is no understanding regarding the extent of the proposed reshaping or its implications for areas of the dump that fall outside of the proposed UGM TSF. No information is presented confirming the suitability of constructing the foundation and embankment over the existing dump and the potential risks of exacerbation of the suggested ARD. The application material suggests construction of the UGM TSF will involve reshaping of the western dump, however,
a) Details the proposed reshaping requirements necessary for the western dump, the potential implications for the entire western dump and the proposed management measures to avoid environmental harm caused by this action, where necessary. b) Details the risks and management measures required to ensure ARD isn’t exacerbated via the construction of the UGM TSF embankment over the existing western dump. Detail how it will be demonstrated that ARD isn’t exacerbated and how it will be determined and demonstrated potential impacts from the UGM TSF will be differentiated from the western dump. c) Confirms the suitability of the building the foundation and embankment of the UGM TSF over the existing western dump. This should involve a discussion of the findings of the relevant geotechnical investigations as recommended in the UGM TSF Design Report (WSP, 2025)[2].
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ISO 9001 • ISO 14001 • ISO 45001
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