SUBTERRANEAN FAUNA MANAGEMENT PLAN 1 ......1 The Subterranean Fauna Management Plan is a subset of...

Extension to the Wiluna Uranium Project

Public Environmental Review Page 3-1

SUBTERRANEAN FAUNA MANAGEMENT PLAN1

1 Environmental Factor

To maintain stygofauna and troglofauna representation, diversity, viability and ecological function at

the species, population and assemblage level.

2 Relevant Legislation and Standards

Subterranean fauna are protected under the following State and Federal legislation:

Wildlife Conservation Act 1950 (WC Act) (WA);

Environmental Protection Act 1986 (EP Act) (WA); and

The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) (Cwlth).

The Environmental Protection Authority of Western Australia (EPA) has developed two key documents

to guide the assessment process for activities that could potentially impact on subterranean fauna:

Guidance Statement No. 54a Sampling Methods and Survey Considerations for Subterranean

Fauna in Western Australia (Technical Appendix to Guidance Statement 54) (2007); and

Environmental Assessment Guideline (EAG) 12 for consideration of Subterranean Fauna in

Environmental Impact Assessment in Western Australia (2013).

These documents provide advice to proponents and the public on the EPA’s minimum requirements

for environmental impact assessment (EIA) and management of subterranean fauna.

3 Project Background

Toro was granted approval in October 2012 by the Western Australian Minister for Environment,

to develop and operate the Wiluna Uranium Project (the Project), located near Wiluna

(Ministerial Statement No: 913). In April 2013, Federal approval was also granted by the Federal

Minister for Sustainability, Environment, Water, Population and Communities (EBBC 2009/5174).

The approved Project consisted of two uranium deposits, Centipede and Lake Way, and the West

Creek borefield (Figure 1). As part of the approval, Ministerial Statement No. 913 imposed two

1 The Subterranean Fauna Management Plan is a subset of the Environmental Management Plan



conditions related to stygofauna: Condition 7 Management of Groundwater Drawdown Impacts

on stygofauna, Tecticornia and inferred groundwater dependent vegetation located within the

groundwater drawdown (0.5 mRL) area); and Condition 11 The assessment and management of

potential impacts to stygofauna (Appendix A).

Since both State and Federal approvals were granted for the Project, Toro acquired two additional

deposits, Millipede and Lake Maitland, and proposes to integrate both deposits into an extended

Wiluna Uranium Project (Environmental Protection Authority 2014) (Figure 1). The Millipede

deposit is directly adjacent to the previously approved Centipede deposit that is associated with

the Hinkler Well calcrete on the western margin of the Lake Way playa. The Lake Maitland

deposit is approximately 105 km southeast of the Millipede deposit and associated with the

Barwidgee calcrete system on the north western margin of Lake Maitland playa.

The Barwidgee, Hinkler Well, Lake Violet, and Uramurdah calcrete systems that are associated with

the Project areas are known to host diverse stygofauna and troglofauna assemblages (Figures 2 to 5).

The stygofauna assemblages associated with each of the calcrete systems are listed as Priority

Ecological Communities (PECs). These PECs are recognised due to the assemblages of stygofauna

invertebrates recorded from the groundwater within each calcrete system. The areas are classified as

a priority 1, under the Western Australian Wildlife Conservation Act (1950), due to the ‘poorly known

ecological communities’ that are ‘known from very few occurrences with a very restricted distribution’.

4 Scope and Objectives

This Subterranean Fauna Management Plan (SFMP) outlines the potential impacts on subterranean

fauna posed by the proposed development of the Millipede and Lake Maitland deposit areas and

management measures to manage and minimise any such impacts. The SFMP will aim to align and

integrate with Ministerial Conditions 7 and 11, where applicable.



Figure 1: Wiluna Uranium Project area locations relative to neighbouring calcrete systems and associated stygofauna PECs.


Public Environmental Review -4

Figure 2: Overview of stygofauna sample locations for Lake Way associated Project areas.



Figure 3: Overview of troglofauna sample locations for Lake Way associated Project areas.



Figure 4: Overview of stygofauna sample locations for Lake Maitland associated Project areas.



Figure 5: Overview of troglofauna sample locations for Lake Maitland associated Project areas.



5 Subterranean Fauna: General Information

5.1 Definition

The term ‘subterranean fauna’ refers to both terrestrial (troglofauna) and aquatic (stygofauna)

organisms, predominantly comprised of invertebrates that occur in underground environments.

Stygofauna (groundwater fauna) are confined to groundwater aquifers. Troglofauna (air-breathing

subterranean fauna) occur in non-saturated subterranean environments above groundwater

aquifers. Both stygofauna and troglofauna are regarded as short range endemic species (SREs) as

they are often obligate inhabitants of subterranean environments and therefore often have

restricted distributions. Short range endemic species are defined as species that have geographically

restricted ranges of less than 10,000 km2 and are considered more vulnerable to extinction because

of their limited distribution range (Harvey et al. 2011, Harvey 2002).

5.2 Prospective Habitat

The prospective habitat for subterranean fauna is dependent on the presence of underground voids

of suitable size and connectivity to satisfy biological requirements. Subterranean fauna were

previously believed to be mostly restricted to karst landscapes (limestone or calcrete dominated

systems) that are considered to provide optimal habitat conditions. In more recent times

subterranean fauna have been found to occur in various types of non-karstic geologies and aquifer

systems that exhibit suitable voids for colonisation. Stygofauna are now known to occur in non-

karstic aquifers in course alluvial sediments, fractured rock, pisolites and thin rocky regoliths.

Likewise, recent surveys have identified troglofauna from non-karstic geologies such as vuggy pisolite

ore beds, and fractured and weathered rock formations in the Pilbara and Yilgarn regions. A

relatively high humidity is also considered to be a key requirement for troglofauna existence.

The extent of subterranean habitat present is dependent on the interconnection of sub-surface

crevices, fractures and voids, within suitable geological units and aquifer systems. Hydrogeological

studies can give an indication of the extent of stygofauna habitat present using groundwater flow or

yield characteristics (aquifer parameters). For troglofauna, knowledge of the geological facies

present can also give an indication of the extent of habitat.

5.3 Potential Impacts

The main direct potential impacts on subterranean fauna generally associated with mining activities

are:

removal of habitat through mining excavation of proposed pit areas; and



drying out of habitat through the lowering of the groundwater table either associated with

the dewatering of mine pits, or groundwater abstraction from proposed production

borefields.

The removal of habitat through mining excavation poses the greater risk to the conservation of

stygofauna and troglofauna species relative to the lowering of the groundwater table only. Mining

excavation will remove potential habitat for good with no prospect for rehabilitation. However,

groundwater drawdowns are considered to be more relatively short term impacts with natural

restoration of groundwater levels post cessation of mining activities.

Groundwater drawdowns are considered to have greater impacts on stygofauna compared to

troglofauna because lowering of the groundwater table can directly reduce the extent of saturated

stygofauna habitat available. In the case of troglofauna, their reliance on stable and relatively high

humid conditions can make them susceptible to artificially changing water tables, particularly if the

lowering of the water table is sufficient to dry out the inhabited zone which could have significant

impacts on any troglofauna species present. However, impacts would be considered negligible if the

proposed groundwater drawdown associated with proposed mining activities were not of a

significant magnitude to deprive the inhabited subterranean environments of a sufficiently high

relative humidity to render them uninhabitable. In addition, the lowering of the water table could

mean that portions of saturated geology containing suitable habitable voids will become unsaturated

and potentially available for colonisation.

Potential indirect impacts posed by proposed mining developments that could impact on aquifers

inhabited by stygofauna include:

fuel spills; and

increase in sediment load in run-off from mining activities that could reduce surface-

subsurface water exchange during flow periods (e.g., lessen input of resources) and alter

groundwater chemistry.

6 Project Area Subterranean Fauna Values

6.1 Millipede/Centipede Project Area

For the environmental impact assessment (EIA) of the proposed Millipede/Centipede

development, 106 stygofauna and 151 troglofauna samples were collected from the Hinkler Well

calcrete system (Figures 6 and 7) (MWH 2015, Outback Ecology 2011, 2012c). The development



of the Centipede deposit has been previously approved (refer section 4.1) with Ministerial

Conditions 7 and 11 imposed. The survey effort conducted recorded 32 stygofauna and nine

troglofauna species from the Hinkler Well calcrete system. An additional four stygofauna species

are known from published records to occur in the Hinkler Well calcrete system, with distributions

extending to the non-impact area of the aquifer system, west of the Goldfields Highway. This

brings the known species richness of the Hinkler Well calcrete stygofauna PEC to 36 species in

total.

6.2 Lake Maitland Project Area

For the assessment of the proposed Lake Maitland development, 165 stygofauna and 110

troglofauna samples were collected (Figures 8 and 9) (Outback Ecology 2012a, b). The survey

effort conducted recorded 27 stygofauna and nine troglofauna species from the Barwidgee

calcrete system. An additional stygofauna species is known from published records to occur in

the Barwidgee calcrete system, with the recorded location occurring in the non-impact area of

the aquifer system, northwest of Little Well. This brings the known species richness of the

Barwidgee calcrete stygofauna PEC to 28 species in total.

6.3 Lake Way and West Creek Borefield Project Areas

The proposed Lake Way deposit and West Creek Borefield developments have been previously

approved (refer section 4.1) with Ministerial Conditions 7 and 11 imposed. For the assessment of

these approved developments, 118 stygofauna and 131 troglofauna samples were collected

(Figures 10 and 11). The assessments, including published records, recorded 36 stygofauna and

nine troglofauna species from the Lake Way project survey area associated with the Uramurdah

calcrete system; and 35 stygofauna and four troglofauna species from the West Creek Borefield

project survey area associated with the Lake Violet calcrete system.



Figure 6: Millipede/Centipede stygofauna sampling locations.



Figure 7: Millipede/Centipede troglofauna sampling locations.



Figure 8: Lake Maitland stygofauna sampling locations.



Figure 9: Lake Maitland troglofauna sampling locations.



Figure 10: Lake Way and West Creek Borefield stygofauna sampling locations.



Figure 11: Lake Way and West Creek Borefield troglofauna sampling locations.


Public Environmental Review

7 Roles and Responsibilities

The roles and responsibilities for subterranean fauna management by Toro are outlined in Table 1. .

Table 1: Roles and Responsibilities

Position Responsibility

Environmental Manager Implementation of this management plan

Review the plan and make changes as required

Environmental Superintendent Ensure staff are aware of their obligations under this plan

Undertake stygofauna and troglofauna monitoring as required

Ensure dewatering monitoring is occurring

Maintain site records of all monitoring

Operations Managers and Site Supervisors

Ensure the plan is being adhered to on site

Participate in the management of this plan as required

Staff, Contractors and Visitors Minimise impacts on the environment

Report all incidents within 24 hours

Clean up all spills

8 Environmental Management

8.1 Project Impacts

Impacts posed by the development of the proposed Millipede/Centipede and Lake Maitland Project

areas can be categorised as being either direct or indirect. Direct impacts, in order of severity of impact

posed, may include:

Mine pit excavation;

Groundwater abstraction;

Dewatering during mining operations;

Contamination of groundwater from spills and leaks; and

Changes to groundwater chemistry.

Indirect impacts may include:

Changes in radionuclide concentrations in the environment above normal background levels;

and

Changes in groundwater flows due to altered sub-surface hydrology during mining.



8.2 Mine Pit Excavation

Subterranean fauna habitat that occurs within the proposed Millipede and Lake Maitland mine pit

boundaries will be lost with mining excavation and will represent a residual impact. Avoidance and

minimisation measures to reduce the impact of mining excavation on components of the

subterranean fauna assemblage recorded are limited. However, proposed mining areas are well

defined and the use of efficient surface mining methods will ensure only target areas will be

disturbed, thereby limiting the area of impact.

8.3 Dewatering

The Millipede and Lake Maitland deposits proposed to be mined require dewatering, the extent of

which is based on the size of the area to be mined, but at the ore bodies themselves local

dewatering could lower the water table by up to 10 m bSWL.

Modelling (RPS Aquaterra, 2010a) was undertaken to ascertain predicted total dewatering volumes

during the life of mine and simulate the use of water barriers to assess their impacts on dewatering.

Prediction Run 1 simulated the mining, without the use of cut-off walls to help decrease inflow to

the open pits, whilst Prediction Run 2 included the simulation of cut-off walls installed around and

within the mine area to help control groundwater inflows (RPS Aquaterra, 2010b). Field trials

undertaken by Toro (2011) and Golder Associates (2011) have confirmed that the barriers have a

similar effect in the field as in the model and can be used to limit water ingress. Field studies have

shown that this ingress may be reduced by up to 80% (Toro, 2011).

At the Lake Maitland borefield, modelling of the drawdown was based upon expected water

demands without the use of barriers. The modelling demonstrated that large drawdowns are

confined to the immediate vicinity of the pumping areas (RPS Aquaterra, 2010a).

8.4 Tailings Deposition

At Millipede, mined pit voids would be back filled with mine overburden as well as used for storage

of tailings created during the processing of the ore. The tailings would be highly alkaline and, in

conjunction with worked mine overburden, would not be considered to provide suitable substrate

for stygofauna or troglofauna habitat.

Toro has undertaken modelling to investigate how uranium in the groundwaters would increase due

to seepage from the Tailings Storage Facility (TSF). The model found that, if unchecked, seepage

could increase groundwater uranium concentrations significantly. Interactions between the tailings

liquids and the clay barrier that would line the pits was input to the model, along with dilution and



reduction due to lake sediments (as demonstrated by Toro during recent drilling). With these inputs

it was found that seepage from the TSF would not lead to significant impacts to local groundwaters

(Prommer et al, 2015).

8.5 Groundwater Reinjection

The Project proposes to reinject mine pit water at the Lake Maitland deposit as a means of managing

potential excess water during operational periods or as a result of significant rainfall events. Water

from the Lake Maitland pit area would be generally hypersaline and not suitable for Project use.

Reinjection of this hypersaline water into the fresh water systems of the Barwidgee calcrete can

alter the salinity of the region and lead to widespread and potentially significant subterranean fauna

habitat loss in the Barwidgee calcrete system.

Toro has identified a preferred borefield to the south of the Lake Maitland deposit in a region where

the groundwater is saline (>14,000 mg/L salinity) (Pennington Scott, 2015). This region is separated

from the Barwidgee Calcrete by some 6km and groundwater flows within the nominal borefield

region flow away from the Barwidgee calcrete and back towards the lake (Pennington Scott, 2015).

For this reason, it is considered unlikely that the reinjection of groundwater will pose a long-term

threat to local subterranean fauna populations.

8.6 Spills and Localised Contamination

Spills or leaks from hydrocarbons or chemicals in the plant area, or from any vehicles or equipment

on the mine site may contaminate soil and groundwater affecting subterranean fauna communities.

On-site chemicals and hydrocarbons would be stored in bunded containers which would be stored in

areas away from drainage lines. Storage vessels and pipelines would be fitted with detection systems

to promptly inform Toro of any leaks. In order for a leak to significantly impact stygofauna species, it

would need to be a prolonged discharge or a catastrophic failure. Given the unlikelihood of such

events occurring due to engineered storage (e.g. double lined/bunded fuel cells) and standard

operating procedures, hydrocarbon and chemical spills would be identified and cleaned up and

remediated in a timely manner. It is considered that groundwater contamination in this area would

be a minor environmental impact.



9 Environmental Objectives and Performance Indicators

The environmental objectives and performance indicators for management of impacts on

subterranean fauna are outlined in Table 2.

Table 2: Environmental Objectives and Performance Indicators

Environmental Objective Performance Indicator

Maintain the abundance and diversity of subterranean fauna species occurring within the Project area

Regular monitoring of subterranean fauna assemblages show that no long-term changes in species richness and assemblage composition is occurring

Avoid or minimise adverse impacts on subterranean fauna assemblages

Groundwater drawdown levels monitoring saturated extent of aquifer shows proposed modelled drawdown extents (vertical and lateral) are not exceeded

Groundwater quality parameters monitored and show that no change in groundwater chemistry due to abstraction or reinjection occurs

Groundwater SWL recovery occurs at or faster than modelled recovery

Subterranean fauna surveys show no decline in species richness and assemblage composition

Ensure no long-term or legacy impacts on subterranean fauna populations

Post-closure monitoring shows the leaching from tailings is not occurring

Contaminant transport monitoring is at or below modelled levels

Subterranean fauna surveys show no decline in species richness and assemblage composition



10 Environmental Aspects and Management Strategies

The environmental aspects and management strategies are presented in Table 3.

Table 3: Environmental Aspects and Management Strategies

Environmental Aspect Management Strategy

Pit excavation Pit outline identified early and surveyed for subterranean fauna

Ongoing periodic sampling of bores within the proposed mine footprint

Water barriers installed to prevent lateral flows of water and reduce the need for dewatering

Dewatering and Reinjection

Ongoing groundwater chemistry monitoring to ensure no changes to groundwater composition are occurring

Monitoring of drawdown rates to ensure that drawdown is occurring as modelled

Groundwater abstraction rates kept within approved Project limits

Sampling of established subterranean fauna bores to ensure assemblages are persisting

Regular monitoring of reinjection borefield for impacts such as mounding

Tailings Deposition Mine voids to be lined with compacted clay prior to tailings deposition

Water barriers installed during mining to prevent water ingress left in place, to prevent tailings egress

Downstream monitoring to commence after tailings cells are backfilled to identify any leakage of contaminants specifically uranium and other radionuclides

Spills and Contamination Spills to be cleaned up immediately

Storage of fuels and reagents to be in bunded areas to prevent contamination of the environment

Regular monitoring of local groundwaters for contaminants to identify whether fuels or reagents are making their way into the environment

Changes in Water Quality

Continued monitoring of local and regional bores to determine whether groundwater chemistry is being adversely impacted by mining activities

Monitoring to include radionuclide concentrations to ensure that they remain stable



10.1 Monitoring

Subterranean fauna monitoring is outlined in Table 4. The monitoring program would involve the

establishment of monitoring bores for each Project area designed to facilitate the survey of

stygofauna and troglofauna, as well as groundwater parameters from within impact areas and from

control bores outside of impact areas. Initially, it would be recommended that monitoring would

consist of four sample rounds per year (quarterly), with the seasonal timing of each sample round

kept consistent between each monitoring year. Complementing the sample rounds for

subterranean fauna would be the more frequent collection (monthly) of groundwater parameters

(e.g. SWL, salinity) undertaken by Toro onsite personnel that would be assessed to ensure

groundwater drawdowns and quality are not exceeding (or approaching exceedance) with modelled

parameters. If the first three to four years of quarterly monitoring indicate that subterranean fauna

assemblages are stable, and monitoring of groundwater levels and physicochemical parameters

continues monthly, then surveys may be reduced to biannually or annually, following consultation

with, and approval from DPAW.

Table 4: Subterranean Fauna Monitoring

Aspect Frequency

Subterranean Fauna Populations

Quarterly surveys of subterranean fauna

Surveys may become biannual if assemblages are shown to be stable

Pit Dewatering Volume Pumps to be fitted with meters to monitor volumes

Data to be collected monthly

Drawdown Level loggers will be placed into monitoring bores to continually monitor drawdown around mine pits (Lake Way, Millipede/Centipede, and the borefields

Pumps at the borefields to be fitted with meters and abstraction volumes are not to exceed section 5C limits

Data to be recovered monthly

Reinjection Volume Reinjection pumps to be fitted with meters to monitor volumes

Volumes to be collected monthly

Groundwater Quality Monthly analysis of basic water chemistry including EC, salinity, dissolved metals

Formulation of groundwater parameter trigger values for each Project area

Quarterly analysis of radionuclides

Annual analysis of organic compounds and potential contaminants

Tailings Storage Facility Integrity

Constant monitoring using real time data loggers that detect changes in EC, uranium concentration and other radionuclide concentrations.



10.2 Trigger Levels

The following trigger levels would be established to inform Toro when contingency measures to

manage subterranean fauna are to be implemented (Table 5).

Table 5: Stygofauna Impacts Trigger Levels

Impact Trigger Level

Excess drawdown Level logger devices show that drawdown is occurring faster than modelled predictions

Monitoring bores SWL show that modelled lateral extent of groundwater 0.5 m bSWL drawdown is exceeded, or likely to be exceeded

Change in subterranean fauna community composition

The assessment of monitoring survey results find a significant reduction in the diversity of subterranean fauna assemblages compared to comparable seasonal baseline results

Changes in groundwater chemistry

Where groundwater monitoring finds that concentration of any analyte is more than two standard deviations from seasonally adjusted established trigger value means contingency action would be taken.

Reinjection is planned to occur inside the 14,000 mg/L salinity zone. If salinities in the zones that are less than 14,000 mg/L are found to increase by more than two standard deviations from seasonally adjusted averages, contingency actions would be taken.

10.3 Contingencies

If a significant change is recorded that can be attributed to the Project, the following would occur:

If there is a saline water/oil/chemical spill, operations in that area would cease until the spill was

halted and cleaned up (including removal of contaminated soil). Depending on the extent of

contamination a survey to ensure all contaminated material has been removed, may be

required.

In the event the subterranean fauna survey identifies a species that may be localised to the

Project area, further sampling outside the Project area may be undertaken to provide more

certainty about the range of the species. Conservation measures may be taken in consultation

with the Department of Environment Regulation and the WA Museum,

If groundwater drawdown is occurring at a faster rate than modelled, and /or extending laterally

or vertically in exceedance of modelled drawdown contours, then the mining method would be

examined to determine if smaller mining cells can be implemented to reduce drawdown.



If seepage in the TSF is identified, work would commence immediately on repairing any breach

and further investigations will take place to find a permanent solution.

Where salinity in the fresh/brine water systems was found to be increasing, the borefield

configuration would be changed with those bores closest to the areas of salinity increase turned

off to give groundwater time to recover.

If there was a prolonged drought, then the rate of abstraction would be monitored to assess

rates of change and dewatering activities may be altered to minimise impacts on subterranean

fauna communities.

10.4 Interpretation and Reporting

Data would be analysed as it is gathered and aim to identify any trends and patterns including;

Any spills;

Any breaches of the TSF wall;

The overall groundwater chemistry, including establishment and modification of trigger values;

and

Groundwater abstraction rates.

All data would be included in Toro’s Annual Environment Report and made publicly available.

10.5 Review and Revision

A more comprehensive SFMP would be designed in consultation with DPAW for approval prior to

groundwater dewatering occurring at any of the proposed Project areas. The SFMP would be

actively managed with annual reviews occurring after the analysis of the monitoring data, and any

actions taken to modify the plan.

References

Environmental Protection Authority. (2007) Guidance for the assessment of environmental factors (in accordance with the Environmental Protection Act 1986). Sampling methods and considerations for subterranean fauna in Western Australia - No. 54a. Technical appendix to guidance statement 54. Environmental Protection Authority, Western Australia.

Environmental Protection Authority. (2013) Environmental Assessment Guideline (EAG) 12 for consideration of subterranean fauna in environmental impact assessment in Western Australia.

Environmental Protection Authority. (2014) Extension to the Wiluna Uranium Project (CMS 14025 Assessment No: 2002 Environmental Scoping Document September 2014.

Harvey, M. E., Rix, M. G., Volker, W. F., Hamilton, Z. R., Johnson, M. S., Teale, R. J., Humphreys, G. and Humphreys, W. F. (2011) Protecting the innocent: studying short-range endemic taxa enhances conservation outcomes. Invertebrate Systematics 25: 1-10.

Harvey, M. S. (2002) Short-range endemism among the Australian fauna: some examples from non-marine environments. Invertebrate Systematics 16: 555-570.



MWH. (2015) Wiluna Uranium Project: Millipede Targeted Subterranean Fauna Assessment Report prepared for Toro Energy Ltd.

Outback Ecology. (2011) Wiluna Uranium Project Subterranean Fauna Assessment, March 2011. Prepared for Toro Energy Ltd, Perth, Western Australia.

Outback Ecology. (2012a) Lake Maitland Uranium Project Level 2 Stygofauna Assessment Prepared for Mega Lake Maitland Pty Ltd, Perth, Western Australia.

Outback Ecology. (2012b) Lake Maitland Uranium Project Level 2 Troglofauna Assessment Prepared for Mega Lake Maitland Pty Ltd, Perth, Western Australia.

Outback Ecology. (2012c) Wiluna Uranium Project Stygofauna Assessment Prepared for Toro Energy Ltd, Perth, Western Australia.



Appendix A: Ministerial Conditions 7 and 11 (Ministerial Statement 913)

7 Groundwater Drawdown

Management of Groundwater Drawdown Impacts on stygofauna, Tecticornia and inferred groundwater dependent vegetation located within the groundwater drawdown (0.5 mRL) area.

7-1 Prior to groundwater abstraction for dewatering, unless otherwise approved by the CEO, the proponent shall prepare a Groundwater Drawdown Monitoring and Management Plan for approval by the CEO to limit potential impacts on stygofauna, Tecticornia dominated vegetation and inferred groundwater dependent vegetation through the design and implementation of a suitable groundwater barrier system around the Project mining areas. The Groundwater Drawdown Monitoring and Management Plan shall include:

1. development of trigger levels for groundwater drawdown levels;

2. design and implementation details of a barrier system to control groundwater drawdown so that the trigger levels are not exceeded; and

3. implementation of the outcomes of the Groundwater Dependent Vegetation Research Plan required by Condition 6-6.

7-2 Prior to groundwater abstraction for dewatering, the proponent shall implement the approved Groundwater Drawdown Monitoring and Management Plan required by condition 7-1 and any subsequent approved revisions, until advised by the CEO that implementation of the Groundwater Drawdown Monitoring and Management Plan can cease.

7-3 Should the results of monitoring from the implementation of the Groundwater Drawdown Monitoring and Management Plan required by condition 7-1 show that trigger levels identified in condition 7-1(1) have been reached or exceeded, the proponent shall take immediate corrective actions to protect Tecticornia dominated vegetation and inferred groundwater dependent vegetation in



response to monitoring results, and shall provide a report to the CEO within 21 days of the trigger levels being reached or exceeded which:

1. describes the event resulting in a trigger level being reached or exceeded;

2. provides information which allows determination of the likely root cause of the trigger levels being reached or exceeded; and

3. proposes actions and associated timelines to remediate the cause of the trigger values becoming reached or exceeded.

7-4 Should the trigger levels being reached or exceeded identified in condition 7-2 be determined by the CEO to be caused by activities undertaken in implementing the proposal, the proponent shall, on approval by the CEO, implement the actions identified in condition 7-3(3) until the CEO determines that the remedial actions can cease.

11 Fauna - Stygofauna

The assessment and management of potential impacts to stygofauna.

11-1 Prior to groundwater abstraction for dewatering, unless otherwise approved by the CEO, the proponent shall prepare a Stygofauna Monitoring Plan for approval by the CEO on advice of the DEC. The Stygofauna Monitoring Plan shall include:

1. a survey regime for stygofauna in the Hinkler Well, Uramurdah and Lake Violet calcretes both within and outside the area of impact of the proposal; and

2. a monitoring regime for water quality and quantity in the Hinkler Well, Uramurdah and Lake Violet calcretes both within and outside the area of impact of the proposal.

11-2 Prior to groundwater abstraction for dewatering, unless otherwise approved by the CEO, the proponent shall implement the approved Stygofauna Monitoring Plan required by condition 11-1 and any subsequent approved revisions until advised by the CEO that implementation of the Stygofauna Monitoring Plan can cease.

11-3 Should results of monitoring from the implementation of the Stygofauna Monitoring Plan required by condition 11-1 show a significant change in groundwater quality and quantity not identified through the implementation of condition 7-1, the proponent shall provide a report to the CEO within 21 days which:

1. describes the event resulting in a significant change; and

2. provides information which allows determination of the likely cause of the significant change;

3. proposes actions and associated timelines to remediate the significant change.

11-4 Should the significant change in groundwater quality and quantity be determined by the CEO to be caused by activities undertaken in implementing the proposal, the proponent shall, on approval by the CEO, implement the actions identified in condition 11-3(3)



until the CEO determines that the remedial actions can cease.

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