Frequently Asked Questions


What are mineral sands by-products?

Iluka processes mineral sands material mined from its operations in Victoria and South Australia at a mineral separation plant in Hamilton. Mineral sands are “heavy minerals” which need to be separated to recover the valuable minerals of zircon, rutile and ilmenite.

Water, magnets, screening equipment and electrostatic tools are used to separate the heavy mineral concentrate. The by-products of this mineral separation process are low-value sands (including quartz and silica), clay and gypsum.

Further information on the mineral sands process can be found here

How are by-products disposed on site?

The material is transported by a covered or enclosed truck from the mineral separation plant to the former Douglas mine site and placed in a designated disposal site at five metres below the surface level and covered in accordance with regulatory approvals.

As with all Iluka operational sites, the area is fenced and accessible only by authorised personnel in accordance with mining licence regulations.

What is the industry standard for by-products disposal?

It is common and accepted mineral sands industry practice that the by-products of a mineral separation plant are disposed of in a mine void and covered in accordance with regulatory requirements. This method is employed at Iluka’s operating sites globally and has been done so for an extended period.

Victoria’s Environmental Protection Authority (EPA) in its review of Iluka’s by-product disposal activities stated the practice “represents best practice within the mineral sands industry.”

Why does Iluka dispose of the by-products at the Douglas sites rather than returning it to the mine where they were sourced?

Disposal at the Douglas site presents the most appropriate environmental, technical and commercial method for the management of Hamilton mineral separation plant by-products.

A detailed comparative assessment of alternative disposal sites, including source mines, has been completed. The assessment concluded that the disposal at Douglas is both the most efficient and environmentally appropriate action; and mitigates the risks of transportation movements to return by-product to remote sites.

The EPA reviewed the assessment and concluded that the disposal site is the most appropriate disposal site.

What is the volume of by-products disposed on site?

On average, processing activities produce approximately 75,000 tonnes of by-product material per year, subject to production rates. 

For every 100 tonnes of concentrate processed, approximately 80 tonnes are recovered as saleable product with the remaining 20 tonnes being disposed.


Are the by-products radioactive?

All mineral sands contain Naturally Occurring Radioactive Material, commonly referred to as NORM.

NORM is a part of the everyday environment and occurs naturally in air, water and soil. It is also found in building materials (and therefore in offices and homes).

The Victorian State Government has set the allowable increase in the annual radiation dose as 1 millisievert for members of the public. As a comparison:

  • the average annual dose from some medical sources, such as x-rays, is 2 – 2.4 millisieverts;
  • the dose received during a single flight from Melbourne to Perth is 0.27 millisieverts; and
  • in order for a member of the public to receive a dose equal to the allowable increase in annual dose (1 millisievert) at the Douglas site, a person would need to stand on the rehabilitated disposal site for a continuous period in excess of 100,000 years.
  • Is there a risk to human health?

    In Victoria the management of radioactive materials, including NORM, is regulated by the Department of Health and Human Services (DHHS). 

    In relation to Iluka’s activities at Douglas, DHHS has stated in its assessment that “the radiation doses estimated to be attributable to the operation of pit 23 [Douglas] both during the proposed disposal period and following site rehabilitation are so low as to be of no public health or environmental concern.”

    Is there a risk to the natural environment?

    All of Iluka’s past and present work at Douglas has been approved and regulated by State Government departments and conducted in accordance with the conditions of relevant approvals.

    On 6 May 2016, the Environmental Protection A​uthority (EPA) issued a public statement regarding the total environmental impact Iluka’s operations at Douglas.

    The EPA stated “neither pollution or environmental hazard has occurred or is likely to occur in the future as a result of current and proposed pit 23 [Douglas] disposal activities.”

    Further information on the EPA assessment can be found here.

    Is there a risk the by-products will enter the water system that could be used for drinking, stock or in the growing of crops? 

    Independent expert studies confirm Iluka’s activities have not contaminated the groundwater or surface water due to the low solubility of materials placed in the void. These include​:

  • a groundwater impact assessment by Jacobs Group Australia;
  • a detailed report on the development, calibration and use of a hydrogeological model of the Douglas Mine site by CDM Smith Australia Pty Ltd;
  • a report by CDM Smith Australia Pty Ltd on the use of the hydrogeological model to investigate the possibility of past disposal of by-products at the Douglas Mine Site being the source of observed spikes in radium isotope activity concentration; and
  • an assessment of the potential radiological impacts of the proposed future disposal of by-products to pit 23 at the Douglas Mine Site by Southern Radiation Services Pty Ltd.
  • Do the by-products contain chemicals?

    While some common chemicals, such as sulphuric acid, are used in cleaning the surface of some products, the mineral sands and by-products are not chemically altered. This practice is approved and regulated by various Victorian Government agencies.


    Does Iluka have experience disposing of mineral sands by-products?

    Yes. Iluka conducted mining operations at Douglas between 2006 and 2012, and has been disposing of by-products at the site since November 2006. Iluka also began progressive rehabilitation of previously mined areas in 2006. At Iluka’s other operations, in Australia and the United States, it has similar and longer experience of managed by-product disposal.

    Iluka is proposing a continuation of a current activity that is well accepted from a regulatory perspective and considered best practice in the mineral sands industry.

    Does Iluka operate in accordance with government regulations?

    Yes. Iluka has fully complied with government regulations and acted in accordance with all necessary standards regarding the management of this material and the Douglas site in general.

  • The State Government (Earth Resources Regulation) currently regulates Iluka’s activities under the Mineral Resources (Sustainable Development) Act. On 19 May 2016, State Government released a comprehensive audit regarding Iluka’s regulatory compliance. The audit found that, with respect to tailings disposal since 2009, which includes MSP by product disposal to the Douglas site, Iluka has been “fully compliant in response to the established audit criteria”.
  • The Department of Health and Human Services (DHHS) regulates Iluka's Radiation Management License under the Radiation Act. DHHS has confirmed Iluka’s compliance with all requirements of its license at all times.

    What degree of government, stakeholder and community consultation has been undertaken?

    Iluka has undertaken extensive consultation with local and state government and other stakeholders.

    Consistent with Iluka’s ongoing transparent approach to this matter, the company has supplemented the statutory exhibition process by making all relevant information available to interested stakeholders, including a public information day and community conferences.

    Iluka’s application has been:

  • the subject of 11 reports by independent technical experts; several more by regulatory authorities;
  • available to the public since 8 July 2015; and
  • the subject of one community information session and two community conferences.
  • In support of the approval process, the company has also:

  • voluntarily submitted to scrutiny by the EPA (found “no environmental hazard” present or future);
  • provided comprehensive responses to 24 community submissions received;
  • conducted 13 site tours;
  • provided more than 15 briefings to State Government agencies;
  • cooperated in comprehensive State Government audits (found “fully compliant”); 
  • provided regular updates at quarterly meetings of the Douglas Environmental Review Committee; and
  • met with owners and occupiers of neighbouring properties.
  • Where is the by-product material stored in relation to towns and houses?

    The nearest residence that is not owned by Iluka is approximately 2.6 kilometres from the disposal site.

    Like all Iluka operational sites, and in accordance with licence conditions for current or former mining sites, the area is fenced to ensure no unauthorised access. This relates in large measure  to avoid the most significant hazard: potential  interaction with heavy mobile equipment.

    Is the disposal site of heritage or cultural significance?

    No. Extensive surveys have not identified any sites of Aboriginal or European cultural heritage value within a 1,500 metre radius of the disposal site. Furthermore, no items of cultural heritage value were discovered during excavation (mining) activities at the site.


    What approvals do Iluka require?

    Iluka proposed a continuation of its current activities that comply with all regulatory requirements.

    The Victorian Department of Environment, Land Water and Planning determined that a planning permit is required to continue this activity with the Horsham Rural City Council delegated as the regulatory authority.

    At the request of the EPA, an application was submitted for Works Approval under the Environment Protection Act. Following extensive assessment, the EPA determined that a Works Approval was not required because:

  • the material to be disposed of is radioactive and therefore is management is regulated under the Radiation Act; and
  • “neither pollution or environmental hazard has occurred or is likely to occur in the future as a result of current and proposed pit 23 [Douglas] disposal activities”.
  • On 27 June 2016, the Horsham Rural City Council rejected Iluka’s planning application, despite the fact that State Government regulatory authorities and independent technical experts confirm that Iluka’s activities are undertaken in a responsible manner, with minimal environmental impact and in accordance with all regulatory requirements.

    The company subsequently referred the matter to the Victorian Civil and Administrative Tribunal (VCAT), which reassessed Iluka’s proposal at a hearing ​that commenced on 7 November 2016. On 27 January 2017, VCAT approved the continuation of Iluka’s disposal of mineral sands by-products from the Hamilton mineral separation plant to the former Douglas mine site.

    VCAT stated:

    • We are satisfied it will have no adverse impacts on its neighbours or the environment and will contribute to significant employment opportunities in regional Victoria.
    • “A great deal of scientific and technical investigation supports this permit application and the Tribunal heard evidence from various experts, which was subject to extensive cross examination by the council and all other parties. We are satisfied that there is no environmental reason why a permit should not be granted. We examine the various environmental issues and analyse the evidence and submissions made, later in this decision and set out our reasons in detail for reaching this conclusion. We are satisfied that the concerns and apprehensions expressed to us by community members have been appropriately addressed and claims of harmful environmental and community health risks have not been substantiated.”
    • “we are satisfied that there is a commitment on the part of Department of Economic Development, Jobs, Transport and Resources, DHHS and the EPA to support the council in dealing with any technical issues that arise under the permit where the council lacks the necessary expertise to assess or respond to such issues in-house or from its own resources.”

    Iluka accepts and welcomes the decision which provides regulatory certainty for the continued operation of the Hamilton plant which:

    • -  provides Iluka’s processing hub in the Murray Basin;
    • -  serves the company’s rail and port infrastructure at Hopetoun and Portland;
    • -  employs 90 people directly and contributes to an estimated additional 175 local contractors across 55 local companies in the region; and
    • -  contributes to the regional and state economies.

    Iluka notes that VCAT’s findings on health, safety and environmental matters are consistent with the company’s longstanding position and operational track record; as well as separate determinations made by State Government regulatory agencies and independent technical experts.

    • The Environmental Protection Authority stated “neither pollution or environmental hazard has occurred or is likely to occur in the future as a result of current and proposed pit 23 [Douglas] disposal activities."
    • The Department of Health and Human Services stated “the radiation doses estimated to be attributable to the operation of pit 23 [Douglas] both during the proposed disposal period and following site rehabilitation are so low as to be of no public health or environmental concern.”

    The company looks forward to ongoing engagement with all stakeholders, including the Horsham Rural City Council and State Government, to give effect to VCAT’s decision.