Marandoo Mine Phase 2 - EPA WA | EPA Western …epa.wa.gov.au/sites/default/files/Proponent_response_to...strategen Marandoo Mine Phase 2 PIR08007.01_MMP2 PER_Response to submissions_FINAL

Marandoo Mine Phase 2 Response to Submissions

Prepared for Rio Tinto by Strategen May 2009

Marandoo Mine Phase 2 Responses to submissions

Strategen is a trading name of Strategen Environmental Consultants Pty Ltd Suite 7, 643 Newcastle Street Leederville WA ACN: 056 190 419 May 2009

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Client: Rio Tinto

Report Version Prepared by Reviewed by Submitted to Client

Copies Date

Preliminary Draft Report V1 CM/MB/BS CW Electronic 18 December 2008

Draft Report V2 CM/MB/BS CW Electronic 17 February 2009

Draft Report V3 BS KO Electronic 13 March 2009

Final Report FINAL BS - Electronic 20 May 2009

s t rategen Marandoo Mine Phase 2

PIR08007.01_MMP2 PER_Response to submissions_FINAL - 20/05/2009

TABLE OF CONTENTS

1. INTRODUCTION 1 1.1 MARANDOO MINE PHASE 2 PROPOSAL 1

1.2 ASSESSMENT PROCESS 1

1.3 PURPOSE AND STRUCTURE OF DOCUMENT 1

2. ADDITIONAL STUDIES AND PROPOSED INVESTIGATIONS 4 2.1 OVERVIEW 4

2.2 ADDITIONAL VISUAL AMENITY ASSESSMENT – ACCOMMODATION CAMP 4

2.3 ONGOING AND PROPOSED HYDROGEOLOGICAL INVESTIGATIONS 9

2.3.1 Minthicoondunna Spring 9

2.3.2 Groundwater chemistry 11

2.4 ONGOING CLOSURE INVESTIGATIONS 14

2.5 PROPOSED SOUTHERN FORTESCUE RIVER SYSTEM AQUATIC FAUNA MONITORING PROGRAM 14

3. ADDITIONAL AND ONGOING CONSULTATION 16 3.1 CONSULTATION SINCE SUBMISSION OF THE PER 16

3.1.1 Meeting with the Martu Idja Banyjima Native Title Claim Group 16

3.1.2 Meetings with the Department of Water 16

3.1.3 Meeting with the Department of Environment and Conservation 17

3.2 PROPOSED ONGOING CONSULTATION 17

4. SUMMARY OF SUBMISSIONS RECEIVED 18 4.1 KARIJINI NATIONAL PARK 18

4.2 GROUNDWATER AND GROUNDWATER QUALITY 19

4.3 WATERCOURSES AND SURFACE WATER QUALITY 21

4.4 FLORA AND VEGETATION 21

4.5 COOLIBAH WOODLAND 22

4.6 TERRESTRIAL FAUNA 22

4.7 SUBTERRANEAN FAUNA 22

4.8 ABORIGINAL HERITAGE 22

4.9 VISUAL AMENITY AND LANDSCAPE CHARACTER 23

4.10 CLOSURE AND REHABILITATION 23

4.11 WASTE 24

4.12 GREENHOUSE GASES 24

4.13 NOISE AND VIBRATION 24



4.14 RECREATION AND TOURISM 24

4.15 MISCELLANEOUS SUBMISSIONS 24

5. CONSOLIDATED PROPONENT RESPONSES – KEY ENVIRONMENTAL FACTORS 26 5.1 OVERVIEW 26

5.2 KARIJINI NATIONAL PARK 26

5.2.1 Submissions received 26

5.2.2 Proponent responses 26

5.3 GROUNDWATER AND GROUNDWATER QUALITY 28















6. DETAILED RESPONSE TO SUBMISSIONS 51 6.1 OVERVIEW 51

6.2 KARIJINI NATIONAL PARK 52

6.3 GROUNDWATER QUANTITY AND QUALITY 53


6.5 FLORA AND VEGETATION 73


6.7 TERRESTRIAL FAUNA 78

6.8 SUBTERRANEAN FAUNA 79



6.11 HEALTH 89



6.12 MISCELLANEOUS ISSUES 92

7. REFERENCES 100

LIST OF TABLES

1. Significance of visual impact of the accommodation camp 8

2. Southern Fortescue River system sampling program 15

3. Response to submissions relating to Karijini National Park 52

4. Response to submissions relating to groundwater quantity and quality 53

5. Response to submissions relating to watercourses and surface water quality 70

6. Response to submissions relating to flora and vegetation 73

7. Response to submissions relating to the Coolibah woodland 76

8. Response to submissions relating to terrestrial fauna 78

9. Response to submissions relating to subterranean fauna 79

10. Stygofauna records from the DEC Pilbara Biological Survey from the Marandoo locality 80

11. Response to submissions relating to visual amenity 83

12. Response to submissions relating to closure and rehabilitation 86

13. Response to submissions relating to health 89

14. Response to miscellaneous issues 92

LIST OF FIGURES

1. Public Environmental Review procedure 3

2. Receptor 1 – Mount Bruce lowest lookout point, existing view looking west towards the proposed camp area 5

3. Receptor 1 – Mount Bruce lowest lookout point, preliminary simulated view looking west towards the proposed camp 5

4. Receptor II – Mount Bruce summit main lookout, existing view looking west towards the proposed camp 6

5. Receptor II – Mount Bruce summit main lookout, preliminary simulated view looking west towards the proposed camp 6

6. Receptor VIII – Hamersley Gorge-Mount Bruce Road, existing view from road looking north-east towards the proposed camp area 7

7. Receptor VIII – Hamersley Gorge-Mount Bruce Road, preliminary simulated view from road looking north-east towards the proposed camp 7

8. Location of existing and proposed groundwater monitoring bores 10



9. Ionic ratios of Minthicoondunna Spring and production bores 12

10. Ionic concentrations of pools sampled 13

11. Sample hydrograph 1 of 3 31



14. Extent of clay beneath the Mount Bruce Flats 34

15. Extent of clay beneath the Mount Bruce Flats (cross-section 1 of 2) 35

16. Extent of clay beneath the Mount Bruce Flats (cross-section 2 of 2) 36

17. Differential heads in nested piezometers on the Mount Bruce Flats 37

18. Differential heads in nested piezometers in the down-dip areas of Marandoo 38

19. Marandoo groundwater model boundaries 39

20. Groundwater drawdown cross-section 40

21. Cross-section A-A’ through the Marandoo groundwater model 41

22. Southern Fortescue borefield groundwater model domain 43

23. Southern Fortescue borefield re-injection modelling scenarios 44

24. Rainfall response of the confined and unconfined aquifer at Marandoo 69

25. Location of subterranean fauna sampling sites 1999–2008 in relation to geology 81

26. Location of subterranean fauna sampling sites 1999–2008 in relation to groundwater drawdown 82

LIST OF APPENDICES

1. Documents provided to the Martu Idja Banyjima Native Title Claim Group

2. Hydrographs for the Marandoo area

3. Hydrographs for the Southern Fortescue borefield


PIR08007.01_MMP2 PER_Response to submissions_FINAL - 20/05/2009 1

1. INTRODUCTION

1.1 MARANDOO MINE PHASE 2 PROPOSAL

The Proponent, Hamersley Iron Pty Ltd, proposes to extend the life of the existing Marandoo Iron Ore Mine (Marandoo), located in the central Pilbara region, Western Australia. Mining at Marandoo commenced in 1994 and currently up to 15 million tonnes per annum (Mtpa) of high-grade Marra Mamba iron ore is produced at the mine through mining operations located above the watertable. Marandoo operates under the Iron Ore (Hamersley Range) Agreement Act 1963 (WA), within a mining lease excised from Karijini National Park in 1991.

The Proponent proposes to extend existing mining operations at Marandoo by mining below the watertable, whilst maintaining the same maximum production rate of approximately 15 Mtpa. This will entail expansion of the existing mine pit and development of new waste dumps. Where possible, the Proposal will utilise existing infrastructure and services associated with current Marandoo mine operations; however, new infrastructure will still be required to be constructed to service the expanded operations. Construction of dewatering infrastructure and an accommodation camp associated with the development are subject to separate environmental approvals; however, the operation of this infrastructure was considered as part of the Proposal.

Minor change to Proposal

Since originally described in the Public Environmental Review (PER), a minor change to the Proposal has resulted from ongoing design and planning studies. The new below-ground 33 kV power line to be installed along the infrastructure corridor to the operations camp described in Section 4.9 of the PER will now be above-ground.

1.2 ASSESSMENT PROCESS

The Proposal was referred to the Environmental Protection Authority (EPA) under section 38 of the Environmental Protection Act 1986 (WA) (EP Act) on 3 July 2007. In December 2007, the EPA determined the Proposal would be assessed at the level of PER with an eight week public review period. In accordance with the EP Act, a PER document was prepared which described the proposal and its likely effects on the environment (Rio Tinto 2008). The PER was released for public comment on 29 September 2008, with the public submission period closing on 25 November 2008 (Figure 1). The EPA extended the public review period until 5 January 2009 to accommodate supplementary submissions from four organisations.

1.3 PURPOSE AND STRUCTURE OF DOCUMENT

The Environmental Impact Assessment (Part IV Division 1) Administrative Procedures 2002 state that the proponent is required to prepare a summary of the pertinent issues raised in public and government agency submissions. The proponent is then required to respond in writing to the summary of issues and any other issues the EPA considers need to be addressed and, where appropriate, amend the proposal and environmental commitments.



The purpose of this document is to provide a summary of submissions on the Marandoo Mine Phase 2 PER and respond to the matters raised in the submissions. Submissions and responses have been grouped according to the environmental factor they addressed (e.g. flora, fauna, surface water).

This document comprises six sections as follows:

1. Introduction: outlines the Proposal, the environmental impact assessment process and the purpose and structure of the document.

2. Additional studies and proposed investigations: describes studies undertaken since the release of the PER and investigations proposed to be undertaken.

3. Additional and ongoing consultation: describes consultation undertaken since the release of the PER and consultation proposed to be undertaken.

4. Summary of submissions received: summarises the submissions received from government agencies and the public.

5. Consolidated Proponent responses – key environmental factors: provides consolidated Proponent responses to the key environmental factors commented on in submissions.

6. Detailed Proponent responses to submissions: provides detailed Proponent responses to each individual comment raised in the submissions.

Figure 1Public Environmental

Review Procedure

Plan No: PDE0049509v1Date: August 2008

Outline of Procedure for PER Assessment



2. ADDITIONAL STUDIES AND PROPOSED INVESTIGATIONS

2.1 OVERVIEW

Further assessment of potential visual impacts associated with the proposed accommodation camp has been undertaken since the PER was released for public comment in September 2008. A summary of the preliminary results of this assessment is provided in Section 2.2.

The PER indicated several surface water and groundwater-related monitoring programs/investigations were either ongoing or due to be implemented as part of the proposed management strategy (refer to the Environmental Management Plan contained in Appendix 2 of the PER). Additional information on these ongoing and proposed monitoring programs/investigations (and preliminary results where available) is summarised below in Sections 2.3–2.5.

2.2 ADDITIONAL VISUAL AMENITY ASSESSMENT – ACCOMMODATION CAMP

A landscape and visual assessment of the Proposal was undertaken and presented in Section 5.9 in the PER. The assessment considered the operational aspects of the Proposal, including the accommodation camp. A photomontage of the view towards the accommodation camp from the Hamersley–Mount Bruce Road (Receptor VIII) was produced as part of this assessment (refer to Figure 51 in the PER). In response to comments raised in the Department of Environment and Conservation (DEC) submission, the Proponent commissioned Sinclair Knight Merz (SKM) to undertake additional work to further classify and assess the visual impact of the accommodation camp from key receptors. This work is ongoing; however, a summary of the preliminary findings is provided below.

The landscape and visual assessment process for the camp followed the same methodology as that used for the original assessment presented in the PER and is based on the guidance provided in Landscape Institute and the Institute of Environmental Management and Assessment (2002) and Department for Planning and Infrastructure (2007).

A 3-D model was developed of the accommodation camp at the following stages of development:

1. Construction camp only.

2. Construction and operations camp.

3. Operations camp only (after removal of the construction camp).

The model was used to generate photomontages from the following locations:

• two locations on Mount Bruce (Receptors I and II)

• along Hamersley-Mount Bruce Road (Receptor VIII).

The preliminary photomontages, along with the existing view of the proposed camp site, are presented in Figure 2 to Figure 7.

Receptor 1 – Mount Bruce lowest lookout point, preliminary simulated view looking west

towards the proposed camp Figure 3

Receptor 1 – Mount Bruce lowest lookout point, existing view looking west towards the

proposed camp area Figure 2

Receptor II – Mount Bruce summit main lookout, preliminary simulated view looking west

towards the proposed camp Figure 5

Receptor II – Mount Bruce summit main lookout, existing view looking west towards the

proposed camp Figure 4

Receptor VIII – Hamersley Gorge-Mount Bruce Road, preliminary simulated view from road

looking north-east towards the proposed camp Figure 7

Receptor VIII – Hamersley Gorge-Mount Bruce Road, existing view from road looking north-

east towards the proposed camp area Figure 6



Persons visiting the lowest lookout point on Mount Bruce (Receptor I) or walking down the access track may experience glimpse views westwards towards the proposed camp, most notably of the roofs and eastern faces of camp buildings (Figure 3). The magnitude of visual impacts is diminished by the significant distance between Receptor I and the location of the proposed camp, as well as the degree to which the camp will be set into the surrounding landform (most notably the hills to the west of the camp). When viewed from Receptor I, the camp buildings will not exceed the ridgeline to the west of the proposed camp.

From the lowest lookout point, the screening effect of the vegetation bordering the eastern extent of the proposed camp access road will be visible (Figure 3). Views of mine vehicles traversing the road will be inhibited by this vegetation.

From the summit of Mount Bruce (Receptor II), the proposed camp and access road will be visible from the valley to the west (Figure 5); however, the significant distance between the receptor and the proposed camp will reduce the visual prominence of the proposed camp and access road. When viewed from Receptor II, the camp buildings will not exceed the ridgeline to the west of the proposed camp. The proposed camp access road is likely to be visible from this location (Figure 5).

The Hamersley Gorge–Mount Bruce Road is the closest receptor to the proposed camp (Figure 7). Views of the camp from stretches of the road to the north and northeast of the camp are likely to be obscured by dense scrub and trees. Very occasional glimpse views of the camp buildings may be possible for people driving east or west but only in areas where vegetation is less prominent. Views of the camp may be more prominent as the road rises slightly above the valley floor. Intermittent, partially-screened views of the camp may be possible, most notably for people driving in an easterly direction along the road.

The visual impact of the accommodation camp at Receptors I–VIII (refer to Figure 39 in the PER for receptor locations) was assessed using the methodology described in Section 5.9 in the PER. This involved rating the significance of the visual impact of the accommodation camp at each visual receptor on a scale from ‘Major Beneficial’ to ‘Severe Adverse’. The assessment was based on the construction and operations camp (Stage 2 listed above), which has the largest footprint of the three stages and would therefore have the greatest potential for visual impact to the surrounding landscape. The assessment assumed coloured colour-bond materials suitable for the environment are used in the construction of facilities rather than use of white materials. The assessment determined that the visual impact of the accommodation camp will range from Neutral to Moderate Adverse (Table 1).

Table 1 Significance of visual impact of the accommodation camp

Receptor Visual impact

I Slight – Moderate Adverse

II Slight Adverse

III Neutral – Slight Adverse

IV Neutral

V Neutral – Slight Adverse*

VI Neutral

VII Slight – Moderate Adverse*

VIII Moderate

* Visual impact at these locations was assessed without the benefit of photos taken from these locations.



2.3 ONGOING AND PROPOSED HYDROGEOLOGICAL INVESTIGATIONS

2.3.1 Minthicoondunna Spring

As described in the Groundwater Management Plan (refer to Appendix 2 in the PER), the Proponent will undertake further hydrogeological investigations to determine the level of risk to Minthicoondunna Spring from the proposed dewatering. This will involve installation of shallow observation bores to the top of the clay layer, as well as deeper piezometers tapping the basement aquifer between the most eastern extent of the proposed mine pit and Minthicoondunna Spring. The location of existing and proposed groundwater monitoring bores is depicted in Figure 8. The investigations will allow the Proponent to determine:

• the hydraulic gradient of the upper tertiary sediments between the proposed mine void and the spring, as well as the connection between the upper and lower confined aquifer at this location

• the presence or absence of the clay layer that occurs extensively across the Mount Bruce Flats

• further quantification of when, if at all, the cone of depression will extend in a south-easterly direction towards Minthicoondunna Spring.

Separation of the effects on water levels of climate change and dewatering will be achieved by analysing historical groundwater level and rainfall data to determine existing trends and relationships. The relationship between the groundwater level and rainfall patterns will allow some understanding of how recharge varies and the amount of groundwater in storage.

Isotope studies and further analyses of groundwater chemistry will also be conducted to assist the investigations.

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2.3.2 Groundwater chemistry

An assessment of both spring and gorge water, which utilised field chemistry measurements, was undertaken by the Proponent and presented in Section 5.1 in the PER. To build upon this initial assessment, the Proponent has, in conjunction with a Masters level project by Canterbury University (New Zealand), used the CSIRO laboratories to further analyse water samples for stable isotopes (δO18 and δH2), chlorofluorocarbons and Carbon-14 to:

• further characterise the source of spring and gorge water in Karijini National Park by using hydrochemistry and environmental isotopes of surface water (natural gorge) and groundwater (springs)

• further understand the flow and transport mechanism in the system.

These groundwater chemistry studies are in progress. Preliminary results are depicted in Figure 9 and Figure 10 and are summarised as follows:

• there is no evidence of hydraulic connection between Marandoo and most of the Karijini National Park catchments

• the relatively low concentration of Cl in most of the gorges relative to Marandoo groundwater precludes same source origin

• the overall chemical composition of Minthicoondunna Spring is similar to that of Marandoo groundwater, although different ionic ratios may suggest a different recharge mechanism

• Hamersley Gorge groundwater may originate from the same catchment as the Southern Fortescue borefield

• geochemical modelling would indicate that groundwater chemistry of Minthicoondunna Spring is most likely evolved from evaporation of water related to the shallow aquifer and less likely from the deep aquifer (if the source of groundwater was the Marandoo deep aquifer, Mg, SO4 and K concentrations would be expected to be 50%, 20% and 50% lower respectively than measured concentrations in Minthicoondunna Spring).

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2.4 ONGOING CLOSURE INVESTIGATIONS

As described in the PER, post-closure development of pit lakes and the associated potential impacts to groundwater quality at Marandoo are subject to ongoing numerical modelling (refer to Section 5.10.4 in the PER). This work forms part of a collaborative research project with UWA investigating the geochemistry of mine voids in the Pilbara, including pits containing sulphidic material and pits containing non-sulphidic material (e.g. Marandoo).

For Marandoo, the objective of the research project is to predict the final void water quality (i.e. what is the water quality as the lake is filling and how will the water quality evolve over time?). The project will involve developing a methodology/process for iterative coupling of 3D groundwater flow output with 1D dynamic reservoir models for groundwater recovery rates and pit void water quality assessment. The project will investigate several closure scenarios for Marandoo (e.g. void is not backfilled and surface water is diverted around the void; void is not backfilled and surface water is diverted into the void; void is backfilled sufficiently to create a throughflow system and surface water is diverted around the void; etc.) to answer the following questions:

1. Do some scenarios result in improved surface water quality (short-term, long-term)?

2. Will a perennial lake result?

3. If a throughflow lake evolves, what is the effect on surrounding groundwater quality and how will this change with time?

Modelling is anticipated to be finalised following commencement of the proposed operations, when aquifer conditions are more fully understood. Preliminary results are anticipated at the end of 2009.

2.5 PROPOSED SOUTHERN FORTESCUE RIVER SYSTEM AQUATIC FAUNA MONITORING PROGRAM

A baseline aquatic fauna assessment of the Southern Fortescue River and its tributaries was undertaken in June 2008 and presented in Section 5.3 in the PER. The assessment identified sampling locations and parameters for the aquatic systems monitoring program described in the Surface Water Management Plan (refer to Appendix 2 in the PER). The sampling program has been designed to assess the potential environmental impact of surface discharge of excess dewatering water into tributaries of the Southern Fortescue River system.

The Proponent commissioned Wetland Research and Management (WRM) to commence this monitoring program. The first round of monitoring is scheduled for March 2009 after substantial seasonal rains and when residual pools are still present (i.e. two to three weeks after wet season flows). The program will involve sampling water quality and aquatic fauna along tributaries of the Southern Fortescue River system and at Hamersley Pool at the head of Hamersley Gorge (Table 2).

The sampling program has been designed to link-in with other targeted and regional studies already being conducted for the Proponent’s Hope Downs 1 (Weeli Wolli Creek), Yandi (Marillana Creek) and Hope Downs 4 developments (Coondiner and Mindy Mindy Creeks), whereby water quality, fish and aquatic invertebrates are routinely sampled to establish baseline conditions and assess impacts.



Table 2 Southern Fortescue River system sampling program

Abbreviations: DO – dissolved oxygen; EC – electrical conductivity; NTU – Nephelometric Turbidity Units.

The sampling design to establish fauna composition, conservation significance and baseline conditions for the tributaries of the Southern Fortescue River system includes:

• six replicate sites upstream and six replicate sites downstream of the discharge point on each of the two creeklines that will be discharged into

• six replicate sites on the Southern Fortescue River system between the confluence of the headwater creeks and the northern end of the Southern Fortescue borefield

• six replicate sites on adjacent, unaffected control/reference headwater creeklines of the Southern Fortescue River system, with one site per creekline.

Parameter Sampling method Sampling location

Macroinvertebrates 250 µm mesh sweep net 1. Hamersley Pool at the head of Hamersley Gorge 2. Representative pools:

(a) downstream of the dewatering discharge (potential impact sites)

(b) upstream of the dewatering discharge (upstream control sites)

(c) in adjacent creeklines (reference sites).

Microinvertebrates 50 µm mesh sweep net

Fish Seine net, gill net, fyke net, electrofisher, visual observations

Water quality (pH, DO, EC, NTU, temperature, Total-N, Total-P, ions, metals)

In situ using calibrated meters and laboratory-based from water samples (0.45 µm filtered and unfiltered)

Incidental aquatic fauna (e.g. frogs and tortoises)

As sampled using above methods



3. ADDITIONAL AND ONGOING CONSULTATION

3.1 CONSULTATION SINCE SUBMISSION OF THE PER

3.1.1 Meeting with the Martu Idja Banyjima Native Title Claim Group

The Proponent held an information session in Tom Price on 10 November 2008 with members of the Martu Idja Banyjima Native Title Claim Group (MIB). Attendees were invited via the group coordinator/facilitator and comprised two members of the MIB, a legal counsel representative for the MIB, four members of the Wintawari Guruma Aboriginal Corporation and Professor Jorg Imberger of UWA.

The session was held in response to MIB interest in the Proposal and was intended to provide the group with an overview of the Proposal, the environmental approvals process and water management aspects. The session was facilitated by, and comprised PowerPoint presentations from, the Proponent. Questions, comments and discussions were encouraged at all times throughout the session.

Key questions/comments raised during the session were:

• the ability to backfill to ground level

• the potential for water from the unconfined aquifer to flow into the mine pit

• the use of groundwater chemistry to model flow paths

• employment opportunities

• support and assistance for Aboriginal communities from the Proponent

• the cultural significance of Minthicoondunna Spring (Site ID 8296) needs to be taken into consideration

• prevention of further sinkhole formation at the Southern Fortescue borefield.

Following the information session, a written request was received from Ngudarra Banyjima (letter dated 11 November 2008) for some of the documents referenced in the PER. A selection of these documents was provided by the Proponent (some reports could not be provided as they are commercially sensitive). The documents provided are listed in Appendix 1.

3.1.2 Meetings with the Department of Water

The following hydrogeological reports (referenced in the PER) were requested by and provided to the Department of Water (DoW) during the public review period:

• Liquid Earth 2005, Marandoo Hydrogeological Investigation Report, unpublished report prepared for Pilbara Iron, August 2005.

• MWH Australia Pty Ltd (MWH) 2006a, Marandoo Model Development 2006, unpublished report prepared for Pilbara Iron, May 2006.

• MWH Australia Pty Ltd (MWH) 2006b, Marra Mamba BWT Project – Dewatering and Re-injection Program, unpublished report prepared for Pilbara Iron, April 2006.



Subsequent to the public review period, meetings were held with the DoW on 11 December 2008 and 12 February 2009 to discuss the key matters raised in the DoW submission on the PER. In these meetings an overview was provided on the hydrogeology of the Proposal area. Discussion focused on:

• the clay layer and the resultant disconnection between the confined and unconfined aquifers

• the hydrology/hydrogeology associated with the Coolibah woodland and Minthicoondunna Spring

• predicting potential impacts based on current knowledge, including sinkhole formation

• surface water discharge.

The PowerPoint presentation on hydrogeology that the Proponent presented to the MIB at the meeting on 10 November 2008 was also provided to the DoW in December 2008.

3.1.3 Meeting with the Department of Environment and Conservation

The three hydrogeological reports provided to the DoW during the public review period were also requested by, and provided to the DEC.

Subsequent to the public review period, a meeting was held with the DEC on 10 March 2009 to discuss the key hydrogeological matters raised in the DEC submission on the PER. Discussion in this meeting focussed on:

• the hydrogeology of the Proposal area, including presentation of cross-sections and hydrographs

• groundwater quality data collected to demonstrate the source of water in various pools

• ongoing hydrogeological investigations proposed

• the nature of the clay layer.

3.2 PROPOSED ONGOING CONSULTATION

The Proponent will continue to meet with stakeholders, including the Traditional Owners, as required and requested throughout the remainder of the PER assessment process.

The Proponent and the DEC have agreed in principle on a consultative process to address issues of potential environmental impact arising from the Marandoo operation by way of a Statement of Mutual Understanding (SMU). The Proponent will continue to consult with the DEC and Karijini National Park management bodies in accordance with existing arrangements under the SMU. The Proponent and the DEC meet typically twice each year to discuss matters relevant to the SMU. DEC officers that typically attend these meetings include the Operations Manager, Environment Officer (Pilbara-based), Parks and Visitor Coordinator, and the Karijini National Park Ranger. The meetings are the appropriate forum to inform the DEC of any new or potential events relevant to the Proposal.



4. SUMMARY OF SUBMISSIONS RECEIVED

Fourteen (14) submissions on the Marandoo Mine Phase 2 PER were received. Submissions were initially received from ten submitters; however, four submitters provided addendums to their initial submissions and these addendums have been included in the count of submissions. Submissions were received from:

1. Government agencies (8 submissions):

• Department of Environment and Conservation (DEC)

• DEC – Addendum

• DEC Noise Branch

• Department of Water (DoW)

• DoW – Addendum

• Department of Industry and Resources (DoIR) (now Department of Mines and Petroleum)

• Department of Health (DoH)

• Tourism Western Australia.

2. Non-government and/or community group organisations (5 submissions):

• Conservation Council of Western Australia (CCWA)

• Wintawari Guruma Aboriginal Corporation

• Wintawari Guruma Aboriginal Corporation – Addendum

• Martu Idja Banyjima Native Title Claim Group

• Martu Idja Banyjima Native Title Claim Group – Addendum.

3. Confidential (1 submission).

4.1 KARIJINI NATIONAL PARK

All submissions commented on or questioned the predicted effects the Proposal would have on the values of Karijini National Park. Some of these comments are summarised in this section, while others are discussed under different sections dealing with specific components of the environment (e.g. comments regarding the Coolibah woodland within Karijini National Park are addressed in Section 4.5)

The CCWA stated that Karijini National Park should be absolutely protected from impacts from mining and that normal management and risk assessment is not appropriate given the proximity of the Proposal to the National Park.

Impacts to springs and pools • Several submissions commented on the risk of groundwater drawdown affecting springs in

Karijini National Park.



• The DEC and both Aboriginal groups commented that the extent of the risk to springs and pools is unclear and stated that further investigation is required.

• The DoW and both Aboriginal groups requested additional information on the methodology the Proponent intends to use to monitor springs and pools within Karijini National Park.

• The DEC stated that the Groundwater Management Plan does not adequately explain or manage potential impacts to pools and springs within Karijini National Park.

• Both Aboriginal groups suggested that management actions, to be implemented if monitoring results show any signs of impacts to springs, are problematic and will be ineffective.

• The confidential submission stated that the Proponent should be liable for any damage to springs, pools and gorges within Karijini National Park.

Impact of workforce • The DEC commented on the effect of the workforce on Karijini National Park and suggested the

Proponent commit to the monitoring and management of workforce behaviour in the Park.

• The DEC recommended that the Proponent provide resources to support additional ranger staff in Karijini National Park during the peak construction period.

4.2 GROUNDWATER AND GROUNDWATER QUALITY

Several submissions commented on groundwater aspects. Most comments related to the impacts of groundwater drawdown from dewatering, the impacts of re-injecting water into the Southern Fortescue borefield and the potential for sinkhole development. Comments regarding the effect of groundwater drawdown on the Coolibah woodland in Karijini National Park are summarised in Section 4.5.

Groundwater modelling • The DEC stated that the groundwater modelling is not sophisticated enough to predict impacts to

the unconfined aquifer and, therefore, not sophisticated enough to predict impacts to groundwater dependent ecosystems.

• The DEC considered that a much higher resolution model for the unconfined aquifer is required.

• The DEC considered that a sensitivity analysis of the groundwater modelling should be conducted.

• The CCWA commented on the Proponent’s previous performance in groundwater modelling and managing subsequent impacts from dewatering at Hope Downs (Weeli Wolli Creek).

• Both Aboriginal groups requested confirmation or correction of the assumptions made for the groundwater modelling, and considered that many of the objectives of the groundwater modelling were not met.

• Both Aboriginal groups commented on several aspects of the groundwater modelling, stating that the broad-scale aquifer variability was not captured, the model boundary conditions were inadequate, and the observation bores were not placed in appropriate locations.

• Both Aboriginal groups questioned why the modelling did not consider future climate change scenarios.



Groundwater drawdown • The DoW and both Aboriginal groups requested more information on the modelled groundwater

drawdown and clarification on what types of drawdown effects will occur.

• The DoW suggested that the Proponent would not be able to satisfactorily monitor groundwater levels without the installation of additional monitoring bores within Karijini National Park, and stated that the DEC and EPA should consider whether the installation of new bores within the boundaries of the National Park is acceptable.

• The DoW requested cross-sections of the predicted groundwater drawdown levels.

• The CCWA stated that any impacts to the unconfined aquifer due to the pit will be permanent.

Re-injection of dewatering water into the Southern Fortescue borefield • Several submissions commented on the viability, management and effects of re-injecting

dewatering water into the Southern Fortescue borefield and requested further modelling or assessment of the impacts of re-injection.

• The DoW suggested the Proponent should have a greater range of contingencies in place for the management of excess water if the capacity of the Southern Fortescue borefield is less than expected.

• The DoH suggested the Proponent confirm that the injection of dewatering water at the Southern Fortescue borefield is agreeable to the DoW Source Protection Group.

• The DEC requested the Proponent provide a rationale to support the 5 m trigger level for reducing or discontinuing injection at the Southern Fortescue borefield.

Sinkholes • Several submissions commented the potential development of sinkholes, particularly in Karijini

National Park, as a result of dewatering.

• The CCWA and DoW stated that sinkhole development in Karijini National Park would be unacceptable.

• The DEC and CCWA requested that further investigation into the potential risk and measures to avoid or minimise the formation of sinkholes be undertaken.

• The DEC and DoW stated that prevention and remediation strategies for sinkholes should be developed.

• The DEC requested a communications protocol be developed to ensure they are regularly informed of any new or potential sinkhole areas forming in Karijini National Park.

Aquifer connection • Several submissions stated that the assertion that the confined and unconfined aquifers were

hydraulically disconnected was not adequately justified, and requested more information and/or investigation on the connectivity between the two aquifers.

• The DEC requested the investigation into the presence of potential preferential flow paths in the swelling clays around the Mount Bruce Flats, which may affect water levels in the unconfined aquifer.



4.3 WATERCOURSES AND SURFACE WATER QUALITY

Several submissions commented on surface water. Most comments were in relation to the impact of discharging excess water into ephemeral tributaries of the Southern Fortescue River system.

Discharge of dewatering water into tributaries of the Southern Fortescue River system • The CCWA stated that discharge of dewatering water into tributaries of the Southern Fortescue

River system should not be allowed.

• The DoW and DEC requested that the Proponent develop stronger contingencies in relation to the discharge of excess water to prevent creating permanently flowing systems.

• The DEC requested that the Proponent investigate alternative discharge locations and provide a rationale for their selection.

• The DEC, DoW and both Aboriginal groups commented that there was inadequate information to support assertions made regarding the effects of discharge into the Southern Fortescue River system.

• The DEC requested further information and investigation on the impacts of the proposed discharge of excess dewatering water.

• The DoW requested further information to demonstrate that the Proponent fully understands the capacity of the ephemeral tributaries.

• The DEC stated that the Proponent should prepare an Environmental Discharge Monitoring, Management and Restoration Plan in consultation with DEC.

Stormwater discharge into drainage lines • The DEC requested that the Proponent monitor the surface water quality entering the drainage

lines and develop appropriate triggers to ensure the Mount Bruce Flats are not adversely affected as a result of the discharge.

4.4 FLORA AND VEGETATION • The DEC asked that the Proponent commit to eradicating ruby dock within the Proposal area and

include this commitment in its Vegetation and Flora Management Plan.

• Both Aboriginal groups indicated that the flora lists should not be limited to the Proposal area, but should include the surrounding areas that may potentially be affected by groundwater drawdown.

• Both Aboriginal groups commented that it was not clear whether surface vegetation was connected to the groundwater system.

• The DEC asked for verification of the identification of Amaranthus sp. within the Proposal area, and stated that, if the identification is accurate, the species should be managed as a significant range extension.

• The DEC requested information on the methodology employed by Mattiske (2008) to measure stress in Eucalyptus victrix.

• The DEC stated that the focus of the Mattiske (2008) report on only tree species should be recognised as a limitation of the report.



• The DEC commented that weed species present along the creek systems surveyed by Mattiske (2008) should be identified and mapped.

4.5 COOLIBAH WOODLAND • The DEC and CCWA commented that the effect of dewatering on the Coolibah woodland in

Karijini National Park and stated that a groundwater drawdown of 0.5 m may be enough to affect the woodland.

• The CCWA stated that the Proponent should cease dewatering if the coolabah woodland is affected by dewatering.

• The DEC, CCWA and DoW stated that some proposed management triggers and associated management responses in the Coolibah Management Plan should be reconsidered.

4.6 TERRESTRIAL FAUNA • The DEC commented that there were insufficient data on the effect of dewatering water discharge

on fauna and suggested that wider surveys are needed.

• The DEC requested further explanation of the scope and design of the Short Range Endemic fauna survey.

• Both Aboriginal groups indicated that the fauna lists should not be limited to the Proposal area, but should include the surrounding areas that may potentially be affected by groundwater drawdown.

• Both Aboriginal groups commented that is was not clear whether surface fauna was connected to the groundwater system.

4.7 SUBTERRANEAN FAUNA • The DEC commented that the adequacy of the stygofauna sampling is difficult to ascertain and

that previous DEC advice on the stygofauna report has not been fully addressed.

• The DEC and CCWA commented on the potential effects of dewatering and fluctuating groundwater levels on subterranean fauna were not clearly addressed.

• The CCWA stated that any loss of stygofauna within Karijini National Park is unacceptable.

4.8 ABORIGINAL HERITAGE • Both Aboriginal groups stated that there is a risk of impact to springs and pools, particularly

Minthicoondunna Spring (Site ID 8296), for which they have an association with.

• Both Aboriginal groups requested an assessment be conducted on the cumulative impacts of dewatering to the cultural heritage of the Banyjima and Guruma people.

• Both Aboriginal groups indicated that the consultation process conducted by the Proponent was inadequately described in the PER.



4.9 VISUAL AMENITY AND LANDSCAPE CHARACTER

Three submissions commented on the impact to visual amenity of the Proposal, particularly within Karijini National Park.

Impacts of the mine • The DEC commented that the design and management of the mine has not taken into account the

effect on visual amenity in Karijini National Park.

• The DEC commented that the PER downplays the effect of the Proposal on visual amenity.

Impacts of the accommodation camp • The DEC commented that the design and management of the accommodation camp has not taken

into account the impact to visual amenity in Karijini National Park.

• Both the DEC and CCWA commented on the proximity of the camp to Karijini National Park and suggested that a new location be selected.

• Tourism WA determined the location of the camp to be acceptable in terms of visual amenity impacts to Karijini National Park.

4.10 CLOSURE AND REHABILITATION • The DEC commented that the rehabilitation and closure objectives are not consistent with the

values of Karijini National Park and that there is a lack of clarity as to whether the surrounding environment has been considered in the design of post-mining landforms.

• The DEC stated that rehabilitation and closure objectives need to be developed in consultation with and to the satisfaction of the DEC and the Conservation Commission.

• The DEC, CCWA and DoW commented on the degree to which the mine pit is proposed to be backfilled following completion of mining:

• the DEC suggested the mine pit should be backfilled as close as possible to the surrounding ground level

• the DoW suggested the mine pit should be backfilled to at least 1 m above the watertable

• the CCWA stated that the Proponent must be required to backfill above the watertable.

• The CCWA commented that existing rehabilitation by the Proponent should be assessed to ensure it is up to standard before approval is granted.

• The DEC requested preliminary information on the pit lake research being undertaken by The University of Western Australia.

• The DEC stated that seeding using local provenance should be undertaken at all times during rehabilitation and noted that there is a strict provenance requirement for Marandoo given the intended return of the mine area to the National Park.



4.11 WASTE

Wastewater • The DEC requested additional information on the level of wastewater treatment and further

discussion of the potential impacts of disposing wastewater into natural drainage lines.

• The DoH stated that dewatering bores should not be located in proximity to any wastewater disposal areas.

• The DoH highlighted that wastewater treatment plants to serve the mine site and accommodation camp will require approval under the Health (Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations 1974.

Residue Storage Facility • The DoIR requested information on the characterisation of material to be deposited in the Residue

Storage Facility.

4.12 GREENHOUSE GASES • The CCWA commented that the greenhouse gas emissions for the Proposal are significant and

suggested that greenhouse gas emissions from any Proposal should be placed in a cumulative impacts context by the EPA.

4.13 NOISE AND VIBRATION • The DEC Noise Branch accepted that noise emissions from the Proposal will be able to comply

with Noise Regulations as it is remote from any noise sensitive premises.

• The DEC Noise Branch recommended that the Proponent commit to an aspirational target of 45 dB(A) for noise levels at Mount Bruce.

4.14 RECREATION AND TOURISM • Both Aboriginal groups commented that analysis on the likely impacts to tourism in the area had

not been undertaken.

• The confidential submission commented that mine impacts will affect tourism in Karijini National Park in the future.

• Tourism WA stated that the tourism experience in the area should not be affected by the Proposal, including flight or accommodation availability in Tom Price and Paraburdoo.

4.15 MISCELLANEOUS SUBMISSIONS

Camp and dewatering infrastructure • The DEC suggested that the separate assessments for the accommodation camp and dewatering

infrastructure were inappropriate and that they should be included in the PER process.



Fire • The DEC suggested that a Fire Management Plan be developed in consultation with the DEC to

manage the increased risk of fire from the Proposal.

Offsets • The DEC suggested the Proponent address EPA Guidance Statement No. 19 (EPA 2007) and

develop an offsets package, given the potential risks and impacts to key biodiversity and conservation estate assets.

Acid Rock Drainage • The DoIR requested information on the volumes of material with potential to generate Acid Rock

Drainage (ARD) to demonstrate that ARD will not be an issue.

Health • The DoH requested a management program be developed by the Proponent to address the

increased health risk associated with mosquitoes and other nuisance insects.

• The DoH highlighted the requirement for any pesticide usage to be in accordance with the Health (Pesticides) Regulations 1956 and that application of pesticides should be carried out by an appropriately trained person.

• The DoH requested a Drinking Water Quality Management Plan be developed to ensure that dewatering water to be used as potable water supplies for mine staff is appropriately treated.

• The DoH commented that the direct transfer of dewatering flows to Tom Price may result in this water bypassing the town’s water treatment plant.

Timing • The confidential submission queried the timing of the release of the PER, when it was known

before the commencement of mining at Marandoo that there was economically viable iron ore in substantial quantity beneath the watertable.



5. CONSOLIDATED PROPONENT RESPONSES – KEY ENVIRONMENTAL FACTORS

5.1 OVERVIEW

The following sections provide consolidated Proponent responses to the following key environmental factors commented on in submissions:

• Karijini National Park (Section 5.2)

• groundwater and groundwater quality (Section 5.3)

• watercourse and surface water quality (Section 5.4)

• Coolibah woodland (Section 5.5)

• visual amenity and landscape character (Section 5.6)

• closure and rehabilitation (Section 5.7).


5.2.1 Submissions received

All submissions commented on the predicted effects the Proposal would have on the values of Karijini National Park. Several submissions commented on the risk of groundwater drawdown affecting springs and pools in Karijini National Park, and the DEC commented on the effect of the workforce on Karijini National Park (Section 4.1).

A consolidated response to the key submissions relating to Karijini National Park is provided below. A consolidated response to submissions commenting on the Coolibah woodland in Karijini National Park is provided in Section 5.5.2.

5.2.2 Proponent responses

Impacts to springs and pools

The PER states that, of the springs and pools occurring in Karijini National Park, only Hamersley Gorge and Minthicoondunna Spring will potentially be affected by the Proposal. The Proponent does not consider permeable groundwater conduits, or “preferred pathways” linking dewatering at Marandoo to any springs or gorges within Karijini National Park would exist, as such geological structures would be highly unlikely to persist over such a significant distance in a fractured rock environment.

Aquifers may be considered a type of conduit with similar characteristics that could be construed as a “preferred pathway”. As such, the Proponent has identified that Hamersley Gorge and Minthicoondunna Spring have groundwater of similar chemical characteristics to that at Marandoo and are therefore potentially hydraulically connected via the same aquifer.



The Proponent has proposed an Environmental Condition (for incorporation into any Statement issued to apply to the Proposal) to ensure surface water and sub-surface base flow resulting from the discharge of excess dewatering water alone does not reach Hamersley Gorge (refer to Condition 9 in Table 28 in the PER).

The existing Groundwater Management Plan is adequate to address the level of risk to Minthicoondunna Spring. The cultural heritage values of Minthicoondunna Spring are protected under the provisions of the Aboriginal Heritage Act 1972 (WA). The proponent will obtain consent in accordance with the requirements of this Act prior to any impact to the heritage values of Minthicoondunna Spring.

Any potential impact to the spring would occur only towards the end of the mine life. The proponent will undertake further hydrogeological investigations between Marandoo and Minthicoondunna Spring to determine the potential for impact, and will monitor (quarterly throughout the life of the proposal) both the water level at Minthicoondunna Spring and groundwater levels between Marandoo and the spring.

Further investigations at Minthicoondunna Spring will involve installation of shallow observation bores and deeper piezometers between the most eastern extent of the proposed mine pit and Minthicoondunna Spring (Section 2.3.1).

Impact of workforce

The Proponent will implement a three-tiered workforce management strategy to minimise the potential for impacts to Karijini National Park.

Firstly, as stated in the PER, the fly-in/fly-out roster type, combined with the length of working days (12 hours) will limit the time available to personnel to undertake recreational pursuits, including within Karijini National Park. Shifts are scheduled such that personnel fly home on ‘days off’, rather than remaining on-site (where they could potentially undertake recreational activities). There is potential for construction personnel to work longer rosters and for rostered days off to be had whilst remaining on-site. In these instances, the Proponent will provide and encourage the use of recreational facilities and will provide instruction on National Park access conditions and behaviour expectations (outlined below).

Secondly, for the limited time that is available, the Proponent will provide recreational facilities at the accommodation camp, including a swimming pool, multi-use tennis and basketball courts, grassed-areas and a gym.

Thirdly, all personnel will be inducted on how to behave in Karijini National Park and will be briefed and referred to the Karijini National Park Management Plan (CALM 1999). Personnel will be instructed on such issues as:

• the requirement to remain on established walking and vehicle tracks wherever possible

• appropriate, low-impact behaviour within Karijini National Park

• the potential for off-road access to result in increased erosion and weed dispersal

• prohibition of alcohol consumption in National Parks, except in areas as permitted by the DEC

• relevant National Park policies and requirements, including in relation to entrance fees, campfires and firewood collection.



The appointment of additional ranger staff in Karijini National Park is not considered necessary given the three-tiered workforce management strategy to be implemented.

5.3 GROUNDWATER AND GROUNDWATER QUALITY


Several submissions commented on groundwater aspects. Most comments related to the reliability of the groundwater model, the prediction of impacts of groundwater drawdown from dewatering, the impacts of re-injecting water into the Southern Fortescue borefield and/or the potential for sinkhole development (Section 4.2).

A consolidated response to the key submissions received relating to groundwater aspects is provided below. Consolidated responses to submissions commenting on the effect of groundwater drawdown on the Coolibah woodland and on springs and pools in Karijini National Park are provided in Section 5.5.2 and Section 5.2.2 respectively.


Groundwater modelling

A well-calibrated predictive numerical model of the Marandoo groundwater system has been developed from data collected from extensive hydrogeological investigations (including drilling, pump testing and geophysical surveys) undertaken at Marandoo since 1978, as well as two dewatering and re-injection trials conducted at Marandoo in 2004 and 2005. A separate groundwater model has been developed to study the proposed re-injection of water into the Southern Fortescue borefield.

The groundwater models have been constructed with the best available data and have drawn on the knowledge and expertise of experienced geologists and hydrogeologists. The inherent risks associated with the predictive capacity of the models arise due to uncertainty in model parameters in both space and time.

Marandoo groundwater model and predicted drawdown

Given the spatial distribution of monitoring points (Figure 8) and long-term water level monitoring, the Proponent considers that the existing model captures adequate variability on the scale (both temporal and spatial) of interest following two long-term injection and dewatering trials.

An understanding of the degree of hydraulic connection between the unconfined and confined aquifers is the critical component in assessing the groundwater drawdown predictions of the Marandoo groundwater model. Monitoring results (in both the unconfined and confined aquifers) of field hydrogeological investigations, including pump testing and re-injection of water, coupled with predictive modelling, would suggest that the risk of hydraulic connection between the unconfined and confined aquifers is very low. Hydrographs from key monitoring points within the model domain are provided in Appendix 2. Sample hydrographs are presented in Figure 11, Figure 12 and Figure 13.

Hydrographs presented in Appendix 2 show groundwater levels from monitoring bores that were monitored for:

• the dewatering and injection trial



• the drop cut metallurgical trial dewatering and injection scheme

• compliance purposes.

The first two sets of hydrographs demonstrate the groundwater level response over specific time periods coincident with dewatering and injection trials to demonstrate the physical data supporting the lack of connection between the unconfined and confined aquifers. Both the trial and scheme focused on dewatering and injection within the confined aquifer only.

The hydrographs from both trials demonstrate that bores screened in the unconfined alluvial/calcrete (denoted “s”), do not draw down during dewatering or draw up during injection. Those monitoring bores screened either in the lower detrital (denoted “I”) and/or the deeper Marra Mamba Ore-body or the Wittenoom Formation (denoted “d”) act as one aquifer unit given by their response to dewatering or injection. The intervening lacustrine clays act as a vertical barrier to water movement. The clay has been found to be consistent across the Mount Bruce Flats in its spatial distribution from both geological and hydrogeological drilling.

The next set of hydrographs in Appendix 2 present individual water level responses in comparison to the long term rainfall recorded at Tom Price. Bores in the unconfined aquifer demonstrate a more dynamic response to rainfall events in comparison to bores screened over the confined aquifer. This is especially so over the Mount Bruce Flats where the unconfined aquifer is recharged more rapidly due to the occurrence of crab holes or root zones acting as direct conduits to the watertable.

The final set of hydrographs show the actual comparison of unconfined and confined water levels from all nested piezometers in the area to illustrate that a consistent head difference exists between the unconfined and confined bores averaging between 3 to 4 m. The intermediate water levels coincide exactly with those of the confined aquifer demonstrating that they are connected. The head difference between water levels in the unconfined and confined aquifer is downwards which indicates that unconfined aquifer water levels do not depend on the confined aquifer; but more the occurrence of the confining clay as the lower boundary to the unconfined aquifer.

Field evidence of a very poor hydraulic connection between the unconfined and confined aquifer across the Mount Bruce Flats includes:

• sequences of tight clay at least 30 m thick intersected in all deep bores on the Mount Bruce Flats and in the down-dip areas of Marandoo (Figure 14, Figure 15 and Figure 16)

• consistent downward differential heads of 3–4 m in all nested piezometers on the Mount Bruce Flats and in the down-dip areas of Marandoo (Figure 17 and Figure 18)

• no response in the unconfined aquifer to water level changes in the confined aquifer during several underdrainage pumping tests, the 44-day pumping and re-injection trial in 2004 (Liquid Earth 2005; Youngs and Brown 2005), or the 72-day pumping and re-injection program in 2005 (Evans 2006; MWH 2006a).

In accordance with the observations from field testing, a low vertical hydraulic conductivity of 10-

5 m/d for the clay layer between the unconfined and confined aquifers across the Mount Bruce Flats was used in modelling. The intersection of the unconfined aquifer by mining was represented as a seepage face during the modelling.

Hydrographs of bores show a hydraulic connection only between intermediate (i) and deep (d) bores, but little or no connection between shallow (s) and deep (d) bores. All bores show a downward head from the unconfined aquifer to the confined aquifer (Appendix 1).



The boundaries of the Marandoo groundwater model were ‘no flow’ to the north and east as controlled by outcropping Brockman Iron Formation, and ‘no flow’ to the south as controlled by the Marandoo Ridge. Flow from the model domain occurs towards the southeast to Turee Creek and to the west toward the Southern Fortescue River Valley. These flow boundaries were general head boundaries, which allow flow out of the model domain in proportion to the head on the boundary (Figure 19).

The no flow boundaries are approximated through geological control on the basin. In addition, permeability within the Wittenoom Formation is directly related to those areas where the Formation has been exposed, which for Marandoo is limited to only those areas covering the Mount Bruce Flats. Permeability development outside the basin is therefore estimated to be limited and its contribution to the overall water balance will be negligible.

The Marandoo groundwater model has four layers, with numerous zones within each layer that represent different geological matrix and hydraulic parameters. The variability in parameters has been determined through both test pumping close to the proposed mine pit and injection trials to the north of the pit in the vicinity of the Mount Bruce Flats. In addition, the model has been validated against long-term monitoring data and can reproduce trends observed in groundwater levels. Thus, the model represents a tool for conducting management, hypothesis testing, understanding potential impacts from dewatering, and providing indicative dewatering volumes.

The Proponent has presented the predicted groundwater drawdown across the Mount Bruce Flats as a cross-section (Figure 20 and Figure 21) in response to the submission from the DoW, and to aid in interpretation.

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Legend

Catchment BoundaryCatchment BoundaryCatchment BoundaryCatchment BoundaryCatchment BoundaryCatchment BoundaryCatchment BoundaryCatchment BoundaryCatchment Boundary

Vibrating WirelineVibrating WirelineVibrating WirelineVibrating WirelineVibrating WirelineVibrating WirelineVibrating WirelineVibrating WirelineVibrating WirelinePiezometer sitePiezometer sitePiezometer sitePiezometer sitePiezometer sitePiezometer sitePiezometer sitePiezometer sitePiezometer site

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Monitoring Bore siteMonitoring Bore siteMonitoring Bore siteMonitoring Bore siteMonitoring Bore siteMonitoring Bore siteMonitoring Bore siteMonitoring Bore siteMonitoring Bore site

Ground Surface RLGround Surface RLGround Surface RLGround Surface RLGround Surface RLGround Surface RLGround Surface RLGround Surface RLGround Surface RLTop of Clay RlTop of Clay RlTop of Clay RlTop of Clay RlTop of Clay RlTop of Clay RlTop of Clay RlTop of Clay RlTop of Clay RlThickness of ClayThickness of ClayThickness of ClayThickness of ClayThickness of ClayThickness of ClayThickness of ClayThickness of ClayThickness of Clay

Known BoundaryKnown BoundaryKnown BoundaryKnown BoundaryKnown BoundaryKnown BoundaryKnown BoundaryKnown BoundaryKnown Boundaryof Clayof Clayof Clayof Clayof Clayof Clayof Clayof Clayof Clay

Estimated BoundaryEstimated BoundaryEstimated BoundaryEstimated BoundaryEstimated BoundaryEstimated BoundaryEstimated BoundaryEstimated BoundaryEstimated Boundaryof Clayof Clayof Clayof Clayof Clayof Clayof Clayof Clayof Clay

Local CatchmentLocal CatchmentLocal CatchmentLocal CatchmentLocal CatchmentLocal CatchmentLocal CatchmentLocal CatchmentLocal CatchmentBoundaryBoundaryBoundaryBoundaryBoundaryBoundaryBoundaryBoundaryBoundary

740

690

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590

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4900

SWm

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MineralisedOre

Deep Water Table

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West Angelas Shale

Dolomite

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Detritals

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Mt BruceC

Joffre Falls

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Groundwater Fed Falls

? ? ?

Pit Outline

3.02m3.02m3.02m3.02m3.02m3.02m3.02m3.02m3.02m

3.73m3.73m3.73m3.73m3.73m3.73m3.73m3.73m3.73m

3.43m3.43m3.43m3.43m3.43m3.43m3.43m3.43m3.43m

3.19m3.19m3.19m3.19m3.19m3.19m3.19m3.19m3.19m

3.02m3.02m3.02m3.02m3.02m3.02m3.02m3.02m3.02m

2.79m2.79m2.79m2.79m2.79m2.79m2.79m2.79m2.79m

3.49m3.49m3.49m3.49m3.49m3.49m3.49m3.49m3.49m4.3m4.3m4.3m4.3m4.3m4.3m4.3m4.3m4.3m

4.72m4.72m4.72m4.72m4.72m4.72m4.72m4.72m4.72m

0.43m0.43m0.43m0.43m0.43m0.43m0.43m0.43m0.43m

6.79m6.79m6.79m6.79m6.79m6.79m6.79m6.79m6.79mOW29/dOW29/dOW29/dOW29/dOW29/dOW29/dOW29/dOW29/dOW29/d PW12/OW12PW12/OW12PW12/OW12PW12/OW12PW12/OW12PW12/OW12PW12/OW12PW12/OW12PW12/OW12




TPB5/OW24sidTPB5/OW24sidTPB5/OW24sidTPB5/OW24sidTPB5/OW24sidTPB5/OW24sidTPB5/OW24sidTPB5/OW24sidTPB5/OW24sid

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PW20/OW20PW20/OW20PW20/OW20PW20/OW20PW20/OW20PW20/OW20PW20/OW20PW20/OW20PW20/OW20





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TPB1/OW21sdTPB1/OW21sdTPB1/OW21sdTPB1/OW21sdTPB1/OW21sdTPB1/OW21sdTPB1/OW21sdTPB1/OW21sdTPB1/OW21sd

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6210

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6220

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6230

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6200

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6180

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7497000 mN

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6170

00 m

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Marandoo 2009Head differences betweenShallow and Deep Aquifers

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Cape LambertDampier

Port Hedland

1:25000 @ A3

SCALE

LOCATION MAP

Plan No:Proj:


Legend

Monitored Bore


-7.20m-7.20m-7.20m-7.20m-7.20m-7.20m-7.20m-7.20m-7.20m

3.95m3.95m3.95m3.95m3.95m3.95m3.95m3.95m3.95m3.73m3.73m3.73m3.73m3.73m3.73m3.73m3.73m3.73m 4.3m4.3m4.3m4.3m4.3m4.3m4.3m4.3m4.3m3.49m3.49m3.49m3.49m3.49m3.49m3.49m3.49m3.49m

3.43m3.43m3.43m3.43m3.43m3.43m3.43m3.43m3.43m

3.19m3.19m3.19m3.19m3.19m3.19m3.19m3.19m3.19m

3.02m3.02m3.02m3.02m3.02m3.02m3.02m3.02m3.02m

2.79m2.79m2.79m2.79m2.79m2.79m2.79m2.79m2.79m






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6250

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6275

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6300

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6225

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7497500 mN

7495000 mN

7492500 mN

6200

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6175

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7487500 mN

7490000 mN

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Port Hedland

1:50000 @ A3

SCALE

LOCATION MAP

Plan No:Proj:


Legend


Monitored Bore

Gen

eral

Hea

dB

ound

ary

Gen

eral

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Calcrete Deposits

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Wittenoom FormationMarra Mamba Formation

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Cross Section A to A'

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Southern Fortescue borefield groundwater model and re-injection

The Southern Fortescue borefield groundwater model domain is presented in Figure 22. Hydrographs from key monitoring points within the model domain are provided in Appendix 3.

Key findings from the four re-injection modelling scenarios (refer to MWH [2008]) were as follows:

• groundwater levels for each of the four scenarios would rise to 10–20 m below ground level (Figure 23)

• extending the Southern Fortescue borefield may reduce the final water level in the area of the existing borefield by approximately 3 m

• injecting 30 ML/day for the first three years, rather than 15 ML/day, will result in a groundwater level rise of an additional 2 m.

Sinkholes

As stated in Section 5.2.4 in the PER, the physical disturbance from existing sinkhole formation near the Southern Fortescue borefield is very limited in area (20–30 m in diameter) and therefore the potential impact to flora and fauna values as a result of sinkhole formation would be minimal. The proposed mitigation and management outlined in Section 5.3.5 of the PER (and included in the Groundwater Management Plan in Appendix 2 of the PER) are considered to be sufficient and, as such, a specific sinkhole management strategy is not required.

Sinkhole formation across the Mount Bruce Flats as a result of the proposed dewatering is possible, but unlikely because the clay layer between the unconfined and confined aquifers is of considerable thickness across the Mount Bruce Flats (Figure 14, Figure 15 and Figure 16) and exhibits properties that would ensure it remains saturated during dewatering. Further geotechnical work will be conducted to determine the spatial extent of this clay layer. In comparison, the Tertiary detritals at the Southern Fortescue borefield (where sinkholes are known to have formed) are a sequence of inter-layered Tertiary clays, gravels and calcrete with properties that are more likely to result in the formation of sinkholes.

Sinkhole formation can be a natural process, especially where calcium, magnesium and bicarbonate are the dominant ions, as is the case with groundwater at Marandoo. Sinkhole formation over the life of the Proposal due to dissolution of either the unconfined or confined carbonate aquifers is unlikely as the effects of dissolution are usually only evident over longer time scales.

Sinkhole formation due to collapse of existing cavities in the Wittenoom Formation or calcrete beds (as a function of depressurisation and in the worst-case lowering of the watertable below the base of these secondary permeability features) is also unlikely as these higher permeability features are expected to remain the main conduits for groundwater flow.

Voids are expected to be larger in the Wittenoom Formation, and only relatively small in the calcrete beds. Voids could be filled by material migrating downwards; however, due to the greater depth of the Wittenoom Formation (less than 100 m) and the thickness of the overlying clay, void migration is considered unlikely to reach the ground surface (i.e. the void would ‘coke’ before reaching the surface). The small size of the calcrete voids suggests they would be filled before propagating to the ground surface, or that the surface expression would be small.

Palaeovalley DepositsCalcrete Deposits

Goethite

Palaeovalley Deposits

Wittenoom Formation

Marra Mamba Formation

B B'

SFB Model: Cross Section B to B'

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Several submissions commented on surface water. Most comments were in relation to the impact of discharging excess water into ephemeral tributaries of the Southern Fortescue River system. The DEC commented also on the potential impacts of discharging stormwater to the Mount Bruce Flats (Section 4.3). A consolidated response regarding the proposed discharge of dewatering water is provided below. Other responses relating to surface water are provided in Table 5.


As detailed in Section 4.7.1 in the PER, the Proponent has developed a surplus water management strategy in accordance with the DoW hierarchy of water management methods. The preferred sequence of surplus water management options is:

1. Use at source.

2. Transfer.

3. Re-injection.

4. Controlled discharge.

The emphasis of the proposed excess water management strategy is on ‘use at source’ and ‘transfer’ methods to maximise opportunities for environmental improvement.

The Proponent has proposed Environmental Conditions (for incorporation into any Statement issued to apply to the Proposal) for the protection of ecological values along drainage lines subject to discharge (refer to Conditions 8 and 9 in Table 28 in the PER).

Proposed Condition 8 will ensure surface water discharges do not cause the quality of surface water or groundwater systems to exceed ANZECC criteria, taking into consideration natural background water quality and environmental values of the receiving environment.

Proposed Condition 9 states that a Dewatering Discharge Baseline Survey and Monitoring Program will be prepared for review by the DEC. This program will then be finalised in accordance with the DEC review. The Condition will ensure the adoption of an acceptable discharge strategy and will ensure surface water and sub-surface water flow resulting from the discharge of excess dewatering water alone does not reach Hamersley Gorge.

The proposed Dewatering Discharge Baseline Survey and Monitoring Program will detail the excess water discharge strategy and will specify in-stream/riparian environmental targets to be met and monitoring requirements to measure performance against these targets. The Program will specify the location of the discharge points and will describe the morphology of the watercourses that will receive the discharge.

Discharge rates will be managed primarily through the alternate use of more than one discharge location, with multiple discharge pipes at each location and energy dissipation infrastructure. This will allow the discharge to be varied at each location to manage the saturation of each watercourse and prevent scouring.



The worst-case scenario for the discharge of excess dewatering water was presented in Section 4.7.1 in the PER as 15 ML/day continuous discharge (with intermittent peaks of 60 ML/day) for the first three years of the Proposal, thereafter followed by only intermittent discharges of 45 ML/day. The limited three year window for continuous discharge presented in this scenario is neither permanent nor irreversible in the context of the ecology of the area. The potential continuous discharge of 15 ML/day correlates to a flow volume of approximately 0.2 m3/s, which would be a very small surface flow for the area.

The impact to vegetation along the two drainage lines that were proposed in the PER to receive discharged dewatering water is expected to be increased localised physiological stress, with localised deaths in areas of prolonged saturation. As stated in the PER, the creek systems and plains that would be affected are considered sufficiently resilient to recover from any temporary impact from discharge and would be expected to return to an ecosystem with a similar community structure and composition to the existing system within a matter of decades after the cessation of discharge (Dr Libby Mattiske, 2008, pers. comm., 19 August).

The impact to aquatic fauna of the Southern Fortescue River system is likely to be a loss of permanent aquatic fauna residents adapted to intermittent flow and colonisation by species adaptable to perennial flow or both regimes. Any permanent aquatic fauna lost from affected areas are likely to be present in nearby, unaffected areas and would re-colonise the system after the cessation of discharge (WRM 2008).

The cumulative effect on groundwater levels in the Southern Fortescue aquifer system resulting from the proposed discharge and re-injection is expected to be minimal. There is a significant distance (approximately 20 km) between the proposed discharge locations and the proposed injection site, which will minimise the potential cumulative rise in groundwater levels. Even under the worst-case scenario presented in the PER, the total volume of water discharged over the life of the Proposal will not exceed the total volume abstracted from the Southern Fortescue borefield to date. If 100% of the excess dewatering water discharged over the first three years of the Proposal was to infiltrate into the groundwater system, this would represent only 10% of the total volume abstracted from the Southern Fortescue borefield since 1970.

5.5 COOLIBAH WOODLAND


The DEC, CCWA and DoW commented on the effect of the Proposal on the Coolibah woodland in Karijini National Park and stated that some of the proposed management triggers and associated management responses in the Coolibah Management Plan should be reconsidered. The DEC and CCWA stated that a groundwater drawdown of 0.5 m may be enough to affect the woodland, and the CCWA stated that the Proponent should cease dewatering if the Coolibah woodland is affected by dewatering (Section 4.5). A consolidated response to the key submissions received relating to the Coolibah woodland is provided below.


Adaptive management approach

The Proponent has proposed an Environmental Condition (for incorporation into any Statement issued to apply to the Proposal) for a Coolibah Baseline Survey and Monitoring Program to be submitted to



the DEC for review, and thereafter modified in accordance with this review. The proposed condition also specifies an adaptive management approach to protect the Coolibah woodland (refer to Condition 6 in Table 28 in the PER).

Any impacts to the Coolibah woodland attributable to dewatering can be adequately managed via the proposed adaptive management approach. The approach features a three-tiered response mechanism to assign appropriate actions to be undertaken if monitoring detects any impact to the Coolibah woodland. Each of the three levels of response stipulates a percentage loss of mean foliage cover that will trigger actions to be implemented. As stated in the Coolibah Management Plan, any loss of foliage exceeding the Level 1 trigger (15% loss) will trigger actions to be implemented by the Proponent, not just the Level 3 trigger (40% loss).

Triggers for management

The triggers proposed as part of the adaptive management approach for the Coolibah woodland (refer to Table 30 in the PER) are identical to management triggers the Proponent and the DEC have previously agreed to regarding foliage loss in riparian trees at both the Yandi and Hope Downs mine sites. The trigger levels of 15%, 25% and 40% foliage loss are considered conservative due to the observed natural losses/gains in foliage cover between monitoring events of up to 10–15% in Coolibah reference sites (Adams 2005, 2006, 2007).

For example, foliage loss of 16% was recorded between 2007 and 2008 in the Mount Bruce Flats Coolibah woodland due to natural events (Sally Madden, Specialist Advisor - Ecology, [Rio Tinto] 2009, pers. comm., 3 February). Riparian trees along Weeli Wolli creek that recorded foliage loss of 23% eight weeks after a fire in March 2007 had recovered 12 months later to a loss of only 4% lower than pre-fire levels (Sally Madden, Specialist Advisor - Ecology, [Rio Tinto] 2009 pers. comm., 3 February).

Eucalypts, including Coolibah, frequently recover from total loss of foliage caused by events such as fire, insect attack and water stress; therefore, even the proposed Level 3 trigger (40%) is still considered conservative (Pauline Grierson [University of Western Australia], 2009, pers. comm., 3 February).

Management response

As part of the proposed adaptive management approach, the Proponent has committed to supply the Coolibah woodland with water using a method agreed with the DEC, should any Level 3 trigger be exceeded. Any method chosen would require adequate assessment prior to implementation to determine its appropriateness. Re-injection of water into the unconfined aquifer to produce a groundwater mound is one option that has been considered; however, the Proponent would investigate other options in consultation with the DEC to determine the most appropriate method.

The Proponent would investigate and (if required) implement surface irrigation as an option only with agreement from the DEC. The DEC has stated that surface irrigation is likely to lead to vegetation changes, such as causing the Coolibah to switch from a deep taproot system to shallower root systems, rendering them dependent on surface water flow that would cease at the completion of mining. There is no evidence that such a switch would occur at Marandoo, which is frequently inundated by seasonal rains (Pauline Grierson [University of Western Australia], 2009, pers. comm., 3 February). As the Mount Bruce Flats Coolibah woodland is regularly inundated following cyclonic rains, the artificial system would simply aim to reproduce such an event. The assertion that surface irrigation at the woodland would cause the Coolibah to switch from a deep taproot system to shallower root systems



may have been raised from speculation of the effect of prolonged inundation (i.e. greater than five years of saturated surface horizons) on Coolibah growing elsewhere within streams, where the tap roots may have rotted; however, the Mount Bruce Flats has a very different surface hydrology to these environments (Pauline Grierson [University of Western Australia], 2009, pers. comm., 3 February).



The DEC commented that the PER downplays the effect of the Proposal on visual amenity through inclusion of the existing Marandoo mine in the visual baseline. The DEC also commented that the design and management of the mine and accommodation camp have not considered potential visual impacts. Both the DEC and CCWA suggested the accommodation camp be relocated; however, Tourism WA determined the location of the camp to be acceptable in terms of visual impact to Karijini National Park (Section 4.9). A consolidated response to the key submissions received relating to visual amenity and landscape character is provided below.


Overview

The existing mine has already significantly affected visual amenity. Additional mine infrastructure at Marandoo will result in only a minor perceivable change in visual amenity from most sensitive receptors (refer to Table 20 of the PER). Exceptions to this are the eastern summit lookout of Mount Bruce and Karijini Drive, where there will be a significant perceivable change to visual amenity. The eastern summit lookout is not frequently used by visitors to Mount Bruce and therefore the adverse impacts will be experienced by only a small number of tourists. Views of the Marandoo expansion from Karijini Drive will be transient in nature, thereby lessening the impact.

Visual impact baseline

The SKM (2008) landscape and visual impact assessment was undertaken in accordance with the methodology and guidelines of:

• Guidelines for Landscape and Visual Impact Assessment (Landscape Institute and the Institute of Environmental Management and Assessment 2002)

• Visual Landscape Planning in Western Australia - a manual for evaluation, assessment, siting and design (DPI 2007).

The LI and IEMA (2002) guidelines provide specific advice on determining an appropriate visual baseline for the purposes of landscape and visual impact assessment. The guidelines state that, for schemes that seek to extend an existing development, the assessment should consider those changes likely to occur as a result of the extension, because the baseline landscape already includes the existing development. The LI and IEMA (2002) guidelines further state that, to inform the decision making process, the emphasis of the landscape and visual impact assessment process is on the changes the proposal would bring to the existing landscape.



The process employed by SKM (2008) to report on the visual baseline for the Proposal is in line with the LI and IEMA (2002) guidelines. The DPI (2007) manual does not provide any guidance on determining an appropriate visual baseline for the purposes of landscape and visual impact assessment.

Visual impact of the accommodation camp

Tourism WA stated in its submission on the PER that it is satisfied with the proposed location of the accommodation camp, as it appears to have little visual impact to Karijini National Park. As stated in the PER, views of the proposed operations camp are likely to be restricted to transient views from roads in the vicinity of the infrastructure, including Karijini Drive and Hamersley Gorge-Mount Bruce Road. Preliminary results from the additional visual impact assessment and classification work undertaken by SKM (Section 2.2) indicate the visual impact of the proposed accommodation camp will range from Neutral to Moderate Adverse (Table 1) at the eight potential visual receptors identified by SKM (2008) as suitable for the visual assessment (refer to Figure 39 in the PER).

The proposed camp is 13 km from the Mount Bruce summit and will be in the background of any views from this location1. Preliminary results from the additional visual impact assessment and classification work undertaken by SKM (Section 2.2) indicate the degree to which the proposed camp will be visible from nearby receptors will vary, but the views of the camp would generally be transient and intermittent in nature depending on the degree of screening afforded by vegetation.

The Colour-bond colours chosen for the accommodation units are Jasper for the walls and Dune for the roof. These colours are non-reflective and have been chosen to achieve a Five Star energy efficiency rating as required by the Building Code of Australia. Other infrastructure at the camp (including water tanks, communication towers and satellite dishes) will have non-reflective surfaces.

Infrastructure such as water tanks, communication towers and satellite dishes will be consolidated within the camp footprint, rather than being located in areas of higher elevation and higher visibility. Light towers will be directed appropriately and will have shrouds fitted to minimise light overspill.

The selection process for the location of the accommodation camp included evaluation of six alternative locations (refer to Figure 3 in the PER) and is described in Section 1.5.3 of the PER. The assessment considered both visual and environmental impact, as well as other factors such as infrastructure and service requirements, tenure, topography, proximity to Marandoo and access to existing roads.

Site 6 was determined to be most appropriate as it is located outside the area that will be returned to the National Park in 2015; is away from significant creek systems; does not conflict with other potential land uses; is situated on tenure held by the Proponent; can provide synergies with other projects in the area, and; has the least potential to degrade the visual amenity of Karijini National Park compared to the other options.

1 According to the CALM (1989) Visual Landscape Management System, areas in the background are those beyond 6.5 km.



5.7 CLOSURE AND REHABILITATION


The DEC, CCWA and DoW commented on the degree to which the mine pit is proposed to be backfilled following completion of mining. The DEC submission also commented on rehabilitation and closure objectives; the research being undertaken by UWA, and; seed provenance requirements for Marandoo. The CCWA stated that the Proponent’s previous performance in rehabilitation should be considered in the assessment of the Marandoo Mine Phase 2 Proposal (Section 4.10). A consolidated response detailing the Proponent’s backfilling strategy is provided below. Other responses relating to closure and rehabilitation are provided in Table 12.


The proposed mine void will be progressively backfilled from the west to east throughout the life of the Proposal. As stated in Section 5.10 in the PER, the generic target level for backfill is 1 m above the pre-mining watertable, with the backfill surface likely to be designed to incorporate topographical low points to create areas for water to pool, thereby reducing the surface area for evaporation. This strategy will be further developed in consultation with relevant stakeholders.

The establishment of a backfill surface that incorporates elevated areas greater than 1 m above the pre-mining watertable and lower areas below the pre-mining watertable (which would become artificial wetlands) is considered likely to provide a better water quality outcome than the establishment of a uniform surface 1 m above the pre-mining watertable; the collaborative research project investigating the geochemistry of mine voids in the Pilbara will provide further insight into predicting final void water quality (Section 2.4). The design of the backfill surface would determine the resultant long-term salinity of the artificial wetlands. Revegetation of these low points will use local native species with adaptations to withstand periodic and extended periods of inundation.

Backfilling the mine pit void at Marandoo to the pre-mining ground level was considered by the DEC to be highly desirable, but would involve disturbing and transporting backfill material from a distant source. This would increase the disturbance footprint and greenhouse emission footprint of the proposal. The Proponent generally aims to maximise backfill in situations where it is environmentally appropriate to do so, but this is balanced by the availability of viable fill material and the cost of backfilling.

If the mine pit void at Marandoo was not backfilled, it would become a groundwater sink for the majority of the time. This would meet the DoW water quality criteria in relation to backfilling mine pit voids. Thus, the Proponent is undertaking to go beyond the DoW backfill criteria to create a better post-mining outcome at Marandoo.



6. DETAILED RESPONSE TO SUBMISSIONS

6.1 OVERVIEW

The following sections provide detailed Proponent responses to individual comments raised in the submissions. The comments and corresponding responses have been tabulated and grouped according to the environmental factor they address as follows:

• Section 6.2: Karijini National Park

• Section 6.3: Groundwater quantity and quality

• Section 6.4: Watercourses and surface water quality

• Section 6.5: Flora and vegetation

• Section 6.6: Coolibah woodland

• Section 6.7: Terrestrial fauna

• Section 6.8: Subterranean fauna

• Section 6.9: Visual amenity and landscape character

• Section 6.10: Closure and rehabilitation

• Section 6.11: Health

• Section 6.12: Miscellaneous issues.




Table 3 Response to submissions relating to Karijini National Park

Item Submission from Comment Proponent response

1 Conservation Council National Parks and A-Class reserves are an essential tool in the protection of WA's unique biodiversity. They are the only areas in the State protected from the impacts of all development and industrial pressures – in particular the only areas protected from mining and mineral exploration. Currently the conservation estate is under-represented, with only 6.9% of the State covered with reserves, far short of a CAR system that is estimated to cover 15% of the State. The reserve system is designed to protect areas in their natural ecological state, not just specific values. This project represents almost a doubling of the area of disturbance of the mine within the boundaries of the National Park. National Parks must be absolutely protected from the impacts of mining.

The Marandoo mining lease was excised from Karijini National Park in 1991. The area of disturbance associated with the Proposal does not fall within the boundaries of the National Park.

2 It is not adequate to apply normal management and risk assessment to a National Park, i.e. identifying the values that might be at risk and attempting to place these within what might be considered acceptable limits of impact. National Parks are different, they have been designated at a level of protection that differentiates them from the rest of the landscape for good reasons that include the precautionary principle, an assurance against mistakes. They are there so that people can know that at least some areas are being protected and managed solely for the protection of the environment, natural landscapes and biodiversity. Thus, the approach appropriate to the rest of the landscape is not appropriate to potential impacts on a National Park. National Parks must be absolutely protected from the impacts of mining.

Section 3.1 of the Karijini National Park Management Plan (CALM 1999), recognises that under the Government Agreement Acts, commercial iron ore deposits within Karijini National Park are allowed to be assessed in accordance with government policy. Further, mining within the National Park may be permitted subject to EPA assessment and the consent of both Houses of Parliament.

3 The National Park is supposed to be an area designated for the complete protection of flora and fauna. The National Park is the place where these species should be guaranteed complete protection and the natural balance of the ecosystem should be maintained as the number one and uncompromised priority; that is the basis of a reserve based system for protection of biodiversity — the core reserves have complete protection. The suggestion that the potential loss of local populations of fauna (or loss of abundance) is acceptable due to the presence of these species elsewhere is not acceptable in a National Park. In particular, the predicted loss of stygofauna populations protected within the National Park is unacceptable, regardless of whether these species are represented outside the park.

Management of Karijini National Park has a number of goals and objectives in addition to the conservation of biological, physical, cultural and landscape resources and values. These include tourism, recreation, community relations, research and commercial goals (CALM 1999). The PER stated that loss of fauna habitat resulting from the Proposal would lead to a reduction in the local abundance of some fauna populations. This was further stated to have no effect on the representation of fauna at a local or regional level. The proposed dewatering is considered unlikely to significantly affect subterranean habitat or communities across the Mount Bruce Flats as subterranean fauna do not occur in the confined aquifer and drawdown in the unconfined aquifer is predicted to be minimal. Refer also to response to Item 3 in Table 9.



6.3 GROUNDWATER QUANTITY AND QUALITY

Table 4 Response to submissions relating to groundwater quantity and quality


1 DoW The most critical decision associated with the project is to determine whether dewatering is acceptable for an operation in an excision within Karijini National Park. The DoW's position is that the project would be difficult to manage through water licensing under the Rights in Water and Irrigation Act 1914 (RIWI Act) unless the proponent commits to the cessation of mining and dewatering when certain environmental water triggers, are hit, only recommencing when the issues are resolved. The proponent needs to describe the numerical triggers which would lead to a cessation of dewatering; these triggers would be written into the water licence.

The Proponent understands the implications and sensitivities of dewatering close to the boundary of Karijini National Park and is therefore committed to undertaking further hydrogeological investigations to understand potential impacts, reduce risks and inherent uncertainty, and to facilitate an adaptive management approach. Trigger levels for potential impacts to the Mount Bruce Flats Coolibah woodland have been proposed in Table 30 in PER. Should these triggers be breached, a managed staged approach to a reduction in dewatering would be sufficient to reverse trends, rather than a complete cessation of dewatering. Complete cessation could lead to loss of access to the pit and would present safety and geotechnical risks. This outcome would be completely unacceptable and is not a practical option. Opportunities for modifying landforms in accordance with the closure strategy would also be lost following complete cessation of dewatering.

2 The assumptions made that led to the proponent's conclusion that the springs will be unaffected may be erroneous because preferred drainage pathways may exist. Reduced flows at the springs may be detected through the monitoring programs. The proponent should have a methodology in place to isolate drawdown components from climate variability and rainfall patterns, should reduction in spring flow occur. A methodology was not provided with the PER, therefore the DoW considers that additional information is required from the proponent.

Refer to detailed response in Section 5.2.2 and the proposed investigations described in Section 2.3. Commitment to undertake the proposed investigations is stipulated in the Groundwater Management Plan (included in Appendix 2 in the PER).

3 The PER has not clarified whether the drawdown effects in the confined aquifer are reduced pressure or actual drying of the aquifer materials. Dewatering can result in compaction of the confined aquifer, with subsequent slumping of the surface material if void volumes become large enough. These matters need to be addressed by the proponent.

The drawdown effects at the immediate area adjacent to the pit will result in the drying of aquifer materials, although depending on material properties, some moisture will be inherently left owing to specific retention within the matrix. With increasing distance from the pit void, the impact will be reduced pressure, i.e. drying will not occur. Pore pressure measurements (taken from vibrating wireline piezometers) for slope stability investigations indicate the average hydraulic head as a relative level (RL) in the upper clay layer is approximately 680 m, which would suggest:

• clays are completely saturated as the static head is approximately 13 m above the top of the unit

• the static water level in the clay approximates to the water level in the deep confined aquifer at 680 mRL and is 3 m less than static water levels as measured in the shallow aquifer of 683 mRL.

Consolidation of the clayey detritals occur if they are depressurised/dewatered. The reduction in moisture content within the clays may bring about a reduction in volume; however, these changes would be relatively small. Surface subsidence is expected to be very small and will likely be mitigated by the strong calcrete units above, which would tend to bridge this subsidence.



Item Submission from Comment Proponent response Slumping is not expected to occur due to compaction/consolidation of the clayey detritals.

4 The modelled groundwater drawdowns have not been well presented as cross-sections; these should have been included after Figures 25 and 26. The DoW is seeking additional technical material from the proponent, but the DoW's advice on this material may not be available by the closing date for submissions.

Refer to Figure 20 and Figure 21.

5 The proposal requires monitoring of drawdown impacts within the national park, therefore the Department of Environment and Conservation (DEC) and Environmental Protection Authority (EPA) should consider whether it is acceptable to have new monitoring bores installed within the park boundary. This would subsequently involve monthly vehicular access for the life of mine. If drilling additional bores is determined unacceptable, then the DoW would consider that the reduced monitoring program would not allow the proponent to satisfactorily manage the water resource.

A number of monitoring bores currently exist in proximity to the Coolibah woodland. Additional bores are planned to be constructed on the mining lease to monitor the shallow aquifer and its connection with the deep aquifer to determine potential impacts to Minthicoondunna Spring (Figure 8). The Proponent considers the existing distribution of monitoring bores in the National Park to be adequate to gauge potential impacts and therefore does not see the necessity for further drilling in Karijini National Park. Installation of additional infrastructure within Karijini National Park is not a preferred option due to initial disturbance and requirements for ongoing access.

6 Reinjection to the Southern Fortescue borefield is an acceptable way of disposing of excess dewater. However, the proponent should have a range of contingencies available to deal with a dewatering excess should the reinjection be less effective than proposed. Groundwater reinjection triggers in Table 30 need to be technically justified to the DoW.

Pre-abstraction groundwater levels at the Southern Fortescue borefield were between 20 and 30 m below ground level. Therefore, a re-injection trigger level of 5 m above historical groundwater levels in monitoring bores equates to groundwater levels between 15 and 25 m below ground level. This is considered adequate to ensure a significant buffer remains between the watertable and shallow rooted non-phreatophytic vegetation that predominates in the area. Re-injection into the Southern Fortescue borefield is one of a number of contingencies available for dewatering excess. The Proponent is mindful that pumping water from Marandoo to a number of receivers represents a supply side water scheme. Therefore, building flexibility into the range of receivers is critical to the long-term success of the scheme. To date the range of contingencies includes water supply to Tom Price, re-injection at the Southern Fortescue borefield, use for irrigation on Hamersley Station and finally direct disposal to the environment via tributaries of the Southern Fortescue River system.

7 The submitted modelling scenarios for reinjection are reasonable (Appendix 1, MWH Report), however no data is provided to show whether final groundwater levels are at, below or above the natural groundwater levels pre-mining. This data is essential for the DoW to judge the environmental risks from reinjecting to the Southern Fortescue Borefield. The DoW considers that overall the modelling for reinjection is reliable since the Southern Fortescue Borefield has been monitored for many years.

The Southern Fortescue borefield groundwater model domain is presented in Figure 22. Hydrographs from key monitoring points within the model domain are provided in Appendix 2. Key findings from the four re-injection modelling scenarios are outlined in Section 5.3.2.

8 The groundwater assessments and modelling are based on no incidence of vertical leakage from the shallow aquifer to the confined aquifer. This assumption is justified in the technical assessments done in 2005, but these were not provided with the PER. The proponent should submit these documents to the DoW. If the confined aquifer is depleted by dewatering, then there is increased likelihood for downward leakage. If the above assumption of no leakage proves to be inaccurate in practice then there is a risk to the nearby Coolibah woodlands (Priority Ecological

Refer to detailed response in Section 5.3.2. A Coolibah Monitoring Program has been proposed and is included as a proposed Environmental Condition (refer to Condition 6 in Table 28 in the PER). The program will include monitoring of groundwater levels across the Mount Bruce Flats and contingency measures to maintain water levels at the Coolibah woodland.



Item Submission from Comment Proponent response Community). Groundwater levels may lower at a rate that is greater than predicted. The proponent should propose a monitoring program and management strategy to maintain water levels for the Coolibah woodlands if this occurs.

9 Groundwater levels and streamflows will be monitored for consistency with the conceptual and numerical models. However it is considered that divergence will be ambiguous, as the model is a simplified approximation. The DoW is unsure how this should be addressed and would like to further discuss the detailed model work with the proponent before making a final comment.

The Proponent discussed this comment with the DoW at an additional consultation session held on 12 February 2009.

10 The PER states that sinkhole formation due to dewatering close to the mine or reinjection at Southern Fortescue Borefield is a possibility. The DoW takes the position that sinkhole formation within the National Park boundary would be an unacceptable outcome which should result in the permanent cessation of dewatering. Sinkholes forming outside the park and outside the excision would be undesirable although not unacceptable and the DoW considers this to be an acceptable risk. The DoW considers the discussion on sinkhole formation to be inadequate as it does not present prevention or remediation strategies.

Refer to detailed response in Section 5.3.2. Expression of subsidence at the surface will only be apparent where the cavity is close to the surface and the overlying sediments/deposits are pre-dominantly unconsolidated. Monitoring subsidence, if any, on this scale could be undertaken using Light Detection and Ranging (LiDAR) where accuracies of +/- 15 cm can be achieved in mapping surfaces. The Proponent intends to use this technique to monitor the risk to infrastructure (i.e. the railway line) as a precautionary measure only.

11 DoW - Addendum The proponent provided a technical briefing on the 11 December 2008, to address some of the points raised in the DoW’s comments on the PER. The discussion was centred on the further technical information requested by the DoW, however some of this information is not yet available in published material, including:

• water chemistry signatures of springs within Karijini Park,

• geotechnical assessments of the distance from the pit where the confining layer and the confined aquifer are expected to dry out,

• detailed modelling of the progression of drawdowns which could possibly impact Mindthi spring, and

• the compiled assessment of the permeability of the confining layer between the surficial aquifer and the confined aquifer.

Several hydrogeological reports (in addition to those contained in Appendix 1 of the PER) were supplied to the DoW during the public review period (refer to Section 3.1). One of these reports (Liquid Earth 2005) provides a detailed description of the modelling and potential impacts (e.g. progression of drawdowns) based on limited data. Combined assessment of permeability of the confining clay layer can also be found in the Liquid Earth (2005) report from the modelling component of the investigation. In addition, two further consultation sessions with the DoW were held on 11 December 2008 and 12 February 2009 to discuss the key hydrogeological aspects of the Proposal. These sessions provided opportunity to discuss the information in relation to this comment. Preliminary findings from water chemistry signatures of springs in Karijini National Park are summarised in Section 5.2.2 of this document.

12 The DoW highlighted in our comments on the PER that it is critical for us to understand how the proponent developed the conclusion that there is no incidence of vertical leakage from the shallow aquifer to the confined aquifer. This information was explained diagrammatically in the technical briefing on 11 December, however the proponent intends to provide a detailed written explanation in their formal Proponent’s Response to Submissions Document. Until this information has been submitted in a format that allows us to critically assess it, we are not able to comment on the validity of the hydrogeological information. In summary, the DoW considers that the groundwater system’s response to dewatering drawdown is the most significant environmental impact of the project. Therefore we intend to provide the best possible technical assessment of submitted material in order to enable the final EPA decision to be based on sound and defensible technical judgement. The Department of Water reiterates the statement made in earlier

Refer to response to Item 8. Figure 20 shows a conceptual cross-section illustrating the predicted groundwater drawdown. Hydrographs for nested piezometers showing consistent difference in unconfined and confined aquifer water levels are provided in Figure 11, Figure 12, Figure 13 and Appendix 2. In addition, two further consultation sessions with the DoW were held on 11 December 2008 and 12 February 2009 to discuss the key hydrogeological aspects of the Proposal. These sessions provided opportunity to discuss the information to be presented in this response to submissions document.



Item Submission from Comment Proponent response correspondance that it is important for the DoW to provide a critical assessment of the new material submitted in the Proponent’s Response to Submissions Document.

13 DEC The PER does not provide sufficient information (i.e. Figure 33 - aquifer levels in the various aquifers) to provide a clear understanding of aquifer connectivity. The water body heads range from being in connection at bore OW 25 to having a downward head at bore OW12, but it is unclear which lines are from which aquifers. The documentation provided does not give sufficient information to confidently demonstrate the disconnection of the confined and unconfined aquifer systems. Logger data and analysis during pumping and rainfall recharge would have been appropriate information to provide. The PER and associated attachments provide limited information regarding the actual set-up of the model, boundary conditions, recharge dynamics and calibration, and are not sufficient to enable adequate evaluation. The only information provided is in Figures 25 and 26 which display predicted drawdowns in the unconfined and confined aquifers. Recommendation: The predicted degree of interaction between the unconfined and the confined aquifer during proposed dewatering indicated in the PER needs to be verified through hydrological testing and modelling.

An amended version of Figure 33 is provided in this document as Figure 24. Refer also to detailed response in Section 5.3.2.

14 Preferential flow paths could exist in the "swelling clays" and may cause drawdown to propagate preferentially (and rapidly) with catastrophic consequences for water levels in the unconfined aquifer and dependent plant communities. This has occurred during mine dewatering at a number of other sites in Western Australia (some of which support threatened ecological communities). Recommendation: The area around the Mt Bruce Flats be investigated for the presence of potential preferential flow paths using airborne geophysics combined with strategic drilling correlation.

Refer to response to Item 2. Airborne geophysics will not determine the presence of preferential flow paths, only the extent of clay in the basin and presence of substantial holes or gaps in the clay, which is very unlikely given the nature of how the clays were deposited (lake environment) and the persistent nature of the clay, which has been proven through extensive geological resource drilling and to a lesser extent hydrogeological drilling.

15 The PER indicates that there is likely to be some risk of impact on particular springs and pools within Karijini National Park, however, the extent of this risk is unclear. Risks to the biodiversity, recreational or heritage values of Karijini National Park resulting from the development need to be managed to a high standard to ensure that any impacts are avoided. Recommendation: The proponent demonstrates (through hydrogeological investigations, modelling and/or testing), that the springs and pools within Karijini National Park will not be adversely affected by changes in groundwater levels due to dewatering of the confined aquifer.

Refer to detailed response in Section 5.2.2. Banjima Pool occurs approximately 25 m above the regional groundwater table and is therefore very unlikely to be fed by groundwater. Water chemistry data collected by Dodson (2008) support this (refer to Section 5.1.4 in the PER). Therefore, there is negligible risk that Banjima Pool will be affected by the Proposal. As stated in the PER, Minthicoondunna Spring is believed to be supported by groundwater discharge and may be affected by the Proposal. Any potential impact to Minthicoondunna Spring would occur only towards the end of the mine life. Further investigations to be conducted by the Proponent will determine the likely impact to the spring and will be the basis for adaptive management.

16 Key areas of risk to springs and pools in Karijini National Park from dewatering at Marandoo mine site include potential decreases in water levels at

Refer to Section 2.3 and to response to Item 15. Chemistry analysis of the water at Banjima Pool has demonstrated that this



Item Submission from Comment Proponent response Minthicoondunna Spring, Banjima Pool and other springs/pools or riparian vegetation that may be receiving water directly or indirectly from groundwater discharge such as along Turee Creek. The Dodson (2008) report (referred to in Appendix 1) includes comments on the connectivity of many springs to the Marandoo ore body, but doesn't sufficiently justify the conclusions in relation to impacts on springs. Other techniques such as isotopic analysis or detailed geochemistry could be employed with minimal impact on the environment to determine water sources for springs and pools. Recommendation: That accurate baseline information for this area be available to assess potential impact from the dewatering activities and set management trigger levels (based on current information, appropriate hydrological and ecological investigations and surveys of the aquatic flora and invertebrate communities appear likely to be required for Minthicoondunna Springs and Turee Creek).

pool is not associated with groundwater. This is illustrated by chloride concentrations found at the pool which are indicative of rainfall and not groundwater. The proposed mitigation and management measures specified in the PER are considered adequate to manage potential impacts to Minthicoondunna Spring.

17 The current Groundwater Management Plan does not adequately explain or manage the level of potential impact on pools and springs in Karijini National Park that may result from the proposed dewatering and re-injection. With regard to Banjima Pool, it is recognised that groundwater investigations to date have indicated that this pool is not fed by groundwater, however, given the short distance between the mine and Banjima Pool and the extent of the dewatering program, DEC still considers this site to be at risk from direct or indirect impacts of dewatering, and therefore this aspect needs to be adequately addressed in the Groundwater Management Plan.

Refer to response to Item 15.

18 The Groundwater Management Plan should be further developed to the requirements of DEC to provide a more effective and transparent mechanism to adequately manage the protection of water levels. Areas that need to be further addressed in the plan include:

• appropriate objectives, agreed by the Conservation Commission, for protection of the ecological and other conservation values of pools and springs in the national park;

• targets relating to acceptable levels of change to meet the defined objectives such as "no changes in water levels of pools and springs in Karijini National Park" as a result of the Marandoo Mine Phase 2 development;

• monitoring of water levels (and if necessary ecological values) at Banjima Pool, at Hamersley Gorge and other pools and springs in Karijini National Park;

• trigger levels relating to water levels of pools and springs that are well defined, specific, and measurable; and

• well defined and specific contingency measures, to be implemented in the event that a trigger level is reached.

The current Groundwater Management Plan is adequate to address the level of risk to Minthicoondunna Spring. Objectives have been developed for the Plan to ensure pools and springs are protected. Further investigation and modelling on Minthicoondunna Spring will be undertaken as part of the Plan. Contingency actions to protect ecological values of the spring will also be enacted should water levels in Minthicoondunna spring to be lowered as a result of the Proposal.

19 The PER does not provide evidence that the proponent understands the processes influencing sinkhole development, and in particular the susceptibility of the two risk areas (Marandoo mine and South Fortescue borefield) to the

Refer to detailed response in Section 5.3.2.



Item Submission from Comment Proponent response formation of sinkholes as a result of dewatering and re-injection. DEC is aware that sinkholes have already formed in the park in the vicinity of the South Fortescue borefield and has discussed possible remediation and additional management of impacts for these with the proponent. Recommendation: Further investigations into the potential risk of new sinkhole formation associated with operations at the Southern Fortescue borefield and Marandoo mine be undertaken by the proponent, and the results provided to DEC to review prior to any approval of the project.

20 It is understood that the proponent will be undertaking further investigations to assess the potential risk of new sinkhole formation at both the Southern Fortescue borefield and Marandoo (p. 74). This assessment should be undertaken as a priority by the proponent, and the results provided to DEC and the EPA to review prior to the approval of the project. Recommendation: The proponent investigates potential measures to avoid the formation and/or minimise the extent of sinkholes in Karijini National Park, and implements these measures where possible. If the formation of sinkholes in the national park cannot be avoided, dewatering operations should either cease or be subject to agreed remedial or mitigation measures as agreed by DEC.

Sufficient modelling and investigations have already been undertaken to enable an impact assessment of the potential risk of new sinkhole formation (e.g. MWH 2007). Further monitoring of the formation of sinkholes can be agreed upon in addition to mitigation measures if determined that impacts are related to dewatering. Refer also to responses to Item 1 and Item 10.

21 If the formation of sinkholes in the national park (and adjoining exclusion area) is identified and considered environmentally acceptable by the Government, resourcing of measures to address rehabilitation and ongoing management and liability for sinkholes needs to be made the responsibility of the proponent. Fencing of sinkholes is not considered to be an effective medium to long-term management strategy.

There are no known effective sinkhole rehabilitation measures. Liaison will continue to take place with the DEC regarding ongoing management of sinkholes (should they form within the boundaries of the National Park). Refer also to response to Item 22.

22 Recommendation: A communications protocol between the proponent and DEC be developed and be informed by monitoring, in order to ensure that DEC is regularly informed of any new or potential sinkhole areas forming in the park.

The meetings held in accordance with the existing SMU (refer to Section 3.2) are the appropriate forum to inform the DEC of any new or potential sinkhole areas forming in the National Park.

23 A sinkhole management strategy be developed by the proponent, to the satisfaction of DEC, that details how sinkholes will be managed in Karijini National Park in order to minimise risks to visitor safety, park infrastructure, biodiversity, visual amenity, and heritage values. Rehabilitation of sinkhole areas by the proponent within the national park and Hamersley Station 2015 pastoral lease exclusion area is an item that needs to be covered by the sinkhole management strategy.

The proposed mitigation and management measures outlined in Section 5.3.5 in the PER include conducting an investigation into the mechanics of sinkhole formation in the Southern Fortescue borefield, identifying high risk areas, monitoring the Marandoo and Southern Fortescue area for the development of sinkholes, fencing, and implementing other measures to reduce potential risks. The Proponent considers that these measures are sufficient and that a specific sinkhole management strategy is not required.

24 Disposal of water from mine dewatering is a significant issue for this project because the proponent is foreshadowing that water that is not able to be utilised at either the mine or the town of Tom Price, or injected into groundwater aquifers, is planned for disposal to arid adapted surface ecosystems. Additionally, there is some risk that groundwater injection at the Fortescue borefield, if not effectively managed, will lead to impacts on flora and vegetation communities at the borefield, which is within an area that will fall under DEC




Item Submission from Comment Proponent response management in 2015. Recommendation: The proponent demonstrates through hydrogeological modeling, that the South Fortescue borefield will be able to support the volumes of water to be re-injected as predicted in the PER.

25 DEC - Addendum The additional information provided appears to indicate that there is variability in the conductivity of the clay layer which separates the superficial and confined aquifers. This uneven permeability has the potential to result in the establishment of preferential flow paths between the two aquifers under a dewatering scenario, resulting in significant drawdown of the superficial aquifer. Review of the modelling conducted by MWH for RIOTIO indicates that although this modelling was appropriate for estimating dewatering requirements for the mine operation, inherent assumption of minimal aquitard variability means that it is unlikely to have been suitable for reliably predicting the potential for long-term changes in groundwater levels / surfaces within the superficial calcrete aquifer that could lead to impacts on biodiversity values. Further investigations on the hydrogeological conditions in the drawdown area and modelling based on the results of these investigations is warranted to support more accurate and conservative prediction of impacts on groundwater and dependant ecosystems and provide reasonable certainty that the impacts on biodiversity can be appropriately managed and mitigated.

The establishment of preferential flow paths is very unlikely given the nature of how the clays were deposited (lake environment) and the persistent nature of the clay, which has been proven through extensive geological resource drilling and to a lesser extent through hydrogeological drilling. Given the spatial distribution of monitoring points and long-term water level monitoring, the Proponent would suggest that the existing model captures adequate variability on the scale (both temporal and spatial) of interest following two long-term injection and dewatering trials. Further hydrogeological investigations regarding the potential impacts on Minthicoondunna Spring are in the process of being planned (Section 2.3.1). As a result, the existing groundwater model will be updated and scenarios further tested to gauge the potential for impacts and subsequent recommended mitigation measures.

26 The PER does not provide sufficient information (i.e. Figure 33 - aquifer levels in the various aquifers) to provide a clear understanding of aquifer connectivity. The water body heads range from being in connection at bore OW 25 to having a downward head at bore OW12, but it is unclear which lines are from which aquifers. The documentation provided does not give sufficient information to confidently demonstrate the disconnection of the confined and unconfined aquifer systems. OW10s, OW21s, OW23s and OW08s appear to show some evidence of connection (and draw down) during pump testing.

Refer to response to Item 13. Hydrographs of bores show a hydraulic connection only between intermediate (i) and deep (d) bores, but little or no connection between shallow (s) and deep (d) bores. All bores show a downward head from the unconfined aquifer to the confined aquifer (Appendix 1).

27 The PER and associated attachments provide limited information regarding the actual set-up of the model, boundary conditions, recharge dynamics and calibration, and are not sufficient to enable adequate evaluation. Additional information provided to DEC by the proponent indicates that the groundwater modeling, although sufficient for determining dewatering/injection volumes and targets, is not sophisticated enough to predict impacts on the superficial unconfined aquifer (refer to Section 4.1 of the MWH (2007) report)) and therefore the impacts on groundwater dependant ecosystems. Additionally, the information provided does not indicate that any uncertainty/sensitivity analysis of the effect of assumptions on model results has been undertaken even though it is a recommendation in the MWH (2007) report (Section 4.2). This uncertainty/sensitivity analysis of the modeling undertaken is critical to understanding the level of confidence in prediction of the potential for long term changes in hydrology resulting from the proposed mining dewatering operations and consequent impacts on groundwater dependant ecosystems. A much higher resolution model for the upper aquifer is required, that incorporates explicit modelling of unsaturated zone processes (MODFLOW-

Model assumptions have been specified in Liquid Earth (2005), which was provided to the submitter during the public review period. Model assumptions on model geometry, aquifer extents, vertical extents, hydraulic properties, recharge area can be sourced from this report. Information on calibration of the model is also available in the report. A sensitivity analysis on the model is currently being undertaken.



Item Submission from Comment Proponent response Surfact or MikeSHE) and the impact of drawdown. This would then allow the impacts of preferential flows to be adequately predicted. Until this analysis is undertaken, the predicted impacts on the Coolabah Woodlands PEC as outlined in the PER are likely to be speculative at best.

28 Preferential flow paths could exist in the “swelling clays” and may cause drawdown to propagate preferentially (and rapidly) with catastrophic consequences for water levels in the unconfined aquifer and dependent plant communities. This has occurred during mine dewatering at a number of other sites in Western Australia (some of which support threatened ecological communities). There is some evidence of the existence of conditions conducive to preferential flow in hydrographs and bore logs provided as additional information to DEC by the proponent. Recommendation: The area around the Mt Bruce Flats should be investigated for the presence of potential preferential flow paths using airborne geophysics combined with strategic drilling correlation. This could be related to the presence of ‘crabholes’ which may indicate surface expressions of preferential flow paths.

Refer to response to Item 2. The establishment of preferential flow paths is very unlikely given the nature of how the clays were deposited (lake environment) and the persistent nature of the clay, which has been proven through extensive geological resource drilling and to a lesser extent through hydrogeological drilling.

29 Martu Idja Banyjima Native Title Claim Group

It is acknowledged in the PER that mining below the water table at Marandoo may cause these springs to dry up. This will result in incalculable loss and damage to our clients and other Aboriginal Groups with responsibility for the springs, including Gurama people.

The submission refers to Minthayi Springs (which is referred to in this document and in the PER as Minthicoondunna Spring). Refer to detailed response in Section 5.2.2.


The boundaries of the model domain were assumed to be closed The amount of water that would need to be removed for dewatering would depend critically on these assumption. Closed boundaries would lead to a conservative estimate for the draw down, but would clearly lead to underestimates of the volume of water that would need to be withdrawn.


31 Wintawari Guruma Aboriginal Corporation


The model had 4 layers in the vertical, the soil properties in each layer were assumed to be horizontally uniform The assumption of uniform soil properties is justified by noting the model coefficients could be adjusted to match 3 pump test results. This is clearly optimistic, particularly as the pump tests were done very close to the pit area.

Refer to detailed response in Section 5.3.2. The assumption of uniform “soil” or aquifer properties is an issue of scale. At the local scale, aquifer properties are heterogeneous and anisotropic (i.e. non uniform). At larger scales (e.g. tens of kilometres), as presented by the Marandoo numerical model, aquifer properties tend to display similar characteristics in hydraulic gradient and thus lend themselves to representation as homogenous and isotropic (i.e. uniform).



The assumed rainfall in the simulations was that currently observed. The model appeared to allow for surface infiltration, but no details were provided to ascertain its adequacy. No allowance was made for the projected increase in rainfall of about 400 to 500 mm over the life of the mine. The assumption of constant rain patterns as have occurred over the last few years is foolish, when the Bureau of Meteorology has excellent published data results showing major past and future changes. What is even more annoying is the response from Rio Tinto, that they have spent "millions" of dollars on climate change research for the area, but this is confidential.

There is no consensus on rainfall projections for the Pilbara region. Following the 2007 release of the Intergovernmental Panel on Climate Change (IPCC) report and owing to the limited detail provided on Australian climate change, the Australian Greenhouse Office (through the Australian Climate Change Science Program) engaged CSIRO and the Bureau of Meteorology to develop climate change projections for Australia. These projections are summarised by CSIRO and Australian Bureau of Meteorology (2007). The outcomes in the report are based upon international climate change research including conclusions from the IPCC fourth assessment report. The report also builds on a large body of climate research that has been undertaken for the Australian region in recent years.





CSIRO and Australian Bureau of Meteorology (2007) indicate that the 50th percentile (which is the mid-point of the spread of model results and provides a best estimate result) shows an overall decrease (2–10%) in the average annual rainfall in the Pilbara region for the 2030 climate change modelling scenarios. These results do not give significant details about the changes in frequency, intensity or duration of rainfall events. Whilst there is substantial disagreement between climate models concerning future changes in tropical cyclone intensity, the highest resolution models show evidence of an increase in tropical cyclone intensity in a warmer world and IPCC (2001) concluded that “there is some evidence that regional frequencies of tropical cyclones may change but none that their locations will change. There is also evidence that the peak intensity of cyclones may increase by 5% to 10% and precipitation rates during cyclones may increase by 20% to 30%. There is a need for much more work in this area to provide more robust results.” These predictions will have implications for the Pilbara, where tropical cyclones and tropical lows are the primary mechanism for producing heavy rainfall in the region. The rainfall scenarios adopted for the Marandoo groundwater modelling are therefore considered appropriate. A sensitivity analysis will be conducted in the future to consider how the range of climate change forecasts influences Marandoo modelling conclusions. Recharge is often minimal as a percentage of total annual rainfall (1–3%). Thus, impacts over the life of the mine, in association with increasing or decreasing rainfall, would be negligible in terms of groundwater volumes. Should rainfall increase over the future years then potential recharge will also increase. This will dampen any potential impacts associated with dewatering.


The model validation relied on reproducing bore depressions from sites in the actual proposed excavation area.

Model validation was based on pump testing in bores in and near the proposed mint pit, as well as pump testing in injection bores prior to injection.



It was assumed that no water would drain from the unconfined surface aquifer The assumption that no water would drain from the surface aquifer is badly flawed, if the report is to be taken verbatim, but this could simply be a problem with the text.

Where the clay layer occurs, there is predicted negligible effect on groundwater levels owing to the very low permeability of the clay and the fact that the groundwater level in the unconfined aquifer is dependent on rainfall recharge events (when a groundwater mound occurs in the centre of the Mount Bruce Flats). Where this clay is absent on the southern margins of the flats, there will be a degree of hydraulic connection, resulting in alteration to the watertable; hence the identification of potential impacts to Minthicoondunna Spring in the PER. In addition, where the pit void occurs, the matrix containing the watertable aquifer will be removed, thereby affecting the watertable.



It appears, as mentioned in the PER, it is likely that the dewatering will impact the Minthi spring area. Rio Tinto has indicated that a careful monitoring programme, along a transect leading from the mine site to the spring, will be maintained. It is further stated that if this monitoring programme shows any signs of adverse impacts on the springs, action will be taken. There are no details in the report of any actions should the monitoring show

a) The PER states there is a risk that dewatering impacts might extend to Minthicoondunna Spring if the local calcrete aquifer supporting the spring is connected to the basement aquifer (due to absence of the clay layer). The installation of the monitoring network will have two benefits:

• firstly, it will provide an opportunity to explore for the presence or absence of the clay layer, reducing uncertainty on the issue




Item Submission from Comment Proponent response potential impacts of the mining activity on the springs. Three main issues arise: a. Given the variability of the rainfall, it will be very difficult to "prove" that

mining is having an impact b. Once problems are detected even a fraction of the distance from the mining

area to the springs, it will be many years before any alleviation measure will be able to correct the incursion

c. There only two ways to reverse any impact. First halt the mine dewatering activity and second inject dewatered water upstream of the springs. Neither is explored, both have major problems in being implemented.

• secondly, it will provide an early warning system for how dewatering impacts are propagating through the watertable and basement aquifers, including magnitude and rate (timing).

b) Changes to the mine plan are possible and could involve modified dewatering plans or reduced target depth or easterly extent of mining, which would likely reduce need for dewatering. Groundwater equilibrium will likely take many years to re-establish once dewatering commences. In fact some analytical modelling sensitivities conducted indicated that impacts would not propagate to Minthicoondunna Spring until after mining has finished. The mine plan is such that initial dewatering is concentrated on the far western end of the proposal and is significantly distal from the spring (approximately 15 km). This distance will allow sufficient time to monitor and re-assess mining plans and potential impacts. As such, the Proponent will be well placed to reduce the uncertainty associated with impact to the spring before mining activities would result in unacceptable risk. c) Contingency actions (to be enacted if monitoring indicates potential impacts to Minthicoondunna Spring) are described in the Groundwater Management Plan in Appendix 2 of the PER. Should a reduction in the water level at observation bores between Marandoo and the spring occur, the Proponent shall: 1. Investigate the cause/s. 2. Commence more frequent (monthly) monitoring of water levels and validate

groundwater model based on observed drawdown. 3. Based on revised groundwater model results, review and revise impact

assessment and management plan. 4. Undertake appropriate remedial action as required. Should a reduction in the extent or depth of the spring occur beyond natural variation, the Proponent shall: 1. Notify the CEO of the DEC immediately. 2. Investigate the cause/s and undertake stakeholder consultation. 3. Provide the CEO of DEC with details of mitigation and management being

undertaken and an assessment of the residual risks to the springs. 4. Undertake appropriate remedial action (e.g. re-injection and/or surface

irrigation) as required to the satisfaction of DEC and Traditional Owners. Actions that could be taken are varied and will be discussed in consultation with Traditional Owners. The options available to mitigate impacts (if observed) can be grouped into:

• supplementation of spring

• changes to the mine plan. Supplementation of the spring could be achieved either directly (e.g. small pump and pipe), or indirectly via injection, the latter being technically difficult to



Item Submission from Comment Proponent response achieve.


The chemical data from different sites showed essentially three or four groups of water origins. The groupings were clear and offer opportunity to identify flow paths. No such analysis seems to have been carried out, nor was it clear at what depth the water samples came from. In response to questions raised during the course of a consultation with the Martu ldja Banyjima and Wirntawari Guruma native title claim groups on 10 November 2008 at Tom Price, an officer of Rio Tinto made the incredible statement that solute transport was impossible to do and has never been done successfully. This is despite the company ascertaining that the ground water moved in two aquifers, one unconfined and one confined, both made up of predominantly sand, silt and some clay. In the dewatering modelling very simply assumptions were made. In such soils salt would move pretty much in a conservative fashion, so modelling its path would be straight forward. Such solute transport modelling would clearly articulate the flow paths and the possible connections between the dewatering water and any surrounding springs.

The water samples presented in the PER came from either production bores at Marandoo, the Southern Fortescue borefield or from the gorges themselves (i.e. surface water). The depths are somewhat irrelevant other than to identify the aquifer types, which were presented in the PER. The chemical analysis clearly indicated that the majority of gorge waters could not be derived from Marandoo groundwater as the systems are not connected. As such, there is no requirement to demonstrate a flow path. Where the chemical analysis indicated groundwater of similar origins, the mechanisms for transport are understood and have been documented, so the need for solute transport modelling is negated and such testing is considered unnecessary. Refer also to detailed response in Section 5.2.2.


44 Martu Idja Banyjima Native Title Claim Group – Addendum

The submission refers to the Liquid Earth (2005) report. In the executive summary it is stated: Pg 3: “The derived aquifer transmissivities at Marandoo range between 50 m2/d and 1800 m2/d,” This is a huge variation!

Variations in transmissivities (or the product of saturated thickness and hydraulic conductivity) at Marandoo are large due in part to the occurrence and/or complete absence of secondary permeability structures such as vugs and fractures. Where present, these structures have developed through the mineralisation process in which silicates are stripped from the host Banded Iron Formation.

45 Wintawari Guruma Aboriginal Corporation – Addendum


The submission refers to the Liquid Earth (2005) report. Pg 7 “There are a number of uncertainties relating to the conceptual hydrogeological understanding of the Marandoo groundwater system and in particular in relation to the degree of connectivity between the major aquifers of the area. This uncertainty has implications for both the estimation of pumping volumes and rates required to dewater the ore body in advance of mining and for the prediction of the potential impacts resulting from a long term dewatering operation on the surrounding groundwater environment.” This point is made almost continuously, yet ignored in the conclusions

The Liquid Earth (2005) report provided the initial hydrogeological understanding of the Marandoo groundwater system. Since that time, field testing and modelling have been ongoing to reduce uncertainties associated with the degree of connectivity. Refer also to response to Item 2.



The submission refers to the Liquid Earth (2005) report. Pg8: “The median annual rainfall at the Marandoo recording station is 346 mm, with a range of 242 to 802 mm over the 28-year record. The 'dry' season of July to November experiences very little rainfall, averaging 8 mm per month. The rainfall record for Marandoo is presented as Figure 2.1.” What about climate change scenarios?




The submission refers to the Liquid Earth (2005) report. Pg 8: “The key unknowns in the understanding of the Marandoo groundwater system are: 1. the degree of connection between the mineralised Marra Mamba and

Wittenoom Dolomite bedrock aquifers, and






2. the degree of connection between the shallow calcrete and deep bedrock groundwater systems beneath the Mt Bruce Flats to the north of the operation.”

These were never answered. Pg 8: “Estimates of dewatering requirements derived from the various investigations completed to date range from 6 MUd to 120 MUd. The hydraulic properties of the two major bedrock aquifers identified in the area (mineralised Marra Mamba and cavernous Wittenoom Dolomite) have been estimated to range between 800 m2/d to 7000 m2/d. In addition there remains significant debate regarding the degree of connection between the two major bedrock aquifers and between the deep bedrock system and a shallower system of valley fill calcrete which underlies the Mt Bruce flats to the north of the Marandoo site” Again!


The submission refers to the Liquid Earth (2005) report. Pg9: The report list the objectives of both the field and modelling work: “The primary objectives of the investigation were as follows:

• to derive representative aquifer properties and conclusively establish the boundary conditions of the Mineralised MalTa Mamba bedrock aquifer at Marandoo;

• to derive aquifer properties of the Wittenoom Dolomite aquifer to the north of Marando o and quantify the connection between the Wittenoom Dolomite and the Mineralised Marra Mamba bedrock aquifers;

• to conclusively quantify the connection between the deep bedrock (Wittenoom Dolomite) and shallow (Calcrete) groundwater systems underlying the Mt Bruce Flats to the north of Marandoo;

• to establish the hydraulics of dewatering bores completed into the Mineralised Marra Mamba aquifer and so optimise future dewatering bore designs;

• to establish the hydraulics of injection bores sited into the Wittenoom Dolomite and so determine the feasibility of aquifer injection as a method of long-term water disposal;

• to quantify the dewatering requirements of Marandoo BWT against an agreed mining schedule; and

• to quantify the potential impacts of bedrock dewatering on the shallow groundwater system and associated environmental and heritage features of the Marandoo area.”

Good objectives, but never answered.

In summary with reference to the same report by Liquid Earth (2005): 1. Representative values for both transmissivity and storage and/or specific

yield have been derived and adequately documented. Testing the nature of the assumed boundary of the West Angeles Member has been proven. Hydraulically the Marra Mamba Iron Formation is connected with the more regional Wittenoom Formation and associated detritals overlying it.

2. As above for the dolomite of the Wittenoom Formation. 3. From the field tests it has been illustrated through the injection trial that

there is no vertical hydraulic connection between the two groundwater systems where the clay separates the aquifers.

4. Given estimates of aquifer properties from field testing scenarios for dewatering, pumping rates have been explored through the groundwater modelling.

5. As with the proposed dewatering bores, design injection rates following field trials have been tested.

6. Dewatering requirements have been estimated given mine plans provided at the time.

7. Potential impacts associated with deep aquifer pumping have been assessed with regards to impacts to both the Coolibah woodland and areas in the vicinity of Minthicoondunna Spring. These assessments will be refined through further verification.



The submission refers to the Liquid Earth (2005) report. The field tests, while extensive were almost all confined to an area close to the proposed excavation, with really only one site in the Wittenoon Dolomite area north of mine area. Further the pump tests were of most only 5 day duration,

Extensive test pumping on all production bores (injection and abstraction) has been conducted prior to the actual injection trial. The injection trial comprised combined abstraction from two bores in close proximity to the proposed mine pit and injection into a dolomite aquifer bore

55 Wintawari Guruma Aboriginal



Item Submission from Comment Proponent response Corporation – Addendum providing only very local snapshots of hydraulic conductivities. near the southern edge of the Coolibah woodland for a total of 44 days.

Subsequent to the 2005 program, a larger “drop cut” trial was undertaken to produce a bulk sample of below watertable ore. In this trial, more than 0.5 GL was abstracted over 56 days and re-injected back into the ore body. The groundwater level response during and following the trial was used to validate the groundwater model. Limitations on the extent of abstraction and injection for the initial trial were based upon:

• logistics to complete the trials on Mount Bruce Flats prior to the start of the wet season

• gaining adequate information/data on absence of responses (especially in shallow bores) for impacts of the trial after a seven week period.

Limitations on the box cut trial were operational and therefore limited to the time of the mining trial.


The submission refers to the Liquid Earth (2005) report. The model was a four layer model, with rather coarse conductivity descriptions. The boundary conditions were, it appears, although not stated in the report, closed. This is very strange given the layered nature of the ground and the assertion that the deep confined aquifer is disconnected from the surface aquifer.




The submission refers to the Liquid Earth (2005) report. The long term 1994 to 2004 simulation shows trends that seem to suggest that the model set up was wrong. The rainfall, as seen from Fig 2.1 shows increasing rain from 1994 to about 1999 and then a gradual decrease from 1999 to 2004. By contrast nearly all groundwater levels in the deep aquifer showed an in increasing measured water level starting from about 1999 (see fig for OW15D) but a decreasing simulated water level. Further, the model results seem to suggest a seasonal water level fluctuations whereas the measured water level shows first a steady decline and then a steady rise over 5 years; clearly the deep aquifer is responding to inflows from a long way upstream, whereas the model does to not allow for this. Suppose we assume a response time of 5 years, and a conductivity of around 40 m/s and a hydraulic gradient of 1 in 1,000 then the water would have come from at least 1,000 km, far outside the model area. This estimate is rough and could be as low as 20km, but given the poor comparisons, as typified by Fig OW15D (representative of all), the larger number is probably closer to reality.

The model set-up is just one approximation or possible conceptualisation of the groundwater system at Marandoo and its surroundings. Given the available data and its distribution of estimated parameters (spatially and temporally), the approximation is representative. Regardless of the amount of testing conducted, uncertainty in the magnitude and spatial distribution of hydraulic conductivity and recharge will remain. On this scale responses will be averages or deterministic in nature. The hydrograph response would suggest the cumulative effect from increased or decreased rainfall may only be propagated as a corresponding increase or decrease in water levels after a time lag of several years. This may illustrate that the actual event is contributing to recharge to the confined aquifer relatively close to piezometers rather than 1000 km away as has been suggested. Some responses to rainfall events such as that of March 2004 would suggest that a time lag existed prior to prominent responses in most confined aquifer piezometers, especially in the Wittenoom Formation, as compared to a more rapid response in the Marra Mamba Iron Formation, which can be linked to the respective confined and unconfined nature of both. Assuming a hydraulic conductivity of 40 m/s is far beyond the range of approximately 0.0003 to 0.01 (approximately 3 to 100 m/d), which would mean the hydrographs are responding to events within the model area on the scale of up to kilometres. This can be substantiated by the fresh water quality found even in deep confined tapping piezometers.



The submission refers to the Liquid Earth (2005) report. The model estimates potential impacts given the available data as best as possible. As more data becomes available, the model will be updated and





The model set up invalidated estimate of ground water impacts of de-water, but the model may give reasonable estimates of the dewater amounts in a period of 10 to 15 years.

scenarios further tested. During this process of re-validation dewatering estimates will also be reviewed.


The submission refers to the Liquid Earth (2005) report. The proposed injection site location does not seem to agree with environmental report.

The Liquid Earth (2005) report presented information on a trial injection bores that were part of the field testing program to improve the understanding of the aquifer interconnectivity. These bores are separate to the re-injection bores and these tests were not used to test the capacity of the re-injection site to accommodate discharged water.



The submission refers to the MWH (2006b) report. This is essentially a model validation of the April Report From Exec Summary: “The focus of the recalibration using the MMBWT dewatering and reinjection program was to refine parameter zonations and quantify aquifer properties in the dewatered area (Marandoo Area A) and around the reinjection bores (predominantly along the southern side of Marandoo Area B). All the hydrogeological work at Marandoo to date has demonstrated extreme variability in the properties of the Marra Mamba orebody aquifer. It is therefore valuable to develop the Marandoo Groundwater Model with local information as that information becomes available. The monitoring associated with the MMBWT dewatering and reinjection program provided an ideal dataset for the refinement of the model.” “The model calibration indicates that the basal Tertiary mudstone (gravels and clays) may play a more significant role in mine dewatering and subsequent impacts than was previously thought. The calibration demonstrated that the basal Tertiary sediments can be moderately permeable and hydraulically continuous across several hundreds of metres. Their significance is enhanced by the variable (from low to high) permeability of the underlying Marra Mamba orebody, which means the two aquifers can be equally as influential in the propagation of hydraulic perturbations. The model calibration confirms that the orebody is, in broad terms, hydraulically continuous along-strike and down-dip across the Marra Mamba orebody. The dewatering strategy proposed in earlier reports (eg Liquid Earth 2005), of dewatering through multiple bores on the down-dip side of the Marra Mamba orebody aquifer, is supported by this finding. The variability of the Marra Mamba aquifer was reinforced strongly during the calibration process, and the variability should be considered carefully at the design stage should development of a dewatering network proceed.” This is a nice validation, at a local scale of dewatering and re-charge. However, it adds little (as admitted in their own conclusions) about the validity of the model in the larger scale impacts or long term trends.

This report referred to focuses more on the drop cut investigation as the mechanism for stressing the system, but the calibration and validation process still involves more distal observation bores such as OWS15D and OWS12D and S (deep and shallow) in the Mount Bruce Flats to the north of the proposed mine pit. Inclusion of these monitoring points in the program is evidence that potential impacts have been allowed for on a broader scale and not just as a process for designing dewatering infrastructure.



The submission refers to the MWH (2006a) report. This is essentially an extensive local dewatering experiment, the results from which were used in the next report to fine tune the model. An extensive field test from 20th Sep 2005 to 12th Dec2005, short term test for testing dewatering amount with injection to the north. Good for mining estimate, but says little about broader long term impact.

To actively assess potential impacts, the aquifer has to be stressed. The trial described in the report mimicked, on a smaller scale, what has been proposed and, as such, answered questions relating to drawdown impacts. Most impact studies are based on limited data (e.g. 72 hour pumping tests extrapolated over the proposed mine life). This trial not only stressed the target aquifer, but also investigated potential disposal options and impacts.


68 Martu Idja Banyjima Native The submission refers to the Liquid Earth (2005), MWH (2006a, 2006b) reports. Refer to detailed response in Section 5.3.2.



Item Submission from Comment Proponent response Title Claim Group – Addendum The three reports, all written by the same company, offer results from a very

extensive field and model investigation. However, the focus of this work was clearly and very obviously on providing Rio Tinto assurance as to the engineering feasibility of the dewatering. All the work was local in scale, short term and focused on the Marra Mamba ore body



The submission refers to the Liquid Earth (2005), MWH (2006a, 2006b) reports. It is clearly that these engineering results were then massaged into format in both the above three reports and the environmental report, to provide a façade of environmental compliance. As detailed above, the model set up is badly flawed when viewed from an environmental impact assessment perspective; the broad scale aquifer variability was not captured, the closed boundary conditions are clearly inadequate and the observation bores were not placed with potential impacts in mind.




Thus while the modeling was adequate from the engineering operational point of view, the the model results and the field test cannot be used, in my opinion to say anything about the likely environmental impacts to springs, water levels or vegetation impacts.




No mention is made of the likely increase in rainfall due to climate change, it appears, contrary to statements at the meeting, that simple historical rainfall data was used.



76 Conservation Council

The proponent has recently displayed a poor performance in ground water modelling and managing subsequent impacts at Hope Downs (Weeli Wolli Creek). The modelling at Weeli Wolli creek was clearly incorrect and now serious ecological and indigenous heritage impacts are occurring, with worse expected. The proponent has not been able to respond to this challenge in an adaptive management framework, instead applying to dewater further volume into the creek, further increasing the impacts. The proponent has also demonstrated a poor attitude to indigenous heritage at this site by failing to commit to the long term protection of a major archaeological site discovered at Hope Downs, another adaptive management failure. There is no justification for taking this risk with the highly significant and broadly appreciated natural values associated with springs and water in the Karijini National park. The proponent's previous failures in ground/surface water modelling and failures in adaptive management response increase the risk of an impact on Karijini National Park (unacceptable as discussed above).

The groundwater modelling predictions at Weeli Wolli Creek have been well validated with dewatering volumes and aquifer response, with predictions closely matching observations. The submitter is referring to the extent of surface water flow and the perceived impacts from the discharge of surplus water. This issue was not presented in the groundwater modelling, nor was it an outcome of the groundwater model. The Hope Downs groundwater model has been very well represented and has proved relatively reliable. Discharge of surplus water into Weeli Wolli Creek and the associated potential impacts are being monitored on a monthly basis. No detrimental environmental impacts have been observed to date, other than increased perennial flow. Perceived impacts and Traditional Owner dissatisfaction with the current situation are readily acknowledged.

77 There are a number of inherent risks in the groundwater modelling for this project; namely that a link between the confined and unconfined aquifers is present or will be created by a failure caused by the dewatering impacts, that the modelling of flow from the unconfined aquifer is incorrect, or that the drawdown of 0.5m at the Coolibah woodlands is enough in a possible drought period to cause impacts on the woodlands (unacceptable in the National Park). Any impacts on the unconfined aquifer due to the pit will be permanent and any dewatering impacts will likely persist in the medium to long term, thus there is a very real risk that GDE's within the National Park will be permanently impacted.

Refer to detailed response in Section 5.3.2. Drawdown in the unconfined aquifer is estimated to be very localised and temporary. This is expected given the rapid recharge that usually follows cyclonic events and becomes concentrated in the centre of the Mount Bruce Flats, with groundwater flowing from the centre of the resulting mound towards the proposed pit margin. This mechanism for recharge and groundwater flow will not be altered by the Proposal.




78 The mechanisms causing sinkhole formation should be fully understood and management demonstrated before any further water abstraction or re-injection is allowed. This is another example of the complete lack of information underpinning water management in the Pilbara and further highlights the risk of this project to Karijini National Park. The formation of sinkholes within the National Park would be a completely unacceptable outcome.


79 Confidential submission Historically, the knowledge of the existence of economically viable iron ore has been known about (namely the Pilbara) for more than 50 years. Yet, the tourism potential of Karijini has only been known for about 20 years. In actual fact, the Karijini National Park has been listed amongst the top 100 “must see” places in the world. For the last 8 years, I have had the privilege of escorting many thousands of visitors to the pristine Karijini gorges. But will the gorges remain pristine if the Phase 2 Proposal goes ahead. The ecosystems in the gorges have to be seen in order to be believed and they are sustained by a ‘seemingly’ never ending source of water (underground water that has been pushed by pressure from inland parts of the country). My technical knowledge of the ‘lay of the land’ pales into insignificance with that of Rio Tinto. But have Rio Tinto got their calculations right with respect to the conclusion that is printed on page 62 of the P.E.R. Quote “There is negligible risk that any gorge, spring or pool in the northern Karijini National Park will be affected by the proposal…” A law need to be proclaimed that if Rio Tinto get it wrong, they should be liable for damages.

Proposed Condition 1 states that the Proponent shall implement the Proposal within a defined footprint. Should the effects of the Proposal extend beyond this footprint (e.g. to the gorges in northern Karijini National Park), an offence would be committed under section 47 (1) of the EP Act. In this instance, the Proponent would be subject to prosecution in accordance with penalties outlined in Schedule 1 of the EP Act.

Refer also to response to Item 42.

80 It has come to my knowledge recently (whether fact or fiction) that the water from the proposed pit will be piped into Tom Price. To reinject the water back into the ground, as per the Proposal suggestion of Rio Tinto, seems far too fanciful because of the expense involved.

As discussed in Section 4.7.1 of the PER, the Proponent has committed to a surplus water management strategy that incorporates the DoW hierarchy of water management methods. The emphasis of the strategy is on ‘use at source’ and ‘transfer’ to maximise opportunities for environmental improvement. The Proponent is committed to piping water to both the town of Tom Price and to the Southern Fortescue borefield and has already undertaken a financial analysis of the expense involved.

Rainfall response of the confined and unconfined aquifer at Marandoo Figure 24

OW30 OW28 OW12 OW15

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Transect 2

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Transect 1

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Mar 2006Dec 2006Sep 2005

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INSET

OW25 OW27 OW12

Transect 2

Unconfined aquifer

Confined aquifer (refer to inset)

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Table 5 Response to submissions relating to watercourses and surface water quality


1 DoW The proponent needs to demonstrate how creek discharge could be managed at a range of discharge rates. The document indicates that the worst case is that there will be a continuous baseflow of 15ML/day for a three year period. This would fundamentally change the surface water regime changing ephemeral creeks to permanent streams within or adjacent to the National Park. This is an undesirable outcome and the DoW considers that the proponent should develop stronger contingencies in relation to the disposal of excess water.


2 The report presents, insufficient data in creek cross-sections to demonstrate that the proponent fully understands the capacity of the ephemeral tributaries to receive up to 60ML/day and consequently the effectiveness of creek discharge. The assessment should examine potential depth/width of flow, channel velocity and bed stability. If this information is available, it should be presented to the DoW and to the DEC.

A discharge volume of 60 ML/day is less than 10% of the natural peak flood volumes generated by a one year ARI flood event at both discharge locations. Thus, the volume of discharge will be significantly lower than an annual flood event, and the flow duration is within the “normal” inundation period for floods to occur (i.e. weeks not months) during a wet season with above average rainfall (i.e. discharge will be within the natural variability of the Pilbara environment). The discharge outlets will be designed to mimic the natural flood conditions of the individual sites, i.e. predominantly diffuse, overland flow at Outlet 1 and confined at Outlet 2, to further simulate natural flood conditions.

3 DEC The discharge of excess dewatering water into the two tributaries of the Fortescue River South identified in the PER will potentially have negative impacts as neither of these has the bio-physical capacity to support significant long-term water flows. These features typically support episodic drainage and most species cited as being present within these creeks (mulga and spinifex communities) will not be able to withstand inundation for more than a few weeks to a month (van Leeuwen pers. comm.). The WRM Report (2008) referred to in Appendix 1 also identifies that this is not a good location for discharge "due to the absence of a well defined channel, extensive vegetation cover, likely poor conveyance capacity and likely erodability of bed/banks" (p. 15). Additionally, groundwater recharge resulting from the discharge could cause local groundwater rise, which will further impact on riparian vegetation. The discharge points need to be in riparian environments, not highly ephemeral systems. Recommendation: The proponent reassesses the necessity of discharge of excess dewatering into a non-riparian system in the Pilbara.

As there are no perennial systems in the vicinity of the Proposal, the only option available for controlled discharge is an ephemeral system. As stated in Section 5.3.4 of the PER, prolonged saturation of the soil profile is expected to cause localised physiological stress to the vegetation along the tributaries downstream of the discharge points. Refer also to the responses to Items 1, 2 and 12.

4 It is noted in the PER that continuous discharge of up to 15 ML/day of excess water would likely result in perennial surface flows along the Southern Fortescue River system for "some distance" (p. 82), perhaps indicating that there is uncertainty in predicting the actual distance that flows may extend. There is no discussion in the PER on whether the projected surface expression

The proponent has provided triggers and mitigation plans in environmental conditions (refer to Section 8 in the PER and the Surface Water Management Plan in Appendix 2 in the PER). Refer also to the responses to Items 1 and 2.



Item Submission from Comment Proponent response may impact on Karijini National Park or the proposed addition on Hamersley Station . The PER indicates that the maximum extent of dewatering water flow is 20 kilometres along the length of the Fortescue River South tributaries (p. 82), however, there is no hydrogeological information provided in the PER to support this assertion. The WRM report states that "preliminary modeling cannot accurately indicate the groundwater and surface water flows that would result from continuous discharge of 15 ML/day into the creek or the effects of intermittent discharges" (p. 17).

5 It should also be noted that these discharge points are within the same aquifer as the borefield, therefore discharge via these creeks is likely to affect the volume and receptiveness of the South Fortescue borefield to the re-injection of water. Recommendation: The proponent identifies contingency plans to be implemented in the event that the re-injection program is unsuccessful or less successful than planned as disposal of all excess water to the environment is not acceptable.


6 If dewatering to the environment is maintained as an excess water management measure, the proponent investigate alternative discharge location options and provide a rationale for the selection of potential discharge location(s) in consultation with DEC.

The selection of the discharge points was determined on the basis of the suitability of the receiving channels to accommodate the maximum discharge capacity and result in the least amount of disturbance to the surrounding environment from the necessary infrastructure. Refer also to the detailed response in Section 5.4.2.

7 The proponent [should] provide information on whether surface water discharge along tributaries of the Southern Fortescue River system will have any impacts on waterways, drainage channels, springs and/or pools within Karijini National Park and the Hamersley Station 2015 exclusion area. Recommendation: The proponent undertakes an investigation of the surface water and groundwater regimes of these tributaries and their linkage to current ecological water requirements.

The potential ecological impacts of the proposed excess water discharge were assessed by WRM (2008) and summarised in Section 5.3.4 in the PER (refer to response to Item 1). Refer also to response to Item 9.

8 Should surface discharge to the environment ultimately be demonstrated to be acceptable through this assessment, the proponent will need to implement an ecological monitoring, maintenance and restoration program to manage weeds along the creeklines and livestock (boundary fencing) particularly within the 2015 additions to the national park.

A Vegetation and Flora Management Plan has been developed by the Proponent and includes six-monthly monitoring of weed species and weed abundance along the dewatering discharge drainage lines. The plan also includes contingency weed control measures should new weed species be introduced and/or existing weed species be spread. This plan was provided in Appendix 2 of the PER. Monitoring at sites in areas to be incorporated into Karijini National Park in 2015 is expected to continue after the 2015 exclusion process is complete. Agreements between the Proponent and the DEC for the areas to be incorporated into Karijini National Park in 2015 are currently being negotiated. Under the current draft agreements (subject to change):

• annual grazing plans shall be provided by the lessee to the DEC

• fencing for livestock will remain the responsibility of the lessee

• the lessee and the CEO will monitor and control declared plants.




9 If dewatering is to occur to the identified tributaries, a condition of approval be that the proponent prepares an environmental discharge monitoring, management and restoration plan, to be developed in consultation with DEC, which includes:

• baseline surveys of vegetation, aquatic fauna and weeds;

• tree and understorey vegetation conservation and condition assessment;

• ecosystem management objectives ;

• triggers which indicate negative impact on the creek ecosystem (reversible impacts) and need for mitigation action;

• contingency actions in the event that trigger levels are reached including an ecological restoration program; and

• weed identification, mapping and control.



The proposed disposal of the dewatered water is badly flawed: a. There is no impact assessment of returning the water to the Fortescue

aquifers, other than to say it has been drawn down and returning water would reverse this. This is even though the PER gives evidence that salinities vary widely.

b. Piping the water to Tom Price is simply stated, few details are given c. It is proposed to dispose of excess water into natural drainage lines in a

"controlled" fashion. No details are provided of what "controlled" means.

a) Groundwater quality from both the Marandoo confined aquifer and that of the Southern Fortescue borefield is very similar (refer to Table 8 in the PER). Groundwater at Marandoo and the Southern Fortescue borefield is dominated by Ca, Mg, HCO3 and Cl ions, with both areas having a neutral pH and similar salinity (as total dissolved solids; 619.9 mg/L at Marandoo compared to 633.7 mg/L at the Southern Fortescue borefield). b) A concept design study has been undertaken that investigated how the current capacity of the pipeline and related infrastructure to Tom Price can be optimised and (in places) duplicated to transfer up to 36 ML/day. c) As presented in Section 5.3.4 in the PER, discharge points will consist of multiple discharge pipes and energy dissipation infrastructure to minimise washout from high flow events.


12 Conservation Council In the event that this project is allowed to go ahead despite the unacceptable risks to Karijini National Park, the following need to be managed by conditions:

• No discharge of groundwater into surface drainage lines should be allowed. The proponent can find better uses for precious quality fresh water than to impact on the downstream environment.




6.5 FLORA AND VEGETATION

Table 6 Response to submissions relating to flora and vegetation


1 DEC

As part of Marandoo Phase 1 Project the proponent made a commitment to control weeds at Marandoo, in particular ruby dock. During initial construction and early years of operation this commitment was honoured, however, since then control of this weed has not been adequate and is now a significant management issue in the area. Natal redtop is very close to the mine (junction of Marandoo Road and Karijini Drive near the rail crossing) and therefore there is a real potential for this weed to be present on the mine site. Management of this weed is particularly important when constructing the pipeline corridor through infested areas and at the waste water discharge points as it will proliferate with additional water. Recommendation: That the Vegetation and Flora Management Plan includes the objective of eradication of ruby dock, and other serious environmental weeds within the project area, and the proponent commits to eradicating ruby dock within the project area.

As stated in Section 5.4.5 in the PER, mitigation and management measures proposed to protect vegetation and flora values in and around the Proposal area include both weed eradication and weed hygiene measures. These measures include identifying and mapping the extent and distribution of target weed species occurring within and adjacent to the Proposal area and eradicating weed occurrences on an ongoing basis. Weed hygiene measures to prevent the spread of weeds will ensure that all mobile construction equipment entering or leaving the Proposal area (i.e. between areas that are weed-infested and weed-free) is free from earth, weeds and weed propagules. Target weed species in this context includes ruby dock.

2 Amaranthus sp is Kimberley flora (range extension) and has been found within the project area (p. 93). This is likely to be a mis-identification and should be verified, or if it is an accurate identification, it should be appropriately managed as a significant range extension.

The Amaranthus sp. A Kimberley Flora (C.A. Gardner s.n. PERTH 00326518) material is distinctive and has been identified with a high degree of confidence as A. induratus, using the draft key to this genus by Jo Palmer. This taxon is listed on FloraBase as being a taxonomic equivalent of Amaranthus sp. A Kimberley Flora (Jeni Alford [Biota Environmental Sciences] 2009, pers. comm., 5 January). Biota (2008a) stated that the single individual of Amaranthus sp. A Kimberley Flora recorded at the Southern Fortescue borefield represents a range extension from the Kimberley bioregion. As such, the location where this species was recorded shall be avoided where practicable.

3 DEC has the following comments in relation to the Mattiske (2008) report:

• The report indicates that the Eucalyptus victrix surveyed was stressed (p. 5), however there is no indication of how tree stress was measured.

• The survey focuses only on tree species, which needs to be recognised as a limitation of this report.

• Weed species present should also be identified and mapped because if dewatering is allowed to occur at these sites, this will result in significant changes to the ecosystem.

The Proponent has proposed an Environmental Condition (for incorporation into any Statement issued to apply to the Proposal) for a Dewatering Discharge Baseline Survey and Monitoring Program to be prepared in collaboration with the DEC (refer to Condition 9 in Table 28 in the PER). The Program will address vegetation condition, vegetation composition and weed infestation. The major objective of the Mattiske (2008) report was to establish the present condition of the creeklines and was not intended as a typical vegetation survey report. As such, particular attention was placed on the condition of perennial species as they are more likely to reflect longer-term changes in local hydrological site conditions. Therefore, whilst the condition of non-tree species, such as weeds, is important to the ecosystem, the condition of the tree species is an indicator of the hydrological condition of the site. Each stem on each tree was assessed for physiological stress through the following method, which has been applied over many years to a wide range of



Item Submission from Comment Proponent response projects in the Pilbara and the Goldfields. Trees were ranked according to the following scale:

• Healthy (H): all leaves healthy and green, canopy intact

• Slightly Stressed (SS): a few leaves browning, canopy mostly intact

• Stressed (S): patches of leaves browning and sections of canopy being lost

• Very Stressed (VS): Regular browning off of leaves and sections of canopy lost

• Recent Death (RD): all leaves brown, so sign of recent growth, bark intact (less than 1 year as winds during summer months remove leaves)

• Moderate Death (MD): leaves lost, variable amounts of fine twigs still in place and bark mostly in place)

• Old Death (OD): leaves lost, fine stems lost and sometimes outer bark missing).

The distribution of understorey species, including weed species, along the transects is summarised in Appendix B of the Mattiske (2008) report. Numerical data on percentage cover alive in the quadrats along the transects were also recorded (although not included in the Mattiske [2008] report) and will be used in longer-term assessments of trends in condition of the vegetation.

4 Seeding using local provenance should be undertaken at all times during rehabilitation of this site, not whenever possible (p. 150). The proponent needs to plan well ahead when collecting seed as there is a strict provenance requirement for Marandoo given the intended return of the mine area to the park. Additionally, the area where seed can be collected is restricted by national park tenure.

The Proponent acknowledges the comments raised in the submission relating to the importance of utilising local provenance seed in rehabilitation at Marandoo. The Proponent is currently reviewing rehabilitation seed collection requirements to ensure rehabilitation objectives are adequately met with respect to local provenance seed. For Marandoo, this will ensure that planning for seed collection is initiated well in advance of undertaking rehabilitation and will also ensure that seed requirements for rehabilitation are fulfilled by local provenance seed.

5 The PER states that "provided that the groundwater does not approach within 5 m of the ground surface, it is not deemed likely that waterlogging would affect the Mulga component of these vegetation units" (p. 102). Although some mulga vegetation associations can withstand root inundation, it is considered unlikely that those in the South Fortescue borefield area are this type (van Leeuwen pers. comm.). The management of the water table needs to be planned and carried out in a way that the altered regime matches, as closely as possible, the natural rise and fall of the aquifer and provides acceptable conditions to support protection of these vegetation communities. Maintaining water levels at five metres below the ground surface is likely to be detrimental to most mulga and other tree vegetation (bloodwoods, other wattles and western coolibah). Recommendation: The proponent provides a rationale for determining the appropriate groundwater levels based on depth to watertable verses rooting depths for the vegetation communities, to support the five metre trigger level for reducing or discontinuing injection. This would require a better understanding of the rooting structure of mulga and how the mulga types present in the borefield area may

Pre-abstraction groundwater levels at the Southern Fortescue borefield were 20–30 m below ground level. Therefore, a re-injection trigger level of 5 m above historical groundwater levels in monitoring bores equates to groundwater levels between 15 and 25 m below ground level. This is considered adequate to ensure a significant buffer remains between the watertable and shallow rooted non-phreatophytic vegetation that predominates in the area.

There are no data to support the statement that maintaining water levels at 5 m below the ground surface is likely to be detrimental to most mulga. Previous observations of the root systems of mulga and measurements of their responses to inundation suggest that the mulga within the Southern Fortescue borefield are likely to be quite shallow-rooted (majority of roots within 2 m of surface) and not deep-rooted as is sometimes suggested (Pauline Grierson [University of Western Australia], 2009, pers. comm., 3 February). The mulga at the Southern Fortescue borefield are of similar physiological types to those found in other drain-on areas in the Hamersley Ranges, which respond quite well and very rapidly to enhanced water availability (Pauline Grierson [University of Western Australia], 2009, pers. comm., 3 February). While they may not tolerate extended periods (greater than 6 months) of a completely



Item Submission from Comment Proponent response respond to root inundation for extended periods. saturated profile, they would be tolerant of short periods of inundation. It is

unlikely that mulga and other tree species would be negatively affected if the saturated zone was at greater than 5 m depth (Pauline Grierson [University of Western Australia], 2009, pers. comm., 3 February).

6 An appropriate level of baseline survey of the vegetation communities potentially impacted by the borefield should be undertaken prior to project approval.

A description of the Southern Fortescue borefield at the time of survey was provided in the PER. As described, the borefield was in relatively poor condition, having been affected by grazing and probably from the current and historical groundwater abstraction. Mulga deaths were noted, but it is difficult to determine if this was due to fire, drought, erosion, change in soil moisture, or a combination of these factors. There were several sinkholes (fenced) in the area and some of the original creeklines were eroded and scalded. The area at the time of the survey was also affected by a mosaic of fire scars.

7 Given that the borefield area is a future extension to the national park (in 2015), a vegetation monitoring and protection plan for the South Fortescue borefields needs to be developed by the proponent in consultation with DEC. This plan should include contingency measures to be implemented if changes in vegetation health are detected.

Agreements between the Proponent and the DEC for the areas to be incorporated into Karijini National Park in 2015 (including the Southern Fortescue borefield) are currently being negotiated. Under the current draft agreements (subject to change), the lessee will maintain access rights for mining and infrastructure developments (including water resources) under its various State Agreement Acts and the Mining Act. The agreements include provision for the development of a management plan for the area and any research and monitoring requirements are expected to be captured in this plan.


The list of flora and fauna species seems rather superficial and based on surveys almost exclusively carried out in the area of the proposed mine, rather than on the expected impact area of the water draw down. The species data also has not been put into a context of broader ecological functioning, nor is it clear whether the surface vegetation and fauna and in any way connected to the ground water system. Modern Lidar and spectral systems are capable of quantifying not only the detailed topography, but also the vegetation species, the growth rates and from this it is possible to infer soil properties. Rio Tinto claimed, when questioned, during the consultation meeting previously referred to, that they spent "Millions" on these surveys. This is clearly nonsense.

The level of vegetation and flora survey and sampling effort undertaken is appropriate to support an environmental impact assessment of the Proposal under Part IV of the EP Act. The species lists referred to have been developed from the results of extensive flora and vegetation survey and sampling work undertaken in the Marandoo mining lease and surrounding areas since the 1970s. The most recent flora and vegetation survey work undertaken by Biota Environmental Sciences (Biota) was in accordance with EPA Guidance Statements No. 51 (EPA 2004a) and No. 56 (EPA 2004b), and was consistent with the Environmental Scoping Document for the Proposal. The Environmental Scoping Document defines the scope of work required during the environmental impact assessment process and has been approved by the EPA. The Proponent does not consider the use of Lidar technology to be necessary for the collection of vegetation data. The methods employed for the assessment are considered more than adequate. The Proponet has been collecting remotely sensed digital multi-spectral imagery over the Mount Bruce Flats since 2005. This information provides an important measure of vegetation health.




6.6 COOLIBAH WOODLAND

Table 7 Response to submissions relating to the Coolibah woodland


1 DoW The DoW considers that the DEC should advise the EPA whether the Coolibah triggers in Table 30 are satisfactory. In particular, the criteria for loss of mean foliage from Table 30 may not be adequate as it would show tree health that could be irreparable. The Department of Water would prefer to see preventive triggers.

The environmental triggers proposed by Rio Tinto currently fit the definition of preventative triggers as suggested by the DoW. Refer also to response to Item 5.

2 DEC

Hydrogeological modelling by the proponent is required to establish that the impacts of groundwater drawdown in the vicinity of the priority ecological community (P3) Coolibah woodlands will be negligible and manageable to ensure no adverse impact on the health of the Coolibah woodlands. In most cases, by the time vegetation stress is evident, it is too late to manage the issue.

An extensive program of hydrogeological investigation and modelling has been undertaken by the Proponent over several years (refer to Section 5.2 in the PER). The modelled groundwater drawdown at the Coolibah woodland is described in Section 5.5.4 in the PER and presented on Figures 25 and 26 in the PER. As stated in Section 5.5.4 in the PER, intersection of the unconfined aquifer by the proposed mine pit is predicted to result in drawdown of groundwater levels of approximately 0–2.5 m at the Coolibah woodland. For the most part, drawdown will be less than 1 m. The estimated maximum rate at which this drawdown would occur is approximately 0.3 m/year, due to rapid phases of pit advancement during the initial eight years of dewatering. The magnitude of the predicted groundwater drawdown in the unconfined aquifer is not anticipated to affect the Coolibah woodland; however, the Proponent has proposed an Environmental Condition (for incorporation into any Statement issued to apply to the Proposal) employing an adaptive approach to ensure protection of the woodland (refer to Condition 6 in Table 28 in the PER). Refer also to response to Item 5.

3 If the proponent can demonstrate through the impact assessment process with a high degree of confidence, that the risk of dewatering impacts on the Coolibah woodlands is acceptably low, the monitoring design (including identification of appropriate control/reference sites) and adaptive management strategies within the proposed Coolibah Management Plan will need to be developed in consultation with and to the requirements of DEC.

The Proponent has proposed an Environmental Condition (for incorporation into any Statement issued to apply to the Proposal) for a Coolibah Baseline Survey and Monitoring Program to be submitted to the DEC for review, and thereafter modified in accordance with this review (refer to Conditions 6-7 and 6-8 in Table 28 in the PER).

4 Appendix 1 refers to a report by Batini (2008a) which indicates that the adaptive management options being considered, if the impact of dewatering on the unconfined aquifer level is greater than has been predicted, are:

• establishment of a grout curtain;

• re-injection into the unconfined aquifer; or

• surface irrigation to affected aquifer dependent areas. Based on available information, the effectiveness of each of these options in protecting the Coolibah woodlands over the long-term is uncertain. In summary, the option of establishing a grout curtain would require experimental trials prior to implementation but is the most attractive to DEC as it would isolate

Establishment of a grout curtain is not being considered by the Proponent. The Batini (2008) report lists it as a possible option, but also states that it is unlikely to succeed over the distances required. The Proponent has committed to supply the woodland with water using a method agreed with the DEC, should any Level 3 Coolibah management trigger criterion prescribed in schedule 2 be exceeded (refer to Condition 6-2 in Table 28 in the PER). Any method chosen would require adequate assessment prior to implementation to determine its appropriateness. The re-injection of water into the unconfined aquifer to produce a groundwater mound is one option that has been considered; however, the Proponent would investigate other options to determine the method that would be most



Item Submission from Comment Proponent response Marandoo mine from the overall Mt Bruce Flats aquifers. Surface irrigation would need more detailed assessment but is likely to lead to vegetation changes, such as causing the Coolibahs to switch from deep taproot system to shallow root systems, rendering them dependent on surface water flow that would cease at the completion of mining. Re-injection into the confined aquifer may help raise groundwater levels during the life of the mine, however at closure this would cease. Additionally, infrastructure for both the surface water flow and re-injection would have to be installed within the national park and this would require assessment.

appropriate. The Proponent will ensure installation of any infrastructure within the National Park is subject to the appropriate level of environmental impact assessment. A number of bores currently exist in proximity to the Coolibah woodland (refer to Figure 33 in the PER), which may be converted into re-injection bores with minimal additional disturbance. Refer also to the detailed response in Section 5.5.2.

5 Given the conservation significance of the Coolibah woodlands, the condition allowing up to 40 per cent loss of canopy foliage cover as a trigger is not supported (p. 220) prior to any contingency measures being implemented. Trigger levels and contingency measures to address impacts on the woodlands would need to be developed in consultation with and to the satisfaction of DEC.


6 As part of the adaptive management plan for the Coolibah woodlands, the proponent plans to monitor a reference site, however, the location of the reference site is not identified and is likely to be difficult to locate as the areas of this unit on the Mt Bruce Flats are the only examples of the Coolibah woodlands community known in the Pilbara (van Leeuwen pers. comm.).

A suitable Coolibah woodland reference site has been identified on the Coondewanna Flats (approximately 70 km to the southeast of the Mount Bruce Flats on Juna Downs station). This reference site is the same Priority Ecological Community that exists in the Mount Bruce Flats (as determined by DEC mapping). Monitoring of the reference site is scheduled to commence in June 2009. The Proponent has proposed an Environmental Condition (for incorporation into any Statement issued to apply to the Proposal) for the selection of a reference site in consultation with the DEC as part of the Coolibah Baseline Survey and Monitoring Program (refer to Conditions 6-4 and 6-5 in Table 28 in the PER).


• Any monitoring of Coolibah woodlands needs to have a requirement to immediately cease dewatering and commence restoration of natural groundwater levels if impacts are noted, regardless if these are directly attributable to the dewatering at the minesite.

Refer to detailed response in Section 5.5.2. Any impacts attributable to dewatering can be adequately managed via the proposed adaptive management approach, which features a three-tiered response mechanism to assign appropriate response measures to be undertaken if monitoring detects any impact. In addition, cessation of dewatering could lead to loss of access to the pit and would present safety and geotechnical risks. This outcome would be completely unacceptable and is not a practical option.



6.7 TERRESTRIAL FAUNA

Table 8 Response to submissions relating to terrestrial fauna


1 DEC Recommendation: The proponent amends the terrestrial fauna management plan to address the potential of entrapment of fauna during trenching activities (i.e. pipeline construction), with management strategies to be agreed with DEC.

As stated in Section 4.2 of the PER, the construction of dewatering infrastructure (including pipelines) is not part of the Proposal and will be subject to a separate environmental assessment process under the provisions of the EP Act and in accordance with other statutes. The potential for fauna entrapment during trenching activities can be adequately addressed via this separate process.

2 DEC It is unclear from the PER whether all areas of potential impact within the project area have been adequately assessed and surveyed for SRE fauna. Explanation of the surveys undertaken needs to include:

• an indication of the predicted prospectivity of the habitats in the study area for supporting SREs;

• an adequate rationale for survey site selection;

• a discussion on the impact area considered (for example were areas with potential groundwater impacts included?);

• the basis for sample site selection; and

• justification of why any areas of potential SRE habitat in the area were not sampled.

Recommendation: The proponent provides additional explanation of the scope, design and selection of sites for the SRE fauna survey of the project area.

As stated in Section 5.6.1 of the PER, non-systematic searches were conducted at the Marandoo mine lease for Short-Range Endemic (SRE) invertebrate groups in a variety of microhabitats including:

• Triodia on loam (targeting terrestrial snails, mygalomorphs and scorpions at MARSN01)

• under flaking bark of Corymbia spp. (targeting pseudoscorpions at PSEUD1, PSEUD2, PSEUD3 and PSEUD4).

The locations of the sites searched are shown on Figure 34 of the PER. As stated in Section 5.6.4 of the PER, the invertebrate groups recorded at the mine lease are not considered to be SRE species, primarily due to the extensive distributions of their preferred habitats outside the proposed disturbance area. Clearing of fauna habitat for dewatering infrastructure and the operations camp does not form part of this Proposal and will be subject to a separate environmental assessment process under the EP Act.



6.8 SUBTERRANEAN FAUNA

Table 9 Response to submissions relating to subterranean fauna


1 DEC The Subterranean Fauna Assessment report (Biota 2008e) referred to in Appendix 1 has undergone minimal changes since it was reviewed in conjunction with the draft PER (May 2008) and DEC's advice on this report has not been fully addressed in the revised document. Recommendation: The proponent provides a map showing the location of all sampling bores from all sampling events (1999-2003) in relation to the mine pit and other impact areas, such as groundwater drawdown cones, and identifies which of the bores were impact or reference bores. (The report currently only shows the bore locations for the 2008 sampling program.)

An update of Figure 35, which was presented the PER, showing the location of all subterranean fauna sampling sites (including historical sampling sites) is presented in Figure 25. An additional figure showing the location of all subterranean fauna sampling sites (including historical sampling sites) in relation to the predicted groundwater drawdown in presented in Figure 26.

2 The report indicates that the three stygal taxa located within the impact zone have also been found elsewhere. Information should be provided on where these taxa have been found.

Table 18 in the PER indicated three stygal taxa collected within the study area had also been collected from the wider Marandoo locality during the DEC Pilbara Biological Survey. Details on where these three taxa have been collected are provided in Table 10 in this document.

3 The Subterranean Fauna Assessment undertaken by Biota (2008e) suggests that as the drawdown of groundwater will be within the levels of natural fluctuation, there will be no impact on stygofauna (p. 33). It is not clear whether this means that groundwater levels will remain within the levels of natural fluctuation. For example, a two metre drawdown on an aquifer with levels naturally ranging from 6 to 10 metres below ground could result in groundwater levels of 12 metres below ground. It would then be necessary to evaluate whether this new minimum level could have ecological impacts. Recommendation: The proponent clarifies whether in this case the groundwater aquifer levels (as distinct from drawdown levels) resulting from dewatering will be within the range of natural variation for the aquifer. (Any drawdown of groundwater levels as a result of dewatering is considered a potential impact zone and the related risks need to be addressed.)

The predicted groundwater drawdown will occur in addition to natural fluctuations in the watertable. As stated in Section 5.7 in the PER, the 2 m groundwater drawdown contour has been accepted in previous assessments as a reasonable, risk-based delineation of where significant impacts to stygal communities could be expected to begin. As such, the 2 m contour has been used in the PER to define the extent of risk to stygofauna communities across the Mount Bruce Flats.

4 Conservation Council Biodiversity in the Pilbara is under threat from massive mining plans, now and into the future – with plans to increase already massive iron ore production by up to 300% a year and sustain this production over periods of decades. In the future much more of the ore in the Pilbara will be below the water table due to the exhaustion of easily accessible higher grade surface deposits. The impacts of dewatering and other mining activities on stygofauna, troglofauna and other GDE's is poorly understood — both in terms of habitat needs and water quality needs (note Bill Humphreys from WA Museum comments at the Conservation Council's 2007 Dewatering in the Pilbara Environment Matters forum that changes in water quality may have impacts on some species of stygofauna).

As stated in Section 5.7.4 in the PER, the risk to stygofauna populations as a result of the Proposal is minimal as it appears that no stygofauna taxa are restricted specifically to the proposed mining area or the dewatering impact area (Biota 2008b). Sampling conducted to date suggests a diverse stygofauna community extends beyond the Proposal area into the Mount Bruce Flats, the majority of which will be subject to less than 1 m of groundwater drawdown as a result of the Proposal (refer to Figure 26 in the PER).



Item Submission from Comment Proponent response There have been no comprehensive independent studies into the impacts of cumulative impacts of dewatering on biodiversity across the Pilbara. If National Parks cannot be protected, then there is nowhere safe from potential widespread loss of groundwater dependent biodiversity in the Pilbara. In context of serious and poorly understood risks to biodiversity across the Pilbara from mining, National Parks like Karijini must be absolutely protected from the impacts of mining.

Table 10 Stygofauna records from the DEC Pilbara Biological Survey from the Marandoo locality

Order Family Identification Site Latitude

deg Latitude

min Longitude

deg Longitude

min

Amphipoda Paramelitidae Paramelitidae sp. 2 (PSS) Warp2 22 25 117 15

Amphipoda Paramelitidae Paramelitidae sp. 2 (PSS) Karijini 22 33 118 27

Amphipoda Paramelitidae Paramelitidae sp. 2 (PSS) Tom Price North 22 43 117 52

Amphipoda Paramelitidae Paramelitidae sp. 2 (PSS) RCB18 22 46 118 18

Copepoda Cyclopidae Diacyclops humphreysi humphreysi Tom Price North 22 43 117 52

Copepoda Cyclopidae Diacyclops humphreysi humphreysi Warp2 22 25 117 15

Copepoda Cyclopidae Microcyclops varicans Karijini 22 33 118 27

Copepoda Cyclopidae Microcyclops varicans Hamersley Station 22 27 117 45

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Karijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National Park



SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1

SFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3B


DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202






OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13


OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S



TPB4 TPB4 TPB4 TPB4 TPB4 TPB4 TPB4 TPB4 TPB4

Figure 35Location of Subterranean

Fauna Sampling Sites:1999 - 2008

Plan No: PDE0049509v1Proj: MGA94 Zone50

Drawn: TCDate: May 2008

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Port Hedland

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DD07MN016DD07MN016DD07MN016DD07MN016DD07MN016DD07MN016DD07MN016DD07MN016DD07MN016







OW12SOW12SOW12SOW12SOW12SOW12SOW12SOW12SOW12SOW12DOW12DOW12DOW12DOW12DOW12DOW12DOW12DOW12D




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DD07MN104DD07MN104DD07MN104DD07MN104DD07MN104DD07MN104DD07MN104DD07MN104DD07MN104OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S





OW36D OW36D OW36D OW36D OW36D OW36D OW36D OW36D OW36D OW36S OW36S OW36S OW36S OW36S OW36S OW36S OW36S OW36S


TPB1 TPB1 TPB1 TPB1 TPB1 TPB1 TPB1 TPB1 TPB1 OW21D OW21D OW21D OW21D OW21D OW21D OW21D OW21D OW21D





TIB1A TIB1A TIB1A TIB1A TIB1A TIB1A TIB1A TIB1A TIB1A

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820820820820820820820820820

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Karijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkPW20PW20PW20PW20PW20PW20PW20PW20PW20



OW19 OW19 OW19 OW19 OW19 OW19 OW19 OW19 OW19


PW12 PW12 PW12 PW12 PW12 PW12 PW12 PW12 PW12

MARRA MAMBA IRON FORMATION, undifferentiated:

Cainozoic colluvium and alluvial sheet wash

JEERINAH FORMATION, undifferentiated

Dolerites and volcanics

Channel Iron Deposit

Cainozoic calcrete & lucastrine limestone

Quaternary alluvium

Cainozoic laterite

Robe Pisolite

HAMERSLEY GROUP

BROCKMAN IRON FORMATION

MOUNT McRAE SHALE

MOUNT SYLVIA FORMATION

WITTENOOM FORMATION

FORTESCUE GROUP

Hematite deposits

BUNJINAH FORMATIONAFu

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GEOLOGY LEGENDGEOLOGY LEGENDGEOLOGY LEGENDGEOLOGY LEGENDGEOLOGY LEGENDGEOLOGY LEGENDGEOLOGY LEGENDGEOLOGY LEGENDGEOLOGY LEGEND

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SEE INSETSEE INSETSEE INSETSEE INSETSEE INSETSEE INSETSEE INSETSEE INSETSEE INSET

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�� Bores containing subterranean fauna

�� Bores not containing subterranean fauna

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MMP2 Project disturbance

Stategic Assets - Perth

620000 mE 630000 mE 640000 mE7510000 m

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640000 mE620000 mE 630000 mE

7490000 m

N7500000 m

N600000 mE 610000 mE

7500000 m

N7510000 m

N75

600000 mE 610000 mE

7490000 m

N

MarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandoo

RailRailRailRailRailRailRail



RailRailRailRailRailRail




Rail

Karijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National Park

MarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandoo

SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6SFO6

S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1S2-1

S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S3-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1S5-1

SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2SFPOLD2

OW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8SOW8S

SFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07ASFO07A

MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNP0300MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007MNWB0007

MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295MNP0295

SFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3ASFO3A


OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D OW29D

OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7OW7




SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1SFPOLD1

SFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3BSFO3B


DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110DD07MN110MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202MNP0202






OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13 OW13


OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S OW23S



Figure 35Location of Subterranean

Fauna Sampling Sites:1999 - 2008

Plan No: PDE0049509v1Proj: MGA94 Zone50

Drawn: B JacksonDate: May 2009

MACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACMACChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannarChannar

Mount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackMount WhalebackParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdooParaburdoo

JimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebarJimblebar

BHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandiBHPIO YandBHPIO YandBHPIO YandBHPIO YandBHPIO YandBHPIO YandBHPIO YandBHPIO Yandi

Eastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern RangeEastern Range

Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2Brockman No.2

NammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiNammuldiMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandooMarandoo

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Cape LambertDampier

Port Hedland

Mine location

Roads

Railway



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TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1 TIB1

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Karijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkKarijini National ParkPW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20PW20



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Bores containing subterranean fauna

Bores not containing subterranean fauna

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KilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometersKilometers

Proposed MMP2 disturbance footprint

Bores containing troglofauna


MMP2 Project disturbance

Stategic Assets - Perth

10 to 20

9 to 10

8 to 9

7 to 8

6 to 7

5 to 6

4 to 5

3 to 4

2 to 3

1 to 2

0 to 1

Active Model Area

Predicted groundwater drawdown (m)




Table 11 Response to submissions relating to visual amenity


1 DEC The proponent has undertaken a visual impact assessment for the proposed development which particularly addresses visual impacts of the project from what the proponent considers to be key visual receptor areas within Karijini National Park. This demonstrates that there will be significant adverse impacts (most of which were found to be moderate to severe, p. 136) on the visual amenity from key sites within the national park, including various points along Mt Bruce, Karijini Drive, and Hamersley Gorge-Mt Bruce Road. The visual amenity values of Karijini National Park are considered to be of world-class significance. Disturbance caused by an enlarged mine site and associated infrastructure is in sharp contrast to the natural environment that people are seeking to experience when visiting Karijini. Mount Bruce in particular is a popular tourist destination within the park, being the second highest peak in Western Australia, which visitors are able to climb to experience the panoramic views of the Hamersley Ranges. Being located in close proximity to the development makes this site particularly sensitive to visual impacts. Karijini Drive is also very important from a tourist perspective. This sealed road is heavily utlised by tourists, attracting a large number of visitors to the park.


2 The PER does not discuss the way in which elements of the development will be designed and managed for the life of the project to minimise impacts on landscape values and visual amenity. Instead, the PER expresses the view that there will be an adverse negative impact in an already "highly modified landscape", and argues that the greater impacts are confined to areas with a lower number of visitors (e.g. Mt Bruce eastern summit lookout). Adoption of this approach for such a highly visited national park as Karijini is not supported.

Refer to detailed response in Section 5.6.2 and to response to Item 3.

3 Features of the development that appear to have the greatest potential impact on landscape value include the residue storage facility, extensive waste dumps, pit expansions, dewatering infrastructure, and the construction/operations camp, all of which could have been subject to locational or design adaptation to minimise impacts. Suitable measures to minimise visual impacts include:

• appropriate alignment of roads, pipelines, powerlines to blend in with the surrounding landscape;

• appropriate location of infrastructure, specifically including the construction and operational camp, where it is screened or hidden from the viewshed of visual receptor areas;

• appropriate positioning and shape of artificial landforms (e.g. waste dumps) to blend in with surrounding landforms;

As stated in the PER, the following management measures will be implemented to minimise the impact of the Proposal to visual amenity:

• preventing unnecessary clearing

• progressively rehabilitating the Proposal area to resemble as close as possible the local landscape value and surrounding environment

• utilising local provenance species and matching local relative plant densities in rehabilitation areas

• locating infrastructure in, or near already disturbed areas where possible

• selecting colour schemes for buildings and infrastructure that blend with the surrounding landscape

• erecting informational signage about the Proposal at the Mount Bruce car




• appropriate colour of infrastructure and facilities to blend in with the surrounding landscape; and

• use of vegetation buffers and screens. Recommendation: The proponent demonstrates how the development and associated infrastructure (e.g. construction/operations camp, dewatering infrastructure) will be designed and managed for the life of the project to minimise visual impacts on Karijini National Park, particularly from Mt Bruce.

park lookout. The dewatering pipeline between Marandoo and the Southern Fortescue borefield will be constructed along an existing disturbance corridor for the majority of its length. In addition, the pipeline may be installed below ground, which would result in a significantly reduced visual impact. The existing 33 kV above-ground power line between Marandoo and Tom Price will be replaced as part of the Proposal (except for the section between Marandoo and the proposed switchyard), which will improve visual amenity in the locality. Positioning and design of waste dumps are guided by the Pilbara Iron Landform Guidelines. Waste dumps will be designed to produce a landform that is safe, stable and aesthetically compatible with the surrounding landscape after rehabilitation. As stated in the PER, the use of vegetation buffers and screens near Marandoo is considered inadequate given the relative absence of local endemic vegetation of sufficient height and the general sparseness of vegetation in the region. Refer also to detailed response in Section 5.6.2.

4 Recommendation: The selection process for the location of the proposed construction/operational camp be described in the PER and a broader range of site alternatives, including those that may involve negotiation with commercial competitors, be included.


5 Recommendation: The proponent's objectives for visual amenity and landscape character for this project align with DEC's Policy Statement No. 34 Visual Resource Management on Lands and Waters managed by CALM (DEC), and associated guidelines. The outcomes of the visual impact assessment in the PER be reviewed in light of these documents.

The Proponent has been advised by the DEC that, because Policy Statement 34 was developed some time ago, it is currently under review, and so at this time should not be regarded as reflecting contemporary practice (Trudy Parker [DEC] 2008, pers. comm., 12 December). The DEC has advised that the government approach to visual landscape planning is outlined in the Department for Planning and Infrastructure (DPI) document entitled ‘Visual Landscape Planning in Western Australia: a manual for evaluation, assessment, siting and design’ (DPI 2007; Tracy Churchill [DEC] 2008, pers. comm., 15 December). As stated in the PER, the SKM (2008) landscape and visual assessment was undertaken in accordance with the methodology and guidelines of the DPI (2007) manual.

6 The PER downplays the potential significance of visual impacts from the proposed development by stating that the environment is already a “highly modified landscape” (p. 131), due to the existing Marandoo mine. The existing mine has affected visual amenity of the park from various locations, including Mt Bruce, however this does not diminish the Proponent’s responsibility to prevent further degradation of visual amenity to an unacceptable level. The Landscape and Visual Impact Assessment Report (SKM 2008) demonstrates through graphic simulations that the additional impacts on visual amenity as a result of the development will be significant.


7 Recommendation: A visual impact management plan for the Proposal is not warranted given the measures that will be implemented to minimise visual impacts (refer to




A visual impact management plan be developed by the proponent, in consultation with and to the satisfaction of DEC and the Conservation Commission, to provide guidance and outline strategies on how visual impacts will be minimised.

response Item 3).

8 The visual impacts of a large construction/operations camp from sites such as Mt Bruce are likely to be significant. The footprint of the camp is expected to be very large, with hundreds of 'donga' style accommodation units, along with administration buildings, associated infrastructure (e.g. sheds/workshops, water tanks, power stations, waste water treatment plants, towers), carparks, and large numbers of light vehicles as well as some heavy plant and machinery. Recommendation: The proposed location of the construction/operations camp for the project be reconsidered and subject to an environmental options analysis and that prior to finalisation of the PER assessment, the following actions be implemented in relation to determining a suitable location for the construction/operations camp for the project:

• The proponent presents the findings of the visual impact assessment report for the camp to DEC and the EPA for review.

• The resolution of the land tenure constraints associated with the proponent's site selection investigation be reviewed in consultation with the Department of Industry and Resources.

• Site selection be based primarily on (but not limited to) criteria relating to impacts on biodiversity, visual amenity and landscape values, and social/tourist values associated with Karijini National Park.

• That should the final agreed camp site be located in proximity to Karijini National Park, the proponent consult with DEC to ensure that the camp and associated infrastructure be designed in a way that blends in with the surrounding environment, and is well hidden and/or screened from key visitor receptor sites within the national park. Final camp designs should be developed to the satisfaction of DEC.

Refer to detailed response in Section 5.6.2 and to the additional work carried out by SKM outlined in Section 2.2. The visual impact to Karijini National Park from the proposed operations camp was determined by SKM (2008) to be minimal, as most views of the camp from the selected receptors would be largely obscured or non-existent. Tourism WA stated in its submission on the PER that it is satisfied with the proposed location of the camp, as it appears to have little visual impact to Karijini National Park. Note that the proposal does not include any “power stations” as referred to in the submission.

9 Conservation Council If this proposal goes ahead, the mining construction camp (a moveable piece of infrastructure) should not be placed in a location where it can be seen from tourist locations such as Mt Bruce.

According to the Visual Impact Assessment conducted by SKM (2008), the camp is unlikely to be visible from the two Mount Bruce summit lookouts or the car park lookout. In other sensitive locations within Karijini National Park assessed by SKM, views of the camp will be largely obscured. Refer also to response to Item 8.



6.10 CLOSURE AND REHABILITATION

Table 12 Response to submissions relating to closure and rehabilitation


1 DoW The DoW considers that following the cessation of mining, the mine voids should be backfilled to at least 1 metre above water table. Backfilling to above water table is the DoW's stated formal preference for mines below water table and an unfilled void is only acceptable if shown to be a groundwater sink. An open void would not be acceptable for this project, due to the potential connection to karstic carbonate aquifers which would prevent an open void acting as a groundwater sink. The proponent should make a clear commitment to backfill to at least 1 metre above water table.


2 DEC The hydrogeological and any ecological implications of the upper and lower aquifers being connected at the Marandoo mine site (within the pit) following closure are not discussed.

The upper and lower aquifers have been demonstrated to be in hydraulic connection where the clay layer is absent prior to mining (AGC Woodward Clyde 1992). The post-closure impact of mining will increase this area of connection only marginally in the context of the extent of the clay layer across the Mount Bruce Flats. The result of the increased connection will be to shorten the southern flow path for discharge of groundwater from the upper watertable mound to the basement aquifer. This is highly unlikely to have any effect on the unconfined aquifer watertable across the Mount Bruce Flats as recharge to the watertable is driven from the centre of the Mount Bruce Flats, rather than at the margins.

3 The EPA objective for rehabilitation and closure for the development as set out on page 146 (section 5.10.2) of the PER is "to ensure, as far as practicable, that rehabilitation achieves a stable and functioning landform that is consistent with the surrounding landscape and other environmental values." The proponent's proposed post-closure land use option for the proposal area is "to be consistent with Karijini National Park objectives" (p. 147). However, the PER does not adequately demonstrate this will be achieved. Standard rehabilitation practices employed on other mine sites in the Pilbara of lesser environmental/landscape value are not considered appropriate in this instance. The commitments in EPA Bulletin 643 Marandoo Phase 1, No. 40 state that the proponent will work with DEC to refine and implement an agreed end-use plan for the site at decommissioning. This previous commitment needs to be taken into consideration for the proposed expansion of the Phase 1 operations. Recommendation: Rehabilitation and closure objectives need to be developed in consultation with and to the satisfaction of DEC and the Conservation Commission and be consistent with the values and management objectives of Karijini National Park.

As stated in Section 5.10.1 in the PER, the Proponent acknowledges closure management at Marandoo is particularly important due to the sensitivity of the area and needs to be determined in consultation with relevant stakeholders. As such, the objectives presented in the PER are conceptual and will evolve throughout the life of the Proposal in consultation with key stakeholders. This is reflected in proposed Environmental Condition 12-1 (refer to Table 28 in the PER), which states that a final closure plan will be developed in consultation with the DEC and DoIR, and will be submitted for review to the DEC at least five years prior to the planned date of closure.

4 Backfilling to a nominal one metre above the water table will still result in a groundwater sink forming during dry conditions (when evaporation exceeds rainfall and surface inflows), increasing the salinity of soil and groundwater.

Refer to detailed response in Section 5.7.2. The UWA research and the Proponent’s void water quality analytical modelling is indicating that mine voids will not result in saline lakes owing to periodic and



Item Submission from Comment Proponent response During rainfall events groundwater recharge will occur, resulting in ponding on the surface of the pit (p. 148). This not only results in an artificial landscape feature (i.e. pit depression), it makes rehabilitation much more difficult, particularly if using local species that are not adapted to this artificial groundwater regime. Backfilling pits to ground level (or at least backfilling to a sufficient height above the highest seasonal water level to minimise the likelihood of ponding) is highly desirable and would minimise the amount of waste material that remains to be rehabilitated in waste dumps as well as controlling groundwater levels. Given the visual impacts of extensive waste dumps along the Marandoo Ridge, visible from both Mt Bruce and Karijini Drive, the intention to stockpile waste material in dumps is undesirable. The PER states that research (numerical modeling) is being undertaken at The University of Western Australia on the "development of pit lakes after closure and the potential impacts of this to groundwater quality at Marandoo" (p. 148). It is indicated that the modelling is likely to be finalised following commencement of the proposed operations, when aquifer characteristics are more fully understood. However, at least preliminary information from this study is required prior to approval as there may be salinity-based or acidity/metal contamination issues which need to be addressed through the PER prior to the commencement of operations. Therefore, without this additional information DEC is not able to assess the potential impacts associated with pit lake water quality after closure. There is also a lack of clarity in regard to whether the surrounding environment was considered in the design and management of post-mining landforms - the battering of slopes to an angle 20° is a standard requirement for all mine sites to create a more stable landform. To date, there have been no discussions between the proponent and DEC regarding specific closure objectives for the project (other than general discussions at the existing Marandoo Statement of Mutual Understanding meetings). Development of completion criteria should involve DEC from the outset of the project. Recommendation: Given the intention for the project area to be ultimately included in the national park, it is requested that:

• The proponent commits to backfill mine pits as close as possible to the surrounding ground level (as opposed to one metre above the pre-mining water table) in order to improve the success of rehabilitation, and to ensure final landforms are consistent with the surrounding national park. Should this option not be pursued, it is recommended that the proponent provide information, to the satisfaction of DEC and the Conservation Commission, on an alternative backfilling strategy.

• The proponent provides DEC with at least preliminary information from research being undertaken at The University of Western Australia regarding the potential impacts of pit lakes on groundwater quality at Marandoo mine prior to project approval to allow an informed assessment to be undertaken.

• The proponent provides information on how the proposed rehabilitation and

intense rainfall events. In fact, void water quality is more than likely to be consistent with final land use (~2000 mg/L TDS). This work will need to be extended to every site on a case-by-case basis as particular characteristics at each site may differ. The research being undertaken by UWA is in its infancy and has centred on the South-East Prongs pit at Tom Price, and thus currently focuses on issues not relevant to Marandoo (i.e. acid rock drainage). The Proponent agrees that the final landscape design should give adequate regard to visual impact given the location of the Proposal near the base of Mount Bruce. Therefore, the dump height has been designed to remain below the level of Marandoo Ridge. The PER states that slopes will be battered to less than/equal to 20°, depending on material characteristics. The key driver is the development of a stable landform and the final slope angles will be dependent on further material characterisation work once mining commences. The Conceptual Closure Plan included a sustainable development assessment of options for the site. Workshops were held in 2006, and included representatives of DoIR, the Shire of Ashburton, the Pilbara Development Commission and Tourism Western Australia. One of the factors included in the assessment of options was visual amenity. The Conceptual Closure Plan is an internal document developed in accordance with the Proponent’s Closure Standard, and is not appropriate for submission to the DEC and Conservation Commission; however, the Proponent is willing to discuss the closure strategies and plans contained within the document, and to involve both groups in future iterations of the plan. The Proponent agrees that further investigation and consultation are required to determine the most desirable final landform. Outcomes may alter the Proponent’s currently proposed backfilling strategies. The Proponent’s internal Closure Standard requires closure studies to be conducted for each site on a five-yearly basis. This requirement is aimed at ensuring that closure strategies remain consistent with current mine plans and stakeholder expectations, and to ensure that the outcomes of ongoing research are appropriately captured. Strategies are therefore continually reviewed and revised during operation, and are developed to increasing levels of detail as the site approaches closure.



Item Submission from Comment Proponent response closure strategies at the project will address compatibility with the surrounding natural landforms in order to ensure that the design and management of post-mining landforms are consistent with the surrounding environment and post-mining land use.

• The Conceptual Closure Plan (which includes a Rehabilitation Plan) be revised and provided for review and endorsement by DEC and the Conservation Commission prior to project approval.


• The proponent must be required to backfill to above the water table. This will reduce the significant risk of attracting feral animals (that damage native vegetation, soils, native fauna and spread weeds) or supporting increased and unnatural populations of native grazing animals within the National Park, and address Indigenous cultural issues associated with open water bodies.

Refer to detailed response in Section 5.7.2 and to response to Item 4.

6 Notwithstanding the absolute objection outlined above to any expansion of the Marandoo mine below the water table, it is also essential that, before any approval for further disturbance within the boundaries of the Karijini National can be considered by the EPA, the results of existing rehabilitation should be assessed. If current rehabilitation is not up to the standard that would be expected for the eventual return of the lands within the mining lease to the National Park, then the application should be deferred until such time as the proponent can demonstrate this level of rehabilitation.

Rehabilitation monitoring at Marandoo has demonstrated that rehabilitated sites are approaching corresponding reference sites in terms of total number of species, diversity, density and cover. The Proponent has been actively monitoring and adaptively managing rehabilitation associated with the current Marandoo operation since 1999. Monitoring results are statistically analysed to evaluate the successional development of the rehabilitation and thereby provide useful feedback for the improvement of rehabilitation techniques, and to assess progress towards long-term rehabilitation objectives. This monitoring and analysis has demonstrated that, although there is considerable variability between the sites in the rates at which the rehabilitation is developing, most sites are becoming more like their corresponding reference site(s). In several cases, the vegetation communities of rehabilitated and reference sites closely match (in terms of total number of species, diversity, density and cover). Classification analysis has also demonstrated the rehabilitated and reference sites do not consist of two identifiably separate plant communities. Sites also continue to perform well in response to fire, which is an important test of resilience in post-mining ecosystems. Note that the Proposal does not include disturbance within the boundaries of Karijini National Park.



6.11 HEALTH

Table 13 Response to submissions relating to health


1 DoH

The Marandoo mine is located in a region of WA that can experience very significant problems with nuisance (biting) insects. Mosquitoes are likely to be the most common problem, but other biting flies, especially Tabanids (March flies) and Ceratopogonids (biting midge), also cause a nuisance and have caused severe allergic reactions in some people living and working in the region. The region is also subject to outbreaks of mosquito-borne disease, especially Ross River virus (RRV), but also Barmah Forest virus and the much rarer but potentially fatal Murray Valley encephalitis, under certain environmental conditions. Considerable numbers of cases of RRV disease occur in some years at other towns and mine sites in the region. (e.g. Telfer, Marble Bar, Newman, Nullagine, Paraburdoo, Roeboume, Tom Price etc) after heavy rains associated with monsoonal activity from January to May. A large proportion of nuisance and disease carrying mosquitoes affecting the proposed camp are likely to emanate from surrounding natural mosquito breeding habitat. For example, temporary cut-off and ground pools created after flooding of the nearby Fortescue River are known to be favourable habitat for certain mosquito species. However, mining and camp site infrastructure also has the potential to create mosquito breeding habitat. Consequently, an integrated program to manage mosquitoes and other nuisance insects that also reduces the risk of exposure of employees to mosquito-borne diseases will be an important OSH component for the site. The program should comprise, but not necessarily be limited to, the following elements:

• monitoring of larval mosquitoes in the surrounding natural environment and mine and village infrastructure to warn of the risk of nuisance/disease carrying mosquitoes and to inform the location and timing of control measures;

• chemical control of larval mosquitoes in man-made breeding sites and in natural breeding sites in close proximity to residential quarters and the workplace;

• control of adult biting insects using fogging and/or residual surface sprays;

• source reduction (removal or modification of mosquito breeding habitat);

• appropriate location, design and maintenance of project infrastructure that may breed mosquitoes (e.g. wastewater, stormwater infrastructure); and

• provision of advice, seasonal warnings, insect screens on accommodation and enclosed workspaces, personal repellents, appropriate clothing, etc to enable employees to reduce their exposure to biting mosquitoes.

A framework mosquito management plan has been developed based on the Department of Health guidelines and the Proponent’s existing mosquito management plan for its Cape Lambert port operations. This framework aims to prevent an increase in mosquito populations as a result of the mining operations and reduce the risk of employee exposure to mosquito-borne diseases. The framework includes strategies to minimise the pooling of water, locate accommodation areas away from potential breeding areas, ensure accommodation areas are ventilated and, where necessary, investigate the use of insect electronic management devices and chemical control methods. The risk to personnel will be mitigated by ensuring accommodation areas are protected by insect screens and ensuring that site specific Personal Protective Equipment (PPE) is used.




2 Key components of project infrastructure described in the PER which require appropriate location, design and management to minimise potential for mosquito breeding include:

• Sewage Lagoons;

• Location of dewatering discharge a minimum of 3km from any areas inhabited by people (employees and/or visitors and tourists). The Department of Health (DOH) does not support dewatering discharge processes that result in the pooling of water for more than four days (the time taken for the aquatic stage of a mosquito's life cycle) as this is likely to become a productive breeding site for the common banded mosquito, Culex annulirostris, which is a known vector of RRV as well as the potentially fatal Murray Valley encephalitis;

• Waste / storm water overflow, run-off or spill areas;

• Alterations to topography that may enhance retention or impoundment of rainwater and runoff (e.g. through installation of the dewatering pipeline).

• Location of the accommodation camp away from potential mosquito-breeding habitat (either natural or man-made) will also be an important aspect of reducing the risk of mosquito-borne disease to mine employees; and,

• Any other water holding infrastructure that may not be specifically outlined (e.g. water storage tanks for potable water; constructed wetlands; waste water storage facilities; dams etc).


3 There are general requirements for RIO Tinto - Marandoo Mine (Phase 2) - to control pests (egg. weeds, feral animals etc) on the site. The treatment and application of pesticides must be applied in accordance with the Health (Pesticides) Regulations 1956. In addition, contractors/ persons who are applying the pesticides for reward must be appropriately trained and hold a current Pesticide Licence and be employed by a Registered Commercial Pest Firm. However, if the proponent/ company wish their own employees to apply pesticide(s) as part of their Pest Management Program, then the employees should be provided with sufficient knowledge, skills, training and the personal protective equipment to safely apply the pesticide(s).

The Proponent will ensure the treatment and application of pesticides is undertaken in accordance with the Health (Pesticides) Regulations 1956 and that relevant staff are provided with sufficient knowledge, skills, training and personal protective equipment to safely apply the pesticide(s).

4 The injection of dewatering flows into a potable water supply aquifer raises risk management issues. The proponent should confirm that injection into the Southern Fortescue bore field is agreeable to the Department of Water Source Protection Group. The protection of the dewatering bores from environmental and mining activity contamination, the protection of the reinjection bores and the nature of the infrastructure used for transferring the dewatering flows will need to be considered under a risk management scenario for the Torn Price drinking water supply. The wastewater treatment plant disposal fields should not be in proximity to such bores or the water treatment plant at the mine or operations camp. Attention should be given to AS 3500 National Plumbing and Drainage Code

The DoW stated in its submission on the PER that re-injection to the Southern Fortescue borefield is an acceptable method of disposing of excess water. The Proponent will ensure water and wastewater management associated with the Proposal is in accordance with AS 3500 National Plumbing and Drainage Code and AS 4020 Testing of products for use in contact with drinking water. Excess dewatering water transferred to Tom Price will be transferred to the town water storage tanks/treatment facility where the water will be tested and treated as per other incoming water supply. As suggested by the submitter, the dewatering water will be subject to appropriate treatment at the plant to ensure it is fit for potable water supply. This may require an upgrade of the testing/treatment process to ensure it is adequate to detect and/or treat possible contaminants (e.g. nitrates).



Item Submission from Comment Proponent response and AS 4020 Testing of products for use in contact with drinking water.

5 There is concern that the direct transfer of dewatering flows to Tom Price may mean that water supplies will bypass the town's water treatment plant. Any water intended for potable supplies should be appropriately treated. Non potable water supplies will still need to be fit for purpose. The use of the dewatering flows as potable water supplies for the mine staff will require a Drinking Water Quality Management Plan. This will include the regular chemical and microbiological analysis of the drinking water supply and such results must be provided to the Department of Health Water Unit. Please find attached the Model Drinking Water Quality Management Plan and Systems Compliance and Routine Reporting for Minesites and Exploration Camps which will assist you with this process.

Refer to response to Item 4. A potable water treatment plant will be installed to treat water to be used by mine personnel. This treatment plant will ensure the necessary level of treatment to meet relevant potable water quality standards.

6 Wastewater treatment plant proposals, to serve the mine site and operation/construction camps, will require individual approval under the Health (Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations 1974. Given the large number of personnel, substantial areas may be required for the proposed effluent disposal areas. Wastewater flow rates, full technical specifications for the wastewater treatment plant and sizing calculations for the disposal fields must be included in all applications. These are to be lodged via the Shire of Ashburton. The proponent may contact the Water Unit on 9388 4941 for assistance.

The Proponent will ensure the required wastewater treatment plant proposals are lodged via the Shire of Ashburton in accordance with the Health (Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations 1974.



6.12 MISCELLANEOUS ISSUES

Table 14 Response to miscellaneous issues

Item Submission from Subject Comment Proponent response

1 DoIR ARD To demonstrate that ARD will not be an issue - The volumes of material that will be encountered which have the potential to generate ARD.

Both the Marra Mamba Iron Formation and the Mount McRae Shale can potentially generate Acid Rock Drainage (ARD). As stated in Section 4.4 of the PER, drilling and geotechnical investigations at the site have indicated negligible amounts of potentially pyrite-bearing Mount McRae Shale within the proposed mine pit shell. Mineralised Marra Mamba Iron Formation is usually considered to pose an ARD risk only where total sulphur exceeds 0.3%. Interpolated resource model blocks at Marandoo have been generated based on approximately 25 000 samples from the deposit. As all resource model blocks are below 0.3% sulphur, the risk of ARD at Marandoo is considered minimal. Sulphur assays will continue to be monitored during future mining and any ARD risk material intersected will be dealt with in accordance with the Proponent’s Mineral Waste Management Plan.


Consultation The report states that community consultation took place and in Table 2 details the meetings that have taken place. No evidence is provided of who was at the meetings. More importantly no evidence was provided to suggest that the meetings were anything more than information sessions. There are modern anthropological investigative tools designed to solicit community input. No evidence is provided in the report, that any systematic methodology was employed. It appears that the so called community input was simply a series of calls for meeting and who every turned up was provided with a synopsis of the proposal.

The Proponent developed a stakeholder consultation plan early in the project planning stages, which identified stakeholders and the consultation tools to be utilised. Numerous tools were utilised during the consultation process for the Proposal, including:

• face-to-face meetings/briefings

• site visits

• presentations

• media releases

• the Proponent’s website

• distribution of information brochures

• shopping centre displays. Face-to-face meetings/briefings were the dominant consultation tool utilised, during which there were always opportunities for attendees to ask questions and provide comment and/or suggestions. Feedback from stakeholders was encouraged at all times in all forms of consultation and the project team was available for contact at any time.



Cumulative impacts The PER does not contain any assessment of the cumulative impacts of mine dewatering on the environment and cultural heritage of the Banyjima or Guruma people, the Fortescue catchment and/or the Pilbara generally. The potential impacts of the dewatering cannot however be

The cultural heritage surveys and investigations undertaken for the Marandoo Mine Phase 2 PER were at the appropriate scale to support the environmental impact assessment of the Proposal. Assessment at the level of PER requires the proponent to prepare an



Item Submission from Subject Comment Proponent response considered by the EPA in isolation. Relevantly, all the Aboriginal groups, including Banyijma, Gurama and Innawonga have already suffered cultural loss and damage to waterholes and springs, such as Weeli Wolli, through existing mines and dewatering operations at Hope Downs, Yandi, Yandicoogina, Eastern Range, Tom Price and Parabadoo. Having regard to the level of mining activity and past destruction of Sites in and around our client's claim area, their cultural heritage could be regarded as critically endangered.

Environmental Scoping Document, which amongst other things, provides a basis of understanding between the Proponent and the EPA regarding the assessment process and outlines the proposed scope of studies for incorporation into the PER. The Environmental Scoping Document for the Marandoo Mine Phase 2 PER was approved by the EPA on 20 March 2008.

5 DEC Fire risk and management

The PER recognises that the development will result in an increased risk of fire ignition due to an increase in mining-related activities in the area. The development of a Fire Management Plan for the project as the mechanism for managing this risk is supported. Given DEC is the proponent's direct neighbour at Marandoo, fire management needs to be addressed collaboratively. Recommendation: The Fire Management Plan for the project be developed in consultation with, and to the satisfaction of DEC.

Adequate mechanisms are already in place to provide a suitable framework for a collaborative and consultative approach between the Proponent and the DEC regarding fire management. The Proponent and the DEC have agreed in principle on a consultative process to address issues of potential environmental impact arising from the Marandoo operation by way of a Statement of Mutual Understanding (SMU). Matters addressed in the SMU include the development of a co-operative program of fire management and a regime for controlled burning at Marandoo. A Memorandum of Understanding (MOU) exists between the Proponent and the DEC, which covers consultative land management of the pastoral leases adjoining Karijini National Park. Matters addressed in the MOU include the development of management plans for all components of the agreement, with input from both parties, to facilitate compatible management practices of the issues relating to cross-boundary effects, such as fire management.

6 Conservation Council

Greenhouse gas emissions

Greenhouse gas emissions of 190,000tpa are significant in a state context. The Conservation Council contends that until the EPA has a policy position on GHG emissions that understands the cumulative impacts of each proposal on WA's emissions profile, and the required greenhouse gas emission reductions for WA to meet its obligations to avoiding dangerous climate change, then no project can be adequately assessed. Greenhouse gas emissions from each project must be placed in a cumulative impacts context by the EPA, and recommendations to the minister made in reference to this context. The EPA will not be asked to assess the proposed ETS, but can assess the impacts of each proposal in a cumulative context. The EPA's broad mandate to protect the environment demands that this is achieved.

The Proposal has been designed in light of the current state of knowledge and potential future commitments, such as emissions trading schemes, which may be introduced during the life of the Proposal. Implementation of greenhouse gas and energy conservation measures will enable the Proponent to minimise emissions and provide a mechanism for continuous improvement in greenhouse gas emissions resulting from the Proposal.

7 DEC Impact assessment Recommendation: The proponent undertakes an assessment of the impacts of the construction camp and dewatering infrastructure as part of the PER process (rather than having separate assessments).

Aspects excluded from the Proposal include:

• the provision of a construction camp

• construction of the dewatering infrastructure

• construction and operation of a pipeline from the existing rail corridor (south of the Southern Fortescue borefield) to Tom Price.

These aspects will be subject to separate environmental approvals processes under the provisions of the EP Act and in accordance with other statutes.



Item Submission from Subject Comment Proponent response

The Proponent has received formal consent from the EPA under section 43A of the EP Act for the removal of the construction of the dewatering pipeline from the scope of the Proposal. The Proponent and the EPA informally agreed during a meeting on 24 June 2008 on the removal of the construction of the accommodation camp from the scope of the Proposal.

8 DEC – Noise Branch

Noise The project is remote from any noise-sensitive premises. Tom Price is about 37 km to the west and Paraburdoo is about 77km to the south-west. The proposed operations camp will be located approximately 13 km to the north-west of project. According to the desktop noise and vibration impacts assessment conducted by SVT Engineering Consultants, there will be no noise impacts on these noise sensitive premises. Considering the long distance of these noise sensitive premises to the project and that the proposal is actually a continuation of an existing project, the Noise Branch would accept that the proposed project will not increase its noise impact on its nearby noise sensitive premises and the noise emission from the project will be able to comply with the noise regulations.

Noted.

9 DEC – Noise Branch

Noise It is noted that Mount Bruce, about 2.5km to the north of the mine, is frequently visited by tourists to Karijini National Park. SVT predicted that the proposed project will increase the noise impact level on this recreational site. The most significant noise emissions that could affect receptors at Mount Bruce are likely to be caused by blasting and mobile mining equipment such as haul trucks, dozers, excavators and graders. In particular, reversing beepers on this equipment have the potential to be audible at the lookout on Mount Bruce. Regarding the noise impact on this site, the proponent states that "Environmental Protection (Noise) Regulations 1997 (WA) set noise limits (assigned levels) for various types of receiving premises and buildings associated with noise-sensitive uses. The regulations are not applicable to Mount Bruce (as there are no noise-sensitive premises at Mount Bruce)." The Noise Branch is reluctant to agree with this statement. The EPA objective for noise is that noise emissions should meet regulatory requirements and acceptable standards. The EPA has previously expressed the opinion that recreational areas should have a much more stringent noise target than the regulatory requirement based on the 60 dB(A) level. For instance, in the assessment of the Methanex Complex project located on the Burrup Peninsula in 2002, the EPA recommended 45 dB(A) cumulative noise value as the ‘aspirational goal’ for Hearson Cove — a recreational beach. This aspirational goal has been followed for other new development proposals on the Burrup Peninsula since then. This position has been reflected in section 3.2.2 of Guidance No. 8, and the proponent should refer to that discussion. Though at the distance of 2.5 km, the noise emission level from the project is likely able to meet the 45 dB(A) ‘aspirational goal' in Mount Bruce, the Noise Branch would recommend that the proponent commit to

The Proponent is committed to using ‘smart reversing alarms’ to mitigate noise from mobile equipment and, as the progression of the pit is in the direction away from Mount Bruce, noise from this equipment is anticipated to be further attenuated. Noise levels at Mount Bruce due to blasting are also expected to decrease as the expansion develops and operational pits move further from Mount Bruce. SVT (2008) concluded that the most significant noise emission sources that could affect receptors at Mount Bruce are likely to be mobile mining equipment items such as haul trucks, dozers, excavators and graders. Noise generated by mobile equipment may be audible more frequently as a result of the Proposal, but will not necessarily become louder. As stated in Section 6.6 in the PER, noise from the Proposal will not perceptively increase above existing operations, and vibration will not increase as a result of the Proposal. Thus, assessment and management of noise level at Mount Bruce using the recommended ‘aspirational goal' is not warranted.



Item Submission from Subject Comment Proponent response such an ‘aspirational goal' for Mount Bruce, and assess and manage the noise impact on this recreational site using this ‘aspirational goal'.

10 DEC Offsets Recognising the high level of uncertainty in relation to key impacts and risks of this project on national park and biodiversity conservation values and their consequences, it would be premature to foreshadow the detailed nature and scope of offset measures required for this project at this time. However, given the potential risks and impacts of the development on key biodiversity and conservation estate assets as identified in this advice, the areas of risk and impact that may need to be addressed in an offsets package include the following:

• Diminished visual amenity values from key tourist locations within Karijini National Park.

• Dewatering of the confined aquifer resulting in a risk of:

• declining health of the Coolibah woodland on the Mt Bruce Flats; o altered groundwater discharge to springs and groundwater-fed

pools within Karijini National Park; o modification of subterranean fauna habitat; and o formation of sinkholes within Karijini National Park.

• Interruption of surface water flows from the mining area to the Coolibah and mulga on the Mt Bruce Flats.

• Risks to tourist/recreational values of Karijini National Park due to an increased workforce being accommodated in close proximity to the park.

• Increased risk of the following impacts on Karijini National Park due to activities over the long-term life of the project including: o introduction or spread of weeds; o wildfire in the national park due to increased ignition sources;

and o hydrocarbon spills contaminating groundwater and surface water

resources. Recommendation: That the proponent addresses EPA Guidance Statement No. 19 on Environmental Offsets – Biodiversity, and develops an offsets package and implementation plan, in consultation with DEC, that adequately addresses the residual impacts and risks to biodiversity and conservation estate values of the development.

The environmental offsets proposed by the Proponent have been developed in accordance with EPA Position Statement No. 9 (EPA 2006) and EPA Draft Guidance Statement No. 19 (EPA 2007) on the relative basis of the environmental assets. The environmental assets identified (refer to Table 27 in the PER) were the Coolibah woodland, Mulga, vegetation (high value assets) and Karijini National Park (Critical Asset). The offsets were developed based on an understanding of the potential impacts to these assets. The Proponent will finalise the offsets package and develop an implementation package in consultation with the DEC.

11 Offsets While it would be inappropriate to discuss acceptability of particular offset proposals or packages at this stage, DEC provides the following preliminary comments regarding the proposed offset options outlined in the PER:

• Offsets relating to residual impacts on the national park need to be




Item Submission from Subject Comment Proponent response considered in more detail in light of the potential risks and consequences of potential impacts outlined in this submission.

• Rehabilitation of an area of Coondewanna Flats requires further discussion with DEC as the affected area on Juna Downs will become DEC-managed land in 2015.

• Research into Coolibah water use requirements (with UWA) needs to be explored in more detail.

• The proponent has already committed to assisting DEC with fire fighting as part of the Marandoo Phase 1 project and while additional capacity as offered in the PER may provide benefits, it should be subject to a benefit analysis in comparison to other possible contributions.

12 Confidential submission

Other projects In the very near future Brockman 4 is going to come on stream and there are other Rio Tinto prospects ‘waiting in the wings’

The Proponent will refer to the EPA all proposals likely to have a significant effect on the environment for a decision on whether they should be subject to environmental impact assessment under the EP Act.

13 DoIR Residue Storage Facility

Characterisation of the material is required, thus demonstrating the benign natural of the material to be deposited in the Residual Storage Facility.

A geochemical assessment of the material to be mined at Marandoo (both waste and ore) has been completed in relation to ARD. Key conclusions were: 1. The risk of ARD generation from high grade material and

processed tailings is low. 2. The risk of ARD generation from waste is low, although there can

be some slightly elevated sulphur concentrations in the Wittenoom Formation and the MacLeod member.

3. Most of the sulphur concentrations above 0.1% in these formations are less than 0.3%. Therefore, if this material is potentially acid-forming, it is anticipated to be of low capacity.


Sustainability The PER states that sustainable principles will be followed in stage 2 as they were in Stage 1. However, the report also, correctly, notes that in the mining industry sustainability must be seen from a more holistic or high level vantage point, because once the ore has been removed it is obviously no longer available to future generations. From this point of view the report suggests that Rio Tinto has adopted a global sustainable approach where benefits from a project flow back to the country, the state and the local community; benefits that can be vested in the community for the benefit of future generations. We find this approach praise worthy, however, the report simply states these objectives, but lists no tangible benefits, except for the royalty stream to the Government. We therefore request a breakdown of the financial gains from the project. In particular we would expect the following breakdown for both Stage 1 as historical proof that the benefits have occurred and for Stage 2 as a terms of reference for the permit: a. Revenue for Stage 1 and 2. b. Operational costs to the company to take this ore from the ground to

The information the submitter has requested is commercially-sensitive and/or not relevant for the purposes of environmental impact assessment.




Item Submission from Subject Comment Proponent response the market place

c. Annual amount returned to shareholder and stock value d. Return to the Federal Government in the form of royalties e. Return to the State Government in the form of royalties f. Return to the community, itemized as detailed in the PER:

I. Subsidies to infrastructure such as rail, road, housing etc II. Establishment of social infrastructure such as schools, staff

developments III. Aboriginal mentoring and employment opportunities IV. Medical care V. Environmental research


Timing A significant question I would like to ask of Rio Tinto. Why was the Phase 2 Proposal document released just now when it was known, before the commencement of the mining of the Marandoo deposit, that there was economically viable iron ore in substantial quantity beneath the water table? Evidence is confirmed in the fact that a 10 kilometre long mineral lease was pegged by surveyors, just a nice size to accommodate the proposed 8 kilometre pit!

Mining the Marandoo deposit below the watertable was not economically viable at the time of the environmental assessment for the Marandoo above watertable operation. In addition, there was insufficient hydrogeological information to enable an accurate prediction to be made regarding the potential impacts associated with dewatering the ore body. As stated in the PER, the numerical groundwater model constructed in 1992 to characterise the aquifer system has been further calibrated through a number of investigations conducted over several years. These investigations have provided suitable data to produce numerical model of the Marandoo groundwater system suitable for the purposes of mine planning and environmental impact assessment.

17 Tourism WA Tourism Short stay accommodation developments in the Pilbara experience average occupancies above 90% for 12 months of the year as a result of accommodating workers. Although this may seem attractive to the hotel industry, it creates pressures in regard to the dispersion of travellers through the region and has the potential to impact on other areas in the State. Tourism Western Australia (Tourism WA) is conscious that any increase in mining activity in the region has a direct impact on the accommodation availability for visitors. It is imperative that proponents of any new industrial developments provide accommodation for workers associated with their projects. Tourism WA agrees that a remote village operations camp is required to best house the workers associated with this project and that using existing accommodation in Tom Price is unacceptable. A site that is in close proximity to Marandoo and has no or little visual impact on Karijini National Park is preferred. The proposed "site 6" for the accommodation camp appears to have met those requirements.

Noted.

18 Tourism WA Tourism Tourism WA advocates strongly that the tourism experience in the area, particularly at Karijini National Park, should not be affected by the

Potential environmental impacts to Karijini National Park as a result of the Proposal will be managed through measures outlined in the EMP



Item Submission from Subject Comment Proponent response Marandoo Mine Phase 2 project, including flight availability at Paraburdoo Airport and the proposed Torn Price Airport, accommodation in Tom Price, and noise and environmental impact within Karijini National Park.

and through the proposed environmental conditions presented in Section 8.4 of the PER. As stated in the PER, noise from the Proposal will not perceptively increase above existing operations, and vibration will not increase as a result of the Proposal. The decision as to whether additional flights are scheduled to respond to increasing demand is a matter for the air service provider. Scheduling of additional flights has occurred in the past to cater for increased demand.


Tourism The report makes a number of major ascertains about tourism and the likely impact of the proposed expansion on tourism. No concrete evidence is provided of any systematic surveys or analysis. On questioning an officer from CALM who was present at the consultation meeting on 10 November 2008, it became clear that this whole section relied on the entries in one visitation sign-in book at one lookout.

Refer to response to Item 18. There was no formal representation from the DEC at the consultation meeting held on 10 November 2008. The officer referred to was present at the meeting in their capacity as a member of the Martu Idja Banyjima Native Title Claim Group. Estimated visitor numbers to Karijini National Park were sourced from the DEC (March 2008). The estimates were extrapolated from Metrocount vehicle classifiers, traffic counters, ticket sales and entry/camping fees. Additional information regarding tourism in Karijini National Park was sourced from the Karijini National Park Management Plan (CALM 1999).



Tourism If the Proposal of Rio Tinto falls foul, then a lot of tourist dollars won’t be coming into the country. It would be a travesty of justice if one of the Australian icons becomes a wasteland. Once all the iron ore of economic value has been extracted, Karijini is going to be around for a long while.


22 DEC Waste water treatment Issue: The disposal of treated wastewater into natural drainage lines is not discussed in sufficient detail in the PER. Recommendation: The level of waste water treatment (primary, secondary or tertiary) be addressed by the proponent and the potential impacts of this adequately discussed in the PER.

The disposal method for treated wastewater is described in Section 4.9 of the PER and states that “Treated sewage will be discharged to a sprayfield that will be established as part of the Proposal” not into drainage lines. The exact location of the sprayfield is yet to be determined, however an indicative location is shown in Figure 15 of the PER. The upgrading of the existing wastewater treatment plants and the disposal of treated wastewater will be managed by other regulatory processes and as such is not an issue for Part IV approvals. Upgrading of the WWTP will require approval under the Health (Treatment of Sewage and Disposal of Effluent and Liquid Waste) Regulations 1974 with applications for such approval requiring specification of wastewater flow rates, full technical specification and sizing calculations for the disposal fields. This application will be submitted to the Shire of Ashburton.

23 DEC Workforce management

The PER states that the project will not have any impacts on the values of the national park, as the workforce will work on a fly-in/fly-out roster based on 12 hour days, therefore leaving limited time for personnel to undertake recreational activities (p. 160). However, contractors and employees working at various exploration and mine sites in the area (not specific to Marandoo) on such a schedule still find time to recreate in




Item Submission from Subject Comment Proponent response Karijini (particularly on 'days off'). There have been several instances where workforce behaviour in the park has had serious adverse impacts on other tourists, as well as DEC park staff (e.g. anti social and aggressive behaviour, leaving rubbish and glass bottles in the gorges). While this behaviour is by no means typical of all rostered contractors/mine site personnel visiting Karijini, occasional incidents of this nature have substantial impacts on visitor perception and enjoyment of the national park. Recommendation: The proponent develops a more detailed workforce management strategy that combines education with a more regulated regime for the workforce when recreating in Karijini National Park. A requirement to develop this strategy in consultation with, and to the satisfaction of DEC, could be considered as a condition of project approval.

24 DEC Workforce management

The proponent has identified this issue and proposes in the PER to manage the activities of mine staff and contractors via inductions and education on appropriate behaviour in the park (p. 160). However, education alone is unlikely to be enough to ensure appropriate workforce behaviour over the long term, particularly given the numbers of personnel involved (up to 700 people during operations, and significantly higher numbers during construction). If the location of the accommodation camp is found to be environmentally acceptable on other grounds, a clear commitment or requirement for active monitoring and management of workforce behaviour is needed. Recommendation: That during the peak construction period, the proponent provides resources to support the appointment of additional ranger staff in Karijini National Park in order to maintain an adequate presence of DEC personnel in the park, commensurate with the increase in contractors/employees visiting the park.

Refer to detailed response in Section 5.2.2. The number of personnel quoted by the submitter (up to 700) will be on-site only during shutdown maintenance periods (which tend to be short in duration). The standard operational workforce will comprise approximately 500 personnel.



7. REFERENCES

Adams M 2005, Monitoring Plan for the Impacts on Tree Health in Riparian Ecosystems surrounding Pilbara Iron’s Yandicoogina Operations, University of Western Australia.

Adams M 2006, Regional Plan for managing riparian zones in the Pilbara, University of Western Australia.

Adams M 2007, Monitoring Plan for the Impacts on Tree Health in Riparian Ecosystems at Hope Downs, Advanced Ecological Consultants.

AGC Woodward Clyde 1992, Marandoo Iron ore project: Investigation of the hydrogeology of the Mt Bruce Flats environs. Volume 1: Main Text and plans, unpublished report prepared for Hamersley Iron.

Batini, F. 2008, Marandoo Phase 2 Proposal – Mining below watertable - Assessment of Impacts from Groundwater Dewatering and Surface Water Drainage on Significant Vegetation - Coolibah and Mulga, unpublished report prepared for Rio Tinto Iron Ore, May 2008.

Biota Environmental Sciences (Biota) 2008a, Marandoo Mine Phase 2 Project Vegetation and Flora Survey, unpublished report prepared for Pilbara Iron, June 2008.

Biota Environmental Sciences (Biota) 2008b, Marandoo Mine Phase 2 Extension Subterranean Fauna Assessment, unpublished report prepared for Pilbara Iron, May 2008.

CSIRO and Australian Bureau of Meteorology 2007, Climate Change in Australia: technical report 2007, CSIRO.

Department for Planning and Infrastructure (DPI) 2007, Visual Landscape Planning in Western Australia: a manual for evaluation, assessment, siting and design, Western Australian Planning Commission, November 2007.

Department of Conservation and Land Management (CALM) 1989, Visual Resource Management on Land and Waters managed by CALM, Policy Statement No. 34, Western Australia.

Department of Conservation and Land Management (CALM) 1999, Karijini National Park Management Plan 1999–2009, Management Plan No. 40, prepared by the Department of Conservation and Land Management for the National Parks and Nature Conservation Authority, Perth, Western Australia.

Dodson, W, 2008, Marandoo Phase II Spring and Gorge Water Assessment, Unpublished report prepared for Rio Tinto, August 2008.

Environmental Protection Authority (EPA) 2004a, Terrestrial Flora and Vegetation Surveys for Environmental Impact Assessment in Western Australia, Guidance Statement No. 51, June 2004.

Environmental Protection Authority (EPA) 2004b, Terrestrial Fauna Surveys for Environmental Impact Assessment in Western Australia, Guidance Statement No. 56, June 2004.



Environmental Protection Authority (EPA) 2006, Environmental Offsets, Position Statement No. 9, January 2006.

Environmental Protection Authority (EPA) 2007, Environmental Offsets, Draft Guidance Statement No. 19, June 2007.

Evans, L. 2006, Preliminary Dewatering–Reinjection Operational Report – Marra Mamba Below Watertable Project, unpublished report prepared for Pilbara Iron, January 2006.

Intergovernmental Panel on Climate Change (IPCC) 2001, Climate Change 2001: The Scientific Basis, Contribution of Working Group I to the Third Assessment Report of the Intergovernmental Panel on Climate Change, Houghton JT, Ding Y, Griggs DJ, Noguer M, van der Linden PJ and Xiaosu D (Eds.), Cambridge University Press, UK.

Landscape Institute and the Institute of Environmental Management and Assessment (LI and IEMA) 2002, Guidelines for Landscape and Visual Impact Assessment, Second Edition, Spon Press, 2002.

Liquid Earth 2005, Marandoo Hydrogeological Investigation Report, unpublished report prepared for Pilbara Iron, August 2005.

Mattiske Consulting Pty Ltd (Mattiske) 2008, Review of flora and vegetation along creek systems near discharge points – Marandoo, unpublished report prepared for Rio Tinto, August 2008.

MWH Australia Pty Ltd (MWH) 2006a, Marra Mamba BWT Project – Dewatering and Re-injection Program, unpublished report prepared for Pilbara Iron, April 2006.

MWH Australia Pty Ltd (MWH) 2006b, Marandoo Model Development 2006, unpublished report prepared for Pilbara Iron, May 2006.

MWH Australia Pty Ltd (MWH) 2007, Southern Fortescue Sinkholes Position Paper, unpublished report prepared for Pilbara Iron, July 2007.

MWH Australia Pty Ltd (MWH) 2008, Southern Fortescue borefield modelling - Preliminary Results, unpublished letter report prepared for Pilbara Iron, August 2008.

Rio Tinto 2008, Marandoo Mine Phase 2, Public Environmental Review.

Sinclair Knight Merz (SKM) 2008, Marandoo Phase 2 Landscape and Visual Impact Assessment, unpublished report prepared for Pilbara Iron, June 2008.

SVT Engineering Consultants (SVT) 2008, Review of Noise Impacts Associated with the Marandoo Mine Phase 2 Project, unpublished report prepared for Pilbara Iron, June 2008.

Wetland Research and Management (WRM) 2008, Dewatering discharge: Potential impacts to aquatic biota of Fortescue River South, unpublished report prepared for Rio Tinto, July 2008.

Youngs, J. and Brown, D. M. 2005, Aquifer re-injection as a low impact groundwater investigation tool – a case study from the Pilbara region, Western Australia, unpublished report prepared for Pilbara Iron, 2005.

Appendix 1 Documents provided to the Martu Idja Banyjima Native Title Claim Group

Adams M 2005, Monitoring Plan for the Impacts on Tree Health in Riparian Ecosystems surrounding Pilbara Iron’s Yandicoogina Operations, University of Western Australia.

Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand (ANZECC/ARMCANZ) 1996, National Principles for the Provision of Water for Ecosystems, Sustainable Land and Water Resources Management Committee Subcommittee on Water Resources Occasional Paper SWR No. 3.

Australian and New Zealand Minerals and Energy Council (ANZMEC) and Minerals Council of Australia (MCA) 2000, Strategic Framework for Mine Closure, National Library of Australia Catalogue.

Australian Heritage Commission 1992, Assessment statement for Karijini National Park on the Register of the National Estate, Australian Heritage Commission, Canberra.

Australian Natural Resources Atlas 2007, Rangelands overview, Western Australia, http://www.aussieheritage.com.au/listings/wa/Wittenoom/HamersleyRangeNationalPark1977boundary/20406, accessed 19 May 2008.

Batley GE, Humphrey CL, Apte SC and Stauber JL 2003, A Guide to the Application of ANZECC/ARMCANZ Water Quality Guidelines in the Mineral Industry, Australian Centre for Mining Environmental Research, September 2003.

Bessen Consulting Services 2007, Pilbara Regional Water Planning Forum – outcomes report, Department of Water, Karratha.

Bradshaw E and Thomson J 2004, Cultural Heritage Management: Community Partnerships and Integrated Business Systems, http://www.minerals.org.au/__data/assets/pdf_file/0012/6051/9B-3BradshawElizabeth.pdf, accessed 19 May 2008.

Commonwealth of Australia 2007a, Biodiversity Assessment – Pilbara – Threatened Ecosystems, http://www.anra.gov.au/topics/vegetation/assessment/wa/ibra-pil-ecosystem-threats.html, accessed 23 April 2008.

Commonwealth of Australia 2007b, Biodiversity Assessment – Pilbara – Species at Risk and the Threatening Process, http://www.anra.gov.au/topics/vegetation/assessment/wa/ibra-pil-species-threats.html, accessed 23 April 2008.

Dodson W, 2008, Marandoo Phase II Spring and Gorge Water Assessment, Unpublished report prepared for Rio Tinto, August 2008.

Fortech 1999, Pilbara Mulga Study Stage 1, prepared for the Department of Resources Development, March 1999.

Government of Western Australia 2003a, Hope for the Future: The Western Australian State Sustainability Strategy, Department of the Premier and Cabinet, Perth.

Johnson SL and Wright AH 2003, Mine void water resource issues in Western Australia, Water and Rivers Commission, Hydrogeological Record Series, Report HG 9.

Kendrick P 2001, Pilbara 3 (PIL3 – Hamersley sub-region) in “A Biodiversity Audit of Western Australia's 53 Biogeographical Sub-regions 2002”, eds. May, JE and McKenzie, NL 2003, Department of Conservation and Land Management, Perth.

Liquid Earth 2005, Marandoo Hydrogeological Investigation Report, unpublished report prepared for Pilbara Iron, August 2005.

MWH Australia Pty Ltd (MWH) 2006a, Marandoo Model Development 2006, unpublished report prepared for Pilbara Iron, May 2006.

MWH Australia Pty Ltd (MWH) 2006b, Marra Mamba BWT Project – Dewatering and Re-injection Program, unpublished report prepared for Pilbara Iron, April 2006.

Ruprecht J and Ivanescu S 2000, Surface Hydrology of the Pilbara Region: Summary Report, Water and Rivers Commission Surface Water Hydrology Report Series, Report No. SWH 32.

van Vreeswyk AME, Payne AL, Leighton KA and Hennig P 2004, An Inventory and Condition Survey of the Pilbara Region, Western Australia, Department of Agriculture Technical Bulletin No. 92.

Appendix 2 Hydrographs for the Marandoo area

OW10s & d

679

680

681

682

683

684

685

686

1/9/05 21/9/05 11/10/05 31/10/05 20/11/05 10/12/05 30/12/05 19/1/06 8/2/06 28/2/06

m R

L

OW10d OS10s

End of I

nject

ion

Start

of In

ject

ion

Shallow Aquifer

Deep Aquifer

No response

Draw-up 1.1m

OW12s & d

679

680

681

682

683

684

685

686

1/9/05 21/9/05 11/10/05 31/10/05 20/11/05 10/12/05 30/12/05 19/1/06 8/2/06 28/2/06

m R

L

OW12d OW12s

End of I

nject

ion

Start

of In

ject

ion

Shallow Aquifer

Deep Aquifer

No response

Draw-up 0.36m

OW15s & d

679

680

681

682

683

684

685

686

1/9/05 21/9/05 11/10/05 31/10/05 20/11/05 10/12/05 30/12/05 19/1/06 8/2/06 28/2/06

m R

L

OW15d OW15s

End of I

nject

ion

Start

of In

ject

ion

Shallow Aquifer

Deep Aquifer

No response

Draw-up 0.31m

OW21s & d

674

676

678

680

682

684

686

1/9/05 21/9/05 11/10/05 31/10/05 20/11/05 10/12/05 30/12/05 19/1/06 8/2/06 28/2/06

m R

L

OW21 d OW21 s

End of D

ewaterin

g

Start

of D

ewaterin

g

Shallow Aquifer

Deep Aquifer

No response

Draw-down 3m

End of I

nject

ion

Start

of In

ject

ion

Shallow Aquifer


OW24s, i & d

679

680

681

682

683

684

685

686

1/9/05 21/9/05 11/10/05 31/10/05 20/11/05 10/12/05 30/12/05 19/1/06 8/2/06 28/2/06

m R

L


No response in shallow aquifer

Average Draw-up 4.4m

OW26s, i & d

679

680

681

682

683

684

685

686

1/9/05 21/9/05 11/10/05 31/10/05 20/11/05 10/12/05 30/12/05 19/1/06 8/2/06 28/2/06

m R

L


End of I

nject

ion

Start

of In

ject

ion

Shallow Aquifer


No response

Draw-up 0.31m

OW12s & d

679

680

681

682

683

684

685

686


m R

L

OW12d OW12s

Start

of In

jection

End o

f Injec

tion

Shallow Aquifer

Deep Aquifer

OW15s & d

679

680

681

682

683

684

685

686


m R

L

OW15d OW15s

Start

of In

jection

End o

f Injec

tion

Shallow Aquifer

Deep Aquifer

OW23s, i1, i2 & d

679

680

681

682

683

684

685

686


m R

L

OW23d OW23i1 OW23i2 OW23s

Start

of In

jection

End o

f Injec

tion

No change in Shallow Aquifer Water Table

Visible rise in Deep Aquifer

Visible rise inIntermediate Aquifers

OW24s, i & d

672

674

676

678

680

682

684

686


m R

L


Start

of P

umpi

ng

End o

f Pum

ping

Shallow Aquifer


Adjacent to Pumping well

OW25s, i & d

679

680

681

682

683

684

685

686


m R

L


Start

of In

jection

End o

f Injec

tion

Shallow Aquifer


OW26s, i & d

679

680

681

682

683

684

685

686


m R

L


Start

of In

jection

End o

f Injec

tion

Shallow Aquifer


OW27s, i & d

679

680

681

682

683

684

685

686


m R

L


Start

of In

jection

End o

f Injec

tion

Shallow Aquifer


OW28s & d

679

680

681

682

683

684

685

686


m R

L

OW28 d OW28 s

Start

of In

jection

End o

f Injec

tion

Shallow Aquifer

Deep Aquifer

OW30s & d

679

680

681

682

683

684

685

686


m R

L

OW30 d OW30 s

Start

of In

jection

End o

f Injec

tion

Shallow Aquifer

Deep Aquifer

Adjacent to Injecting well

OW3

678

679

680

681

682

683

684

685

686

Mar-05 Sep-05 Apr-06 Oct-06 May-07 Nov-07 Jun-08 Dec-08

m R

L

0

50

100

150

200

250

Rainfall

OW3

OW06

682

684

686

688

690

692

694

696


m R

L

0

50

100

150

200

250

Rainfall

OW06

OW8d

681

681.2

681.4

681.6

681.8

682

682.2

682.4

682.6


m R

L

0

50

100

150

200

250

Rainfall

OW8d

OW8s

674

674.1

674.2

674.3

674.4

674.5

674.6

674.7

674.8


m R

L

0

50

100

150

200

250

Rainfall

OW8s

OW9

680.8

681

681.2

681.4

681.6

681.8

682


m R

L

0

50

100

150

200

250

Rainfall

OW9

OW10d

679.5

680

680.5

681

681.5

682

682.5

683

683.5

684

684.5

Jan-93 Sep-95 Jun-98 Mar-01 Dec-03 Sep-06

m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW10d

OW10s

682

682.5

683

683.5

684

684.5

685

685.5

686


m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW10s

OW11d

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6

681.8

682


m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW11d

OW11i

679.5

680

680.5

681

681.5

682


m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW11i

OW12d

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6

681.8

682

Jan-03 May-04 Sep-05 Feb-07 Jun-08

m R

L

0

50

100

150

200

250

Rainfall

OW12d

OW12s

684

686

688

690

692

694

696


m R

L

0

50

100

150

200

250

Rainfall

OW12s

OW13

670

670.5

671

671.5

672

672.5

673

673.5

674

674.5


m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW13

OW14

672

672.5

673

673.5

674

674.5

675

675.5

676

676.5


m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW14

OW15d

680.4

680.6

680.8

681

681.2

681.4

681.6

681.8

682

682.2

682.4


m R

L

0

50

100

150

200

250

Rainfall

OW15d

OW15s

684.5

685

685.5

686

686.5

687

687.5


m R

L

0

50

100

150

200

250

Rainfall

OW15s

OW17

683.6

683.8

684

684.2

684.4

684.6

684.8

685

685.2

685.4

685.6

685.8


m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW17

OW18

682

682.2

682.4

682.6

682.8

683

683.2

683.4

683.6

683.8


m R

L

0

50

100

150

200

250

300

350

400

Rainfall

OW18

OW20

679

680

681

682

683

684

685

686

687

688

689


m R

L

0

50

100

150

200

250

Rainfall

OW20

OW21d

674.5

675

675.5

676

676.5

677

677.5

678

678.5

679

679.5


m R

L

0

50

100

150

200

250

Rainfall

OW21d

OW21s

679.5

680

680.5

681

681.5

682

682.5

683

683.5

684

684.5


m R

L

0

50

100

150

200

250

Rainfall

OW21s

OW22d

670

672

674

676

678

680

682

684

686


m R

L

0

50

100

150

200

250

Rainfall

OW22d

OW22s

681

681.5

682

682.5

683

683.5

684


m R

L

0

50

100

150

200

250

Rainfall

OW22s

OW23d

676.5

677

677.5

678

678.5

679

679.5

680

680.5

681

681.5

682


m R

L

0

50

100

150

200

250

Rainfall

OW23d

OW23i1

680

680.5

681

681.5

682

682.5


m R

L

0

50

100

150

200

250

Rainfall

OW23i1

OW23i2

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6

681.8

682


m R

L

0

50

100

150

200

250

Rainfall

OW23i2

OW23s

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6

681.8

682

682.2

682.4


m R

L

0

50

100

150

200

250

Rainfall

OW23s

OW24d

672.0

674.0

676.0

678.0

680.0

682.0

684.0

686.0

688.0


m R

L

0

50

100

150

200

250

Rainfall

OW24d

OW24i

672.0

674.0

676.0

678.0

680.0

682.0

684.0

686.0


m R

L

0

50

100

150

200

250

Rainfall

OW24i

OW24s

679

680

681

682

683

684

685

686


m R

L

0

50

100

150

200

250

Rainfall

OW24s

OW24s

679.6

679.8

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW25d

OW25i

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW25i

OW25s

683.5

684

684.5

685

685.5

686


m R

L

0

50

100

150

200

250

Rainfall

OW25s

OW26d

679.6

679.8

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW26d

OW26i

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW26i

OW26s

683.5

684

684.5

685

685.5

686


m R

L

0

50

100

150

200

250

Rainfall

OW26s

OW27d

645.0

650.0

655.0

660.0

665.0

670.0

675.0

680.0

685.0


m R

L

0

50

100

150

200

250

Rainfall

OW27d

OW27i

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW27i

OW27s

683.5

684

684.5

685

685.5

686

686.5

687

687.5

688

688.5


m R

L

0

50

100

150

200

250

Rainfall

OW27s

OW28d

679.4

679.6

679.8

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW28d

OW28i

680.4

680.6

680.8

681

681.2

681.4

681.6

681.8

682


m R

L

0

50

100

150

200

250

Rainfall

OW28i

OW28s

683

684

685

686

687

688

689

690


m R

L

0

50

100

150

200

250

Rainfall

OW28s

OW29

680

680.2

680.4

680.6

680.8

681

681.2


m R

L

0

50

100

150

200

250

Rainfall

OW29

OW30d

680

680.5

681

681.5

682

682.5

683

683.5

684

684.5


m R

L

0

50

100

150

200

250

Rainfall

OW30d

OW30s

684.0

685.0

686.0

687.0

688.0

689.0

690.0


m R

L

0

50

100

150

200

250

Rainfall

OW30s

OW31d

674

674.5

675

675.5

676

676.5

677

677.5

678

678.5

679


m R

L

0

50

100

150

200

250

Rainfall

OW31d

OW32d

674.0

676.0

678.0

680.0

682.0

684.0

686.0

688.0


m R

L

0

50

100

150

200

250

Rainfall

OW32d

OW33d

677

677.5

678

678.5

679

679.5


m R

L

0

50

100

150

200

250

Rainfall

OW33d

OW34d

678.5

679

679.5

680

680.5

681

681.5


m R

L

0

50

100

150

200

250

Rainfall

OW34d

OW35d

679

679.5

680

680.5

681

681.5

682


m R

L

0

50

100

150

200

250

Rainfall

OW35d

OW36d

679.4

679.6

679.8

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW36d

OW36i

679.4

679.6

679.8

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6


m R

L

0

50

100

150

200

250

Rainfall

OW36i

OW8s & d

673

674

675

676

677

678

679

680

681

682

683

Feb-05 Sep-05 Mar-06 Oct-06 Apr-07 Nov-07 Jun-08 Dec-08

m R

L

OW8 d OW8 s

OW10s & d

679

680

681

682

683

684

685

686

687


m R

L

OW10d OS10s

OW11i & d

679.5

680

680.5

681

681.5

682

Jan-93 Sep-95 Jun-98 Mar-01 Dec-03 Sep-06 Jun-09

m R

L

OW11d OW11i

OW12s & d

678

680

682

684

686

688

690

692

694

696

Sep-02 Jan-04 May-05 Oct-06 Feb-08 Jul-09

m R

L

OW12d OW12s

OW15s & d

680

681

682

683

684

685

686

687

688


m R

L

OW15d OW15s

OW21s & d

674

676

678

680

682

684

686


m R

L

OW21 d OW21 s

OW22s & d

670

672

674

676

678

680

682

684

686


m R

L

OW22 d OW22 s

OW23s, i & d

677

678

679

680

681

682


m R

L

OW23d OW23i1 OW23i2 OW23s

OW24s, i & d

672

674

676

678

680

682

684

686

688


m R

L


OW25s, i & d

679

680

681

682

683

684

685

686

Dec-02 Jun-03 Jan-04 Aug-04 Feb-05 Sep-05 Mar-06 Oct-06 Apr-07 Nov-07 Jun-08 Dec-08

m R

L


OW26s, i & d

679

680

681

682

683

684

685

686

Jun-03 Jan-04 Aug-04 Feb-05 Sep-05 Mar-06 Oct-06 Apr-07 Nov-07 Jun-08 Dec-08

m R

L


OW27s, i & d

677

679

681

683

685

687

689


m R

L


OW28s, i & d

678

680

682

684

686

688

690


m R

L


OW30s & d

679

680

681

682

683

684

685

686

687

688

689

690


m R

L

OW30 d OW30 s

OW36i & d

679.4

679.6

679.8

680

680.2

680.4

680.6

680.8

681

681.2

681.4

681.6

Jan-04 Aug-04 Feb-05 Sep-05 Mar-06 Oct-06 Apr-07 Nov-07 Jun-08 Dec-08

m R

L

OW36d OW36i

Appendix 3 Hydrographs for the Southern Fortescue borefield

Scenario SFB1: Hydrograph of Water Depth at SF015

0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF015

Pre-Borefield Levels


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF010

Pre-Borefield Level


600

610

620

630

640

650

660

670

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF08

Pre-Borefield Level


0

10

20

30

40

50

60

70

80

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF05

Pre-Borefield Level

Scenario SFB1: Hydrograph of Water Depth at SF07D

0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF07D

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF015



0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF010

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF08

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF07D

Pre-Borefield Level


0

10

20

30

40

50

60

70

80

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF05

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF015



0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF010

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF08

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF07D

Pre-Borefield Level


0

10

20

30

40

50

60

70

80

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF05

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF015



0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF010

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF08

Pre-Borefield Level


0

10

20

30

40

50

60

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF07D

Pre-Borefield Level


0

10

20

30

40

50

60

70

80

2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2029

Dep

th t

o W

ater

(m

bg

l)

SF05

Pre-Borefield Level