Mining Management Plan - Prodigy Gold · Project Description ... DESIGN AND CONSTRUCTION METHOD. ... Table 8-3: Security Estimation for Upgraded Twin Bonanza Gold Mine Project 01/09/17

Care and MaintenanceOperation

Mining Management PlanAuthorisation No: 0909 01

ML29822 and EL28322

Twin Bonanza Gold Project

November 2018

Distribution: DPIRCentral Land Council

Prodigy Gold NL – Twin Bonanza Project AN0909-01 November 2018

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Please Note:

Effective 21 May 2018, ABM Resources NL (ASX: ABU) changed its name to Prodigy Gold NL (ASX: PRX). The name changed occurred towards the end of the Reporting year and both names are used interchangeably in this document revision.

Prepared by: Colin Woolard, Woolard Consulting Pty Ltd

Signature:

Approved by: Matt Briggs

Position: Managing Director

Date: 6 December 2018

Revision No. Description of Revision

Date Comment

1.0 New Authorisation 0909-01

First Issue

01/09/2017 Site on C & M

1.1 MMP Update 30/11/2018 Site on C & M


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CONTENTSINTRODUCTION .............................................................................. 12

Operator Details .............................................................................................. 12

ORGANISATIONAL STRUCTURE AND RESPONSIBILITY ................................... 13

Title Details ..................................................................................................... 14

Project Description .......................................................................................... 16

LOCATION ............................................................................................................... 16

PROJECT SUMMARY AND IMPROVEMENTS ....................................................... 16

CURRENT SITE CONDITIONS ....................................................... 24Physical Environment...................................................................................... 24

CLIMATE.................................................................................................................. 24

LAND SYSTEMS ..................................................................................................... 26

2.1.2.1 Topsoil and Subsoil ............................................................................. 26

2.1.2.2 Topography and Geology .................................................................... 26

2.1.2.3 Geology ............................................................................................... 27

2.1.2.4 Groundwater and Surface Water ......................................................... 27

2.1.2.5 Vegetation ........................................................................................... 31

FLORA AND FAUNA ............................................................................................... 31

2.1.3.1 Flora .................................................................................................... 31

2.1.3.2 Fauna .................................................................................................. 36

Socio-Economic Environment ......................................................................... 41

CURRENT LAND USE ............................................................................................. 41

IDENTIFIED STAKEHOLDERS ............................................................................... 41

WORKFORCE DESCRIPTION AND DEMOGRAPHY ............................................. 43

COMMUNITY AFFAIRS ........................................................................................... 43

STATUTORY AND NON-STATUTORY REQUIREMENTS ............ 45Statutory Requirements .................................................................................. 45

Non-Statutory Obligations ............................................................................... 46

Sacred, Archaeological and Heritage Sites ..................................................... 46

SACRED SITES ....................................................................................................... 46

HERITAGE AND ARCHAEOLOGICAL SITES ......................................................... 46

OPERATIONAL ACTIVITIES .......................................................... 48Mining Activities and Mine Design .................................................................. 48


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WASTE ROCK DUMP (WRD) .................................................................................. 52

MINING RESERVES AND GEOLOGY .................................................................... 60

MINING PERFORMANCE AGAINST PREVIOUS MMP .......................................... 60

Processing Activities ....................................................................................... 70

RAW WATER DAM .................................................................................................. 70

DESIGN AND CONSTRUCTION METHOD. ............................................................ 71

4.2.2.1 Source of Construction Materials ......................................................... 72

4.2.2.2 Estimated Flood Heights...................................................................... 72

4.2.2.3 Erosion Protection ............................................................................... 72

4.2.2.4 Spillway design and construction. ........................................................ 73

4.2.2.5 Sub Drainage and Collection Sumps. .................................................. 73

4.2.2.6 Residue Quantities Generated. ........................................................... 73

4.2.2.7 Character of Contained Water. ............................................................ 73

Exploration Activities ....................................................................................... 73

PROPOSED EXPLORATION ACTIVITIES FOR 2018/19 ....................................... 74

ENVIRONMENTAL MANAGEMENT ............................................... 75Environmental Management Structure ............................................................ 75

Environmental Policy....................................................................................... 75

Environmental Commitments .......................................................................... 77

COMMITMENTS CONTAINED IN THE 2017 MMP ................................................. 77

COMPLIANCE WITH PREVIOUS COMMITMENTS (AUTHORISATION 730-01 AND 0909-01) ....................................................................................... 77

5.3.2.1 Environmental Inspections ................................................................... 77

RECOMMENDATIONS RESULTING FROM FORMAL ENVIRONMENTAL ASSESSMENT ................................................................................................. 79

Environmental Training and Education ........................................................... 79

Environmental Emergency Preparedness and Response ............................... 80

Implementation, Monitoring and Review ......................................................... 80

IDENTIFICATION OF ENVIRONMENTAL ASPECTS AND IMPACTS .................... 80

RISK ASSESSMENT ............................................................................................... 83

RISK MANAGEMENT PROCESS ............................................................................ 83

RISK METHODOLOGY ........................................................................................... 84

EXISTING OPERATIONS ........................................................................................ 87

RISK ASSESSMENT OF OPERATIONS ................................................................. 87

ENVIRONMENTAL MANAGEMENT PLANS (EMP) ................................................ 87


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5.6.7.1 Structure of EMP ................................................................................. 88

5.6.7.2 Objectives and Targets ........................................................................ 89

5.6.7.3. Management and Mitigation Strategies ............................................... 90

5.6.7.4 Monitoring and Measurement .............................................................. 90

5.6.7.5 Specific EMPs ..................................................................................... 90

5.6.7.6 Review Effectiveness of Management and Mitigation Strategies ...... 115

5.6.7.7 Non-Conformance and Corrective Action .......................................... 126

Key Environmental Activities for the Oncoming Period ................................. 127

WATER MANAGEMENT PLAN .................................................... 128Current Conditions ........................................................................................ 128

SURFACE WATER ................................................................................................ 128

GROUNDWATER .................................................................................................. 131

Information/Knowledge Gaps ........................................................................ 135

IDENTIFICATION OF INFORMATION/KNOWLEDGE GAPS ................................ 135

WATER ACCOUNT ............................................................................................... 135

6.2.2.1 Water Account for the Previous Period .............................................. 135

6.2.2.2 Water Account for the Upcoming Period ........................................... 136

6.2.2.3 Water Account for a 1:100 Yr Peak Rainfall Scenario ....................... 136

Risk Management ......................................................................................... 137

IDENTIFY HAZARDS AND RANK RISKS ............................................................. 137

ACTIONS AND STRATEGIES IN RESPONSE TO IDENTIFIED RISKS ............... 138

6.3.2.1 Surface water .................................................................................... 138

6.3.2.2 Groundwater ...................................................................................... 139

Monitoring ..................................................................................................... 139

MONITORING PROGRAM .................................................................................... 139

DATA REVIEW & INTERPRETATION. .................................................................. 140

6.4.2.1 Raw Water Dam - pH and Alkalinity .................................................. 140

6.4.2.2 Raw Water Dam TDS & Electrical conductivity (EC) ......................... 140

6.4.2.3 Raw Water Dam Major Anions - Sulfate (SO4), Chloride (Cl) and Fluoride (F) 140

6.4.2.4 Raw Water Dam Major Cations – Ca, Mg, Na and K ......................... 140

6.4.2.5 Raw Water Dam BTEX (N), Total Petroleum Hydrocarbons (TPH) and TRH 140

6.4.2.6 Raw Water Dam Water Dissolved Metals .......................................... 140

6.4.2.7 Conclusion ......................................................................................... 141


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6.4.2.8 Strezza’s/Timmy’s Groundwater Production Bore and Monitoring Bores BF01 – BF04 (Palaeochannel Aquifer) ....................................................................... 141

6.4.2.9 Corsair Groundwater Production Bore and Surrogate Bore M11 ....... 141

6.4.2.10 Wilson’s Groundwater Production Bore and Surrogate Bore M10A .. 142

6.4.2.11 Groundwater Monitoring Bores M01, M09 and A01-A03 ................... 142

6.4.2.12 Groundwater Extraction from Wilson’s, Corsair and Strezza’s/Timmy’s 142

6.4.2.13 Proposed Changes to the Groundwater Monitoring Program ............ 144

Management ................................................................................................. 146

REMEDIAL OR CORRECTIVE MANAGEMENT ACTIONS................................... 146

INCIDENT REPORTING ................................................................ 147

CLOSURE PLANNING .................................................................. 149Rehabilitation and Closure Activities ............................................................. 151

RAW WATER STORAGE DAM ............................................................................. 152

TRIAL PROCESSING AREA ................................................................................. 152

HAUL AND ACCESS ROADS ................................................................................ 152

BORES AND PIPELINES ...................................................................................... 152

EXPLORATION AREAS (I.E. DRILLING AND EXPLORATION TRENCHING) ................................................................................................. 153

ROM PAD AREAS AND LOW GRADE STOCKPILES .......................................... 153

PISOLITE AND SANDSTONE STOCKPILES ........................................................ 153

WASTE ROCK DUMPS ......................................................................................... 153

WORKSHOP AREAS AND HYDROCARBON AREAS (INCLUDING EXPLOSIVE MAGAZINE) ............................................................................... 153

PITS ....................................................................................................................... 154

AIRSTRIP............................................................................................................... 154

BORROW PITS ...................................................................................................... 154

Life of Plan – Unplanned Closure ................................................................. 154

PLANNING ............................................................................................................. 154

8.2.1.1 Environmental audit ........................................................................... 154

8.2.1.2 Volumes of Key Rehabilitation Materials ........................................... 155

8.2.1.3 Progressive Rehabilitation and Remediation ..................................... 155

8.2.1.4 Monitoring and Maintenance ............................................................. 155

8.2.1.5 Reporting ........................................................................................... 155

Background for Costing of Closure Activities ................................................ 155

Security Estimate .......................................................................................... 162


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REFERENCES ....................................................................................................... 164

ABBREVIATIONS ................................................................................................... 167

APPENDICES ...................................................................................... 170Appendix 1 – Regulatory Communications ............................................................. 170

Appendix 2 – Biodiversity Monitoring Report (LES 2018) ....................................... 170

Appendix 3 – Annual Groundwater Monitoring Report (Saprolite August 2018) ..................................................................................................... 170

Appendix 4 – Biodiversity Management Plan 1.K ................................................... 170

Appendix 5 – Twin Bonanza Rehabilitation Report (Updated August 2018) ........... 170

Appendix 6 – Waste Rock Dump Management Plan 2.0 ........................................ 170

Appendix 7 – Water Management Plan (updated November 2018) ....................... 170

Appendix 8 – Erosion and Sediment Control Plan RevC4 ...................................... 170

Appendix 9 – MMP Commitments (updated October 2018) ................................... 170

Appendix 10 – Performance against 2017 MMP Commitments (October 2018) ..................................................................................................... 170

Appendix 11 – Emergency Response Management Plan 3.0 ................................ 170

Appendix 12 – Twin Bonanza Risk Assessment 1.0 ............................................... 170

Appendix 13 – Fire Management Plan ................................................................... 170

Appendix 14 – Mine Closure Plan (updated November 2018) ................................ 170

Appendix 15 – Care and Maintenance Plan ........................................................... 170

Appendix 16 – Hazardous Substance Management Plan 1.0 ................................ 170


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LIST OF TABLES Table 1-1: Register of Ownership for Mining Interests and Section 19 Leases ........ 14

Table 2-1: Rainfall Frequency Data for the Project Area (depth mm) (BOM 2013) ..................................................................................................... 25

Table 2-2: Vegetation Types described within the Twin Bonanza Project Area. ....... 34

Table 4-1: Stage 2 Open Pit Production Statistics for March – April 2016 ................ 50

Table 4-2: Old Pirate Revised Mineral Resource Estimate, July 2016. .................... 60

Table 4-3: A Summary of Historical Exploration and Disturbance Rehabilitation – 2010 to 2015 ....................................................................................... 74

Table 5-1: Environmental Inspection Findings Prior to Transition to Care and Maintenance .......................................................................................... 77

Table 5-2: Aspects and Potential Impacts Associated with Activities. ...................... 81

Table 5-3: Risk Matrix Measure of Consequence. .................................................... 84

Table 5-4: Qualitative Measures of Likelihood. ......................................................... 85

Table 6-1: Rainfall Frequency Data for the Project Area (depth, mm) (BOM, 2013) ................................................................................................... 128

Table 6-2: Production Bore Construction ................................................................ 134

Table 6-3: Proposed Monitoring Program 2017/18 ................................................. 144

Table 6-4: Summary of Historical Groundwater Quality Data and Current Wilson's, Corsair and Strezza's/Timmy's Bore Monitoring. .................. 145

Table 7-1: Recorded Incidents during Reporting Period (March 2016 – June 2018) ................................................................................................... 148

Table 8-1: Progression against closure objectives as per Mine Closure Plan ........ 149

Table 8-2: Disturbance Detail used in Security Calculation ................................... 156

Table 8-3: Security Estimation for Upgraded Twin Bonanza Gold Mine Project 01/09/17 ............................................................................................... 163


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LIST OF FIGURES Figure 1-1. Project Location Map .............................................................................. 12

Figure 2-1. Graphical presentation of weather from Rabbit Flat (Weather Station 015666), (BOM, 2012). .......................................................................... 24

Figure 2-2. Speed Rose of wind direction versus wind speed in km/h (15 Nov 1996 to 30 Sep 2010) at Rabbit Flat. Rabbit Flat is the nearest weather station with most accurate weather observations for Twin Bonanza (BOM, 2012). .......................................................................... 25

Figure 2-3. Simplified plan of geology, mineralisation and results ........................... 29

Figure 2-4. Topography including regional salt lakes and palaeochannels in the Tanami region ........................................................................................ 30

Figure 2-5. Vegetation communities of the Twin Bonanza area ............................... 35

Figure 2-6. Fauna survey sites established for Twin Bonanza. ................................ 37

Figure 2-7 Threatened species distribution within the project area based on current survey effort. Please note that at the PRE 2015 bilby sites, bilby activity was not observed during 2015. ......................................... 40

Figure 3-1. Map detailing the location of recorded archaeological sites (red dots) and declared heritage places (aqua squares) relative to Exploration Licence 28322 that surrounds Twin Bonanza. (Map supplied by the Department of Lands, Planning and the Environment 2013). ................ 47

Figure 4-1. Left Map: Twin Bonanza Proposed Mine Site Layout. Right Map: Twin Bonanza Actual Site Layout .......................................................... 49

Figure 4-2. NWRD Construction. .............................................................................. 56

Figure 4-3: SWRD Construction ............................................................................... 57

Figure 4-4. Plan View of the NWRD showing the 3D design and contour plan. ....... 58

Figure 4-5: Plan View of the SWRD showing the 3D design and contour plan. ........ 59

Figure 4-6: Proposed Old Pirate Central, South and East Open Pits - Plan View .... 62

Figure 4-7: Actual Old Pirate Central, South, and East Open Pits as at 31 January 2016 - Plan View (Please note Old Pirate East has been backfilled) .............................................................................................. 63

Figure 4-8: Proposed Western Limb Open Pit - Plan View ....................................... 64

Figure 4-9: Actual Western Limb Open Pit as at 31 January 2016 - Plan View ........ 65


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Figure 4-10: Proposed Golden Hind Open Pit - Plan View ....................................... 66

Figure 4-11: Actual Golden Hind Open Pit as at 31 January 2016 - Plan View (note ramp moved to the east from original design) .............................. 67

Figure 4-12: Proposed Old Glory Trench - Plan View ............................................... 68

Figure 4-13: Actual Old Glory Trench - Plan View (now backfilled) .......................... 69

Figure 4-14: Aerial photograph of the raw water dam in 2014. Note extent of deposited gravity tailings. ...................................................................... 71

Figure 4-15: Cross section through existing raw water dam. .................................... 72

Figure 5-1: Prodigy's Environment Policy. ................................................................ 76

Figure 5-2: Risk Rankings from Combined Consequence to Likelihood. .................. 86

Figure 6-1. Precipitation and Evaporation data for weather stations near Twin Bonanza. ............................................................................................. 129

Figure 6-2. Regional Digital Elevation Model with the location of the infrastructure detailed in black (Data Geoscience Australia, 1 Second STRM v 1.0 DEM-H). .............................................................. 130

Figure 6-3 Groundwater infrastructure / features (Please note Strezza’s/Timmys bore is included for completeness and has been redrilled as the original hole collapsed). ....................................................................... 133

Figure 6-4: Twin Bonanza 2016 Water Account ..................................................... 136

Figure 6-5: Water Extraction and SWL at Twin Bonanza during the 2015/16 reporting period ................................................................................... 143


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AMENDMENTSIn accordance with section 41(3) of the Mining Management Act, an MMP reviewed and amended under section 41(1) is to clearly identify amendments made.

Section Pg. No. Amendments

1.1 12 Change of Company Name: To Prodigy Gold NL

1.1.1 13 Company Organisation Chart::Updated company organisation chart and nomination of Exploration Manager as responsible person for TWB Site.

1.3.2 17 Project Summary and Improvements: Environmental activities undertaken in reporting period.

1.3.2 21-23 Audits and Inspections: Corrective actions for aspects identified in DPIR Inspection Report ’20th September 2017 and ‘2nd May 2018’.

2.1.3.1 32 Sensitive or Notable Vegetation Committees: Comment: Update on palaeochannel water levels and paleochannel vegetation (G.D.E) health monitoring.

2.1.3.1 33 Weed Control: Current status in respect to cessation of weed control in minesite area but retention of monitoring as part of annual EFA assessment and equipment hygiene procedures.

2.1.3.2 36 Fauna: Brief outline of the background to track activity monitoring. program and continuing opportunistic monitoring in 2018.

2.1.3.2 39 Fauna Survey Summary: Update on results from opportunistic fauna survey in August 2018.

2.2.4 44 Community Feedback: No complaints occurred in 2017/18 reporting period.

4.0 48 Operational Activities: Advice that no mining or ground disturbing activities were undertaken at TWB Project area in 2017/18

4.0 51 Dewatering and Water Requirements: General detail on past operational water requirements.

4.2.2.7 73 Character of Contaminated Water: Comment on water quality in Raw Water Dam.

4.3 73 Exploration Activities: Rehabilitation of remaining 48 drill holes at Buccaneer completed.

4.3.1 74 Proposed Exploration Activities for 2018/19:.No ground disturbing exploration activities are proposed for 2018/19 for TWB Project tenure.

5.0 75 Environmental Management Structure: Amended DPIR Incident Reporting requirements are described.


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5.3.2.1 78 Environmental Inspections: Details on environmental inspections undertaken by DPIR personnel in September 2017 and May 2018 and corrective actions.

5.4 79 Environmental Training and Education: description of mining amendments to induction training.

5.6.7 87-115 Environmental Management Plans: List of minor Plans amended to reflect transition to Care and Maintenance.

5.6.7.6 115-125 Review of Effectiveness of Management and Mitigation Strategies: Summary of results of Biodiversity and Groundwater Monitoring.

5.6.7.6 125 Incidents and Complaints Management: Outlines recent DPIR changes to the incident and complaints reporting requirements.

5.7 127 Key Environmental Activities for the Oncoming Period: Reports that no significant changes to Care and Maintenance Monitoring programs proposed for 2018/19 Reporting Period.

6.0 128 Water Management Plan: Water supply is sourced from Strezza’s Bore. The more saline Wilsons and Corsairs bores have been partially decommissioned. Saprolite have suggested the 2 bores be removed from the Care and Maintenance monitoring schedule.

6.2 135 Information Knowledge Gaps: Additional monitoring results confirm no impacts to GDEs identified with paleochannel abstraction.

6.2.2.2 136 Water Account for Upcoming Period: Likely project water abstraction in 2018/19 anticipated to be very low while on Care and Maintenance.

6.3 137-139 Risk Management: No significant changes to Care and Maintenance risk profile.

6.4.2.8 141-142 Results from Production Monitoring: No significant changes reported in production bore aquifer water chemistry.

6.4.2.13 144 Proposed changes to Groundwater Monitoring Program: No changes proposed for 2018/19 monitoring program.

6.5 146 Borefield Management: No amendments over the reporting period in respect to Borefield management.

7.0 147 Incident Reporting: Amended DPIR requirements in respect to incident reporting.

8.4 162 Security Estimate: No change to site environmental liabilities or risk profile identified in monitoring or regulatory inspections. No revision to the current security calculation is required.


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INTRODUCTION

Operator Details Prodigy Gold NL (Prodigy or the Company) is the current owner and operator of the Twin Bonanza Gold Project (Twin Bonanza, the Project or the Site) and surrounding mineral tenure. Prodigy is a Western Australian (WA) based resource company operating within the Northern Territory (NT). The company is publicly listed on the Australian Securities Exchange (ASX) under the code PRX.

The Company has a multi-tiered approach to exploration and development with a combination of high-grade gold projects, large scale discoveries such as Buccaneer (located on Mineral Lease (ML)29822), and regional exploration discoveries such as the Hyperion gold project. Some of the project areas are wholly managed by Prodigy or are held in joint venture (JV) with other operators.

This 2018 Mining Management Plan (2018 MMP) applies to Twin Bonanza ML29822 and EL28322 that underlies and surrounds the Twin Bonanza area (Figures 1-1 and 1-3).

Figure 1-1. Project Location Map

The Twin Bonanza Project was mined for a 14 month period from January 2015 to March 2016 and processing was undertaken offsite. The mine site was rehabilitated at the close of mining and the site was placed on monitored Care and Maintenance in April 2016. Following a review of the Department’s Guidance Document on Project Care and Maintenance (March 2017), and previously submitted documentation, some sections of this MMP were considered redundant as they relate to, or describe ceased operational aspects of the Project. They are retained in the document for completeness.


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Organisational Structure and Responsibility The organisational chart for Prodigy is detailed in Figure 1-2. The review and update of the organisational chart occurs on an as-needs basis to reflect any changes to the management structure. In the event of absences, delegation of authority is to the next upward level as shown on the organisational chart, unless specifically delegated otherwise. The organisational chart as presented in Figure 2.1 reflects care and maintenance status of operations as of June 2018.

Figure 1.2 Prodigy Gold NL Organisational Structure – June 2018.

Overall responsibility for environmental management and compliance at Twin Bonanza lies with the Prodigy Managing Director (MD) with the assistance of a contracted Environmental Consultant and specialist subconsultants. Implementing, resourcing and maintaining environmental management as documented in this 2018 MMP and supporting documents is the responsibility of the MD and delegated personnel. Environmental support is provided by specialist environmental Consultants for the relevant disciplines. On-ground implementation is the responsibility of Prodigy’s Exploration Manager with assistance of the delegated site personnel.

The Exploration Manager and relevant onsite personnel are responsible for defining and communicating relevant environmental responsibilities and accountabilities to employees, consultants and contractors within their area of responsibility during the Care and Maintenance and exploration activities.

Managing DirectorMatt Briggs

Chief Financial OfficerJutta Zimmermann

Environmental &Groundwater Consultants

Exploration ManagerNeil Jones

Geology Team Field Staff

LandManager

Gillian McBain


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Key Personnel/Contacts

Mr Matt Briggs , Managing Director [email protected]

Ms Jutta Zimmermann, CFO/Company Secretary [email protected] Mr Neil Jones, Exploration Manager [email protected] Ms Gillian McBain, Land Manager [email protected]

Title Details ML29822 includes the Old Pirate, Golden Hind, Old Glory and Buccaneer deposits. The ML under Section 41(3) of the Mineral Titles Act 2011, covers 3,258 hectares over the south eastern portion of EL28322. The tenements are located on Aboriginal Land Trust land and Prodigy has current agreements with the Central Land Council (CLC) for work on the Project and surrounds. A Section 46 (Mining Proposal under the Aboriginal Land Rights Act 1976) is approved over the Project with a mining agreement in place with the CLC on behalf of the Traditional Owners of the area. This 2018 MMP has been submitted to the CLC for review and comment.

Access to Twin Bonanza is by gravel road, from the Tanami Road. Gaining access involves utilising an access road across EL’s that are outside of the ML but within Section 19 agreement areas. Section 19 agreements (pursuant to the Aboriginal Land Rights (Northern Territory) Act 1976) have been executed with the CLC for areas outside the ML. Two Section 19 leases also cover the various water extraction points and airstrip.

The location of the project on the ML is shown in Figures 1-3 and 1-4.

Table 1:1 provides a register of ownership for the mining interests and Section 19 leases associated with the project. The project is located on Aboriginal Land Trust land owned by the Mt Frederick No.2 Aboriginal Land Trust and, as a result, is subject to a number of agreements with the CLC on behalf of the Traditional Owners. The CLC has approved all previous exploration and mining activities, and the CLC anthropology team and Traditional Owners have conducted several sacred site clearances and surveys over the areas of activity.

Table 1-1: Register of Ownership for Mining Interests and Section 19 Leases

Title number Title holder Grant Date Expiry Date

ML29822 Prodigy Gold NL 28/03/2014 28/03/2039

EL28322 Prodigy Gold NL 03/01/2012 02/01/2018

Section 19 Lease for Bore and pipeline (underlain by EL28322)

Prodigy Gold NL (Granted under the Aboriginal Land Rights (Northern Territory Act 1976)

01/05/2013 30/04/2038

Section 19 Lease for access road and airstrip (underlain by EL28322)

Prodigy Gold NL (Granted under the Aboriginal Land Rights (Northern Territory Act 1976)

01/05/2013 30/04/2038


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Figure 1.3: ML29822 boundary and other tenure.


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Project Description

Location Twin Bonanza is located approximately 750km NW of Alice Springs (Figure 1-1) and approximately 16km east of the NT and WA border. The mine site is located approximately 33km south of the Tanami Road, which runs North West from Alice Springs to the NT and WA border (Figures 1-1 and 1-3).

Regional communities include Alice Springs, Halls Creek, Balgo, Billiluna, Ringer Soak (Kundat Djarau) and Yuendumu. The closest permanent settlement is Balgo which is located 120km to the west of the Site.

Project Summary and Improvements In December 2016 a new Authority No 0909-01 replaced Authorisation 0703-01 for the Twin Bonanza Project. Prodigy is seeking continuing approval for Authorisation Number: 0909-01. All mining operations, ore haulage and rehabilitation ceased in April 2016. Parts of the Twin Bonanza site (pilot processing plant) remain on care and maintenance, disturbed areas are rehabilitated and closed, except for the moth-balled Pilot Gravity Plant and Wilson’s Camp which is used by exploration personnel as a base during the field season.

The 2017 MMP provided a review of Q4-2015/2016 activities as detailed in Section 4.1 and activities that were completed in 2016/2017 to June 30 2017:

Completion of mining five open pits including backfilling of the Old Glory Costean;

Rehabilitation of two waste rock land forms;

Rehabilitation of haul roads, contractors area, stockpile areas, explosives compound;

Construction of abandonment bunds around the pits, and

Establishment of post closure monitoring programs to complement existing baseline and operational programs.

No expansion of the existing mining footprint is anticipated to occur during the period of this 2017/18 MMP and while the site is on Care and Maintenance.

Further details on the mining activities are documented in Section 4 with the site layout presented in Figure 4-1. The total area of Project disturbance from commencement to the cessation of mining activities was 104.78 hectares (ha), as illustrated in Figure 1-4 (further details in Section 4.1.3). This 104.78ha of disturbance is a significant reduction of the area originally approved under Authorisation 0730-01 .

Activities during Q4 2015/16 involved:

The mining of 22,338 tonnes of ore and 41,0205 tonnes of waste from the Golden Hind, Old Pirate South, Old Pirate East, Old Pirate Central and Western Limb Pits and also the Old Glory Trench;

Construction and rehabilitation of north and south waste rock landforms;

Rehabilitation of areas cleared for topsoil, pisolite and sandstone stockpiles;

Removal of site infrastructure and rehabilitation of mining infrastructure areas including site offices, contractors workshop, park up area, two Run of Mine (ROM) pads, explosive compound and haul roads;

Limited water extraction from existing bores – Strezza’s, Wilson’s and Corsair; and partial decommissioning; and


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Continued biodiversity monitoring to satisfy approved Northern Territory and Federal (Controlled Actions) programs.

Activities during 2016/17 included;

Establishment of 8 EFA transects on WRLs

Establishment of 13 photomonitoring stations on disturbed land;

Preparation of Environmental Improvement Plans (EIPs) to provide directions on managing environmental issues identified in regulatory inspections in August 2016

Continuation of operational monitoring program covering activity track monitoring for terrestrial fauna, vegetation health monitoring, paleochannel vegetation health monitoring and groundwater monitoring.

Activities undertaken in 2017/18 included:

Construction of erosion control structures in accordance with Environmental Improvement Plan # 2016/02 for the eastern section of the perimeter drain around the Golden Hind Pit;

Continuation of post closure monitoring programs covering landform vegetation health monitoring, paleochannel vegetation health monitoring, ecosystem function analysis covering rehabilitation and stability progress on waste rock landforms and groundwater monitoring.

Implementation of improvement plans covering issues identified during regulatory inspections in May 2018

Completion of outstanding drill site rehabilitation on 48 holes at Buccaneer in August 2017. This completes rehabilitation of the exploration program for the TWB Project tenure.

Activities to be undertaken include the establishment of additional photomonitoring points covering erosion (rilling) identified in DPIR Inspection in May 2018 on the North Landform. This will be undertaken when the biological team are on site in mid-2019.


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Figure 1-4. Existing areas of disturbance as at April 2016


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Historical Exploration Disturbances Pre 2013 ML29822 covers a portion of EL28322. Therefore exploration work conducted prior to the grant of the ML, under the EL, will be considered historical disturbance on the tenement.

Historical MMPs (Authorisation 0562-01, 0562-02 and 0562-04) covered exploration activities. A summary of the approved, actual and rehabilitated exploration disturbance is presented in Section 4.3.

Rehabilitation of Historical Disturbance

From 2010 to 2013, 424 drill holes were drilled and all holes have either been rehabilitated or were engulfed in the 2013 Stage 1 bulk sampling trial mining program disturbance on EL28322. This disturbance subsequently became encompassed by mining operations in 2015, which occurred on ML29822. Of the 424 drill holes, 142 rehabilitated holes were reported in the document titled “2014 Rehabilitation Report for Buccaneer and Regional Prospects located on EL28322, Authorisation numbers 0562-01 0562-02 and 0562-04” that was originally lodged on 17 April 2014 with a corrected version lodged on 29 April 2014. A total of 275 drill holes at Old Pirate and associated prospects that were engulfed by clearing or rehabilitated were detailed in the rehabilitation report “Old Pirate Rehabilitation Report EL28322” lodged on 11 June 2014. The remaining 7 holes were included in the most recent rehabilitation report lodged with the 2016 MMP on 3 March 2016 titled “Twin Bonanza and Regional Targets Located on ML29822 and EL28322”

During 2013, a total of 15 bulk sample pits and 205 costeans were excavated. Any disturbance not engulfed within the 2015 Stage 2 mining areas was rehabilitated in the year excavation occurred. Details of rehabilitation were reported in the 3 March 2016 rehabilitation report.

In 2014, a total of 544 holes were drilled, of these, 379 were engulfed by mining operations and 151 holes were rehabilitated. The remaining 14 RC holes were established as monitoring bores in the event processing infrastructure was constructed at TWB. See 3 March 2016 rehabilitation report.

Mining officers from the DPIR conducted a site visit on 13 August 2015 and inspected a number of drill holes and areas that had been rehabilitated at Buccaneer (Report received 25 August 2015). The inspection confirmed that the drill sites had been rehabilitated with drill collars cut below ground and backfilled, drill spoils removed, and drill pads and access tracks ripped.

Audits and Inspections

DPIR Site Inspection: 13 August 2015

The DPIR completed a field inspection of the Site on 13 August 2015 that examined exploration and mining activities associated with Twin Bonanza across ML29822 and EL28322. The visit incorporated a tour and examination of key components of the project and the associated environmental controls. The following areas were included in the inspection:

Wilson’s Camp;

waste rock landforms;

water storage dam;

costeans and pits;

hydrocarbon storage areas;

exploration drilling locations; and

rehabilitated areas.


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The DPIR’s report (Ref no: MR2015/0101) provided a number of recommendations which are summarised in Section 1.2.3 of the previous 2015/16 MMP.

DPIR Site Compliance Audit: 15 – 18 February 2016

DPIR department officers conducted a comprehensive site compliance audit (Doc Ref: MDOC2016/02541) based on commitments made in Prodigy’s 2015 Mining Management Plan. Officers noted the overall performance of the operation was continuing to improve with ongoing identification and close out of raised issues.

A summary of the audit is as follows:

The audit team identified the following non-conformances and observations during the audit: No Category 1 non-conformances were identified by the audit team; and One (1) Category 2 non-conformance and Fourteen (14) conditional acceptances were

identified by the audit team.

A Category 2 non-conformance usually relates to an isolated lapse of control or an identified activity that is not in compliance with the approved Mining Management Plan or applicable legislation that could result in Low or Moderate Risk. The Category 2 non-conformance was in regards to Prodigy’s Emergency Response Management Plan (ERMP) in which current site procedures did not reflect procedures within the ERMP. Concerns were raised regarding fire-fighting equipment and a lack of emergency response team or training or evacuation drills. The Category 2 non-conformance identified on site was an area of concern, which might have resulted in a significant environmental and safety risk if left unattended or if improvements in management did not occur. The DPIR expected outcome was that emergency management should be carried out in accordance with the ERMP, and although the site was approaching closure at the time, emergency management procedures, practice and equipment should be suitable to address any potential emergency. Mining operations have subsequently been suspended.

DPIR Site Inspection: 9 August 2016

DPIR departmental officers conducted a site field inspection on 9 August 2016. The purpose of the visit was to inspect post-mining rehabilitation at the Twin Bonanza Mine, to assess the status of rehabilitation at the site and provide recommendations to ABM regarding potential areas of improvement. A letter was sent in response to DPIR recommendations on 7 November 2016.

The DPIR’s report (Ref no: MR2016/0296) provided a number of recommendations which are summarised below:

Implement regular site wide inspections of all rehabilitated areas to monitor for erosion;

Corrective Action Time Frame

An Environmental Improvement Plan (2016/01 – Erosion Monitoring) has been developed. This Plan outlines erosion monitoring tasks in areas that may be at risk from erosion. Commencing with installation of 2 additional photomonitoring points on the northern WRL. Refer to Mine Closure Plan for EIP 2016/01.

Additional photo monitoring points were installed on 30 November 2016, with photos taken of all monitoring sites. Erosion monitoring will be undertaken annually until such a time monitoring is deemed to be no longer required. Monitoring results are referenced in LES (2017a & b)


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Address erosion on waste rock dump batters and implement management strategies to prevent further erosion


An Environmental Improvement Plan (EIP 2016/01 – Erosion Monitoring) has been developed. This plan outlines an erosion monitoring plan and steps (2017/01) to mitigate erosion when identified. Commencing with the installation of 2 additional photo monitoring points to monitor the stability of slopes in respect to erosion for the sites identified on the Northern Waste Rock Dump in DPIR inspection report. The sites will be monitored as part of the Mine Closure Plan.

Additional photo monitoring points were installed on 30 November 2016, with photos taken of all monitoring sites. Erosion monitoring commenced in December 2016 and will be undertaken annually until monitoring is deemed to be no longer required.

Identify and address erosion in drainage lines


An Environmental Improvement Program (EIP 2016/02 – Remedial Drain Earthworks). Tasks associated with this program will include the placement of a series of bunds constructed of run of mine oxide mixed rock and clay material in the eroding perimeter pit drain. The earthen structures will slow run off water velocity and divert runoff into the vegetated drain verge. A photo monitoring site was installed in December 2016 to monitor up and down the slope. See Mine Closure Plan for EIP 2016/02.

Earthworks will be implemented when suitable equipment can be sourced. Erosion (photo monitoring) was established in December 2016) and will be undertaken annually until monitoring is deemed to be no longer required following stabilisation of the site.

Guidance material: Northern Territory DLRM Diversion Banks – Tech Note No 8.

DPIR Site Inspection – 20 September 2017

DPIR departmental officers conducted a site field inspection on 20 September 2017. The purpose of the visit was to inspect post-mining rehabilitation at the Twin Bonanza Mine, and assess compliance against the 2017 MMP and Mining Management Act. A letter was sent to DPIR in response to DPIR recommendations on 7 November 2017.

The DPIR’s report (Ref no: MR2017/0332) provided a number of recommendations to Prodigy which are summarised below and referenced in Appendix 1.


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Identify and address erosion in drainage lines


An Environmental Improvement Program (EIP 2016/02 – Remedial Drain Earthworks). –Tasks associated with this program will include the placement of a series of Whoa boys (bunds) constructed of run of mine oxide mixed rock and clay material in the eroding perimeter pit drain. The earthen structures are designed to slow run off water velocity and divert runoff into the vegetated drain verge. A photo monitoring site was installed in December 2016 to monitor up and down the slope. Photomonitoring results are reported in the Biodiversity Monitoring Report October 2018 referenced in Appendix 2

Earthworks were being undertaken at the time of the DPIR visit. Erosion (photo monitoring) was established at site in December 2016) and will be undertaken annually until monitoring is deemed to be no longer required following stabilisation of the site.

Guidance material: Northern Territory DLRM Diversion Banks – Tech Note No 8.

Address developing rill erosion on northern waste rock dump central lift batters and implement management strategies to prevent further erosion


An Environmental Improvement Plan (EIP 2016/01 – Erosion Monitoring) has been developed. This plan outlines an erosion monitoring plan and steps (2017/01) to mitigate erosion when identified. Commencing with the installation of 2 additional photo monitoring points to monitor the stability of slopes in respect to erosion for the sites identified on the Northern Waste Rock Dump in DPIR inspection report. The sites will be monitored as part of the Mine Closure Plan, review in n 2019.

Additional photo monitoring points were installed on 30 November 2016, with photos taken at all monitoring sites during annual monitoring. Erosion monitoring results is reported in the Biodiversity Monitoring Report (October 2018) referenced in Appendix 2. EFA and photomonitoring will be undertaken annually until monitoring is deemed to be no longer required. EIP’s scopes for remedial earthworks and timelines will be established following the proposed DPIR post closure review following submission of the 2019 MMP.

Address the fire risk from vegetation growth around the tank infrastructure and genset at Wilsons Camp


This housekeeping matter required the removal of vegetation from around water tank infrastructure and the camp genset to reduce fire risk and property damage.

This an annual housekeeping activity undertaken before the exploration team vacates the Wilsons Camp. The work was completed in September 2017.


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DPIR Site Inspection – 2 May 2018

DPIR departmental officers conducted a site field inspection on 2 May 2018. The purpose of the visit was to (a) observe operations, (b) acquire orthophoto imagery of rehabilitated landforms and (c) assess compliance against the 2017 MMP and Mining Management Act.

The DPIR’s report (Ref no: MR2017/0332) provided a number of observations to Prodigy which are summarised below with proposed actions

No weeds, rubbish, or contaminated soils were observed during the inspection.

Vegetation recruitment on the Northern and Southern Waste Rock Dumps is occurring in discrete areas, with the majority occurring on the lower batter slopes.

Minor rilling is occurring on all batter slopes of the waste rock dumps, although no major gully systems have been identified on the imagery.

Response: Rill development is being monitored during annual EFA and photomonitoring surveys and results are reported in the attached Biodiversity Monitoring Report (LES 2018). LES (2018) has recommended that an additional photomonitoring station be established at the base of the North WRL and this will be established when personnel are next on site. Planned remedial earthworks will be outlined in 2019 following the DPIR 3 year post closure review of the 2018/19 MMP.

The installed erosion control works, adjacent to the Golden Hind Pit, appear to be functioning correctly.

The site should be continually monitored for stability and revegetation to ensure successful rehabilitation.

Response: Monitoring results are reviewed annually and reported in the Biodiversity Monitoring Report (LES 2018) referenced in Appendix 2.


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CURRENT SITE CONDITIONS

Physical Environment

Climate The Tanami region has a typical semi-arid Australian climate with most of the average annual rainfall occurring during a ‘wet season’ between November and April. The summers are hot with temperatures in excess of 40ºC and winters are usually mild, although nights are cold with occasional overnight minimum temperatures below 0ºC. The closest weather station is located at Rabbit Flat, approximately 90km to the East. Average annual maximum temperature is 33.6ºC and average annual minimum temperature is 16.6ºC with an average annual rainfall of 430.7mm (Figure 2-1).

Figure 2-1. Graphical presentation of weather from Rabbit Flat (Weather Station 015666), (BOM, 2012).


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Summer rainfall is characterised by infrequent, but intense rainfall events, with single events delivering >50mm in 24 hours on average at least once per year (Table 2:1). Average pan evaporation for this region is between 2,400 and 2,800mm per annum, far exceeding the average rainfall (BOM, 2012).

Table 2-1: Rainfall Frequency Data for the Project Area (depth mm) (BOM 2013)

Duration 1:1 yr 1:5 yr 1:10 yr 1:20 yr 1:50 yr 1:100 yr 1:1,000 yr

5Mins 6.3 10.4 11.8 13.5 15.8 17.6 23.1

10Mins 9.9 16.4 18.5 21.3 24.8 27.7 36.3

30Mins 19.4 31.9 35.9 41.3 48.2 53.5 55.3

1Hr 26.4 43.8 49.5 57.0 66.8 74.2 97.5

6Hrs 38.8 70.8 82.8 98.4 119.4 136.2 182.5

24Hrs 57.6 109.4 130.1 156.2 192.0 220.3 297.5

72Hrs 83.5 157.7 187.2 223.9 274.3 313.9 423.7

Winds are calm year round, particularly during the dry season and generally in an easterly direction, tending northeast during the wet season (Figure 2-2). Wind speeds average 14.9km/hour in the morning to 15.5km/hour in the afternoon (BOM, 2012).

Figure 2-2. Speed Rose of wind direction versus wind speed in km/h (15 Nov 1996 to 30 Sep 2010) at Rabbit Flat. Rabbit Flat is the nearest weather station with most accurate weather observations for Twin Bonanza (BOM, 2012).


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Land Systems Twin Bonanza occurs within the Tanami Desert, a semi-arid sand plains region. Physiographic characteristics include sand plains with minor longitudinal dunes in the south, floodplains and floodouts on the margins. Twin Bonanza lies within a series of palaeochannels to the east and west, all of which trend southwest. The Site is on a flat, to gently undulating depositional plain covered by a veneer of colluvial sheetwash sediments and ferruginous lag; there are also some aeolian components of the regolith. The rocks that host the mineralised system outcrop.

2.1.2.1 Topsoil and Subsoil To characterise the Site soils, three surficial soil samples and eight samples spaced every 10cm from a single soil profile were collected. The three soil samples and profile samples were analysed for particle size, gravel content, erosion characteristics, pH, electrical conductivity, nutrients and exchangeable cations.

The soil profile is characterised as a shallow sandy loam, consisting of surficial red sandy loam cover (i.e. upper 30-50cm), overlying a partially to completely weathered sandstone (i.e. reflects a saprock or transition material). Plant roots were present throughout the sampled profile. The surficial cover material contains a significant residual gravel fraction (15-40% gravel), with generally fewer gravels present in the underlying weathered transition zone (5-25%). The underlying in situ sandstone is considered to be well cemented, but a high proportion of gravel (55-65%) was measured in the laboratory sample, which is thought to be representative of the properties of this material once broken up during excavation.

Surficial soil covering the area are naturally anomalous in arsenic and lead. The Old Pirate deposit was discovered as a result of the local arsenic anomalism and contains multiple narrow high grade veins which don’t tend to outcrop as well as the bucky exposed and barren quartz in the region. Local arsenic values vary from <10ppm to <4000ppm in soil and rock chip samples. Rock samples and soil samples around Old Pirate report readings in excess of 1ppm Bismuth (natural crustal abundance 0.17ppm) and an average of 1.5ppm Uranium (average crustal abundance 2.7ppm).

The surficial cover material is strongly acidic (pH = 4.0 – 4.9), while the underlying sandstone is moderately alkaline (pH = 8.2 at 135cm depth). The majority of salts appear to have been leached from the measured profile, and the surface soils are subsequently considered non saline and non-sodic. The soils are generally low in nutrients and organic carbon highlighting their low chemical fertility and lack of pedogenic development. Cation exchange capacity (CEC) of the surface soils was low, with the exchange complex dominated by calcium and magnesium cations. This low CEC implies that kaolinite is the dominant clay mineral, and thus these materials are likely to be macro-structurally unstable, with the individual clay plates wanting to separate and mobilise (Note: this is different from micro-structural dispersion caused by elevated Na levels).

An analysis of dispersion showed that most of the topsoils are potentially dispersive after mechanical disturbance of the soil structure (i.e. after excavation and stockpiling). This classification is mainly attributed to the lack of salts within the soil solution to facilitate aggregation and flocculation of clays. Thus, soils containing the largest fractions of clay (i.e. the weathered “transition” layer) are at the greatest risk of dispersion. Conversely, soils containing larger fractions of gravel will be at the least risk of the effects of dispersion.

No contaminated sites have been recorded within the areas of previous disturbance.

2.1.2.2 Topography and Geology The Site is located relatively high in the landscape. Locally the area surrounding the Site is flat with a general fall across the site of around 5.0m to 7.0m, predominantly in a south-westerly


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direction. The maximum relief across the larger area is around 20m to 25m, with gentle slope geometries of between 1 to 3 degrees.

2.1.2.3 Geology The regional geology of the Site is almost exclusively on Proterozoic age marine turbidite sediments, of the Dead Bullock Group and Killi Killi formations (Boucher, 2011), and intruded by the Buccaneer Monzogranite in the northwest of the project area. To the east the Killi Killi formation transitions to the Dead Bullock Group. Air-photo interpretations and field mapping show low-levels of outcrop outside of the main Old Pirate trend. The rocks are all Proterozoic age with deposition 1900 to 1800Ma and intrusions / mineralisation 1800Ma to 1790Ma.

Local geology

In the vicinity of the Old Pirate deposit, outcrop and drill core reveal very coarse to fine grained sands inter-bedded with 2 to 8m wide shale units. Occasional amalgamated coarse sands and thicker-shales occur, with the latter hosting the gold-bearing quartz veins. A solitary chert bed has been found at Old Pirate and acts as a key marker horizon in geological mapping. The Old Pirate anticline can be traced 2.5km south and 5km north of the main deposit area. Recent work has shown that dolerites are increasingly common, particularly in the south and east of the Old Pirate area. From low confidence mapping, some of the dolerites appear to conform with bedding, however mapping in the recently excavated pits shows clear intrusive relationships. At Golden Hind, there is a thick, very coarse grained immature sandstone that may be of fluvial origin.

The sequence is folded into a moderately south plunging anticline. From lithological relationships, it is clear that quartz veins have been introduced into the system prior to deformation, with evidence to support further introduction of veins at the time of folding, and during subsequent ductile (shear) and brittle (fault) episodes.

Mineralisation

The Old Pirate gold deposit sits within a 4 kilometre long anomaly of gold in soil samples (Figure 2-3). Multiple veins have been mapped covering an overall area of 1,800 metres by 300 metres and range from a few centimetres to several metres in width. Drill results indicate gold extends from surface to a depth of at least 200 metres. Gold is very coarse and can be extremely high grade in the veins, however, is unevenly distributed resulting in a statistical nugget effect.

Old Pirate consists of outcropping gold bearing quartz veins hosted by folded shale and sandstone, with the quartz veins locally preferentially developed in the thicker shale units. Gold is known from numerous generations of quartz, based on the paragenetic observations made through mapping at various scales. At Old Pirate South, gold is hosted in a vein that clearly pre-dates the main folding event, whereas at Golden Hind, gold is hosted in a shear that post-dates veining and folding. Western Limb was previously interpreted to comprise a laterally extensive vein within a single shale unit. Recent pit mapping suggests that the vein may occupy a fault position, as the sediments in the foot wall and hanging wall have differing strikes.

2.1.2.4 Groundwater and Surface Water The water table is generally between 60-100m below surface with an average of around 80m over the Old Pirate deposit area, this varies due to changing rock types and fractures. Mining activities have validated that groundwater is not present at around 35 metres, as the excavations have not encountered any major influxes of water that require dedicated management. Regionally the majority of groundwater is contained in palaeochannels (or palaeodrainage systems) which are buried ancient drainage systems. Palaeochannels located to the east and west of the project are defined as higher order palaeochannel (Wilford 2000) and are characterised by surficial


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deposits of aeolian sand, alluvial sand/silt/clay, gravel, calcrete and silcrete. Palaeochannels are considered to be unconfined with variable depths to water of 3-6m in calcrete aquifers and 5-10m in alluvial systems (seasonally variable).

The Site is located relatively high in the landscape, and does not intersect any regional-scale surface water features (Figure 2-4). The shape of the landscape indicates that sheet flow will be the dominant surface water flow process, with some accumulation of flows possible in lower-lying areas after large storm events, although there are no permanent water features present. Regionally surface water flows concentrate along topographic depressions formed by the palaeochannels.


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Figure 2-3. Simplified plan of geology, mineralisation and results


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Figure 2-4. Topography including regional salt lakes and palaeochannels in the Tanami region


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2.1.2.5 Vegetation Geology, land form, and soils have a dominant influence in shaping the vegetation types present within the Project area. Additionally, fire also strongly influences the structure and composition of the vegetation in the region (Latz 1995) which makes some boundaries of vegetation types difficult to distinguish (from both in the field and aerial imagery). Refer to Section 2.1.3 for more detailed information regarding species and maps.

Flora and Fauna Surveys and monitoring undertaken in 2015 beyond work undertaken for the Environmental Impact Statement (EIS) and reported in previous MMPs includes work by Low Ecological Services, Desert Wildlife Services and the collection of data by Prodigy personnel. The findings and information of this work is provided below.

2.1.3.1 Flora Previous vegetation surveys identified and described five vegetation types within the Twin Bonanza area (Table 2-2 and Figure 2-5). All vegetation types are widespread within the bioregion. Vegetation associated with the palaeochannel land unit has been considered an important vegetation type due to biodiversity values, and cultural importance (discussed below).

During the reporting period one biodiversity monitoring survey was undertaken in August 2018 with three previous surveys being undertaken in June 2016 and 2017 and December 2016. A baseline survey was undertaken in December 2014, this survey commenced biodiversity monitoring prior to mining by recording the vegetation status of the site and commenced closure planning with the establishment of control sites. The report pertaining to the reporting period’s monitoring event is contained in Appendix 2. The following monitoring programs were established to support the biodiversity objectives:

Four (4) palaeochannel sites were established in the vicinity of Strezza’s extraction bore and the monitoring bores;

Four (4) vegetation health monitoring transects; and

Three (3) Ecosystem Function Analysis (analogue for closure planning).

Vegetation was of good health with floristic variation between sites and the understorey dominated by Triodia pungens. The June 2015 survey confirmed the vegetation was in good health, however the presence of dust was noted. On 23 October 2015 a bushfire, started by lightning, burnt a large area surrounding Twin Bonanza, thus the majority of sites were denuded of vegetation during the December 2015 survey. However, the June 2016 and 2017 surveys show very good regrowth recovery in response to above average rainfall.

In the general vicinity of the Old Pirate mining area the most extensive vegetation type is vegetation type 3 (Table 2-2), which is associated with lateritic and loamy sand plains. The operation largely falls within vegetation types 1 and 2, as these communities were associated with rocky hills land units that are associated with the target ore resource.

Sensitive or Notable Vegetation Communities

There are no threatened ecological communities or significant habitat types within the Site. However, the Tanami Desert is regarded collectively as being a “significant habitat” for several threatened species and a diversity of native species (SEWPaC 2013).

Key habitat types within this part of the Tanami Desert would include ephemeral wetlands, ephemeral salt lakes, and palaeochannels. These habitats are known for their importance in supporting a diversity of native species (including threatened species) and providing general


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refugia during dry periods. Additionally, these habitats are not widespread like sand plain habitats and also have the potential for fragmentation due to a relatively linear landform structure.

The Site is adjacent to a palaeochannel (Figure 2-5). Palaeochannels (or palaeodrainage systems) are characterised by being the surface expressions of ancient drainage systems. There are two distinctive types described by Lundie-Jenkins (1989). Type 1 is the saline system associated with salt lakes, and soils affected by various salts including sodium chloride and gypsum and others. Type 2 is the drainage depressions which today appear not to be so affected by salinity, or where the salinity has been masked by overlying sediments such as aeolian or alluvial sands. Vegetation and habitat surveys of the palaeochannel located to the west of the Site fit the description of a Type 2 palaeochannel system. During the mining period which ceased in March 2016, water extracted from the palaeochannel resulted in the temporary lowering of the water table in one location by 1.77 metres (m). Groundwater levels have increased marginally at all sites (between 0.08 and 0.45 m higher than 2017 recorded levels) in the August 2018 survey (Saprolite 2018, and LES 2018). Since December 2016, SWLs have steadily recovered and remained relatively stable, corresponding with significant reductions in water abstraction and the closure of mine site operations in March 2016. Plant stress was widely observed across the project area in 2017/18 and declines in tree health and vegetation abundance are likely a response to below average rainfall in the year preceding the August 2018 survey and the ongoing impacts of widespread fires across the site in 2015 (LES 2018 Appendix 2).

When flood events occur, the palaeochannels flow in a southerly direction. The receiving saline lake environment is approximately 50km from the Site and no clear linkage is evident.

Significant Flora Species

No threatened flora species were identified within the Site during the reporting period.

The desert walnut (Owenia reticulata) was not identified within the Site (this species is of cultural significance to the local indigenous people) during the period of operation. Other larger trees (Hakea spp., Grevillea spp., Eucalyptus spp., and Corymbia spp.) were potentially of significance to Traditional Owners, and consultations were undertaken to determine the level of significance and measures to protect them within the Site.

Weeds

During the establishment of infrastructure related to the Twin Bonanza Project one additional area containing buffel grass (Cenchrus ciliaris) was identified. Including the previously identified areas (i.e. Wilsons Camp, Wilson’s Bore and the Junction of the Tanami Road and Wilsons Camp access road) this brings the number of areas with buffel grass infestation to four (4). The introduction of buffel grass into these areas is a function of previous land clearing practices (i.e. a legacy issue inherited by Prodigy). No declared weeds have been observed within the Site, despite there being database records of some significant (e.g. WONS) species in the bioregion.

The new weed area is situated at bore RN018999 that is located to the south of the Tanami Road and Wilson Camp access road junction. Buffel grass occurs at the bore and turkeys nest storage. It is evident that earthworks associated with the establishment of bore RN018999 and the turkeys nest are likely responsible for the introduction of buffel grass at this site.

No weeds were identified along exploration tracks, drill pads, general roads, airstrip, or other areas within Twin Bonanza. Purple-top Rhodes grass (Chloris barbata) is present in low densities at Wilson’s Camp but is not generally regarded as a threat to native biodiversity (therefore has low priority for control). Additionally, during the second weed campaign, a plant known as Caribbean Stylo (Stylosanthes hamate) was identified on the Tanami road. This plant


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is a non-endemic rapid coloniser. To limit the plants spread across the Site, the plants were removed or sprayed.

Past weed management has focused on buffel grass, as this species is responsible for significantly changing the ecological function of landscapes in central Australia (such as changing fire regimes, displacement of native flora, and altering habitat availability for fauna) (CRC 2008). In previous reporting periods four campaigns were conducted and reports submitted as an Appendix in the 2016 MMP. During the Closure Program one campaign was undertaken by CLC Traditional Rangers in March 2016, with the final report submitted as Appendix 3 to the 2017 MMP. These campaigns were to meet the offsets required by the Commonwealth Department of the Environment and Energy (DoEE) as part of the project approval. Buffel grass, present at Wilson’s Camp, Wilson’s Bore, Tanami Road/Wilsons Road junction and RN018999 Bore, were manually removed, followed by spot spraying with a glyphosate based herbicide to kill buffel grass seedlings.

Following the cessation of project operations, advice was received from DOEE that Compliance Reporting in accordance with Approval 2013/6784 could cease. (DOEE 18th August 2017). Weed monitoring, external to the TWB minesite, and treatment management has therefore ceased. Weed monitoring of mine disturbed areas is undertaken annually as part of EFA monitoring and is reported in the Biodiversity Monitoring Report (LES 2018) referenced in Appendix 2. (Correspondence from DOEE in respect to cessation of compliance reporting is referenced in Regulatory Communications - Appendix 1).

Exploration personnel using Wilson’s camp as a base will continue to follow equipment plant hygiene requirement designed to assist in limiting weed spread.


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Table 2-2: Vegetation Types described within the Twin Bonanza Project Area.

Representative Photo Description Area (ha)

Vegetation Type 1Low Eucalyptus brevifolia isolated trees ± mid high Acacia lysiphloia or low A. hilliana isolated shrubs over Triodia basedowii open hummock grassland. Occurs on rocky outcropping.

Within ML29822

534ha

Vegetation Type 2Triodia basedowii and T. intermedia mid open hummock grassland with Acacia minutifolia and A. adoxa var. adoxa low open shrubland. Occurs on gravel flat to gentle relief.

Within ML29822

264ha

Vegetation Type 3Open Triodia spp. hummock grassland ± low Eucalyptus brevifolia or Hakea lorea isolated trees with tall ± Grevillea wickhamii or Acacia spp. open shrubland. Occurs in sand plains.

Within ML298222251ha

Vegetation Type 4Low Corymbia opaca or Eucalyptus victrix ± Eucalyptus brevifolia open woodland with tall Acacia sericophylla open shrubland over Triodia pungens open hummock grassland. Occurs in Palaeochannels and drainages.

Within ML29822

183ha

Vegetation Type 5Acacia aneura woodland over mixed tussock grass. Occurs within a variety of landform, present on heavy soils with high clay content.

Within ML29822

1ha


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Figure 2-5. Vegetation communities of the Twin Bonanza area


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2.1.3.2 Fauna Three, (3) baseline fauna surveys were initially conducted for the Twin Bonanza EIS and discussed in previous MMP’s. The surveys were as follows:

late wet season, April 2012 (GHD 2012);

late dry season, September 2012 (EcOz 2012); and

early dry season, May 2013 (EcOz 2013).

During the 2015 reporting period three (3) fauna monitoring surveys occurred in December 2014, June and December 2015 (see Figure 2-6 for fauna survey sites). During 2016 two (2) biodiversity monitoring surveys occurred in June and December, These monitoring surveys were undertaken across three (3) permanently established activity plot areas. In 2017/18 one opportunistic survey was undertaken during site traverses in August 2018.

Based on previous records of threatened taxa and feral species, the focus the surveys focussed on the greater bilby, brushtail mulgara, cat, fox (fox not currently recorded at site), camel and dingo. At each plot all fauna activity was recorded. Track activity monitoring ceased in December 2016 as fauna monitoring over the six prior survey events covering preoperational, operational and post closure phases had demonstrated that mine activities had not impacted adversely on fauna related environmental values. An account of the most recent opportunistic fauna monitoring effort, methodology and findings are presented in LES (2018) Appendix 2.

A summary of the opportunistic recordings are provided below.

Fauna Survey Summary

The combined pre-mining fauna surveys presented in the previous MMPs for the Site recorded a total of 117 species, including 30 reptiles, 58 birds, 2 amphibians and 24 mammals. During the biodiversity monitoring and cat control campaigns a further 1 reptile, 3 amphibians, 1 bird and 4 mammals were identified. None of the recently identified species are classified as threatened. Evidence of the two threatened species and three introduced species was recorded over the reporting period. Further discussion of these species and the recently identified species are provided below.


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Figure 2-6. Fauna survey sites established for Twin Bonanza.


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Reptiles

An additional species was identified bringing the total to 31 species that have been recorded across the Site which, include dragons, skinks, geckoes, monitors, legless lizards, and snakes. No threatened or introduced species were recorded.

Reptiles were abundant during all surveys/monitoring when temperatures were high, with notably reduced activity during cold snaps and rainfall. The most recently identified species was a Bynoe’s gecko (Heteronotia binoei) that was captured in a pitfall trap adjacent to Wilson’s camp.

Amphibians

During the 2014/2015 wet season a further three frog species were identified. The species identified were the Giant Frog (Cyclorona australis), Northern Burrowing Frog (Neobatrachus aquilonius) and Mains Frog (Cyclorona maini).

Birds

A total of 59 bird species have been recorded to date. No threatened or introduced species were recorded.

As recorded during pre-mining surveys, bird diversity remained relatively low within the Site, reflecting the low variety of habitat structure. Habitat complexity is an important determinant of species richness in birds (Cousins & Phillips 2008). Vegetation cover throughout the Site is generally low, with large trees and shrubs sparsely scattered throughout. In most areas the upper and middle canopy is either very open or absent, which limits foraging and roosting options for birds. The additional species to be recorded during the reporting period was an emu (Dromaius novaehollandiae) whose tracks were observed along an access track during the cat campaign in April 2015.

Mammals

Previously a total of 28 mammals were recorded during the fauna surveys, including two threatened species and three introduced species..

The most commonly trapped and observed species were spinifex hopping mouse (Notomys alexis) and sandy inland mouse (Pseudomys hermannsburgensis). The further species to be observed were the spectacled hare wallaby (Lagorchestes conspicillatus), northern nailtail wallaby (Onychogalea unguifera), one striped faced dunnart (Smithnopsis macroura) and white striped freetail bat (Austronomus australis)

Some notable observations are listed below:

On several occasions dingoes were seen with baby cats they had preyed upon; and

Spectacled hare wallabies and northern nailtail wallabies were recorded on night cameras and tracks were observed on a number of occasions. It is considered that these recordings may be at the southern end of these two (2) species range.

Significant fauna species

Two (2) threatened fauna species have been recorded around the Site, these are:

Brush-tailed mulgara (Dasycercus blythi) – vulnerable under the TPWC Act; and

Greater bilby (Macrotis lagotis) – vulnerable under the TPWC Act and EPBC Act.

Since the initial identification of these species further evidence of these two (2) species has been recorded during the biodiversity monitoring surveys and cat campaigns. Mulgara activity has been recorded at all the monitoring sites. Locations of where mulgara activity were recorded are presented in Figure 2-7. During the cat campaign an area with extensive bilby activity was


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identified 6km from the mining operation. Figure 2-7 details the location of the bilby activity that was identified. Further searches for the great desert skink (Liopholis kintorei) did not result in any evidence that the species occurs in the site habitats.

Some interesting observations are listed below.

Over the period at each of the monitoring sites the level of brushtail mulgara increased until a bushfire in October; and

The greater bilbies located directly east of the site vacated the area at least 4 to 6 months before mining commenced. The reason for the departure is unclear and is unlikely to be mining related. During the cat campaigns CLC rangers located an area of bilby activity approximately 6km east-southeast of mining operations. Night cameras recorded the presence of three distinct individuals at the locality.

As part of the EIS assessment of Twin Bonanza a specific Biodiversity Management Plan was developed to ensure that impact to these species is minimised and appropriately monitored. Over the reporting period the Biodiversity Management Plan was amended to reflect a range of regulatory feedback. Each update of the document was submitted to the DoEE under the Environment Protection and Biodiversity Conservation Act 1999. The currently approved version is contained in Appendix 4. Although not required under current regulatory approvals, fauna and fauna signs were opportunistically observed and recorded during the 2018 survey period, both at survey sites and while traversing between survey sites. Signs of target threatened species including bilbies (Macrotis lagotis) and brush-tailed mulgara (Dasycercus blythi) were searched for incidentally throughout the duration of the survey. No sign of brush-tailed mulgara was recorded in the August 2018 survey. Bilby burrows and scats, but no fresh tracks, were recorded at analogue site VH4, in the north-east of the project area and diggings were located at the base of numerous Acacia lysiphloia shrubs. An inactive burrow was identified at the base of a Corymbia opaca mallee.

Feral animals

Three (3) introduced fauna species have been confirmed during previous surveys at the Project Site, including the feral cat (Felis catus), one-humped camel (Camelus dromedaries), and house mouse (Mus musculus). These species are widespread and established in the region and are regarded as a threatening process toward ecological biodiversity. As part of the Site’s environmental commitments, quarterly cat control campaigns were commenced in April 2015. The program involved the driving of all active roads within a 15km radius of the Site to identify areas of cat activity. Once identified, lines of cage and soft leghold traps were deployed.

During the first campaign potential signs of a fox were observed, however subsequent surveys failed to find further evidence for the presence of foxes. Camel and cat signs (no physical sightings) were recorded during the August 2018 survey.

Over previous reporting periods a total of 4 cat control campaigns were conducted by Desert Wildlife Services with CLC Traditional rangers, capturing 6 cats. The final campaign was conducted in April 2016 as the Project was transitioning to Care and Maintenance. Cat control across the Site was a measure implemented to meet the offsets required by the DoEE as part of the Environment Protection and Biodiversity Conservation Act 1999 approval. DOEE authorisation to cease control programs was received on the 18 August 2017. Full details of each campaign were provided in the 2017 MMP.


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Figure 2-7 Threatened species distribution within the project area based on current survey effort. Please note that at the PRE 2015bilby sites, bilby activity was not observed during 2015.


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Socio-Economic Environment

Current Land Use Land underlying the Site is Aboriginal freehold land (owned by the Mt Frederick No 2 Aboriginal Land Trust) that is used by the Traditional Owners, for traditional purposes, and has more recently been explored for mineral potential. The nearest Traditional Owners’ settlement, Balgo, is 120km to the west of the Project area. The Balgo community has a population of 459 (Census 2011). The community is an aboriginal community serviced with an airstrip, health clinic, school, community services, a shop and sports facilities. Unemployment in Balgo is high (above the national average) and the health and well-being of residents endures the typical challenges of remote communities. Prodigy has received strong support from the Traditional Owners.

Mining tenure in the area is currently held by Prodigy as either a ML or as ELs for the surrounding areas. Mineral exploration has been conducted on the land for several decades by numerous companies, those most recent include, Tanami Gold NL, Newmont Tanami Pty Ltd and Prodigy.

There is no public infrastructure on the ML or surrounding ELs, with the exception of the Tanami Road which is 33km north of the ML. The status of private infrastructure constructed for the project includes:

Access track (un-paved);

Exploration tracks to prospects (un-paved);

Airstrip;

Three (3) water bores (one (1) water bore outside ML contained within Section 19 Area), 18 monitoring bores (5 monitoring bores outside ML contained within Section 19 Area) & pipelines (supplying camp and mine site);

Wilson’s camp – accommodation, landfill, sullage leach pond for sewage, power supply; workshops, offices;

Minesite Infrastructure

Bulk sample gravity processing plant;

Raw water/tailings storage facility dam;

Laydown area (Rehabilitated);

Haul roads (Rehabilitated);

Workshop and parking areas (Rehabilitated);

Site Offices (Rehabilitated);

5 opencut pits (Secured and Bunded);

Two waste rock landforms (Rehabilitated);

Explosive compound (Rehabilitated); and

Small waste and topsoil stockpiles (Materials utilized for rehabilitation).

Identified Stakeholders To better understand the effect of Twin Bonanza on the social environment ABM mapped key stakeholders potentially affected by the Twin Bonanza Project. Stakeholders are considered to be the individual(s) and/or groups that have an interest in a given decision associated with Twin Bonanza. ABM has communicated with and engaged with the separate stakeholders regarding the life of the mine and at mine closure to ensure stakeholder concerns are valued and fully considered.


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As part of the 2013 draft EIS, requested by the NT Environmental Protection Agency (EPA) and Commonwealth Government, Prodigy conducted economic and social impact assessments. These assessments examined economic and social impacts on the stakeholders (listed below) and outline measures for management and mitigation of risks and impacts associated with the mining operation.

The defined stakeholders are:

CLC;

Traditional Owners;

Central Desert Shire;

Prodigy employees and contractors;

Prodigy shareholders;

NT DPIR;

NT EPA;

NT Department of Lands, Planning and Environment;

Commonwealth DoEE and

NT Department of Treasury and Finance.

Additionally, as Prodigy processed ore off site at the Coyote gold processing plant in Western Australia that required the haulage of ore, three (3) further stakeholders were identified and consulted. The three (3) stakeholders were:

NT Department of Transport;

NT Department of Infrastructure, and

WA Department of Mines and Petroleum.

There are 4 forms of stakeholder engagement strategies that ABM employs: 1. formal engagement with Traditional Owners – through the CLC; 2. informal engagement with Traditional Owners – inadvertent through visitors, employees

and colleagues; 3. engagement with the Governments of the NT and WA; and 4. engagement with the people, businesses and NT inhabitants as a whole.

As part of the EIS process the Social and Cultural Management Plans were reviewed by the CLC.

Preliminary feedback from the CLC resulted in:

modifying procedures and processes to ensure compatibility with traditional activities and surrounding land management practices;

modifying the design of infrastructure to manage the project’s impact; and

shaping the management of social and cultural heritage impacts.

In addition, since the commencement of exploration, progressing into mining and finally closure and Care and Maintenance at Twin Bonanza, regular ongoing ‘on country meetings’ have been held with the Traditional Owners via the CLC to detail work programs, undertake surveys and discuss any concerns that have arisen. This process has created a clear dialogue and an understanding of the surrounding community’s expectations. In the future these meetings will continue.

Through the EIS assessment process for the project, NT government agencies and the Commonwealth government have provided a number of comments, conditions and


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recommendations. These have been incorporated into the environmental management of the project and continue to be reflected in this updated MMP document. The government agencies that have provided comment are:

Commonwealth DoEE;

NT EPA;

NT DPIR;

NT Department of Land Resource Management;

NT Department of Primary Industries and Fisheries; and

NT Department of Lands, Planning and the Environment.

Workforce Description and Demography Until March 2016, the total operational workforce for mining at Twin Bonanza was approximately 46 personnel. The majority of the operational employees worked a 2 weeks on and 2 weeks off roster (mine – day shift only). These numbers reduced significantly in April 2016 to approximately 5-6 site personnel, who remained until late May 2016. Currently, there are no permanent staff at Twin Bonanza, and exploration personnel use Wilson’s Camp as a base with a maximum of 8 people usually on site at one time.

Planned Aboriginal Employment and Training Opportunities

The Site is on Aboriginal Land Trust land and is subject to a mining agreement between Prodigy and the CLC on behalf of the Traditional Owners. The mining agreement has provisions for employment opportunities whereby Prodigy must advertise and offer employment to local Aboriginal people for any role (subject to experience and competency). To date, and at various stages a total of 8 Aboriginal people have been employed by Prodigy for the cat and weed control programs. Aboriginal people were employed for a total of 90 working days during the life of the project.

Community Affairs Access to the land is overseen by the CLC, as the Aboriginal Land Rights Act (1976) does not permit, by law, companies to enter into direct negotiation with the Traditional Owners without the CLC. Exploration work conducted over the past 11 years has been through exploration access agreements which provide provisions for compensation, payments pro-rata on exploration expenditure and employment opportunities. In addition, community consultation has been carried out as part of the mining agreement with the CLC / Traditional Owners. This consultation has involved detailed description of the project scope. Prodigy has received strong support from the Traditional Owners.

A mining agreement has been negotiated with the CLC on behalf of the Traditional Owners. The mining agreement sets out: 1. rents on the ML;2. protection of sacred sites;3. royalty payments on production (percentage of total production paid quarterly); 4. capital expenditure payments (percentage of capital and sustaining expenditure);5. major activities and infrastructure; 6. employment programs; and7. liaison.


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The mining agreement and estimated financial contribution cannot be disclosed due to confidentiality restrictions of the CLC and existing agreements.

Payments to Traditional Owners

The agreements with the CLC (acting on behalf of the Traditional Owners) cover a wide range of topics including the responsibilities of Prodigy to avoid exclusion zones (sacred sites), protect the environment and heritage, provide employment opportunities and provide infrastructure. The agreements also cover set payments to be made to the CLC for the benefit of the Traditional Owners and these payments include rents (for ML and Section 19 land leases) and payment of a metal based (not profit based) royalty to the Traditional Owners.

The details and magnitude of payments is, at the request of the CLC, confidential.

Community Feedback

No complaints were reported during the 2017/18 reporting period.

Complaints when received, are recorded in the Complaints Registrar and reported in the annual MMP. Environmental complaints are investigated, with necessary actions taken and subsequently monitored to assess effectiveness.

Environmental Initiatives

During the mine operational period, Prodigy supported the following initiatives:

Empty aluminium cans were donated to the Apex Club of Central Australia who use the proceeds from the can sales to support a scholarship for an under-privileged child in Alice Springs.

Where practicable, utilised local Traditional Owners to assist in controlled burning, locating and monitoring threatened species, feral animal control, rare flora and weeds.


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STATUTORY AND NON-STATUTORY REQUIREMENTS

Statutory Requirements Prodigy will operate in accordance with the following legislation:

Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act); o Environment Protection and Biodiversity Conservation Regulations 2000;

Commonwealth Native Title Act 1993 and Native Title Amendment Act 1998;

Aboriginal Land Rights (Northern Territory) Act 1976;

Environmental Assessment Act 1982 (NT); o Environmental Assessment Administrative Procedures;

Northern Territory Aboriginal Sacred Sites Act 1989;

Northern Territory Heritage Act 2011;

Northern Territory Mineral Titles Act 2010; o Mineral Titles Regulations;

Northern Territory Mining Management Act 2001 (as amended); o Mining Management Regulations;

Northern Territory Weeds Management Act 2001;

Planning Act 1999 (NT); o Planning Regulations;

Work Health and Safety (National Uniform Legislation) Act (and related Regulations) 2007 2011 (NT) (WHS(NUA) Act); o Work Health and Safety (National Uniform Legislation) Regulations;

Waste Management and Pollution Control Act 1998;

Plant Health Act 2008; and o Plant Health Regulations.

Other legislation that maybe referred to from time to time are:

Territory Parks and Wildlife Conservation Act 2000;

Water Act 2004;

Traffic Act 1987;

Aboriginal Land Act 1980 (NT);

Soil Conservation and Land Utilisation Act; and

Bushfires Management Act 2016.

The Site falls within the jurisdiction of the Central Desert Regional Council, which is covered by the Local Government Regional Management Plan (RMP) for the Central Australian Region. The RMP is a statutory instrument under part 3.1 of the Local Government Act 2008 (NT). Prodigy will comply with any Central Desert Shire bylaws or requirements that become applicable.


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Non-Statutory Obligations The Site is on Aboriginal Land Trust land and is subject to a mining agreement between Prodigy and the CLC on behalf of the Traditional Owners. The mining agreement requires: 1. Management of water resources; 2. Rehabilitation; 3. Meeting legal compliance obligations; and 4. Meeting a range of general environmental principles.

The details of the mining agreement with the CLC on behalf of the Traditional Owners is confidential.

Sacred, Archaeological and Heritage Sites

Sacred Sites The CLC has approved all previous exploration and mining work, and the CLC anthropology team and Traditional Owners have conducted several heritage surveys on the Site. The CLC have issued Sacred Site Clearance Certificates in respect of Prodigy’s activities at Twin Bonanza. There are a number of exclusion zones defined in proximity to the ML, though none of these are actually present on the ML29822 tenure.

Two Sacred Site Clearances were performed within EL28322 (prior to the Stage 1 2013 bulk sample trial mining program) which includes the area of mining activity. No sacred sites were recorded for the Project Site.

Public circulation of sacred site information is prohibited under agreements with the CLC. If this information is required the DPIR must consult directly with the CLC.

In addition, to prevent destruction of sacred sites that have been recorded independently of the surveys, a search was obtained from the Aboriginal Areas Protection Authority (AAPA) annually when operations are active. A search was not conducted for this 2018 MMP as no disturbance works were scheduled for the project and none are proposed in the coming reporting year. From previous searches, no sites have been identified within the Site footprint.

Heritage and Archaeological Sites A NT Heritage register check was conducted in January 2016. As illustrated in Figure 3-1, no nominated, proposed or declared heritage places and no prescribed Aboriginal archaeological sites were identified within the footprint of the Site, except for sites TB1 to TB6 within EL28322, previously reported and discussed below.


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Figure 3-1. Map detailing the location of recorded archaeological sites (red dots) and declared heritage places (aqua squares) relative to Exploration Licence 28322 that surrounds Twin Bonanza. (Map supplied by the Department of Lands, Planning and the Environment 2013).

In 2013, Prodigy conducted an Aboriginal and non-Aboriginal archaeological survey over the Twin Bonanza EL28322 area. The survey was conducted by Tim Hill Heritage Management and Planning (THHMP).

The surveys and report were prepared with reference to the guidelines for the Burra Charter: Procedures for undertaking the studies and reporting have been provided in previous MMP’s.

The THHMP surveys covered 37.8 kilometres of transects and used a predictive model to search for locations of archaeological sites. Six Aboriginal archaeological sites or objects (sites TB1 to TB6) were recorded during the survey – one being a spatially extensive / low density stone artefact scatter (TB3), two spatially discreet / low density stone artefact scatters with small ephemeral clay-pans (TB5 and TB6) and three isolated artefacts (TB1,TB2 and TB4). The predominant stone material for tool / production was chert and silcrete. Of note is that only a very low relative percentage of flakes were produced from stone materials sourced within the study area and most artefacts/flakes were produced from high-quality materials indicating that quarries are located outside the study area.

Archaeological sites within the Twin Bonanza study area were determined to be of low significance. While the scientific significance is noted, this assessment considers the following: 1. The sites and area were not identified as being culturally significant during anthropological

investigations; and 2. The artefacts located during the survey appear not to be a reflection of the local geology

and therefore there is a likelihood that a larger quarry and occupation sites are located in the greater area outside of the proposed disturbance footprint.

The CLC has been previously notified of the findings from THHMP surveys.


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OPERATIONAL ACTIVITIES

No mining or ground disturbing activities were undertaken at the TWB site during the reporting period. The 2017 environmental security calculation has not changed with the summary provided in Table 8:1. Section 8 provides a breakdown of the current and proposed disturbance areas for the project. No mining activities or ground disturbing exploration activities are proposed for the upcoming 2018/19 MMP reporting year.

Mining Activities and Mine Design During the 2015/16 reporting period, mining at the Old Pirate Pit targeted gold ore with some accompanying silver. As a result of lower than anticipated gold grades, mining at the Old Pirate deposits ceased in March 2016. The 2017 MMP detailed the final period (March 2016 – April 2016) of mining and describes the associated minesite rehabilitation and closure activities that were completed prior to the site being placed on C & M.

Mining occurred in only three of the proposed five open cut pits by mechanised mining methods. The open pits that were mined and completed were - Old Pirate Central/South Western Limb and Golden Hind. Details were included in the 2015/16 MMP of the mining and backfilling of Old Pirate East and Old Glory trench.

The quantities of ore and waste extracted in the final period of mining relate to Old Pirate Central, Western Limb and Golden Hind pits. A total of 22,416.6 tonnes of ore and 41,204.5 tonnes of waste were produced during the 2015/16 reporting period. The Northern Waste Rock Dump (NWRD) received waste from the Old Pirate Central, South, East and Western Limb pits. The Southern Waste Rock Dump (SWRD) received waste from Golden Hind pit and Old Glory trench. Elements related to mining and their closure status are detailed below with details of the site layout presented in Figure 4-1:

Sandstone stockpiles (materials used for rehabilitation- then pads rehabilitated);

Pisolite stockpiles (materials used for rehabilitation- then pads rehabilitated);

ROM pads (removed for processing or placement on waste rock dump - then pads rehabilitated);

Topsoil stockpile (materials used for rehabilitation - then pads rehabilitated);

Haulage and access roads (roads no longer required have been rehabilitated);

Water pipelines and bores (retained for exploration purposes);

Mining contractors workshop offices and heavy vehicle parking area (no longer required sections have been removed and the area rehabilitated);

Operation of Wilson’s camp (majority of camp facilities removed), minor facilities remain for exploration use;

Explosives magazine area (removed and area rehabilitated);

Fire breaks (retained to protect remaining infrastructure);

Abandonment bunds around pits (completed); and

Drainage structures (only structures required at closure remain)

A Rehabilitation Report was lodged with the DPIR in June 2016, titled TWB-RP-ENV-001-TwinBonanzaRehabReport-1.0 outlining the rehabilitation activities undertaken.


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Figure 4-1. Left Map: Twin Bonanza Proposed Mine Site Layout. Right Map: Twin Bonanza Actual Site Layout


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Table 4-1: Stage 2 Open Pit Production Statistics for March – April 2016

Month Mar 15 Apr 15 May 15 Jun 15 Jul 15 Aug 15 Sep 15 Oct 15 Nov 15 Dec 15 Jan 16 Feb 16 Mar 16 Apr 16 TotalOld Pirate Central/Old Pirate South (Proposed) 0 5410 1229 4181 9183 9183 8072 8072 12150 9732 11209 2870 3775 2224 87290Old Pirate Central/Old Pirate South (Actual) 117 800 271 2270 9223 4292 6141 5290 9529 6946 271 24259 13556.5 78.6 83044Old Pirate East (Proposed) 0 0 0 0 0 0 0 0 0 0 493 493 1316 794 3096Old Pirate East (Actual) 1748 0 0 0 0 0 0 0 0 0 0 0 0 0 1748Western Limb (Proposed) 0 298 2117 0 2117 2372 0 2372 2455 2455 2354 0 0 0 16540Western Limb (Actual) 0 124 60 81 1863 3112 2387 1366 3436 1670 60 2157.31 2519.1 180.8 19016Golden Hind (Proposed) 0 732 732 1981 0 1981 3905 3914 2930 7336 5583 4446 3836 1444 38820Golden Hind (Actual) 269 0 5170 8593 10536 3533 6293 8358 5007 9830 5170 7202.3 6081.6 0 76043Total Proposed 0 6440 4078 6162 11300 13536 11977 14358 17535 19523 19639 7809 8927 4462 145746Total Actual 2134 924 5501 10944 21622 10937 14821 15014 17972 18446 5501 33618.61 22157.2 259.4 179851

Month Mar 15 Apr 15 May 15 Jun 15 Jul 15 Aug 15 Sep 15 Oct 15 Nov 15 Dec 15 Jan 16 Feb 16 Mar 16 Apr 16 TotalOld Pirate Central/Old Pirate South (Proposed) 136561 129504 135278 132165 128817 128817 129928 129928 126248 130577 128883 44529 33489 14690 1529414Old Pirate Central/Old Pirate South (Actual) 22230 28584 22692 20693 68598 46797 72466 47333 83903 28276 22692 23836.57 19058.26 0 507159Old Pirate East (Proposed) 0 0 0 0 0 0 0 0 0 22978 22403 22410 15934 5306 89031Old Pirate East (Actual) 5265 0 170 170 0 0 13655 0 0 0 170 0 0 0 19430Western Limb (Proposed) 30340 55132 55233 57429 55264 55128 57500 55128 55045 32046 32146 32422 33542 33632 639987Western Limb (Actual) 8117 75544 71709 71689 107538 135164 64617 95326 65948 26736 71709 36874.98 4646 0 835618Golden Hind (Proposed) 68726 67310 67375 67019 69000 67019 65094 65086 66070 61664 63417 41554 30664 12649 812647Golden Hind (Actual) 57495 93847 138446 135026 89683 104797 54636 49510 50973 47611 138446 26571.44 17500.47 0 1004542Total Proposed 235627 251946 257886 256613 253081 250964 252522 250142 247363 247265 246849 140915 113629 66277 3071079Total Actual 93107 197975 233017 227578 265819 286758 205374 192169 200824 102623 233017 87282.99 41204.73 0 2366749

Month Mar 15 Apr 15 May 15 Jun 15 Jul 15 Aug 15 Sep 15 Oct 15 Nov 15 Dec 15 Jan 16 Feb 16 Mar 16 Apr 16 TotalOld Pirate Central/Old Pirate South (Proposed) 136561 134914 136507 136346 138000 138000 138000 138000 138398 140309 140092 47399 37264 16914 1616704Old Pirate Central/Old Pirate South (Actual) 22347 29385 22963 22963 77821 51089 78607 52623 93432 35222 22963 48095.57 32614.76 78.6 590204Old Pirate East (Proposed) 0 0 0 0 0 0 0 0 0 22978 22896 22903 17250 6100 92127Old Pirate East (Actual) 7013 0 170 170 0 0 13655 0 0 0 170 0 0 0 21178Western Limb (Proposed) 30340 55430 57350 57429 57381 57500 57500 57500 57500 34501 34500 32422 33542 33632 656527Western Limb (Actual) 8117 75668 71769 71769 109401 138275 67004 96692 69384 28406 71769 39032.29 7165.1 180.8 854632Golden Hind (Proposed) 68726 68042 68107 69000 69000 69000 68999 69000 69000 69000 69000 46000 34500 14093 851467Golden Hind (Actual) 57765 93847 143617 143619 100219 108330 60929 57869 55980 57441 143617 33773.74 23582.07 0 1080589Total Proposed 235627 258386 261964 262775 264381 264500 264499 264500 264898 266788 266488 148724 122556 70739 3216825Total Actual 95242 198900 238519 238521 287441 297694 220195 207184 218796 121069 238519 120901.6 63361.93 259.4 2546603

Total Movement

Waste Movement

Ore Movement


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Dewatering and Water Requirements During mining, pit operations did not require dewatering as the water table was below the design floor of the pits. Temporary water storage in the pits could occur as a result of heavy rainfall similar to the >100mm within 48hrs event that occurred at the end of January 2016. This temporary inundation water is ephemeral with major losses to infiltration into the pit floor and assisted by evaporation.

There are no pit water quality issues expected with water from incident rainfall. Old Pirate open pit mining was a zero discharge operation, including rainfall captured in open pits. The relatively short duration of mining and the variable nature of the wet season make the construction of a dedicated evaporation structure unnecessary and impracticable.

As a result of changes to the Project scope, and off site processing, water requirements were substantially reduced, and supply was adequately serviced from the existing Wilson’s and Corsair bores, and Strezza’s/Timmy’s 2 bore which was commissioned during 2015.

From initial hydrogeological assessment, the three bores had the following measurable yields:

Wilson’s (bore number): 1.0 l/s Corsair (bore number): 1.3 l/s Strezza’s 2 (bore number): 5.0 l/s

During the mining period all three bores were utilised with the average extraction rates over a 365 day period given below:

Wilson’s (bore number): 0.18 l/s Corsair (bore number): 0.82 l/s Strezza’s 2 (bore number): 1.81 l/s

During the months when mining and heavy water usage occurred, total extraction rates varied from 3.3 to 4.4 l/s across the three bores. Placing the site on C & M has resulted in a substantially reduced water requirement which is met from Strezza’s bore for servicing Wilson’s Camp and regional exploration activities. Details of the reporting year’s water balance and estimates for the upcoming year are presented in Section 6.2.3.

During mining, water was used for dust suppression both on the ML and outside the ML along the access road (within Section 19 area) and on the Tanami Road. ABM took water from the raw water/dam and one other registered bore (RN018999) along the haulage route and outside of the ML. ABM was given permission/access from the NT Department of Infrastructure (registered bore owner) to use the additional bore.

In the last two months of mining, Wilsons and Corsair bores were decommissioned and Strezza’s/Timmy’s bore was used for mine activities and camp water usage. Further details of the water quality for each bore are presented in Table 6.4 and in the Annual Groundwater Monitoring Report (2018) prepared by Saprolite Pty Ltd- Groundwater Consultants. The Report is attached as (Appendix 3).

Two ROM pads were constructed, one for the Old Pirate Central / South / East and Western Limb open pits and one for the Golden Hind open pit and Old Glory trench (Figure 4-1). Material on both ROMs was removed either for processing or placement in the waste rock dump, and the cleared area rehabilitated.

As all ore, including low grade, was transported to the Coyote Mill for processing, the only ore stockpiles were the material present on the ROM at any given time. The construction of the ROM can be described as follows:

To minimise both haul distance and footprint, ROM pads were constructed adjacent to the abandonment bunds;


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The perimeter of the ROM was graded to create a moderate depression with a small, approximately 1m bund, to demarcate the stockpile area and provide a small sediment trap;

The ROM was then built up, leaving a 1m gap to the bund, toe to toe, by approximately 0.5m to ensure above general ground level and drainage during mining operations. Run of mine waste – inert intercalated sandstone / siltstone (SN) – was used to build up the ROM pads; and

With the ROM positioned to the west of the waste rock dumps their location is encompassed by planned water diversion structures.

Sediment captured from the ROM pad bund was sent for processing. All ore stockpiles were removed for processing, and the pad surface scalped for gravity values. The risk of potential leachates occurring following rehabilitation treatment is considered very low. Further to the closure rehabilitation treatment detailed above, no seepage monitoring was put in place for the ROM pads as it was deemed unnecessary. Overall seepage for the site is monitored by the installed bore network and surface water sampling. If an issue is identified during closure inspections, further management measures will be introduced.

Waste Rock Dump (WRD) As there are two existing waste rock dumps, this section will detail the actual design and construction methods of the waste rock dumps, and should be read in conjunction with the Waste Dump Management Plan (Appendix 6). Two waste rock dumps: NWRD encompassing 14.61 hectares and SWRD, encompassing 7.09 hectares were established. The NWRD received waste material from the Old Pirate, Central, South, East and Western Limb Pits and the SWRD from the Golden Hind Pit and Old Glory trench.

The two waste rock dumps sites were established via the following process:

Marking out of the designed clearing areas using timber pegs or cones and biodegradable flagging tape;

Preclearance inspection by site based personnel looking for potential bilby burrows that were not present during previous surveys. No burrows were detected;

An internal clearing permit was issued that required the heritage, sacred site and approvals to be checked. Once checked the machine operator was shown the on-ground area and the permit was signed off;

Vegetation was windrowed to form a bund around the perimeter to capture sediment during construction. Then clearing the top 100mm of topsoil from the area occurred. This was done by a loader or bulldozer with a blade pushing the top soil into rows for loading into trucks; and

Topsoil was placed in the designated topsoil stockpile.

The Site’s location in a semi-arid region that has an average of 430mm of rainfall a year and pan evaporation of 2,800mm had a major influence on the parameters employed during the waste rock dump design process. The tops of the waste rock dumps have been designed to contain water with the capacity to contain a 1:100 year 72 hour event that equates to 314mm of rainfall. The storage capacity of the top sections of the waste rock dumps has been achieved by the construction of a sloping surface (approx. 1.4%) draining into the centres of the dumps, this creates tops having a dish like shape. Internal bunds were created within this dish to distribute the pooling of water across a greater surface area to speed up evaporation.

Erosion testing (provided in the 2015 MMP) was undertaken on sandstone to understand the erosion behaviour from the direct detachment and entrainment of particle from incipient rainfall


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on the outer waste rock dump slopes. By allowing surface water (resultant from rainfall) to freely move from the top and down the sides of the waste rock dump a high potential occurs to have concentrated surface flow paths that are characterised by larger volumes and higher velocities of water leading to localised gullies and associated sediment plumes as seen during the Site rain event of 68mm on the 30 January 2016. The purpose of the inward draining top section design is to reduce the catchment area of the slope batters and to contain surface water so that the topsoil and growth mediums stabilise over time on the upper surfaces and slopes thus allowing the establishment of self-sustaining vegetation and reducing the potential for erosion.

In terms of the hydroecological functioning of the upper surface of the waste landforms at closure, this strategy of surface water management mimics the 'source-' and 'sink-zones' characteristics of patched arid-land ecosystems, as occur naturally in the site environs. Field trials undertaken within the Mt Whaleback iron ore mine in the Pilbara, WA, since the mid-1990s have shown that bare-ground evaporation alone (i.e. without transpiration from vegetation) is capable of drying to depths of at least 3-4 metres. These findings were from a ROM mine-waste materials which were reasonably well graded, and which were wetted to near field-capacity to 3+ m through successive unusually wet years (Maiers et al. 2010).

The height of the original waste rock dump designs was limited to 15m in line with discussions and advice from the CLC on behalf of the Traditional Owners. However, with mining not occurring to the full extent of the proposed pit depths, backfilling of the Old Glory trench and Old Pirate East pit, both waste dumps were only constructed to 10m above the natural surface.

The south (Golden Hind) waste rock dump (SWRD) was constructed to a single level of approximately 10m. The north (Old Pirate) waste rock dump (NWRD) has a north and south section which is constructed to 10m with a middle section being constructed to approximately 3m. This is in variance to the 2015 MMP where the waste rock dumps would have two levels and attain a height of 15m. Despite the variance in height of the constructed waste rock dumps compared to those proposed in the 2015 MMP, the construction methodologies employed when constructing the dumps were the same as that detailed in the 2015 MMP. This height variance is a function of the reduction in waste rock volumes mined. The 10m has been taken as the lowest point on the waste rock dump perimeter based on previous aerial surveys. There is little ground level difference at the south waste rock dump but at the north waste rock dump the ground RL varies from 447.5m to 450m, and thus the average height is lower than 10m.

The slope of the external waste rock dump batters is 1:4 (rise:run) which is just over 14 degrees from the horizontal and much less than the recommended 18 degrees, as a result of erosion modelling provided in the 2015 MMP.

During mining, sub-economic quartz (that has the potential to liberate arsenic and fluoride) and siltstone (that can erode over time) were selectively placed in the centre of the waste rock dumps. The segregation of the siltstone started by mapping of the pit floors by a geologist that identified the rock type, this information was communicated to the excavator and truck drivers with the material being trucked to the designated location in the waste rock dumps. In the case of the sub-economic quartz due to the potential nugget effect (possibility of containing course gold) identified quartz veins were selectively stockpiled and resampled before positioning in the waste rock dumps. The process detailing the management and resampling of sub-economic quartz veins was contained in Appendix 13. Preliminary reconciliations indicate that a total of 8,378 bank cubic metres (bcms) or 19,269 tonnes (using a specific gravity (SG) of 2.3) of quartz were placed in the SWRD and 10,689 bcms or 24,584 tonnes (using an SG of 2.3) for NWRD. This is in comparison to the total waste rock moved of 1,088,000 tonnes to SWRD and 1,406,000 tonnes to NWRD.


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Sandstone for the external batters that was originally defined by drilling was further refined during pit floor mapping. The sandstone units were marked up and the excavator operators were informed that this material was to be sent to the dedicated sandstone stockpiles. During excavation the excavator operator directed each of the truckloads that were excavated from the marked area to the sandstone stockpile areas.

Details of the construction phases are presented below. It is important to note that the phases had some overlap. Specifically, more than one type of material was going to the waste rock dump and therefore multiple tipping locations were used.

The waste rock dumps were completed in April 2016 and EFA monitoring is tracking the return of local province species. Construction phases 1-4 are shown in Figures 4-2 and 4-3 with details outlined in the following sections.

Phase 1- Completed

Phase 1a has established a 2m thick layer of inert intercalated siltstone / sandstone as a base, preventing long term interaction between the ground and any water flowing through the base of the waste rock dump with the higher arsenic material. It was during this time that some minor volumes of material were stockpiled on the waste rock dump footprint for relocation on top of the base layer once it had been completed.

Phase 1b for the SWRD established the first donut of intercalated siltstone / sandstone as a low arsenic perimeter. The lift will be up to 3.5m high depending on topography, and establish a level 10m wide top.

At Phase 1b of the NWRD, the initial height of the donut on the northern and southern side was approximately 10 metres. This change from the 2015 MMP was to build the donut as high as possible thus having the sub-economic quartz deep to the profile. After this had been completed the eastern and western sides were to be completed. However, as the gold grades weren’t as predicted a pit re-optimisation was undertaken in November/December 2015 which resulted in the Old Pirate Central and Old Pirate South pit depths being reduced by 10 and 25 metres respectively with less waste rock reporting to the NWRD. This has resulted in a NWRD design whereby the Eastern and Western sides of the phase 1b donut will only be above 3 metres.

Phase 2 - Completed

Phase 2 for the SWRD was completed, the construction of the first lift to 9m above topography being the lowest point. For phase 2a, the interior of the dump will be filled with a mix of:

Vein material – higher arsenic;

Siltstone – low arsenic/ with high erodibility; and

Intercalated siltstone / sandstone – low arsenic.

For phase 2b the next 3.5m high perimeter of intercalated siltstone / sandstone will be constructed similar to phase 1b.

In the case of phase 2 for the NWRD sub-economic quartz and siltstone was placed in the lower section in the centre between the north and south high ends with a mix of:

Vein material – higher arsenic;

Siltstone – low arsenic/ with high erodibility; and

Intercalated siltstone / sandstone – low arsenic.


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Phase 3 - Completed

Phase 3 saw the capping of both waste rock dumps with a 1m thick layer of low arsenic intercalated siltstone / sandstone.

Phase 4 - Completed

Phase 4 waste rock dump construction involved sandstone, pisolite and topsoil previously stockpiled, shifted to the waste rock dump for design completion.

A 0.5m to 1.0m thick mix of pisolite and topsoil were placed on the top of the waste rock dumps for Phase 4a.

For Phase 4b, a 2m thick layer of sandstone was placed on the side walls to stabilise the waste rock dumps from erosion.

Finally, a 1m thick layer rock mulch of mixed sandstone, pisolite and topsoil was placed on the top surface and sides for the establishment of vegetation with the shaping of the dish and internal bunds and perimeter bunds.

Prior to commencement of rehabilitation the final ratios of sandstone, pisolite and topsoil for the rehabilitation were sufficient, based on the available material.


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Figure 4-2. NWRD Construction.


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Figure 4-4. Plan View of the NWRD showing the 3D design and contour plan.


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Figure 4-5: Plan View of the SWRD showing the 3D design and contour plan.


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Figures 4-4 and 4-5 show the final rehabilitated designs that have been implemented. The environmental impacts and mitigation aspects associated with the waste rock dumps have been detailed in the risk assessment Section 5.6.2 and Waste Rock Dump Management Plan (Appendix 6) with associated waste rock geochemistry contained in Appendix 14 of the 2017 MMP.

Twenty three (23) waste rock samples across the range of lithologies encountered in the proposed pits underwent leaching via leach column testing to confirm the validity of the waste rock management plan. Testing confirmed the waste rock management plan was environmentally acceptable. Further information was provided in Appendix 14 of the 2017 MMP. Discussions on the geochemical characteristics and management of the waste rock are contained in the waste rock dump management plan. Details of the ongoing management of these impacts are contained in the Biodiversity Management Plan (Appendix 4), Water Management Plan (Appendix 7) and Erosion and Sediment Control Plan (Appendix 8).

Mining Reserves and Geology In April 2012, Prodigy completed its first resource modelling and estimation of the Old Pirate deposit. The resource estimation was subsequently revised in February 2013 and predicted an indicated and referral resource of 1,632,000 tonnes ore for 618,400 ozs of gold.

Following several months of production it became evident that recorded head grades were significantly short of forecast. Although a review was undertaken in November 2015, and the mine design was re-optimised resulting in reduced waste production, mining of the pits was completed in March 2016 with total production of 155,367t grading 5.9glt for 29,376 ozs of gold. The July 2016 revised material resource for this Old Pirate Deposit is presented in Table 4.2

For better comparison, the table previously reported in the 2015 MMP has been modified to reflect the depletion due to mining based on the pit shells as of the 31 January 2016 (Table 4:2).

Table 4-2: Old Pirate Revised Mineral Resource Estimate, July 2016.

Category Tonnes Gold grade Contained Ounces

Indicated 40,000 4.6 6,500

Inferred 720,000 4.7 108,500

TOTAL 760,000 4.7 114,900

ABM Resources NL 2016 Annual Report Table 5.0

Details of the mine geology have been discussed in Section 2.1.2.3. Mining and waste rock characterisation across the lithologies has highlighted that Potential Acid Forming (PAF) material was not present and as such no detailed block modelling of PAF is provided.

Mining Performance against Previous MMP In 2016, mining was largely in line with documentation provided in the previous MMP. Minor adjustments were undertaken as plans were implemented and new information or minor issues came to hand. Principal alterations include:

Due to lower than expected grades a re-optimisation study resulted in the Old Pirate

Central and Old Pirate South pits final depth being reduced by 10 and 25 metres respectively;


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22,416 tonnes of ore were mined during March 2016 – April 2016 where as it was proposed in the last MMP to mine 13,389 tonnes of ore, this difference resulted from the inclusion of ore from the ROM that was recovered, and final cuts along pit walls.

41,204.5 tonnes of waste were mined during March 2016 – April 2016 where as it was proposed in the last MMP to mine 179,906 tonnes of waste.

A map of the current/actual footprint for the 2016-2017 mining activities and the approved/proposed footprint lodged in the 2015 MMP are provided in Figure 4-1. Minor variations in shape and area of the clearance areas exist, however overall the actual footprint is 73.7ha less than that which was approved i.e. 104.78ha versus 178.48ha. A comparison between the actual and approved disturbance footprint is provided in Table 8-1.

Prior to mining only minor bulk sample costeans existed within the pit footprint. These costeans were either engulfed by the mining footprint or progressively rehabilitated by backfilling. Mining over the period generally conformed to the proposed pit designs except for the construction of the Golden Hind ramp that was moved further to the east and the final depth at Old Pirate Central, Old Pirate East and Old Pirate South pits, with these pits not reaching their proposed depths. A comparison of proposed pit designs and actual pits as surveyed at 31 January 2016 are provided in Figures 4-6 to 4-13.

From the 5 open pits and one (1) trench, mining was scheduled over a 14 month period, generally advancing at a vertical rate of 5m per month. However, due to lower than expected grades, mining was completed in 13 months with site rehabilitation running concurrently with final mining activities. The comparison of the proposed waste rock scheduled and actual waste rock movements on a monthly basis are presented in Table 4.1. Originally it was proposed that on average 250,000 tonnes were to be moved each month for the first 10 months, then declining during the remaining months. As seen in the Table 4.1, the mining rate fluctuated between 41,000 to 286,000 tonnes per month.

Both the final waste rock dumps constructed have retained the approved footprints, however they have varied from the original design in respect to height and shape due to the reduction in the volume of waste rock. Section 4.1.1 provides details on the changes.

The recovery of rehabilitation resources/materials including sandstone, pisolite and topsoil occurred systematically during operations with a large focus on recovering topsoil and pisolites at the early stages of mining with the focus then shifting to sandstone as the pits accessed the underlying geology. Volumes of encountered pisolites, topsoil and sandstone were generally as expected. These materials have been placed on finalised surfaces and slopes as rehabilitation progressed.


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Figure 4-6: Proposed Old Pirate Central, South and East Open Pits - Plan View


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Figure 4-7: Actual Old Pirate Central, South, and East Open Pits as at 31 January 2016 - Plan

View (Please note Old Pirate East has been backfilled)


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Figure 4-8: Proposed Western Limb Open Pit - Plan View


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Figure 4-9: Actual Western Limb Open Pit as at 31 January 2016 - Plan View


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Figure 4-10: Proposed Golden Hind Open Pit - Plan View


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Figure 4-11: Actual Golden Hind Open Pit as at 31 January 2016 - Plan View (note ramp moved

to the east from original design)


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Figure 4-12: Proposed Old Glory Trench - Plan View


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Figure 4-13: Actual Old Glory Trench - Plan View (now backfilled)


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Processing Activities Prodigy did not process ore on site as a lease agreement existed with Tanami Gold NL (TGNL) to use their Coyote processing plant and TSF. The Coyote minesite is located 77km by road (44km along the Tanami Road) from the Site across the border in WA. The processing of all gold ore was conducted in WA. All relevant approvals required with the WA Department of Mines and Petroleum (DMP), WA Department of Water (DoW) and WA Department of Environment Regulation (DER) were in force. Therefore no further processing details are provided.

Raw Water Dam The raw water dam was originally designed to hold gravity wash residues (no process chemicals used) produced during the 2013 trial mining program. Subsequently approval was given to use the facility as a raw water dam for Twin Bonanza mining. There is no external catchment associated with the dam. The top of the raw water dam is elevated approximately 1.5m above ground level at the highest ground level location and 2.7m above ground level at the lowest ground level location. The depth of the raw water dam, below top is approximately 5.5m.

Final constructed volumes for the dam are:

Total: 29,500m3

Above ground level: 10,800m3

Below ground level: 18,700m3

More than 1m below ground level: 12,702m3 (tailings capacity)

The total lined surface area, including the dam surface is 8,660m2. The top of the raw water dam, including unlined surface area is approximately 9,600m2 and this area can be considered as the maximum possible catchment. The dam is empty for most of the year, temporarily holding limited water during the wet season. The dam (Figure 4-14) is centred at 776,7120N and 516190E (MGA Zone 52).

The dam integrity is inspected annually as part of the site C & M inspection undertaken by the Prodigy Site Manager. No issues with the storage were reported during the DPIR Inspection on the 27 September 2017 (MR2017/0332) or the Site Manager’s inspection in August 2018, when it was noted the dam was dry.


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Figure 4-14: Aerial photograph of the raw water dam in 2014. Note extent of deposited gravity tailings.

Design and Construction Method. For the 2013 bulk sample trial mining program the raw water dam was designed to hold all gravity wash residues (GWR) 1m below ground in preparation for potential rehabilitation. The raw water dam has a 1V:5H internal slope on the western side, both internal and external, to allow egress in and out as well as potential future vehicle access. Other walls are approximately 1V:2H.

Material was removed from the footprint and placed on the wall in approximately 0.75m lifts/intervals. This material was then compressed through the traffic of machinery (truck, loader and excavator).

The raw water dam was lined using a 2mm HDPE liner and underlain with a geotextile fabric. The liner was secured in a key trench around the top of the dam (Figure 4:15).


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Figure 4-15: Cross section through existing raw water dam.

Design Specifications (Standards).

The dam was designed and built to contain all gravity wash residues below ground and operate with the water level at or below ground level. It was HDPE lined with all joins tested for leaks. The raw water dam was constructed for below ground storage and therefore dam failure was not contemplated. No cyanide or hazardous chemicals were used in processing and the dam effectively contains milled near surface material (sands) and for short periods, rainwater.

The facility was constructed below ground with sufficient volume and freeboard to allow for the future conversion of the facility into a raw water dam for the expanded project as the dam was unsuitable for use as long term storage for process tailings. The residue contained in the dam may still retain sufficient gold to be of economic value and at some point in the future it is possible that this material may be reclaimed for further processing.

4.2.2.1 Source of Construction Materials Material for the construction of the embankments was sourced from the material excavated as part of the below ground construction of the dam. Excavated material consists of transported cover, weathered granite and other oxide material.

4.2.2.2 Estimated Flood Heights A flood modelling assessment around the Site illustrated that the convex shape of the overall landform (i.e. low potential for flow concentration), high position in the landscape, small catchment areas, and soil type would have no inundation of greater than 10cm depth across the Site provided that onsite drainage was implemented appropriately.

For longer term Site layouts, calculated highs for drainage design were based on concentrated/peak flow rather than flooding depths. Each design incorporated the predicted flow depth plus a safety factor.

4.2.2.3 Erosion Protection There is no specific erosion protection for the external embankments of the raw water dam. During the period erosion occurred along the external batters. At defined locations erosion monitoring has been undertaken. Monitoring highlighted that during larger rain events >15mm erosion gullies have been increasing in size. Prior to earthmoving equipment leaving site in April 2016 remediation of the gullies occurred with competent material used as armouring. Around the processing plant a small windrow was constructed to prevent sediment liberating into the environment.


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4.2.2.4 Spillway design and construction. There is no spillway associated with the raw water dam.

4.2.2.5 Sub Drainage and Collection Sumps. Due to the low permeability of the HDPE liner and quality assessment to confirm that construction met design specifications, no sub drainage or collection sumps have been installed.

4.2.2.6 Residue Quantities Generated. There is approximately 8,100t of GWR material stored in the raw water dam. There is no intention to increase the amount of material stored. It is expected that as the material may still retain economic grade due to gravity recoveries only attaining 85%. The material may be reprocessed in the future.

4.2.2.7 Character of Contained Water. Over the mining period the water quality in the raw water dam has largely reflected the composition of the abstracted bore. Early in the reporting period water was sourced from Wilsons and Corsair bores that resulted in the Total Dissolved Salts (TDS), arsenic, uranium and fluoride being 6,160 mg/L, 0.119 mg/L, 0.045 mg/L and 0.9 mg/L respectively. Later in the period the main water input was from Strezza’s bore and incident rainfall which resulted in a decline in TDS, arsenic and uranium to 1,160 mg/L, 0.049 mg/L, 0.012 mg/L respectively while fluoride increased to 1.2 mg/L.

Water quality monitoring results (ph and TDS) for the raw water dam to December 2016 are presented in Appendix B of the Annual Groundwater Monitoring Report 2018 (Saprolite 2018) referenced in Appendix 3).

Exploration Activities During the 2017/18 Reporting Period no exploration activities were undertaken in the Project Area. The focus of on-ground activities was the post closure biodiversity monitoring of rehabilitated landforms and disturbed mining areas and the remediation of erosion at the Golden Hind perimeter drain. All previous exploration disturbances across EL28322 and ML29822 have been rehabilitated and their status reported. The 48 holes at the Buccaneer Prospect described in previous MMPs as requiring removal of cuttings were rehabilitated in September 2017. A rehabilitation report, titled TWB-RP-ENV-001-Twin Bonanza and Regional Targets Rehabilitation Report-1.0 was lodged with the previous 2016/17 MMP. Table 4-3 provides a summary of historical exploration activities and rehabilitation.


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Table 4-3: A Summary of Historical Exploration and Disturbance Rehabilitation – 2010 to 2015

TOTAL KNOWN APPROVED GROUND DISTURBING EXPLORATION 2010 to 2015

Exploration Licence Prospect

Approved RC Drill Holes

Approved Diamond

Holes

Drill Pad Clearing

(Ha) Costeans -

Trench's (m3) Line Clearing (km)

ML29822 Tenement Wide 1855 47 13.9 27,490 11.33

EL28322 (Formerly SEL23661 & EL22228)

Tenement Wide 256 47 10.64 20,420 24.7

TOTAL GROUND DISTURBING EXPLORATION TO DATE

Exploration Licence Prospect

Completed RC Drill Holes

Completed Diamond Drill

Holes

Drill Pad Clearing

(Ha) Costeans -

Trench's ( m3 ) Line

Clearing (km)

RCDDrill

Holes

ML29822 Tenement Wide 645 8 8.43 4,236 0.5 0


Tenement Wide 401 4 24.5 7,491 23.5 7

TOTAL REHABILITATION TO DATE

Exploration Licence Prospect RC Drill

Holes Diamond Drill

Holes Drill Pad Clearing

(Ha) Costeans -

Trench's ( m3 ) Line

Clearing (km)

RCDDrill

Holes

ML29822 Tenement Wide 597 8 8.31 4,236 0.5 0


Tenement Wide 401 4 24.5 7,491 23.5 7

Proposed Exploration Activities for 2018/19 There are no proposed ground disturbing exploration activities scheduled for the Twin Bonanza project (EL28322 and ML29822) in 2018/19 as Prodigy is continuing its efforts to divest the Twin Bonanza project.


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ENVIRONMENTAL MANAGEMENT

Environmental Management Structure The environmental management structure for Twin Bonanza is detailed in Figure 1-2. As outlined in Section 1.1.1 the Managing Director together with advice from external consultants are responsible for implementing, resourcing and maintaining environmental management as documented in this MMP.

It is also the responsibility of Prodigy employees, consultants and contractors when delegated to perform any duties that may potentially impact on the environment that they undertake those duties in accordance with the requirements in this 2018 MMP and supporting documents. Additionally, all persons have a general duty to prevent environmental harm. If environmental harm, or potential to cause environmental harm, is observed, personnel are required to (a) report all environmental Incidents to their Supervisor or the Site Manager, who must record them in the Site Register, and in accordance with Section 29 of the Mining Management Act must report them to the Chief Executive Officer of the DPIR (Variation of Authorisation 0909-01 Attachment A – MR2017/0332) of October 16, 2017.

Environmental Policy Prodigy recognises its responsibility to conduct its operations in an environmentally responsible manner. The Company is committed to environmentally acceptable and sustainable activities, to be achieved through consultation with the various regulatory bodies, the community and other stakeholders.

Prodigy, its employees and contractors are collectively accountable for preservation of the natural environment and minimisation of any impact their activity may have on the surrounds of the locations in which the Company has a presence.

It is Prodigy’s policy that it shall tread lightly when undertaking its exploration and mining activities, maintaining a constant regard for all others who depend upon the preservation of the surrounding environment, and maintaining an awareness of Corporate rehabilitation obligations.

Prodigy’s corporate Environmental and Community Policy is provided in Figure 5-1:


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Figure 5-1: Prodigy's Environment Policy.


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Environmental Commitments

Commitments Contained in the 2017 MMP Environmental commitments made by Prodigy in the 2017 MMP are detailed in Appendix 9. This section should be read in conjunction with the Environmental Management Plans contained in Section 5.6.7.5 that provide greater details. Performance will be measured against these commitments in subsequent MMPs.

Compliance with Previous Commitments (Authorisation 730-01 and 0909-01) Environmental commitments were made by Prodigy within the 2017 MMP, including responses to feedback from the DPIR. Appendix 10 details the performance measured against the commitments made in 2017 and the compliance achieved since the lodgement and approval of the September 2017 MMP.

5.3.2.1 Environmental Inspections During operations to 30 March 2016, Prodigy conducted fortnightly environmental inspections across the Site. The findings of Prodigy’s inspections completed during the reporting period are summarised in Table 5:1. The inspections were conducted between February 2015 and April 2016. Once operations ceased, there were no onsite personnel to conduct inspections. In June 2016 Perth office environmental personnel conducted a final site inspection while conducting 6 monthly biodiversity monitoring survey and a site inspection was undertaken in August 2016 by WCPL during a regulatory inspection by DPIR Officers.

The pilot processing plant infrastructure and Wilson’s camp remain, with the camp being occupied for short term use by exploration personnel who will continue to monitor site maintenance.

Table 5-1: Environmental Inspection Findings Prior to Transition to Care and Maintenance

During 2016 ABM was compliant in the following categories:

Air Quality Monthly dust monitoring completed

Dust mitigation methods implemented

Cultural Heritage

No disturbance to the heritage area occurred during operations

Fire Prevention Controlled burning undertaken

Firebreaks maintained

Flora and Fauna Management Maintenance of fauna register

Maintenance of clearing permit register and issuing of clearing permits

Groundwater Monthly groundwater monitoring (extraction, SWLs etc.)

Regular inspections and maintenance of pipelines

Hazardous Materials


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During 2016 ABM was compliant in the following categories: Chemicals, fuels and hydrocarbons stored appropriately Spill kits placed around site and maintained Hydrocarbon contaminated soils placed in bioremediation pad

Hazardous materials stored appropriately

Rehabilitation – Program Completed

Completion of rehabilitation of the project according to approved conditions

Socio-Economic Complaints register regularly maintained – no complaints received

Stakeholder engagement undertaken with CLC and Traditional Owners

Surface Water – Monitored by Exploration Team Regular inspections of water storage dam and water management around site Fauna egress matting placed on dam walls Regular maintenance of sullage ponds, sewage pipes and freeboard Monthly potable water sampling (ceased in April 2016) Regular dosing/monitoring of chlorine in potable water (ceased in April 2016, exploration team to continue on as needs basis)

Waste Management – Managed by Exploration Team Regular rubbish pick up and general site cleanliness maintenance Responsibility of exploration team Burning of rubbish at landfill every second day and regular inspections/tidying of landfill Recycling of glass, aluminium cans and aerosol cans

Hydrocarbons disposed in appropriate hydrocarbon bin for disposal offsite

Weed and Pest Management Regular control of buffel grass (weed campaigns ceased in April 2016, exploration team to monitor weeds)

Regular control of pests (cat control and house mice control) Program ceased with Care and Maintenance

Erosion and Sediment Control – Monitored by Consultants and Exploration Team Regular inspections of potential erosion sites (water dam etc.) and installation of photo monitoring sites in higher risk areas. In the previous MMP several housekeeping issues required action in order to achieve compliance acrossthe Twin Bonanza Project: Avgas not stored correctly on bunded pallets - has since been rectified. Dust was an ongoing issue needing constant management (now that operations have ceased, dust will no longer be an issue) Ongoing hydrocarbon management could be improved – storage and disposal offsite (this was rectified and all hydrocarbon waste has been taken offsite)

Following the transition to Care and Maintenance, regulatory inspections of the TWB minesite have been undertaken by DPIR Officers on three occasions: in August 2016, on the 20th September 2017 and on the 2nd May 2018. Aspects requiring remedial attention have included a requirement for additional monitoring of potential erosion on the north-west landform, erosion control measures in the perimeter drain around the Golden Hind Pit, removal of vegetation encroaching on Wilson Camp infrastructure and a recommendation to undertake additional photomonitoring in rill prone areas on the northern waste rock landform. Prodigy has undertaken corrective action through Environmental Improvement Plans with correspondence referenced in Appendix 1.


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Recommendations Resulting from Formal Environmental Assessment Twin Bonanza underwent a formal environmental impact assessment under the NT Environmental Assessment Act 1982 (Assessment Report 74) and also under the Environment Protection and Biodiversity Conservation Act 1999 via Commonwealth jurisdiction (reference EPBC 2013/6784). Final approval for Twin Bonanza was given in July 2014.

Following completion of obligations under EPBC 2013/6784 when the project was placed on Care and Maintenance in April 2016, ABM applied to the DoEE Environmental Standards Division to cease Annual Compliance Reporting. DoEE approval to cease monitoring and compliance reporting was received on 18 August 2017 and is referenced in Appendix 1.

NT EPA recommendations and Commonwealth Government conditions of project approval were detailed in Appendix 19 of the 2017 MMP. To ensure consistency across approval documents this 2017/18 MMP has been written to incorporate the EIS assessment outcomes and performance against these recommendations/outcomes.

Environmental Training and Education All new employees, contractors and visitors to Prodigy sites or properties are required to undergo an induction that details the environmental elements and requirements relating to the Tanami region.

The induction includes the following items: 1. Understanding of the environmental and social principles and their obligations behind the

Environmental Policy, MMP and commitments;2. Knowledge of relevant legislation and discussion of the consequences of breaching

legislative requirements;3. Understanding of requirement to conserve and cause no harm to significant native fauna of

the Tanami region;4. Understand the principles behind Prodigy’s approach to flora and vegetation management

and the requirement to minimize clearing;5. Knowledge of erosion control methods and responsibilities;6. Knowledge of the storage and handling requirements for chemicals, fuels and other

potentially polluting substances;7. Knowledge of waste disposal requirements and the need to adopt housekeeping habits

that minimize access for vermin(especially feral cats and foxes) to disposal sites8. Knowledge of spill management procedures,9. Respect for aboriginal cultural heritage and an understanding of avoidance requirements

for identified sites, and10. Knowledge of environmental incident reporting procedures.

Informal environmental onsite training was conducted by Senior Managers and Consultants to ensure consistency in approach during Care and Maintenance at the Wilson Camp and during biodiversity monitoring activities.


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Environmental Emergency Preparedness and Response Prodigy has an Emergency Response Management Plan (ERMP) which has been written as a component of the Prodigy safety management system and encompasses environmental responses to emergencies for Twin Bonanza and surrounds (Appendix 11). The ERMP has been updated to reflect the care and maintenance/closure phase of the project. The ERMP details the:

emergency preparedness, and prevention;

resources and measures;

response procedures and recovery; and

post-emergency activities specific to mining activities.

The ERMP applies to all personnel working with, or under contract to, Prodigy at Twin Bonanza and is a requirement of the NT Work Health and Safety (National Uniform Act) 2011 under Division 2 Primary Duty of Care. OH&S is administered through NT WorkSafe under the legislative requirements of the NT Work Health & Safety (National Uniform Legislation) Act and Regulations; however some actions required may be similar for either an environmental or occupational emergency.

The aims of the ERMP are to: 1. prevent subsequent injury or loss of life; 2. minimise property loss, damage to equipment and the environment; 3. provide a chain of command to ensure that there is a prompt and coordinated approach to

emergency situations; 4. ensure all necessary equipment, personnel and other resources are available for effective

control of an emergency situation; and 5. ensure all personnel are aware of their responsibilities in the event of an emergency.

The ERMP covers the following emergency events: 1. injury / medical emergency / fatality; 2. fire; 3. explosion; 4. pit wall failure; 5. flood / sediment dam failure and overflow of ponds; 6. hazardous chemical / material spills or releases; and 7. vehicle accident.

The ERMP provides step-by-step guidance for the management of any emergency such as fire, flood, dam collapse, fuel spill and explosion, which can impact the site. Emergency procedures are reviewed annually for relevance and effectiveness. Changes arising at any time are communicated to all employees and contractors through regular safety meetings.

Implementation, Monitoring and Review

Identification of Environmental Aspects and Impacts An assessment of the risk of each of the environmental aspects and impacts for the C&M phase is provided in Section 5.6.2 and Environmental Management Plans (EMPs) designed to mitigate and manage loss events are provided in Section 5.6.7.5.


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The risks associated with the development, construction and operation of project identified by the NT EPA in the EIS can be summarised as follows:

change to socio-economic environment;

damage and degradation of cultural heritage values;

fragmentation and degradation of threatened fauna species habitat;

reduction in the quality and quantity of surface and ground water; and

liability and negative legacy at closure.

Breaking the above broad scale hazards down, a list of the environmental aspects and impacts identified for Twin Bonanza during operations are presented in Table 5.2. A more extensive risk assessment is presented in Appendix 12.

Table 5-2: Aspects and Potential Impacts Associated with Activities.

Aspect Potential Impact/Hazard

Surface and ground water

Improper storage and handling of hazardous materials and hydrocarbons

•Contaminated ground water and surface water

Failure of raw water dam wall •Inundation of flora from tailings •Contamination of surface water •Death of any present fauna

Water dam pipeline leak •Contamination of surface water •Death or injury of any present fauna

Liberation of sediment from waste rock dumps •Increased turbidity in surface water

•Smothering of flora and fauna

Liberation of leachates from waste rock dump and workshop area.

•Contamination of ground and surface water •Flora and fauna exposed to environmental contaminates

Liberation of hydrocarbons and other chemicals from processing plant (existing bulk sample plant)

•Contaminated ground water and surface water •Secondary detrimental impacts on plants

Uncontrolled waste disposal - solid waste & sewerage (existing camp)

•Fauna deaths •Potential eutrophication of surface water during rain events •Illness from waterborne diseases •Contamination of ground water from solid wastes

Water extraction beyond sustainable yields •Detrimental effect on groundwater dependent ecosystems flora and fauna.

Biodiversity (including threatened species)

Vegetation clearing activities •Reduction in habitat availability for flora and fauna •Fragmentation of habitat •Increases erosion by wind and water •Fauna injury and mortality

Reduction and/or fragmentation in threatened species habitat

•Decline in population dynamics of threatened species

Failure to implement mitigation and management •Poor clearing techniques


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Aspect Potential Impact/Hazard

measures •No recovery of topsoil •Increased wind and water erosion

Improper driving practices leading to fauna deaths, increased risk of vehicle collisions outside of the disturbance area

•Fauna fatalities and injury

Driving off designated tracks leading to flora and fauna damage

•Inadvertent damage to habitats and individuals including damage to bilby burrows.

Failure to place fauna egress matting in existing raw water dam)

•Fauna deaths

Poorly managed site equipment hygiene leading to the potential incursion of weeds

• Reduced habitat quality for native flora and fauna • Reduced biodiversity values • Increased fuel load, fire frequency and intensity • Increased presence of out competing weed species

Improper disposal of putrescible and general waste •Increase in dingo and cat populations placing pressure on threatened species

Improper practices leading to unsuitable fire regimes •Hot fire burns resulting in slow recovery of vegetation and habitats •Potential for fauna deaths and injury •Erosion generated from loss of vegetation

Community / employees - cultural & health safety

Failure to protect cultural heritage and aboriginal archaeological sites

•Destruction of cultural and scientific values •Lead to prevention of traditional practices

Inappropriate staff activities leading to environmental incidents

•Vegetation destruction •Fauna deaths and injury •Uncontrolled chemical / hydrocarbon spills

Operations inhibit traditional land management practices

•Restriction of access to sites of cultural significance and land use

Poor implementation of approved environmental management processes and mitigation measures

•Environmental degradation across the entire ecosystem

Failure for contractors and consultants to adhere to environmental management and mitigation requirements

•Environmental degradation across the entire ecosystem

Air quality and noise / vibration

Unacceptable levels of dust generated

•Staff health issues •Vegetation smothering and secondary effects on fauna

Rehabilitation

Poor life of mine planning •Failure to optimise rehabilitation leading to environmental degradation.

Failure to undertake progressive rehabilitation •Increasing economic, social and environmental liabilities

Inappropriate resourcing for rehabilitation •Failure to optimise rehabilitation leading to environmental degradation

Premature mine closure •Erosion, non-sustainable ecosystem •Increased cost to regulatory agencies and community for inappropriate rehabilitation.


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Risk Assessment The objectives of the risk assessment are specifically designed to:

identify the hazards and resultant risks from the Project and potential threats from aspects to the Project;

rank and prioritise risks through a risk assessment process; and

evaluate the risks and identify sensible management measures to mitigate the risks. This risk assessment describes the process and presents results of an assessment of the risks associated with identified aspects and potential impacts of the project. It is designed to identify the potential hazards that affect human health, the socio-cultural environment, and the natural environment. The approach is systematic and congruous with international best practice standard methodologies including:

AS/NZS ISO 31000:2009: Risk management— Principles and guidelines (Standard);

HB 203:2006: Environmental risk management — Principles and process (Guide); and

HB 158:2010: Delivering assurance based on ISO 31000:2009 — Risk management – Principles and guidelines (Guide).

The tolerable risk approach using the ‘As Low As Reasonably Practicable’ (ALARP) concept in line with AS/NZS ISO 31000:2009 was adopted to identify and rank potential risks according to the ability of the operation to manage the risk. This method identifies risks that are either:

Intolerable; o risk cannot be justified or managed;

tolerable; o risk can be managed; o acceptable; and o risk is minimal and requires little if any intervention or management.

Risk management measures to be implemented aim to reduce significantly the likelihood, and seek to eliminate any potentially extreme or high risks to people and the environment.

A regular review of risk assessment will also be conducted to ensure that it remains appropriate and to incorporate any changes.

Risk Management Process When considering risk mitigation for safety hazards including those in the mining industry, the hierarchy of controls provides a useful guide for determining appropriate controls. This is a commonly used set of control principles, applied across the industry in the mitigation of safety hazards. In the case of ABM, these principles have been extended to environmental hazards. The hierarchy applies a prioritised order ranging from elimination, (the most desirable strategy), to personal protective equipment, (the least desirable strategy).

The more significant the risk, the higher the control strategy from the hierarchy, or combination of control strategies should be applied. The ultimate aim is to eliminate hazards and their subsequent risk or, if this is not possible, to minimise exposures to as low as reasonably practicable: 1. ELIMINATION - Remove or avoid the hazard completely, i.e. cease using a device, tool,

practice etc.; 2. SUBSTITUTION - Replacing with a safer alternative;


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3. ISOLATION - Separating the hazard from the person, environment or process at risk by isolation, guarding, barricading, alternate duties etc.;

4. ENGINEERING CONTROLS - Constructing new devices to reduce risk, e.g. ergonomic devices, shock absorbent mats, robotics, etc.;

5. ADMINISTRATIVE CONTROLS - Promote awareness of hazards. Delineation - signage, procedures, training etc.; and

6. PERSONAL PROTECTIVE EQUIPMENT (PPE) - PPE is considered only when other controls are not practical or to increase protection.

Risk Methodology The ranking for event consequence is shown in Table 5:3. The likelihood of an event occurring provides a measure of the known or anticipated frequency of occurrences (Table 5:4). Combining likelihood with consequence provides guidance on risk levels of each aspect and enables ranking of priorities (Figure 5-2).

Table 5-3: Risk Matrix Measure of Consequence.

Consequence

1 Insignificant

Limited/rectifiable impact within project boundary Contained and recoverable minor environmental incident <10m2 Very small number of individuals (1%) in local population of non-significant or significant species may be affected First aid attendance / no lost time Internal process delay < 1 day, <$2k loss Will not affect a critical or high value asset

2 Minor

Minor reversible short term impact at local level Small environmental footprint (<20m2), area easily rehabilitated with no lasting effects. Small number of (<10%) of individuals in the local population of non-significant or significant species may be affected First aid treatment lost time injury < 2 days Internal business impacts, <$20k Loss, < 2 day delay in operation A minor affect to a critical or high value asset

3 Moderate

Major but reversible short term impact. Little/no impact on ecosystem function. Offsite/regional disturbance Large environmental footprint (100m2), no lasting effects, good outlook for recovery. A significant species is affected but not significantly. Disturbance, but reversible, short term impact to <50% of individuals in the local population Medical treatment and/or impairment, lost time injury > 2 days Damage to business reputation, > $40k loss. Reduced ability to operate (stop work). A critical asset is affected but not significantly. A high value asset is significantly affected.

4 Major

Serious long term impact at regional level Large environmental footprint (<=500m2), long term effects, medium outlook of recovery. Major loss to significant species at the local level. Disturbance with long term impact to >50% of individuals in the local population Permanent disability Damage to business reputation, <= 2 million dollar loss. Temporary suspension of authorization. Critical asset is significantly affected

5 Catastrophic Irreversible impact at regional level Largest environmental footprint (>500m²), lasting effects, poor outlook on recovery.


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Consequence

Extinction of species regionally Fatality Lasting damage to business reputation, > 2 million dollar loss. Operations shut down. Loss of major portion of critical asset at the regional level

Table 5-4: Qualitative Measures of Likelihood.

Probability/Likelihood Likelihood Criteria

A Rare:Practically impossible, will only occur in exceptional circumstances. Has never occurred in the industry. 0-1%

B Unlikely:Will probably not occur in most circumstances. Could occur at some time but highly unlikely. Has occurred in the industry previously.

1-10%

C Moderate: Might occur at some time. Has occurred in associated companies previously. 11-50%

D Likely:Known to occur or will probably occur in most circumstances. Has occurred several times/year in associated companies.

51-90%

E Almost Certain:Common or repeating occurrence. Is expected to occur several times/year in any associated business. Imminent – or expected in near future.

91-100%


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Figure 5-2: Risk Rankings from Combined Consequence to Likelihood.

Extent of Impact Environmental Species / Biodiversity Health and Safety Business Critical Test

15 19 22 24 25 5 CatastrophicIrrevers ible impact at regionallevel

Largest environmenta l footprint(>500m²), lasting effects , pooroutlook on recovery.

Extinction of species regiona l ly Fata l i tyLasting Damage to bus iness reputation,> 2 mi l l ion dol lar loss . Operations shutdown.

Loss of major portion of cri tical asset atthe regiona l level

10 14 18 21 23 4 MajorSerious long term impact atregiona l level

Large environmental footprint(<=500m2), long term effects ,medium outlook of recovery.

Major loss to s igni ficant species at the local level .Di s turbance with long term impact to >50% ofindividua ls in the loca l population

Permanent disabi l i tyDamage to bus iness reputation, <= 2mi l l ion dol lar loss . Temporarysuspens ion of authorization.

Cri tical asset is s igni ficantly affected

6 9 13 17 20 3 Moderate

Major but revers ible short termimpact. Li ttle/no impact onecosystem function. Offs i te/regiona l dis turbance

Large environmental footprint(100m2), no lasting effects , goodoutlook for recovery

A s igni ficant species is a ffected but not s igni ficantly.Di s turbance, but revers ible, short term impact to <50%of individual s in the local population

Medica l treatment and/or impairment, losttime injury > 2 days

Damage to bus iness reputation, > $40klos s . Reduced abi l i ty to operate (stopwork).

A cri tica l asset is affected but nots igni ficantly . A high va lue asset iss i gni ficant affected.

3 5 8 12 16 2 MinorMinor revers ible short term impactat loca l level

Smal l environmental footprint(<20m2), area eas i lyrehabi l i tated with no lastingeffects .

Smal l number of (<10%) of individual s in the loca lpopulation of non s igni ficant or s igni ficant speciesmay be affected

Firs t aid treatment lost time injury < 2 daysInterna l bus iness impacts , <$20k Loss ,<2 day delay in operation

A minor affect to a cri tica l or high va lueasset

1 2 4 7 11 1 InsignificantLimited/recti fiable impact withinproject boundary

Conta ined and recoverableminor envi ronmenta l incident<10m2

Very smal l number of individua ls (1%) in loca lpopulation of non s igni ficant or s igni ficant speciesmay be affected

Firs t aid attendance / no lost time Interna l process delay < 1 day, <$2k lossWi l l not affect a cri tical or high va lueasset

A B C D E Likel ihood scale

Rare Unlikely Moderate Likely Almost Certain Likel ihood descriptor

0 1% 1 10% 11 50% 51 90% 91 100% Probabi l i ty (%)

Practica l lyimposs ible, wi l lonly occur inexceptiona lci rcumstances .Has neveroccurred in theindustry.

Wi l l probably notoccur in mostci rcumstances .Could occur atsome time buthighly unl ikely.Has occurred inthe industryprevious ly.

Might occur atsome time. Hasoccurred inassociatedcompaniesprevious ly.

Known to occur orwi l l probablyoccur in mostci rcumstances .Has occurredsevera ltimes/year inassociatedcompanies .

Common orrepeatingoccurrence. Isexpected to occurseveraltimes/year in anyassociatedbus iness .Imminent – orexpected in nearfuture.

Likel ihood defini tion

RISK LEVELExtreme

High

Moderate

Low

Consequence descriptors ( risks may present consequences to multiple descriptors)

Acceptable Manage by routine procedures

Tolerable or acceptable Management respons ibi l i tyspeci fied

Intolerable or tolerable Senior managementaccountabi l i ty

In tolerable Immediate action required

Likelihood

Conseq

uence

Based on AS/NZS 4360: 2004 5 X5 Risk Matrix

AS/NZS 4360: 2004Guideline Risk Treatment

Minor mitigation may be required but usua l ly adequately addressed in EMP as routine controls

Some mitigation required

Substantia l modification and/or miti gation required

Potentia l ly unacceptable, major modification of proposa l required


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Existing Operations Prodigy’s risk management procedures require the maintenance of a site hazard and risk register to ensure that any potential risk to the safety, health, environmental and business aspects of the operation are minimised. The register is formally reviewed by systematically identifying the potential hazards during all aspects of operations and putting in place measures to mitigate hazards. Steps taken to achieve this are be detailed below: 1. assessing the risks; 2. documenting how they are to be controlled; and 3. identifying any actions required.

The constant updating of the register provides a mechanism to keep a track of developing issues and hazards. This in turn allows management to be adaptive in mitigating future hazards. Additionally, continuously reviewing the register will ensure final detailed design and operating plans are specifically evaluated prior to commencement to confirm mitigation measures are suitable.

Risk Assessment of Operations Appendix 12 details the key risks and hazards associated and identified with the current and works. These tables also give brief details on the management measures to mitigate risks and hazards, with the column titled “Applicable Management Plan” referencing Prodigy’s Management Plans that are contained in this document that provide further detail.

Environmental Management Plans (EMP) As part of the EIS process, as detailed in Section 5.3.3, a number of Environmental Management Plans (EMPs) for the proposed development of Twin Bonanza were developed and are listed below. These EMPs have received NT EPA approval and outline mitigation and control measures to be used to prevent and minimise environmental impacts that have been identified in the risk assessment matrix. The plans were revised in 2016/2017 to reflect the change in project status to Care and Maintenance, the completion of rehabilitation of the minesite and landforms and risk input from Government Agencies and stakeholders that were consulted during the period. The Plans that related specifically to previous operational activities (shown in Italics below) are not included as appendices to this 2017/18 MMP. They are available upon request from the Land Manager at the contact address listed on page 14.

1. Biodiversity Management Plan; 2. Water Management Plan; 3. Mine Closure Plan; 4. Care and Maintenance Plan; 5. Erosion and Sediment Control Plan; 6. Hazardous Substances Management Plan; 7. Vehicle Management Plan; 8. Social Impact Management Plan; 9. Cultural Heritage Risk Management Plan; 10. Fire Management Plan; 11. Ground Disturbance Management Plan; 12. Noise Management Plan; 13. Biting Insects Management Plan;


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14. Air Quality Management Plan; 15. Emergency Response Management Plan; and 16. Waste Rock Dump Management Plan (was not part of the original EIS documentation but

has been formulated for the MMP)

To facilitate remedial actions while the site is on Care and Maintenance, Environmental Improvement Plans (EIPs) have been introduced into the EMP process. EIPs typically identify the reason for the action, the context and tasks to be undertaken within a nominated timeline. EIP 2016/01, 2016/02 and EIP 2017/01) have been prepared covering

(a) additional establishment of photomonitoring stations at sites with potentially higher risk of erosion;

(b) remedial erosion control activities for the Golden Hind Pit perimeter drain; and

(c) review of adaptive management options for eroding sites identified in annual biodiversity monitoring and regulatory inspections.

The following EMP tables cover the current mining operations as well as the 2017/18 MMP Reporting period. The EMP tables provide a succinct summary of what is contained in the EMPs contained in Appendices 6, 7, 8, 15, 16, 22, 25, 33-38 and outlines the achievement of objectives and targets; management of environmental impacts, compliance with regulatory requirements and adherence to Prodigy’s environmental policy.

5.6.7.1 Structure of EMP An EMP table is organised around identified environmental elements, and the activities that may impact each element. Management of elements are structured as sub-plans and are organised as follows.


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ENVIRONMENTAL MANAGEMENT PLAN – STRUCTURE

Objectives The guiding environmental management objective/s and activities that apply to the element.

Targets Sets the benchmarks by which the successes of the management strategies are judged.

Management and Mitigation

Strategies

The procedures to be employed to ensure that the relevant objectives are met.

Performance indicators/ criteria Sets the performance indicators and criteria for measuring the effectiveness of the actions or measures.

Monitoring and Measurement The process of measuring actual performance, or how well the objective has been achieved. This includes the format, timing and responsibility for reporting and auditing of the monitoring results.

Non-Conformance &

Corrective actions

The action/s to be implemented in the case of non-compliance. This includes strategies of remediation and the person(s) responsible for the actions. Corrective Actions are implemented through Environmental Improvement Plans (EIP) that describe remedial actions, reporting timelines and supervisory responsibility and signoff.

Responsibilities Those responsible for ensuring that the environmental management system is established, implemented and maintained in accordance with the requirements of the EMP.

Response timing Specified timing for response in the case of non-compliance with the EMP.

Review Effectiveness of

Management and Mitigation

Strategies

Requirements for review and reporting of the EMP and associated management plans.

Responsible agency Government and regulatory agencies responsible for compliance.

Relevant legislation and standards Relevant legislation and standards associated with the environmental aspect discussed in the EMP.

Refer to Section 5.6.7.5 for details on specific EMP tables.

5.6.7.2 Objectives and Targets Prodigy has adopted a number of objectives, with associated targets and performance indicators, to track the success of risk management and mitigation in minimising environmental impact.


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These objectives and targets ensure that Prodigy’s environmental policy is continually upheld which is achieved by ensuring EMP’s adopt a hierarchical order of objectives, targets and performance indicators to ensure that the desired environmental outcomes are measurable and that Prodigy is in compliance with relevant statutory requirements.

Measurable environmental objectives and targets are set based on:

reduction of significant environmental risks;

compliance with legal requirements and commitments;

continual improvement;

available technology;

financial resourcing; and

operational and business requirements.

Environmental objectives, targets and performance indicators are communicated to each work area and where relevant, incorporated into work place duties to improve employee awareness, resourcing and timeframes to achieve the desired outcomes.

Specific objectives and targets for individual hazards / risks are outlined in Section 5.6

5.6.7.3. Management and Mitigation Strategies Refer to Section 5.6.7.5 for specific management and mitigation strategies proposed for specific environmental aspects.

5.6.7.4 Monitoring and Measurement Refer to Section 5.6.7.5 for specific monitoring and measurement strategies proposed for specific environmental aspects.

5.6.7.5 Specific EMPs Each EMP table (below) corresponds to a specific environmental hazard/risk associated with the proposed works. The EMP section, Actions/Measures/Land Management, details the specific environmental measures that will be implemented to ensure the desired environmental outcomes are attained during the proposed works.

Biodiversity Management Plan: Flora and Fauna

To conserve biodiversity and key habitats of the Greater bilby and brush tailed mulgara, management of vegetation clearing, feral fauna and weeds are required. The Biodiversity Management Plan in Appendix 4 is an amalgamated document containing a Weed Management Plan, Pest Management Plan, Paleochannel Management Plan, Water/Migratory Bird Management Plan, Greater Bilby Management Plan and Brush-tailed Mulgara Management Plan.

FLORA & FAUNA / BIODIVERSITY MANAGEMENT

Objectives To minimise risk of impacts to flora and fauna.

To minimise risk to identified threatened species.

Targets No injury or death to native fauna especially threatened species outside of the approved footprint.

No fragmentation of fauna and flora habitats outside of approved footprint.

No loss of viable topsoil during clearing processes.


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FLORA & FAUNA / BIODIVERSITY MANAGEMENT No vegetation clearing beyond approvals.

No introductions of non-native fauna and flora species (weeds).

No decline in tree health within palaeochannel due to Project groundwater abstraction.

Management and Mitigation Strategies

Measures to achieve targets:

If threatened species are identified within the proposed clearing area, this will trigger further investigation and a case by case plan as required to minimise potential harm to individuals.

All land clearing activities associated with the project will require completion and compliance with Prodigy’s Land Clearing Procedure.

A dedicated wash down with associated sump is to be located at the administration/camp area. This location will ensure any seeds washed/removed from vehicles will be contained in the area preventing weeds from spreading to other areas

An appropriate method of weed treatment, either chemical or mechanical, will be used for each identified weed species.

Vegetation clearing will only occur when required, as clearing prior to development exposes soils to wind and water erosion.

Compulsory inductions detail the presence of threatened species and employee’s duty to comply with Prodigy’s environmental requirements.

Pest management for the Twin Bonanza project to ensure that predation pressure on threatened species is not increased as a result of the mining operation.

Identified areas of bilby and mulgara activity will be demarcated on maps, with access restricted to these areas.

Fire only being used under controlled condition and there will be no intentional starting of bush fires without explicit approval from government authorities and the CLC (refer to Fire Management Plan)

Construct and decommission all production and monitoring bores in accordance to the document titled “Minimum Construction Requirements for Water Bores in Australia, Edition 3”. If deeper aquifers are targeted then management measures will ensure cross aquifer contamination does not occur (i.e. sealing of the aquifer by concreting).

Site cleanliness will be maintained at a high level to avoid attracting introduced fauna species by making sure rubbish around the camp; mining and processing area is managed.

Waste from covered bins will be collected regularly and transferred to landfill.

Fence is to be erected around landfill.

Pests will be baited and/or trapped.


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FLORA & FAUNA / BIODIVERSITY MANAGEMENT Putrescible wastes will be burned.

As far as practicable the effects and availability of man-made water sources on terrestrial fauna will be reduced (namely one-humped camels, dingoes, cats).

Machinery and equipment leaving/arriving at site will be inspected for signs of stowaway pests and weeds.

Trapping and/or hunting will be implemented across the project area for feral predators that have the potential to adversely affect threatened species (namely greater bilby and brush-tailed mulgara which are known to persist at Twin Bonanza).

To dissuade dingoes and other scavengers from entering camps, food scraps are to be burnt, standing water is to be avoided and feeding and any other interaction with fauna is not permitted.

Performance indicators/criteria

No Greater bilby deaths as a result of the proposed activities.

No brush-tailed mulgara deaths as a result of proposed activities.

Clearing within approved boundaries

Fully recovery of topsoil.

No new pest species introduced to the site.

No increase in the existing populations of known pest species.

No new weed species introduced to the site.

No increase in the existing populations of known weed species.

Monitoring and Measurement

Monitoring will include:

Regular inspections of work sites, tracks and camp areas, land fill and camp area for evidence of pest fauna (such as feral cats and dingoes).

As part of regular monitoring of the mine water plan and sewerage dam, the presence of water bird/migratory species and evidence of illness or fatalities will be recorded.

Vegetation monitoring program to monitor conditions across the site and to detect flora degradation in accordance with agreed schedule

Sand plot monitoring during active site operations will be used to estimate activity and population of pest fauna within the Twin Bonanza project area within agreed schedule.

Non-Conformance and Corrective Action

Any failures to comply will be investigated, with appropriate actions taken to overcome the non-compliance. Actions may include:

• In the event of encountering a site of apparently major flora or fauna significance the area will be avoided or work ceased.

• Any new weed or feral animal species occurrence shall be recorded by the employee and reported to the site manager, DPIR & Department Lands, Planning and Environment; as applicable. An eradication program will then be implemented.


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FLORA & FAUNA / BIODIVERSITY MANAGEMENT • An injury or death of a greater bilby and mulgara as a result of mining

related activities (i.e. vegetation clearing, haul trucks traffic, and light vehicle traffic) would be immediately reported to DPIR and DOEE. This would trigger a response that reviews reasons why the incident occurred and how the risk of re-occurrence could be minimised.

• If cats are detected during weekly site inspections of camp area and landfill site, this will trigger an appropriate control program using baits within the landfill compound that does not provide access to native species. During C&M, when the Camp is only occupied for a short Period each year, the management control approach for feral cats is to (a) manage landfill backfill operations,(denial of access to waste food resources), (b) control physical access to the facility and (c) monitor presence through tracks around the fenced landfill facility

Responsibilities Site Manager

Response timing Report incidents as soon as possible. Time taken for remedial actions depend on action to be taken.

Review Effectiveness of Management and Mitigation Strategies

Include details in an updated MMP as required.

Annual audits of biodiversity management compliance will be conducted and reported as part of the annual MMP review and renewal process.

Incident reporting will be implemented to record any safety or environmental non-conformances or incidents.

Any recording of a Declared Weed, Class A, B, C within ML29822 and EL28322 will be reported to the DLRM – Weeds Branch as soon as practicable following recording.

Any complaints from the public or specific project stakeholders to the site general manager will be reported and subsequently recorded in a complaints register and raised in daily toolbox meetings.

Any recording of a new pest species will be reported to the DLRM

Responsible agency

Department of Primary Industry and Resources – Section 29 of Mining Management Act

Department of Land Resource Management - NT

Environmental Protection Agency (EPA) - Environmental Assessment Act 1982

Department of the Environment and Energy (Commonwealth Government)

Relevant legislation and standards

Environment Protection and Biodiversity Act 1999 (Cth)

Territory Parks and Wildlife Conservation Act 2000 (NT)

Water Act 2004 (NT)

Waste Management and Pollution Control Act 1998 (NT)

Weed Management Act 2001 (NT)

Revised National Weeds Strategy 1999

Bushfire Act 2009 (NT)


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FLORA & FAUNA / BIODIVERSITY MANAGEMENT Bushfire Regulations 2005

Environmental Assessment Act 1982 (NT)

Fire and Emergency Act 2012 (NT)

Fire and Emergency Regulations 2011

Work Health and Safety (NUL) Act 2011 (NT)

National Recovery Plan for the Greater Bilby Macrotis lagotis (Pavey 2006)

Northern Territory Land Clearing Guidelines (Department of Natural Resources, Environment, the Arts and Sport. 2010. Land Clearing Guidelines. Technical Report 20/2009D, NT Government, Darwin

Northern Territory Guidelines and Field Methodology for Vegetation Survey and Mapping. Technical Report No. 02/2007D, NT Government, Darwin

Supplement to the NT Parks and Wildlife Conservation Master plan for bioregional conservation significance

DLRM threatened species fact sheets

Commonwealth's guidelines for the assessment of the significance of impacts on matters of national environmental significance

LPSD - Biodiversity Management

Fauna Egress Matting and Ramps - Western Australia Department of Mines and Petroleum

Northern Territory Government (2010) Guidelines for Weed Data Collection in the Northern Territory, Northern Territory Government of Australia.

Guideline for the General Management of Hazardous Waste in the NT

Guidelines for the Siting, Design and Management of Solid Waste Disposal Sites In the Northern Territory - NTEPA January 2013

Surface water

The Site is situated in a semi-arid area with a distinct rainfall period from November to April. To manage the effect on surface water during these periods the following measures are detailed below. This section should be read in conjunction with Section 6.

SURFACE WATER MANAGEMENT

Objectives To minimise risk of mining impacts to surface water resources. To maximise the efficient use of water on site.

Targets Minimise amount of sediment runoff.

No significant erosion on site from mining related activities.

All hydrocarbons and hazardous materials onsite stored in accordance with Australian Standards.

No major spills of hydrocarbons or hazardous materials/chemicals.


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SURFACE WATER MANAGEMENT


Action and measures to be taken include:

Appropriately train employees and ensure management measures are implemented.

Some potential for flooding was identified along the lower lying areas of the main access road, and within the adjacent borefield area. The main access road is already established, and has been fitted with low pass crossings in areas with a high likelihood of seasonal flooding. The flood potential within the borefield area has not been assessed in detail, as there will be little infrastructure installed in this area. It is anticipated that any equipment installed within the borefield area should be able to cope with seasonal flooding.

Hydrocarbons and other chemicals will be stored onsite, primarily in the workshop and processing plant. All tanks, fuel drums and chemical products shall be stored within self bunded tanks, bunded/lined areas or within portable self bunded pallets. Permanent bunded storage areas are to be located away from the accommodation site and drainage lines.

An Emergency Response Management Plan has been developed to outline more detailed procedures for spills that occur outside of the main risk areas outlined here.

Design and operation of the sewerage facility will be accordance with the code of practice for small onsite sewage and sullage treatment systems and the disposal or reuse of sewage effluent - NT Department of Health and Families. Water from ablutions will be sent from approved septic tanks to leach system.

Appropriate clearing methods to minimise potential risk of erosion and sedimentation of downstream surface waters.

Gravity wash residues contained in HDPE lined facility.


Regular inspections of work sites, tracks and camp areas. Opportunistic sampling of surface water will be undertaken as

required when rain events produce discernible surface water during mine operation.


In general, most monitoring activities will be conducted monthly when the site is occupied, to ensure hydrocarbons and chemicals are stored appropriately and sediment erosion is not excessive. In the case of surface water from natural rainfall, monitoring will occur during rain events when discernible surface water is present.


Serious spills require cessation of all works at the site, and containment of pollution. Non-compliance requires investigation and remedial actions by the delegated onsite person and reporting to DPIR.

Responsibilities Site manager

Response timing Serious spills require cessation of all works at the site, and immediate containment.


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SURFACE WATER MANAGEMENT All other issues require immediate action to be undertaken as soon as possible within receipt of a complaint or identified during an inspection.


Surface water quality will be sampled during the operational phase and reported in the MMP in accordance with the Mining Management Act 2001.

Report incidents to DPIR, in accordance with Section 29 of the Mining Management Act.

Responsible agency

NT DPIR

Water Resources Division of the Department of Land Resource Management - Water Act 2011

NT EPA - Environmental Assessment Act 1982


Water Act 2004 (NT)

Mining Management Act 2001 (NT)



International Erosion Control Associations (IECA) Best Practice Erosion and Sediment Control Guidelines (BPESC) (Books 1-6)

AS1940-2004 - The storage and handling of flammable and combustible liquids

LPSD - Hazard Materials Management

LPSD - Water Management

Code of practice for small onsite sewage and sullage treatment systems and the disposal or reuse of sewage effluent - NT Department of Health and Families

NT Department of Health - Environmental Health Fact Sheet #700 - Requirements for Mining and Construction Projects

Waste Management and Pollution Control (Administration) Regulations. NT GOVT

Groundwater

To prevent any potential impacts on the groundwater resource or to GDEs during mining or abstraction activities. The following measures are to be implemented. This section should be read in conjunction with Section 6.

GROUNDWATER MANAGEMENT

Objectives To minimise risk of impacts to groundwater resources and GDEs. To minimise adverse effects to groundwater aquifers through extraction.

Targets All hazardous materials and hydrocarbons onsite stored in accordance with Australian Standards. Operation of Raw Water Dam in line with design specifications.


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GROUNDWATER MANAGEMENT No un-controlled waste disposal and release of waste water. No sign of tree health stress associated with mining activities in the palaeochannel aquifer. Abstraction rates sustainable and below recommended maximum pumping rates.


Use temporary bunded pallets for small hydrocarbon containers. Concrete bunds and double skinned tanks for bulk storage. Appropriate storage and handling of hazardous materials and monitoring of storage facilities in accordance with Australian Standards.

Existing RWD has been built with a HDPE liner to prevent seepage. Optimise water conservation opportunities by exploring alternatives to

water such as dust suppressants.


Water storage facilities are constructed to design specifications.

Fuel storage and waste water management systems designed to specifications.


Field and laboratory parameters and static water levels for nominated production and analogue bores to be monitored in accordance with operational and C&M requirements in the Plan, to be revised annually. See Table 6.3 of MMP for current specific schedule.


Serious spills require cessation of all works at the site, and containment of pollution. Non-compliance requires investigation and remedial actions by the delegated onsite person and reporting to DPIR if applicable.


Response timing Serious spills require cessation of all works at the site, and containment of pollution.

All other issues require immediate action to be undertaken as soon as possible within receipt of a complaint or issue identified.


Water Quality to be reported in the MMP in accordance with the Mining Management Act 2001 and agreed monitoring timeframe.

Report any incident to DPIR, in accordance with Section 29 of the Mining Management Act.

Responsible agency

NT DPIR – Section 29 of Mining Management Act

Department of Health and Families - NT Public Health Act and NT Public Health Regulation

Water Resources Division of the Department of Land Resource Management


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GROUNDWATER MANAGEMENT - Water Act 2011



Water Act 2004







Code of practice for small onsite sewage and sullage treatment systems and the disposal or reuse of sewage effluent - NT Department of Health and Families


Waste Management and Pollution Control (Administration) Regulations. NT Government


Minimum Construction Requirements for Water Bores in Australia 2012 (3rd Edition) 1 (National Uniform Drillers Licensing Committee, 2011)

Fire Management

To prevent the potential for site activities to modify natural fire regimes within the surrounding environment, the following measures detailed below will be adopted.

FIRE MANAGEMENT

Objectives Minimise the potential for uncontrolled fires associated with mining activities. Ensure that fire control practices are implemented on site to minimise the risk of fire from site operations and bush fires.

Ensure that Prodigy complies fully with its legal obligations in relation to fire safety

Targets No wildfires caused by mining activities, establish appropriate fire management procedures to protect mine site infrastructure and personnel:

Install all required firebreaks Install appropriate fire extinguishers at all required locations Ensure sufficient firefighting equipment and training is provided to be

able to fight bushfire No human injuries or loss of equipment/facilities from bushfires.


Around the site fire breaks will be used to prevent naturally occurring fires from damaging buildings and infrastructure and non-natural fires from spreading beyond operational areas.

All mining equipment and gensets will be equipped with appropriate fire


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FIRE MANAGEMENT extinguishers.

Housekeeping will play a major part in Prodigy’s fire management, including reducing waste and dry vegetation, not only in fire breaks but also around infrastructure on site.

Prodigy personnel are strictly banned from lighting fires except under controlled conditions.

Prescribed burning has been recommended by the CLC to maintain a reduced-fuel buffer for standard fire protection. This will be adopted as required for future MMP’s and will be utilised where practicable, in between fire breaks and infrastructure.

The site induction, which covers environmental and safety aspects, will inform all personnel about fire awareness, the requirement to obtain a Hot Work Permit before undertaking welding, cutting or grinding activities, emergency contact numbers, and procedures in case of a fire.

Strategic fire breaks will be constructed around all buildings and operating plant. Firebreaks will aim to enable vehicle access to fight fires (approximately 6m wide), will stop a fire under mild conditions, and are essential as control lines from which back burning may be undertaken to stop wildfires in extreme conditions. Back burning and/or controlled burning will only be undertaken with a permit under the Bushfire Act that is currently administered by Bushfires NT (where applicable) and in consultation with the Traditional Owners.

Hydrocarbons and hazardous materials are to be stored in accordance with AS1940-2004 - The storage and handling of flammable and combustible liquids; appropriate hazard separation zones of fire risk areas from fuel storage and hazardous chemical storage facilities will be enforced.

Personnel are to comply with Hot Work Permits when conducting welding, cutting and grinding activities onsite. The permit will specify fire control practices to ensure no fires are started from conducting these activities.

Prodigy will incinerate solid wastes, i.e. cardboard and food scraps in a bunded pit, or a turbo burner, only on days where wind is low and the fire risk is low to moderate.


No fires will intentional or unintentional will adversely affect the environment surrounding the mine site.

No injuries, fatalities or loss of infrastructure will occur as a result of a wild fire.


Hot work Permits are applied for and adhered to.

Records in Environmental Observations and Incident Register.


If a fire is a result of Prodigy activities, investigate then instigate procedural change. If deemed necessary further workforce training.

Review processes and feed back into future Fire Management Plan.


Response timing Immediate response to any fire threatening staff, environment and/or infrastructure. Investigation and corrective action time frame dependent on


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FIRE MANAGEMENT type of fire management non-compliance.


Reporting of any incidents internally and to DPIR in accordance with Section 29 of the Mining Management Act.

The company representative is to report major fires to and consult with the NT Bushfires Council, DPIR and local communities as appropriate.

Review of inspections/checks to be provided in annual MMP reporting.

Responsible agency

NT Bushfires Council

Department of Mines and Energy


Bushfire Act 2009 (NT)

Bushfire Regulations 2005 (NT)


Fire and Emergency Act 2012 (NT)

Fire and Emergency Regulations 2011 (NT)

Work Health and Safety (NUL) Act 2011 (NT)



AS 4665-2002, Guidelines for Fire Safety Audits for Buildings (Int)

AS 3745-2002, Emergency Control Organisation and Procedures for Buildings, Structures and Workplaces

Fire Engineering Guidelines 2001

Air quality

Dust has the potential to have the greatest effect on air quality. Since the 2013 EIS process, Prodigy has commissioned a peer review of the Air Quality Management Plan (AQMP) undertaken and submitted in operational MMPs as Appendix 22. The peer review recommended Prodigy change the number of dust monitoring gauges around Site from 6 to 4. It was also recommended that research by Doley & Rossato (2010) on mineral particles and vegetation should be used to guide for dust deposition monitoring values which suggested 15g/m²/month for dust deposition on vegetation. Measures to manage dust on site are detailed below. Following site closure and rehabilitation of disturbed areas, dust monitoring has ceased.

AIR QUALITY MANAGEMENT

Objectives To identify and control potential air quality impacts and to minimise the dust impact generated from operations on Prodigy staff, external stakeholders and the environment.

Targets No complaints from staff, contractors or the public.


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AIR QUALITY MANAGEMENT

No reported OH&S issues caused by dust generated during operations

No evidence of significant erosion resulting from operational activities


Mitigate and manage dust generation through the strategies outlined below. A conservative and a progressive approach to vegetation clearances will

be followed, ensuring a minimum area is clear at any one time and the majority of the area is still vegetated and undistributed.

Topsoil will be removed during periods when soil moisture and wind conditions limit dust generation where practical.

The use of a dust suppressant will be investigated to reduce the water consumption while maintaining dust suppression.

A vegetative cover will be established by progressively ripping and rehabilitating areas no longer required.

Vehicle speeds will be limited around site.

To reduce greenhouse gases staff and contractors will: maintain equipment including tyres to maximise efficiency and prevent

incomplete combustion of hydrocarbons purchase fuel product with a low sulphur content if practicable.

Additional measures include:

Rehabilitation as soon as possible to stabilise any areas exposed or disturbed to minimise dust generation.

Whenever possible, avoid conducting dust generating activities during high wind speed conditions.

Vehicle movements are restricted to cleared access tracks and nominated tracks.


Visual Monitoring of nuisance dust levels that heavily coat vegetation. Dust levels will not exceed the New South Wales Department of Environment and Conservation standards as well as Doley & Rossato’s (2010) recommendations for dust deposition, monitoring and mitigation. 1. Nuisance dust levels are defined as a total of 4 grams/m2/month,

and monitoring is recommended over the space of a month. In addition, an increase of 2 grams/m2/month can be considered a nuisance. This applies to the accommodation village.

2. Dust deposition can inhibit plant growth if levels exceed 15grams/m2/month and thus this level will be used for all other dust monitoring sites.


On–site supervisors will monitor current dust conditions on a daily basis during operations. Depending on conditions this will facilitate management measures for example, more frequent water application via a water cart.

Dust deposition levels are to be monitored using four dust monitoring sites. Strategically positioned dust gauges mounted on stands will be established based on the prevailing wind with a focus on the waste rock dump, proximal to the main haul road and near the accommodation complex Records in Environmental Observations and Incident Register.

Non-Conformance and Corrective

The following actions are to be undertaken when an incident or non-conformance is identified:


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AIR QUALITY MANAGEMENT Action an investigation into the incident or non-conformance is to be

immediately undertaken by the site supervisor

the identified cause/s is/are to be rectified to prevent additional incidents or non-conformance; for example, further dust management measures may need to be established.

Review processes, instigate procedural change and feed back into the management plan.


Response timing Immediate response to any emissions threatening staff and environment.

Direct reporting of incident to site delegated manager


Report any significant issues as an incident to DPIR, in accordance with Section 29 of the Mining Management Act. Review of any observations/incidents in annual MMP reporting.

Responsible agency


Department of Health and Families - NT Public Health Act and NT Public Health Regulation


Work Place Health and Safety NT


Work Health and Safety (NUL) Act 2011 (NT) under Division 2 Primary Duty of Care (NT)


Leading Practice Sustainable Development (LPSD) - Airborne Contaminants, noise and vibration

Leading Practice Sustainable Development (LPSD) - Biodiversity Management

International Erosion Control Associations (IECA) Best Practice Erosion and Sediment Control Guidelines (BPESC) (Books 1-6).

New South Wales Department of Environment and Conservation Standards for Dust Deposition

Doley, D and Rossato, L. 2010. Mineral Particulates and Vegetation: Modelled Effects of Dust on Photosynthesis in Plant Canopies

Waste Management

Waste materials generated at the Site can be divided into limited volumes of sub grade mineralised waste material stored in the RWD, barren waste rock and clays and solid industrial or putrescible waste materials. No solid mining waste materials and limited volumes of solid camp wastes were produced in the Reporting Period while the site was on C&M.


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Mineralised

MINERALISED WASTE MANAGEMENT

Objectives To prevent waste rock from impacting the surrounding environment. To prevent the gravity wash residue produced during the bulk sample (contained in the existing RWD storage) from impacting the surrounding environment homogeneity.

Targets Uniformity in waste rock identification across site. Design appropriate scheduling format to ensure the waste rock dumps are constructed to accordance to the agreed design. Maintain the existing structural integrity of the existing RWD. No impacts to surface or groundwater quality.


Waste rock. o Waste rock characterisation has been undertaken o Appropriate design and construction of the waste rock dump to

ensure structural integrity and selective handling of adverse materials

o Implement waste rock identification as part of mining process. To ensure appropriate scheduling and placement in the waste rock dump.

Seepage or release from GWR in RWD.

o Facility designed and constructed with HDPE liner. o Regular inspections of embankments and linear. o Regular inspections of freeboard capacity.


No failure of RWD embankments.

Waste rock dump constructed to agreed design.

No impacts to surface or groundwater quality.


Monitoring of the erosion and water around the RWD and waste rock dumps.


If performance indicators are not meet, investigate then instigate required changes and modifications.

Review processes and feed back into site management.

Notify appropriate authorities if required.


Response timing Immediate response to any waste rock or RWD risks impacting staff and environment. Timeframe for remediation dependent on nature of issue.


Reporting of monitoring data in annual update of MMP. Report any significant issues as an incident to DPIR, in accordance with Section 29 of the Mining Management Act.


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MINERALISED WASTE MANAGEMENT

Responsible agency

NT DPIR.

NT EPA


The regulatory requirements governing waste management in the Northern Territory are contained within the following legislation:


Waste Management and Pollution Control (Administration) Regulations 2001 (NT)

Water Act 2004 (NT)


Regulations and guidelines that are applicable and have been consulted are outlined below:

ANCOLD Guidelines - Guidelines on tailings dams; planning, design, construction, operation and closure.

LPSD - Tailings Management


TEAM NT: Technologies for the Environmental Advancement of Mining in the Northern Territory, Toolkit.

Non-Mineralised

NON-MINERALISED SOLID WASTE MANAGEMENT

Objectives Achieve the best possible environmental outcome by minimising waste generation, maximising waste re-use, maximising recycling and safely treating and disposing of non-recyclable materials. To prevent wastes from contaminating the surrounding environment.

Targets Achieve efficient waste management by: optimising the processes/products that produce minimal waste requiring

disposal not contaminating surrounding environment reduce, reuse and recycle wherever possible safely disposing of non-reusable and recyclable materials.


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Waste management actions will include: segregating wastes that are recyclable and reusable, and will endeavour

to recycle wastes in appropriate recycling facilities or use on site if applicable

re-using or recycling wastes such as oil, scrap metal and timber pallets while others will be disposed of on-site

utilising processes/products that produce minimal waste requiring disposal

utilising processes/products which minimise contamination of the surrounding environment

placing contaminated wastes, including materials that have been in contact with lubricants, greases, hydrocarbons and other hazardous chemicals in designated disposal bins for transporting off site and disposal

recycling saline water rejected from the plant as a by-product of the reverse osmosis and mixing it with the water to the water storage dam.

storing waste oil in waste oil tanks/containers prior to offsite disposal

Performance indicators criteria

Appropriate waste management resulting in minimal environmental effects.

Effective recycling and reuse of appropriate materials to reduce resource use.


Regular inspections/audits of camp and operational areas to ensure that waste is being managed appropriately. Records kept of waste disposed to licenced facilities.


If an incident occurs including improper waste disposal and failure to recycle waste, investigate incident then instigate procedural change. If deemed necessary further workforce training.


Response timing Immediate response to any waste management incident. If training is required implement over required training timeframe.


Records will be reviewed on a regular basis and appropriate corrective actions formulated to reduce or eliminate waste generation or impacts associated with waste. Reporting of any incidents internally and to DPIR in accordance with Section 29 of the Mining Management Act. During operational phases, Include summary of inspections/audits and waste management activities (including recycling) in annual MMP update.

Responsible agency

Department of Mines and Energy – Section 29 of Mining Management Act

Work place Health and Safety NT - Work Health and Safety (NUL) Act 2011 under Division 2 Primary Duty of Care

Environmental Protection Agency (EPA) - Environmental Assessment Act 1982


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Relevant standards and legislation


Waste Management and Pollution Control (Administration) Regulations 2001 (NT)

Public and Environmental Health Act 2011 (NT)

Water Supply and Sewerage Services Act 2000 (NT)

Water Act 2004 (NT)



Code of Practice for Small On-site Sewage and Sullage Treatment Systems and the Disposal or Reuse of Sewage Effluent (1996)

AS 1940-2004: The storage and handling of flammable and combustible liquids

Guidelines for the Siting, Design and Management of Solid Waste Disposal Sites in the Northern Territory (2013)


Community

The Site is located on freehold Aboriginal land. The management of cultural and social aspects are intertwined based on the Sites location. As such this community section will cover both cultural and social management.

Cultural & Heritage

CULTURAL & HERITAGE MANAGEMENT

Objectives To protect cultural heritage and Aboriginal archaeological sites.

To ensure that operations do not inhibit traditional land management practices.

To minimise the impact on aesthetic values and the cultural landscape.

Targets No unapproved disturbance to cultural heritage sites.

No unplanned economic social impacts on local community.

No impediments to traditional land management practices.

No inadvertent impact on aesthetic and cultural values for local communities.


Prodigy will maintain a register of sites and these sites will be marked on maps, development plans and advertised at the site (unless the location of the site is deemed confidential by the CLC).

All employees and contractors will be advised of cultural and heritage sites, as well as exclusion zones.


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CULTURAL & HERITAGE MANAGEMENT

Prodigy will conduct surveys of any sites that are subject to development or disturbance. These surveys will be conducted by professional practitioners and where applicable will be carried out in conjunction with the CLC.

In addition, members of Prodigy staff will be trained on how to identify new areas.

All new sites will be reported to executive management who will report the findings to the CLC and other government organisations as appropriate.

Prodigy and employees will adhere to a “IF IN DOUBT – MARK IT OUT” policy to areas of potential new sites. Should an employee identify a potential site they will mark it out with blue pegs and not disturb the site until an archaeological survey can be arranged by Prodigy.

Ongoing consultation with underlying landholder, through the CLC, under the Aboriginal Land rights Act 1976. The engagement process will include topics such as future work programs and mine development.

Infrastructure and operations aimed at maintaining aesthetic and cultural values for local communities, where practicable.


No un-authorised disturbance of archaeological and CLC designated sacred sites.

No recorded disturbance of cultural heritage sites.

No unplanned economic social impacts on local community.

Level of feedback and concerns raised at on ground meetings on the operations effect on cultural values and traditional land management practices.


Regular meetings and communication with the CLC to ensure all practices are in line with Prodigy’s cultural/social and legal agreements with the CLC.

• Notification of any accidental disturbance to the relevant authorities.

• Evidence of notification of the new sites to the CLC and the relevant authorities.


A register of all external communications relevant to the mine’s operations will be maintained in Prodigy Incident and Complaints Register. This will incorporate any details from on-country meetings. This will lead to an appropriate action to overcome the problem.

Responsibilities Managing Director

Response timing Immediate response to any cultural issues time taken to overcome the problem reflects the nature of the matter.

Review Effectiveness of Management and

Prodigy has a policy to notify the relevant authorities, including the CLC and relevant government agencies, if deemed appropriate, should any new sites be identified.


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CULTURAL & HERITAGE MANAGEMENT Mitigation Strategies

Any relevant complaints and enquiries for the reporting calendar year will also be reported in the MMP under the Mining Management Act 2001 and to the CLC and Traditional Owners through on ground meetings, discussing the scope and project direction, and through technical reporting under the mining agreement with the CLC.

Prodigy will maintain mechanisms to update Cultural and Heritage management, particularly recognising new and emerging issues and implementation into the plan. These mechanisms include:

• making all employees aware of cultural and heritage management, and providing regular opportunity for feedback they have been receiving in the wider community

• allowing open and honest dialogue with the CLC and Traditional Owners.

Responsible agency

CLC –Central Land Council - under the Aboriginal Land Rights Act 1976

Department Lands, Planning and Environment

Aboriginal Areas Protection Authority


Aboriginal Land Act 1980 (NT)

Northern Territory Aboriginal Sacred Sites Act 1989 (NT)

Native Title Act 1993 (Cth)

Aboriginal Land Rights (Northern Territory) Act 1976 (Cth)


Heritage Act 2011 (NT)

Social Impact Assessment: Guideline to preparing a Social Impact Management Plan - Queensland Government

LPSD - Working with Indigenous Communities

LPSD - Community Engagement

Social

SOCIAL MANAGEMENT

Objectives Maximise the positive effect on the surrounding communities while minimising the negative effect.

Targets No unplanned economic social impacts on local communities.

No environmental degradation across the entire ecosystem that has an effect on local communities.

No complaints about social and community impacts.


Adoption of appropriate health and safety practices.

Ongoing consultation with underlying landholder and communities, through the CLC, under the Aboriginal Land Rights Act 1976.


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SOCIAL MANAGEMENT

Appropriate implementation of the environmental management and mitigation measures.

Prodigy will adhere to agreements with the Traditional Owners (that make up the local communities) and the CLC.

Traditional Owners are not to be denied access to any part of the project area or surrounding lands for hunting or bush food gathering (except for reasons of mine-safety).

As per agreements with the Traditional Owners, should there be roles that become available for which local people are suitable or may be trained for, Prodigy must seek to employ via the communities first.

The company will prioritise and select service providers on a best efforts basis, within the reasonable expectation of free-market principals / efficiency of service based on their locality and proximity to the project area.

Timely response to community and stakeholder concerns.


Number of health and safety incident concerning either staff or community involving Prodigy.

Formal engagement with Traditional Owners

Positive contributions to the community including grants, employment and delivery of local services.


Meetings and communication with the CLC to ensure all practices are in line with Prodigy’s legal agreements with the CLC.

Ongoing consultation with underlying landholder and local communities, through the CLC, under the Aboriginal Land Rights Act 1976.


Corrective actions may include:

working with local communities to resolve and rectify issues and concerns

responding to valid complaints

increasing variety of training available

establishing reasons for leaving / absenteeism and try to remedy

discussing with CLC and Traditional Owners programs available for funding

assessing impact on restricted entry around the mine site and implement changes as per the plan

consulting with affected peoples to see if new areas can be offset programs can be implemented

searching for new businesses to supply and offer tender in local / regional centres.


Response timing Immediate response to any social compliant or concerns raised by the local community.


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SOCIAL MANAGEMENT


Complaints and enquiries will also be reported in the MMP under the MiningManagement Act 2001 and with the CLC and Traditional Owners through on ground meetings, discussing the scope and project direction, and through technical reporting under the mining agreement with the CLC.

A register of all external communications relevant to mine’s operations will be maintained in Prodigy’s Incident and Complaints Register. Community complaints and inquiries will be registered recording details such as the date, time, complainant/inquirer name and address, information about the complaint/inquiry, response and corrective actions.

Responsible agency

Department Lands, Planning and Environment

CLC –Central Land Council - under the Aboriginal Land rights Act 1976


Environment Protection and Biodiversity Conservation Act 1999 (Cth)

Aboriginal Land Rights (Northern Territory) Act 1976 (Cth)



Heritage Act 1991(NT)

Aboriginal Land Act 1980 (NT)

Work Health and Safety (National Uniform Legislation) Act (and related Regulations)2007 (NT)

Social Impact Assessment: Guideline to preparing a Social Impact Management Plan - Queensland Government


LPSD - Working with Indigenous Communities


Chemicals and Hazardous Substances

Apart from hydrocarbons (i.e. fuel and oils), there will be minimal or no storage of hazardous materials at the Site during C&M. Any fuel brought to Site is stored in secure fuel cells and bunded. Large Volume Fuel (greater than 1,000L) are stored on Site in approved double skin/self-bunded fuel container/tank. During Care and Maintenance only limited fuel quantities are stored on site for Exploration Team use.

HAZARDOUS SUBSTANCE MANAGEMENT

Objectives To ensure that transport, storage and handling of dangerous goods on-site does not cause environmental harm or harm to persons.

Targets No harm to environment or persons resulting from transport, storage and handling of dangerous goods. Compliance across the whole site with the required standards for the transport, handling and storage of chemicals and hazardous goods. No complaints from staff, contractors or the public.


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HAZARDOUS SUBSTANCE MANAGEMENT Management and Mitigation Strategies

Documented risk assessment conducted prior to working with hazardous substances and repeated any time the scope of work changes or any surrounding conditions change.

Field personnel will respond to an emergency situation as described in the Emergency Response Management Plan.

Any licences required for storage will be obtained. Bunding will be inspected for damage regularly and repaired as soon as

is practicable if any damage is detected. Hazardous substances will be stored on site in accordance with the

relevant legislative requirements MSDS’s and guidelines. Key personnel will be trained in the appropriate handling of the various

chemicals to be stored on site. Spill kits will be available where hazardous materials are used and

stored and personnel trained in correct use. Refuelling shall not be done within 100 metres of a watercourse. The area supervisor shall maintain an inventory for each separate

hazardous substance storage area on site. No asbestos or asbestos containing substances shall be brought onto

site. Storage facilities for all Hazardous Substances and Dangerous Goods

shall comply with the Dangerous Goods Act 2012 (NT) and Dangerous Goods Regulations 2012 (NT), prior to storing hazardous substances on site to ensure that the necessary licences or exemptions are clarified.

Where required by the Dangerous Goods Act 2012 (NT) storage areas shall be contained within bunds. Bund construction shall comply with AS1940:1993 The Storage and Handling of Flammable and Combustible Liquids and regulatory requirements. In the event of inconsistency, regulatory requirements shall be followed.

The site delegated manager is responsible for ensuring that all waste and unused hazardous substances are removed from site in accordance with legislative requirements.

PPE is considered the last line of defence against hazardous substances. Safety Data Sheets (SDS) normally contain recommendations on the selection and use of PPE for the particular materials being used. Supervisors shall ensure that: • protective devices are selected which are suitable for the individual and

give the required level of protection from the risks associated with the particular task

• all PPE meets relevant Australian Standards (AS) • use of correct PPE is enforced • PPE is readily available, clean and functional, and employees are

individually fitted • there is a proper instruction on the need for, and correct use of,

personal protective clothing • an effective system of cleaning and maintenance for PPE is

implemented.


No harm to environment or persons resulting from transport, storage and handling of dangerous goods.


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HAZARDOUS SUBSTANCE MANAGEMENT No complaints from staff, contractors or the public.


Storage facilities will be inspected regularly (at least weekly) and any resulting recommendations and corrective actions shall be implemented. Records in Environmental Observations and Incident Register. Administration controls consist of properly designed and implemented work practices and procedures and may include: • safe work procedures that describe the correct methods for performing

all activities associated with storing, handling and disposing of dangerous goods

• training and supervision to provide the necessary knowledge and skill and ensure correct procedures are followed safely

• good housekeeping, including regular cleaning of contamination from walls and surfaces, dust and drip removal from all work areas, and keeping lids on containers when not in use

• workplace monitoring to ensure safe working conditions is maintained.


Corrective actions may include:

• enforcing safe work practices

• enforcing PPE use and consider further training and awareness

• reviewing practices and amend procedures in light of review.


Response timing Immediate response to any event threatening staff and environment


Spills and clean-up are to be documented and reported by the staff and reported to the site delegated manager Reporting of any incidents internally and to DPIR in accordance with Section 29 of the Mining Management Act. Summary of inspections to be provided in annual MMP reporting. Reporting to NT Worksafe if required.

Responsible agency


Work place Health and Safety NT - Work Health and Safety (NUL) Act 2011 under Division 2 Primary Duty of Care



Work Health and Safety (NUL) Act 2011 (NT).

Dangerous Goods Act 2012 (NT).

Work Health and Safety (NUL) Regulations 2012 (NT).


LPSD - Hazardous Materials Management


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Incidents and complaints management

As detailed in Prodigy’s community and environment policy (Section 5.2), there is an ongoing commitment to ensuring stakeholders and the wider community interests and concerns are fully considered. During Care and Maintenance this aspect is managed by Prodigy’s Land Manager.

INCIDENTS AND COMPLAINTS MANAGEMENT

Objectives Manage environmental or social incidents and complaints.

Targets Action undertaken as soon as possible within receipt of a complaint.

Investigations completed within of receipt of a complaint.

All corrective actions implemented by the nominated due date.


All incidents or complaints about either environmental or social issues will be managed in accordance with the relevant ABM procedure. The procedure requires the following actions to be undertaken:

1. Take any necessary immediate action 2. Report the incident or complaint 3. Undertake an investigation (if warranted) 4. Determine root causes 5. Undertake necessary corrective or preventative actions 6. Monitor action implementation 7. Audit effectiveness of action


Number of complaints received.

Number of complaints resolved within specific timeframe.


The Land Manager will monitor compliance against the targets.


If further incidents occur or complaints are received in relation to previous occurrences, the following corrective actions will be undertaken ( where applicable):

• additional environmental awareness training of the workforce with respect to the procedures to be followed for environmental incidents or complaints

• investigation into why the incident/complaint was not addressed within the specified time frame

• Undertake incident/complaint follow-up according to the results of the investigation.

Responsibilities Site manager and/or Land Manager

Response timing Immediate action undertaken as soon as possible within receipt of a complaint and/ or notification of review.

Review Effectiveness of Management and Mitigation

All incidents and complaints will be recorded in the Environmental Management Incident report register on site. Once an incident has occurred, appropriate Prodigy personnel will report the incident to the CEO of the DPIR using the notification forms located at http:/nt.gov.au/industry/mining-and-


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INCIDENTS AND COMPLAINTS MANAGEMENT Strategies petroleum/mining-activities/report-a–mining-environmental-incident.

The complainant will be advised of what action, if any, is taken as a result of the complaint.

Responsible agency

NT DPIR


Section 29 of Mining Management Act. Management process

Rehabilitation

The Twin Bonanza project is on monitored Care and Maintenance, and all mine site disturbance has been rehabilitated, Prodigy is committed to rehabilitating the remaining, pilot plant, water storage dam, bore infrastructure and exploration areas at final closure. In accordance with the approved Mine Closure Plan (Prodigy Rev 2.2 November 2018).

REHABILITATION AND CLOSURE MANAGEMENT

Objectives Rehabilitate the disturbed areas to be safe, stable and non-polluting with compatibility to future land use.

Targets Meet all closure objectives defined in the Mine Closure Plan (Rev 2.2 November 2018).


Retaining the topsoil as a viable resource to use for rehabilitation purposes at a later date.

Progressive rehabilitation will be undertaken, to optimise topsoil properties.

Removal and disposal of equipment and rubbish

Rehabilitate the closure domains in accordance to the Mine Closure Plan.

Rehabilitate the bulk sample pilot plant disturbance areas.

Rehabilitate all exploration including costeans, sumps and, drill holes and pads.

Native plant cover of local provenance, species type and diversity similar to surrounding areas.

Vegetation community that can accommodate local fire regime.


Soil profiles across the site are compliant with the design and closure strategy.

foliage cover and species density within the range of values of the analogue sites in the reference ecosystem

no evidence of listed weed species and buffel grass

presence of leaf litter/organic material

erosion is comparable to surrounding environment.


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Rehabilitation monitoring programs will include assessments of erosion, vegetation cover, flora diversity, fauna colonisation and the presence of weeds.


If results of the monitoring programs reveal that the rehabilitation is not meeting the completion criteria set in the Mine Closure Plan (i.e. not meeting target vegetation growth, stability etc.), remedial work will be scoped, approved by regulatory authorities and completed to rectify any issues identified with the mine site rehabilitation.


Response timing Immediate response to any event impacting staff, environment and/or infrastructure.

Remediation timeframe dependent on type, nature and scale of issue.


Following all the rehabilitation work a rehabilitation/compliance audit will be conducted. The audit will focus on identifying any areas where rehabilitation requirements have not been met.

The results of all these monitoring programs will be reported annually within the MMP until the completion criteria have been met. Once completion criteria have been met annual monitoring will cease.

Responsible agency

NT DPIR

CLC - under the Aboriginal Land rights Act 1976



Aboriginal Land Rights(Northern Territory) Act 1976 (Cth)

5.6.7.6 Review Effectiveness of Management and Mitigation Strategies A review of the effectiveness of management and mitigation strategies for each specific EMP using the targets/objectives from the previous MMP has been completed and are discussed below.

Flora & Fauna/Biodiversity Management

In order to achieve the outlined objectives and targets in the specific EMP for biodiversity management the following management and mitigation strategies were implemented during operational phases: Biodiversity management during C&M is implemented in accordance with an approved Plan. The Biodiversity Management Plan and 2018 Monitoring Report are referenced in Appendices 4 and 2.

a) Progressive clearing: vegetation was only cleared when required to prevent exposure of soils to wind and water erosion. A land clearing procedure was introduced which required the approval of an internal clearing permit before any clearing took place. Prodigy’s land clearing procedure enabled the target ‘No loss of viable topsoil during clearing processes’ and ‘No vegetation clearing beyond approvals’ to be achieved during the operational period. No clearing was undertaken during the Reporting Period while the site was on C&M.

b) Weed control program: a quarterly weed control program was implemented during operations targeting buffel grass as well as using the employment of skilled Traditional


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Rangers. Five (5) campaigns were completed during the operational period, a summary of each campaign is provided as Appendix 3 submitted with previous year’s MMP. Each quarterly weed control campaign involved the digging out, chemical spraying and/or controlled burning of buffel grass at four (4) locations around Twin Bonanza with Prodigy environmental personnel monitoring the buffel grass between each campaign. The buffel grass at Twin Bonanza has reduced significantly at all four locations, with no new outbreaks of buffel grass (or any other weed) during the reporting period. Buffel grass requires minimal annual monitoring – hand weeding or chemical spraying of young shoots, which will be managed by exploration personnel. Weed control management strategies have been effective in reducing spread of weeds and thus reducing risks posed to flora biodiversity. In addition to the weed control program, all machinery and equipment was inspected for weeds and seeds both entering site and leaving site once operations ceased (a weeds and seeds inspection register is kept on site). No records showed evidence of weeds/seeds on machinery; however some machinery/equipment caked in mud was required to be washed in the designated wash down bay. The weed control program enabled the target ‘No introductions of non-native fauna and flora species (weeds)’ to be achieved over the reporting period.

c) Predator control program: a quarterly predator control program was undertaken during operations at Twin Bonanza targeting fox and cat control within a 15km radius of the centre of the project. The program objective was to decrease predation on bilby populations around the project area. No definite evidence of fox activity has been recorded within the area of Twin Bonanza. Six (6) cats were caught and removed during the operational period, no evidence of bilbies was found within any of these 6 cat stomachs. However, further analysis of a much larger sample size of cat scats that have been collected will give a better indication of the level of cat predation on bilbies. There is evidence of bilby activity located approximately 6km east of the mining area, with a total of 4 different individual bilbies captured on camera traps and numerous fresh bilby burrows, tracks, diggings and scats found. However, there is also evidence of cat activity in this area. It is too soon to assess whether the cat control program is directly contributing to increased survivorship and/or breeding success of bilbies due to reduced predation pressure, however the current trends are positive. The predator control program enabled the target ‘No introductions of non-native fauna and flora species (weeds)’ to be achieved during the operational stage of the Project. While visual monitoring of cat presence is undertaken around the landfill facility during periods when the exploration camp is occupied on C&M, lethal control programs ceased in mid-2016.

d) Biodiversity monitoring program: Biodiversity monitoring surveys have been undertaken by Low Ecological Services Pty Ltd (LES) in all 3 Stages of the Project: pre-operational (December 2014), during the short operational phase (June and December 2015) and during the post rehabilitation C&M Phase (June and December 2016, June 2017 and August 2018). The focus and frequency of the biodiversity monitoring program changed in 2016 to annual surveys with the completion of minesite rehabilitation. The monitoring program aims to monitor the impact of Twin Bonanza mining activities on biodiversity as well as gather data to support ongoing closure/rehabilitation of the mine. Assessment is through vegetation health surveys, palaeochannel tree health monitoring, fixed point photomonitoring and Ecosystem Function Analysis (EFA).

Paleochannel Health Monitoring: LES (2018) reports that groundwater level have increased marginally at all sites (between 0.08 and 0.45 m higher than the 2017 recorded levels) in the most recent survey and remained relatively stable. Average tree health scores declined at all sites from December 2016 to August 2018 including tree health at analogue site BF01


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located 1 km north of Timmy’s/Strezza’s bore. This continues an overall declining trend in tree health scores since (pre-operational) monitoring began in 2014. Average crown density and dead branch scores remained similar to 2016 values whilst litter had decreased at all sites. Vegetation abundance had similarly declined at all sites with an average reduction of 46% across all sites between December 2016 and August 2018. Plant stress was widely observed across the project area and declines in tree health and vegetation abundance are likely a response to below average rainfall in the year preceding the survey and ongoing impacts of widespread fires across the site in 2015.

The PHM program ceased in December 2016 following positive evidence that the limited past extraction of groundwater was not having a measurable impact on tree health and recommenced in August 2018 at DPIR’s request who were seeking 3 years of post closure abstraction data prior to the review scheduled in 2019 .

Activity Plot Monitoring: Although not required under current regulatory approvals, fauna signs were opportunistically observed and recorded during the 2018 survey period, both at survey sites and while traversing between survey sites. Signs of target threatened species, including bilbies (Macrotis lagotis) and brush-tailed mulgara (Dasycercus blythi), were searched for incidentally throughout the duration of the survey. No sign of brush-tailed mulgara was recorded in the August 2018 survey. Bilby burrows and scats were recorded at analogue site VH4, in the north-east of the project area adjacent to the pit. Diggings were located at the base of numerous Acacia lysiphloia shrubs across a 1 km2 area search area. No fresh tracks were recorded in the search area adjacent to site VH4. Signs of introduced fauna species including camels and cats were recorded in the project area.

Vegetation Health Monitoring: VHM was conducted at five baseline sites representing habitat types identified in the Twin Bonanza project area. Baseline data obtained has been used as a comparison for rehabilitated vegetation structures following closure and rehabilitation of the minesite. An extensive hot fire burned all survey sites in late October 2015, dramatically reducing vegetation coverage across the project area. Good post fire recovery was facilitated across most sites following above average summer rainfall in 2015 and 2016, with increasing vegetation coverage and species diversity recorded in the 2016 and 2017 surveys. Perennial vegetation cover continued to increase in the August 2018 survey however cover of annuals and species diversity had declined significantly across all sites. This is likely due to the dieback of post-rain ephemerals and below average rainfall in the year preceding the most recent survey.

Ecosystem Function Analysis: Three EFA analogue transects have been monitored from December 2014 to provide baseline data for comparison to waste rock landform rehabilitation sites. Eight EFA transects on waste rock landforms were established in early 2016 and monitoring conducted for the first time in June 2016. EFA sites were analysed for stability, infiltration, nutrient cycling, erosion and vegetation dynamics. Results were compared against ‘average’ regional data ranges established for the Tanami bioregion (Fairbrass, et al., 2013) and is used to predict achievable and acceptable completion criteria for rehabilitationof mine disturbed areas.

The EFA results at the analogue transects have been highly variable between sites and visits, with some apparent patterns relating to time since fire and seasonal and climatic variation. Stability, infiltration and nutrient cycling continue the general trend of fluctuating around average values for the region and erosion remains minimal.

EFA indices at rehabilitated Waste Rock Dump (WRD) results, continue to exhibit a high range in values in all indices scored. In August 2018, infiltration indices were recorded as increasing at most sites to within or above the regional average. Nutrient cycling scores


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had increased at half WRD site and decreased at half. Stability was found to have declined at the majority of WRD sites, with the exception of sites NDE and NDW. Perennial vegetation cover (<1 m) had increased at the majority of WRD sites, with the exception of NDN and SDS where a decline in vegetation cover was recorded.

Species diversity had conversely declined across all sites, likely the result of below average annual rainfall in the year preceding the 2018 survey. Mean bank erosion refers to the proportion of the slope hosting erosion lines and was previously recorded as average compared to the region at five sites (North Dump East (NDE), North Dump West (NDW), North Dump West Central (NDWC), In August 2018, below average (>9% mean bank erosion) was recorded at all WRD sites, ranging from 14.7% to 30.9% with LES (2018) recommending ongoing monitoring is required until a stable EFA index is achieved.

Photopoint Monitoring: PPM has shown that for the 2018 monitoring round, the number of species recorded at all sites had decreased; likely the result of below average rainfall in the preceding year. Vegetation regrowth was deemed to be progressing well at five sites (>15% vegetation cover); including the Contractor’s Area (CA), Explosive’s Magazine (EM), South ROM Pad (SROM), Southern sandstone stockpile (SSS) and Southern pisolite and topsoil stockpile (SPTS).

It is still early stages to make any valid conclusion on the overall status of revegetation of the waste dumps; however, vegetation regrowth is occurring slowly on the slopes but not to the same extent on the dump tops and minor localised erosion gullies are evident on the North dump. Photopoint monitoring stations have been established across a range of disturbed areas and further stations will be established at potentially high erosion risk locations in 2019. A scope for remedial earthworks will be prepared following the submission of the 2019 MMP.

e) Fortnightly environmental inspections: Site inspections were conducted fortnightly at Twin Bonanza during operations. A final environmental inspection of the site was conducted in June 2016 after all personnel had left site, and the mine was placed on Care and Maintenance. Site inspections during C&M are undertaken by the site manager of the confines of Wilsons Camp, the landfill and the refuelling facility during annual exploration campaigns.

f) Blast Vibration monitoring: Blast vibration monitoring was implemented at Twin Bonanza to ensure that ground vibration limits were not exceeding the AS2187.2-2006 standard of 25mm/s at known bilby locations (and that blasting was done at dawn and dusk when bilbies are most active i.e. between 4am-8am and 4pm-8pm). Blast vibration monitoring ceased at the close of mining in March 2016.

Mining operations at TWB (Old Pirate) ceased at the end of March 2016 with the project environmental focus shifting to biodiversity monitoring to support rehabilitation management. Therefore programs such as blast vibration monitoring, predator and weed control and activity track monitoring have been discontinued. However, maintaining equipment hygiene procedures, inspection of the fuel dispensing unit, RWD and production bore (Strezza’s), and monitoring of the landfill for cat signs during exploration occupation of the Site will continue. The biodiversity monitoring program will be conducted annually with a major review scheduled in 2019 to ensure rehabilitation stability and ecosystem function analysis data is available for input into completion criteria assessment. Relevant elements of the biodiversity monitoring have been incorporated into the post closure monitoring program. The scope of the fortnightly inspections have changed to reflect the current environmental risks associated with the exploration activities conducted at the site.


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Surface Water Management

In order to achieve the outlined objectives and targets in the specific EMP for surface water management the following management and mitigation strategies were implemented during the operational phase:

a) Fortnightly environmental inspections: Site inspections were conducted fortnightly (see Section 5.3.2.1 for details) during mining operations. No hydrocarbon spills were recorded during the 2017/18 reporting period and therefore surface water was not affected by hydrocarbons or chemicals. The target ‘Management including storage and handling of hazardous material and hydrocarbons aligned with Australian Standards’ was achieved.

As part of the operational fortnightly inspections, erosion and sediment control was monitored around the Site, including the raw water dam and sullage ponds. No major erosion, flooding or sediment runoff was recorded during the 2017/18 MMP reporting period. Erosion monitoring is now undertaken annually as part of the Biodiversity Monitoring Survey following the wet season. In addition to visual inspections of constructed and disturbed areas, EFA and Photo monitoring stations have been installed.

b) Drinking water monitoring: Potable water was monitored/analysed on a monthly basis during operations. The drinking water monitoring program has been discontinued since operations ceased end of March 2016 and the site reverted to an Exploration Camp. The use of the RO plant which injects Aquasafe into the potable water tanks automatically will be continued for the purposes of exploration personnel who may continue to use Wilsons Camp.

Groundwater Management

This section should be read in conjunction with Section 6. In order to achieve the outlined objectives and targets for groundwater management the following management and mitigation strategies were implemented:

a) Groundwater monitoring program: A monitoring bore network was set up around Twin Bonanza Project Area in order to undertake the baseline groundwater monitoring program in 2015 (Jan 2015 - Dec 2015). Monitoring of bores in the operational area was discontinued in 2017 following advice from DPIR.

b) Groundwater monitoring was undertaken in August 2018. Groundwater is monitored as per the Water Management Plan as amended (Appendix 7) and Groundwater Standard Operating Procedure (SOP). An external analysis of the results of the annual monitoring data was undertaken by Saprolite and full details of the 2018 report can be found in Appendix 3. A brief summary of the results of the groundwater chemistry indicate slightly alkaline pH across the project, typically between 7 and 8. Groundwater is typically saline at all monitoring and productions bores outside of the palaeochannel (Strezza’s borefield). Groundwater in the palaeochannel area is fresh to marginal. Sulphate is naturally high and above the ANZECC 2000 Livestock Watering Criteria guideline value of 1000mg/L. Nutrient contents and dissolved metals were typically low and below ANZECC guidelines.

In 2014 Saprolite conducted a Bore Completion Report which predicted the drawdown response of aquifers at each production bore. A comparison was made using actual abstraction rate data and standing water level data. The comparison indicated a better than predicted rate of drawdown over a relatively short period of abstraction.


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Average abstraction rates for 2017/18 are substantially below the respective recommended maximum pumping rates for Strezza’s bore (the only bore equipped for abstraction for Wilson’s Camp during 2017/18) as presented in the 2014 Bore Completion Report.

The Annual Groundwater Quality Assessment report (Saprolite 2018) indicates that abstraction rates and standing water levels in production bores were well within recommended limits and no impacts to aquifers are recorded. Chemistry analysis of the monitoring bore network results do not indicate any concerns. The groundwater sustainability management targets have been achieved.

Since Prodigy has ceased mining at Twin Bonanza and the site is on Care and Maintenance with intermittent visits by exploration staff, groundwater utilisation is limited, and Saprolite has recommended seeking approval for a less onerous groundwater monitoring schedule which includes (a) removal of Wilsons and Corsairs bores (and associated monitoring bores) from the monitoring schedule and (b) complete a stage I decommissioning of the two bores. Monitoring is only undertaken when exploration personnel are in residence.

Saprolite (2017 and 2018) has recommended, based on comparison of pre-operational monitoring results and those from the analogue bores in both fractured rock and palaeochannel aquifers (and accounting for natural fluctuations), that the original objective of maintaining a similar level of water quality post closure, as was present in the pre-mine environment, has been met.

Based on the data from post closure monitoring results, and comparison with pre-mining baseline data, which has continued to demonstrate the low potential risks to the groundwater environment, Prodigy are seeking to reduce current annual monitoring requirements to a mid-year triennial monitoring event commencing in 2019 following the DPIR review, while the site remains on Care and Maintenance. Prodigy are proposing the program would be reviewed and the relevant parameters and frequency amended as required in future MMPs if the current Care and Maintenance status changes. Prodigy’s request of 18 May 2017 to DPIR seeking changes to the Groundwater Monitoring program has resulted in some changes to the ongoing post Monitoring Program. The Annual Groundwater Monitoring Report for August 2018 is referenced in Appendix 3.

Fire Management

In order to achieve the outlined objectives and targets for fire management the following management and mitigation strategies were implemented:

a) Firebreaks: Firebreaks were constructed around the Site at 6m wide to prevent naturally occurring fires from damaging buildings and infrastructure and non-natural fires from spreading beyond operational areas. No infrastructure was damaged nor were personnel injured by fire during the reporting period. Firebreaks were an effective management strategy and enabled Prodigy to achieve the target ‘No human injuries or loss of equipment/facilities from bushfires.

b) Housekeeping: This involved the reducing of waste and dry vegetation around Site, not only along firebreaks but around infrastructure. Controlled burning between the camp infrastructure and the camp firebreak was undertaken to reduce the fuel load in the situation of a bushfire coming through the site. Waste was burnt on a regular basis (food scraps and cardboard etc.) to reduce the solid and putrescible waste around camp, burning of waste was undertaken early in the morning when wind and temperatures were at their lowest. All generators and buildings have been equipped with appropriate fire


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extinguishers. The storage of flammable and combustible liquids were stored in appropriately separated zones to fire risk areas. The general housekeeping at Twin Bonanza allowed for the target ‘no wildfires caused by mining activities, whether deliberate or accidental’ to be achieved.

c) Site Inductions: All personnel employed at Twin Bonanza were required to be inducted. Inductions covered environmental and safety aspects and informed all personnel of fire awareness and the requirement to obtain a Hot Work Permit before undertaking welding, cutting or grinding. Procedures in the case of fire are also addressed in inductions.

d) Fire Management Plan and Fire Response Action Plan: Prodigy implemented its Fire Management Plan (Appendix 13) during operations, as a result of the October 2015. The fire management plan guides policies and management practices relating to fire risk and safety as well as outlining legal obligations. The fire response action plan guides actions and responses in the case of an emergency bushfire using an alert level system (blue, yellow, red and grey). These documents have ensured safety of personnel and infrastructure as well as guided proper management practices during operations to minimise fire risk. These management strategies have therefore allowed for the target ‘noimproper practices leading to unsuitable fire regimes’ to be achieved over the reporting period.

Air Quality Management

In order to achieve the outlined objectives and targets in the specific EMP for air quality management the following management and mitigation strategies were implemented during the operational phase and have since been modified to reflect the reduced risks during Care and Maintenance:

a) Progressive clearing and progressive rehabilitation: During operations a conservative and progressive approach was followed, ensuring only the minimum area was cleared at one time and the majority of areas still vegetated/undisturbed. Rehabilitation of disturbed areas was completed as soon as practicable by covering over with topsoil and ripping in order to stabilise any areas exposed and thus minimise dust generation. No new clearing was undertaken in the reporting period.

b) Dust suppressants: In addition to the regular use of a water cart to suppress dust around the project, a dust suppressant chemical was added to the water cart which works by binding dust particles together, preventing the release of dust and subsequent deposition onto surrounding vegetation. Not undertaken in the reporting period.

c) Restricted vehicle movements: Vehicle speed restrictions were implemented around the project and restricted to cleared tracks and nominated tracks. Prodigy committed to the purchase of low sulphur diesel on site and maintenance of vehicles and machinery was conducted regularly to maximise efficiency and prevent incomplete combustion of hydrocarbons. Remains in force.

d) Dust monitoring program: Dust deposition monitoring gauges were placed in 4 strategic locations around the mine site and samples analysed monthly. The dust monitoring program ceased in February 2016.

Mineralised Waste Management

In order to achieve the outlined objectives and targets in the specific EMP for mineralised waste management the following management and mitigation strategies were implemented during mining operations and closure rehabilitation activities: No movement of mineralised waste was undertaken in the Reporting Period.


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a) Waste Rock Characterisation: Ongoing waste rock characterisation was undertaken on an ongoing basis and reported quarterly during operations to determine potential effects of exposed waste rock. The most recent waste characterisation report (October 2015) indicates that neither acidification, nor the production of saline (e.g. chloride-, and/or sulphate-enriched) discharges by the waste-dumps, are geochemical issues to contend with at Twin Bonanza. Sources of soluble-As forms are essentially negligible, or weak at most (e.g. SS-Oxide composite from OG Waste-Zone) and sources of soluble F may result in F concentrations in pore fluids and drainage-waters within the low-mg/L range initially, but decreasing to the sub-mg/L range following the elution of F loadings. A letter from the DPIR stated waste characterisation was no longer required.

b) Waste rock dump design and construction: In addition to waste characterisation, a waste rock identification method was adopted as part of the mining process to ensure appropriate scheduling and placement of waste in the waste rock dump. Thirdly, an appropriate design of the waste dump was developed to ensure structural integrity and selective handling of adverse materials. Based on the investigations and results of the October 2015 waste characterisation report, it was concluded by the author the management plan for the operation and closure of the waste-dumps for Twin Bonanza (ABM 2014) is deemed environmentally sound;

c) Existing tailings dam (raw water dam) designed appropriately and inspected regularly: The existing raw water dam was constructed with an HDPE liner to prevent seepage. The raw water/TSF dam has since been converted to the raw water dam which was inspected fortnightly as part of the environmental inspections to ensure appropriate freeboard capacity, the HDPE liner integrity was intact and monitoring of erosion of embankments was conducted with competent material filled into small erosion gullies before mining ceased

d) Waste rock dump management plan: The process and principles within the waste rock management plan were adhered to thus ensuring the waste rock dump was constructed to achieve the desired outcomes.

The above mentioned management and mitigation strategies have been effective in ensuring Prodigy met the following outlined targets: ‘maintain the existing structural integrity of the existing water/tailings dam’; no impacts to surface or groundwater quality’ and ‘management of waste rock identification and scheduling to ensure the waste rock dumps are constructed in accordance to the agreed design’. During operations the design of the north and south waste rock dump was altered due to the pits not being mined to the originally proposed depth and therefore less waste available to build the dump. Both waste dumps were only built to a height of the first lift at 10m (refer to Section 4.1.1).

Non-mineralised Waste Management

In order to achieve the outlined objectives and targets in the specific EMP for non-mineralised waste management the following management and mitigation strategies were implemented: a) Recycling: As far as practicable, waste has been segregated into recycling bulka bags and

carted off Site to appropriate recycling depots either in Alice Springs or Perth. This includes glass, aerosol cans, aluminium cans, scrap metal, batteries and waste kitchen oil;

b) Hydrocarbon Management: oil and grease contaminated items were disposed of in a number of hydrocarbon bins around Site and carted off Site to a licensed facility for disposal. Waste oil was kept in bulka containers until full and subsequently carted off Site for disposal. Hydrocarbon contaminated soils were disposed into the bioremediation pad and spills kept in a hydrocarbon spill register. Once the soil was remediated it was placed in the waste dump. A review of spill registers and inspections revealed that no


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contamination of the environment has occurred during the 2018 reporting period; and c) Fortnightly Inspections: Environmental inspections of the Camp area were undertaken

fortnightly to ensure waste around the Site was being managed appropriately. Rubbish pickups were conducted by exploration personnel who managed the burning of putrescible waste in a designated fenced burn pit to dissuade pest species.

The above management strategies have been effective in achieving the proposed targets: ‘notcontaminating surrounding environment’, ‘safely disposing of non-reusable and recyclable materials’ and ‘maximising the principle of avoid, reduce and recycle wherever possible’.

Cultural & Heritage Management

In order to achieve the outlined objectives and targets for cultural and heritage management the following management and mitigation strategies were implemented during the C&M phase. a) Inductions: All personnel at Twin Bonanza were required to be inducted, in the inductions

personnel were made aware of all heritage or cultural sites around the Site. These locations are displayed on map plans for all personnel to see and are demarcated and signed on ground. All personnel are made aware of the IF IN DOUBT – MARK IT OUT policy during inductions. This policy states that if an employee identifies a potential site they will mark it out with blue pegs and not disturb the site until an archaeological survey can be completed. A record of cultural/heritage sites is kept in the fortnightly inspections and is regularly monitored for disturbance or damage. During operations no damage or disturbance occurred on the aboriginal heritage area located in the mining area and no new sites were recorded.

b) Consultation with CLC: If Prodigy intend to disturb any new areas across the tenements in this MMP, the CLC is consulted to conduct surveys with Traditional Owners to determine areas of cultural/heritage significance.

c) Cultural Heritage Risk Management Plan: This management plan was implemented during operations and relates particularly to areas of potential archaeological significance. The management plan outlines the relevant legislation and obligations relating to cultural heritage, as well as policies and processes in the case that a potential site is discovered.

The above management plans have been effective in achieving the proposed targets for cultural and heritage management. During the reporting period, all targets were met:

No unapproved cultural heritage sites disturbed;

Prevention of unplanned economic social impacts on local community;

No adverse effect to traditional land management practices; and

No inadvertent impact on aesthetic and cultural values for local communities.

Social Management

In order to achieve the outlined objectives and targets in the specific EMP for social management the following management and mitigation strategies were implemented during the 2018 C&M phase: a) Ongoing consultation with CLC and Traditional Owners: Prodigy has consulted regularly

with landholders and communities during operations – any new disturbances or proposed works first seeks approval from the CLC. Any agreements as stipulated by Traditional Owners and the CLC, Prodigy has adhered to. Traditional Owners are not denied access to any part of the project area or surrounding areas for land management practices – except for reasons of mine safety. Where possible Prodigy sought the employment of local people via local communities first before advertising positions.


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b) Appropriate implementation of the environmental management plan: During C&M all environmental related management plans relevant to the status of the Project were implemented. In particular, the biodiversity management plan was adhered to throughout the reporting period with groundwater monitoring, tree health, vegetation health and EFA programs.

c) Adoption of appropriate health and safety practices and timely response to community/stakeholder concerns: A review of the incidents and complaints register revealed no records of concerns from the local community or stakeholders.

d) Prioritise local business/services: Prodigy utilised a procedure/policy whereby employees were to seek the business or service of a local NT company to provide services to Prodigy and thereby creating and supporting business within the NT.

e) Social Impact Management Plan: This management plan guided the legal obligations for social impacts and monitored the impacts of the project on key stakeholders (Traditional Owners, government, people and businesses of the NT).

The above management and mitigation strategies have been effective in achieving the targets for social impact management. All set targets, as stated below, were achieved during the reporting period:

Prevention of unplanned economic social impacts on local communities;

No environmental degradation across the entire ecosystem that has an effect on local communities; and

No complaints about social and community impacts.

Results from the biodiversity monitoring programs have indicated that while ecosystems across the Twin Bonanza have not been negatively impacted by mining activities, rehabilitation success is very dependent on a favourable climatic conditions. Prodigy has maintained an open and transparent relationship with the CLC during operations at Twin Bonanza. The project is extremely remote with the closest local community, Balgo, located 120km to the West and therefore there is little to no direct impact on communities.

Hazardous Substance Management

In order to achieve the outlined objectives and targets for hazardous substance management the following management and mitigation strategies were implemented: a) Appropriate storage and handling: Apart from hydrocarbons (i.e. fuel and oils) there was

minimal storage of hazardous substances at the Site. All fuel that was brought to Site was stored in an approved double skin/self bunded fuel container/tank. The refuelling bay is located more than 100m metres away from any watercourse. Storage facilities for dangerous goods/hazardous substances complied with the Dangerous Goods Act and Regulations 2012 (NT) as well as relevant SDS’s guidelines. All necessary licences were procured for the storage of dangerous goods (explosives etc.). All SDS’s were located in the safety office, where a register of all chemical substances is also stored. One case of inappropriate storage was recorded during the reporting period; Avgas drums were stored on unbunded pallets however the matter has since been rectified;

b) Fortnightly Inspections: Site environmental inspections were conducted fortnightly which involve the inspection of all bunding for damage, inspection of appropriate storage of hydrocarbons and other chemicals and the inspection of spill kits located in various areas around Site to ensure they are fully stocked. Environmental personnel ensured the appropriate transportation of hydrocarbon or hazardous waste offsite and disposed of into licensed facilities according to legislative requirements. Hydrocarbon management improved during the reporting period with the implementation of hydrocarbon bins


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strategically placed around site and a general tidy up which involved the removal of numerous waste oil drums;

c) Job Safety Analysis: Prior to any work involving the handling of hazardous substances a job safety analysis (JSA) is to be completed and repeated any time the scope of work changes. These JSA’s are then to be assessed and approved by area supervisor or safety officer; and

d) PPE: PPE which meets Australian Standards is available to all personnel on Site and is enforced as a requirement for all personnel. Stored SDS also provided specific PPE recommendations when handling a particular substance.

The above management and mitigation strategies were effective in achieving set targets:

No harm to environment or persons resulting from transport, storage and handling of dangerous goods;

Compliance with the required standards for the transport, handling and storage of chemicals and hazardous goods; and

No complaints from staff, contractors or the public.

Incidents & Complaints Management

In order to achieve the outlined objectives and targets in the specific EMP for incident reporting and complaints management the following management and mitigation strategies were implemented: a) Incidents & Complaints Procedure: A procedure was implemented during operations if a

compliant was received which required a number of actions to be undertaken. This included taking immediate action, reporting of the incident/complaint, undertaking an investigation, determining root cause, undertaking necessary corrective action and auditing of effectiveness of the action; and

b) Incidents & Complaints Register: A site register of all incidents and complaints is kept in order to monitor trends, actions taken and ensuring the closing out of complaints. DPIR has advised that the Incident Reporting Guide has been revised and that Operators are now required to record all environmental incidents and report them to the Chief Executive Officer of DPIR pursuant to Section 29 of the Management Mining Act.

No incidents or complaints were reported during the reporting period.

The management and mitigation strategies for Incidents & Complaints have been effective in achieving the proposed targets: ‘immediate action undertaken within the receipt of a complaint’, investigations completed within receipt of a complaint’ and ‘all corrective actions implemented by the nominated due date’.

Rehabilitation and Closure Management

In order to achieve the outlined objectives and targets for rehabilitation and closure management the following management and mitigation strategies were implemented: a) Topsoil recovery: During operations, 10cm of topsoil was recovered at all disturbed/cleared

areas and stored as a viable resource for rehabilitation. This included a topsoil stockpile at each waste dump that was recovered from the surface of the pits and stored for rehabilitation of the waste dumps at closure. The topsoil has been used as a growth medium on the surfaces of the waste dumps.

b) Progressive rehabilitation: Prodigy committed to progressive rehabilitation during operations and has rehabilitated all areas that were no longer required within four (4) weeks of site closure in April 2016. The rehabilitation of the waste dumps is complete on both waste


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dumps. All roads that are no longer required have been rehabilitated with the windrows pulled back over and ripped. Bore sumps have been backfilled. Unused burn pits have been backfilled and ripped. All exploration disturbances have been rehabilitated including the plugging of holes, ripping of pads and backfilling of costeans

c) Rehabilitation according to the Mine Closure Plan (MCP): The MCP was used as a guide for the rehabilitation progress of the project and included rehabilitation of the closure domains in accordance with the MCP (Appendix 14).

As only the pits, waste rock dump, rehabilitation stockpiles and selected roads have been rehabilitated at Twin Bonanza, not all whole of site (WOS) closure management and mitigation strategies have not yet been implemented, However, topsoil has been successfully recovered for all disturbed areas and progressive rehabilitation is completed and Prodigy is meeting closure objectives (safe, stable and non-polluting) by satisfying defined completion criteria defined in the MCP.

5.6.7.7 Non-Conformance and Corrective Action Incident and non-conformance management aims to identify hazards and system deficiencies to prevent recurrence. Moreover, findings from investigations were used to take corrective action and implement measures to prevent future occurrence. A review of corrective actions was put in place to ensure the actions were successful in preventing reoccurrence.

At the Site, the incident and non-conformance management process involved: 1. Reporting; 2. Investigations; 3. development and implementation of corrective actions; 4. priority given to corrective and preventive actions; 5. documenting incidents and non-conformances in the register; 6. statutory reporting if required; 7. using findings from incidents and non-conformance to improve systems, procedures and

processes; and 8. communicating incidents across operational staff and the organisation.

During the reporting period no non-conformances were identified. Corrective action covering EIP 2016/01 (erosion in Golden Hind Pit perimeter drain) was completed and inspected by DPIR during the inspection on the 27TH September 2017.


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Key Environmental Activities for the Oncoming Period Over the forthcoming period, no operational disturbance activities will be taking place across the project tenure; however the focus of environmental activities will continue to be biodiversity monitoring of rehabilitation and ground waters and identification of any remedial works required. Activities will include:

Monitoring of rehabilitation of disturbed mining areas, including vegetation regrowth, works required. Stability of waste dumps and erosion monitoring across the site using both EFA, photomonitoring and visual inspections;

Annual groundwater sampling in accordance with the revised DPIR correspondence of 13 June 2017 and biodiversity monitoring (including EFA on waste dumps)

The Bilby honours project research is completed and has been published on Prodigy’s website as part of the proposed EIS offsets. No further action is required in respect to monitoring of conservation species although opportunistic monitoring will be undertaken when environmental personnel are on site.

Correspondence has been received from DoEE Environmental Standards Division confirming that annual compliance reporting, in respect to EPBC Act Approval 2013/6784, may cease.


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WATER MANAGEMENT PLAN Water usage across the Site decreased significantly in 2016 as Stage 2 mining at Old Pirate finished in March 2016. Water during operations was used for camp and workshop purposes, dust suppression and blast hole drilling. During the 2018 reporting period water was sourced solely from Strezza’s Bore located in the paleochannel to service the Wilson’s Exploration Camp which was occupied intermittently for several months.

Strezza’s bore was constructed in July 2014 and commissioned in June 2015 at the site of an existing bore which had collapsed. Corsair and Wilson’s bores have not been abstracted since the site was placed on Care and Maintenance in March 2016, and Saprolite (2018) has suggested both bores be removed from the monitoring schedule and the bores undergo a Stage 1 decommissioning. The quality of Wilson’s bore water is lower than Strezza’s bore.

Current Conditions Sections 6.1.1 and 6.1.2 provides details on surface and groundwater based on the current information. A water balance to the cessation of mining (March 2016) was contained in Appendix 28 of the 2017 MMP. There is no proposed water balance for 2019 as no operations or activities will occur across the project, with the exception of exploration personnel pumping minimal water from Strezza’s bore on an as needs basis.

Surface water The Tanami Desert Region has a semi-arid climate, characterised by hot, wet summers and mild, relatively dry winters. Average annual rainfall in the region ranges from 400-500mm, and approximately 85% of this falls between November and April (Figure 6:1). Summer rainfall is characterised by infrequent, but intense rainfall events, with single events delivering > 50mm in 24 hours on average at least once per year (Table 6:1). Average pan evaporation for the region is approximately 2,800mm/yr, far exceeding the average annual rainfall.

The Project area is located relatively high in the landscape, and does not intersect any regional-scale surface water features (Figure 6:2). Flood modelling at 1:100yr flood levels highlighted that the majority of the main infrastructure areas are located on topographic highs with localised catchments and will have no inundation greater then 10cm. The shape of the landscape indicates that sheet flow will be the dominant surface water flow process, with some accumulation of flows possible in lower-lying areas after large storm events. The borefield and some sections of the main access road that intersect regional palaeochannels have the potential for higher 1:100yr flood levels approaching 1 to 2 metres.

Hydrological and hydrogeological setting

Table 6-1: Rainfall Frequency Data for the Project Area (depth, mm) (BOM, 2013)

Duration 1:1 yr 1:5 yr 1:10 yr 1:20 yr 1:50 yr 1:100 yr 1:1,000-yr

5Mins 6.3 10.4 11.8 13.5 15.8 17.6 23.1

10Mins 9.9 16.4 18.5 21.3 24.8 27.7 36.3

30Mins 19.4 31.9 35.9 41.3 48.2 53.5 55.3

1Hr 26.4 43.8 49.5 57 66.8 74.2 97.5

6Hrs 38.8 70.8 82.8 98.4 119.4 136.2 182.5

24Hrs 57.6 109.4 130.1 156.2 192 220.3 297.5

72Hrs 83.5 157.7 187.2 223.9 274.3 313.9 423.7


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Figure 6-1. Precipitation and Evaporation data for weather stations near Twin Bonanza.

As surface water across the Site is characterised by ephemeral sheet flow, surface water sampling can be problematic due to collecting representative samples and getting samples to a laboratory in a timely manner to prevent sample degradation. No surface water sampling was undertaken in 2018.


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Figure 6-2. Regional Digital Elevation Model with the location of the infrastructure detailed in black (Data Geoscience Australia, 1 Second STRM v 1.0 DEM-H).


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Groundwater A preliminary desktop hydrogeological assessment was completed in 2013. From the assessment a conceptual hydrogeological model has been developed based on the geological and hydrogeological setting and is summarised as follows:

The ML is almost exclusively located on a bedrock sequence of Proterozoic metasediments punctuated by the Buccaneer Monzogranite;

Deep Mesozoic palaeochannels are incised into the bedrock and are filled with alluvial sedimentary deposits including sands and gravels, clays and silts. Secondary calcrete and silcrete deposits are present in places within the channels;

Palaeochannels could be up to 5 or 6km wide and up to 90m thick, but local boreholes (Strezza’s/Timmy’s Bore) are shallower and only confirm depths up to 40m;

Surface water flow only occurs after periods of intense rainfall (>50mm in 24-48 hours) but can persist for several weeks or months. There is no permanent surface water flow;

Groundwater recharge to palaeochannel aquifers occurs primarily as a result of infiltration following periods of heavy rainfall. Rainfall levels across the region are low and evaporation and evapotranspiration rates are high. Rainfall intensity of >50mm in 24-48 hours is required to induce recharge. A total annual average of 4.5mm/year or 1% of rainfall is considered to be a reasonable estimate of recharge to palaeochannels (and potentially bedrock);

Groundwater flow in palaeochannels is intergranular whilst in calcrete and silcrete this is predominantly fracture flow. Fracture flow dominates in bedrock;

Groundwater resources are currently understood to be present locally at shallow depths in palaeochannel aquifers (approx. 5mbgl) and at depth in the bedrock aquifer (>90mbgl);

There is likely to be a hydraulic connection between calcrete, silcrete and alluvium in the palaeochannels;

Higher groundwater levels in the palaeochannel aquifers relative to the bedrock aquifers indicate that, within the Project area, there is likely to be poor hydraulic connection between these aquifers2. However, shallower bedrock water levels have been recorded within 40km of the Project area and this suggests that at some locations there is potential for a good hydraulic connection to exist. Groundwater recharge to bedrock aquifers is possible via percolation from palaeochannel aquifers;

Where a hydraulic connection exists between the palaeochannel and bedrock aquifers, the potential groundwater resource will be greater than that considered here, since there could be some flow from the bedrock aquifer to palaeochannels during extraction for Project water supply; and

Proximal to the Project area, groundwater yields from bedrock boreholes are estimated to be potentially up to 4L/s and of the order of 2L/s from palaeochannels,

On-ground work in 2014, targeted the two types of aquifers within the Project area to define the potential extraction yields. Hard-rock aquifers and an unconsolidated sedimentary aquifer hosted within Tertiary to Recent palaeochannels were targeted. Work was designed to define available water resources and sustainable yields. Work involved the following:

Drilling of a replacement production bore at Strezza’s/Timmy’s Bore (pre-existing bore collapsed) for longer term water supply (nominal casing size 155mmND);

Test Pumping Three (3) Production Bores:


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1. Two (2) pre-existing previously equipped production bores (Wilson’s Bore and Corsair Bore) to assess the existing pumping capacity; and

2. One (1) replacement production bore at Strezza’s/Timmy’s Bore to assess the longer term water resource capacity.

Pump testing confirmed that Corsair, Wilson’s and Strezza’s/Timmy’s bores fall within the expected ranges for the type of aquifers in which they occur (Table 6:2). Preliminary assessment has recommended that conservative pump rates over a five year period should be set at 1.3L/s for Corsair, 1L/s for Wilson’s (intermittent) and 5L/s for Strezza’s/Timmy’s Bore 2.


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Figure 6-3 Groundwater infrastructure / features (Please note Strezza’s/Timmys bore is included for completeness and has been redrilled as the original hole collapsed).


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Table 6-2: Production Bore Construction

Bore Easting Northing Casing

Elevation (mAHD)

Geology Depth

(m)(approximate)

Approximate Water Level

(mbgl) Notes

Corsair Bore 516540 7770174 438 Fractured bedrock 150 54

Drilled in 2010 near high yielding exploration borehole. Measured yield at this bore has been calculated at 1.3L/s. Average extraction rate of this bore during Stage 2 mining was 0.82L/s with a related drawdown of 0.75m. Water level drawdown did vary dependent on pumping rate.

Wilson’s Bore 513261 7767167 430 Unknown (Fractured bedrock?)

83 45

In 2013 bore was used intermittently for the bulk sampling. Measured yield at this bore has been calculated at 1L/s (intermittent). During 2015, extraction rate was 0.18L/s. During periods of sustained heavy pumping water levels dropped by 10 metres but rebounded once pumping ceased

Strezzas/Timmy’s Bore 2 509516 7764903 424

Palaeochannel –Tertiary silcrete and

alluvium. 42 3

Original bore hole is registered (RN016568). Bore redrilled in 2014 within 10m of the original bore. Measured yield at this bore has been calculated at 5L/s. Over a 7 month period with average extraction of 3.1L/s drawdown was 1.82m compared to the predicted drawdown of 4.39m.


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In addition, a total of 18 dedicated monitoring bores (nominal casing size 50mmND) were installed around the Project area in 2014. In 2016, monitoring campaigns involving the sampling of field parameters and water chemistry were completed and results are reported in Saprolite (2017). Following a submission to DPIR in May 2017, monitoring of these bores was discontinued. While the site is on C&M and exploration personnel are in attendance, monitoring of production bores will be undertaken if groundwater is abstracted. Because exploration is focussed elsewhere, it is anticipated that monitoring will be undertaken with annual biodiversity monitoring. This sampling is discussed in Section 6.4.

Information/Knowledge Gaps

Identification of Information/knowledge gaps The knowledge gaps that were identified in the pre operational MMP’s regarding surface and groundwater can be detailed as follows: 1. Establishment of baseline water conditions and resources for water quality and levels

associated with the fractured rock environments underlying the proposed site; and 2. Monitor effects on potential groundwater dependent ecosystems (GDE’S) that may be

associated with the palaeochannel systems.

Details on the progress to fill these knowledge gaps are provided in Section 6.2.2. Filling Information/Knowledge Gaps To infill the knowledge gaps from 2014, Prodigy has undertaken pump testing of Strezza’s/Timmy’s Corsair, and Wilson’s bores to determine the potential of the groundwater resource. Additionally, the following monitoring programs were implemented during the operational phase with some continuing during C&M:

Eight (8) groundwater sampling campaigns encompassing field parameters and water analysis of the water and monitoring bores;

End of month recordings of water extraction volumes and standing water levels; and

Five (5) palaeochannel monitoring events assessing tree health of selected trees at the production and monitoring bores in the palaeochannel. This monitoring has been focused on the deeper rooting plants that may be affected by water level changes.

Based on the current C&M status of the site, the significantly reduced water usage since March 2016, monitoring evidence of SWL recovery and similar limited water requirements in 2018/19, no significant risks to the environment or GDEs due to the limitations of groundwater information have been identified. As such current management measures are considered sufficient in light of limited impacts to groundwater resources reported in August 2018 – Appendix 3 (Saprolite 2018).

During the planned review of future monitoring requirements planned for 2019, the relevant government agencies will be consulted to ensure all programs meet agency requirements. Once completed, the findings and recommendations will be incorporated into future MMPs

Water Account

6.2.2.1 Water Account for the Previous Period A water account in accordance to the Minerals Council of Australia Water Accounting Framework was prepared for operations during 2015/16. Figure 6.4 provides a diagrammatic representation of water use in this period.


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Water usage during the completion of the Stage 2 mining in 2016 equated to approximately 26.29 ML. This usage occurred over a 4 month period from 1 January 2016 to 30 April 2016. Most water was used for mining operations with the majority used for dust suppression.

Non potable water storage on site is limited to the HDPE lined Raw Water Dam at the Pilot Plant. At any given time the dam could hold 3,000 tonnes and maintain adequate freeboard. Water losses occur through evaporation. As at February 2016 the only water in the system was incident rainfall that had collected within the dam as supernatant water (approximately 1,000 tonnes). Seepage from the facility is limited due to the presence of a HDPE liner.

Figure 6-4: Twin Bonanza 2016 Water Account

6.2.2.2 Water Account for the Upcoming Period During the upcoming 2018/19 period, the volume of projected water abstraction is anticipated to be minimal as mining operations ceased in March 2016 and the Project remains on C&M. Strezza’s bore will provide water for exploration personnel based at Wilsons Camp.

6.2.2.3 Water Account for a 1:100 Yr Peak Rainfall Scenario It is anticipated that the Water Account for a 1:100-yr peak rainfall scenario will not differ significantly from the Water Account prepared for average site conditions as identified during mining and would cover:

The majority of rainfall onsite will either be diverted around active areas, or will be collected in drains and directed out of the active work areas via sediment basins;

All diversions and drains have been specifically sized to handle the 1:100-yr peak storm flows; and

The surface water storages will be constructed and maintained with sufficient freeboard to accommodate a 1:100-yr storm event.


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Risk Management

Identify Hazards and Rank Risks Section 5.6.6 details the entire Site environmental risk assessment that was reviewed in 2017, with the sections below summarising the risks associated with water management. In addition, This section should be read in conjunction with Section 5.6.3.

Surface water

The following have been identified as the primary risks to surface water associated with post closure mining activities within the Project area:

Erosion of waste rock dumps and disturbed areas: Significant erosion of disturbed land areas has the potential to cause sedimentation of the surrounding near environment. Waste rock dumps are considered at increased risk of erosion, as these will contain disturbed soil materials, and with slope angles that are steeper than the surrounding natural landscape;

Failure of existing water/tailings dam and sewage pond: The water stored in the surface water storage facilities (i.e. raw water storage dam, and sewage pond) contain material that could result in short term local impacts to the natural environment. This collected rain water has the potential to contact the surrounding surface environment if the storage facility wall is compromised, but risks to the environment are considered low; and

Positioning of waste rock dumps, infrastructure and roads that inhibit surface flow: The positioning of infrastructure roads and elevated landforms has the potential to cause upslope ponding and deprive downslope vegetation of sheet flow.

Run off from disturbed surfaces are assessed as a low erosion risk to the post rehabilitated environment due to subdued natural topography variations which enhance resource trapping .

Groundwater

The following risks have been identified as the primary risk to groundwater associated with the mining activities within the Project area:

Chemical spills and uncontrolled waste disposal: Any chemicals stored (e.g. hydrocarbons) or landfill waste disposal on site have limited potential to come into contact with the groundwater system due to the depth (>40m) to the water table. Uncontrolled releases could result in localised degradation of surface soils that come into contact with any large volume the spilled material. Due to the soil profile lithology and type of fractured rock aquifer present in the TWB area, the potential to restrict future uses of the groundwater if substantial seepage were occurs is ranked as low risk.;

Liberation of leachates from the waste rock dumps: Any rock types that can potentially liberate elements due to being exposed to atmospheric conditions could degrade the quality of surface soils and thus enter the groundwater. The depths to groundwater in the mine area are deep (below mining depth), subsurface lithologies are clay rich, providing reduced infiltration capacity and potential for attenuation and in combination these attributes represents a low risk of leachates contaminating groundwater.

The potential risk associated with the liberation of elements from the crushed gravity residue was not included as a significant risk as the crushed material stored in a dam have not been treated with chemicals and the dam has been HDPE lined. The liner was 2mm and QA during installation to ensure a permeability barrier of 1x10-11m/s was established. Ongoing inspections have not detected any deterioration in the liner.


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Further detail of the risks with associated mitigation and management measures are detailed in Section 5.6.7 and 6.3.2.

Actions and Strategies in Response to Identified Risks

6.3.2.1 Surface water The following strategies are implemented to mitigate the risks to surface water identified in Section 6.3.1. Not all risks are present during C&M.

Failure of existing the water dam and sewage pond: In order to avoid failure of the water storages, each of these facilities (i.e. water storage dam, and sewage pond) were constructed with a minimum freeboard sufficient to hold the entire volume of a 1:100-yr, 72-hr rainfall event.) to ensure that the maximum operating level is not exceeded. Additionally, the majority of water contained in the facilities remained below ground. Regular inspections will be undertaken to identify any issues. Additionally, external embankments are monitored with remedial action undertaken in respect to developing erosion gullies.

Erosion of waste rock dumps and disturbed areas: To manage erosion at these areas within the Project. The measures taken will include:

Implementation and adherence to an Erosion and Sedimentation Control Plan across the site, and

Annual inspection and monitoring of waste rock dumps for erosion;

Lower quality water discharge and uncontrolled waste disposal: The strategies and measures adopted to manage spills of hydrocarbons, uncontrolled waste and pipeline leaks will include:

Bunding of all fuel and chemical storage areas to contain the potential volume of spillage if not self bunded;

Appropriate storage and handling of hazardous materials and monitoring of storage facilities in accordance with AS1940;

Adequate training (e.g. inductions);

Regular inspections to ensure meeting objectives for the management for containment of storage vessels and small containers;

Spill kits available for use at refuelling areas if required;

Management of waste types to ensure onsite and offsite disposal meets regulatory requirements; and

Regular pipeline inspections and repairs if required; • Positioning of waste rock dumps, infrastructure and roads that inhibit surface water

flow: The strategies and measures adopted to manage the effect of the mine footprint includes:

Locating waste rock dumps and infrastructure in small catchment areas and designing a compact site layout to reduce the number of affected catchments;

Implementation and adherence to an Erosion and Sedimentation Control Plan across site;

Construction of diversion structures to pass water downslope of the Site;

Construction of roads at the level of the natural ground surface; and

Allow water of an appropriate quality to discharge downstream of disturbed areas.


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6.3.2.2 Groundwater The following strategies are being implemented to mitigate the risks to groundwater identified in Section 6.3.1:

Chemical spills and uncontrolled waste disposal: The strategies and measures adopted to manage spills of hydrocarbons and other chemicals, and uncontrolled waste will include:

Bunding of all fuel and chemical storage areas to contain the potential volume of spillage if not self bunded;

Appropriate storage and handling of hazardous materials and monitoring of storage facilities;

Adequate training (e.g. inductions);

Regular inspections to ensure meeting objectives for the management for containment of storage vessels and small containers;

Spill kits available for use at refuelling areas if required; and

Management of waste types to ensure onsite and offsite disposal meets regulatory requirements;

Liberation of leachates from the waste rock dump: The strategies and measures will be in accordance to the Waste Rock Dump Management Plan (Appendix 6) that is based on waste rock characterisation. The plan includes:• Waste rock types and volumes; • Design and construction of the waste rock dumps; • Identification and scheduling of waste rock during mining; and • Management of surface water.

Monitoring During the EIS process a draft Water Management Plan was prepared which has undergone further reviews based on input from hydrological works, operational and regulator feedback and post closure monitoring. This section should be read in conjunction with Section 6.1.

The Project occurs in a mineralised geological system with some analytes having naturally higher concentrations than those in the ANZECC 2000 Livestock Watering Criteria, the 2015 sampling data has been used to define warning and trigger levels. These levels will be used during closure monitoring. Further details are provided in Appendix 3 and Section 6.4.2. The pH across the bores ranged from 6.02 to 8.03. Two of the three production bores are located in fractured rock aquifers exhibited higher EC, TDS and major cations in comparison to the palaeochannel aquifer which is a shallow annual recharge aquifer.

Monitoring Program Work in 2013 focused on collating available literature and data in the vicinity of the Site. Ground water studies in 2014 focused on collecting an initial set of baseline results comprising physical and chemical parameters. The objective of the more extensive monitoring program in 2015/16 when water draw was highest for operational usage, was to build upon the existing data to create an understanding on natural conditions overtime, set warning limits for future monitoring and to potentially detect any changes overtime in the mine impacted areas. Monitoring during the first half of 2016 was to monitor effects of water abstraction for mining on ground water aquifers in both fractured rock and paleochannel environments. Saprolite (2017) commented that comparison of pre operational monitoring results and with those from the analogue bores in both


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fractures and paleochannel aquifers (and accounting for natural fluctuations) suggest the original objective of maintaining a similar level of water quality post closure has been met. Biodiversity monitoring of paleochannel tree health confirms the absence of impacts to vegetation from mine related abstraction. The 2017/18 monitoring report confirms the findings reported 12 months after mining ceased. The report is included as Appendix 3.

The raw water dam was used as a water storage dam for the 2015-2016 operations. Regular water samples were collected from the facility to assess if any potential gravity tailings reactions were occurring and the effects of mixing bore water from Strezza’s, Corsair and Wilson’s bore. The water samples were tested for a full suite of dissolved metals, TDS, major ions, petroleum hydrocarbons and general parameters (e.g. pH and electrical conductivity). The dam was not utilised during the 2017/18 reporting period and observations during the site inspections suggests it was largely dry for the period when personnel were on site.

Data Review & Interpretation. The monitoring data is provided in Appendix 3. An interpretation of the water monitoring data from the Raw Water Dam and water bores are provided below.

6.4.2.1 Raw Water Dam - pH and Alkalinity The pH was alkaline over the period with levels fluctuating throughout the year with values ranging from 8.15-8.84 pH units. Results for the water dam are a reflection of the bore input of Corsair, Wilsons and Strezza’s, that can range up to pH 8, temperature and the high level of evaporation experienced at the site.

Alkalinity is again dominated by the bicarbonate ion. The bicarbonate concentration in the water dam ranged from 124mg/L to 228mg/L.

6.4.2.2 Raw Water Dam TDS & Electrical conductivity (EC) TDS values declined from 6,160mg/L to 1,160mg/L reflecting the greater input of Strezza’s bore after June 2015. EC and TDS trends are reflective of each other over the 2015 period with EC declining.

6.4.2.3 Raw Water Dam Major Anions - Sulfate (SO4), Chloride (Cl) and Fluoride (F) Sulfate concentration range declined dramatically from 1,320mg/L to 190mg/L. Reflecting the larger combined water input from Corsair (196mg/L to 361mg/L) and Strezza’s (9mg/L to 109mg/L) bore. Chloride, also showed a similar trend, however fluoride increased from 0.9 to 1.2 reflecting high fluoride levels within the palaeochannel aquifer (Strezza’s bore).

6.4.2.4 Raw Water Dam Major Cations – Ca, Mg, Na and K Calcium magnesium, sodium and potassium concentrations declined greatly.

6.4.2.5 Raw Water Dam BTEX (N), Total Petroleum Hydrocarbons (TPH) and TRH There are no changes in BTEXN, TPH and TRH in the water dam with also results below detection limits. Highlighting no hydrocarbon products entered the dam during operational use or during C&M.

6.4.2.6 Raw Water Dam Water Dissolved Metals The majority of metals recorded values below or just above the limits of detection with arsenic, barium, uranium and boron being above detection limits. Arsenic (from 0.119mg/l to 0.049mg/L) uranium (from 0.045mg/L to 0.012mg/L) and boron (from 0.89mg/L to 0.38mg/L) all showed


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declining trends whereas barium increased from 0.032mg/L to 0.293mg/L. Changes in metal concentrations was a function of the increase input of Strezza’s bore.

6.4.2.7 Conclusion Water quality testing for the water storage facility to the cessation of mining has indicated the water input from Corsair and Wilson’s bores determined the water chemistry during the period of mining use. An improvement in water chemistry from June 2015 onwards is the result of the input of Strezza’s bore which became the major source of water. Additionally, the water chemistry has also been affected by temperature and evaporation. From this perspective the nature/impacts of the gravity crushings contained at the bottom of the dam are as predicted with little if any input affecting the water chemistry.

6.4.2.8 Strezza’s/Timmy’s Groundwater Production Bore and Monitoring Bores BF01 – BF04 (Palaeochannel Aquifer) During the August 2018 monitoring event groundwater field parameter pH values were 7.37 in both bores. This value is consistent with the historic range of 7.6 to 8.03 classifying Strezza’s, and BF01 to BF04 as slightly alkaline

Across the metals a large proportion are below or just at detection levels potentially indicating that limited metals are present and/or groundwater conditions are not conducive for metal liberation.

Boron ranged from 0.02mg/L to 0.46mg/L across the bores reflecting localised variation. High levels of Boron in groundwater is generally associated with evaporite minerals that contain sodium or calcium borate salts. Upon dissolution these salts produce the primary dissolved species of boron - orthoboric acid (H3BO3), although orthoboric acid will only dissociate at high pH levels. At pH levels less than 8.2, the ration of H3BO3 to H2BO3- is greater than 10 to 1 (Roscoe Moss Company, 1990).

Barium levels ranged from 0.148 – 0.44mg/L. Barium generally forms insoluble compounds with other components such as carbonates, chromates, fluorides, oxalates, phosphates and sulphates and therefore is not normally mobile. Although the acetates, halides and nitrates are soluble in water; the solubility of these barium compounds do increase with deceasing pH levels (increasing acidity levels). Organic barium compounds are ionic and are hydrolysed in water therefore the concentration of barium ions in natural aquatic systems is limited by the presence of naturally occurring anions and possibly also by adsorption onto metal oxides and hydroxides.

F is naturally elevated with the highest reading being obtained at BF04 that recorded 2.1mg/L.

The measurements for BTEXN, TPH and TRH at Strezza’s were below detection limits, highlighting that no hydrocarbon products were present in the aquifer.

In conclusion, monitoring over the period has again recorded natural variations in water chemistry with the water quality reflective of groundwater chemistry of other upper catchment palaeochannels seen in the Tanami region (Table 6.4).

6.4.2.9 Corsair Groundwater Production Bore and Surrogate Bore M11 Since 2014, the water chemistry at Corsair and M11 has been reasonably consistent with some natural oscillations during the period. No water was abstracted from Corsairs bore during the reporting period which is decommissioned.

Arsenic is naturally elevated in Corsair ranging from 0.062mg/L to 0.209mg/L. Results for August 2018 were slightly lower at 0.04mg/L.

In August 2014, elevated levels of BTEXN, TPH and TRH were reported in Corsair bore, further


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investigation determined that the presence of the hydrocarbons was due to the use of drilling hammer oil that was present on the surface of the standing water level and was sampled by the sample bailer. Subsequent sampling via the submersible production pump in 2015, that was located deeper in the water column, reported BTEXN, TPH and TRH below detection limits. Previous testing at M11 the surrogate sampling bore located adjacent to Corsair has not recorded the presence of hydrocarbons. Hydrocarbon sampling is not required if no source of hydrocarbon is stored or used at the well head.

Monitoring over the period has recorded natural variation in water chemistry with the water quality reflective of groundwater chemistry of other bedrock aquifers seen in the Tanami region (Table 6.4). As the bore is decommissioned Saprolite (2018) has recommended further monitoring is not justified unless the bore is recommissioned.

6.4.2.10 Wilson’s Groundwater Production Bore and Surrogate Bore M10A Wilsons and M10A have the highest TDS of all the production bores with Wilsons consistently around 8,000mg/L and M10A around 10,000mg/L. In the August 2018 monitoring event TDS was 7,950 mg/L. Over the longer period, water chemistry of the two bores has been fairly consistent with only minor natural variations.

In summary, monitoring over the period has recorded natural variation in water chemistry with the water quality reflective of groundwater chemistry of other bedrock aquifers seen in the Tanami region (Table 6.4). This bore has been decommissioned and Saprolite (2018) has recommended further monitoring is not justified unless the bore is recommissioned.

6.4.2.11 Groundwater Monitoring Bores M01, M09 and A01-A03 All the shallow monitoring bores A02, A03, M01, M02, M03, M04, drilled to 36 or 42 metres, have remained dry during previous monitoring events and were authorised for removal from the monitoring schedule (DPIR correspondence 15th June 2017).

Due to the loss of sampling equipment previously down the hole and the related time taken to retrieve it A01 (analogue/control bore 5km north of mine impact) was only sampled from August through to December 2015. Water sampling was again conducted during August 2018 and despite the hole access difficulties, sampling was successfully completed. Water quality is saline with a TDS of 7,060mg/L, but generally consistent with previous results. Of interest is that fluoride is naturally elevated ranging from 1.8mg/L.

In conclusion, monitoring evidence suggests the presence of the mine has had no discernible impact on the groundwater resource. It is likely that the minor variation in some analyte concentrations during the period is a function of seasonal variations in groundwater conditions.

6.4.2.12 Groundwater Extraction from Wilson’s, Corsair and Strezza’s/Timmy’s This section should be read in conjunction with Section 6.2.3 and Appendix 3. A total of 24.3ML of groundwater was extracted over the mining period with 22.7ML extracted from Strezza’s/Timmy’s, 1.3ML from Corsair and 8.35ML from Wilsons. Extraction levels were slightly lower than estimated with 24.3ML extracted versus the pre-mining estimate of 25.1ML. The minor difference was due to the semi-arid and windy climate conditions that results in the ongoing management of dust using water as a dust suppressant. The required extraction levels were accommodated by the commissioning of Strezza’s/Timmys bore. Averaged over the year the overall extract rates for each bore were less than the sustainable measured yield from hydrogeological testing. The responses in standing water level at each bore to these extraction rates aligned to predicted drawdowns (Appendix 3). Figure 6.6 provides a comparison of the mining extraction rates versus water level drawdown for the various bores.


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Figure 6-5: Water Extraction and SWL at Twin Bonanza during the 2015/16 reporting period


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While limited abstraction occurred from Strezza’s bore to support Wilson’s Camp no abstraction was undertaken from Corsair or Wilson’s bores which are both decommissioned.

6.4.2.13 Proposed Changes to the Groundwater Monitoring Program Mining operations ceased end of March 2016, with all rehabilitation work finalised in April 2016. Since April 2016 there has been minimal personnel onsite, and since no activities (exploration or mining) are planned for the 2017/18 period and monitoring over several sites in 2015/16 has shown no impacts to groundwater resources, a reduction in monitoring was proposed by Saprolite in their assessment report.

Following representation to DPIR in May 2017 some changes to the monitoring program were authorised (DPIR June 2017). The revised groundwater monitoring schedule outlined in Table 6.3 commenced in 2018. Further details of the schedule are contained in Appendix 3 and in correspondence to DPIR (Appendix 39). In 2016, in order to monitor groundwater chemistry immediately after cessation of activities, groundwater monitoring occurred in March, June and December 2016 in conjunction with Biodiversity monitoring programs. As a result of changes to the annual MMP reporting dates, future annual sampling will be undertaken in midyear of each year. During 2017/18 water abstraction and water levels were monitored as in Table 6.3.

Table 6-3: Proposed Monitoring Program 2017/18

Area Monitoring Locations Parameters Frequency

Water Supply Bores

Production Bores

Corsair Bore, Wilson’s Bore, and Strezza’s/Timmy’s Bore.

Abstraction (kl)¹ Annually

Water Levels (mbtc) Annually

Field Parameters², Laboratory³ Parameters, Major Ions and Cations,Metals/Metalloids,Hydrocarbon

Annually

Monitoring Bores (associated with production bores) M10a, M11 and BF03A

Water Levels Annually

Paleochannel Monitoring Bores BF01, BF02, and BF04


Analogue Bore

Monitor Bores (Deep) A01


Field Parameters, Laboratory Parameters, Major Ions, Metals/Metalloids

Annually

¹Abstraction: Meter readings, pump status, duration of pump status. ²Field Parameters: Electrical conductivity (EC) and pH. ³Laboratory Parameters: Electrical conductivity (EC), pH and total dissolved solids (TDS). Major Ions Ca, Na, Mg, K, SO4, Cl, HCO3, CO3, F

Metals/Metalloids: Al, Sb, As, B, Cd, Cr, Cu, Pb, Hg, Ni, Mn, Se, U, V, and Zn, Hydrocarbons: Total Petroleum Hydrocarbons (TPH (C6-C36)) and Total Recoverable Hydrocarbons (TRH (C6-C40)) for

bores with associated hydrocarbon storage.


Page 145 of 171

Table 6-4: Summary of Historical Groundwater Quality Data and Current Wilson's, Corsair and Strezza's/Timmy's Bore Monitoring.

Analyte

Registered boresWilson’s

(MonitoringResults)

Corsair (MonitoringResults)

Strezza’s/Timmy’s(MonitoringResults)

NRMMC(2011)1

Bedrock Palaeovalley Bedrock/Palaeovalley Bedrock Palaeovalley

pH 7.3 – 7.6 7.6 – 8.1 7.33 7.96 7.43 7.87 7.67 8.03 n/a

EC (μS/cm) 1,570 –9,860

9,100 –14,070 11,100 13,000 2,300 3,570 508 857 n/a

TDS (mg/L) 955 –7,610 4,700 – 9,710 7,330 – 7,840 1400 – 2,480 318 604 1,200

Totalhardness(mg/L)

421 –6,360 939 – 2,100 1,830 1,030 190 201 500

Totalalkalinity(mg/L)

210 – 462 221 – 424 504 611 237 – 354 190 269 n/a

Na (mg/L) 148 –1,435 1,204 – 2,135 1,640 – 2,020 220 342 27 122 n/a

K (mg/L) 26 – 128 163 – 330 165 – 199 35 52 29 44 n/a

Ca (mg/L) 76 – 948 100 – 173 156 283 103 172 26 41 n/a

Mg (mg/L) 49 – 1,019 143 – 339 303 384 85 145 19 24 n/a

Fe (mg/L) 0.2 – 1.3 < 0.1 – 5.3 <0.05 <0.05 <0.1 n/a

SiO2 (mg/L) 13 – 38 76 – 80 106 n/a

Cl (mg/L) 260 –8,260 400 – 3,724 2,290 3080 489 807 20 91 5

SO4 (mg/L) 103 –4,464 428 – 1,690 1,620 – 2,210 162 368 19 21 500

NO3 (mg/L) 0 – 53 158 – 252 <0.01 <0.01 23 50

HCO3 (mg/L) 243 – 431 269 – 517 504 611 250 354 196 281 n/a

CO3 (mg/L) 0 – 31 <1 0 n/a

F (mg/L) 0.7 – 1.8 1.5 – 2.3 0.8 – 1.2 0.4 – 0.6 0.9 – 1.9 n/a

PO4 (mg/L) < 1 < 1 n/a

NaCl (mg/L) 659 – 6,137 40 n/a

Al (mg/L) <0.01 0.04 <0.01 – 0.02 <0.04 0.2

As (mg/L) 0.001 – 0.005 0.062 – 0.209 0.002 – 0.009 0.01


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Analyte

Registered boresWilson’s

(MonitoringResults)

Corsair (MonitoringResults)

Strezza’s/Timmy’s(MonitoringResults)

NRMMC(2011)1

Bedrock Palaeovalley Bedrock/Palaeovalley Bedrock Palaeovalley

Be (mg/L) <0.001 <0.001 <0.001 0.06

Ba (mg/L) 0.017 – 0.020 0.017 – 0.059 0.08 – 0.48 2

Cd (mg/L) <0.0001 0.0001 0.0013 <0.0001 0.002

Cr (mg/L) 0.007 0.014 <0.001 – 0.003 <0.001 0.05

Co (mg/L) <0.001 <0.001 0.001 <0.001 n/a

Cu (mg/L) 0.003 – 0.008 <0.001 – 0.002 <0.001 0.001 2

Pb (mg/L) <0.001 <0.001 <0.001 0.01

Mn (mg/L) <0.001 – 0.002 0.009 0.28 <0.001 – 0.018 0.5

Mo (mg/L) <0.001 <0.001 0.05

Ni (mg/L) 0.001 0.004 <0.001 – 0.01 <0.001 – 0.001 0.02

Se (mg/L) 0.01 0.03 <0.01 – 0.01 <0.01 0.01

Sr (mg/L) 4.5 2.88 n/a

Ti (mg/L) <0.01 <0.01 n/a

V (mg/L) <0.01 <0.01 <0.01 0.02 n/a

Zn (mg/L) <0.005 0.041 0.007 – 0.124 <0.005 0.205 3

B (mg/L) 1.14 – 1.42 0.56 – 0.66 0.17 – 0.32 4

Notes: 1 Australian Drinking Water Guidelines (bolded values exceed the guidelines

Management

Remedial or Corrective Management Actions Troubles experienced with airlifting of monitoring bore M09 resulted in hydrocarbon products entering the bore. During 2015, a drill rig was used to airlift the hole on two occasions resulting in a large reduction in TPH concentrations. This trend has continued in 2016 with TPH fractions (C10-C36) falling from 2.41mg/L in June 2016 to below detectable limits (<50μg/L) in December 2016. In accordance with DPIR correspondence of 18 June 2017, monitoring for hydrocarbons will cease, except at bores where hydrocarbons are stored in close proximity. Actions Proposed Over the Reporting Period and their Potential to Impact on Water Quality

No actions were undertaken over the reporting period in respect to the borefield that would impact on water quality.


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INCIDENT REPORTING

During the 2017/18 reporting period zero incidents was recorded in the Environmental Incidents Register and one outstanding EIP was actioned. The EIP related to erosion occurring in a former pit permitter drain (Golden Hind) that had not received appropriate diversionary closure works. The matter was identified during a DPIR site inspection on 9 August 2016 and reported in Inspection Report MR 2016/0296.

Environmental Improvement Plan (EIP2016/02) was prepared and submitted to DPIR on 7 November 2016. Implementation of the plan was completed in August 2017.

Advice was received form DPIR in October 2017 site operators are required to record all environmental incidents in a site register and report them to the CEO of DPIR pursuant to Section 29 of the Mining Management Act. The advice is noted and included in site incident site procedures.


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Table 7-1: Recorded Incidents during Reporting Period (March 2016 – June 2018)

Date Nature of Incident Cause of Incident Negative Outcomes Actions taken to Rectify/Remediate/Rehabilitate

Reported to Authorities?

Operational actions taken to address future

management of similar incidents

Jan-16 Localized erosion on some waste dump profiles

Onflow of water from top surface catchment. Surface has not yet been contoured to dish shape.

Rehabilitation of sections of waste rock dump could be comprised if erosion gullies develop.

Install dish shape contour on top surface and incorporate compartmentalised bunds within dish.

No.

Scheduling of top surface contouring to be completed prior to finalisation of slope rehabilitation in April 2016 Annual stability monitoring included in EFA and photomonitoring programs-ongoing.

August 16

Erosion in permitter drain of Golden Hind pit.

Low angle drain installed outside of abandonment bund on long slope to direct water away from pit without diversion structures to direct run off back into natural flow zones

Confirmed erosion and uncontrolled sediment loss into rehabilitation areas

Environmental Improvement Plan (EIP 2016/02) prepared to manage remedial works. Photomonitoring station established to monitor post remedial outcomes.

Identified during DPIR Inspection

August 2016

Slope drainage requirements to be included in any future .mine planning. Erosion control; structures installed in September 2017

2017/18 No incidents reported in reporting period. - - - N/A -


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CLOSURE PLANNING Prodigy has two (2) separate management documents for closure planning: Mine Closure Plan; and Care and Maintenance Plan.

Closure planning detailed in this section should be read in conjunction with the two closure documents. With the Site occurring on Aboriginal freehold land (Mt Frederick No. 2 Aboriginal Land Trust) that is used by Traditional Owners for traditional land practices, the intended closure strategies have been aligned so that the end land use is compatible with current land practices. Prodigy acknowledges that the land belongs to the Traditional Owners and will attempt to rehabilitate to as close as practicable to the original state and in accordance with agreements in place with the Traditional Owners.

The main objective of post-mining closure and rehabilitation is to restore a natural ecosystem back to as near as possible to the pre-disturbance ecosystem, thus integrating into current land management practices. The closure objectives can be summarised as follows:

Meeting Compliance;

Infrastructure and rubbish clean-up;

Physical safety (all landforms are structurally safe thus preventing effects on health and wellbeing of people and fauna);

Stability of landforms and landscape (including visual amenity), design and build landforms to be non-polluting;

Re-establish soil profiles and establish vegetation that will be comparable in function and resilience to surrounding ecosystem; and

Low risk to biota, successfully revegetate to encourage the use by native fauna.

Further detail on closure criteria and actions to achieve criteria are provided in Table 6 of the Mine Closure Plan (MCP) (Appendix 14). Table 8-1 below shows progression against the closure objectives documented in Table 6 of the MCP:

Table 8-1: Progression against closure objectives as per Mine Closure Plan

Objective Section in MCP

Progress

Meeting compliance (CLC, NT Govt., Commonwealth Govt. and commitments

Table 6 of Mine Closure Plan

Ongoing. Performance indicator: “continuing agreement and compliance on closure strategies leading to the relinquishment of mine site tenure”. The DPIR has relinquished half of the Twin Bonanza security bond, indicating that rehabilitation and closure of the site was in good standing during the DPIR audit in August 2016. All reporting requirements have been met with both DPIR and CLC. All Commonwealth conditions have been met during the reporting period and annual compliance reporting to Cwlth has ceased. All 2016 MMP commitments regarding closure were met (recovering topsoil, progressive rehabilitation etc) – see Appendix 10 performance against commitments for more details. Multiple event (3) closure, biodiversity, groundwater and erosion monitoring occurred in August 2018. Following release of new Project authorisation and September 17 report submission, some elements of past closure monitoring have been revised (i.e. biodiversity, groundwater) and will report annually until Departmental review in 2019.


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Infrastructure and rubbish clean up


Achieved. All non-required infrastructure has been removed from site (dongas, mess, workshops, offices, ablutions, machinery). The only remaining infrastructure is the pilot processing plant and raw water dam, a small portion of Wilson’s camp and a small workshop. This infrastructure will remain for exploration personnel and the processing plant and dam for possible future trial mining of Buccaneer deposit. All rubbish has been removed from site or was burned in the rubbish pit. According to DPIR audit in August 2016, the status of rehabilitation and cleanliness of Twin Bonanza was in good standing.

Physical safety (all landforms are structurally safe thus preventing effects on health and wellbeing of people and fauna)


Achieved and ongoing. All non-required infrastructure has been removed. Closure of open pit access using safety bund and signage has been completed. All explosives and chemicals removed from site – limited fuel is stored in fuel tank for exploration personnel. Stability and erosion monitoring have been expanded, are ongoing and will continue until monitoring results illustrate stable landforms and acceptable levels of erosion no greater than analogue sites occur.

Stability of landforms and landscape (including visual amenity), design and build landforms to be non-polluting


Ongoing. Post closure groundwater and surface water monitoring commenced in 2016 and will continue annually until results confirm no discernible changes in quality and are consistent with baseline data. Erosion monitoring commenced in 2016 and will continue annually until erosion is no longer greater than analogue site data. A review of monitoring requirements will be made in mid-2019. Waste material movement was planned and monitored to ensure most erosion resistant and inert material was placed on external batters; topsoil was recovered and placed on batters of waste dumps to allow for a growth medium. Revegetation is evident on both waste dumps but has not yet achieved positive reconciliation with Analogue site/completion criteria. Drainage is consistent with closure designs as per Erosion and Sediment Control Plan – however some drainage structures are causing erosion, are being closely monitored and will be remediated once available machinery is on site.

Revegetated or otherwise improve, re-establish soil profiles and establish vegetation that will be comparable in function and resilience to surrounding ecosystem


Achieved and ongoing. Soil profiles across the site are compliant with the design and closure plan strategy (quartz at centre, sandstone and inert material on outer profile and pisolite/topsoil profile on external batter). Topsoil volumes were sufficient for capping waste dumps and covering all cleared areas. EFA monitoring results are still in the very early stages and a conclusion on the success of the rehabilitation cannot be made at this early stage – however noticeable revegetation is occurring on waste dumps and no weed species have occurred in any rehabilitated areas.

Low risk to biota, successfully revegetate to encourage the use by native fauna


Achieved and ongoing. Removal of all non-required infrastructure to prevent obstruction to fauna movement has been completed. Biodiversity reports indicate some fauna movement.


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Rehabilitation and Closure Activities For the purposes of rehabilitation, Twin Bonanza has been divided into a number of rehabilitation domains that represent separate features which require differing rehabilitation treatments. This section of the 2018 MMP is a synopsis of the rehabilitation detail for each domain; further details are outlined in Appendix 14: (Mine Closure Plan). Prodigy has completed rehabilitation of each of the domains as detailed in the following sections. Generally, areas have been contoured back to original ground level or into stable landforms, compacted areas ripped to allow infiltration of water and covered by 100mm of topsoil. Since areas have been rehabilitated, signage and access has been restricted with bunds to prevent disturbance to the rehabilitation. The closure domains are as follows, each with brief details of their completed rehabilitation methods:

Raw water dam;

trial processing area;

haul and access roads;

bores and pipelines;

exploration areas (i.e. drilling and trenching);

accommodation village;

waste rock dumps;

ROM areas and low grade stockpile;

pisolite and sandstone stockpiles;

workshop areas and hydrocarbon areas (including explosive magazine);

pits;

airstrip; and

borrow pits.

During the 2015/16 reporting period the following domains were rehabilitated:

trial processing area (except for pilot processing plant and raw water dam);

haul and access roads (no longer required roads rehabilitated);

exploration areas (except for the 48 drill holes at Buccaneer)

accommodation village (2 dongas remain for exploration);

waste rock landforms;

ROM areas and low grade stockpile;

pisolite and sandstone stockpiles);

workshop areas and hydrocarbon areas (offices and explosive magazine completed, part of workshop remains for exploration);

Wilson’s and Corsair bores were decommissioned,

pits; and

borrow pits (areas exhausted of gravel rehabilitated).


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Raw Water Storage Dam The decommissioning and rehabilitation of the raw water dam is proposed to be completed as part of the final site closure the Whole of Site (WOS) project. Prior to being used as a water dam the facility was used for the disposal of gravity residues (tailings not treated with chemicals) during the 2013 Bulk Sampling program. To manage seepage during the trial the facility was fully lined with a 2mm plastic HDPE liner.

Prodigy has received approval from the CLC to leave the HDPE plastic liner below the gravity materials in situ (contained in the MMP under Authorisation 730-01).

The dam will be backfilled using the embankments as fill. As all of the material cannot be placed back into the dam an elevated pad (1.3m) will be formed. The elevated pad will ensure that any future subsidence will not leave a depression below ground level. Walls will be sloped to 15 degrees to establish a low angle, low erosion profile.

Trial Processing Area The pilot processing plant has not yet been decommissioned and rehabilitated as it may still be used for future trial mining (possibly from the Buccaneer deposit). However, when a decision is made to rehabilitate it, the following process will take place.

Prior to rehabilitation any reagents and fluids will be removed. Prodigy proposes to dismantle and remove the plant and associated steel work. This material will be recycled and removed from Site. Concrete pads are inert and will be broken up and disposed of in a purpose approved costean.

Once the plant has been removed any residual ore or residual ore material will be graded into windrows and placed in the raw water dam. The area will then be re-contoured into the surrounding landscape, ripped and covered with topsoil to ensure water infiltration, establish a soil profile and vegetation regrowth.

Haul and Access Roads The current access road provides entry into the region for the Traditional Owners to undertake land management and traditional practices. During consultation with the CLC confirmation will be sought as to whether the Traditional Owners wish the access road and any other roads to remain after closure. DPIR will be advised of the outcome.

Rehabilitation of roads that are no longer required, involve lengthwise ripping, windrows being pulled back across the road and natural drainage patterns being re-established, where possible. The compacted surface will be ripped to promote water infiltration.

Bores and Pipelines Pipelines consist of HDPE black poly pipe and are still in place for Wilson’s, Corsair and Strezza’s for possible future use. Pipelines will either be rehabilitated by rolling up for removal off site or cut into sections for reuse or recycled unless the Traditional Owners request the pipelines be left in place. If required, pipeline routes will be ripped to breakup compacted areas that may have formed during the movement of vehicles along the pipeline. Groundwater bores will be decommissioned to industry standards (NUDLC 2012), well head infrastructure removed and the surrounds rehabilitated if they are not transferred to the Traditional Owners or a third party. Rehabilitation of the bore holes will encompass:

the removal of pumping infrastructure; and headworks

the permanent plugging of the holes below surface; and

reshaping the surface, topsoil placement and ripping of any compacted areas.


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Exploration Areas (i.e. drilling and exploration trenching) In general, exploration disturbance (including costeans, sumps, access tracks, drill pads etc.) were back filled to the natural surface, mounded to accommodate settlement (where necessary) and ripped. Drill holes have been permanently plugged below ground. All rubbish/waste will be removed from site and/or disposed of appropriately on Site.

Accommodation Village

The buildings leased to Prodigy within the accommodation village have been demobilised by the leasing company. The remaining Prodigy owned buildings at Wilsons Camp have been retained for relocation to future projects in the region or removed altogether at a later stage. For decommissioned areas, below ground services (i.e. electrical cabling) within 0.5 metre of the surface have been removed. Deeper services were cut 0.5 metre below the ground surface and backfilled. Ponds, landfills and below ground septic systems have not yet been decommissioned due to exploration personal making use of the camp. However, in future, they well be decommissioned and backfilled. The area will then be re-contoured into the surrounding landscape, ripped and covered with topsoil to ensure water infiltration, establish a soil profile and vegetation regrowth.

ROM Pad Areas and Low Grade Stockpiles Two (2) ROM pad areas were constructed within the project to manage the differing ore grade stockpiles produced from the various pits. Following removal of all stockpiles from the ROM pads, any residual ore material was graded into windrows and processed at the processing plant. The area was re-contoured into the surrounding landscape, ripped and covered with topsoil to ensure water infiltration, the establishment of a soil profile and vegetation re-growth.

All low grade stockpiles were processed at the Coyote processing plant with the majority of the material reporting to the Coyote tailings dam.

Pisolite and Sandstone Stockpiles

The pisolite and sandstone stockpiles were located adjacent to the NWRD and SWRD and were used to encapsulate waste within the waste rock dumps. Once the stockpile material was placed on the waste rock dumps, the remaining area on which the stockpiles were located was re-contoured into the surrounding landscape, ripped and covered with topsoil to ensure water infiltration, the establishment of a soil profile and re-vegetation.

Waste Rock Dumps As a result of a lower than expected performance of the ore body (i.e. lower gold grades), the NWRD and SWRD did not obtain the intended design due to a reduction in mined waste volumes. A redesign of the dumps has ensured the non-economic quartz and erosion susceptible siltstone was encapsulated in the centre of the waste rock dump with inert sandstone placed on the external batters (Appendix 6). The external batters were designed to be stable if constructed at 18 ; in light of the reduced waste volumes, batter slopes were constructed at 15 . During

construction/rehabilitation, the waste rock dumps were assessed to ensure the impact of each waste rock dump is in harmony with the cultural landscape so that slope angles and height are compatible with similar to the natural hilly vista observed in the region.

Workshop Areas and Hydrocarbon Areas (including explosive magazine) The hydrocarbon and chemical tanks stored at the workshop have been emptied, decommissioned and transported off Site. The majority of the workshop and all associated machinery has been dismantled and removed from Site - except for two sea containers with a


Page 154 of 171

dome which have been left for exploration use. Once the workshop and hydrocarbon storage tanks were removed and any hydrocarbon contaminated soils (if any spills occurred) were collected, the area was re-contoured into the surrounding landscape, ripped and covered with topsoil to ensure water infiltration, establish a soil profile and vegetation to support regrowth.

Pits The pits have been left as open voids. Abandonment bunds have been constructed around the perimeter of the pit void (in accordance to the current WA guideline titled “Safety Bund Walls Around Abandoned Open Pit Mines” (DOIR 1997). The establishment of the bund is to make the pit safe, by minimising inadvertent access after closure. Old Glory pit and Old Pirate East have been backfilled and the infill contoured to blend in with the surrounds. Erosion control structures have been installed in the Golden Hind perimeter drain.

Airstrip The airstrip remains for exploration personal and regional emergency use. At the time of final (walk away) closure, stakeholders will be consulted on final land use, and if the strip is no longer required all the cones, the wind sock and shelter will be removed from the airstrip. The surface will be contoured and ripped with available topsoil placed over the surface. As the airstrip covers a large area and is located on a slope, ripping will be along the slope contour to minimize erosion.

Borrow Pits For areas that were exhausted of gravel, the internal batters of the borrow pits were re-contoured to 140 [1(V):4(H)] into the surrounding landscape, ripped and covered with topsoil to ensure water infiltration, establish a soil profile and re-vegetation. Where practicable the re-contouring the aim was to minimize the amount of water that will be stored in the depression. Gravel stockpiles that were not used remain for possible future works on the Tanami road, once these have been used the same rehabilitation methods as above will be undertaken.

Life of Plan – Unplanned Closure This section is no longer applicable to the mining component of the project, since closure was anticipated (and occurred) by March 2016 in accordance with the plan. Since closure, the Site has been made secure, safe and each domain’s rehabilitation as documented above has been implemented. The risk assessment in Section 5.6.2 identified that “Failure to undertake progressive rehabilitation” and “Inappropriate resourcing of rehabilitation” would affect successful closure outcomes; this is also the case for unplanned closure. However, resourcing of material for rehabilitation was undertaken at early stages of the project and therefore sufficient rehabilitation material volumes were available for all cleared/disturbed areas.

The majority of the Twin Bonanza project has been rehabilitated and closed out, however the pilot processing area and Wilson’s camp are on care and maintenance and more details are provided in the Care and Maintenance Plan (Appendix 15).

Planning

8.2.1.1 Environmental audit Prodigy completed a post closure environmental inspection in June 2016, two months after closure of the site. DPIR inspections were conducted in August 2016 (MR2016/0296) September 2017 and May 2018 (MR2017/0332). The aim of these audits/inspections was to establish the status of all disturbed areas and infrastructure with respect to the environmental risks and to identify any issues that may limit closure success or requires remediation.


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8.2.1.2 Volumes of Key Rehabilitation Materials Sufficient material volumes were available to ensure the rehabilitation strategies were attainable. The rehabilitation materials balance contained in the Mine Closure Plan illustrates that adequate materials were available for rehabilitation of the Site. All disturbed areas were replaced with a minimum of 10cm of topsoil.

8.2.1.3 Progressive Rehabilitation and Remediation Prodigy committed to undertaking, where practical, progressive rehabilitation to reduce liabilities and ensure progression towards land use objectives. Prodigy fulfilled this commitment and before mining ceased, rehabilitation works were underway so that onsite machinery could be used before demobilisation. Once an area was no longer required, topsoil was spread over and the area ripped to allow water infiltration and vegetation regrowth.

8.2.1.4 Monitoring and Maintenance Once rehabilitation was completed, rehabilitated landforms were monitored using EFA monitoring photopoint, erosion monitoring, a rehabilitation/compliance audit and groundwater and surface water monitoring. The objective of the monitoring is to identify whether a rehabilitated site is progressing to be stable, non-polluting and self-sustaining ecosystem comparative to the target ecosystem. Monitoring programs occurred in June, December 2016, June 2017 and August 2018, with results reported in LES (2017a,b and 2018) and Saprolite (2018)

Results of all monitoring and inspections were recorded as per usual processes and analysed by competent and qualified people. In the event that the rehabilitation is not trending as anticipated, remedial actions will be reviewed and an EIP prepared for necessary actions.

8.2.1.5 Reporting Regular reporting to the NT DPIR on the current status of rehabilitation and closure activities will be contained in subsequent MMPs in accordance with the new reporting timeframe. Any environmental incidents and potential major incidents will be reported at the time of occurrence and/or discovery.

Background for Costing of Closure Activities Details of the background information used for the security estimate are detailed below in Table 8:2. Additional information was contained in the comments section of the Security “Calculation Tool” (Provided as Appendix 32 to the 2017 MMP).


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Table 8-2: Disturbance Detail used in Security Calculation


DisturbanceType

Volume(m3)

Proposed area (ha)2014 MMP andamendments

Actual/Existingarea (ha) as ofFeb 2016

Description Comment Validator

EngulfedDisturbanceOP Central A Pit 0.0631 (not

included in total)0.0631 (notincluded intotal)

Open Pit Excavation2013 Bulk Sample

Verified by surveypick up. Disturbancenot used in totaldisturbancecalculation.

BV

OP Central B Pit 0.0251 (notincluded in total)

0.0251 (notincluded intotal)



BV

OP Central C Pit 0.0789 (notincluded in total)




BV

OP Central E Pit 0.0099 (notincluded in total)




BV

OP Central F Pit 0.0062 (notincluded in total)


Open Pit Excavation2013 Bulk Sample.


BV

OP Central J Pit 0.065 (not includedin total)




BV

OP Central K Pit 0.0561 (notincluded in total)




BV

OP east A Pit 0.0327 (notincluded in total)




BV

OP East B Pit 0.0177 (notincluded in total)




BV


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DisturbanceType

Volume(m3)




OP East C Pit 0.0183 (notincluded in total)




BV

OP East D Pit 0.0097 (notincluded in total)




BV

OP East E Pit 0.0202 (notincluded in total)




BV

OP South Pit 0.0868 (notincluded in total)




BV

OP WesternLimb Pit

0.27 (not includedin total)




BV

Golden Hind Pit 0.1655 (notincluded in total)




BV

Total Pits 13,258 0.9252 0.9252 Subtotal Majority engulfed bythe mining footprint

Mining Area(includes pits at0.9252ha)

8.86 (not includedin total)


2013 Bulk Sample. Verified by surveypick up. Of themining area 1.8hawill not be engulfed

BV

Mining Area(Bulk samplepits not fullyengulfed)

710 for 0.068ha for 0.068ha 2013 Bulk Sample All pits backfilled

BV

Rehabilitatedbulk sample

1.8 1.8 Subtotal Area rehabilitatedJR

Pits

Golden HindMine Pit

399725 1.9 1.986 Volumes reflectboth ore and waste.

Verified by surveypick up.

HW

Central andSouth Mine Pit



HW

Old Pirate EastMine Pit



HW

Western LimbMine Pit



HW


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DisturbanceType

Volume(m3)




Old Glory BulkSample Pits



HW

Total Mine Pits 1472055 9.69 8.623 Subtotal Engulfs bulk samplemining area.

ROM

Golden HindROM

1.13 1.09 Ore received fromGolden Hind

Verified by surveypick up

HW

Old Pirate ROM 1.99 1.74 Ore received fromCentre, East, Westand South OldPirate


HW

Total ROMs 3.12 2.83 Subtotal

Stockpiles

Golden HindPisoliteStockpile

0.64 0.64 Used forrehabilitation


HW

Old PiratePisoliteStockpile

2.52 2.49 Used forrehabilitation


HW

Golden HindSandstoneStockpile

107799 1.4 2.41 Used forrehabilitation


HW

Old PirateSandstoneStockpile

186811 2.4 2.37 Used forrehabilitation


HW

Total Stockpiles 6.96 7.91 Subtotal

Waste RockDumpsGolden HindWaste RockDump

497618 7.09 6.47 Waste from GoldenHind


HW

Old PirateWaste RockDump

1288922 14.61 14.45 Waste from Centre,East, West andSouth Old Pirate.14.45ha includes1.3ha for toeextension.


HW

Total WasteRock Dumps

21.7 20.92 Subtotal

TopsoilStockpilesGolden HindTopsoilStockpile

1.7 1.68 Topsoil fromGolden Hind Pit,Stockpiles andWaste Rock Dump


HW

Old PirateTopsoilStockpile

3.92 3.91 Topsoil fromCentre, East, Westand South OldPirate Pits,Stockpiles andWaste Rock Dump


HW


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DisturbanceType

Volume(m3)




Road TopsoilStockpile

0.5 0.5 Multiple stockpilesin close proximity toclearing areas.


HW

ExplosiveMagazineTopsoilStockpile

0.14 0.5 Topsoil/Pisolitestockpiles along Nand S edge ofmagazine

Verified by on groundpersonnel

FB

Water DamTopsoilstockpile

0.05 0.05 Existing

Process TopsoilStockpile

0.18 0.18 Existing

Contractor AreaTopsoilStockpile

0.14 0.78 Topsoil/pisolitestockpiles alongwestern side andeastern side


FB

Abandonmentbund topsoil

0.04 0 Never cleared thearea forabandonment bund


HW

Minor AreasTopsoilStockpile

0.01 0.01 Verified by surveypick up

HW

Total TopsoilStockpiles

6.68 7.61 Subtotal

Mining AreaInfrastructureExistingProcessing area

1.23 1.23 2013 Bulk Sample.Includes topsoilstockpiles.

Verified by aerialimagery

KB

Existing ROMpad (includedin processingarea)

0.2 (not included intotal)


Storage andmanagement of orestockpiles.

Verified by aerialimagery.Incorporated in theworkshop area.

KB

MiningContractorsArea

1.36 1.2 Includes offices,bioremediation padand go line


HW

Tailings/Waterstorage

18,700(materialexcavatedto createturkeysnest)

1.35 1.35 Current tails/waterstorage facility.

Verified by surveyand aerial imagery

KB

Explosivemagazine

1.7 1.47 Area 100 by 170mcontainingexplosive storage


HW

Diversion drainsmining area

5.29 2.28 Diversion drainsaround the pits,waste rock dumpsand stockpiles


HW

Abandonmentbund

2.77 0.74 Abandonment bundlocated aroundmining pits at 2.5mwide. No clearingundertaken.


HW


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DisturbanceType

Volume(m3)




Contingencyminor areas

0.1 0.78 Minor laydown areaincludes currentsand pile near bulksample 125m2.New standpipe andwalking track.


HW

Total MiningInfrastructure

13.8 9.05 Subtotal

Fire Breaks

Fire breaks 1.05 0 No firebreaks wereconstructed aroundmine infrastructure.


HW

Fire breakscamp

0.64 1.21 Fire break extendedfrom 6 metres wideto 10m during wildbushfirethreatening camparea. A number ofsmall emergencyfirebreaks wereconstructed nearcamp.


HW

TotalFirebreaks

1.69 1.21 Subtotal

Roads

Access Road 1366 22.69 12.84 Within ML29822 22m wide road fromML boundary to Haulroad intersection(5km). 8m wide roadfrom Haul roadintersection to camp(2.3km).

HW

Roads 8.8 9.66 Maintained roadsacross project forexploration, bore,explosivesmagazine, Stezza'sand Wilsons.


HW

Haul road 3 3 1.3km Haul roadlinking north of OldPirate to accessroad. Includes roadintersection. Andmine area haulroads.


HW


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DisturbanceType

Volume(m3)




3 borrow pitsand accessroads

32.86 5.2 1 borrow pit (8ha)never clearedwithin ML28922.Remaining 2 pits(16ha) not clearedto full proposedarea. Includes0.86ha of originallyproposed borrowpits and spoondrains.


HW

Total Roads 67.35 30.7 Subtotal

Camp Area

Camp 4.4 4.4 Existing disturbanceused for laydown,storage and landfill.


KB

Diversion drainscamp area

1.04 0.43 Drains associatedwith the camp andwaste water pond.No drain built atburn pit.


HW

Water bores 0.2 0.2 Each Water Bore30m x 30m area.


KB

Airstrip 12.1 (not includedin total)


Based on airstrip1.6km length x 80mwidth and arefuelling/turnaround area. Notwithin EL28322


KB

ExistingLandfill/burnarea

1.8x10 8 (notincluded in total)

1.8x10 8 (notincluded intotal)

Burn area withfenced landfill area.Contained withincamp area.


KB

New burn Areaand Landfill

2219 1 1.02 Burn area forrubbish.


HW

Existing sewagepondwastewaterarea

1.9 1.9 Earthen dam forleaching andevaporation.


KB

New wastewater pond

2890 1 0.88 Earthen dam forleaching andevaporation,including topsoilstockpile butexcluding drainarea.


HW

Tracks 1.33 0.15 Tracks to gainaccess to burn andwaste water area


HW

Total Campinfrastructure

10.87 8.98 Subtotal


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DisturbanceType

Volume(m3)




Exploration

Proposed/completed drilling

0 15.92 0 Proposed clearingfor 2016 drilling notundertaken

AvR

Proposed/completedcosteaning

0 14.87 0 All costeanrehabilitated andno furtherproposedcosteaning.


JL

Proposed/completedexplorationtracks

3.4 0 No furtherproposed tracks tobe cleared.

Prodigy 20102012 drilling

0.63 0 All outstandingliabilities nowrehabilitated.

As confirmed viainternal rehab audit

HW

TotalExploration

34.82 0 Subtotal

Totaldisturbance

178.48 104.783 Total Twin Bonanza Substantial footprintreduction

Security Estimate Disturbance values used in the calculator have, for the post rehabilitation phase, been sourced from Table 8:2. Existing disturbance areas have been established via on-ground surveys or by aerial photograph.

The estimate is consistent with third party costs and remediation requirements for the current liabilities in the event of an unplanned closure as detailed in Section 8. In accordance with the new Authorisation 0909/01 (MDOC2016/09884), DPIR has determined the discounted current security amount required to be $1,223,952.

As no change to site environmental liabilities have been identified in monitoring and regulatory inspection reports, no revision to the current security calculation has been undertaken.


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Table 8-3: Security Estimation for Upgraded Twin Bonanza Gold Mine Project 01/09/17


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ABBREVIATIONSAAPA Aboriginal Areas Protection Authority ABA Acid Base Accounting ABM ABM Resources NL or Proponent or Company (now Prodigy Gold NL) AC Air Core AHD Australian Height Datum ALARP As Low As Reasonably Practicable AMD Acid Mine Drainage ANCOLD Australian National Committee on Large Dams ANZECC Australian and New Zealand Environment and Conservation Council AQMP Air Quality Management Plan APR Acid Potential Ratio ARD Acid Rock Drainage (also known as Acid Mine Drainage – AMD) AS/NZS Australian Standard/New Zealand Standard ASLP Australian Standard Leaching Procedure BCM Bank Cubic Metres BOM Bureau of Meteorology BPESC Best Practice Erosion and Sediment Control Guidelines BTEXN Benzene, Toluene, Ethylbenzene, Xylene, Naphthalene CEC Cation Exchange Capacity CLC Central Land Council Cth Commonwealth DD Diamond Drilling DEM-H Digital Elevation Model DLRM Department of Land Resource Management DME Department of Mines and Energy DPIR Department of Primary Industries and Resources (previously DME) DOC Dissolved Organic Carbon DOE Department of Environment EFA Ecosystem Function Analysis EC Electrical Conductivity EIS Environmental Impact Statement EL Exploration Licence EMP Environmental Management Plan EMR Environmental Mining Report EPA Environmental Protection Agency EPBC Act Environment Protection and Biodiversity Conservation Act (Commonwealth) ERMP Emergency Response Management Plan g/t Grams per Tonne GDE Groundwater Dependent Ecosystems GWR Gravity wash residues in Raw Water Dam from Trial mining ha Hectares HB Hand Book HCL Hydrochloric Acid HDPE High-density polyethethylene liner material HSEC Health Safety and Environment Coordinator


Page 168 of 171

IECA International Erosion Control Associations ISO International Organisation for Standardisation JORC Joint Ore Reserves Committee km kilometres KOW Octanol Water Partition Coefficient kW kilo Watts L/s Litres per second LOR Limit of Reporting

LPSD The Leading Practice Sustainable Development Program for the Mining Industry is a program that promotes sustainable development and industry self-regulation through proactive adoption of leading practice principles.

m Meters m3 Cubic Meters mAHD Meters Australian Height Datum mbgl m below ground level MEC Mining Environmental Compliance mg/l Milligrams Per Litre MGA94 Map Grid of Australia 1994 ML Mining Lease MLA Mining Lease Application MMA Mining Management Act (NT) MMP Mining Management Plan MSDS Material Safety Data Sheet NAF Non Acid Forming NAG Net Acid Generation NL No Liability NRETAS Department of Natural Resources, Environment the Arts & Sport (NT) NT Northern Territory NTEPA Northern Territory Environment Protection Authority NUA National Uniform Authority NUL National Uniform Legislation OH&S Occupational Health & Safety OP Old Pirate OPR Operational Performance Report oz Ounce

PAF Potentially Acid Forming PAH Polycyclic Aromatic Hydrocarbons PPE Personal Protective Equipment ppm Parts per million Prodigy Prodigy Gold NL (formerly ABM Resources NL) PVC Poly(vinyl chloride) QA Quality Assurance RWD Raw Water Dam – used to store limited crushed surface rock from gravity

processing trial and water. RL Reduced Level (based on AHD) RMP Regional Management Plan


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RO Reverse Osmosis ROM Run of Mine SEWPaC Department of Sustainability, Environment, Water, Population and

Communities SG Specific Gravity TDS Total Dissolved Solids TGNL Tanami Gold NL THHMP Tim Hill Heritage Management and Planning TO’s Traditional Owners TOC Total Organic Carbon TPH Total Petroleum Hydrocarbons TPWC Act Territory Parks and Wildlife Conservation Act TRH Total Recoverable Hydrocarbons TSF Tailings Storage Facility uS/cm Microsiemens Per Centimetre UV Ultra Violet VOC Volatile Organic Carbons WMP Water Management Plan WONS Weeds of National Significance WRD Waste Rock Dump WCPL Woolard Consulting Pty Ltd


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APPENDICES

Appendix 1 – Regulatory Communications Appendix 2 – Biodiversity Monitoring Report (LES 2018) Appendix 3 – Annual Groundwater Monitoring Report (Saprolite August 2018) Appendix 4 – Biodiversity Management Plan 1.K Appendix 5 – Twin Bonanza Rehabilitation Report (Updated August 2018) Appendix 6 – Waste Rock Dump Management Plan 2.0 Appendix 7 – Water Management Plan (updated November 2018) Appendix 8 – Erosion and Sediment Control Plan RevC4 Appendix 9 – MMP Commitments (updated October 2018) Appendix 10 – Performance against 2017 MMP Commitments (October 2018) Appendix 11 – Emergency Response Management Plan 3.0 Appendix 12 – Twin Bonanza Risk Assessment 1.0 Appendix 13 – Fire Management Plan Appendix 14 – Mine Closure Plan (updated November 2018) Appendix 15 – Care and Maintenance Plan Appendix 16 – Hazardous Substance Management Plan 1.0

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Mining Management Plan - Prodigy Gold · Project Description ... DESIGN AND CONSTRUCTION METHOD. ... Table 8-3: Security Estimation for Upgraded Twin Bonanza Gold Mine Project 01/09/17