Springvale MPPS Water Treatment Project

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1 Springvale MPPS Water Treatment Project Construction Environmental Management Plan SMPPS-O-00-M DOCUMENT CONTROL Rev Date Revision Comments Prepared by Reviewed by Approved by 0 18/08/2017 Draft for internal review Elena Ivanova Project Manger Jonas Ball Linchpin Environment 1 27/10/2017 Final Elena Ivanova Project Manger Jonas Ball Linchpin Environment Huw Thomas HSEQ Lead

2 Page: Page 2 of 50 CONFIDENTIALITY CONDITIONS All information whether oral, electronic, printed or graphic contained in this document or obtained by you from VANZ (Information) is confidential to VANZ and shall not be used by you other than for the purpose of reviewing this document and the proposal contained herein. You shall not copy or reproduce any Information except when, and then only to the extent, reasonably necessary for the purpose of reviewing this document and the proposal contained herein. Upon receiving notice that our proposal has not been accepted, and if notified by VANZ, you shall destroy, in a secure manner, this document and any Information. You shall ensure that any employee or any other person to whom you supply the Information is bound by the terms of these conditions.

3 Term AIMS AHIMS BCSI BMP BMS CoDC DP&E EIS, 2016 EI&C EMP EMS Page: Page 3 of 50 DEFINITIONS AND ACRONYMS Table 1 Definitions and Acronyms Definition Abergeldie s Integrated Management System Aboriginal Heritage Information Management System Baseline Contaminated Site Investigation Biodiversity Management Plan Business Management System Conditions of the Development Consent Department of Planning and Environment Environmental Impact Statement Electrical, Instrumentation & Controls Contractor s Environmental management Plan Environmental Management System EP&A Act Environmental Planning and Assessment Act 1979 EPA EPL JSEA CEMP Contractor NSW Environment Protection Authority Environmental Protection Licence Job Safety & Environment Analysis Abergeldie Contractors Pty Ltd CLM Act Contaminated Land Management Act 1997 Customer ML/day MPPS PAC Springvale Coal Pty Ltd and NSW EnergyAustalia Pty Ltd mega litres a day Mount Pipe Power Station Planning Assessment Commission POEO Act Protection of the Environment Operation Act 1997 SMPPS WTP or Project PM PMP REA SWMS WTF WTS VANZ or Veolia Springvale MPPS Water Treatment Project Project Manager Project Management Plan Reject Emplacement Area Safe Work Method Statement Water Treatment Facility Water Treatment System Veolia Australia and New Zealand WARR Act Waste and Resource Recovery Act 2001 WHS Act Work Health and Safety Act 2011

4 Page: Page 4 of 50 TABLE OF CONTENTS Section 1 Introduction Background Scope and Objectives Supporting Management Plans Veolia s Overall Management System... 8 Section 2 Statutory and Policy Considerations Relevant Environmental Legislation Other Requirements Summary of Licensing and Permit Requirements Conditions of Development Consent Section 3 Project overview Project Overview Project Location Project Phases Construction Hours Predicted Construction Impacts Section 4 Implementation of the CEMP Roles and Responsibility Subcontractor Management Training and Awareness Stakeholder Management Plan Incident and Emergency Response Notification and Action Protocol Emergency Contacts Pollution Incident Management Environmental Performance Criteria Contingency Plan Performance Reporting Section 5 Monitoring and Review of the CEMP Monitoring and Inspections Auditing Review of the CEMP Corrective Action Appendices Appendix A - Copy of the Development Consent Appendix B1 - Water Management Plan Appendix B2 - Biodiversity Management Plan Appendix B3 - Aboriginal Cultural Heritage Management Plan Appendix B4 - Construction Noise Management Plan Appendix B5 - Construction Traffic Management Plan Appendix B6 - Stakeholder Management Plan Appendix B7 - Construction Waste Management Plan Appendix C - EPL requirements EPA Clarifications Appendix D - Pre-Construction Compliance Report... 50

5 Page: Page 5 of 50 TABLES Table 1 Definitions and Acronyms... 3 Table 2 Licencing and Permitting Requirements Table 3 Development Consent Requirements Table 4 Construction Operating Hours Table 5 Air Control Measures Table 6 GHD Mitigation Measures Table 7 Visual Mitigation Measures Table 8 Summary of Key Roles and Responsibilities Table 9 Training and Awareness Methods Table 10 Environmental Risks Table 11 Communication Mechanism Table 12 Project Emergency Incident Reporting Contacts Table 13 Environmental Performance Criteria Table 14 Summary of Contingency Measures Table 15 Summary of Monitoring and Inspections FIGURES Figure 1 Integrated Services Management Flowchart... 9 Figure 2 Project Overview Figure 3 Project Location Figure 4 Land Ownership Figure 5 Incident Response Flow Chart... 34

6 Page: Page 6 of 50 SECTION 1 INTRODUCTION 1.1 Background This (CEMP) and supporting management plans have been prepared to comply with the Conditions of Development Consent granted on 19 June 2017 (CoDC) for the construction of the Water Transfer System (WTS) from existing Springvale Mine dewatering facilities on the Newnes Plateau to a new Water Treatment Facility (WTF) located at the Mount Piper Power Station (MPPS). Springvale Coal Pty Ltd has collaborated with EnergyAustralia Pty Ltd to develop the above, which is known as the Springvale MPPS Water Treatment Project (SMPPS WTP) (Project). The Project includes the following major elements: A system to transfer (approximately 15 km ) up to 42 mega litres a day (ML/day) of dewatered mine water from the existing gravity tank forming part of the approved dewatering facilities on the Newnes Plateau to a new WTF to be located at the MPPS site (see Figure 2 below). A WTF incorporates desalinisation processes to reduce the salinity in mine water to a standard suitable for either industrial reuse or environmental release. Transfer of treated water from the water treatment plant to the MPPS cooling water to contribute to the demand for make-up water. Transfer via a new 2.4 km pipeline and discharge of any excess treated water not able to be reused within the MPPS cooling water system to Thompsons Creek Reservoir. Transfer of residual material from the pre-treatment process to the existing reject emplacement area (REA) at the Western Coal Services Site. Installation of a crystalliser to provide further treatment of the additional salt load generated within the MPPS cooling water blowdown system. The project would remove the current need to discharge a large amount of mine water to the drinking water catchment, and provide a beneficial reuse of this water in the operation of the MPPS. This project will improve environmental outcomes and water quality within the upper Cox s River catchment area. Veolia has been selected as specialist water services company to finance, design, construct, test and commission, operate and maintain the Project. The duration of the operations and maintenance phase is 15 years. This arrangement is documented under a Water Treatment Services Contract to be entered into between the Springvale Coal Pty Ltd, NSW EnergyAustalia Pty Ltd (Customer) and Veolia. Veolia has selected Abergeldie Complex Infrastructure Pty Ltd (Contractor) as the construction subcontractor for the Project. Abergeldie will be responsible for the design, construction and commissioning of the WTS, including the Mine Water Transfer Pipeline, Residuals Transfer Pipeline, Treated Water Pipeline connecting to Thompsons Creek Dam and a new WTF. Abergeldie shall also be responsible for the design and construction of the civil and buildings portion of the WTF as well as the mechanical and EI&C construction, based on Veolia s design. The NSW Department of Planning and Environment (DP&E) has assessed the State Significant Development (SSD 7592) in accordance with section 89(C) of the Environmental Planning and Assessment Act 1979 (EP&A Act). DP&E has delegated SSD 7592 to the Planning Assessment Commission (PAC) for determination under the Minister s delegation of 14 September The PAC determined the development application for the Project on 19 June 2017 as well as two

7 Page: Page 7 of 50 modifications associated with the Project: Wester Coal Services Residuals Emplacement Modification (SSD 5579 MOD1) and Springvale Mine Extension Project (SSD 5594 MOD2). This CEMP has been prepared to detail the processes and procedures adopted by Veolia to identify, manage and control construction environmental aspects and impacts associated with the Project. The project area contains significant environmental values, including threatened flora species, aboriginal artefacts and significant amounts of native vegetation. 1.2 Scope and Objectives This CEMP responds to the Environmental Management Strategy (EMS) required under CoDC Schedule 4, condition 1 for construction phase of the Project. Approval has been obtained from the Secretary under CoDC Schedule 4, condition 3 to phase the submission of the EMS. Three stages have been approved namely construction, commissioning and operations. This Construction EMS includes: the strategic framework for environmental management of the Project; identification of the statutory approvals that apply to the Project; description of the role, responsibility, authority and accountability of all key personnel involved in the environmental management of the Project; describe the procedures that will be implemented to: o o o o o keep the local community and relevant agencies informed about the construction and environmental performance of the Project; receive, handle, respond to, and record complaints; resolve any disputes that may arise; respond to any non-compliance; respond to emergencies; copies of any plans required under the CoDC; and a clear plan depicting all the monitoring to be carried out in relation to the Project construction. While the Environmental Management Strategy is predominantly an externally oriented document, containing commitments to specific stakeholders, this CEMP is the chief internal document for environmental management of construction and commissioning of the Project. The objectives of this CEMP are to: Provide a working environmental management tool to follow during the construction phase of the Project; Comply with relevant environmental legislation, including the Conditions of Development Consent (refer to Appendix A) relating to the construction phase of the Project and the recommendations provided in the Licensing Guide (EPA NSW, 2016); Provide a means of implementing the recommended mitigation measures for the key environmental issues, associated with construction of the Project, identified in the Environmental Impact Statement (EIS) prepared by GHD in 2016; Define roles and responsibilities of the project management team and contractors during the construction phase of Project;

8 Page: Page 8 of 50 Provide a guide for the interaction with relevant government authorities and other relevant stakeholders, including the community during the construction phase of the Project. This CEMP and supporting management plans have been prepared to provide the management measures to be implemented to minimise potential adverse impacts on the environment during the construction phase of the Project. This CEMP is a live document and outlines the management strategies and control measures which will be reviewed and updated, where necessary, to reflect changes introduced by the construction project team, site specific outcomes, non-conformances and recommendations arising out of inspections, meetings and audits. 1.3 Supporting Management Plans The Project has planned to take actions to address significant environmental aspects, compliance obligations and the risks and opportunities they present, as well as its objectives. These have been incorporated in the supporting management plans to provide the management and control measures to be implemented to minimise potential adverse impacts on the environment. These plans are listed below and presented as separate documents in Appendix B. Water Management Plan (Refer to Appendix B1); Biodiversity Management Plan (Refer to Appendix B2); Aboriginal Cultural Heritage Management Plan (Refer to Appendix B3); Construction Noise Management Plan (Refer to Appendix B4); Construction Traffic Management Plan (Refer to Appendix B5); Stakeholder Management Plan (Refer to Appendix B6); Construction Waste Management Plan (Refer to Appendix B7). 1.4 Veolia s Overall Management System Veolia has developed and implemented a Business Management System (BMS) to assist in meeting the corporate objective of its water operations through sustainable development. In the case of the CEMP and environment programs in Veolia generally, ISO 14001:2004 and ISO 31000:2009 are used as the base standards when constructing environmental systems for each project. Veolia has an excellent environmental management record of accomplishment and will bring to the project companies and personnel with substantial experience of delivering outstanding environmental performance. The integrated structure is described in Figure 1 below.

9 Page: Page 9 of 50 Figure 1 Integrated Services Management Flowchart Contractor will manage construction works under Abergeldie s Integrated Management System (AIMS). AIMS brings together and cross-references safety management, environmental management and quality management systems, which are all third party certified to ISO and AS/NZS standards. Contractor s environmental obligations for the Project include compliance with applicable environmental legislation and guidelines including Veolia s environmental policies and procedures, and requirements and commitments of the project governance documents outlined in this plan Environmental policies Veolia s business strategy is guided by five elements: our business, our customers, our people, our environment and our community. These elements shape all aspects of Veolia s current and future performance. Its corporate policies and practices are linked to delivering excellence in one or more of these elements. Veolia has developed a suite of company-wide policies in support of the sound management of its facilities. All policies have been endorsed by Veolia s Executive Committee and are reviewed periodically. All Veolia employees are required to commit to the implementation of these policies. Veolia environmental policies support minimisation of emissions to land, air and water and the wise use of natural resources. This commitment is documented in Veolia s environmental and sustainability policies (see below) Environment policy Veolia is committed to minimising the environmental impacts of its operations and continually improving its environmental performance within a framework of sustainable development by: effectively managing our significant environmental impacts, monitoring progress and reviewing environmental performance against objectives and targets on a regular basis driving continual improvement, and meeting the requirements of ISO environmental management systems standard as part of the integrated business management system

10 Page: Page 10 of 50 complying with applicable environmental legislation, contractual and other necessary requirements related to our activities and assist customers and suppliers to use products and services in an environmentally sensitive way striving to ensure that our policies, objectives and achievements are communicated to all persons working for and on behalf of the business and to educate and train employees and ensure competence in environmental issues and the environmental effects of their activities preventing pollution and harm to the natural, heritage and built environments and to reduce the use of all raw materials, energy and supplies consulting with relevant stakeholders, taking into account local environmental conditions and working with local communities to achieve shared and lasting outcomes. All managers, employees, contractors and visitors are responsible for being aware of, and complying with this policy Sustainability policy For Veolia, sustainable development means adopting business strategies and activities that meet the needs of Veolia and its stakeholders today, while protecting, supporting and enhancing the human and natural resources that will be needed in the future. This outcome is expressed clearly in Veolia s Sustainability Policy: Being ethically responsible, to create value in what we do, and to use sound risk and hazard management principles in conducting our business. As part of its non-negotiables Veolia will comply with all relevant legislation including pollution prevention and will strive to develop and improve our integrated business management system to support a consistent and disciplined approach to business processes. We will ensure that appropriate resources (both internally and externally) are utilised to assist in achieving our goals. Partnering in innovation and to understand and support our customers in achieving their business objectives. Attracting and retaining diverse and talented employees. This will include providing development opportunities so our employees are continually learning, communicating, providing workplace consultation, and creating an Always Safe workplace, with an aspiration of no workplace injury or illness for our employees, visitors and contractors. Continually designing and implementing sustainable solutions to develop access to resources and to protect and replenish them. Additionally, Veolia is committed to providing environmental leadership in its operations and solutions, which includes the management of its own environmental impacts, improving waste, water, energy and carbon outcomes, as well as protecting and conserving biodiversity and natural capital. Working closely with local communities to achieve shared and lasting outcomes. Additionally Veolia will engage with government, policy makers, advocacy groups, industry associations and other stakeholders in the areas which we operate to create better value and outcomes in sustainable practices.

11 Page: Page 11 of 50 SECTION 2 STATUTORY AND POLICY CONSIDERATIONS This section provides an overview of the environmental planning and statutory context for the construction of the Project. It also provides a discussion of the Project construction in the context of Veolia s corporate environmental and sustainability policies. Veolia is committed to complying with all of its legal obligations and other voluntary commitments made by the company. Compliance to applicable regulatory requirements concerning the construction of the Project will be achieved through: identifying and accessing legal and other requirements which are directly applicable to the organisation; consulting and involving relevant government agencies; internally communicating relevant information regarding legal and other requirements; continually auditing, reviewing and upgrading company systems, management plans and supporting documentation; and providing relevant training. 2.1 Relevant Environmental Legislation Acts and regulations This CEMP has been developed in the context of the following key NSW legislation: Environmental Planning and Assessment Act 1979 PAC reviewed this State Significant development (SSD 7592) and the two related modifications and granted Development Consent for the State Significant development on 19 June 2017 in accordance section 89(E) of the Environmental Planning and Assessment Act 1979 (EP&A Act). These conditions are required to: prevent, minimise, and/or offset adverse environmental impacts including economic and socials impacts; set standards and performance measures for acceptable environmental performance; require regular monitoring and reporting; provide for the ongoing environmental management of the Project Protection of Environment Operations Act 1997 The main object of the Protection of Environment Operations Act 1997 (POEO Act) is to regulate air, noise, water and land pollution. As well as imposing a general requirement not to cause pollution, the Act also allows pollution to occur through a system of licensing. Both the mines and power station are licenced under the POEO Act. The EIS confirms that the Project will require the modification of existing Environment Protection Licences (EPL) held for the Springvale Mine, Angus Place Colliery and the MPPS. The EPL modifications are required to allow the transfer of mine water to the new WTF and for the transfer and management of residuals and brine to the Springvale Coal Services Site and MPPS. The Springvale Mine EPL will also be required to be modified to amend the timeframes to achieve Mine Water discharge limits for the Springvale Mine (which replicate the modification being sought in relation to the Springvale Mine Extension Planning Approval discussed in the EIS).

12 Page: Page 12 of 50 Consultation has been undertaken with the EPA regarding EPL requirements for the Project and the EPA has confirmed that the EPL is not required for the construction and operation of the Project under Schedule 1 of the POEO Act. As noted above the Project will result in modifications to the existing EPLs of MPPS and mining facilities. (Refer to Appendix C The EPA s with clarification) Water Management Act 2000 The Water Management Act 2000 aims to facilitate the sustainable and efficient use of water in such a way that benefits the environment and communities. The Water Management Act 2000 provides for the preparation of water management plans that outline arrangements for water sharing, water source protection and drainage management. The Proposal site is located within the area covered by the 2010 Metropolitan Water Plan (NSW Office of Water, 2010); the key aims of which are to: provide a secure supply of water to meet the medium-term needs of Sydney, while planning for long-term goals; protect the health of Sydney s rivers; ensure water supplies are adequate throughout drought. The construction of the Project will have a minimal impact on the quality and quantity of water discharged from the Site, and will minimise the demand for potable water at the Site Waste Avoidance and Resource Recovery Act 2001 The Waste and Resource Recovery Act 2001 (WARR Act) is the principal piece of legislation governing waste and resource management in NSW. The Act seeks to maximise the utility of resources including waste, and minimise disposal of resources to landfill. A Waste Management Plan has been prepared in consideration of the objectives of the WARR Act including: encouraging the most efficient use of resources; reducing environmental harm; ensuring that resources are managed against the waste hierarchy of avoidance, resource recovery, and then disposal; diversion of waste from landfill; ensuring industry takes part in reducing and dealing with waste; achieving integrated, state-wide waste and resource management planning and service delivery Contaminated Land and Management Act 1997 The principal object of the Contaminated Land Management Act 1997 (CLM Act) is to establish a process for investigating and, where appropriate, remediating land that the Environmental Protection Authority (EPA) considers to be contaminated significantly enough to require regulation. Under the CLM Act, contamination of land is defined as: the presence in, on or under the land of a substance at a concentration above the concentration at which the substance is normally present in, on or under (respectively) land in the same locality, being a presence that presents a risk of harm to human health or any other aspect of the environment (CLM Act, s5).

13 Page: Page 13 of 50 Land may be considered contaminated even if it became contaminated partly, or entirely, by the migration of contaminants into, onto or under the land from other land. The soil at the WTF site shows elevated levels of some contaminants and further investigations into the site are planned including the installation of groundwater monitoring wells. Based on the results of further investigations the WTF site may require some remediation before construction. A Remediation Action Plan will be developed and implemented if required Roads Act 1993 The objectives of the Roads Act 1993 are to: set out the access rights to public roads; establish procedures for opening and closing public roads; provide for the classification of roads; establish the Roads and Maritime Services and confer functions associated with road works and maintenance to the Roads and Maritime Services and other roads authorities. The Act regulates the carrying out of various activities on public roads. Approval under the Act would be required for any pipeline crossings of public roads and for any temporary modifications to traffic arrangements (eg. lane closures) to allow construction to be undertaken Forestry Act 2012 The main objective of the Forestry Act 2012 is to authorise forestry activities and for the management of Crown timber land and land owned by the Forestry Corporation of NSW. As the pipeline will be partially located on land owned by the Forestry Corporation of NSW, an occupation permit (or a modification to the existing permit) will be required Work Health and Safety Act 2011 The main object of the Work Health and Safety Act 2011 (WHS Act) is to provide for a balanced and nationally consistent framework to secure the health and safety of workers and workplaces by: protecting workers and other persons against harm to their health, safety and welfare through the elimination or minimisation of risks arising from work or from specified types of substances or plant; providing for fair and effective workplace representation, consultation, cooperation and issue resolution in relation to work health and safety; encouraging unions and employer organisations to take a constructive role in promoting improvements in work health and safety practices, and assisting persons conducting businesses or undertakings and workers to achieve a healthier and safer working environment; promoting the provision of advice, information, education and training in relation to work health and safety securing compliance with this Act through effective and appropriate compliance and enforcement measures; ensuring appropriate scrutiny and review of actions taken by persons exercising powers and performing functions under this Act; providing a framework for continuous improvement and progressively higher standards of work health and safety;

14 Page: Page 14 of 50 maintaining and strengthening the national harmonisation of laws relating to work health and safety and to facilitate a consistent national approach to work health and safety in this jurisdiction. The Act requires that workers and other persons should be given the highest level of protection against harm to their health, safety and welfare from hazards and risks arising from work or from specified types of substances or plant as is reasonably practicable Project Specific Applicable Regulatory Requirements An Environmental Impact Statement (EIS) for Project has been prepared by GHD Pty on behalf of Springvale Coal Pty Ltd and NSW EnergyAustralia Pty Ltd to support the development application. The EIS has been prepared using a risk-based assessment approach to identify and evaluate environmental, social and economic aspects associated with the Project. This has been achieved through a process of ongoing engagement with stakeholders from government agencies and the community, risk assessment to identify and scope key environmental assessments of the impacts and development of appropriate safeguards to mitigate any such impacts for the Project. 2.2 Other Requirements Relationship of the CEMP to ISO 14001:2004 As discussed in Section 1.4, this CEMP forms the basis of the EMS for the construction phase of the Project. The CEMP is consistent with ISO 14001:2004 Environmental management systems - Requirements with guidance for use Other Requirements In addition to the requirements discussed above, this CEMP is being developed in accordance with the Guideline for Preparation of Environmental Management Plans (DIPNR, 2004). Other environmental standards, guidelines and documentation are included in the relevant supporting management plans, which are included as appendices to the CEMP.

15 Page: Page 15 of Summary of Licensing and Permit Requirements Table 2 provides a summary of the Licence and Permits that will require, in addition to Development Consent for the Project construction. Legislation/ Guideline Approval/ Licence Table 2 Licencing and Permitting Requirements Assessment Authority Status Responsibility Road Act 1993 (section 138) Approval RMS Approval to construct pipeline across highway reserve Contractor Road Act 1993 (section 183) Consent (Road Occupancy Licence) RMS Contact RMS to determine if the Licence is required. If required, the Licence to be issued prior to works commencing within three (3) metres of the travel lanes in the Castlereagh Highway Contractor Road Act 1993 (section 138) Approval Lithgow City Council Approval to construct pipeline across local road reserve Contractor Road Act 1993 (section 183) Consent (Road Occupancy Permit) Lithgow City Council Permit to be issued prior to works commencing on Wolgan Rd Contractor Crowns Land Act 1989 Approval Lithgow City Council Approval to be issued prior to any groundwater extraction Contractor Forestry Act 2012 (section 60) Occupational Permit Forest Corporation Permit to be issued prior to works commencing within Newnes State Forest Customer Water Management Act 2000 and Water Act 1912 Approval NSW Office of Water Approval to be issued prior construction of pipeline infrastructure within 40m of water source Contractor Inclosed Lands Protection Act 1901 Consent/Lease Agreement Owner of the Land (Janette Winifred Hunt) Consent to assess the land to be issued prior construction of pipeline infrastructure Customer Inclosed Lands Protection Act 1901 Consent/Lease Agreement Owner of the Land (Springvale Centennial) Consent to assess the land to be issued prior construction Customer Inclosed Lands Protection Act 1901 Consent/Lease Agreement Owner of the Land (EnergyAustralia) Consent to assess the land to be issued prior construction Customer 2.4 Conditions of Development Consent Refer to Appendix A for the conditions of the Development Consent for the Project. Conditions of approval relevant to the construction phase have been incorporated within this CEMP. A Pre-Construction Compliance Report (refer to Appendix D) details the relevant conditions of consent addressed in each supporting management plans which address the management and control measures to be implemented in a manner to minimise adverse impacts on the environment during construction phase.

16 Page: Page 16 of 50 Condition 1 and 2 of Schedule 4: Environmental Management and Reporting of the Development Consent provide details regarding the Environmental Management Strategy and Management Plan Requirements for the Project, as outlined in Table 3 below. Relevant Conditions of Consent (Schedule 4) Environmental Management Strategy 1 Table 3 Development Consent Requirements Definition Prior to the commencement of construction, the Applicant must prepare an Environmental Management Strategy for the development to the satisfaction of the Secretary. This strategy must: CEMP Document Reference 1 (a) provide the strategic framework for environmental management of the development Section (b) identify the statutory approvals that apply to the development Section 2 1 (c) 1 (d) 1 (e) describe the role, responsibility, authority and accountability of all key personnel involved in the environmental management of the development describe the procedures that would be implemented to: and include: keep the local community and relevant agencies informed about the operation and environmental performance of the development; receive, handle, respond to, and record complaints; resolve any disputes that may arise; respond to any non-compliance; respond to emergencies copies of any plans approved under the conditions of this consent; and a clear plan depicting all the monitoring to be carried out in relation to the development. Section 4.1 Sections Section 1.3 Section 5 1 Following approval, the Applicant must implement the Environmental Management Strategy Section 1.1 Management Plan Requirements 2 The Applicant must ensure that the management plans required under this consent are prepared in accordance with any relevant guidelines, and include: 2 (a) detailed baseline data Section (b) 2 (c) 2 (d) a description of: the relevant statutory requirements (including any relevant approval, licence or lease conditions); any relevant limits or performance measures/criteria; the specific performance indicators that are proposed to be used to judge the performance of, or guide the implementation of, the development or any management measures a description of the measures that would be implemented to comply with the relevant statutory requirements, limits, or performance measures/criteria a program to monitor and report on the: impacts and environmental performance of the development; effectiveness of any management measures (see c above) Section 2 Section 4.9 Section 4.9 Section 3.5 Section (e) a contingency plan to manage any unpredicted impacts and their consequences Section (f) 2 (g) a program to investigate and implement ways to improve the environmental performance of the development over time a protocol for managing and reporting any: incidents; complaints; non-compliances with statutory requirements; and exceedances of the criteria and/or performance criteria; and Sections 5.2 Section 4.6

17 Page: Page 17 of 50 Relevant Conditions of Consent (Schedule 4) Definition CEMP Document Reference 2 (h) a protocol for periodic review of the plan. Section 5.3 Annual Review 5 5 (a) 5 (b) 5 (c) By the end of March each year, the Applicant must submit a review of the environmental performance of the development for the previous calendar year to the satisfaction of the Secretary. This review must: 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; include a comprehensive review of the monitoring results and complaints records of the development over the past year, which includes a comparison of these results against the: relevant statutory requirements, limits or performance measures/criteria; monitoring results of previous years; and relevant predictions in the EIS. identify any non-compliance over the last year, and describe what actions were (or are being) taken to ensure compliance; Section Section Section 5.3 Sections 5.2&5.4 5 (d) identify any trends in the monitoring data over the life of the development; Section (e) identify any discrepancies between the predicted and actual impacts of the development, and Section (f) analyse the potential cause of any significant discrepancies; and Section (g) Progress Reporting 7 7 (a) 7 (b) 7 (c) 7 (d) describe what measures will be implemented over the next year to improve the environmental performance of the development The applicant must monitor the status of the development and submit a quarterly progress report to the Secretary. The Report must: be submitted within 3 months of 19 June 2017 and every 3 months thereafter until the opration of the Water Treatment Plan; Section 5.3 Section describe the development (including any construction) that was carried in the past 3 months, and development that is proposed to be carried out over next year; Section Identify any poetical delays and describe measures to ensure that the Water Treatment Plan is operational by July 2019: and Section Be made publically available on the Applicant s website; to the satisfaction of the Secretary Section

18 SECTION 3 PROJECT OVERVIEW Page: Page 18 of Project Overview The Project includes the following major elements: A system to transfer (approximately 15 km ) up to 42 ML/day of dewatered mine water from the existing gravity tank forming part of the approved dewatering facilities on the Newnes Plateau to a new WTF to be located at the MPPS site (see Figure 2 below). A WTF incorporates desalinisation processes to reduce the salinity in mine water to a standard suitable for either industrial reuse or environmental release. Transfer of treated water from the water treatment plant to the MPPS cooling water to contribute to the demand for make-up water. Transfer via a new 2.4 km pipeline and discharge of any excess treated water not able to be reused within the MPPS cooling water system to Thompsons Creek Reservoir. Transfer of residual material from the pre-treatment process to the existing reject emplacement area (REA) at the Western Coal Services Site. Installation of a crystalliser to provide further treatment of the additional salt load generated within the MPPS cooling water blowdown system. Figure 2 Project Overview 3.2 Project Location Springvale Mine is underground coal mine located in the western coalfield of NSW, approximately 15 kilometres (km) west of Lithgow. The MPPS located about 8 km west of the Springvale Mine pit top at Lot 363 Boulder Road, Blackmans Flat, NSW (see Figure 3).

19 Page: Page 19 of Property Figure 3 Project Location The remainder of the Project is located within land owned or under access agreements with the Springvale (unincorporated joint venture with participants Centennial Springvale Pty Limited (as to 50%) and Springvale SK Kores Pty Limited (as to 50%)) and land owned by Energy Australia Pty Ltd. Construction of the pipeline for the Project is predominantly located on Springvale owned lands as shown in Figure 4 some section of the pipeline will across land owned by Forestry Corporation of NSW, Crown lands and privately owned property. Approval for access these lands will be obtained subject to compliance of this Plan (Refer to section 2.2). Figure 4 Land Ownership

20 Page: Page 20 of The Project Application Area The Project Application area comprises a number of infrastructure elements primarily including a 10m wide linear pipeline corridor extending between the existing Gravity Tank on Newnes Plateau and the Water Treatment Plant location within the MPPS site. The Project application area is partially situated within the Newnes State Forest, extending from the east on Newnes Plateau to west into lower lying vegetated and disturbed lands. In these portions of the Project application area, connected vegetation occurs for a distance of greater than two kilometres to the north, east and south-east. Being a State Forest in these portions of land, the native vegetation is periodically selectively logged but there are no areas of clear felling of native vegetation. The Newnes State Forest is connected to the Gardens of Stone National Park and Wollemi National Park to the north, Blue Mountains National Park to the east and Ben Bullen State Forest to the northwest. The western half of the Project application area is situated on largely disturbed lands due to existing farming lands, roads, easements and mining lands. Remnant vegetation exists to the south of the pipeline, which tentatively connects to the northern side. Castlereagh Highway creates a wide disconnection between vegetation tracts further north, and that situated to the north of these western portion of the Project application area. The proposed water treatment plant site at MPPS has been extensively cleared and modified for construction of the power station and associated infrastructure. 3.3 Project Phases The implementation of environmental controls for specific risks will be applied through various phases of the Project. Key project phases, where environmental controls and opportunities will be assigned to implementation, are: Pre-construction: planning, design and procurement phases (August 2017 October 2017); Construction: delivery phase of the project, includes vegetation removal and earthworks (October 2017 December 2018). Commissioning: commissioning phase of the project includes testing of all systems and components of industrial plant to according to the operational requirements (January 2019 May 2019); Operation: operational phase of the project includes accepting and treating mine water at the water treatment facility according to the operational requirements (June 2019 June 2034). Post-construction; occurs in sections of the project area which are no longer required for construction activities. At this stage, project areas will be re-instated to their previous condition, including reinstatement of vegetated areas. The Construction period of the Project would be approximately 19 months, commencing in October 2017.

21 Page: Page 21 of Construction Hours The proposed construction activities will be restricted to the construction hours specified in Table 4. Table 4 Construction Operating Hours Activity Day Hours Construction Monday - Friday Saturday Sunday & Public Holidays 7:00am 6:00pm 8:00am 1:00pm At no time 3.5 Predicted Construction Impacts Construction environmental impacts for the project were identified and evaluated in the EIS through reviewing the Project in the context of the existing environmental and operational settings within western coalfields; engagement with government and community stakeholders and through a preliminary environmental risk assessment process. A summary of the key potential environmental impacts that will require management prior to, during and post-construction of the project, are listed below and form the basis of the environmental risk assessment Surface Water Quality Sensitive receptors located in proximity to the Project application area include Wangcol Creek and Coxs River. Erosion and sediment controls will be developed for the both the WTF site and for installation of the WTS in accordance with Managing Urban Stormwater: Soils and construction 4 th edition. The Blue Book. Erosion and sediment controls will be implemented to avoid pollution of waterways and the MPPS stormwater system. To ensure suitable control are addressed during the construction, management strategies for disturbance of soil on site, sedimentation and erosion control measures have been detailed in the Water Management Plan (Refer to Appendix B1) Biodiversity A comprehensive biodiversity assessment was undertaken for Project as part of the EIS, which included survey effort, desktop analysis. The key biodiversity impacts of the project relate to the clearing of vegetation in a 10 m wide linear pipeline corridor extending between the existing Gravity Tank on Newnes Plateau and the WTF. Project will trigger the following direct impacts: removal or modification of up to ha of native vegetation and associated habitat for threatened fauna species with potential to occur in a 10 m wide linear pipeline corridor; removal of approximately 67 hollow bearing trees. The impact assumptions will be confirmed prior to construction through the completion of preclearance surveys to validate offsetting requirements. However, by observing careful construction techniques through the course of Project construction opportunity (i.e. use of pre-clearance surveys and minor route adjustment) exists to avoid impacts on individual threatened plants and hollow-bearing trees. Biodiversity management strategy is described in a Biodiversity Management Plan (Refer to Appendix B2).

22 Page: Page 22 of Aboriginal Cultural Heritage Based on the aboriginal cultural heritage assessment undertaken in the EIS, seven Aboriginal Heritage sites were found in the vicinity of the Project application area. These include three artefact scatters, three isolated finds and one scarred tree site. These are located within 30 meters of the Project application area boundary; however, none is in the Project application area. The project alignment has been modified since the EIS was prepared and now intersects with one of the artefact scatter (AHIMS # ). Where the project alignment intersects with AHIMS # , the Project consists of a subsurface pipeline, approximately 8 metres underground. The pipeline will be constructed with a directional drilling machine that will be launched approximately 300 metres away from the site. AHIMS # will therefore be avoided by the Project. A no go zone will be installed around the site to ensure its protection from potential surface impacts. The significance of these sites is low and no Aboriginal Heritage sites would be impacted by the Project. Nonetheless, details of control measures to minimise potential impact on the aboriginal cultural heritage are outlined in the appended Aboriginal Cultural Heritage Management Plan (Refer to Appendix B3) Noise and Vibration A noise and vibration impact assessment was undertaken in the EIS for the construction phase of the Project associated with construction activities at potentially affected receivers. The noise levels are predicted to meet the Interim Construction Noise Guideline, (DECC, 2009) at all the times and at all identified residential receiver locations. Based on EIS modelling, it is not anticipated that excessive noise impacts will occur at residential receivers throughout the construction program. Any likely exceedance has been identified to be limited to the receivers located along pipeline route subject to short-term elevated noise levels during pipeline trenching and construction. In the event of noise exceedances or complaints received, a review of construction activities, plant and equipment will be undertaken to resolve the issue. Noise management and mitigation measures are outlined in the appended Construction Noise Management Plan (Refer to Appendix B4). No vibration impacts on human comfort and structural damage are expected. Nonetheless, details of control measures to minimise potential vibration impacts are outlined in the appended Construction Noise Management Plan (Refer to Appendix B4) Traffic and Transport An assessment of the traffic and transport impacts was undertaken as part of the EIS for the construction phase of the Project. The Project will generate additional vehicles movements on the Castlereagh Highway, Chifley Road, Newnes State Forest Road and it is considered to have negligible traffic impacts. The Castlereagh Highway is expected to continue to operate within the Roads and Maritime Services recommended operating performance standards.

23 Page: Page 23 of 50 A risk assessment will be undertaken for the site to identify the potential traffic hazards by the Contractor at the commencement construction works, and any changes required to the management strategies will be reported. The risk assessment will be updated as required during the construction works. Traffic management strategies outlined in the appended Construction Traffic Management Plan (refer Appendix B5) Other Environmental Impacts Soils and Contamination The Project construction includes boring, pipeline trenching and clearing, regrading and building infrastructure for the WTF and WTS. The WTF application area contains significant amount of fill (mine overburden). Jacobs was commissioned by Veolia to undertake a Baseline Contaminated Site Investigation (BCSI) for portions of land to be occupied by the WTF and the WTS associated with the Project in August The objective of the BCSI was to assist Veolia in obtaining sufficient information to assess baseline soil and groundwater contamination conditions of the site (comprising the WTF and the WTS) to support both the lease agreement and ongoing environmental monitoring requirements during operation of the WTF and WTS. The BSCI assumed that the WTF sites will be considered a commercial industrial land use. For the WTS there would a variety of different land uses from commercial/industrial in the coal services areas and to natural land uses in the Newnes State Forest. Based on the results of the fieldwork program, site observations and results of the laboratory analysis, contamination was not identified in soils beneath the WTF or the WTS that would impact upon construction and/or operation of the project in consideration of a commercial / industrial land use. Based on the results of the BCSI, the risk of existing significant contamination being present at the WTF site areas that will be disturbed by construction and operations of the facility is considered to be low. Should surplus material be generated during construction of the project and requires off-site disposal, this material will be classed the NSW Waste Classification Guidelines (EPA, 2014) and disposed to a licensed facility. Groundwater beneath the WTF sites contains elevated concentrations (i.e. concentrations above the site acceptance criteria) of some heavy metals and hydrocarbon compounds. This is likely to be from groundwater coming in contact with overburden material containing remnants of coal, however, this can not be conclusively determined. At the time of the BSCI, groundwater was only encountered in two groundwater wells (7 wells installed) to the limit of the investigation (approximately 10m bgl). These wells were located in the northern most portion of the WTF within the operational areas of the MPPS and therefore dewater in unlikely to be required. However if groundwater levels increase and dewatering of groundwater is required to facilitate construction, this water will need to be managed to prevent discharge and impacts to the fresh water ecosystems of the Coxs River and associated tributaries (Wangcol Creek and Sawyers Swamp Creek). Prior to any discharge of water (if encountered) during construction, water quality investigations be undertaken to quantify actual risks (if present) to receptors and to assist in the selection of appropriate disposal options. In addition, the disturbed areas during construction phase will be progressively rehabilitated except those areas where permanent access roads are being established.

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