Bulli Seam Operations Surface Water Management Plan

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1 Bulli Seam Operations Surface Water Management Plan Bulli Seam Operations Surface Water Management Plan

2 DOCUMENT SIGN OFF SHEET AND REVISION LOG Document Owner: Peter McMillan 27/06/2018 (Name) (Date) Authorised by: Peter McMillan 27/06/2018 (Name) (Date) VERSION HISTORY VERSION DESCRIPTION OF CHANGES DATE 1.0 Original Document September Addressed comments from government agencies December Update following Triennial Independent Audit October 2014 The following changes have been made following the BSO consent amendment - Updated Roles and Responsibilities References to parent company - References to documents update January Minor changes following feedback from the Department of Planning and Environment Minor changes following feedback from the Department of Planning and Environment April 2018 June 2018 PERSONS INVOLVED IN THE REVIEW OF THIS PLAN INCLUDE: NAME TITLE EXP (YRS) Peter McMillan Environment Supervisor 9 Michelle 5 Environmental Officer Grierson Kim Vaux Specialist Mining Approvals 10 Page 2 of 40

3 CONTENTS 1 Introduction Plan Objectives Scope Consultation Roles and Responsibilities Legislation and Planning Project Approval Conditions Relevant Legislation and Licences Guidelines and Standards Baseline and Water Balance Operational Water Management Operational Water Management - Summary Minewater Management Surface and Stormwater Runoff Management Surface Water Discharges Effluent Treatment and Management Water Supply Water Storage Facilities (Surface) Other Issues Management Risk Identification and Control Summary Improvement activities (5, 7 and 10 years) Monitoring, reporting and review Monitoring Program Surface Water and Stream Impact Assessment Criteria Reporting Review of Surface Water Management Plan Independent Environmental Audit Complaints and non-compliance management Complaints and Dispute Resolution Compensatory Water Supply Non-Compliance, Corrective Action and Preventative Action Notification of Pollution Incident to Government Authorities and the Public References Acronyms Plans/Appendices Plan 2: Surface Water Drainage and EPL 2504 Points Appin East Plan 3: Surface Water Drainage and EPL 2504 Points Appin West Plan 4: Surface Water Drainage and EPL 2504 Points West Cliff (South Site) Plan 5: Surface Water Drainage and EPL 2504 Points West Cliff (North Site) Plan 6: Bulli Seam Operations Water Reporting Framework (Water Balance) APPENDIX B: BSO Project Environmental Assessment Commitments APPENDIX C: Consultation with Agencies APPENDIX D: Triennial Independent Environmental Audit Findings (Surface Water) Page 3 of 40

4 1 INTRODUCTION The Bulli Seam Operations (BSO) incorporates the underground mining and associated surface activities at the Appin and West Cliff mines, which extract coal from the Bulli Seam. Appin and West Cliff mines are located approximately 25 kilometres (km) north-west of Wollongong in New South Wales (See Plan 1). These mines are owned and operated by Illawarra Coal Holdings Pty Ltd (ICHPL), a wholly owned subsidiary of South32. ICHPL received Project Approval from the NSW Department of Planning and Infrastructure (DoPI) on the 22nd December 2011 for current and proposed mining of the Bulli Seam Operations for the next 30 years, and production of up to 10.5 Mt/pa of ROM coal. This approval incorporates underground mining, transport and emplacement activities undertaken 24 hours a day, seven days per week. This Surface Water Management Plan (SWMP) has been prepared to detail the control measures, compliance procedures, monitoring programs, evaluation protocols, notification and communication processes for surface water management for the BSO. This plan has been prepared to satisfy Schedule 4, Condition 16 of the BSO approval. 1.1 Plan Objectives This SWMP has been prepared to comply with the intent and requirements of Schedule 4, Condition 16 of the BSO approval. The objectives of this SWMP are to: 1.2 Scope Establish responsibilities for the surface water management across the BSO operations; Comply with all relevant regulatory requirements, Environmental Protection Licence 2504 and South32 policies and standards for water management; Describe the water management systems including measures to comply discharge limits and minimise potable water usage; Outline the framework for water monitoring, auditing and reporting; Provide a water balance for the project including sources, usage and discharge quality; Outline the process to reduce the impacts on biota from the Brennans Creek dam discharge; and Specify investigation and communication processes in response to water related issues and complaints. The SWMP applies to all existing and future activities related to the Bulli Seam Operations Project including surface water management for operational and construction needs at: Appin East, Appin West and West Cliff (Appin North) pit top areas; Appin No. 1, No. 2 and No. 3 shaft sites; Douglas North Substation; West Cliff CPP; West Cliff Coal Wash Emplacement; and Vent Shaft 6 Refer to Plan 1 for locations of the above. 1.3 Consultation As required by the Project Approval (Schedule 4, Condition 16), the initial version of the SWMP was provided to the DoI Water (formerly NSW Office of Water NOW) and the Environment Protection Authority (EPA) for review. The comments from the consultation process have been incorporated into the current version of the management plan. Page 4 of 40

5 2 ROLES AND RESPONSIBILITIES The table below outlines the roles and responsibilities associated with the implementation and periodic review of this plan. Table 1: Roles and Responsibilities Role Responsibilities Site Environmental Representatives Environmental Supervisor Maintenance and Operations Supervisors. Site Maintenance Managers. Corporate Affairs Lead of Health, Safety and Environment (ICH) Environmental Supervisor West Cliff CPP Manager Mine Site Managers Meeting the commitments (including monitoring, auditing, investigation and reporting) for the operational areas contained within this management plan. Implementation and periodic review of this Management Plan. Operation and maintenance of surface infrastructure in accordance with the design specification/s. Meeting the commitments contained within this management plan in relation to stakeholder engagement. Provide the necessary resources and systems to meet the requirements of this Management Plan. Page 5 of 40

6 3 LEGISLATION AND PLANNING 3.1 Project Approval Conditions Potential surface water usage and impacts associated with the BSO project were addressed in the BSOP Environmental Assessment (EA) The EA was assessed and approved under the Environmental Planning and Assessment Act 1979 (EP&A Act) and associated Regulations. Appendix A outlines the surface water management requirements of the project approval and cross references where the requirements have been addressed within this Plan. Appendix B summarises the requirements of the commitments included within the EA and cross references where the requirements have been addressed within this Plan. Appendix C summarises the feedback from the consultation with the relevant agencies and cross references where the feedback/comments have been addressed within the Plan. 3.2 Relevant Legislation and Licences Key regulatory and surface water management plan obligations applicable to the BSO are managed via an online compliance management system. The online system can be accessed from the following link (internal access only). The obligations are allocated to responsible site or office personnel. The process is managed in accordance with the following Illawarra Coal (internal) procedures: Legal Compliance (ICHP0105) Compliance Evaluation (ICHP0100). Legislation applicable to water, erosion and sediment control management includes but is not limited to: Protection of the Environment Operations Act 1997 (POEO Act); Environmental Planning and Assessment Act 1979; Water Management Act 2000; Water Management (General) Amendment (Aquifer Interference) Regulation 2011; The Mining Act 1992; Sydney Water Catchment Management Act 1998; Soil Conservation Act 1938.Underground Petroleum Storage Systems Regulation 2008 National Environment Protection (National Pollutant Inventory) Measure 3.3 Guidelines and Standards This SWMP has been developed to be consistent with the principles of the following: ISO14001 for Environmental Management Systems. The Bulli Seam Operation mines are certified to ISO South32 Sustainability Policy Other relevant guidelines for the management of surface water include: Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC 2000); Technical Guidelines: Bunding and Spill Management (DECC); National Water Quality Management Strategy: Guidelines for Sewerage Systems Effluent Management (ANZECC/ARMCANZ, 1997); National Water Quality Management Strategy: Guidelines for Sewerage Systems Use of Reclaimed Water (ANZECC/ARMCANZ, 2000c); Environmental Guidelines: Use of Effluent by Irrigation (DEC, 2004); Managing Urban Stormwater Soils and Construction, Volume 1 (Blue Book) (Landcom, 2004); Managing Urban Stormwater Soils and Construction, Volume 2A Installation of services (DECC, 2008); Page 6 of 40

7 Managing Urban Stormwater Soils and Construction, Volume 2C Unsealed Roads (DECC, 2008); Managing Urban Stormwater Soils and Construction, Volume 2D Main Road Construction (DECC, 2008); and Managing Urban Stormwater Soils and Construction, Volume 2E Mines and Quarries (Landcom, DECC). 4 BASELINE AND WATER BALANCE Baseline (EA) A comprehensive environmental assessment was completed for the Appin and West Cliff Collieries in 2009 (Bulli Seam Project Environmental Assessment: Resource Strategies 2009) as part of the Part 3A application. The assessment included comprehensive baseline datasets for rainfall and evaporation, and water flow and quality data for the Nepean River, Georges River, Cataract River, O Hares Creek, Woronora River and Punchbowl Creek catchments and surface water resources. This baseline data can be viewed in the EA (Bulli Seam Operations Project Environmental Assessment / Volume 2 Appendices / Appendix C Surface Water Assessment Baseline Hydrology on pp ) at the following link: Recommendations from the baseline water assessment included in the EA have been considered in the development of this management plan. Water Balance A Water Balance model was developed for the Bulli Seam Operations in line with the Minerals Council of Australia Water Accounting Framework. The Water Balance model for the Bulli Seam Operations is shown in Plan 6. Internal and external measuring points have been installed to monitor the inputs, outputs and recycling to inform the water balance. A water model simulation was conducted as part of the EA and can be accessed (Appendix C Surface Water Assessment Baseline Hydrology on pp ) via the following link: 5 OPERATIONAL WATER MANAGEMENT This section of the plan provides a detailed summary of the operational water management processes that are utilised across the BSO to manage water resources. 5.1 Operational Water Management - Summary Table 2 provides a summary of the water management processes and activities that are implemented to comply with surface water discharge/epl limits. More detail is provided in the proceeding sub-sections. Page 7 of 40

8 Table 2: Water Management Processes and Activities Type Description Storage and Treatment Minewater Blend of process water from underground operations and groundwater inflows that is initially stored in old underground workings (goaf areas). Appin: Underground storage - Areas 1 and 4. Treatment via the Water Filtration Plant located at the Appin West pit top. West Cliff: Underground storage (sumps) and pump out to the Concrete Settling Tanks located adjacent to the Coal Preparation Plant. Treated minewater Minewater that has been treated to a suitable quality for reuse (surface and underground operations) and / or licensed discharge points. Appin: Water from the Water Filtration Plant is stored in the Product water tank prior to delivery underground. West Cliff: Minewater pumped from Area 5 is treated (when required) at the Concrete Settling Tanks prior to being supplied to the West Cliff Washery. Surface and Stormwater Management Clean and potentially contaminated stormwater is separated at each of the sites. Potentially contaminated stormwater is treated, reused and / or discharged via a licensed discharge point. Appin East: Stormwater is chemically treated, settled in the main dam and filtered via a dynasand filter prior to discharge. Appin West Stormwater is settled in the surface water basins and filtered via a stormfilter prior to discharge. Vent Shaft 6 Stormwater is settled in the surface water basins and discharged to Harris Creek. West Cliff: Stormwater is chemically treated, settled in settling dams and stored in Brennans Creek dam for use or discharge. Effluent Effluent is a waste product from site toilets, bathhouse and kitchen facilities. Appin East: Effluent from the toilets and kitchen and bathhouse is connected into the Sydney Water sewage system. Potable water Potable water supplied by Sydney Water is used for drinking, bathhouse facilities, surface cooling systems and hydraulics at West Cliff. A fresh water supply is also used to temporarily dilute discharge from Brennans Creek Dam to reduce salinity levels in-line with the EPL. Appin West Effluent from the toilets, kitchen and bathhouse is treated via a sewage treatment package plant and treated effluent is irrigated on site via a licensed discharge point. West Cliff: Effluent from the toilets, kitchen and bathhouse is treated via a sewage treatment package plant and treated effluent is irrigated on site via a licensed discharge point. Appin and West Cliff: Potable water is either stored in Sydney Water tanks or transferred from the main line to the fresh water supply line at Appin East. Oils and oily water Waste oil and oily waters and stored in waste tanks for off-site treatment. Appin and West Cliff: Oil is removed from oily waters via oil / water separators. Waste oil and oily waters are treated off-site at a licensed waste facility. Page 8 of 40

9 5.2 Minewater Management Appin Mine Minewater is pumped from Appin mine s current mining areas into old mine workings in Area 1 (White panel) and Area 4. The combined storage capacity of Area 1 and Area 4 is in excess of 0.5 GL. Minewater is pumped from Areas 1 and 4 to the Appin West pit top for treatment through the Water Filtration Plant (including desalination). Treated water is recycled back underground as process water with surplus water blended with minewater and discharged via a licensed discharge point. Minewater Make The mining process results in the liberation of groundwater from the coal seam and strata immediately overlying and underlying the working areas of the mine. Groundwater from the Bulli Seam is unsuitable for direct re-use in the mining operations and is transferred into old mine workings in Area 1 (White panel) and Area 4 for solids settling and storage. The combined storage capacity of Area 1 and Area 4 is in excess of 0.5 GL. Minewater is pumped from Areas 1 and 4 to the Appin West pit top for treatment through the Water Filtration Plant (including desalination). Treated water is recycled back underground as process water with surplus water blended with minewater and discharged via a licensed discharge point. Underground Supply Process water is used underground for machine cooling, controlling dust emissions in active underground mining areas, hydraulic oil emulsions, conveyors and fire-fighting purposes. Water supplied to underground operations needs to meet specific minimum water quality requirements for human health and operational needs. The water is sourced from treated mine water (primary supply) or Sydney Water (backup supply). Treatment System The Water Filtration Plant (WFP) provides treated mine water for the underground operations at the Appin Mine. The WFP includes mine dams for solids settlement and nutrient removal, filter units (multimedia, granular activated carbon, and microfiltration units), water softeners and a reverse osmosis unit. The WFP reduces the level of suspended solids and salinity to acceptable levels for underground operations and to meet EPL2504 conditions. Back wash and cleaning waste water from the WFP is returned to Mine dam 2 where it undergoes treatment through the Backwash Treatment Plant (Mine dam aerators, Dynasand filter and sludge separator). Brine from the WFP is transported off site to licensed discharge EPL 3241 Point 5. Waste from the water softener and backwash treatment plant sludge is transported to an appropriate licensed waste facility. West Cliff Minewater Minewater is pumped from West Cliff mine s mining areas into minewater retention sumps, then to the West Cliff surface concrete settling tanks for further settling and chemically assisted treatment (if required). The water is then pumped into the West Cliff Coal Preparation Plant for use in the washing process. Process Water Coal Processing Plant (CPP) process water no longer required by the plant is directed to Pond 3 for initial settlement prior to being gravity fed through the Pond P4A treatment system and ultimately released down into Brennans Creek Dam for reuse and/or discharge via a licenced discharge point. Treatment System The Concrete Settling Tank treatment system is used to chemically assist coagulation, flocculation and settling of underground mine waters pumped to the surface. The treatment system is located adjacent to the WCCPP and takes the form of large concrete settling tanks. The tanks treat mine dewatering water, with an estimated maximum treatment capacity of 5.5ML/day. The treated water is pumped into the WCCPP for reuse. Page 9 of 40

10 The concrete settling tanks are operated separately and independently of the Pond P1/P2/P3/P4A surface runoff system, as that system has been designed exclusively to treat surface stormwater runoff. The concrete tanks are required to be cleaned out (i.e. sediment to be removed) periodically to ensure the treatment system operates efficiently. The clean out of this system is coordinated by the West Cliff CPP Supervisor. Periodic inspections are completed by the site environmental representative to ensure the system is operating and associated chemical storage is adequately bunded. 5.3 Surface and Stormwater Runoff Management Appin East The surface water drainage and EPL2504 Points at Appin East is shown in Plan 2. A summary is provided below. Clean Stormwater Catchment Clean stormwater from undisturbed areas around the site is diverted around the Appin East Pit Top to avoid potential contamination. Mine Entrance and Sheriff Roads Catchment Stormwater runoff from the Mine entrance and Sheriff Roads is diverted into a treatment system that is designed to capture the first flush after rain events. The treated stormwater is then pumped into the Main dam for use in the stockpile suppression system or truck wash facility. During rainfall events, the system is designed to capture the first flush (136kL), the captured water is transferred into the Main dam. During heavy rainfall events (above the capacity of the first flush system), clean stormwater overflows from the first flush system into the Georges River. Disturbed and Potentially Contaminated Surface and Stormwater Catchments Surface and stormwater from the internal roads, workshop, stockpile and other disturbed areas is directed to the silt trap (for settlement of coal fines and other particulates) via the chemical treatment system. A slurry pit is in place at the base of the surface elevator belt to capture coal fines. Coal fines are removed from the slurry pit, Main dam silt trap, Main dam and settling pond, and placed onto the drying areas (adjacent to the coal bins or on the coal stockpile) on an as required basis. Water from the Main dam is used as the primary water supply for the following activities: dust suppression sprays on the stockpiles and internal roads; water cart supply; truck wheel wash; and other surface uses including washdown water and fire supply. Appin West The surface water drainage and EPL2504 Points at Appin West are shown in Plan 3. A summary is provided below. Clean Stormwater Catchment Clean stormwater from undisturbed areas around the site is diverted around the Appin West Pit Top to avoid potential contamination. Disturbed and Potentially Contaminated Surface and Stormwater Catchment Storm and surface water from disturbed and potentially contaminated areas is diverted to the surface basins. The catchment includes the pit top, stormwater drainage system, internal roads, hardstand areas, car park and the workshop. Surface water from the sealed areas around the workshop and store which has the potential to be contaminated with oily water is sent to Basin 1. All other surface water can be transferred to either Basin 1 or Basin 2. The surface water management system (basins and Storm Filter System) is designed to capture and treat a 1 in 10 year, 72 hour duration rainfall event. Surface water is treated to reduce suspended solids, oil and Page 10 of 40

11 grease, odour and nutrient load prior to discharge into Sandy Gully (Clements Creek) via a licenced discharge point. West Cliff The West Cliff Surface Water Management System has been designed to: Collect all groundwater inflows affecting active underground workings and pump them to the surface for treatment with CPP process water (separate from the treatment of surface water runoff); Collect, store, and treat all dirty water surface runoff from rainfall events up to a 1 in 10 year ARI 3 day duration storm; Convey all treated water to Brennans Creek Dam (BCD) for storage and reuse onsite, or discharge to the Upper Georges River; and Control discharges to the receiving aquatic environment (Upper Georges River) and ensure wherever possible that such discharges are environmentally benign or beneficial (neural or positive effect). The SWMS includes a number of onsite drains, treatment systems, and surface water storage/treatment ponds, including Ponds P1 to P7, ponds EP2, EP3, and P4A with a combined storage capacity of over 200 ML. This infrastructure is used to store and treat all site dirty surface runoff from coal stockpile areas, haul roads, active coal wash emplacement areas, and process flows from the CPP and underground mine water The surface water drainage and EPL2504 Points at West Cliff are shown in Plans 4 and 5. A summary is provided below. Clean Water Catchment The segregation of clean and dirty water is an important feature of the site water management system as it minimizes the clean catchment area draining to the active emplacement catchment, and ensures that the emplacement water management system is not overloaded. The Brennans Creek clean water diversion channels are located to the: South West of the emplacement area; and Adjacent to Brennans Creek on both sides of the valley. These clean water diversion channels have been established to divert clean water runoff around the active emplacement area and dirty water ponds EP2 and EP3. The clean water diversion system must be maintained throughout the operational lifetime of the emplacement area to ensure that the amount of clean water catchment draining to the emplacement water treatment system is minimized Stormwater runoff from the pit top (South Site) office/administration area is considered clean and directed to Brennans Creek via the Brennans Creek diversion channel around the emplacement. Stormwater runoff from emplacement areas with established landform (with vegetation spread) is considered to be clean runoff and is directed to the clean water diversion system to minimise the load entering the emplacement water management system. Disturbed and Potentially Contaminated Catchment A number of smaller storage ponds located within the North Site also form part of the site water management system. Their function is summarised as follows: Pond P1 (23ML) captures runoff from coal stockpile areas, with controlled release and spill to Pond P2; Pond P2 (24ML) captures runoff from adjacent coal stockpile areas. Water from Pond P2 is gravity fed to the concrete settling tanks at the West Cliff CPP or spills to Pond P4; Pond P3 (23ML) is located adjacent to the concrete settling tanks at the West Cliff CPP. Water from Pond P3 is either pumped back to the settling tanks (if required) or gravity fed to P4A. Spill from Pond P3 reports to Pond P4.; Page 11 of 40

12 Pond P4A captures overflow from P3 and the active emplacement area. Inflow water is dosed with flocculant to facilitate solids removal. Clean water from P4A is discharged to a clean water diversion drain which flows into BCD. Pond P5 (33ML) is located adjacent to a ROM coal stockpile area north of the West Cliff CPP area. Water is released from Pond P5 to Ponds P6 and P7; and Ponds P6/P7 (21ML) are located immediately downslope of Pond P5. Inflow water is dosed with flocculant to facilitate solids removal. Water from the ponds is discharged to BCD. Pond EP2/EP3 (68ML) are located downstream of the active emplacement area. The first catch pond is used for primary settlement prior to the water being dosed with flocullant and released into the second catch pond for settlement prior to discharge to BCD. In summary, the majority of water used at West Cliff is recycled from stormwater or treated underground minewater. Prior to storage in BCD, the water passes through water treatment systems which use chemicallyassisted coagulation, flocculation and settling. Prior to reuse or storage, BCD water is pumped from the dam through a chlorination plant to reduce microbiological growth, into the: North Tank, South Tank; or Underground workings water system via the water supply borehole. Water is pumped from BCD through a chlorination plant to reduce microbiological growth, into North Tank. Water from the North Tank is used for firefighting capacity for the North Site, make-up requirements for the West Cliff CPP, methane gas plant, for semi-trailer wash down and to supply the South Tank, located at the South Site. The South Tank is used to provide water for fire-fighting capacity at the South Site and to supply bath house and vehicle wash down requirements The key aspects of the system are provided in more details in the following sub-section. Dirty Water and No 4 Stockpile Dirty water from stockpiles (with the exception of Stockpile No.4) and workshop areas is diverted to Pond P1, P2 or P3 prior to being transferred to Pond P4A for treatment. The treated water is then gravity fed down to BCD for reuse or discharge. Runoff from No.4 Stockpile is treated in Ponds P5, P6 and P7 prior to being gravity fed into BCD via the adjacent valley. The management of water levels in each of the ponds is reliant on manual processes such as visual observations of pond volumes, and cumulative pumping rates. The levels are heavily influenced by rainfall events and hence the ponds are generally kept empty during dry periods as this allows for sufficient storage capacity to capture and treat rainfall events as per their design specifications. Active Emplacement Area Runoff Runoff from the active emplacement areas (or areas where the vegetation has not yet been spread) is directed to the emplacement water management system (i.e. Ponds P4, EP2, and EP3) for treatment prior to being gravity fed to BCD. The emplacement water treatment system is designed for a: 1 in 10 year 72 hour duration storm event; and Maximum active emplacement area of 21 hectares. The active emplacement area draining to Pond P4, EP2, and EP3 is maintained at or below 18ha. If additional treatment is required prior to delivery into BCD (i.e. during/following a rainfall event), the water can be re-circulated through the EP2 (or future EP3) dosing flume to improve the water quality. Clean catchment areas (including rehabilitated emplacement areas) are diverted around the emplacement water treatment system, either via the Brennans Creek diversion channel or the clean water cutoff drains. Page 12 of 40

13 Emplacement under Drainage Emplacement under-drainage flows are generally clean. The emplacement under-drainage is pumped to the clean water diversion channel for release into BCD. If required (ie. If the water is turbid), the underdrainage can be directed into the emplacement dirty water system. Overflow from the emplacement under-drainage system feeds directly to the emplacement water treatment system. Vent Shaft 6 Surface runoff that was captured on site during the construction phase was treated with flocculent in surface dams prior to discharge into Harris Creek via LDP 36. Vent Shaft 6 site has since moved into operation phase and the majority of the construction site is either vegetated or sealed so surface runoff no longer requires treatment under normal operating conditions. 5.4 Surface Water Discharges Water releases from the Bulli Seam Operations Pit Tops are undertaken in accordance with the requirements of EPL2504. A summary of EPL 2504 monitoring points is shown in Table 3. Additional commentary for each of the operational sites is provided in the following sub-sections. Table 3: Licenced Discharge Points Surface Waters LDP Description Receiving Environment Monitoring Frequency West Cliff Point 1 Overflow (spillway) from Brennans Creek Dam Brennans Creek / Georges River N/A N/A Point 3 Spray irrigation to utilisation area West Cliff and North Cliff Collieries N/A N/A Sample Method Point 4 Discharge Quality Monitoring. Volume Monitoring. - West Cliff and North Cliff Collieries. Sampling tap in settling chamber of STP. Monthly during discharge Water grab sample Point 10 Discharge from Brennans Creek Dam Brennans Creek / Georges River Monthly during Discharge Continuous during discharge Water grab sample In Line Instrumentation Point 11 Located in the Georges River upstream of Brennans Creek confluence Point 12 Located in the Georges River downstream of Brennans Creek confluence --- Monthly during discharge --- Monthly during discharge Water grab sample Water grab sample Point 13 Volume monitoring West Cliff and North Cliff Collieries. Appin East FM13 on map titled Bulli Seam Operations Point 10 Discharge Water EPL Variation dated 12 January 2015 Continuous during discharge In Line Instrumentation Point 18 Underflow from the filter lagoon Georges River Monthly during discharge Point 19 Dynasand Filter outlet Georges River Monthly during discharge Point 21 Overflow (spillway) from the site main dam Georges River Monthly during discharge Water grab sample Water grab sample Water grab sample Page 13 of 40

14 LDP Description Receiving Environment Monitoring Frequency West Cliff Appin West Sample Method Point 23 Stormwater discharge Sandy Gully / Nepean River Monthly during discharge Point 24 Minewater discharge Sandy Gully / Nepean River Monthly during discharge Water grab sample Water grab sample Point 25 Overflow (spillway) from the sand filtration dam Sandy Gully / Nepean River N/A N/A Vent Shaft No.6 Point 36 Discharge from the primary sediment pond Harris Creek / Nepean River Monthly during discharge Water grab sample The monitoring requirements and licence limits for the BSO can be accessed via the following link: Environmental monitoring (sampling) required under EPL2504 is undertaken by suitably trained site environmental representatives with the lab analysis performed at a NATA accreditated laboratory. Appin East The first flush from the entrance road and Sherriff Road is diverted into the Main Dam. Clean stormwater and clean overflows from the first flush system are diverted into the Georges River. Excess surface and stormwater from the main dam is treated and settled in the Sediment Dam. After settling occurs treated surface and stormwater is filtered via a Dynasand filter and discharged into the Georges River via EPL2504 Point 19. During high rainfall events, the main dam may spill to the Georges River via EPL2504 Point 21. Appin West Surface water is settled in the stormwater basins, then filtered via the Stormfilter which reduces suspended solids, oil and grease, odour and nutrient load prior to release via EPL2504 Point 23. During high rainfall events, the surface water basins may spill to Sandy Gully via the main spillway (designed for a 1 in 1000 year rainfall event) at EPL2504 Point 25 to protect the integrity of the dam walls. Mine water is treated at the Water Filtration Plant, resulting in a reduction in suspended solids, electrical conductivity, nutrient load and metals. Treated mine water is discharged into Sandy Gully via EPL2504 Point 24. West Cliff Releases from BCD are authorized via licensed discharge points Point 1 (spillway) and Point 10. Quality criteria as well as a number of Pollution Reduction Programs to drive continuous improvement are set by the NSW EPA. Details of the current Pollution Reduction Programs are provided in the Environmental Protection Licence Water is continuously discharged from BCD under controlled conditions to minimise uncontrolled releases over the BCD spillway to Georges River past LDP1 to: Minimise the impact to the aquatic environment in Georges River; Control discharges to Georges River to control ph levels; Provide dry weather environmental flow (where required); and Provide sufficient capacity and settlement time for treatment after rainfall events. Page 14 of 40

15 The volume of BCD to its spillway is 320ML, with a maximum depth behind the dam wall of 12.5m. A target depth in the dam is maintained to provide security of supply and to accommodate rainfall events. 5.5 Effluent Treatment and Management Effluent irrigation from the Bulli Seam Operations Pit Tops are undertaken in accordance with the requirements of EPL2504. A summary of EPL 2504 monitoring points relevant to effluent irrigation is shown in Table 4. Additional commentary for each of the operational sites is provided in the following sub-sections. Table 4: Licenced Discharge Points Effluent Irrigation LDP Description Receiving Environment West Cliff Point 3 / 4 Spray Irrigation onto grassed utilisation area On-site Appin East Point 20 Spray irrigation onto grassed utilisation area On-site (No longer utilised) Appin West Point 22 Spray irrigation onto grassed utilisation area On-site Appin West Bathhouse water and sewage is treated at the Appin West site through a primary aeration pond and a Smith and Lovelace Sewage Treatment Plant (STP) that discharges into a holding pond. The treated effluent is spray irrigated via EPL2504 Point 22 onto the Licensed Irrigation Area (located on-site). Appin East The primary method for disposal of Bathhouse waters (grey waters) and sewage effluents (black waters) is through the Sydney Water wastewater system (low pressure sewer connection). Prior to connection to the sewer in February 2015, Appin East sewage was treated via an Envirocycle System, then spray irrigated via EPL2504 Point 20 onto the Licensed Irrigation Areas. West Cliff Sewage from bathhouse and toilet facilities is treated on site using a Smith and Lovelace Sewage Treatment Package Plant (STP). Treated effluent is used to irrigate via EPL2504 Point 4 to a dedicated irrigation area (located on-site). 5.6 Water Supply Water Supply Potable water is supplied to the Appin East, Appin West and Vent Shaft 6 sites by Sydney Water via mains connections to the Sydney Water network. Potable water is supplied to the West Cliff site via: An overland pipeline to the WCCPP/WestVAMP from the Appin East A fresh water supply pipeline - used to temporarily dilute discharge from Brennans Creek Dam to reduce salinity levels in-line with the EPL. This pipeline will be used as future water supply to the West Cliff (Appin North) Washery during drought as projects under PRP19 are completed.; and Tanker to the remainder of the West Cliff site. Potable water capacities are contained in Table 5, Table 6 and Table 7. Potable water is used in the administration buildings, workshops and bathhouse. Potable water is also used in areas that require high quality water, including: Page 15 of 40

16 Water for the longwall hydraulics emulsion; and Underground supply at Appin Mine (above that which is provided from the Appin West Water Treatment Plant). Vent Shaft 6 Water is extracted from the Nepean River and used on site for operational purposes. The water is extracted under the Surface Water License No. 10WA117285, issued by NSW Office of Water (NOW) on the 15 November The Licence allows up to 53 ML to be diverted - Comprising of 40 ML for mining use and 13 ML for industrial use in any one year commencing 1 July. 5.7 Water Storage Facilities (Surface) The Bulli Seam Operations stores and treats water for operational needs via a number of storage bodies as listed in Table 5, Table 6 and Table 7. Table 5: Key Water Storages at Appin East Facility Capacity (kl) Comments Bathhouse water and treated effluent Bathhouse tank wastewater 24 Concrete tank which collects the bathhouse water for daily pumpout and disposal into the local sewage system by a licensed contractor. Sewage treatment tanks 34 Set of 5 concrete tanks for aeration and primary and secondary settlement of sewage for the EnviroCycle sewage treatment system. Fresh Water Green Tank 1,400 Provides water for underground mining operations and WestVAMP power station. Water can be supplied to the tank from the Water Filtration Plant or Sydney Water. The Tank is set up with an emergency valve to ensure 200kL of fire water is available at all times. Yellow Tank 600 Provides potable water supplied by Sydney Water: Onsite for offices, bathhouse, toilets and workshop. Off site for EDL Power Plant and mine cottages. Potentially contaminated storm and surface waters Main Dam 20,000 This earthen dam is used to capture, treat and recycle surface and stormwater from the Pit Top. Water is harvested from the main dam for dust suppression and the truck wheel wash. Water can also be pumped through the treatment system and into the sediment dam for further treatment and discharge. Sediment Dam 2,000 This dam is used as a settling dam after surface and stormwater from the Main dam has been treated. The treated water can be drawn from the dam to the Dynasand filter for Georges River discharge. Sand filter lagoon 500 Sand filter for the filtration of clean storm water prior to discharge via EPL2504 Point 18. First flush system 136 Collects and treats potentially contaminated storm water from the mine entrance and Sheriff Roads. Surface elevator sump 10 Collects coal fines washed from elevator belt structure. Workshop sump and oil / water separator 9 Collects, stores and treats wastewater from the wash down facility in the Workshop. Page 16 of 40

17 Table 6: Key Water Storages at Appin West Facility Capacity (KL) Comments Potentially contaminated storm and surface waters Surface Water Basin 1 4,000 The surface water dams are kept low to capture and treat storm event. The volume stored is dependent upon rainfall and volume diverted prior to dams for reuse Surface Water Basin 2 3,500 Storage Tank under Coal Bins 1,000 Not currently in use. Available for additional surface water storage. Drying Dam 1,700 Dam is used for the drying of solids as required. Workshop Sump 40 Contains wastewater from the Workshop. Wastewater is pumped into an Oily water separator. Waste oil is transferred to the waste oil tank and clean water is transferred into Surface Water Basin 1. Water Filtration Plant Mine Dam 1 1,900 Currently around 2500kL/day is pumped from the Underground Workings into Mine Dam 1. Mine Dam 2 3,400 Mine Dam 2 is set up as a Biological lagoon to treat the backwash and cleaning wastes from several of the stages of the Water Filtration Plant. Raw Water Buffer Tank 250 Pre-treated mine water storage tank. Acts as an operational buffer to keep Water Filtration Plant operational when underground pumps are being maintained. Product Water Tank 500 Tank stores treated minewater from the Water Filtration Plant for use in underground operations. Bulk storage tanks 2 X 1000 Tank stores RO treated (Process water) from Water Filtration Tank and Sydney water for underground use. Brine Tank 300 Tank stores waste brine from the Desalination Plant process. Brine is transported from site and discharged via a licensed discharge point. Sludge Tank 15 Sludge from the backwash treatment plant is stored ready for transportation off site. MF filtrate tank (under construction expected June/July 2017) 2000 Filtered mine water storage for sustaining of production of the Reverse osmosis system and source of supply for blending waters Potable water Sydney Water Tank 300 Tank stores potable water supplied by Sydney Water. Tank provides potable water supply for offices, bathhouse, cooling towers, toilets, workshop and backup supply for underground operations. The Tank is set up to maintain 200kL of fire water for firefighting. Treated effluent Effluent Pond 1 1,200 Effluent is gravity from the Mutrator, then into the Sewage Treatment Package Plant (STP) for aeration and settling. Pond 1 receives treated effluent from the STP, which then cascades into Effluent Pond 2 1,200 Pond 2. Treated effluent is transferred from Pond 2 to the Effluent Tank. Irrigation Tank 3 Treated effluent is irrigated onto the licensed Irrigation Area from the Irrigation Tank. Underground storage Areas 1 and 4 >500,000 Currently >500ML is stored in old mine workings (Area 1 and Area 4). Page 17 of 40

18 Table 7: Key Water Storages at West Cliff Facility Capacity (kl) Comments North Site Brennans Creek Dam 320,000 Brennans Creek dam is the key water body at West Cliff. It was constructed in the lower reaches of Brennans Creek, downstream of pit top disturbance and the emplacement area. Pond P1 23,000 Captures runoff from coal stockpile areas, with controlled release and spill to Pond P2 Pond P2 24,000 Captures runoff from adjacent coal stockpile areas. Water from Pond P2 is gravity fed to the concrete settling tanks at the West Cliff CPP or spills to Pond P4 Pond P3 23,000 Located adjacent to the concrete settling tanks at the West Cliff CPP. Water from Pond P3 is either pumped back to the settling tanks (if required) or gravity fed to P4A. Spill from Pond P3 reports to Pond P4. Pond P4A 45 Pond P4A captures overflow from P3 and the active emplacement area. Inflow water is dosed with flocculant to facilitate solids removal. Clean water from P4A is discharged to a clean water diversion drain which flows into BCD. Pond P5 33,000 Adjacent to a ROM coal stockpile area north of the West Cliff CPP area. Water is released from Pond P5 to Ponds P6 and P7. Ponds P6/P7 21,000 Downslope of Pond P5. Inflow water is dosed with flocculant to facilitate solids removal. Water from the ponds is discharged to BCD. Pond EP s 68,000 Combined capacity of the emplacement catch pond system. Collects dirty water runoff from the active emplacement area. West VAMP water 500 Stores water from the desalination plant or Sydney Water to be used for cooling purposes. Washery Tanks 455 Supplies the Washery with recycled water. Firefighting supply tanks 1,200 2 tanks (660kL each) which store. The tanks store recycled water for firefighting. South Site Bathhouse water tank 60 Supplies potable water for bathhouse and amenities. Longwall hydraulics 120 Supplies potable water to the longwall hydraulics system. Surface tank 22 Supplies recycled water for surface hose down and fire water. 5.8 Other Issues Management Surface Cooling Towers All operational cooling towers are required to have certified microbial treatment. The treatment systems for the Gas Extraction Plant cooling towers have been certified by a chemical treatment company. The maintenance and microbiological management of cooling and seal water systems is in accordance with the relevant Australian standards. Chemicals and Hydrocarbon Management Storage and Handling The chemical and hydrocarbon products in use within the Bulli Seam Operations are stored in appropriately designed and maintained facilities. SDS s are required for all substances brought onto site by Illawarra Coal and its contractors. The site SDS s are stored in the ChemAlert System and available through ipick to all personnel. The hydrocarbon storages have been assessed as per the requirements of the Underground Petroleum Storage Systems Regulations Page 18 of 40

19 Diesel fuel is brought to Appin East, Appin West and West Cliff sites by road tanker and stored in above ground bunded tanks from where it is transferred to diesel pods for underground use or direct to machinery. Spills and leakages are directed to oil separators to remove the hydrocarbons from the surface water streams. There are a number of oil-water separators within the Bulli Seam Operations to reduce oil contamination into the surface water management systems. Pollution Incident Response Management Plans Inventory Pollution Incident Response Management Plans have been developed in accordance with requirements of the Protection of Environment Operation (General) Amendment (Pollution Incident Response Management Plans) Regulation 2012 for each of the Pit Tops. The objectives of the plans (as per the EPA s Environmental Guidelines for the preparation of pollution incident response management plans are to: Ensure comprehensive and timely communication about a pollution incident to staff at the premises, the Environment Protection Authority (EPA), other relevant authorities and community members who may be affected by the impacts of the pollution incident; Minimise and control the risk of a pollution incident at the facility by requiring identification of risks and the development of planned actions to minimise and manage those risks; Ensure that the plan is properly implemented by trained staff, identifying persons responsible for implementing it, ensuring that the plan is regularly tested for accuracy, currency and suitability. Liquid Waste Management Waste Management (including liquid waste) is conducted in accordance with the BSO Waste Management Plan. Construction Activities Construction activities will be undertaken from time to time across the Bulli Seam operations. When site specific disturbance occurs due to construction activities or remediation works, temporary sediment controls (e.g. sand bags, filter fabric) will be installed where appropriate to intercept sediment movement that may occur during the works and for a period after completion. Erosion and sediment control works will be designed and installed in accordance with applicable erosion and sediment control principles and guidelines (e.g. the requirements of the NSW Blue Book Managing Urban Stormwater Soil and Construction 2004 ). Such measures may include sediment fencing and/or sandbags and coir logs would be proposed for the sediment controls. At the pit tops, runoff water will be directed to site dirty water management system for treatment and discharge. These controls would be maintained as required by removing any excessive build-up of sediment and repairing any failure of the structures e.g. due to storm activity. Mining Induced Subsidence Extraction Plans address the management of potential impacts and / or environmental consequences of mining on water courses and aquifers. Water Management Plans for each of the mining areas are detailed in approved Subsidence Management Plans (SMP) or Extraction Plans and can be accessed, via the following link: Risk Identification and Control Summary A summary of the identified risk and associated controls with respect to water management and minimisation is provided in the Table 8, Table 9 and Table 10 below. Page 19 of 40

20 Table 8: Appin East Surface Water Management and Usage Minimisation Measures Area Potential Water Management Issue Operational Controls Surface and Stormwater management Storage and Handing of Chemicals, Oils and Fuels Oil-Water Separator Contaminated water may exit the site if not contained and treated prior to discharge, resulting in pollution of water and land. Inadequate handling and storage of chemicals, oils and fuels could result in water contamination If the integrity of the oil-water separator(s) is compromised there is potential of oil entering the stormwater system and potentially contaminating the water discharged into waterways, exceeding EPL limits Clean Storm water (from undisturbed areas) is diverted around the site. In extreme rain events some is discharged via Point 18. Surface water (from disturbed and sealed areas) is diverted to storages and treated prior to reuse, or further treated and discharged via Point 19. Continuous monitoring of waters discharged to the Georges River via Point 19 enables alarms to be sent to Control should discharges approach licence limits. Inspection of the surface water drain system is conducted by the Environmental representative as part of the routine inspection program to ensure drains and silt traps on site are maintained. Detailed surface water management measures are outlined throughout the SWMP. Chemicals, oils and fuels are segregated and stored within appropriately covered and bunded areas to prevent spills leaving the site. Inspections of storages are undertaken by site personnel. Multiple oil-water separators are installed across the BSO to treat collected spills and leakages and prevent oil entering the stormwater system. To reduce the potential of a failure of the oilwater separator systems, the systems are regularly maintained using the maintenance system. Removal of waste oil from the separator is undertaken by a licensed contractor. Responsible personnel conduct weekly inspections which include inspecting the condition and levels within the oil-water separators. If there is a failure of the system, contaminated water / oil can be isolated in the Main Dam. Waste Management Inappropriate disposal of waste products, poor waste management and housekeeping have the potential to contaminate and/or impact the surface water management system. Waste is stored, transported and disposed of in accordance with regulatory requirements. Page 20 of 40

21 Table 9: Appin West Surface Water Management and Usage Minimisation Measures Area Potential Water Management Issue Operational Controls Surface and Stormwater management Management of mine water (from underground) Storage and Handing of Chemicals, Oils and Fuels Oil-Water Separator Waste Management Sewage and bathhouse waste water Management Contaminated water may exit the site if not contained and treated prior to discharge, resulting in pollution of water and land. The surface water management system can be impacted by build-up around drains and blockage caused by debris and waste. Minewater is mildly saline and may result in discharges exceeding licence requirements if not stored and treated prior to discharge. Inadequate handling and storage of chemicals, oils and fuels could result in water contamination If the integrity of the oil-water separator(s) is compromised there is potential of oil entering the stormwater system and potentially contaminating the water discharged via POINT s to waterways, exceeding EPL limits Inappropriate disposal of waste products, poor waste management and housekeeping have the potential to contaminate and/or impact the surface water management system. Inadequate treatment or overloading of the sewage treatment system could result in EPL licence non-compliance and pollution to land and water. Clean Storm water is diverted around the site and into Sandy Gully via natural drainage lines. Surface water (from disturbed and sealed areas) is diverted to surface water basins and filtered through a storm water filter system before being discharged into Sandy Gully via Point 23. During high rainfall events, the dams may spill to Sandy Gully via the main spillway (Point 25) to protect the integrity of the dam walls Detailed surface water management measures are outlined throughout the SWMP. Minewater from underground is treated at the Water Treatment Plant prior to reuse or discharged via Point 24. Chemicals, oils and fuels are segregated and stored within appropriately covered and bunded areas to prevent spills leaving the site. An oil-water separator is installed to prevent oil entering the stormwater system. Inspections of storages are undertaken by site personnel. To reduce the potential of a failure of the oilwater separator system, the system is regularly maintained using the maintenance system. Removal of waste oil is undertaken by a licensed contractor. If there is a failure of the system, contaminated water can be isolated in Surface Water Basin 1. Waste is stored, transported and disposed of in accordance with regulatory requirements. Sewage and bathhouse waste is treated on site, with the treated effluent, spray irrigated via the licensed irrigation area. Page 21 of 40

22 Table 10: West Cliff Surface Water Management and Usage Minimisation Measures Area Potential Water Management Issue Operational Controls Surface and Stormwater management Storage and Handing of Chemicals, Oils and Fuels Sewage and bathhouse waste water Management Waste Management Management of mine water (from underground) Oil-Water Separator Uncontrolled, there is potential for contaminated waters to leave the site, resulting in EPL licence non-compliance and pollution to land and waters Inadequate handling and storage of chemicals, oils and fuels could result in water contamination Inadequate treatment or overloading of the sewage treatment system could result in EPL licence non-compliance and pollution to land and water. Inappropriate disposal of waste products, poor waste management and housekeeping have the potential to contaminate and/or impact the surface water management system. Mine waters are saline and have potential to impact surface water environments if discharged untreated. If the integrity of the oil-water separator(s) is compromised there is potential of oil entering the stormwater system and potentially contaminating the water discharged via POINT s to waterways, exceeding EPL limits Clean stormwater (from undisturbed areas) is diverted around the site. Surface water (from disturbed and sealed areas) is diverted to site dirty water management system for treatment and directed into BCD Inspection of the surface water drain system is conducted by the environmental personnel during weekly inspections. Chemicals, oils and fuels are segregated and stored within appropriately covered and bunded areas to prevent spills leaving the site. Oil-Water separators are installed to prevent oil entering the stormwater system. Inspections of storages are undertaken by site personnel. Sewage and bathhouse waste is treated on site, with the treated effluent, spray irrigated via the licensed irrigation area. Waste is stored, transported and disposed of in accordance with regulatory requirements. Coal wash emplacement is managed in accordance with Emplacement Management Plan Mine water is taken from underground, treated and directed to BCD. The water is then either recycled on site or discharged in accordance with EPA licence requirements. To reduce the potential of a failure of the oilwater separator systems, the systems are regularly maintained using the maintenance. Removal of waste oil is undertaken by a licensed contractor. Site personnel conduct weekly inspections, which includes inspecting the condition and levels of the oil-water separators. If there is a failure of the system, contaminated water can be isolated in the dirty water management system. 6 IMPROVEMENT ACTIVITIES (5, 7 AND 10 YEARS) As part of the Part 3A Approval, Illawarra Coal is required to identify and deliver improvement projects that will reduce the impacts on biota in the Georges River as a result of the discharge from the West Cliff site. The below tables provide a summary of the identified projects; the projects are aligned with the requirements of Pollution Reduction Programs 18, 19 and 20 of EPL2504. Note that the projects listed in Table 11 below are still subject to internal approval processes and hence are subject to change. Progress against the listed projects will be provided annually via the Annual Environmental Management Report. 5 Year Horizon Page 22 of 40

23 Table 11: Improvement Activities Proposed for 2018 to 2022 Period Activity/Project Assumptions Expected benefits 2018 to 2022 Complete PRP20 (Aquatic Health) Monitoring Program Water filtration plant upgrades Integrated Membrane plant (part of expansion of current water filtration plant) Modification to the Washery water management system to create a semi-closed loop. Work has commenced on increasing the height of a water fill point from the concrete settling tanks so the water tankers (used for dust suppression) can fill up directly from the closed loop process water. This will help remove excess water from the closed loop reducing spill over volumes to the BCD catchment. Works have also commenced to connect pipework and drainage from Pond1 & Pond 2(stockpile ponds) which when complete will bypass Pond 3 (Pond used in the closed loop for water recycling for the washery) and go straight to Pond 4a (BCD catchment pond). This will reduce the amount of surface water runoff that enters the closed loop system which in turn reduces the amount of water that comes in contact with the washery waters Nil Design works have now been completed and construction of the plant has commenced. Forecast completion of the project has been revised to August Confirm outcomes of the above activities with regards to overall river health. Increase processing capacity of mine water. This project along with the pretreatment upgrade and bulk storage upgrades will increase the total treatment capacity up to 4.7ML/day with an expected average output of 4.2ML/day. Reduce BCD water taken for process water in the Washery. Reduce diversion of Washery waters into BCD 7 to 10 year Horizon Table 12: Improvement Activities Proposed for 2021 to 2025 Date Illawarra Coal Commitment Assumption/s Expected benefits Upgrade water filtration plant to meet the dewatering and supply need of Appin mine Reduce potable water use, improve discharge water quality 7 MONITORING, REPORTING AND REVIEW 7.1 Monitoring Program Licenced Discharge Points Monitoring of licenced discharge points is undertaken in accordance with the requirements of EPL A summary of the licenced discharge points is provided in Section 5, Table 3 of this plan. The monitoring program is designed to: Inform management decisions relevant to operations; Ensure compliance with all regulatory requirements set out in EPL 2504 with regards to water management; and Page 23 of 40

24 Measure the influence of discharge(s) from the site on the Georges River and Sandy Gully/Allans Creek. Note that the monitoring sites and frequencies are subject to change through consultation with the relevant agencies and approving authorities and hence a summary has not been provided in this plan. EPL 2504 provides the most up to date monitoring regime relevant to the licenced discharge points and hence should be used as the main reference point. A copy of the licence is available online via the following link: A summary of the results from the licenced discharge monitoring program is made available to the public (via the South32 website) in accordance with the requirements of the POEO Act. The summary can be accessed via the following link: A more detailed summary of the monitoring results is provided annually via the Annual Review which is also available via the link provided above. Groundwater (Contamination) Monitoring There are a number of groundwater monitoring bores located across the BSO surface facilities which have been strategically positioned to monitor the level and extent of the potential groundwater contamination. The bores are generally located at sites where there is potential for contamination to have occurred in the past (ie. Old Underground Storage Tanks). The location of the monitoring bores and the frequency at which monitoring occurs was developed through discussions with a specialist consultant in 2010 /11, the monitoring program was subsequently endorsed by the EPA. Table 13 below provides a summary of the groundwater (contamination) monitoring bores located across the BSO surface facilities. Table 13: Groundwater (Contamination) Monitoring Bores Surface Facility Reason Monitoring Site Monitoring Frequency Appin East Bores are located in upstream and downsteam of decommissioned UST s. The UST s were removed from site in West Cliff Bore is located downstream of a decommissioned UST. The UST was removed from site un 2010/11 P1 P2 P3 T1 (reference site) BH8 Six monthly Six monthly Six monthly Six monthly Six monthly A summary of the monitoring results is provided annually via the Annual Report. Surface Water Monitoring Subsidence Zones Water monitoring programs for each of the active mining areas are detailed in approved Subsidence Management Plans (SMP) or Extraction Plans which can be accessed, via the following link: SMP s or Extraction plans describe the measures and procedures: to investigate, notify and mitigate any ground or surface water exceedances outline ways to minimise, prevent or offset any adverse impacts to ground or surface water resources. collection of baseline data on surface water quality in creeks and other waterbodies that could potentially be affected by the project; and surface water and stream health impact assessment criteria. Page 24 of 40

25 A summary of the results from the surface water monitoring associated with active mining zones is provided in the End of Panel reports which are also available via the link above. 7.2 Surface Water and Stream Impact Assessment Criteria Surface and stream water quality for operational sites is assessed against the limits (where appropriate e.g. where licence discharge points have specific pollutant concentration limits) of the EPL. For mining areas, stream impact assessment criteria are included in the relevant Extraction Plan. In addition to the above, the Georges River Environmental Improvement Program (EIP2) details a monitoring and improvement program for the Upper Georges River. The program includes:quantitative sampling of macroinvertebrates conducted in line with previous studies Ecological assessment of the sediments using a DNA-based approach, referred to as metabarcoding; In-stream water quality testing; and Laboratory ecotoxicological testing of the discharge water from Brennan s Creek Dam. The full program is available on our website: Reporting The results of water monitoring are compiled and reported to internal and external stakeholders (as required). The reports include: Compliance with Environmental Protection Licence monitoring conditions (updated via South32 website); Compliance with Development Consent and Management Plan compliance criteria; Annual Reports; Environmental Protection Licence Annual Return; NPI; End of Panel reporting for mining areas; and Periodic environmental and operational updates to the CCC. 7.4 Review of Surface Water Management Plan In accordance with Condition 5 of Schedule 6 of the BSO Project Approval, this Plan and associated monitoring program will be reviewed, and if necessary revised, within 3 months, of: the submission of an annual review; the submission of an incident report related to dust that has caused, or threatens to cause, material harm to the environment; the submission of an independent Environmental Audit report; or any modification to relevant Project approval conditions (unless the conditions require otherwise). 7.5 Independent Environmental Audit In accordance with Condition 9 of Schedule 6 of the BSO Project Approval, an independent Environmental Audit of this Plan and air quality monitoring program will be undertaken every three years. The report will be submitted to the Secretary within 6 weeks of completion. The 2013 Audit was conducted by URS. The audit commenced November 2013 and was completed in February 2014; the report was provided to Illawarra Coal on 2nd April A copy of the report was also provided to DoE to satisfy Condition 18 (g) of the EPBC Approval. Recommendations directly related to this Plan and how they have been addressed are summarised in Appendix D. Page 25 of 40

26 The 2016 audit was approved to be postponed by the Department of Resource Assessments at NSW Planning & Environment (Letter dated 1/12/16). The new submission date for the Independent Environmental Audit is 28 February The audit was postponed as the independent audit team was unable to commence by 31 December 2016 and as such there was insufficient time for Illawarra Coal to procure a different team. 8 COMPLAINTS AND NON-COMPLIANCE MANAGEMENT 8.1 Complaints and Dispute Resolution All water related complaints received in relation to the Bulli Seam operations are managed in accordance with the Illawarra Coal procedure, Handling Community Complaints Enquiries and Disputes (Document No. ICHP0112). Upon receipt of a community complaint, preliminary investigations will commence as soon as practicable to determine the likely cause of the complaint using information such as activities being undertaken on site at the time of the complaint and available monitoring data. Additional monitoring may be required to be undertaken to verify and validate community concerns. A response will be provided to the complainant as soon as practicable. This may include the provision of relevant monitoring data if requested. A summary of all complaints received during the reporting year will be provided as part of the Annual Report. 8.2 Compensatory Water Supply Should a privately-owned water supply be adversely affected by BSO mining activities (other than an impact that is negligible), a compensatory water supply will be provided to the land owner. A supply equivalent to the loss attributed to the project will be provided (at least on an interim basis) within 24 hours of the loss being identified. Long term supply will be provided following identification of the most feasible alternative. Such supplies will be provided in consultation with NOW and to the satisfaction of the Secretary, as required by Project Approval Schedule 4, Condition Non-Compliance, Corrective Action and Preventative Action Non-compliance, corrective actions and preventative actions are managed in accordance with the ICHPL Event Reporting and Investigation procedure and ICHPL Corrective Action and Effectiveness Review procedure. These procedures, which relates to all ICHPL operations, details the processes to be utilised with respect to the event reporting and identification of non-conformances, the application of appropriate corrective action(s) to address non-conformances and the establishment of preventative actions to avoid non-conformances. The key elements of the process include: Identification of non-conformance and/or non-compliances: Recording of non-conformance and/or non-compliance in a web-based reporting system; Evaluation of the non-conformance and/or non-compliance to determine specific corrective and preventative actions; Corrective and preventative actions to be assigned to responsible person and entered into a web-based reporting system; and Management review of corrective actions to ensure the status and effectiveness of the actions. Non-compliances with the water related criteria will be reported to all relevant agencies via the Annual Report and EPL Annual Return. 8.4 Notification of Pollution Incident to Government Authorities and the Public The EPA and other relevant agencies are notified of incidents causing or threatening material harm to the environment immediately (as per the Pollution Incident Response Management Plan). The EPA must be notified by telephoning and written details must be provided within 7 days. For any other incident associated with the project, Illawarra Coal will notify the Secretary and any other relevant agencies as soon as practicable. Page 26 of 40

27 9 REFERENCES Illawarra Coal Environmental Aspects and Impacts Register Resource Strategies, 2009, Bulli Seam Environmental Assessment Appin and West Cliff Water management plans Bulli Seam Project Annual Report (AEMR) ISO 14001:2004 Environmental Management Systems Standard Bulli Seam Mining Operations Plan (MOP) / Rehabilitation Management Plan 10 ACRONYMS AR Annual Report CPP Coal Preparation Plant DPE NSW Department of Planning Environment EPA Environmental Protection Authority EPL Environment Protection Licence EP&A Environmental Planning and Assessment HSE Health, Safety and Environment IC Illawarra Coal NPI National Pollutant Inventory POEO Act Protection of the Environment Operations Act P&L Processing and Logistics SIR Significant Incident Report SMP Subsidence Management Plan WestVAMP West Cliff Ventilation Air Methane Project Page 27 of 40

28 Page 28 of 40

29 11 PLANS/APPENDICES Plan 1: Bulli Seam Operations Locality Plan Page 29 of 40

30 BSO Surface Water Management Plan Plan 2: Surface Water Drainage and EPL 2504 Points Appin East Document ID ICHMP0235 Version 4.2 Last Date Updated 27/06/2018 Next Review Date 26/06/2020 Page 30 of 40

31 BSO Surface Water Management Plan Plan 3: Surface Water Drainage and EPL 2504 Points Appin West Document ID ICHMP0235 Version 4.2 Last Date Updated 27/06/2018 Next Review Date 26/06/2020 Page 31 of 40

32 BSO Surface Water Management Plan Plan 4: Surface Water Drainage and EPL 2504 Points West Cliff (South Site) Document ID ICHMP0235 Version 4.2 Last Date Updated 27/06/2018 Next Review Date 26/06/2020 Page 32 of 40

33 Plan 5: Surface Water Drainage and EPL 2504 Points West Cliff (North Site) Page 33 of 40

34 Plan 6: Bulli Seam Operations Water Reporting Framework (Water Balance) Note: Figures shown are total volume used or discharged in Megalitres for FY17 Page 34 of 40