Appendix X

Environmental management
A-1 Sandy Ridge Facility – Environmental
Management Policy (Tellus, 2013) (see
Appendix A(A-17))

A-2 Sandy Ridge Facility – Environmental

Management Policy (Tellus, 2021)

A-3 Sandy Ridge Facility – Operational

Environmental Management Plan (Tellus,
2021)
 Publicly Available

SUSTAINABILITY AND ENVIRONMENT POLICY

1. PURPOSE AND SCOPE
1.1 As a developer of world’s best practice geological repository waste solutions, Tellus Holdings Ltd and its
related bodies corporate (together, “Tellus” or the “Company”) is committed to protecting the environment
and to sustainable management.
1.2 We aim to generate economic, social and environmental value and to manage our operations and resources
in a manner that creates beneficial outcomes for our employees, customers, community members,
shareholders and other stakeholders with a view to ensuring the long-term viability of Tellus. Through
carrying out Tellus’ purpose - to help clean up Australia’s environment of hazardous waste - we contribute
more broadly to sustainability in Australia by enabling cleaner land, air and water, healthier ecosystems and
safer living spaces for people. Respect for our environment is a core foundation of such purpose.
1.3 This Sustainability and Environmental Policy (the “Policy”) is communicated and understood throughout
Tellus and is available to relevant interested parties, as appropriate.
1.4 This Policy applies to the entirety of the Tellus group of companies, its offices, operations and all persons
under their control.
2. POLICY STATEMENT
2.1 Tellus will display strong environmental leadership by:
(a) Complying with applicable environmental laws, regulations, approvals, licences, permits and other
criteria that apply to our operations, including our geological repositories.
(b) Preventing pollution through environmentally conscious design and development of our facilities.
(c) Contribute to circular economy by seeking methods to reuse or recycling materials within the waste
handling process, recovery and treatment of client wastes, where possible, and reuse or recycling of on-
site generated wastes to reduce their environmental impacts.
(d) Improving efficiency in the use of natural resources, such as water and fossil fuels, by reducing the use,
or engaging in re-use or recycling of natural resources relative to operational activities.
(e) Avoiding or reducing emissions of greenhouse gases.
(f) Making environmental decisions based on current scientific evidence.
(g) Developing, implementing and maintaining an Environmental Management System (EMS) that complies
with the requirements of international standard ISO 14001.
(h) Minimising the significant adverse environmental impacts from our business through integrated
environmental management processes to conserve biodiversity, habitats and ecosystems.
(i) Continually striving to improve our environmental performance and management system.
(j) Promoting initiatives, systems, values and behaviours through education and training that drive
environmental sustainability.
(k) Motivating and influencing our suppliers and contractors to join us in our approach towards responsible
and sustainable environmental practice.
3. QUESTIONS
3.1 For questions about the operation of this policy, please contact Tellus’ Company Secretary.

Approved by: Nate Smith, CEO

Version No: 4 Version Date: 26/04/2021

Page 1 of 2
 Publicly Available
4. REVISION HISTORY

Revision Prepared Date Author Reviewed By Approved By

0 24/06/2013 R Charter Tellus Board Duncan van der Merwe
1 Unknown R Charter - Duncan van der Merwe
2 Unknown R Charter - Duncan van der Merwe
3 02/05/2018 N Ballard Duncan van der Merwe
4 27/04/2021 N Ballard Barbara King Barbara King on behalf of the
Board and the CEO.

Revision Status / Description of Changes

0 Initial Release
1 Unknown
2 Unknown
3 Updated to address requirements of AS/NZS ISO 14001:2015. New template
4 Consolidation of Environment Policy (TEL-01.002), Sustainability Policy (TEL-01.023) and Sustainable
Development Policy (TEL-01.024) and expansion to all of Tellus’ subsidiaries and activities. Includes
wider sustainability commitments. New template.
5

Version No: 4 Version Date: 26/04/2021

Page 2 of 2
OPERATIONAL ENVIRONMENTAL
MANAGEMENT PLAN

February 2021
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Document Control

The signatures below certify that this Management Plan has been reviewed and accepted. It demonstrates
the signatories are aware of all the requirements contained herein and, are committed to ensuring their
provision.

Document: Sandy Ridge Operational Environmental Management Plan

Status: Approved for Use

Prepared for: Internal

Ref: SR-08.501

Effective Date: 25/02/2021

Prepared by: Adam Donegan - Environmental Scientist – Sandy Ridge

Reviewed by: Julie Mahony – Environment Manager (WA)

Reviewed by: David Parker – Facility Manager Sandy Ridge

Approved by: Nick Ballard – Environmental Compliance Manager

REVISION HISTORY
This Management Plan is reviewed to ensure its continuing relevance to the systems and process that it
describes. A record of contextual additions or omissions is given below:
Page No. Details Version Date
- Initial Release 0 25/02/2021

The electronic version of this management plan is the latest version. It is the responsibility of the individual
to ensure that any paper material is the current version. The printed version of this management plan is
uncontrolled.

© Tellus Holdings Ltd (Tellus). All rights reserved.

Tellus has prepared this document for the specific purpose as expressly stated in the document. No other party should rely on this document without
the prior written consent of Tellus. Tellus undertakes no duty, nor accepts any responsibility, to any third party who may rely upon or use this
document. This document has been prepared based on Tellus’s experience, having regard to assumptions that Tellus can reasonably be expected to
make in accordance with sound professional principles. Tellus may also have relied upon information provided by third parties to prepare this
document, some of which may not have been verified. Subject to the above conditions, this document may be transmitted, reproduced or
disseminated only in its entirety.

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Table of Contents

1 INTRODUCTION .................................................................................................................................................................... 1
1.1 PURPOSE.......................................................................................................................................................................1
1.2 SCOPE ..........................................................................................................................................................................1
1.3 OBJECTIVES ...................................................................................................................................................................4
1.4 DOCUMENT STRUCTURE ..................................................................................................................................................4
2 ROLES AND RESPONSIBILITIES ............................................................................................................................................ 5
3 ENVIRONMENTAL MANAGEMENT FRAMEWORK ................................................................................................................. 7
3.1 OVERVIEW ....................................................................................................................................................................7
3.2 TELLUS INTEGRATED MANAGEMENT SYSTEM .......................................................................................................................7
3.2.1 Measurement and evaluation ..............................................................................................................................9
3.2.2 Annual Reporting ................................................................................................................................................10
3.3 REVIEW.......................................................................................................................................................................13
3.3.1 Event based .........................................................................................................................................................13
3.3.2 Time based ..........................................................................................................................................................13
3.4 EVALUATION OF COMPLIANCE ........................................................................................................................................13
3.4.1 External audits ....................................................................................................................................................14
3.4.2 Internal audits .....................................................................................................................................................15
4 ENVIRONMENTAL OBJECTIVES AND TARGETS ................................................................................................................... 16
5 STATUTORY REQUIREMENTS ............................................................................................................................................ 18
5.1 ASPECTS AND IMPACTS ..................................................................................................................................................18
5.2 COMMONWEALTH GOVERNMENT APPROVAL EPBC 2015/7478 .......................................................................................18
5.3 WESTERN AUSTRALIAN GOVERNMENT MINISTERIAL STATEMENT 1078 ................................................................................19
5.4 LICENCES AND PERMITS .................................................................................................................................................19
5.5 MINING TENEMENTS.....................................................................................................................................................20
5.6 OTHER LEGISLATION......................................................................................................................................................21
6 MANAGING THE ENVIRONMENT......................................................................................................................................... 22
6.1 ENVIRONMENTAL ASPECTS – STAND-ALONE MANAGEMENT PLANS .....................................................................................23
6.1.1 Leachate Monitoring and Management ...........................................................................................................23
6.1.2 Deep Groundwater Monitoring and Management ...........................................................................................23
6.1.3 Potable Water Management .............................................................................................................................23
6.1.4 Flora and Vegetation Management ..................................................................................................................24
6.1.5 Construction (Fauna) Environmental Management Plan .................................................................................24
6.1.6 Hazardous Materials and Dangerous Goods.....................................................................................................25
6.1.7 Radiation Management .....................................................................................................................................25
6.1.8 Emergency Response Plan ..................................................................................................................................25
6.1.9 Bushfire ...............................................................................................................................................................26
6.1.10 Waste Facility Decommissioning and Closure ..............................................................................................26
6.1.11 Mine Closure ...................................................................................................................................................26
6.2 OTHER ENVIRONMENTAL ASPECTS ..................................................................................................................................27
6.2.1 General ................................................................................................................................................................27
6.2.2 Air ........................................................................................................................................................................30
6.2.3 Fauna ...................................................................................................................................................................33
6.2.4 Erosion and Sediment .........................................................................................................................................36
6.2.5 Surface Water .....................................................................................................................................................38
6.2.6 Wastes – Site Generated ....................................................................................................................................40
6.2.7 Energy..................................................................................................................................................................43
6.2.8 Other ...................................................................................................................................................................45

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7 INFORMATION AND COMMUNICATION ............................................................................................................................... 46
7.1 COMMUNITY ...............................................................................................................................................................46
7.1.1 Tellus website ......................................................................................................................................................46
7.1.2 Complaints and enquiries ...................................................................................................................................46
7.1.3 Dispute resolution ...............................................................................................................................................48
7.2 INTERNAL REPORTING....................................................................................................................................................48
7.3 GOVERNMENT AGENCIES ...............................................................................................................................................48
8 EMERGENCY AND CRISIS MANAGEMENT ............................................................................................................................ 49
9 INCIDENT / NON-COMPLIANCE MANAGEMENT................................................................................................................... 50
9.1 INTERNAL ....................................................................................................................................................................50
9.2 EPBC 2015/7478 ......................................................................................................................................................50
9.3 MS 1078 ...................................................................................................................................................................51
10 TRAINING ........................................................................................................................................................................... 52
10.1 VISITORS INDUCTION ....................................................................................................................................................52
10.2 SITE INDUCTION ...........................................................................................................................................................52
10.3 TASK SPECIFIC TRAINING ................................................................................................................................................52
11 DOCUMENTED INFORMATION ............................................................................................................................................ 53
11.1 DOCUMENT CONTROL ...................................................................................................................................................53
11.2 RECORDS MANAGEMENT ...............................................................................................................................................53

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TABLES
Table 1: Structure of the management plan ............................................................................................................. 4
Table 2: Roles and responsibilities for environmental management............................................................................ 5
Table 3: Management system framework ................................................................................................................ 9
Table 4: Environmental reporting requirements ..................................................................................................... 12
Table 5: Audit program ........................................................................................................................................ 15
Table 6: Sandy Ridge environmental objectives and targets ..................................................................................... 16
Table 7: Commonwealth government approval details ............................................................................................ 18
Table 8: Western Australian government approval details ....................................................................................... 19
Table 9: Facility licences and permits ..................................................................................................................... 19
Table 10: Mining tenements ................................................................................................................................. 20
Table 11: Summary of Environment Aspects/Impacts and their Management Document ........................................... 22

FIGURES
Figure 1: Site Location Plan ..................................................................................................................................... 2
Figure 2: Site Layout Plan ....................................................................................................................................... 4
Figure 3: Tellus environmental strategy framework .................................................................................................. 8
Figure 4: Sandy Ridge environmental document structure ....................................................................................... 10
Figure 5: Sandy Ridge complaints handling process ................................................................................................. 47

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ABBREVIATIONS
AER Annual Environment Report
BMP Bushfire Management Plan
CAR Compliance Assessment Report (required by Ministerial Statement 1078)
CEMP Construction Environmental Management Plan
COO Chief Operating Officer
CR Compliance Report (required by Federal approval EPBC2015/7478)
DGMMP Deep Groundwater Monitoring and Management Plan
DMIRS Department of Mines, Industry Regulation and Safety
EMP Environmental Management Plan
ERP Emergency Response Plan
EP Act Environmental Protection Act 1986
EPBC 2015/7478 Commonwealth Government Approval 2015/7478
FVMP Flora and Vegetation Management Plan
GHG Greenhouse Gas
ha Hectares
IA Irrigation Area
kL Kilolitres
LMMP Leachate Monitoring and Management Plan
L9240/2020/1 Licence 2940
MCP Mine Closure Plan
MS 1078 Ministerial Statement 1078 (Western Australian Government Approval)
OEMP Operational Environmental Management Plan
PWMP Potable Water Management Plan
RMP Radioactive Management Plan
RO Reverse Osmosis
the Facility Sandy Ridge Facility
Tellus Tellus Holdings Ltd
WA Western Australia
WFDCP Waste Facility Decommissioning and Closure Plan
WWTP Wastewater Treatment Plant

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1 Introduction

Tellus Holdings Ltd (Tellus) has been approved by the Commonwealth and Western Australia governments to
develop a kaolin open cut mine and use the mine voids for the secure storage and isolation of hazardous,
intractable (Class IV and Class V), low-level radioactive waste in a near surface geological repository. The
Sandy Ridge Facility (the Facility) has been designed and constructed using best practice techniques that is
supported by a system of management plans, procedures, closure plans and financial assurances and
insurances to verify the Facility remains operationally safe.

The Facility is located approximately 75 kilometres north-east of Koolyanobbing in the Shire of Coolgardie,
within the Goldfields Region of Western Australia. Figure 1 provides a site location plan and Figure 2
presents the site layout plan.

This Operational Environmental Management Plan (OEMP) is an internal document has been developed to
explain how Tellus manages the environment at the Facility and, the associated regulatory obligations during
operation.

1.1 Purpose

The purpose of this OEMP is to explain the environmental management structure in use at the Facility to
control potential environmental aspects and impacts and achieve compliance with its corporate,
Commonwealth, State and Local government environmental obligations.

1.2 Scope

This OEMP applies to the Facility, associated tenure and work sites. It applies to all employees and
contractors working at those sites.

All Facility works (including construction, operation and maintenance) and other related activities (e.g.
monitoring) consistent with the regulatory requirements listed in Section 5 are covered by this OEMP. This
OEMP does not cover exploration activities beyond the Facility Boundary presented in Project Approvals
(Ministerial Statement No. [MS]1078 and Environmental Protection Biodiversity Conservation
[EPBC]2015/7478) and mining lease boundaries which are subject to separate regulatory requirements.

The OEMP has been prepared to assist those undertaking works at the Facility to apply appropriate
environmental management measures to their tasks and activities. Where there is a conflict between the
requirements of this OEMP and the contractual obligations of any contactor, the statutory requirements are
to take precedence. In the case of any real or perceived ambiguity between elements of this OEMP and
statutory requirements, a contractor shall first request clarification from the Manager Environment (WA)
prior to implementing that element of the OEMP over which the ambiguity is identified.

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 Figure 1: Site Location Plan

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Figure 2: Site Layout Plan

1.3 Objectives

The objectives of this OEMP are to:

a) Provide a strategic framework for environmental management across Facility operations;
b) Describe the role, responsibility, authority and accountability of key personnel involved in the
environmental management of the Facility (Section 2);
c) Identify the statutory environmental approvals that apply to the Facility (Section 5);
d) Include environmental risk mitigation measures to be implement (Section 6);
e) Include environmental monitoring requirements to be implemented (Section 6);
f) Describe the procedures that would be implemented to:
1) keep the local community and relevant agencies informed about the operation and
environmental performance of the Facility (Section 7);
2) Management of complaints and disputes (Section 7);
3) Management of environmental emergencies (Section 8); and
4) Management of incidents and non-compliances (Section 9).

1.4 Document structure

The structure of the OEMP is outlined in Table 1.

Table 1: Structure of the management plan

Section Content

1 Provides an overview of the site and objectives of the plan.

2 Provides environmental roles and responsibilities for key staff.
3 Provides an overview of environmental management framework at Tellus.
4 Outlines the environmental objectives and targets for the Facility.
5 Provides the environmental statutory requirements for the Facility.
6 Provides requirements for managing environmental aspects/impacts associated with the Facility.
7 Provides an overview of environmental information and communication for the Facility.
8 Summaries the environmental emergency, crisis management.
9 Summarises the environmental incident and non-compliance reporting requirements.
10 Summarises the environmental training requirements.
11 Summarises environmental document management requirements.

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2 Roles and Responsibilities

The Facility Manager carries ultimate responsibility for the ongoing development and implementation of this
plan and providing the necessary resources as required. The Manager Environment - WA is responsible for
carrying out and/or coordinating the monitoring and reporting requirements of this plan, document review
and updates and stakeholder engagement. Operations personnel are responsible for implementing the
measures and onsite actions contained in the OEMP.
Achieving effective environmental and community management requires responsible and proactive
leadership. Every employee and contractor have a responsibility for protecting the environment and
adhering to Tellus’ Corporate Environmental Policy (refer to Section 3.1). Tellus’ Corporate Environmental
Policy provides the governing principles for environmental and community management and is available on
the Company’s SharePoint site.
The environmental roles and responsibilities for the Facility are presented in Table 2.
Table 2: Roles and responsibilities for environmental management
Role Responsibilities & Accountabilities Authorities
Chief Operating - Ensure environmental management - Liaison with Government on the progress of
Officer (COO) strategies, plans, programs and associated mining tenure applications.
procedures are implemented in accordance
with the requirements of this OEMP and other
external requirements.
- Ensure that the Facility is adequately
resourced to implement the EMS.
- Ensure appropriate tenure is in place for
operations.
Facility Manager - Ensure adequate operational resources are - Make changes to the plant, stop or suspend
available on a day to day basis to ensure the operations as required to meet environmental
EMS and this OEMP are implemented obligations.
effectively and maintained.
- Ensure environmental management
strategies, plans, programs and associated
procedures are implemented in accordance
with the requirements of this OEMP.
Manager - Ensure environmental management - Make recommendations to suspend
Environment - WA strategies, plans, programs and associated operations as required to meet environmental
procedures are developed to support obligations
implementation of the requirements of this - Liaise with Government authorities re:
OEMP and other external requirements. environmental issues on behalf of the
- Provide leadership, advice and support to the operations
Facility to ensure that the OEMP is - Institute any additional environmental
understood, implemented effectively and controls as necessary to meet environmental
maintained. obligations.
- Ensure WA environmental approval outcomes - Make recommendations to the operations,
are managed with appropriate systems at a stop or suspend operations as required to
high standard that is consistent with company meet environmental obligations.
and government expectations and reasonable
- Undertake Environmental Assessments and
expectations of the broader community
monitoring for WA.
- Submission of approval applications for WA.
- Liaison with Government on the progress of
WA approvals.

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 Role Responsibilities & Accountabilities Authorities
- Reporting impacts and management for WA to
Government.

Environmental Assist the Environment Manager – WA to: - Make recommendations to suspend

Scientist (WA) - Support the Manager – Environment to ensure operations as required to meet environmental
environmental management strategies, plans, obligations
programs and associated procedures are - Make recommendations to stop or suspend
developed and communicated in accordance operations as required to meet environmental
with the requirements of this OEMP and other obligations.
external requirements. - Undertake Environmental Assessments and
- Provide leadership and support to the monitoring for WA.
Facility’s Team to ensure that the OEMP is
implemented effectively and maintained.
- Ensure WA environmental approval outcomes
are managed with appropriate systems at a
high standard that is consistent with company
and government expectations and reasonable
expectations of the broader community
Laboratory Manager - Manage and provide on-site laboratory - Undertake environmental monitoring as
/ Environmental services for environmental monitoring. required.
Officer - Implement site environmental management - Assist in the management of site
and monitoring requirements. environmental incidents.
Production - Ensure approval outcomes in production areas - Undertake Environmental Assessments and
Supervisor – Sandy are managed with appropriate systems at a monitoring for production areas.
Ridge high standard that is consistent with company - Provide technical data and advice to support
and government expectations and reasonable submission of approval applications for
expectations of the broader community. mining.
- Provide technical data and advice to Manager
Environment to support reporting of
production environmental impacts and
management to Government.
Environmental - Conduct environmental compliance audits of - Report findings and recommendations of EMS
Compliance Manager environmental approvals, licences, permits and compliance audits to Senior Management.
and other environmental regulatory - Provide advice and recommendations to the
requirements. Environment Manager (WA) concerning the
- Conduct audits of EMS documentation development of environmental management
relevant to the Facility. documentation.
- Liaise with and provide advice and
recommendations to the Environment
Manager (WA), or delegate concerning
environmental compliance and EMS issues at
the Facility.
General Manager - Strategic environmental management and - Report to Tellus Board.
External Affairs & compliance advice. - Advise key stakeholders of environmental
Approvals - Strategic external affairs liaison. management commitments within all State
and Territory Departments.
Employees - Manage their activities in an environmentally - Stop works if impact to the environment is
(inclusive of responsible manner and in line with this OEMP suspected or known.
contractors) - Report any environmental concerns,
opportunities for improvement, near misses
or incidents to their supervisor ASAP.

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3 Environmental Management Framework

3.1 Overview

The context for environmental management at the Facility is guided by the Tellus Corporate Environmental
Policy, regulatory compliance, community awareness/expectations and the proximity of the site to sensitive
receivers.
The Tellus Environmental Policy (TEL-01.002, available in Management Standard 01 – Leadership &
Compliance) underpins the way in which the environment is managed across all of Tellus activities. Tellus is
committed to pursuing industry specific best practice in environmental performance, complying with
environmental legislation and open, constructive engagement with communities surrounding its operations.
The Tellus Environmental Policy (TEL-01.002) provides the foundation for the environmental objectives and
the commitment that the Company operates in consideration of.
It is a Tellus corporate requirement that the Environmental Policy is clearly displayed in prominent locations
at all operations and is included in training and induction programs undertaken by all employees and
contractors.
Local communities are aware of the environmental performance of industry and have resulting high
expectations. The Goldfields region is no different, and accordingly, we will engage with our community to
earn their trust and support for what we do.

3.2 Tellus integrated management system

The Facility operates in accordance with the Tellus integrated Health Safety, Environment and Quality
Management System which establishes a strategic platform for regulatory compliance and continual
improvement in environmental management.

Key Documents
Document No. Document Name
TEL-03.001 Integrated Management System Manual

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The management system is formed of ten Management Standards and provides structure and guidance on:
• Company environmental objectives;
• Identification, monitoring and management of environmental aspects;
• Impacts associated with all Tellus operations;
• Regulatory compliance;
• Roles and responsibilities; and
• Community expectations.
Management Standard 08 – Process Control & Delivery contains the sub-group 08.500 Environment &
Approvals which includes environmental management plans and procedures.

The Facility operates under site-specific documents, identified with the document number commencing SR-,
where these don’t exist a corporate document, identified with the document number commencing TEL- is
implemented. Documents exclusive to the Facility can be accessed from the home page of the Sandy Ridge
Operations SharePoint homepage.
The Tellus management system is aligned with the international standard ISO 14001, and contains the
elements associated with Policy and Planning, Implementation and Maintenance, and Checking and Review.
The overarching strategic framework for environmental management at Tellus is presented in Figure 3.

Figure 3: Tellus environmental strategy framework

Any necessary revisions to the plans and programs required to environmental authorisations are to be made
to the satisfaction of the relevant regulatory approver or internal Document Owner.

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Table 3 presents the company-wide management system structure that dictates document numbering.
Table 3: Management system framework
01 - Leadership & Compliance 07 – People & Organisation
01.000 Policies 07.000 General
01.100 Legal Compliance 07.100 Engage
01.200 Leadership & Commitment 07.200 Retain
01.200 Board Policies & Procedures 07.300 Perform
02 – Sales & Marketing 07.400 Attract
02.000 Sales 08 – Process Control & Delivery
02.200 Sales & Customer Relations 08.000 Process Control
02.300 Sales & Social Responsibility 08.100 Emergency & Crisis Management
03 – Planning & Project Management 08.200 Laboratory
03.000 Objectives & Planning 08.300 Health & Occupational Hygiene
03.100 Change Management 08.400 Journey Management
03.200 Engineering & Project Management 08.500 Environment & Approvals
03.300 Land Management 08.600 Traffic & Vehicle Management
03.400 Mine Planning & Utilisation 08.700 Radiological Management
04 – Documented Information 08.800 Waste Acceptance
04.100 Document Management 08.900 Transport / Logistics
04.200 IT & Information Security 09 – Monitoring & Testing
05 – Finance & Procurement 09.000 General
05.000 Procurement 09.100 Management Review
05.100 Capital, Assets & Liabilities 09.200 Reporting
05.200 Tax Management 09.300 Auditing
06 – Risk Management 09.400 Traceability
06.000 Risk Management 10 – Incident Management & Improvement
06.100 Critical Risks 10.000 Incident Management
10.100 Non-conforming Output
10.200 Improvement

3.2.1 Measurem ent and evaluati on

A list of related management plans to this OEMP is provided in Section 6.
Environmental monitoring is addressed within the Environmental Management Plans (EMPs) developed to
manage each environmental aspect.
The Environment Manager (WA) is responsible implementing EMPs and mitigation measures stated in
Section 6.
Figure 4 presents the environmental document structure for the Facility.

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Figure 4: Sandy Ridge environmental document structure

3.2.2 Annual Reporting

EPBC 2015/7478

The annual Compliance Report will be developed in accordance with Part B, Condition 9 of EPBC 2015/7478.
The report will be submitted to the compliance section of DAWE and will also be made available on the
Sandy Ridge Facility Regulatory Information section of the Tellus website.
Any communications with DAWE will be recorded in the INX InForm Communications database.
MS 1078
The annual Compliance Assessment Report will be developed in accordance with Condition 4-6 of MS 1078.
The report will be submitted to the compliance section of DWER and will also be made available on the
Sandy Ridge Facility Regulatory Information section of the Tellus website.
Any communications with DWER will be recorded in the INX InForm Communications database.
L9240/2020/1
The annual Environment Report will be developed in accordance with Condition 24 and will include the
information specified in Table 5 of L9240. The report will be submitted to the compliance section of DWER
and will also be made available on the Sandy Ridge Facility Regulatory Information section of the Tellus
website.

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Any communications with DWER will be recorded in the INX InForm Communications database.
Mining Act
Mining Act tenement conditions require Tellus to submit Annual Environment Reports (AER) in May each
year. The AER objectives are to:
• Document mining activities for the reporting year and proposed activities for the following year.
• Document environmental management and rehabilitation activities for the reporting year, and
proposed activities and developments in the following year.
• Report on the progress and status of achieving environmental outcomes and closure objectives for
the site, including the provision of relevant monitoring reports or data.

• Provide an assessment of compliance with conditions.

AERs are to be prepared in accordance with DMIRS Guideline for the preparation of and Annual
Environmental Report, and are submitted online via DMIRS’ website.

Table 4 provides a summary of reporting requirements for the Facility.

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Table 4: Environmental reporting requirements

Report Requirement Distribution Frequency Distribution Responsibility for Responsibility for Responsibility
Method Data Collection Preparation for Submission
Compliance Assessment MS 1078 DWER Annually: 27 June to 26 Email & Website
Report (CAR) June
Deadline: 23 Sept Environmental Environmental
Environment
Compliance Compliance
Compliance Report (CR) EPBC 2015/7478 DAWE Annually: 7 July to 6 July Email & Website Manager (WA)
Manager Manager
Deadline: 28-Sept
Deadline: 04-Oct
Incident Report MS 1078 DWER As Required Phone, Email Environment Environment Environment
EPBC 2015/7478 DAWE Manager (WA) Manager (WA) Manager (WA)
L9240 DMIRS
Mining Proposal DPLH
Certification Body
Radiation Registration Radiation Health Unit Managed under the Radiation Management Radiological Radiological Radiological
Plan - Refer to Section 6.1.7 Manager (WA) Manager (WA) Manager (WA)
Mining Rehabilitation Fund All Tenements
Reporting
Annual Environmental Sandy Ridge Tenements
DMIRS Annually in May DMIRS Website Environment Environment Environment
Report 85106
Manager (WA) Manager (WA) Manager (WA)
Annual Environmental Ancillary Infrastructure
Report Tenements 79370
RIWI Reporting GWL 202536(1) DWER Monthly DWER Website
Annual Audit Compliance L9240/2020/1 – DWER Annually: 1 July to 30 June
Environment
Report & Annual Conditions 23 & 24 Email Environmental Environmental
Deadline: 29 August Manager (WA)
Environment Report Compliance Compliance
Environmental Authorisation Crown Lease Condition DPHL As Reports are Approved Email Environment Manager Manager
Reports 19(d) by Government Agencies Manager (WA)

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3.3 Review

The Tellus management system is reviewed on a regular basis. The Facility OEMP is reviewed in response to
the following.
3.3.1 Event based
Events which may trigger a review of the OEMP include:
• The submission of a compliance report.
• The submission of an incident report.
• The submission of a regulatory required audit report.
• Any modification to the conditions of a regulatory approval.
• New approvals, guidelines or codes of practice applied to the Facility.
• As requested by government departments.
3.3.2 Time bas ed
Tellus will submit compliance reports in accordance with the requirements of MS 1078 and EPBC/2015/7478
(refer to Section 3.2.2). Within three months of Tellus receiving regulator comments on compliance reports,
Tellus will review, and if necessary, revise this OEMP, noting that this document is not subject to regulatory
approval.
The OEMP review will include review of:
• This document.
• Legislation, approval and licence changes.
• Community complaints and enquiries.

3.4 Evaluation of compliance

Key Documents
Document No. Document Name
TEL-01.101 Health, Safety and Environment Compliance Obligations Procedure

Statutory obligations applicable to the Facility have been identified and are managed via the online internal
compliance management system (INX InForm) as described in Section 3. The obligations are allocated to
relevant managers and other responsible site personnel.
Compliance against statutory requirements, as managed in the INX InForm system, is reported through to
the Tellus Senior Leadership Team monthly.
The Environment Manager (WA) (or delegate) will undertake regular site inspections and initiate directions
identifying any remediation/rectification work required, and areas of actual or potential non-compliance.
The Environmental Compliance Manager will in addition to the inspections undertaken by the Environment
Manager (WA) undertake periodic site inspections, conduct audits and initiate directions identifying any
remediation/rectification work required, and areas of actual or potential non-compliance.

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3.4.1 Exter nal audits
EPBC 2015/7478
Conditions 12, of EPBC 2015/7478 requires independent audits of compliance with the conditions are
conducted as requested in writing by the Minister.

13 For each independent audit, the approval holder must:

a) provide the name and qualifications of the independent auditor and the draft audit criteria
to the Department;
b) only commence the independent audit once the audit criteria have been approved in
writing by the Department; and
c) submit and audit report to the Department within the timeframe specified in the approved
audit criteria.

14 The approval holder must publish the audit report on the website within 10 business days of
receiving the Department's approval of the audit report and keep the audit report published on the
website until the end date of this approval.
Ministerial Statement 1078
Condition 8, of MS 1078 requires an Independent Annual Audit to be undertaken of the waste disposal
operations at the Facility.

8-2 The first audit shall be undertaken twelve (12) months from the date of waste acceptance. The
audit shall address site operations, including whether:
A each waste is uniquely identified.
B the origin, quantity and characterisation of each waste is recorded.
C the waste acceptance criteria and procedures have been adhered to.
D all required regulatory approvals and permits were in place for transport and disposal of the
waste;
E there is a clear and documented chain of custody from client to waste receival;
F the final location of each waste in the waste cell is accurately recorded in three dimensions
(northing, easting and elevation);
G all regulatory requirements have been met; and
H other options have become available to reuse, recycle or recover wastes that are being
accepted at the Sandy Ridge Facility.

8-2 The proponent shall provide the annual audit report required by condition 8-2 to the CEO within
twelve (12) weeks of the audit date until the CEO has confirmed by notice, in writing, that provision
of the annual audit report is no longer required.
8-4 In the event that the annual audit report identifies issues with waste acceptance, waste tracking or
compliance with regulatory requirements, the proponent shall immediately notify the CEO, and
other relevant regulators where a non-compliance against other legislation has occurred, and
implement investigations to identify the cause.
8-5 Should the cause identified in condition 8-4 result in a potential risk to human health or a sensitive
environmental receptor, then the proponent shall commence remedial actions immediately until
otherwise advised by the CEO.

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 AS/NZS ISO 14001
Activities and operations at the Facility may be audited by Tellus’ appointed certification body as part of its
certification to AS/NZS ISO 14001 1 on an annual or six-monthly basis.
3.4.2 Internal audits
Key Documents
Document No. Document Name
TEL-09-.301 Auditing Procedure

A system of environmental auditing is undertaken across Tellus, including at the Facility, and includes the use
of competent internal and accredited external auditors. In addition, regular audits are undertaken to
maintain certification under AS/NZS ISO 14001. The audit program is implemented in accordance with the
schedule outlined below in Table 5.
Table 5: Audit program

Audit Type Frequency

Internal Environment – Audited against regulatory required environmental management plans 2 - At least every 12 months
auditor(s) selected from Tellus corporate compliance team
Internal Environmental – Audited against Tellus’ environmental management plans and procedures - At least every 12 months
auditor(s) selected from Tellus corporate compliance team on a risk-based profile
External Environmental – independent certified auditor(s) – waste management system, Condition 8, Every 12 months
MS 1078
AS/NZS ISO 14001 Certification – independent Every 12 months
certified auditor(s)

1 AS/NZS ISO 14001:2016 - Environmental management systems - Requirements with guidance for use
2 E.g. Leachate Monitoring Management Plan, Flora & Vegetation Management Plan, Deep Groundwater Monitoring & Management Plan

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4 Environmental Objectives and Targets

Key Documents
Document No. Document Name
TEL-03.002 Objectives, Targets & Programmes
TEL-03.003 Board Level Business Plan
TEL-03.004 Company Level Plan

As part of a continual improvement process, the environmental performance of every Tellus site is measured
against progress and achievements on objectives, targets and program milestones.
A number of objectives and associated performance criteria have been developed for the Facility and are
outlined in the management plans listed in Section 6.
Activities / initiatives in this OEMP are managed (scheduled / monitored) in INX InForm, InViron and
InControl.
Table 6: Sandy Ridge environmental objectives and targets
Objectives Targets Section Aimed to Achieve Target/s
Compliance
On time reporting of non-
compliances / potential non- No regulatory non-compliances. Section 9: Incident / Non-Compliance Reporting
compliances
Water
Reduction of water consumption Section 6.1.3: Potable Water Management
Minimise water consumption rate (based on tonnes of waste
received) year on year.
Potable Water Management
Increase of surface water reuse rate
Maximise surface water reuse (based on tonnes of waste received) Section 6.2.5: Surface Water
year on year
Groundwater
Section 6.1.1: Leachate Monitoring and
Preserve groundwater quality
No groundwater threshold Management Plan; and
inside and outside the
exceedances due to site activities. Section 6.1.2: Deep Groundwater Monitoring and
development envelope
Management Plan
Energy
Reduction of diesel electricity
generation year on year.
Maximise Energy Efficiently Section 6.2.7: Energy
Increase use of electricity generated
from solar power year on year.
Air
No environmental harm to flora
from site generated dust.
No complaints from
Reduce dust from unsealed areas accommodation village.
Section 0: Air
(i.e. stockpiles, roads) Monthly site environmental dust
deposition gauge results less than
those recorded at the control
location

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 Objectives Targets Section Aimed to Achieve Target/s
Minimise emissions to air from
Emissions below NPI 3 reporting
fuel consumption and waste
thresholds
management activities.
Hazardous Waste
No reportable environmental non-
Hazardous and radioactive waste compliances associated with Section 6.1.5: Hazardous Materials and Dangerous
storage and disposal complies hazardous and radioactive wastes Goods; and
with legal requirements resulting from waste management Section 6.1.7: Radiation Management
activities.
On-site Generated Waste
Reduce the volume of waste to Reduce of waste to landfill year on
landfill year.
Increase volume of on-site Increase recycled waste year on
Section 6.2.6: Wastes – Site Generated
generated waste that is recycled year.
Avoid generating wind-blown Zero litter observed in native
litter vegetation adjacent to the Facility.
Flora and Vegetation
No impacts to flora and native
Section 6.1.4: Flora and Vegetation Management
vegetation outside of No reportable non-compliances.
Plan
development envelope
Fauna
Zero fatalities or injuries caused by
No impacts to native fauna Section6.2.3: Fauna
site works.
Erosion and Sediment
Minimise impacts to the
Zero environmental incidents
environment from erosion and Section 6.2.4: Erosion and Sedimentation
caused by erosion or sedimentation.
sedimentation.

3
National Pollutant Inventory ([Link])

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5 Statutory Requirements

The success of the EMS requires detailed understanding and planning towards the Site’s environmental
impacts and controls, regulatory compliance requirements, internal corporate obligations, and community
expectations. This Section outlines the planning aspects of the OEMP.
All obligations and relevant conditions must be entered into INX InForm and assigned an Owner(s) and
Endorser(s). Evidence of compliance must be uploaded or linked to each obligation/condition by the
Owner(s).

5.1 Aspects and impacts

The identification and control of environmental risks at the Facility is undertaken in accordance with the
Management Standards which aligns with Australian & New Zealand Standard AS/NZS 31000:2018 Risk
Management - Principles and Guidelines.
In accordance with the Tellus Management Standards, every Tellus operational site is required to develop an
aspects and impacts register with the implementation of appropriate controls to minimise environmental
risks associated with site-based activities, products and services.
The aspects and impacts register is subject to scheduled reviews and updates (if required) to reflect any
operational changes. The Facility has an Aspects and Impacts register in place.

Key Documents
Document No. Document Name
SR-06.002 Risk Management Plan
TEL-08.501 Environmental Aspects & Impacts
TEL-06.001.03 Hazard Identification & Risk Control Procedure

5.2 Commonwealth government approval EPBC 2015/7478

The Commonwealth government approval EPBC 2015/7478 requires the development of and
implementation of a Deep Groundwater Monitoring and Management Plan.
In accordance with Condition 1, Part A, the EPBC Approval requires compliance with Conditions 1 and 9 of
the Western Australian Government Ministerial Statement 1078, refer to Section 5.3.
Condition 9, Part A requires that environmental compliance reports be made available on the Tellus website
([Link]).
Table 7: Commonwealth government approval details

Approval Issued By / Approved By Date of Issue / Approval Expiry Date

EPBC 2015/7478 Department of Agriculture, 7 January 2019 31 December 2048
Water and the Environment

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5.3 Western Australian government ministerial statement 1078

Ministerial Statement 1078 (MS 1078) requires the development of and implementation of several
management plans and monitoring programs to ensure all aspects are managed in an environmentally
responsible manner.
The following management plans are required by MS 1078:
• Flora and Vegetation Management Plan.
• Construction Environmental Management Plan (Construction Fauna Management Plan).
• Leachate Monitoring and Management Plan.
• Waste Facility Decommissioning and Closure Plan.
Condition 4-6 requires that environmental assessment reports be made available on the Tellus website
([Link]).
Table 8: Western Australian government approval details

Approval Issued By / Approved By Date of Issue / Approval Expiry Date

Ministerial Statement Department of Water and 27 June 2018 27 June 2043
1078 Environmental Regulation
MOD 1: 5 February 2019

5.4 Licences and permits

The Facility is required to operate in accordance with the licences and permits listed in Table 9.
Table 9: Facility licences and permits
Licence / Permit Issued By Date of Issue Expiry Date Details
L9240/2020/1 DWER 29/06/2020 28/06/2040 • Cat 61: Liquid Waste Facility.
• Cat 61A: Solid Waste Facility.
W6243/2019/1 - DWER 20/05/2019 19/05/2022 • Cat 12 – Screening etc., of material (not
Works Approval #1 constructed or licensed).
W6243/2019/1 - DWER 28/11/2019 N/A • Cat 85 – Sewage facility operated under
Works Approval #1  Registration R2498.
Registration R2498

W6243/2019/1 - DWER 27/02/2020 N/A • Cat 89 – Putrescible landfill site operated

Works Approval #1  under Registration R2501.
Registration R2501

W6305/2019/1 - DWER 29/06/2020 10/09/2040 • Cat 61 - Liquid waste facility.

Works Approval #2  • Cat 61A - Solid waste facility.
Licence L9240/2020/1 • Combined capacity of 150,000 tonnes
above-ground storage
W6308/2019/1 - DWER Pending amendment • Cat 61 - Liquid waste facility.
Works Approval #3  • Cat 61A - Solid waste facility.
Licence L9240/2020/1 • Cat 65 - Class IV secure landfill site
(pending).
• Cat 66 - Class V intractable landfill site
(pending).
• Combined capacity of 15,000 tonnes
above-ground storage and 100,000
tonnes per annum waste acceptance.

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 Licence / Permit Issued By Date of Issue Expiry Date Details
GWL202536(1) DWER 08/03/2019 07/03/2029 Groundwater extraction licence for Carina
Production Bore in L16/121. 180,000 kL per
annum

GWL202536(1) DWER 08/03/2019 07/03/2029 Groundwater extraction licence for Carina

Production Bore in L16/121. 180,000 kL per
annum.

82941/1 Clearing DWER 07/02/2019 - Allows mechanical removal of 53.22 ha for

Permit borrow pits.
RS 210/2018 30289 Radiological 21/10/2019 17/10/2022 Site Registration and licence to accept and
Council store low level radioactive waste.
RX 149/2019 31606 Radiological 10/10/2019 10/10/2022 Registration of radiological equipment.
Council
DGS022452 DMIRS 27/09/2018 27/09/2023 Dangerous Goods Site Licence.

5.5 Mining tenements

The Facility is required to operate in accordance with the conditions of the granted tenements listed in Table
10 under the Mining Act 1978. The Facility would need to apply to the Department of Mines, Industry
Regulation and Safety (DMIRS) for additional leases.
Table 10: Mining tenements

Tenement Issued By Commencement Expiry Comment

Crown Lease DPLH 4 27/11/2019 Applies to Lot 510 on Deposited Plan 413497
O289974
Exploration Leases

E 16/440 DMIRS 23/01/2013 22/01/2023

General Purpose Leases

G 16/0021 DMIRS 21/03/2017 20/03/2038 W6243/2019/1 / W6305/2019/1 /
W6243/2019/1 apply to this tenement
Miscellaneous Leases

L 16/0129 DMIRS 03/07/2020 02/07/2041

L 15/0361 DMIRS 14/08/2018 13/08/2039 82941/1 Clearing Permit applies to this tenement

L 15/0362 DMIRS 14/08/2018 13/08/2039 82941/1 Clearing Permit applies to this tenement

L 15/0394 DMIRS 07/06/2019 06/06/2040

L 16/0119 DMIRS 14/08/2018 13/08/2039 82941/1 Clearing Permit applies to this tenement

L 16/0121 DMIRS 14/08/2018 13/08/2039 Groundwater extraction licence No.

GWL202536(1) for Carina Production Bore
applies to this tenement
L 16/0124 DMIRS 07/06/2019 06/06/2040
L 16/0125 DMIRS 07/06/2019 06/06/2040

4
Department of Planning, Lands and Heritage

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 Tenement Issued By Commencement Expiry Comment
L 16/0129 DMIRS 03/07/2020 02/07/2041

Mining Leases

M 15/1864 DMIRS 05/03/2020 04/03/2041

M 15/1865 DMIRS 05/03/2020 04/03/2041

M 15/1866 DMIRS 05/03/2020 04/03/2041

M 15/1867 DMIRS 05/03/2020 04/03/2041

M 16/0540 DMIRS 13/08/2018 12/08/2039 W6243/2019/1 / W6305/2019/1 /

W6243/2019/1 apply to this tenement
M 16/0574 DMIRS 13/03/2020 12/03/2041

The conditions of each tenement listed in the above table can be found in INX InForm.
Further information on the above referenced tenements is available on the DMIRS online Minerals Title
database ([Link]).

5.6 Other legislation

Refer to the INX InForm for details of obligations relevant to the Facility.

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 6 Managing the Environment

There are two groupings for managing environmental aspects and impacts at the Facility.
Key environmental aspects/impacts 1 Stand-alone documents external to OEMP Refer to Section 6.1
Remaining environmental aspects/impacts Managed under this OEMP Refer to Section 6.2
1 Management documents required by legislation or conditions of regulatory approval.

Table 11 summarises each environmental aspect/impact and each associated management document.
Table 11: Summary of Environment Aspects/Impacts and their Management Document

Environment Aspect / Impact Management Document/s

Gaseous
Air OEMP
Particulate/Dust
Surface water and Leachate Section 6.2.5 & Leachate Monitoring &
Management Plan Management Plan

Water Groundwater Deep Groundwater Monitoring and Management

Drinking Water Potable Water Management Plan
Water Reuse Surface Water Control Procedure

Native Flora
Flora Flora and Vegetation Management Plan
Exotic (weeds)
Native Fauna OEMP
Fauna Exotic (pests/feral) Construction Environmental Management Plan
(subject to review).

Erosion
Soil
Sedimentation
General Wastes OEMP
Site Generated Wastes Sewage
Hazardous Wastes

Hazardous Materials and Hazardous Materials Hazardous Materials and Dangerous Goods
Dangerous Goods Dangerous Goods Management Plan

Radiation Radioactive Wastes to Cell Radiation Management Plan

Solar
Energy Usage OEMP
Fuel
Hazardous Material Spills
Emergency Response Plan
Incidents / Emergencies Adverse Weather (i.e. floods, cyclone, etc.)

Bushfire Bushfire Management Plan

Facility Decommissioning and Closure Waste Facility Decommissioning and Closure Plan;
Closure
and Mine Closure Plan

Odour
Artificial light
Other OEMP
Noise
Vibration

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Environment Aspect / Impact Management Document/s
Non-Operational Project

6.1 Environmental Aspects – Stand-alone Management Plans

6.1.1 Leachate Monitoring and Management

Leachate is a liquid that has passed through material and extracted some of the constituents of that
material, e.g. water passing through waste and becoming contaminated with elements of that waste.
There is potential for leachate to be generated at the Facility, mainly from waste cells, and polluting the
surrounding environment. Ministerial Statement 1078 issued by the Western Australian Minister for the
Environment, requires Tellus to develop and implement a Leachate Monitoring and Management Plan
(LMMP). The LMMP focusses on managing impacts from leachate to the environment in the regolith layers
above the unweathered granite (see also Section 6.1.2).

Document Title ( No..) Sandy Ridge - Leachate Monitoring and Management Plan (SR-08.507)

Location Management Standard 08 Process Control & Delivery / 08.500 – Environment & Approvals

Key document content: • Required by Condition 9-1 to 9-6 of MS 1078.

• Management of potential leachate to soil and groundwater (above bedrock).
• Monitoring of potential leachate to soil and groundwater (above bedrock).
• Incident/non-conformance requirements.
• Reporting requirements.

6.1.2 Deep Groundwater Monitoring and Management

Related to management of leachate (see Section 6.1.1), the Australian Government’s approval for the Facility
(EPBC 2015/7478) required groundwater monitoring and management for leachate and other impacts to
groundwater within both the weathered granite (aka kaolinised granite) and the granite hard rock (bedrock)
below it. The Deep Groundwater Monitoring and Management Plan (DGMMP) describes this management.

Document Title ( No..) Sandy Ridge - Deep Groundwater Monitoring and Management Plan (SR-08.508)

Location Management Standard 08 Process Control & Delivery / 08.500 – Environment & Approvals

Key document content: • Required by Condition A.2 of EPBC 2015/7478.

• Management of potential leachate groundwater (below bedrock).
• Monitoring of potential leachate to groundwater (below bedrock).
• Incident/non-conformance requirements.
• Reporting requirements.

6.1.3 Potable Water Manag ement

Western Australian mine sites that provide drinking water to employees are required to comply with the
Australian Drinking Water Guidelines and to implement a drinking water quality management plan to
support the site’s Health and Hygiene Management Plan. The Sandy Ridge Potable Water Management Plan
describes drinking water treatment, storage, monitoring, reporting and incident management.
Management of drinking water quality is the responsibility of the Facility Health and Safety Manager. The
sustainable use of water is the responsibility of the Environmental Manager (WA).

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 Document Title ( No..) Sandy Ridge - Potable Water Management Plan (SR-08.307)

Location Management Standard 08 Process Control & Delivery / 08.300 – Occupational Health & Hygiene

Key document content: • Required by Department of Health

• Management of potable made by groundwater abstracted from Carina bore and filtration of
the water through the site Reverse Osmosis (RO) plant.
• Monitoring of potable water.
• Incident/non-conformance requirements.
• Reporting requirements.

6.1.4 Flora and Vegetati on Managem ent

There is potential for impacts to flora and vegetation at the Facility, mainly from clearing vegetation,
introducing weeds, dust emissions and saline water. Ministerial Statement 1078 issued by the Western
Australian Minister for the Environment, requires Tellus to develop and implement a Flora and Vegetation
Management Plan (FVMP) to avoid and manage impacts to Calytrix creswellii, Lepidosperma lyonsii and an
undescribed Lepidosperma species.

Document Title ( No..) Sandy Ridge - Flora and Vegetation Management Plan (SR-08.503)

Location Management Standard 08 Process Control & Delivery / 08.500 – Environment & Approvals

Key document content: • Required by Condition 10-5 of MS 1078.

• Management of potential direct and indirect impacts to flora and vegetation; specifically,
Calytrix creswellii, Lepidosperma lyonsii, and the undescribed Lepidosperma sp.
• Monitoring requirements (i.e. flora surveys).
• Incident/non-conformance requirements.
• Reporting requirements.

6.1.5 Constructi on ( Fauna) Environmental Manag ement Plan

There is potential for impacts to fauna at the Facility, mainly from clearing vegetation, drowning in artificial
water bodies and vehicle strikes. Ministerial Statement 1078 issued by the Western Australian Minister for
the Environment, requires Tellus to develop and implement a Construction Environmental Management Plan
(CEMP) to avoid and manage impacts to terrestrial Fauna.
As construction of the Facility was completed in October 2020, much of the CEMP is not relevant during
operations, or can be managed adequately under this OEMP. Tellus will liaise with DWER to determine how
to transition fauna management into operations. In the meantime, the CEMP must continue to be
implemented. See also Section 6.2.3 for key fauna management measures to be taken during operations.

Document Title ( No..) Sandy Ridge – Construction Environmental Management Plan (SR-08.501)

Location Management Standard 08 Process Control & Delivery / 08.500 – Environment & Approvals

Key document content: • Required by Condition 11-2 of MS 1078.

• Pre-clearance survey and clearing procedures
• Avoidance, mitigation and management measures for fauna, focussing on conservation
significant species and feral fauna control.
• Adaptive management with trigger and management actions
• Incident reporting.
• Reporting and auditing requirements.

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6.1.6 Hazar dous Materi als and Danger ous G oods
The purpose of this procedure is to manage hazardous materials used for completing tasks at the Facility to
minimise the risk of potential illness and/or injury to workers, prevent damage to property and the
environment and to meet compliance requirements.

Document Title ( No.) Sandy Ridge – Hazardous Materials and Dangerous Goods Management (SR-06.001)

Location Management Standard 06 Risk Management

Key document content: • Applies to all chemical materials utilised at the Facility.
• Requires a risk assessment prior to bringing any new hazardous material or dangerous good to
the Facility.
• Details hazardous materials and dangerous good requirements associated with, for example
(however not limited to:
o Transport
o Storage
o Handling
o Disposal
o Incident response

6.1.7 Radi ation Managem ent

The Radiation Management Plan is designed to satisfy the requirements of the Radiation Safety Act 1975 for
the identification, assessment, control and reporting of radiation hazards and risks on and associated with
the operations of the Facility.

Document Title ( No..) Sandy Ridge - Radiation Management Plan (SR-08.701 under review)

Location SharePoint/HSECQ Sandy Ridge/Pre-Development/Low Level Radioactive Waste Site

Registration/NORM Site Registration

Key document content: • Applies to the radiation safety measures associated with all operations involving radioactive
substances.
• Provides guidance and information on the safe handling of such radioactive substances as well
as rules relating to the safety and security of radioactive substances and the limitation of
radiation exposure to persons on site.
• Refers to Radiation Management Procedure (TEL-08.701) for internal and external radiation
reporting requirements.

6.1.8 Emergency Res ponse Plan

This document was developed to help ensure compliance with Part 4, Division 3 “Emergency Preparation” of
the WA Mines Safety and Inspection Regulations 1995 as a guideline, and more specifically Regulation 4.30
“Preparation of emergency plan” (ERP). This ERP is aligned with Australian Standard 3745-2010 Planning for
emergencies in facilities (AS 3745-2010).

Document Title ( No..) Sandy Ridge - Emergency Response Plan (SR-08.101)

Location Management Standard 08 Process Control & Delivery / 08.100 – Emergency Response Plan

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 Key document content: • Defines the methods to be followed in the case of an emergency to limit the injury of people
and minimize the damage to the environment, property, process and production.
• Provides information concerning site responsibilities, actions, reporting requirements and
resources available to ensure an effective and timely response is undertaken in the event of an
emergency situation.
• Relates to employees, visitors, members of the public and contractors.
• Provides reference to relevant procedures depending on the emergency. For example:
o Hazardous Materials Response Procedure
o Chemical Spill Procedure

6.1.9 Bushfire
The site is within a designated bushfire prone area as per the Western Australia State Map of Bush Fire Prone
Areas (DFES 2018; Figure 1-2), which triggers bushfire planning requirements under State Planning Policy 3.7
Planning in Bushfire Prone Areas (SPP 3.7; WAPC 2015). The primary purpose of this Bushfire Management
Plan is to act as a technical supporting document to inform planning assessment in accordance with the
Guidelines for Planning in Bushfire Prone Areas v 1.3 (the Guidelines; WAPC 2017).

Document Title ( No.) Sandy Ridge - Bushfire Management Plan (SR-08.504)

Location Management Standard 08 Process Control & Delivery / 08.500 – Environment & Approvals

Key document content: • Required by Condition 8 of the Facility Development Approval DAP17/01318.
• Details the site bushfire risk rating and rating assessment process
• Details bushfire preventative and response measures

6.1.10 Waste Facility Decom missioning and Closur e

When the Facility ceases operations, the site must be closed in a manner that minimises impacts to the
environment. This closure is regulated under both the Mining Act 1978 by way of a Mine Closure Plan (see
Section 6.1.11) and MS1078 which requires implementation of the Waste Facility Decommissioning and
Closure Plan (WFDCP). The WFDCP details management of closing waste-related infrastructure at the
Facility.

Document Title ( No.) Sandy Ridge - Waste Facility Decommissioning and Closure Plan (SR-08.509)

Location Management Standard 08 Process Control & Delivery / 08.500 – Environment & Approvals

Key document content: • This plan describes a sequence of events for decontamination of the Facility and structures
used to manage and contain mixed waste during the receipt and emplacement operations
• This plan is intended to meet condition 12 of MS 1078 and, the requirements, terms and
conditions of the Facility’s Crown Lease, and agreed financial assurance and insurance
framework.

6.1.11 Mine Cl osur e

Under the Mining Act 1978, mining cannot occur without an approved Mine Closure Plan (MCP). The Sandy
Ridge MCP is designed to ensure mining activities and infrastructure “are rehabilitated and closed in a
manner that makes them physically safe to humans and animals, is geotechnically stable, geo-chemically
non-polluting/non-contaminating and capable of sustaining an agreed post-closure land use without
unacceptable liability to the State” (DMIRS Mine Closure Plan Guidance 2020).
At the Facility, the MCP scope is limited to infrastructure directly related to mining activities and excludes
waste facility infrastructure (see also Section 6.1.10).

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 Document Title ( No.) Sandy Ridge - Mine Closure Plan (SR-03.301)

Location Management Standard 03 – Planning and Project Management / 03.300 - Land Management

Key document content: • Required by the WA Mining Act 1978 and must meet the form and content requirements of
Part 1 of the Statutory Guidelines for Mine Closure Plans.
• The Mine Closure Plan is a dynamic document that must be regularly reviewed and refined over
time to ensure that it reflects the current knowledge relevant to the development and
rehabilitation status of the mine.

6.2 Other Environmental Aspects

6.2.1 Gener al
The following tables provides a summary of the mitigation measures which typically relate to all
environmental management aspects (vs specifically one).

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 General Monitoring and Management Measures
Section Item Accountability Timing
Management All personnel working at the Facility must complete a site induction, which includes as a minimum: Facility Manager As required
- key environmental aspects and potential impacts
- key environmental management documents
- how to manage the potential risk to environment
Weekly toolbox talks are to include a section on environment management where the following is Facility Manager Weekly
discussed:
- Environment incidents
- Environment inspection/audit completed and their outcomes
- Environment topic to discuss
Environmental incidents and near-misses to be managed as per Section 9. Facility Manager As required
Training to be provided to staff in line with Section 10. Facility Manager As required
Monitoring Facility Manager Daily Inspection Checklist Facility Manager Daily
Potential/actual environmental impacts are to be reported, investigated, and mitigated
Weekly Environmental Inspection Checklists Facility Manager Weekly
Potential/actual environmental impacts are to be reported, investigated, and mitigated
Monthly Environmental Inspection Checklists Environment Manager (WA) Monthly
Potential/actual environmental impacts are to be reported, investigated, and mitigated
Reporting Environmental Incidents and near-misses will be reported, investigated, and mitigated (as required) Facility Manager As required
via InControl.
Environmental Incidents and near-misses will be reported in the environment section of the Monthly Environment Manager (WA) Monthly
Performance Report.
Records to be Maintained Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly
Monthly Performance Report – Environmental Section. Environment Manager (WA) Monthly

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 General Monitoring and Management Measures
Section Item Accountability Timing
Incident/Non-conformance/complaint/dispute records (via InControl), as relevant Environment Manager (WA) As required
Stakeholder communications (via InForm) Environment Manager (WA) As required
Internal and external reports - see Section 3.2.2 and 7
Corrective actions (via InControl and InForm) Environment Manager (WA) As required
Facility induction record sheets Facility Manager As required
Pre-start and Toolbox meeting attendance and record sheets Facility Manager As required

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6.2.2 Air
Air
Risk / Impact Controls Accountability Timing
Dust emissions - general Where visible airborne dust is present, corrective actions will be implemented (e.g. applying Facility Manager At all times
suppression or changing operations).

Dust emissions from newly exposed If unacceptable dust is observed work shall cease or phase down while the cause is being actively All Personnel At all times
surfaces investigated and suppression measures are implemented.

Dust emissions from stockpiles Stockpiles are to be designed to minimise dust generation. Facility Manager At all times
Dust emissions from earthworks Loads will be appropriately managed to prevent dust emissions (e.g. dampened, covered, or loaded Facility Manager At all times
and haulage trucks less than the height of the side and tailboards).
All vehicles to travel on designated roadways. All Personnel At all times
Plant or equipment not to be left/parked with the motors running when not in use. All Personnel At all times
Where visible dust emissions are present during unloading/loading events near to sensitive Facility Manager At all times
receptors, water sprays and/or mists to be used.

Dust emissions from access routes Ensure that vehicles travel at speeds that do not generate excessive amounts of dust. Facility Manager At all times
Apply dust suppression to access routes. As required
Ineffective use / poor maintenance Plant, equipment, and vehicles to be maintained and operated in accordance with the All Personnel At all times
of equipment and machinery manufacturers specifications to minimise the emission of air pollutants and offensive odours and
causing excessive emissions minimise the generation of dust.
Plant or equipment is not to be left/parked with the motors running when not in use to reduce the All Personnel At all times
potential for impact on air quality.

Material transfer requirements to be optimised through excavation planning, such that material Facility Manager At all times
double handling will be avoided where possible and work areas will be minimised.

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 Air
Risk / Impact Controls Accountability Timing
Extreme weather conditions Review weather forecasts and current weather conditions. All Personnel At all times
causing airborne emissions Adjust operations in consideration of weather forecasts, to minimise the risk of excessive dust (e.g.
high winds).
Visually assess the dust levels and the effectiveness of any controls implemented, adjusting
accordingly.
Greenhouse Gas (GHG) Equipment will be inspected and maintained to ensure efficient running and so it is appropriately Maintenance Supervisor As required
sized for the task in hand.

Local supplies and/or facilities will be utilised to minimise vehicle kilometres travelled (where All Personnel As required
responsible and feasible).

Monitoring Daily visual observation during works. Workers to maintain a visual awareness of dust emissions. All Personnel At all times
Environmental Inspection Checklist(s).
Dust deposition sampling and analysis is completed monthly with results aimed to assist site Environment Manager (WA) Monthly
operators on the effectiveness of dust mitigation measures.
Dust monitoring to be completed in accordance with Sandy Ridge - Dust Deposition Gauge Sampling
Safe Work Procedure (SR-09-203).
Monitoring of wind speed, wind direction, rainfall and temperature. The weather station will be Maintenance Supervisor As required
regularly calibrated and maintained to ensure acceptable data quality.

Reporting The Facilities air quality performance will be reported in the environment section of the Monthly Environment Manager (WA) Monthly
Performance Report.

The Facility will report greenhouse gas metrics (as advised by the Environmental Compliance Facility Manager Monthly
Manager) the in the Monthly Performance Report.
The Facility will quantify greenhouse gas emissions and submit annual reports to the Australian Environmental Compliance Annually
Greenhouse Office on performance against emission management targets. Manager

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 Air
Risk / Impact Controls Accountability Timing
Records to be Maintained Completed Environmental Inspection Checklist(s). Laboratory Manager At all times
Dust deposition field sheets / chain of custodies / certificates of analysis. Environment Manager (WA) Monthly
Maintenance records Maintenance Supervisor At all times

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6.2.3 Fauna
Fauna
Risk / Impact Controls Accountability Timing
Impact to fauna – General Site No fauna is permitted to be brought on-site (i.e. pets) All Personnel As required
Operations
Feeding of fauna is not permitted. All Personnel As required
Any suspected/known impact to fauna is to be reported to your supervisor ASAP and reported via All Personnel As required
InControl. The Sandy Ridge Fauna Strike Procedure (SR-08.500.01) is to be followed in the event of
fauna being impacted by a vehicle.
Manage waste and rubbish appropriately to ensure fauna are not attracted to the Facility. All Personnel As required
Maintain fencing around operational areas (e.g. infrastructure area, surface water ponds) to exclude Facility manager As required
medium to large fauna.
If fauna impact operations and/or pose a health or safety risk, the impact is to be; reported via Facility manager As required
InControl, risk assessed, and risk mitigation measures implemented as necessary.
Impact to fauna - No clearing activities to commence until a Native Vegetation Clearing Permit (SR-08.502.01) has Permit Holder As required
Impact to vegetation ground been approved by the Environment Manager (WA), or delegate.
disturbances - Permit requirements include, but are not limited to: Conducting pre-clearing surveys to
determine if there are any signs of fauna (particularly conservation significant fauna).
- The requirement for an experienced and licenced Fauna/Spotter Handler to be present
during vegetation clearing, to remove any observed fauna.
- Avoidance areas (i.e. large trees with nests/nesting hollows, Malleefowl mounds, etc.).

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 Fauna
Risk / Impact Controls Accountability Timing
Impact to fauna – Ground disturbances could pose a risk to fauna where there is a potential for fauna to be: Permit Holder As required
No impact during ground - Struck by machinery during disturbances (i.e. road maintenance works);
disturbances - Buried during disturbances (i.e. excavation and/or stockpiling of soil); or
- Isolated (excavations and trenches where fauna cannot escape);
Risks (inclusive of potential environmental risks) are assessed as part of the Sandy Ridge Permit to
Work – Excavation (SR-096.106.01). It is the permit holder’s responsibility to ensure the works are
completed in accordance with the permit. Typical permit conditions (related to fauna) may include,
however are not limited to:
- Conducting pre-disturbance surveys to determine if there are any signs of fauna.
- The requirement for an experienced and licenced Fauna/Spotter Handler to be present
during vegetation clearing, to remove any observed fauna.
- Regular inspection of voids for fauna.
- Fauna egress points in voids.
Monitoring Observations of the following are to be reported to your supervisor ASAP and logged in InControl: All Personnel As required
- Feral fauna within the site boundary.
- Conservation-significant fauna species onsite or offsite (i.e. Fork-tailed Swift, Peregrine
Falcon, Malleefowl, Southern Death Adder, Woma).
- Malleefowl mounds.
Facility Manager Daily Inspection Checklist – To record potential/actual impact to fauna and/or Facility manager Daily
fauna potential/actual impact to site. To be investigated and mitigated (as necessary)

Weekly Environmental Inspection Checklists – To record potential/actual impact to fauna and/or Facility manager Weekly
fauna potential/actual impact to site. To be investigated and mitigated (as necessary)

Monthly Environmental Inspection Checklists – To record potential/actual impact to fauna and/or Environment Manager (WA) Monthly
fauna potential/actual impact to site. To be investigated and mitigated (as necessary)

Reporting Impact to fauna incidents and opportunities for improvement will be reported, investigated and All Personnel As required
mitigated (as required) via InControl.
Records to be Maintained Fauna incidents will be reported via the environment section of the Monthly Performance Report. Environment Manager (WA) Monthly

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 Fauna
Risk / Impact Controls Accountability Timing
Completed Permits to Work – Excavations and Native Vegetation Clearing Permit Holder As required
Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly
Fauna Sightings Environment Manager (WA) As required

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6.2.4 Erosion and Sediment
Erosion and Sediment
Risk / Impact Controls Accountability Timing
Erosion/Sedimentation – General Review weather forecasts and current weather conditions. Facility Manager At all times
Plan and/or adjust operations in consideration of weather forecasts, to minimise the risk of
erosion/sedimentation (e.g. high winds, heavy rainfall).
Assess the risk of erosion and sedimentation associated with relevant tasks, and the effectiveness of
controls implemented, making adjustments accordingly.
If erosion or sedimentation is observed which could impact the structure integrity, surrounding Facility Manager At all times
structure integrities and/or environment; associated work shall cease or scale back while the cause is
investigated, and mitigation measures implemented (as required).
Water cart spraying to dampen (not flood) surfaces Water Cart Operator At all times
Erosion/Sedimentation – ground Works to be completed in accordance with the Permit to Work – Native Vegetation Clearing and Permit Holder At all times
disturbance Permit to Work - Excavation.
Minimise ground disturbance areas as much as possible. Permit Holder At all times
Complete ground disturbance works in a staged manner. Permit Holder At all times
Disturbed areas to be treated to establish a crust if remaining open, or re-vegetated as soon as Permit Holder At all times
practicable after works completion.
Erosion/Sedimentation – Material Stockpiles to be designed and maintained to minimise erosion and maintain propagation viability Facility Manager As required
Stockpiles (where relevant)
Once formed, minimise disturbing material stockpiles. All Personnel At all times
Vehicles to keep to the stockpile access/egress tracks. All Personnel At all times
Material stockpiles to be treated to maintain a surface crust. Facility Manager As required
Erosion/Sedimentation – Surface Surface water management and storage infrastructure (i.e. drains, spillways, ponds, sumps, outlets, Facility Manager At all times
Water Catchments and Storages etc.) are to be constructed to withstand storm events for which they are rated.

Surface water infrastructure is to be maintained free of sediment. Maintenance Supervisor At all times

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 Erosion and Sediment
Risk / Impact Controls Accountability Timing
Extreme weather conditions Erosion and sedimentation-generating activities are to be assessed during periods of adverse All Personnel At all times
weather (i.e. heavy rainfall) and rescheduled where control of erosion or sedimentation generation
cannot be achieved.
Monitoring Daily visual observation during works which have the potential for erosion and sedimentation. All Personnel At all times
Workers to maintain a visual awareness of erosion and sedimentation potential.

Weekly Environmental Inspection Checklists – To record signs of erosion and sedimentation. To be Facility Manager Weekly
investigated and mitigated (as necessary)
Monthly Environmental Inspection Checklists – To record signs of erosion and sedimentation. To be Environment Manager (WA) Monthly
investigated and mitigated (as necessary)
Site to be inspected for damage after adverse weather events. Erosion and sedimentation to be Facility Manager As required
included as part of this inspection (as relevant).

Reporting Erosion and sedimentation incidents and opportunities for improvement will be reported, All Personnel As required
investigated and mitigated (as required) via InControl.

Erosion and sedimentation incidents will be reported via the environment section of the Monthly Environment Manager (WA) Monthly
Performance Report.
Records to be Maintained Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly
Permit to Work – Ground Disturbances Facility Manager At all times

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6.2.5 Surface Water
Surface Water
Risk / Impact Controls Accountability Timing
Contaminated surface water Site has been designed and constructed with surface water storage infrastructure in high risk areas Chief Development Officer Complete
release to the environment with capacity to contain a 1:100 year 72-hour storm event
Ensure all personnel are trained in surface water management that is relevant to their role and Facility Manager (on advice Induction - Prior to
responsibilities: from Environment Manager) commencing work.
• Site Induction Toolbox - Annually
• Toolbox topic – Surface water management
Implement the Surface Water Control Procedure (SR-08.510) which outlines the following to ensure Facility Manager At all times
compliance with the operating licence (see Section 5.4):
• surface water catchments at the Facility.
• how each catchment collects and retains surface water.
• reuse options for captured surface water.
Conduct daily and weekly environmental site inspections (InControl) to monitor surface water Facility Manager Daily and weekly
storage infrastructure to ensure compliance with operating licence (See Section 5.4):
• storm capacity is retained at all times.
• Valves and other drainage devices are working as designed.
• Confirm stormwater capacity is being maintained
• Assess environmental incidents for trends.
Conduct surface water sampling and analysis to determine water reuse options Environment Manager (WA) As required
Overuse of groundwater Implement the Potable Water Management Plan (refer to Section 6.1.3). All Personnel As required
Monitor water abstraction volumes from Carina Bore in accordance with ground water licence (See Facility Manager Monthly
Section 5.4).

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 Surface Water
Risk / Impact Controls Accountability Timing
Water used for dust suppression Implement Work Instruction for Dust Suppression (in development) which outlines: All Personnel As required
damages native vegetation. • Water sources to be used for dust suppression
• Authorisations required prior to using surface water for dust suppression
• Operating the Water Cart.
• Recording water consumption
• Reporting hazards and incidents.
Chemical or hydrocarbon spills Refer to Section 8. All Personnel As required
contaminate surface water
Monitoring Complete Facility Manager Daily Inspection Checklist. Facility Manager Daily
Complete Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Complete Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly
Reporting Incidents and opportunities for improvement will be reported, investigated and mitigated (as All Personnel As required
required) via InControl.
Incidents will be reported via the environment section of the Monthly Performance Report. Environment Manager (WA) Monthly
Records to be Maintained Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Water sampling/volume records (i.e. Laboratory reports, chain of custody certificates, field sheets, Facility Manager As required
flow meter readings)

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6.2.6 Wastes – Site Generated
Wastes - Site Generated
Risk / Impact Controls Accountability Timing
General Wastes are to be managed as per the Waste Hierarchy: Avoid, Reduce, Reuse, Recycle, Recover, All Personnel At all times
Treat then Dispose.
A waste inventory is to be developed and maintained to identify waste streams and opportunities to Facility Manager Within 12 months of
avoid, reduce, reuse and recycle each stream. commencement of
operations.
Wastes are to be managed at all times and are not permitted to enter the environment. All Personnel At all times
General Wastes General wastes are to be placed in the designated bins with lids. All Personnel At all times
(i.e. non-hazardous wastes or After consideration of the above ‘Waste Hierarchy’, general wastes are to be disposed of at the All Personnel At all times
sewage) landfill.
General wastes placed in the landfill are to be regularly covered with soil stockpiled at the landfill. All Personnel At all times
The covered waste is not to be disturbed. All Personnel At all times
Sewage Sewage is to be managed via two systems: All Personnel At all times
1. Wastewater Treatment Plant (WWTP) and Irrigation Area (IA)
2. Tellus Office Biocycle System
The above systems are to be maintained in accordance with manufacturer specifications. Maintenance Supervisor At all times
Sewerage leaks/unusual odour/spills/etc. are to be reported via InControl, investigated and Facility Manager As required
mitigated promptly.

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 Wastes - Site Generated
Risk / Impact Controls Accountability Timing
Putrescible landfill The landfill must be managed in accordance with the Environmental Protection (Rural Landfill) Facility Manager At all times
Regulations 2002, including the following key operational requirements:
• Tipping area less than 30 m long by 2m high.
• Waste to be covered at least monthly with clean inert material (soil) so that no waste is
left exposed.
• Enough clean soil to cover the tipping area twice must be stockpiled at all times.
• Waste must not escape the landfill and must be returned to the tipping area at least
monthly.
• No waste within 35 m of the fence.
• Stormwater to be diverted away from the tipping area, and contaminated stormwater to
be contained on site.
• Dust is to be managed.
• A firebreak of at least 3m around the boundary.
• Fire in the landfill must be reported to DWER CEO.
• No clinical waste or asbestos.
Hazardous Wastes After consideration of the above ‘Waste Hierarchy’, hazardous wastes are to be disposed via an Facility Manager As required
(i.e. contaminated soils/liquids, appropriately licensed waste facility. Disposing of site generated hazardous wastes in the Facility
waste oils, spilt materials, etc.) Cell is to be considered.

Monitoring Site generated general waste streams are to be monitored, which includes: volumes, sources, waste Facility Manager As required
types, end use or disposal location.
Site generated hazardous waste streams are to be monitored, which includes: volumes, sources, Facility Manager As required
waste types, end use or disposal location.
Village- generated sewage waste volumes are monitored using the WWTP daily check sheet. Office Maintenance Supervisor Daily
generated sewage is minimal and therefore not actively monitored. However, the system is to be
inspected regularly and maintained as required.
Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly

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 Wastes - Site Generated
Risk / Impact Controls Accountability Timing
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly
Reporting Waste incidents and opportunities for improvement will be reported, investigated and mitigated (as All Personnel As required
required) via InControl.
Waste volumes and incidents will be reported via the environment section of the Monthly Environment Manager (WA) Monthly
Performance Report.
Fire at the landfill must be reported to the CEO of DWER within 14 days. Report must include: Facility Manager Within 14 days of an
• Date, time and location of the fire unauthorised fire.
• Time and location that the fire was declared safe by the Fire Control Officer (SR Emergency
Services Officer)
• Cause or suspected cause of the fire.
Records to be Maintained WWTP Daily check sheet. Maintenance Supervisor Daily
Site generated (general and hazardous) wastes register. Facility Manager As required
Offsite waste disposal dockets Facility Manager As required
Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly

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6.2.7 Energy
Energy
Risk / Impact Controls Accountability Timing
General Energy use is to be minimised and energy efficiency is to be maximised, where possible All Personnel At all times
Renewable energy options are always to be considered over fossil fuel reliant equipment. All Personnel At all times
Solar The solar farm is to be appropriately maintained to maximise efficiency and energy output. Maintenance Supervisor At all times
Solar energy use during day time is to be maximised to minimise the reliance on fuel generated All Personnel At all times
energy
Fuel – Generator Generators are to be appropriately maintained to maximise efficiency and energy output. Maintenance Supervisor At all times
Fuel – Other Fuel reliant equipment is to be appropriately maintained to maximise efficiency . Maintenance Supervisor At all times
(i.e. vehicles, machinery, etc.)
Monitoring Solar energy generation and usage is to be monitored Facility Manager Weekly
Fuel use is to be monitored Facility Manager Weekly
Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Routinely conduct power generation system inspections Maintenance Supervisor Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly
Reporting Incidents and opportunities for improvement will be reported, investigated and mitigated (as All Personnel As required
required) via InControl.
Energy usage and incidents will be reported via the environment section of the Monthly Environment Manager (WA) Monthly
Performance Report.
Records to be Maintained Solar Farm Inspection Checklist Maintenance Supervisor As required
Generator Inspection Checklist Maintenance Supervisor As required
Light Vehicle Inspection Checklist All Personnel As required
Heavy Vehicle Inspection Checklist All Personnel As required
Energy Generation/Consumption Register Facility Manager As required

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 Energy
Risk / Impact Controls Accountability Timing
Fuel delivery dockets/invoices Facility Manager As required
Plant Inspection Checklist All Personnel As required
Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly

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6.2.8 Other
Other
Risk / Impact Controls Accountability Timing
Odour Odour is to be minimised, where possible. All Personnel As required
Significant odour is to be investigated/mitigated (as required). All Personnel As required
Artificial light Artificial light overspray is to be minimised, where possible. All Personnel As required
Significant artificial light overspray is to be investigated/mitigated (as required). All Personnel As required
Noise Noise is to be minimised, where possible. All Personnel As required
Significant noise is to be investigated/mitigated (as required). All Personnel As required
Vibration Vibration is to be minimised, where possible. All Personnel As required
Significant vibration is to be investigated/mitigated (as required). All Personnel As required
Non-Operational Projects Potential/actual environmental risks associated with non-operational projects (i.e. exploration COO As required
campaigns, the Facility expansion, construction of additional Cells) will require project specific
assessment and risk mitigation measures.
This assessment and risk mitigation measures are to be documented in a project specific
management plan (i.e. Project Management Plan or Environment Management Plan).
Pre-approval of this management plan is required from the COO and Environment Manager (WA).
Monitoring Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly
Reporting Incidents and opportunities for improvement will be reported, investigated and mitigated (as All Personnel As required
required) via InControl (see Section 9).
Incidents will be reported via the environment section of the Monthly Performance Report. Environment Manager (WA) Monthly
Records to be Maintained Completed Facility Manager Daily Inspection Checklist. Facility Manager Daily
Completed Weekly Environmental Inspection Checklist(s). Facility Manager Weekly
Completed Monthly Environmental Inspection Checklist(s). Environment Manager (WA) Monthly

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7 Information and Communication

Key Document
Document No. Document Name
TEL-07.101 Health, Safety & Environmental Communication

7.1 Community

The community will be kept informed about the Facility and the environmental performance by the following
methods.
7.1.1 Tellus website
The following information will be made publicly available on the Sandy Ridge Facility Regulatory Information
section of the Tellus website:
• All approved strategies, plans and programs required under the conditions of regulatory
approvals, except where permission has been granted by DWER, or another agency, not to make
the information publicly available.
• A summary of the monitoring results which will be reported in accordance with the approved
plans or programs.
• Annual compliance reports.
• Any independent audits conducted under regulatory approval requirements.
7.1.2 Complai nts and enquiries
Condition 20 of L9240 requires the following concerning complaints:

20 The Licence Holder must record the following information in relation to complaints received by the
licence holder (whether received directly from a complainant or forwarded to them by the
Department or another party) about any alleged emissions from the premises:
a) the name and contact details of the complainant, (if provided);
b) the time and date of the complaint;
c) the complete details of the complaint and any other concerns or other issues raised; and
d) the complete details and dates of any action taken by the licence holder to investigate or
respond to any complaint.

The Facility will publicise the following telephone numbers on the ‘Contact Us’ section of the Tellus website:
• Sandy Ridge Site Administration: 0438 452 889.
• Sandy Ridge Site Emergency Services: 0438 353 387.
Complaints are entered into INX InForm Communications database online form. The Facility will respond to
any community inquiries or complaints received. Personal information of the complainant will not be
released. Each complaint is assigned a unique reference number in INX InForm to provide a reference and
the records are retained permanently.
An e-mail general enquiries email address (info@[Link]) is available on Tellus’ website for the
community or stakeholders to register concerns or comments.

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It is the responsibility of the Facility Administrator to record community complaints/enquiries received via
the above number and for the Environment Manager (WA) (or delegate) to investigate the nature of the
complaint/enquiry. Complaints will be followed up by the Environment Manager (WA) as soon as the
outcomes of the investigation have been completed and no more than 24 hours after the complaint was
received, if contact details have been provided.
The Facility’s Emergency Response Team will respond to any call made to the Sandy Ridge Site Emergency
Services telephone number.
INX InForm Communications is the Facility’s community complaints register. The Environment Manager (WA)
shall ensure that key staff are trained and competent in the use of INX InForm Communications as the
central repository for all complaints relating to Facility activities. Figure 5 shows the complaints handling
process for that Facility.

Figure 5: Sandy Ridge complaints handling process

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7.1.3 Dispute res olution
Neither EPBC 2015/7478 nor MS 1078 provide requirements and actions for situations where a community
member may not be satisfied with Tellus’ actions undertaken as a result of a complaint as described in
Section 7.1.2. Tellus will endeavour to address the complainant’s concerns; however, in situations where this
is not possible Tellus may seek independent advice on how to resolve the issue.

7.2 Internal reporting

The Environment Manager (WA) is responsible for collating environmental data on a monthly basis and
providing this to the COO for inclusion in a monthly report.
The information collected must comprise of the number of:
• Non-compliances for the month (e.g. enforcement action).
• Environmental incidents for the month.
• Environmental non-conformances for the month.
• Environmental observations for the month.
• Weekly and monthly inspections conducted for the month.
The Facility Manager is to ensure site metrics (see “Records to be maintained” and “Reporting” fields in
Section 6) are recorded and accessible for internal and external reporting.

7.3 Government agencies

As with all Tellus operations, open and frequent dialogue will be maintained with the DWER, DMIRS, DAWE
and other government agencies that have an interest in the Facility.
Regulatory authorities will be informed of key operational activities in addition to the annual reporting
required through compliance reports (see Section 3.2.2) and website publishing of environmental
monitoring data, where required.
See Section 9 for environmental incident reporting.

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8 Emergency and Crisis Management

Key Documents
Document No. Document Name
SR-08.101 Emergency Response Plan
SR-08.101.01 Emergency Management Procedure
SR-08.101.02 Emergency Duty Cards
SR-08.102 Bushfire Response Procedure
TEL-08.103 Crisis Management Plan

Emergency response documents detail the actions required during an emergency to mitigate damage and
loss and expedite recovery. The documents also define the organisational structure to be in place during an
emergency and the duties to be carried out by members of the Emergency Response Team and Crisis
Management Teams where relevant.

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9 Incident / Non-Compliance Management

Management of an environmental incident or non-conformance that has caused or threatens to cause

material or significant harm to the environment will be conducted in accordance with the following. The key
incident reporting document for Sandy Ridge is SR-10.101 Environmental Incident Classification & Reporting
Procedure.

Key Documents
Document No. Document Name
SR-10.101 Environmental Incident Classification & Reporting Procedure
SR-10.09.202 Compliance Assessment Plan
TEL-10.101 Incident Management Procedure
TEL-10.104 Incident Investigation Procedure
TEL-10.201 Non-conformance, Corrective & Preventive Actions Procedure
Regulator Incident Report Form (External) – Form dependant on incident type and
SR-10.101.01
which regulator the incident is being report to

9.1 Internal

Internal management of an environmental incident is conducted in accordance with the Environmental

Classification & Reporting Procedure [SR-10.101] and the Tellus Incident Investigation Procedure [TEL-
10.104].
Internal management of non-conformances is conducted in accordance with the Tellus Non-conformance,
Corrective & Preventive Actions Procedure [TEL-10.201].

9.2 EPBC 2015/7478

Incidents and non-compliances with the requirements of EPBC 2015/7478 must be reported in accordance
with Conditions 10 and 11:

10 The approval holder must notify the Department in writing of any: incident; non-compliance with
the conditions; or non-compliance with the commitments made in management plans. The
notification must be given as soon as practicable, and no later than two business days after
becoming aware of the incident or non-compliance. The notification must specify:
a) the condition which is or may be in breach; and
b) a short description of the incident and/or non-compliance.
11 The approval holder must provide to the Department the details of any incident or non-compliance
with the conditions or commitments made in plans as soon as practicable and no later than 10
business days after becoming aware of the incident or non-compliance, specifying:
a) any corrective action or investigation which the approval holder has already taken or
intends to take in the immediate future;
b) the potential impacts of the incident or non-compliance; and
c) the method and timing of any remedial action that will be undertaken by the approval
holder.

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9.3 MS 1078

Incidents, potential non-compliances and non-compliances with the requirements of MS 1078 must be
reported to DWER in accordance with the requirements of the approved Compliance Assessment Plan.

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10 Training

Key Documents
Document No. Document Name
TEL-07.301 Competency & Awareness Procedure

Tellus is responsible for ensuring staff and contractors are appropriately trained, competent and have an
appropriate level of experience and understanding to undertake their work at The Facility in a manner that
minimises impacts on the environment and community. The site induction provides employees and
contractors with general environmental awareness training on the key environmental issues at the Facility.
A register of training records and competencies is maintained in the Facility’s Training Register in INX
InTuition.
Inductions will be reviewed in accordance with the Control of Documented Information procedure (see
Section 11.1).

10.1 Visitors Induction

Visitors to the Facility will undergo a visitor’s induction, which will outline the overarching environmental,
health and safety requirements. The nominated Tellus contact for the visitor will be responsible for the
actions and conduct of their visitors and will reinforce the Facility’s environmental requirements.
Visitors will be accompanied at all times by the nominated Tellus contact unless specific direction is
provided, and the visitor will be restricted from performing certain work duties on-site.
Inductions are administered via INX +LMS and INX +Process.

10.2 Site Induction

Prior to commencing any work duties on site, personnel will undergo a site-specific online induction. The
site-specific induction includes a detailed summary of the Facility’s operations as well as associated health,
safety, environment and community requirements. The induction also provides a comprehensive
understanding of the Facility’s key environmental impacts and aspects with a focus on the relevant
legislation and legal responsibilities applicable to the Facility.
Individuals are required to complete the online induction HSE before they attend site. Inductions are
administered via INX +LMS and INX +Process.

10.3 Task specific training

Occasions may arise where employees or contractors are required to undertake training in specific
environmental management duties (i.e. use of air quality monitoring equipment or use of real-time response
protocols). A training needs analysis will be used when these instances occur.

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11 Documented Information

11.1 Document control

Key Documents
Document No. Document Name
TEL-04.101 Control of Documented Information Procedure
TEL-04.102 Management Standards Document Control

All Facility documentation will follow the requirements of the above referenced documents available in
Company-wide Management Standard 04 - Documented Information, including:
• Identification of document need.
• Assigning author, unique identifier and header/footer requirements.
• Document approval.
• Document review.
Documents must first be independently reviewed and approved from a technical perspective. They must
then be reviewed by a Document Controller before being published to the Management Standards.
Environmental documents for the Facility will be available in the following section of the Sandy Ridge
SharePoint site:
Management Standard 08 – Process Control & Delivery / 08.500 Environment & Approvals

11.2 Records management

A copy of any document that includes environmental data or records will be kept and maintained by the
Facility to demonstrate compliance with relevant legislation, leases, licences, approvals, and any other
document that governs internal or external operations at the Facility. The Environment Manager (WA) is
responsible for the management of any necessary environmental records.
Environmental related documented information (i.e. records) must be maintained in at least one of the
following online software platforms:

InControl Main Module - incident, injury, audit & corrective actions, observations
InTuition & INX + LMS Training / Competence – needs analysis, skills monitoring, online courses
InViron Environmental Monitoring – exceedance alerts, real-time visibility
InForm Compliance - Obligations, stakeholder and issues management
InX BI Reporting and graphing
SharePoint Tellus’ principal company-wide cloud-based document management system.

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