Care and Maintenance Mining Operations Plan

Transcription

1 Sedgman Limited [ASX: SDM] ABN Head Office Level 2, 2 Gardner Close Milton QLD 4064 AUSTRALIA Ph: Fax: Postal Address PO Box 1801 Milton QLD 4064 AUSTRALIA mail@sedgman.com Web: Cullen Valley Mine Care and Maintenance Mining Operations Plan Castlereagh Coal LC/lc Revision: 1.0

2 Revision Status Revision Number Author Description Date Approved By Draft LC Draft for review 12 Nov 2015 J. Duffy Version 1.0 LC Final for submission 17 Dec 2015 A. O Brien Distribution Company Name Contact Name Revision Date Castlereagh Coal Brett Moore December 2015 Invincible Colliery John Duffy December 2015 Department of Trade & Investment Chris Hammersley December 2015 Copyright Notice Sedgman 2016 This Document is copyright. Other than for the purposes and subject to the conditions prescribed under the Copyright Act 1968 (Commonwealth), no part of it may in any form or by any means (electronic, mechanical, micro-copying, photocopying, recording or otherwise) be reproduced, stored in a retrieval system or transmitted without prior written permission. Page ii

3 Table of Contents MOP Title Block 1 Summary of Tables, Figures and Plans 2 1 Introduction History of Operations Current Consents, Leases and Licences Land Ownership and Land Use Stakeholder Consultation 4 2 Proposed Mining Activities Project Description Asset Register Activities over the MOP Term Exploration Construction Mining operations Rock/overburden emplacement Processing residues and tailings Waste management Decommissioning and demolition activities Temporary stabilisation Water management Drainage and water pollution controls Groundwater management Hazardous materials Equipment maintenance and inspections Progressive rehabilitation and completion Material production schedule during MOP term 11 3 Environmental Issues Management Environmental Risk Assessment Environmental Risk Management Specific Risks relating to Rehabilitation Geology and geochemistry Material prone to spontaneous combustion Subsurface heating Material prone to generating acid mine drainage Mine subsidence Erosion and sediment control Soil type and slope management Flora and fauna Other risks 19 4 Post Mining Land Use Regulatory Requirements Post Mining Land Use Goal Rehabilitation Objectives 25 5 Rehabilitation Planning and Management Domain Selection Domain Rehabilitation Objectives Rehabilitation Phases 27 6 Performance Indicators, and Completion/Relinquishment Criteria 28 7 Rehabilitation Implementation Status at MOP Commencement Proposed Rehabilitation Activities during the MOP Term 29 Page iii

4 7.2.1 Maintenance of existing rehabilitation areas Subsurface heating monitoring and rectification works Repair and reconstruction of erosion control devices Replanting/reseeding in existing rehabilitation areas Summary of Rehabilitation Areas during the MOP Term Relinquishment Phase achieved during MOP period 33 8 Rehabilitation Monitoring and Research Rehabilitation Monitoring Research and Rehabilitation Trials and Use of Analogous Sites 34 9 Intervention and Adaptive Management Threats to Rehabilitation Trigger Action Response Plan Reporting 37 Appendices Appendix A MOP Plans Appendix B Care & Maintenance Risk Assessment Appendix C Rehabilitation Tables Appendix D Plan of Works Variation to the Mining Operations Plan, 30 January 2013 Appendix E Subsurface Heating Program of Works 26 November 2015 List of Tables Table 1-1: Status of current consent, leases and licences... 4 Table 2-1: Asset register... 5 Table 3-1: Risk assessment Table 4-1: Regulatory requirements for rehabilitation and post-mining land use Table 5-1: Primary and secondary domains Table 5.2: Domain rehabilitation objectives Table 5-3: Summary of rehabilitation phases Table 7-1: Rehabilitation Seed Mix Table 7-2: Summary of Rehabilitation Areas during the MOP Term Table 9-1: Threats to rehabilitation Table 9-2: Trigger Action Response Plan Page iv

5 MOP Title Block Cullen Valley Mine - Mining Operations Plan Name of Mine: Cullen Valley Mine MOP Commencement Date: 31 December 2015 MOP Completion Date: 31 December 2017 Mining Authorisations: Name of Authorisation/Authorisation Holder(s): Name of Mine Operator: Name and Contact Details of Mining Engineering Manager Name and Contact Details of Environmental Representative: Name of Representative(s) of the Authorisation Holder(s) Title of Representative(s) of the Authorisation Holder(s) Signature of Representative(s) of the Authorisation Holder(s) ML1455, ML1488, ML1557, ML1556 Shoalhaven Coal Pty Ltd Sedgman Limited John Duffy Invincible Colliery, Castlereagh Highway Cullen Bullen, NSW 2790 (02) Andrew O Brien Sedgman, Level 2, 2 Gardner Close Milton Qld 4064 (07) Brett Moore Manildra Group, 6 Frank Street Gladesville NSW 2111 (02) Group Financial Accountant Date: 17 December 2015 Version: Page 1

6 Summary of Tables, Figures and Plans Section of MOP Table Reference Plan Reference Source Section 1: Introduction Section 2: Proposed Mining Activities Section 3: Environmental Issues Management Section 4: Post Mining Land Use Section 5: Rehabilitation Planning and Management Section 5: Rehabilitation Planning and Management Section 5: Rehabilitation Planning and Management Section 7: Rehabilitation Implementation Section 7: Rehabilitation Implementation Section 9: Intervention and Adaptive Management Section 9: Intervention and Adaptive Management Table 1-1: Status of current consents, leases and licences NA Statutory documents Table 2-1: Asset register NA Existing data Table 3-1: Risk assessment Table 4-1: Regulatory requirements for rehabilitation and postmining land use Table 5-1: Primary and secondary domains Table 5-2: Domain rehabilitation objectives Table 5-3: Summary of rehabilitation phases Table 7-1: Rehabilitation seed mix Table 7-2: Summary of rehabilitation areas during the MOP term Table 9-1: Threats to rehabilitation Table 9-2: Trigger Action Response Plan NA NA NA NA NA NA NA NA Project Risk Assessment Statutory documents and management plans Existing data Existing data Existing data Flora and Fauna Management Plan Annual Biodiversity Monitoring data Flora and Fauna Management Plan Flora and Fauna Management Plan Appendix A: MOP Plans NA Plan 1A: Project Location Spatial Data Appendix A: MOP Plans NA Plan 1B: Pre-MOP Environment - Natural Environment Appendix A: MOP Plans NA Plan 1C: Pre-MOP Environment - Built Environment Appendix A: MOP Plans NA Plan 1D: Pre-MOP Environment Underground Workings Appendix A: MOP Plans NA Plan 2: Mine Domains at Commencement of MOP Appendix A: MOP Plans NA Plan 3: Final Rehabilitation and Post-Mining Land Use Appendix A: MOP Plans NA Plans 4-5: Final Rehabilitation Landform Cross Sections Ecological Impact Assessment data Existing data Existing data Existing data Existing data Existing data Page 2

7 1 Introduction The available coal within the approved mining area at the Cullen Valley Mine has been exhausted and mining operations have been suspended. This Care and Maintenance Mining Operations Plan (C&M MOP) describes the arrangements and proposed management of the Cullen Valley Mine during the C&M MOP period. Approval has previously been sought from the Department of Trade and Investment, Regional Infrastructure and Services Division of Resources and Energy (DRE) for the suspension of mining operations at the Cullen Valley Mine on the 16 January 2013 under Section 70(1)(a) of the Mining Act 1992 NSW (Mining Act). Approval to suspend mining operations was granted by DRE on 14 February The Cullen Valley Mine will be managed under a care and maintenance arrangement until the recommencement of mining activities or until a decision has been made to close the mine. This C&M MOP covers the period from 31 December 2015 to 31 December 2017 and has been prepared in accordance with the ESG3: Mining Operations Plan (MOP) Guidelines prepared by the NSW Department of Trade and Investment (T&I), dated September History of Operations Underground mining commenced at the Tyldesley Colliery around 1904 and continued up until the 1960 s when the workings were abandoned. Open cut operations were conducted on the site between 1948 and Modern open cut operations began after 19 August 1999 when the Lithgow Coal Company was granted Mining Lease (ML) 1455 by the Minister for Mineral Resources. Mining commenced on site in May 2000 following a four month construction phase. Following the identification of additional open cut coal reserves, a further EIS and Development Application was lodged for an extension of the mine in April The lease extension area lies along the western side of Tyldesley Hill adjacent to the main railway line. Approval of the Development Application was granted by the Department of Planning and Infrastructure (DP&I) 19 August A MOP was prepared and approved to cover the mining operations within the new lease extension area for a seven year period. Cullen Valley Mine has historically supplied coal under contract to Mount Piper Power Station. However, with the failure of the mine to renew a supply contract in 2007, it was proposed to place the operation on a care and maintenance program until such time as sufficient contracts were awarded that would make the operation of the mine viable once again. Coalpac Pty Ltd purchased the Lithgow Coal Company Pty Ltd, which owned the Cullen Valley Mine, in January 2008 and the previous plans to place the mine on Care and Maintenance were discarded. Recommencement of the open cut mining operations occurred in February Mining of the available approved area at Cullen Valley Mine was completed in early December Any remaining stockpiled ROM coal was transported to the Invincible Colliery during February 2013 and processed through the Invincible Coal Crushing Plant. The Mine was then placed under care and maintenance. Shoalhaven Coal purchased the mine from Coalpac administrators in May 2015 and will continue to operate the mine under a care and maintenance arrangement until such time as approvals can be obtained for future mining operations. 1.2 Current Consents, Leases and Licences The Cullen Valley Mine is classified as a Level 1 Mine being a State significant development. The locality of the project and context within the State is shown on Plan 1A (Appendix A). Page 3

8 A list of the current consents, leases and licences that will be maintained during care and maintenance is shown in Table 1-1. Table 1-1: Status of current consent, leases and licences Document Date Granted Expiry Date Development Consent DA_200_5_ August August 2025 EPL No December (anniversary date) Renewed annually Authorisation January April 2016 Authorisation August April 2016 Exploration Licence October October 2014 (renewal application submitted) Exploration Licence April April 2014 (renewal application submitted) Mining Lease August August 2020 Mining Lease June June 2022 Mining Lease September September 2025 Mining Lease September September 2025 Water Access Licence June Water Supply Work Approval 80WA January July Land Ownership and Land Use Plan 1C contained in Appendix A shows the land ownership and land use surrounding the Cullen Valley Mine. Land contained within the mining leases is either freehold land owned by Shoalhaven Coal Pty Ltd or Crown Land contained in the Ben Bullen State Forest. The Ben Bullen State Forest is managed by the NSW Forestry Corporation. 1.4 Stakeholder Consultation This C&M MOP has been developed in consultation with DRE. Issues raised by DRE were addressed during revision of this document. Page 4

9 2 Proposed Mining Activities 2.1 Project Description There are no planned mining activities to be undertaken at Cullen Valley Mine during the C&M MOP term. Activities relating to existing licences and approvals such as water management and sediment control, environmental monitoring, rehabilitation maintenance and monitoring works and general housekeeping will be undertaken and are described in more detail in Section 2.3. The maintenance of existing site infrastructure and the storage of some heavy earthmoving equipment is proposed during the C&M MOP term. Proposed activities that will be undertaken during the C&M MOP term will include: Statutory inspections including mining, electrical and mechanical; Implementing the approved Subsurface Heating Area Plan of Works Variation to the Mining Operations Plan (PoW MOP Variation), dated 30 January 2013 and approved by DRE on 11 March 2013 (refer Appendix D) and the Subsurface Heating Program of Works (refer Appendix E); Maintaining the water management system including sediment and erosion control; Ongoing environmental monitoring and reporting including air quality, water and noise; Monitoring and maintenance of Compensatory Habitat Areas and rehabilitation areas; Sedgman Limited will continue to maintain regulatory compliance with current consents, leases and licences. Ongoing stakeholder consultation will be undertaken during the care and maintenance period as required. 2.2 Asset Register Domains within the C&M MOP area including major assets within each domain are listed in Table 2-1 below. Table 2-1: Asset register Domain Area Major Assets Infrastructure Areas 20.6 Offices, workshops, coal mining facilities, ROM stockpiles, mine access roads Unshaped emplacement areas 32.5 Waste rock emplacements Mine voids and pits 1.4 Mine extraction areas Water Management Structures 2.2 Environmental dams, sump dams, sediment ponds Shaped and topsoiled emplacement areas 4.4 Waste rock and topsoil placement Rehabilitation Areas 61.7 Areas seeded between 2009 and 2012 (includes areas of erosion to be repaired) Established Rehabilitation Areas 71.1 Areas previously seeded prior to 2009 (includes areas of erosion and subsurface heating to be monitored and repaired) 2.3 Activities over the MOP Term Exploration There are no planned exploration activities proposed to be undertaken during the C&M MOP term. Page 5

10 2.3.2 Construction There are no planned construction activities proposed to be undertaken during the C&M MOP term. Some earthworks will be required to implement the PoW MOP Variation and the Subsurface Heating Program of Works for monitoring and rectification works in the subsurface heating area. It should be noted that these works will be undertaken in areas previously disturbed by mining activities Mining operations There are no planned mining activities proposed to be undertaken during the C&M MOP term. Most mobile plant and equipment has been removed from the site. Any equipment remaining on site will be periodically run, where possible, with pre-start inspections conducted at each instance. Any new equipment introduced to site, will have a MDG15 inspection performed on it prior to the commencement of any works. The earthworks proposed to be undertaken for the PoW MOP Variation and the Subsurface Heating Program of Works in the sub-surface heating area will require some earthmoving equipment which may include an excavator, dozer, trucks and water cart. In addition to this, excavators and dozers will be used periodically for short periods for specific tasks such as erosion control and rehabilitation maintenance Rock/overburden emplacement There are no plans to move overburden or waste rock for mining purposes during the C&M MOP term Processing residues and tailings There are no planned coal processing activities proposed to be undertaken during the C&M MOP term and therefore no residues and tailings will be produced Waste management Sewerage disposal All sewage from the crib huts and office areas is directed to septic systems which are pumped out by a licensed waste collection and disposal contractor on an as-needs basis. Sewage waste will continue to be managed in this manner during the C&M MOP term. Oil / grease containment and disposal Any maintenance works required on machinery and equipment during the C&M MOP term will be undertaken within existing bunded areas at the Cullen Valley Mine. Waste oils and grease from these bunded areas including the workshop, is pumped or gravity flows to an oil-water separator and is cleaned on an as needs basis. Under emergency circumstances, i.e. breakdowns in the pit area, oils and grease will be pumped from the equipment to a tank on the service truck using an evacuation pump and will subsequently be transferred to the bulk waste oil storage tank at the maintenance workshop. All parts, packaging etc. will also be collected and transferred to the maintenance workshop for disposal or for future recycling. Page 6

11 Waste oils and grease stored at the maintenance workshop are collected by a licensed waste recycling contractor on an as needs basis. It should be noted that no mining activities will be undertaken during the C&M MOP term and as such only minimal oil and greases will be required to be stored on site. Rubbish disposal All paper and general wastes originating from the Cullen Valley Mine site offices will be disposed of in garbage bins located adjacent to the administration buildings. The bins are regularly collected and the contents placed in large waste skip bins positioned adjacent to the heavy vehicle maintenance building to await removal by a licensed industrial waste collector. Industrial waste collection is generally undertaken fortnightly Decommissioning and demolition activities There are no planned decommissioning and demolition activities to be undertaken during the C&M MOP term. Existing machinery and equipment will be inspected and maintained as required Temporary stabilisation Existing water management structures such as dams, sediment ponds and contour drains will be maintained in accordance with the approved Environmental Management Plan (Water Management Plan). Unshaped emplacement areas and the mine infrastructure area will be maintained to facilitate future mining. Where ground stabilisation is required in these areas this will be undertaken in accordance with the Environmental Management Plan (Erosion and Sediment Control Plan) Water management The water management system at Cullen Valley Mine has been designed (as far as possible) as a closed loop system. All water which enters the site via rainfall or through the water table is diverted to a series of settlement dams within the site. The existing water management system will remain in place during the C&M MOP term and will be managed in accordance with the approved Environmental Management Plan (Water Management Plan). There are four dams currently on site, two of which are licenced discharge points: Dam 1 (LD001) and Dam 4 (LD004). Two other settlement dams (Dam 2 and Dam 3) will be utilised as storage dams during heavy rainfall events from predominately hardstand areas and excess water from Dam 1 and Dam 4. The dams are generally kept at low levels, approximately 1/3 of capacity, unless periods of extended dry conditions are forecast or experienced. The primary source of water for Cullen Valley Mine is from the abandoned and flooded Tyldesley Mine underground workings via the Tilley s Bore (GW01). The water is pumped from the workings to two 500,000L tanks. Distribution around the site is by gravity fed water mains. Secondary sources of water come from the mine s pollution control dams. Any excess water captured in the open void (Pit 106) will be pumped to Dam 4. Water from Dam 4 can be transferred to Dam 1 to be used for dust suppression and/or pumped into the underground workings. Controlled discharges will only occur if EPL water quality parameters are met and if the water demands of the operation are not put at risk. The water quality discharge criteria specified in EPL include <50mg/L suspended solid, <10mg/L of oil and grease and ph with a range of The water management system and associated pumps and pipe work will be inspected during regular statutory inspections and any maintenance work will be carried out as required. Page 7

12 Periodic maintenance and repair works to the water management system will be undertaken during the care and maintenance period, these will likely include: The de-silting and maintenance of sediment dams and drainage lines; The installation of silt fences and hay bales to minimise soil erosion during rainfall events; The construction of additional drainage lines as required; and The continuation of the water quality monitoring program. The above measures will ensure environmental impacts are minimised and regulatory compliance is achieved in regards to water management during the care and maintenance period. In the event that heavy vehicles are required for planned activities or maintenance works and the haul road is used, a water cart will be made available to ensure air quality impacts are minimised. The water cart will draw water from designated water fill points as per the water management system. The potable water supply will continue to be sourced from an existing connection to the Fish River Water Supply pipeline Drainage and water pollution controls The surface water management system has been designed to separate clean and dirty water and wherever possible clean water is diverted around the site. Suitable pollution control facilities are constructed to contain and then treat the dirty water to a standard acceptable for discharge or reuse on site. Temporary structures such as hay bales and sediment fences are also used to enhance the performance of the permanent structures. All existing pollution control structures and storage dams will be maintained on site during the care and maintenance period to capture and treat surface water on site in accordance with the approved Environmental Management Plan (Water Management Plan). Rehabilitated areas have been constructed with drainage lines along the contour, this will enable runoff from these areas to be collected, and redirected to sediment control dams. During the C&M MOP term, maintenance works will be undertaken to ensure the rehabilitation drainage lines are maintaining their structural integrity and effectiveness. Regular inspections of the Compensatory Habitat Areas will be conducted by the Mining Engineering Manager (MEM) or his delegate Groundwater management It is not anticipated that any disturbance to groundwater aquifers will occur during the C&M MOP term. Groundwater is monitored and results are reported annually by a qualified consultant. Any trends that indicate that care and maintenance activities are having a potentially adverse impact to groundwater aquifers would be identified by this monitoring program. It should be noted that no adverse impacts have been identified to groundwater aquifers at the Cullen Valley Mine to date Hazardous materials Hazardous material storage tanks containing oils, grease and degreasers have been emptied, isolated and secured. Any additional storage tanks have been removed from the site. Storage tanks remaining onsite will be kept emptied during the care and maintenance period. Any bunds containing storage tanks or drums have been cleaned and will be checked during regular statutory inspections. One of the above ground self bunded diesel tanks (Transtank) will be operational during the care and maintenance period with up to 35,000L of diesel stored in the facility. Two EPA registered radionuclide fixed radiation gauges (No. RR20215 and No. RR21832) have been decommissioned and are stored onsite. Inspections are carried out on the devices and the Page 8

13 storage container by a qualified consultant as required by the licence. A register of hazardous materials is maintained on site. In addition, any contractor is required to maintain a register of hazardous materials utilised by its operations and service personnel whilst activities are being undertaken at Cullen Valley Mine Equipment maintenance and inspections All mining related equipment will be maintained in reasonable condition such that it is safe at all times. As such, periodic electrical and mechanical inspections will be undertaken during the care and maintenance period in accordance with relevant legislation and approved Management Plans. A risk assessment was conducted on the 27 and 28 May 2015 for the preparation of the C&M MOP. The risk assessment considered associated hazards relating to safety, environmental and security matters while the site is being maintained under the care and maintenance arrangement. The risk assessment is outlined in Section 3. Electrical Routine electrical inspections and the coordination of any electrical related maintenance activities will be conducted by a qualified Electrical Engineer. The electrical inspections will include the following: Monthly internal and external inspections of all electrical apparatus, including residual current and earth leakage protection devices, operation of electrical safety devices such as emergency stops, pull wires and probes etc.; Six monthly internal inspections of all electrical apparatus, including detailed internal inspections, earth connection integrity and insulation resistance testing; Annual testing and tagging of all office equipment; and Power line easement vegetation clearing prior to bushfire season, as required. Specifically, electrical inspections will be undertaken on the following equipment at the Cullen Valley Mine during the care and maintenance period, these will include the: 11kV power line and circuit breaker; All Water Management System infrastructure including the Dam 1 pump, Dam 4 pumps, inpit pump and Tilley s Bore pump; and Training Cottage electrical circuits. All works and inspections conducted will comply with relevant Australian Standards relating to Electrical Engineering including: AS Wiring Rules; AS Electrical Equipment for Coal Mines Maintenance and Overhaul; AS Electrical Installations; and AS Electrical Protection Devices for Mines and Quarries. Mechanical Routine inspections and the coordination of ongoing maintenance activities will be conducted by a qualified Mechanical Engineer. Mechanical inspections will be undertaken at the Cullen Valley Mine during the care and maintenance period on the following equipment: The heavy equipment, and heavy and light vehicles remaining on site; The above ground self-bunded diesel storage tank (Transtank) and pumps; The Water Management System and associated pumps, pipes, tanks and other related infrastructure; Page 9

14 The septic systems; The buildings, structures, bins, steelwork, walkways, stairs etc. to ensure there has been no damage due to vandalism, storm events, erosion, corrosion or impact etc.; The fire extinguishers and fire suppression systems as per AS1851; and The pressure vessels and mobile plant including light vehicles. All tooling, lifting machines, pressure vessels and oxy / acetylene equipment on site will be removed or locked up on site. If any equipment needs to be used, the Mechanical Engineer will inspect this equipment prior to use. Equipment will be inspected on a regular basis, and additional inspections will be undertaken prior to any work commencing as required. Mining area The Work Health and Safety (Mines) Act 2013 and Work Health and Safety (Mines) Regulation 2014 apply to all mining workplaces in NSW. This new legislation commenced on 1 February 2015 and replaced the Coal Mine Health and Safety Act 2002, Coal Mine Health and Safety Regulation 2006 (CHMS Regulation), Mine Health and Safety Act 2004 and Mine Health and Safety Regulation However, the CHMS Regulation will continue to apply to the site during the transitional period for this new legislation. As such, inspections of the mining area during the care and maintenance period will be undertaken in accordance with the CMHS Regulation which states: Inspection at least once each shift of all places where people work; Inspection at least once every 24 hours of all roadways where people regularly travel; and Inspection at least once every 7 days of all safely accessible places. Due to care and maintenance activities only being undertaken, the OCE District will be inspected at least once every 7 days in accordance with the CMHS Regulation. This inspection will be undertaken by an appointed OCE or the MEM. The area checked as part of this inspection will include everything within the perimeter of the OCE s District such as: Waste dumps, high walls, low walls and stock piles; The water management system including dams, pipes and the Pit 106 storage area; Erosion and sediment controls including drainage lines, silt traps, sumps and diversion bunds; Roads and access tracks; General security including locks and chains on entrance gate; Buildings, maintenance workshop, crib hut and other mining related infrastructure; Rehabilitated areas; and The sub-surface heating area. Inspections will be undertaken on a more frequent basis during any scheduled works or maintenance activities as required. The outcomes from the statutory inspections will be documented in the OCE Designated District Inspection Report Progressive rehabilitation and completion Rehabilitation works to be undertaken during the C&M MOP term are described in Section 7. Proposed rehabilitation works will include stabilisation (erosion control) and replanting/reseeding where required in existing rehabilitation areas. No new rehabilitation areas will be established during the C&M MOP term. Page 10

15 Material production schedule during MOP term There are no planned mining activities and no planned material stockpiling to be undertaken during the care and maintenance period. As such there is no material production schedule required for the C&M MOP term. Page 11

16 3 Environmental Issues Management 3.1 Environmental Risk Assessment A formal risk assessment for the Cullen Valley Mine care and maintenance period was undertaken by Sedgman on 27 and 28 May A site tour was undertaken to ensure all areas of the Cullen Valley Mine and adjacent lands held within mining leases were considered in the scope of the risk assessment. The risk assessment was conducted in accordance with the Sedgman HSEQ Risk Management Procedure (HSE-PC ). Risks identified during the assessment and the associated risk ratings are detailed in Table 3-1. Management controls are required for all items which have been identified as either high or medium risk. It is expected that current controls listed in Table 3.1 are sufficient to manage risks. 3.2 Environmental Risk Management Cullen Valley Mine operates in accordance with Development Consent DA_200_5_2003 granted by the Minister of the Department of Planning and Infrastructure on 19 August 2004 and EPL issued by the EPA which is renewed on 10 December each year. To ensure the Cullen Valley Mine achieves regulatory compliance with DA_200_5_2003, EPL and other relevant legislation, a number of management plans have been developed in consultation with regulators and other relevant stakeholders. Approved management plans currently in place at Cullen Valley Mine include the: Flora and Fauna Management Plan; Species Management Plan (Clandulla Geebung); Environmental Management Plan; Environmental Monitoring Program; Blast Management Plan; Fire Management Plan; PoW MOP Variation; Particulate Matter Pollution Reduction Program; and Pollution Incident Response Management Plan. The Cullen Valley Mine will continue to be managed in accordance with approved management plans as required. Any variations required to the above management plans or the C&M MOP will be undertaken in consultation with DRE and other relevant stakeholders. Page 12

17 Table 3-1: Risk assessment Risk Description Current Controls Consequence Likelihood Risk Rating Strata Failure Statutory non-compliance (electrical) Statutory non-compliance (mechanical) Unauthorised access to site Contractor Management Dust Water discharge offsite General waste/sewerage Fuel/Oil Spills Theft of equipment - fixed and mobile plant Annual geological survey completed by content expert Daily inspections or prior to entry from mining engineering manager Site in care and maintenance, limited persons onsite Visitors escorted by authorised persons Electrical Engineering Manager appointed (caretaker mode) Electrical statutory checks in current Care and Maintenance MOP Mechanical Engineering Manager appointed (caretaker mode) Mechanical statutory checks in current Care and Maintenance MOP Locked gate to restrict access on all public accesses Highwall bunding along highwalls Security signs Locked buildings and equipment Inducted, trained and authorised personnel OTJ risk assessment, SWMS in place MDG15 inspections on equipment Familiar with work area Supervision by authorised persons Watercarts available when truck movements onsite Environmental monitoring as per Environmental Approval Licence Restricted access to pit Licenced discharge points Environmental dams Environmental monitoring as per Environmental Approval Licence Inspection after rainfall events Pit pumps in place Regular inspections Natural discharge points through Marangaroo sandstone Environmental Management Plan in place Designated collection for waste - SITA Licenced sewerage collection from council on as needs basis - manual inspection Oil separators Contained onsite Self-bunded fuel tanks (1 x 75000L not in use) Spill kits Servicing done in pit - decanted into containers and then disposed of through seperator Light vehicles serviced offsite Fuel spills pipeline flows down to separator Approved disposal Current SHMS Locked gate to restrict access on all public accesses Security signs Locked buildings and equipment Major Unlikely High Minor Unlikely Low Minor Unlikely Low Low Unlikely Low Minor Unlikely Low Low Unlikely Low Minor Unlikely Low Low Unlikely Low Low Unlikely Low Low Unlikely Low Page 13

18 Risk Description Current Controls Consequence Likelihood Risk Rating Damage to equipment - fixed and mobile plant Unauthorised use of equipment - fixed and mobile plant Damage to infrastructure Noise Statutory non-compliance (Mining) Equipment in care and maintenance Restricted access to site Power can be isolated at CHPP Regular statutory inspections of equipment Minor Unlikely Low Current SHMS - contractor management, training and authorisations and inductions Minor Unlikely Low Visual inspections by Mechanical Engineering Manager Structural integrity audits in the past Traffic management plans and signage Environmental monitoring as per Environmental Approval Licence Restricted access to pit Quarterly noise monitoring by content experts Pumps run during daylight hours only Mining Engineering Manager in caretaker mode (not appointed at present) Statutory checks in current Care and Maintenance MOP EPL in place Current SHMS Minor Unlikely Low Low Unlikely Low Minor Unlikely Low No appointment of statutory roles Energised equipment Mine subsidence Bushfire & fire Vehicle interaction onsite Spontaneous combustion and monitoring Resource for role being sourced Appointment pending operator arrangement Previous MEM still engaged onsite Current SHMS (isolation) Restricted access to site Contractor management Mine subsidence plan Regular inspections Fenced off and signposted Bushfire Management Plan Fire extinguishers onsite Regional bushfire brigade Fire trail access Regular inspections Traffic Management Plan in place Restricted access to site (in care and maintenance) Authorised to drive onsite Pumping water underground Plan of works to manage spon com Restricted access Inspections Remedial work of known spon com areas Gas monitoring when active Moderate Unlikely Medium Major Unlikely High Minor Unlikely Low Major Unlikely High Major Unlikely High Low Unlikely Low Page 14

19 Risk Description Current Controls Consequence Likelihood Risk Rating Statutory non-compliance (environmental) Personal injury from working alone Personal injury from Working at heights Lack of rescue and treatment of person who suffers injury Personal injury from Confined spaces Personal injury from Working over water Personal injury from Working under loads Weed control Checks in current Care and Maintenance MOP EPL in place Current SHMS Environmental management plan Monitoring programs Annual Environmental audits Restricted access to inducted and persons familiar with site Phone coverage available in majority of areas of pit Supervision Stay in main areas of the site Minor Unlikely Low Minor Unlikely Low No WAH tasks onsite identified, if so, complete JSA and be competent as per current SHMS Low Rare Low First aid kits available onsite - vehicle, first aid rooms and kitchen Mines rescue not currently needed onsite as in care and maintenance Local emergency services available Mines rescue station at Lithgow if required No confined spaces tasks onsite identified, if so, complete JSA and be competent as per current SHMS Current confined spaces fenced and locked off No Working over water tasks onsite identified, if so, complete JSA and be competent as per current SHMS No Working under loads tasks onsite identified, if so, complete JSA and be competent as per current SHMS Weed Management Plan in place Wheel wash Low Unlikely Low Low Rare Low Low Rare Low Low Rare Low Low Unlikely Low Aboriginal Heritage Disturbance Aboriginal Heritage Management Plan Low Unlikely Low Visual pollution Methane venting Neighbours Exposure to Hazardous Substances Planned rehabilitation of old workings as part of Mine Closure Plan Mine in care and maintenance Not a risk at this site Community Consultative Committee Meetings Noise agreements with neighbours Complaints hotline and register Site in Care and Maintenance Chemwatch to manage SDS's Cabinets for storage Current SHMS PPE available Low Unlikely Low Minor Possible Medium Low Unlikely Low Unplanned movement Traffic Management Plan Trained, competent and appointed personnel Restricted access to site Site in care and maintenance JSA prior to lifting onsite Low Unlikely Low Page 15

20 Risk Description Current Controls Consequence Likelihood Risk Rating Site access from public roads Inrush of water Tyre and rim failure Overhead power lines Underground services Lack of water quality in underground workings Vermin and pest control Radiation source Limited access to site Site in care and maintenance Not a risk at this site at present Mine in care and maintenance Not a risk at this site at present Mine in care and maintenance Traffic Management Plan Signage Site in care and maintenance Dig permits Up to drawings of services Current SHMS Site in care and maintenance Monitoring and inspection of water quality Monitor any discharges out of main dam Baiting programs in place as required Report any signs of vermin Regular inspections of work area Designated, locked, signposted storage area Radiation Management Plan Low Unlikely Low Low Rare Low Low Rare Low Major Unlikely High Low Unlikely Low Low Unlikely Low Low Unlikely Low Low Unlikely Low Page 16

21 3.3 Specific Risks relating to Rehabilitation 3.4 Geology and geochemistry The Cullen Valley Mine is located within the Western Coalfield of NSW on the western edge of the Sydney Basin. The Sydney Basin consists of a series of gently dipping sedimentary beds of shale and sandstone of Permo-Carboniferous age capped by massive sandstones of Triassic Age. Directly beneath the Triassic sandstone, these beds contain coal seams and form the Upper Coal Measures. The measures extend from the western boundary of the Western Coalfield in an easterly direction, dipping generally at an angle of 1-3 to the northeast, towards the coast, and extending out to sea. The Western Coalfield is characterised by the prominent cliffs and eroding plateaus of the Triassic age sandstone and shale Narrabeen Group which overlies the shale, sandstone, conglomerate and coal of the Permian aged Illawarra Coal Measures. These form the slopes which fall away from the sandstone and shale cliffs. The Western Coal field extends from south of Lithgow to north of Ulan and is generally bound to the west by outcroppings of the Lithgow seam, the deepest coal seam of the measures. There is no defined eastern boundary given the dipping of coal measures to the northeast (below the Hawkesbury Sandstone of the Blue Mountains). There are seven identified coal seams in the Illawarra Coal Measures, which in descending order are as follows: Katoomba Seam; Middle River Seam; Moolarben Seam; Upper Irondale Seam; Irondale Seam; Lidsdale Seam; and Lithgow Seam. Previous underground workings exclusively mined the Lithgow seam. The most recent open cut mining extracted predominately the Upper Irondale, Irondale, Lidsdale, and Lithgow seams. The Katoomba, Middle River, and Moolarben seams were mined in a reduced capacity where present. Despite currently approved available coal reserves having been exhausted, there are known economically viable reserves remaining in the mining leases Material prone to spontaneous combustion Experience to date at the Cullen Valley Mine has demonstrated that the stockpiled coal and insitu coal resources have a low propensity to spontaneously combust. However, to ensure that it is not relevant to the subsurface heating issue, a study was undertaken to supplement the existing knowledge of the spontaneous combustion propensity of the coal and overburden in the backfill. The results detailed in a report by RGS Environmental (May 2013) have confirmed that the insitu coal is low-risk for spontaneous combustion. This has provided a more complete understanding of the very low potential for spontaneous combustion to be a contributing factor to the initiation and spread of subsurface heating at Cullen Valley Mine. Page 17

22 3.4.2 Subsurface heating A comprehensive assessment of subsurface heating at the Cullen Valley Mine has been undertaken in consultation with DRE. The PoW MOP Variation (dated 30 January 2013) was prepared following site assessments of the subsurface heating area by Olsen Consulting Group (OCG). The PoW MOP Variation was approved by DRE on 11 March The approved PoW MOP Variation details the history, proposed management and mitigation strategies and schedule of works proposed to treat the heat affected area. A copy of the approved PoW MOP Variation is provided in full in Appendix D. A further site assessment was conducted by OCG on 29 October 2015 to provide an update on subsurface heating issues at Cullen Valley Mine. During this assessment it was noted that: Previously capped areas continue to show no evidence of reheating indicating that capping provides a potential treatment for the remaining heating areas; Heating affected vegetation adjacent previously capped areas had increased and showed evidence of combustion actions are required to address this combustion; Level of obvious heating on the steep face above the haul road has continued to decrease and vegetation has continued to improve but there is still thermal activity on the western edge monitoring is required and containment of further extension of heating to the west; Backfilled areas along the interface of the highwall and overburden showed much less emissions than previously and this practice should be continued The area adjacent to the haul road that was previously treated by extracting heating material and replacing with inert clay and stone has worked successfully with no obvious indication of reheating. The remaining heating in this area had increased slightly in size and treatment is required for containment of further extension of heating to the west; and The treated noise bund wall showed no obvious signs of reheating. The recommendations arising from this site assessment are as follows: Further monitoring and observations of heating areas should continue to confirm the appropriate level of heating management; Capping of heating areas should be continued as a management strategy. Continue monitoring of treated areas to record success or identify the need to modify actions; Treatment of vegetation die back in heating areas should include water management to ensure overland water flow does not enter the site. Initial investigation could include a trench excavated at the active front of the heated area to assist in planning a suitable response; Remaining heating areas could be treated by removal of heating material and substitution with inert clay and rock (if available); Martin Olsen should be onsite when any recommended treatments are undertaken to enable direct input into the team managing the day to day activities; and The current Plan of Operations should be amended to reflect changes as a result of care and maintenance activities. The monitoring and rectification works in subsurface heating areas recommended by the OCG site assessment will be conducted in accordance with the PoW MOP Variation and Subsurface Heating Program of Works Material prone to generating acid mine drainage Coarse reject material is emplaced within the void of the open cut in such a manner that it does not encroach on in-situ coal seams (i.e. emplaced 5m away from exposed in-situ coal seams). In addition to this, course reject material is buried at a minimum 5m depth below the surface. This management measure is intended to significantly reduce the risk of any potential acid generating material entering the underlying water table, due to the coal seam being permeable. Page 18

23 In addition to the above measures, coal rejects have been placed at least 5m from the exposed highwall to minimise any potential for acid mine leachate to enter the subsurface water system via the exposed interburden or coal seam Mine subsidence There will be no underground or highwall mining undertaken during the C&M MOP term. As such, no subsidence is expected to occur Erosion and sediment control Permanent erosion and sediment control measures within the Cullen Valley Mine include containment and diversion of "clean" water around disturbed areas and containment of runoff from within disturbed areas by the sediment basins. Temporary measures including contour banks, drains and silt-stop fences will be installed and maintained in accordance with the Environmental Management Plan (Erosion and Sediment Control Plan) Soil type and slope management Soil characteristics at Cullen Valley Mine are typically deficient in nitrogen, phosphorus and potassium. During the seeding process, chemical fertilizers will be added to increase soil nutrients and promote greater seed germination within the rehabilitated landscape. Erosion has been observed on slopes in rehabilitation areas. Rectification of erosion in these areas will be undertaken by re-construction of contour banks on slopes to prevent runoff from reaching high velocities that may cause erosion Flora and fauna Existing vegetation communities and fauna habitat have been identified during an ecological impact assessment conducted for the Environmental Assessment. The Pre-mining vegetation communities and fauna habitat are shown on Plan 1B (Appendix A). There are no vegetation clearing activities proposed during the C&M MOP term. No new rehabilitation areas will be established during the C&M MOP term. Rehabilitation works will focus on remediation of failed vegetation in existing rehabilitation areas. Remediation of existing rehabilitation areas will proceed generally in accordance with the approved Flora and Fauna Management Plan Other risks Air quality There are no mining activities planned to be undertaken during the C&M MOP term, this includes blasting, coal haulage by trucks and overburden removal. As such, potential impacts to air quality will be minimal. Control measures to minimise air quality impacts include utilising a water cart on haul roads when undertaking maintenance works during the C&M MOP term. Dust monitoring will continue to be undertaken in accordance with the Environmental Management Plan (Air Quality Management Plan) to verify the effectiveness of air quality control measures and will include dust deposition, PM 10, and meteorological conditions. Surface water Surface water will be monitored and managed in accordance with the approved Environmental Management Plan (Water Management Plan) as discussed in Section Page 19

24 Groundwater There are no impacts to groundwater anticipated to occur during the C&M MOP term. Groundwater monitoring will be undertaken to identify any potential adverse impacts. Contaminated land There are no known areas of land contamination at the Cullen Valley Mine. There are no planned works proposed to be undertaken during the C&M MOP term that would cause significant land contamination. Control measures regarding hazardous materials that may cause contamination are discussed below. Hazardous materials Hazardous material storage tanks containing oils, grease and degreasers have been emptied, isolated and secured. Any additional storage tanks have been removed from the site. Storage tanks remaining onsite will be kept emptied during the care and maintenance period. Any bunds containing storage tanks or drums have been cleaned and will be checked during regular statutory inspections. The above ground self bunded diesel tank (Transtank) will be operational during the care and maintenance period with up to 35,000L of diesel stored in the facility. Two EPA registered radionuclide fixed radiation gauges (No. RR20215 and No. RR21832) have been decommissioned and are stored onsite. Inspections are carried out on the devices and the storage container by a qualified consultant as required by the licence. A register of hazardous materials is maintained on site. In addition, any contractor is required to maintain a register of hazardous materials utilised by its operations and service personnel whilst activities are being undertaken at Cullen Valley Mine. Greenhouse gases, methane drainage/venting Due to the cessation of mining activities at the commencement of the care and maintenance period, greenhouse gas emissions is minimal and is generally limited to fuel (diesel) use for operation of light vehicles and pumps and electricity use at the administration buildings and workshops. There are no methane drainage issues and venting is not conducted at the site. Blasting Due to the cessation of mining activities at the commencement of the care and maintenance period, blasting is not conducted and there are no planned blasting activities during the C&M MOP term. Noise There will be no proposed mining activities undertaken at the Cullen Valley Mine during the C&M MOP term. As such no potential adverse noise impacts are anticipated during this time. Quarterly monitoring of noise at various locations around the site is conducted in accordance with approval conditions. Visual and lighting There will be no proposed mining activities undertaken at the Cullen Valley Mine during the C&M MOP term. As such, no potential adverse visual or lighting impacts are anticipated during this time. Heritage (Aboriginal and European) Previous archaeological surveys did not locate any Aboriginal Artefacts or sites within the approved open cut mining area. However, two sites of significance were recorded in close proximity to the approved mining area. A campsite-stone artefact scatter (C-OS-1) and a rock Page 20