Report. Banksia Woodland Rehabilitation - Age 7

Transcription

1 Falcon Report Compliance 2017 Banksia Woodland Rehabilitation - Age 7

2 MS790 Compliance Report 2017 CONTENTS: 1. Introduction Company Number and Site Address Site Operations and Lease Description Environmental Management System Project Status Compliance Monitoring and Management Stakeholder Consultation Public Reporting References Figures Appendix 1: Statement of Commitment Appendix 2: Audit Table Ministerial Conditions FIGURES: Figure 1: Land Tenure Figure 2:: Mining and Backfill Falcon Extension FIGURE 3: Vegetation Clearing and Topsoil Stripping Falcon Extension Figure 4: Falcon Rehabilitation Figure 5: Aerial View Falcon Project Figure 6: Andersonia gracilis Status (Returned and Avoided) Figure 7: Environmental Monitoring Locations Falcon Extension TABLES: Table 1: Key Agency Consultations during Reporting Period... 9 Table 2: List of Reports to be Made Available to the Public Page 1 of 29

3 MS790 Compliance Report 2017 THIS PAGE HAS BEEN LEFT BLANK INTENTIONALLY Page 2 of 29

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5 MS790 Compliance Report INTRODUCTION This report details performance and compliance with conditions outlined in Ministerial Statement 790 (M790) and the subsequent amendment detailed in Ministerial Statement 799 (M799). This report specifically relates to the Tronox, a minor extension of the dry-mining operations within the Cooljarloo Mining Lease. This report addresses events during 2017 but could also contain subject matter outside this period where relevant and appropriate COMPANY NUMBER AND SITE ADDRESS ABN: Tronox Cooljarloo Mine Site Tenement ML268/SA Brand Highway CATABY WA SITE OPERATIONS AND LEASE DESCRIPTION The Cooljarloo Mining Lease (ML268/SA) is located some 170 km north of Perth and about 12 km north of Cataby in Western Australia and covers three freehold lots (1,092 ha) and an area of Unallocated Crown Land (UCL) (8,651 ha), as granted in accordance with the Mineral Sands (Cooljarloo) Mining and Mineral Processing State Agreement Act, See Figure 1. The Falcon Extension lies within the north-western-most extremity of ML268/SA and encompasses the 25,000 and Lone ore-bodies, as well as minor portions of the 13,000 ore-body as presented in Figure 2. At Cooljarloo the deeper, low-grade ore-bodies tend to be dredge-mined while the mid- to upper-level ore-bodies are dry-mined. The Falcon Extension was exclusively dry-mined. Page 4 of 29

6 1.3. ENVIRONMENTAL MANAGEMENT SYSTEM MS790 Compliance Report 2017 Tronox communicates its commitment to environmental management in the Cooljarloo Environmental and Community Statement of Commitment (Appendix 1) and maintains an ISO14001 certified Environmental Management System (EMS) to drive continuous improvement. The EMS defines the processes, standards and procedures Tronox use to achieve the outcomes mandated in the statement of commitment. The Cooljarloo Environmental Management Programme (EMP) summarises key components of the EMS system as they apply to the management of the site s environmental aspects. The EMP was revised and subsequently endorsed by the Office of the Environmental Protection Authority (OEPA) in May Page 5 of 29

7 MS790 Compliance Report PROJECT STATUS The Falcon Extension received environmental approval during March 2009 and mining (ore removal) commenced during May Mining was completed during October 2011 and rehabilitation activities were completed in April A total of ha were disturbed and rehabilitated over the life of mine for the Falcon Extension. Completed activities are presented Figure 2 (ore-mining and backfilling) in Figure 3 (Disturbance progress), Figure 4 (Rehabilitated area) and Figure 5 is an aerial photograph of the Falcon Project. Page 6 of 29

8 MS790 Compliance Report COMPLIANCE A detailed listing of the status of all Ministerial Conditions is provided in the Audit Table in Appendix 2. During 2014 the Minister for Environment agreed to change the implementation of Ministerial Statement 790 (M790) through an amendment to Condition 7 and associated schedules in line with Section 46 of the Environmental Protection Act These changes are set out in Statement 977 (M977) which was issued on the 30 July 2014 and removed conditions relating to groundwater trigger levels which were no longer considered relevant. Tronox was compliant with relevant sections of M790 and M977 at the end of year Page 7 of 29

9 MS790 Compliance Report MONITORING AND MANAGEMENT Monitoring was conducted during 2017 in accordance with the requirements of M790 and associated management plans. Further detail is provided in the 2017 Falcon Monitoring Report. Page 8 of 29

10 5. STAKEHOLDER CONSULTATION MS790 Compliance Report 2017 TABLE 1: KEY AGENCY CONSULTATIONS DURING REPORTING PERIOD Description: Agencies: Timing: Outcome / Status: 2017 Mineral Sands Agreement Rehabilitation Coordinating Committee (MSARCC) Site Meeting Department of State Development 19/10/2017 DSD feedback regarding a site meeting, successful rehabilitation and ongoing research. Page 9 of 29

11 MS790 Compliance Report PUBLIC REPORTING Reports to be made public by means of posting on the company website are listed in Table 2. TABLE 2: LIST OF REPORTS TO BE MADE AVAILABLE TO THE PUBLIC Report: Woodman 2015: Falcon Mineral Sands Project Monitoring of Potential Groundwater Drawdown Impacts on Vegetation at Falcon Winter 2015 Assessment. Unpublished report by Woodman Environmental Consulting Pty Ltd for (WEC 2015). Woodman 2012: Declared rare flora and priority flora health monitoring for the Falcon project area. Unpublished report by Woodman Environmental Consulting Pty Ltd for (WEC 2012) Reference Audit Code: 790: M : M6-6 Page 10 of 29

12 MS790 Compliance Report REFERENCES Woodman Environmental Consulting (WEC) 2012: Declared Rare Flora and Priority Flora Health Monitoring for the Falcon Project Area. Unpublished report by Woodman Environmental Consulting Pty Ltd for Tiwest Pty Ltd. Woodman Environmental Consulting (WEC) 2015: Monitoring of Potential Groundwater Drawdown Impacts on Vegetation at Falcon, Winter 2014 Assessment. Unpublished report by Woodman Environmental Consulting Pty Ltd for. Page 11 of 29

13 8. FIGURES MS790 Compliance Report 2017 Page 12 of 29

14 MS790 Compliance Report 2014 FIGURE 1: LAND TENURE Page 13 of 29

15 MS790 Compliance Report 2014 FIGURE 2:: MINING AND BACKFILL FALCON EXTENSION Page 14 of 29

16 MS790 Compliance Report 2014 FIGURE 3: VEGETATION CLEARING AND TOPSOIL STRIPPING FALCON EXTENSION Page 15 of 29

17 MS790 Compliance Report 2014 FIGURE 4: FALCON REHABILITATION Page 16 of 29

18 MS790 Compliance Report 2014 FIGURE 5: AERIAL VIEW FALCON PROJECT Page 17 of 29

19 MS790 Compliance Report 2014 FIGURE 6: ANDERSONIA GRACILIS STATUS (RETURNED AND AVOIDED) Page 18 of 29

20 MS790 Compliance Report 2014 FIGURE 7: ENVIRONMENTAL MONITORING LOCATIONS FALCON EXTENSION Page 19 of 29

21 MS790 Compliance Report 2014 APPENDIX 1: STATEMENT OF COMMITMENT Page 20 of 29

22 Page 21 of 29 MS790 Compliance Report 2014

23 MS790 Compliance Report 2014 APPENDIX 2: AUDIT TABLE MINISTERIAL CONDITIONS Page 22 of 29

24 MS790 Compliance Report 2017 Ministerial Statement MS-790 and MS-977 as amended. Key: C = Completed, NR = Not Required, CLD = Completed Completed commitments are shaded grey Audit Code: Subject: Requirement: How: Evidence: Phase: Timeframe: Status: Further Information: 790:M1.1 Proposal Implementati on The proponent shall implement the proposal as assessed by the Environmental Protection Authority and described in schedule 1 of this statement subject to the conditions and procedures of this statement. Project to be implemented in accordance with these criteria. Annual Compliance Report. Overall Throughout project life. C Compliant for 2009, 2010, 2011, 2012, 2013, 2014,2015 and 2016 This report addresses :M2.1 Proponent Nomination and Contact Details The proponent for the time being nominated by the Minister for Environment under sections 38(6) or 38(7) of the Environmental Protection Act 1986 is responsible for the implementation of the proposal. Annual Compliance Report. Overall C Compliant for 2009, 2010, 2011, 2012, 2013, 2014, 2015 and 2016 This report addresses :M2.2 Proponent Nomination and Contact Details The proponent shall notify the Chief Executive Officer (CEO) of the Department of Environment and Conservation of any change of the name and address of the proponent for the serving of notices or other correspondence within 30 days of such change. Letter notifying the CEO of any change in proponent details. Overall Within 30 days of such change. NR Notification of name change in :M3.1 Time Limit of Authorisation The authorisation to implement the proposal provided for in this statement shall lapse and be void within five years after the date of this statement if the proposal to which this statement relates is not substantially commenced. Project commenced during April, Overall Commence by 16 March, CLD 790:M3.2 Time Limit of Authorisation The proponent shall provide the CEO of the Department of Environment and Conservation with written evidence which demonstrates that the proposal has substantially commenced on or before the expiration of five years from the date of this statement. Letter notifying CEO that project has substantially commenced. Notification provided 17 March, Overall Within one year of commencement. CLD. 790:M4.1 Compliance Reporting The proponent shall submit to the CEO of the Department of Environment and Conservation environmental compliance reports annually reporting on the previous twelve-month period, unless required by the CEO of the Department of Environment and Conservation to report more frequently. Submit annual environmental compliance reports, covering the conditions of this audit program, unless required by the CEO to report more frequently. Annual Compliance Report. Overall Annually by 31 March each year, unless otherwise required by CEO of DEC. C Compliant for 2009, 2010, 2011, 2012, 2013, 2014, 2015 and 2016 This report addresses Page 23 of 29

25 MS790 Compliance Report 2014 Audit Code: Subject: Requirement: How: Evidence: Phase: Timeframe: Status: Further Information: 790:M4.2 Compliance Reporting The environmental compliance reports shall address each element of an audit program approved by the CEO of the Department of Environment and Conservation and shall be prepared and submitted in a format acceptable to the CEO of the Department of Environment and Conservation. Submit: 1 Hard copy and 1 CD copy to Manager PIMB, Locked Bag 33, Cloisters Square, Perth WA CD Copy to DEC Library (Atrium) Locked Bag 104, Bentley Delivery Centre WA 6983 Audit program and Annual Compliance Report. Overall C Compliant for 2009, 2010, 2011, 2012, 2013, 2014,2015 and 2016 This report addresses :M4.3 Compliance Reporting Submission of Environmental Compliance Reports. The environmental compliance reports shall: 1. be endorsed by signature of the proponent s chief executive officer or a person, approved in writing by the CEO of the Department of Environment and Conservation, delegated to sign on behalf of the proponent s chief executive officer; Annual Compliance Report. Overall C Compliant for 2009, 2010, 2011, 2012, 2013, 2014,2015 and 2016 This report addresses state whether the proponent has complied with each condition and procedure contained in this statement; 3. provide verifiable evidence of compliance with each condition and procedure contained in this statement; 4. state whether the proponent has complied with each key action contained in any environmental management plan or program required by this statement; 5. provide verifiable evidence of conformance with each key action contained in any environmental management plan or program required by this statement; 6. identify all noncompliances and nonconformances and describe the corrective and preventative actions taken in relation to each noncompliance or nonconformance; 7. review the effectiveness of all corrective and preventative actions taken; and 8. describe the state of implementation of the proposal 790:M4.4 Compliance Reporting The proponent shall make the environmental compliance reports required by condition 4-1 publicly available in a manner approved by the CEO of the Department of Environment and Conservation. In accordance with Proposal Implementation Monitoring Section Fact Sheet 1 Draft - Making Documents Publicly Available May Document posted on Tronox corporate website. Overall Within 2 weeks of submission to OEPA. C Relevant reports at lia/sustainablebusiness/environment/ Page 24 of 29

26 MS790 Compliance Report 2017 Audit Code: Subject: Requirement: How: Evidence: Phase: Timeframe: Status: Further Information: 790:M5.1 Performance Review and Reporting The proponent shall submit to the CEO of the Department of Environment and Conservation Performance Review Reports at the conclusion of the second and fourth years after the start of productive mining and then, at such intervals as the CEO of the Department of Environment and Conservation may regard as reasonable. The Performance Review Reports shall address: 1. the major environmental risks and impacts; the performance objectives, standards and criteria related to these; the success of risk reduction/impact mitigation measures and results of monitoring related to the management of the major risks and impacts; Performance Review Reports Overall At the conclusion of the 2 nd and 4 th years after the start of productive mining and then, at such intervals as the CEO of the DEC may regard as reasonable. C First (2 nd -year) report produced in April, Second (4 th -year) report submitted with the 2012 report. 2. the level of progress in the achievement of sound environmental performance, including industry benchmarking, and the use of best available technology where practicable; and 3. significant improvements gained in environmental management which could be applied to this and other similar projects. 790:M5.2 Performance Review and Reporting The proponent shall make the performance review reports required by condition 5-1 publicly available in a manner approved by the CEO of the Department of Environment and Conservation. In accordance with Proposal Implementation Monitoring Section Fact Sheet 1 Draft - Making Documents Publicly Available May Document posted on Tiwest (now Tronox) corporate website. Overall Within 2 weeks of submission to OEPA. C Relevant reports at lia/sustainablebusiness/environment/ 790:M6.1 Flora and Vegetation Prior to clearing, the proponent shall, subject to the requirements of the Wildlife Conservation Act 1950, translocate Declared Rare Flora growing within areas required for clearing to suitable temporary locations for retention for rehabilitation following completion of mining. Translocate Declared Rare Flora to suitable temporary locations as follows (See Fig 3 attached): 1. Populations of Andersonia gracilis from areas F and H (delineated by AMG coordinates listed in schedule 2 Table 1); and Topsoil removal records as reported in Annual Compliance Report. Overall Prior to clearing. C Part of population H removed with topsoil spread onto rehabilitation in Refer to Figure All scattered individual plants of Andersonia gracilis within proposed clearing areas (delineated by AMG coordinates listed in schedule 2 Table 2). 790:M6.2 Flora and Vegetation Notwithstanding the requirements of condition 6-1, the proponent shall implement the proposal to avoid disturbance of Declared Rare Flora populations C, D, E, and G shown in Fig 3 (attached) and delineated by AMG coordinates listed in schedule 2 Table 1, and to avoid Declared Rare Flora and Priority flora generally within the proposal area and outside the areas to be cleared. Avoid disturbance of Declared Rare Flora populations C, D, E, and G shown in Fig 3 (attached) and delineated by AMG coordinates listed in schedule 2 Table 1 and avoid Declared Rare Flora and Priority flora generally within the proposal area and outside the areas to be cleared. Clearing and disturbance records as reported in Annual Compliance Report. Overall Annually. C Refer to Figure 3. Page 25 of 29

27 MS790 Compliance Report 2014 Audit Code: Subject: Requirement: How: Evidence: Phase: Timeframe: Status: Further Information: 790:M6.3 Flora and Vegetation The proponent shall monitor the health and abundance of native vegetation (including Declared Rare Flora and Priority flora species) outside the areas to be cleared to ensure that there is no decline in the health or abundance of such vegetation through the implementation of the proposal. This monitoring is to be carried out to the satisfaction of the CEO of the Department of Environment and Conservation. In accordance with Falcon Groundwater Management Plan (Attachment 18 of Cooljarloo Mine (M268SA) Falcon Extension Environmental Protection Statement 30 July 2008). Monitoring Report submitted with Annual Compliance Report as per 790M6.4. Overall Annually. C Details reported in 2017 Falcon Environmental Monitoring Report to be submitted concurrently. 790:M6.4 Flora and Vegetation The proponent shall submit the results of monitoring required by condition 6-3 to the CEO of the Department of Environment and Conservation annually. Monitoring Report submitted with Annual Compliance Report. Monitoring results. Overall Annually. C This report and 2017 Falcon Environmental Monitoring Report to be submitted concurrently. 790:M6.5 Flora and Vegetation In the event that monitoring required by condition 6-3 indicates a decline in the health or abundance of native vegetation outside the areas to be cleared, the proponent shall report such findings to the CEO within 21 days of the decline being identified, and shall state the actions the proponent shall take remediate the decline. Letter to CEO notifying of monitoring findings and remedial actions. Letter to CEO. Overall Within 21 days of a decline in the health or abundance of native vegetation is identified as a result of the monitoring required by condition 6-3. C Stressed vegetation (<1ha) noted adjacent to Lone orebody during Reported to DEC (EMB and PIMS) on 3 March, :M6.6 Flora and Vegetation The proponent shall make the monitoring reports required by condition 6-4 publicly available in a manner approved by the CEO of the Department of Environment and Conservation. In accordance with Proposal Implementation Monitoring Section Fact Sheet 1 Draft - Making Documents Publicly Available May Document posted on Tiwest (now Tronox) corporate website. Overall Within 2 weeks of submission to DEC. C Relevant reports at lia/sustainablebusiness/environment/ 790:M7.1 Groundwater Drawdown At all times, the proponent shall ensure that groundwater drawdown in the proposal area and in the vicinity of the proposal area does not exceed the absolute minimum magnitude and absolute minimum rate trigger levels defined in schedule 2 - Table 3 Groundwater drawdown does not exceed the absolute minimum magnitude and absolute minimum rate trigger levels defined in schedule 2 - Table 3 as measured in groundwater level monitoring in accordance with Falcon Groundwater Management Plan (Attachment 18 of Cooljarloo Mine (M268SA) Falcon Extension Monitoring data as included in Annual Compliance Report. Overall NR Condition 7 replaced by M977. This no longer relevant. Environmental Protection Statement 30 July 2008). 977:M7.1 Groundwater Drawdown At all times, the proponent shall ensure that the limit of groundwater drawdown in the proposal area and in the vicinity of the proposal area does not approach the potentially acid-forming substrate to the extent that acidic waters are generated and/or released. Groundwater quality monitoring in accordance with Falcon Groundwater Management Plan (Attachment 18 of Cooljarloo Mine (M268SA) Falcon Extension Environmental Protection Statement 30 July 2008). Groundwater monitoring results as reported in Annual Compliance Report. Overall C Details reported in 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 Falcon Environmental Monitoring Reports. Page 26 of 29

28 MS790 Compliance Report 2017 Audit Code: Subject: Requirement: How: Evidence: Phase: Timeframe: Status: Further Information: 977:M7.2 Groundwater Drawdown At all times, the proponent shall ensure that groundwater drawdown from mining does not impact on the hydrology of the Mount Jetty Creek system. Groundwater managed in accordance with Management Plan (Attachment 18 of Cooljarloo Mine (M268SA) Falcon Extension Environmental Protection Statement 30 July 2008). Ground and Surface Water monitoring results as reported in Annual Compliance Report. Overall C Details reported in 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 Falcon Environmental Monitoring Reports. 977:M7.3 Groundwater Drawdown The proponent shall monitor groundwater from bores indicated in Figure 4 (attached to 790) to facilitate determination of whether the requirements of conditions 7-1 and 7-2 are being met. This monitoring is to be carried out to the satisfaction of the CEO of the Department of Environment and Conservation. Groundwater monitoring in accordance with Falcon Groundwater Management Plan (Attachment 18 of Cooljarloo Mine (M268SA) Falcon Extension Environmental Protection Statement 30 July 2008). Groundwater monitoring results as reported in Annual Compliance Report. Overall Measure monthly. Report annually. C Details reported in 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 Falcon Environmental Monitoring Reports. 977:M7.4 Groundwater Drawdown The proponent shall submit annually the results of the monitoring of groundwater required by condition 7-3 to the CEO of the Department of Environment and Conservation. Submitted with compliance reports as required by condition 977:M7.3 Groundwater monitoring results included in Annual Compliance Report. Overall Annually C Details reported in 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 Falcon Environmental Monitoring Reports. 977:M7.5 Groundwater Drawdown The proponent shall provide proposed management measures to the CEO of the Department of Environment and Conservation in the event that the requirements of conditions 7-1 and 7-2 are not met or are not likely to be met. Letter to CEO notifying of proposed management measures. Letter to CEO. Overall In the event that the requirements of conditions 7-1 and 7-2 are not met or are not likely to be met. NR 7-1 and 7-2 compliant therefore not required. 977:M7.6 Groundwater Drawdown To avoid doubt, nothing in this approval is taken to approve the generation or exposure of acid sulfate soils or the discharge of acidic waters to the environment. N/A. N/A. Overall NR 790:M8.1 Closure and Rehabilitation Prior to commencement of productive mining, the proponent shall conduct surveys of the proposal area to collect baseline information. Conduct surveys of the proposal area to collect baseline information on the following: 1. Pre-mining soil profiles; Letters to CEO, DEC and OEPA:PIMS, 17 March, Overall Prior to commencement of productive mining. CLD Reported in letter to CEO, DEC and OEPA: PIMS, 17 March, Groundwater levels; 3. Surface water flows; 4. Vegetation complexes; and 5. Landscape and landforms. 790:M8.2 Closure and Rehabilitation Within 12 months following cessation of productive mining, the proponent shall, subject to the requirements of the Wildlife Conservation Act 1950, translocate the Declared Rare Flora plants referred to in condition 6-1 from their temporary locations back into their original areas. By means of placement of topsoil in accordance with Falcon Rehabilitation Management Plan (Attachment 19 of Cooljarloo Mine (M268SA) Falcon Extension Environmental Protection Statement 30 July 2008). Rehabilitation signoff records for relevant areas as reported in Annual Compliance Report. Closure Within 12 months following cessation of productive mining. C Refer to Falcon Monitoring Reports and Figure 6. Topsoil has been replaced. Page 27 of 29

29 MS790 Compliance Report 2014 Audit Code: Subject: Requirement: How: Evidence: Phase: Timeframe: Status: Further Information: 790:M8.3 Closure and Rehabilitation As mining progresses, the proponent shall commence rehabilitation of the mined area. In accordance with the following: 1 Re-establishment of vegetation in the rehabilitation area to be comparable with that of the pre-mining vegetation such that the following criteria are met within three years following the cessation of productive mining: (1) Species diversity is not less than 70 percent of the known original species diversity; Rehabilitation monitoring data and signoff sheets. Overall As mining progresses. C Details reported in 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 Falcon Environmental Monitoring Reports. Mine Closure Plan and associated completion criteria endorsed by OEPA 7/1/2014. (2) Declared Rare Flora and Priority flora are re-established with not less than 50 percent success after three years and 65 percent success after five years; and (3) Weed coverage not to exceed the recorded baseline weed cover levels or species within the proposal area, with the baseline to be established by the proponent prior to the commencement of clearing. 2. A schedule of rate of rehabilitation acceptable to the CEO of the Department of Environment and Conservation. 790:M8.4 Closure and Rehabilitation In liaison with the Department of Environment and Conservation, the proponent shall monitor progressively the performance of rehabilitation against the criteria in condition 8-3 based on annual monitoring in spring. Monitor in accordance with Monitoring procedure as agreed with OEPA (Tiwest (now Tronox) Procedure C0919: Rehabilitation Monitoring) and report monitoring data in Annual Compliance Report. Rehabilitation monitoring data as reported in Annual Compliance Report. Overall Annual monitoring in spring. C Details reported in 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 Falcon Environmental Monitoring Reports. 790:M8.5 Closure and Rehabilitation The proponent shall submit annually a report of the rehabilitation performance monitoring required by condition 8-4 to the CEO of the Department of Environment and Conservation. The report shall address the following: 1 Progress towards meeting the criteria required by condition 8-3 and milestone criteria; and 2 Contingency management measures in the event that criteria are unlikely to be met. Rehabilitation performance monitoring reports. Overall Annually. C Details reported in 2010, 2011, 2012, 2013, 2014, 2015, 2016 and 2017 Falcon Environmental Monitoring Reports. Page 28 of 29

30 MS790 Compliance Report 2017 Audit Code: Subject: Requirement: How: Evidence: Phase: Timeframe: Status: Further Information: 790:M8.6 Closure and Rehabilitation The proponent shall report the findings of the Nicholls-Woodman review of rehabilitation practices and standards to the CEO of the Department of Environment and Conservation. If findings indicate that rehabilitation criteria defined in condition 8-3 can be improved, then the new criteria defined in the findings shall be used. Report and revised Completion Criteria submitted to DEC in letter correspondence. DEC to advise Tiwest (now Tronox) in letter to General Manager Northern Operations of suitability of revised criteria for application to Falcon. Nicholls-Woodman review circulated and workshopped in March, Draft Completion Criteria for the Cooljarloo Mine submitted in November, Overall If findings of the Nicholls- Woodman review indicate that rehabilitation criteria defined in condition 8-3 can be improved. CLD Mine Closure Plan and associated completion criteria endorsed by OEPA 7/1/2014. Page 29 of 29