Environmental Management Strategy

Transcription

1 Document

2 Table of Contents 1 Commitment and Policy Introduction Purpose and Scope Glencore Corporate Practice EMS Supporting Documents Consultation ning Project Approvals Environment and Community Aspect and Impacts Risk Assessment Catastrophic Hazards Risk and Change Management Legal and Other Requirements Legal Compliance Other requirements Voluntary ning Agreement Objectives and Targets Mine Closure ning Implementation and Operation Roles and Responsibilities Training and Competency Consultation and Communication Internal Communications External Communications Social Involvement (SIP) Aboriginal Stakeholder Consultation Media Sharing of Information Community Complaints Dispute Resolution Independent Review Additional Noise Mitigation Measures Ulan Road Strategy Land Acquisition Issues specific to Aboriginal Stakeholders Environmental Incidents Incident Management Process Environmental Incident Categories Document Control and Records Management Operational Control Environmental Management s and Procedures Work Authorisation Ground Disturbance Permit Excavation Works Permit Contractor Management Page 2 of 70

3 3.8 Project Management Emergency Preparedness and Response Cumulative Impacts Measurement and Evaluation Environmental Performance Environmental Monitoring Programs Visual Amenity and Lighting Lighting Baseline Data Reporting Framework External Reporting Annual Review Internal Reporting SMP Reporting Access to Information Inspections Audits Evaluation of Compliance Non Conformity, Corrective Action and Preventative Action Review and Continuous Improvement Accountabilities Document Information Definitions Abbreviations Reference Information Change Information Appendix A - Glencore Values Appendix B - Environment and Community Risk Register Appendix C - Environmental and Community Training Needs Analysis Appendix D - Environmental Monitoring Locations Page 3 of 70

4 1 Commitment and Policy 1.1 Introduction The Ulan Mine Complex is situated in the central west of New South Wales. It is located in the Mid- Western Regional Council (MWRC) Local Government Area (LGA) near the village of Ulan; approximately 38 kilometres north-northeast of Mudgee and 19 kilometres northeast of Gulgong (Figure 1.1). Ulan Coal Mines Limited (UCML) operates the mine as a joint venture, managed by Glencore Coal Assets Australia (GCAA). UCML owns or has long term leases over the majority of land within the project area that will be subject to mining activities and required for surface facilities. The area is primarily surrounded by rural landholdings, native bushland and primary industries including agriculture, forestry, mining (including other coal mining operations) and extractive industries. The UCML landholdings are located within the headwaters of the Goulburn and Talbragar River catchment areas. Project Approval (PA 08_0184) was issued by NSW ning and Environment (DP&E), on 15 November 2010 for continued operations. PA08_0184 authorises current and proposed mining of the Ulan Mine Complex for the next 21 years, and production of up to 20 Mtpa (million tonnes per annum) of product coal. The approval provides for an open cut and Ulan West and Ulan Underground mines to operate twenty-four hours a day, 7 days per week. Infrastructure and supporting operations include the Bobadeen Irrigation Scheme (BIS) and Bobadeen Basalt Quarry (Figure 1.2). The approval was modified as follows: Environmental Assessment: Ulan Coal Continued Operations North 1 Underground Mining Area, Minor Modification to Ulan Underground & Ulan West Mine s & Proposed Concrete Batching t (Umwelt, 2011) - (MOD1) approved 7 December 2011 Land and Environment Court final orders issued on the 5 April Ulan West Mine and Construction Blasting (Umwelt, 2012) (MOD2) approved 29 May 2012 Environmental Assessment: Ulan West Modification (southern extension) (Umwelt 2015) (MOD 3) 14 March UCML are required to prepare and implement an (EMS) for the project. 1 1 PA 08_0184 Schedule 5, and Development Approval (DA) (for ML1468), Condition 1 until the completion of LWW3 at the Ulan Underground, PA prevails to the extent of any inconsistency. Page 4 of 70

5 Figure 1.1 Location of the Ulan Mine Complex Page 5 of 70

6 Figure 1.2 Ulan Coal Complex Operations Project Area Page 6 of 70

7 Figure 1.3 Biodiversity Offset Areas Page 7 of 70

8 1.2 Purpose and Scope The purpose of this EMS is to: document and implement the systems and processes which provide the means to apply consistent environmental and community management across the Ulan Mine Complex; ensure adherence to statutory requirements, including regulatory approvals and licences; comply with applicable legislation, standards, codes and other external requirements; align UCML s operating philosophy with the GCAA Health, Safety, Environment and Community (HSEC) framework and the principles of ISO14001; and manage and minimise environmental impacts. The EMS describes the process for planning, communication, documentation, monitoring, evaluation, review and feedback. UCML aims to maintain and improve environmental and community performance through regular monitoring, review and audits of the EMS and environmental performance. The EMS applies to the existing and future operations within land owned or managed by UCML (Figure 1.2 & Figure 1.3). Environmental management is the responsibility of all employees and contractors and the EMS applies to UCML management, employees and contractors. UCML aims to provide sufficient strategic planning, resources, controls, and leadership to maintain a high standard of management, continually improving performance, ongoing compliance with relevant, legal and other external requirements, and improved efficiency with regard to management. Environment and community responsibilities are defined, documented and communicated by establishing: Roles, responsibilities and accountabilities for specific risks and controls; Specific and measurable performance indicators; and Organisational structures and lines of reporting. The EMS and management plans are available on the UCML website: Glencore Corporate Practice The Glencore Corporate Practice (GCP) framework, includes the Glencore Values, Code of Conduct and HSEC Policies. Our Values are fundamental principles by which UCML conducts business. Everyone who works for Glencore, regardless of location or role, must comply with the Code of Conduct and encourage those around them to meet its requirements. Corporate policies reflect areas and issues of group-wide strategic importance, such as crisis management, human rights and anti-corruption. The GCAA HSEC framework provides group-level operational standards that detail expectations for management processes, procedures and achievements. Figure 1.4 The GCP Framework 2 PA 08_0184 Schedule 5, Condition 10 Page 8 of 70

9 1.3.1 EMS Supporting Documents This EMS is supported by specific documents, including management plans, procedures, forms, permits and approvals. These documents have been developed to: satisfy the relevant requirements of PA 08_0184 and DA ; satisfy the relevant statement of commitments made as part of PA 08_0184; satisfy the relevant conditions of other approvals, licences and other legal requirements, including Subsidence Management (SMP) and Extraction (EP) Approvals, Mining Operations (MOP), Water Licences and Environment Protection Licence (EPL) 394; identify the controls and mitigation measures that are in place to manage the potential impacts and risks associated with the operations; provide guidance in managing and mitigating community impacts associated with the operations; and incorporate the requirements of the GCP and applicable Standards, Guidelines and associated annexures, where appropriate. This EMS has been developed in accordance with: PA 08_0184; DA ; Statement of Commitments (Appendix 9 of PA 08_0184); SMP Approvals for LW 23-26, W1 and W2 and W3; SMP/EP Approvals for LW27-29, W4 W5 and LW C, E and F (North 1); SMP/EP Approvals for LW1,2,3 & 4 For Ulan West; identified environmental aspects and impacts; identified objectives and targets; regulatory requirements that apply to UCML s operations; environmental management requirements; and internal corporate and operational requirements. Figure 1.5 displays the structure of UCML s Environmental Management System, Identifying key management plans and monitoring programs. Table 1.1 details the relevant management plans and associated monitoring programs required by PA 08_0184. Table 1.3 details other management plans required by SMP/EP Approvals. Table 1.4 details other supporting documents in the Environmental Management System. Page 9 of 70

10 Figure 1.5 EMS and Supporting Documents Structure Page 10 of 70

11 Table 1.1 Management s & Monitoring Programs required by PA 08_0184 Condition Requirement Document Number 9, Schedule 3 Noise Management ULN SD PLN , Schedule 3 Blast Management ULN SD PLN , Schedule 3 Air Quality & Greenhouse Gas Management ULN SD PLN , Schedule 3 Subsidence Management and Extraction ULN SD PLN , Schedule 3 Water Management ULN SD PLN , Schedule 3 Site Water Balance Part of ULN SD PLN , Schedule 3 Goulburn River Diversion Remediation ULN SD PLN , Schedule 3 Erosion & Sediment Control ULN SD PLN , Schedule 3 Surface Water Monitoring Program ULN SD PLN , Schedule 3 Groundwater Monitoring Program ULN SD PLN , Schedule 3 Surface & Ground Water Response ULN SD PLN , Schedule 3 Biodiversity Management ULN SD PLN , Schedule 3 Heritage Management ULN SD PLN , Schedule 3 Aboriginal Conservation Management ULN SD PLN , Schedule 3 Old Ulan Conservation Management ULN SD PLN , Schedule 3 Bobadeen Homestead Conservation Management ULN SD PLN , Schedule 3 Ulan Road Strategy N/A 53, Schedule 3 Waste Management ULN SD PLN , Schedule 3 Integrated Mining Operations ULN SD PLN 0079 Construction Traffic Management ULN SD PLN 0051 Table 1.2 Management s & Monitoring Programs required by EPL 394 Condition Requirement Document Number POEO Act Pollution Incident Response Management ULN SD PLN 0089 Section 8 Dust Management Procedure ULN SD PRO 0068 Table 1.3 Other Management s & Monitoring Programs required by SMP/EP Approvals Condition Requirement Document Number Ulan Underground Mine 26, Schedule 3 Built Features Management ULN SD PLN , Schedule 3 Public Safety Management ULN SD PLN , Schedule 3 Essential Energy Management ULN SD PLN , Schedule 3 Subsidence Monitoring Program ULN SD PLN 0061 Ulan West Underground Mine 26, Schedule 3 Water Management for LW1-4 ULN SD ANN , Schedule 3 Land Management for LW1 4 ULN SD ANN , Schedule 3 Biodiversity Management for LW1-4 ULN SD ANN , Schedule 3 Built Features Management for LW1-4 ULN SD ANN , Schedule 3 Heritage Management for LW1 4 ULN SD ANN 0062 Page 11 of 70

12 26, Schedule 3 Public Safety Management for LW1 4 ULN SD ANN , Schedule 3 Subsidence Monitoring Program for LW1 4 ULN SD ANN , Schedule 3 Rehabilitation Management for LW1-4 ULN SD ANN 0065 Table 1.4 Other Internal EMS Supporting Documents UCML Document Document Number Social Involvement ULN SD PLN 0015 Environmental Monitoring Program ULN SD PLN 0032 Site Security Management ULN SD PLN 0022 Conceptual Mine Closure ULN SD PLN 0084 Moolarben Dam Operations & Maintenance ULN SD PLN 0058 Moolarben Dam Safety Emergency ULN SD PLN 0047 Spill Response Procedure ULN SD PRO 0061 Water Infrastructure Management ULN SD PLN 0088 Complaints Procedure ULN SD PRO 0001 Waste Management Procedure ULN SD PRO 0065 Waste tyre In pit Burial Procedure ULN SD PRO 0069 Annual Rehabilitation ULN SD ANN 0056 Community and Employee Information Line ULN SD PRO 0052 Product Stewardship Management ULN SD PLN 0086 Hydrocarbon & Hazardous Substances Procedure ULN SD PRO 0071 Bushfire Management ULN SD ANN 0086 Pre Clearing Survey Procedure ULN SD PRO 0054 Habitat Tree Felling Procedure ULN SD PRO 0073 Nest Box/Salvaged Hollow Installation Procedure ULN SD PRO 0057 Hollow Salvage Procedure ULN SD PRO 0056 Salvage and Reinstatement of Habitat Features other than Tree Hollows Procedure ULN SD PRO Consultation Consultation undertaken during the preparation of the EA included project briefings, a ning Focus Meeting and separate meetings with relevant government authorities to discuss specific issues. 3 This EMS was first submitted to DP&E on 31 March 2011, 4 it was approved, subsequent to review and comment, on 29 September It has since been re-submitted and, having incorporated feedback, the latest version was approved on 11 November 2015 Revised EMS and other management plans as required by the PA08_0184 are provided to the relevant government agencies as required including the Environment Protection Authority (EPA), DPI - Water, DRE and MWRC for comment. Section 7.4 of this EMS provides an historical summary of amendments. Copies of correspondence in relation to the development of this plan are available upon request. 3 Detail provided in Section 3 of the EA (Umwelt, 2009) 4 PA08_0184 Schedule 5, Condition 1(a) Page 12 of 70

13 2 ning 2.1 Project Approvals Development consents and project approvals under Environmental ning and Assessment Act 1979 (EP&A Act) applicable to UCML are provided in Table 2.1. Table 2.1 Current Development Consents & Project Approvals Approval Description Approval Authority Approval Date DA Stage 4 MLA 80 Application EIS Extension of Underground Mining Operations DP&E December 1999 Modification to DA Modification to DA Modification of Stage 4 Consent for communication tower DP&E June 2002 Modification of Stage 4 Consent for basalt quarry DP&E June 2003 Modification to DA Modification of DA for the installation of a reverse osmosis plant adjacent to Rowans Dam DP&E December 2008 PA 08_0184 Ulan Coal Continued Operations Project DP&E November 2010 PA 08_0184 MOD 1 Longwall extraction of the North 1 mining area Modify Ulan No. & Ulan West mine plans Concrete Batching t DP&E December 2011 PA 08_0184 Court Orders Land & Environment Court Judgement DP&E April 2012 PA 08_0184 MOD 2 PA 08_0184 MOD 3 Modify Ulan West mine plan LW1-5 Remove restrictions on construction blasts Minor amendments to European and natural heritage sites where blasting measures are applicable Modify Project Boundary and Area as well as Ulan West mine plan. Amendments to commitments regarding Aboriginal cultural heritage sites. DP&E May 2012 DP&E March 2016 Tables 2.2 and 2.3 summarise the requirements of PA 08_0184 issued in March 2016 as a result of MOD3, and the section of the EMS where the requirement has been addressed. 5 The surrender of DA will be provided in accordance with Schedule 2 Condition 9, within 3 months of the completion of longwalls 26, West 2, and West 3, or as otherwise agreed by the Director-General. Page 13 of 70

14 Table 2.2 Compliance Table for PA 08_0184 Condition Requirement Section Schedule 3 Condition 52 Schedule 5 Condition 1. Schedule 5 Condition 6 Schedule 5 Condition 7 Schedule 5 Condition 10 Visual Amenity and Lighting The Proponent shall: a) minimise the visual impacts, and particularly the off-site lighting impacts, of the main infrastructure area and associated ancillary surface works; b) take all practicable measures to further mitigate off-site lighting impacts from the project; and c) ensure that all external lighting associated with the project complies with Australian Standard AS4282(INT)1995 Control of Obtrusive Effects of Outdoor Lighting, to the satisfaction of the Secretary. The Proponent shall prepare and implement an for the project to the satisfaction of the Secretary. This strategy must: (a) (b) (c) (d) (e) (f) be submitted to the Secretary for approval within three months of the date of final Orders being made by the Land and Environment Court in proceedings No of 2010; provide the strategic framework for environmental management of the project; identify the statutory approvals that apply to the project; describe the role, responsibility, authority and accountability of all key personnel involved in the environmental management of the project; describe the procedures that would be implemented to: include: keep the local community and relevant agencies informed about the operation and environmental performance of the project receive, handle, respond to, and record complaints; resolve any disputes that may arise during the course of the project; respond to any non-compliance; respond to emergencies; and copies of any strategies, plans and programs approved under the conditions of this approval; and a clear plan depicting all the monitoring required to be carried out under the conditions of this approval. The Proponent shall notify the Secretary and any other relevant agencies of any incident associated with the project as soon as practicable after the Proponent becomes aware of the incident. Within 7 days of the date of the incident, the Proponent shall provide the Secretary and any relevant agencies with a detailed report on the incident. The Proponent shall provide regular reporting on the environmental performance of the project on its website, in accordance with the reporting arrangements in any plans or programs approved under the conditions of this approval. Within 1 month of the date of final Orders being made by the Land and Environment Court proceedings No of 2010, the Proponent shall: (a) make copies of the following publicly available on its website: the documents referred to in Condition 2 of Schedule 2; all current statutory approvals for the project; all approved strategies, plans and programs required under the conditions of this approval; the monitoring results of the project, reported in accordance with the specifications in any conditions of this approval, or any approved plans and programs; a complaints register, updated on a monthly basis; minutes of CCC meetings; the annual reviews of the project; any independent environmental audit of the project, and the Proponent s response to the recommendations in any audit; any other matter required by the Secretary; and (b) keep this information up-to-date, to the satisfaction of the Secretary. Section This document This document Section 2.1 Section 7 Section Section Section Section Section 3.10 Section Section 4.1 Section Section 3.5 Section Page 14 of 70

15 Table 2.3 Commitments relating to Visual amenity and Lighting Commitment UCML will implement the following visual controls to screen or filter views of the project infrastructure from residential and public road locations: maintaining vegetation screening along Ulan Road; ensuring that all lighting associated with the project complies with Australian Standard AS4282(INT)1995 Control of Obtrusive Effects of Outdoor Lighting; all buildings and infrastructure potentially visible to the public to be coloured in suitable natural tones, where practicable; directing light towards work areas and not towards private residences; progressive rehabilitation of disturbed areas; and revegetation will be progressively undertaken of the Goulburn River Diversion, as described in the approved Goulburn River Diversion Remediation (GRDRP). Section BMP Section Section Section BMP GRDRP Page 15 of 70

16 2.1.1 Environment and Community Aspect and Impacts An environmental aspect refers to an element of an organisation s activities, products or services which can have a beneficial or adverse impact on the environment and/or community. An environmental impact refers to the change which takes place in the environment as a result of the aspect. The identification of environmental and community aspects is an ongoing process that determines the past, current and potential impact of an organisation s activities on the environment 6. The Environment and Community Risk Register (ULN SD ANN 0054) is detailed in Appendix B. This register outlines the relevant environment and community risks associated with the Ulan Mine Complex and represents a summary of key risks identified in risk assessment processes undertaken in accordance with the Risk Management process and as required through different legislative guidelines. The risk register is updated annually after completing the annual review of environment and community risks as described in Section Risk Assessment The (ECM) is responsible for maintaining the operation s aspects and impacts register through the risk assessment process, where personnel identify risks to the environment and community, prioritise them in order of risk, assess the suitability of controls and determine if any additional controls are required. The typical inputs into the BBRA will include, but not be limited to the following: Baseline environmental studies; Review of environmental performance data; Review of any existing and/or proposed changes to the operations; Review of relevant legislation, standards, codes and additional external requirements; Industry experience; and Input from relevant stakeholders, particular needs, interests and local knowledge Catastrophic Hazards Catastrophic hazards are the most significant hazards. Generally they have a very low likelihood but a high potential consequence, and present a particular set of risks that require additional attention, management and continuing vigilance. The Ulan Mine Complex s business risk register maintains the catastrophic hazard s and associated control measures. Impacts are reviewed at least annually or as required by legislative requirements. UCML management continually support and maintain catastrophic hazard management culture by: Endorsing relevant requirements; Maintaining knowledge and awareness of catastrophic hazards; Monitoring the status of nominated control measures; Reviewing and responding to recommendations and actions emanating from assurance activities; and Committing the organisation to the ongoing task of better anticipating, understanding and, where reasonably practicable, eliminating or controlling catastrophic hazards Risk and Change Management Implications of changes operations and management are assessed against external and internal risk contexts and additional controls are identified and implemented where required. A decision, change or event is significant if it could potentially have a material impact on the achievement of objectives. The ECM is responsible for maintaining the changes concerning the environment and community in the compliance management tracking system. 6 AS/NZS ISO 14004:2004 Environmental Management Systems - General guidelines on principles, systems and supporting techniques. Page 16 of 70

17 2.2 Legal and Other Requirements Federal and State environmental legislation, regulations, planning policies and project specific approvals are considered in developing plans, reviewing risk assessments, preparing Ground Disturbance Permits (GDPs) and training and awareness or proposing changes to the approved mine plan. Approvals are registered on the GCAA intranet based Approvals Registry in accordance with CAA HSEC PCL Environmental Compliance Management. The main approvals are: Development approvals (PA 08_0184 and DA ); Environmental Assessment (2009 EA and modifications); Mining leases and approvals (e.g. SMPs, Mining Operations (MOP), Section 126 and 138 approvals etc.); Environment Protection Licence (EPL 394); Department of the Environment (DoE) approval (EPBC Ref: 2009/5252); Extraction s; Other licences and permits (e.g. Radiation, Dangerous Goods, Water Licences); and Native Title Agreement. Mining and exploration authorisations, issued in accordance with the Mining Act 1992, by the DRE are listed below. Table 2.4 Mining & Exploration Titles Instrument Authority Date of Grant Duration of Approval Mine Area Applicability Consolidation Coal Lease (CCL) 741 DRE 2/01/ /05/2027 All operations Mining Purpose Lease 315 DRE 3/08/ /08/2014* 3/08/2035^ Ulan Underground (Surface Lease) Mining Lease 1341 DRE 25/01/ /01/2015* Ulan Underground 25/01/2036^ Mining Lease 1365 DRE 9/03/ /01/2014* 9/12/2032^ Ulan Underground (Surface Lease) Mining Lease 1366 DRE 9/03/ /01/2014* 9/12/2032^ Ulan Underground (Surface Lease) Mining Lease 1467 DRE 17/04/2000 Ulan Underground 16/04/2021 (Surface Lease) Mining Lease 1468 DRE 16/05/ /05/2021 Ulan Underground Mining Lease 1511 DRE 24/04/2002 Ulan Underground 23/04/2023 (Surface Lease) Mining Lease 1554 DRE 1/09/2004 Ulan Underground 31/08/2025 (Surface Lease) Mining Lease 1656 DRE 03/03/2011 Ulan Underground 03/03/2032 (Surface Lease) Mining Lease 1697 DRE 22/05/ /05/2035 Ulan Open Cut Mining Lease Application (ML469) DRE TBA TBA Ulan Open Cut Mining Lease Application (ML470) DRE TBA TBA Ulan Open Cut Mining Lease Application (ML475) DRE TBA TBA Ulan Open Cut Exploration Licence 5573 DRE 12/03/ /02/2017 Ulan Underground Exploration Licence 7542 DRE 6/05/ /05/2015 Ulan West Note: *Expiry date of Lease. ^Period of Lease renewal until. Page 17 of 70

18 2.2.1 Legal Compliance The approval details including date of approval, renewal, reporting, conditions and current compliance status are recorded in a compliance database. Internal compliance audits on are undertaken on a regular basis and independent external audit are undertaken every commencing June 2013, unless the Secretary directs otherwise. 7 A review of legal and other requirements is undertaken annually as part of the EMS review. This includes reviewing the legislative changes advice provided annually by GCAA and any agency notifications. The ECM advises the General Manager and Operations Managers of any changes in legislation, policy and guidelines that may have implications for the Ulan Mine Complex. Awareness of ongoing changes to legislation, standards, codes and other external requirements is maintained through the receipt of regular updates from legal advisers, participation in industry groups such as the NSW Minerals Council and Hunter Coal Environment Group, notification from the General Manager Environment and Community (GMEC) and through access to legislation via the internet. The Environment and Community Coordinator (ECC) is responsible for ensuring that personnel and contractors are aware of their relevant legal and other requirements by reviewing and updating Induction Training packages as required Other requirements The following codes, programs and standards are relevant in addition to legal requirements: Australian Minerals Industry Enduring Value; Global Reporting Initiative (GRI); United Nations Global Compact; International Council for Mining and Minerals (ICMM); and The CEO Water Mandate Voluntary ning Agreement A Voluntary ning Agreement (VPA) was agreed with MWRC (in consultation with DP&E) on 16 March Contributions assist the provision of local infrastructure and services and maintenance of Cope Road. Ongoing consultation is conducted with MWRC. 2.3 Objectives and Targets Environment and community objectives and targets are developed in consideration of aspects and impacts identified through risk assessments, legal and other requirements, operational practices, industry standards and corporate objectives. They are established at the commencement of the year and reviewed as part of quarterly reviews. Objectives are focussed on continual environment performance improvement and targets include year on year reductions in number of incidents and community complaints and targets for completion of rehabilitation and or implementation of community programs. 2.4 Mine Closure ning The continued development and review of ULN SD PLN 0084 Conceptual Mine Closure (CMCP) for the Ulan Mine Complex is undertaken annually. 8 The Mine Closure is conceptual as the operation has a Life of Mine (LOM) of greater than five years. As part of the conceptual planning for mine closure, the development of preliminary closure criteria will be ongoing to ensure the operation is progressing towards achieving relinquishment. 7 PA 08_0184, Schedule 5, Condition 8 8 Integrated Mining Operations (MOP) ( ) (ULN SD PLN 0079) Page 18 of 70

19 3 Implementation and Operation The ECM will be responsible to ensure the appropriate resources are identified annually during the budgeting process to implement the EMS. 3.2 Roles and Responsibilities The management structure of the Ulan Mine Complex includes three separate operations. Figure 3.1 Ulan Mining Complex Management Structure Achieving a high standard of environmental management and outcomes is the responsibility of managers, employees and contractors. Positional roles and responsibilities for maintaining and implementing the EMS are provided in section 6. Roles and accountabilities specific to aspects are detailed in the relevant management plan. 3.3 Training and Competency Training and Competency Management Standards are maintained relevant to each operation i.e. Ulan Surface Operations, Ulan Underground and Ulan West Operations. Competencies are identified, assessed and recorded for each team member. The Environment and Community Training Needs Analysis (TNA) (Appendix C) is captured in the system and included in the training program. An induction package, including an introduction to the EMS is provided to new employees and contractors prior to commencing work. Induction training packages are revised and updated as required. Information from the TNA is reviewed during the preparation of the UCML Annual, to identify training requirements necessary to ensure all employees and contractors have obtained the necessary skills and knowledge. All training is to be competency based. The content of training packages will be dependent on the target audience, however environment and community training provided to UCML employees and contractors during the induction process will as a minimum include the following: the importance of conformance with the GCP and relevant standards; conformance with this EMS; relevant legal and other requirements; the potential environmental impacts and associated controls for general mining activities; their roles and responsibilities in achieving conformance; requirements of the EMS, including emergency preparedness and response requirements; and Page 19 of 70

20 the potential consequences of non-compliance with environmental and community policies and EMS requirements. Requirements for the education and awareness, instruction and communication relating to the environment, biodiversity and landscape functions are set out in the roles and accountabilities, and the competencies required for each position and role. Appropriate education and awareness regarding the environment, biodiversity and landscape function is provided to relevant personnel, using specialist advice as required. Each Training Coordinator will be responsible for ensuring all environmental training records are maintained for their site in accordance with the EMS and CAA HSEC PCL Environment and Community Training. 3.4 Consultation and Communication UCML recognises that implementing the EMS and improving its performance requires the cooperation of its entire workforce (including employees and contractors) and the effective communication between management and its workforce. UCML also recognises the knowledge and experience of its workforce is a valuable resource and it encourages its workforce to participate in the development, implementation and maintenance of its EMS. This is achieved through consultation and involvement in the development, communication, implementation and maintenance of the sites Annual and the setting of objectives, goals and targets. UCML have developed and implemented a Consultation and Communication Procedure (ULN SD PRO 0016) to establish a systematic consultative approach to decision making on issues that have Health Safety Environment and Community (HSEC) implications by ensuring: Hazards and issues are known, addressed and mitigated; Informed decisions are made; and People are motivated and encouraged to understand and accept efforts to improve performance. The SIP outlines the management approach to external stakeholder engagement, community development and complaints management (Section 3.5.4) Internal Communications Communications between all levels of mine management, employees, contractors and other relevant stakeholders are undertaken in accordance with Consultation and Communication Procedure (ULN SD PRO 0016). Internal communication at the Ulan Mine Complex includes (but is not limited to) the following: Induction Training; Pre-shift Talks; Crew Talks; Core Hazard Review Meetings; Management Meetings; HSEC/SD Committees; Project Control Group meetings; Safety Alerts; Tool Box Talks; Work Permits; Newsletters; ; Safety Interactions; and ned Task Observations External Communications Communications between UCML and external stakeholders are undertaken in accordance with the SIP. Key external stakeholders identified in the SIP include: Page 20 of 70

21 Government agencies; Local communities; The Community Consultative Committee (CCC); Registered Aboriginal Groups; Regional environmental groups; and Neighbouring mining operations. The SIP identifies the social impacts, community concerns, needs and social risks regarding operations at the Ulan Mine Complex. Stakeholder consultation is undertaken at all phases of the project life cycle - including development, concept, operational and mine closure Social Involvement (SIP) The SIP has been aligned with the GCP and other relevant standards and guidelines and describes the processes to uphold and promote human rights and respect cultural considerations and heritage, considerations of community safety and environmental impacts, and social investment activities. The SIP is aimed at enhancing the socio-economic capacity and well-being of the communities associated with our activities, avoiding dependency and contributing to the development of sustainable livelihoods. The SIP provides for a strategic framework to engage local communities that includes the following: Identifying social and community issues; Engaging with the community, as appropriate; Engaging with indigenous communities; Providing support to the communities through social investment activities; Developing a community strategy; Implementing and maintaining a stakeholder engagement strategy; Managing performance; Implementing and maintaining project specific consultation strategies; Implementing and maintaining a community inquiry/complaint system; Reporting to the community, as appropriate; and Managing media engagement Aboriginal Stakeholder Consultation Media Consultation with UCML s registered Aboriginal Stakeholders is undertaken in accordance with the SIP and ULN SD PLN 0013 Heritage Management (HMP). The HMP details the consultation strategies that UCML undertakes with the registered Aboriginal stakeholder groups. All media communications must be prepared in accordance with the SIP. Media statements are used at UCML on an as needs basis to address specific issues and in response to particular events of significance. Only the UCML General Manager and Operations Managers are authorised to liaise with the media and issue media statements Sharing of Information UCML have developed mechanisms for sharing information and good practice with both internal and external stakeholders. These methods include: Reporting of monitoring and performance data to corporate, regulators and the community; Participation in internal forums such as Environment & Community meetings to discuss issues, challenges and good practice; Involvement in research programs such as ACARP 9 ; Participation within industry forums such as the NSW Minerals Council Environment and Community conference; Providing Case Studies for the Annual Report; and External Reports and site websites. 9 Australia Coal Association Research Program (ACARP) Page 21 of 70

22 To facilitate the development of an extensive environmental monitoring network in the vicinity of the Village of Ulan and other private residences adjacent to the Ulan Mine Complex, UCML have developed a Data Sharing Agreement (ULN SD CON 0001) with Moolarben and Wilpinjong coal mines to enable access to monitoring results across all operations Community Complaints Community complaints management includes receipt of complaints, investigation, implementation of appropriate remedial action, and feedback to the complainant as well as communication to site management or personnel and notification to external bodies, such as the EPA, where necessary. Community complaints received by the Ulan Mine Complex are managed in accordance with the SIP. UCML have developed ULN SD PRO 0001 Complaints Procedure to assist in recording complaints, complaint investigation and follow up actions. UCML maintain a 24 hour, 7 day a week community and employee information telephone line and address ulancommunity@glencore.com.au to: manage complaints received by UCML that may be a result of mining and/or associated activities conducted within land owned or managed by UCML; provide access to open cut blasting information for interested stakeholders; and provide access and incident information to employees during emergency situations. The ECM (or delegate) will investigate the complaint, which will include contacting the complainant, within 24 hours of the complaint, to discuss the complaint and recommending corrective or preventative action. Wherever practicable this will include meeting the complainant in person. A review of the effectiveness of the corrective or preventative action is to be conducted within one month of the complaint and the relevant work procedures updated if required. Documentation of changes to work procedures is to be undertaken and the updated procedures communicated to relevant personnel. Details of community complaints will be provided to GCAA as part of the monthly internal environmental reporting process (Section 4.3). The details of community complaints will be kept, in accordance with UCML's document control procedure, for at least four years (Section 3.6) and recorded in a database for tracking actions for historical purposes. Community complaints will be continually assessed to note any trends that may require the implementation of further mitigation measures. Further community information, including UCML s contact details are provided on its website 10 for the purposes of external review and transparency Dispute Resolution Disputes with internal stakeholders that may arise during operations at the Ulan Mine Complex will be managed in accordance with Consultation and Communication Standard (ULN SD PRO 0016). Disputes arising during operations with external stakeholders will be managed in accordance with PA08_0184 conditions Independent Review In the event a landowner considers the Ulan Mine Complex to be exceeding the relevant project criteria 11 they may request an independent review of the Secretary. 12 UCML will provide such review, as directed, within 2 months, consistent with the requirements specified in PA08_0184. In the event no exceedance is identified, the independent review will cease and if an exceedance is identified, UCML will be required to implement mitigation or instigate the acquisition process Additional Noise Mitigation Measures Upon receiving a written request from the owner of any residence on the land listed in Tables 1 or 6 of PA 08_0184 and on privately-owned land where subsequent noise monitoring shows that the noise generated by the project is greater than or equal to LA eq (15 minute) 38 db(a) on a systemic basis, UCML shall implement additional noise mitigation measures (such as double glazing, insulation, 10 PA 08_0184, Schedule 5, Condition 10, of a 11 PA 08_0184, Schedule 3 12 PA 08_0184, Schedule 4, Conditions 3-5 Page 22 of 70

23 and/or air conditioning) at the residence in consultation with the owner. These measures must be reasonable and feasible. If within 3 months of receiving this request from the owner, UCML and the owner cannot agree on the measures to be implemented, or there is a dispute about the implementation of these measures, then either party may refer the matter to the Secretary for resolution Ulan Road Strategy The Ulan Road Strategy provides for the upgrade and maintenance of Ulan Road between Mudgee and the entrance to the underground surface facilities at the Ulan mine over the next 21 years. Agreement on the Ulan Road Strategy, in conjunction with Moolarben Coal Mines (MCM), Wilpinjong Coal Mine (WCM) and MWRC, was achieved in If there is any dispute between the various parties involved in the implementation of the strategy, then any of the parties may refer the matter to the Secretary for resolution Land Acquisition Land owners with acquisition rights are entitled to request that UCML purchase their property at current market value in addition to reasonable costs for legal advice, relocation and disturbance. 13 The terms of purchase and dispute resolution processes are detailed in Condition 6 of Schedule 4 in PA08_ Issues specific to Aboriginal Stakeholders In accordance with the HMP, when previously unrecorded Aboriginal heritage evidence is identified within the Project Approval Boundary (see Figure 2) during the course of operations or further heritage investigations 14, this evidence will be subject to temporary protection, recorded and appropriate management strategies implemented, in consultation with the registered Aboriginal stakeholders. Management procedures are outlined in the HMP and these vary depending on the nature of the heritage evidence (site type), the level of significance of the evidence, and the type of proposed impacts. Where previously unrecorded Aboriginal sites of moderate to high, or high significance will be subject to impacts, mitigation measures as determined by the consensus agreement of UCML and the registered Aboriginal stakeholders will be implemented. In the event that consensus agreement cannot be reached, the procedures for resolution are specified in the HMP. However, in relation to Aboriginal skeletal remains (refer to the HMP) UCML will manage the remains in consultation with the registered Aboriginal stakeholders and DP&E. Where consensus agreement cannot be reached, the matter will be referred to the Secretary for resolution Environmental Incidents An incident is defined as a set of circumstances that causes or threatens to cause material harm to the environment, and/or breaches or exceeds the limits or performance measures/criteria in PA 08_0184 and EPL 394. Reportable incident notifications are detailed in the Pollution Incident Response Management (ULN SD PLN 0089). 15 The ECM (or delegate) must immediately contact the EPA and the DP&E 16 after becoming aware of an incident in accordance with the PIRMP by telephoning the Environment Line service on and the other relevant agencies. Written details of the incident will be provided to the Secretary and the EPA within 7 days of the date on which the incident occurred. All reportable incidents are detailed in the Annual Review (AR) and the EPL Annual Return, if appropriate. 13 PA 08_0184, Schedule 4, Condition 6 14 Other than new evidence identified during heritage mitigation works in a location where evidence has previously been recorded (for example, new stone artefacts identified during the surface collection or excavation of a known site). Such evidence is dealt with under Section 3.8 of the HMP (ULN SD PLN 0013). 15 Required by Protection of the Environment Operations Act Condition 6, Schedule 5 of PA 08_0184 Page 23 of 70

24 Incident Management Process Personnel (UCML employees and contractors) must report environmental incidents to their immediate supervisor/site contact who will contact a member of the Environment and Community Department, immediately after becoming aware of the incident. The details and final investigation results from all environmental incidents must be recorded. Environmental incidents are recorded in CMO. The UCML incident management process follows the key steps below, which includes: Secure the Scene: Immediately after an environmental incident occurs or a hazard is identified, all attempts to be made to remove or isolate the risk or impact and secure the location. Gather Information: Once notified of the incident, the ECM (or delegate) will establish initial facts such as what exactly happened, names of all people involved (including witnesses), time and location and initial action taken. Take witness statements and gather any other evidence available. Determine Investigation Level: The ECM (or delegate) will determine the level of investigation regarding the category of the environmental incident (refer to Table 9), for example: Category 3 and above: Incident Cause Analysis Method (ICAM) or other comprehensive investigation process required, facilitated by a competent incident investigator; Category 2: Investigation required conduct mini ICAM Category 1: Complete incident report and consider need for mini-icam Commence ICAM: The detail and quality of the investigation should be proportional to the risk or impact rating of the environmental incident and recorded Ulan Coal Incident Report & Investigation Form. The investigation should be conducted as soon as practical after the event. Review and Classify Information and Determine Actions: The ECM (or delegate) shall complete the investigation of the incident, in conjunction with the persons involved, and recommend actions to be taken. From the analysis of the causes, determine the appropriate action to prevent a recurrence of the incident. Complete Actions: Interim corrective actions, to address direct causes of incidents, will be lodged in the site HSEC incident/ action database. Generally, these actions will be completed within one month. Long term preventive actions will have a direct link to the root cause of the incident and target preventing a recurrence and reducing the risk or impact. Trend Analysis and Reports: The ECM will collate and analyse the incident and investigation data to identify trends in order to take actions to reduce the likelihood and severity of reoccurring incidents. The analysis will take place annually. Results will be used for continuous improvement and to provide feedback on the effectiveness and where necessary initiate appropriate responses Environmental Incident Categories Table 9 provides the definitions to assist UCML to determine the appropriate environmental incident category, with typical examples of each category. Page 24 of 70

25 Table 3.1 Environmental Incident Category Matrix Page 25 of 70

26 3.5 Document Control and Records Management UCML have developed a Document Control and Records Management procedure (ULU SD PRO 0034). This procedure details the processes implemented at UCML in relation to document control and records management including: The structure and application of the SD Management Framework The management of control of SD Documentation (internal and external) in the SharePoint document management system Document development or review, approval and implementation Consultation and authorisation processes associated with document development or review; and SD Records Management physical and electronic data, records and samples (including retention periods) Environmental documents, including correspondence and environmental monitoring data is kept on site for a minimum of four years or as required with relevant statutory requirements in a centrally maintained filing system. In accordance with EPL 394 Schedule 05 Condition M1.3 the following records must be kept in respect of any samples required to be collected for the purposes EPL 394: a) the date(s) on which the sample was taken; b) the time(s) at which the sample was collected; c) the point at which the sample was taken; and d) the name of the person who collected the sample. The UCML Intranet is the system used by the Ulan Mine Complex for the control of all EMS and HSEC documents. The ECC and Environment Community Officer (ECO) will be responsible to ensure all versions of the EMS and related documents on UCML Internet are current and available to employees and contractors. UCML respects the privacy of its stakeholders, customers and visitors. Personal information collected by UCML is treated as confidential. Personal information is information relating to an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion provided. Personal information will not be released unless the law requires or permits it or permission is given. 3.6 Operational Control Where activities are identified as having an environmental impact, operational controls and procedures must be implemented. To ensure that these activities are carried out in accordance with the objectives and targets, a range of operational controls, including (but not limited to) shall be utilised: Environmental Management s; Environmental Procedures; Glencore Coal Assets Australia HSEC standards; Works Authorisation (WA) Forms; Ground Disturbance Permits (GDP) Work Permits; and UCML s BBRA Environmental Management s and Procedures Supporting the EMS are a number of Environmental Management s (EMPs). The EMPs have been developed to satisfy the requirements of PA 08_0184 and identify the controls and mitigation measures that are in place on site to manage the potential environmental impacts associated with UCML s operations. They are integral components of the EMS. The plans identify and define legislative requirements, environmental and community aspects and impacts and the actions required in order to satisfy corporate requirements (Section 4.6.3). EMPs have made reference to (and been developed in accordance with): identified environmental aspects and impacts; Page 26 of 70

27 identified objectives and targets; internal corporate requirements; and regulatory requirements. EMPs will be accessible via the UCML Intranet and relevant personnel will receive appropriate training in regards to the requirements of these plans. These personnel will have the authority to implement the plans and to stop work should there be any real or potential risk to the environment or community as a result of mining activities. These EMPs will be properly communicated to the work force via training programs identified in Section 3.4. Where required, UCML will also make EMPs publically available on UCML s website Work Authorisation A Work Authorisation Form must be completed prior to the commencement of: all tasks undertaken by contractors (excluding labour hire contractors); or when anyone conducts work covered by a work permit (Figure 7). The Work Authorisation Form, which incorporates a Safe Work Method Statement (SWMS), shall be maintained for the duration of the task at the job site. Upon completion of the task the completed authorisation form will be forwarded to the relevant Task Coordinator. The introduction of the Work Authorisation Form approval process has been established in order to: ensure compliance with UCML s statutory obligations; ensure appropriate environmental controls are identified and implemented for new projects/tasks; and ensure due consideration is given to potential environmental, community and heritage impacts identified for new projects/tasks. Figure 3.2 UCML Specific Work Permits Page 27 of 70

28 Additional planning instruments may be required prior to the introduction of a new project/task to site, relative to the scale of the project proposed. A copy of the Work Authorisation Form is maintained on the UCML s Intranet. The two main work permits relevant to environmental management at UCML are the Ground Disturbance Permit and the Excavation Works Permit Ground Disturbance Permit The purpose of the Ground Disturbance Permit (GDP) is to ensure site clearing of vegetation and topsoil is planned and carried out in a manner to minimise impacts of flora, fauna, water ways, heritage, provate property for example. This work activity should comply with the site approval conditions, management plans and in accordance with this site permit. All works must be undertaken in an environmentally responsible manner so as to ensure conservation of natural resources and the natural environment. Ground disturbance includes drilling, clearing/grubbing, non-habitat tree disturbance, trenching, access roads etc. Until the ECM (or delegate) is satisfied that the proposed work activity complies with the site approval conditions, the proposed work cannot commence Excavation Works Permit The Excavation Works Permit must be completed for any work involving the excavation or filling of trenches, drilling, placement of pegs into the ground, ditches, shafts, wells, tunnels and pier holes. Until the ECM (or delegate) is satisfied that the proposed work activity complies with the site approval conditions, the proposed exaction work cannot commence. 3.7 Contractor Management All contractors and suppliers (including designers and manufacturers) are to uphold Glencore Corporate Practice, HSEC Standards and Guidelines. Systems and procedures shall be established, implemented and maintained to confirm that contractors and suppliers (including designers and manufacturers) have adequate resources, systems and processes to identify and comply with applicable legislation, standards, codes applicable to the products or services they are supplying or their relationship with site. Contractors and suppliers (including designers and manufacturers) shall be managed and/or monitored through systems that include: Documentation of roles, accountabilities and lines of communication; Setting, monitoring and reporting on targets; Monitoring and reporting on compliance with contractual obligations; Feedback on performance throughout the duration of the contract; Consequences for HSEC non-compliance; and Post completion including formal handover, briefing of safe use of plant and/or equipment installed or modified, evaluation of performance and close out of documentation etc. For the purposes of clarification, where there is inconsistency between a Contractor s Management System and this EMS, this EMS will prevail to the extent of that inconsistency. 3.8 Project Management Project Management at the Ulan Complex will be undertaken in accordance with Project Management Procedure (ULN SD PLN 0046). The careful identification of hazards and evaluation and control of risks and impacts of projects at each stage of the project/operation life cycle, including major projects such as new greenfield sites through to the introduction of new plant, equipment and infrastructure to the site. The integration of performance and risk management systems into the project life cycle management system. Early development and regular review of mine closure plans (MCPs). Page 28 of 70

29 All major projects will be managed through the project management manual found which is maintained on the intranet. Key components of the project management system that is implemented and maintained include: Compliance with Glencore Corporate Practice, Standards, Guidelines and relevant legislation, standards, codes, and additional external requirements across all phases of the project life cycle; Construction risks and impacts, constraints and opportunities are managed across all phases of the life cycle; Closure planning requirements are considered in the design, construction and operational phases of the project so as to minimise closure costs and risks and impacts; Assignment of responsibility for design and development activities to the appropriate qualified personnel; Requirement to include design inputs and outputs and the evaluation of alternative designs to address identified hazards and assessed risks and impacts; A design control process that manages changes to the design; Management of technical interfaces between different disciplines; Capacity to apply experience from previous projects and current operations in the appropriate context to project development; Design and construction that complies with sound engineering and technical standards; Review, approval and monitoring processes that measure performance, progress and outcomes; Conduct of audits over the life of the project to monitor performance, progress, milestones and outcomes; and Commissioning plan that addresses operability requirements and employee competency, for example, supervision, training and emergency control. 3.9 Emergency Preparedness and Response The Ulan Mine Complex has developed an Emergency Response Management (ERMP) (ULN SD PLN 0024) maintained on UCML s Intranet. The ERMP covers potential environmental emergencies as well as other emergency situations that relate to the operations. All responses to emergencies will be carried out in accordance with this plan. The ERMP includes emergency situations identified from risk assessments to identify foreseeable site emergencies, and assigns responsibilities and lists contacts in case of an emergency, as well as internal and external communication procedures. The ERMP includes, but is not limited to: A site plan of the operation; The roles and accountabilities associated with emergency response team; Training requirements; Information on emergency response personnel will gain access to and identify all service isolation points, emergency equipment; Procedures for: - Responding to specific likely scenarios; - Safe evacuation, both from underground and from surface buildings; - Initial and ongoing emergency notification to internal and external resources, including contact details for individuals and organisations required; Maintaining an events and communication log. Actions after the emergency has passed: Control of any remaining hazards; and Arrangements for cleaning up and restoring the site. UCML will undertake simulated emergencies to physically test the emergency response system as required by the ERMP Cumulative Impacts The local environment in which UCML currently operates has changed substainally with the development of recent projects. UCML were historically the only coal extractive operation within the Page 29 of 70

30 area, however with the commencement of the Wilpinjong Coal Mine (WCM) and Moolarben Coal Mine (MCM), cumulative impacts have become a siginificant consideration to UCML s continued operations. Other projects in the vicinity of Ulan Mine Complex include existing clay and sandstone quarrying activities. Where possible, the ECM will continue to work with above mentioned operations to minimise the potential cumulative impacts, in accordance with relevant requirements of the Project Approval. UCML inconsultation with WCM and MCM, have developed, or are in the process of developing, the following agreements and protocols, including: Water Sharing Agreement with MCM; Head of Agreements with WCM; Blast Notification Protocol with both MCM and WCM; The Ulan Road Strategy with both MCM and WCM ; Data sharing agreement with MCM and WCM; and Noise and dust monitoring synergies with MCM. The site s current environmental management plans and monitoring program are designed to ensure that the operation s activities (including proposed new works) do not result in any significant increase in cumulative impacts upon the environment or local community. Section 3.7 of this EMS outlines the existing operational controls in place at UCML to mitigate the potential impacts of the operation, which would also apply to mitigating cumulative impacts. 4 Measurement and Evaluation 4.1 Environmental Performance Establishing and assessing the adequacy of the environmental monitoring network for the Ulan Mine Complex to ensure compliance with PA 08_0184 and EPL 394 requirements will be the responsibility of the ECM. The maintenance of the environmental monitoring network and routine data analysis will be the responsibility of ECC and ECO. The results from the environmental monitoring program will be evaluated routinely to determine if the project is complying (Section 4.6) with all the relevant project specific criteria identified in Schedule 3 of the PA08_0184and relevant EPL condition requirements. The measurement and evaluation component of the EMS covers not only compliance with the site s PA08_0184 and EPL requirements, the performance of the operation against its objectives and targets. The results are analysed and used to identify areas of success and areas requiring further attention for improvement. Through the ongoing monitoring of performance and routine management reviews, the suitability, adequacy and effectiveness of strategies, plans, systems, programmes and processes are routinely assessed and actions are taken to improve performance across the organisation. UCML are able to determine EMS non-compliances from the following: site inspections; internal and external audit results; incident and complaint records; environmental monitoring results; quarterly review of performance against objectives and targets; and performance criteria Environmental Monitoring Programs UCML has developed an internal Environmental Monitoring Program (EMProg) (ULN SD PLN 0032) to consolidate the various monitoring requirements of the Project Approval, EPL and other environmental approvals into a single document. The EMProg (ULN SD PLN 0032) consolidates and outlines environmental monitoring undertaken by UCML to assess environmental performance of its mining Page 30 of 70

31 operations and the Bobadeen Irrigation Scheme (BIS) to determine compliance with UCML s various regulatory requirements. The ECC and ECO are responsible for ensuring environmental monitoring is undertaken in accordance with the EMProg. UCML will only engage suitably professionally trained personnel to conduct environmental monitoring applying relevant standards and using standardised monitoring techniques with calibrated equipment. The ECC and ECO will keep calibration records of the monitoring equipment used. Calibration will be undertaken in accordance with the equipment manufacturer s recommendations. Analysis of samples is to be conducted under quality control procedures. Monitoring requirements are outlined in each respective management plan associated with the aspect being examined. Figures detailing UCML s environmental monitoring programs are included in Appendix D Visual Amenity and Lighting Lighting UCML operate a twenty-four (24) hour operation. The facilities are lit at night; however, since operations in this area are limited to mine access and hygiene activities the level of lighting required and its impacts are minimal. UCML have significant buffer lands between the operations and adjacent receptors which mitigate against lighting impacts. Lighting is directed away from the points along Ulan Road where the mine is visible. On site rehabilitation and screen planting, along with the fact that mining activities in the open cut are typically under the pre-existing surface level of the ground, reduces the visual impact of lighting from open cut operations. Australian Standard AS4282 (INT) 1997 Control of the Obtrusive Effects of Outdoor Lighting was first introduced by Standards Australia in The current 1997 standard supersedes the earlier standard. In November 2010 UCML engaged Multiskilled Resources Australia to undertake an audit of UCML s operations to determine compliance with AS4282 (INT) 1997 Control of Obtrusive Effects of Outdoor Lighting (Multiskilled Resources Australia, 2010). The audit found that UCML generally complied with AS4282. A number of recommendations were made to reduce lighting impacts from the operation. These recommendations were entered into XstraSafe as actions for follow up by relevant people. A lighting audit will be undertaken annually for all new infrastructure to ensure UCML is complying with AS Buildings and Infrastructure Where it is possible to dictate a colour preference, all infrastructure will be painted a colour similar to Dulux colour bond Rivergum Green. The condition of painted structures will be assessed periodically and repainted as required. Buildings and structures will be designed and constructed so as to blend as far as possible with the surrounding landscape. As mentioned in Section above, a native tree screen has been planted along Ulan Road to reduce the visual impact of the CHPP infrastructure area on users of the Ulan Road. These trees were planted in 2008 and, as they grow, will continue to reduce visual impacts of the mine on passing motorists. 4.2 Baseline Data In accordance with PA 08_0184, all relevant management plans and studies will be prepared with a detailed baseline data assessment to provide a comparison for assessing any potential impacts from the Ulan Mine Complex. In addition the following baseline data assessments required by the PA08_0184must be undertaken for: Condition 13, Schedule 3: establish the baseline condition of the buildings and/or structures on the land or update the previous property inspection report; Page 31 of 70

32 Condition 26(h), Schedule 3: a program to collect sufficient baseline data for future Extraction s; Condition 38(a), Schedule 3: detailed baseline data on surface water flows and quality in creeks and other water bodies that could be affected by the project; Condition 39(a), Schedule 3: detailed baseline data of groundwater levels, yield and quality in the region, and particularly any groundwater bores, springs and seeps; Condition 47(d), Schedule 3: baseline dilapidation surveys of all heritage items potentially affected by subsidence and/or blasting; Condition 1, Schedule 4: any privately-owned land within 2 kilometres of the approved open cut mining pit on site that they are entitled to ask for an inspection to establish the baseline condition of any buildings or structures on their land, or to have a previous property inspection report updated; Condition 2(a) UCML shall ensure that the management plans required under this approval are prepared in accordance with any relevant guidelines, and include detailed baseline data; and Statement of Commitments 6.5.5: Establish baseline ecological, hydrological and geomorphological conditions of the Talbragar River downstream of the discharge point. Baseline studies will be conducted at the concept, pre-feasibility and exploration phase of projects or as soon as practicable after acquisition of an operation and for major modification to an existing operation. Baseline studies will be conducted at the Conceptual, Pre-feasibility and Feasibility stages of a project. 4.3 Reporting Framework External Reporting All external reporting will be the responsibility of the ECM. A summary of UCML external reporting requirements are summarised below in Table 4.1. Page 32 of 70

33 Table 4.1 External Reporting Requirements External Report Frequency Recipients Regulatory Requirement Incident Reporting As Required (refer to Section & Section 3.5.8) EPA DP&E EPL 394 PA08_0184 EPL Annual Return Annually EPA EPL day EPL Monitoring Reports Every 14 days UCML Internet EPL 394 Annual Review Annually DP&E DRE EPA DPI - Water CCC MWRC PA 08_0184 AEMR Guidelines for MOPs prepared to EDG03 requirements National Pollution Inventory Report (NPI) Annually EPA National Environmental Protection Measure National Greenhouse and Reporting System (NGERS) Annually Clean Energy Regulator National Greenhouse and Energy Reporting Act 2007 Community Newsletters Twice annually Internet Local landholders SIP Community Complaints Monthly Internet PA 08_0184 Quarterly Monitoring Results Quarterly Internet PA 08_0184 DP&E SMP Status Reports 4 monthly DRE DPI Water OEH SMP Approvals End of Panel Reports Within 3 months of the end of mining in panels DP&E DRE SMP Approvals Annual Report On or before anniversary date of Approval DoE Approval (EPBC Ref: 2009/5252) Annual Report (Subsidence) Provied in the Annual Review DP&E DRE OEH SMP Approval (Ulan West LW1-2) Annual Review The ECM (or delegate) will prepare a review of the environmental performance of the Ulan Mine Complex to the satisfaction of the Secretary (the Annual Review), in accordance with the requirements of PA 08_0184 and the DP&E Annual Review Guideline, by the end of March each year. The review will: a) describe the development (including any rehabilitation) that was carried out in the past year, and the development that is proposed to be carried out over the next year; b) include a comprehensive review of the monitoring results and complaints records of the project over the past year, which includes a comparison of these results against the: o o o relevant statutory requirements, limits or performance measures/criteria; the monitoring results of previous years; and the relevant predictions in the EA; c) identify any non-compliance over the past year, and describe what actions were (or are being) taken to ensure compliance; Page 33 of 70

34 d) identify any trends in the monitoring data over the life of the project; e) identify any discrepancies between the predicted and actual impacts of the project, and analyse the potential cause of any significant discrepancies; and f) describe what measures will be implemented over the next year to improve the environmental performance of the project Internal Reporting Several internal environmental reports are prepared on a monthly basis by the ECC and ECO, including; The Environment and Community Status Report to the Group Environmental Manager; and Environmental monitoring results, to regularly provide information on the environmental performance of the project on UCML s website. The Environment and Community Status Report contains the following information: Non-compliance with legal and other requirements; Summary of environmental incidents; Summary of community complaints; and Details of any pending/upcoming approvals. On a quarterly basis an SD review is undertaken with Glencore to review performance against objectives and targets (i.e. updates on the progress of the Annual ). UCML will also communicate relevant environmental and community information to employees, contractors and visitors through newsletters, inductions and Tool Box Talks etc. SD data collected internally for reporting to external organisations is collected using the Glencore database and NGERS reporting platform. Review and verification of data is undertaken in accordance with SD Database Reporting and the NGERS Standard - Facilities Requirements SMP Reporting Subsidence Status Management Report Reporting conditions within each SMP Approval submission of a Subsidence Status Management Report to the Mine Subsidence Board, the Director of Environmental Sustainability (DPI) and the Principal Subsidence Engineer (DPI) every four months i.e. in March, July, August and November, until completion of subsidence in the application area. The report may also be made available to other relevant stakeholders if requested. The report will generally include but not be limited to: a) the current face position of the LW panel being extracted; b) a summary of any subsidence management actions undertaken by UCML in the period subsequent to the last status report; c) a summary of any comments, advice and feedback from consultation with stakeholders in relation to the implementation of the SMP approval (including the preparation, implementation and review of plans, programmes, reports or strategies required by this approval) undertaken or received in the period subsequent to the last status report and a summary of UCML s response to the comments, advice and feedback given by the stakeholders; d) a summary of the observed and/or reported subsidence impacts, incidents, service difficulties, community complaints, and any other relevant information reported to UCML in the period subsequent to the last status report and a summary of UCML s response to these impacts, incidents, service difficulties and complaints; e) a summary of subsidence development based on monitoring information compared with any defined triggers and/or the predicted subsidence to facilitate early detection of potential subsidence impacts; f) a summary of the adequacy, quality and effectiveness of the implemented management processes based on the monitoring and consultation information summarised above; and Page 34 of 70

35 g) a statement regarding any additional and/or outstanding management actions to be undertaken or the need for early responses or emergency procedures to ensure adequate management of any potential subsidence impacts due to LW mining. When requested, UCML will also provide a copy of these reports to the Mine Subsidence Board, the Director of Environmental Sustainability (DPI), owners/operators of any infrastructure within the application area and any other stakeholders. End of Panel Report Conditions within each SMP Approval require submission of an End of Panel Report to the Director, Environmental Sustainability (DPI), within 3 months of extraction being completed for each LW panel. This report will encompass environmental and subsidence monitoring, including a comparison of actual impacts with predicted subsidence impacts as follows: a) include an analysis of these monitoring results against the relevant: o impact assessment criteria; o monitoring results from previous panels; and o predictions in the SMP; b) identify any trends in the monitoring results over the life of the activity; and describe what actions were taken to ensure adequate management of any potential subsidence impacts due to LW mining. Incident Reporting Conditions within each SMP Approval require that an incident report is provided to the Mine Subsidence Board, the Director Environmental Sustainability (DPI), the Principal Subsidence Engineer (DPI) and the owners/operators of any infrastructure within the application area notification within 24 hours of occurrence or identification of the following during the development of subsidence caused by LW mining: a) Any significant unpredicted and/or higher than predicted subsidence and/or abnormalities in the development of subsidence; b) Any exceedance of predicted impacts on groundwater resources and/or the natural environment that may have been caused (whether partly or wholly) by subsidence; c) Any observed subsidence impacts adverse to the serviceability and/or safety of infrastructure and other built structures that may be affected by LW mining; d) Any significant subsidence induced cracking and/or ground deformations observed in any surface areas within the SMP application area; e) Any adverse subsidence impacts reported by a relevant stakeholder, and f) Any other relevant information requiring prompt notification. The information will be made available to other relevant stakeholders, if requested. Annual Report The Leasholder shall prepare an annual report. This report shall be submitted to the Secretary within twelve months of the date of this approval and annually thereafter. The annual end of panel report must: a) include a summary of the subsidence and environmental monitoring results for the year; b) include an analysis of these monitoring results against the relevant; c) impact assessment criteria, d) monitoring results from previous panels, and e) predictions in the SMP; f) identify any trends in the monitoring results over the life of the activity; and g) describe what actions were taken to ensure adequate management of any potential subsidence impacts due to longwall mining. Note: The requirement of this condition may be satisfied via an Annual Review prepared under conditions of development consent or project approval. Page 35 of 70

36 4.3.5 Access to Information Regular reporting on the environmental performance of the project is available at 17 The following are included: the documents referred to in Condition 2, Schedule 2 of PA 08_0184; current statutory approvals for the project; approved strategies, plans and programs required under the conditions of PA 08_0184; the monitoring results of the project, reported in accordance with the specifications in any conditions of PA 08_0184, or any approved plans and programs; a complaints register, updated on a monthly basis; minutes of CCC meetings; the annual reviews of the project; any independent environmental audit of the project, and UCML s response to the recommendations in any audit; and any other matter required by the Secretary. 4.4 Inspections The ECC (or delegate) is responsible for undertaking and recording Environmental Inspections to ensure compliance with the EMS. An Environmental Inspection Checklist (ULN SD ANN 0044) is available on the intranet for use by Ulan staff. Operational personnel will be periodically given the responsibility of participating in these reviews to increase awareness and ownership of environmental issues. These inspections will assist in determining on-site compliance with the EMS. They will be used in conjunction with environmental monitoring and incident/complaint reporting procedures. Other inspections may be undertaken as required e.g. for new projects, as required by the GDP process. Typical inspections undertaken at the Ulan Mine Complex are listed in Table 4.2. Non-conformances identified through the environmental inspection program are recorded and entered into the site incident and action database CMO by the ECC. Any potentially high risk nonconformances identified during inspections, are reported immediately to the ECM and responsible persons of the area for urgent action. The ECC will recommend corrective and/or preventative action and the effectiveness of this action will be assessed at the next monthly site inspection. Table 4.25 Environmental Inspections Type of Inspection General Site Inspections Dam Inspections Moolarben Dam Inspections Pipeline Inspections Subsidence Frequency Monthly/Six Monthly Monthly/Annually Weekly/Annually Weekly/Monthly/Annually Pre, during and post mining* Note:* As required by each respective subsidence monitoring program (i.e. ULN SD ANN 0064 and ULN SD PL 0061) 17 PA 08_0184, Schedule 5, Condition 10 Page 36 of 70

37 4.5 Audits Internal and external audits will be undertaken to assess whether the EMS has been properly implemented and maintained and conforms to the GCP Standards and Guidelines, PA08_0184and EPL requirements, objectives and targets and other requirements. The results of these audits will be communicated to UCML management. Independent environmental audits are required tri-ennially, audit reports and response to the recommendations are available at 18 The ECM is responsible for the co-ordination of the UCML audit schedule, as listed in Table 4.3. Internal audits undertaken by GCAA personnel will include: An audit team is made up of a team leader and could include one or more team members; The audit team leader of an internal audit should be from another part of the organisation than the one being assessed. He or she should be trained in auditing processes; The audit team leader of an external audit must be accredited to carry out the type of audit being undertaken; Team members could include a cross section of employees and contractors, or persons external to the site. Ideally they should be trained in audit processes; Audit reports must include adequate detail of methodology, scope, findings and recommendations and an audit score if applicable; The manager of the audit area must be given the opportunity to review the draft report for comment before it is finalised; and On completion of each audit report an action plan summarising the recommendations, planned actions and due-by dates must be completed. Actions are entered and tracked to completion in the site action database. Operational personnel will be included where possible in internal reviews in order to increase awareness and ownership of environmental issues. Results from the audits and reviews undertaken shall be included in the management review. Other external and internal audits will be determined by either Glencore s Executive Environmental Committee or by the level of risk to an aspect of UCML s operations respectively. Table 4.36 Auditing Schedule Type of Audit Frequency Description Arranged by Critical Control Monitoring Program Internal Compliance Review GCAA Assurance External - Independent Environmental Compliance Audit Other Environmental Audits Monthly Annual Separate schedule Annual and then 3 Yearly thereafter Targets Critical Hazards. An audit of each critical hazard is undertaken either quarterly, six monthly or annually. Annual compliance review in accordance with PA 08_0814 Targeted assurance processes which may include assurance and verification selfassessments and audit carried out by appropriately trained external auditors Conducted by external auditors. Compliance audit of statutory conditions applicable to Ulan Complex as per PA 08_ Yearly Targeted audits on focus areas: hydrocarbon and dangerous goods audits lighting audit Group Environmental Manager ECO or delegate General Manager Environment and Community ECM or delegate ECM 18 PA08_0184, Schedule 5, Condition 10, Page 37 of 70

38 4.6 Evaluation of Compliance Specific monitoring programs have been developed to evaluate environmental performance in relation to noise, air quality, water quality, soil and pasture quality, subsidence, biodiversity status, rehabilitated performance as well as land owned and managed by the operation. Details of each of these monitoring programs are included in the relevant environmental management plans as detailed in Appendix D. Management plans will include as a minimum: documented procedures for the monitoring programs; relevant project specific criteria and EPL limits; clear allocation of responsibilities; recording of information such that performance may be tracked; detailed relevant operational controls; demonstrated conformance with environmental objectives and targets and compliance with relevant environmental legislation and regulations; requirements for recording of equipment calibration and maintenance; and processes for ongoing review of both monitoring results and the overall monitoring programs. If a non-compliance is identified during the following evaluation measures discussed above, as a result of: an environmental site inspections; an internal or external audits; an environmental incident or community complaint; a review of environmental monitoring results against project specific/epl criteria; or failure to adequately meet the objectives and targets of the EMS. The ECM will be responsible for: recording all EMS non-compliances; investigating the cause of any non-compliance; identifying the correct reporting requirements; recommending corrective and/or preventative actions to prevent the non-compliance from occurring again; and communicating the non-compliance to: - UCML management team; and/or - Group Environmental Manager where applicable. Furthermore, the ECM will evaluate compliance with relevant environmental legislation and regulations and the statutory provisions as detailed within PA 08_0184 and DA Reporting of audit findings shall be undertaken in accordance with the respective statutory provisions of the statutory approval. 4.7 Non Conformity, Corrective Action and Preventative Action The ECM will be responsible for managing EMS non-compliances, as identified in Section 4.6. The key requirements are not limited to include: procedures for handling and investigating of non-conformances, including allocation of responsibility, external and internal reporting requirements, and initiating and completing corrective and preventative actions; preparing Environmental Alerts for Category 2 and 3 Incidents to the Group Environment and Community Manager, who will distribute. preparing Environmental Alerts for all Critical and High Potential Risk Incidents to the Group Safety or, within: o 24 hrs for Critical Incidents; o 72 hours for High Potential Risk Incidents (HPRI). Page 38 of 70

39 The ECM (or delegate) will notify the Secretary and EPA of incidents causing or threatening material harm to the environment immediately on becoming aware of the incident. 19 Within 7 days of the date of the incident, UCML shall provide the Secretary and any relevant agencies with a detailed report on the incident. Communications and resultant actions are managed as described above. Changes are managed as described in Section The effectiveness of the corrective and/or preventative action will be assessed by the ECM for adequacy 5 Review and Continuous Improvement The ECM (or delegate) will periodically review the EMS with senior management team. This review, as a minimum, will include: The Environment and Community BBRA; The Projects performance against Project Specific Criteria; and Setting the objectives and targets for the following year's Annual. The revised EMS will be resubmitted to DP&E at least every three years, or earlier if required. Any changes made to the EMS or supporting documents as a result of the review will be made in consultation with the DP&E and MWRC. A copy of the revised documents will be supplied to the Secretary for approval. On an annual basis and after submission of the Annual Review (i.e. AR) report, UCML shall review, and if necessary revise, the strategies, plans, and programs required under PA 08_0184 to the satisfaction of the Secretary within 3 months of: a) the submission of an annual review under Condition 3 (Schedule 5); b) the submission of an incident report under Condition 6 (Schedule 5); c) the submission of an audit report under Condition 8 (Schedule 5); and d) any modification to the conditions of this approval, (unless the conditions require otherwise). In accordance with Environmental Monitoring Programs and Management s will be dynamic and be revised regularly to reflect changes in operational practices, legislative requirements and to strive towards continual improvement. In addition, the performance of the EMS in achieving the objectives and targets shall be reviewed at least quarterly, which includes the environment & community component of the Annual. This review shall enable the identification of non-conformances and the formulation corrective action where targets are not being met. 19 PA 08_0184, Schedule 5, Condition 6; EPL 394; and ULN SD PLN PRIMP) Page 39 of 70

40 6 Accountabilities EMS roles and accountabilities will be clearly documented and all employees, contractors and suppliers (including designers and manufacturers), as appropriate. Performance against roles and accountabilities are assessed, including the specific and measurable goals, actions and targets as part of annual performance appraisals of employees. Specific roles and accountabilities for implementation of the EMS are detailed in each relevant management plan. Details of the roles and responsibilities for management, employees and contractors for the maintenance and implementation of the EMS are listed below. Role General Manager Accountabilities for this document Provide visible and proactive leadership in relation to the GlencoreBusiness Principles, Policy and Standards. Approve the strategy and plans for implementing and maintaining the Glencore Business Principles, Policy and Standards for the Ulan Complex Approve resources and management structure to ensure the effective implementation and maintenance of the UCML EMS. Allocate appropriate resources within delegated authority consistent with the strategy and plans. Communicate the Strategy and Annual to the workforce and relevant contractors and stakeholders. Ensure any potential or actual issue (environmental incidents) are reported in accordance with legal requirements and the corporate standard. Approve position descriptions for all roles and positions that are direct reports. Participate in the GCAA planning process. Review site annual plans quarterly. Coordinate and participate in Divisional meetings and forums. Validate the effectiveness of site communication processes. Monitor the effectiveness of the Risk/control management and treatment plans for accurate and effective reporting of risk issues and report to the Chief Operating Officer (COO) on key risk issues. Monitor outcomes of Site legal compliance audits. Verbally notify Chief Operating Officer of any critical incident. Assist Operations Manager in classifying incident. Monitor, report and verify the performance of Operations and Projects. Page 40 of 70

41 Role Operations Manager Accountabilities for this document Develop strategy and plans for implementing and maintaining the Glencore Business Principles, Policy and Standards that support the implementation of the EMS. Support the implementation of the EMS through approval of adequate resources and budgets. Ensure management systems are implemented and maintained to ensure compliance with legislative requirements as required by the EMS. Facilitate mine operations under their control in accordance with the EMS, in particular, with the operational and environmental plans and procedures. Monitor adherence to legal and corporate requirements and the effectiveness of all relevant procedures and standards. Ensure any potential or actual issue (environmental incident) is reported in accordance with legal requirements and the corporate standard. Approve position descriptions for all roles and positions identifying their responsibility in implementing the EMS. Support the provision of resources and time for appropriate training to all employees regarding their and legislative environmental responsibilities. Provide input during annual reviews regarding the relevance of and the compliance with sections of EMS and environmental procedures. Ensure inclusion of the UCML ECM in the assessment of any proposed or new works associated with the operation that may have an impact on the operating approvals, environment and community. Provide visible leadership to employees on site. Participation in Audit processes. Approve the site annual plan. Include responsibilities and performance measures for direct reports resulting from the plan and the monthly reviews of the plan. Facilitate quarterly reviews of the annual plan. Communicate outcomes of the reviews to managers and relevant employees. Communicate outcomes of the quarterly review to GCAA. Monitor and report performance of site KPIs. Provide systems to manage training awareness and competence on site. Page 41 of 70

42 Role Operations Manager Accountabilities for this document Implement an effective behaviour management programme. Articulate and communicate matters important to the site workforce. Participate in Site and Divisional meetings and forums. Implement and maintain communication and consultation processes. Establish, implement and maintain systems for risk management and assessment. Provide resources to conduct risk assessments, implement actions and management plans. Organise annual review of the Risk Register. Establish, implement and maintain systems for the management and review processes to manage catastrophic hazards. Monitor Site performance of catastrophic hazard management. Participate in legal compliance audits. Approve the operation's Policies and Guidelines. Nominate owners of Management Systems and documents. Participate in formal community consultative committees (CCC). Authorise information to be shared with CCC s. Approve reports to government agencies as required. Approve all management plans. Conduct annual review of this EMS and site performance of biodiversity and landscape functions KPI s as part of the annual strategy and planning process. Establish a system, including all necessary processes, for managing contractors, suppliers and partners in accordance with the requirements of the GCAA Guideline and relevant legislation, standards, codes and additional external requirements. Participate in stakeholder engagement forums and activities. Review community donation requests with the management team. Review and approve (as appropriate) donations as per GCAA requirements. Report significant community feedback and complaints, issues or concerns. Provide reports on actions against life of mine and mine closure plans. Page 42 of 70

43 Role Operations Manager Accountabilities for this document Review progress of compliance with life of mine and mine closure plans. Authorise annual review of life of mine and mine closure plans. Oversee the implementation of site based product stewardship strategies, programs and plans, including the annual Energy Savings Actions. Review progress and report compliance with programs. Report to the General Manager all Critical and Serious Incidents as specified (immediate verbal notification, or as soon as possible). Submit alerts for critical and HPRI incidents within 24 hours to GCAA. Provide to GCAA a written report on investigation of significant incidents within one month of incidents. Monitor and report site performance. Implement and monitor actions relating to audits, inspections and reviews. Develop and implement emergency management and incident/ crisis management systems including a site Emergency Response meeting the minimum requirements of the GCAA Guideline. Provide the necessary resources to prepare for and deal with emergencies. Review the Emergency Response periodically or following a relevant event. Environment and Community Manager Develop, implement and maintain the EMS, which includes facilitating the commitments outlined in the annual Strategy with the assistance of the Operation Managers and other senior managers. Oversee the implementation of the EMS through the development and identification of adequate resources and budgets. Ensure management systems are implemented and maintained to ensure compliance with legislative requirements as required by the EMS. Report to and assist the GCAA Group Environmental Manager in aspects of environment and community, including the strategy, planning and review processes. Compile monthly, quarterly and annual reports and presentation for the sites' senior management and GCAA managers. Assist in the coordination of the Assurance Program, relevant compliance audits and environmental reviews of the EMS. Page 43 of 70

44 Role Environment and Community Manager Accountabilities for this document Monitor and review change management activities for consistency with Standards and Guidelines. Develop strategies and coordinate efforts as required to influence and comply with new regulatory requirements and stakeholder expectations. Provide visible and proactive leadership in relation to implementation of the EMS. Review and endorse all corrective actions arising from environmental incidents and community complaints. Support the implementation of the UCML Social Involvement. Liaise with government and community stakeholders regarding environment and community matters associated with the Ulan Mine Complex. Prepare statutory environmental reports to ensure compliance with the approvals associated with the Ulan Mine Complex. Provide environmental advice for risk assessments and assist in the development of management protocols for proposed works associated with existing operations and any new or altered works. Coordinate the review of this EMS. Assist in developing and implementing the annual plan. Provide the site with advice to assist the site to manage their requirements. Participate in management review meetings. Assist in developing accountabilities in position descriptions for all employees and contractors. Provide data and statistics to assist in monthly and quarterly plan review meetings. Assist with the monitoring and reporting of site KPIs. Assist with the implementation of an effective behaviour management programme. Coordinate meetings, as required. Coordinate the development and revision of the operation's system documents, relevant to the EMS. Manage documentation in accordance with the GCAA document management system. Page 44 of 70

45 Role Environment and Community Manager Accountabilities for this document Provide an allocation for community support programmes in annual budgets. Facilitate the mine closure planning and review process. Facilitate the site implementation and maintenance of GCAA strategies, programmes and plans. Review reports for site on actions relating to Product Stewardship. Programme and report on progress against life of mine and mine closure plans. Assist the Operations Managers in preparing Alerts and investigations, as required. Facilitate audits, monitoring and reporting processes. Undertake roles as per the site ERP and incident management team. Environment & Community Coordinator and all Environment & Community Team Members; Maintain a working knowledge of this EMS and be aware of all environmental legislative requirements associated with the Ulan Mine Complex. Coordinate the development, communication, implementation and maintenance of management plans and environmental monitoring programs and regularly review of all environmental monitoring data for compliance against the Project Approval criteria. Oversee the collection and reporting of environmental monitoring data and deal with any quality or technical data collection issues. Coordinate the incident and complaint investigation process including associated reporting requirements. Provide advice and support on environmental issues. Support the development of monthly, quarterly and annual reports and presentations for the sites' senior management and GCAA managers. Co-ordinate and manage the tracking of the sites' performance and compliance with strategy and Annual s. Provide visible and proactive leadership in relation to implementation of the EMS. Undertake regular site inspections and audits to ensure compliance with the EMS. Page 45 of 70

46 Role Environment & Community Coordinator Accountabilities for this document Ensure implementation of corrective actions arising from environmental incidents and audits. Conduct training programs to ensure workforce awareness of the EMS (including associated management plans and procedures) and regulatory obligations. Liaise with senior management personnel to promote awareness and delegate tasks associated with the management of environmental issues/commitments at the Ulan Mine Complex. Coordinate the activities of specialist sub-consultants and project personnel for environmental assessment/monitoring/auditing responsibilities. Provide environmental assistance and advice on legislative and approval requirements for any proposed works. Assess and approve the environmental and community aspects of all GDPs Participate in the review of this EMS. Facilitate baseline studies. Establish, implement and maintain processes for document management of all data collection and monitoring programs. Have new and revised system documents loaded onto the intranet. Coordinate the development of the site rehabilitation monitoring. Prepare internal & external reports for environmental data i.e. sustainable development figures through GCP, NGERs/AQS, NPI and EPL annual returns. Develop reports for site on actions relating to Product Stewardship. Page 46 of 70

47 Role All Managers Accountabilities for this document and all Supervisors, Employees and Contractors; Maintain a working knowledge of this EMS and be aware of all environmental legislative requirements and community responsibilities associated with their areas of responsibility. Allocate appropriate resources within delegated authority to ensure compliance with the EMS and MS. Use appropriate risk management tools to identify hazardous work, assess and control the risks and impacts. With team members, apply relevant risk management processes before starting all work. Provide visible and proactive leadership in relation to implementation of the EMS. Monitor and review the effectiveness, and compliance with completion of role accountabilities by subordinates. Contribute to the process of developing the annual plan as appropriate. Develop and monitor the application of work plans to manage risks. Implement and participate in an effective behaviour management programme. Implement and participate in communication and consultation processes. Participate in Site meetings and forums. Implement and comply with the GCAA Guideline for all new major projects and introduction of any new plant, equipment and infrastructure. Conduct regular reviews/ inspections of project/operation to check for compliance with requirements; report any deviations from the plans. Conduct regular reviews/ inspections of performance and any actions in programs. Participate in the audit process. Advise the Manager of any identified needs for new or revised documents. Respond to all incidents and secure the scene as required. Conduct incident investigations as required Complete Incident Report and Investigation forms or Potential Hazard / Improvement forms where applicable. Page 47 of 70

48 7 Document Information Relevant legislation, standards and other reference information must be regularly reviewed and monitored for updates and should be included in the site management system. Related documents and reference information in this section provides the linkage and source to develop and maintain site compliance information. 7.1 Definitions Definitions, listed in Table below, are directly related to or referenced within this document. Table 7.1 Related documents Term Definition Auditor Person with the competence to conduct an audit (ISO 9000:2000) Continual improvement Environment Environmental aspect Environmental impact Environmental management system Environmental management system audit Environmental objective Environmental performance Environmental policy Environmental target Intranet Procedure Recurring process of enhancing the environmental management system in order to achieve improvements in overall environmental performance consistent with the organisations environmental policy (ISO 14001) Surroundings in which an organisation operates, including air, water, land, natural resources, flora, fauna, humans and their interaction (ISO 14001) Element of an organisations activities or products or services that can interact with the environment (ISO 14001) Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisations environmental aspects (ISO 14001) Part of an organisations management system used to develop and implement its environmental policy and manage its interaction with the environment (ISO 14001) Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the environmental management system audit criteria set by the organisation are fulfilled (ISO 14001) Overall environmental goal, consistent with the environmental policy, that an organisation sets itself to achieve (ISO 14001) Measurable results of an organisations management of its environmental aspects (ISO 14001) Overall intentions and direction of an organisation related to its environmental performance as formally expressed by top management (ISO 14001) Detailed performance requirement, applicable to the organisation or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives (ISO 14001) UCML s internal internet Specified way to carry out an activity or a process Page 48 of 70

49 7.2 Abbreviations Abbreviations, listed in Table below, are directly related to or referenced within this document. Table 7.2 Related documents Acronym Title ACARP Australian Coal Association Research Prograp AR Annual Review AFE Application For Expenditure AS Australian Standards AS/NZS Australian Standard / New Zealand Standard BBRA Broad Brush Risk Assessment BIS Bobadeen Irrigation Scheme BMP Biodiversity Management CCC Community Consultative Committee CHPP Coal Handling and Preparation t (C)MCP (Concerptual) Mine Closure CMO Compliance Manager On-line COO Chief Operating Officer CSI Corporate Social Involvement db(a) A-weighted Decibels DP&E NSW Department of ning and Environment DoE Department of Environment (Cth) DPI Department of Primary Industries DRE Department of Resources and Energy EA Environmental Assessment ECC Environment and Community Coordinator ECM ECO Environment and Community Officer EMP Environmental Management EMProg Environmental Monitoring Program EMS Environmental Management System/Strategy EP&A Act Environmental ning and Assessment Act 1997 EPA Environmental Protection Authority EPBC Environmental Protection and Biodiversity Conservation EPL Environment Protection Licence (394) (G)CAA (Glencore) Coal Assets Australia GCP Glencore Corporate Practice GDP Ground Disturbance Permit GEM Group Environmental Manager GMEC General Manager Environment and Community GRDRP Goulburn River Diversion Remediation GRI Global Reporting Initiative HMP Heritage Management HPRI High Potential Risk Incidents HSEC Health, Safety, Environment and Community ICAM Incident Cause Analysis Method ICMM International Council on Mining and Metals ISO International Organisation for Standardisation KPI Key Performance Indicator LA eq LGA Equivalent Continuous Noise Level Local Government Area Page 49 of 70

50 Acronym Title LOM Life of Mine LW Longwall MBGS McElroy Bryant Geological Services MCA Minerals Council of Australia MCM Moolarben Coal Mine ML Mining Lease MOP Mining Operations MWRC Mid-Western Regional Council NPI National Pollutant Inventory OEH Office of Environment & Heritage PA Project Approval (08_0184) PLN POEO Protection of the Environment Operations Act 1997 POL Policy PRO Procedure SIP Social Involvement SMP Subsidence Management STD Standard SWMS Safe Work Method Statement TBA To Be Advised TBT Toolbox talk TNA Training Needs Analysis VPA Voluntary ning Agreement UCML Ulan Coal Mines Limited WA Work Authorisation WCM Wilpinjong Coal Mine 7.3 Reference Information Reference information, listed in Table below, is information that is directly related to the development of this document or referenced from within this document. Table 7.3 Reference information Reference Legislation Title Mining Act 1992 The Mining Act 1992 as administered by DRE on behalf of the Minister for Mineral Resources and Energy, amongst other legislative instruments, places controls on methods of exploration and mining, the disposal of mining waste, land rehabilitation and environmental management activities. The principal means of regulation is the requirement for nearly all exploration and mining to be conducted under a title, such as an exploration licence or a mining lease. It also addresses the environmental responsibilities of explorers and miners, royalties and compensation Water Management Act 2000 The Water Management Act 2000 (WMA) provides for the sustainable and integrated management of the State s water and is administered by the Department of Primary Industries (DPI) - Water. The WMA governs the issue of new water licences, the trade of water licences and allocations for those water sources (rivers, lakes and groundwater) in NSW where water sharing plans have commenced. Under the WMA, water access licences entitle a licence holder to a share of the water in a listed water source that can be sustainably extracted. Licences must also be obtained for new groundwater monitoring bores where water sharing plans have commenced. Environment Protection and Biodiversity Conservation Act 1999 The Commonwealth Environmental Protection and Biodiversity Conservation Act 1999 (EPBC Act) has established a national assessment framework based on the principles of ecologically sustainable development. Proposed actions, including projects, developments, activities and alterations that are considered likely to have a significant impact on matters protected by and listed under the EPBC Act need approval from the Minister for Sustainability, Environment, Water, Population and Communities. Page 50 of 70

51 Reference CAA Environment and Community Standards and Protocols Title Commonwealth Native Title Act 1993 The Commonwealth Native Title Act 1993 (NT Act) is a set of rights and interests in relation to land or waters that have qualities identified and administered by the National Native Title Tribunal. The Tribunal is responsible for maintaining a National Native Title Register (NNTR) of native title claimants and bodies to whom native title rights have been granted. These native title holders and claimants must be consulted prior to the granting of a mining lease over land to which the native title claim or right applies. The NT Act prescribes that native title can be extinguished under certain circumstances, including the granting of freehold land. Water Act 1912 The Water Act 1912 is administered by the NSW Office of Water and governs the issue of new water licences and the trade of water licences and allocations in areas where Water Sharing s under the WMA have not commenced. The licence is tied to the land as the licence covers both the right to take a specific volume of water as well as the works to be constructed. Heritage Act 1977 The Heritage Act 1977 provides for the conservation and management of the State s built, marine, moveable and natural heritage. The Act provides for the constitution of the Heritage Council of NSW by which authority it is administered through the NSW Heritage Office. The Heritage Council maintains the State Heritage Register and the State Heritage Inventory, which list respectively heritage items of State significance and of local significance. The Heritage Council may also request local councils to prepare environmental planning instruments to protect items of local significance. National Parks and Wildlife Act 1974 The National Parks and Wildlife Act 1974 (NP&W Act)provides for the protection of native flora and fauna and the protection, preservation and management of all Aboriginal relics throughout NSW, irrespective of land tenure. The Act is administered by the Office of Environment and Heritage (OEH). Native Vegetation Act 2003 The Native Vegetation Act 2003 (NV Act) is administered by OEH and provides for the management, protection and rehabilitation of native vegetation in accordance with the principles of ecologically sustainable development. The NV Act provides that clearing undertaken as part of an approved designated development, for bushfire management plans, authorised by the Mining Act 1992, for the purposes of survey, or for routine agricultural practices is exempt from the provisions of the NV Act. Activities which are not exempt or permissible under the Act will comply with the requirements of the NV Act. Threatened Species Conservation Act 1995 The Threatened Species Conservation Act 1995 (TSC Act) is administered by OEH and provides protection for threatened plants and animals native to NSW (excluding fish and marine vegetation, which are protected under the Fisheries Management Act 1994) and integrates the conservation of threatened species into the development approval processes under the EP&A Act. Under the EP&A Act, impacts on threatened species listed under the TSC Act are assessed by a seven-part test. Where a development is likely to have a significant impact on a threatened species, population or ecological community, the preparation of a Species Impact Statement is required Community - CAA HSEC STD Environment - CAA HSEC STD Change - CAA HSEC STD Stakeholder Engagement - CAA HSEC PCL Community Development and Investment - CAA HSEC PCL Internal Communications - CAA HSEC PCL Media and Public Relations - CAA HSEC PCL Community Complaints Management - CAA HSEC PCL Environmental Compliance Management - CAA HSEC PCL Pipeline Management - CAA HSEC PCL Water Management - CAA HSEC PCL Dams and Diversions - CAA HSEC PCL Erosion and Sediment Control - CAA HSEC PCL Hydrocarbon Management - CAA HSEC PCL Waste - CAA HSEC PCL Exploration and Drilling - CAA HSEC PCL Air Quality Management - CAA HSEC PCL Noise Management - CAA HSEC PCL Blast - CAA HSEC PCL Carbon Management - CAA HSEC PCL Environment & Community Training - CAA HSEC PCL Land and Property Management - CAA HSEC PCL Rehabilitation Management - CAA HSEC PCL Biodiversity Offset Management - CAA HSEC PCL GIS Spatial Data Management - CAA HSEC PCL Statutory Approval Management - CAA HSEC PCL Statutory Approvals NSW - CAA HSEC PCL Aboriginal Cultural Heritage NSW - CAA HSEC PCL 0013 Page 51 of 70

52 Reference UCML s (and Annexures to s) UCML Procedures, Standards and Forms Approvals External Title Mining Tenement Management - CAA HSEC PCL Native Title Process for Exploration and Mining Leases - CAA HSEC PCL 0015 ULN SD PLN Emergency Response Management ULN SD PLN Emergency Preparedness ULN SD PLN Pollution Incident Response Management ULN SD PLN Heritage Management ULN SD PLN Visual and Landscape Management ULN SD PLN Social Involvement ULN SD PLN Waste Management ULN SD PLN Water Management ULN SD PLN Site Security Management ULN SD PLN Subsidence Management and Extraction ULN SD PLN Erosion and Sediment Control ULN SD PLN Biodiversity Management ULN SD PLN Bushfire Management ULN SD PLN Built Features Management ULN SD PLN Public Safety Management ULN SD PLN Noise Management ULN SD PLN Environmental Monitoring Program - ULN SD PLN Goulburn River Diversion Remediation ULN SD PLN Surface Water Monitoring Program ULN SD PLN Groundwater Monitoring Program ULN SD PLN Surface Water and Groundwater Response ULN SD PLN Moolarben Dam Operations and Maintenance ULN SD PLN Air and Greenhouse Gas Management ULN SD PLN Aboriginal Conservation Management ULN SD PLN Integrated Mining Operations ULN SD PLN Blast Management ULN SD PLN Conceptual Mine Closure ULN SD ANN Environmental Inspection checklists ULN SD ANN Sustainable Development Risk Register (E&C) ULN SD ANN Offset Management Program ULN SD PLN Bobadeen Homestead Conservation Management ULN SD PLN Old Ulan Conservation Management ULU SD PLN Training and Competency Management ULW SD PLN Training and Competency Management USO SD PLN Training and Competency Management ULN SD PRO Complaints Procedure ULN SD PRO Hazard and Incident Management Procedure ULN SD PRO Consultation and Communication Standard ULN SD PRO Records Management Standard ULN SD PRO Document Control ULN SD PRO Legal Compliance ULN SD PRO Water Infrastructure Management Procedure ULN SD PRO Spill Response ULN SD FRM Ulan Coal Incident Report & Investigation Form ULN SD FRM Induction and Medical Requirements Matrix Project Approval 08_0184 (as modified) Statement of Commitments Land and Environment Court Judgement and Final Orders (April 2012) Development Approval DA Environment Protection Licence (EPL) 394 SMP Approvals for Longwalls 23-26, W1 and W2 and W3 SMP Approval for LW C, E, F Extraction Approval for LW C, E, F SMP & Extraction Approval LW27-29, W4 to W5 (March 2013) SMP & Extraction Approval Ulan West LW1 2 (April 2014) ANZECC/ARMCANZ, National Water Quality Management Strategy: Australian Guidelines for Fresh and Marine Water Quality. Department of Environment and Conservation (DEC), Methods for the Sampling and Analysis of Water Pollutants in NSW. Mackie Environmental Research (MER), Ulan Coal Continued Operations Groundwater Assessment. Prepared for Ulan Coal Mines Limited. Mackie Environmental Research (MER), Ulan Coal Continued Operations Groundwater Assessment. Prepared for Ulan Coal Mines Limited. Smakhtin, 2001, Low-flow Hydrology: A review, Journal of Hydrology, Vol. 240, Umwelt (Australia) Pty Ltd, Ulan Coal Continued Operations Preliminary Environmental Page 52 of 70

53 Reference Title Assessment. Prepared for Ulan Coal Mines Limited. Umwelt (Australia) Pty Ltd, Ulan Coal Continued Operations Environmental Assessment. Prepared for Ulan Coal Mines Limited. Umwelt (2011) Ulan Coal Continued Operations North 1 Underground Mining Area, Minor Modification to Ulan Underground & Ulan West Mine s & Proposed Concrete Batching t Umwelt (May 2012) Environmental Assessment Modification to Ulan Coal Continued Operations, Ulan West Mine ( Panels 1 4) and Construction Blasting Draft Guidelines for Groundwater Monitoring (Department of Water and Energy). Standards Australia (1998) AS : Guidance on sampling Groundwaters. Queensland Government Department of Natural Resources and Water (QLD NRW) Facts Land Series: Measuring Salinity. GSSE Environmental (2007) Environmental Risk Assessment and Establishment of a Risk Register for the Ulan Open Cut and Underground Coal Mines. GSS Environmental (2005) Subsidence Management Longwalls and W1. Department of Natural Resources (1999) A Guide for Establishing a Groundwater Monitoring Program for Mine Sites within the Hunter Region. DII Guidelines to the Mining, Rehabilitation and Environmental Management Process. UCML (October 2013). Longwalls 1 & 2 Subsidence Management and Extraction, Ulan West Operations Page 53 of 70

54 7.4 Change Information Full details of the document history are recorded in the document control register, by version. A summary of the current change is provided in Table below. Example detail shown below. Table 7.4 Change information Version Date Review team (consultation) Change Summary 1 31 Dec 2010 XCN IT Transfer document into new Intranet platform 2 31 March 2011 Jamie Lees, Dan Clifford, Rod Reinhard, Michael Map, Brian Pease, Cheryl Henriques, Ian Flood, Dave O Brien (XCN), Phil English (Minespex) EMS revised (Version 1) in accordance with Project Approval 08_0184. Revised EMS incorporates XCN revised Sustainable Development Management System. 3 1 April 2011 Cheryl Henriques Formatting no change to content 4 26 July 2011 Jamie Lees, Stephen Bragg, Cheryl Henriques 5 20 April 2012 Jamie Lees, Rachel Murray, Stephen Bragg June 2012 Robyn Stoney, Ian Flood, Rachel Murray EMS revision based on comments received from DP&E on the 16 May Amendments provide more details on Roles & Accountabilities and increased detail on the relevant SD guidelines. EMS revision based on compliance with SD guidelines, changes to Project Approval 08_0184, update of documentation and training systems. Annual Review & updated based on MOD 2 & EPL 394 variation 6 7 June 2013 Tara Stokes, Robyn Stoney AER 2012 Management Review 7 30 June 2015 Robyn Stoney, Stephen Bragg Updated into Glencore template 8 11 November 2015 Robyn Stoney Annual Review January 2016 Angela van der Kroft Updated TNA May 2016 Robyn Stoney Commenced update to reflect MOD May 2016 Robyn Stoney Commenced update to reflect MOD May 2016 Robyn Stoney Further update to reflect MOD June 2016 Robyn Stoney Further update to reflect MOD June 2016 Bianca Connop Updated Figures 2, 3 and those in Appendix D June 2016 Angela van der Kroft Updated Figures 5 and 6. Added Visual Amenity and Lighting commitments. 4 November 2016 Tara Stokes Updated effective date to when version approved by DP&E Page 54 of 70

55 Appendix A - Glencore Values Page 55 of 70

56 Consequence Likelihood Risk Rank Number Ulan Complex Appendix B - Environment and Community Risk Register Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d 1 Office / Admin / Training Complex Others based on agreement from the group Maintenance of Legal Compliance with numerous licenses conditions Administrative Non Compliance with reporting, licencing or related timeline Impact / Inhibit Business Process / Operations delays / stoppages / costs Non Compliance with Environmental Protection Licence (EPL, Project Approval (PA), Water and other license conditions including Exploration and Mining Lease conditions Regulator Concern Increased scrutiny / stricter regulatory conditions Environmental Management System (EMS) Accountabilities in specific job roles EMS Legal Register 2 Minor D - Unlikely 5 (L) 6 Moderate 2 Office / Admin / Training Complex Others based on agreement from the group Changes to mine plan / Timing of SMP approvals ning Approvals not in place in time Impact / Inhibit Business Process / Operations delays / stoppages / costs LTA approvals, planning and scheduling Significant ($) liability exposure - Details unknown or not well understood Approvals pipeline meeting LOM planning and RA 2 Minor C Possible 8 (M) 3 Moderate Implement action tracking in pipeline meeting Prepare business case for assessment of broader environment sensitivities to enable outcome based approvals SEAC LTA human rights controls, 3 Office / Admin / Training Complex Others based on agreement from the group Changes to mine plan / Timing of SMP approvals ning Approvals not in place in time Impact / Inhibit Business Process / Operations delays / stoppages / costs a) Fair treatment in the workplace, including access to grievance mechanisms. b) Security in the workplace and related service providers. Legal actions from external party Appropriate human resources and GCAA policy and stakeholder engagement SIP, AHCMP, NT agreement 2 Minor D Unlikely 5 (L) 3 Moderate c) Rights of communities in which we operate. Site security plan d) Indigenous peoples. Social & Economic Impact Assessment 4 Office / Admin / Training Complex Others based on agreement from the group Increased demand causes housing shortages on a community level Administrative - Noncompliance with reporting, licencing or related timeline Community Amenity Increase in employee and contractor workforce Objections lodged to expansion / extension projects delays & legal costs Gulgong Subdivision Voluntary ning Agreement Mudgee Doctors Incentive Program Social Involvement 2 Minor E - Rare 3 (L) 3 Moderate Monitored implementation of the Ulan Road Strategy Social Involvement 5 Office / Admin / Training Complex Others - based on agreement from the group Complex community program engagement appropriate Administrative - Noncompliance with reporting, licencing or related timeline Community complaints / mistrust Community issues (e.g. Noise, dust, changing community attitudes) Objections lodged to expansion / extension projects - delays & legal costs Goulburn River remediation program Operating equipment at low levels in high noise travel conditions Stakeholder engagement matrix Community Development Program CCC meetings Newsletter 2 Minor C - Possible 8 (M) 9 Moderate Consider Community Broad Brush Risk Assessment (BBRA) in stakeholder engagement strategy ECM Website ( 6 Office / Admin / Training Complex Water - Ground Community complaints - Impacts on 'The Drip Perception of Impact Technical Standard - Non-compliance with external regulatory condition / standard Community complaints / mistrust Depressurised / Impact on "The Drip" Objections lodged to expansion / extension projects - delays & legal costs EA Near goaf and far field GW Monitoring studies Subsidence Monitoring 3 Moderat e C - Possible 13 (M) 3 Moderate In consultation with MCM, Develop and Implement monitoring program of 'The Drip' ECM Page 56 of 70

57 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d Program Groundwater Monitoring Program Water Management Drip piezometer monitoring program Hydro-geological assessment of drip water 7 Office / Admin / Training Complex Others - based on agreement from the group Damage to property and/or equipment and/or injury to persons Land - Property accessed without approvals in place Infrastructure or property damage Unauthorised access to the site Significant ($) liability exposure - Details unknown or not well understood Both gates to the Open Cut and Underground are closed after hours CCTV Random surveillance by site security contractors Inspections Remote access gates are padlocked. Social Involvement, communication and consultation Land Access agreements Site Security Management Public Safety Management 2 Minor D - Unlikely 5 (L) 3 Moderate Acquisition of roads 8 Office / Admin / Training Complex Others - based on agreement from the group Unauthorised access to the site results in damage to property and/or equipment and/or injury to persons General - Impact not well understood - immediate (s/term issue) Community complaints / mistrust Human rights compromised by community impacts Regulator Concern - Increased scrutiny / stricter regulatory conditions Boundary of operations and operations controls to avoid impacts Property acquisitions controlled throughout the approvals process 2 Minor E - Rare 3 (L) 3 Moderate Establish a management strategy for known security locations 9 Office / Admin / Training Complex Others - based on agreement from the group Unauthorised access to the site results in damage to property and/or equipment and/or injury to persons General - Impact not well understood - immediate (s/term issue) Community complaints / mistrust Unauthorised access to the site Regulator Concern - Increased scrutiny / stricter regulatory conditions Restricted entry to site - security gates at major access points Site security contractors Surveillance cameras 24/7 operations - staff always on site Signage Inspections Site Security Management 2 Minor B - Likely 12 (M) 3 Moderate Establish a management strategy for known security locations Remote access gates are padlocked. Drilling and Exploration Management. 10 Drilling Complex Water - Ground Sedimentation of local waterways. Water (ground) - Localised impacts - no sensitive receptors - within ML boundaries Community complaints / mistrust LTA Exploration Drilling / Erosion and Sediment Control - Dirty water management (Unlicensed discharge) Objections lodged to expansion / extension projects - delays & legal costs Erosion and Sediment Control. Ground Disturbance Permit process Pre-drilling and during drilling inspection 2 Minor C - Possible 8 (M) 2 Minor Updating the GDP process to include improvement with erosion sediment control. E&CC Environmental training and awareness program 11 Clearance of land / vegetation Underground Biodiversity - Flora Flora - Damage / Impact - Protected vegetation / ecosystem Habitat destroyed / Ecological impact - Protected species proposal for work in SCA Objections lodged to expansion / extension projects - delays & legal costs Review of Environmental factors 2 Minor D - Unlikely 5 (L) 12 Clearance of land / vegetation Complex Water - Surface Erosion and sediment control Uncontrolled release (failure / overflow) - outside contained catchment, going offsite Water quality impact or deterioration LTA erosion and sediment controls Regulatory Action - ii - Penalty Infringement Notice Dirty water management system. Progressive rehabilitation. Engineering and design of all erosion and sediment control Ground Disturbance Permit process. Environmental and statutory inspections. Environmental training and awareness program. Erosion and Sediment 3 Moderat e D - Unlikely 9 (M) 3 Moderate Page 57 of 70

58 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d structures. Control Final landform design. CEMP's for all construction works includes erosion and sediment control measures. 13 Clearance of land / vegetation Complex Others - based on agreement from the group GDPs approvals and constraints - too late in process ning - Approvals not in place in time Impact / Inhibit Business Process / Operations - delays / stoppages / costs Lack of early engagement in projects Significant ($) liability exposure - Details unknown or not well understood Approvals pipeline and GCAA protocol 2 Minor D - Unlikely 5 (L) 14 Clearance of land / vegetation Complex Biodiversity - Flora No more than 69Ha EECs can be cleared Fauna - Damage / Impact - Protected species Habitat destroyed / Ecological impact - Protected species LTA monitoring of clearing data Regulatory Action - iii - Prosecution Clearing register updated for each GDP. Land Clearing procedure 2 Minor D - Unlikely 5 (L) Heritage Management 15 Clearance of land / vegetation Complex Cultural / European Heritage LOM is able to proceed but in a different manner to the preferred option Moderate capital costs Could cause disruptions to the operation, potential prosecution and fine Cultural / European Heritage - area impacted Community complaints / mistrust Aboriginal Archaeological Sites (Non-Disturbance Areas) Regulator Concern - Increased scrutiny / stricter regulatory conditions Aboriginal Conservation area offset known and agreed Barriers around conservation sites Mine plan area survey Cultural heritage management meetings Ground Disturbance Permits. 3 Moderat e C - Possible 13 (M) 3 Moderate Conduct a desktop review of broader areas for significant project sites E&CC Rock shelter salvage program 16 Clearance of land / vegetation Complex Biodiversity - Flora Loss of native flora and fauna. No more than 69Ha EECs can be cleared Legal & Compliance i.e. breach of Project Approval conditions Flora - Damage / Impact - Unprotected vegetation / ecosystem Habitat destroyed / Ecological impact - Protected species Unauthorised ground disturbance Regulatory Action - ii - Penalty Infringement Notice Native seed harvesting/banking program Flexibility in infrastructure design to mitigate impact Signage Biodiversity Management Offset management program Ground Disturbance Permits Clearing procedure (draft). 2 Minor B - Likely 12 (M) 3 Moderate Finalise Land Clearing Procedure E&C Coord. Biodiversity offset area Drilling and Exploration Management 17 Clearance of land / vegetation Complex Land / Soil Introduction or spread of noxious weeds Land - Weed management not appropriate to address spread - outside lease Community complaints / mistrust Weeds, vermin etc. Regulator Concern - Increased scrutiny / stricter regulatory conditions Weed Treatment program Post-drilling and ongoing environmental inspections. 2 Minor C - Possible 8 (M) Annual Land & Rehab MP Bushfire management plan. 18 Clearance of land / vegetation Complex Biodiversity - Flora Damage to infrastructure, flora and fauna, rehabilitation and biodiversity offset areas. May result in smoke entering underground ventilation system or damaging ventilation system. General - Impact not well understood - medium term issue Community complaints / mistrust Bushfire Regulator Concern - Increased scrutiny / stricter regulatory conditions Maintenance of APZ's Co-operation with local RFS. Bushfire Training TARP's Site Emergency Management Response 3 Moderat e C - Possible 13 (M) Review appropriate management plans for bushfire maintenance strategy around all surface infrastructure (GDP) E&C Manager Page 58 of 70

59 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d Real time notification for total fire ban days Underground monitoring systems 19 Blasting Open Cut Noise / Vibration Noise and vibration community complaints. Possible non-compliance. Penalty Infringement Notice. Impacts on underground operations. Noise - General Mine Noise Community complaints / mistrust Scheduled blast events exceed EPL and PA criteria - poor blast design, poor meteorological conditions Regulator Concern - Increased scrutiny / stricter regulatory conditions Large buffer areas. Blast Management, includes blast monitoring program Blast engineer and blast modelling Met conditions checked prior to all blasts Blast Notification Protocol developed 2 Minor D - Unlikely 5 (L) NA EPL 394 approval 20 Blasting Open Cut Others - based on agreement from the group Fume management and control Air Emission - Blasting Fume / Other Odour Community Amenity Unknown definition for fume having crossed site boundary Regulator Concern - Increased scrutiny / stricter regulatory conditions Licensed explosives handler. Licensed magazine facility. Explosives management plan. UCML Site Security 3 Moderat e D - Unlikely 9 (M) NA 21 Load & Haul Open Cut Fugitive dust from rail operations Air Emission - Dust (general operations) Community Amenity 2 Minor D - Unlikely 5 (L) 22 Load & Haul Open Cut Air Quality - Fume / Smoke - Spontaneous Combustion Impacts on air quality & rehabilitation Air Emission - Spon Com Impact / Inhibit Business Process / Operations - delays / stoppages / costs Spontaneous Combustion Increase in Financial Assurance / Rehabilitation / Closure liability Spon Com Management. Inspections and remediation Conceptual mine closure plan 2 Minor C - Possible 8 (M) 2 Minor 23 Load & Haul Open Cut Noise / Vibration Impact on land use, land capabilities and agricultural productivity Degradation of noise amenity (cumulative). Technical Standard - Non-compliance with external regulatory condition / standard Community complaints / mistrust Exploration Drilling / Noise Generation Objections lodged to expansion / extension projects - delays & legal costs Regulated operational hours. Permanent noise monitoring logging around site. Drilling and Exploration Management Noise Management Mechanical compliance inspections. During drilling inspection includes noise. 2 Minor D - Unlikely 5 (L) 24 Storage - Dams, TSFs Complex Water - Surface Increasing EC East Pit Water (surface) - >3- Year trend of salinity increases or ph reduction / increase, or other Water quality impact or deterioration Increased brine make Significant ($) liability exposure - Details unknown or not well understood Water treatment plants Re-use infrastructure Waste Water Strategy Maximise RO reject reuse 4 Major C - Possible 18 (H) 3 Moderate Update WMP and WIMP with processes to maximise re-use E&C Manager 25 Storage - Dams, TSFs Open Cut Water - Surface Maintenance of capacity and safety of Moolarben Dam Water (surface) - Excess volume - exceed high-level storage target Water quality impact or deterioration Degeneration of Moolarben Dam infrastructure Significant ($) liability exposure - Details unknown or not well understood Regular monitoring, including engineering inspections and assessments Dam emergency response plan Flood studies 2 Minor D - Unlikely 5 (L) 3 Moderate Water Infrastructure MP 26 Storage - Dams, TSFs Complex Water - Surface Prevent schedule from proceeding due to LTA discharge licence - Ability to dispose of more water Unlicensed discharge due to filling up site storages/ Ability to discharge at Water (surface) - Excess volume - exceed high-level storage target Water quality impact or deterioration Increased surface water run-off into east/west pit void. Surface water licensed discharge capacity Regulator Concern - Increased scrutiny / stricter regulatory conditions Water treatment plant sized to resolve East pit volume over time Water Management Existing EPL Option to instigate Talbragar River discharge in PA 2 Minor D - Unlikely 5 (L) 33 Moderate Page 59 of 70

60 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d different locations 27 Storage - Dams, TSFs Complex Water - Surface Environment Community/Reputation Health & Safety Water (surface) - Excess volume - exceed high-level storage target Water quality impact or deterioration Dam wall failure or integrity of dams allows water to be discharged in an uncontrolled event. Significant ($) liability exposure - Details unknown or not well understood Requirements under the NSW Dam Safety Committee Annual inspections performed by engineer Monthly environmental inspections in accordance with the EMS 2 Minor C - Possible 8 (M) 7 Moderate 28 Storage - Dams, TSFs Complex Water - Ground Recharge of aquifers (down dip). Water stored in voids adding to inrush potential and increased water makes it to underground workings. Water (ground) - Localised impacts - no sensitive receptors - within ML boundaries Impact / Inhibit Business Process / Operations - delays / stoppages / costs LTA Groundwater Management (stored water) Objections lodged to expansion / extension projects - delays & legal costs Water sharing with Moolarben. East Pit and Bobadeen Water Treatment Facilities. Clean Water System for West Pit rehabilitation area to achieve final landform and discharge water off site. Water Management Groundwater Monitoring Program Surface Water and Groundwater Response Water balance model (6mnthly review) Water Infrastructure Management. 3 Moderat e B - Likely 17 (H) 36 Moderate 29 Storage - Dams, TSFs Open Cut Water - Surface Sewage treatment at USO does not function as intended irrigation is not possible and dam integrity Water (surface) - Excess volume - exceed high-level storage target Water quality impact or deterioration Seepage or spillage from sewage treatment plant Regulatory Action - ii - Penalty Infringement Notice Water level monitoring and high level alarm Pump out on schedule Inspections 2 Minor C - Possible 8 (M) Include the identified E&C risk in AFE justification for STP upgrade USO OM 30 Storage - Dams, TSFs Complex Water - Surface Storm water management controls maintained for changed operations Water (surface) - Excess volume - exceed high-level storage target Water quality impact or deterioration LTA Stormwater controls Regulatory Action - ii - Penalty Infringement Notice Drainage Structures Surface Hydrology Model Storage Capacity Pumping Infrastructure 3 Moderat e C - Possible 13 (M) Develop procedure for Systematic Review of SHM ECC 31 Maintenance Complex Land / Soil Soil and water contamination Hydrocarbon Management - UG = cost liability Closure - Liability - Creation of Contaminated Site Water quality impact or deterioration Not compliance with hydrocarbon and chemical storage standards Regulator Concern - Increased scrutiny / stricter regulatory conditions Oil water separators Dedicated bunding and storage (AS1940) areas Spill response kits. Awareness Training for the correct storage and handling 2 Minor D - Unlikely 5 (L) 2 Minor Bioremediation area. 32 Maintenance Complex Water - Surface Regulatory non-compliance Pipelines and Dams / Haul roads Proximity to clean water drain Uncontrolled release (failure / overflow) - outside contained catchment, going offsite Water quality impact or deterioration Burst pipe Regulatory Action - iii - Prosecution Detection, alarms and auto shut down Water infrastructure management plan 3 Moderat e D - Unlikely 9 (M) 15 Moderate 33 Monitoring Complex Others - based on agreement from the group Aesthetics of mine surface facilities. General - Impact not well understood - medium term issue Community Amenity Visual Amenity Objections lodged to expansion / extension projects - delays & legal costs Tree screening Large buffer areas. Design of infrastructure to minimise visual impact Audit of site lighting to ensure compliance with AS Minor D - Unlikely 5 (L) 3 Moderate Consider visual impact on future infrastructue and imidiate planting of vegetation to mitigate future risks. Environment al & Community Officer Noise Management 34 Monitoring Open Cut Noise / Vibration Degradation of noise amenity - Project specific and cumulative. Noise - CHPP Mine Noise Community complaints / mistrust LTA Noise Generation Monitoring - Open Cut mining and Coal Handling infrastructure Legal actions from external party Open Cut noise attenuated equipment Large buffer areas. Engineering noise mitigation measures (Conveyor covers etc.). Noise procedure TARPs Environmental monitoring network. Workplace observations. Attended noise monitoring. 2 Minor A Almost Certain 16 (M) 2 Minor ned maintenance inspections 35 Monitoring Open Cut Air Quality - Dust from stockpiles / rehab areas in Air Emission - Dust Community complaints LTA Dust Suppression Regulator Concern - Increased Environmental monitoring network - alarms Air Quality Management. Statutory 2 Minor B - Likely 12 (M) 3 Moderate Investigate and implement a dust USO OM Page 60 of 70

61 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d Dust proximity to Ulan village/ Rail loop TSF (general operations) / mistrust scrutiny / stricter regulatory conditions triggered. Dust suppression - water carts, sprays etc. inspections Air quality monitoring training suppression strategy around product stockpile Site speed restrictions. Large buffer areas Progressive rehabilitation Subsidence Assessment 36 Monitoring Complex Water - Ground Possible reduction in base flow in Goulburn and Talbragar River and tributary streams due to reduction in hard rock base flows greater than predicted in the EA Water (ground) - Regional impacts - sensitive receptors - outside ML boundaries Community Amenity Dewatering of underground mines Objections lodged to expansion / extension projects - delays & legal costs Water discharged to Goulburn system in excess of baseflow loss estimate Ground water modelling & assessment (calibration) Near goaf and far field GW Monitoring studies Surface & Groundwater Monitoring Program 4 Major D - Unlikely 14 (M) 34 Moderate Water Management Purchase licences equivalent to baseflow losses Erosion and Sediment Control 37 Monitoring Complex Water - Surface Contamination of clean water that should otherwise be diverted around the disturbance footprint. Loss of clean water from catchment. Increased water inventory on site due to clean water ingress. Water (surface) - Excess volume - exceed high-level storage target Community complaints / mistrust LTA Surface Water Management - Clean water entering dirty water management system Objections lodged to expansion / extension projects - delays & legal costs Progressive rehabilitation Clean water drain around open cut Clean water system Ground Disturbance Permit process. Environmental and statutory inspections. Environmental training and awareness program. Dirty water management system. 3 Moderat e B - Likely 17 (H) 35 Moderate Amend EPL 394 to enable permanent offsite discharge. Final landform design. CEMP's for construction works 38 Disposal of waste Complex Waste - Nonmineral Potential contamination of waste going to landfill and not achieving annual waste reduction targets Waste - No segregation / recycling Community complaints / mistrust Not compliance with waste management plan Regulator Concern - Increased scrutiny / stricter regulatory conditions Waste segregation bins Licensed waste management contractor Signage Waste Management Awareness training 2 Minor D - Unlikely 5 (L) 5 Moderate 39 Disposal of waste Complex Waste - Nonmineral Water and soil contamination from sewage treatment facilities Waste (hazardous) - Inappropriate disposal Health Impacts - noise/dust/odour/vibrat ion Non-compliance with EPL and PA conditions Regulator Concern - Increased scrutiny / stricter regulatory conditions Sewerage treatment plant maintained Licensed maintenance contractor to remove wastes 2 Minor D - Unlikely 5 (L) 8 Moderate 40 UG Coal Mining Underground Others - based on agreement from the group Subsidence impact - technical nonconformance Technical Standard - Non-compliance with external regulatory condition / standard Community complaints / mistrust Failure to notify the appropriate authority of significant subsidence related impacts to permanent survey control mark(s) / trig station. Regulator Concern - Increased scrutiny / stricter regulatory conditions subsidence monitoring program 1 Negligib le C - Possible 4 (L) 2 Minor Develop action management process for SMP. Survey commence, data delivery, data analysis, notification of movements outside the predicted and reporting to DP&E. ECC 41 UG Coal Mining Underground Biodiversity - Flora Subsidence impact biodiversity Subsidence - Impacts greater than predicted Habitat destroyed / Ecological impact - Protected species Loss of water into overburden strata through surface cracks, with Objections lodged to expansion / extension projects - delays & legal Subsidence Assessment Groundwater Model & assessment Installation of monitoring stations on nominated water courses as per Water MP 1 Negligib le D - Unlikely 2 (L) 14 Moderate Page 61 of 70

62 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d subsequent reduction in surface flows greater than predicted in EA costs Surface water Assessment EA & Part 3A Project Approval Visual inspections and monitoring Mitigation works where required Monitoring study of Ulan Creek & Bobadeen creek from previous underground mining (LW W2-W3 & 26) Experience from previous mining areas Water Management Surface Water Monitoring Program Discharge strategy Water treatment facilities 42 UG Coal Mining Underground Land / Soil Subsidence impact cliff lines Subsidence - Impacts greater than predicted Downstream users impacted - fauna Mining impacts the cliff line and/or visible rock falls (>20% of undermined length subject to rock falls) greater than predicted in the EA Regulator Concern - Increased scrutiny / stricter regulatory conditions Cliff Line Inspections & Monitoring Program Subsidence Monitoring 2 Minor D - Unlikely 5 (L) 19 Moderate 43 UG Coal Mining Underground Water - Surface Subsidence impact on surface water flows/ quality Subsidence - Impacts greater than predicted Water quality impact or deterioration Surface cracking Regulatory Action - i - Warning Labour and machinery available to complete repairs Fences and signage Visual inspections and monitoring Erosion and sediment control plan 2 Minor D - Unlikely 5 (L) 11 Moderate 44 UG Coal Mining Underground Water - Ground Subsidence impacts - groundwater Water (ground) - Regional impacts - sensitive receptors - outside ML boundaries Downstream users impacted - people / business Impact on surface vegetation due to lowering of water table by underground mining activities greater than predicted in the EA Significant ($) liability exposure - Details unknown or not well understood Groundwater modelling Near goaf and far field GW Monitoring studies Surface & Groundwater Monitoring Program Water Management 2 Minor D - Unlikely 5 (L) 16 Moderate 45 UG Coal Mining Underground Cultural / European Heritage Subsidence impacts - Cultural heritage sites Subsidence - Impacts greater than predicted Community complaints / mistrust Rock/tree fall (pagodas, cliffs, steep slopes, cracking) Regulator Concern - Increased scrutiny / stricter regulatory conditions Avoiding high significance sites Heritage Management Monitoring and inspections 2 Minor D - Unlikely 5 (L) 12 Moderate 46 UG Coal Mining Underground Others - based on agreement from the group Subsidence impacts - public safety (vehicle/horse/motorbike/walking) Subsidence - Impacts greater than predicted Community complaints / mistrust Rock/tree fall (pagodas, cliffs, steep slopes, cracking) Regulator Concern - Increased scrutiny / stricter regulatory conditions 4 Major E - Rare 10 (M) 47 UG Coal Mining Underground Others - based on agreement from the group Subsidence impacts - infrastructure Subsidence - Impacts greater than predicted Downstream users impacted - people / business Unsafe, unserviceable or unrepairable infrastructure powerlines or telephone cables Significant ($) liability exposure - Details unknown or not well understood Labour and machinery available to complete repairs Signage SMP / Extraction plan approval and management plan. Surface Infrastructure Management Baseline Surface Features Survey 2 Minor D - Unlikely 5 (L) 20 Moderate Page 62 of 70

63 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d Subsidence Monitoring Program Consultation with owner SMP / Extraction plan approval and management plan. 48 UG Coal Mining Underground Others - based on agreement from the group Subsidence impacts - private property/ agricultural infrastructure dams/ fences Subsidence - Impacts greater than predicted Downstream users impacted - people / business Impacts on dams and fencing on private property greater than predicted in the EA Significant ($) liability exposure - Details unknown or not well understood Labour and machinery available to complete repairs Signage Private Property Management Baseline Surface Features Survey Subsidence Monitoring Program 2 Minor D - Unlikely 5 (L) 20 Moderate Consultation with owner 49 UG Coal Mining Underground Others - based on agreement from the group Subsidence impacts - roadways Subsidence - Impacts greater than predicted Downstream users impacted - people / business Cracking of roadways sufficient to cause a traffic hazard/ greater than predicted in the EA - Bobadeen the only public Rd Significant ($) liability exposure - Details unknown or not well understood Labour and machinery available to complete repairs Fences and signage SMP / Extraction plan approval and management plan. Baseline Surface Features Survey Subsidence Monitoring Program 1 Negligib le B - Likely 7 (M) 20 Moderate SMP / Extraction plan approval and management plan. 50 UG Coal Mining Underground Others - based on agreement from the group Subsidence impacts - residences Subsidence - Impacts greater than predicted Downstream users impacted - people / business Impacts on residences greater than predicted in the EA Significant ($) liability exposure - Details unknown or not well understood Private Property Management Baseline Surface Features Survey Subsidence Monitoring Program 2 Minor D - Unlikely 5 (L) 20 Moderate Consultation with owner Mine Subsidence Board process Noise modelling. 51 UG Coal Mining Underground Noise / Vibration Regulatory non-compliance Community reputation Noise disturbance management specific locations, implications of complex activities Noise - Other Mine Noise Community complaints / mistrust Noise Generation - vent fans Objections lodged to expansion / extension projects - delays & legal costs Enclosed fan shaft Construction in day/ suitable weather Enclosed machinery Large buffer areas Noise Management. Environmental monitoring network. Workplace observations. Attended noise monitoring. 2 Minor D - Unlikely 5 (L) 17 Moderate ned maintenance inspections. 52 Rehabilitation Underground Mine Closure #3 Closure / sealing of FS#1 Closure - Liability (FA / ned / Unplanned Closure) Estimates not up to date or inadequate Impact / Inhibit Business Process / Operations - delays / stoppages / costs LOM budget omission Increase in Financial Assurance / Rehabilitation / Closure liability LOM includes review of CMCP 2 Minor D - Unlikely 5 (L) 53 Rehabilitation Complex Biodiversity - Flora Biodiversity offset implementation complexity Closure - Liability (FA / ned / Unplanned Closure) Estimates not up to date or inadequate Impact / Inhibit Business Process / Operations - delays / stoppages / costs Impractical methodology Increase in Financial Assurance / Rehabilitation / Closure liability BMP and OMP 2 Minor D - Unlikely 5 (L) Prepare schedule for revision of plans and resubmission to DP&E and DoE Rehabilitation Superintende nt Page 63 of 70

64 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d 54 Rehabilitation Complex Cultural / European Heritage Bobadeen homestead management and maintenance Closure - Liability (FA / ned / Unplanned Closure) Estimates not up to date or inadequate Impact / Inhibit Business Process / Operations - delays / stoppages / costs OHS issues with the property Increase in Financial Assurance / Rehabilitation / Closure liability advice and revised plan to DP&E with Heritage Architect agreement 2 Minor D - Unlikely 5 (L) 55 Rehabilitation Complex Mine Closure Rehabilitation maintenance/ Rehabilitation performance e.g. Rehab at Hill Faces - Liddle Closure - Liability (FA / ned / Unplanned Closure) Estimates not up to date or inadequate Impact / Inhibit Business Process / Operations - delays / stoppages / costs LTA resourcing (ops budget) for rehab maintenance works Increase in Financial Assurance / Rehabilitation / Closure liability Progressive rehabilitation including Goulburn River and CWS Annual rehabilitation/mine closure reviews Conceptual Mine Closure ALRMP Inspections 3 Moderat e D - Unlikely 9 (M) Investigate appropriate mitigation for poor performance of Rehab on highwalls Annual Walkover - revise timing to suit budget 56 Rehabilitation Complex Mine Closure Final land form voids cannot be closed due to lack of material. Risk for final landform around tailings and reject strategy Closure - Liability (FA / ned / Unplanned Closure) Estimates not up to date or inadequate Impact / Inhibit Business Process / Operations - delays / stoppages / costs Failure to adequately rehabilitate the tailings and rejects emplacement in accordance with regulatory requirements. Potential shortfall and/or logistical constraints for delivering suitable capping material. closure prior to reject emplacement Increase in Financial Assurance / Rehabilitation / Closure liability Use existing voids for reject emplacement. LOM reject emplacement strategy. Section 101 approval for discontinuance of reject emplacement area Final landform design. Conceptual Mine Closure. Detailed capping procedures. Consideration of rehabilitation in current tailings dam design. 3 Moderat e D - Unlikely 9 (M) Ecological Impact Assessment EA 57 Rehabilitation Complex Biodiversity - Fauna Non-compliance with Project Approval conditions Environmental Impact Technical Standard - Non-compliance with external regulatory condition / standard Community complaints / mistrust Greater than predicted impact to fauna (e.g. Pied Ear Bat) as a result of damaged habitat Objections lodged to expansion / extension projects - delays & legal costs Cliff Line Management Areas Pre & Post-mining Due Diligence Bat Surveys Cliff Line Inspections & Monitoring Program 2 Minor D - Unlikely 5 (L) Biodiversity Rehabilitation Offset MP Drilling and Exploration Management, which includes rehabilitation requirements. 58 Rehabilitation Complex Mine Closure Failure of site rehabilitation - includes site access tracks and plugging/capping of boreholes ning - Rehabilitation planning not adequate - does not cover full LOM and full lease Impact / Inhibit Business Process / Operations - delays / stoppages / costs Rehabilitation Objections lodged to expansion / extension projects - delays & legal costs Post-drilling and ongoing environmental inspections. Biodiversity Management plan MOP 2 Minor C - Possible 8 (M) Develop strategy for legacy borehole rehabilitation - include LOM RA and annual budgets ECC Inrush Management (New) - doesn t cover historic activities 59 Rehabilitation Complex Mine Closure Inadequate road and community service infrastructure to support increased use resulting in LTA service provision or infrastructure deterioration ning - Rehabilitation planning not adequate - does not cover full LOM and Community complaints / mistrust Rehabilitation and Mine Closure Significant ($) liability exposure - Details unknown or not well understood Rehabilitation execution Flora and fauna management plan. Conceptual mine closure planning. 2 Minor D - Unlikely 5 (L) 5 Catastrophic Page 64 of 70

65 Consequence Likelihood Risk Rank Number Ulan Complex Process/Activity in Mining Cycle STEP 1 Physical Site/Location Name STEP 2 Functional Risk Type STEP 3 Optional Descriptive Notes (Volume/Size) STEP 4 Risk Description/Detail STEP 5 Potential Impact Description Primary (Environment/Comm unity) STEP 6 Caused By (Additional Descriptive Info) STEP 7 Secondary Impact Description (Legal, Objections, Regulatory, Financial) if applicable STEP 8 Current Controls (Control Effectiveness) Current/Existing Controls (Primary Hard i.e. Prevention/Engineering STEP 9 Current/Existing Controls Soft i.e. Administrative/Training Current Risk (potential foreseeable outcome & associated likelihood with that specific consequence STEP 10 Potential Maximum Consequence (Plausible worst case consequence where all active/existing risk controls are ineffective) STEP 11 Risk Treatment/Action s (To reduce risk to an acceptable level) What Action detail STEP 12 Responsible Party Role When To be complete d full lease Environmental monitoring and inspections - long term. I&I NSW security deposit. AEMR inspection. Develop rehabilitation success criteria. Ensure the MOP reflects final rehabilitation and landform objectives detailed in the EA. Annual review of mine closure costs. Develop dewatering borehole sealing strategy. Establishing a timeframe for understanding pilot area construction and remediation works. 60 Rehabilitation Open Cut Water - Surface Instability and/or sedimentation of waterway. Water (surface) - >3- Year trend of salinity increases or ph reduction / increase, or other Community complaints / mistrust Goulburn River Diversion Regulator Concern - Increased scrutiny / stricter regulatory conditions Pilot project completed Goulburn River Diversion Remediation Environmental monitoring program 3 Moderat e C - Possible 13 (M) 3 Moderate Develop an inspection and maintenance schedule and review LOM plan to ensure inclusion. Consider suitability of closure criteria/ alternative monitoring techniques to demonstrate ecological function maintenance and improvement E&C Coord. Page 65 of 70

66 Surface Operations Personnel Underground Personnel Long-term contractors Short-term or Irregular Contractors All Staff All Supervisors & Managers underground operations All Supervisors & Managers surface operations Major projects/contract Engineering /Construction Projects Staff & supervisors Environmental Personnel Ulan Complex Appendix C - Environmental and Community Training Needs Analysis Skill Code Training Description Scenario Description Responsibility to supply training Method of Providing Training Frequency training required Environmental Overview Induction Training Ulan Complex or USO site familiarisation. Human Resources Site Familiarisation 3 yearly 2770 Environmental Management System Training HSMS, Mgmt., environmental system. Training Department Run at training days all staff and crews once per year 2 yearly 1978 Pollution Incident Response Training Training, enviro & comm, spill prevention & control. Training Department Run at training days all staff and crews once per year Annual 3157 Cultural Heritage Awareness Training Training, enviro & comm, cultural heritage awareness. Training Department Run at training days all staff and crews once per year 2 yearly 2962 Erosion and Sediment Control Training Training, enviro & comm, erosion & sediment control. E&C. Officer 2 sessions/year External Provider onsite 2 yearly 3804 legislation & Approvals Overview Training, enviro & comm, legislation. E&C Manager Run at SLTs and weekly approvals pipeline meeting 2 yearly 2772 Environmental Auditing Training, enviro & comm, environmental audit. E&C Manager External Provider Offsite Once off 4328 Community Community and stakeholder engagement training. GCAA External Provider Offsite Once off Page 66 of 70

67 Appendix D - Environmental Monitoring Locations Air Quality Monitoring Network Page 67 of 70

68 Noise and Blast Monitoring Network Page 68 of 70

69 Surface Water Monitoring Network Page 69 of 70

70 Groundwater North Monitoring Network Page 70 of 70