BHP Billiton PowerPoint Template and Style Guide

Environmental protection and non-

human biota: emerging regulatory

implications David Kruss

Advisor Environment, Uranium Projects

16 August 2012

Includes contribution from Jim Hondros

Disclaimer

Reliance on Third Party Information

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have not been independently verified. No representation or warranty is made as to the accuracy,

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recommendation or forecast by BHP Billiton.

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Overview

Regulatory Framework

Expansion approval conditions

Monitoring program review

Airborne emissions program

Environmental radiation

Setting the reference levels

Monitoring program in depth

David Kruss, Advisor Environment, Uranium Projects, 16 August 2012 Slide 3

Unique regulatory framework

Roxby Downs (Indenture Ratification) Act 1982 requires;

compliance with codes or recommendations from;

– ARPANSA* (e.g. RPS9 - Code of Practice and Safety Guide for Radiation Protection and Radioactive Waste Management in

Mining and Mineral Processing 2005)

– ICRP

– IAEA

Use best endeavours to keep radiation exposure to workers and public at levels consistent with ICRP103

A 3 year Environmental Protection and Management Program (EPMP)

The EPMP incorporates the requirements of a radioactive waste management plan (RWMP) from ARPANSA RPS9

ISO14001:2004 certified and made available to public

Monitoring programs related to environmental radiation

Airborne emissions

Waste


*ARPANSA - Australian Radiation Protection and Nuclear Safety Agency


Olympic Dam Expansion

David Kruss, Advisor Environment, Uranium Projects, 16 August 2012

In October 2011 BHP Billition received approval from State and Federal Governments for a major

expansion;

Development of an open pit mine capable of delivering 40 million tonnes/year ore

Construction of new process plant to produce 750,000 tonnes copper/year and 14,000 tonnes uranium

Will take over 5 years to reach ore

Slide 5

Expansion approval conditions

Draft and Supplementary EIS written 2007-2011 and consideration of NHB was quite new – no

Australian regulatory codes or safety guide

NHB assessment performed for Supplementary EIS

No commitments from the company relating to NHB in EIS

Both State and Federal approved expansion and included specific conditions relating to

Airborne emissions (dusts, gases and radon)

Non human biota (including reference levels and leading indicators for NHB)

Radioactive waste rock and tailings

Licensing

No changes to licence to mine radioactive material until pit has substantially progressed

Amendments to some non radiation environment licences


Airborne emissions monitoring

Existing program

Isokinetic stack sampling of process plant stacks

Fugitive emission monitoring using deposition monitors (data feeds to NHB)

High volume air sampling and radon decay product sampling at critical populations to assess doses to

public

Changes for expansion approval conditions

Deployment of real time dust monitors at critical populations and north and west of mine lease

Monitoring PM10, PM2.5, meteorology and radon/radon decay products

TSP using high volume air samplers

– Using wind activation to differentiate between mine and background sectors

Sampling according to relevant Australian Standards

Additional fugitive emission sample points once pre-mining underway


Air quality monitoring system (AQMS)

Roxby Downs Olympic Dam

Hiltaba Village

Wind activated high

volume sampler

Radon/Radon decay

product monitor

Data captured via SRA

EnviroSys


AQMS challenges

Real time dust

Only TEOM and BAM1020 certified to Australian & US EPA standards

These instruments are high power users and may require air conditioning

EBAM works similar to BAM1020 however not certified Australian & US EPA standards

EBAM easily powered off solar

2 year side by side performance trial of all 3 instruments showed EBAM consistent with TEOM

and BAM1020

Received approval to use EBAM

EBAM site TEOM site



New monitoring program to address new approval conditions and centralise radiation

monitoring obligations

Cross reference index to RPS9 RWMP requirements

New items

Radionuclide analysis of soils at dust deposition sites

Tri-annual radionuclide analysis of flora and fauna

Annual ERICA assessments

Addition of radon monitoring (previously only measured radon decay products)


Non human biota approval conditions

State

“Radiation doses to non-human biota arising

from the expanded Olympic Dam operations

and radioactive waste management area are

as low as reasonably achievable”.

“The proponent must set a reference level for

impacts on non-human biota (interim criteria

for non-human biota may be set until such

time as an agreed national approach is

determined)”.

Federal

“Target Criteria must reflect a level of impact that is as low as reasonably achievable for radiation exposure to humans, and must be minimised to the lowest reasonable levels for Non-human Biota.”

“..... must include Target Criteria for radiation exposure in the form of a radiation Dose Constraint for Members of the Public and a Reference Level for impacts on Non-human Biota. “

“The program required under condition 4 must demonstrate that the Approval Holder uses Best Practicable Technology to ensure exposure of the public to radioactive releases is as low as reasonably achievable and exposure of Non-human Biota is also minimised to the lowest reasonable levels”

“Target Criteria are measurable standards or specification of parameters that reflect a level of impact that is as low as reasonably achievable or minimised to the lowest reasonable levels for non-human biota. Practices must be reviewed if criteria are exceeded.”


Setting the reference level / target criteria

EPMP Heading Aim NHB Specific

Environmental Outcome The overall desired

outcome

No significant adverse

radiological impacts to

reference plants and

animals from ODC’s

activities

Compliance Criteria The level at which the

regulator can take action

(or the Minister instigate

action)

Deposition of project

originated 238U less than 25

Bq/m2/y at the non-human

biota assessment sites

Leading Indicator The level that indicates that

the company are on a path

to exceeding the

compliance criteria

Indications that a reference

level of 10 µGy/h for

impacts on NHB above

natural background will be

exceeded


Setting the reference level / target criteria

Reference level is not an indicator of compliance rather than a level which may require action

Adopted a reference level of 10 uGy/h (ERICA default)

Exceeding the reference level of 10 uGy/h triggers the need to further investigate emissions and perform ERICA assessment at Tiers 2 and 3.

Calculated annual deposition rate required to remain below the reference level to be 6 Bq/m2/y U238 (in secular equilibrium).

Compliance criteria 25 Bq/m2/y (2 g/m2/m) at critical locations (eg Roxby Downs)

Criteria will be reviewed once local regulations introduce NHB

1 g dust ≈ 1 Bq/g U238


NHB monitoring

Existing passive dust deposition monitoring

sufficient for regular ERICA assessments

Additional monitoring points to be added once

pre-mining begins

Leading indicator will be 2 g/m2/m. If samples

return above then we have the option of

radionuclide analysis

Tri-annual soil, flora and fauna monitoring used

to derive site specific concentration ratios


Complications

Bulk of fugitive emissions are from mine and rock storage facility – uranium series in secular

equilibrium

Can also have non equilibrium emissions from process plant namely;

Uranium oxide calciner scrubber stacks (U238, U234)

Smelter stacks (Pb210, Po210)

Tailings dams ( U238 1/7th of ore activity, Th230 onwards same as ore)

Smelter contribution difficult to resolve due to background Pb210

Historic monitoring shows minimal smelter contribution outside mine lease


Summary

One of the first operations to receive specific NHB conditions.

Able to incorporate additional NHB obligations into existing program with minimal additional

monitoring

Modelling shows that we should remain compliant under worse case scenario

Well positioned to adopt any new codes/recommendations.


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