1. Air Quality Management Plan V5.0 Final - yorke.sa.gov.au

Hillside Copper Mine Air Quality Management Plan Program for Environment Protection and Rehabilitation (PEPR)

ML 6438 | EML 6439 | MPL 146

PEPR Submission Date: 02/02/2018

AIR QUALITY MANAGEMENT PLAN


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Table of Contents

1. INTRODUCTION .............................................................................................. 1

1.1 ENVIRONMENTAL MANAGEMENT SYSTEM ........................................................................ 1

1.2 OBJECTIVES ............................................................................................................................ 1

2. AIR QUALITY CONDITIONS ............................................................................ 1

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

4. BASELINE MEASUREMENTS AND MODELLING ............................................. 5

5. UNCERTAINTY ASSESSMENT ........................................................................ 6

6. KEY RISKS ...................................................................................................... 7

6.1 DUST......................................................................................................................................... 7

6.2 ODOUR ..................................................................................................................................... 8

7. AIR QUALITY CONTROL MEASURES ............................................................. 8

7.1 PROACTIVE AIR QUALITY CONTROL MEASURES .............................................................. 8

7.2 RESPONSE AIR QUALITY CONTROL MEASURES ............................................................... 8

7.3 MITIGATION MEASURES ........................................................................................................ 8

8. CONSULTATION ........................................................................................... 13

9. RESPONSE PROCEDURES ............................................................................ 13

9.1 OPERATIONAL RESPONSE PROCESS ...............................................................................13

9.2 EXCEEDANCE PROTOCOL ..................................................................................................13

9.3 COMMUNITY RESPONSE PROCESS ..................................................................................14

9.4 LANDOWNER NOTIFICATION ..............................................................................................15

10. MONITORING PROGRAM .............................................................................. 15

10.1 MONITORING METHODOLOGY ...........................................................................................16

10.2 PM2.5, PM10 AND TSP REAL-TIME MONITORING ................................................................17

10.3 REAL-TIME MONITORING – EARLY WARNING ..................................................................17

10.4 HIGH VOLUME AIR SAMPLER MONITORING (PM10) ..........................................................19

10.5 DUST DEPOSITION MONITORING .......................................................................................19

10.6 METEOROLOGICAL MONITORING ......................................................................................20

10.7 CHEMICAL AND TOXICOLOGICAL COMPOSITION OF DUST EMISSIONS ......................20

10.8 WATER QUALITY TESTING OF RAINWATER TANKS ........................................................20

10.9 MONITORING LOCATIONS ...................................................................................................21

10.10 DATA ANALYSIS ....................................................................................................................22

10.10.1 Data Validation Procedure .......................................................................................22


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10.10.2 Real-Time Particulate Monitoring (PM10) .................................................................22

10.10.3 Dust Deposition Monitoring .....................................................................................23

10.10.4 Calibration of Equipment .........................................................................................23

11. REPORTING .................................................................................................. 23

12. PERFORMANCE INDICATORS ...................................................................... 24

13. CONTINUAL IMPROVEMENT ........................................................................ 24

14. REVIEW ......................................................................................................... 24

15. REFERENCES ................................................................................................ 25

16. APPENDICES ................................................................................................ 26


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List of Tables

Table 1: Background concentration data .................................................................................................. 5 Table 2: Major sources of dust in Year 5 .................................................................................................. 5 Table 3: Major sources of dust in Year 9 .................................................................................................. 6 Table 4: Actions to be taken to check air quality related assumptions during early operations ............... 6 Table 5: Dust sources, mitigation measures and responsibilities ............................................................ 9 Table 6: Summary of air quality compliance criteria ..............................................................................15 Table 7: Trigger levels and description of responses (suggested for commencement of operations)...18 Table 8: Hillside Mine air quality proposed monitoring locations ...........................................................21

List of Figures

Figure 1: Sensitive Receptor Locations ..................................................................................................27 Figure 2: Monitoring Locations ...............................................................................................................28 Figure 3: Location Map of year 5 operations – Predicted Annual Average PM2.5 Concentrations ........29 Figure 4: Location Map of year 5 operations – Predicted Maximum 24hr PM10 Concentrations ...........30 Figure 5: Location Map of year 5 operations – Predicted Annual Average TSP Concentrations ..........31 Figure 6: Location Map of year 5 operations – Predicted Annual Average Dust Deposition .................32 Figure 7: Location Map of year 9 operations – Predicted Annual Average PM 2.5 Concentrations .......33 Figure 8: Location Map of year 9 operations – Predicted Maximum 24hr PM10 Concentrations ...........34 Figure 9: Location Map of year 9 operations – Predicted Annual Average TSP Concentrations ..........35 Figure 10: Location Map of year 9 operations – Predicted Annual Average Dust Deposition ...............36

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 Study 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

4.0 14/11/2017 DPC Response Revision

5.0 20/12/2017 Approved by Management – Ready for PEPR submission


ML 6438 | EML 6439 | MPL 146 v


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

AWS

Automatic weather station

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

BAM

Beta attenuation monitoring

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)

DPC Department of the Premier and Cabinet, South Australia

DSD Department of State Development, South Australia

EML Extractive Minerals Lease 6439

EMS Environmental Management System

EPA Environment Protection Authority, South Australia

GHG Greenhouse Gas Emissions

HVAS

High volume air sampler

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

IS14001:2015 Environmental management systems – Requirements with guidance for use

ML Mineral Lease 6438

MPL Miscellaneous Purposes Licence 146

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 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


ML 6438 | EML 6439 | MPL 146 ii


Total suspended particulates

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


ML 6438 | EML 6439 | MPL 146 1 PEPR Submission Date: 02/02/2018

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 14001:2015. This Air Quality Management Plan (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, 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.



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 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.

There are no EML and MPL conditions (Second Schedule) that relate to Air Quality.

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 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.

The following EML conditions (Sixth Schedule) relate to Air Quality.

Air Quality Outcomes

1. The Tenement Holder must in construction, operation and post mine completion, ensure that there

are no public health and/or public nuisance impacts from air emissions and/or dust generated by

mining operations.

There are no MPL conditions (Sixth Schedule) that relate to Air Quality.

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

4. BASELINE MEASUREMENTS AND MODELLING

Baseline dust emission measurements and assumptions for the Hillside Mine were obtained from

modelling undertaken by independent expert, Pacific Environmental Limited in September 2015 that

identified the following background concentration data (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 (Adelaide) 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 Year 5 and Year 9 of production

because these are the years where maximum mine activity occurs. Modelling has shown that the majority

of dust emissions will be generated from haul roads.

This latest modelling is the most accurate for the Project. It uses actual EFS mine design and material

movement tonnages, based on maximum mine activity years.

Table 2 and Table 3 below show the major sources of dust during Years 5 and 9. Year 9 shows the

contribution of dust emissions during stage five construction of the Tailings Storgae Facility (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 5

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



Table 3: Major sources of dust in Year 9

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 1) 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 5 and year 9 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.



Assumption Action

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 by visual observation during operations and

make adjustments if necessary.

Salt crusting on the TSF

surface is effective

Assess the performanceof dry tailings surfaces by visual observation 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 has shown that generally dust will be well below the ML and EML compliance limits using

standard industry control practices (eg. water trucks on haul roads) (PEL, 2015).

Potential dust emission sources associated with the Hillside Mine operations include:

Pit, drill and blast activities generating dust emissions.

Wheel generated dust emissions from mobile plant from driving on unsealed haul roads.

Unloading, transport and storage of ore, concentrate and waste material.

Crushing circuit dust emissions.

TSF construction, increased dust during staged construction.

Potential dust emission impacts associated with the Hillside Mine operations include:

Potential contamination of rainwater through dust deposition on roofs.

Potential contamination to the environment from deposition of dust.

A key risk identified in the modelling is the potential for exceedance of the PM2.5 criteria in Year 9 to

receptor 25 (see Figure 1 and Figure 7 in Appendix 1 Location Maps) during the construction of the TSF.

Additional monitoring will be implemented near sensitive receptors where modelling has identified the

potential for exceedance of the air quality criteria. This may require additional control measures and will

require monitoring to be in place to ensure dust emissions during construction of the TSF will be

controlled.

This AQMP refers to dust management and monitoring. Risks to crop and livestock from dust are

discussed in Section 5 of the PEPR.



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.

7. AIR QUALITY CONTROL MEASURES

The Hillside Mine AQMP includes a comprehensive set of both proactive (see Section 7.1) and monitoring

based response 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 RESPONSE AIR QUALITY CONTROL MEASURES

Response 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 response alerts based air quality control methodology are provided in Section 10.

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

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

A visual indicator system for supervisors and operators will enable recognition of potential nuisance dust generating situations (eg. tiered photos of dust generating from a haultruck wheel).

Plant Operations 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 will be at risk of creating dust, then maximisation of wetted surface needs to be undertaken, either by water truck sprays or by rotating use of the slurry outlet pipes.


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.

A wheel wash will be established at the exit of the operational area/plant area and every piece of equipment that has been on unsealed roads within the site will go through this.


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 required, to prevent the generation of unacceptable dust.


As required

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

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 (automated where possible and feasible), 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

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


As required




Hard stand areas around processing area

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 non-sealed roads are speed limited to 40kph (to be confirmed once operation commences). 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 investigation of the source of dust, 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

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

Air quality mitigation measures Responsibility Timing

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



Operational Response Processes

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.


Ensure that all employees and contractors are given

adequate training in environmental awareness, legal

responsibilities, and air quality control methods.


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,


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,


Annual

8. CONSULTATION

This Plan is being prepared in consultation with the DPC, 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 the relevant air quality monitoring

measurement criteria as outlined in the trigger and response plan in Table 7, 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 (in the case of a lease condition

exceedance) 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 DPC in accordance with Mining Regulations 87

(2011) SA and will require an investigation by Hillside Mine personnel (and the DPC where required)

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. The HMCV will receive update reports which will contain this information.

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.

Two methodologies can be applied to evaluate the mine contribution to dust deposition at the boundary:

1. Real-time dust monitoring data plotted as PM10 rose diagrams for the same periods as the dust

deposition monitoring results for evaluation of dust concentrations in different wind directions to

infer levels of contribution.

2. Should the real-time data evaluation method be found not to provide adquate detail, the use of

DDD gauges in three loactions (northern, western and southern boundary) could be trialled and

considered. The intention with the DDD data would be to apply the percentage of deposited dust

in the gauge facing the mine as the mine contribution percentage applied to the dust deposition

results.

9.3 COMMUNITY RESPONSE PROCESS

All complaints received regarding operational air quality will be responded to in accordance with the

Complaints Management Procedure EC Pro 320. 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.

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 3 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.

Rex will give the complainant feedback as to measured levels, record action to mitigate concern and report if there was an exceedance.

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 Hillside Mine 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.

Table 6: Summary of air quality compliance criteria

Substance Criteria Units Averaging Period Reference

PM10 50 µg/m3 24 hoursa Hillside Mine MLb

Air EPPc

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

Air NEPMe

PM2.5 8 µg/m3 12 months Hillside Mine MLb

Air NEPMe

TSP 120 µg/m3 24 hours Hillside Mine MLb

TSP 90 µg/m3 12 months Hillside Mine MLb

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

Hillside Mine MLb

Air NEPMe

Air EPPc



Substance Criteria Units Averaging Period Reference

NSW EPAg

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

Air EPPc

NSW EPAg

a. 24 hour period is defined as a calendar day (midnight to midnight).

b. Hillside Mine ML 6438.

c. Environment Protection (Air Quality) Policy 2016.

d. Compliance requirement that total dust deposition is below 4 g/(m2 month).

e. Air NEPM (National Environment Protection Measure) for Air Quality Standard PM2.5

f. Compliance with annual average not specifically listed in Hillside Mine ML.

g. NSW EPA (2016) Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales, Table 7.1.

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.

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.

The real-time dust monitoring includes five locations (M2, M3, M5, M11, and M13) are to measure for

PM10 (BAM monitors as approved by the US-EPA Federal Equivalent Method), locations listed in Table

8 and Figure 2 in Appendix 1. 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.

One of these locations (M2) will also have a real-time monitor to measure for PM2.5 that is located in the

prevailing SSE downwind direction from the mine.

The rationale is that the PM10 is accurately measured at each location, and the PM2.5 measured at the

M2 location provides a real-time measurement of the ratio between PM10 and PM2.5 on an ongoing basis.

This measured ratio can then be used to calculate the PM2.5 at the other locations.

Real time TSP monitors are proposed for M2 and M13, again covering the prevailing SSE and winter

time/NW wind directions up and downwind from the mine.

The high volume air sampler (HVAS) located at M1 provides an accurate measure of dust content (ie.

metals analysis) on an ongoing basis.

Dust deposition gauges are planned at the five real-time locations, as well as six other locations around

the site. Along with these, additional dust deposition gauges are planned at individual landowner locations

around the lease area depending on negotiatios and requests. Within the operating site, Rex will have

additional mobile and temporary dust monitors as part of its daily dust management control, depending

on wind direction and site activities planned. Final dust monitoring locations will be determined after

practical considerations such as power availability and land access agreements.

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. Measurements will occur continuously at

intervals of not more than 10 minutes.

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 4 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

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.

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 PM10

Hourly average

Review current and planned operations considering:

dust generating sources;

the current level of dust controls being applied;

check real-time dust monitors and note areas of increase;

24-hour average from midnight to midnight;

consider the current/forecast meteorological conditions (measure and

record wind speed and direction, temperature, humidity, atmospheric

pressure, solar radiation, rainfall and evaporation) with respect to

mobile plant locations and plan operations accordingly.

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

required.


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.



Trigger Level Concentration Description response triggered


Hourly average

This is a prompt that 50 µg/m3 PM10 (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

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 PM10,

40 µg/m3 PM10 and 50 µg/m3 PM10 could be set based on 1-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 as addressed in the trigger and response plan

10.4 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 in Appendix 1 Location Maps for the monitoring locations).

The samples from the TSP HVAS sampling will be submitted to a NATA accredited laboratory on a

monthly basis for the chemical and toxicological composition of dust monitoring requirements Data from

this sampling enable determination of the compliance status of the mining operations at private properties

in the vicinity of the mine site.

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.

10.5 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.

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.



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 DPC 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.

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.

10.6 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. On site measurements during early operations will determine which

wind speeds cause dust issues. These conditions may change over the live of the mine.

10.7 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.

10.8 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 rainwater tank monitoring program will commence prior to the commencement of construction and

mining operations to establish a baseline.



10.9 MONITORING LOCATIONS

The AQMP consists of the following:

five BAMs;

one HVAS;

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 five 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). In addition, there will be an additional TDD gauge near the closest Black Point receptor, location

yet to be determined.

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

*

Continuous 760230E

6178975N

Monitoring of TSP, PM10 and PM2.5

* 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

760114E

6178768N

Co-located for additional dust levels and type information.

Additional data

M3 Northeast of site after first year

BAM: PM10

Continuous 765572E

6178973N

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

765460E

6178747N


Additional data

M5 West of site

BAM: PM10

Continuous 760233E

6175134N

Targeting of nearest sensitive receptor.

Compliance


30 days continuous

760099E

6174941N


Additional data

M11 South of site

BAM: PM10

Continuous 762364E

6172772N

Targeting of nearest sensitive receptor.

Compliance



Site no.

Location Instrument Frequency Approximate coordinates (MGA)

Reason for location Purpose


30 days continuous

762209E

6172556N


Additional data

M13 Southeast of site

BAM: PM10 TSP

Continuous 765041E

6171529N

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 processing plant

HVAS: TSP and weather station

1 day in 6 762006E

6177264N

Co-located for boundary conditions and metals analysis at exposure location near plant.

Compliance

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

760082E

6177209N


M12 South-eastern corner of site


30 days continuous

764259E

6171774N


M14 Southeast of site south of pine point


30 days continuous

763830E

6170317N


M8 Southwest of site


30 days continuous

759993E

6173413N

Target receptor. Compliance

M6 Eastern lease boundary


30 days continuous

764737E

6176286N


M7 Near Black Point


30 days continuous

764209E

6166835N


*PM2.5 will be measured until a relationship between PM10 and PM2.5 can be proven to the satisfaction of the Director of

Mines.

10.10 DATA ANALYSIS

10.10.1 Data Validation Procedure

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

10.10.2 Real-Time Particulate Monitoring (PM10)

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



Values recorded are not removed unless the data is considered anomalous or below -5 μg/m3 (or negative value determined as per instrument operation manual). 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 typically 75% of the data available is required. For hourly periods this translates to 5 out of 6 ten minute periods.

*AS 3580.911:2016: Occasionally BAMs may record short-term (<24 h) negative PM10 concentrations. This is often

associated with the loss of moisture or semi-volatile compounds in the collected particulate matter from the filter media

that can occur during the measurement process. Short-term negative values resulting from such loss should be considered

to be real data and should not be invalidated from the dataset.

10.10.3 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.

10.10.4 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.

Rex will retain the monitoring data and will make this accessible on an internet site for the life of the mine.

Rex will check the live air quality monitoring systems currently being used on the Victoria, NSW and

Queensland EPA websites before developing the website.

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. Rex will endeavour to undertake community surveys

in relation to air quality with the HMCV on an ongoing basis as part of the community engagement.

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 Hillside 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.

14. REVIEW

This Plan will be reviewed, and if necessary revised, to the satisfaction of the DPC 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; ie. following two or more exceedances at one monitor or if there are unresolved complaints in relation to compliance dust exceedances;

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

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

- Deposited matter - Gravimetric method.

AS/NZS 3580.9.11:2016 Methods for sampling and analysis of ambient air - Determination of suspended

particulate matter - PM10 beta attenuation.


particulate matter - PM2.5 beta attenuation monitors.


particulate matter - Total suspended particulate matter (TSP) - High volume sampler gravimetric method.

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

equipment.

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

ambient air quality monitoring.

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

Mining, Version 2.3.

Department of Science, Information Technology, Innovation and the Arts, (2013). Queensland Air Monitoring

Report 2012.

Environment Protection (Air Quality) Policy 2016, South Australia.

EPA (2016) Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales, Table

7.1, New South Wales.

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

commencement).

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

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.

National Greenhouse and Energy Reporting Act 2007 (NGER Act).

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.

Rex Minerals Ltd, Hillside Mine Mineral Lease Application.

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.



16. APPENDICES

Appendix 1: Location Maps



Figure 1: Sensitive Receptor Locations



Figure 2: Monitoring Locations

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



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



Figure 4: Location Map of year 5 operations – Predicted Maximum 24hr PM10 Concentrations



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



Figure 6: Location Map of year 5 operations – Predicted Annual Average Dust Deposition



Figure 7: Location Map of year 9 operations – Predicted Annual Average PM 2.5 Concentrations



Figure 8: Location Map of year 9 operations – Predicted Maximum 24hr PM10 Concentrations



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



Figure 10: Location Map of year 9 operations – Predicted Annual Average Dust Deposition



Appendix 2: Correspondence Records

Key relevant communications with DSD, DPC, EPA, HMCV and the community relating to this

management plan are detailed below.

Date Communication with

Action or Outcomes

03/03/2017 DSD Meeting to update on PEPR progress and initial discussion on Air Quality plan proposed structure.

06/03/2017 HMCV Presentation and outline of initial draft of AQMPand Monitoring Plan covering including objectives, control measures, pictures of examples of monitoring equipment, summary of monitoring options – draft copies of Plan provided.

14/03/2017 HMCV Circulation of draft AQMP and Monitoring Plan to HMCV members.

23/03/2017 DSD Update on status of AQMP and consultation with HMCV and landowners.

03/04/2017 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.

13/04/2017 DSD Review of structure of AQMP.

01/05/2017 HMCV Updated draft of AQMP tabled – updated e-version sent.

18/06/2017 Public Meeting - AQMP

Public meeting held to present management plan. Written public feedback from both DPC and public received as a result presentation and discussion.

18/06/2017 Public Meeting – rainwater tank testing

Public meeting held to present rain water tank testing. Written public feedback from both DPC and public received as a result presentation and discussion.

23/08/2017 Public Meeting – Farmers Meeting

Public meeting held to present dust impact on crops. Written public feedback from both DPC and public received as a result presentation and discussion.

20/12/2017 DPC Feedback from public meeting and DPC was addressed and where applicable incorporated into management plan. A Table of all feedback on each topic and how they were addressed is incorporated in the PEPR in Section 7.



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.



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 four to five locations.

Calculation:

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



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, 10.10

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., 10.2

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

2, 10.10

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

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

2, 9

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




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

10.7, 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

10.8

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

10.8

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.

10.8

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

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.

10.6

Rex Minerals Hillside Mine Miscellaneous Purposes Licence Conditions (MPL 146) Second Schedule

There are no Hillside Mine MPL conditions (Second Schedule) relating to air quality.

Rex Minerals Hillside Mine Extractive Minerals Lease Conditions (EML 6439) Second Schedule

There are no Hillside Mine EML conditions (Second Schedule) relating to air quality.

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


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

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:

3, 7.3

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, 7.3, 10.7, 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, 10.6

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, 10.3

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

2, 3, 10.1, 10.5

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, 10.5 43.1 reduction in crop yield;



Rex Minerals Hillside Mine Miscellaneous Purposes Licence Conditions (MPL 146) Second Schedule

There are no Hillside Mine MPL conditions (Sixth Schedule) relating to air quality.

Rex Minerals Hillside Mine Extractive Minerals Lease Conditions (EML 6439) Sixth Schedule


1. The Tenement Holder must in construction, operation and post mine completion, ensure that there are no public health and/or public nuisance impacts from air emissions and/or dust generated by mining operations.

3, 9

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