Independent Environmental Audit

Transcription

1 Commercial in Confidence Independent Environmental Audit Integra Coal Underground Independent Environmental Audit Integra Coal Underground

2 Integra Coal Underground Independent Environmental Audit - AECOM Independent Environmental Audit Integra Coal Underground Prepared for Integra Coal Underground Prepared by AECOM Australia Pty Ltd 17 Warabrook Boulevard Warabrook NSW 2304, T F ABN January 2010 N AECOM * AECOM Australia Pty Ltd (AECOM) has prepared this document for the purpose which is described in the Scope of Works section, and was based on information provided by the client, AECOM's understanding of the site conditions, and AECOM's experience, having regard to the assumptions that AECOM can reasonably be expected to make in accordance with sound professional principles. * This document was prepared for the sole use of the party identified on the cover sheet, and that party is the only intended beneficiary of AECOM's work. * No other party should rely on the document without the prior written consent of AECOM, and AECOM undertakes no duty to, nor accepts any responsibility to, any third party who may rely upon this document. * All rights reserved. No section or element of this document may be removed from this document, extracted, reproduced, electronically stored or transmitted in any form without the prior written permission of AECOM. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1

3 Integra Coal Underground Independent Environmental Audit - AECOM Quality Information Document Ref Independent Environmental Audit N \\auntl1fp001\public\jobncl\ncl\n7\n \n70045 integra compliance audit\5. delivery\5.1 reports drafts\n _rpt_13jan10.docx Date 13 January 2010 Prepared by Alison O'Neill Author Signature Reviewed by Peter Horn Technical Peer Reviewer Signature Distribution Copies Recipient Copies Recipient 1 Chris Ellis Environmental Advisor Integra Coal Underground 640 Middle Falbrook Rd Glennies Creek NSW AECOM File P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1

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5 Integra Coal Underground Independent Environmental Audit - AECOM Contents 1.0 Introduction Audit Scope Audit Approach Audit Team Audit Timing Documents Reviewed Personnel Interviewed Background Information with Consents, Licences and Approvals Assessment Against the Statement of Commitments Assessment of Environmental Performance Recommendations for Improvement List of Tables Body Report Table 1: Recommendations for Improvement List of Appendices Appendix A with Project Approvals, EPL and Statement of Commitments P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1 i

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7 Integra Coal Underground Independent Environmental Audit - AECOM 1.0 Introduction AECOM Australia Pty Ltd (AECOM) was appointed by Integra Coal Underground (Integra) to undertake an Independent Environmental Audit of the development referred to as the Glennies Creek Coal Project, including the Integra Underground complex and associated Surface Facilities. This report outlines the findings of the audit, and provides recommendations to improve compliance and the environmental performance of the mine against relevant statutory documents and the Integra Coal environmental management system. 1.1 Audit Scope The scope of work for the environmental audit is set out in two separate project approvals for the Underground operations and the Surface Facilities components of the project. Schedule 5, Condition 5 of the Project Approval for the Glennies Creek Coal Mine Surface Facilities Project (MP 06_0057) issued by the NSW Minister for Planning states: Independent Environmental Audit 5. Every 5 years (and consistent with the mine s existing audit schedule), unless the Director- General directs otherwise, the Proponent shall commission and pay the full cost of an Independent Environmental Audit of the project. This audit must: (a) be conducted by suitably qualified, experienced and independent expert/s whose appointment has been endorsed by the Director-General; (b) assess the various aspects of the environmental performance of the project, and its effects on the surrounding environment; (c) assess whether the project is complying with the relevant standards, performance measures and statutory requirements; (d) review the adequacy of any strategy/plan/program required under this approval; and, if necessary, (e) recommend measures or actions to improve the environmental performance of the project, and/or any strategy/plan/program required under this approval. Schedule 4, Condition 6 of the Project Approval for the Glennies Creek Underground Coal Project (MP 06_0213) issued by the NSW Minister for Planning states: Independent Environmental Audit 6. By the end of 2009, and every 3 years thereafter, unless the Director-General directs otherwise, the Proponent shall commission and pay the full cost of an Independent Environmental Audit of the Integra Underground Complex. This audit must: (a) be conducted by a suitably qualified, experienced and independent team of experts whose appointment has been endorsed by the Director-General; (b) include consultation with the relevant agencies; (c) assess the various aspects of the environmental performance of the project, and associated surface facilities and whether it is complying with the relevant requirements in this approval and any relevant mining lease and environment protection licence (including any strategy, plan or program under these approvals); and (d) review the adequacy of strategies, plans, and/or programs required under these approvals; and, if necessary, (e) recommend measures or actions to improve the environmental performance of the project, and/or any strategy, plan, or program required under these approvals, including changes to the mine plan. Notes: - The timing of the audits required in the Glennies Creek Coal Mine Surface Facilities Project (MP 06_0057) approval will need to be adjusted to coincide with the requirements of this approval. - The audit team should be led by a suitably qualified auditor, and include experts in the field of subsidence, surface water and groundwater. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1 1

8 Integra Coal Underground Independent Environmental Audit - AECOM 1.2 Audit Approach The audit was undertaken in general accordance with AS/NZS ISO 19011:2003 Guidelines for Quality and/or Environmental Management Systems Auditing. Following discussion about the approach to the audit between AECOM and Integra, the audit program was divided into the following components: Assessment of compliance and environmental performance of the site against the two project approvals, and the Environment Protection Licence (EPL) (refer Section 3.0). Assessment of environmental performance of the project against the Statement of Commitments contained in the Environmental Assessment (EA) prepared for the Glennies Creek Underground Coal Project and the Draft Statement of Commitments contained in the EA prepared for the Glennies Creek Coal Mine Surface Facilities Project (refer Section 4.0). Assessment of environmental performance and environmental management of the project, including review of management plans and mitigation measures implemented at the site (refer Section 5.0). with relevant statutory documents and the environmental management performance of the project was assessed using the following approach: The consent conditions and associated documents were reviewed; Interviews were conducted with Integra personnel to progressively identify and obtain copies of evidence to support compliance; and A site inspection was undertaken to confirm the results of the interviews and document review. 1.3 Audit Team The audit was undertaken by the following AECOM staff: Greg Schumacher, Manager Hunter. Greg was responsible for peer review of the audit and provided highlevel project support Quality Assurance. Peter Horn, Associate Director. Peter was the Lead Auditor, responsible for planning the audit, conducting the site audit, and providing direction and assistance for the preparation of audit materials and the audit report Lead Auditor. Alison O Neill, Project Environmental Scientist. Alison was part of the audit team responsible for conducting the site audit, preparing audit materials and the audit report Auditor. Amanda Kerr, Senior Environmental Engineer. Amanda advised the site audit team on questions related to surface water and subsidence Technical Quality Assurance. Ainslie Williams, Senior Professional Hydrogeologist. Ainslie advised the site audit team on questions related to groundwater Technical Quality Assurance. The NSW Department of Planning (DoP) confirmed by letter (dated 12 October 2009) that the Director-General endorsed the appointment of the above audit team. 1.4 Audit Timing The environmental audit was conducted on the 3 4 December The audit report was finalised in January P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1 2

9 Integra Coal Underground Independent Environmental Audit - AECOM 1.5 Documents Reviewed The following principal documents were reviewed during the conduct of the audit: Project Approval for MP 06_0057 Glennies Creek Coal Mine Surface Facilities Project (as modified 25 August 2009); Project Approval for MP 06_0213 Glennies Creek Underground Coal Project; EPL 7622; Statement of Commitments prepared for Underground EA; and Draft Statement of Commitments prepared for Surface Facilities EA. Numerous subsidiary documents were obtained and reviewed during the audit as references in the Audit table in Appendix A. In addition, numerous correspondence documents were inspected and referred to during specific aspects of the audit. These are referenced in the relevant sections of this report. 1.6 Personnel Interviewed The following Integra personnel were interviewed during the course of the audit: Chris Ellis, Environmental Advisor; David Roxby, Maintenance Superintendent; and Chris Smith, Project Manager. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1 3

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11 Integra Coal Underground Independent Environmental Audit - AECOM 2.0 Background Information Integra Coal Underground is an unincorporated joint venture, between majority owner Vale Australia (62.9%) and a number of companies controlled by major Asian steel mills. Integra Coal Operations Pty Ltd is the management company responsible for all operations at the Underground site on behalf of the joint venture owners. The Integra Coal Underground complex and associated surface facilities are located within the Singleton Shire, approximately 12km north of Singleton. The Underground complex is located immediately adjacent to the Integra Coal Open Cut operation. Major interest in the coal resource in the area commenced in the mid 1970s, and a Development Consent (DA 105/90) for an underground mine was granted on 1 November 1991 (this DA does not form part of the scope for this audit). Underground development commenced in May In 2006 a Part 3A application was made to consolidate the existing and additional surface facilities required for ongoing operation into one planning approval. Project Approval (MP 06_0057) was issued for the surface facilities project on 31 st January This approval was modified on 21 November 2008 to allow additional infrastructure at the ventilation shaft site and associated boreholes to reticulated services to the underground workings. The approval was also modified on 25 August 2009 to extension the installation date for the overland conveyor. In 2008 a Part 3A application was prepared for the underground coal mining of Longwalls within the Middle Liddell Seam. Project Approval (MP 06_0213) for the underground complex was issued on 16 June The maximum production level at the Integra Underground complex is limited by these approvals to 4.5 million tonnes per annum of run-of-mine (ROM) coal. Approximately 280 full time staff and contractors are employed at the Integra Underground complex. Additional personnel are also employed on a casual basis to undertake specific tasks. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1 5

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13 Integra Coal Underground Independent Environmental Audit - AECOM 3.0 with Consents, Licences and Approvals Schedule 5, Condition 5(c) of the project approval MP 06_0057 requires the audit to: Assess whether the project is complying with the relevant standards, performance measures and statutory requirements. Schedule 4, Condition 6(c) of the project approval MP 06_0213 requires the audit to: Assess the various aspects of the environmental performance of the project, and associated surface facilities and whether it is complying with the relevant requirements in this approval and any relevant mining lease and environment protection licence (including any strategy, plan or program under these approvals). Appendix A provides an assessment of compliance against the conditions of the project approvals (MP 06_0057 and MP 06_0213 ) and the conditions of EPL For each approval or licence condition, compliance was defined by the following terms: Integra complies with this condition (compliance); Integra partially complies with this condition (partial compliance); Integra does not comply with this condition (non-compliance); or This condition has not yet been activated (not yet activated). In general a high degree of compliance with the project approvals and the EPL conditions has been achieved. During the audit a small number of non compliances and partial compliances were identified along with areas where improvement to environmental management could occur. Two non compliances were identified, including one incident involving a spill of hydraulic fluid and one overpressure exceedance as a result of Open Cut blasting operations. The partial compliances identified relate to construction and occupation certificates, stakeholder consultation with relevant agencies, recording of air quality monitoring information, and monitoring of underground blasts. Details of the non compliances and recommendations are included in Section 6.0 of this report. It is noted that the original sent by Integra to DoP submitting the various site management plans prior to March 2007 was not available. A copy of the was provided which did not specify the date or recipient, however it was considered to provide sufficient evidence of compliance for the relevant conditions. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1 7

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15 Integra Coal Underground Independent Environmental Audit - AECOM 4.0 Assessment Against the Statement of Commitments The EA prepared for the Integra Underground Complex project application included a Statement of Commitments, which was revised as a result of submissions made during the public exhibition process. The EA prepared for the Surface Facilities project also included a Draft Statement of Commitments. As part of this audit, the environmental performance of the project was assessed against the Statement of Commitments prepared for these two projects, and the results are included in Appendix A. The actual environmental performance of the mine was determined from monitoring results reported in the Annual Environmental Management Report (AEMR) for 2006, 2007 and 2008, and was verified by site inspection. For each commitment, compliance was defined by the following terms: Integra has met this commitment (compliance); Integra has partially met this commitment (partial compliance); Integra has not met this commitment (non-compliance); or This commitment has not yet been activated (not yet activated). It was generally considered that the development is operating in accordance with the commitments made in the respective EAs. Underground mining of Longwalls had not yet commenced at the time of the audit and therefore a number of commitments had not yet been activated. There were no non-compliances identified during the audit, however some improvements were recommended relating to the documentation of certain site procedures. These recommendations are outlined in Section 6.0 of this report. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan10 1 9

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17 Integra Coal Underground Independent Environmental Audit - AECOM 5.0 Assessment of Environmental Performance The environmental performance of the project was assessed during this audit by reviewing the Environmental Management Strategy and associated environmental management plans (as referenced in the project approvals) and then assessing the effectiveness of their implementation during the audit site inspection and audit interviews. The environmental performance of the project was also determined from monitoring results reported in the AEMR for 2006, 2007 and For each approval or licence condition, the need for improvement was defined by the term: Improvement Recommended. The recommendations for improvement are included in Section 6.0 of this report. The improvements generally relate to the amendment of site management plans, reports or procedures so as to document specific requirements or information. It was also suggested that Integra consider amending EPL 7622 to cover only underground mining and associated activities, so as to remove the conditions and obligations that relate to Open Cut operations. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan

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19 Integra Coal Underground Independent Environmental Audit - AECOM 6.0 Recommendations for Improvement This section presents the recommendations arising from the Independent Environmental Audit undertaken for the Integra Underground complex and associated surface facilities in accordance with MP 06_0213 and MP 06_0057. Table 1: Recommendations for Improvement No. Approval/Licence/Aud it Reference Condition No. Recommendation 1 MP 06_0057 Schedule 2, Condition 8 Partial Not all construction certificates had matching occupation certificates. 2 MP 06_0057 MP 06_0213 Schedule 3, Condition 2 Schedule 3, Condition 4 Partial The Site Water Management Plan was prepared by a suitably qualified person, however their appointment was not approved by the Director- General of the DoP. Evidence was provided of consultation with DWE for the revised plans in 2009, however no evidence was provided to show that the original 2007 version was prepared in consultation with DNR/DWE. It is recommended that Integra ensure plans are prepared by personnel approved by DoP where required, and that all stakeholder consultation required by the relevant approvals is undertaken. 3 MP 06_0057 Schedule 3, Condition 12 Improvement Recommended The meteorological monitoring reports should state that the monitoring station is operated in accordance with the Approved Methods for Sampling of Air Pollutants in NSW. 4 MP 06_0057 Schedule 3, Condition 14 Improvement Recommended The AEMR or lighting protocol should state that external lighting is undertaken in accordance with AS MP 06_0057 MP 06_0213 Schedule 5, Condition 9A Schedule 4, Condition 10 Partial No evidence was provided that the Greenhouse Gas Management Plan was sent to Council or other relevant agencies. It is recommended that the Greenhouse Gas Management Plan be submitted to Council and relevant agencies. Any further plans approved by DoP should be provided to Council, relevant agencies and the CCC. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan

20 Integra Coal Underground Independent Environmental Audit - AECOM No. Approval/Licence/Aud it Reference Condition No. Recommendation 6 MP 06_0213 Schedule 4, Condition 2 Partial Evidence was provided of consultation with DPI and DECCW for the revised Environmental Management Strategy in 2009, however no evidence was provided to show consultation with DWE. It is recommended that Integra ensure all stakeholder consultation required by the relevant approvals is undertaken. 7 EPL 7622 L 1.1 Non One incident occurred, involving a spill of hydraulic fluid into the dirty water system. The incident was reported to the EPA and remedial action taken to prevent a re-occurrence. 8 EPL 7622 L M 8.1 R 4.1 Improvement Recommended Blasting limits and monitoring requirements specified in EPL 7622 apply to the Open Cut operations, rather than the Underground operations. It is recommended that Integra consider amending EPL 7622 to cover only underground mining and associated activities. 9 EPL 7622 L 7.4 Non One overpressure exceedance occurred as a result of Open Cut blasting operations. The incident was reported to the EPA and Integra are reviewing their blasting procedures. As detailed above, it is recommended that Integra consider amending EPL 7622 to cover only underground mining and associated activities. 10 EPL 7622 M 1.3 Partial The air quality monitoring records do not include all the details required by EPL Field records provided for High Volume Air Sampling do not include the time at which the sample was collected. It is recommended that the field sheets used to record the Air Quality monitoring results be amended to specify the details required (date, time, sample point, and name of field staff). 11 EPL 7622 M 3.1 Improvement Recommended The Air Quality Monitoring report should state that sampling is undertaken in accordance with the Approved Methods for Sampling and Analysis of Air Pollutants in NSW. 12 EPL 7622 M 7.1 Improvement Recommended The meteorological monitoring report should state the sampling method, units of measure, averaging period and sample frequency of each parameter. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan

21 Integra Coal Underground Independent Environmental Audit - AECOM No. Approval/Licence/Aud it Reference Condition No. Recommendation 13 EPL 7622 M 8.1 Partial Some of the underground blasts are monitored but not all. It is noted that these conditions relate to the Open Cut operations which EPL 7622 also covers. As detailed above, it is recommended that Integra consider amending EPL 7622 to cover only underground mining and associated activities. 14 SoC Surface EA SoC Underground EA Improvement Recommended Approved hours for construction materials delivery could be written into contracts or purchase orders to ensure that contractors comply with these time restrictions. 15 SoC Surface EA 6.8 Improvement Recommended The Air Quality Management Plan or relevant site procedure / protocol should specify how dust emissions are to be controlled when utilising percussion drilling. 16 SoC Surface EA 12.1 Improvement Recommended The Bushfire Hazard Reduction Plan should state that topsoil / vegetation removal activities are not to be undertaken during periods of extreme fire danger or total fire bans. 17 SoC Underground EA 49 & 52 Improvement Recommended Relevant site standards or procedures should state that electrical and diesel efficiency are to be considered prior to purchasing new equipment. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.1 Reports Drafts\N _Rpt_13Jan

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23 Integra Coal Underground Independent Environmental Audit - AECOM Appendix A with Project Approvals, EPL and Statement of Commitments

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25 Point Document Requirement Verification/Comment Documentary Evidence # Audit Finding # Project Approval - Surface Facilities SCHEDULE 2 - ADMINISTRATIVE CONDITIONS Obligation to Minimise Harm to the Environment MP 06_ The Proponent shall implement all practicable measures to prevent and/or minimise any harm to the environment that may result from the construction, operation, or rehabilitation of the Environmental Management Strategy prepared for Environmental Management Strategy project. the site in accordance with ISO (OMP_0200) Terms of Approval MP 06_ The Proponent shall carry out the project generally in accordance with the: (a) Project Application 06_0057; (b) EA titled Glennies Creek Colliery: Environmental Assessment of Surface Facilities and Activities, dated August 2006; (c) letter from the Proponent to the Department amending the project application, dated 3 October 2006; (d) modification application and supporting information titled Proposed Modifications to Forest Road Ventilation Shaft Area, dated October 2008; and (e) modification application and supporting information titled Supporting Information for a s75w Application to Modify Condition 16 of Schedule 3, Project Approval (PA) 06_0057 Integra Coal Operations Pty Ltd, dated June 2009; and (f) conditions of this approval. Notes: 1. This approval relates to construction and use of surface facilities associated with the Glennies Creek coal mine only. Underground coal mining, coal haulage beyond the site boundary, and coal processing are regulated under separate approvals. 2. The general layout of the project is shown on the plans in Appendix 2. This audit, AEMR 2008, 2007, 2006, Annual Return 07/08, 06/07 MP 06_ If there is any inconsistency between the above documents, the most recent document shall prevail to the extent of the inconsistency. However, the conditions of this approval shall prevail to Noted. the extent of any inconsistency. MP 06_ If there is any inconsistency between the conditions of this approval and the conditions of any other development approval for the Glennies Creek colliery, the conditions of this approval shalnoted. prevail to the extent of the inconsistency. MP 06_ The Proponent shall comply with any reasonable requirement/s of the Director-General arising from the Department s assessment of: (a) any reports, plans, programs or correspondence that are submitted in accordance with this approval; and (b) the implementation of any actions or measures contained in these reports, plans, programs or correspondence. No correspondence received from DoP with further requirements. MP 06_0057 5A The Proponent shall prepare revisions of any strategies, plans or programs required under this approval if directed to do so by the Director-General. Such revisions shall be prepared to the No correspondence received from DoP with satisfaction of, and within a timeframe approved by, the Director-General. further requirements. Limits on Approval MP 06_ This approval lapses on 1 January Noted. MP 06_ The Proponent shall not process more than 4.5 million tonnes of ROM coal a year at the site. AEMR 2008, 2007, 2006 Structural Adequacy MP 06_ The Proponent shall ensure that all new buildings and structures, and any alterations or additions to existing buildings and structures, are constructed in accordance with the relevant requirements of the BCA. Notes: 1. Under Part 4A of the EP&A Act, the Proponent is required to obtain construction and occupation certificates for the proposed building works. 2. Part 8 of the EP&A Regulation sets out the requirements for the certification of the project. Several construction certificates sighted, not all had matching Occupation certificates. Partial Demolition MP 06_ The Proponent shall ensure that all demolition work is carried out in accordance with Australian Standard AS : The Demolition of Structures, or its latest version. Operation of Plant and Equipment MP 06_ The Proponent shall ensure that all plant and equipment used at the site is: (a) maintained in a proper and efficient condition; and (b) operated in a proper and efficient manner. Site Inspection. Interview with maintenance team. SCHEDULE 3 - SPECIFIC ENVIRONMENTAL CONDITIONS SURFACE AND GROUND WATER Discharge Limits MP 06_ Except as may be expressly provided by a DEC Environment Protection Licence or DNR water licence, the Proponent shall not discharge any mine water from the site. Chris Ellis confirmed no discharges occur. AEMR 2008, 2007, 2006 Site Water Management Plan MP 06_ The Proponent shall prepare (and following approval implement) a Site Water Management Plan for the project, to the satisfaction of the Director-General. The Plan shall be prepared in consultation with the DNR, and be submitted to the Director-General by the end of March The Plan must be prepared by a suitably qualified hydrogeologist/hydrologist whose appointment/s have been approved by the Director-General, and shall include: (a) a Site Water Balance; (b) an Erosion and Sediment Control Plan; (c) a Surface Water Monitoring Program; (d) a Groundwater Monitoring Program; and (e) a Surface and Groundwater Response Plan. Note: The Surface and Groundwater Response Plan is to be submitted by the end of March Plan submitted to DoP, no correspondence Site Water Mgmt Plan (EMP_0001), Site Water received from DoP to indicate approval. Mgmt Plan for longwalls (EMP_0007), Chris Ellis confirmed Plan was prepared by submitting management plans to DoP suitably qualified person but appointment was not (not dated), Letter submitting revised plans to approved by DoP. DoP (21 October 2008), submitting Site Evidence provided for consultation with DWE in Water Mgmt Plan for longwalls to DoP May 2009 for revised plan, however no evidence (31 March 2009), Consultants' meeting notes that the 2007 version of the plan was prepared in from their meeting with DWE (7 May 2009). consultation with DNR/DWE. Recommendation : Ensure plans are prepared by personnel approved by DoP. Ensure all stakeholder/agency consultation requirements are undertaken for future preparation of management plans. Partial P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.2 Reports Final\N _Audit_Protocol_13Jan10.xlsx 1 13/01/2010

26 Document Point # Requirement Verification/Comment Documentary Evidence # Audit Finding MP 06_ The Water Balance shall: (a) include details of: - sources of water (including groundwater make from underground workings and from Camberwell overburden emplacement areas); - reliability of water supply; - water use on site; - volume of water storages on site; - water management on site; - on-site and off-site water transfers; - reporting procedures; and (b) describe measures to minimise water use by the project. Site Water Mgmt Plan (EMP_0001), Site Water Mgmt Plan for longwalls (EMP_0007) MP 06_ The Erosion and Sediment Control Plan shall: (a) be consistent with the requirements of the Department of Housing s Managing Urban Stormwater: Soils and Construction manual; (b) identify activities that could cause soil erosion and generate sediment; (c) describe measures to minimise soil erosion and the potential for the transport of sediment to downstream waters; (d) describe the location, function, and capacity of erosion and sediment control structures; and (e) describe what measures would be implemented to maintain the structures over time. MP 06_ The Surface Water Monitoring Program shall include: (a) baseline data on surface water flows and quality in waterbodies that could potentially be impacted by the mine; (b) surface water impact assessment criteria; (c) a program to monitor surface water flows and quality; (d) a program to monitor water volume and levels in water storages across the site; (e) a protocol for the investigation, notification and mitigation of identified exceedances of the surface water impact assessment criteria; and (f) a program to monitor the effectiveness of the Erosion and Sediment Control Plan. MP 06_ The Groundwater Monitoring Program shall include: (a) a program to monitor the volume and quality of groundwater make within the Camberwell North Pit and underground mine workings; (b) regional groundwater levels and quality in the surrounding aquifers; and (c) the groundwater pressure response in the surrounding coal measures. MP 06_0057 6A The Surface and Groundwater Response Plan must describe the measures and/or procedures that would be implemented to: (a) respond to any exceedances of the surface water and groundwater assessment criteria; (b) offset the loss of any base flow to connected alluvium caused by the project; (c) compensate landowners of privately-owned land whose water supply is adversely affected by the project; and (d) mitigate and/or offset any adverse impacts on groundwater dependent ecosystems or riparian vegetation. Site Water Mgmt Plan (EMP_0001), Site Water Mgmt Plan for longwalls (EMP_0007) Site Water Mgmt Plan (EMP_0001), Site Water Mgmt Plan for longwalls (EMP_0007) Site Water Mgmt Plan (EMP_0001), Site Water Mgmt Plan for longwalls (EMP_0007) Site Water Mgmt Plan for longwalls (EMP_0007) NOISE Noise Impact Assessment Criteria MP 06_ The Proponent shall ensure that the noise generated by the project does not exceed the noise impact assessment criteria presented in Table 1 at any residence on privately owned land. Noise monitoring undertaken by Global Acoustics. AEMR 2008, 2007, 2006 Table 1: Noise impact assessment criteria db(a) LAeq (15 min) Location Day/Evening/Night Mordey, Lambkin, Donellan, Hardy, Noble Watling, Oxford, G. Hal l, Proctor, Richards, Burgess Egan, Payne, Moore Notes: (a) The noise criteria do not apply to residences within the Zone of Affectation for the Camberwell coal mine (Dulwich and Tisdell), or to properties where the Proponent and the affected landowner have reached a negotiated agreement in regard to noise, and a copy of the agreement has been forwarded to the Director-General and DEC. (b) Noise from the project is to be measured at the most affected point or within the residential boundary, or at the most affected point within 30 metres of a dwelling (rural situations) where the dwelling is more than 30 metres from the boundary, to determine compliance with the LAeq(15 minute) noise limits in the above table. Where it can be demonstrated that direct measurement of noise from the project is impractical, the DEC may accept alternative means of determining compliance (see Chapter 11 of the NSW Industrial Noise Policy). The modification factors in Section 4 of the NSW Industrial Noise Policy shall also be applied to the measured noise levels where applicable. (c) The noise emission limits identified in the above table apply under meteorological conditions of: - wind speeds of up to 3 m/s at 10 metres above ground level; or - temperature inversion conditions of up to 3ºC/100m. Ballast Delivery Hours of Operation MP 06_ Ballast delivery operations at the Forest Road Ventilation Shaft Area shall be restricted to 8:00am to 5:00pm, Monday to Friday. Noise Monitoring Program MP 06_ The Proponent shall prepare (and following approval implement) a Noise Monitoring Program for the project, to the satisfaction of the Director-General. The program must include a noise monitoring protocol for evaluating compliance with the noise impact assessment criteria in this approval, and be submitted to the Director-General by the end of March Note: The noise monitoring program may be integrated with any similar program for the Camberwell coal mine. Plan submitted to DoP, no correspondence received from DoP to indicate approval. Plan includes monitoring procedure and monitoring locations. Noise Management Plan (EMP_0003), submitting plans to DoP (not dated), Letter submitting revised plans to DoP (21 October 2008). AIR QUALITY Impact Assessment Criteria MP 06_ The Proponent shall ensure that the dust emissions generated by the project do not cause additional exceedances of the air quality impact assessment criteria listed in Tables 2, 3, and 4 at any residence on, or on more than 25 percent of, any privately owned land. Annual averages were below criteria. Some exceedances of the 24 hour PM10 criteria occurred, however investigations indicated the exceedances were not related to Integra operation. AEMR 2008, 2007, 2006 P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.2 Reports Final\N _Audit_Protocol_13Jan10.xlsx 2 13/01/2010

27 Document Point # Requirement Verification/Comment Documentary Evidence # Audit Finding Table 2: Long term impact assessment criteria for particulate matter Pollutant Averaging period Criterion Total suspended particulate (TSP) matter Annual 90 μg/m 3 Particulate matter < 10 μm (PM10) Annual 30 μg/m 3 Table 3: Short term impact assessment criterion for particulate matter Pollutant Averaging period Criterion Particulate matter < 10 μm (PM10) 24 hour 50 μg/m 3 Table 4: Long term impact assessment criteria for deposited dust Pollutant Averaging period Maximum Increase in Maximum Total Deposited Dust Level Deposited Dust Level Deposited dust Annual 2 g/m 2 /month 4 g/m 2 /month Note: Deposited dust is assessed as insoluble solids as defined by Standards Australia, 1991, AS : Methods for Sampling and Analysis of Ambient Air - Determination of Particulates - Deposited Matter - Gravimetric Method. Air Quality Monitoring Program MP 06_ The Proponent shall prepare (and following approval implement) an Air Quality Monitoring Program, to the satisfaction of the Director-General. The program must include an air quality monitoring protocol for evaluating compliance with the air quality impact assessment criteria in this approval, and be submitted to the Director-General by the end of March Note: The air quality monitoring program may be integrated with any similar program for the Camberwell coal mine. METEOROLOGICAL MONITORING MP 06_ By the end of March 2007, the Proponent shall establish and subsequently maintain a suitable meteorological station operating in the vicinity of the project in accordance with the requirements in Approved Methods for Sampling of Air Pollutants in New South Wales, and to the satisfaction of the DEC and the Director-General. Note: The meteorological station may be integrated with a similar station established for the Camberwell coal mine. Plan submitted to DoP, no correspondence received from DoP to indicate approval. Plan includes monitoring program and protocol. Details outlined in AEMR which is submitted to DEC and DoP, therefore satisfaction of these departments is assumed. Recommendation : Meteorological monitoring report should state that the monitoring station is operated in accordance with Approved Methods for Sampling of Air Pollutants in NSW. Air Quality Management Plan (EMP_0002), submitting plans to DoP (not dated), Letter submitting revised plans to DoP (21 October 2008). AEMR 2008, 2007, 2006, submitting plans to DoP (not dated) VISUAL IMPACT Visual Amenity MP 06_ The Proponent shall minimise the visual impacts of the project to the satisfaction of the Director-General. Detailed in AEMRs, which are submitted to DoP for review, therefore satisfaction of Director- General is assumed. Lighting Emissions MP 06_ The Proponent shall: (a) take all practicable measures to mitigate off-site lighting impacts from the project; and (b) ensure that all external lighting associated with the project complies with Australian Standard AS4282 (INT) 1995 Control of Obtrusive Effects of Outdoor Lighting, to the satisfaction of Council, the DPI and the Director-General. AEMR 2008, 2007, Some complaints received about lighting, AEMR 2008, 2007, investigations were made and mitigative action was taken. This is outlined in AEMR which is submitted to Council, DPI and DoP, therefore satisfaction of these departments is assumed. Recommendation : AEMR or lighting protocol should state that external lighting is undertaken in accordance with AS4282. P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.2 Reports Final\N _Audit_Protocol_13Jan10.xlsx 3 13/01/2010

28 Document Point # Requirement Verification/Comment Documentary Evidence # Audit Finding ABORIGINAL CULTURAL HERITAGE Aboriginal Cultural Heritage Management Plan MP 06_ The Proponent shall prepare (and following approval implement) an Aboriginal Cultural Heritage Management Plan, to the satisfaction of the Director-General. The Plan shall be prepared in consultation with DEC and the Aboriginal communities, and be submitted to the Director-General by the end of March The Plan must include: (a) measures to protect and preserve identified Aboriginal sites on the mine site; (b) a monitoring program for identified Aboriginal sites; and (c) a protocol for the ongoing consultation and involvement of the Aboriginal communities in the conservation and management of Aboriginal cultural heritage on the site. Plan submitted to DoP, no correspondence received from DoP to indicate approval. March 2007 version of the Plan (EMS 002-4) outlines consultation undertaken with DEC and Aboriginal communities. Aboriginal Cultural Heritage Mgmt Plan (EMP_0004) and (EMS 002-4), submitting plans to DoP (not dated), Letter submitting revised plans to DoP (21 October 2008). TRAFFIC & TRANSPORT Coal Transport MP 06_ From no later than 31 December 2011, the Proponent shall cease truck haulage of coal from the mine to the Camberwell CHPP, with all ongoing transport via overland conveyor. Letter from DoP (dated 28/08/09) confirming modification to consent to extend the timeline until MP 06_0057 By 31 December 2009, the Proponent must submit a report to the Director-General detailing the status of investigations and plans for constructing the overland conveyor. An updated report Interviewed Chris Smith, who confirmed that must be submitted to the Director-General by the end of each subsequent quarter, until construction of the conveyor is completed. report will be submitted within December, and subsequent quarterly reports will be submitted. MP 06_0057 Truck haulage (along the RL 100 haul road) may continue to be undertaken in emergency circumstances or during maintenance of the overland conveyor. In these situations, the Proponent shall advise the Director-General and Council in writing of the need to haul coal by truck. Local Road Maintenance Contributions MP 06_ The Proponent shall pay reasonable contributions to Council for the ongoing maintenance of Forest Road, Middle Falbrook Road, Stony Creek Road and Bridgman Road, to the satisfaction of the Director-General. GREENHOUSE GAS MP 06_ The Proponent shall: (a) monitor or calculate the greenhouse gas emissions generated by the project; (b) investigate ways to reduce greenhouse gas emissions on site; and (c) report on these investigations in the AEMR, to the satisfaction of the Director-General. AEMR submitted to DoP, therefore satisfaction of Director-General is assumed. Methane re-use investigated. Invoices from Council and relevant remittance advice. Greenhouse Gas Mgmt Plan (EMP_0006), AEMR 2008, 2007, WASTE MINIMISATION MP 06_ The Proponent shall minimise the amount of waste generated by the project to the satisfaction of the Director-General. AEMR submitted to DoP, therefore satisfaction of AEMR 2008, 2007, 2006 Director-General is assumed. HAZARDS MANAGEMENT Spontaneous Combustion MP 06_ The Proponent shall take the necessary measures to prevent, as far as is practical, spontaneous combustion on the site. Chris Ellis confirmed no spontaneous combustion Spontaneous Combustion Hazard Mgmt Plan incidents have occurred. (HMP_0103), AEMR 2008, 2007, Dangerous Goods MP 06_ The Proponent shall ensure that the storage, handling, and transport of dangerous goods is done in accordance with the relevant Australian Standards, particularly AS1940 and AS1596, Explosives and diesel are stored on site. Workcover Acknowledgement of Notification (7 and the Dangerous Goods Code. Aug 09), ShotFiring & Explosives Hazardous Mgmt Plan (HMP_0108), AEMR 2008, 2007, BUSHFIRE MANAGEMENT MP 06_ The Proponent shall: (a) ensure that the project is suitably equipped to respond to any fires on-site; and (b) assist the Rural Fire Service and emergency services as much as possible if there is a fire onsite during the project. Site inspection. Chris Ellis confirmed there have been no fires on site as yet. AEMR 2008, 2007, 2006 P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.2 Reports Final\N _Audit_Protocol_13Jan10.xlsx 4 13/01/2010

29 Document Point # Requirement Verification/Comment Documentary Evidence # Audit Finding MINE CLOSURE STRATEGY MP 06_ At least 3 years prior to the cessation of mining, the Proponent shall prepare a Mine Closure Strategy for the development, in consultation with Council, DPI and DEC, and to the satisfaction of the Director-General. The plan must: (a) define the objectives and criteria for mine closure; (b) investigate options for the future use of the site, including the pit top and surface facilities area; (c) investigate ways to minimise the adverse socio-economic effects associated with mine closure, including reduction in local employment levels; (d) define a strategy for the ongoing management of water inflow to the mine; (e) describe the measures that would be implemented to minimise or manage the ongoing environmental effects of the development; and (f) describe how the performance of these measures would be monitored over time. REHABILITATION MANAGEMENT PLAN MP 06_ The Proponent shall prepare and implement a Rehabilitation Management Plan for the development to the satisfaction of the DPI and Director-General. This plan must include: (a) the objectives for rehabilitation of the site; (b) a description of the short, medium, and long term measures that would be implemented to rehabilitate the site and manage the remnant vegetation and habitat on the site; (c) detailed performance and completion criteria for the rehabilitation of the site; (d) a detailed description of how the performance of the rehabilitation of the site would be monitored over time to achieve the stated objectives; (e) a detailed description of what measures and procedures would be implemented over the next 3 years to rehabilitate the site; (f) a description of the potential risks to successful rehabilitation and/or revegetation, and a description of the contingency measures that would be implemented to mitigate these risks; and (g) details of who is responsible for monitoring, reviewing, and implementing the plan. Rehabilitation Mgmt Plan (EMP_0009), Letter submitting Plan to DoP (30 November 2009), submitting Plan to DPI (30 December 2009). SCHEDULE 4 - ADDITIONAL PROCEDURES FOR AIR QUALITY AND NOISE MANAGEMENT NOTIFICATION OF LANDOWNERS MP 06_ If the results of monitoring required in schedule 3 identify that impacts generated by the project are greater than the relevant impact assessment criteria in schedule 3, then the Proponent shall notify the Director-General and the affected landowners and/or existing or future tenants (including tenants of mine owned properties) accordingly, and provide quarterly monitoring results to each of these parties until the results show that the development is complying with the criteria in schedule 3. INDEPENDENT REVIEW MP 06_ If a landowner (excluding mine owned properties) considers the project to be exceeding the impact assessment criteria in schedule 3, then he/she may ask the Proponent in writing for an independent review of the impacts of the project on his/her land. If the Director-General is satisfied that an independent review is warranted, the Proponent shall within 3 months of the Director-General advising that an independent review is warranted: (a) consult with the landowner to determine his/her concerns; (b) commission a suitably qualified, experienced and independent person, whose appointment has been approved by the Director-General, to conduct monitoring on the land, to determine whether the project is complying with the relevant criteria in schedule 3, and identify the source(s) and scale of any impact on the land, and the project s contribution to this impact; (c) give the Director-General and landowner a copy of the independent review. MP 06_ If the independent review determines that the project is complying with the relevant criteria in schedule 3, then the Proponent may discontinue the independent review with the approval of the Director-General. MP 06_ If the independent review determines that the project is not complying with the criteria in schedule 3, and that the project is primarily responsible for this non-compliance, then the Proponent shall: (a) take all practicable measures, in consultation with the landowner, to ensure that the project complies with the relevant criteria; and (b) conduct further monitoring to determine whether these measures ensure compliance; or (c) secure a written agreement with the landowner to allow exceedances of the relevant criteria in schedule 3, to the satisfaction of the Director-General. If the additional monitoring referred to above subsequently determines that the project is complying with the relevant criteria in schedule 3, then the Proponent may discontinue the independent review with the approval of the Director-General. If the Proponent is unable to finalise an agreement with the landowner, then the Proponent or landowner may refer the matter to the Director-General for resolution. If the matter cannot be resolved within 21 days, the Director-General shall refer the matter to an Independent Dispute Resolution Process (see Appendix 3). MP 06_ If the independent review determines that the relevant criteria in schedule 3 are being exceeded, but that the project and another project/mine are responsible for this exceedance, then the Proponent shall, together with the relevant project/mine: (a) take all practicable measures, in consultation with the landowner, to ensure that the relevant criteria are complied with; and (b) conduct further monitoring to determine whether these measures ensure compliance; or (c) secure a written agreement with the landowner to allow exceedances of the relevant criteria in schedule 3, to the satisfaction of the Director-General. If the Proponent is unable to finalise an agreement with the landowner and/or other project/s, then the Proponent or landowner may refer the matter to the Director-General for resolution. If the matter cannot be resolved within 21 days, the Director-General shall refer the matter to an Independent Dispute Resolution Process (see Appendix 3). MP 06_ If the landowner disputes the results of the independent review, either the Proponent or the landowner may refer the matter to the Director-General for resolution. If the matter cannot be resolved within 21 days, the Director-General shall refer the matter to an Independent Dispute Resolution Process. Sighted examples of initial notification and quarterly follow up notification. No written correspondence received from landowners requesting independent review. Notification to DoP (28 April 2009 and 28 July 2009), Notification to landowners (28 April 2009 and 28 July 2009). P:\JobNCL\NCL\N7\N \N70045 Integra Audit\5. Delivery\5.2 Reports Final\N _Audit_Protocol_13Jan10.xlsx 5 13/01/2010