Compliance and Performance Report

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1 Compliance and Performance Report Environmental Management System

2 This page is intentionally blank. D2018/73234 Review Date: September_2018 2

3 Contents 1. Introduction Purpose of the Report Objectives and Targets Minimise the environmental impact of our infrastructure and operation activities Positively influence third party activities to protect the Sydney catchment area Promote and environmentally responsible culture that anticipates and responds to our environmental obligations Activities and Programs Results and Outcomes Future Activities and Programs Significant Changes Major Non-Conformities... 9 D2018/73234 Review Date: September_2018 3

4 1. Introduction WaterNSW s Environmental Management System (EMS) has been developed in accordance with ISO14001:2015 Environmental Management Systems standards to ensure compliance with the requirements of the current Water NSW Operating License , specifically section 5.2 Environmental Management System. Furthermore, WaterNSW must complete periodic reporting in accordance with the WaterNSW Reporting Manual. 2. Purpose of the Report The purpose of this report to is to outline compliance and performance against the relevant objectives and targets developed and included within the EMS ( Environmental Objectives and Targets). These objectives and targets nominate key goals and measures to address significant environmental risks, compliance obligations and facilitate continual improvement in environmental management and inform the EMS. 3. Objectives and Targets WaterNSW central audit program captures the audit schedules of the Business Management System, and of the other management systems. The audit schedule is implemented to ensure management of environmental impacts and risks to the environment are being managed, and Environmental Objectives and Targets that have been developed are being met. The three broad environmental objectives are: 1. minimise the environmental impact of our infrastructure and operational activities 2. positively influence third party activities to protect the Sydney catchment area 3. promote an environmentally responsible culture that anticipates and responds to our environmental obligations. Under each of these objectives are multiple specific, measurable and timely control targets defined in order to manage the identified risks in the context of the business. The below tables outline the targets and measures to be completed as part of the EMS. 3.1 Minimise the environmental impact of our infrastructure and operation activities Reference Targets Measures Key environmental impacts are managed All projects and works requiring a Review of Environmental Factors comply with the Procedure for Part 5 Environment Assessment WaterNSW meets its environmental obligations for Environmental Flow releases from dams Key Heritage Management Action Plan outcomes are met Environmental process system health check program executed 100% of scheduled releases completed 100% of actions relating to State Significant Heritage Items are implemented 90% of scheduled audits are completed 100% of non-conformances (NCR) addressed within timeframe D2018/73234 Review Date: September_2018 4

5 3.2 Positively influence third party activities to protect the Sydney catchment area Reference Targets Measures WaterNSW ensures compliance with its Part 5 and Access Consent Conditions WaterNSW reports compliance breaches of third parties with their planning or other consent conditions Submissions to mining proposals include the WaterNSW mining principles Response to requests for SEPP concurrence matters meet statutory timeframes Carry out an Annual Environmental process system health check for highest risk consents (mining companies) 100% non-compliances reported 100% review and comment 100% response rate 3.3 Promote and environmentally responsible culture that anticipates and responds to our environmental obligations Reference Targets Measures Environmental training program developed and implemented Operational sites issued with an Environment Protection Licence (EPL) are compliant Report all notifiable incidents to the Appropriate Regulatory Authority (ARA) 100% staff complete Environmental Essentials modules by July % compliance with EPL 100% of incidents reported 4. Activities and Programs Across WaterNSW, a range of supporting activities contribute to the effectiveness of environmental controls. These are identified as Supporting Programs and contain environmental checks and measures that can further support environmental performance as detailed in the below table. Supporting Programs 4.1 Asset Management System Environmental Impact Assessments were undertaken for maintenance management activities as required. 4.2 Project Delivery Framework Triggers for environmental consultation/approval have been incorporated in all stages of the Project Delivery Framework: Initiation, Planning, Execution and Completion D2018/73234 Review Date: September_2018 5

6 4.3 Contaminated Land Management Plan The Contaminated Land Management Plan was approved in September 2017 and it provides a framework for the ongoing management of all WaterNSW contaminated land. The Plan: establishes necessary processes to demonstrate compliance with contaminated land regulatory obligations; documents a methodology for the identification, assessment and management of contaminated land; and includes an action plan developed from recommendations of review of risks contamination presents to current/proposed land use. A Contaminated Land Action Plan was implemented throughout the year. 4.4 Water Quality Management System Supports protection of the environment and influences positive water quality outcomes. The Water Quality Management System 2018 which replaces the Water Quality Management Framework was approved in May Catchment Protection Work Program The Catchment Protection Work Program outlines works and activities WaterNSW plans to undertake to protect the health of the Sydney Catchment Area to ensure reliable, quality drinking water is available for the 5 million people of Sydney and the Illawarra, Blue Mountains, Southern Highlands, Goulburn, and Shoalhaven regions. The Annual Catchment Management Report is being prepared and is in draft form and will be reviewed, approved and reported to IPART by 30 November The report outlines the planned and actual catchment activities undertaken in the WaterNSW catchment work program for This report also identifies where actions are addressing recommendations of previous Catchment or Operating Licence audits. 4.6 Special Areas Strategic Plan of Management The Special Areas Strategic Plan of Management is a long-term plan nested within the Catchment Protection Work Program to secure high quality water for the storages and ensure ecosystem integrity of the Special Areas with programmed works completed for 2017/2018 financial year. Reporting on the progress is completed via the Annual Catchment Management Report. 4.7 HSE integration WHS Start Card includes environmental controls and approval requirements. WaterNSW has performed integrated systems audits for Safety and Environment. WHS & EMS audits have been completed concurrently to ensure alignment with the Business Management System (BMS) common elements. 5. Results and Outcomes Reference Targets Status / Environmental Achievements Key environmental impacts are managed 100% projects and works requiring a Review of Environmental Factors complied with the Environment Impact Assessment Procedure WaterNSW meets its environmental obligations for Environmental flow releases from dams Key Heritage Management Action Plan outcomes are 100% of obligations for environmental flow releases were met. when comparing actual vs required volumes for this financial year. 100% of Heritage management activities relating to State Significant Heritage Items were completed, including: Three new CMPs produced on items assessed as State D2018/73234 Review Date: September_2018 6

7 Reference Targets Status / Environmental Achievements met Environmental process system health check program executed Significant: Nepean, Cordeaux and Cataract Dams Agency exemptions have been drafted to be distributed internally for comment prior to being presented to the Heritage Division. A draft Moveable Heritage Program has been developed and is ready to go for consultation with BU s in A Heritage Management e-learning module has been developed and will be rolled out to nominated staff in 2018/2019. Heritage was celebrated during open days at Burrendong and Chaffey Dams. 157 scheduled heritage jobs completed. An environmental system health check program has been implemented across WaterNSW projects and operational sites to ensure the ongoing compliance and implementation of environmental mitigations measures in accordance with project approvals and best practice. Audit Performance as follows: 100% target audits completed. 33 system health checks were undertaken during the reporting period (target 25). Audit findings: No Major non-conformance identified. No Minor non-conformances identified. The measure for this target is to conduct an annual environmental process health check for highest risk consents (mining companies). WaterNSW ensures compliance with its Part 5 and Access Consent Conditions WaterNSW reports compliance breaches of third parties with their planning or other consent conditions Submissions to mining proposals include the WaterNSW mining principles. Following a number of incidents involving oil-spills from transformers owned by mining companies in the Special Areas, WaterNSW worked with a number of agencies (EPA, Department of Planning and Environment (DPE) Compliance, Division of Resources and Geosciences (DRG) and the Resources Regulator) to develop and implement an interagency audit program of mining sites within Special Areas, to address both the chemical storage aspects of each site as well as identification of redundant infrastructure and sites. The six highest risk mining-related sites audited: Burrawang Coal - Wollondilly Coal Preparation Plant and associated sites. Wollongong Coal o Russell Vale Colliery and associated sites; and o Wongawilli Colliery and associated sites. South32 Illawarra Coal o Dendrobium Mine s Corrimal No. 3 vent shaft site; and o Cordeaux Colliery pit-top. Peabody Energy - Metropolitan Mine s Vent Shaft #3 site. Individual reports were sent to all companies, setting out issues of non-compliance, issues of concern and recommendations for improvement. 100% of non-compliances of third parties with their planning or other consent conditions that were brought to our attention were reported. The Mining Principles are advocated at all appropriate opportunities as WaterNSW s policy position. The following submissions were made for the reporting period 100% submissions included reference to the mining principles: D2018/73234 Review Date: September_2018 7

8 Reference Targets Status / Environmental Achievements Dendrobium Mine Area 3B Longwall 16 SMP WaterNSW submission on DPE discussion paper on improving mine rehabilitation in NSW. Presentation to SORAC and government agencies on Standardised Assessment Framework for Mining in the Special Areas (SAFM) WaterNSW response letter to DPE - Angus Place Colliery Modification Response to requests for SEPP concurrence matters meet statutory timeframes Environmental training program developed and implemented Operational sites issued with an Environment Protection Licence (EPL) are compliant The Standardised Assessment Framework for Mining (SAFM) has been developed and presented to the board who requested consultation with industry and community. Consultation has been completed and a report is being prepared for presentation to the board for approval. 100% of responses to requests for SEPP concurrence matters met statutory timeframes for and concurrence was not withheld on any development applications. In addition to providing concurrence advice, WaterNSW also provides advice on Section 96 modifications, amendments to council DA s, requests to execute section 88B instruments and advise to DPE on state significant developments and state significant infrastructure projects. For the FY2017/2018 the statistics for these advise are as below: 45 requests from councils for advice on Section 96 modifications 49 requests from councils for further advice on amendments to DAs 46 requests to execute section 88b Instruments. 18 responses to DPE on state significant developments and state significant infrastructure projects were given, 17 of those within agreed timeframe. WaterNSW Environmental Management Training Plan (developed in December 2016) is currently under review and will be replaced with a training matrix. The training matrix will outline the training requirements for WaterNSW in relation to Environmental Management and will communicate the procedures to the relevant stakeholders. The Environmental Essentials e-learning module continues to be offered to new starters at WaterNSW. 93% of staff have completed the module (to end June 2018), with 21% of those that have not completed the program being new WaterNSW starters. Other E-Learning modules including Heritage Management and Environmental Management have been finalised. No infringements or penalty notices were issued to WaterNSW during the period. Operational sites (Duckmaloi Water Treatment Plant) issued with an Environment Protection Licence (EPL) remains 100% compliant. An Annual Return for the Duckmaloi Water Clarification Plant was submitted and received by the EPA on 12 December 2017 with no non-compliances reported. Compliance with operating licence conditions is assessed in October each year, to coincide with the EPA licence annual return (licence anniversary date is 13 Oct). D2018/73234 Review Date: September_2018 8

9 Reference Targets Status / Environmental Achievements Report all notifiable incidents to the Appropriate Regulatory Authority (ARA) There were no WaterNSW notifiable incidents during the reporting period. 6. Future Activities and Programs Consistent with our environmental policy, measurable objectives and targets are set annually and recorded in Environmental Objectives and Targets. This document also lists key performance indicators (KPIs) to monitor progress in achieving the objectives and targets. Performance is reviewed during each year on the extent to which objectives and targets have been met, and annually reviewed for the suitability of the objectives and targets. The Environmental Objectives and Targets for WaterNSW have been developed and were submitted for consideration by the Board in the Annual Environmental Management System (EMS) Health Check report completed in August Significant Changes The new WaterNSW Environment Policy was drafted for Board approval [and subsequently approved in August 2018] to comply with the requirements of ISO14001:2015, replacing the current policy that was approved by the Board in October An ISO14001 upgrade gap analysis was conducted by BSI on 30 April 2018 to assess WaterNSW preparedness for its management system certification transition to ISO 14001: Four areas of concern were identified in the following aspects: - Identifying issues / expectations related to interested parties. - Mandatory inputs to management review. - Documenting business process flow. - Defining leadership commitments in compliance with requirements. Twelve opportunities for improvement were also identified in the report. All findings in this audit were addressed in preparation for the July ISO14001:2015 transition and surveillance audit. The ISO14001:2015 transition and surveillance audit was completed at the end of July 2018 and it was confirmed that WaterNSW achieved certification and transition to ISO14001: Major Non-Conformities There were no major nonconformities identified in the Annual Management Review D2018/73234 Review Date: September_2018 9