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NYRSTAR HOBART

TRIENNIAL PUBLIC ENVIRONMENT REPORT

2015 – 2017

VERSION 2: SUBMITTED 21 MAY 2018

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TABLE OF CONTENTS

General Manager’s Letter of Introduction ...........................................................................................................4 1. Nyrstar Operations Overview..............................................................................................................................5 2.

2.1 Corporate Overview .......................................................................................................................................... 5

2.1.1 Primary Products .................................................................................................................................... 5

2.1.2 Nyrstar’s Strategy ................................................................................................................................... 6

2.2 Nyrstar Hobart Smelter...................................................................................................................................... 6

2.3 Production .............................................................................................................................................. 8

2.4 Raw Materials .............................................................................................................................................. 9

2.5 Site Products and their Uses ............................................................................................................................ 12

2.6 The Production Process ................................................................................................................................... 13

2.7 Changes to Site Material Structures, Equipment and / or Processes ................................................................. 13

2.7.1 Major Projects for Nyrstar Hobart ......................................................................................................... 14

Environmental Management System ................................................................................................................ 21 3.

3.1 Introduction and Overview .............................................................................................................................. 21

3.2 Environmental Policy ....................................................................................................................................... 21

3.3 Leadership ............................................................................................................................................ 23

3.4 Planning ............................................................................................................................................ 23

3.4.1 Environmental Aspects & Impacts ......................................................................................................... 23

3.4.2 Environmental Objectives and Targets .................................................................................................. 24

3.4.3 Legal Requirements .............................................................................................................................. 28

3.5 Implementation and Operation ....................................................................................................................... 29

3.5.1 Environmental Training ......................................................................................................................... 29

3.5.2 Communications ................................................................................................................................... 30

3.6 Checking ............................................................................................................................................ 31

3.6.1 Monitoring and Measurement .............................................................................................................. 31

3.6.2 ISO 14001 Certification ......................................................................................................................... 31

3.7 Environmental Compliance .............................................................................................................................. 35

3.8 Summary of Fulfilment of 2015–17 Environmental Objectives.......................................................................... 37

3.8.1 Other Environmental Achievements ...................................................................................................... 42

Monitoring Programs ....................................................................................................................................... 43 4.

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4.1 Atmospheric Emissions .................................................................................................................................... 43

4.2 Atmospheric Emissions .................................................................................................................................... 43

4.2.1 Point Source Stack Emissions ................................................................................................................ 43

4.2.2 Ambient Sulphur Dioxide ...................................................................................................................... 56

4.2.3 Ambient Particulate Matter .................................................................................................................. 63

4.3 Site Water Management.................................................................................................................................. 74

4.3.1 Process Water ...................................................................................................................................... 74

4.3.2 Potable, Reused and Recycled Water Consumption ............................................................................... 77

4.3.3 Stormwater .......................................................................................................................................... 79

4.3.4 Groundwater ........................................................................................................................................ 81

4.4 Receiving Waters .......................................................................................................................................... 103

4.4.1 Water Quality Monitoring ................................................................................................................... 103

4.4.2 Biota ............................................................................................................................................... 116

4.5 Noise .......................................................................................................................................... 132

4.5.1 Noise Monitoring Program Details ...................................................................................................... 133

4.5.2 Noise Results & Discussions ................................................................................................................ 134

4.6 Process and Non-process Waste .................................................................................................................... 137

4.6.1 Process Waste and By-products .......................................................................................................... 137

4.6.2 Non-Process Waste Materials ............................................................................................................. 140

4.7 Energy Management & Climate Change ......................................................................................................... 146

4.8 Flora and Fauna .......................................................................................................................................... 146

4.9 Cultural Heritage .......................................................................................................................................... 147

Glossary ......................................................................................................................................................... 148 5. Appendices .................................................................................................................................................... 150 6.

6.1 Appendix 1 – Community Complaints 2015 – 2017......................................................................................... 150

6.2 Appendix 2 – Notifiable and reportable environmental incidents 2015 – 2017 ............................................... 158

6.3 Appendix 3 – Environment Protection Notice 7043/4 ..................................................................................... 170

6.4 Appendix 4 – 2017 Stack Emission Reports .................................................................................................... 210

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GENERAL MANAGER’S LETTER OF INTRODUCTION 1.

It is my pleasure to present Nyrstar Hobart’s Triennial Public Environmental Report. I acknowledge the contents of this report as representing the environmental performance and work conducted at the site during the reporting period.

This Triennial Public Environment Report provides a summary of Nyrstar Hobart’s environmental activities for the period 1 January 2015 to 31 December 2017, comparing environmental performance against commitments and regulatory obligations, while monitoring progress particularly in the areas of air, water, land, noise and the local community.

Our aim is to minimise the environmental impact of both our production processes and our products and to conduct our operations in compliance with all relevant environmental legislation, regulation, and licenses.The environmental challenges posed by the site are not insignificant. Smelting operations over the past 100 years have resulted in contamination of soil and groundwater, accumulated waste stockpiles, and ecosystem impacts on the Derwent estuary. However, Nyrstar Hobart acknowledges and accepts these challenges and has made significant and increasingly rapid progress in addressing these issues.

Throughout the reporting period we continued to improve the effectiveness of our Environmental Management System and have maintained certification to ISO14001:2004, a means of ensuring the site utilises best practice environmental management principles.

Air quality performance during the reporting period was promising with improved lead in air results from fugitive dust and an observed decrease in sulphur dioxide (SO2) concentrations from the site’s primary emission point (foreshore stack).

Monitoring of both ambient SO2 and total suspended particulate matter recorded results well within the licence limits throughout the 2015-2017 period. On site dust focus groups continued to concentrate on improving operational controls to further reduce dust emissions within the plant, with a strong focus on wharf-based emissions.

The implementation of the Nyrstar Hobart Groundwater Management Strategy continues to be a primary focus for the site. Sealing of the Electrolysis cell house basement was completed in 2017, largely removing a significant pathway for groundwater contamination. Additional investigative works were conducted to further assess contaminant levels in the deeper aquifer underneath the site, and to better understand the hydrogeology in specific areas. Design work for the next major groundwater extraction system commenced in 2017, with completion expected in early 2018.

Overall, 2015 - 2017 has been a successful period for the site with strong environmental performance and a number of key objectives of site environmental management plans completed. 2018 - 2021 will see continued focus on the key

areas of groundwater management, waste management and air emissions management.

During the reporting period, we did breach the site’s environmental licence on six occasions. On each occasion the incident was thoroughly investigated with full reports submitted to the regulator. Each of the 6 investigation reports, and associated preventative/corrective actions were accepted by the regulator.

I encourage you to read this report and hope you find it interesting and informative. If you have any comments or suggestions in relation to either the content or format of this review, please contact our Environment Principal, Kylie Veale on (03) 6278 4604.

REINHARDT VILJOEN

GENERAL MANAGER

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NYRSTAR OPERATIONS OVERVIEW 2.

Corporate Overview 2.1

Nyrstar is a global multi-metals business with market leading positions in zinc and lead, and growing positions in other base and precious metals, such as copper, gold and silver. Nyrstar has six smelters, one fumer and four mining operations located in Europe, the Americas and Australia and employ approximately 4,300 people. Nyrstar is incorporated in Belgium and has its corporate office in Switzerland. Nyrstar is listed on Euronext Brussels under the symbol NYR.

Figure 2-1 The World of Nyrstar.

2.1.1 Primary Products

Zinc A global leader in zinc, Nyrstar is one of the world’s largest zinc smelting companies based on production volumes. Nyrstar produces zinc in concentrate from its mining operations and a variety of refined market zinc products including special high grade zinc, zinc galvanising alloys, and zinc die-casting alloys as an outcome of its zinc smelting process. Zinc has diverse applications and uses, from construction and infrastructure, to transport, industrial machinery, communications, electronics and consumer products. This makes it an essential and highly sought-after resource. Lead Nyrstar produces lead in concentrate and refined market lead (99.9%). Lead’s primary usage is for the production of batteries. In fact, more than 80% of world production goes into the manufacture of lead acid batteries which continue to play an important part in the starter mechanism for automobiles as well as in batteries for e-bikes where demand from developing economies remains significant. Other end uses for lead include underwater cable sheathing, glassware, solder and roof sheeting.

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Copper Nyrstar produces copper in concentrate and copper cathode. Copper is predominantly used in building construction. Other significant end-use markets include electrical and electronic products, transportation equipment, consumer products and industrial machinery and equipment. Gold Gold is produced in concentrate from our mining operations. Nyrstar also recovers gold in the lead refining process. Silver Silver is produced in concentrate from our mining operations. Nyrstar also recovers silver from the lead refining process as a silver doré and as a by-product from the zinc refining process into various leach products.

2.1.2 Nyrstar’s Strategy

Nyrstar management has a strategy aimed at positioning the business for a sustainable future as a leading metals processing business. Through its deep market insight and unique processing capabilities, Nyrstar aims to generate superior returns by extracting the maximum value inherent in the mineral resources and by-products it processes. Accordingly, Nyrstar has developed a coordinated approach to redeveloping and operating its asset portfolio to optimise the concentrate feed into its smelters, maximise minor and precious metal extraction, and enhance the margins of its end-product mix. To realise its strategy, management has determined the following strategic priorities:

Selectively invest in existing smelter network to allow the processing of higher margin feeds

Redevelop Port Pirie metal recovery and refining facility to maximise the value from concentrates and residues

Streamline the asset base with a focus on smelting operations

Strengthen and maintain a more conservative balance sheet

Optimise the feed book of raw materials

Improve end product mix and integration with key end users

Nyrstar Hobart Smelter 2.2

Nyrstar Hobart (NH) is a large scale zinc smelter located on the western bank of the Derwent estuary in Hobart, Tasmania. The Hobart site has operated for over 100 years, celebrating its centenary in 2017. The site is one of the world’s largest and most efficient zinc producers, with a production capacity of 280,000 tonnes of marketable metal. The facility uses the Roast, Leach, Electrolysis (RLE) process for zinc production and is closely integrated with the Nyrstar Port Pirie multi-metals smelter, which processes Hobart’s paragoethite by-product as well as other leach by-products.

The Hobart smelter is focused on high value added products for export to growing markets in Asia. This site has been significantly upgraded and modernised over the last 40 years, with improvements such as modernisation of gas purification and acid plants in the roasting facility, the modernisation of the leaching and purification processes, the introduction of mechanised zinc stripping in electrolysis and the automation of the casting plant. These major capital works and operational improvements have increased the plant’s annual operating capacity from approximately 170,000 tonnes of zinc in 1977 to approximately 280,000 tonnes today. Hobart’s key products are special high grade zinc, die cast alloys (branded ‘EZDA’) and continuous galvanising grade alloys. In addition, the site produces by-products of cadmium, copper sulphate, paragoethite, lead sulphate leach concentrate and sulphuric acid.

NH owns approximately 120 ha of land on the western shore and 100 ha on the eastern shore of the Derwent estuary, maintaining substantial buffer zones between the site and surrounding residential community.

The smelter is partially surrounded by a number of neighbouring facilities and stakeholders, shown in Figure 2-2.

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Figure 2-2 Nyrstar Hobart and immediate surrounds.

Hobart is built around the Derwent estuary on a coastal plain, with the majority of the population within a 10 km radius of the CBD. The climate is cool and temperate. The dominant wind direction is northwesterly, though airflows are strongly modified by the complex hill and mountain topography surrounding the city. The regional geology is dominated by Permian to Triassic sedimentary rock intruded by Jurassic dolerite. Hobart experiences variable rainfall over a large catchment, with the majority of potable water sourced from highland catchments that yield high quality water. NH operates within the management catchment of Glenorchy City Council.

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Production 2.3

Annual production rates for zinc and other major NH products for the three year period 1 January 2015 to 31 December 2017 is shown below.

Cathode zinc production

Lead sulphate leach concentrate

Paragoethite

Copper sulphate

Cadmium

Figure 2-3 Product and by-product production 2015 – 17.

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Raw Materials 2.4

The major raw material required for site operations is zinc concentrate, made from the milling and beneficiation of

mined zinc sulphide (sphalerite) ore. Concentrates arrive by ship and are unloaded at the NH wharf, on the eastern

frontage of the smelter, then stockpiled in a closed concentrates shed prior to use. The concentrates shed is a purpose-

built facility, constructed in 1997, to reduce dust emissions from stockpiling concentrates and other by-products.

During 2015 – 2017, the majority of concentrates were sourced from Min Metals Group (MMG) Century mine and Mt

Isa mine in northwest Queensland and the Rosebery mine on the west coast of Tasmania.

NH processed the last of the Century mine feed in February 2016, and since then has sourced concentrates from

numerous mines around the world. In 2016 and 2017, the Rosebery mine provided the largest volume of concentrates

of any individual mine. The proportion of feed concentrates from each of the mines for the reporting period is shown

below and tabulated in Table 2-1.

Another significant source of feed material to the site is zinc oxide fume, a by-product of Nyrstar Port Pirie. This

material is processed in Hobart on an ongoing basis with an average volume of 34,455 tonnes processed per annum.

Figure 2-4 Total zinc concentrates roasted (tonnes p/a).

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Figure 2-5 Proportion of feed materials by source 2015 – 17.

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Table 2-1 Total tonnes of concentrates and oxides processed from 01/01/15 to 31/12/17

Raw Materials 2015 2016 2017

Rosebery Concentrate 168,643 139,586 140,915

Mt Isa Concentrate 20,264 80,827 39,306

Contonga Concentrate 5,514 9,067 0

Cannington Concentrate 1,962 10,263 0

McArthur River Concentrate 17,064 2,732 19,666

Broken Hill Perilya Concentrate 905 25,333 55,815

Endeavor Concentrate 0 10,055 0

Antamina Concentrate 0 9,705 379

Casapalca Concentrate 0 4,493 0

Catalina Huanca Concentrate 0 50,241 22,847

Trafigura Peruvian Blend Concentrate 0 20,142 34,270

Century Concentrate 261,678 15,094 0

ESAN Concentrate 0 19,713 0

Cerro Lindo Concentrate 0 8,377 0

Red Dog Concentrate 0 10,212 0

Black Mountain Concentrate 0 8,682 0

RASP Concentrate 0 0 10,168

Jaguar Concentrate 0 0 18,454

Mexican Blend Concentrate 0 0 10,262

TF Contract Blend Concentrate 0 0 30,630

Penasquito Concentrate 0 0 11,691

Golden Grove Concentrate 0 0 10,075

Port Pirie Oxide 26,979 31,881 44,506

Horsehead Oxide 0 2,649 22,524

TOTAL 503,009 459,052 471,508

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Site Products and their Uses 2.5

NH produces a range of premium products, including value-

added alloys. Zinc is alloyed with other metals such as

aluminium and manganese to produce targeted products.

Zinc provides excellent corrosion resistance to iron and steel. It

is also a relatively hard metal with a low melting point, making

it suitable for die casting, but still soft enough to be formed,

rolled, or extruded.

You’ll find zinc in everything from: construction and

infrastructure; transport and industrial machinery; and

communications and electronics, to consumer products and

human health applications.

The major uses for NH’s zinc products are as follows:

Galvanising – zinc’s most important use is in protecting steel from corrosion. A thin layer of zinc protects the

underlying steel, extending the life of motor vehicles, bridges, fences, buildings and a wide range of other

products for many years. Zinc is also used as sacrificial anodes attached to ships’ hulls, pipelines and

underwater structures to prevent corrosion.

Die Casting – one of the fastest growing uses of zinc is for the production of die-casting alloy – the shortest

distance between raw material and finished product. Because of the quality of these zinc alloys, complex

precision parts are mass-produced for products as diverse as bathroom fittings, zippers, automobile parts,

vacuum cleaners, refrigerators, carburettors, and scale model vehicles and other toys.

Brass and Bronze – a wide variety of brasses and bronzes are produced, which include zinc as an essential alloying ingredient. Modern uses include high purity zinc alloys used to purify water by removing chlorine, hydrogen sulphide, iron and other metals.

Chemicals – in the form of various chemicals, zinc is essential in the manufacture of plastics, ceramics, medicinal products, paints, motor oil additives, soldering fluxes and many other items. Zinc is also used in the manufacture of a number of chemicals, most frequently zinc oxide, zinc sulphate and zinc chloride. These products are used in fertiliser, pharmaceuticals, paper, rubber, rayon, wood and other industries that require high quality zinc.

NHs other main products include:

Sulphuric Acid – we recover sulphur in our production processes to produce a significant quantity of high purity sulphuric acid. Sulphuric acid is a vital commodity in any modern economy. In fact it is so widely used that its consumption rate – like steel production or electricity power – is a good barometer of a nation’s prosperity. It is used either directly or indirectly in almost every industry. It is an essential ingredient in the production of fertilisers, fibres, paint, rubber, plastics, steel, detergent and medicines, and can even be found, perhaps surprisingly, in many beers and soft drinks. One of its more specialised uses is in the production of high strength fibres for use in bulletproof vests and yacht sails.

Cadmium is a soft, bluish-white, ductile metallic element that occurs in association with zinc ores. Its main use is in the production of nickel cadmium batteries.

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The Production Process 2.6

The production process at NH is shown in Figure 2-6.

The sequences of steps in the zinc production at NH are as follows:

Roasting of zinc concentrate to calcine to make it more readily soluble for further purification. A by-product of this step is the production of sulphuric acid.

Leaching of the calcine in a five stage counter-current process, using the spent electrolyte from the electrolysis step. This produces an impure zinc sulphate solution and leaves a lead-silver product. Iron is also removed as paragoethite, which is normally further treated at Nyrstar’s lead smelter at Port Pirie, South Australia.

Purification of the zinc sulphate solution, removing metallic impurities by their displacement through the addition of zinc dust. Copper is recovered as a copper sulphate by-product, and cadmium metal is also recovered for sale.

Electrolysis of the purified solution, whereby it is depleted of a portion of its zinc and regenerates sulphuric acid. This produces cathode zinc and spent electrolyte, which is recycled to the leaching stage.

Casting of cathode zinc into slabs and blocks, and the production of alloys.

Figure 2-6 Production process.

Changes to Site Material Structures, Equipment and / or Processes 2.7

NH implemented a number of major projects during the reporting period, which have resulted in changes to the structures, equipment, and processes on the site. These changes have been implemented, and managed in such a way that they have not resulted in a material difference to site emissions, nor is it considered that they have the potential to cause environmental harm.

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2.7.1 Major Projects for Nyrstar Hobart

The 2015–17 reporting period has seen considerable investment in operational aspects at NH. Implementation of major projects has been driven by a number of key factors:

Closure of Century Mine in 2015 leading to a changing feed book (the mix of raw materials processed at NH) and therefore a need for operational readiness to adapt to variability in process arising from changing feed compositions;

Safety and environmental issues present at the Wharf including structural deterioration and need for stormwater management upgrade;

Opportunity to implement a further treatment step in the existing wastewater treatment process at NH and reuse treated water on site; and

Opportunity to improve recycling of zinc dross back into the Casting process.

Ongoing management and minimisation of contamination sources to soil and groundwater

Century Mine Closure – Operational Readiness

Throughout the previous reporting period (2012 – 2014) and up until 2016 NH predominantly processed two concentrates – sourced from Century (~70% of feedstock) and Rosebery (~25% of current feedstock) mines. Hence, the imminent closure of Century Mine in 2015 led to a Smelting Strategic Review (SSR) by Nyrstar in 2013. The review clearly identified that while the Century concentrate provided security in feedstocks, closure of the mine represents many opportunities for NH. A broadening feed book post Century Mine closure enabled additional value realisation through increasing extraction of metals such as cadmium, valuable minor metals and improving the value of by-products such as paragoethite and lead sulphate leach concentrate.

However, a broadening feed book also represented process challenges for many of the Nyrstar smelters. For the NH site, a number of projects (known as SSR projects) were identified as a priority. While no material change to the current process resulted from these projects, the technical and infrastructure modifications enabled NH to optimise processing of different zinc concentrates and oxides (the ‘feed book’) following the cessation of Century Mine in 2015.

The SSR projects commenced at varying times depending on need for approvals, internal prioritisation and nature of the work which enabled staging of design and construction aspects. The location of SSR projects are shown in Figure 2-7, followed by a brief overview of the projects.

Figure 2-7 Location of SSR projects.

SSR:3 – New Lead Residue Filter

SSR:29 – Cadmium Plant Upgrade

SSR:3 – HAL Process Upgrade

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SSR3: Hobart Residue Volume

This project involved removing the iron constraint from the leaching process via upgrade of the lead residue filtration system to handle a greater volume of iron. In addition, an upgrade of the Hot Acid Leach (HAL) step was required to enable the processing of increased iron levels.

Design of the building to house the new lead residue filter, filter selection and process integration commenced mid-2014. Construction activities were underway by late 2014 with filter installation occurring mid-2015. Commissioning of the new lead residue filter occurred in September 2015 with the new facility being fully operational by the end of 2015.

Figure 2-8 New Lead Sulphate Leach Cementate Building.

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Demolition of the old HAL plant infrastructure, including two thickener and three reactor vessels, commenced in October 2014. A specific waste management plan was developed for this project due to the numerous types and large volumes of waste generated during the demolition phase. This plan was largely successful in managing waste in a timely and appropriate manner. The installation of the new HAL tanks and associated equipment occurred throughout 2015 with commissioning completed in 2016.

Figure 2-9 New HAL tanks.

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SSR29: Hobart Cadmium

This project involved upgrading the site’s cadmium production capacity as the post Century feed book anticipated higher levels of cadmium in concentrates. The project focussed on two main areas; an upgrade of the cadmium plant to process greater volumes, and modification of the purification circuit to facilitate the removal of the greater volumes of cadmium. This project was important in maintaining Nyrstar’s commitment to strong materials stewardship values and continuing to strive to produce products and avoid generating waste materials.

Similar to the lead residue filter project, design of the building to house the new cadmium plant infrastructure commenced mid-2014. Construction activities were underway by late-2014 and were completed in 2016. The plant was commissioned in 2016.

Figure 2-10 New Cadmium plant.

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Reverse Osmosis Plant Project

A funding opportunity from the Federal government facilitated the design and construction of a reverse osmosis (RO) plant at NH during 2015. The RO process provides an additional treatment step for the wastewater that is currently treated by the site’s Effluent Treatment Plant (ETP). The current process treats the site’s wastewater to a standard that allows the treated water to be released to the Derwent estuary. However, the extra treatment step provided by the RO Plant will allow the water to be reused on site. Hence the project also involved identification of on-site users for the treated water and the installation of a treated water pipe system across the site. The benefits of this project to the environment are clear – reduced volume of treated wastewater to the river, and reduced potable water use on site.

Figure 2-11 New reverse osmosis plant.

Casting Metaullics® Zinkoff Recovery System Project – Improved Zinc Dross Recycling

Zinc dross is generated by the Casting Department. Historical practices involved the material being recycled back into the process through inefficient storage and handling practices. The previous procedure had also been the subject of safety and environmental scrutiny and consequently, both played a significant role in driving the need for operational change in this part of the Casting process.

After consideration of a number of options, design and construction of an alternative process to recycle zinc dross commenced in early 2015. The installation of Metaullics® Zinkoff Recovery (MZR) rotation equipment allows direct handling of cooled dross that has been removed from the Casting furnaces into a dumper. The process in short involves: a dumper is loaded into the MZR rotator then rotated to allow larger clumps to be captured and returned immediately to the furnace. The physically smaller material passes through a screen, which is then funnelled into an MZR barrel. The barrel is then placed in one of two furnaces and the heat up started again.

This new process was commissioned in 2017.

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Wharf Upgrade Project

Approvals were sought and granted in 2013 to undertake much needed structural upgrade work at the NH Wharf. The EPA (Tasmania) conducted an assessment under EMPCA and set Environmental Permit Conditions (PCE 8664). The Glenorchy City Council then issued NH with a Land Use Permit (PLN-12-262) which included the EPAs environmental conditions. The permit conditions are incorporated into the project’s Construction Environmental Management Plan (CEMP) and translated in practical terms to ensure compliance with, and responsibility for meeting the stated requirements.

The project was designed to be completed in stages to facilitate a prioritised approach given some aspects of the work were more urgent.

The stages include:

Stage 1 – demolition of the failed wharf in Zone 1 and construction of a new apron, including any stormwater management design aspects in this zone; and

Stage 2 – selected repair of wharf apron in Zone 2 including any stormwater management design aspects in this zone.

Stage 1 works were completed in 2015. Stage 2 works commenced in 2016 with completion planned for 2019.

The NH Environment Department maintains representation on the project team to facilitate compliance with the permit and provide advice as new matters arise. The benefit of this collaboration is evident in the successful reuse of the contaminated wharf timber in a process furnace at the Nyrstar Port Pirie (NPP) site, diverting the material from a Level 3 landfill. After trials at NPP confirmed reuse of the timber was acceptable and would not cause any process or environmental issues, approval was sought from the South Australian EPA and granted. Shipments of containerised timber are now regularly sent from NH to NPP.

Figure 2-12 Timber bound for Nyrstar Port Pirie.

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Electrolysis Cell House Basement Sealing Project

Commencing in 2010, the sealing of the Electrolysis cell house basement was completed in 2017. This project was a significant milestone for the site, with the cell house basement considered to be a major contributor of ongoing contamination to soil and groundwater.

The basement, previously unsealed soil, underwent significant ground surface preparation and was then coated with an impervious poly-urea, specifically chosen due to the ability of the material to withstand the acidic nature of the cell house liquors. The project was technically challenging due to the aggressive nature of the process solution and the difficult working environment.

Figure 2-13 Newly sealed sections of the basement floor.

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ENVIRONMENTAL MANAGEMENT SYSTEM 3.

Introduction and Overview 3.1

NH has integrated management into a one-business system covering the areas of Safety, Health, Environment and Quality (SHEQ). Specifically the SHEQ Management System has been developed to encompass:

Strategic planning;

Asset management;

Environmental management;

Occupational health and safety;

Human resource management; and

Quality management.

The objective of the management system is to share the responsibility for management of SHEQ at all levels in the organisation and to ensure that every individual is aware of and accountable for safety, health, environment and quality management issues in their area of influence.

NH has achieved accreditation to the international standards ISO 14001:2004 – Environmental Management Systems, ISO 9001:2008 – Quality Management System and AS/NZS 4801:2001 – Occupational Health and Safety Management System.

The site’s Integrated Management System is internally evaluated against the above standards by applying specific audits and checklists, which are scheduled on a rotational basis. An external certified auditing body conducts annual external surveillance and triennial recertification audits.

The site has a specific Environmental Management System (EMS) that forms part of the Integrated Management System. The EMS is a step-by-step approach to environmental management that ensures environmental aspects are not overlooked, tasks are completed and checked, provision is made for changes, and response procedures are established for emergencies. An EMS also provides a process that is applicable across the different levels of the organisation to develop objectives and targets and review progress against those targets.

The NH EMS is applicable to all areas of the organisation’s processes.

Environmental Policy 3.2

The Nyrstar Environment Policy, as shown in Figure 3-1, is specifically designed to represent all Nyrstar operations. This policy was developed in Hobart with representatives from all Nyrstar sites, including regional and corporate offices. The policy was written collaboratively and consultatively with the aim of ensuring it reflected Nyrstar’s values and received Board approval.

The Policy comprises three sections; 1 ’Overview‘ which provides the business context, 2 ’Intent’ which outlines what Nyrstar hopes to achieve with respect to the Policy, and 3 ’Action Plan‘ or ’Bullet Point Actions‘ to outline how Nyrstar plans to fulfil the commitments made in the policy. This policy is the cornerstone of our Environmental Management System. It drives the goals, objectives and strategies we use to achieve targets against which we measure our performance.

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Figure 3-1 Nyrstar environment policy statement.

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Leadership 3.3

Top management at Nyrstar demonstrate leadership and commitment with respect to the environmental management system through a number of channels. These include but are not limited to:

The development of an Environmental Policy (Figure 3-1)

Establishing environmental objectives and tracking of those objectives through weekly and monthly internal NH reporting, and quarterly reporting to the Nyrstar Corporate group

Establishment of a specialist environment team, whose responsibility includes the continual improvement of the environmental management system

Ensuring the integration of the environmental management system requirements into the business process through the implementation of tools, systems, equipment, training etc. Examples include; risk assessment tools, emergency management tools, environmental incident and hazard reporting tools, a document management system.

Enabling open discussion on environmental issues at a twice weekly extended leadership team meeting.

Assigning the responsibility and authority for the EMS to the SHEQ Manager and the Environment Principal through specific position descriptions.

Planning 3.4

3.4.1 Environmental Aspects & Impacts

NH holds a register of environmental aspects and impacts for all issues related to current and historical activities on site. The register fulfils requirements for identification of aspects and impacts as well as risk, and has been verified through external audit as part of ISO14001:2004 certification. This register is reviewed on a continual basis as identified risk profiles change and when new risks are identified. The risk register is held in the site’s Risk Information Management System (RIMS) database, which is routinely reviewed to ensure the currency of information.

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3.4.2 Environmental Objectives and Targets

Nyrstar’s key environmental objective is to: ‘operate our business in an environmentally responsible way by preventing harm to the environment and the community.

NH environmental objectives, targets & programs are determined through the following means:

NH significant environmental aspects;

Nyrstar Corporate Environmental Policy;

The Environment Protection Notice issued by EPA Tasmania; and

NH site Environmental Management Plan.

NH reviews the site’s Environmental Management Plan (EMP) on an annual basis in preparing the Annual Environment Review (AER). The AER reports are submitted to the Tasmanian EPA (DPIPWE) and include details of NH environmental objectives and targets and the site’s progress towards meeting objectives and targets and annual environmental performance.

Objectives as defined through the aforementioned documents are assigned at the commencement of the year to the relevant personnel through the environment work plan tracker.

Actions associated with achieving environmental objectives may also be assigned to personnel as an action in RIMS.

The Environment Strategy and associated objectives are developed each year as part of the strategic planning process. The Nyrstar Global Environment Policy and Nyrstar Way form the cornerstones of the planning process; driving the vision for the future, agreed objectives and all strategies and actions required to achieve these.

Table 3-1 outlines the environmental strategic direction for NH. In 2015 objectives were set that would see NH work towards this strategy. Progress against those objectives is included in Table 3-7.

New objectives have been developed for the coming three year period and are included in Table 3-2. Progress against these objectives will be reported on in each AER, and in the 2018-2021 Public Environment Report.

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Table 3-1 Environmental strategic objectives

•Produce resources not wastes. Decontaminate and divert non-process wastes to beneficial reuse where possible. If storage is required, manage appropriately to prevent environmental harm.

Waste and By-products

•Manage noise sources to reduce ambient noise levels and prevent nuisance to the community.

Noise

•Minimise the process footprint and improve the visual impact of the smelter site. Progressively rehabilitate land to an agreed end-use.

Land Use and Aesthetics

•Actively maintain our risk management system and implement mitigation strategies to reduce risks from hazardous chemicals and prevent harm.

Hazardous Chemicals

•Make energy and raw materials efficiency a part of the way we do business.

Energy Use & Greenhouse

•Manage emissions to soil and groundwater to prevent further pollution to on site soil and groundwater and prevent off site harm. Systematically rehabilitate the site to an agreed standard.

Soil and Groundwater

•Manage stormwater and effluent to prevent impacts upon the receiving environment. Maximise water use efficiency and reuse.

Water

•Manage emissions to air to prevent environmental harm or nuisance.

Air Emissions

•Establish ourselves as a valued Tasmanian business who leads by example.

Stakeholder Engagement

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Table 3-2 Environmental objectives 2018–21

Waste and By-products

Reduce existing stockpiles of process and non-process wastes by seeking out new and innovative recycling and stabilisation technologies.

Develop outlets for future waste products to prevent stockpiling.

Noise

Develop and implement an action plan for reducing nuisance noise sources.

Investigate options to upgrade the community noise monitors in order to be able to better understand the source of community noise issues when they arise.

Land Use and Aesthetics

Continue to implement the site wide weed management plan to prioritise weed removal effort.

Monitor ongoing foreshore erosion issue and develop protection projects as required.

Ensure all the existing re-vegetated zones are sustained through development and implementation of a maintenance plan.

Energy Use and Greenhouse

Continue to identify and pursue energy efficiency opportunities.

Soil and Groundwater

Continued implementation of the site’s Groundwater Management Strategy, including:

» Completion of the detailed design of the next groundwater extraction system

» Commencement of the construction of the groundwater extraction system

» Support upgrades to the sites effluent treatment facility - required to manage the additional load to be produced from the future groundwater extraction systems

» Support for repairs to the Secondary Purification bund – a current source of cadmium contamination

Continue to review groundwater data as it is collected to ascertain any upward trends in metal concentrations.

Undertake an annual review of the groundwater monitoring program to ensure it continues to provide the necessary data to inform decisions.

Undertake a review of bunds and sumps in the Leach plant and develop a prioritised plan for repair.

Ensure the Electrolysis Cell House basement sealing is maintained.

Investigate feasibility of a site wide drain / sump inspection campaign and develop a prioritised improvement program.

Water

Investigate the feasibility of diverting NH car park catchment out of the main site stormwater system.

Increase site use of the recycled water produced through the site’s Reverse Osmosis plant to further reduce potable water use.

Complete the design and construction of new stormwater capture infrastructure across the wharf under the Wharf Structural Recovery Project.

Obtain further understanding of the interaction of the site’s effluent stream with the Derwent estuary.

Air Emissions

Upgrade those stacks identified as being most at risk of causing a breach of the environmental licence.

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Implement a program of works to better understand emissions from the MZR furnace, and to control emissions if required.

Work with the Wharf team to better control dust emissions during ship loading and unloading, and from by-product storage sheds.

Stakeholder Engagement

Meet all self-imposed obligations for community engagement, including community meetings and community newsletters.

Increase visibility of NH environmental management in the surrounding community through promoting school visits, and involvement with community groups such as the Hobart City Council Bush Care program and Conservation Volunteers.

Environmental Risk

Continue to review and update the site’s Risk Register by department.

Develop management plan / controls for critical environmental risks based on the environmental risk review.

Undertake departmental environmental audits.

Environmental Management

Complete the Environmental Data Project to improve efficiency in data review and environmental management.

Develop and implement an ongoing environmental education program. This program may include aspects such as site-wide competitions, development of educational posters, recognition and reward for environmental awareness and improvement to the environmental induction for new-starters.

Review / develop mechanism for systemised approach to SHE considerations in early capital project development.

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3.4.3 Legal Requirements

The NH Environmental Management System (EMS), certified to ISO 14001:2004, defines the process for managing the site's compliance program. Key components of the management system that assist in the maintaining our strong compliance record are:

A procedure outlining the identification and management of site-specific legal and other environmental obligations; and

A consents register detailing all of the environmental licences and other consents with environmental requirements, that have been specifically issued to the site.

The principal environmental obligation for NH operations is the Environmental Management and Pollution and Control Act 1994 (EMPCA). Tasmania enacts the requirements under EMPCA through a suite of legislation which forms the framework for Tasmania’s resource management and planning systems, comprising the following:

» Land Use Planning and Approvals Act 1993;

» Resource Planning and Development Commission Act 1997;

» Resource Management and Planning Appeal Tribunal Act 1993;

» State Policies and Projects Act 1993;

» Environmental Management and Pollution Control Act 1994;

» Historic Cultural Heritage Act 1995; and

» Major Infrastructure Development Approvals Act 1999.

3.4.3.1 Environment Protection Notice

NH operates under Environment Protection Notice (EPN) 7043/4 (Appendix 3 – Environment Protection Notice 7043/4) which was issued in November 2015 by the Environment Protection Authority (EPA) Tasmania under the EMPCA.

3.4.3.2 Proceedings and Infringements

NH did not incur any of the following during the reporting period 01/01/15 to 31/12/17:

Proceedings (prosecutions) issued under Tasmanian or Commonwealth environmental legislation, or the environmental provisions of other legislation; or

Enforcement action taken under any other Tasmanian or Commonwealth environmental legislation, the environmental provisions of other legislation, or the environmental provision of council by-laws; or

Infringements notices issued under the EMPCA.

3.4.3.3 Other Regulatory Instruments Relevant to Operations†

Tasmanian policy under the State Policies and Projects Act 1993;

Tasmanian Coastal Policy 1996;

State Policy on Water Quality Management 1997;

National Environment Protection Measures (NEPMs) are automatically adopted as State Policies under section 12A of the State Policies and Projects Act 1993 and are administered by the Environment Protection Authority. Relevant NEPMs to the operation include:

» National Environment Protection (Air Toxics) Measure 2004;

» National Environment Protection (Ambient Air Quality) Measure 1998;

http://www.epa.tas.gov.au/

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» National Environment Protection (Assessment of Site Contamination) Measure 1999;

» National Environment Protection (Diesel Vehicle Emissions) Measure 2001;

» National Environment Protection (Movement of Controlled Waste between States and Territories) Measure 1998;

» National Environment Protection (National Pollutant Inventory) Measure 1998;

» National Environment Protection (Used Packaging Materials) Measure 2011;

» Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations 2010;

» Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations 2010;

» Australian Energy Efficiency Opportunities Act, 2006;

» Australian National Greenhouse & Energy Reporting System Act 2007 (NGERS);

» Clean Energy Legislation (Carbon Tax Repeal) Act 2014 (superseding the Clean Energy Act 2011);

» Environment Protection and Biodiversity Conservation Act 1999;

» Hazardous Waste (Regulation of Exports and Imports) Act 1989.

† This list represents a sample of key regulatory mechanisms relevant to operations at NH, however is not exhaustive.

3.4.3.4 Voluntary Agreements and Other Requirements

Australian National Industrial Chemicals Notification and Assessment scheme (NICNAS);

International Zinc Association (IZA) Sustainability Charter;

International Lead Association ‘Lead Action 21’ Charter.

Implementation and Operation 3.5

3.5.1 Environmental Training

Competence, training and awareness are critical to the continued implementation of the EMS as the framework for continual improvement. While accepting that the highest responsibility for the EMS lies with the Environment Department, NH uses a number of tools to provide basic understanding to the broader workforce and key users. The following tools and forums are used to propagate awareness of environmental issues at NH and the EMS and its requirements, particularly with respect to legal obligations:

Site Induction – covers the general hazards associated with the plant, site policies, systems of work and other requirements. Environmentally it clarifies responsibilities with respect to environmental incident reporting, materials movement authority, hazardous chemicals, waste management, spill response and general care for the environment.

Departmental Inductions – personnel working in operating departments must also undertake a specific departmental induction, which provides more detailed information about hazards in that respective area of the plant, and also informs personnel of specific environmental aspects and impacts associated with that section of the process. A competency test is also conducted as part of these inductions.

Contractor Site Work Conditions – contractors who work on site must comply with documented standard site work conditions known as SC1. A section of these conditions deal with contractor’s obligations in regard to site environmental requirements such as the Environmental Policy, EMS, waste management, materials movement, emissions and incident reporting.

Emergency Response Officers (EROs) – undergo a specific environmental training program to enable them to appropriately respond to incidents that may have an environmental impact. ERO’s are also specifically trained to conduct environmental inspections for material leaving site under the Materials Movement Authorisation Procedure, and in the use of the gaseous sulphur dioxide (SO2) modelling tool to assist them in responding in the event of an SO2 or SO3 release.

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Training and Assessment Guides – a process by which employees / contractors are deemed competent in all aspects of the required duty of work through a combination of on-the-job training, verification of learning outcomes, completion of an assessment and demonstration of a sound understanding of operating procedures, that apply to their tasks.

Standard Operating Procedures – of most critical importance for current environmental performance is the inclusion of environmental aspects into Standard Operating Procedures (SOP) where impacts on the environment could result. This ensures that operators are aware of the critical operating parameters for the plant they are operating and the impact of operating outside of those parameters. This is most critical for Roast operations where loss of plant stability could result in SO2 emissions, and at the Effluent Treatment Plant where failure to follow SOPs could result in discharge of contaminated effluent to the Derwent estuary.

Job Safety and Environment Analysis – is used to identify the jobs steps, associated safety and environment hazards and mitigating controls for work where a SOP has not been developed and the task risk rating is greater than low or involves Defined Hazardous Work (DHW).

3.5.2 Communications

NH has established and implemented a number of internal environmental communication processes that have been employed across the site.

Site and corporate reporting procedures that have been established predominantly relate to reporting requirements. All of these procedures are retained on DMS and are maintained according to procedural stipulations – see Related Documents below.

Internal communications are carried out through the following means:

Daily Reporting – a RIMS report is circulated site wide to all NH email recipients, which covers the site’s safety and environmental performance for the last 24 hours.

Weekly Site Review – attended by managers and superintendents to share information relating to key performance indicators and environmental incidents.

Weekly Reporting – management team review of significant environmental incidents through the COO report.

Toolbox – a weekly newsletter which communicates general information relating to site activities at a departmental level. Environmental information and initiatives are communicated as needed.

Monthly Reporting – internal report to Zurich Head Office, NH managers and superintendents on the site’s environmental performance, legal obligations updates, and progress on environmental projects to address risk areas. NH also reports monthly to TasWater regarding trade waste.

Quarterly Compliance Reporting – General Manager reviews progress on the NH environmental objectives and targets.

NH has also established and implemented processes for external communication to key stakeholders including neighbours, community groups, regulatory agencies, and customers. These processes include:

Community Consultation Meetings – held 2 – 3 times a year and provide an opportunity for feedback and discussion of issues relating to the smelter’s operations;

Department of Primary Industries, Water and Environment (Tasmanian EPA) liaison meetings – to update on current business position and key projects, and to provide a forum for open discussion.

Community notices for specific issues – where a specific environmental issue warrants community notification NH produce and distribute this material as required;

Annual Environmental Review (AER) – NH produces an AER on an annual basis, and a Public Environment Report (PER) on a triennial basis. The AER and PER are submitted to the Tasmanian EPA and includes details of NH environmental objectives and targets and the site’s progress towards meeting objectives and targets and annual environmental performance; and

Nyrstar Group Sustainability Report – reports on annual sustainability performance for wholly Nyrstar owned mine and smelter sites. Group sustainability reporting is designed to align with the Global Reporting Initiative (GRI) Sustainability Reporting Guidelines to an intended level of Level B+ (GRI Report Application).

Community Consultation Meetings – held 2 – 3 times a year and provide an opportunity for feedback and discussion of issues relating to the smelter’s operations.

In addition, NH uses electronic media to communicate with the local community, adopting such tools as:

The NH website for general information including environmental reports and information relating to the site’s

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Major Hazard Facility status; and

Subscription email and SMS groups to provide newsletters and emergency response information.

A register of all community complaints received by the facility, along with follow-up investigations and actions, is maintained. Complaints received over the reporting period are summarised in Appendices

Appendix 1 – Community Complaints 2015 – 2017.

NH also engages in proactive community involvement activities such as annual Clean-up Australia Day, hosting a stall at the Moonah Taste of the World Festival and a community grants program that distributes grants of up to $3,000 to not for profit community groups.

Checking 3.6

3.6.1 Monitoring and Measurement

NH conducts extensive environmental monitoring and measurement to:

Ensure that smelting activities do not unduly impact upon the receiving environment and surrounding community;

Assess compliance against the site’s Environment Protection Notice (EPN);

Track performance against the site’s objectives and targets;

Monitor the effectiveness of control and remedial actions taken; and

Fulfil other legal requirements such as National Pollutant Inventory and Derwent Estuary Program partnership.

Environmental monitoring programs are currently in place for groundwater, stormwater, effluent discharge (both to the Derwent Estuary and trade waste), receiving waters and sediments, stacks, ambient air quality, noise, process and non-process waste, and biota.

All monitoring and measurement is undertaken in accordance with the site’s Standard Operating Procedures, designed to comply with Australian Standards.

Critical and non-critical monitoring equipment is calibrated and serviced in accordance with the manufacturers’ recommendations and relevant Australian Standards. The SAP electronic business system is used to manage the ongoing preventative and special maintenance requirements of critical environmental monitoring equipment. Recurring service requests are generated by this system to notify relevant personnel of calibration testing requirements. Specific controls are also invoked for items listed on the critical equipment / instrumentation register to ensure completion of calibration and maintenance.

3.6.2 ISO 14001 Certification

NH is audited triennially for recertification against ISO 14001:2004, ISO 9001:2008 and AS/NZS 4801:2001. The last recertification audit was held in March 2016, during the reporting period. In addition, two surveillance audits were conducted during the reporting period. All three audits were conducted by JAS/ANZ accredited auditing bodies to monitor and maintain the site’s Integrated Management System (IMS), incorporating the Environmental Management System (EMS), and its certification,

NH uses the outcomes for these reviews to operate within the broad intent of the standard and management systems in general – that is, to strive for continuous improvement.

All ‘areas of concern’ raised during audits are formally tracked in the RIMS system through the year to ensure that the any system deficiencies are rectified and opportunities for improvement are acted upon. Non-conformances with the standard or significant areas of concern are the subject of investigations to ensure that not only are deficiencies rectified, but the root cause of failure is understood and addressed.

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Table 3-3 Key findings of ISO 14001 2015 IMS Surveillance Audit

Strengths

Operational controls in the Effluent Treatment Plant.

Material Safety Data sheets have been amended and converted to Safety Data Sheets to meet the additional requirements identified in the Workplace Health and Safety Regulations and the Global Harmonised System codes.

Stormwater and groundwater management projects, and the continual isolation of the site from the estuary.

Areas of Concern - Corrective Action Required Comments/Actions on Area of Concern

The wharf project’s “Risk Assessment Matrix” contained inconsistent EMS evaluations for the same impacts e.g. waste management, sediment management.

The risk assessment matrix utilised was appropriate at the time it was used during the project. Risk ratings will vary as the risk assessment process is applied at initial concept/design phase (identifying relevant env risks at a high level) through to detailed JSEAs (considering the risk with controls that will be applied)

Not all of the risk / consequence assessments have been completed for the environmental risks that have been identified in the system e.g. RSK-44838.

All environment risks were looked at. Only 1 that did not have a PMC was identified, and this was addressed.

Environmental risk ratings in the JSEAs that are undertaken for specific projects / actions do not align with the site’s risk register.

In 2015 the site implemented a new risk framework to align with the Nyrstar corporate guidelines. The new framework required JSEA’s, pre-start books, RIMS risk assessments and other risk assessment tools to be updated. Whilst the changes were rolled out, there were some inconsistencies between the ratings using the different tools (i.e. differ risk ratings in RIMS as compared to the JSEAs).

IMO; MARPOL; IMSBC; IMDG; SOLAS requirements have not been identified in the Environment Essential Legal Obligations Database.

The environmental news alert service from Workplace Environment Australia Pty Ltd covers those requirements. Additionally, Environmental Essentials offers the following: MARPOL: Australia implements its international maritime obligations (such as under MARPOL) through Marine Orders. Environmentally relevant obligations from these orders are summarised in the EnviroLaw Marine category under Pollution from Ships (Commonwealth Waters). Updates to relevant Marine Orders are published in the corresponding EnviroLaw Update. IMO: Significant news about the International Maritime Organisation is included in our HSE Bulletin released monthly. However this does not capture all IMO news and EnviroEssentials recommend monitoring the IMO website and media centre. EnviroLaw will be adding a link to the IMO website in the EnviroLaw Marine category under Other Guidance Information for your assistance (this will be notified in the January 2016 EnviroLaw Updates). IMDG: Marine Order 41, which gives effect to IMDG, is not currently included in EnviroLaw as the Order gives effect to parts of SOLAS, which is safety-related. However, they will include an obligation (of a more environmental nature) from this in EnviroLaw which will include a link to the IMDG Code. These changes will also be notified in the January 2016 EnviroLaw Updates, and future changes to this obligation and the

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Code will also be notified in the corresponding EnviroLaw Update. IMSBC: This is not summarised as it is not currently within the scope of EnviroLaw, however a link to the IMO webpage for this Code will also be included in the January EnviroLaw update. SOLAS: This is not currently covered in EnviroLaw as it is largely safety-related.

No evidence of verification of effectiveness of the corrective actions that have been applied for the rectification of the issue in HEN 369083. The need for verification of effectiveness has not been identified for HEN 381217, but an Action Effectiveness Audit has been planned as one of the required corrective actions

HEN 369083 - the Anode Casting scrubber has not been upgraded but the change in process is still in place (as identified in the investigation). Verification of effectiveness of actions could be considered to be fulfilled through the 6 monthly stack emissions testing, and the anode casting scrubber returning results below the EPN 7043/3 limit. In addition, the plant engineer is looking into an upgrade in response to the impending change in emission limits (as per the proposed EPN7043/4). HEN 381217 - an action verification audit was completed on 16/06/2015.

Table 3-4 Key findings of ISO 14001 2016 IMS Re-certification Audit

Strengths

EPN reporting and environmental monitoring.

Televisions had been installed in some of the offices and department areas that were used to communicating safety, environmental and process updates and awareness to employees, contractors and visitors.

The new chemical risk assessment process prompts the assessment of legal compliance associated with dangerous goods storage and handling and requirements for conducting atmospheric monitoring.

A new process has been written for inducting new materials onto the site. The “New Raw Material Acceptance” prompts the review of legal, health and safety, equipment and Infrastructure requirements and the assessment of technical, packing and waste disposal considerations.

Development of a stabilisation processes for the Mercury Filter Cake.

Since the last SAI Global there has not been a recorded breach of the EPN licence.

There had been a significant improvement in the segregation and removal of stockpiles of waste from the site.

Waste maps identifying the waste stream and disposal route had been written for most of the departments.

Areas of Concern - Corrective Action Required Comments/Actions on Area of Concern

The corrective action processes and procedures have not been applied in accordance with the requirements of the standards and management systems.

SHEQ Internal / External Audit Procedure written and re-located to new SHEQ sub process HP-861-00006 Corrective / Preventative Action Procedure written HP-934-03361 Helpful Hint - Record Audit Finding into RIMS written HW-843-00038.

JSEAs and critical instrument risk categorisation processes have not been updated to reflect the requirements of the current procedures. Some departments are unable to extract the risk and impacts assessments from the RIMS database. Not all of the environmental aspects and OHS hazards e.g. eating and drinking in hazardous process areas, have been identified and assessed in accordance with the requirements of the new risk procedure.

JSEA and critical instrument risk categorisation updated to reflect current procedures. Due to a change in the RIMS risk system some of the risk information in RIMS had not been carried over from one system to the next. All site environmental risks were updated across 2015 and 2016. Direct links to the risks in RIMS have been added to the SHEQpoint page to improve the ease of access for all personnel.

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The system as not ensured that all obsolete copies of documents have been removed from use e.g. EPN, SDS, ERCs etc.

Obsolete copies of documents have been removed. The system is such that as a new version of a document is required/received, the old version is superseded.

The NH Hazardous Chemical Classification Procedure has not been approved but is in use.

Classification procedure has been incorporated into the process for requesting a new NH material SDS.

Table 3-5 Key findings of ISO 14001 2017 IMS Surveillance Audit

Strengths

A continual improvement attitude in all areas visited. Sighted some impressive improvement and mature initiatives in place in a number of QSE areas including innovative environmental and safety plans, advanced risk management methodology, well considered and enacted improvement plans.

Good level of attention towards forward planning

Good levels of practical communication and risk awareness being exercised

Areas of Concern - Corrective Action Required Comments/Actions on Area of Concern

No areas of concern identified Not applicable

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Environmental Compliance 3.7

The prevention of environmental incidents is promoted as an integral part of everyone’s work responsibility. When incidents do occur there is a procedure to investigate and implement corrective actions to reduce the risk of that particular incident occurring again.

The site uses a database referred to as ‘RIMS’ to track all environmental incidents impacting both on and off site, as well as near misses and community complaints, which ultimately provides data on areas where the operation can make environmental improvements. A daily incident report is generated from RIMS for all site personnel, which shows the details of reported incidents.

NH also uses an incident categorisation matrix (refer Table 3-6) to classify incidents depending on compliance or otherwise.

Incident investigations are completed for all environmental incidents with a consequence rating greater than 1 and for all ‘off-site impact’ incidents. Incident risk ratings are used to determine the level of investigation required. All incidents require the basic ‘root cause’ to be identified, but for more significant incidents a full investigation using the Incident Cause Analysis Methodology (ICAM) is required.

While we ultimately aim to be 100% compliant we recorded six separate regulatory non-compliances during the 2015–17 period; 3 incidents in 2016, and 3 in 2017. Figure 3-2 shows the number of non-compliances for the period, while details of these incidents, including corrective actions, are presented in Appendix 6.2.

No incident that constituted material environmental harm as defined by the Environmental Management & Pollution Control Act 1994 occurred during the reporting period.

Figure 3-2 Regulatory non-compliances 2015–17.

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Table 3-6 Nyrstar internal incident categorisation matrix

Category Description

Critical Environmental Incidents (CEI) Reportable to Corporate

An event which has caused material environmental damage measured as an incident with an actual environmental consequence rating of 3 or above.

High Potential Environmental Incident (HPEI) Reportable to Corporate

An event, or near miss which could have caused a critical environmental incident, measured as an incident or near miss with a potential environmental consequence rating of 3 or above.

Notifiable Non-Compliance A regulatory non-compliance for which notification to regulatory authority is legally required

Regulatory Non-Compliance Breach of a licence / consent condition or the requirements of national, regional or local regulations.

Community/environmental complaints made to site – Reportable to Corporate

Internal or external complaints attributable to site activities.

Contained in Department An incident fully contained on site whether by the effect of the effluent treatment system or by containment within the plant.

Contained on site Minor incident with little potential to impact outside the immediate work area i.e. acid leak to ground or emission of SO2 from foreshore stack >500ppm.

Off-site Impact An incident where site activities have impacted on the local environment i.e. elevated metal concentrations in outfall.

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Summary of Fulfilment of 2015–17 Environmental Objectives 3.8

NH had a number of environmental objectives for the 2015–17 period. These were reported in the 2014 Environmental Management Plan. An update against each objective is provided in Table 3-7.

Table 3-7 Progress against 2014–17 environmental objectives

Waste and By-products

2014–17 EMP Objectives 2015 - 2017 Progress

Increase waste segregation, drive recycling initiatives and reduce inputs to landfill through the site’s waste management contract.

Housekeeping was a major focus for the site in 2015 - 2016 with significant quantities of waste removed from the site. Where possible, these wastes are recycled, and a number of new recycling ventures were assessed. Unfortunately due to the nature of the wastes generated at the site, many of them are unsuitable for recycling and reuse.

Continued focus on departmental waste management initiatives and performance through departmental waste management groups.

NH Environment Department completed a waste mapping project with all departments in 2015. The purpose of the project was to assess and map all waste streams in the individual departments. The exercise has enabled the environment department to better understand the waste streams produced and be proactive in finding outlets for them. The departments now have a greater awareness of waste processes and consult with the environment department in the event of waste generation. Problematic wastes were encountered in 2017 which has resulted in the site finishing the reporting period with some large stockpiles of partially treated wastes on site.

Continue process of disposing of stabilised historical acid plant sludge via Roast department (under EPA approval).

This project has continued throughout the reporting period. New acid plant sludge was generated during the 2017 major turnaround project. This material was pH stabilised, and stockpiled for ongoing processing through the roasters.

Build on previous studies to determine options for the disposal / recycling / reuse of material stockpiles in the site’s quarry.

An Expression of Interest was put out to the market via Tenderlink in 2016 for the options assessment into recycling / disposal of the contaminated timber located in the quarry. Eleven submissions were received and reviewed.

Build on previous studies and investigate options for the disposal / processing of historic jarosite stockpiled at the Loogana–Inshallah area.

All work completed on this project pre-2015 was collated and summarised in a succinct memo that can be used in the future when the project next becomes a focus.

Monitoring data collected from the area continues to demonstrate that the land cell in which the jarosite is stockpiled within is robust. Contaminated leachate is being successfully captured and treated through the on-site effluent treatment plant.

Noise

2014–17 EMP Objectives 2015 - 2017 Progress

Undertake a triennial community noise survey, including monitoring from a residential location

This noise survey was completed in 2017. No significant changes in noise were identified when compared to the 2014 survey. A number of recommendations for improvement were put forward. These

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at East Risdon

Build on community noise survey and investigate nuisance noise sources across all departments.

have been used to formulate an action plan to improve those noises deemed to be of most nuisance to the surrounding community.

Develop departmental noise management plans based on findings from site wide surveys.

No work was completed on this project during the reporting period. This work will form part of the 2018 – 2021 environmental objectives for the site (refer Table 3-2.

Develop nuisance noise source database to assist in incident investigations and continuous improvement activities.

Data regarding nuisance noise is reported through the RIMS incident reporting system.

Land Use and Aesthetics (Smelter in the Park)

2014–17 EMP Objectives 2015 - 2017 Progress

Continued implementation of the Revegetation Plan (Smelter in the Park).

In 2016 minor beautification works were conducted around the entrance to site. In 2017 a steep slope on the entrance to the site was revegetated, with works including removal of contaminated soils, importation of clean topsoil and mulch, planting and irrigation.

Develop and implement site wide weed management strategy to prioritise weed removal effort.

A Weed Management Plan was developed for the site, with weeds in revegetated areas prioritised for removal. Spraying of weeds in priority areas was completed in November 2016 and again in 2017. In 2017, a large gorse infestation was also removed.

Monitor ongoing foreshore erosion issue and develop protection projects as required.

The foreshore area is monitored on a six monthly basis. Rectification works were completed in the area of the main wharf in 2016.

Review and implement ‘site pride’ days focusing on the clean-up of departmental laydown areas (removal of redundant equipment etc).

Housekeeping has been a major focus for the site in 2015 - 2017, with significant quantities of waste removed from the site. This has largely been achieved through specific campaigns conducted within the departments, and regular scheduled clean up events.

Continued implementation of the Demolition Strategy.

No work was completed on this project during the reporting period.

Hazardous Chemicals

2014–17 EMP Objectives 2015 - 2017 Progress

Develop and deliver education program on hazardous chemicals (site systems and procedures).

The site shifted across to the Global Harmonisation System for classifying and labelling chemicals in 2017. Information was sent out to site, and disseminated during pre-starts. The system has a process for approving new chemicals for site, and maintains a chemical database. This process is understood and followed.

In conjunction with the Global Harmonisation System (GHS) Project, develop a materials stewardship database.

A classification review of NH Safety Data Sheets (SDS) was completed during 2016 - 2017. Updated SDSs are available through the sites ChemAlert system.

Energy Use and Greenhouse

2014–17 EMP Objectives 2015 - 2017 Progress

Continue to identify and pursue energy efficiency opportunities.

Feasibility studies were conducted in 2015 to assess the option of an 8.5 mW steam turbine. The project was fully assessed in 2016,

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however found not to be viable for the site at this time.

Off Site Contamination

2014–17 EMP Objectives 2015 - 2017 Progress

Fulfil commitments made under the 2008–09 Community Soil Review to ensure communications continue.

NH continues to maintain its community communication strategy.

Soil and Groundwater

2014–17 EMP Objectives 2015 - 2017 Progress

Completion of the ‘Old Acid Plant’ Groundwater Remediation Project.

Completed and commissioned in August 2015.

Continued implementation of the site’s Groundwater Management Strategy, including:

Intensive investigation in areas identified within the strategy.

Development and installation of targeted remediation system based on intensive monitoring data.

Works continued throughout 2015 - 17 and included:

Completion of the Electrolysis cell house basement sealing project.

Improvements to the existing monitoring bore network.

Review and amendment of the NH groundwater monitoring program.

Additional aquifer characterisation works to further understand the TGS, OL and wharf foreshore areas, and update of the groundwater model.

A peer review of proposed remediation options by CSIRO.

Completion of further groundwater investigation works to address data gaps highlighted by CSIRO, focussing on the deeper aquifer under the site.

Commencement of the detailed design of the next groundwater extraction system.

Undertake biennial site wide Groundwater Quality Program in 2015 and 2017.

2015 and 2017 program completed.

Water

2014–17 EMP Objectives 2015 - 2017 Progress

Continue implementation of the Integrated Water Management Project to improve stormwater detention infrastructure and recycling opportunities.

Construction of the Reverse Osmosis plant was completed in 2015. A pilot trial was conducted in February 2016, and the plant commenced full operations in April 2016.

Investigate feasibility of diverting NH car park catchment out of the main site stormwater system.

No work was completed on this project during the reporting period. Rain gardens had been previously installed which do catch a significant volume of runoff from the carpark.

Continue to work with GCC to source a recycled stormwater resource for use on site.

NH worked with GCC throughout the reporting period to increase the volume of recycled stormwater sent to NH from the GCC systems.

Complete the design and construction of new stormwater capture infrastructure across the wharf under the Wharf Structural Recovery Project.

Progress has continued on this project, with expected completion in 2018.

Drain instrumentation review, preventative No work was completed on this project during the reporting period.

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maintenance re-establishment, alarms and protocols.

Investigate feasibility of a site wide drain / sump inspection campaign and develop prioritised improvement program.

An increase in cadmium concentrations in groundwater collected from beneath the Purification Plant has resulted in a capital project to repair the secondary purification bunds being planned for 2018.

Air Emissions

2014–17 EMP Objectives 2015 - 2017 Progress

Drive continuous improvement opportunities identified during the site wide gas cleaning systems review.

Design works were conducted for improvements to the Roaster Baghouse, the Copper Sulphate Vent Stack, and the Anode Casting Scrubber Stack with improvement works in the

Complete SO2 dispersion modelling and develop / amend emergency response guidelines based on results.

This project was completed in 2015.

Continue implementation of the Dust Management Plan via the Dust Excellence Group.

Dust focus groups operate on the site throughout 2015 - 2017. Works completed during the reporting period has included application of dust suppressant, increased use of the sprinkler systems, and a regular inspection program in the wharf area. Site waste materials have been put to use in enclosing some dusty areas. For example, the #6 Roaster basement was enclosed using waste rubber. Other repairs and improvements to infrastructure were also instigated by these groups.

Progressively upgrade community SO2 monitors.

A new SO2 monitor was purchased and installed in 2017.

Review of ship loading / unloading procedures to implement opportunities for improvement.

Collaboration with Impact Fertilisers was undertaken in order to identify opportunities to improve Impact Fertilisers shipping infrastructure used on the Nyrstar Wharf. Several improvements were subsequently implemented, including automation of some parts of the loading infrastructure in order to better control the material loaded into the ship.

Stakeholder Engagement

2014–17 EMP Objectives 2015 - 2017 Progress

Meet all self-imposed obligations for community engagement, including community meetings and community newsletters.

NH continues to maintain its community communication strategy.

Undertake community feedback survey. No work was completed on this project during the reporting period.

Environmental Risk

2014–17 EMP Objectives 2015 - 2017 Progress

Review and update the site’s risk register by department.

All site environmental risks have been reviewed and updated.

Develop management plan / controls for critical environmental risks based on the environmental risk review.

No work was completed on this project during the reporting period.

Undertake departmental environmental audits. Audits were completed in 2016 and 2017 in a selection of departments.

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Undertake environmental audits on all major projects.

Environmental audits were undertaken on major projects as required.

Environmental Management

2014–17 EMP Objectives 2015 - 2017 Progress

Comple