Water Management Plan - Mine

OP-PLN-00300

Key Environmental Factor: Inland Waters

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TABLE OF CONTENTS
Summary.................................................................................................................................................................. 3
1 Context, Scope and Rational ............................................................................................................................ 4
1.1 The Proposal ....................................................................................................................................... 4
1.2 Key Environmental Factors ................................................................................................................. 8
1.3 Condition Requirements ..................................................................................................................... 9
1.4 Rationale and approach .................................................................................................................... 10
1.4.1 Survey and Study Findings................................................................................................................................ 10
1.4.2 Key assumptions and uncertainties ................................................................................................................. 10
1.4.3 Management approach .................................................................................................................................... 11
1.4.4 Rationale for choice of provisions .................................................................................................................... 13
1.5 Index of Biodiversity Surveys for Assessments ................................................................................. 14
2 Environmental Management Plan Provisions................................................................................................ 15
2.1 Reporting........................................................................................................................................... 24
2.1.1 Trigger and Threshold Exceedance .................................................................................................................. 24
2.1.2 Annual Reviews and Compliance Assessment Reporting ................................................................................. 24
3 Adaptive Management and Review of the EMP............................................................................................ 24
4 Stakeholder Consultation .............................................................................................................................. 26
5 Abbreviations ................................................................................................................................................. 27
6 References ..................................................................................................................................................... 28

TABLES
Table 1 - Summary ...................................................................................................................................................3
Table 2 – Key Environmental Factor........................................................................................................................8
Table 3 – Proposal activities and impacts to Environmental Factors ......................................................................8
Table 4 - Outcome Based Provisions .....................................................................................................................16
Table 5 - Management-based provisions ..............................................................................................................22
Table 6 - Water Management Plan Reporting Table Template – Outcome-based Condition ..............................24
Table 7 – Stakeholder Consultation.......................................................................................................................26
Table 8 – Abbreviations .........................................................................................................................................27
Table 9 – References .............................................................................................................................................28

FIGURES
Figure 1 – Location of the Roy Hill Iron Ore Mine ...................................................................................................5
Figure 2 – Roy Hill Mine Revised Development Envelope and Borefield Locations ................................................6
Figure 3 – Managed Aquifer Recharge Indicative Bore Types and Locations .........................................................7
Figure 4 - Environmental Management System Framework.................................................................................11

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Summary
This Water Management Plan (WMP) has been prepared to outline Roy Hill Iron Ore Pty Ltd’s (RHIO’s)
approach to monitoring and managing Inland Waters at the RHIO Mine as outlined in Table 1.

Table 1 - Summary

Title of proposal Roy Hill Iron Ore Mine

Proponent Roy Hill Iron Ore Pty Ltd

Ministerial Statement numbers To be determined

Purpose of this Condition EMP Outline RHIO’s approach to monitoring and managing groundwater and surface at the Roy Hill
Mine.

Key Environmental Factors and Inland Waters - To maintain the hydrological regimes and quality of groundwater and surface
Objectives water so that environmental values are protected.

Key Provisions of the Plan Outcome-based and Management-base provisions to:

 Minimise potential environmental impacts associated with groundwater abstraction
and reinjection including water levels and groundwater quality
 Minimise potential impacts to riparian vegetation and groundwater dependent
vegetation
 Undertake appropriate monitoring and report sufficiently to demonstrate compliance
with approval requirements and enable appropriate and informed water
management decisions.

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1 Context, Scope and Rational

1.1 The Proposal
Roy Hill Iron Ore Pty Ltd (RHIO), a wholly owned subsidiary of Hancock Prospecting Pty Ltd (HPPL), currently
operates the RHIO Iron Ore Mine (the Mine). The Mine is located 280km south of Port Hedland and 110km
north of Newman in the Pilbara Region of Western Australia (Figure 1). The overall RHIO Project involves the
open cut mining, processing, transport via heavy haul railway and export of bedded Marra Mamba and detrital
iron ore from port facilities in Port Hedland.

The mining activities are undertaken within mining tenements M46/518 and M46/519. RHIO also have
miscellaneous licences for the purposes of remote borefields, access roads, dewatering, re-injection and
groundwater search activities. Following the granting of the required approvals, construction of the mine
commenced in October 2013. Mining began in Delta mine pit in July 2014 and Zulu mine pit in February 2015.

RHIO has submitted a Revised Proposal which incorporates a Life of Mine Water Management strategy (LOM
WMS). The LOM WMS identifies the requirement to:

 increase the volume of groundwater abstracted for dewatering from 396GL total to 626GL total for LOM;
 dispose of surplus water via managed aquifer reinjection (MAR) of up to 508GL for life of mine (LOM) utilising
re-injection bores;
 dispose of surplus TSF decant water, RO reject water and saline water via dust suppression and/or MAR; and
 dispose of surplus TSF decant water, RO reject water and saline water via evaporation ponds.

The Revised Development Envelope of RHIO Mine and indicative borefields relevant to the LOM WMS, as per
the Revised Proposal, are outlined on Figure 2. The current existing infrastructure in the South West Injection
Borefield (SWIB) and Stage 1 Borefield are outlined in Figure 3.

Implementation and operation of the Revised Proposal may have impacts to vegetation health, groundwater
and surface water quality, groundwater and surface flows, subterranean fauna or the Fortescue Marsh Priority
Ecological Community (PEC). This Water Management Plan (WMP) has been prepared to outline RHIO’s
approach to monitoring and managing water at the Mine.

This WMP has been prepared in accordance with the Instructions on how to prepare Environmental Protection
Act 1986 Part IV Environmental Management Plans (2018) developed by the Environmental Protection
Authority (EPA).

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Figure 1 – Location of the Roy Hill Iron Ore Mine

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Figure 2 – Roy Hill Mine Revised Development Envelope and Borefield Locations

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Figure 3 – Managed Aquifer Recharge Indicative Bore Types and Locations

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1.2 Key Environmental Factors

This WMP has been developed to meet the EPA’s key environmental factor objectives as outlined in Table 2.

Table 2 – Key Environmental Factor

Environmental Factor Objective

Inland Waters To maintain the hydrological regimes and quality of groundwater and surface water so that
environmental values are protected.
Flora and Vegetation To protect flora and vegetation so that biological diversity and ecological integrity are maintained.
Subterranean Fauna To protect subterranean fauna so that biological diversity and ecological integrity are maintained.

Table 3 outlines site specific values, proposal activities and the resulting potential impacts of these activities.

Table 3 – Proposal activities and impacts to Environmental Factors

Environmental Factor Site Specific Value Potential Impact Original and Revised Proposal activities
Inland Waters Fortescue Marsh, Fortescue Contamination of  Construction of infrastructure including
River and tributaries Surface Water waste rock landforms, roads, borefields
and pipelines can alter surface water
flows and increase erosion causing
increases in sedimentation and
turbidity.
 Clearing activities and operation of
machinery and vehicles can increase
erosion causing increases in
sedimentation and turbidity
 Use of saline water sources for dust
suppression has potential to alter the
quality of surface water
 Inappropriate waste management or
leaking chemical and hydrocarbon
storage facilities can result in release of
hydrocarbons and chemicals to the
environment and surface water
 Leaching of contaminants from waste
rock landforms can alter quality of
surface water
Changes to surface  Downstream flows and sheet flows can
water flows be altered by:
 surface water diversions
structures
 clearing of land; and
 development of infrastructure.
Subterranean Fauna Stygofauna Changes to  Changes in groundwater quality from
groundwater quality MAR and in-pit tailings storage
outside the range of
tolerance of
stygofauna
Changes to  Reduction in groundwater levels from
groundwater flows and abstraction and dewatering
levels impacting
habitat availability for
stygofauna
Troglofauna Changes to  Mounding of groundwater from MAR
groundwater levels and in-pit tailings storage
impacting habitat
availability for
troglofauna

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Environmental Factor Site Specific Value Potential Impact Original and Revised Proposal activities
Flora and Vegetation Riparian Vegetation and Changes to water  Mounding of groundwater from MAR
Groundwater Dependant available at root depth and in-pit tailings storage
Vegetation (GDV) causing waterlogging  Reduction in groundwater levels from
or reducing available abstraction and dewatering
water.  Surface water diversion structures
altering flow of surface water
Fortescue Marsh Priority Changes to water  Mounding of groundwater from MAR
Ecological Community quality and quantity and in-pit tailings storage altering water
impacting on available at root depth
vegetation and water  Reduction in groundwater levels from
of Fortescue Marsh abstraction and dewatering altering
water available at root depth
 Surface water diversion structures
altering flow of surface water
 Inappropriate waste management or
leaking chemical and hydrocarbon
storage facilities can result in release of
hydrocarbons and chemicals to the
environment and surface water
 Leaching of contaminants from waste
rock landforms can alter quality of
surface water
Terrestrial Fauna Habitats Changes to  Mounding of groundwater from MAR
groundwater and and in-pit tailings storage altering water
surface water quality available at root depth
and quantity impacting  Reduction in groundwater levels from
on fauna habitats abstraction and dewatering altering
water available at root depth
 Surface water diversion structures
altering flow of surface water
 Inappropriate waste management or
leaking chemical and hydrocarbon
storage facilities can result in release of
hydrocarbons and chemicals to the
environment and surface water
 Leaching of contaminants from waste
rock landforms can alter quality of
surface water

1.3 Condition Requirements

The Mine was originally approved under Part IV of the Environmental Protection Act 1986 (EP Act) through
Ministerial Statements 824, 829, 979 and 980 and amended via subsequent s45C and s46 applications (herein
after collectively referred to as the “Original Proposal”). These Ministerial Statements require RHIO to monitor
and report on potential impacts to groundwater and surface water.

RHIO currently has a Revised Proposal being assessed by the EPA under s38 of the EP Act. This WMP addresses
the potential impacts to Inland Waters arising from the Mine as a whole under the Original and Revised
Proposal.

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1.4 Rationale and approach

This WMP addresses the Inland Waters environmental factor and the EPA’s objective to maintain the
hydrological regimes and quality of groundwater and surface water so that environmental values are
protected.

A combination of surveys and study findings, risk assessments, monitoring, and the assessment of assumptions
and uncertainties have contributed to the establishment of this WMP ensuring that the objective of the EPA is
met.

1.4.1 Survey and Study Findings

RHIO have undertaken groundwater monitoring at the Mine since 2007 and surface water monitoring since
2013. Monitoring has consisted of infield measurement and analysis and collection of water samples for
analysis at a National Association of Testing Authorities, Australia (NATA) accredited laboratory in line with the
requirements of:

 Ministerial Statements;
 Operating Licence and Works Approvals;
 Mining Proposals and Tenement conditions; and
 Groundwater Operating Strategies (GWOS) and 5C licences.

An annual groundwater and surface water monitoring assessment report has been submitted to the EPA since
commencement of mining operations in 2015. The assessments have reviewed monitoring data against licence
limits, ANZECC/ARMCANZ trigger values and baseline conditions. Conclusions from these reports have
indicated that there have been no significant impacts to groundwater or surface water from RHIO mining
operations to date.

In 2019 GHD completed an assessment of groundwater change for the RHIO LOM WMS which included
dewatering, disposal of surplus water through MAR The results of this assessment have contributed to the
assessment of potential impacts to inland waters associated with the mine outlined in section 1.2.1.

In 2020, RHIO commissioned Stantec to undertake an assessment of groundwater and surface water
monitoring in the context of RHIO’s operations. The assessment addressed potential impacts from waste rock
landforms (WRLs), tailing storage facilities (TSFs) and landfill and provided recommendations for a monitoring
program including monitoring locations, sampling and an analytics program for the purpose of validating
predictions and monitoring for potential environmental harm where identified in the assessment. The results
of this assessment have contributed to Section 2.1 and have been incorporated in the Mine monitoring
program. It has been determined that there is a slight to minor risk from contamination of surface water
quality from above ground infrastructure (Stantec, 2020). As such, it is considered that surface water quality
sampling is not required.

1.4.2 Key assumptions and uncertainties

The following key assumptions and uncertainties apply in relation to this WMP:

 As the LOM changes, the exact location, extent and duration of groundwater abstraction and reinjection
may change over time.

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 This WMP has been developed based on information incorporated into the LOM WMS (GHD, 2019) and
available at the time of preparation. As requirements change and knowledge increases over time this WMP
may require update.
 Exact monitoring bores locations will change and adapt over time as mining progresses.
 Trigger levels will be refined over time as additional data is collected and collated.
 The exact area and extent of some surface flow modifications and locations of mining infrastructure are still
in the design stage, but the indicative location is known. As the LOM changes, the timing for the installation
of these diversion structures may change over time.
1.4.3 Management approach
1.4.3.1 Environmental Management System

The RHIO Environmental Management System (EMS) Framework provides a framework for achieving the key
environmental management objectives during the operational phases of the Mine. The framework is
illustrated in Figure 4. Implementation of the EMS Framework ensures environmental performance is achieved
through environmental management practices that are consistent with RHIO’s Environmental Policy and
objectives. Management measures and controls are specifically detailed in environmental plans, procedures
and work instructions which are implemented during the Operation phase of the Mine. RHIO’s key
environmental management documents have been developed to address environmental risks posed by mining
and associated activities.

Plan
Environment Policy
Environmental Risk Management
Legal and Other Requirements
Objectives and Targets

Do
Act (Implementation and Operation)
(Management Review) Roles, Resources , Responsibility and Accountability
Annual review of Vegetation Condition EMP Training, Competency and Awareness
Communication
Improvement measures identified during planning, Documentation and Document Control
checking and doing Operational Control
Emergency Preparedness and Response

Check
Monitoring and Measurement
Evaluation of Compliance
Incidents and Action Management
Control of Records

Figure 4 - Environmental Management System Framework

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All activities that could impact on Inland Waters are undertaken in accordance with RHIO procedures to
minimise environmental impact.

1.4.3.2 Available Information

This WMP has been developed using all available and relevant information. RHIO will continue to utilise and
improve on current information to continue to inform best practice management, including:

 Utilisation of results of an annual Groundwater and Surface Water Monitoring Assessment to provide a basis
for regular review of monitoring data;
 Consideration and investigation of use of new technologies and techniques that will inform updates to
monitoring parameters, monitoring sites, and management measures;
 Regular review and update of the monitoring program based on changes to mine planning, reinjection
quantities; diversion designs, timings of construction and operations of these diversion structures,
operations, hydrological and surface water flood models, and groundwater monitoring data;
 Review of management measures to be implemented in the event of trigger criteria being exceeded;
 Measurement and review of effectiveness of implemented response actions; and
 Assessment of other effects or impacts not related to mining activities such as rainfall, fire, climate change,
grazing and historic degradation from previous land use.
1.4.3.3 Monitoring Approach

The purpose of monitoring is to inform, through the environmental criteria, if the environmental outcomes are
being achieved and if required, when trigger level or threshold levels are exceeded, what contingency
management measures need to be implemented. This section describes how RHIO will undertake monitoring
to determine performance against the environmental criteria.

The Mine water monitoring program has been developed to specify locations, timing, parameters, triggers and
thresholds at monitoring sites for both groundwater and surface water monitoring. The program has
considered:

 Existing approvals and compliance requirements (i.e. Operating Licence, Mining Proposal etc)
 Risk Assessments
 Potential impacts and sensitive receptors
 Background water quality and standing water levels (SWL)
 Specific location of monitoring sites

RHIO have developed monitoring procedures and work instructions to ensure that water monitoring is
conducted accurately and in accordance with relevant standards.

RHIO have adopted early response indicators and criteria with multiple performance indicators to track
impacts and guide management measures. These include:

 Applying triggers at specific monitoring sites;

 An immediate retest of any monitoring site whereby a monitoring result has exceeded a trigger. This will be
undertaken to ensure that the result is not due to an anomaly in testing or error;
 If the retest also exceeds the same trigger level, RHIO will:

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o Commence more frequent monitoring of the affected bore (monthly groundwater levels and quarterly
water quality analysis).
o Investigate the potential cause of the trigger level exceedance, and identify and monitor potential
other impacts which may be caused due to the exceedance (i.e. vegetation health).
o Undertake a review of monitoring data and groundwater data from surrounding areas to determine if
the changes are localised to the monitoring location.
1.4.3.4 Risk Assessment

Risk assessments have been undertaken across the mine site to evaluate risk from water management
activities. Risk assessments have been undertaken as components of the following:

 Life of Mine Water Management Strategy – Groundwater Change Assessment (GHD, 2019)
 Management of Saline Water Used for Dust Suppression – Desktop Study and Risk Assessment (Astron,
2015)
 Tailings Storage Facility (TSF) Decant Water Disposal Risk Assessment (GHD, 2019)
 Life of Mine Water Management Strategy Vegetation Risk Assessment (Astron, 2019)
 Roy Hill Mine Water Monitoring Assessment (Stantec, 2020)

Risk assessments have been utilised to inform the trigger levels for monitoring sites and to identify focus areas
for water management to manage, monitor and reduce potential environmental impact.

1.4.4 Rationale for choice of provisions

This WMP has been developed based on the assessment of potential impacts for Inland Waters, and
monitoring requirements of relevant approvals such as the RHIO Operating Licence (L8621/2011/1),
Groundwater Abstraction Licence (GWL172642) and existing Ministerial Statements.

The potential impacts to Inland Waters are:

 Contamination of groundwater resulting from mining and associated activities

 Changes in the quality of groundwater from MAR
 Mounding of groundwater from MAR
 Mounding of groundwater from TSF
 Changes to groundwater flows by abstraction for water supply and mine dewatering.
 Changes to surface water flows from creek diversions, additional clearing or development of infrastructure
 Contamination of groundwater or surface water from leaching of WRL and Tailings Storage Facilities

The outcomes for this WMP are:

 Minimise potential environmental impacts associated with groundwater abstraction and reinjection
including water levels and groundwater quality
 Minimise potential impacts to riparian vegetation and groundwater dependent vegetation
 Undertake appropriate monitoring and report sufficiently to demonstrate compliance with approval
requirements and enable appropriate and informed water management decisions.

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RHIO propose outcome-based and management-based provisions to ensure the outcomes for the WMP and
the EPA’s objective for Inland Water are achieved.

1.4.4.1 Outcomes-based Provisions

Outcome‐based provisions are performance‐based and may be used where the part of the environment is
capable of objective measurement and reporting. The outcomes-based provisions for this WMP are outlined in
Table 4 and have been chosen as they provide a basis for detecting and avoiding or otherwise managing
potential impacts, such that the condition environmental outcomes and objectives can be achieved.

Trigger criteria are set at a conservative level to ensure response actions are implemented in advance of the
environmental objective being compromised. Exceedance of a trigger criterion will, therefore not be treated as
a non-compliance. There is potential for trigger criteria to be exceeded due to natural variability; this must be
accounted for in the management response. Exceedance of a threshold criterion will be treated as a potential
noncompliance against the environmental outcome.

The selected guidelines for triggers and thresholds (referenced in the provisions tables) are based on project
requirements, environmental risk assessments, the findings of annual monitoring assessments and the
monitoring requirements of the RHIO Operating Licence.

These have been chosen as they provide a basis for detecting and avoiding or otherwise managing potential
impacts, such that the condition environmental outcomes and objectives can be achieved.

1.4.4.2 Management-based Provisions

Management‐based provisions relate to management actions and may be used where the part of the
environment is not capable of objective measurement and reporting.

RHIO are proposing management-based provisions (Table 5) for water quality (both surface and groundwater)
and regional groundwater level monitoring on site due to the natural variability of water quality and
groundwater levels both stratigraphically and regionally across the Revised Development Envelope. Objective
measurement of water quality at the Mine and regional groundwater levels through triggers and thresholds
would likely result in false positives and unnecessary restrictions to operations due to natural background
variations.

Through management-based provisions RHIO will monitoring for potential impacts to Inland Waters and
conduct annual assessments of trends to identify change resulting from RHIO operations that could lead to
environmental impact. The results of these assessments will be provided to the EPA in the Annual Compliance
Assessment Report.

Contamination events identified during the year will be reported to relevant regulatory bodies in accordance
with section 72 of the Environmental Protection Act.

1.5 Index of Biodiversity Surveys for Assessments

In the event that RHIO is required to undertake any biodiversity surveys to support this WMP, RHIO will submit
Index of Biodiversity Surveys for Assessments (IBSA) data packages in accordance with Preparation of data
packages for the Index of Biodiversity Surveys for Assessments (IBSA) guidelines.

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2 Environmental Management Plan Provisions

This WMP outlines outcome-based and management-based provisions and minimum key requirements. All
requirements will be undertaken during operations and until the Mine is decommissioned and closed.

The outcome-based provisions are outlined in Table 4. Compliance with outcome-based conditions is
measured by assessment of monitoring results against trigger and threshold criteria. Where outcome-based
conditions are not compliant with trigger or threshold criteria, trigger level management measures and
threshold level management measures will be applied.

The management-based provisions are outlined in Table 5.

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Table 4 - Outcome Based Provisions

Environmental
Inland waters
Factor
Objective To maintain the hydrological regimes and quality of groundwater and surface water so that environmental values are protected.
- Groundwater Dependent and Non-dependant Vegetation
Key
- Riparian and Groundwater Dependent Vegetation
Environmental
- Fortescue Marsh Priority Ecological Community
Values
- Troglofauna and Stygofauna

Key Impacts and Risks Environmental Criteria Response Actions Monitoring

Trigger Response
Mine Bulk Fuel Storage Area and An immediate retest of the bore will be undertaken Groundwater quality analysis for parameters required in
Landfill to ensure that the result is not due to an anomaly the Operating Licence L8621/2011/1.
Trigger Criteria in testing or error.
Total Recoverable Hydrocarbon (TRH) Groundwater sampling, infield analysis and NATA
results above the detectable limit Undertake a review of all Mine Bulk Fuel and accredited analysis.
from the Mine Bulk Fuel or landfill Landfill monitoring data and groundwater data
groundwater monitoring sites. from surrounding areas to determine if the changes Sampling to be undertaken on a quarterly basis.
are localised to the area.
Contamination of
groundwater resulting
from mining and
Mine Bulk Fuel Storage Area and
associated activities
Landfill
Threshold Criteria Threshold Response
TRH results above the detectable limit If the review determines that the changes in
over monitoring event and groundwater quality are related to the operation of As above for trigger level monitoring.
subsequent retest. the Mine Bulk Fuel Storage Area or Landfill, RHIO
AND will undertake an impact assessment and identify Monitoring of the effectiveness of contingency actions.
Subsequent investigations determine appropriate management responses for
that impacts are resulting from implementation.
leaching of the Mine Bulk Fuel Facility
or landfill.

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Key Impacts and Risks Environmental Criteria Response Actions Monitoring

SWIB – MAR Water Quality Trigger Response Monitoring is undertaken through EC meters fitting to
Trigger Criteria Undertake a review of MAR monitoring data to injection bores.
Monthly flow weighted average of determine if threshold criteria may be exceeded
total injected water in the borefield and enact management measures to ensure A confirmation sample for TDS will be collected from each
with water quality of Total Dissolved reinjection water quality remains under threshold injection bore quarterly and sent to a NATA accredited
Solids (TDS) is above 45,000 mg/L. criteria. laboratory.

SWIB – MAR Water Quality

Threshold Criteria
Monthly flow weighted average of
total injected water in the borefield Threshold Response
with water quality of TDS is above If the review determines that the changes in the
As above for trigger level monitoring.
50,000 mg/L. groundwater quality are related to the operation of
AND the MAR, RHIO will undertake an impact
Monitoring of the effectiveness of contingency actions.
Subsequent investigations determine assessment and identify appropriate management
that the receiving aquifer will be responses for implementation.
impacted above what the
Changes in the quality groundwater change assessment has
of groundwater from forecast.
MAR
Stage 1 – MAR Water Quality Trigger Response Monitoring is undertaken through EC meters fitting to
Trigger Criteria Undertake a review of MAR monitoring data to injection bores.
Monthly flow weighted average of determine if threshold criteria may be exceeded
total injected water in the borefield and enact management measures to ensure A confirmation sample for TDS will be collected from each
with water quality of TDS is above reinjection water quality remains under threshold injection bore quarterly and sent to a NATA accredited
4,500 mg/L. criteria. laboratory.
Stage 1 – MAR Water Quality
Threshold Criteria
Monthly flow weighted average of
total injected water in the borefield Threshold Response
with water quality of TDS is above If the review determines that the changes in the
As above for trigger level monitoring.
5,000 mg/L. groundwater quality are related to the operation of
AND the MAR, RHIO will undertake an impact
Monitoring of the effectiveness of contingency actions.
Subsequent investigations determine assessment and identify appropriate management
that the receiving aquifer will be responses for implementation.
impacted above what the
groundwater change assessment has
forecast.

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Key Impacts and Risks Environmental Criteria Response Actions Monitoring

Remote MAR – Water Quality Trigger Response Monitoring is undertaken through EC meters fitting to
Trigger Criteria Undertake a review of MAR monitoring data to injection bores.
Monthly flow weighted average of determine if threshold criteria may be exceeded
total injected water in the borefield and enact management measures to ensure A confirmation sample for TDS will be collected from each
exceeds the background TDS mg/L reinjection water quality remains under threshold injection bore quarterly and sent to a NATA accredited
+10%. criteria. laboratory.

Remote MAR – Water Quality Threshold Response

Threshold Criteria If the review determines that the changes in the
As above for trigger level monitoring.
Monthly flow weighted average of groundwater quality are related to the operation of
total injected water exceeds the the MAR, RHIO will undertake an impact
Monitoring of the effectiveness of contingency actions.
background TDS mg/L +15%. assessment and identify appropriate management
responses for implementation.

Southern Borefields – MAR

Trigger Response Monitoring is undertaken through EC meters fitting to
Water Quality
Undertake a review of MAR monitoring data to injection bores.
Trigger Criteria
determine if threshold criteria may be exceeded
Monthly flow weighted average of
and enact management measures to ensure A confirmation sample for TDS will be collected from each
total injected water in the borefield
reinjection water quality remains under threshold injection bore quarterly and sent to a NATA accredited
with water quality of TDS is above
criteria. laboratory.
4,500 mg/L.

Southern Borefields – MAR

Threshold Response
Threshold Criteria
If the review determines that the changes in the
Monthly flow weighted average of As above for trigger level monitoring.
groundwater quality are related to the operation of
total injected water with water quality
the MAR, RHIO will undertake an impact
in the borefield of TDS is above 5,000 Monitoring of the effectiveness of contingency actions.
assessment and identify appropriate management
mg/L.
responses for implementation.
Mine area – Water Quality Trigger Response Monitoring is undertaken through EC meters fitting to MAR
Trigger Criteria Undertake a review of MAR monitoring data to outlets.
Monthly flow weighted average of determine if threshold criteria may be exceeded
total MAR water exceeds the and enact management measures to ensure A confirmation sample for TDS will be collected from each
background TDS mg/L +10%. reinjection water quality remains under threshold MAR outlet quarterly and sent to a NATA accredited
criteria. laboratory.

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Key Impacts and Risks Environmental Criteria Response Actions Monitoring

Mine Area – Water Quality Threshold Response

Threshold Criteria If the review determines that the changes in the
As above for trigger level monitoring.
Monthly flow weighted average of groundwater quality are related to the operation of
total MAR water exceeds the the MAR, RHIO will undertake an impact
Monitoring of the effectiveness of contingency actions.
background TDS mg/L +15%. assessment and identify appropriate management
responses for implementation.

Trigger Response
An immediate retest of the bore will be undertaken
to ensure that the result is not due to an anomaly
Depth to Groundwater:
in testing or error. More frequent SWL monitoring
Trigger Criteria
will be undertaken (monthly). SWL monitoring in MAR monitor bores. Monitoring to be
Depth to groundwater level in MAR
If the retest also exceeds the same trigger level, undertaken on a quarterly basis.
injection control is less than 6 meters
RHIO will:
below surface.
Implement management measures to ensure water
Mounding of levels does not rise to threshold level
groundwater from
MAR

Depth to Groundwater: Threshold Response

Threshold Criteria MAR: implement management measures to ensure
Depth to groundwater level in MAR groundwater mounding is reduced below
As above for trigger level monitoring.
injection control bores is less than 5 threshold.
meters below surface.
Monitoring of the effectiveness of contingency actions.
AND RHIO will undertake an impact assessment and
Subsequent investigations determine identify appropriate management responses for
that impacts are resulting from MAR. implementation.

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Key Impacts and Risks Environmental Criteria Response Actions Monitoring

Trigger Response
Review the extent of erosion/deposition of the
Water Diversion Structures
diversion structure and assess the risk to Annual (post-wet season) geomorphic survey of permanent
Trigger Criteria
environment. diversion structures.
Geomorphic survey identifies +/-1m
of change in permanent surface water
Undertake appropriate actions to ensure stability
diversion structures.
of diversion structure and to mitigate any potential
risk to environment.

Changes to surface
water flows from
creek diversions,
additional clearing or
development of
infrastructure
Water Diversion Structures Threshold Response
Threshold Criteria Undertake an investigation to assess the impact (if
Geomorphic surveys identify a breach any) to the environment. If impact to environment As above for trigger level monitoring.
(water is flowing outside of its is determined, report externally.
intended course) of surface water Monitoring of the effectiveness of contingency actions.
diversion structure that has then led Redesign and reconstruct the surface water
to environmental impacts. diversion with findings from investigation.

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Key Impacts and Risks Environmental Criteria Response Actions Monitoring

Groundwater Abstraction
Abstraction bore flow meters connected to supervisory
Trigger Criteria Trigger Response
control and data acquisition (SCADA) system.
Water abstraction for water supply Review groundwater abstraction requirements and
and mine dewatering exceeds 65GL whether an amend to the Groundwater Licence
Short Term Water Management Plan (monthly) monitoring
(only 5GL remaining in Annual Water may be required to remain compliant.
abstraction against GWL limits
Changes to Entitlement).
groundwater flows by
abstraction for water
supply and mine
dewatering.
Groundwater Abstraction Threshold Response
Threshold Criteria Confirm exceedance by reviewing all water
As above for trigger level monitoring.
Water abstraction for water supply abstraction data.
and mine dewatering exceeds the
Monitoring of the effectiveness of contingency actions.
GWL172642 abstraction limit of 70GL Notify DWER of the exceedance in accordance with
DWER regulations

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Table 5 - Management-based provisions

Environmental
Factor Inland waters
Objective To maintain the hydrological regimes and quality of groundwater and surface water so that environmental values are protected.

Key Impacts and Risks Management Actions Management Targets Monitoring

1. Undertake water monitoring at locations If the assessment of water quality data identifies Groundwater quality sampling infield analysis and NATA
around the site to identify water quality abnormal trends (outside of seasonal fluctuations or accredited analysis.
Contamination of change resulting from mining and forecast water quality change) conduct an investigation
groundwater associated activities. to identify the source of the contamination. Opportunistic surface water monitoring to be undertaken
resulting from mining post rain-fall (sufficient to cause a flow event) infield
and associated 2. Review the water monitoring data If the source of the contamination is resulting from analysis and NATA accredited analysis.
activities annually to identify trends in water RHIO operations engage a suitably qualified specialist
quality outside of seasonal fluctuations. to determine the risk to the environment and outline
mitigation measures to prevent significant impacts.

1. Undertake water monitoring at locations If the assessment of water quality data identifies WRL - Six monthly groundwater quality sampling infield
around the site with potential to identify abnormal trends (outside of seasonal fluctuations or analysis and NATA accredited analysis.
Contamination of water quality change resulting from forecast water quality change) conduct an investigation
groundwater from leaching of WRL and TSF. to identify the source of the contamination. TSF - Quarterly groundwater quality sampling infield
leaching of WRL and analysis and NATA accredited analysis.
Tailings Storage 2. Review the water monitoring data If the source of the contamination is resulting from
Facilities annually to identify trends in water RHIO operations engage a suitably qualified specialist Opportunistic surface water monitoring to be undertaken
quality outside of seasonal fluctuations. to determine the risk to the environment and outline post rain-fall (sufficient to cause a flow event) infield
mitigation measures to prevent significant impacts. analysis and NATA accredited analysis.

1. Undertake water monitoring in MAR If the assessment of water quality data identifies Quarterly groundwater quality sampling infield analysis
monitor bores with potential to identify abnormal trends (outside of seasonal fluctuations or and NATA accredited analysis.
water quality change resulting from forecast water quality change) conduct an investigation
Changes in the MAR. to identify the source of the contamination.
quality of
groundwater from 2. Review the water monitoring data If the source of the contamination (exceeding predicted
MAR annually to identify trends in water change) is resulting from RHIO operations engage a
quality outside of seasonal fluctuations. suitably qualified specialist to determine the risk to the
environment and outline mitigation measures to
prevent significant impacts.

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Key Impacts and Risks Management Actions Management Targets Monitoring

1. Undertake water monitoring in MAR If the assessment of water monitoring data identifies Quarterly groundwater quality sampling infield analysis
monitor bores with potential to identify abnormal trends (outside of seasonal fluctuations or and NATA accredited analysis.
mounding resulting from MAR. forecast water level change) conduct an investigation
Mounding of to identify the source.
groundwater from 2. Review the water monitoring data
MAR annually to identify trends in water If the source of the mounding is resulting from RHIO
quality outside of seasonal fluctuations. operations engage a suitably qualified specialist to
determine the risk to the environment and outline
mitigation measures to prevent significant impacts.

1. Undertake water monitoring in TSF If the assessment of water monitoring data identifies SWL monitoring. Monitoring to be undertaken on a
monitor bores with potential to identify abnormal trends (outside of seasonal fluctuations or quarterly basis.
mounding resulting from Tailings forecast water level change) conduct an investigation
deposition. to identify the source.
Mounding of
groundwater from 2. Review the water monitoring data If the source of the mounding is resulting from RHIO
TSF annually to identify trends in water operations engage a suitably qualified specialist to
quality outside of seasonal fluctuations. determine the risk to the environment and outline
mitigation measures to prevent significant impacts.

1. Design surface water infrastructure such Surface water diversion structures return diverted Monitor the construction of surface water diversion
Changes to surface that where possible diverted water will water to the same water catchment it originated from. structures compliance against design.
water flows resulting be returned to the same water In cases where this is not possible address a design for
from creek catchment. environmental flows down stream. Conduct flood risk modelling to predict flood risk areas.
diversions, additional Review mine plan design and changes against flood model.
clearing or 2. Conduct inspections of surface water Integrity of the surface water diversion structures is Conduct a risk based approach in design including duration
development of diversion structures. maintained. of open pit, longevity of Hydraulic Structure and review
infrastructure design principals on the as built information.

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2.1 Reporting
2.1.1 Trigger and Threshold Exceedance

All environmental criteria trigger, and threshold exceedances will be reported in the RHIO internal incident
management system. Any documentation and actions resulting from the exceedance investigation will be
captured in the event for future reporting purposes.

In the event of a threshold criteria exceedance RHIO will notify DWER within 7 days of the non-compliance
being known and provide a report within 21 days of the non-compliance being known.

2.1.2 Annual Reviews and Compliance Assessment Reporting

The environmental outcome will be reported against each trigger criteria for each calendar year in an Annual
Water Review Report and provided to the EPA in the Compliance Assessment Report (CAR). If the trigger
criterion was exceeded during the reporting period, the Annual Water Review Report will discuss potential
reasons for exceedance of the trigger criterion and include a description of the effectiveness of trigger level
actions. If the threshold criterion was exceeded during the reporting period, the Annual Water Review Report
will include a description of the effectiveness of threshold contingency action/s that have been implemented
to manage the potential impact.

Table 6 outlines the format to be used in the Annual Water Review Report to outline the compliance status of
RHIO against the Condition EMP requirements.

Table 6 - Water Management Plan Reporting Table Template – Outcome-based Condition

Condition environmental outcome and threshold and Reporting on the environmental outcome, Status1
trigger criteria set in the Water Management Management threshold and trigger criteria for [January
Plan 20xx] to [December 20yy]
Trigger criteria: Trigger criteria: YES or
NO
Geomorphic survey identifies +/-1m of change in 1: Example: Trigger not exceeded.
permanent surface water diversion structures.
Threshold criteria: Threshold criteria: YES or
NO
Geomorphic surveys identify a breach of surface water 1: Example: Threshold not exceeded
diversion structure that has then led to environmental
impacts.
1: The status of achievement of environmental outcome is indicated by the following symbols:
Environmental outcome achieved
Environmental outcome not achieved

3 Adaptive Management and Review of the EMP

RHIO will employ adaptive management through the LOM to incorporate knowledge from the implementation
of mitigation measures, monitoring and evaluation of data against trigger and threshold criteria, to more
effectively meet the condition environmental outcomes outlined in this WMP. The following approach will be
followed:

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 Monitoring data will be systematically evaluated and compared to baseline data and predictions on an
annual basis to verify whether groundwater and surface water responses to operational activities are the
same or similar to predictions;
 Re-evaluate the risk assessments annually after monitoring is completed;
 Incorporate additional knowledge as it comes to hand to address assumptions and uncertainties to gain
increased understanding of vegetation and aquifer response;
 Review mine planning program, Groundwater Operating Strategy, and input changes into risk assessments
to refine or modify the monitoring program;
 Undertake revision when Management Plan Provisions are not as effective as predicted, or trigger levels do
not have the outcome anticipated or required;
 Incorporate alternative techniques, technologies and methodologies to enhance and improve the program;
 Develop other monitoring programs as required to respond to additional operational activities ; and
 Incorporate and modify the program to include any external changes during the life of the proposal (e.g.
changes to the sensitivity of the vegetation, climate change, implementation of other activities in the area,
etc.).

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4 Stakeholder Consultation
RHIO has actively consulted with stakeholders on a range of environmental matters since the Project
commenced. Stakeholder consultation in relation to this WMP is outlined in Table 7.

Table 7 – Stakeholder Consultation

Stakeholder Date Outcome

OEPA 29/06/2017 Meeting to discuss s38 revised proposal and in-pit tailings and s45C for the
Long-Term Water Strategy
OEPA 02/02/2018 MAR Strategy meeting
OEPA 16/04/2018 Section 45C MAR application - additional information response
OEPA 23/10/2018 Site visit to the Mine to view existing reinjection bores in Stage 1 borefield.
Overview of SCADA system, View Zulu 5 pit, explanation of SWIB MAR, view of
SWIB monitoring bores on L41/141
OEPA 22/11/2018 Meeting to discuss Zulu 5 in-pit tailings detailed design
OEPA 27/11/2018 Meeting to discuss EPBD referral, s45C in-pit tailings, s38 Revised Propsoal
OEPA 22/06/2019 Meeting to discuss S38 revised proposal to cover MAR
OEPA 05/02/2020 RHIO Technical Water Presentation with DWER (Water and EPA Services) on 5
February 2020 for Roy Hill Revised Proposal
OEPA 08/02/2020 Pre-referral presentation provided to EPA and update of status for s45C for in-
pit tailings disposal

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5 Abbreviations
Abbreviation Definition
BACI Before-after-control-impact
DMSI Digital Multi-Spectral Imagery
EC Electrical Conductivity
EIA Environmental Impact Assessment
EMP Environmental Management Plan
EMS Environmental Management System
EP Act Environmental Protection Act 1986
EPA Environmental Protection Authority
GD Groundwater drawdown
GDV Groundwater dependent vegetation
IBSA Index of Biodiversity Surveys for Assessments
LOM Life of Mine
MS Ministerial Statement
OEPA Office of the Environmental Protection Authority
RHIO Roy Hill Iron Ore Pty Ltd
SFDV Surface flow dependent vegetation
TDS Total Dissolved Solids
TSF Tailings Storage Facility
WMP Water Management Plan
WMS Water Management Strategy
Table 8 – Abbreviations

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6 References
Author Title
Alluvium, 2014 Criteria for functioning river landscape units in mining and post mining
landscapes. Australian Coal Association Research Project (ACARP) Report
C200017
ANZECC/ARMCANZ, 2000 National Water Quality Management Strategy
Astron, 2015 Management of Saline Water Used for Dust Suppression
Desktop Study and Risk Assessment
Astron, 2018 Life of Mine Water Management Strategy Vegetation Risk Assessment
Department of Water and Environmental GWL172642 – Licence to Take Water
Regulation

Environmental Protection Authority (EPA) 2018 Instructions on how to prepare Environmental Protection Act 1986 Part IV
Environmental Management Plans.
http://epa.wa.gov.au/forms-templates/instructions-part-iv-environmental-
management-plans
GHD, 2018 Roy Hill Holdings Pty Ltd Roy Hill Life of Mine Water Management Strategy
– Groundwater Impact Assessment

GHD, 2018a Section 38 Referral, Hydraulic structures, Unpublished report prepared for
Roy Hill Iron Ore, August 2018

GHD, 2019 Roy Hill Iron Ore TSF Decant Water Disposal Risk Assessment
Managed Recharge, 2018 Roy Hill Remote MAR Project – Phase 1, Unpublished report prepared for
Roy Hill Iron Ore, May 2018

SMEC, 2009 Roy Hill 1 Iron Ore Mining Project, Acid Mine Drainage Investigation. Report
for Roy Hill Iron Ore Pty Ltd, 2009

SRK, 2017 Roy Hill- Geochemical Characterisation of Iron Ore Tailings

Stantec, 2020 Roy Hill Mine Water Monitoring Assessment
Table 9 – References

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