Operational Environmental Management Plan Environment

Transcription

1 Rev Document Number Author Approver / BFO Approver Signature Issue Date Review Date Page 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

2 TABLE OF CONTENTS 1 Introduction Purpose Roy Hill Vision Roy Hill Values Lead Care Think Perform Integrated Management System al Management System EMS Structure EMS Document Structure Roy Hill al and Social Management Plan Plan al Policy al Risk Assessment al Risk Register Legal Requirements Objectives and Targets Do (Implementation and Operation) Operational Control al Performance Standards Operational al Management Plan and Procedures Contractor al Management Plans Roles, Resources, Responsibilities and Accountability Leadership Team General Manager Health, Safety and Manager and Approvals al Superintendents al Advisors Operational Managers and Supervisors Roy Hill Personnel Roy Hill Contractors Training, Competency and Awareness Roy Hill Inductions and Awareness Awareness Training OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

3 7.3.3 Training Register Training Records Communications Internal Communications External Communications Documentation and Document Control Document Management System Hard Copy Documents Updated, Superseded, Obsolete or Withdrawn Documents Controlled Documents Emergency Preparedness and Response Check Monitoring, Measurement and Data Monitoring and Measurement al Data Evaluation of Compliance Audits and Inspections al Reporting Incident and Action Management Incident Reporting and Investigation Corrective and Preventative Actions Control of Records Act (Management Review) Accountabilities Abbreviations Definitions References Review OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

4 TABLES Table 1: EPA Key al Factors...10 Table 2: Key Project Approvals...11 Table 3: Accountabilities...26 Table 4: Abbreviations...27 Table 5: Definitions...28 Table 6: References...29 FIGURES Figure 4-1: Roy Hill Integrated Management System...6 Figure 5-1: EMS Framework...7 Figure 5-2: EMS Document Hierarchy OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

5 1 Introduction 1.1 Purpose Roy Hill recognises that environmental management is an integral component of Roy Hill operations. This is reflected within the Roy Hill Policy (RH-POL-00002). The purpose of this Operational al Management Plan (OEMP) is to outline the environmental management framework, standards, plans and procedures that have been developed to ensure that the Roy Hill Policy objectives are met during the operation of the Roy Hill Mine, Rail and Port. This document provides the environmental management framework for Roy Hill personnel and contractors to ensure that environmental requirements are applied at all work sites during operations. 2 Roy Hill Vision To create a high performing iron ore business where people contribute and realise their full potential. The Management System aims to deliver high performance in environment management by providing a framework for compliance with legal requirements, supporting operational activities to minimise impact to the environment and evaluating, improving and delivering cost effective environmental performance. 3 Roy Hill Values The Roy Hill values help to define how we approach our work on the Project. The values underpin the behaviours that Roy Hill personnel and contractors are expected to demonstrate when undertaking work activities. These values and expectations are outlined below as they relate to environmental management. 3.1 Lead Roy Hill takes accountability for its actions and commits to protecting the environment and community it interacts with. 3.2 Care Roy Hill cares for the environmental values within the Roy Hill community. Roy Hill collaborates within and across teams, and respects individual differences by being open and fair. 3.3 Think Roy Hill combines cross-industry methods, technology and judgement to create innovative and environmentally sustainable solutions. Roy Hill values learning, shares knowledge and carefully considers the environmental impacts of decisions. 3.4 Perform Roy Hill manages risk and focuses on sustainable outcomes by being decisive to deliver results. The Department aims to lead the business in caring for the environment and delivering innovative, sustainable, cost effective and high performance outcomes in environmental management. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

6 4 Integrated Management System The Roy Hill Integrated Management System (Figure 4-1) provides the structure and framework to achieve business goals and objectives and aligns the workforce in the delivery of the Roy Hill Core Values. The implementation of the Integrated Management System ensures the delivery of sustainable outcomes, continual improvement, consistency and reliability at all levels of the business. Figure 4-1: Roy Hill Integrated Management System 5 al Management System The Roy Hill al Management System (EMS) provides the structure and framework for the strategic management of environmental risks and compliance with legal requirements and standards in accordance with the Roy Hill Policy. The EMS provides personnel and contractors with guidance on environmental standards, procedures and instructions to be implemented in conducting activities within or on behalf of Roy Hill. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

7 5.1 EMS Structure The structure of the Roy Hill EMS is consistent with the Australian Standard AS/NZS ISO 14001:2004 Management Systems. It comprises the following four principal elements (steps): Plan: establish objectives, targets, processes, documents and training necessary to deliver results in accordance with Roy Hill s environmental policy; Do (Implement and Operate): implement approved environmental plans, procedures, guidelines and work instructions during operations; Check: undertake audits, inspections, monitoring and measurement of performance against environmental requirements and report the results to internal and external stakeholders; and Act (Management Review): conduct an annual review of the EMS to achieve continual improvement in environmental performance. Figure 5-1 illustrates the Roy Hill EMS structure. Plan Policy al Risk Management Legal and Other Requirements Objectives and Targets Act (Management Review) Annual review of ESMP Annual audit of EMS Improvement measures identified during planning, checking and doing Do (Implementation and Operation) Roles, Resources, Responsibility and Accountability Training, Competency and Awareness Communication Documentation and Document Control Operational Control Emergency Preparedness and Response Check Monitoring and Measurement Evaluation of Compliance Incidents and Action Management Control of Records Figure 5-1: EMS Framework Sections 6 to 9 outline the implementation of the EMS through the Plan, Do, Check and Act framework. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

8 5.2 EMS Document Structure To deliver the required objectives of the EMS, Roy Hill has developed a document hierarchy that aligns with Roy Hill s Integrated Management System. The hierarchy as outlined in Figure 5-2 provides a structured framework for the implementation of the EMS. Figure 5-2: EMS Document Hierarchy This OEMP outlines the interaction between the policy, manuals, standards, plans, procedures and work instructions and assists with the implementation of the EMS framework. It also outlines the requirements for the management of environmental risks during the operation of the Roy Hill Mine, Port and Rail. 5.3 Roy Hill al and Social Management Plan The Roy Hill al and Social Management Plan (ESMP) (OP-PLN-00075) demonstrates Roy Hill s conformance with international environmental and financial standards applicable to the Roy Hill Project. The Roy Hill ESMP is an overarching plan that establishes the al and Social Management Framework and defines key objectives for environmental and social management during project construction and operations. The al Management Framework meets the environmental requirements of the following International and National al and Social Standards: Principles of ISO 14001:2004 al management systems - requirements with guidance for use (ISO14001:2004); Equator Principles (June 2013); International Finance Corporation Performance Standards (January 2012); 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

9 Export Credit Agency requirements: o Japan Bank for International Cooperation; o Nippon Export and Investment Insurance; o Export Import Bank of the United States; and o Organisation for Economic Cooperation and Development; Australian Standards relating to environmental and social management; and International Conventions relating to the environment to which Australia is a signatory and which have been ratified into Law in Australia (International Conventions). This OEMP captures the environmental management requirements of the ESMP within the ISO EMS framework and provides the mechanism for implementing the ESMP. 6 Plan 6.1 al Policy The Roy Hill Policy (RH-POL-00002) outlines the key principles that underpin environmental management at Roy Hill. The Policy is to be communicated to all personnel through the Roy Hill induction process, notice boards and made available on the Roy Hill e-care intranet portal. The Policy acknowledges Roy Hill s responsibility to perform its activities in an environmentally responsible manner and communicates the corporate aspirational goals of striving to achieve environmental excellence and seeking innovative solutions to environmental issues. 6.2 al Risk Assessment Roy Hill's Risk Management Standard (RH-STD-00014) establishes clear requirements for management of environmental risks. The process for the identification of risks is detailed within the Risk Management Procedure (CO-PRO-00038) and is based on the International Standard, ISO 31000:2009, Risk Management- Principles and Guidelines. Roy Hill utilises the Risk Assessment Criteria (5x5) matrix to assess and prioritise risks. Key environmental risks are to be captured in the Corporate Risk Register and risk owners assigned accordingly. It is the responsibility of the designated risk owner to ensure that the risk controls and other mitigation measures that have been identified are implemented, and that the register is updated with new or amended risks and controls al Risk Register The Roy Hill Project was subject to al Impact Assessments by State and Commonwealth governments. The al Protection Authority (EPA) identified that key environmental factors may be affected by the Roy Hill Project (as outlined in Table 6-1), and determined that they must be managed to meet the EPA s environmental objectives for these values. These values are managed through conditions outlined in Ministerial Statement approvals. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

10 Ministerial Statement Location Key al Factors MS824 and 829 Mine Flora and Fauna Subterranean Fauna Groundwater Fortescue Marsh Surface Water Rehabilitation and Closure MS858 and 859* Port Benthic Primary Producer Habitat Surface Water and Tidal Processes Dust and Noise Emissions MS847 Rail Flora and Vegetation Terrestrial Fauna Rehabilitation Table 1: EPA Key al Factors * The Pilbara Ports Authority was the proponent for this Ministerial Statement, with Roy Hill undertaking the dredging at South-west Creek Key risks associated with project construction, operations and closure that have the potential to impact on these environmental values will be captured in Risk Registers. This OEMP sets out the framework under which risks will be managed to minimise potential impacts to the environment Legal Requirements Roy Hill operates in accordance with relevant Commonwealth and State legislation and regulations. Roy Hill manages compliance with legislation in accordance with the Legal Requirements and Commitments Standard (RH-STD-00012). Key State and Commonwealth legislation includes: al Protection Act 1986 and subsidiary regulations; al Protection and Biodiversity Conservation Act 1999 and subsidiary regulations; Mining Act 1978 and subsidiary regulations; Railway (Roy Hill Infrastructure Pty Ltd) Agreement Act 2010; Land Administration Act 1997; Rights on Water and Irrigation Act 1914 and subsidiary regulations; Aboriginal Heritage Act 1972; Wildlife Conservation Act 1950; al Protection (Sea Dumping) Act 1981; Dangerous Goods Safety Act 2004 and subsidiary regulations; Building Act 2011 and subsidiary regulations; Health Act 1911 and subsidiary regulations; Contaminated Sites Act 2003; Town Planning and Development Act 1928; Port Authorities Act 1999; and Heritage of Western Australia Act The Team receives notifications from the Department of Premier and Cabinet State Law Publisher regarding changes to environmental legislation, and communicates these to the business as needed. Roy Hill has access to current Australian Standards through SAI Global. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

11 Key approvals have been granted for the construction and operation of the Roy Hill project under legislation as outlined in Table 6-2. Legislation Part IV of the al Protection Act 1986 (EP Act) and the Protection and Biodiversity Conservation Act 1999 Railway (Roy Hill Infrastructure Pty Ltd) Agreement Act 2010 and the Rail Safety Act 1998 Part V of the EP Act Mining Act 1978 Port Authorities Act 1999, Sea Dumping Act 1981 Health Act 1911 Town Planning and Development Act 1928 and Building Act 2011 Rights in Water and Irrigation Act 1914 Dangerous Goods Safety Act 2004 Table 2: Key Project Approvals Approval Purpose al Impact Assessment and Ministerial approval Construction and operation of a railway Construction and operation of prescribed premises (Works Approvals and Operating Licences) Construction and operation of a mine Construction and operation of Port facilities Construction and operation of premises Construction and operation of premises Construction of water bores, abstraction of groundwater and surface water and disturbance to beds and banks of a watercourse Storage and handling of dangerous goods Approval applications and granted approvals contain commitments and conditions (legal requirements) that must be met during operations. Roy Hill maintains its legal requirements in the corporate Obligation Management System (OMS). The OMS tracks the status of obligations, expiry dates and accountabilities and responsibilities for each obligation. The OMS also captures and tracks actions required to meet legal obligations and reports on completion of actions to Senior Management. Legal requirements have been embedded into environmental performance standards, management plans, procedures and work instructions. Legal requirements are also to be met through the implementation of studies, surveys and monitoring programs. 6.3 Objectives and Targets Consistent with ISO 14001:2004, measurable objectives and targets are to be set for significant environmental risks and recorded in the al Objectives, Targets and Key Performance Indicators (KPIs) Register (OP-REG-00010). The environmental objectives and targets are to align with the Roy Hill Policy and the al Performance Standards. The KPIs are to be set to reflect the achievement of environmental targets, and the KPIs are reported on a quarterly basis to management. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

12 The register also includes an Annual Action Plan which sets actions, improvements and controls for achieving the objectives and targets. The Annual Action Plan is to be reviewed on a quarterly basis to determine effectiveness in meeting the KPIs and amendments are made if the KPIs are not being met. The objectives, targets and KPIs are to be reviewed annually as a part of the management review of the EMS, to identify if any changes are required. 7 Do (Implementation and Operation) 7.1 Operational Control al Performance Standards The al Performance Standards define the key minimum requirements to be applied for the management of environmental risks. Compliance with the al Performance Standards is mandatory for all Roy Hill personnel, contractors and sub-contractors. al Performance Standards have been developed for the following key environmental factors: al Performance Standard Land; al Performance Standard Fauna; al Performance Standard Water; and al Performance Standard Air. al management plans, procedures and work instructions facilitate and complement the implementation of these minimum performance standards Operational al Management Plan and Procedures al management documents detail the way environment risks that have been identified in the ERR, are managed. Specifically: al plans detail why specific management measures are required; al procedures outline the management actions to be implemented to comply with legal requirements and minimise impacts to the environment; and Work instructions provide specific step-by-step detail on how actions are to be undertaken. The implementation of plans, procedures and work instructions is the primary mechanism for the management of environmental risks. The use of the approved plans, procedures and work instructions is mandatory. The current list of approved plans, procedures and work instructions relating to environment management can be viewed in the Roy Hill e-care portal on the Roy Hill intranet Contractor al Management Plans Contractors should develop an al Management Plan (EMP) and procedures to outline how environmental risks related to their activities will be managed. These documents should align with the Roy Hill OEMP, al Performance Standards and approved plans, procedures and work instructions as detailed in the contractor s Operating Principal Requirements (OPR) list. Irrespective of the contents of the EMP however, the requirements outlined in the OPR listed documents must be complied with by the contractor and their subcontractors. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

13 Prior to mobilising to site the contractor should submit an EMP to Roy Hill for review and acceptance. The contractor s EMP should: Outline activities in their scope of work that have a potential environmental impact; Outline their environmental management system to show that it is aligned with the requirements of ISO 14001:2004 al Management Systems; Identify the relevant legal obligations and commitments; Refer to the relevant environmental Operating Principal Requirement documents; Identify environmental risks relevant to their scope of work; and Detail the specific management measures to be implemented to minimise risk of impact to the environment. Contractor EMPs should be reviewed and accepted by the Team prior to the contractor mobilising to site. The contractor should ensure their personnel are familiar with the contents of the EMP, and that their subcontractors comply with the approved contractor EMP. Contractor EMPs should be subject to periodic review by the contractor to: Reflect changes in contractual or operational requirements; Correct non-compliances identified during auditing; Incorporate improvements identified during incident investigations and audits; and Be consistent with the conditions of Project permits, approvals and licences as they are issued. 7.2 Roles, Resources, Responsibilities and Accountability Leadership Team The Roy Hill Leadership Team is accountable to: Support the development, implementation and maintenance of the Roy Hill OEMP; Conduct annual reviews of the Roy Hill Policy; Promote environmental awareness; Provide input into management reviews of the Roy Hill OEMP; and Provide adequate resources to enable Roy Hill to comply with legislation, regulations and other environmental obligations General Manager Health, Safety and The General Manager Health, Safety and (HSE) is accountable to: Support the development, implementation and maintenance of the Roy Hill OEMP; Review and update the Roy Hill Policy; Promote environmental awareness; Participate in management review of the Roy Hill OEMP; and Allocate sufficient human, physical and financial resources to ensure compliance with legislation, regulations and legal requirements. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

14 7.2.3 Manager and Approvals The Manager and Approvals is responsible to: Review and update the Roy Hill Policy; Review and approve the Roy Hill OEMP, plans, procedures and work instructions; Identify required human, physical and financial resources to comply with legislation, regulations and legal requirements; Report the performance of the Roy Hill OEMP and improvement opportunities to the Leadership Team; Liaise with the general public and key stakeholders (e.g. government departments) as required; Manage and resolve community complaints; Delegate responsibilities to the al Team Superintendents; and Undertake strategic planning to ensure; o Support and advice is provided to operational teams on environmental management and legal requirements; o Delivery of environmental awareness; o Maintenance of environmental data and records; o Recording and reporting of non-compliances in the Roy Hill incident and management system and to regulatory authorities; o Achievement of environmental approvals; o Compliance with legal requirements; o Development and update of environmental training and awareness; o Delivery of environmental monitoring programs; and o Reporting to government regulatory authorities al Superintendents al Superintendents are responsible to: Co-ordinate the development and implementation of environmental monitoring programs; Review and update the Roy Hill OEMP, plans, procedures and work instructions; Implement the Roy Hill OEMP, plans, procedures and work instructions; Conduct audits and inspections, identify and track implementation of contingency actions and prepare audit and inspection reports; Provide support and advice to operational teams on environmental management and legal requirements; Develop and conduct environmental awareness and training; Supervise, guide and mentor environmental advisors; Liaise with government departments officers on permitting, licensing and compliance issues; and Prepare environmental plans, approval applications and compliance reports in consultation with government authorities and Manager and Approvals. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

15 7.2.5 al Advisors al Advisors have responsibility to: Provide support, advice and information to the business in relation to environmental legal requirements, standards and operational procedures; Implement the OEMP and associated procedures, plans and work instructions; Conduct audits and inspections of compliance with the OEMP and associated procedures, plans and work instructions; Develop and conduct environmental awareness training; Develop environmental management documentation for use by the business; Consult and collaborate with the Human Resources Team in the development and delivery of environmental induction programs; Undertake reporting of environmental performance; and Monitor operational team and contractor reporting of environmental incidents into the incident management system Operational Managers and Supervisors The Operational Managers and Supervisors are responsible to: Comply with the Roy Hill Policy; Comply with relevant environmental Acts, Regulations, codes of practice and standards; Comply with conditions of licences, permits, approvals, agreements and other legal requirements as recorded in the Legal Requirements and Other Obligations Management System. Implement the OEMP and associated procedures, plans and work instructions in the workplace; Undertake environmental inspections and audits in accordance with the Roy Hill Inspection and Audit Schedule (IAS); Investigate environmental incidents and report incidents in the incident management system; Identify and implement corrective, preventative and contingency actions arising from inspections, audits and incidents; Undertake appropriate action in the event of inadequate environmental performance or unacceptable risk; Allocate adequate and appropriate resources to ensure environmental obligations and reporting are met; and Oversee supplier and contractor compliance with environmental requirements Roy Hill Personnel All Roy Hill personnel are required to: Comply with the Roy Hill Policy; Comply with relevant environmental Acts, Regulations, codes of practice and standards; Comply with conditions of licences, permits, approvals, agreements and other legal requirements as recorded in the Legal Requirements and Other Obligations Management System. Implement the OEMP and associated procedures, plans and work instructions in the workplace; Report to management promptly regarding any hazards, non-compliances, incidents and/or breaches; 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

16 Participate in awareness environmental training; and Conduct operational activities in an environmentally responsible manner Roy Hill Contractors All Roy Hill contractors are required to: Comply with the Roy Hill Policy; Comply with relevant environmental Acts, Regulations, codes of practice and standards; Comply with conditions of licences, permits, approvals, agreements and other legal requirements as recorded in the Legal Requirements and Other Obligations Management System. Implement the OEMP and associated procedures, plans and work instructions in the workplace; Report hazards, non-compliances, incidents and/or breaches in the incident management system; Implement corrective, preventative and contingency actions to resolve non-compliances; Take appropriate action in the event of inadequate environmental performance or unacceptable risk; Conduct operational activities in an environmentally responsible manner; Allocate adequate and appropriate resources to ensure environmental obligations and reporting are met; Ensure suppliers and subcontractors comply with environmental obligations; and Provide training to workforce on environmental requirements relating to the Roy Hill Project. 7.3 Training, Competency and Awareness All personnel shall be competent to conduct their work without unauthorised effects on the environment, in accordance with the Training, Competency and Awareness Standard (RH-STD-00018). All personnel shall participate in environmental inductions and training that is relevant to their work Roy Hill Inductions and Awareness All personnel shall receive training on minimum environmental standards. This training is delivered through: Roy Hill inductions; E-learning training; and Awareness and information sessions. All site based personnel are to undertake an induction program that includes: Corporate Induction; Health, Safety, Emergency, Security and (HSESE) induction (Business Induction); and Site induction specific to the work area (e.g. mine). The induction program includes training and assessment so that all personnel are aware of their environmental responsibilities and are assessed as being competent to carry out their work in an environmentally acceptable manner. Monthly toolbox meetings are to be held on site and must include environmental content relevant to the work activities. Toolbox meetings are to discuss environmental risks, environmental incidents and environmental performance. al awareness training is also to be delivered at toolbox meetings as required. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

17 al induction and toolbox sessions should include information on: Project approvals; Key legislation; Regulatory penalties and impacts of non-compliance; Ground Disturbance Permits (GDPs); Land access restrictions; Protection of vegetation and flora, including mangroves; Identification of weeds, management measures and reporting requirements; Protection and preservation of fauna, identification of protected fauna species and reporting requirements (sightings & injuries); Identification of feral fauna species and reporting requirements; Dust management; Water management and water use efficiency; Fire risk, impacts, management and response; Erosion prevention; Hazardous substances storage and use; Use of spill kits and other procedures for cleaning up spills of potentially contaminating materials and substances; Waste management; Fibrous minerals and materials management; GHG emissions and energy efficiency; Fortescue Marsh, migratory birds and the impact of artificial lighting; Incident and hazard reporting; and Special requirements relevant to the specific work location. al alerts are to be issued on a periodic basis where new information needs to be released to Project personnel, such as learnings from incidents and non-compliances. The al Alert Template (100RH-0000-HS-TMP-2001) can be used for this purpose, or information can be included in the Return to Site awareness package Awareness Training Personnel performing tasks that may potentially cause significant environmental impacts shall: Receive additional induction and/or training in an e-learning modular or face-to-face format to further inform them of particular requirements, risks and controls; or Be certified as having completed relevant induction and training processes, and/or as having gained appropriate experience, before undertaking such tasks. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

18 Specific awareness training packages may include: Kick-off environmental briefing covering major risks and management measures; Specific environmental approvals; Key legal obligations and penalties and impacts of non-compliance GDP training SageSURPASS; GDP briefing covering management of ground disturbance; al data reporting briefing Contractor al Report; al data management system; Incident investigation training; Dust management at the Port; Hazardous materials storage and use; Spill response training; and Fauna handler training Training Register Job descriptions are to outline the tasks, responsibilities, and selection criteria of the position and also include the minimum standards for qualifications, work experience and physical fitness. An al Training Register has been developed in conjunction with the Human Resources Team and outlines the environmental training requirements for Roy Hill personnel and the timeframes for delivery. Personnel must possess appropriate accreditation, suitable qualifications, competency, skills and experience specific to the job requirements, and be fit for work. Current and valid licences and/or certificates of competency or appropriate statutory exemptions are to be inspected and documented in the Roy Hill training database Training Records Training records are to be maintained in the Roy Hill Document Management System (DMS) and include the following as a minimum: Records of training attendance (e.g. awareness training, toolbox meetings); Copies of the training materials; Competency assessments (where relevant to the training provided); and Training matrix. 7.4 Communications Internal and external communications are to be managed in accordance with the Roy Hill Consultation, Communication and Participation Standard (RH-STD-00026). The Roy Hill Consultation and Communication Procedure (OP-PRO ) details the requirements for effective and open communication and consultation between Roy Hill personnel, contractors, suppliers, customers and external stakeholders. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

19 7.4.1 Internal Communications As outlined in Section 7.3, all personnel are expected to participate in regular discussions including toolbox and prestart meetings. al (or integrated HSESE) notice boards are to be established at various locations on site to inform personnel of relevant environmental information including environmental performance, environmental incident alerts and environmental notices. The notice boards are to be updated on a regular basis. al risks and key site environmental issues are to be communicated through site and toolbox meetings and return to work programs. A record of the communication topic, names of personnel in attendance and the presenter s name shall be maintained on site as an auditable record. Significant environmental issues are to be escalated to the Roy Hill Manager and Approvals and/or appointed delegate. All significant internal communication relating to the environment are to be maintained and recorded in the DMS. An environmental newsletter called Green Scene is issued on a periodic basis to Roy Hill personnel and contractors, and incorporates interesting environmental information and updates. The Intranet e-care portal is the central location for Roy Hill personnel to access EMS information including the Policy, environmental plans, procedures, work instructions, forms/checklists, alerts, toolbox topics and manuals. The e-care portal also contains key environmental approvals and legislation, standards and reports, as well as providing specialist information on biological science programs and rehabilitation External Communications Roy Hill is responsible for all external communication relating to matters concerning the environment. Members of the Team are responsible for external communication with government regulators (including Department of Regulation, Office of the al Protection Authority, Department of Mines and Petroleum, Department of Health) particularly in relation to approvals and the reporting of environmental incidents. External communication with the Department of Water is managed by the Water Team. Contractors are not to communicate directly with government agencies on key environmental matters unless they relate to approvals that they are responsible for. The General Manager External Affairs or nominated delegate is responsible for the management of communications with the media, and high level discussions with government and other agencies as required. Roy Hill personnel and contractors are required to refer all media communications to the External Affairs Team. Records of all external communication are to be maintained in the Roy Hill DMS. Roy Hill personnel are to ensure that communication received from external stakeholders is documented and responded to in accordance with the Roy Hill Consultation and Communication Procedure (OP-PRO-00980). 7.5 Documentation and Document Control Document Management System All documents are to be stored in and accessed via the DMS. A controlled document is one that has significant value to the organisation, whose unrestrained amendment can result in inconsistent documentation across the business, and potentially endanger the health or safety of personnel and impact the environment. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

20 All Controlled Documents therefore must be: Managed and controlled by Document Control; Approved for adequacy and appropriateness before being used; Reviewed using a formal process with reviewer details and formal signoffs being obtained; Updated (as necessary) using a formal process where the document will be reviewed and approved; Version controlled so that at any point the status and version history is available; Available for use once finalised with historical versions retained; Communicated to Roy Hill personnel and contractors via Intranet, and contractual letters when changes are made; Easily read and understood; and Identified using a unique document name and numbering scheme. The Systems Documentation and Document Control Standard (RH-STD-00019) outlines the high level requirements for the review and management of controlled documents. All key operational environmental documents are required to be lodged with Roy Hill Operations Document Control, and the relevant processes followed to finalise the documents Hard Copy Documents Documents with wet signatures or that have been completed (such as checklists, inspection forms) are to be scanned and stored in the relevant location within the DMS. As all hardcopy documents are uncontrolled, it is the user s responsibility to ensure that they have the most up to date version by checking in DMS Updated, Superseded, Obsolete or Withdrawn Documents Any updated, superseded obsolete or withdrawn controlled documents are to be maintained in DMS for audit purposes. Updated document are to be communicated to all relevant personnel via correspondence, the intranet e-care portal and toolbox meetings. Contractors are to be informed of updated documents through formal correspondence issued by the Commercial Team Controlled Documents All key environment documents are held in the Roy Hill DMS Controlled Documents folder. All key environment documents that form part of the EMS are available on the Roy Hill Intranet e-care portal. 7.6 Emergency Preparedness and Response The Roy Hill Emergency Management Plan (OP-PLN-00086) provides an overview of the emergency management arrangements and principles of implementation in relation to the operations of the Roy Hill Mine, Port and Rail. All environmental emergencies will be managed in accordance with the Roy Hill Emergency Management Plan. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

21 8 Check 8.1 Monitoring, Measurement and Data Monitoring and Measurement al monitoring of operations is required in order to understand the impacts on key environmental values. Monitoring is a requirement of permits, approvals and licences. The Mine al Monitoring Manual (OP-MAN-00007) and the Port and Rail al Monitoring Manual (OP-MAN-00011) document the monitoring requirements for the Project operations. Procedures and work instructions also detail the monitoring and measurements that are required and how they are to be conducted. Examples of environmental monitoring to be completed include: Water monitoring (groundwater, surface water, wastewater); Fuel and chemical use; Fauna monitoring; Mangrove and vegetation monitoring; Dust monitoring; Air emissions monitoring; and Rehabilitation monitoring. All monitoring and measurement records are to be retained and stored within the Roy Hill DMS. Monitoring and measuring equipment is to be regularly maintained, serviced and calibrated according to the manufacturer s instructions/specifications and/or recognised national/international standards. Personnel conducting the equipment calibration are to be trained and competent, and records of maintenance, service and calibration must be retained al Data al data is required to be collected across all Project sites for reporting to government regulatory agencies on a periodic basis. A monthly environmental report is to be used to collate the required key environmental data from contractors and Operational teams. The data is to be captured in the environmental data management system as per the relevant work instructions, and reviewed on a regular basis to compare against licence limits and other environmental criteria. personnel assist by providing training on the use of the monthly environmental report to operational teams and contractors as needed. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

22 8.2 Evaluation of Compliance Audits and Inspections al audits and inspections are to be conducted to ensure that operational activities are implemented in accordance with the Policy, legal and approval requirements, environmental standards, the OEMP, environmental plans, procedures and work instructions. Audits and inspections are to be conducted in accordance with the Monitoring, Audit and Review Standard (RH-STD-00023), the al Audit Procedure (OP-PRO-00018) and the Inspection Procedure (OP-PRO ) Audit and Inspection Schedule Inspections and audits are to be scheduled by operational teams, contractors and the Team. The status of planned versus completed inspections and audits is to be recorded and reported to the Leadership Team on a monthly basis Operational Team Inspections Operational teams are to conduct inspections of their work areas and activities in accordance with the SharePoint schedule, using approved HSE and environmental inspection checklists. Actions arising from inspections are to be entered by operational teams into the Roy Hill action management system for tracking and close out Contractor Audits and Inspections Roy Hill contractors are required to conduct weekly environmental inspections and quarterly audits of their work areas and activities against environmental requirements. Records of these inspections and audits are to be retained by the contractor and copies made available to the operations and Team upon request. Actions arising from inspections are to be entered into the contractor s action management system for tracking and close out Team Inspections The Team is to conduct regular inspections of operational areas and activities where there are potential environmental risks, using approved environmental inspection checklists. All actions raised during the inspection are to be loaded into the Roy Hill action management system for tracking and close out Team Audits The Team is to conduct audits of activities undertaken by operational teams and contractors to determine compliance key EMS documents, legal requirements and approval/licence/permit conditions. Audits are to be undertaken in accordance with the al Audit Procedure (OP-PRO-00018), and the results are to be communicated to the Leadership Team. Actions raised during the audit are to be communicated to the auditees and entered into the Roy Hill action management system for tracking and close out External Audits and Inspections External audits and inspections are conducted periodically by government regulators to ensure compliance with permits, licences and commitments made by Roy Hill. Relevant Roy Hill representatives are to accompany the regulator during their inspection or audit. Findings and recommendations of these audits are to be recorded as corrective actions by the Team in the Roy Hill action management system. Actions are to be undertaken by operational teams and contractors as required to close them out within agreed time frames. Evidence of close out of actions is to be provided to regulators where required. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

23 8.2.2 al Reporting Internal Reporting Operational teams and contractors (including subcontractors) are to complete a monthly data report to ensure that data relating to their activities is provided. The Team is to conduct a review of the submitted data for completeness and accuracy. Reports provided to the Team may be used as evidence of legal compliance or non-compliance and therefore must be correct and auditable. The Team is required to submit a monthly environmental report to the COO, Roy Hill Holdings Pty Ltd Chairman and Board and Financiers External Reporting Roy Hill prepares and submits a range of reports to financiers and government regulatory agencies including: al compliance reports to government regulatory agencies in accordance with approval requirements; and Monthly and bi annual reports to financiers. 8.3 Incident and Action Management Incidents are to be managed in accordance with the Incident Reporting and Investigation Standard (RH-STD ) Incident Reporting and Investigation All environmental hazards, high potential near misses and incidents shall be reported and recorded using the incident and hazard reporting system. The Incident Owner is responsible to: Participate in incident investigations relating to their work area or scope of work; Ensure that the necessary incident investigation is undertaken within the prescribed timeframes; Establish suitable corrective actions to prevent recurrence; Ensure incident reports and investigations are completed; Monitor the close out of action items and provision of supporting evidence; Evaluate the effectiveness of actions that have been undertaken; and Provide feedback on the outcomes of the incident. All environmental incidents are to be reported, categorised and investigated within the timeframe specified in the Incident and Hazard Reporting Procedure (100RH-0000-HS-PRO-2004). Incident investigations are to be conducted in accordance with the Incident Investigation Specification (OP- SPC-00156). Actions resulting from incidents are to be managed in accordance with the Incident, Nonconformance and Action Management Procedure (OP-PRO-00702). External reporting of significant environmental incidents is to be undertaken by the Manager and Approvals or delegate. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

24 8.3.2 Corrective and Preventative Actions Corrective and/or preventative actions are to be identified to address the root cause of the incident and prevent further incident occurrence. These actions are to be recorded in Roy Hill s action management system for tracking and close out, and should align with the following: Action required (should be SMART ); o Specific what needs to be accomplished and where; o Measurable quantifiable so one is able to know when the action is completed; o Attainable results that can realistically be achieved, given available resources; o Relevant actions are worthwhile and it is the right time to be doing them; and o Time-bound when the result(s) can be achieved to establish a sense of urgency. Target close out date (should be achievable); and Person assigned responsibility for the completion of the action item (should be a person with the authority to resolve the root cause of the incident). The person responsible for the action item shall close out the required action in the action management system by the due date. Action close shall only be undertaken when evidence has been attached in the system demonstrating that the action has been adequately resolved. The type of evidence that may be applicable to be loaded into the Roy Hill incident and hazard reporting system includes: Correspondence; s; Procedures; Job Hazard Analysis; Photographs; Waste receipts; Training materials; Training attendance records; and Meeting minutes (including tool box and prestart). The Corrective and Preventive Action Procedure (100RH-0000-QA-PRO-2001) provides further direction on the management of corrective and preventative actions. The status of reported incidents is to be reviewed in the Incident Register, and monitored by the environmental team to determine whether: Incident investigations have been adequately undertaken; Corrective actions identified will adequately address the root cause of the incident and prevent future incident recurrence; Action closeouts are overdue; The actions have been adequately addressed to prevent current or future non-compliance; and Evidence has been provided to support the close out of the actions. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30

25 Overdue environmental actions heighten the risk of environmental non-compliance and the occurrence of additional incidents. Overdue actions are to be escalated to the responsible person s line manager for their review and action. Where the action item requires further investigation or processes to be implemented, time frames can be extended with the approval from the action assignee. 8.4 Control of Records The following records shall be maintained including (but not limited to): Training records; Incident reports; Trench inspections; Completed inspection checklists; Completed audit reports; Corrective Action Register (CAR); Fuel and oil use receipts; Monitoring results; Controlled waste receipts and tracking numbers; and Weight and/or volume of waste to landfill, waste recycled and waste disposed of offsite. Records are to be appropriately named and stored in the DMS or the environmental data management system as appropriate. Copies of records are to be provided by contractors to the environmental team with submission of the monthly environmental report. 9 Act (Management Review) The review of environmental standards, plans, procedures and work instructions is to be undertaken at least annually. Contractors are required to review the effectiveness of their EMP on an annual basis. Management review of the EMS is also to be undertaken annually. A report outlining the results of the review is to be prepared by the Team and presented to the Roy Hill Leadership Team. The review will include, as a minimum: Results of internal and external audits; al performance (lead and lag indicators); Objectives, targets and key performance indicators; Details of community complaints and reportable incidents; Status of corrective and preventative actions; Status of actions from previous management reviews; Changes in regulatory circumstances including legislative changes, and Recommendations for EMS improvement. 3 OP-PLN D Richards Manager & Approvals 21/12/ /12/ of 30