Attachment 3A · 2019. 12. 3. · Table 1- Mineral Assemblage Eneabba Mineral Sands Concentrate MINERAL TYPICAL RANGE % BY WEIGHT Zircon 21.3 – 26.5 Rutile 1.0 – 1.3 Monazite

Attachment 3A

8 November 2019

Works Approval Supporting Information – Mid West Ports Authority Proposal for Iluka Mineral Sands Concentrate Export Through the Port of Geraldton - L4275/1982/15

Mid West Ports Authority (L4275/1982/15)

Proposal for Iluka Mineral Sands Concentrate Export Through the Port of Geraldton A1246870 - 8 November 2019 1

Document Title Mid West Ports Authority Proposal for Iluka Mineral Sands Concentrate Export Through the Port of Geraldton

Document Reference A1246870

Version Date Author(s) Reviewer(s) Comments

Draft 14/10/2019 Kylie Reynolds R Browne, P Spalding

1 (Final) 05/11/2019 Kylie Reynolds Caitlin Monti

P Spalding



Contents 1. Introduction .......................................................................................................................................... 3

1.1. Background ......................................................................................................................................... 3

1.2. Key Characteristics ............................................................................................................................ 3

1.3. Product Details .................................................................................................................................... 4

2. Project Logistics ................................................................................................................................. 5

2.1. Mine to Storage .................................................................................................................................. 5

2.2. Storage Facility ................................................................................................................................... 7

2.3. Port Loading ........................................................................................................................................ 7

2.4. Proposed Timeframes ....................................................................................................................... 9

2.5. Alternative Methods ........................................................................................................................... 9

3. Source-Pathway-Receptor Analysis .............................................................................................. 10

3.1. Proposed Handling Method Controls............................................................................................. 11

3.2. Potential Environmental Impacts .................................................................................................... 15

3.3. Potential Health Effects ................................................................................................................... 15

4. Consultation ....................................................................................................................................... 17

5. References.......................................................................................................................................... 19

6. Appendices ........................................................................................................................................ 21

Appendix 1- Self assessment decision making flowchart – Mineral Sands Concentrate not suitable for trial. ......................................................................................................................................... 21

Appendix 2- Prescribed Premises and Distance to nearest receptors ............................................ 23

Appendix 3 – MSC Safety Data Sheet .................................................................................................... 25

Appendix 4- Dust Extinction Moisture (DEM) for MSC ....................................................................... 26

Appendix 5- MSC Mineral Analysis ........................................................................................................ 27

Appendix 6- Respirable Silica Analysis for MSC ................................................................................. 28

Appendix 7- Asbestos content (%) for MSC ......................................................................................... 29

Appendix 8 - Risk Assessment ............................................................................................................... 30

Appendix 9 - Community Consultation ................................................................................................. 31

Tables Table 1- Mineral Assemblage Eneabba Mineral Sands Concentrate ................................................ 4

Table 2- Radiological Components of Eneabba Mineral Sands Concentrate ................................... 4

Table 3- Summary of Project Logistics .............................................................................................. 5

Table 4 - Potential Emissions and Discharges from the prescribed premises ................................ 10



1. Introduction

The purpose of this document is to provide an overview of the methodology proposed to export Iluka Resources Ltd mineral sands concentrate through the Geraldton Port, managed by the Mid West Port Authority (MWPA). The Geraldton Port is licenced as a prescribed premise (Environmental Protection Act Regulations, Schedule 1, Category 58) under Part V of the Environmental Protection Act 1986.

Using the Department of Water and Environmental Regulation (DWER) self-assessment decision making flowchart (Appendix 1), the proposal to introduce mineral sands concentrates (MSC), containing naturally occurring radioactive material (NORM), triggers the need for MWPA to submit a works approval application to amend Environmental Licence L4275/1982/15.

1.1. Background

Iluka Resources Limited (Iluka) owns a mineral sands mine at Eneabba, approximately 300 km north of Perth. Iluka’s Eneabba Mineral Sands Mine is administered subject to:

• Environmental Licence L5646/1994/10 issued under Part V of the Environmental Protection Act 1986 (EP Act (WA)); and

• Mineral Sands (Eneabba) Agreement Act 1975, Mining Lease M267SA.

On the 1st of August 2019, Iluka successfully obtained Works Approval W6251/2019/1 for the Eneabba Mineral Sands Recovery Project (EMSRP) involving the establishment of a new mineral sands mining and processing facility. Iluka will construct a mineral sands recovery plant (consisting of a conveyor, a mobile screening unit and de-sliming cyclones) for the purpose of producing a mineral sands concentrate suitable for export through the Geraldton Port.

These new activities require the amendment of both the Iluka Eneabba and MWPA Geraldton Port Environmental licences L5646/1994/10 (Eneabba) and L4275/1982/15 (Geraldton Port) respectively. Iluka intends to commence operation of the mineral sands recovery plant in the first quarter of 2020 with the intention to export the MSC product through the Geraldton Port in March of 2020.

1.2. Key Characteristics

Iluka currently transports approximately 30,000 tonnes per annum of by-product material from the Narngulu Mineral Separation Plant (MSP) to Eneabba for storage in the Eneabba Monazite Pit (EMPt).

Under this proposal the MSP by-product resource will be mined from the EMPt using front end loaders and a mobile screening unit located in the pit. Screened material will then be transported by haul trucks to the processing plant, located adjacent to the pit. The mineral separation process involves the use of water, a mobile screening unit and de-sliming cyclones to recover the saleable MSC product and separate it from unwanted oversize rocks and fine clay particles.

The process will consist of:

• feeding material into a feed hopper and conveyor;

• processing material through a wet vibrating screen to remove oversize;

• processing through two de-sliming cyclones to remove clay fines;

• stockpiling of final product in a bunker at Eneabba; and

• loading into Rotainer Boxes for transport to Geraldton and export through the Geraldton Port.



1.3. Product Details

Mineral Sands Concentrate Specifications The product specifications are a “mineral sands concentrate” with approximately 20.5% monazite, 23% zircon and 30% ilmenite. The product also contains small percentages of aluminosilicates, xenotime, quartz and rutile. Chemical Analysis including Elemental Oxides are provided in Appendices 3 and 5. An estimate of the typical mineral assemblage is outlined below:

Table 1- Mineral Assemblage Eneabba Mineral Sands Concentrate

MINERAL TYPICAL RANGE % BY WEIGHT Zircon 21.3 – 26.5 Rutile 1.0 – 1.3

Monazite 17.4 – 21.7 Xenotime 0.9 – 1.1 Ilmenite 25.5 – 31.7

Aluminosilicates 14.7 – 18.3 Quartz 11.1 – 13.8 Others 2.6 – 3.2

Radiological Composition All mineral sands products and by-products contain naturally occurring radioactive material (NORM). NORM is a part of the everyday environment and occurs naturally in air, water and soil. The MSP by-product contains NORM, as does the material associated with previous mining and processing activities at Eneabba and the current mineral sands material being imported and exported through the Geraldton Port. A Safety Data Sheet is provided in Appendix 3 and radiological components of MSC are summarised below;

Table 2- Radiological Components of Eneabba Mineral Sands Concentrate

COMPONENT TYPICAL CONCENTRATION

Thorium (Th) 11,906 - 14,708 ppm

Uranium (U) 191 - 236 ppm

Specific Activity1 50.8 - 62.7 Bq/g 1 Specific Activity is calculated from the Th & U assay (Head of Chain)

Moisture Content Following processing through the Wet Screening Plant, the MSC will be pumped to a designated product storage bunker. This material will remain wet (~4 to 10% moisture) and once a haulage truck arrives the MSC will be loaded directly into Rotainer Boxes (Rotainers) on the truck. The Rotainers will be transported by road to Iluka’s Narngulu Operations where the material will be stored (within the Rotainers) until sufficient material has been processed to fill a shipment.



2. Project Logistics The EMSRP has a mine life of 11 years and is summarised in the table provided below:

Table 3- Summary of Project Logistics

Cargo Mineral Sands Concentrate (‘MSC’) Import or Export Export Company Iluka Resources Port Geraldton Mine Eneabba Form Bulk via Rotainer Colour Light brown to yellow Estimated Min. tonnes per year 50,000 Estimated Max. tonnes per year 100,000 Parcel size tonnes per shipment - 10,000 No. of truck deliveries per day 120 (5/hr) Loading System Rotainer Box Loading Rate tonnes per hour 250 Estimated Max. tonnes per day 6000 Project Longevity: 11 years Timing March 2020

2.1. Mine to Storage

The transportation of the mineral sands concentrate will be overseen by the Iluka RSO or Deputy RSO (Eneabba or Narngulu). Safety requirements for the transport of MSC will be applicable to:

• Transport of Rotainers from Eneabba to Narngulu; and • Transport of Rotainers to the Geraldton Port, including loading to the ship.

Iluka Standard Job Procedures (SJP’s) have been developed which outline the process for transport of radiation gauges and MSC. SJPs have also been developed to outline emergency response actions relating to radiation gauges and mineral transport.

The MSC will be loaded into the Rotainers at Eneabba. Product specific Rotainer boxes will be used for MSC. Once the boxes are loaded with MSC (based on weights provided by a weigher on the loader, load-rite or similar) the lid will be replaced and locked into place. After the Rotainer Box has been filled and the lid is in place and locked, the truck will move through the wash-pad, where an automatic water spray system (the operator will remain in the truck) will remove any spilled MSC before the truck leaves the area.

The configuration of the truck will be 3 Rotainers per truck from Eneabba to Narngulu and stored at the Narngulu Synthetic Rutile Plant storage area. It is anticipated that MSC haulage will require placarding as transport activity levels are expected to be around 20 to 50 Bq/g. MSC is classified as a Dangerous Good by the criteria of the ADG code ‘Radioactive - Transport Hazard Class 7’.

All transport of the mineral sands concentrate will be carried out under the ARPANSA code of practice for Safe Transport of Radioactive Material (ARPANSA 2014) and in accordance with license conditions



provided under the Radiation Safety Act (1975) Section 36, including “radioactive substances to be transported in compliance with the Radiation Safety (Transport of Radioactive substances) Regulations 2002, and radioactive packages to be stored in accordance with regulation 30 of the Radiation Safety (General) Regulations”.

Iluka have developed a Radiation Management Plan which addresses radiation risks associated with the processing, transport, storage and exporting of the mineral sands concentrate. Iluka are working with DMIRS and the Radiological Council to obtain approval of this Radiation Management Plan.

The transport route from the mine to the storage area at NSR Narngulu is provided in Figure 1.

Figure 1. Transport Route – Eneabba to Narngulu Storage Area



2.2. Storage Facility

The Rotainers will be stored at the Narngulu Synthetic Rutile Plant Storage area, 324 Goulds Road Lot 34. This area is zoned industrial land and under the full control and ownership of Iluka Resources and has the required infrastructure and security procedures in place to safely store the product. When the loaded truck arrives at the Narngulu Rotainer Box storage area the driver will unlock the Rotainer Box from the tray of the truck and the Rotainer Box will be lifted off the truck. The Rotainers will be stacked on the storage pad until enough MSC material is consolidated for shipping.

2.3. Port Loading

MSC will be stored at Iluka’s Narngulu storage facility and transported, in Rotainers, to the Geraldton Port (Port) on the day of ship loading. The proposed method for handling the Iluka MSC product was chosen to avoid the need for storage of the product at the Port and to minimise the time in which MSC is transported and handling within the Port Prescribed Premises.

Transport from Narngulu Storage to Berth 6

The targeted annual shipping is currently 50,000 tpa (10,000 per shipment). It is estimated that each truck movement from Narngulu will deliver an average 55 tonnes of MSC to the Port for ship loading. This will equate to 182 truck movements per shipment and this will occur five times per year. The carting of MSC from Narngulu to the Port precinct increases the truck traffic for Iluka products by approximately 5.5% per annum.

Transport of all MSC material is overseen by the Iluka RSO and carried out under the license issued by the Radiological council. This will occur in conjunction with the transport contractor. The Iluka RSO or deputy RSO undertakes random checks of MSC trucks to ensure all required measures are implemented as required by the licence and the approved Radiation Management Plan. MWPA will have a Deputy RSO available to support Iluka RSO to implement the requirements of the radiation management plan applicable to Port Prescribed Premises.

The transport route from the storage location at Narngulu Synthetic Rutile plant to the Port is shown below in Figure 2.

Rotainer Loading System

Ship loading will occur at Berth 6 via a Rotainer loading system. Three Rotainers will be loaded onto trucks and locked into place at the Narngulu storage area. The truck will drive directly to the Geraldton Port where the driver will unlock the Rotainers the truck and a crane will lift the Rotainers from the truck.

The rotating tipping frame fitted to the crane will be lowered onto the Rotainers and locked in place. The Rotainer will be lifted, slewed and lowered into the hold of the ship, as the Rotainer is lowered into the hold the lid is lifted and the Rotainer rotates 180 degrees to empty the contents as shown on Figure 3. Once empty the Rotainer will be rotated upright again inside the hold, lid lowered back into place and then lifted out of the hold. Empty Rotainers are placed on the wharf and any residue or material will be brushed down. Vacuum trucks and/or street sweepers will be available to collect any residue material. A fork lift is used to load the containers back on to a truck. This process eliminates spillage and significantly reduces dust and nuisance odour. Empty Rotainers will be returned to the Narngulu storage area.



Figure 2. Transport Route from Narngulu Storage to Geraldton Port.

Figure 3. Rotainer boxes being unloaded into a ship’s hold at Geraldton Port



2.4. Proposed Timeframes

Iluka anticipate the first shipment of MSC to be exported from the Geraldton Port in March 2020. Approximately 5 shipments of 10,000 tonnes each are planned to occur during 2020 calendar year. The commissioning period for this project will be 2 shipments. The second shipment is anticipated to occur in May / June 2020. These additional volumes fall within the current estimated throughput of 44,000 tonnes per day, permitted under the MWPA Environment Licence L4275/1982/15.

Depending on commercial arrangements, it is estimated that up to 100,000 tonnes of mineral sands concentrate may be exported through Geraldton Port in future years. Any increases to planned shipments will be monitored to ensure compliance with our estimated throughput volumes.

2.5. Alternative Methods

The only other method available to load this type of product at the Geraldton Port would be via the “Minimum Handling Method 3” outlined on the DWER self-assessment decision making flowchart (Appendix 1). This would involve the product being received and stored in bulk within an Iluka shed within the Port precinct. MSC would require rehandling within the shed via truck movements and front-end loaders to feed the hopper delivering MCS to the Port’s covered conveyor system. Vessels would be loaded using the ship loader at Berth 4.

This method would involve significantly more risk of spillage, dust and equipment contamination than the Rotainer Box method. The bulk loading facilities would require extensive cleaning after each loading event and the shed would need to be carefully managed and monitored for NORMs.


MWPA Proposal for Iluka Mineral Sands Concentrate Export Through the Port of Geraldton A1246870 - 5 November 2019 10

3. Source-Pathway-Receptor Analysis

Table 4 - Potential Emissions and Discharges from the prescribed premises

Emission risks from prescribed premises

Type (Source / Activity)

Potential Receptors Pathway Type Pathway Assessment Potential Impact Controls

Po

ten

tial

Em

issi

on

or

Dis

char

ge

Typ

e

Emissions to Air - Dust (from materials handled via Rotainer Box unloading system)

• Residence • Light Industrial

neighbours • Fishing Boat Harbour • Marine Environment

Air (wind borne) Pathway through prevailing winds. Distance to nearest sensitive receptors (Appendix 2):

Residence: Zoned residential areas are approximately 840m to the southeast of Berth 6.

Industrial neighbours: The nearest light industry leases are approximately 700m south.

Fishing Boat Harbour is ~220m west of the prescribed premises.

Recreational Areas: The Geraldton foreshore open public space is directly adjacent to the east of the premise boundary.

Amenity Impacts: Visual dust emissions shall be significantly reduced using Rotainer Box technology. Public Health Effects: The product is not classified as hazardous according to Safe Work Australia criteria. MSC contains; • No asbestos fibres. • A small amount of respirable crystalline silica.

• Loading via Rotainer Boxes • Stevedore Rotainer Box Safe Operations Procedure • MWPA Operational procedures • MSC stockpiled at mine site and loaded into

containers at an average moisture content of 5%w/w • Routine site inspections and audit programs • Complaints and Incident Reporting Processes • Environmental Monitoring (Air Quality)

Noise (from machinery operations and truck movements)

• Residence • Industrial neighbours

Air (wind dispersion).

Noise associated with truck movements, minimal off-site impacts associated with crane and container unloading.

Amenity Impacts: • Minimal impact to residential and light industry

areas. • 5.5% increase in Iluka truck traffic into the Port.

(~5 vessels per year, which equates to ~15 days per year).

• Minimal handling method chosen. • No shed handling or storage. • 3 containers per truck to reduce truck movements. • Traffic Management Plan to control truck

movements and designated transport routes.

Naturally Occurring Radioactive Material (NORM)

• Residence • Light Industrial

neighbours • Fishing Boat Harbour

Physical presence monazite within Rotainers during transport of containers and ship loading. Radon gas release from containers at time of opening

Geraldton to Narngulu Transport Corridor (~16km): Transportation of containerised product through the Port Precinct. MSC is classified as a Dangerous Good and transported under placard ‘Radioactive’ Transport Hazard Class 7. Radon gas is heavier than air and will sit in the ships hold. Ship’s crew and Stevedores requiring access to the hold have potential for exposure to Radon gas.

Human health: Containerised concentrate will have elevated radiation levels. Potential impacts if exposed repetitively to MSC (NORM) for prolonged periods of time.

Environmental Values: Potential for fugitive dust emissions to contain NORM, which could impact marine sediments within Commercial Harbour.

• Targeted / campaign shipments minimising exposure to MSC.

• Dust management controls such as maintaining product moisture.

• Iluka Radiation Management Plan including pre and post gamma radiation surveys.

• Occupational exposure surveillance monitoring.

Discharge to Waters (from contaminated stormwater runoff)

• Marine Environment • Aquaculture

Spillage - Incident related.

Air - wind dispersed dust.

Dust settling in or spillage to Commercial Harbour may enter the marine environment during Ship loading. Marine environmental values include:

Geraldton Inner Harbour environment directly adjacent to the premise boundary and activities.

Seagrass communities in Champion Bay approximately 1 km from the harbour entrance.

Aquaculture: Indian Ocean Fresh Fish Farm located in Champion Bay.

Ecosystem condition of Ports and Marinas is considered slightly to moderately disturbed. ARMCANZ (2000) Ecosystem Health: MSC is considered insoluble and non-toxic. Potential impact on the marine environment include; • Temporary and localised increase in

suspended solids; and • MSC contamination of marine sediments.

Ecotoxicity: MSC in not considered a Marine Pollutant. The toxicity if ingested by marine life is unknown

• Loading method via Rotainer Boxes prevents spillage.

• Environmental Monitoring (Marine sediments)

• Stormwater Spillage – if not adequately recovered could result in contamination of Berth and stormwater.

Stormwater discharging directly to Marine Environment.

MSC dust mobilised during rainfall washing through to drains or direct to ocean.

Geraldton Inner Harbour environment directly adjacent to the premise boundary and activities.

• Emergency management procedures – e.g. controls to protect surface water including the use cut-off booms to minimise discharge.

• Clean-up and Berth handover procedures • Regular sweeping up of any spillages and correct

disposal.

Discharge to Land (from seepage of contaminated stormwater)

• Soil Product Spillage Soil contamination is possible as a result of a transport or loading incident. Spillage may result in contaminated stormwater or washdown water discharging to unsealed or reclamation areas. Seepage to groundwater is an unlikely occurrence as MSC is insoluble.

Ecosystem Health: Spillage causing soil contamination, elevating gamma radiation (NORM) levels.

• Regular housekeeping to remove mineral spillage from the plant area

• Sealed handling surfaces • Procedures for product handling to avoid spillage • Spill clean-up procedures • Incident response protocols • Groundwater

Odour • Community Proximity to receptors Direct through atmosphere

See above description of residential, light industry and recreational areas.

Amenity Impacts: Product is not anticipated to have a distinct odour.

• Rotainer system will minimise time product is exposed to the atmosphere.

• Stevedores will monitor product for odour. • Customer complaints and regulatory reporting

process.



3.1. Proposed Handling Method Controls

MWPA maintains an Environmental Management Plan (EMP) as part of achieving the commitments defined in its Strategic Development Plan and Environmental Policy. The EMP describes MWPA environmental management and continual improvement programs. It is designed to demonstrate how MWPA’s compliance obligations and enterprise priorities align to sustain and manage port services and activities in a manner that prevent and mitigate impacts to the environment and community in which it operates. A key management control described in the EMP is the formal process MWPA employs to assess new activities, products and or services. MWPA works closely with new customers and port users to ensure that all environmental and public health risks are identified and managed. A formal process is outlined in procedure HSE-PRO-019 HSE Approvals Process for New Cargoes. As part of this procedure a detailed Risk Assessment (Appendix 8) was completed for the transport and handling of MSC to and within the Port. Key controls identified during the formal risk assessment between MWPA, Iluka and Stevedores have been outlined in Table 4 (above) and are summarised below.

Preventative Control Measures.

The key controls identified to prevent fugitive dust emissions from transport and MSC ship loading activities are:

• Loading the product directly into containers at the Eneabba mine site with a moisture content of 4 to 10% w/w. The Rotainers will be sealed preventing moisture loss in transport or storage;

• Trucks and containers are cleaned prior to leaving the mine site to remove any hung-up product preventing dust generation during transport;

• MWPA Operational procedure HSE-PRO-028 Loading Metal Concentrates via Container will be followed and amended to include MSC (Appendix 11);

• Stevedoring services will develop product-specific loading procedures including dust management controls during crane and rotainer operations;

• Stevedores are responsible for reporting fugitive dust generation during tipping; • MWPA staff will monitor loading activities for any visible dust; • High housekeeping standards will be maintained, spilled material would be swept up using a

street sweeper then if further clean-up was required a vacuum truck would be deployed to remove the remaining mineral; and

• MWPA will conduct regular inspections of the operations to assess the effectiveness of controls.

Spill and release events will be prevented by strict adherence to administrative controls and preventative maintenance programs:

• All plant and equipment shall be operated by qualified, experienced and competent operators;

• All equipment shall be regularly inspected, tested and maintained, including container seals and lubrication of moving parts (dedicated containers for product);

• Equipment which fails inspection or testing shall be removed from service until repaired and re-inspected;

• All incidents will be reporting and investigated to prevent repeat or escalation of events; and • The effectiveness of the above controls shall be audited to ensure compliance.



Risks associated with the transport and handling of MSC containing NORM are managed in accordance with the Iluka Radiation Management Plan:

• MSC Product will not be stored at the Port and will be transported on the day(s) of ship loading;

• Targeted campaign shipments are made for MSC export, minimising Port exposure to the product;

• Iluka Standard Job Procedure for Transport of Radioactive Materials (SJP MW RMP 08) outlines the driver responsibilities including:

o Correct signage in place and holding a copy of the standing consigners declaration form in the truck along with the Iluka Radiation Emergency Procedure (SJP MW RMP 01);

o No stopping with a loaded truck anywhere near members of the general public (particularly near a built-up area on the route);

o A record of the weight of the material in the truck is kept; o Sufficient understanding of the risks posed by the material they are carrying (Drivers

have completed radiation awareness training); and o Driver sign-off by transport contractor in relation to this task and the driver

understands transport contractor’s emergency response requirements. • The Iluka RSO or deputy RSO undertakes random checks of MSC trucks to ensure all required

measures are implemented as required by the licence and the approval of this RMP; • Deputy RSO will be appointed by MWPA to undertake compliance checks and provide advice

as required; • Stevedoring services will develop product-specific loading procedures to ensure all

environmental and health risk are addressed; • All personnel entering the Berth 6 loading area shall complete a relevant site induction which

shall include, amongst other things, information regarding to the product risks and the relevant controls;

• During loading, access to Berth 6 will be limited to operational staff and appropriate signage will be deployed at all entrance points to the berth;

• The MWPA established metal concentrate PPE requirements will be applied to the loading of MSC (including coveralls, P2 dust masks and standard personal safety equipment);

• Iluka will provide radiation training to all personnel involved with MSC export activities; • Iluka will provide an RSO to support ship loading activities at the Port. The Iluka RSO will be

supported by a MWPA Deputy RSO; and • The Iluka Radiation Management Plan outlines anticipated dose levels and sets exposure

limits for personnel involved in MSC operations.

Mitigative Control Measures.

Iluka and MWPA have well developed spills clean-up protocols that will be applied in the event of an incident during transport or ship loading:

• MWPA maintain adequate stocks of pollution control equipment; • The Iluka Radiation Management plan outlines spill clean-up procedures, specifically Iluka

Radiation Emergency Procedure (SJP MW RMP 01); • Regular housekeeping to remove mineral spillage from the plant area is facilitated by the

MWPA Berth Operator Handover procedure (MAR-PRO-001); • Any MSC waste material must be recovered and returned to the mine site to process; and



• Any contaminate PPE is managed in accordance with MWPA Waste Management Procedure (HSE-PRO-013).

Complaints will be managed through the following processes:

• Public and Workforce Consultation programs have been developed to increase awareness and address any health or exposure concerns stakeholders may have (refer to Appendix 8);

• Complaints received by MWPA will be entered into the MWPA incident management system along with the results of any investigations in accordance with HSE-PRO-005 Incident Reporting and Investigation. MWPA will also inform Iluka of any community or stakeholder concerns;

• Iluka and MWPA Emergency Procedures include regulatory reporting processes and responsibilities.

• MWPA includes a summary of complaints within its Annual Environmental Report submitted to DWER.

Significant Incident Management Protocols As part of Iluka and MWPA assessment and risk management processes, contingencies are in place to manage risks resulting from significant unplanned events.

Emergencies on the public road system involving Rotainers loaded with MSC: • A contingency plan is in place with the transport contractor carting the Rotainers, for an

emergency on a public road involving Rotainers loaded with MSC. In an event of this type where MSC is release of from the Rotainer Box into the environment, Iluka managed equipment would be deployed to recover the spilled material and return it to the nearest Iluka site.

• The RSO for the project/site would oversee radiological aspects of the emergency and clean-up. Gamma surveys would be carried out after the incident to ensure gamma radiation levels were within an expected background range of radiation (not elevated above what would be normal).

• In the event of any serious incident outside the Port precinct the Narngulu site Emergency crisis team would be activated to deal with the incident. This system is called EMQNET and allows a systematic approach to dealing with emergencies, recording actions and activities carried out during an incident. Incidents can be escalated to include corporate support (in the event of a significant incident).

Incident during ship loading: • If an incident occurred during the ship loading process where MSC was spilled (in a significant

quantity) street sweeping equipment will be available at the Berth as part of the normal shipping process. The spilled material would be swept up using the street sweeper then if further clean-up was required a vacuum truck would be deployed to remove the remaining mineral.

• An RSO will be available during ship loading process to ensure radiological aspects of an incident are correctly handled and post event monitoring is conducted as required.

• In the event of any serious incident within the Port precinct the MWPA Emergency Management Team would be activated to deal with the incident. MWPA has a well-developed systematic approach to dealing with emergencies, recording actions and activities carried out during an incident.



Monitoring and Detection Measures

Environmental Radiation and Fugitive Dust Monitoring Programs will be implemented to detect impacts and assess the effectiveness of controls:

• Iluka Gamma Surveys: Baseline and routine surveys are undertaken along transport routes and Berth 6 to ensure gamma radiation levels are within an expected background range of radiation (not elevated above what would be normal).

• Iluka Dust monitoring: Hi-Vol dust monitoring will be undertaken at Berth 6 during the first 3 shipments and filters will be analysed for alpha radiation. This sampling will be conducted as a continuous (40 hour) sample during ship loading at a safe location close to the activity.

• MWPA Dust monitoring: The existing Port real time PM10 dust monitoring network will be used to monitor and assess fugitive dust impacts from operations according to the existing licence conditions.

• Annual Reporting: MWPA provides a summary of Hi-Vol and Real time dust monitoring results in the Annual Environmental Report to DWER.

• Real Time Dust Monitoring: MWPA environmental and operations personnel monitored dust levels in real time via the software application Envirosuite. Automated alarms have been set to trigger email and SMS notifications when dust levels exceed internally set trigger levels.

Occupational surveillance monitoring programs will be implemented to assess exposure levels of Port personnel including Stevedores managing ship loading operations:

• Personal gamma monitoring: Personal Electronic Gamma meters worn by selected workgroups. Assessed daily and used to determine annual exposure.

• Area gamma monitoring: Surveys conducted by Iluka RSO at Berth 6 pre and post ship loading to assess impact and ensure recovery of all product from the berth.

• Long lived Alpha Dust monitoring: Personal dust samples collected via small air pumps and tested for Alpha radiation counts. Will only be conducted as a baseline activity during first shipment.

• Radon/Thoron Gas monitoring: Passive or electronic detectors will be deployed in the work area to detect levels of gas released from Rotainer once open. Frequency will be determined after first shipment data validates dispersion assumptions.

• Surface Contamination: Electronic monitoring will be used randomly to validate housekeeping and Personal Hygiene compliance, targeting stevedore crib room, Berth 6 site office and Berth infrastructure.

• Occupational Radiation Monitoring: A report will be submitted by Iluka to DMIRS and MWPA annually.

• MWPA monitoring and auditing: MWPA HSE-PLN-003 Occupational Hygiene Risk Assessment and Surface Ventilation Plan will target audit and inspection programs to verify procedure are being implemented correctly and records of results are correctly communicated and retained.

Operations are monitored throughout ship loading to ensure environmental conditions facilitate safe and controlled loading of the shipment:

• Surge and wind conditions are continuously monitored by the MWPA Operations Supervisor and Marine Team;

• Shoreline Tension Units (STU) are available for use at Berth 6. STUs apply constant mooring line pressure to dampen the movement of moored vessels. This effectively minimises movement improving stability and making container unloading and movement smoother;

• The Berth 6 Rotainer area is sign posted as both a “Hazardous Cargo Loading” and "Mandatory PPE" area. The Berth Operator controls all access to the area during loading;



• Housekeeping standards are maintained and monitored by the MWPA Wharf Supervisor via the Berth Operator Handover procedure (MAR-PRO-001) and associate checklist.

Audit and Assurance Measures

Various inspections and assurance activities will be undertaken throughout the process to check the effectiveness of controls. Key assurance activities include but are not limited to:

• Inspection of empty Rotainers by Iluka and/or the nominated transport company prior to loading onto trucks;

• Berth Handover Inspections by the Wharf Supervisor; • Implementation of environmental monitoring programs for air quality and marine

sediments; • Routine inspections by MWPA Environmental Officers to confirm compliance with

environmental licence conditions; • Inspections and routine monitoring of operational activities by Iluka RSO and/or Deputy RSO

to check radiation controls are effective; and • Periodic updates of MWPA environmental sampling and analysis plans using a risk-based

approach.

3.2. Potential Environmental Impacts

ANZECC/ARMCANZ (2000) guidelines provide provision for classification of Port areas as slightly to moderately disturbed ecosystems. ANSTO leachability studies, completed for Iluka, showed the components of MSC were comparable to drinking water standards, except for low pH conditions (



• Frequency and duration of exposure; • Effectiveness of control measures; and • Protective equipment used and method of application.

Iluka’s Radiation Management Plan outlines: • Guideline exposure levels; • Internal investigations levels; • Annual anticipated radiation dose assessments for specific work groups; and • Methods for minimising exposure.

One of the key controls for minimising impacts to health is through radiation training and area inductions. Training will be required and provided for;

• Transport workers driving the MSC between Eneabba, Narngulu and the Port; • Stevedores loading the ship at the Geraldton Port; and • General workforce and supervisors at the Geraldton Port.

Training and awareness programs are designed to provide an understanding of the risks posed by NORMs and what precautions need to be taken to reduce personal radiation exposure. The Iluka Radiation Management Plan specifies mandatory radiation training for workers who need to enter MSC loading areas.

MSC transport drivers will be provided with radiation training specific to the nature of their tasks and potential exposures. The training will cover sources and characteristics, safe practices to minimise exposure and emergency response procedures.

MWPA workforce consultation and HSE committees will used to communicate and reinforce key messages around the safety handling of MSC.

Iluka has identified Radon Gas as a potential health risk specifically associated with ship’s crew. Radon gas will accumulate within the Rotainer Boxes and be released when the containers are emptied into the ships hold. As Radon gas is heavier than air the Radon is likely to accumulate in the hold posing a risk to the ship’s crew should there be a need to enter the hold.

Iluka will have an established direct relationship with the Ship’s Owner and each voyage is bound by a Charter Party. Under the International maritime solid bulk cargoes (IMSBC) code minerals sands concentrate is classed as “Sand, mineral concentrate, radioactive material low specific activity (LSA-1), UN2912” consistent with dangerous goods code. Owners are required to hold a current statement of compliance for the carriage of solid bulk cargos which is issued in accordance with the provisions of the IMSBC code under the authority of the Government of the Owners flag and class. The vessels statement of compliance list of cargos must contain “RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1) UN 2912.

Radon gas will readily disperse in light to moderate wind conditions and therefore is not anticipated to be a high risk in ship loading activities for either the stevedores or Port users. Iluka’s Radiation Management Plan includes deployment of gas detectors in the Berth 6 work area to detect levels of gas released from Rotainer once open. Ongoing frequency of monitoring will be determined after first shipment data validates dispersion assumptions.



4. Consultation Iluka Resources, in conjunction with Promanage Australia, developed the Phase One Eneabba Mineral Sands Recovery Project Pre-Works Approval Engagement Plan this plan is attached in Appendix 9. This consultation supported the Works Approval W6251/2019/1 submission which was successfully assessed and approved in August 2019.

Consultation was undertaken with the following stakeholders mid 2019;

• Eneabba Community information session – 15th of June • Geraldton Community information session – 12th of June

Both sessions were actively promoted via community targeted mediums, namely:

• the Mid-West Times Newspaper, Carnamah Mat and Eneabba News Newspaper; • social media posts via the Shire of Carnamah, City of Greater Geraldton and Eneabba Notice

Board; • an event listing on the City of Greater Geraldton website; and • a letter to the residents and businesses of Eneabba.

Of note, the Mid-West Times newspaper had a circulation of over 19,000 across Geraldton, Carnarvon, Mingenew, Carnamah, Cue, Denham, Dongara, Eneabba, Greenough, Jurien, Kalbarri, Latham, Meekatharra, Morawa, Mt Magnet, Mullewa, Murchison, Northampton, Shark Bay, Three Springs and Yalgoo.

Overall the community viewed the proposed Eneabba Mineral Sands Recovery Project as a positive in terms of reactivating the Eneabba area during construction and providing additional job opportunities into the future.

MWPA are working with Iluka as part of their Phase 2 consultation plan which identifies the following key Project Milestones for targeted communication:

• Commencement of construction of the Eneabba Mineral Sands Recovery Plant; • Commencement of Operations; • Commencement of Transport to Narngulu; • Production Capacity reaching First Shipment volumes;

Iluka’s Phase 2 Consultation plan identifies the key stakeholders and proposed engagement method as follows;

REGION STAKEHOLDER ENGAGEMENT METHOD / COMMUNICATION TOOL

Eneabba Stakeholders and Community Members

Eneabba Local Post Office/General Store (owner)

Letter-drop/Fact sheet/newsletter

Eneabba Primary School Letter-drop/Factsheet/newsletter Education sessions

Eneabba community (population approximately 75)

Letter-drop/Factsheet/newsletter Community information session at well attended local Eneabba event

Shire of Carnamah (CEO, elected members, local MPs)

One on one meetings Briefing paper Presentation



Eneabba Smash Repairs (owner and resident)

One on one meetings Letter-drop/Fact sheet/newsletter

Geraldton Stakeholders and Community Members

Mid-West Ports Authority Community Consultation Forum

Presentation at quarterly forum meeting Briefing via forum membership email distribution list

City of Greater Geraldton (CEO, elected members, local MPs)


Irwin Shire (CEO, elected members, local MPs)


Geraldton community (population approximately 40,000)

Community information session at well attended local Geraldton event

Mid-West Development Commission, Mid-West Ports Authority, Mid-West Chamber of Commerce and Industry


Geraldton Fisherman’s Cooperative Brolos and Geraldton Professional Fisherman’s Association

One on one meetings Presentation

Perth Government Stakeholders

Radiological Council One on one meetings Briefing paper Presentation

Department of Job, Tourism, Science and Innovation Department of Mines, Industry, Regulation and Safety Department of Water and Environmental Regulation

Where appropriate MWPA will collaboratively present information with Iluka. MWPA have identified the following additional stakeholder groups and consultation committees and engagement methods.

MWPA STAKEHOLDER GROUP

ENGAGEMENT METHOD / COMMUNICATION TOOL

Proposed Dates

Port Users and Lease Holders (including Stevedores and Shipping Agents)

Letters / Port Newsletter.

Presentations or information sessions at scheduled monthly or quarterly meetings.

13 November 2019

Fishing Boat Harbour Consultation Committee

Targeted Presentations Port Newsletter

27 November 2019

Stakeholder Engagement Committee

Targeted Presentations Port Newsletter

25 November 2019

EHS and Workforce Consultation Committees

Targeted Presentations Project Updates - Monthly or Quarterly

21st November 2019

General workforce and contractors (including casual Moorers)

Port Newsletter / Weekly Updates Radiation Awareness Training

November 2019 Early 2020

Community Social media platforms / Newspaper articles / Website

Dec 2019 – March 2020



5. References Health / Environment References and Guidelines

ANZECC & ARMCANZ (2000) Australian and New Zealand Guidelines for Fresh and Marine Water Quality. (National Water Quality Management Strategy No. 4 & 7) Australian and New Zealand Environment and Conservation Council & Agriculture and Resource Management Council of Australia and New Zealand, Canberra

ARPANSA. (2011) Monitoring, Assessing and Recording Occupational Radiation Doses in Mining and

Mineral Processing. Safety Guide. Radiation Protection Series 9.1 Australian Radiation Protection and Nuclear Safety Agency, Commonwealth of Australia, Canberra, ACT. ISBN 978-0-9806797-8-6

ARPANSA. (2005) Radiation Protection and Radioactive Waste Management in Mining and Mineral

Processing. Code of Practice and Safety Guide. Radiation Protection Series 9. Australian Radiation Protection and Nuclear Safety Agency, Commonwealth of Australia, Canberra, ACT. ISBN 0-9752133-9-3

DMIRS. (2010a). Managing naturally occurring radioactive material (NORM) in mining and

mineral processing NORM 2.2 – Preparation of a radiation management plan – mining and processing. Department of Mines and Petroleum. Perth, Western Australia.

NOHSC: 3008(1995) Exposure Standards for Atmospheric Contaminants in the Occupational Environmen.t

National Transport Commission. (2018) Australian Code for the Transport of Dangerous Goods by Road & Rail, Edition 7.6 (ADG Code).

Radiation Safety (Transport of Radioactive Substance) Regulations 2002, Western Australia.

Other References

ANSTO Minerals. 2016. Leachability of Iluka Monazite, Memorandum prepared by Sue Brown for Iluka resources, March 2016.

ARPANSA. 2019. Units of ionising radiation measurement. Understanding radiation. Australian

Radiation Protection and Nuclear Safety Agency, Commonwealth of Australia, Canberra, ACT. https://www.arpansa.gov.au/understanding-radiation/what-is-radiation/radiation/measurement

ARPANSA. 2014. Safe Transport of Radioactive Material. Code of Practice and Safety Guide.

Radiation Protection Series 9. Australian Radiation Protection and Nuclear Safety Agency, Commonwealth of Australia, Canberra, ACT.

ARPANSA. 2014. Background Radiation Environment in Australia – Spatial Variability Project.

Presentation at ARPS Conference by Scott Muston. ARPANSA. 2011. Monitoring, Assessing and Recording Occupational Radiation Doses in Mining and

Mineral Processing. Safety Guide. Radiation Protection Series 9.1 Australian Radiation

https://www.arpansa.gov.au/understanding-radiation/what-is-radiation/radiation/measurementhttps://www.arpansa.gov.au/understanding-radiation/what-is-radiation/radiation/measurement



Protection and Nuclear Safety Agency, Commonwealth of Australia, Canberra, ACT. ISBN 978-0-9806797-8-6

ARPANSA. 2005. Radiation Protection and Radioactive Waste Management in Mining and Mineral

Processing. Code of Practice and Safety Guide. Radiation Protection Series 9. Australian Radiation Protection and Nuclear Safety Agency, Commonwealth of Australia, Canberra, ACT. ISBN 0-9752133-9-3

DMIRS. 2010a. Managing naturally occurring radioactive material (NORM) in mining and mineral

processing NORM 2.2 – Preparation of a radiation management plan – mining and processing. Department of Mines and Petroleum. Perth, Western Australia.

DMIRS. 2010b. Managing naturally occurring radioactive material (NORM) in mining and mineral

processing NORM 4.2 – Preparation of a radiation waste management plan – mining and processing. Department of Mines and Petroleum. Perth, Western Australia.

DMIRS. 2010c. Managing naturally occurring radioactive material (NORM) in mining and mineral

processing NORM 6 – Reporting Requirements. Department of Mines and Petroleum. Perth, Western Australia.

ICRP (International Commission for Radiation Protection). 2017. Occupational intakes of

Radionuclides: Part 3. ICRP Publication 137. Ann. ICRP 46(3/4). ICRP. 2007. Recommendations of the ICRP. ICRP Publication 103. Elsevier Ltd. Iluka. 2009. Zircon-Monazite Export Radiation Management Plan. Prepared by Iluka Resources Ltd.

Capel. Western Australia. Iluka. 2019. Midwest Rehabilitation Operations Radiation Management Plan. Prepared by Iluka

Resources Ltd. Perth. Perth, Western Australia. Iluka. 2018. Eneabba Operations Dust Management Plan. Prepared by Iluka Resources Ltd. Perth.

Perth, Western Australia. Iluka 2019. Narngulu Radiation Management Plan. Prepared by Iluka Resources Ltd. Perth. Perth,

Western Australia.

NHMRC & NRMMC. 2011. National Water Quality Management Strategy. Australian Drinking Water Quality Guidelines 6. Joint publication of the National Health and Medical Research Council and National Resource Management Ministerial Council, Canberra, ACT (updated 2013).



6. Appendices

Appendix 1- Self assessment decision making flowchart – Mineral Sands Concentrate not

suitable for trial.



Appendix 2- Prescribed Premises and Distance to nearest receptors



Appendix 3 – MSC Safety Data Sheet

1. IDENTIFICATION OF THE MATERIAL AND SUPPLIER

ILMENITE ZIRCON MONAZITE CONCENTRATE ● MONAZITE 20Synonyms

RAW MATERIAL FOR PRODUCTION OF RARE EARTH COMPOUNDSUses1.2 Uses and uses advised against

1.3 Details of the supplier of the product

ILUKA RESOURCES LIMITEDSupplier name

Level 17, 240 St Georges Terrace, Perth, WA, 6000, AUSTRALIAAddress

+61 8 9360 4700Telephone

+61 8 9360 4777Fax

+61 8 9360 4700 (8:00 to 17:00 AWST)Emergency13 11 26Poison Information

Centre

1.4 Emergency telephone numbers

http://www.iluka.comWebsite

1.1 Product identifier

MINERAL SANDS CONCENTRATEProduct name

2. HAZARDS IDENTIFICATION

NOT CLASSIFIED AS HAZARDOUS ACCORDING TO SAFE WORK AUSTRALIA CRITERIA

2.2 GHS Label elements

Signal word WARNING

Disposal statementsNone allocated.

Storage statementsNone allocated.

Call a POISON CENTER or doctor/physician if you feel unwell.P312Response statements

Prevention statementsNone allocated.

May be harmful if swallowed.H303Hazard statements

Pictograms

Physical Hazards

Not classified as a Physical Hazard

Health Hazards

Acute Toxicity: Oral: Category 5

Environmental Hazards

Not classified as an Environmental Hazard

2.1 Classification of the substance or mixture

SDS Date: 04 Jul 2019

Version No: 4ofPage 1 7

http://www.iluka.com

MINERAL SANDS CONCENTRATEPRODUCT NAME

No information provided.2.3 Other hazards

3. COMPOSITION/ INFORMATION ON INGREDIENTS

Ingredient CAS Number EC Number Content

20 to 25%14940-68-2 239-019-6ZIRCON


7. HANDLING AND STORAGE

Store in a well ventilated area, removed from incompatible substances and foodstuffs. Ensure containers are adequately labelled,protected from physical damage and sealed when not in use. When stockpiled, ensure leachate and runoff cannot enter drains orwaterways.

7.2 Conditions for safe storage, including any incompatibilities

No information provided.7.3 Specific end uses

7.1 Precautions for safe handling

Before use carefully read the product label. Use of safe work practices are recommended to avoid eye or skin contact and inhalation.Observe good personal hygiene, including washing hands before eating. Prohibit eating, drinking and smoking in contaminated areas.

8. EXPOSURE CONTROLS / PERSONAL PROTECTION

8.1 Control parameters

Exposure standards

Ingredient ReferenceTWA STEL

ppm mg/m³ ppm mg/m³

Nuisance Dust SWA [AUS] -- 10 -- --

Zirconium compounds SWA [AUS] -- 5 -- 10

Zirconium compounds (as Zr) SWA [AUS] -- 5 -- 10

Biological limitsNo biological limit values have been entered for this product.

PPE

Eye / Face Wear safety glasses and if there is a potential for dust, wear dust-proof goggles.

Hands Wear industrial grade gloves when handling material. Where heavy contamination is likely, wear PVC or rubber gloves.

Body Where heavy contamination is likely, wear coveralls.

Respiratory In general the use of respirators should be limited and engineering controls employed to avoid exposure. Ifrespiratory equipment must be worn ensure correct respirator selection and training is undertaken.Remember that some respirators may be extremely uncomfortable when used for long periods. The use ofair powered or air supplied respirators should be considered where prolonged or repeated use is necessary.

Avoid inhalation. Use in well ventilated areas. Where an inhalation risk exists, mechanical extractionventilation is recommended. Maintain dust levels below the recommended exposure standard.

8.2 Exposure controlsEngineering controls

9. PHYSICAL AND CHEMICAL PROPERTIES

9.1 Information on basic physical and chemical propertiesLIGHT BROWN TO YELLOW COLOURED GRANULAR SOLIDAppearanceODOURLESSOdourNON FLAMMABLEFlammabilityNOT RELEVANTFlash pointNOT AVAILABLEBoiling point1900°C to 2300°CMelting pointNOT VOLATILEEvaporation rate5 to 7.5pHNOT AVAILABLEVapour density4.8 to 5.2Specific gravityINSOLUBLESolubility (water)




9.1 Information on basic physical and chemical propertiesNOT VOLATILEVapour pressureNOT RELEVANTUpper explosion limitNOT RELEVANTLower explosion limitNOT AVAILABLEPartition coefficientNOT AVAILABLEAutoignition temperatureNOT AVAILABLEDecomposition temperatureNOT AVAILABLEViscosityNOT AVAILABLEExplosive propertiesNOT AVAILABLEOxidising propertiesNOT AVAILABLEOdour threshold

10. STABILITY AND REACTIVITY

10.2 Chemical stability

Stable under recommended conditions of storage.

10.4 Conditions to avoid

No information provided.

10.5 Incompatible materials

None in normal or expected use.

May evolve toxic gases when heated to decomposition.10.6 Hazardous decomposition products

Polymerization is not expected to occur.

10.3 Possibility of hazardous reactions

10.1 ReactivityCarefully review all information provided in sections 10.2 to 10.6

11. TOXICOLOGICAL INFORMATION

Non-toxic. There are no known hazards resulting from accidental ingestion of this product as may occurduring normal handling. Ingestion of large quantities may cause irritation to the gastrointestinal system,mainly as a result of abrasion.

Acute toxicity

Not classified as a skin irritant. Contact may result in mechanical irritation.Skin

Not classified as an eye irritant. Contact may result in mechanical irritation.Eye

Not classified as causing skin or respiratory sensitisation.Sensitisation

No known effects from this product.STOT - singleexposure

This product does not present an aspiration hazard.Aspiration

The normal grain size of the product precludes it from being an inhalation hazard. This product contains asmall amount of respirable crystalline silica and precautions should be taken to avoid inhaling the dust.Radiation: This product contains low levels of naturally occurring radioactive elements of the uranium andthorium series. Low level gamma radiation from bulk or bagged stockpiles of this product can increasegamma levels slightly above normal background.

STOT - repeatedexposure

Not classified as a reproductive toxin. Radioactive materials are known to cause reproductive effects.Reproductive

This product contains a small amount of respirable crystalline silica and precautions should be taken to avoidinhaling the dust. Crystalline silica is classified as carcinogenic to humans (IARC Group 1). The normal grainsize of the product precludes it from being an inhalation hazard. Zircon, monazite and xenotime are slightlyradioactive due to the presence of natural uranium and its daughter products which produce low levels ofalpha particles and gamma rays. Although this radiation is classified as low level, unnecessary exposure tothe product should be avoided. Some human data indicates that uranium compounds may lead to lung andbone cancers. These deposits also contain low levels of thorium, which is classified as a confirmed humancarcinogen (IARC Group 1).

Carcinogenicity

Not classified as a mutagen.Mutagenicity

11.1 Information on toxicological effects

12. ECOLOGICAL INFORMATION




12.1 Toxicity


12.2 Persistence and degradabilityNo information provided.

12.4 Mobility in soil



12.5 Other adverse effects

12.3 Bioaccumulative potentialNo information provided.

13. DISPOSAL CONSIDERATIONS

Disposal must be in accordance with Federal, State and Local Council regulations. If approved, may betransferred to an approved landfill site. Many states are developing new regulations for the disposal of wastecontaining Naturally Occurring Radioactive Materials (NORM) or Technologically Enhanced NaturallyOccurring Radioactive Materials (TENORM) above background levels. Consult and comply with currentregulations.

13.1 Waste treatment methods

Waste disposal

Dispose of in accordance with relevant local legislation.Legislation

14. TRANSPORT INFORMATION

LAND TRANSPORT (ADG) SEA TRANSPORT (IMDG / IMO) AIR TRANSPORT (IATA / ICAO)

None allocated.

7 7

None allocated. None allocated.

714.3 Transporthazard class

14.4 Packing Group

RADIOACTIVE MATERIAL, LOWSPECIFIC ACTIVITY (LSA-I), non

fissile or fissile-excepted

2912



2912 2912



14.1 UN Number

14.2 ProperShipping Name

Not a Marine Pollutant

14.5 Environmental hazards

None allocated.Hazchem code

F-I, S-SEMS

REFERGTEPG

14.6 Special precautions for user

CLASSIFIED AS A DANGEROUS GOOD BY THE CRITERIA OF THE ADG CODE

15. REGULATORY INFORMATION

A poison schedule number has not been allocated to this product using the criteria in the Standard for theUniform Scheduling of Medicines and Poisons (SUSMP).

15.1 Safety, health and environmental regulations/legislation specific for the substance or mixture

Poison schedule

Safework Australia criteria is based on the Globally Harmonised System (GHS) of Classification andLabelling of Chemicals.

Classifications




AUSTRALIA: AICS (Australian Inventory of Chemical Substances)All components are listed on AICS, or are exempt.

Inventory listings

16. OTHER INFORMATION

RADIOACTIVE COMPOUNDS - ALPHA EMITTERS: Alpha radiation is emitted by radioactivematerials as they decay. Alpha radiation does not penetrate below the outer layer of skin. Restrict allpotential routes of internal exposure by inhalation, ingestion and contact with open wounds.

RADIOACTIVE COMPOUNDS - GAMMA EMITTERS: Gamma radiation is emitted by radioactivematerials as they decay. Gamma radiation penetrates the body and a distance in air. Based on themeasured emission level of a gamma radiation source, warning signs may be required foridentification. Reduction to gamma radiation exposure is achieved by increasing distance from thesource, a reduction of the time in contact with the source and by the use of a shield made from lead,concrete or thick steel between a person and the source.

PERSONAL PROTECTIVE EQUIPMENT GUIDELINES:The recommendation for protective equipment contained within this report is provided as a guideonly. Factors such as form of product, method of application, working environment, quantity used,product concentration and the availability of engineering controls should be considered before finalselection of personal protective equipment is made.

HEALTH EFFECTS FROM EXPOSURE:It should be noted that the effects from exposure to this product will depend on several factorsincluding: form of product; frequency and duration of use; quantity used; effectiveness of controlmeasures; protective equipment used and method of application. Given that it is impractical toprepare a report which would encompass all possible scenarios, it is anticipated that users willassess the risks and apply control methods where appropriate.

ACGIH American Conference of Governmental Industrial HygienistsCAS # Chemical Abstract Service number - used to uniquely identify chemical compoundsCNS Central Nervous SystemEC No. EC No - European Community NumberEMS Emergency Schedules (Emergency Procedures for Ships Carrying Dangerous

Goods)GHS Globally Harmonized SystemGTEPG Group Text Emergency Procedure GuideIARC International Agency for Research on CancerLC50 Lethal Concentration, 50% / Median Lethal ConcentrationLD50 Lethal Dose, 50% / Median Lethal Dosemg/m³ Milligrams per Cubic MetreOEL Occupational Exposure LimitpH relates to hydrogen ion concentration using a scale of 0 (high acidic) to 14 (highly

alkaline).ppm Parts Per MillionSTEL Short-Term Exposure LimitSTOT-RE Specific target organ toxicity (repeated exposure)STOT-SE Specific target organ toxicity (single exposure)SUSMP Standard for the Uniform Scheduling of Medicines and PoisonsSWA Safe Work AustraliaTLV Threshold Limit ValueTWA Time Weighted Average

Abbreviations

Additional information




This document has been compiled by RMT on behalf of the manufacturer, importer or supplier of theproduct and serves as their Safety Data Sheet ('SDS').

It is based on information concerning the product which has been provided to RMT by themanufacturer, importer or supplier or obtained from third party sources and is believed to representthe current state of knowledge as to the appropriate safety and handling precautions for the productat the time of issue. Further clarification regarding any aspect of the product should be obtaineddirectly from the manufacturer, importer or supplier.

While RMT has taken all due care to include accurate and up-to-date information in this SDS, it doesnot provide any warranty as to accuracy or completeness. As far as lawfully possible, RMT acceptsno liability for any loss, injury or damage (including consequential loss) which may be suffered orincurred by any person as a consequence of their reliance on the information contained in this SDS.

Report status

Risk Management Technologies 5 Ventnor Ave, West Perth Western Australia 6005 Phone: +61 8 9322 1711 Fax: +61 8 9322 1794 Email: [email protected] Web: www.rmtglobal.com

Prepared by

[ End of SDS ]





Appendix 4- Dust Extinction Moisture (DEM) for MSC

Client: Iluka ResourcesJob number: 19_1650Lab ID: 19_1650_01Client ID: Monazite Concentrate/Mineral sandsAnalysis Date: 8/11/2019Report Date: 8/11/2019Analysis: Dust Extinction Moisture (DEM) following AS4156.6 - 2000

Sample preparation

Analysis

SummaryThe results were determined to be:

Lab ID

19_1650_01

Analyst: Rick Hughes, B.Sc.(Hons)Physics, MAIP

Reported by: Rick Hughes, B.Sc.(Hons)Physics, MAIP

Approved by: Nimue Pendragon, B.Sc.(Nanotechnology)

Be Confident We See More www.microanalysis.com.auPage 1 of 1

The sample was tested as received.

A representative subsample of approximately 1000.32 g of the sample was weighed out and transferred to a sealeddrum. The drum was rotated/agitated and the genereated dust vacuumed out of the drum and collected in a pre-weighed vacuum bag of 5 µm nominal pore size. The mass of collected dust was recorded. A known quantity of waterwas added to a series of separate sub-samples, each thoroughly mixed before being placed in the drum and the dustcollection procedure repeated. Separate sub-samples were repeated with increaseing moisture contents until nosignificant (



Appendix 5- MSC Mineral Analysis

MSCMineral Sand Concentrate

GENERAL SPECIFICATION

Chemical Analyses Typical Mineral AssemblageWeight percentages unless indicated.

REO Typical 11.6 - 14.3CeO2 Typical 5.3 - 6.5TiO2 Typical 17.9 - 22.1 21.3 - 26.5ZrO2 Typical 15.1 - 18.7 1.0 - 1.3Fe2O3 Typical 12.0 - 14.8 17.4 - 21.7SiO2 Typical 12.2 - 15.1 0.9 - 1.1P2O5 Typical 5.5 - 6.8 25.5 - 31.7Y2O3 Typical 0.43 - 0.53 14.7 - 18.3HfO2 Typical 0.26 - 0.32 11.1 - 13.8Cr2O3 Typical 0.09 - 0.11 2.6 - 3.2CaO Typical 0.30 - 0.38Al2O3 Typical 7.6 - 9.4MnO Typical 0.3 - 0.3U (as ppm) Typical 191 - 236Th (as ppm) Typical 11,906 - 14,708Specific Activity1 (Bq/g) Typical 50.8 - 62.71Specific Activity is calculated from the Th & U assay

All analytes on an "as received” basis

Product Notes OTHERINFORMATION

MSC is produced at Iluka Resources Limited's operations.

MSC is a natural product and as such variance in the chemical analysis and mineralogical composition may be expected. See www.iluka.com for

Special contracts covering guarantees other than those specified may be negotiated. Safety Data Sheets

For further information contact Iluka Resources Limited (ABN 34 008 675 018) at www.iluka.com or at the regional offices:

Iluka Resources Limited Iluka Trading (Shanghai) Co., Ltd Iluka Atlantic LLC.Level 14 Unit 2601, 26th Floor, 8601 Six Forks Road, Suite 400240 St Georges Tce Westgate Mall, Raleigh NC 27615Perth WA 6000 1038 Nanjing West Road, Phone +1 919 676-5300Australia Jing'An District, Fax +1 919 676 5305Ph: +61 (0) 8 9360 4700 Shanghai PRC 200041Fax: +61 (0) 8 9360 4755 Ph: +86 21 6253 2266 - 108

Fax: +86 21 6253 2266 - 113

This specification supersedes any former publication and is subject to change without notice. The technical advice contained herein is based on

tests believed to be reliable and is offered as a helpful suggestion, it being expressly understood that all such advice being given and accepted at

buyer's risk. This information is not a licence to operate under, nor intended to suggest infringement of any existing patents.

ISSUED: ISSUE No: 1

Quartz Others

Typical range %by weight

Jun-2019

Mineral

Zircon Rutile

MonaziteXenotimeIlmenite

Aluminosilicates



Appendix 6- Respirable Silica Analysis for MSC

Client: IlukaClient ID: Monazite ConcentrateJob No : 19_1650Lab ID No : 19_1650_01

Analysis:

Results:

Sample Non- inhalableInhalable,

PM100Thoracic,

PM10Respirable,

PM4Monazite Concentrate 99.77 0.23 0.23 0.21

Lab number Client ID % PM4 α-

quartz of bulk

% PM4 cristobalite of bulk material

% PM4 tridymite of bulk

material

19_1650_01 Monazite Concentrate 0.036



Appendix 7- Asbestos content (%) for MSC

Be Confident We See More www.microanalysis.com.au This document may not be reproduced, except in full, without written approval of the laboratory. Revision 0

Page 1 of 7

Client: Iluka Resources Client address: Level 14/240 St Georges Tce, Perth WA 6000 Job number: 19_1650 Lab ID: 19_1650_01 Client ID: Monazite Concentrate Revision No. 0 Date received: 26/09/2019 Date analysed: 05/11/2019 Date reported: 05/11/2019 Analysis: Fibre characterisation by scanning electron microscopy (SEM) with elemental analysis by energy

dispersive spectroscopy (EDS) following AS 4964 Sample preparation The sample was supplied to Microanalysis Australia as a bulk sample. The sample was inspected visually (both with the naked eye and with a low-powered lens) for fibrous material before sub-sampling. As no fibrous material was visually apparent for immediate pre-selection, a representative sub-sample was placed on top of a double sided carbon tab before being carbon coated. Non-conducting samples require coating prior to SEM analysis to prevent charging whilst being analysed by the electron beam. Analysis The sample was analysed using a Carl Zeiss EVO50 scanning electron microscope (SEM) fitted with an Oxford INCA energy dispersive spectrometer (EDS). The sample was scanned at low magnification to identify any possible fibre clusters before the magnification was increased to 2000x magnification for closer examination. EDS is a semi-quantitative technique (at best) on well prepared, optically flat samples. Factors such as sample unevenness may adversely bias elemental concentration interpretation. EDS has a spatial resolution of ~5 µm meaning spectra from particles less than this size may contain elemental concentrations biased by their surroundings. All images were acquired using backscatter electrons. Image brightness is proportional to average atomic number – the brighter the pixel, the higher the atomic number of the element.

37 Kensington Street East Perth WA 6004

http://www.microanalysis.com.au/http://www.microanalysis.com.au/


Page 2 of 7

Summary Following AS 4964, asbestos is defined as:

- Many particles with aspect ratios (i.e. length to width ratios) ranging from 20:1 to 100:1 or higher for particles >5 micrometers in length. Bundles of fibres may have lower aspect ratios.

- Sets of fibre bundles generally less than 0.5, but always less than 1.0 micrometres in width, unless in thick bundles.

- In addition to the mandatory fibrillar crystal growth, one or more, and preferably three of the following aspects: Parallel fibres occurring in bundles. Fibre bundles displaying splayed ends. Matted masses of individual fibres. Fibres showing characteristic curvature.

- Respirable asbestos fibres are defined as: Asbestos fibres less than 3 micrometres in width, and greater than 5 micrometres in length,

and with a length to width ratio greater than 3 to 1. None of the 3 observed fibres had an elemental composition and morphology indicative of asbestos mineral fibre, according to the definition in AS 4964. Depending upon sample condition, composition and fibre type, the detection limit of AS 4964 has been found to lie generally in the range of 1 in 1,000 (0.1 wt %) to 1 in 10,000 (0.01 wt %) parts by weight, equivalent to 1 to 0.1 g/kg. For this report, a limit of reporting of 0.01 wt % has been assumed, as stated in AS 4964. The sample was found to contain


Page 3 of 7

Project: 19_1650 Owner: lab Site: Site of Interest 1

Sample: 19_1650_01 Type: Default ID:

http://www.microanalysis.com.au/


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Appendix 8 - Risk Assessment

Risk Assessment for: Mineral Sands Concentrate (MSC) export through Mid West Ports Authority

Activity Critical Success Factor Risk Issue Causes Impact Rating Basis Consequence Likelihood Risk Rating Risk LevelExisting Control Measures

Consequence Likelihood Risk Rating Risk Level Risk Owner

List the High Level Key Activities

List the factors required to successfully undertake the activity

List scenarios or issues that could prevent achievement of the CSF's

Identify what would cause the scenario or issue (Risk Issue) to occur.

What is the impact (s) if the CSF is not achieved?

Drop Down Score as per Procedure

Score as per Procedure

Automatic Do Not Enter


What documented, communicated, up to date & effective controls are currently in place to mitigate the risk? Score as per Procedure

Score as per Procedure



This is the Senior Manager Responsible

1. Ship Scheduling

Pre Shipment Planning / Expected Shipping Arrivals

Avoid loading MSC whilst Cruise Ships are in harbour. Schedule around Cruise Ships.

Weather conditions

Surge

Conflicting shipping activities

Lack of communication from shipping agents

Ship Scheduling Conflicts

Containers on port for extended period.

Unplanned arrival of containers on Port.

Adverse public perception.

Loss of Trade or Tourism Opportunities

6 - Interruption to services /

Stakeholder impact

1 1 1 Low

MWPA ControlsPIL-PRO-001/FRM05a Application for Berth to be submitted 4 days prior to arrival.- Dangerous goods must be shown separately, and notice given on the prescribed AMSA forms- A loading plan must be submitted with this berth application- Vessel vetting process

Iluka Controls- When chartering vessel confirm ship is certified under International Maritime Solid Bulk Cargoes code to carry radioactive material low specific activity (LSA-1) UN2912.- Containers not released until Berth is handed over. Stored at Narngulu.

Stevedore- TMP submitted prior to vessel loading- Triples confirmed and can be used for transport down Transport Corridor

1 1 1 Low Iluka - Supply Chain Manager

6 - Interruption to services /

Stakeholder impact

1 2 2 Low

MWPA ControlsMWPA Operations Supervisor - MWPA key point of contact during loading operations.Communication to Port Users via Daily Works Update - Wharf SupervisorMAR-PRO-001 BERTH OPERATOR HANDOVER- Outlines sign-off standards and hand over process.- For Berth 6 the stevedore is the Berth Operator. - All equipment and plant brought to site is removed, any damage is repaired (or reported to MWPA) and the berth is left in a clean, tidy and safe state.MAR-PRO-001/FRM01 Berth Operator Handover Checklist - Completed with the Duty Wharf Supervisor. HSE-PRO-028 Loading Metal Concentrates via Container;- Pre-start meeting held between MWPA, ILUKA and QUBE prior to loading commencing.- MWPA Operations Manager is the Registered Manager under the jurisdiction of the Mines Safety and Inspection Act for this operation.- Access to the berth during loading is to be limited to operational staff only- All personnel entering the area must wear mandatory PPE.- Signage is deployed: “Hazardous Cargo Loading”, "Mandatory PPE" requirements listed.- All personnel inducted and hold a MSIC.HSE-PRO-005 Incident Reporting and Investigation.- All incidents are to be reported to MWPA and entered into incident databaseHSE-PRO-013 Waste management procedures- Concentrates are allocated Pale Blue wheelie bins for PPE disposal.HSE-PLN-003 Occupational Hygiene Risk Assessment And Surface Ventilation Plan- Covers metal concentrate monitoring.- Exposure Standards for Atmospheric Contaminants in the Occupational Environment [NOHSC: 3008(1995)].

1 1 1 Low MWPA Operations Manager

1 - WH&S (injury or illness)

1 2 2 Low

Iluka ControlsILUKA Radiation Management Plan (IRMP)IRMP: Specific radiation training for workers is mandatory if employees need to enter classified areas. Under the ILUKA IRMP Berth 6 MSC loading will be considered a "Restricted" area.

Training will be carried out every 2 years and training records will be stored on the Iluka training database. MSC transport drivers will be provided with radiation training specific to the nature of their tasks and potential exposures. (Training is assessed)

1 1 1 LowILUKA - Product and

Transport Coordinator (Port Supervisor)

7 - Reputation 2 2 4 Low

Iluka ControlsIluka's Radiation Management Plan (IRMP)- Trucks placarded, records of weights, consigners declaration form, emergency procedures.- Haulage Truck driver responsibilities and awareness (e.g. trained in Emergency response and hazards of product)- The transportation of mineral sands concentrate will be overseen by the Iluka RSO or Deputy RSO (Eneabba or Narngulu). The RSO or deputy RSO undertakes random checks of MSC trucks to ensure all required measures are implemented as required by the licence and the approval of this RMP.

MSC will be handled in accordance with the code of practice for Safe Transport of Radioactive Material (ARPANSA 2014) and licensed under the Radiation Safety Act (1975) Section 36 .

Iluka Emergency Response Plan in place with haulage contractor (QUBE). In an emergency any spilled material would be recovered and returned to Iluka. Gamma surveys would be carried out after the incident to ensure gamma radiation levels were within an expected background range of radiation (not elevated above what would be normal). In the event of any serious incident outside the Port precinct the Iluka Narngulu site Emergency Crisis Team would be activated.

SJP MW RMP 08 Transport of radioactive material

2 1 2 Low Iluka - Supply Chain Manager

1 - WH&S (injury or illness)

2 2 4 Low

Transport Company Controls(Qube) self imposed speed restrictions for certain intersections - Safe Work Procedures for Loading Containers onto Trucks and inspecting prior to departure. 2 1 2 Low Iluka - Supply Chain

Manager

5 - Community 3 2 6 Moderate

MWPA ControlsEMR-PLN-001 Emergency Response Plan - ERP 05 - Dangerous Goods/Hazardous Material ReleaseMWPA/Iluka Community consultation plans

3 1 3 LowMWPA Harbour

Documents

Attachment 3A · 2019. 12. 3. · Table 1- Mineral Assemblage Eneabba Mineral Sands Concentrate MINERAL TYPICAL RANGE % BY WEIGHT Zircon 21.3 – 26.5 Rutile 1.0 – 1.3 Monazite