UNDERGROUND OPERATION

Transcription

1 UNDERGROUND OPERATION Approved Mine Manager Date: Environmental Adviser Date:

2 Integra Coal Underground ENVIRONMENTAL MANAGEMENT STRATEGY TABLE OF CONTENTS 1 GENERAL 5 C:\Users\oshan\AppData\Local\Microsoft\Windows\Temporary Internet Strate gy[1].doc 1.1 PROJECT OVERVIEW PURPOSE & SCOPE 6 2 RELEVANT CONSENT CONDITIONS 6 3 ENVIRONMENTAL POLICY 8 4 PLANNING IDENTIFICATION OF ENVIRONMENTAL IMPACTS LEGAL AND OTHER REQUIREMENTS Stakeholders Statutory & Policy Requirements ENVIRONMENTAL OBJECTIVES & TARGETS ENVIRONMENTAL MANAGEMENT PLANS / STANDARDS 10 5 IMPLEMENTATION & OPERATION STRUCTURE & RESPONSIBILITY Resources TRAINING, AWARENESS & COMPETENCE Environmental Awareness Training Induction Training Pre-start Meetings Training Records COMMUNICATION Internal Consultation and Communication Internal Environmental Incident Reporting External Consultation Community Consultative Committee Complaints Handling and Response Dispute Resolution Annual Environmental Management Report ENVIRONMENTAL MANAGEMENT SYSTEM DOCUMENTATION /6/07 6/6/10 ii of 26

3 5.4.1 Document Control OPERATIONAL CONTROL Operational Procedures EMERGENCY PREPAREDNESS AND RESPONSE Emergency Response Plan 21 6 MONITORING, EVALUATION & CORRECTIVE ACTION MONITORING & MEASUREMENT ENVIRONMENTAL MONITORING PROGRAM NONCONFORMANCE, CORRECTIVE AND PREVENTATIVE ACTION CUMULATIVE IMPACT MANAGEMENT RECORDS & RECORD MANAGEMENT ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT 25 7 REVIEW AND IMPROVEMENT MANAGEMENT REVIEW OF THE EMS 26 8 REFERENCES 26 Figures Figure 1 Figure 2 Figure 3 EMS Framework Independent Dispute Resolution Process EMP Documentation Framework Strate 1 6/6/07 6/6/10 iii of 26 gy[1].doc

4 Integra Coal Underground ENVIRONMENTAL MANAGEMENT STRATEGY DISTRIBUTED LIST Mine Manager Environmental Adviser Safety / Training Manager Operations Manager Mechanical Engineer All Personnel Share drive H Controlled Hardcopy Share drive H Share drive H Share drive H Share drive H Review Status Review By Date Original Document K. Barry March 2006 Review C. Ellis April 2007 Strate 1 6/6/07 6/6/10 iv of 26 gy[1].doc

5 1 GENERAL 1.1 PROJECT OVERVIEW Integra Coal Underground is an underground coal mine located approximately 12km north of Singleton in the Hunter Valley, NSW. The mine abuts the northern boundary of the Camberwell Coal Pty Ltd Coal Lease (now Integra Open Cut) with access to the underground lease (CL 382) provided from the north-western highwall of the former North Pit. Support facilities are located adjacent the highwall entry area within the North Pit and the surface facilities area is adjacent to the former Oak Park School (both within ML 1437). All coal produced from the mine is transported to, processed through and despatched from the Integra Open Cut facilities. A formal Environmental Management System (EMS) has been developed as a systematic and structured approach to managing environmental issues at the operation. This has been developed in general accordance with the requirements of the international standard ISO This strategy provides a documented guide to the Integra Coal Underground EMS. It is intended as a stand alone document that provides all the necessary information and tools for implementation of the EMS and managing the environment. Various additional documents and levels of the EMS are detailed in Section 5.4. Figure 1 EMS Framework Policy Environmental Policy Act Ownership Commitment Continual Improvement Planning Risk Review Legal Requirements Objectives and Targets Management Programs Check Monitoring and Measurement Non-conformance and Corrective Action Records EMS Audit Do Structure and Responsibility Training and Awareness Communication EMS Procedures Document Control Operational Control Emergency Response 1 6/6/07 6/6/10 5 of 26

6 1.2 PURPOSE & SCOPE The EMS has been developed to: Facilitate the management of environmental issues Ensure compliance with regulatory requirements Improve environmental performance and Meet stakeholder and community expectations of Integra Coal Underground. The EMS has been designed to support a dynamic system, which is responsive to the organizational needs, and ongoing developments in best practice environmental management. The overall aim of this management system is to promote a high level of environmental performance through the systematic minimisation of environmental impacts 2 RELEVANT CONSENT CONDITIONS The document has been prepared in accordance with the relevant conditions in the 2007 Section 3(A) modification that was approved by the Department of Planning for Glennies Creek Coal Mine Surface Facilities Project (now Integra Underground). The conditions of approval under schedule 5, that are applicable to the EMS are summarised in Table /6/07 6/6/10 6 of 26

7 Table 1 Relevant Consent Conditions CONSENT CONDITION EMS REFERENCE 1. ENVIRONMENTAL MANAGEMENT STRATEGY By the end of June 2007, the Proponent shall prepare and implement an Environmental Management Strategy for the project to the satisfaction of the Director-General. This strategy must: a) provide the strategic context for environmental management of the project; b) identify the statutory requirements that apply to the project; c) describe in general how the environmental performance of the project would be monitored and managed during the project; d) describe the procedures that would be implemented to; 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; manage any cumulative impacts; and respond to emergencies; and e) describe the role, responsibility, authority, and accountability of all key personnel involved on the environmental management of the project. This Document All sections Section Section 6 Section Section Section Section 6.3 Section 6.4 Section Section INDEPENDANT ENVIRONMENTAL AUDIT Following each Independent Environmental Audit, the Proponent shall review and if necessary revise each of the environmental management and monitoring strategies/plans/programs in schedules 3 and 5, to the satisfaction of the Director-General. The revised strategies/plans/programs shall be submitted to the Director- General within 6 months of completing the audit. Section /6/07 6/6/10 7 of 26

8 3 ENVIRONMENTAL POLICY Integra Underground has, and is committed to an Environmental Policy which states: At Integra Coal Underground we are committed to the development of a positive culture where we are responsible and accountable for our actions at all levels of our business. We are committed to operating in an environmentally responsible and safe manner through the application of our Operating Philosophy and Environmental Management System for; Complying with applicable environmental laws, regulations and statutory obligations; Communicating regularly with stakeholders; and Making environmental considerations an integral part of our activities. Copies of the policy are displayed in prominent positions across the site and further communicated through inductions and training. Copies of the policy are also included in public documentation such as the Annual Environmental Management Report. 4 PLANNING 4.1 IDENTIFICATION OF ENVIRONMENTAL IMPACTS An Environmental Risk Assessment for the project has been undertaken in accordance the Risk Assessment Guidelines. The Environmental Risk Assessment (EMS 004-8) shall be reviewed on an event basis, or as decided by relevant personnel as listed in section 5.1 with regard to the level of changing circumstances of the project. 4.2 LEGAL AND OTHER REQUIREMENTS Stakeholders Integra Coal Underground provides ongoing consultation with all stakeholders, consideration of their views, and timely feedback. Relevant stakeholders include: Department of Environment and Climate Change Department of Planning Department of Primary Industries Mineral Resources Catchment Management Authorities Singleton Shire Council Local Indigenous Groups Local Community 1 6/6/07 6/6/10 8 of 26

9 4.2.2 Statutory & Policy Requirements The Register of Legal and Other Requirements in EMS lists obligations, statutory requirements (licences, documentation) and industry codes. It indicates their application to the project and how the EMS addresses those obligations/requirements/codes. All activities conducted on a mine site are governed by statutory acts and regulations of New South Wales. Integra Underground is committed to complying with all regulatory requirements relevant to the environmental aspects of the operation and to the extent of the nature of the works being undertaken. Copies of the relevant Acts, Regulations, Standards, Licences, Leases and Approvals are maintained at Integra Underground, and can be readily accessed when required. Up-to-date legal environmental information for NSW and Australia applicable to the operation are obtained on a regular basis through the internet site the government gazette, and information provided by the minerals council and various other organisations. It is the responsibility of the Safety & Environmental Adviser and Manager Safety & Environment to monitor changes to environmental regulatory requirements and to ensure that all site personnel are made aware of these changes. The Safety & Environmental Adviser also ensures the EMS is amended as required to reflect any changes in regulatory requirements. Table 2 Integra Coal Underground - Approvals Statutory Authority Department of Primary Industries- Mineral Resources (DPI) Department Planning NSW of Department of Water and Energy Legislation Type of Approval Date Mining Act, 1992 Coal Lease 382 Expires 2012 Environmental Planning and Assessment Act, 1979 Water Management Act Consolidated Development Consent comprising: DA 105/90, Modifications dated Nov 1998, Dec 2001, June 2002, Feb 2005, Nov 2005, and Sep Section 3(A) approval, Jan Water Access Licences: o 960 o 961 o 484 o 485 o 1172 o 1173 Sep 2006 Jan 2007 In Perpetuity In Perpetuity In Perpetuity In Perpetuity In Perpetuity In perpetuity 1 6/6/07 6/6/10 9 of 26

10 Department of Environment and Climate Change Protection of the Environment Operations Act, 1997 WorkCover NSW Explosives Act 2003 Explosives Regulation 2005 Occupational Health and Safety Act 2000 o 1242 o o 20BL o 20BL o 20BL o 20BL o 20BL o 20BL Environment Protection Licence No 7622 For magazines, explosives, detonators & onsite diesel storage. In perpetuity In perpetuity In perpetuity In perpetuity In perpetuity In perpetuity 25/09/ /09/2010 Annually Expires 09/03/2006 (In process of renewing under new legislation) 4.3 ENVIRONMENTAL OBJECTIVES & TARGETS The list of Objectives and Targets for significant items identified as part of the EMS is located in document EMS Targets demonstrate commitment to legal and productivity requirements in addition to the promotion of sustainable development and pollution prevention (eg water conservation and waste minimisation). Environmental Objectives aim to promote a regime of continual improvement in environmental management. 4.4 ENVIRONMENTAL MANAGEMENT PLANS / STANDARDS EMS 002 documents contain Environmental Management Programs for the project. A number of management plans/programs relating to separate environmental aspects of the project are in existence to ensure both legislative compliance with relevant consent conditions and to assist in overall environmental management on the site. Specific environmental management programs are listed in Table 3. Table 3 Environmental Management Plans / Standards Document No. Title EMS Site Water Management Plan EMS Air Quality Monitoring Program EMS Noise Management Program EMS Aboriginal Cultural Heritage Management Plan 1 6/6/07 6/6/10 10 of 26

11 5 IMPLEMENTATION & OPERATION 5.1 STRUCTURE & RESPONSIBILITY Roles, responsibility and authorities are defined, documented and communicated in order to facilitate effective environmental management. The organisational structure for Integra Coal is presented in the Integra Organisational Chart (FRM-0124). A basic outline of the environmental responsibilities is described below. Mine Manager The Mine Manager is accountable for the Environmental performance of the Integra Coal Underground operation. The Mine Manager is responsible for reinforcing leadership and commitment by being actively involved in the review of policy core values and promoting continual improvement in the operations environmental performance. Area Managers/ Superintendents Management are responsible for providing resources essential to the implementation and control of the EMS within their work areas. Resources include human resources and specialised skills, technology and financial resources. Managers and Superintendents have overall accountability for the environmental performance of their work areas. Environmental Adviser The Environmental Adviser is responsible for all aspects of the development and implementation of the EMS to ensure all business targets are achieved and risks minimised. The Environmental Adviser is responsible for reporting the performance of the EMS to management for review and as a basis for improvement of the EMS. The Environmental Adviser acts as a contact person for Integra Coal Underground with government authorities and community in relation to the environmental performance during the operation of the Integra Coal Underground Mine. The Environmental Adviser is specifically responsible for: Promoting best practice environmental management; Maintaining and providing assistance in the implementation of the environmental policy, management plans, procedures and statutory requirements; 1 6/6/07 6/6/10 11 of 26

12 Coordinating monitoring and ensuring statutory compliance with government agencies and/or legislation and the requirements outlined in the EMS; Reporting on license/regulatory breaches and assisting in the rectification of such breaches; Assisting employees, contractors and managers in fulfilling their environmental responsibilities; Increasing environmental awareness amongst site personnel; Maintaining environmental records including environmental monitoring data, complaints and environmental incident reports; and Receiving and responding to complaints. All Personnel All personnel have a responsibility to protect the environment through their actions or the omissions of their actions. Generally, their responsibility and duty of care requires all personnel to: Undertake activities in accordance with all Integra Coal Underground Environmental Policy, procedures, management plans and statutory requirements; Implement appropriate environmental measures as outlined in the Environmental Management System; Recognising environmental hazards associated with specific activities through a risk based assessment process; Reporting all incidents and dangerous occurrences including harm to the environment as soon as practicable; Reporting all substandard or abnormal conditions that may cause harm to the environment; and Taking necessary action to prevent harm to the environment Resources Significant financial and personnel resources are allocated to Environmental Management at Integra Underground. Additional Information on the allocation of these resources can be obtained from the Environmental Adviser. 1 6/6/07 6/6/10 12 of 26

13 5.2 TRAINING, AWARENESS & COMPETENCE Environmental Awareness Training Training is an essential component of the implementation phase of the EMS. All personnel are required to undergo Environmental Awareness Training as a minimum. Topics discussed in Environmental Awareness training include the following: Reasons for protecting the environment; Environmental hazard and incident identification and reporting; Environmental legal and regulatory requirements; Key environmental issues and impacts; Requirement of the EMS and roles and responsibilities; and Emergency response requirements. Additional training modules are developed based on key risk areas of the operation and are delivered on an ongoing basis as required. Table 4 below provides a summary of training modules to be developed for key risk areas at Integra Underground. Table 4 Training Modules Training Modules Personnel Description Hydrocarbon and Spill Management Waste Management Air, Land and Water Management General workforce General workforce General workforce Overview of the minimum requirements for storage, handling and disposal of hydrocarbons. Introduction to hydrocarbon management practices, including use of MSDS s, spill response procedures and use of site spill kits. Overview of the minimum requirements for avoiding/ minimising, recycling/ reusing and disposing of waste from Integra Underground. Overview of the minimum requirements for managing air quality, water and land at Integra Underground including an outline of the monitoring programs Induction Training All personnel entering the site to perform work for or on behalf of Integra Underground are required to undergo an induction. The level of training given relates to the areas that the employee requires access. There are two types of Induction training conducted, namely: General Surface Inductions; and Underground Inductions. 1 6/6/07 6/6/10 13 of 26

14 A certified company employee or the Training & Human Resources Adviser is responsible for conducting this training. The Safety & Environmental Adviser and the Training & Human Resources Adviser ensure that the content of the induction adequately reflects the ongoing changes of the operations conditions and activities in relation to managing the environment. The Area Managers and Superintendents are responsible for ensuring that all persons entering their work area have undergone the correct induction training Pre-start Meetings Pre-start meetings are a minute training session discussing current issues relevant to the Integra Coal Underground work site; this includes production, safety and environmental issues. All employees are required to attend pre-start meetings. Environmental pre-start topics are developed as both a proactive and reactive response to environmental issues. Proactive pre-start topics are based upon identified risks in the operation and the mining industry. In general, these topics may be identified through risk assessments; environmental alerts; industry environmental statistics or employee/management requests. Reactive pre-start topics are based upon an increase in the number of environmental incidents; failure to comply with procedures; a breakdown within the system or other negative occurrences within the operation Training Records Training records are maintained for all personnel who complete environmental training. Training records include copies of training packages, assessments and attendance record sheets. The Training & Human Resources section is responsible for maintaining environmental training records for a minimum of 4 years. 5.3 COMMUNICATION Internal Consultation and Communication Integra Underground encourages a constructive and consultative approach to environmental management and active participation by all personnel in the environmental management of the operation. The main internal communication channels are;- Shift Changeover Meetings: a shift meeting where all hazards & incidents as well as production information for the previous shift are raised and discussed. Monthly Communication Meetings: as implied by the title these meetings occur monthly and provide a detailed presentation in regards to the previous months mine operation, this includes environmental matters and concerns for that period. 1 6/6/07 6/6/10 14 of 26

15 Toolbox Meetings: training session are held to raise the OHS and environmental awareness of the workforce and to discuss identified OHS and environmental aspects/ impacts in the workplace. Toolbox meetings also provide an opportunity for employees to discuss any environmental concerns / issues. Notice Boards: Notice boards are used to display relevant Environmental and OH&S information, alerts, and statistics Internal Environmental Incident Reporting All personnel are required to report environmental incidents that cause potential or actual harm to the environment and/or are determined to be a non-conformance. Environmental incidents are to be reported on an Incident Report Form (FRM0028) as soon as possible by the person/s involved. The following information is recorded on the Incident Report Form: Time, date, location and name of person who identified the incident; Description of the incident and investigation: How and why the incident occurred; What was the actual environmental impact; Corrective actions to reduce short term recurrence and risk; and Preventative Actions to prevent long term recurrence of the incident. If there are any requirements for external reporting such as: o Reporting of incident to EPA, DMR or other regulatory agency; or o Reporting to external emergency services such as police and the fire brigade. Once completed the Incident Report Forms are required to be signed-off by the following: The person/s completing the incident form; The Head of the Department responsible for the incident; The Mine Manager (for all major environmental incidents); and The Safety & Environmental Adviser (confirming that the required corrective and preventative actions have been implemented). All environmental incidents are lodged in the Incident Register. The Safety & Environmental Advisor is responsible for maintaining this Incident register and the Incident Report Forms. Where an environmental incident occurs that is required to be reported to external agencies, the Safety & Environmental Adviser is responsible for investigating and completing any external environmental reports for the notifying bodies. 1 6/6/07 6/6/10 15 of 26

16 5.3.3 External Consultation Community Consultative Committee A Community Consultative Committee (CCC) has been established to monitor compliance with the conditions of consent and to discuss any issues of concern. The committee comprises representatives from the local community, Singleton Shire Council and Integra Coal Underground. Representatives from the relevant government agencies are invited to attend meetings of the committee as required. The committee holds meetings bi-annually with Integra Coal Underground providing: Information on the progress of works; Monitoring data; Complaints report; Such other information that the chairperson of the committee may request concerning the environmental performance of the operation; and Reasonable access for site inspections by the committee. Minutes of the committee meetings are maintained by the Safety & Environmental Adviser and reported in the Annual Environmental Management Report (AEMR) Complaints Handling and Response Integra Underground has a 24-hour telephone hotline (Phone number ) for members of the public to lodge complaints, concerns or to raise issues associated with the operation. This service aims to promptly and effectively address community concerns and environmental matters. The hotline number is advertised regularly in the local newspaper and members of the community are encouraged to contact the hotline if they need to highlight any environmental issues or seek information regarding environmental aspects associated with Integra Underground. The hotline also enables the EPA to directly contact a representative from Integra Underground who can respond to incidents and provide any information required under the EPA license. In addition members of the community can contact the Integra Underground Safety & Environmental Advisor in person, by phone, fax, or letter. Any person that is likely to be in a position to receive concerns is trained to deal with complaints in a professional and effective manner. 1 6/6/07 6/6/10 16 of 26

17 All complaints received are recorded on Complaints Form (EMS 004-3) and lodged in the complaints register. Information recorded includes: Date and time the complaint was lodged; Personal details provided by the complainant; Nature of the complaint; Action taken or if no action was taken, the reason why; and Follow up contact with the complainant Dispute Resolution All disputes will be handled by the site Safety & Environmental Advisor, if the response of Integra Underground is not considered to satisfactorily address the concern of the complainant, a meeting will be convened with the Mine Manager and/or the Manager of Safety and Environment and the Environmental Advisor. The complainant will be advised of the outcomes from the meeting and the actions to be implemented as a result. After implementation of the proposed actions the complainant will be contacted and advice sought as to the satisfaction or otherwise with the measures taken. If no agreed outcome is determined, an Independent Review may be requested by landowners to determine if the relevant Impact Assessment Criteria of the project is being exceeded. If determined to be warranted by the director-general, an Independent Dispute Resolution Process, outlined in Figure 2, will be implemented to achieve an agreed outcome. 1 6/6/07 6/6/10 17 of 26

18 Figure 2 Independent Dispute Resolution Process Independent Dispute Resolution Process (Indicative Only) Matter referred to Independent Dispute Facilitator appointed by the Department in consultation with Council. Independent Dispute Facilitator meets with parties to discuss dispute Dispute resolved Dispute not resolved Facilitator consults relevant independent experts for advice on technical issues Facilitator meets with relevant parties and experts Dispute resolved Dispute not resolved Facilitator consults the Department and final decision made Agreed Outcome 1 6/6/07 6/6/10 18 of 26

19 5.3.6 Annual Environmental Management Report An Annual Environmental Management Report (AEMR) is produced for Integra Underground as part of the Mining, Rehabilitation and Environmental Management Process (MREMP). The AEMR provides a summary of operations within the reporting period, community contact/response reporting and a review of environmental management and monitoring performance for the preceding 12 months. The AEMR also includes any proposed modification to environmental management and monitoring procedures for the ensuing 12- month period. Specifically, the AEMR includes the following matters: An annual compliance audit of the performance of the operation against development consent conditions and other statutory approvals; A review of the effectiveness of the environmental management of the operation in terms of relevant government agency requirements; Interpretations and trends of environmental monitoring results; A listing of any variations obtained to approvals during the previous 12 months; An outline of the water management system, including the quantity of water used and details of any water discharged from site; Environmental management targets and strategies for the ensuing 12-month period; Rehabilitation report; and An annual evaluation of the feasibility of methane drainage and reuse. The AEMR is distributed to DEC, DPI, EPA, Singleton Council and the Community Consultative Committee. The AEMR is also made public information at Singleton Council. 5.4 ENVIRONMENTAL MANAGEMENT SYSTEM DOCUMENTATION Specific Environmental Management System Standards and Procedures have been developed for the EMS. It is intended that these documents will: describe the core elements of the management system and their interaction provide direction to related documentation and other references. The five levels of documentation within the EMS are summarised in Table 5 and diagrammatically represented in Figure 3, with procedures incorporated within the EMS /6/07 6/6/10 19 of 26

20 Figure 3 EMP Documentation Framework Environmental Policy EMS 000 Environmental Management Strategy OMP 0300 Management Plans/Standards EMS 002 Procedures EMS 003 Supporting Documents EMS 004 Table 5 EMS Documentation Document No. EMS 000 OMP 0300 EMS 002 EMS 003 EMS 004 Title Environmental Policy Environmental Management Strategy Management Plans / Standards Procedures Supporting Documents The Safety & Environmental Adviser manages all documentation relating to the EMS. All documentation is available through controlled document manuals, which are maintained by the Safety & Environmental Adviser Document Control All EMS documentation is developed within the guidelines of the Document Control Procedure in the Safety Management Plan and are termed as standards for that purpose. The document control system aims to ensure that;- Documents are periodically reviewed and are accessible; Relevant people are informed of new documents and changes to existing documents; Superseded and obsolete documents are promptly removed; and Documents to be retained for legal purposes are identified and stored. Controlled document tracking is minimised by having one controlled hardcopy of the EMS (Safety & Environmental Adviser) with a controlled read only access on the site LAN. 1 6/6/07 6/6/10 20 of 26

21 5.5 OPERATIONAL CONTROL Operational Procedures Environmental procedures provide an outline of how activities will be carried out in a manner that minimises potential harm to the environment. Environmental procedures are drafted for major risk activities and work areas identified in the risk assessment to help control and/or mitigate the risk. Environmental procedures include purpose, scope, objective, definitions, references, responsibilities, procedural requirements/steps and training sections where required. These procedures provide the step-by-step process of how to carry out a specific task or provide specific or further detail for environmental requirements within the work areas. Table 6 provides a list of the current documented procedures for Integra underground. Table 6 Environmental Procedures Document No EMS EMS EMS EMS EMS Title Hydrocarbon and Chemical Management Waste Management Water Management Land Management Air Quality Management Where procedures do not exist for a work activity, a risk assessment is required to be undertaken prior to commencement of work. Risk assessments are aimed at identifying potential risks/ hazards associated with the work tasks. This includes environmental risks or hazards. Risk assessments are undertaken in accordance with the SMP Risk Assessment Management Plan. 5.6 EMERGENCY PREPAREDNESS AND RESPONSE Emergency Response Plan The environmental emergency response plan is an integral component of the OHS Emergency Response Plan. Emergency procedures have been developed for major environmental incidents. Examples of major environmental incidents include: Major spill of hydrocarbons or chemicals; Release of water off-site into watercourses; Bushfire events 1 6/6/07 6/6/10 21 of 26

22 Controlled copies of the Emergency Response Manuals are located at designated areas across the site. It is the responsibility of the Safety & Environmental Adviser to ensure that the environmental section of the Emergency Response Plan is reviewed every 12 months and changes are communicated to all interested parties. It is the responsibility of the area manager to ensure that Emergency Response Plans are applicable to their work area and made available to all employees, contractors and interested parties. Further detail on the Emergency Response Plan can be obtained in the OHS Emergency Response Management Plan. 6 MONITORING, EVALUATION & CORRECTIVE ACTION Measuring, monitoring and evaluating are key activities that ensure Integra Underground is performing in accordance with the EMS Policy, objectives and targets, whilst also addressing ongoing planning. 6.1 MONITORING & MEASUREMENT Integra Underground have a number of monitoring and measurements systems established that provide a means by which to evaluate and demonstrate improvements in environmental management. Table 7 provides an outline of the main monitoring/measurement systems utilised at Integra Underground that are an integral component of the operations EMS. Table 7 Monitoring and Measurement Systems System Hazard Incident Reporting Environmental Inspection Performance Auditing Systems Auditing Environmental Action Plans Description A system for reporting hazards, incidents, complaints, nonconformances. Summary reports are generated monthly to monitor performance and identify trends. A system for inspecting work areas across the operation. A system utilised to audit the environmental performance of Integra Underground. A system utilised to audit Integra Undergrounds EMS documentation. Monitoring of actions plans developed for Integra Underground. 1 6/6/07 6/6/10 22 of 26

23 6.2 ENVIRONMENTAL MONITORING PROGRAM All key characteristics of the operation that can have an impact on the environment are monitored on a regular basis in accordance with development consent conditions, environmental licences and other statutory conditions. An overview of the environmental monitoring that occurs at Integra Underground is provided in the Integra Coal Underground Environmental Monitoring Program. This document consolidates the various monitoring programs contained within management plans / standards implemented at Integra Underground. A brief overview of the environmental monitoring program is provided in Table 8. Further details of each monitoring focus are provided in the relevant environmental management plan / standard. Table 8 Environmental Monitoring Program Overview Parameter Monitored Monitoring Program Frequency Water Surface Water Site Water Management Plan Various - Refer Integra Underground Site Water Ground Water Management Plan Water Supply and Demand Erosion and Sediment Control Structures Noise Attended noise monitoring Noise Monitoring Program Quarterly Air Quality Dust deposition Air Quality Monitoring Program Monthly High volume air sampling (TSP and PM10) Run every 6 days, collated monthly Meteorology Local Air Quality Monitoring Program Collated monthly Regional Aboriginal Heritage Aboriginal Cultural Heritage Management Plan Obtained as required As outlined in Aboriginal Cultural Heritage Management Plan The Safety & Environmental Adviser is responsible for the implementation of the environmental monitoring programs. The Safety & Environmental Adviser is also responsible for maintaining environmental data and records in a legible form for a minimum of 4 years in accordance with the EPA licensing requirements. 1 6/6/07 6/6/10 23 of 26

24 Monitoring data and trends are reported in the Annual Environmental Management Report as detailed in section Monitoring results will also be made publicly available through the website, with updating of results occurring at least every 6 months. 6.3 NONCONFORMANCE, CORRECTIVE AND PREVENTATIVE ACTION Non-conformances can be either an environmental non-conformance or a system nonconformance and can include: Failure to comply with legislative or licensing requirements; Failure to comply with systems or procedures; Exceedances of monitoring criteria; Repeated environmental incidents of similar nature; and Deviations from the Environmental Policy, objectives or targets. Non-conformances are identified through the following processes: Environmental Inspections; Internal and External Auditing; Incident and Complaints Reporting; Communications and Meetings; Environmental Monitoring; and Management Reviews. Integra Underground utilises the Incident Reporting System as detailed in section for the reporting and actioning of all non-conformance incidents and hazards. The reporting process involves identifying: Actual or potential harm to the environment; The causes of the non-conformance; Corrective actions to reduce short term recurrence and risks; and Preventative actions to prevent long term recurrence of the non-conformance such as: - Modifying systems or procedures; - Providing training; or - Communicating legislative requirements, policies and procedures. Non-compliances related to Integra Undergrounds Environmental Protection Licence will be reported in the annual licence return. 1 6/6/07 6/6/10 24 of 26

25 6.4 CUMULATIVE IMPACT MANAGEMENT Due to the location of Integra Underground and its locality in respect to a number of other mines within the local area, cumulative impacts are expected to exist within the vicinity of the mine. The following management strategies will be implemented to deal with cumulative impacts. Where practicable, Integra Underground will share monitoring and other environmental data with Integra Open Cut. Meteorological conditions recorded will be used to determine the most likely source of any pollutant that exceeds the Impact Assessment Criteria guidelines. The Safety & Environmental Advisor will also communicate with the Environmental Advisors of surrounding mines in an attempt to facilitate a joint conflict resolution in regards to complaints received with specific emphasis on cumulative impact. 6.5 RECORDS & RECORD MANAGEMENT The Safety & Environmental Adviser maintains all EMS records, which are not of a confidential nature. Records that are maintained include: Monitoring data and equipment calibration; Environmental inspections and auditing results; Environmental incident and complaint reports; Risk register; and Licenses and permits. All records are stored so that they are legible, readily retrievable and protected against damage, deterioration and loss. Records are maintained for a minimum of 4 years. Environmental records are stored under the relevant sections of the EMS as outlined in the EMS system documentation framework (Figure 3 and Section 5). 6.6 ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT Both internal & external EMS audits are conducted to determine if the system has been properly implemented, maintained and whether the operation is meeting the performance objectives set in the Environmental Policy. An internal EMS Audit is conducted nominally on annual basis by the Safety & Environmental Adviser and nominated team. External audits will be conducted on at least a 5 yearly basis, as required by relevant consent conditions. An action plan (EMS 004-1) has been developed for any improvements or recommendations identified in the audits. Progress against the action plans are monitored, at a minimum 1 6/6/07 6/6/10 25 of 26

26 annually, against completion dates for each recommendation by the Safety & Environmental Adviser. 7 REVIEW AND IMPROVEMENT 7.1 MANAGEMENT REVIEW OF THE EMS A management review that includes review of this Environmental Management Strategy will be carried out annually, after independent environmental reviews, and as required by relevant consent conditions. The purpose of the review is to ensure that the Environmental Management Strategy remains suitable, adequate and effective. Items to be addressed include, inter alia, the Policy, Objectives, control measures, auditing and Action Plans. Senior management will conduct this review. identified are documented in meeting minutes. The review and improvement measures 8 REFERENCES Environmental Management Systems Specification with guidance for use. (AS/NZS ISO 14001:1996) 1 6/6/07 6/6/10 26 of 26