Independent Environmental Compliance Audit Report

Independent Environmental Compliance Audit - Drayton Coal - Project Approval 06_0202 and Development Application 106-04-00

October 2012

Anglo American (Drayton Management) Pty Ltd

Parsons Brinckerhoff Australia Pty Limited ABN 80 078 004 798

Level 3 51–55 Bolton Street Newcastle NSW 2300 PO Box 1162 Newcastle NSW 2300 Australia Telephone +61 2 4929 8300 Facsimile +61 2 4929 8382 Email [email protected]

Certified to ISO 9001, ISO 14001, AS/NZS 4801 A+ GRI Rating: Sustainability Report 2010 2172813A/PR_0665

2172813A/PR_0665

Revision Details Date Amended By

00 Draft 30 November 2012 Jeremy Arnott

01 Finalised version 4 January 2013 Jeremy Arnott

©Parsons Brinckerhoff Australia Pty Limited [2013].

Copyright in the drawings, information and data recorded in this document (the information) is the property of Parsons Brinckerhoff. This document and the information are solely for the use of the authorised recipient and this document may not be used, copied or reproduced in whole or part for any purpose other than that for which it was supplied by Parsons Brinckerhoff. Parsons Brinckerhoff makes no representation, undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document or the information.

Authors: Jeremy Arnott, Hugh Madden ........................................................

Signed: ........................................................................................................

Reviewer: Derek Low ......................................................................................

Signed: ........................................................................................................

Approved by: Jeremy Arnott .................................................................................

Signed: ........................................................................................................

Date: 4 January 2013...............................................................................

Distribution: Anglo American (Drayton Management) Pty Ltd, Parsons Brinckerhoff

Please note that when viewed electronically this document may contain pages that have been intentionally left blank. These blank pages may occur because in consideration of the environment and for your convenience, this document has been set up so that it can be printed correctly in double-sided format.

Independent Environmental Compliance Audit - Drayton Coal - Project Approval

06_0202 and Development Application 106-04-00

PARSONS BRINCKERHOFF 2172813A/PR_0665 Page i

Contents Page number

Audit certificate v

Glossary and acronyms vii

1. Introduction 1

1.1 Drayton Mine 1

1.1.1 Project Approval 06_0202 1 1.2 Drayton Rail Loop and Antiene Rail Spur 2

1.2.1 Development Application 106-04-00 3 1.3 Structure of this audit report 3

2. Audit process 5

2.1 Audit scope and methodology 5

2.2 Audit team 8

2.3 Audit overview 8

2.4 Site interviews and inspections 8

2.4.1 Opening meeting 8 2.4.2 Audit interviews 9 2.4.3 Data collection and verification 9 2.4.4 Site inspection 10 2.4.5 Closing meeting 10

2.5 Agency consultation 10

2.6 Reporting 11

2.7 Definitions 11

3. Agency consultation 13

3.1.1 Department of Planning & Infrastructure 13 3.1.2 Office of Environment & Heritage 13 3.1.3 Department of Trade & Investment, Regional Infrastructure and Services 13 3.1.4 Office of Water 14 3.1.5 Muswellbrook Shire Council 14

4. Compliance with PA 06_0202 15

4.1 Condition 1, Schedule 3 – Noise Impact Assessment Criteria 15

4.1.1 Recommendation 16 4.2 Condition 3, Schedule 3 – Cumulative Noise Criteria 16

4.2.1 Recommendation 16 4.3 Condition 9, Schedule 3 – Airblast Overpressure Criteria 16

4.3.1 Recommendation 16



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4.4 Condition 16, Schedule 3 – Public Notice 17

4.4.1 Recommendation 17 4.5 Condition 27, Schedule 3 – Surface Water Discharges 17

4.5.1 Recommendation 17 4.6 Condition 30, Schedule 3 – Erosion and Sediment Control 18

4.6.1 Recommendation 18 4.7 Condition 35, Schedule 3 – Offset Strategy 19

4.7.1 Recommendation 19 4.8 Condition 39, Schedule 3 – Rehabilitation and Offset Management Plan 20

4.8.1 Recommendation 20 4.9 Condition 40, Schedule 3 – Final Void Management 20

4.9.1 Recommendation 21 4.10 Condition 41, Schedule 3 – Mine Closure Plan 22

4.10.1 Recommendation 22 4.11 Condition 44, Schedule 3 – Monitoring of Coal Transport 22

4.11.1 Recommendation 22 4.12 Condition 3, Schedule 4 – Independent Review 22

4.12.1 Recommendation 23 4.13 Condition 5, Schedule 5 – Annual Reporting 23

4.13.1 Recommendation 24 4.14 Condition 10, Schedule 5 – Access to Information 24


5. Compliance with DA 106-04-00 25

5.1 Condition 2.1, Schedule 2 – Environmental Coordinator 25

5.1.1 Recommendation 25 5.2 Condition 2.2, Schedule 2 – Environmental Management Strategies and Plans 25

5.2.1 Recommendation 26 5.3 Condition 3.1, Schedule 2 – Surface & Ground Water Management and Monitoring 27

5.3.1 Recommendation 27 5.4 Condition 5.1, Schedule 2 – Air Quality Management and Monitoring 27

5.4.1 Recommendation 27 5.5 Condition 5.3.1, Schedule 2 – Noise Levels 27

5.5.1 Recommendation 28 5.6 Condition 7, Schedule 2 – Monitoring/Auditing 28


6. Evaluation of environmental management plans 29

6.1 Noise Management Plan and Blast Management Plan 30

6.1.1 Opportunities for improvement 30 6.2 Spontaneous Combustion Management Plan 31

6.2.1 Opportunities for improvement 33 6.3 Air quality management 34



PARSONS BRINCKERHOFF 2172813A/PR_0665 Page iii

6.3.1 Air monitoring locations 34 6.3.2 Air Quality Management Plan 36 6.3.3 Opportunities for improvement 39

6.4 Water Management Plan 40

6.4.1 Opportunities for improvement 40 6.5 Landscape Management Plan 41

6.5.1 Opportunities for improvement 42 6.6 Aboriginal Cultural Heritage Management Plan 43

6.6.1 Opportunities for improvement 43 6.7 Greenhouse and Energy Efficiency Plan 43

6.7.1 Opportunities for improvement 43 6.8 Environmental Management Strategy 44

6.8.1 Opportunities for improvement 44

7. Environmental performance 45

7.1 Assessment against predictions made in relevant environmental assessments and associated documentation 45

7.1.1 Mine Extension Environmental Assessment (2007) 45 7.1.2 Antiene Joint User Rail Facility Environmental Impact Statement (2000) 49 7.1.3 Project Approval Modification Environmental Assessment (Modification 1) 50 7.1.4 East Pit Tailings Emplacement & Explosive Storage Facility Environmental

Assessment (Modification 2) 51 7.1.5 Project Approval 06_0202 - Statement of Commitments 51

7.2 Site inspection 52

7.2.1 Key observations and compliance issues 53 7.2.2 Recommendations 55

7.3 Environment Protection Licence (No. 1323) 55

7.3.1 Non-compliances reported during audit period 55 7.4 Annual Environmental Management Reports 56

7.4.1 2009 Annual Environmental Management Report 56 7.4.2 2010 Annual Environmental Management Report 58 7.4.3 2011 Annual Environmental Management Report 59 7.4.4 Critical review of Drayton Coal’s Annual Environmental Management Reports 60

7.5 Mining Lease 1531 61

7.6 Coal Lease 229 62

8. Summary of audit findings 63

9. References 77

List of tables Page number

Table 2.1 Required audit methodology 5 Table 2.2 Opening meeting attendees 9



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Table 2.3 Audit interviews 9 Table 2.4 Closing meeting attendees 10 Table 7.1 Mine Extension Environmental Assessment (2007) assessment of predicted impacts 45 Table 7.2 Antiene Joint User Rail Facility Environmental Impact Statement (2000) assessment of

predicted impacts 49 Table 7.2 Performance (via exception) against the Statement of Commitments 52 Table 8.1 Summary of audit findings 63 Table 8.2 Summary of recommendations for improvements 71

Appendices Appendix 1 PA 06_0202 checklist Appendix 2 DA 106-04-00 checklist Appendix 3 Audit documents Appendix 4 Site photographs Appendix 5 Agency consultation log Appendix 6 Audit team curriculum vitae



PARSONS BRINCKERHOFF 2172813A/PR_0665 Page v

Audit certificate This is to certify:

Parsons Brinckerhoff Australia Pty Ltd (the Auditor) has prepared the accompanying ‘Independent Environmental Compliance Audit - Drayton Coal - Project Approval 06_0202 and Development Application 106-04-00’ Audit Report, 4 January 2013 (the Report) from certain information provided by Anglo American (Drayton Management) Pty Ltd (the Auditee) at the request of and exclusively for the use and benefit of the Auditee. A draft report was supplied to the Auditee on 30 November 2012.

This report has been prepared in accordance with the scope of work/services set out in a contract, or as otherwise agreed, between the Auditor and the Auditee. In preparing this report, the Auditor has relied upon data, surveys, analyses, designs, plans and other information provided by the Auditee and other individuals and organisations, most of which are referred to in the report (the data). Except as otherwise stated in the report, the Auditor has not verified the accuracy or completeness of the data. To the extent that the statements, opinions, facts, information, conclusions and/or recommendations in this report (conclusions) are based in whole or part on the data, those conclusions are contingent upon the accuracy and completeness of the data. The Auditor will not be liable in relation to incorrect conclusions should any data, information or condition be incorrect or have been concealed, withheld, misrepresented or otherwise not fully disclosed to the Auditor.

This report has been prepared for the exclusive benefit of the Auditee and no other party. The Auditor assumes no responsibility and will not be liable to any other person or organisation for or in relation to any matter dealt with in this report, or for any loss or damage suffered by any other person or organisation arising from matters dealt with or conclusions expressed in this report (including without limitation matters arising from any negligent act or omission of the Auditor or for any loss or damage suffered by any other party relying upon the matters dealt with or conclusions expressed in this report). Other parties should not rely upon the report or the accuracy or completeness of any conclusions and should make their own inquiries and obtain independent advice in relation to such matters.

The Audit has examined the Auditee’s compliance with Project Approval (from Section 75J of the Environmental Planning & Assessment Act 1979) 06_0202 and Development Application 106-04-00 for the period from 22 October 2009 to 28 October 2012. The Auditor has relied on information provided by the Auditee. The Auditor expresses no opinion as to the accuracy, truth, sufficiency or legality of the information provided by the Auditee in respect of the Auditee’s compliance standards.

This Report has been prepared in accordance with generally accepted practices (including the standards set out in ISO AS/NZS 19011:2002 Guidelines for quality and/or environmental management systems auditing) using standards of care and diligence normally practiced by recognised consulting firms performing services of a similar nature.

The Audit Lead (Jeremy Arnott) is a certified Lead Auditor in the Environmental Scheme by RABQSA International (Certificate No: 112595). The Audit Team Member (Hugh Madden) is a certified Principal Auditor in the Environmental Scheme by RABQSA International (Certificate No: 14761). These qualifications satisfy the requirements of section 7.4 (Education, work experience, auditor training and audit experience) of ISO 19011:2002 Guidelines for quality and/or environmental management systems auditing.

To the best of the Auditor’s knowledge, the facts and matters described in this report reasonably represent the conditions at the time of printing of the report. However, the passage of time, the manifestation of latent conditions or the impact of future events (including a change in applicable law) may result in a variation to the conditions. The Auditor will not be liable to update or revise the



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report to take into account any events or emergent circumstances or facts occurring or becoming apparent after the date of the report.

This Report is issued with the understanding that it is the responsibility of the Auditee to ensure that the information contained herein is brought to the attention of the appropriate regulatory agencies, where required by law. Additionally, it is the sole responsibility of the Auditee to properly rectify any findings from the audit that indicate that relevant laws or regulations have been or may be breached.

Neither the Auditor nor any member associate or employee of the Auditor undertakes any responsibility for any injury, loss or damage claimed by the Auditee arising out of a claim by any third party against the Auditee in connection with this Report.



PARSONS BRINCKERHOFF 2172813A/PR_0665 Page vii

Glossary and acronyms AEMR Annual Environmental Management Report

ACHP Aboriginal Cultural Heritage Plan

Antiene EIS Antiene Joint User Rail Facility Environmental Impact Statement (Umwelt, 2000)

Approval Project Approval 06_0202

ARL Action response level

ARTC Australian Rail and Track Corporation

AQMP Air Quality Management Plan

BMP Blast Management and Monitoring Plan

C Compliant

CCC Community Consultative Committee

Consent Development Application 106-04-00

CSIRO Commonwealth Scientific and Industrial Research Organisation

DA Development Application

DECCW NSW Department of Environment, Climate Change and Water

DPI NSW Department of Planning & Infrastructure

Drayton Coal Anglo American (Drayton Management) Pty Ltd

DTIRIS NSW Department of Trade & Investment, Regional Infrastructure and Services

EA Environmental Assessment EMS Environmental Management Strategy

EPA New South Wales Environment Protection Authority

EPL Environment Protection Licence

ESCP Erosion and Sediment Control Plan

FVMP Final Void Management Plan

GEEP Greenhouse and Energy Efficiency Plan

GMP Groundwater Monitoring Plan

HVAS High volume air samplers

LGA Local Government Area

LMP Landscape Management Plan

MCP Mine Closure Plan

MDG Mining Design Guideline

MIA Mining Infrastructure Area

ML Megalitre

MOP Mining Operations Plan

MSC Muswellbrook Shire Council

Mtpa Million tonnes per annum

N/A Not Applicable

N/C Non-compliant

NMP Noise Management Plan

NOW NSW Officer of Water

OCE Open Cut Examiner OEH NSW Office of Environment and Heritage

PA Project Approval



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CHPP Coal Handling and Preparation Plant

RMS Roads and Maritime Services

ROM Run of mine

ROMP Rehabilitation and Offset Management Plan

SCMP Spontaneous Combustion Management Plan

SGWRP Surface and Ground Water Response Plan

SHE Safety, Health and Environment

SMP Spontaneous Management Plan

SOC Statement of Commitments

SWMMP Surface Water Management and Monitoring Plan

TEOM Tapered Element Oscillating Microbalance

TSP Total suspended particles

TSS Total suspended solids

WMP Water Management Plan



PARSONS BRINCKERHOFF 2172813A/PR_0665 Page 1

1. Introduction Anglo American (Drayton Management) Pty Ltd (Drayton Coal) commissioned Parsons Brinckerhoff Australia Pty Ltd to conduct an independent environmental compliance audit of the Drayton Mine and Antiene Rail Spur.

The audit was conducted under the direction of the NSW Department of Planning and Infrastructure (DPI) in accordance with the current project approval for the Drayton Mine (PA 06_0202, the approval) and the development application for the Drayton Rail Loop and Antiene Rail Spur (DA 106-04-00, the consent).

1.1 Drayton Mine

Drayton Coal mine (the Project) is an open cut mine located between Muswellbrook and Singleton in the Hunter Valley, New South Wales.

Drayton Coal is wholly owned by Anglo American and joint venture partners NCE Australia, Mitsui Coal Holdings, Daesung Australia and Hyundai Australia. The mine is managed by Anglo American.

Drayton Coal mine, operating since 1983, currently produces approximately five million tonnes of thermal coal annually.

1.1.1 Project Approval 06_0202

Condition 6, Schedule 5 of the approval requires an independent environmental audit of the Drayton Mine to be undertaken within two years of the approval (February 2010) and every three years thereafter (or as otherwise directed by DPI).

Specifically, Condition 6, Schedule 5 requires the audit to:

a) be conducted by a suitably qualified, experienced, and independent team of experts whose appointment has been endorsed by the Director-General;

b) assess the environmental performance of the project, and its effects on the surrounding environment;

c) assess whether the project is complying with the relevant standards, performance measures, and statutory requirements;

d) review the adequacy of any strategy/plan/program required under this approval; and, if necessary,

e) recommend measures or actions to improve the environmental performance of the project, and/or any strategy/plan/program required under this approval.

DPI was consulted by Drayton Coal prior to the audit and the following additional requirements were specified by the Department:

The audit team should include a spontaneous combustion specialist who can review Drayton Coal’s Spontaneous Combustion Management Plan and recommend improvements in Drayton Coal’s spontaneous combustion management.



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The audit team should include a rehabilitation specialist who can review Drayton Coal’s Rehabilitation and Offset Management Plan and recommend improvements in Drayton Coal’s rehabilitation management.

The audit team should include an air quality specialist who can review Drayton Coal’s Air Quality Management Plan and recommend improvements in Drayton Coal’s dust management.

DPI also supplied a required audit methodology which is addressed in Section 2.1.

Drayton Coal also contacted other relevant agencies prior to the audit. Agencies included:

NSW Office of Environment and Heritage (OEH).

NSW Department of Trade and Investment, Regional Infrastructure and Services (DTIRIS).

NSW Office of Water (NOW).

Muswellbrook Shire Council (MSC).

Of the abovementioned groups, only DTIRIS and NOW provided responses:

NOW requested that the audit assess the nature and metering of the licensable taking of water in the mining operation.

DTIRIS requested that the audit address:

Management and performance in accordance with the required Spontaneous Combustion Management Plan.

Management and rehabilitation performance of Drayton's biodiversity offset areas.

DTIRIS’ additional requirements are consistent with DPI’s requirements.

1.2 Drayton Rail Loop and Antiene Rail Spur

Drayton Coal Pty Ltd and Mt Arthur Coal developed the Antiene Joint User Rail Facility, located on the northern boundary of the Drayton Mine.

The facility incorporates the existing Antiene Rail Spur, Drayton Rail Loading Facility and a Rail Loading Facility for Mt Arthur Coal. The facility is used to transport coal from the Drayton and Mt Arthur mines.

The Drayton Rail Loading Facility and Antiene Rail Spur are wholly owned by Drayton Coal. The Antiene Joint User Rail Facility provides Drayton Coal with the capacity to transport up to 7 megatonnes per annum (Mtpa) of coal from the loop, and use the Antiene Rail Spur up to a limit of 20 Mtpa (although Mt Arthur Coal’s equivalent consent regarding use of the spur has since been suspended).




1.2.1 Development Application 106-04-00

Development Application 106-04-00 (the Drayton Rail Loop and Antiene Rail Spur approval) applies to the operation of rail loading and transport operations at the Antiene and Drayton rail lines.

Condition 7.1, Schedule 2 of the consent requires an independent environmental audit of the Drayton Rail loop operation and Antiene rail spur to be undertaken every three years thereafter (or as otherwise directed by DPI).

Specifically, Condition 7.1, Schedule 2 requires the audit to:

a) assess compliance with the requirements of the consent, licences and approvals

b) assess the development against the predictions made in the EIS

c) review the effectiveness of the environmental management of the coal transportation operations, including any mitigation works;

d) be carried out at the Applicant’s expense

e) be conducted by a duly qualified independent person or team approved by the Director-General in consultation with Muswellbrook Shire Council (MSC).

1.3 Structure of this audit report

This report contains the following sections:

Section 1: Introduction – An overview of the Drayton Mine and the background to this audit.

Section 2: Audit process – A detailed description of the audit process and scope.

Section 3: Agency consultation – An overview of the outcomes from consultation with relevant agencies during the audit.

Section 4: Audit findings – An overview of the findings of the audit for PA 06_0202, including detailed descriptions of any non-compliance identified.

Section 5: Audit findings – An overview of the findings of the audit for DA 106-04-00, including detailed descriptions of any non-compliance identified.

Section 6: Evaluation of management plans – A critical review of the environmental management plans required under the approval.

Section 7: Environmental performance – A discussion of observations made during the audit and site inspections relating to the environmental performance of Drayton Coal. This includes a review of the environmental protection licences, statement of commitments, predictions made in the relevant environmental assessments, mining leases and the annual environmental management reports.

Section 8: Summary of audit findings – A summary of all non-compliances and opportunities for improvement with their associated recommendations for improvement.




Section 9: References – A list of applicable literature referenced during the review of the environmental management plans.

Appendix 1: PA 06_0202 checklist – A detailed checklist of PA 06_0202 which reviews each compliance condition applicable to the project.

Appendix 2: DA 106-04-00 checklist – A detailed checklist of DA 106-04-00 which reviews each compliance condition applicable to the project.

Appendix 3: Audit documents – A list of the documents obtained from Drayton Coal for the purposes of this audit.

Appendix 4: Site photographs – Photographs of key site features referred to in this report.

Appendix 5: Agency consultation log – A register of agency consultation undertaken as part of the audit.

Appendix 6: Audit team curriculum vitae – Provision of relevant skills and experience of the audit team (refer to Section 2.2).




2. Audit process

2.1 Audit scope and methodology

The audit was undertaken according to AS/NZS ISO 19011:2003 – Guidelines for Quality and/or Environmental Management Systems Auditing in order to meet the requirements outlined in Condition 8, Schedule 5 of the approval (refer to Section 1.1.1 and 1.2.1) and the additional requirements provided by DPI and other agencies.

The audit was conducted in accordance with the required methodology as provided to Drayton Coal on 2 October 2012. Table 2.1 provides a summary of the required methodology and references to the section of the report where each component is addressed.

Table 2.1 Required audit methodology

Required assessment How it was assessed Reference

Conditions of consent

“All conditions of consent are to be audited”

All conditions from PA 06_0202 and DA 106-04-00 were addressed in the audit interview

Refer Appendices 1 and 2 for responses to all requirements. Refer to Sections 4 and 5 for a summary of non-compliant findings. Refer to Section 8 for a summary of all audit findings.

“The condition numbers must be included in the report”

All conditions are numbered. Refer Appendices 1 and 2 for responses to all requirements. Refer to Sections 4 and 5 for a summary of non-compliant findings. Refer to Section 8 for a summary of all audit findings.

“The audit must be sequential (.e.g. all development consent requirements, then EPL, then Mining Lease)”

Sections 4 and 5 address approval and consent conditions. Section 6 addresses environmental management plans. Section 7 addresses environmental performance (site inspection, performance against environmental assessments, EPL, AMER, statement of commitments, mining lease). Section 8 provides a summary of findings.

Refer to Sections 4-8.

Management plans

“The commitments in management plans have been implemented”

Section 6 addresses environmental management plans.

Refer to Section 6.





Requirements of other relevant environmental legislation (where specified by consent)

“Environmental Protection Licence conditions”

Section 7 addresses environmental performance (site inspection, performance against environmental assessments, EPL, AEMR, statement of commitments, mining lease).

Refer to Section 7.

“Environmental aspects of the Mining Lease”


Refer to Section 7.

EA/EIS or SEE predictions and commitments

“This will include but not be limited to items such as mining phase, dump heights, landform, noise attenuation etc.”


Refer to Section 7.

Statement/s of commitments

“The commitments made have been implemented/complied with”


Refer to Section 7.

Monitoring results and trends

“Including against regulatory limits and EA/EIS/SEE predictions”

It was determined that the approval and consent limits match environmental assessment predictions; therefore these were addressed in the assessment of the conditions.


Community complaints

“Community complaints should be reviewed for any trends”

Review of complaints was undertaken as part of the assessment for the annual reporting.

Refer to Section 7.

“Identifying the source of an established trend”

See above. See above.

“Is additional monitoring required for identified trends”






Regulatory action

“Including any letters, penalty notice prosecutions etc.”

It was determined that this is a requirement under the project approval; therefore this was addressed in the assessment of the conditions.


“What was the outcome of the action?”


“What was committed to following the regulatory action? Was it completed?”


“Are recommendations required to prevent recurrence?”


Annual reviews

“Annual reviews are to be reviewed to provide the author with information as a basis for recommendation regarding ongoing environmental improvement.”

Annual reviews are assessed as part of the assessment of approval conditions.

Refer Appendices 1 and 2 for responses to all requirements.

“As far as possible the audit should verify the validity of the annual review”


Any other specific matter raised by relevant agencies or the Department

“Ensure that all specific matters raised by relevant agencies or the Department are addressed.”

Specific requirements raised by the DPI and other relevant agencies were addressed in this report.

Refer to Sections 1.1.1 and 3.

Improvement opportunities

“Including opportunities to improve the environmental performance of the mine”

Recommendations accompany all non-compliant findings, issues relating to the environmental management plans and concerns raised during the site inspection.

Refer to Section 8.

“Opportunities to improve or update any strategy, plan or program required under the consent. This includes any suggestions to improve management plans.”


The audit covered the period 22 October 2009 to 28 October 2012. The site component of the audit was undertaken between 29 and 31 October 2012. The offsite component was completed on 16 November 2012.




2.2 Audit team

The audit was undertaken by the following Parsons Brinckerhoff staff (refer to Appendix 6 for curricula vitae):

Jeremy Arnott, Environment Scientist (Certified RABQSA Lead Environmental Auditor No. 112595). Jeremy was the lead auditor.

Hugh Madden, Principal Environment Scientist (Certified RABQSA Principal Environmental Auditor No. 14761). Hugh was an auditor.

Justine Firth, Environmental Scientist. Justine was a technical advisor and provided expertise in the field of air quality management.

Dr Basil Beamish, Director of B3 Mining Services. Basil was a technical advisor and provided expertise in the field of spontaneous combustion management.

Michael Frankcombe, Principal Environment Scientist at Landloch. Michael was a technical advisor and provided expertise in the field of rehabilitation management.

Steven Walker, Senior Environmental Acoustician. Steve was a technical advisor and provided expertise in the field of noise management.

Derek Low, Principal Advisor, Environment. Derek was responsible for peer review of the audit report.

2.3 Audit overview

The audit process involved:

Auditee consultation with relevant government agencies.

Interviews with site personnel.

Detailed reviews of relevant documentation and samples of records provided by Drayton Coal.

A detailed site inspection.

The following sections describe these processes in more detail.

2.4 Site interviews and inspections

The on-site component of the audit was undertaken between 29 and 31 October 2012.

2.4.1 Opening meeting

An opening meeting was held at Drayton Coal offices, commencing at 9.00 am on 29 October 2012. The participants of this meeting and their role are listed in Table 2.2.




Table 2.2 Opening meeting attendees

Staff Organisation Title

Clarence Robertson Drayton Coal General Manager

Scott Doran Drayton Coal Coal Handling & Processing Manager

Shawn Geary Drayton Coal Technical Services Manager

Chris Gardner Drayton Coal Engineering & Maintenance Manager

Peter Forbes Drayton Coal Safety, Health and Environment Manager

James Benson Drayton Coal Environmental Coordinator

Brooke Lavis Drayton Coal Environmental Officer

Morgan Yeatman Drayton Coal Environmental Graduate

Jeremy Arnott Lead Auditor (Parsons Brinckerhoff)

Environmental Scientist

Hugh Madden Audit Team Member (Parsons Brinckerhoff)

Principal Environmental Scientist

The purpose of the opening meeting was to introduce the audit team, discuss the scope of the audit and the audit process. The methods to be used by the team to conduct the audit were explained. It was stated that the audit team would be interviewing personnel, evaluating site management plans, examining records and conducting a site inspection in order to address specific compliance requirements.

2.4.2 Audit interviews

Audit interviews were conducted by the audit team during the on-site component of the audit between 29 and 30 October 2012. Table 2.3 describes staff with operational roles associated with Drayton Coal who were interviewed for the audit.

Table 2.3 Audit interviews



Brooke Lavis Drayton Coal Environmental Officer


2.4.3 Data collection and verification

A number of documents were provided to the audit team prior to the on-site component of the audit. Several documents were also provided following the site audit. Where possible, documents and data collected during the audit were reviewed on site.

All information obtained during the audit was verified where possible. For example, statements made by on-site staff were verified by reviewing relevant documentation and/or undertaking site inspections.

Any instances where suitable verification could not be ascertained have been outlined in the detailed audit findings (refer to Sections 4-5 and Appendices 1-2).

A list of documents reviewed and/or evaluated during this audit is provided in Appendix 3.




2.4.4 Site inspection

A detailed site inspection was undertaken on 30 and 31 October by the audit team (including Michael Francombe, Justine Firth and Basil Beamish), who were accompanied by James Benson (Environmental Coordinator), Brooke Lavis (Environmental Officer) and Morgan Yeatman (Environmental Graduate).

The site inspection was restricted to the areas within the boundary of the Project Approval; however selected sites (e.g. monitoring locations) to the north of the boundary were inspected where relevant.

Appendix 4 provides photographs taken during the site inspection.

2.4.5 Closing meeting

A closing meeting was held at Drayton Coal offices, commencing at 3.30 pm on 31 October 2012. The participants of the closing meeting are listed in Table 2.4.

Table 2.4 Closing meeting attendees


Clarence Robertson Drayton Coal General Manager

Scott Doran Drayton Coal Coal Handling & Processing Manager

Shawn Geary Drayton Coal Technical Services Manager

Peter Forbes Drayton Coal Safety, Health and Environment Manager



Jeremy Arnott Lead Auditor (Parsons Brinckerhoff)

Environmental Scientist

During the closing meeting, a brief overview of key audit findings was given followed by a discussion of any issues raised. The Audit Team also thanked the relevant personnel for their time and cooperation throughout the site component of the audit.

2.5 Agency consultation

Prior to the audit, Drayton Coal contacted NSW government agency staff with a regulatory role relating to Drayton Coal and Muswellbrook Shire Council. As described in Section 1.1.1, only the DPI, DTIRIS and NOW provided responses.

After the site component of the audit, the Audit Team contacted the following NSW government agency staff:

Scott Brooks (Team Leader Compliance) of DPI on 31 October 2012.

Greg Summerhayes (A/Manager Environment Operations, Environmental Sustainability Unit Mineral Resources) of DTIRIS on 22 November 2012.

A log of agency consultation is provided in Appendix 5.

The outcomes of the agency interviews are discussed in Section 3.




2.6 Reporting

Following completion of the site component of the audit, the PA 06_0202 and DA 106-04-00 compliance checklists were completed (refer to Appendices 1 and 2) and audit notes were reviewed in order to confirm any compliance matters to be noted in the audit report.

As a result of completion of the checklist, this report was prepared to provide an overview of any compliance issues and any other observations made by the auditors during the audit. This report has been prepared on an exception basis, highlighting any areas where action or improvements are required or recommended.

2.7 Definitions

The categorisation of results from the audit was based on the following definitions:

Compliant (C) – The intent and all specific requirements of the condition have been met.

Non-compliant (N/C) – The intent or one or more specific requirements of the condition have not been met.

Not Applicable (N/A) – A condition or requirement has an activation or timing requirement that had not been sufficiently triggered at the time of the audit, therefore a determination of compliance could not be made.




3. Agency consultation As discussed in Section 2.5, phone interviews and meetings were conducted with key government agencies with a regulatory role relating to environmental management at Drayton Coal. Overall, the agencies provided few comments relating to the project. The following sections outline the responses received from these agencies.

3.1.1 Department of Planning & Infrastructure

A meeting was held with Scott Brooks (Team Leader Compliance) of DPI, on 31 October 2012 at his Singleton office. The purpose of the meeting was to discuss the audit and to confirm the content of the audit report.

The following outcomes were reached during the meeting:

Drayton Coal’s overall performance during the audit was discussed and although the audit identified a number of minor concerns (refer to Section 7.2), no major issues requiring the immediate attention of the DPI were found.

Drayton Coal had submitted a number of environmental management plans to the DPI for review on 31 October 2012 (the last day of the site audit and the day of the meeting with DPI). It was agreed that the audit would assess the adequacy of these plans as opposed to Drayton Coal’s respective existing pre-revision plans. This would allow Drayton Coal to revise these plans in accordance with the findings of this audit and resubmit the plans at a later date. DPI subsequently approved an extension of the submission date to 29 March 2013.

The intended content of the audit was discussed with DPI and no issues were raised.

A phone conversation was also held with Scott Brooks of DPI on 22 November 2012. The purpose of this conversation was to discuss the replacement of Dr Martin Predavec with Derek Low as the approved reviewer for the audit report. It was discussed that Martin was no longer available to provide a review of the audit in a suitable timeframe and that Derek was appropriately qualified to undertake the quality review. DPI approved the replacement.

3.1.2 Office of Environment & Heritage

Drayton Coal contacted the OEH prior to the audit. No further comment or instruction was provided.

3.1.3 Department of Trade & Investment, Regional Infrastructure and Services

Drayton Coal contacted DTIRIS prior to the audit. As stated in Section 1.1.1, DTIRIS requested that the audit address:

Management and performance in accordance with the required Spontaneous Combustion Management Plan.

Management and rehabilitation performance of Drayton's biodiversity offset areas.

DTIRIS’ additional requirements are consistent with DPI’s requirements.




A phone interview was also conducted with Greg Summerhayes (A/Manager Environment Operations, Environmental Sustainability Unit Mineral Resources) of DTIRIS on 22 November 2012. The purpose of the interview was to discuss the outcomes of the audit with respect to the additional requirements originally put forward by DTIRIS and to discuss any issues relating to statutory compliance at Drayton Coal.

Greg raised an enquiry regarding the extent of mining within the approval boundary. It was reported that the Audit Team did not encounter any evidence during the site inspection to suggest that mining operations were in contradiction to the approval.

3.1.4 Office of Water

Drayton Coal contacted NOW prior to the audit. As stated in Section 1.1.1, NOW requested that the audit assess the nature and metering of the licensable taking of water in the mining operation.

The audit found that the only area where water is taken is in the East Pit. A meter was installed in the East Pit approximately 3 months prior to the audit. Before metering, the amount of water taken was calculated using known flow rates versus time. No concerns were identified by the Audit Team.

3.1.5 Muswellbrook Shire Council

Drayton Coal contacted MSC prior to the audit. No further comment or instruction was provided.




4. Compliance with PA 06_0202 This section outlines Drayton Coal’s compliance with the conditions of the approval. The audit found that Drayton Coal has satisfied most conditions, but is also non-compliant with a number of conditions. A full checklist of compliance with the approval is provided in Appendix 1. This checklist details compliance status, evidence sighted and non-compliance issues/recommendations for each consent condition.

It is important to note that part of the audit process involved separating out the components of each condition into separate auditable requirements. This is reflected in the PA 06_0202 checklist provided in Appendix 1. Although each condition was separated into its components during the audit, compliance reporting was undertaken for the complete condition. This means that, in cases where multiple components were found to be non-compliant, the entire condition was reported as non-compliant.

The following sections outline the conditions with which Drayton Coal was found to be non-compliant.

4.1 Condition 1, Schedule 3 – Noise Impact Assessment Criteria

This condition requires Drayton Coal to ensure that the noise generated by the project does not exceed the noise impact assessment criteria in Table 1 (of the approval) at any residence on privately-owned land.

The relevant EPL Annual Returns (the noise limits in the EPL are consistent with the approval) were reviewed and the following findings noted:

2009 (Annual Return) – the noise limits were exceeded at locations 71, 72, 75 and 76 (eight exceedences), there was a failure to monitor at all noise locations specified in the EPL, and the noise report did not provide results of monitoring for LA1(1 minute) noise levels.

2010 (Annual Return) – the noise compliance assessment, while undertaken, did not occur at every location depicted in the EPL.

2011 (Annual Return) – no non-compliances were reported.

Drayton Coal employ a specialised consultancy, Spectrum Acoustics, to undertake six monthly acoustics reports. A review of these reports identified the following:

April 2010 report – minor to moderate (1-3dB) exceedences at Sharman and Horder during the evening.

September 2010 report – no exceedences.

April 2011 report – no exceedences.

August 2011 report – no exceedences.

March 2012 report – no exceedences.




September 2012 report – minor to moderate (2-3 dB) exceedences at Sharman and Horder were recorded when wind speeds were above the upper 3m/s limit of wind speeds for noise criteria to be applicable.

4.1.1 Recommendation

Although there are no further actions required regarding the non-compliances associated with the noise monitoring, it is suggested that Drayton Coal request that future Spectrum Acoustics reports clearly provide compliance/non-compliance assessments against the specific project approval conditions that relate to noise.

4.2 Condition 3, Schedule 3 – Cumulative Noise Criteria

This condition requires Drayton Coal to take all reasonable and feasible measures to ensure that the noise generated by the project combined with the noise generated by other mines does not exceed the following amenity criteria at any residence on privately-owned land:

LAeq(11 hour) 50 dB(A) – Day.

LAeq(4 hour) 45 dB(A) – Evening.

LAeq(9 hour) 40 dB(A) – Night.

It was determined that the 2011 AEMR contained a small number of occasions where the night noise limits were exceeded.


Drayton Coal should ensure the recommendations for improvement provided in Section 6.1 are completed.

4.3 Condition 9, Schedule 3 – Airblast Overpressure Criteria

This condition requires Drayton Coal to ensure that the airblast overpressure level from blasting at the project does not exceed the criteria in Table 4 (of the approval) at any residence on privately-owned land.

Relevant AEMRs were reviewed and the following findings noted:

AEMR (2009) – No exceedences were reported.

AEMR (2010) – No exceedences were reported.

AEMR (2011) – One exceedence was reported(6 May 2011, 122.4dB(L).

Year to date data was also reviewed and the following finding noted

One exceedence was reported (5 May 2012, 121.2dB(L).


No further action required.




4.4 Condition 16, Schedule 3 – Public Notice

This condition requires Drayton Coal to publicise an updated blasting schedule on its website.

It was determined that at the time of this audit, an updated blasting schedule was not available on the Drayton Coal website.

It was reported that all websites dedicated to Anglo American mines are controlled by the corporate office in Brisbane and there was generally a lag time between submitting the data to Brisbane and it getting posted online.

It should be noted that Drayton Coal has informed all relevant residents of the blasting information hotline which is also provided on the website. The blasting schedule is advertised in local newspapers four times a year.

It was reported that the Environmental Coordinator’s contact details are well known to all relevant residents.

It is also appreciated that blasting is only undertaken when meteorological conditions are suitable so there are often variations from the schedule.


Drayton Coal should review their website management processes so that either Drayton Coal assumes control of the information uploads or processes are made more efficient at the corporate office.

4.5 Condition 27, Schedule 3 – Surface Water Discharges

This condition requires Drayton Coal to only discharge water from the site in accordance with the provisions of an environmental protection license (EPL) or the Protection of the Environment Operations (Hunter River Salinity Trading Scheme) Regulation 2002

Drayton Coal does not intentionally discharge water from the site.

During the audit period, there were two occasions where water was unintentionally discharged from site and not in accordance with this requirement:

15 June 2011 – approximately five megalitres (ML) was discharged from the Rail Loop Dam during heavy rain.

5 October 2010 – water sprayers were unintentionally left on causing an overflow into a neighbouring farm dam.

The site inspection identified the dams where the discharges took place and found that Drayton Coal had implemented appropriate actions to prevent or minimise the likelihood of future discharges.






4.6 Condition 30, Schedule 3 – Erosion and Sediment Control

This condition requires Drayton Coal to develop and implement an Erosion and Sediment Control Plan (ESCP) which::

is consistent with the requirements of the Managing Urban Stormwater: Soils and Construction Manual (Landcom 2004, or its latest version)

describes measures to minimise soil erosion and the potential for the transport of sediment to downstream waters

describes the location, function, and capacity of erosion and sediment control structures

specifies what measures would be implemented to maintain the structures over time.

It was determined that the existing ESCP is not consistent with the requirements of the Managing Urban Stormwater: Soils and Construction Manual.

The following aspects would need to be included for the ESCP to be consistent with the manual:

existing site contours, including catchment area boundaries

locations of critical natural areas requiring special planning or management

stages of mining

nature and extent of earthworks, including cut and fill

location of all soil stockpiles

location of proposed roads

location and types of proposed erosion control measures

site rehabilitation proposals, including final contours.

There is no detail in the ESCP on how erosion will be controlled, particularly erosion resulting from dispersive soils. There is discussion in the ESCP on the use of diversion banks (channel banks) but these are inappropriate for dispersive mine spoil given their tunnel erosion risk. There is discussion of perimeter sediment control measures but no information on what type of sediment dam they are (Type C, D or F) or what chemical treatment might be required.

The ESCP describes limited maintenance of sediment control structures and diversion banks but doesn’t provide specific details.

4.6.1 Recommendation1

It is recommended that the following aspects of the ESCP be revised (in accordance with the Managing Urban Stormwater: Soils and Construction Manual):

1 Drayton Coal stated that the ESCP is part of the WMP. The WMP will be reviewed in early 2013 will the listed

recommendations incorporated into the ESCP.




existing site contours including catchment area boundaries

locations of critical natural areas requiring special planning of management

stages of mining

nature and extent of earthworks, including cut and fill

locations of all soil stockpiles

locations of proposed roads

existing and proposed drainage patterns

location and types of proposed erosion control measures

site rehabilitation proposals including final contours.

It is also recommended that the ESCP be revised to include more specific detail regarding the maintenance process for sediment control devices.

4.7 Condition 35, Schedule 3 – Offset Strategy

This condition requires Drayton Coal to prepare an Offset Strategy that describes the measures:

that would ensure that adequate resources are dedicated towards the implementation of the offset

that would demonstrate that the proposed offset is generally consistent with the principles in Appendix 9, and that it would result in a net improvement in the biodiversity value of the local area in the medium to long term.

The existing Offset Strategy does not describe what measures have been adopted to ensure that adequate resources are dedicated towards the implementation of the offsets.

The principles in Appendix 9 are also not thoroughly explained and complied with in the Offset Strategy.


Drayton Coal should revise the Offset Strategy to include:

commitment of resources for the implementation of offsets. Referencing of appropriate documentation (e.g. the Rehabilitation and Offset Management Plan) will suffice

a compliance table demonstrating how the offset areas comply with the principles provided in Appendix 9 of the approval.




4.8 Condition 39, Schedule 3 – Rehabilitation and Offset Management Plan

This condition requires Drayton Coal to prepare and implement a Rehabilitation and Offset Management Plan (ROMP) which includes descriptions of:

how the performance of the rehabilitation of the site and implementation of the Offset Strategy and Thomas Mitchell Drive tree screens would be monitored over time to achieve the relevant objectives and completion criteria.

The Rehabilitation and Offset Management Plan is also required to include procedures to be implemented for:

progressively rehabilitating areas disturbed by mining

controlling access

It was determined that the existing ROMP does not:

adequately provide detailed procedures for progressively rehabilitating areas disturbed by mining

provide procedures for controlling access to the Northern Offset Area.

It was also determined that while Section 7.2 of the ROMP describes the bushfire management process, it is considerably brief and does not provide any detail on how the process is to be achieved. Section 7.2 states that vegetation is to be maintained and managed to ensure a minimum fuel load and no risk of fires. There is no explanation of how vegetation will be managed or maintained.

The ROMP provides key performance indicators for the offset areas and the Thomas Mitchell Drive tree screen. Monitoring procedures are provided for the offset areas only.


Drayton Coal should revise the ROMP to include:

the short, medium, and long term measures to implement the Offset Strategy

progressive rehabilitation methodologies for disturbance areas and recently completed mining zones

access management processes for the Northern Offset Area

monitoring procedures for the Thomas Mitchell Drive tree screen.

4.9 Condition 40, Schedule 3 – Final Void Management

This condition requires Drayton Coal to prepare a Final Void Management Plan (FVMP) that:

justifies the planned final location and future use of the final voids




incorporates design criteria and specifications for the final voids based on verified groundwater modeling predictions and a re-assessment of post-mining groundwater equilibration

assesses the potential interactions between creeks on the site and the final voids

describes what actions and measures would be implemented to minimise any potential adverse impacts associated with the final voids

describes what actions and measures would be implemented to manage and monitor the potential impacts of the final voids over time.

The existing FVMP describes the location of the final voids and lists potential future use. It does not include a justification of the locations and the future use of the final voids.

The FVMP provides an indication of final water levels but does not provide the verified groundwater modelling predictions to justify these levels.

Construction of a bund at the crest has significant potential to contribute to geotechnical and tunnel erosion failure of the highwall(s). Design criteria and specifications have not been provided for critical aspects, including:

slope

erosion rates

soil/spoil

spontaneous combustion

soil surface cover

wave erosion

salinity.

Section 5.6.3 of the plan states that the creeks will not be impacted but the plan provides no science to justify these statements. It simply refers to the 2007 EA.

The FVMP does not adequately address measures to minimise any potential adverse impacts associated with the final voids or measures to manage and monitor the potential impacts of the final voids over time.

It was stated by Drayton Coal that the FVMP may be reviewed in 2013 but the review is heavily dependent on pending agreements with Macquarie Generation regarding their use of the voids.


Drayton Coal should revise the Final Void Management Plan to include:

a justification of the locations and the future use of the final voids

design criteria and specifications




justification(s) for the assessment of potential creek/void interactions

measures to minimise any potential adverse impacts associated with the final voids and to manage and monitor the potential impacts of the final voids over time.

4.10 Condition 41, Schedule 3 – Mine Closure Plan

This condition requires Drayton Coal to prepare a Mine Closure Plan that:

defines the objectives and criteria for mine closure

investigates options for the future use of the site, including the final voids

describes the measures that would be implemented to minimise or manage the ongoing environmental effects of the project.

The existing plan provides objectives for mine closure but does not provide adequate criteria.

The plan nominates various possible post mine land-uses but does not investigate options.

The plan discusses monitoring of environmental effects but does not describe the measures that would be implemented to minimise of manage the on-going environmental effects.


Drayton Coal should revise the Mine Closure Plan to include:

mine closure criteria

investigation results for post mine options

measures that would be implemented to minimise and manage the on-going environmental effects.

4.11 Condition 44, Schedule 3 – Monitoring of Coal Transport

This condition requires Drayton Coal to keep records of the dates and times of each train movement generated by the project and to include them in the AEMR.

It was determined that the existing AEMR records do not include the times of each train movement.


Drayton Coal should ensure that future AEMRs provide the times of all train movements associated with Drayton Coal.

4.12 Condition 3, Schedule 4 – Independent Review

This condition requires Drayton Coal to commission a suitably qualified, experienced and independent person, whose appointment has been approved by the Director-General, to conduct monitoring on the land to determine whether the project is complying with the relevant impact assessment criteria in Schedule 3, if the Director-General is satisfied that an




independent review is warranted. Drayton Coal is required to commission this expert within three months of the Director-General’s decision.

It was determined that there were three requests to DPI for an independent review of Drayton Coal’s environmental impact during the audit period:

de Boer residence on 22 November 2010 and again in mid-2011.

Doherty residence in mid-December 2011.

Drayton Coal commissioned three separate independent reviews in response to the three requests. Suitably qualified, experienced and independent consultancy, SLR, was commissioned in all cases.

Commissioning SLR for the first review (de Boer residence) was not undertaken within three months. It was reported that SLR was commissioned for the other reviews within the three month limit.

The report for the first independent review was not supplied within three months.



4.13 Condition 5, Schedule 5 – Annual Reporting

This condition requires Drayton Coal to submit an AEMR to the Director-General and relevant agencies. Specifically the AEMR is required to:

Include a summary of the complaints received during the past year, and compare this to the complaints received in previous years.

Include an analysis of these monitoring results against the relevant:

Limits/criteria in this approval.

Monitoring results from previous years.

Predictions in the EA.

Identify any trends in the monitoring results over the life of the project.

Identify and discuss any non-compliance during the previous year.

Describe what actions were, or are being, taken to ensure compliance.

It was determined that all three AEMRs completed and submitted during the audit period follow a consistent template.

All three AEMRs provide performance results for all environmental aspects associated with Drayton Coal. However, none of the reports adequately:

provide performance targets (statutory or initiative) for most of the aspects (air quality parameters are included)




provide a comparison to the complaints received in the previous reporting period

include an analysis against:

limits/criteria in this approval

monitoring results from previous years

predictions in the EA

identify any trends in the monitoring results over the life of the project

discuss identified non-compliances.


Drayton Coal should ensure that future AEMRs provide:

a comparison to the complaints received in the previous reporting period. It is also suggested that the type and nature of the complaints be compared to allow for trending and focus for improvement initiatives

an analysis against:

limits/criteria in this approval

monitoring results from previous years

predictions in the EA

trending analysis for all monitoring results

an improved discussion on identified non-compliances.

4.14 Condition 10, Schedule 5 – Access to Information

This condition requires Drayton Coal to put a copy of an audit required under this approval on its website within 3 months of completion.

It was determined that the previous audit report (AECOM, November 2009) has not been posted, nor is it currently available.


Drayton Coal should ensure that the November 2009 audit report is posted on the Drayton Coal website.




5. Compliance with DA 106-04-00 This section outlines Drayton Coal’s compliance with the conditions of the consent (Drayton Rail Loop and Antiene Rail Spur).

A full checklist of compliance against the consent is provided in Appendix 2. This checklist details compliance status, evidence sighted and non-compliance issues/recommendations for each consent condition.

The following sections outline conditions which Drayton Coal was found to be non-compliant with.

5.1 Condition 2.1, Schedule 2 – Environmental Coordinator

This condition requires Environmental Coordinator(s) employed by Drayton mine to have the authority and independence to require reasonable steps to be taken to avoid or minimise unintended or adverse environmental impacts and failing the effectiveness of such steps, to stop work immediately if an adverse impact on the environment is likely to occur.

It was reported by both the Environmental Coordinator and the SHE Manager that the Environmental Coordinator has the authority to enforce cease work orders on activities where he is concerned about adverse environmental impacts.

However, the position description for Drayton Coal’s Environmental Coordinator does not include authorities or specifically, the authority to order work cessations if necessary.


Drayton Coal should revise the Environmental Coordinator’s position description to include the authority to cease work activities that may cause adverse environmental impact, or require any other reasonable steps to be taken to avoid or minimise unintended or adverse environmental impact.

5.2 Condition 2.2, Schedule 2 – Environmental Management Strategies and Plans

This condition requires Drayton Coal to prepare an Environmental Management Strategy (EMS) that includes:

overall environmental management objectives and performance outcomes, during, operation and decommissioning of the rail loop and Antiene rail spur, for each of the key environmental elements for which management plans are required under this consent

overall ecological and community objectives for the project, and a strategy for the restoration and management of the areas affected by operations, including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives

overall objectives and strategies to protect economic productivity within the area affected by the operations




documentation of the results of consultations undertaken in the development of the strategy.

It was determined that the EMS prepared and implemented for the Drayton Mine under PA 06_0202 was amended to include the requirements for DA 106-04-00.

Section 5.6.3 of the EMS provides a table which details Drayton Coal’s environmental management objectives. Although the environmental objectives include aspects and actions pertinent to the rail loop and spur, there is no direct reference to either the loop or spur and furthermore, performance outcomes during operation and decommissioning of the loop and spur are not included.

Section 5.6.4 includes the list of environmental management plans applicable to Drayton Coal and their relationship with applicable approvals and licenses. The consent is not referenced, nor are the management plans applicable to the spur and loop (e.g. Joint Acquisition Management Plan, JAMP).

The EMS does not adequately provide:

ecological and community objectives for the rail loop and spur

a strategy for the restoration and management of the areas affected by the rail loop and spur, including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives.

Although it is appreciated that it is unlikely that the rail loop and spur may adversely impact on the economic productivity within the area, the EMS does not adequately discuss this or account for this requirement.

Appendix 1 of the EMS allows for regulatory correspondence. No correspondence is recorded. A provision for non-regulatory consultation (e.g. CCC) is not provided.


Drayton Coal should revise the EMS to include a clearer reference to the consent. This would include:

providing performance outcomes during operation and decommissioning of the loop and spur

improving Table 4 to include reference to the consent

including the environmental management plans applicable to the loop and spur

providing ecological and community objectives for the rail loop and spur

incorporating a strategy for the restoration and management of the areas affected by the rail loop and spur including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives

defining overall objectives and strategies to protect economic productivity within the area affected by the operations.




5.3 Condition 3.1, Schedule 2 – Surface & Ground Water Management and Monitoring

This condition requires Drayton Coal to prepare a site water management plan and monitoring system that includes a program for reporting on the effectiveness of the water management systems and performance in relation to the objectives contained in the water management plan.

It was determined that Section 4.16 of the Water Management Procedure – Rail discusses managing the water system against performance objectives. Although the procedure provides performance objectives (essentially the target capacity of the rail loop dam), there are no reporting processes (internal or external/regulatory) provided.


Drayton Coal should ensure that the internal and/or external reporting of performance objectives is included in the 2013 consolidation of the WMP and Water Management Procedure – Rail.

5.4 Condition 5.1, Schedule 2 – Air Quality Management and Monitoring

This condition requires Drayton Coal to prepare a dust management plan that includes appropriate mechanisms for community consultation.

It was determined that there are no mechanisms for community consultation provided in the AQMP.


Drayton Coal should revise the AQMP to include appropriate mechanisms for community consultation.

5.5 Condition 5.3.1, Schedule 2 – Noise Levels

This condition requires Drayton Coal to cooperate with the relevant mining operators to limit the cumulative noise contributions from the Drayton rail loop and Antiene rail spur such that these noise levels in conjunction with the total cumulative noise contributions from the operations of the Drayton coal mine, Mt Arthur rail loading facility and rail loop, Mt Arthur mine and the Antiene rail spur, do not exceed the dB(A) Leq(9 hour/4 hour/11 hour) noise limits in Table 2 at any non-mine owned dwellings.

Drayton Coal shall also ensure that the noise levels from the Drayton rail loop and Antiene rail spur alone do not exceed the dB(A) Leq(15 minute) noise limits also shown in Table of the consent.

It was determined that the available monitoring data does not clearly report on compliance in relation to this condition of the approval.





Drayton Coal should include in the monitoring data report, a section on compliance with Condition 3, Schedule 3 of the approval.

5.6 Condition 7, Schedule 2 – Monitoring/Auditing

This condition requires Drayton Coal to ensure that all sampling strategies and protocols undertaken as part of any monitoring program include a quality assurance/quality control plan.

It was determined that the Environmental Monitoring Program does not include a quality assurance/quality control plan.


Drayton Coal should revise the Environmental Monitoring Program to include a quality assurance/quality control plan which is suitable for all monitoring undertaken on site.




6. Evaluation of environmental management plans As required by Condition 6, Schedule 5 of the approval, the audit is required to “review the adequacy of any strategy/plan/program required under this approval”.

The evaluation of the environmental management plans focused on whether Drayton Coal has employed:

Necessary actions to effectively manage the respective impacts on the plans.

Industry leading practice and technology.

It is important to note that the content and recommendations provided in this section are advisory and are suggestions for improvement only. Although the evaluations considered the requirements set out in the respective conditions of the approval; actual compliance is provided in Section 4 and Appendix 1.

The following plans and strategies have been assessed:

Noise Management Plan (NMP).

Blast Management Plan (BMP).

Spontaneous Management Plan (SMP).

Air Quality Management Plan (AQMP).

Water Management Plan and its associated sub-plans:

Erosion and Sediment Control Plan (ESCP).

Surface Water Management and Monitoring Plan (SWMMP).

Groundwater Monitoring Plan (GMP).

Surface and Ground Water Response Plan (SGWRP).

Landscape Management Plan (LMP) and its associated sub-plans:

Rehabilitation and Offset Management Plan (ROMP).

Final Void Management Plan (FVMP).

Mine Closure Plan (MCP).

Aboriginal Cultural Heritage Plan (AHP).

Greenhouse and Energy Efficiency Plan (GEEP).

Environmental Management Strategy (EMS).




It was determined during the audit that all required strategies, plans and programs were submitted to DPI within the required timeframes with the exception of the updated LMP which is due at the end of 2012.

Drayton Coal submitted the AQMP, BMP (including the Road Closure Management Plan) and NMP on 31 October 2012. Considering that the purpose of this audit included an evaluation of the plans, DPI suggested to Drayton Coal that submission of the plans to DPI be postponed until 29 March 2013 to allow for amendments resulting from this audit to be incorporated.

Drayton Coal consulted with DPI and DTIRIS prior to commissioning this audit and was informed that DPI requires specific focus on the AQMP, SCMP and LMP.

It is important to note that only environmental management plans required under the approval were assessed and that plans required for the consent were only evaluated when they had been or were in the process of being incorporated into the corresponding plan required under the approval. There are two approval required management plans currently being incorporated into the equivalent consent plan:

Air Quality Management Plan (consolidated with the Dust Management Plan for the consent).

Noise Management Plan (consolidated with the Noise Management Plan for the consent).

6.1 Noise Management Plan and Blast Management Plan

Condition 8, Schedule 3 of the approval requires Drayton Coal to prepare and implement a NMP for the project to the satisfaction of the Director-General.

Condition 20, Schedule 3 of the approval requires Drayton Coal to prepare and implement a BMP for the project to the satisfaction of the Director-General.

It was determined that both plans adequately comply with the conditions of approval and an overview of noise/blasting monitoring. The plans also adequately define the environmental requirements and how potential noise/blast levels are measured.

6.1.1 Opportunities for improvement

6.1.1.1 Noise Management Plan

Drayton Coal may wish to consider revising the NMP to include the following:

Noise monitoring data at the identified receiver locations could be summarised to identify trends in ambient noise and also any measurable contribution from mine operations. The last twelve months of data would be a viable period to consider.

The noise management measures in Section 5.4 and 5.8 could be consolidated and cross referenced to specific activity and measured noise levels – this should provide a singular point in the plan for staff to turn to in the event of a noise issue.

Specific detail could be provided on what monitoring and management measures are contained within the Joint Acquisition Management Plan – the NMP only states this joint




venture is in place but provides no details, timeframes or specific responsibilities for Drayton Coal.

All monitoring could be confirmed to be consistent with guidance in relevant Australian standards, including the calibration of all equipment.

6.1.1.2 Blasting Management and Monitoring Plan

Drayton Coal may wish to consider revising the BMP to include the following:

All measures undertaken by the blasting personnel to minimise impacts could be detailed in the plan. The plan currently assigns the responsibility for achieving the blasting criteria on to the contractor – there should be specific direction for how blasts are controlled.

The blasting and meteorological monitoring procedures and methodologies provided in Section 4.6.4 could be revised to include more detail including maps of monitoring locations, specifications for measurements and historical results. In the event there are any issues or the plan is handed to another staff member, there may not be enough information to maintain current systems.

Any properties that have been already surveyed could be listed in Section 4.6.12.

Section 4.6.14 should be revised to be more consistent with the reporting requirements in the approval.

6.2 Spontaneous Combustion Management Plan

Condition 24, Schedule 3 of the approval requires Drayton Coal to prepare and implement a SCMP for the project to the satisfaction of the Director-General.

A detailed site inspection on Drayton Coal’s spontaneous combustion management and performance was undertaken on October 30, 2012. Discussions were held with site personnel prior to and after a detailed inspection of operating and non-operating areas of the open cut mine. The following documentation was supplied:

the current SCMP

the Safe Job Procedure for working in and around material affected by spontaneous combustion

examples of Mine Spontaneous Combustion Six Monthly Reports.

The audit included an assessment of the compliance of the operations with industry leading practice for spontaneous combustion risk assessment and management planning, and the effectiveness displayed by the operations to manage and monitor events as they arise.

The procedural aspects of the existing SCMP are clearly defined and the roles and responsibilities are appropriately designated. Actions for planning to minimise the impacts of any spontaneous combustion events are incorporated into the roles of all personnel on site, and there are links into the sections of the plan on prevention and management of spontaneous combustion and rehabilitation. This “closing the loop” is a good practice that is often overlooked in industry.




The current purpose of the plan is centred on describing how spontaneous combustion is managed at the mine. It would be advantageous to provide a more comprehensive statement that conveys a health and safety aspect as well as identifying the key mining legislation requirements.

Specific act requirements, such as complying with the Coal Mine Health & Safety Act 2002 and other relevant acts should be identified as well. The management plan also makes no reference to Mining Design Guideline (MDG) 1006: Spontaneous Combustion Management Guideline (May 2011) which is the standard reference provided by DTIRIS.

The audit/review schedule is set such that the SCMP will be updated every three years, which appears to be a standard adopted by Drayton Coal. The revisions listed show a good responsive approach to changing conditions, although this could also be captured in the initial statement on the audit/review schedule by specifying that additional reviews should be undertaken following any of these events:

a major spontaneous combustion incident

significant change in mining systems, conditions or circumstances

a change of management structure.

Updating the plan every three years would seem to be too long in terms of leading practice and a better approach would be to do this every two years.

The plan contains a very detailed operational hierarchy for preventing and managing spontaneous combustion events. This is supported with an excellent Safe Job Procedure for working in and around material affected by spontaneous combustion. The pit dump arrangements contained in the plan are consistent with leading practice for handling and mitigation of spontaneous combustion events. There appears to be no hazard identification incorporated into the plan other than the use of past experience with events, and therefore in the case of ROM and stockpile handling, a maximum time is applied to relocation or loading out. In other words, historical evidence is used but no supporting documentation of any coal testing (or testing of surrounding strata) is present in the plan. Monitoring of events appears to rely on visual inspections according to the plan, which is generally considered a reactive measure.

Although the coal measures are known to be prone to spontaneous combustion, to maintain leading practice requires some fundamental testing to be applied to assess the spontaneous combustion risk. This area of assessment has advanced significantly in the last two years and a new test procedure is available that can quantify the time taken to reach thermal runaway for a given mine condition (Beamish and Beamish, 2012). This enables the opportunity to use forward planning and proactive management for unmined areas.

Visual monitoring of spontaneous combustion events poses elements of risk to personnel. A new technique is being developed by Commonwealth Scientific and Industrial Research Organisation (CSIRO) to use unmanned aerial vehicle surveillance to monitor the development of subsurface heatings, their extent and effectiveness of mitigation strategies. An example of the IR-Image for a trial area is shown in Figure 6.1. While the major hot spots in the middle of the image were easily visible the smaller hot spot in the bottom right of the affected zone was not. Such images provide the opportunity to proactively monitor subsurface heating development with minimal risk to personnel. It is suggested that Drayton Coal investigate the possibility of applying this technique as a research project for




developing leading practice in this area. The same equipment can be used to provide remote gas monitoring over affected areas.

Figure 6.1 Thermal and visible-band overlay of old mine spoil showing signs of

subsurface heating. Note the yellow and orange regions represent temperatures in the range of approximately 60°C through to 200°C (Malos et al, 2013).

The six monthly reporting of spontaneous combustion events by the mine provides a valuable reference of management effectiveness. The details provided help to establish an improving trend in management practice, which is to be commended. Some additional analysis of events may also help to establish seasonal effects such as rain events as a precursor to promoting spontaneous combustion. If such a trend could be identified it would help to implement an appropriate management strategy for dealing with these occurrences.

The Drayton SCMP contains no reference to training. MDG1006 provides a comprehensive list of requirements for training of persons with responsibilities under the SCMP. A competency based approach could be applied to meet these requirements.

Operationally the SCMP complies with leading practice in terms of how spontaneous combustion events are managed. The general impression is that this is a reactive plan that captures essential elements of roles and responsibilities linked with an operational hierarchy for prevention and managing spontaneous combustion events, which is often lacking in most plans.


Drayton Coal may wish to revise the SCMP to include:

A more comprehensive objective that conveys a health and safety aspect as well as identifying the key mining legislation and guideline requirements such as:

Coal Mine Health & Safety Act 2002.

Mining Design Guideline (MDG) 1006: Spontaneous Combustion Management Guideline (May 2011).




A shorter period between reviews of the plan (i.e. every two years) and to include a revision response approach to changing conditions such as after:

A major spontaneous combustion event.

Significant change in mining systems, conditions or circumstances.

Change of management structure.

A more proactive hazard identification process that requires some fundamental testing to be applied to assess the spontaneous combustion risk. Drayton Coal should investigate incorporating the suggested test procedure that can quantify the time taken to reach thermal runaway for a given mine condition.

It is suggested that Drayton Coal investigate the feasibility of unmanned aerial vehicle investigation (potentially as a research project) for developing leading practice in spontaneous combustion identification and management.

Drayton Coal may wish to revise six monthly reporting of spontaneous combustion events by including additional analysis of events (e.g. rain events) to establish seasonal effects as a precursor to promoting spontaneous combustion.

6.3 Air quality management

Condition 25, Schedule 3 of the approval requires Drayton Coal to prepare and implement an AQMP for the project to the satisfaction of the Director-General.

An additional requirement of the DPI (and DTIRIS) was to assess air quality management on site (refer to Section 1.1.1).

6.3.1 Air monitoring locations

A review of the Drayton air quality monitoring network was completed on 30 October 2012. This included reviewing a tapered element oscillating microbalance (TEOM), a hi-volume air sampler (HVAS) and two dust deposition gauges.

6.3.1.1 Tapered element oscillating microbalance monitor

The TEOM is located to the northwest of the Drayton mining lease boundary at the closest residence. PM10 concentrations are continuously monitored at this site.

The TEOM complies with AS3580.9.8:20082. However, as indicated in the Photograph 13, there are a number of trees in proximity to the TEOM. The distance of the TEOM to the nearest trees should be measured and compliance with AS3580.1.1:20073 ascertained and remedied if required.

No prevailing wind information has been provided in the AQMP. This information is useful to ascertain the upwind/downwind contributions of particulate matter within the local air shed. In general, the prevailing wind direction in the Upper Hunter Valley follows a

2 Methods for sampling and analysis of ambient air (Method 9.8: Determination of suspended particulate matter -

PM10 continuous direct mass method using a tapered element oscillating microbalance analyser). 3 Methods for sampling and analysis of ambient air (Part 1.1: Guide to siting air monitoring equipment).




northwest/southwest axis. With the TEOM at this location, its usefulness in assisting with the management of on-site dust impacts may require reconsideration4 because its location is outside of the prevailing wind that would transport particulate matter from the mine towards the monitor.

The use of the Upper Hunter Air Quality Monitoring Network station at Camberwell as an alternate upwind/downwind monitor is limited. This site is located approximately 19 km southeast of Drayton Coal and particulate measurements would be significantly influenced by contributions from other mining activities which are closer to the monitor.

It is understood that Drayton Coal is in the process of setting up a real-time air quality monitoring network that would include continuous monitors to the north, south, east and west of the project boundary. This real-time monitoring network is scheduled to be installed in early 2013. At the time of the audit there was no information available to validate the commitment.

The review of recent calibration certificates indicate that the TEOM is operating within the AS 3580.9.8-2008 requirements.

6.3.1.2 Hi-volume air sampler

The HVAS is located to the north of the mining lease boundary at a nearby residence. Total suspended particle (TSP) concentrations are measured every sixth day at this site.

The HVAS appears to comply with the AS3580.9.6:20035. However, as indicated in Photograph 14), there is a tree in proximity to the HVAS. The distance of the HVAS to the tree should be measured and compliance with AS3580.1.1:2007 determined.

Review of recent calibration certificates indicate that the HVAS is operating within the AS 3580.9.6:2003 requirements.

The site inspection identified an additional TSP monitor co-located at the meteorological station, to the west of the CHPP and within the project boundary. Calibration certificates have been provided for this HVAS but it has not been identified as part of the AQMP.

6.3.1.3 Dust deposition gauges

The AQMP identifies eight dust deposition gauges that are a part of the Drayton air quality monitoring network. All gauges are located to the north and northwest of the mining lease.

Three dust deposition gauges were sighted on the day of the audit. These dust deposition gauges comply with AS3580.10.1:20036. The distance of the dust deposition gauges to the nearest trees should be measured and compliance with AS3580.1.1:2007 determined. It should also be checked that the dust deposition gauges are firmly secured and the gauge stands are vertical.

4 Upon review of the draft report, Drayton Coal stated that the TEOM location was determined by nearest residence.

New TEOM to be installed will be within the suggested prevailing wind direction. 5 Methods for sampling and analysis of ambient air (Method 9.3: Determination of suspended particulate matter - total

suspended particulate matter (TSP) - High volume sampler gravimetric method) 6 Methods for sampling and analysis of ambient air (Method 10.1: Determination of particulate matter- deposited

matter- gravimetric method)




6.3.2 Air Quality Management Plan

6.3.2.1 Dust monitoring network

The description of the Drayton dust monitoring network is not clear and there appears to be discrepancies in the number of HVASs that are operational. For example, there is no description of the decommissioned monitor that is located at the meteorological station or explanation of the decommissioned HVAS at the Lot 9 Antiene monitoring location.

Figure 1 of the AQMP identifies the locations of the air quality monitoring network. The map should identify that that HVAS is a TSP monitor. It would also be useful to identify the location of the nearby sensitive receivers.

6.3.2.2 Project approval air quality criteria

The AQMP has adopted the standard air quality impact assessment criteria as prescribed in PA 06_0202 and in line with the current NSW guidelines, Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (DEC, 2005).

6.3.2.3 Reactive and proactive management system

Condition 25(b) of the CoA requires that reactive and proactive mitigation measures be included as part of the AQMP. This includes the development of a real-time air quality management system. The requirement is to describe the best practice management measures that would be implemented to ensure compliance.

Real-time monitoring

The continuous monitoring system that has been installed meets the requirements of a real-time air quality management system. In having only one continuous monitor, potential contributions from upwind sources and contributions from Drayton Coal are not captured.

It is understood that Drayton is in the process of setting up a real-time air quality monitoring network that would include continuous monitors to the north, south, east and west of the project boundary. This real-time monitoring network is scheduled to be installed in early 2013. The implementation of such a system would enable upwind/downwind and Drayton mine contributions to be adequately monitored.

The AQMP identifies that when particulate matter concentrations measured at the TEOM are above 50 µg/m3 for one hour or more, and Drayton mining operations are determined to be the source of the elevated levels, then the OCE is notified. This triggers a review of the current mining operations that follow air quality control measures identified in Table 4 of the AQMP. It is important that decisions made by mining personnel when modifying onsite mining operations take into account the prevailing meteorological conditions so that the most effective dust mitigation strategies can be employed. For example, during windy conditions, wind sensitive dust emissions sources are identified as having the greatest potential for reducing potential downwind elevated dust measurements. As with calm conditions, when wind insensitive sources should be the focus for dust emission reducing potential.

A key tool used in real-time dust management is the establishment of action response levels (ARLs). These aid in the assessment of impact potential, and establish an early warning system during adverse trends, reducing complaint potential and non-compliance issues. An ARL trigger would be a defined measurement of elevated dust levels for a prolonged period.




The ARL could also be based on the predicted impacts that were defined as part of the Air Quality Impact Assessment for the EA.

The ARLs act as triggers for the implementation of appropriate management measures. An example ARL system has been provided below:

ARL 1 - this is the lowest response level. When monitored air quality parameters are below this level no further action other than continuation of monitoring is required. When one or more air quality parameter are above this level but below ARL 2, then the source of the emissions will be identified and additional emissions control measures will be undertaken to manage the emissions.

ARL 2 - this is the second response level. When one or more air quality parameters are above this level but below the MaxARL then an order to suspend works may be issued for all operations that could be contributing to the pollutant of concern. The source of the emissions will be identified and the related work will not recommence until conditions contributing to the elevated levels (for example, the prevailing wind direction) change or existing emission control techniques are improved/ upgraded to appropriately manage the emissions.

Maximum Air Quality Level (MaxARL) - this is the proposed project specific compliance criteria for each pollutant. If one or more air quality parameters exceed this level then the responses described for ARL 2 will be immediately implemented and Drayton Operations notified in accordance with the reporting system described in Section 2.11 of the AQMP.

The AQMP has included a basic ARL in that when particulate matter concentrations measured at the TEOM are above 50 µg/m3 for one hour or more, and Drayton mining operations are determined to be the source of the elevated levels, then the Mining operations Supervisor is notified. The ARL should be updated as part of the implementation of the reactive management system7.

This real-time monitoring system could also be shared with the neighbouring mines to ensure that a collaborative approach is taken to ensure compliance with the NSW air impacts assessment criteria.

Meteorological forecasting

The AQMP has identified that meteorological forecasting is used to assess mining operation decisions. This audit is satisfied with this approach.

It is recommended that further detail in the assessment of the meteorological forecasting is included in the AQMP. This detail would be linked with the mitigation measures employed at Drayton Coal.

6.3.2.4 Review best management practices

The recommended air quality control management measures identified in Table 4 of the AQMP is high level and does not provide an adequate action plan for how the best management practices are to be implemented into onsite operations. While it is

7 It was stated by Drayton Coal that the new dust monitoring system introduced in 2013 will work on a ARL (TARP)

system.




acknowledged that the onsite operations utilise some best practice air quality control measures, the documentation in the AQMP as to how these are actioned is unclear.

The NSW Coal Mining Benchmarking Study: International Best Practice measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining (Benchmark Study, Katestone Environmental, 2011) has identified that wheel generated dust from haul trucks travelling on unsealed roads is the most significant source of TSP and PM10 emissions, and the second most significant source of PM2.5 emissions. The Benchmark Study has identified a number of reasonable and feasible measures for haul road dust suppression for the design, maintenance and management of haul roads. This includes, for example, Level 2 watering of unsealed roads to achieve a 75% control and the restriction of vehicles travelling on unsealed roads to 40 km/h. Such measureable actions are recommended to be detailed in the AQMP.

Wind erosion is the second highest contributor to TSP and PM10 emissions from open cut coal mining. Additional best practice measures that should be included in the AQMP include the shaping and orientation of stockpiles to minimise emissions with consideration of the prevailing wind direction and location of sensitive receivers.

Onsite observations of the dragline operations identify it as a key source of particulate matter emissions from Drayton Coal. The AQMP has identified some management practices to mitigate potential emissions from the operation of the drag line. Such additional practices identified in the Benchmark Study would include the modification of operations during adverse meteorological conditions, water sprays and the elimination of side casting.

Air quality management practices have only been included in the AQMP for the loading and unloading of material at the CHPP. Onsite observations of the transfer of coal from the ROM pad to the hopper showed visible plumes of coal dust being generated. Best practice measures to minimise dust generated at the ROM pad is to minimise rehandling of the ROM coal through bypassing stockpiling. The Benchmark Study has recommended measures for minimising emissions from overburden dumping to include the minimisation of drop height from the excavator or dump truck, the application of water sprays to unloading of material from trucks and the modification of operations on dry and windy days.

6.3.2.5 Air Quality Monitoring Program

The air quality monitoring plan has been included in Section 4.12 of the AQMP. The air quality monitoring program should be provided as an appendix to the AQMP and referenced within the AQMP document. This allows for the continuous improvement of the monitoring plan in line with the most up to date information on the air quality monitoring network.

It is recommended that the particulate matter size fraction be clearly stated for each HVAS. It is the PM10 size fraction of particulate matter that is most often measured at elevated concentrations that approach the 24 hour average and annual average NSW air impact assessment criteria.

As discussed in Section 2.2.1, it is recommended that the current air quality monitoring network be tabulated with reference to important information such as the relevant Australian standard, equipment number and geo-referenced coordinates.

The standard operating procedures for the handing of the dust deposition gauges, HVAS, TEOM and the continuous meteorological station should be included as part of the air quality monitoring plan. Implementing the standard operating procedure would ensure:




The correct procedures are followed in the handling of sample and subsequent lab analysis or data handling.

The correct procedures are followed for the downloading of data.

Instrumentation is calibrated at the required time intervals and compliance with the relevant Australian standard.

In the event of equipment failure, a procedure to ensure that the equipment is fully operational as soon as feasible would reduce potential downtime for the real-time monitoring network.

Once the trigger levels (or ARLs) are developed for the real-time air quality management system, this should be presented as an easy to reference table where mine personnel can access the most appropriate action required. The suggested actions should also take into account wind sensitive and wind insensitive emissions sources.

Condition 25(d) of the approval requires that PM2.5 be monitored or that justification be provided in using the regional air quality monitoring data. The AQMP has identified that PM2.5 concentration measurements have been adopted from the Muswellbrook monitoring station that forms part of the Upper Hunter Air Quality Monitoring Network. A review of the location of the Muswellbrook monitor with respect to Drayton indicates that using this data is satisfactory.

6.3.2.6 Cumulative impacts protocol

Condition 25(e) of the approval requires a protocol to be prepared to minimise the cumulative impacts with other mines. This protocol is to be developed in consultation with the community.

This audit is satisfied with the AQMP in addressing this condition.


Drayton Coal should proceed with the installation of the real-time air quality monitoring network as soon practicable. The location of each of the monitors should be reviewed in consultation with an air quality specialist. It is also recommended that a full review of air monitoring network is undertaken to assess validity, adequacy and appropriateness of the current monitoring locations and those that are being operated in conjunction with other nearby mining operations.

Drayton Coal may wish to consider undertaking an internal audit of all dust deposition gauges to assess compliance with AS3580.1.1:2007 and AS3580.10.1:2003.

Drayton Coal may wish to revise the AQMP to:

Clarify and update the air monitoring network information. This would include providing a table indicating the location of monitors (numbered), monitor averaging periods, location coordinates and primary purpose (i.e. monitoring of sources, background, sensitive receptor). Figure 1 in the AQMP should be updated accordingly.

Provide the air quality monitoring program as an appendix to the AQMP. This would allow for the continuous improvement of the monitoring plan in line with the most up to date information on the air quality monitoring network.




Amend the air quality control management practices for dust suppression to take into account the best management practices described in the NSW Coal Mining Benchmarking Study: International Best Practice measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining.

Ensure that the adopted management practices are more definitively described, actioned and listed with consideration to each mining activity for personnel referencing the AQMP. The suggested actions should also take into account prevailing meteorological conditions, wind sensitive and wind insensitive emissions sources.

6.4 Water Management Plan

Condition 28, Schedule 3 of the approval requires Drayton Coal to prepare and implement a WMP for the project to the satisfaction of the Director-General.

The WMP comprises the:

ESCP.

SWMMP.

GMP.

SGWRP.

Erosion and sedimentation management at Drayton Coal was reviewed by the Rehabilitation Specialist – refer to Section 6.5.

It was determined that the plans generally comply with the conditions of approval and provide an overview of required monitoring.

It is important to note that water management is not considered an issue for concern as water tends to drain into the site, and the site does not draw a significant amount of water for processing.

The review of the WMP identified a number of potential improvements.


Drayton Coal may wish to revise the WMP to include the following:

Details on the methodology for the estimated values of water demands, including how variability of demands in different climatic conditions are taken into account.

A stochastic site-wide water balance model which is developed and verified for the available historical data.

A calculation of maximum runoff based on catchment area, rainfall and soil types to determine flow contributions from:

Upstream catchment.

Mine site.




Downstream catchment to the confluence with the Hunter River.

This will demonstrate the insignificance of runoff affectation by the site.

Methodologies for surface water monitoring including:

Timing.

Chains of custody protocols.

Quality assurance procedures.

6.5 Landscape Management Plan

Condition 38, Schedule 3 of the approval requires Drayton Coal to prepare and implement a LMP for the project to the satisfaction of the Director-General.

An inspection of the overall site was undertaken on 30 October 2012. No significant erosion was observed during the inspection despite sub-optimal soil surface cover in many of the rehabilitation areas. It is important to note that there had been limited rain on site.

It is however likely that Drayton Coals does not test and ameliorate spoils, subsoil and topsoils and this has contributed to the poor resilience of rehabilitating areas8. Dispersive mine spoils have limited pore space, are often hydrophobic and crust following rainfall, limiting water infiltration, hydraulic conductivity and water storage.

These spoils and soils also typically have chemical factors that limit vegetation growth – poor calcium to magnesium ratio, high phosphorous absorption, elevated sodicity and salinity, and low organic carbon. Soil testing is critical to determine how to manage and ameliorate spoils and soils.

There is a strong reliance on the use of channel banks (diversion banks) on rehabilitating areas. Channel banks are not suitable for use in the presence of dispersive soils9 due to their potential to pond water and create tunnel erosion.

Spoil and soil testing

Mine spoils and soils have physical, chemical and biological properties that are limiting to vegetation establishment.

Mine closure criteria

Drayton Coal does not appear to have specifications for any aspects of rehabilitation.

8 Upon review of the draft report, Drayton Coal stated that ad hoc testing has taken place in the past. Testing in 2012

did not indicate dispersive soils. Drayton Coal also questioned the assessment of the soil’s poor resilience.

9 Upon review of the draft report, Drayton Coal stated that Drayton Coal typically do not have problems with dispersive soils. Existing contour banks indicate that soils are not dispersive.




Diversion banks

Channel bank diversion banks are not suitable for use on dispersive soils due to their tunnel erosion and then gully erosion risk. The channel banks on site appear not to drain to any specific locations10.

Topsoil management

Topsoil stockpiles appeared to be excessively high and weed infested. This is likely to result in physical, chemical and biological degradation of topsoil resources

Topsoil stripped for placement in offset areas

The majority of nutrients required to establish open woodland communities is contained in the biomass and not in the soil. Direct placement of stripped topsoil without adequate amelioration will result in sub-optimal and stunted growth11.


Drayton Coal may wish to adopt the following strategies and recommended improvements to its erosion and sediment control and rehabilitation methodologies and document these in its LMP:

Undertake a first principles review of suitable post mine land-use(s). It is likely that a biodiversity post mine land-use is the only appropriate use for spoil dumps and low walls.

Test and characterise mine soils and spoils. Ameliorate spoils, sub-soils and topsoil to improve growing conditions for vegetation.

Test and ameliorate soils in already rehabilitated areas to improve rehabilitation performance.

Develop specifications for all aspects of rehabilitation and implement quality assurance processes to demonstrate compliance with specifications.

Undertake spoil erosion assessment and erosion modelling to determine an appropriate slope gradient.

Remove channel banks where adequate vegetation cover exists to return drainage to sheet flow conditions instead of concentrated flow conditions.

Test and ameliorate spoil and soil to increase infiltration, to reduce runoff and improve revegetation performance.

Limit the height of topsoil stockpile to 1.5 metres. Test topsoil prior to stripping and ameliorate during the stripping process. Revegetate topsoil stockpiles as soon as possible.

10 Upon review of the draft report, Drayton Coal stated that this is part of the uncompleted final drainage design. Due

to limited dispersive soils, there have been no issues with tunnelling or erosion of banks. 11 Upon review of the draft report, Drayton Coal stated that the offset areas have already been rehabilitated with soils

laid and that limited biomass is available due to areas being stripped.




Retain cleared vegetation and manage on site to form compost. Ameliorate the topsoil with sufficient phosphorous, calcium and organic carbon levels (and other ameliorants as determined by soil and plant tissue testing) to establish open woodland communities.

6.6 Aboriginal Cultural Heritage Management Plan

Condition 43, Schedule 3 of the approval requires Drayton Coal to prepare and implement an AHP for the project to the satisfaction of the Director-General.

Drayton Coal has developed and implemented an AHMP. The plan has been approved by DPI.

The development of the AHMP included the necessary consultation with key stakeholders.

The audit assessed that the AHMP is generally adequate for the management of the impacts to Aboriginal heritage at Drayton Coal.

The review of the ACHMP indicates that it addresses the requirements of Condition 43, Schedule 3 and the relevant commitments listed in the SOC. Refer to Appendix 1 for more information.



6.7 Greenhouse and Energy Efficiency Plan

Condition 46, Schedule 3 of the approval requires Drayton Coal to prepare and implement a GEEP for the project to the satisfaction of the Director-General.

A GEEP has been prepared and implemented by Drayton Coal and it has been approved by DPI.

The GEEP generally complies with the requirements of the approval however the following areas for improvement were identified:

Very little baseline information has been provided and as such, performance against the “2011 and onwards” improvement measures is not known.

Corrective actions or equivalent performance review mechanisms are not included.

Improvement measures are provided without firm commitment with an emphasis on “measures could include”.

The “improvement measures” section does not specify enough detail on the methodology for achieving the measures.


Drayton Coal may wish to revise the GEEP to include the following:

Baseline and historical data on greenhouse gas and energy consumption data compared and trended over subsequent revisions, with updated monitoring information.




A revised discussion of improvement measures which includes a commitment to actual measures with specified and detailed actions and associated methodologies, accountabilities and performance indicators.

A protocol for periodically assessing performance and applying corrective actions where necessary.

6.8 Environmental Management Strategy

Condition 43, Schedule 3 of the approval requires Drayton Coal to prepare and implement an EMS for the project to the satisfaction of the Director-General.

Drayton Coal has developed and implemented an EMS. The EMS has been approved by DPI.

The EMS can be considered a mapping document that provides general instructions and references to key internal procedures.

It is important to note that Drayton Coal operate an environmental management system which allows for comprehensive management of all environmental impacts.

The review of the EMS found that it complies with all requirements provided in the approval and that it is adequate for its intended purpose.






7. Environmental performance

7.1 Assessment against predictions made in relevant environmental assessments and associated documentation

There are two environmental assessments (EA) applicable to Drayton Coal:

Mine Extension Environmental Assessment (Hansen Bailey, November 2007).

Antiene Joint User Rail Facility Environmental Impact Statement (Umwelt, March, 2000).

The EA for the Drayton mine has had two subsequent modifications:

Project Approval Modification Environmental Assessment (Hansen Bailey, July 2009).

East Pit Tailings Emplacement & Explosive Storage Facility Environmental Assessment (Hansen Bailey, July 2011).

7.1.1 Mine Extension Environmental Assessment (2007)

The 2007 EA allowed for Ravensworth Operations to continue open cut mining of the Greta coal measures of up to 8 Mtpa of ROM coal for up to 10 years. The EA also provided for the existing CHPP, stockpiles and reclamation system to be upgraded.

It is important to note that the requirements of the approval are generally consistent with the mitigation measures provide in the EA and thus, the audit considers the compliance assessment provided in Appendix 1 adequately assesses Drayton Coal’s compliance with the EA. The following table provides a brief summary of the audit’s assessment of the EA’s predicted impacts.

Table 7.1 Mine Extension Environmental Assessment (2007) assessment of predicted impacts

EA prediction Audit findings

Air quality

Air quality modelling indicates that all relevant air quality criteria will be met during the life of the Project and there are no predicted exceedences of any air quality criteria at any receivers.

No exceedences of air quality criteria have been reported during the audit period (refer to Appendix 1).

Spontaneous combustion

Analysis suggests that it is unlikely that the OEH’s ambient air quality criteria for odour will be exceeded in the Antiene Estate due to the Project.

It was reported that an occasional odour complaint is received from a Scone resident. Considering that Scone is over 50 km from Drayton Coal, there are doubts that Drayton Coal is responsible. The site inspection did not identify any odour issues (refer to Section 7.2).





While some spontaneous combustion emissions and odour impacts may continue to occur sporadically, the monitoring data indicates that the levels of particulate matter and hydrocarbons, coupled with ongoing management, will comply with health-based air quality standards at the closest adjoining private receivers.

Impacts as predicted.

It is envisaged that the occurrence of spontaneous combustion will decrease and the effects of spontaneous combustion will be effectively reduced to zero by the end of the life of the Project.

It was reported that spontaneous combustion (especially in the Southern Pit) has improved over time. Several occurrences of spontaneous combustion were observed during the site inspection.

Greenhouse Gas

The annual average emissions from Scope 1 and 2 sources for the Project are predicted to be 355,627 tonnes CO2 equivalent emissions, whilst the approximate worst-case annual average emission rate for spontaneous combustion is predicted to be 30,280 tonnes CO2 equivalent emissions.

The GEEP does not provide any baseline or monitoring figures with respect to CO2 emissions. Refer to Section 6.7.

Noise

Noise levels predicted for the Project were found likely to remain within the appropriate noise criteria at all receivers during neutral and noise reducing weather conditions, which occur for a significant proportion of the time.

Impacts generally as predicted however a number of noise exceedences were recorded during the audit period (refer to Section 4).

23 receivers are expected to receive noise levels over the adopted intrusive noise criteria in at least one assessed year and time period under prevailing weather conditions. In a worst-case modelling scenario, two receivers may incur noise levels 5 dBA above the criteria. A further two receivers may incur noise levels slightly below this.

Impacts generally as predicted.

Blasting and vibration

The Project will generally result in additional, rather than larger blasts, using similar blast hole diameters and charge weights as currently utilised. The increase in the average number of blasts per week for the Project is unlikely to result in any damage to receivers.

Impacts as predicted. Although two independent investigations were requested from local residents, there have been no reports of damage resulting from blasting and vibration.

The Project will result in blasts occurring up to approximately 500 metres closer to the nearest Antiene Estate receivers than is currently the case.

Impacts as predicted. Drayton Coal notifies residents in advance of blasting in accordance with the approval.

With careful ongoing management, the OEH’s amenity criteria will continue to be achieved for all blasts.

There have been a considerable number of blast related complaints during the audit period. There have been two exceedences of blast approval limits during the audit period although in both cases, complaints were not received.

Groundwater

The assessment concluded that the simulated groundwater inflow into the Environmental Assessment Boundary will remain unchanged as a result of the Project from current conditions with a predicted peak inflow of 2.7 ML per day.






A search of the Department of Water and Energy database indicates that there are three private groundwater bores within 10 km of the Environmental Assessment Boundary, which may be affected by the Project. A census of these bores will be undertaken to manage any impacts.

Private bores are no longer being used (refer to Section 7.1.3).

Three voids will remain at the cessation of mining as a result of the Project. If these voids are left as open water bodies, they will act as groundwater sinks and the final steady state void water level will be reached after more than 200 years.

This prediction cannot be assessed at this time. To be assessed in future audits.

Flora and fauna

An Assessment of Significance conducted for the Forest Red Gum Open Forest & Woodland determined that the Project is not expected to have a significant impact on this community.

The site inspection appear to support this. To be assessed in future audits.

The ‘Natural Zone’ of the Drayton Wildlife Refuge will not be impacted by the Project and will continue to be managed to enhance its flora and fauna values. The management of this area will compensate for the impacts of the Project on flora and fauna.

Drayton Coal has developed the Northern and Southern Offset Areas. The Northern Offset Area has essentially fenced off an area of the Drayton Wildlife Refuge to leave it untouched.

Rehabilitation, final landform and void

Rehabilitation of land disturbance will continue to occur progressively, aiming to link rehabilitation and remnant vegetation through the establishment of woodland corridors. Rehabilitation will aim to establish as much of the pre-mining floristic diversity as possible.

Rehabilitation is progressing although the DPI expressed concerns in 2011 that Drayton Coal was not achieving their targets (refer to Appendix 1). Rehabilitation processes were raised as concerns in Section 6.5.

It is anticipated the North Pit void may be used for coarse reject emplacement from adjacent mining operations, whilst the South Pit void is expected to retain water. An agreement is in place between Drayton Mine and Macquarie Generation for Macquarie Generation to place fly ash in the East Pit void. The placement of fly ash in this void and its rehabilitation will be the responsibility of Macquarie Generation.

This prediction cannot be assessed at this time as mining activities are still being undertaken in both pits. To be assessed in future audits.

Surface water

The existing mine water management system will be expanded for the Project and while the volume of water managed through the system will generally increase, the water balance will remain substantially unchanged.

Impacts as predicted (refer to Appendix 1).

The upgrade to the Coal Handling Plant will allow the continued reuse and recirculation of water through the water management system.

This is described in the site water balance (as part of the WMP). Current usage and recirculation of water appear to be complying with the WMP.





Visual

This assessment concluded that some viewing sectors surrounding the Project may experience moderate to low visual impacts for short periods until shaping and rehabilitation is completed. No long-term significant visual impact was identified at any of the viewing sectors throughout the life of the Project. The visual effect of lighting associated with the Project will be at a similar level to that currently approved and experienced.

Impacts as predicted. There is one area where the North Pit and its associated emplacements are visible from Thomas Mitchell Drive. Vegetation screening was reportedly not possible. Rehabilitation works are currently underway. Refer to Appendix 1 and Section 7.2. To be assessed in future audits.

The Project extends the timeframe to which direct and diffuse lighting effects will be experienced; however, the level of impact from both direct and diffuse light effects is not considered significant.

Offsite lighting is restricted predominantly to some parts of the rail loader and to lighting around the rail loop. The lighting is similar to street lighting.

Aboriginal archaeology

The majority of material consisted of exposed stone artefacts located within gully features on sloping ground. The Project is likely to impact on a total of 29 of these Aboriginal sites.


The Aboriginal Archaeology and Cultural Heritage Plan will be revised for the Project to facilitate the salvage of the 29 sites identified to be impacted and ensure the continued management and protection of the remaining Aboriginal sites.

Drayton Coal has revised the ACHP in accordance with the approval requirements.

Non-Aboriginal heritage

The field survey identified five Non-Aboriginal heritage sites within the Environmental Assessment Boundary, none of which were statutorily listed. One of these sites was of high local significance and although this site will not be impacted by the Project, a physical barrier will be established around it to prevent accidental damage and maintain its heritage value.

Drayton Coal has installed a physical barrier.

Traffic and transport

The Project is considered to have no significant impacts on the surrounding road network and thus, no significant cumulative impacts are anticipated.


Domestic coal from Drayton Mine will continue to be transported via an overland conveyor to Macquarie Generation’s Bayswater Power Station. Up to 7 Million tonnes per annum of export coal will continue to be railed to the Port of Newcastle from the Antiene Rail Spur as approved in the Antiene Rail Spur Development Consent (DA 106-04-00). No change to rail transport is therefore required for the Project.

Drayton Coal has decommissioned the conveyor and all coal is transported off site via the rail loop and spur.

Waste

Drayton has an existing waste management system which incorporates waste reuse and recycling and addresses all issues relevant to the management of waste.

Waste management on site was found to be in need of improvement (refer to Section 7.2).





The current waste management system and sewage treatment plant will continue to be utilised for the Project. There will be no significant change or additional demand for these waste services as the respective number of employees of each shift will not significantly increase.


Socio-economics

The Project will result in the following approximate economic benefits: The continued employment of 329 employees

whilst potentially providing an additional 59 full time positions.

$374 million in wages and salaries with a predicted flow-on effect to the regional economy of $354 million.

$2,327 million in sales revenue. $135 million in State Government royalties. $110 million in Commonwealth Government

taxes. $2.3 million in contributions to the Australian

Coal Association Research Program.

The Drayton Mine SEAT Report states that between 2009 and 2011, 199.3 million dollars was spent on procurement in Muswellbrook and Singleton. The SEAT also provided payments to government and other authorities in line with predictions.

A Voluntary Planning Agreement has been agreed in principle between Drayton Mine and Muswellbrook Shire Council.

The agreement was reached prior to the audit period.

7.1.2 Antiene Joint User Rail Facility Environmental Impact Statement (2000)

The 2000 EIS allowed for Drayton Coal to operate the existing Drayton Rail Loading Facility to transport up to 7 Mtpa of coal from the loop, and for use of the Antiene Rail Spur up to a limit of 20 Mtpa. This provided capacity for increased saleable export production from the Drayton mine and proposed extensions, if and when approval is sought and granted.

Table 7.2 Antiene Joint User Rail Facility Environmental Impact Statement (2000) assessment of predicted impacts


Air quality

Air quality impacts associated with construction of the Bayswater Rail Loading Facility and operation of the Antiene Joint User Rail Facility are predicted to be low. Dust mitigation measures are proposed for both the construction and operation stages of the development.

Impacts as predicted. No significant amounts of dust were observed from the rail loop or spur during the site inspection.

Noise and vibration

Noise assessment indicates that there will not be a significant noise impact as a result of the proposed development provided that appropriate noise abatement measures are adopted.

Although Drayton Coal has encountered a small number of noise exceedences, they have generally operated within all cumulative assessment limits.





Water quality

During construction of the Bayswater Rail Loading Facility there is potential for water quality impacts to occur. Comprehensive soil and water management controls will be adopted to minimise these impacts.

Impacts to water quality have been minimal with some fluctuations observed in some of the monitoring characteristics. It is important to note that characteristics are within limits Mitigation measures have improved since the unintentional discharge in 2011.

Flora and fauna

The area to be disturbed by construction of the Bayswater Rail Loading Facility is vegetated with grassland and approximately 5.75 hectares of remnant woodland. The flora and fauna surveys conducted for this project indicate that there will be no significant adverse impacts associated with the proposed development. Proposed habitat compensation will lead to an increase in the total area of woodland, once established.

Impacts as predicted. Rail spur is adjacent to the Northern Offset Area.

Visual

The proposed Bayswater Rail Loading Facility is located in an area with high surrounding topography. The topographic relief ensures that the facility is not visible from any residence. Visual impacts from train headlights on a public road adjacent to the proposal development will be mitigated through the provision of visual screens and vegetation corridors. There are no significant visual impacts associated with the existing rail facilities.

Refer to Sections 7.1.1 and 7.2 regarding lighting and visual impacts at the rail loop.

Socio-economic

The construction phase of the development will provide economic benefits to the region as a result of capital expenditure of approximately $40 million. Operation of the facility will ensure that Bayswater and Drayton mines are able to transport coal to market to support continued employment and services in the area.


Cumulative impacts

Cumulative impact assessment of the proposal in conjunction with existing and approved activities within the area has been undertaken in accordance with the recommendation of the Upper Hunter Cumulative Impact Study and Strategy (DUAP 1997). This assessment indicates that there will be no significant adverse cumulative impacts as a result of the development.

A considerable number of complaints are received by Drayton Coal and Mt Arthur Coal. Although Drayton Coal has encountered a small number of noise exceedences, they have generally operated within all cumulative assessment limits.

7.1.3 Project Approval Modification Environmental Assessment (Modification 1)

The first modification to the approval allowed Drayton Coal a minor 8 hectare extension of the approved mining disturbance footprint to the north and the establishment of a new conservation area to provide an appropriate offset for this additional disturbance.

Relevant environmental impact assessments were undertaken in relation to air quality and greenhouse gas emissions, noise, ecology, groundwater, surface water, heritage (both




Aboriginal and Non-Aboriginal), soil and land capability, traffic management, rehabilitation and final landform, spontaneous combustion, visual and waste.

The minor extension to the mining disturbance footprint predicted the removal of 7.5 hectares of vegetation consisting of a fragmented Hunter Lowland Redgum Forest (listed as an Endangered Ecological Community under the Threatened Species Conservation Act 1995) and disturbed grassland that may potentially provide foraging habitat for nine threatened fauna species. This ecological impact is offset through the establishment of an additional 12 hectare area of vegetation adjacent to the Drayton Wildlife Refuge (The Northern Offset Area).

The impact assessments undertaken for the remaining environmental issues determined that the activities associated with the Modification were found to be generally consistent with those approved in the Drayton Mine Extension EA (refer to Section 7.1.1).

7.1.4 East Pit Tailings Emplacement & Explosive Storage Facility Environmental Assessment (Modification 2)

The second modification to the approval allowed Drayton Coal to facilitate the emplacement of raw tailings within the East Pit void. The modification also allowed for the construction and operation of an explosives storage facility at Drayton Coal.

Relevant environmental impact assessments were undertaken in relation to air quality, noise, ecology, groundwater, rehabilitation and final landform, surface water, spontaneous combustion, visual, heritage (both Aboriginal and Non-Aboriginal), traffic management, socio-economic and waste.

The impact assessments undertaken determined that the activities associated with the modification are consistent with those approved in the Drayton Mine Extension EA and the first modification EA.

7.1.5 Project Approval 06_0202 - Statement of Commitments

Performance against the Statement of Commitments (SOC) (provided in Appendix 3 of the approval) was evaluated as part of the audit. The evaluation considered the following aspects:

requirements from the approval take precedence where inconsistencies exist between the approval and the SOC

only requirements from the SOC not included in the approval were evaluated

performance against the applicable SOC was reported via exception only (i.e. only SOC requirements deemed to be non-compliant were reported).




Table 7.2 provides the non-compliant findings from the evaluation of the SOC.

Table 7.3 Performance (via exception) against the Statement of Commitments

Ref. Commitment Audit finding

10 Drayton will undertake a census of privately owned groundwater bores identified in Table 26 to ascertain their current usage and provide a baseline against which to compare any future impacts. In the event of interruption to water supply resulting from the Project, an alternative water supply will be provided.

It was reported that the boreholes in question could not be found. The WMP reports that NOW has formally notified that the boreholes in question are no longer active. Recommendation The Environment Department should submit a request to the DPI to formally remove this commitment.

7.2 Site inspection

As described in Section 2.4.4, a detailed inspection of Drayton Coal (including the rail loop and spur, Photographs 1-2) was undertaken on 30 and 31 October 2012.

The site inspection focused on operational areas of the site, including:

Disturbed areas such as haul roads, stockpiles and pits.

On site monitoring locations (including meteorological) and some monitoring locations outside the project area.

Water storages.

The mine infrastructure area (MIA) including:

Maintenance workshop (heavy and light vehicle) and its associated infrastructure (e.g. stores, fuel/oil storages, wash bay, oil water separators).

Sewage treatment area.

Office and administration buildings.

Bioremediation area.

Rehabilitated areas including areas currently being rehabilitated.

Coal handling and processing plant (CHPP).

The two offset areas.

The rail loop and rail loader.

The rail spur.

The audit team also travelled along Thomas Mitchell Drive adjacent to the project’s northern boundary and viewed the site from the road to determine any adverse visual impacts and the effects of vegetation screening.




Although a number of minor concerns were identified, it was found that environmental management practices on site were generally undertaken in accordance with the approval and respective management plans.

7.2.1 Key observations and compliance issues

The workshop was found to be engineered, constructed and maintained well. The floor of the workshop is sealed and thus provides little opportunity for hydrocarbon contamination. All oil water separators appeared to functioning well and there was no apparent hydrocarbon contamination in water bodies downstream of the separators. Unfortunately, several minor concerns were identified:

Workers were observed degreasing and hosing the workshop floor at a pressure that forced apparently contaminated water past the slit drain catchment area and onto unsealed ground. Although the volume of the water observed during the audit would not pose significant adverse impact, continual/habitual practice (the worker in question stated that this was common practice) may increase remediation/rehabilitation costs post mine closure.

There appeared to be an inadequate supply of spill response and containment equipment available to people in the MIA. It was reported that spill kits are housed in the store and that staff retrieve the kits when required. Only two stocked spill kits were found in the store and it was reported that the contractor that supplies and manages spill kits was currently being replaced. Although it was a concern that spill kits are kept in the store as opposed to being readily available at points of use (thus decreasing the lag time between observed spill, kit retrieval and containment), there are few areas within the MIA that do not have access to secondary containment (all drainage lines feed oil water separators).

Although it was reported that Drayton Coal has recycling initiatives in place, very little evidence of recycling (outside scrap steel) was observed. Almost every general waste bin had recyclable material (Photograph 3) and cross contamination of waste specific bins (i.e. rubbish in the oily rags bins) was evident throughout the MIA.

The bulk diesel tank was inspected and found to be well maintained with an earthen bund of adequate size as the primary containment. Drainage from the bund feeds into an oil water separator which was found to be maintained. The separator feeds into the Access Road Dam (Photograph 4) and no apparent contamination was evident. Unfortunately, it was apparent that workers are shovelling the hydrocarbon contaminated dirt/sludge that collects around the fill point into the bund (Photograph 5). Considering the amount of dried sludge within the bund wall, it is evident that this is a common practice.

Used car and truck batteries were observed being stored outside a designated acid store or in a contained area (Photograph 6).

A considerable amount of litter was observed throughout the MIA.

The truck and light vehicle wash bays and their associated infrastructure (i.e. storage, oil water separator) appeared to be used properly and to be well maintained.

The bioremediation area (Photograph 7) was well maintained with appropriate containment measures installed.




Water management controls on site appear to be working well, with no issues being observed. All dams appeared to be free from contamination (Photographs 4 and 8).

Weed management appeared to be a concern in several areas with infestations evident in low traffic areas (e.g. access track to Savoy Dam, Photograph 8). It was reported that periodic weed spraying was essentially the only weed management measure applied on site and vehicle inspection and washing was not enforced.

The sewage treatment area appeared to be well engineered and maintained.

Much of the project is protected from view due to the natural topography and does not present any significant adverse visual and/or off-site impacts. Parts of the North Pit and its associated emplacements are visible from Thomas Mitchell Drive (Photograph 9) but it was reported that a creek line and the rocky nature of the area prevents natural tree screening. Rehabilitation works have begun on the emplacements which should, over time improve the view from the road.

The fixed lighting around the rail loop is visible from Thomas Mitchell Drive however these are fixed downward with shielding preventing light shining above the horizontal.

Active dust suppression was observed with water carts routinely in operation around haul roads and other disturbed areas. Dust generated from the dragline (Photograph 1) was observed in the South Pit but active dust suppression (fixed water hoses) was observed. It was reported that the dust generation was typical for the dragline. It is appreciated that the dispersive nature of the overburden and the active spontaneous combustion preventing the standard water suppression techniques makes it difficult to effectively control all dust generated. It was noted that the dust generated was comparably low during times where views of the project neighbouring mines were possible. Some public areas adjacent to the project area were inspected. No obvious signs of high amounts of dust (e.g. deposition on vegetation) were observed.

The boundary of the northern offset area (Photograph 10) was appropriately fenced and signposted to prevent access. No evidence of unauthorised access or incursion from mining operations was found.

The southern offset area is not fenced or signposted however it was reported that this will be addressed by early 2013. Access to the offset area is restricted to persons without authority from the Open Cut Examiner (OCE). A considerable hydrocarbon spill that encroached into the offset area from a pump adjacent to the area was identified on the first inspection day (Photograph 11). Initial concern was the poor spill containment and corrective measures applied. Of greater concern was that 24 hours later, the Environmental Coordinator was not aware of the spill and corrective actions had still not been applied (Photograph 12).

All Drayton Coal and subcontractor plant/equipment was observed to be well maintained and used as intended.

All monitoring locations (Photographs 13-14) appeared in working order and to be well maintained.

The office and administration buildings were clean, tidy and well maintained. No leaks were observed from the amenities buildings. Drains and drainage channels appeared to be well maintained with sedimentation control devices installed.




7.2.2 Recommendations

Drayton Coal should revisit hydrocarbon management awareness with maintenance staff. This would include appropriate management of bunds (including disposal of contaminated sludge) and hosing of the maintenance shed.

The Environment Department should ensure that an adequate number of spill containment kits are available on site and that they are stored close to the sites where they are most likely to be needed.

Drayton Coal should review and revise where necessary, waste management measures on site. This review should include:

The availability (and use) of recycling bins.

The availability of acid storage sheds (or equivalent) for waste batteries.

Measures to improve housekeeping/litter control.

Drayton Coal should review and revise where necessary weed spraying measures to control numerous weed outcrops throughout the site. Drayton Coal may also wish to investigate the introduction of vehicle inspection and washing protocols to control weed spread.

The Environment Department should install the fencing and signage at the Southern Offset Area as soon as possible12.

Drayton Coal should complete the incident investigation (and its applicable corrective actions) for the hydrocarbon spill adjacent to the Southern Offset Area as soon as possible with a focus on:

Adequate knowledge of spill management/containment.

Availability of spill containment material.

Communication processes to be implemented during incidents.

7.3 Environment Protection Licence (No. 1323)

A review of the publically available information on the OEH website for EPL No. 1323 was undertaken as part of this audit. The following is a summary of the annual return information for the audit period.

7.3.1 Non-compliances reported during audit period

7.3.1.1 Reporting Period 01 May 2009 – 30 April 2010

Condition L6.1 – Noise limits exceeded at locations 71, 72, 75 and 76. Eight incidents reported.

Condition M9.1 – Failure to monitor at all noise locations specified at Condition L6.1. Six incidents reported.

12 It was reported that the signage was installed in December 2012.




Condition R6.1 – Noise report required by condition R6.1 did not provide results of monitoring LA1(1 minute) noise levels. One incident reported.


Condition A1.2 – ROM coal mined exceeded 5,000,000 tonnes specified on the licence scale for fee based activity (mining for coal). ROM coal for the period was 5,245,176 tonnes.

Condition M2.1 – Monitoring Point 1 (Particulates – Deposited Matter). One monthly sample required by the licence was collected but could not be analysed due to accidental breakage in transit.

Condition M2.1 – Monitoring Point 2 (Total Suspended Particulates). One six daily sample required by the licence was not collected due to operator error. Two other six daily samples were collected on days other than approved run dates.

Condition M2.1 – Monitoring Point 3 (PM10). On 12 days during the period, continuous sampling required by the licence was not undertaken due to an intermittent fault with the monitoring equipment.

Condition M9.1 – Noise compliance assessment was undertaken however does not occur at every location depicted in Table L6.1.


Condition L1.1 – Water discharged from rail loop dam (15 June 2011), reported to OEH (16 June 2011), high intensity rainfall event attributed as cause, rail loop dam desilted, maintenance schedule reviewed to maintain adequate capacity.

Condition L4.1 – Blasting airblast overpressure recorded 122.4dBA at DeBoer monitor (6 May 2011), reported to OEH (12 May 2011), reinforcement, stemming ejection and weather conditions attributed as cause, blast design timing and weather forecast examined to extract improvements, stemming application monitored.

Condition M2.1 – Monitoring Point 2 (Total Suspended Particulates) HVAS equipment failure resulting in three samples collected on days other than the approved run day, cause of equipment failure was attributed to auto timer failure, make up runs were conducted on each occasion to obtain the required number of samples, HVAS equipment replaced on 19 December 2011.

7.4 Annual Environmental Management Reports

7.4.1 2009 Annual Environmental Management Report

7.4.1.1 Air Quality (Dust)

Background levels of deposited matter in the Antiene area, to the north of the mine and in the direction of Drayton’s near neighbours generally remain below the licence requirements of 4g/m2/month. In addition, the DECCW amenity based criteria of a maximum increase in deposited dust levels of 2g/m2/month in the Antiene area was not exceeded during 2009.

Average annual geometric means for total suspended particulates (TSP) for all stations were well below the 90ug/m3 limit and for PM10 was 30ug/m3 (below limits).




With regards to PM10 monitoring, this is undertaken at Lot 9 Antiene. Six instances were recorded where the 50ug/m3 criterion was exceeded. Of these, on four occasions wind direction did not support any influences/contributions from Drayton’s mining operations as wind directions were south-east and north. On the remaining two, other TSP locations also recorded higher than normal levels. These were related to some severe dust days heavily influenced by dry and very hot weather conditions which brought wind and dust storms from Central Australia. All other results at Lot 9 Antiene were reported as being well below the relevant criteria/guidelines.

TSP monitoring was also reported as being undertaken in two locations, to the north of the mining operation (i.e. one to the east of the coal processing plant [met] and the other Lot 22 which is located within the Antiene rural sub-division, close to residential premises). The average TSP levels at Lot 22 were reported as being well within the DECCW guideline. The met station returned one exceedence of the DECCW guideline on 8 December 2009, which was attributed to extreme heat (42.4 Degrees Celsius) and winds from the south.

With respects to dust emission trends, data sets studied throughout the Antiene rural subdivision, generally indicate no increase in dust emissions over a period of in excess of 20 years.

7.4.1.2 Water

There were no off site water discharges during 2009.

A review of the water quality results for the Drayton Rail Loop Dam indicates that the water quality has remained generally stable throughout 2009. Sulphate concentrations are noted as elevated when compared to the min-max range for individual results and the min-max range for average results (as presented in Table 2.5 of the EIS).

Overall, the water quality results at the Drayton Rail Loop Dam do not reflect degradation in water quality.

7.4.1.3 Noise

Ambient background noise monitoring was undertaken by independent consultants and at ad-hoc times selected by the consultants. Up to 12 locations were used and all of these locations were residences located to the north of the mining operations.

Attended monitoring results were reported as overall being acceptable for most periods of independent monitoring. September and December monitoring results were elevated, possibly due to increased wind conditions. No complaints relating to noise were received during the periods of monitoring.

A Barn Owl noise monitoring system is also in operation 24 hours per day providing unattended noise monitoring.

With respect to trends, whilst noise monitoring was conducted randomly during 2009, trends over the period of 1998-2009 show noise levels in Lea are reducing. It must be noted that these figures encompass all noise emissions, which largely are non-mine related. Major noise influences include the New England Highway, Thomas Mitchell Drive, birds, dogs and wind.




7.4.1.4 Blasting

During 2009, a total of 152 blasts took place. No exceedences of either the airblast or vibration levels as per the EPL in force at the time.



All gauges within the Antiene area displayed acceptable levels throughout the year. Background levels in the Antiene area generally remain below licence requirements of 4g/m2/month. In addition the DECCW amenity based criteria of a maximum increase in deposited dust levels of 2g/m2/month in the Antiene area was not exceeded during 2010.

The average annual geometric means for TSP for stations were well below the 90ug/m3 limit and for TEOM monitoring of PM10 was below 30ug/m3.

TSP monitoring was also reported as being undertaken in two locations, to the north of the mining operation (i.e. one to the east of the coal processing plant [met] and the other Lot 22 which is located within the Antiene rural sub-division, close to residential premises). Average TSP levels at Lot 22 were well within DECCW guidelines. During 2010, all results remained below DECCW guidelines.

Real time dust monitoring for PM10 continued throughout 2010. Results indicate the mine is well below its statutory limits for PM10 levels.

7.4.2.2 Water

A small water discharge event occurred during October 2010, where evaporation sprays continued to operate following rainfall. Due to ground saturation from rainfall and high humidity, evaporation sprays led to a water discharge event. This was reported to the then DECCW and a self-report was completed. No further action has been received as at the end of December 2010. Drayton reported that no environmental harm was caused by this incident.

A review of the water quality results for the Drayton Rail Loop Dam (ref: W2114) indicates that the water quality has remained generally stable throughout 2010.

Sulphate concentrations are noted as elevated when compared to the min-max range for individual results and the min-max range for average results (as presented in Table 2.5 of the EIS). TDS and EC were also elevated. All values were within required limits


7.4.2.3 Noise

Attended background noise levels were measured at six stations during 2010. These locations are focussed on the local community and near neighbours.

Results from attended noise monitoring have been compared with long-term averages. 2010 results for the Antiene area generally indicate noise levels are slightly higher for Leq however are lower than the long term averages for L90. In addition to attended monitoring, an independent assessment was also undertaken during April 2010 where results showed




general compliance with the noise criteria, with the exception of minor to moderate (i.e. 1-3dB) exceedences at Sharman and Horder during the evening.

The Barn Owl noise monitoring system remained in operation 24 hours per day providing unattended noise monitoring.

7.4.2.4 Blasting

During 2010, a total of 171 blasts took place, with no reportable exceedences of either the airblast or vibration levels as per the EPL in force at the time.



All gauges within the Antiene area (and in close proximity to all near neighbours) displayed acceptable levels throughout the year. Background levels in the Antiene area remain below the OEH licence requirements of 4g/m2/month. In addition, the OEH amenity based criteria of a maximum increase in deposited dust levels of 2g/month in the Antiene area was not exceeded during 2011.

The average annual geometric means for TSP for the Antiene station were well below the 90ug/m3 limit as well as being slightly down for long-term average compared to 2010. Annual TEOM monitoring for PM10 indicated levels well below 30ug/m3 although monthly averages were slightly higher than in 2010.

TSP monitoring was also reported as being undertaken in two locations, to the north of the mining operation (i.e. one to the east of the coal processing plant [met] and the other at Lot 22 which is located within the Antiene rural sub division, close to residential premises). Average TSP levels at Lot 22 were well within the 90ug/m3 annual criteria.

Real time dust monitoring in the Antiene area for PM10 continued throughout 2011. Results indicated that levels were typically in compliance with statutory limits for PM10 levels. The 24 hour average PM10 results were above the OEH limit of 50ug/m3 twice during the year (i.e. January and October 2011).

On 27 January 2011, the 24 hour average was 60.3 ug/m3 at the TEOM. This was a day of high winds and high temperatures. The Muswellbrook OEH data also indicated that max PM10 levels were very high with a maximum level of 115.73 ug/m3 during this day. Wind on the day was predominantly from the South East with the results not reflecting particulate matter sourced from the Drayton operation.

On 22 October 2011, the 24 hour average was 51.3 ug/m3 at the TEOM. In assessing the 1 hour averages for this day, very high levels of PM10 were recorded in the early hours of the morning which correlated to a strong north wind. The 1 hour averages lowered as the wind speed reduced and turned from the west throughout the rest of the day. On this day, the TEOM was located upwind of the mining operation; hence the results would not have been influenced by the mine.

7.4.3.2 Water

No off site water discharges were reported in 2011.




A review of the water quality results for the Drayton Rail Loop Dam indicates that the water quality remained generally stable throughout 2011.

As with previous years, sulphate concentrations were initially noted as elevated when compared to the min-max range for individual results and the min-max range for average results (as presented in Table 2.5 of the EIS). De-silting works and rainfall influx resulted in reductions of electrical conductivity and salinity.


7.4.3.3 Noise

An independent contractor is engaged by Drayton Coal to conduct quarterly attended noise monitoring to assess compliance. Drayton Coal continues to operate a real time noise monitoring system which operates 24 hours per day.

Results for 2011 attended noise monitoring in the Antiene area generally indicate that noise levels are consistent with long term averages.

7.4.3.4 Blasting

During 2011 a total of 178 blasts took place with one reportable exceedence of the air blast criteria. The exceedence occurred at 3.59 pm on 6 May 2011 during blasting in the East Pit. The blast resulted in an air blast level of 122.4 dB(L) at the de Boer monitor.

The subsequent investigation revealed that a combination of waveform reinforcement, stemming ejection caused by undetected bridging between holes and calm weather conditions at the time of the blast lead to the exceedence occurring. This incident was reported to OEH and DPI. Drayton Coal advised that no complaints were received in relation to the blast and associated exceedence of the air blast criteria.

7.4.4 Critical review of Drayton Coal’s Annual Environmental Management Reports

Condition 5, Schedule 5 of the approval and Condition 8.1, Schedule 2 of the consent requires Drayton Coal to submit an Annual Environmental Management Report.

Refer to Appendices 1 and 2 for a comprehensive assessment of Drayton Coal’s compliance to the specific requirements of the approval and consent respectively.

The following sections provide a critical review of Drayton Coal’s annual reporting. Opportunities for improvement are supplied and should be read in conjunction with the recommendations associated with Drayton Coal’s compliance with the approval and consent conditions (refer to Sections 4 and 5).

7.4.4.1 Noise reporting

The AEMRs should clearly state where noise limits have been complied with and where they have not, rather than providing overall/general assessments. The EPL provides specific noise limits as does the Project Approval for specific receptors.




Opportunities for improvement

Future AEMRs should be revised to present a clearer interpretation of compliance or non-compliance with respect to noise criteria and specific receptors.

7.4.4.2 Complaints reporting

The AEMRs list all received complaints (often referred to as enquiries) in each annual report. It is appreciated that several listed complaints are for the rail spur and are often redirected to Mt Arthur Coal (determined party responsible).

The annual reporting does not provide any significant analysis of the complaints received for each reporting year. If undertaken, such trending analysis would include grouping the complaints against an environmental aspect (e.g. noise, dust etc.), time of day (i.e. day or night operations) and/or types of activities being performed (e.g. rail loading, train movements, blasting, general mining activity etc.).

There is also a lack of response from Drayton Coal in relation to comparing the number and types of complaints against expected/targeted performance. There is very little information provided by Drayton Coal as to whether the number of complaints received in a given year is acceptable (or not), trending from the previous year(s) or what targets and strategies are in place to reduce the number of complaints in a given area or overall.

Opportunities for improvement

Future AEMRs should be revised to include a more comprehensive analysis of complaints received during the reporting period. Drayton Coal may wish to consider including in this analysis:

categorisation of the complaints into their respective environmental aspect (i.e. dust, noise etc.)

categorisation of the complaints into the time of day and type of activity undertaken if possible

trending from the previous reporting period(s)

comparison with corporate performance targets for number and types of complaints received.

Drayton Coal may also wish to include formal objectives and targets for addressing results of the analysis that would be implemented in the following reporting period.

7.5 Mining Lease 1531

Drayton Coal was granted Mining Lease No. 1531 on 26 February 2003.

The mining lease comprises 54 conditions.

Performance against the mining lease conditions was evaluated as part of the audit. The evaluation considered the following aspects:

requirements from the approval take precedence where inconsistencies exist between the approval and the mining lease




only requirements from the mining lease not included in the approval were evaluated

performance against the applicable mining lease conditions was reported by exception only (i.e. only conditions deemed to be non-compliant were reported).

No conditions of the Mining Lease applicable to the abovementioned criteria were assessed as non-compliant.

7.6 Coal Lease 229

Drayton Coal was granted Coal Lease No. 229 on 3 February 1983.

The mining lease comprises 54 conditions.

Performance against the coal lease conditions was evaluated as part of the audit. The evaluation considered the following aspects:

requirements from the approval take precedence where inconsistencies exist between the approval and the coal lease

only requirements from the coal lease not included in the approval were evaluated

performance against the applicable coal lease conditions was reported by exception only (i.e. only conditions deemed to be non-compliant were reported).

No conditions of the Coal Lease applicable to the abovementioned criteria were assessed as non-compliant.




8. Summary of audit findings Table 8.1 provides a summary of non-compliances identified during the audit.

Table 8.1 Summary of audit findings

Reference Finding Recommendation

PA 06_0202 Condition 1, Schedule 3

2009 (Annual Return) – noise limits exceeded at locations 71, 72, 75 and 76 (eight exceedences), failure to monitor at all noise locations specified, noise report did not provide results of monitoring for LA1(1 minute) noise levels. April 2010 Spectrum report – minor to moderate (1-3dB) exceedences at Sharman and Horder during the evening.

Although there are no further actions required regarding the non-compliances associated with the noise monitoring, it is suggested that Drayton Coal request that future Spectrum Acoustics reports clearly provide compliance/non-compliance assessments against the specific project approval conditions that relate to noise.


It was determined that the 2011 AEMR contained a small number of occasions where the night noise limits were exceeded.

Drayton Coal should ensure the recommendations for improvement provided in Section 6.1 are completed.


Two exceedences recorded during audit period 6 May 2011 5 May 2012.



It was determined that at the time of this audit, an updated blasting schedule was not available on the Drayton Coal website. It was reported that all websites dedicated to Anglo American mines are controlled by the corporate office in Brisbane and there was generally a lag time between submitting the data to Brisbane and it getting posted online. It should be noted that Drayton Coal has informed all relevant residents of the blasting information hotline which is also provided on the website. It was reported that the Environmental Coordinator’s contact details are well known to all relevant residents. It is also appreciated that blasting is only undertaken when meteorological conditions are suitable so there are often variations from the schedule.

Drayton Coal should review its website management processes so that either Drayton Coal assumes control of the information uploads or processes are made more efficient at the corporate office.






Drayton Coal does not intentionally discharge water from the site. During the audit period, there were two occasions where water was unintentionally discharged from site and not in accordance with this requirement: 15 June 2011 – approximately

five megalitres (ML) was discharged from the Rail Loop Dam during heavy rain.


The site inspection identified the dams where the discharges took place and found that Drayton Coal had implemented appropriate actions to prevent or minimise the likelihood of future discharges.







It was determined that the existing ESCP is not consistent with the requirements of the Managing Urban Stormwater: Soils and Construction Manual. The following aspects would need to be included for the ESCP to be consistent with the manual: existing site contours, including

catchment area boundaries locations of critical natural areas

requiring special planning or management

stages of mining nature and extent of earthworks,

including cut and fill location of all soil stockpiles location of proposed roads location and types of proposed

erosion control measures site rehabilitation proposals,

including final contours. There is no detail in the ESCP on how erosion will be controlled, particularly erosion resulting from dispersive soils. There is discussion in the ESCP on the use of diversion banks (channel banks) but these are inappropriate for dispersive mine spoil given their tunnel erosion risk. There is discussion of perimeter sediment control measures but no information on what type of sediment dam they are (Type C, D or F) or what chemical treatment might be required. The ESCP describes limited maintenance of sediment control structures and diversion banks but doesn’t provide specific details.

It is recommended that the following aspects of the ESCP be revised (in accordance with the Managing Urban Stormwater: Soils and Construction Manual): existing site contours including

catchment area boundaries locations of critical natural areas

requiring special planning of management

stages of mining nature and extent of earthworks,

including cut and fill locations of all soil stockpiles locations of proposed roads existing and proposed drainage

patterns location and types of proposed

erosion control measures site rehabilitation proposals

including final contours. It is also recommended that the ESCP be revised to include more specific detail regarding the maintenance process for sediment control devices.


The existing Offset Strategy does not describe what measures have been adopted to ensure that adequate resources are dedicated towards the implementation of the offsets. The principles in Appendix 9 are also not thoroughly explained and complied with in the Offset Strategy.

Drayton Coal should revise the Offset Strategy to include: Commitment of resources for the

implementation of offsets. Referencing of appropriate documentation (e.g. the Rehabilitation and Offset Management Plan) will suffice.

A compliance table demonstrating how the offset areas comply with the principles provided in Appendix 9 of the approval.






It was determined that the existing ROMP does not: adequately provide detailed

procedures for progressively rehabilitating areas disturbed by mining

provide procedures for controlling access to the Northern Offset Area.

It was also determined that while Section 7.2 of the ROMP describes the bushfire management process, it is considerably brief and does not provide any detail on how the process is to be achieved. Section 7.2 states that vegetation is to be maintained and managed to ensure a minimum fuel load and no risk of fires. There is no explanation of how vegetation will be managed or maintained. The ROMP provides key performance indicators for the offset areas and the Thomas Mitchell Drive tree screen. Monitoring procedures are provided for the offset areas only.

Drayton Coal should revise the ROMP to include: the short, medium, and long term

measures to implement the Offset Strategy

progressive rehabilitation methodologies for disturbance areas and recently completed mining zones

access management processes for the Northern Offset Area

monitoring procedures for the Thomas Mitchell Drive tree screen.






The FVMP describes the location of the final voids and lists potential future use. It does not include a justification of the locations and the future use of the final voids. The FVMP provides an indication of final water levels but does not provide the verified groundwater modelling predictions to justify these levels. Construction of a bund at the crest has significant potential to contribute to geotechnical and tunnel erosion failure of the highwall(s). Design criteria and specifications have not been provided for critical aspects: slope erosion rates soil/spoil spontaneous combustion soil surface cover wave erosion salinity.

Section 5.6.3 of the plan states that the creeks will not be impacted but provides no science to justify these statements. It simply refers to the 2007 EA. The FVMP does not adequately address measures to minimise any potential adverse impacts associated with the final voids and to manage and monitor the potential impacts of the final voids over time.

Drayton Coal should revise the Final Void Management Plan to include: a justification of the locations and

the future use of the final voids design criteria and specifications justification(s) for the assessment of

potential creek/void interactions measures to minimise any potential

adverse impacts associated with the final voids and to manage and monitor the potential impacts of the final voids over time.


The existing plan provides objectives for mine closure but does not provide adequate criteria. The plan nominates various possible post mine land-uses but does not investigate options. The plan discusses monitoring of environmental effects but does not describe the measures that would be implemented to minimise of manage the on-going environmental effects.

Drayton Coal should revise the Mine Closure Plan to include: mine closure criteria investigation results for post mine

options measures that would be

implemented to minimise and manage the on-going environmental effects.


It was determined that existing AEMR records do not include the times of each train movement.

Drayton Coal should ensure that future AEMRs provide the times of all train movements associated with Drayton Coal.






It was determined that there were three requests to DPI for an independent review of Drayton Coal’s environmental impact during the audit period: De Boer residence on 22

November 2010 and again in mid-2011.

Doherty residence in mid-December 2011.

Drayton Coal commissioned three separate independent reviews in response to the three requests. Suitably qualified, experienced and independent consultancy, SLR, was commissioned in all cases. Commissioning SLR for the first review (de Boer residence) was not undertaken within three months. It was reported that SLR was commissioned for the other reviews within the three month limit. The report for the first independent review was not supplied within three months.



All three AEMRs provide performance results for all environmental aspects associated with Drayton Coal however none of the reports adequately:

Provide performance targets (statutory or initiative) for most of the aspects (air quality parameters are included).

Provide a comparison to the complaints received in the previous reporting period.

include an analysis against: Limits/criteria in this approval. Monitoring results from previous years. Predictions in the EA.

Identify any trends in the monitoring results over the life of the project.

Discuss identified non-compliances.

Drayton Coal should ensure that future AEMRs provide: A comparison to the complaints

received in the previous reporting period. It is also suggested that the type and nature of the complaints are also compared to allow for trending and focus for improvement initiatives.

An analysis against: Limits/criteria in this approval. Monitoring results from previous years. Predictions in the EA.

Trending analysis for all monitoring results.

An improved discussion on identified non-compliances.


It was determined that the previous audit report (AECOM, November 2009) has not been posted or is currently unavailable.

Drayton Coal should ensure that the November 2009 audit report is posted on the Drayton Coal website.





DA 106-04-00 Condition 2.1, Schedule 2

It was reported by both the Environmental Coordinator and the SHE Manager that the Environmental Coordinator has the authority to enforce cease work orders on activities where he is concerned about adverse environmental impacts. However, the position description for Drayton Coal’s Environmental Coordinator does not include authorities or specifically, the authority to order work cessations if necessary.

Drayton Coal should revise the Environmental Coordinator’s position description to include the authority to cease work activities that may cause adverse environmental impact, or require any other reasonable steps to be taken to avoid or minimise unintended or adverse environmental impact.


Section 5.6.3 of the EMS provides a table which details Drayton Coal’s environmental management objectives. Although the environmental objectives include aspects and actions pertinent to the rail loop and spur, there is no direct reference to either the loop or spur and furthermore, performance outcomes during operation and decommissioning of the loop and spur is not included. Section 5.6.4 includes the list of environmental management plans applicable to Drayton Coal and their relationship with applicable approvals and licenses. The consent is not referenced nor are the management plans applicable to the spur and loop (e.g. JAMP). The EMS does not adequately provide: ecological and community

objectives for the rail loop and spur

a strategy for the restoration and management of the areas affected by the rail loop and spur, including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives.

Although it is appreciated that it is unlikely that the rail loop and spur may adversely impact on the economic productivity within the area, the EMS does not adequately discuss this or account for this requirement. Appendix 1 of the EMS allows for regulatory correspondence. No correspondence is recorded. A provision for non-regulatory consultation (e.g. CCC) is not provided.

Drayton Coal should revise the EMS to include a clearer reference to the consent. This would include: providing performance outcomes

during operation and decommissioning of the loop and spur


including the environmental management plans applicable to the loop and spur

providing ecological and community objectives for the rail loop and spur

incorporating a strategy for the restoration and management of the areas affected by the rail loop and spur including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives

defining overall objectives and strategies to protect economic productivity within the area affected by the operations.






It was determined that Section 4.16 of the Water Management Procedure – Rail discusses managing the water system against performance objectives. Although the procedure provides performance objectives (essentially target capacity of the rail loop dam), there are no reporting processes (internal or external/regulatory) provided.

Drayton Coal should ensure that internal and/or external reporting of performance objectives is included in the 2013 consolidation of the WMP and Water Management Procedure – Rail.


It was determined that there are no mechanisms for community consultation provided in the AQMP.

Drayton Coal should revise the AQMP to include appropriate mechanisms for community consultation.

DA 106-04-00 Condition 5.3.1, Schedule 2

It was determined that available monitoring data does not clearly report on the compliance against this condition of the approval.

Refer to Condition 3, Schedule 3 of the approval.

DA 106-04-00 Condition 7, Schedule 2

It was determined that the Environmental Monitoring Program does not include a quality assurance/quality control plan.

Drayton Coal should revise the Environmental Monitoring Program to include a quality assurance/quality control plan which is suitable for all monitoring undertaken on site.

Site inspection Workers were observed degreasing and hosing the workshop floor at a pressure that forced apparently contaminated water past the slit drain catchment area and onto unsealed ground. It was apparent that workers are shovelling the hydrocarbon contaminated dirt/sludge that collects around the fill point into the bund.

Drayton Coal should revisit hydrocarbon management awareness with maintenance staff. This would include appropriate management of bunds (including disposal of contaminated sludge) and hosing of the maintenance shed.

Site inspection There appeared to be an inadequate supply of spill response and containment equipment available to people in the MIA.

The Environment Department should ensure that an adequate amount of spill containment kits are available on site.

Site inspection Although it was reported that Drayton Coal has recycling initiatives in place, very little evidence of recycling (outside scrap steel) was observed. Almost every general waste bin had recyclable material and cross contamination of waste specific bins (i.e. rubbish in the oily rags bins) was evident throughout the MIA. Used car and truck batteries were observed being stored outside a designated acid store or in a contained area. A considerable amount of litter was observed throughout the MIA.

Drayton Coal should review and revise where necessary waste management measures on site. This review should include: the availability (and use) of recycling

bins the availability of acid storage sheds

(or an equivalent) for waste batteries

measures to improve housekeeping/litter.





Site inspection Weed management appeared to be a concern in several areas with infestations evident in low traffic areas (e.g. access track to Savoy Dam).

Drayton Coal should review and revise where necessary weed spraying measures to control numerous weed outcrops throughout the site. Drayton Coal may also wish to investigate the introduction of vehicle inspection and washing protocols to control weed spread.

Site inspection The southern offset area is not fenced or signposted however it was reported that this will be addressed by early 2013.

The Environment Department should install the fencing and signage at the Southern Offset Area as soon as possible.

Site inspection A considerable hydrocarbon spill that encroached into the offset area from a pump adjacent to the area was identified on the first inspection day. Initial concern was the poor spill containment and corrective measures applied. Of greater concern was that 24 hours later, the Environmental Coordinator was not aware of the spill and corrective actions had still not been applied.

Drayton Coal should complete the incident investigation (and its applicable corrective actions) for the hydrocarbon spill adjacent to the Southern Offset Area as soon as possible with a focus on:

adequate knowledge of spill management/containment

availability of spill containment material

communication processes of the incident to the Environmental Coordinator.

Statement of Commitments, Commitment 10

It was reported that the boreholes in question could not be found. The WMP reports that NOW have formally notified that the boreholes in question are no longer active.

The Environment Department should submit a request to the DPI to formally remove this commitment.

Table 8.2 provides a summary of recommendations determined from the evaluation of the adequacy of Drayton Coal’s plans, programs, strategies and reports.

Table 8.2 Summary of recommendations for improvements

Plan, program, strategy or report

Recommendation

Noise Management Plan

Drayton Coal may wish to consider revising the NMP to include the following: Noise monitoring data at the identified receiver locations could be

summarised to identify trends in ambient noise and also any measurable contribution from mine operations. The last twelve months of data would be a viable period to consider.

The noise management measures in Section 5.4 and 5.8 could be consolidated and cross referenced to specific activity and measured noise levels – this should provide a singular point in the plan for staff to turn to in the event of a noise issue.

Specific detail could be provided on what monitoring and management measures are contained within the Joint Acquisition Management Plan – the NMP only states this joint venture is in place but provides no details, timeframes or specific responsibilities for Drayton Coal.

All monitoring could be confirmed to be consistent with guidance in relevant Australian standards, including the calibration of all equipment.





Recommendation

Blast Management Plan

Drayton Coal may wish to consider revising the BMP to include the following: All measures undertaken by the blast contractor to minimise impacts

could be detailed in the plan. The plan currently assigns the responsibility for achieving the blasting criteria on to the contractor – there should be specific direction for how blasts are controlled.

The blasting and meteorological monitoring procedures and methodologies provided in Section 4.6.4 could be revised to include more detail including maps of monitoring locations, specifications for measurements and historical results. In the event there are any issues or the plan is handed to another staff member, there may not be enough information to maintain current systems.

Any properties that have been already surveyed could be listed in Section 4.6.12.

Section 4.6.14 should be revised to be more consistent with the reporting requirements in the approval.

Spontaneous Combustion Management Plan

Drayton Coal may wish to revise the SCMP to include: A more comprehensive objective that conveys a health and safety aspect as well as identifying the key mining legislation and guideline requirements such as: Coal Mine Health & Safety Act 2002. Mining Design Guideline (MDG) 1006: Spontaneous Combustion Management Guideline (May 2011) A shorter period between reviews of the plan (i.e. every two years) and to include a revision response approach to changing conditions such as after: – A major spontaneous combustion event. – Significant change in mining systems, conditions or

circumstances. – Change of management structure. A more proactive hazard identification process that requires some fundamental testing to be applied to assess the spontaneous combustion risk. Drayton Coal should investigate incorporating the suggested test procedure that can quantify the time taken to reach thermal runaway for a given mine condition.

It is suggested that Drayton Coal investigate the feasibility of unmanned aerial vehicle investigation (potentially as a research project) for developing leading practice in spontaneous combustion identification and management.

Drayton Coal may wish to revise six monthly reporting of spontaneous combustion events by including additional analysis of events (e.g. rain events) to establish seasonal effects as a precursor to promoting spontaneous combustion.





Recommendation

Air Quality Management Plan

Drayton Coal should proceed with the installation of the real-time air quality monitoring network as soon practicable. The location of each of the monitors should be reviewed in consultation with an air quality specialist. It is also recommended that a full review of air monitoring network is undertaken to assess validity, adequacy and appropriateness of the current monitoring locations and those that are being operated in conjunction with other nearby mining operations.

Drayton Coal may wish to consider undertaking an internal audit of the all dust deposition gauges to assess compliance with AS3580.1.1:2007 and AS3580.10.1:2003.

Drayton Coal may wish to revise the AQMP so to: Clarify and update the air monitoring network information. This would include providing a table indicating location of monitors (numbered), monitor averaging periods, location coordinates and primary purpose (i.e. monitoring of sources, background, sensitive receptor). Figure 1 in AQMP should be updated accordingly. Provide the air quality monitoring program as an appendix to the AQMP. This allows for the continuous improvement of the monitoring plan in line with the most up to date information on the air quality monitoring network. Amend the air quality control management practices for dust suppression to take into account the best management practices described in the NSW Coal Mining Benchmarking Study: International Best Practice measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining. Ensure that the adopted management practices are more definitively described, actioned and listed with consideration to each mining activity for personnel referencing the AQMP. The suggested actions should also take into account prevailing meteorological conditions, wind sensitive and wind insensitive emissions sources.

Water Management Plan

Drayton Coal may wish to revise the WMP to include the following: Details on the methodology for the estimated values of water

demands, including how variability of demands in different climatic conditions are taken into account.

A stochastic site-wide water balance model is developed and verified for the available historical data.

A calculation of maximum runoff based on catchment area, rainfall and soil types to determine flow contributions from:

Upstream catchment. Mine site. Downstream catchment to Hunter confluence.

This will demonstrate the insignificance of runoff affectation by the site. Methodologies for surface water monitoring including:

Timing. Chains of custody protocols. Quality assurance procedures.





Recommendation

Landscape Management Plan

Drayton Coal may wish to adopt the following strategies and recommended improvements to their erosion and sediment control and rehabilitation methodologies: Undertake a first principles review of suitable post mine land-use(s) for

Drayton Coal. It is likely that a biodiversity post mine land-use is the only appropriate use for spoil dumps and low walls.

Test and characterise mine soils and spoils. Ameliorate spoils, sub-soils and topsoil to improve growing conditions for vegetation.

Test and ameliorate soils in already rehabilitated areas to improve rehabilitation performance.

Develop specifications for all aspects of rehabilitation and implement quality assurance processes to demonstrate compliance with specifications.

Undertake spoil erosion assessment and erosion modelling to determine an appropriate slope gradient.

Remove channel banks where adequate vegetation cover exists to return drainage to sheet flow conditions instead of concentrated flow conditions.

Test and ameliorate spoil and soil to increase infiltration, to reduce runoff and improve revegetation performance.

Limit the height of topsoil stockpile to 1.5 metres. Test topsoil prior to stripping and ameliorate during the stripping process. Revegetate topsoil stockpiles as soon as possible.

Retain cleared vegetation and manage on site to form compost. Ameliorate the topsoil with sufficient phosphorous, calcium and organic carbon levels (and other ameliorants as determined by soil and plant tissue testing) to establish open woodland communities.

Aboriginal Cultural Heritage Plan


Greenhouse and Energy Efficiency Plan

Drayton Coal may wish to revise the GEEP to include the following: Baseline and historical data on greenhouse gas and energy

consumption data compared and trended over subsequent revisions with updated monitoring information.

A revised list of improvement measures which commit to actual measures with specified and detailed actions and associated methodologies, accountabilities and performance indicators.

A protocol for periodically assessing performance and applying corrective actions where necessary.

Environmental Management Strategy






Recommendation

Annual Environmental Management Report

Future AEMRs should be revised to present a clearer interpretation of compliance or non-compliance with respect to noise criteria and specific receptors.

Future AEMRs should be revised to a more comprehensive analysis of complaints received during the reporting period. Drayton Coal may wish to consider including in this analysis:

Categorisation of the complaints in their respective environmental aspect (i.e. dust, noise etc.). Categorisation of the complaints into the time of day and type of activity undertaken if possible. Trending from previous reporting period(s). Comparison with corporate performance targets for number and types of complaints received.

Drayton Coal may also wish to include formal objectives and targets for addressing results of the analysis that would be implemented in the following reporting period.




9. References Beamish, B and Beamish, R, 2012. Testing and sampling requirements for input to

spontaneous combustion risk assessment, in Proceedings of the Australian Mine Ventilation Conference, B Beamish and D Chalmers (eds), pp 15-21 (The Australasian Institute of Mining and Metallurgy: Melbourne).

Katestone Environmental, NSW Coal Mining Benchmarking Study: International Best Practice measures to Prevent and/or Minimise Emissions of Particulate Matter from Coal Mining (Benchmark Study), 2011

Malos, J, Beamish, B, Munday, L, Reid, P and James, C, 2013. Remote monitoring of subsurface heatings in opencut coal mines, (in Press), Proceedings of Coal Operators’ Conference, February 2013, Wollongong.

NSW Department of Industry & Investment, Mine Safety Operations Branch, 2011. MDG 1006: Spontaneous Combustion Management Guideline, May 2011, www.resources.nsw.gov.au/__data/assets/pdf_file/0007/419515/MDG-1006.pdf.

Appendix 1

PA 06_0202 checklist

Appendix 1 PA 06_0202 checklist

PARSONS BRINCKERHOFF 2172813A/PR_0665 Page 1.1

Table A1 Drayton Coal Compliance Audit (PA 06_0202) – Approval Conditions Checklist

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n Requirement Finding Recommendation Rating

2 1 The Proponent shall implement all practicable measures to prevent and/or minimise any harm to the environment that may result from the construction, operation, or rehabilitation of the project.

The site inspection found that the site was managing the majority of their respective environmental impacts well. Minor concerns were identified with respect to waste management and spill response but these issues were contained within the site and should not present major issues off site (refer to Section 7.2). Some issues were identified with the air quality, spontaneous combustion and rehabilitation management practices on site (refer to Section 6).

Refer to Sections 6 and 7.2 for opportunities for improvement.

C

2 2(a) The Proponent shall carry out the project generally in accordance with the EA.

Refer to Section 7.1.1. Although some opportunities for improvement were identified, Drayton Coal can be considered operating in general accordance with the EA (Document 1).

Nil C

2 2(b) The Proponent shall carry out the project generally in accordance with the statement of commitments.

Refer to Section 7.1.2. Although Drayton Coal was found to be non-compliant with Commitment 10 from the SOC, Drayton Coal can be considered operating in general accordance with the SOC.

Nil C

2 2(c) The Proponent shall carry out the project generally in accordance with the EA (Mod 1).

Refer to Section 7.1.1. Drayton Coal can be considered operating in general accordance with the EA - Mod 1 (Document 2).

Nil C

2 2(d) The Proponent shall carry out the project generally in accordance with the EA (Mod 2).

Refer to Section 7.1.1. Drayton Coal can be considered operating in general accordance with the EA - Mod 2 (Document 3).

Nil C



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2 2(e) The Proponent shall carry out the project generally in accordance with the conditions of this approval.

This requirement is assessed throughout this report. Refer to Section 4.

Refer to Section 4. N/A



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2 4(a) The Proponent shall comply with any reasonable requirement/s of the Director-General arising from the Department’s assessment of any reports, plans, programs, strategies or correspondence that are submitted in accordance with this approval.

It was reported that seven applicable requests (Documents 4-10) have been received from DPI during the audit period: February 2011 – requesting website upload

of previous audit report and the LMP. Drayton Coal reported that the website issues had been addressed.

6 May 2011 – requesting that blast designs are monitored and that all blasts are videoed. Drayton Coal reported that this happens.

9 May 2011 – requesting revising the community hotline processes. Drayton Coal reported that the community hotline process is consistent with the Environmental Enquiries Procedure approved by the DPI.

27 May 2011 – identified 11 issues with the 2010 AEMR and requested corrective actions. Drayton Coal provided a report to the Audit Team (Document 47). Of the 11 issues raised, 9 were completed and the remaining 2 issues are being rectified on an ongoing basis.

13 July 2011 – requesting desilting the Rail Loop Dam and a timetable for installing a telemetry system. Dam was desilted.

22 September 2011 – requesting relocation of desilted material from the Rail Loop Dam. The site inspection found no signs of the original stockpile of desilted material in question.

7 December 2011 – requesting feedback regarding a community complaint. Drayton Coal adequately responded.

Nil C



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2 4(b) The Proponent shall comply with any reasonable requirement/s of the Director-General arising from the Department’s assessment of the implementation of any actions or measures contained in these reports, plans, programs, strategies or correspondence.

Refer to Condition 4(a), Schedule 2 of PA 06_0202.

Nil C

2 4A Within 3 months of any modification to this approval, the Proponent shall review and if necessary revise any strategies/plans/programs required under this approval which are relevant to the modification to the satisfaction of the Director-General.

Submission dates for revised plans resulting from Mod 2 are triggered after the audit period. Refer to Section 6.

Nil C

2 5 Mining operations may take place on the site until 31 December 2017.

The mine is currently in operation. Nil N/A

2 6 The Proponent shall not extract or process more than 8 million tonnes of ROM coal a year on site.

All three AMERs reported that ROM production for 2009-2011 was within approval limits. Drayton Coal – Coal Production Statistics – Fiscal Period Oct-2012 (Document 11) was reviewed. The report stated that year-to-date production totalled 4,391,269 tonnes extracted and 4,571,743 tonnes of ROM coal processed.

Nil C

2 7 The Proponent shall only transport coal from the site by rail or overland conveyor.

The site inspection found no evidence of coal being transported on public roads by truck.

Nil C

2 8 Within 12 months of this approval, the Proponent shall surrender all previous development consents for the Drayton coal mine to the satisfaction of the Director-General.

This requirement was triggered prior to the audit period.

Nil N/A

2 9 With the approval of the Director-General, the Proponent may submit any strategy, plan or program required by this approval on a progressive basis.

It was reported that management plans and/or programs by the nature of the required submission dates, have been submitted progressively.

Nil N/A



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2 10 The Proponent shall ensure that all new buildings and structures, and any alterations or additions to existing buildings and structures are constructed in accordance with the relevant requirements of the BCA.

It was reported that a coal treatment facility was constructed in the audit period. The facility was commissioned in April 2011 and is an addition to the existing CHPP. The construction certificate (Document 12) was issued on 4 July 2011.

Nil C

2 11 The Proponent shall ensure that all demolition work is carried out in accordance with AS 2601-2001: The Demolition of Structures, or its latest version.

It was reported that no demolition works was undertaken during the audit period.

Nil N/A

2 12(a) The Proponent shall ensure that all plant and equipment used at the site is maintained in a proper and efficient condition.

The site inspection found that most plant observed on site to be well maintained. A pump adjacent to the Southern Offset Area was found to be leaking hydrocarbons (Photographs 11-12). The audit team is comfortable with this being an atypical occurrence. It was reported that all machinery are logged and maintained in accordance with manufacturer’s specifications. Refer to Section 7.2.

Nil C

2 12(b) The Proponent shall ensure that all plant and equipment used at the site is operated in a proper and efficient manner.

The site inspection did not observe any plant or equipment The dragline operator was observed maintaining as low as possible tip and scrape heights. Refer to Section 7.2.

Nil C

2 13(a) Within 12 months of this approval, the Proponent shall enter into a planning agreement with Council and the Minister, in accordance with Division 6 of Part 4 of the EP&A Act.


Nil N/A



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2 13(b) Within 12 months of this approval, the Proponent shall enter into a planning agreement with Council and the Minister, in accordance with the terms of the Proponent’s offer to the Council on 19 January 2007, which includes the matters set out in Appendix 4.


Nil N/A



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3 1 The Proponent shall ensure that the noise generated by the project does not exceed the noise impact assessment criteria in Table 1 at any residence on privately-owned land.

The relevant EPL Annual Returns (the noise limits in the EPL are consistent with the approval) were reviewed. 2009 (Annual Return) – noise limits

exceeded at locations 71, 72, 75 and 76 (eight exceedences), failure to monitor at all noise locations specified, noise report did not provide results of monitoring for LA1(1 minute) noise levels.

2010 (Annual Return) – noise compliance assessment while undertaken did not occur at every location depicted in EPL.

2011 (Annual Return) – no non-compliances reported.

Drayton Coal employ specialised consultancy Spectrum Acoustics to undertake six monthly acoustics reports. April 2010 report – minor to moderate (1-

3dB) exceedences at Sharman and Horder during the evening.

September 2010 report – no exceedences. April 2011 report – no exceedences. August 2011 report – no exceedences. March 2012 report – no exceedences. September 2012 report – Minor to moderate

(2-3 dB) exceedences at Sharman and Horder recorded when wind speeds were above the upper 3m/s limit of wind speeds for noise criteria to be applicable.

Although there is no further actions required regarding the non-compliances associated with the noise monitoring, it is suggested that Drayton Coal request that the consultant’s report clearly provide compliance/non-compliance assessments against the specific project approval conditions that relate to noise.

NC



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3 1 The Proponent shall ensure that the noise generated by the project does not exceed the noise impact assessment criteria in Table 1 on more than 25% of any privately-owned land.

Refer to Condition 1, Schedule 3 of PA 06_0202.


NC

3 2 If the noise generated by the project exceeds the criteria in Table 2 at any residence on privately-owned land or on more than 25 percent of any privately-owned land, the Proponent shall, upon receiving a written request for acquisition from the landowner, acquire the land in accordance with the procedures in conditions 8-10 of Schedule 4.

It is noted that 2009 and 2010 noise monitoring data was incomplete. 2011 noise monitoring data reviewed by the audit team indicates that this requirement has not been triggered.


C

3 3 The Proponent shall take all reasonable and feasible measures to ensure that the noise generated by the project combined with the noise generated by other mines does not exceed the following amenity criteria at any residence on privately-owned land: LAeq(11 hour) 50 dB(A) – Day LAeq(4 hour) 45 dB(A) – Evening LAeq(9 hour) 40 dB(A) – Night.

Review of the 2011 AEMR highlighted a small number of occasions where the noise limits for night were exceeded.

Refer to Section 6.1. NC



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3 3 The Proponent shall take all reasonable and feasible measures to ensure that the noise generated by the project combined with the noise generated by other mines does not exceed the following amenity criteria on more than 25 percent of any privately owned land: LAeq(11 hour) 50 dB(A) – Day LAeq(4 hour) 45 dB(A) – Evening LAeq(9 hour) 40 dB(A) – Night.



NC

3 4 If the noise generated by the project combined with the noise generated by other mines exceeds the following amenity criteria at any residence on privately owned-land or on more than 25 percent of any privately owned land, then upon receiving a written request from the landowner, the Proponent shall acquire the land on as equitable basis as possible with the relevant mines in accordance with the procedures in conditions 8-10 of Schedule 4: LAeq(11 hour) 53 dB(A) – Day LAeq(4 hour) 48 dB(A) – Evening LAeq(9 hour) 43 dB(A) – Night.

It was reported that a formal request for acquisition request (in accordance with this requirement) was received at the same time the request for an independent review was requested (refer to Condition 3, Schedule 4 of PA 06_0202). Noise limits had not exceeded the criteria at the landowner’s property (refer to Condition 4, Schedule 4 of PA 06_0202). It was reported that Drayton Coal sought an independent property valuation and made an offer based on the valuation. A counteroffer was made by the resident which was refused by Drayton Coal. It was reported that the acquisition processes was suspended by both parties.

Nil N/A



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3 5 Within 12 months of this approval, unless otherwise agreed by the Director-General, the Proponent shall implement the noise mitigation measures outlined in Section 4.5 of the noise impact assessment, of the EA (see Appendix 6).

Of the 10 items listed in Appendix 6, the following is summary of the current status of implementation: Item 1 – implemented, mine planning

ensures compliance with this requirement. Item 2 – implemented, tip edges shielded as

part of normal operations. Item 3 – implemented, haul roads have been

located below pit level in the North Pit area. Item 4- implemented, loading units are

operated below natural surface in the NN area during evening and night operations.

Item 5 – Not implemented (no change in haul routes required as yet).

Item 6 – Not implemented (new ROM stockpile not constructed yet).

Items 7 – Not implemented (new ROM stockpile not constructed yet).

Item 8 – Not implemented (new reclaimers and stacker have not eventuated).

Item 9 – Implemented (completed in February 2008).

Item 10 – All 789 trucks at Drayton have upgraded mufflers on them (completed in February 2010).

The audit team notes that Drayton Coal has not formally advised DPI of those measures which will not be implemented due to changes in business cases or planned mining activities.

Nil C



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3 6 Upon receiving a written request from the owner of land 14, 16, 19, 20, 21, 22, 28, 32, 33, 61, 69, 70, 71, 72, 75, 76, 86, the Proponent shall implement additional reasonable and feasible noise mitigation measures (such as double glazing, insulation, and/or air conditioning) at the residence in consultation with the landowner. These additional mitigation measures must be reasonable and feasible.

It was reported that two neighbouring residences (numbers 22 and 76) verbally requested air conditioners from Drayton Coal. Although not receiving written requests, Drayton Coal installed air conditioners in both residences. Records were reviewed for one of the air conditioners purchased in May 2012 (Documents 13-14).

Nil C

3 6 Upon receiving a written request from the owner of any residence on privately-owned land where subsequent noise monitoring shows the noise generated by the project is greater than or equal to the relevant criteria in Table 3, the Proponent shall implement additional noise mitigation measures such as double glazing, insulation, and/or air conditioning at any residence on the land in consultation with the landowner. These additional mitigation measures must be reasonable and feasible.

It was reported that Drayton Coal did not receive any written requests for additional noise mitigation measures.

Nil N/A

3 6 If within 3 months of receiving this request from the landowner, the Proponent and the landowner 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 Director-General for resolution.


Nil N/A



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3 6 Within 3 months of this approval, the Proponent shall notify all applicable landowners that they are entitled to receive additional noise mitigation measures.

This requirement was triggered before the audit period. The previous audit determined Drayton Coal to be compliant with this requirement (Document 15).

Nil N/A

3 7(a) The Proponent shall implement all reasonable and feasible noise mitigation measures.

During the review of the NMP, it was determined that the plan adequately provide the conditions or approval and an overview of monitoring. The plan also adequately defines the environmental requirements and how potential blast levels are measured. Refer to Section 6.1 for more information including opportunities for improvement.

Refer to Section 6.1. C

3 7(b) The Proponent shall investigate ways to reduce the noise generated by the project, including maximum noise levels which may result in sleep disturbance.



3 7(c) The Proponent shall report on these investigations and the implementation and effectiveness of these measures in the AEMR.

Refer to Section 7.4.4. Refer to Section 7.4.4. C

3 8 The Proponent shall prepare and implement a Noise Management Plan for the project to the satisfaction of the Director-General.

Drayton Coal has prepared and implemented the NMP (Document 16).

Nil C

3 8(a) The Noise Management Plan must be be submitted to the Director-General by 31 October 2012 for approval.

The NMP was submitted to DPI on 31 October 2012 (Document 17). The DPI has approved a request for the submission of the NMP to March 29 2013 to allow for amendments resulting from this report (refer to Section 6). Although Drayton Coal is currently operating under the existing NMP, this audit report will assess the draft revision in accordance with the request from DPI (refer to Section 3).

Nil C



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3 8(b) The Noise Management Plan must describe the measures that would be implemented (including a real-time noise management system that employs both reactive and proactive mitigation measures) to ensure best management practice is being employed and compliance with the relevant conditions of this approval.

Sections 5, 5.1 and 5.2 of the NMP provide the relevant conditions from the approval and the consent and the criteria/method for compliance. Section 5.4 provides the noise control and mitigation measures including a real-time noise management system. Measures provided in the NMP include reactive and proactive actions however refer to Section 6.1 for a review of these measures.


3 8(c) The Noise Management Plan must describe the proposed noise management system in detail.

Section 5.2 provides the noise monitoring program.

Nil C

3 8(d) The Noise Management Plan must include a noise monitoring program that: uses a combination of real-time and

supplementary attended monitoring measures to evaluate the performance of the project;

adequately supports the proactive and reactive noise management system on site;

includes a protocol for determining exceedences of the relevant conditions in this approval;

evaluates and reports on the effectiveness of the noise management system on site;

provides for the annual validation of the noise model for the project.

The NMP satisfies the requirements of the condition. Refer to Section 6.1 for identified opportunities for improvement.

Nil C



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3 8(e) The Noise Management Plan must include a protocol that has been prepared in consultation with the owners of nearby mines (including the Mt Arthur mine) to minimise the cumulative noise impacts of the mines.

The NMP refers to the JAMP however as Section 6.1 describes, more information should be included.

Refer to Section 6.1 C

3 9 The Proponent shall ensure that the airblast overpressure level from blasting at the project does not exceed the criteria in Table 4 at any residence on privately-owned land.

Relevant AEMRs were reviewed: AEMR (2009) – No exceedences reported. AEMR (2010) – No exceedences reported. AEMR (2011) – One excceedance (6 May

2011, 122.4dB(L). Year To Date (2012) – One exceedence (5 May 2012, 121.2dB(L).

No further action required. NC

3 10 The Proponent shall ensure that the ground vibration level from blasting at the project does not exceed the criteria in Table 5 at any residence on privately-owned land.

All monitoring data reviewed for the audit period indicated that vibration levels were compliant for all relevant blasts

Nil C

3 11 The Proponent shall only carry out blasting on the site between 9am and 5pm Monday to Saturday (EST), and 9am to 6pm Monday to Saturday (DST) inclusive.

Review of blast records for the audit period did not identify any non-complying blast times and/or dates.

Nil C

3 11 No blasting is allowed on Sundays, public holidays, or at any other time without the written approval of OEH.


Nil C

3 12(a) The Proponent may carry out a maximum of 2 blasts a day averaged over a 12 month period.

Review of blast records for the audit timeframe did not identify any non-compliance associated with this condition.

Nil C



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3 12(b) The Proponent may carry out a maximum of 8 blasts a week, averaged over a 12 month period.

Drayton Coal and the audit team believe that this requirement conflicts with that of Condition 12(a), Schedule 3 of PA 06_0202. As such, Drayton Coal has adopted Condition 12(a) as the limiting criteria. It was suggested that Drayton Coal seek formal clarification from DPI regarding the blasting limits for site.

Nil C

3 13(a) During mining operations, the Proponent shall implement best blasting practice to protect the safety of people and livestock in the area surrounding blasting operations to the satisfaction of the Director-General.

During the review of the BMP, it was determined that the plan adequately provide the conditions or approval and an overview of monitoring. The plan also adequately defines the environmental requirements and how potential blast levels are measured. Refer to Section 6.1 for more information including opportunities for improvement.


3 13(a) During mining operations, the Proponent shall implement best blasting practice to protect public or private infrastructure/property in the area surrounding blasting operations from blasting damage to the satisfaction of the Director-General.





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3 13(a) During mining operations, the Proponent shall implement best blasting practice to minimise the dust and fume emissions from blasting at the project to the satisfaction of the Director-General.

Refer to Condition 13(a), Schedule 3 of PA 06_0202. It was reported that spontaneous combustion precautions precipitate the use of inhibited explosives (to prevent spontaneous explosion whilst loading). It was reported the inhibited explosive may lead to increased fuming however Drayton Coal stated that dust and fume emissions have not been an issue. No blasts were shot during the site component of the audit.


3 13(b) During mining operations, the Proponent shall co-ordinate blasting on site with the blasting at the adjoining Mt Arthur coal mine to minimise the potential cumulative blasting impacts of the two mines to the satisfaction of the Director-General.

It was reported that Drayton Coal contacts Mt Arthur Coal prior to a blast as part of the blasting protocol. It was also reported that Mt Arthur do the same. No blasts were shot during the site component of the audit.

Nil C

3 14(a) The Proponent shall not undertake blasting within 500 metres of Thomas Mitchell Drive without the approval of Council.

Approval was sought and granted from MSC prior to the audit period.

Nil C

3 14(b) The Proponent shall not undertake blasting within 500 metres of any privately-owned land or land not owned by the Proponent, unless suitable arrangements have been made with the landowner and any tenants to minimise the risk of flyrock-related impact to the property to the satisfaction of the Director-General.

It was reported that no privately owned land is within 500 metres of the North Pit, the closest area to residents where blasting occurs.

Nil N/A



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3 16(a) During mining operations, the Proponent shall notify the landowner/occupier of any residence within 2 kilometres of the site who registers an interest in being notified about the blasting schedule at the mine to the satisfaction of the Director-General.

It was reported that Drayton Coal telephones the four residences neighbouring the north side of the site prior to any blast in the North Pit. Drayton Coal also sends letters to potentially affected residents informing them of upcoming closures of Thomas Mitchell Drive (Document 18).

Nil C

3 16(b) During mining operations, the Proponent shall operate a Blasting Hotline, or alternate system agreed to by the Director-General, to enable the public to get up-to-date information on the blasting schedule at the mine to the satisfaction of the Director-General.

Drayton Coal operates a blasting hotline (02 6542 0328).

Nil C

3 16(c) During mining operations, the Proponent shall advertise the blasting hotline number in a local newspaper at least 4 times each year to the satisfaction of the Director-General.

It was reported that Drayton Coal advertises the blasting hotline in the two local newspapers every three months.

Nil C



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3 16(d) During mining operations, the Proponent shall publicise an updated blasting schedule on its website to the satisfaction of the Director-General.

At the time of this audit, an updated blasting schedule was not available on the Drayton Coal website. It was reported that all websites dedicated to Anglo American mines are controlled by the corporate office in Brisbane and there was generally a lag time between submitting the data to Brisbane and it getting posted online. It should be noted that Drayton Coal has informed all relevant residents of the blasting information hotline which is also provided on the website. The blasting schedule is advertised in local newspapers four times a year. It was reported that the Environmental Coordinator’s contact details are well known to all relevant residents. It is also appreciated that blasting is subject to meteorological conditions as such, often vary from the schedule.

It is recommended that Drayton Coal review their website management processes so that either Drayton Coal assumes control of the information uploads or processes are made more efficient at the corporate office.

NC

3 17 Within 6 months of this approval, the Proponent shall advise all landowners of privately-owned land within 2 kilometres of the project that they are entitled to a structural property inspection.


Nil N/A

3 18(a) If the Proponent receives a written request for a structural property inspection from any of these landowners, the Proponent shall within 3 months of receiving this request commission a suitably qualified, experienced and independent person, whose appointment has been approved by the Director-General, to inspect the condition of any building or structure on the land, and recommend measures to mitigate any potential blasting impacts.

One independent structural assessment was requested and commissioned during the audit period. It was reported that the report was commissioned, actioned and delivered within three months. The report determined that there was no structural damage attributable to Drayton Coal.

Nil C



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3 18(b) If the Proponent receives a written request for a structural property inspection from any of these land owners, the Proponent shall within 3 months of receiving this request give the landowner a copy of the property inspection report.


Nil C

3 19(a) If any landowner of privately owned land within 2 kilometres of the site claims that buildings and/or structures on his/her land have been damaged as a result of blasting at the project, the Proponent shall within 3 months of receiving this claim, commission a suitably qualified, experienced and independent person, whose appointment has been approved by the Director-General, to investigate the claim;


Nil C

3 19(b) If any landowner of privately owned land within 2 kilometres of the site claims that buildings and/or structures on his/her land have been damaged as a result of blasting at the project, the Proponent shall within 3 months of receiving this claim, give the landowner a copy of the property investigation report;


Nil C



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3 19 If this independent property investigation confirms the landowner’s claim, and both parties agree with these findings, then the Proponent shall repair the damages to the satisfaction of the Director-General. If the Proponent or landowner disagrees with the findings of the independent property investigation, then either party may refer the matter to the Director-General for resolution. If the matter cannot be resolved within 21 days, the Director-General shall refer the matter to an Independent Dispute Resolution Process (see Appendix 10).


Nil N/A

3 20 The Proponent shall prepare and implement a Blast Management Plan for the project to the satisfaction of the Director-General

Drayton Coal has prepared and implemented the BMP (Document 19).

Nil C

3 20(a) The Blast Management Plan must be submitted to the Director-General for approval by 31 October 2012.

The BMP was submitted to DPI on 31 October 2012 (Document 17). The DPI has approved a request for the submission of the BMP to March 29 2013 to allow for amendments resulting from this report (refer to Section 6). Although Drayton Coal is currently operating under the existing BMP, this audit report will assess the draft revision in accordance with the request from DPI (refer to Section 3).

Nil C

3 20(b) The Blast Management Plan must describe the measures that would be implemented to ensure best management practice is being employed and compliance with the relevant conditions of this approval.

Section 4.6.2 of the BMP provides the statutory requirements (essentially the approval conditions). Section 4.6.3 provides the compliance criteria. Sections 4.6.4 and 4.6.5 provide the monitoring and management measures respectively.

Nil C



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3 20(c) The Blast Management Plan must include a road closure management plan for blasting within 500 metres of a public road that has been prepared in consultation with the RTA and Council.

Section 4.6.9 of the BMP provides instruction for a road closure management plan for all blasts within 500 metres of Thomas Mitchell Drive. The BMP requires the plan to be prepared in consultation with MSC. Drayton Coal consulted the RMS regarding the BMP (Document 48). The RMS did not provide any objections (Document 49).

Nil C

3 20(d) The Blast Management Plan must include a monitoring program for evaluating the performance of the project, including compliance with the applicable criteria and minimising the fume emissions from the site.

Refer to Condition 20(b), Schedule 3 of PA 06_0202.

Nil C

3 20(e) The Blast Management Plan must include a protocol that has been prepared in consultation with the owners of nearby mines (including the Mt Arthur mine) to minimise the cumulative blasting impacts of these mines and the project.

Section 4.6.9 of the BMP describes the processes for consultation with Mt Arthur Coal.

Nil C



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3 21 The Proponent shall ensure that the dust emissions generated by the project do not cause additional exceedences of the air quality impact assessment criteria listed in Table 6 at any residence, on privately-owned land, or on more than 25 percent of any privately-owned land.

AEMR (2009) – Average annual geometric mean for TSP for all stations were well below the 90ug/m3 criterion. Average annual geometric means for PM10 for all stations were well below the 30 ug/m3. AEMR (2010) – Average annual geometric mean for TSP for all station were well below the 90ug/m3 criterion. Average annual geometric mean for PM10 for all stations were well below the 30 ug/m3. AEMR (2011) – Average annual geometric mean for TSP did not exceed the criteria. Average annual geometric mean for PM10 did not exceed the criteria. Year to date (2012) – No exceedences.

Nil C


AEMR (2009) – Six instances were recorded where the 50ug/m3 criterion was exceeded. Four of these instances the wind direction did not support any influences/contributions from the mine’s operations. The other two exceedences were attributed to the wind/dust storms from Central Australia. AEMR (2010) – results comply with criteria. AEMR (2011) – results generally complied with the criteria. Two exceedences were reported (Jan and Oct 2011). Wind for the January exceedence was predominately from the SE with results not reflecting particulate matter sourced from the Drayton operation. The October exceedence saw the TEOM located upwind of the mining operation, hence the result would not have been influenced by the mine. Year to date (2012) – No exceedences.

Nil C



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AEMR (2009) – results generally remain below the criteria. AEMR (2010) – results generally remain below the criteria. AEMR (2011) – results general remain below the criteria. Year to date (2012) – No exceedences.

Nil C

3 22 If the dust emissions generated by the project exceed the criteria in Table 8 at any residence on privately-owned land, or on more than 25 percent of any privately-owned land, the Proponent shall, upon receiving a written request for acquisition from the landowner, acquire the land in accordance with the procedures in conditions 8-10 of Schedule 4.

It was reported that a formal request for acquisition request (in accordance with this requirement) was received.

Nil N/A



Nil N/A



Nil N/A



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3 23(a) The Proponent shall ensure any visible air pollution generated by the project is assessed regularly, and that mining operations are relocated, modified, and/or stopped as required to minimise air quality impacts on privately-owned land to the satisfaction of the Director-General.

It was reported that OCEs have quick reference guides to assist in determining the extent of dust generation. It was reported that OCEs regularly suspend activities or relocate plant when conditions require. It was reported that the Environmental Coordinator has the authority to issue a stop work order if required. The site inspection did not observe any significant off site air pollution (refer to Section 7.2).

Nil C

3 23(b) The Proponent shall ensure that the real-time air quality monitoring and meteorological monitoring data are assessed regularly, and that mining operations are relocated, modified and/or stopped as required to ensure compliance with the relevant air quality criteria to the satisfaction of the Director-General.

Drayton Coal has implemented a real-time monitoring network. Refer to Section 6.3 for more information and an assessment of the real-time network.


3 23(c) The Proponent shall implement all practicable measures to minimise the off-site odour and fume emissions generated by any spontaneous combustion on site to the satisfaction of the Director-General.

It was reported that although odour and fumes generated from spontaneous combustion can often pose safety risks to workers in the immediate vicinity, fumes and odours are often dispersed into the atmosphere well before they reach the project boundary. The site inspection did not encounter any off site odour or fume emissions.

Nil C

3 24 The Proponent shall prepare and implement a Spontaneous Combustion Management Plan for the project to the satisfaction of the Director-General.

Drayton Coal has prepared and implemented the SCMP (Document 20).

Nil C



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3 24(a) The Spontaneous Combustion Management Plan must be prepared in consultation with OEH and DRE by suitably qualified expert/s whose appointment/s have been approved by the Director-General;


Nil N/A

3 24(b) The Spontaneous Combustion Management Plan must be submitted to the Director-General for approval within 6 months of this approval.


Nil N/A

3 25 The Proponent shall prepare and implement an Air Quality Management Plan for the project to the satisfaction of the Director-General.

Drayton Coal has prepared and implemented the AQMP (Document 21).

Nil C

3 25(a) The Air Quality Management Plan must be submitted to the Director-General by 31 October 2012 for approval.

The AQMP was submitted to DPI on the 31 October 2012 (Document 17). The DPI has approved a request for the submission of the AQMP to March 29 2013 to allow for amendments resulting from this report (refer to Section 6). Although Drayton Coal is currently operating under the existing AQMP, this audit report will assess the draft revision in accordance with the request from DPI (refer to Section 3).

Nil C

3 25(b) The Air Quality Management Plan must describe the measures that would be implemented (including a real-time air quality management system that employs both reactive and proactive mitigation measures) to ensure best management practice is being employed and compliance with the relevant conditions of this approval.

The AQMP provides mitigation measures. Refer to Section 6.3 for more information and an assessment of the real-time network.




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3 25(c) The Air Quality Management Plan must describe the proposed air quality management system.

The AQMP describes the air quality management system. Refer to Section 6.3 for more information and an assessment of the real-time network.


3 25(d) The Air Quality Management Plan must include an air quality monitoring program that: uses a combination of real-time

monitors and supplementary monitors to evaluate the performance of the development

adequately supports the proactive and reactive air quality management system

includes PM2.5 monitoring (although this obligation may be satisfied by the regional air quality monitoring network if sufficient justification is provided)

evaluates and reports on the effectiveness of the air quality management system

includes a protocol for determining any exceedences of the relevant conditions of this consent.

The AQMP provides an air quality monitoring program. Refer to Section 6.3 for more information and an assessment of the real-time network.


3 25(e) The Air Quality Management Plan must include a protocol that has been prepared in consultation with the owners of nearby mines (including the Mt Arthur mine) to minimise the cumulative air quality impacts of the mines.

The AQMP provides measures to minimise cumulative air quality impacts. Refer to Section 6.3 for more information and an assessment of the real-time network.




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3 26 During the life of the project, the Proponent shall ensure that there is a suitable meteorological station in the vicinity of the site that complies with the requirements in the Approved Methods for Sampling of Air Pollutants in New South Wales guideline.

Drayton Coal operates and maintains a meteorological station on site. It was reported that Drayton Coal was not aware if the station complies with the requirements in the Approved Methods for Sampling of Air Pollutants in New South Wales guideline. It was reported that Drayton Coal will be installing a new station in 2013.

Nil C

3 27 The Proponent shall only discharge water from the site in accordance with the provisions of an EPL or the Protection of the Environment Operations (Hunter River Salinity Trading Scheme) Regulation 2002.

Drayton Coal does not intentionally discharge water from the site. During the audit period, there were two occasions where water was unintentionally discharged from site and not in accordance with this requirement: 15 June 2011 – approximately five

megalitres (ML) discharged from the Rail Loop Dam during heavy rain.


The site inspection identified the dams where the discharges took place and found that Drayton Coal had implemented all necessary corrective actions. Refer to Condition 3, Schedule 5 of PA 06_0202.


3 28 The Proponent shall prepare and implement a Site Water Management Plan for the project to the satisfaction of the Director-General.

Drayton Coal has prepared and implemented the WMP (Document 22).

Nil C



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3 28(a) The Site Water Management Plan must be prepared in consultation with OEH and NOW by suitably qualified expert/s whose appointment/s have been approved by the Director-General.


Nil N/A

3 28(b) The Site Water Management Plan must be submitted to the Director-General for approval within 6 months of this approval.


Nil N/A

3 28(c) The Site Water Management Plan must include a Site Water Balance.

Section 5.6.1 of the SWP contains the Site Water Balance.

Nil C

3 28(c) The Site Water Management Plan must include an Erosion and Sediment Control Plan.

Section 5.6.2 of the SWP contains an ESCP. Nil C

3 28(c) The Site Water Management Plan must include a Surface Water Monitoring Program.

Section 5.6.3 of the SWP includes a surface water monitoring program.

Nil C

3 28(c) The Site Water Management Plan must include a Ground Water Monitoring Program.

Section 5.6.4 of the SWP includes a ground water monitoring program.

Nil C

3 28(c) The Site Water Management Plan must include a Surface and Ground Water Response Plan.

Section 5.6.5 of the SWP contains the SGWRP. Nil C

3 29(a) The Site Water Balance must include details of sources and security of water supply.

Section 5.6.1.1 provides the sources and security of water supply.

Nil C

3 29(a) The Site Water Balance must include details of water use on site.

Section 5.6.1.2 provides details of water use on site.

Nil C

3 29(a) The Site Water Balance must include details of water management on site.

Section 5.6.1.3 provides the water management system.

Nil C



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3 29(a) The Site Water Balance must include details of off-site water transfers.

Section 5.6.1.4 provides off-site water transfers. The only off-site transfer applicable to Drayton Coal is excess mine water transfers to the neighbouring Mt Arthur Coal.

Nil C

3 29(b) The Site Water Balance must investigate and describe measures to minimise water use by the project.

Section 5.6.1.5 provides details of water use minimisation. Water use minimisation is limited to potable water as historically Drayton Coal has never encountered mine water shortages.

Nil C

3 30(a) The Erosion and Sediment Control Plan must be consistent with the requirements of the Managing Urban Stormwater: Soils and Construction Manual (Landcom 2004, or its latest version).

It was determined the ESCP is not consistent with the requirements of the Managing Urban Stormwater: Soils and Construction Manual. The following aspects would be required to be consistent with the manual but were not included the ESCP: existing site contours including catchment

area boundaries location of critical natural areas requiring

special planning of management stages of mining nature and extent of earthworks, including

cut and fill location of all soil stockpiles location of proposed roads existing and proposed drainage patterns location and types of proposed erosion

control measures site rehabilitation proposals including final

contours.

It is recommended that the ESCP is revised to the following aspects (in accordance with the Managing Urban Stormwater: Soils and Construction Manual): existing site contours including catchment

area boundaries location of critical natural areas requiring

special planning of management stages of mining nature and extent of earthworks, including

cut and fill location of all soil stockpiles location of proposed roads existing and proposed drainage patterns location and types of proposed erosion

control measures site rehabilitation proposals including final

contours.

NC



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3 30(b) The Erosion and Sediment Control Plan must identify activities that could cause soil erosion and generate sediment.

The ESCP generally identifies activities that could cause soil erosion and generate sediment.

Nil C

3 30(c) The Erosion and Sediment Control Plan must describe measures to minimise soil erosion and the potential for the transport of sediment to downstream waters.

There is no detail on how erosion will be controlled, particularly erosion resulting from dispersive soils. There is discussion on the use of diversion banks (channel banks) which are inappropriate for dispersive mine spoil given their tunnel erosion risk. There is discussion of perimeter sediment control measures but no information of what type of sediment dam they are (Type C, D or F) nor is there any detail on chemical treatment or dewatering of the basins.


3 30(d) The Erosion and Sediment Control Plan must describe the location, function, and capacity of erosion and sediment control structures.

Refer to Condition30(c), Schedule 3 of PA 06_0202.


3 30(e) The Erosion and Sediment Control Plan must describe what measures would be implemented to maintain the structures over time.

The ESCP describes limited maintenance of sediment control structure and diversion banks but with no specific detail.

It is recommended that the ESCP is revised to include more specific detail in the maintenance process for sediment control devices.

NC

3 31(a) The Surface Water Management and Monitoring Plan must include detailed baseline data on surface water flows and quality in creeks and other waterbodies that could be affected by the project.

The Surface Water Management and Monitoring Plan must include baseline data including surface water quality of potentially affected creeks.

Nil C

3 31(b) The Surface Water Management and Monitoring Plan must include surface water impact assessment criteria.

Section 5.6.3.2 of the Surface Water Management and Monitoring Plan describes the impact assessment criteria.

Nil C

3 31(c) The Surface Water Management and Monitoring Plan must include a program to monitor the impact of the project on surface water flows and quality and downstream water users.

Section 5.6.3.2 of the Surface Water Management and Monitoring Plan provides downstream management which is predominantly responsive as Drayton Coal does not intentionally discharge water off site (except piped transfers to Mt Arthur Coal).

Nil C



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3 31(d) The Surface Water Management and Monitoring Plan must include reporting procedures for the results of this monitoring.

Section 5.6.3.4 of the Surface Water Management and Monitoring Plan describes the reporting requirements.

Nil C

3 32(a) The Groundwater Monitoring Plan must include detailed baseline data of groundwater levels, yield and quality in the region (including privately owned groundwater bores within the predicted drawdown impact zone identified in the EA).

The Groundwater Monitoring Plan provides baseline data including discussion and analysis. Drawdown impacts are compared with EA predictions. The plan reports that privately owned bores are no longer available.

Nil C

3 32(b) The Groundwater Monitoring Plan must include a program to augment the baseline data over the life of the project.

Section 5.6.4.2 of the Groundwater Management Plan discusses augmenting the baseline data.

Nil C

3 32(c) The Groundwater Monitoring Plan must include groundwater assessment criteria, including trigger levels for investigating any potentially adverse groundwater impacts.

Section 5.6.4.3 of the Groundwater Management Plan provides the groundwater assessment criteria, including trigger levels for investigating any potentially adverse groundwater impacts.

Nil C

3 32(d) The Groundwater Monitoring Plan must include a program to monitor regional groundwater levels and quality in the surrounding aquifers.

Section 5.6.4.4 of the Groundwater Management Plan provides the groundwater monitoring program which satisfies all requirements of Condition 32(d), Schedule 3.

Nil C

3 32(d) The Groundwater Monitoring Plan must include a program to monitor impacts on the groundwater supply of potentially affected landowners.

Refer to Condition 32(d), Schedule 3 of PA 06_0202.

Nil C

3 32(d) The Groundwater Monitoring Plan must include a program to monitor the volume of ground water seeping into the open cut mine workings;


Nil C

3 32(d) The Groundwater Monitoring Plan must include a program to monitor the groundwater pressure response in the surrounding coal measures.


Nil C



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3 32(d) The Groundwater Monitoring Plan must include a program to monitor the seepage/leachate from any tailings dams, water storages or backfilled voids on site.


Nil C

3 32(e) The Groundwater Monitoring Plan must include procedures for the verification of the groundwater model.

Section 5.6.4.5 of the Groundwater Management Plan provides the model verification procedures.

Nil C

3 32(f) The Groundwater Monitoring Plan must include reporting procedures for the results of the monitoring program and model verification.

Section 5.6.4.5 of the Groundwater Management Plan provides reporting requirements.

Nil C

3 33(a) The Surface and Ground Water Response Plan must include a protocol for the investigation, notification and mitigation of any exceedences of the surface water and groundwater impact assessment criteria.

Response protocols are provided in the Surface and Ground Water Response Plan. These include responses to exceedences, landowner compensation/mitigation and for unforeseen circumstances. Investigation and notification requirements are included.

Nil C

3 33(b) The Surface and Ground Water Response Plan must include measures to mitigate and/or compensate potentially affected landowners with privately owned groundwater bores within the predicted drawdown impact zone identified in the EA, including provision of alternative supply of water to the affected landowner that is equivalent to the loss attributed to the project.


Nil C

3 33(c) The Surface and Ground Water Response Plan must include the procedures that would be followed if any unforeseen impacts are detected during the Project.


Nil C



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3 34 The Proponent shall progressively rehabilitate the site in a manner that is generally consistent with the final landform and proposed rehabilitation strategy in the EA (shown conceptually in Appendix 7) to the satisfaction of the DRE.


Nil C

3 35(a) The Proponent shall offset the following vegetation clearing of the project at a ratio of at least 2:1 to ensure there is a net improvement in the biodiversity value of the local area in the medium to long term: 36 ha of Narrow-leaved Ironbark

woodland 1 ha of Spotted Gum-Grey Box open

forest woodland 1.3 ha of Forest Red Gum open forest

and woodland (Hunter Lowland Redgum Forest EEC)

6 ha of revegetated Yellow Box and Grey Gum woodland.

to the satisfaction of the Director-General.


Nil N/A

3 35(b) The Proponent shall ensure that this offset is located in close proximity to the Natural Zone of the Drayton Wildlife Refuge (see Appendix 8), to the satisfaction of the Director-General.


Nil N/A



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3 35(c) The Proponent shall make suitable arrangements to protect this offset from development in the long term, to the satisfaction of the Director-General.

Drayton Coal has implemented two offset areas: adjacent to the northern boundary inside the southern boundary.

The northern offset area is off-site and is fenced and signposted (Photograph 10). The southern offset area is not fenced or signposted, however it was reported that this was to be completed by early 2013. It was reported that the southern offset area is protected from development and entry to the area is restricted.

Nil C

3 35A(a) By the end of December 2009, the Proponent shall incorporate an offset of at least 12 hectares, generally consistent with the offset described in the 2009 EA, into the Drayton Wildlife Refuge.


Nil N/A

3 35A(b) By the end of December 2009, the Proponent shall establish mechanisms within the Offset Strategy for long-term conservation and management of this offset in accordance with condition 36.


Nil N/A

3 36 Within 6 months of this approval, the Proponent shall prepare an Offset Strategy for the project to the satisfaction of the Director-General.


Nil N/A

3 36(a) The Offset Strategy must be prepared in consultation with the OEH.


Nil N/A

3 36(b) The Offset Strategy must describe the measures that would offset the specified vegetation clearing of the project.

Measures for the Southern and Northern Offset Areas are included in the Offset Strategy.

Nil C



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3 36(b) The Offset Strategy must describe the measures that would ensure that adequate resources are dedicated towards the implementation of this offset.

The Offset Strategy does not describe the measures that would ensure that adequate resources are dedicated towards the implementation of the offsets.

It is recommended that the Offset Strategy is revised to include commitments of resources for the implementation of offsets. Referencing appropriate documentation (e.g. the Rehabilitation and Offset Management Plan) will suffice.

NC

3 36(b) The Offset Strategy must describe the measures that would demonstrate that the proposed offset is generally consistent with the principles in Appendix 9, and would result in a net improvement in the biodiversity value of the local area in the medium to long term.

The principles in Appendix 9 are not thoroughly approached and complied with.

It is recommended that the Offset Strategy is revised to include a compliance table demonstrating how the offset areas comply with the principles provided in Appendix 9 of the approval.

NC

3 36(b) The Offset Strategy must describe the measures that would provide appropriate long term security for this offset.

The Offset Strategy describes measures for long term security.

Nil C

3 37 Within 2 years of this approval, the Proponent shall plant additional trees along the Thomas Mitchell Drive corridor to provide a mature tree screen for the project.


Nil N/A

3 37 These trees must be planted in consultation with Council, and subsequently monitored to the satisfaction of the Director-General.

The trees were planted prior to audit period. It was reported that the Environmental Officer regularly monitors the condition and effectiveness of the trees. The trees were observed during the site inspection and found to be in good health.

Nil C

3 38 The Proponent shall prepare and implement a detailed Landscape Management Plan for the project to the satisfaction of the DRE and the Director-General.

Drayton Coal has prepared and implemented the LMP (Document 23).

Nil C



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3 38(a) The Landscape Management Plan must be prepared in consultation with OEH, NOW and Council by suitably qualified expert/s whose appointment/s have been approved by the Director-General.

This requirement was triggered before the audit period.

Nil N/A

3 38(b) The Landscape Management Plan must be submitted to the Director-General for approval within 12 months of this approval.


Nil N/A

3 38(c) The Landscape Management Plan must include a Rehabilitation and Offset Management Plan.

The LMP contains a ROMP. Nil C

3 38(c) The Landscape Management Plan must include a Final Void Management Plan.

The LMP contains a FVMP. Nil C

3 38(c) The Landscape Management Plan must include a Mine Closure Plan.

The LMP contains a MCP. Nil C

3 39(a) The Rehabilitation and Offset Management Plan must include the objectives for the rehabilitation of the site and provisions of the offset.

The ROMP provides objectives for rehabilitation and offset provisions.

Nil C

3 39(b) The Rehabilitation and Offset Management Plan must include a detailed description of how the rehabilitation of the site and implementation of the Offset Strategy would be integrated with the rehabilitation and Offset Strategy for the Mt Arthur North mine and remnant vegetation on Macquarie Generation’s land, to ensure there is a comprehensive integrated strategy for the restoration and enhancement of the local landscape over time.

Section 7.6 of the ROMP provides integration of offset areas with local rehabilitation strategies. This includes collaborative works with Mt Arthur Coal.

Nil C

3 39(c) The Rehabilitation and Offset Management Plan must include a description of the short, medium, and long term measures that would be implemented to rehabilitate the site.

Section 6 of the ROMP provides rehabilitation strategies.

Nil C



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3 39(c) The Rehabilitation and Offset Management Plan must include a description of the short, medium, and long term measures that would be implemented to implement the Offset Strategy.

The ROMP describes how the Offset Strategy will be implemented.

Nil C

3 39(c) The Rehabilitation and Offset Management Plan must include a description of the short, medium, and long term measures that would be implemented to implement the Thomas Mitchell Drive Tree Screens.

Section 7.4 of the ROMP provides measures for the Thomas Mitchell Drive Tree Screens.

Nil C

3 39(c) The Rehabilitation and Offset Management Plan must include a description of the short, medium, and long term measures that would be implemented to manage the remnant vegetation and habitat on the site.

Section 7.1 of the ROMP provides measures that would be implemented to manage the remnant vegetation and habitat on the site.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for progressively rehabilitating areas disturbed by mining.

The ROMP does not adequately provide detailed procedures for progressively rehabilitating areas disturbed by mining.

It is recommended that the ROMP is revised to include progressive rehabilitation methodologies for disturbance areas and recently completed zones.

NC



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3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for implementing revegetation and regeneration within the disturbance areas and offset areas, including establishment of canopy, sub-canopy (if relevant), understorey and ground strata.

Procedures for the revegetation and regeneration within disturbance areas (including canopy, sub-canopy and ground strata) is provided in the ROMP.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for managing the remnant vegetation and habitat on site.

Refer to Condition 39(c), Schedule 3 of PA 06_0202.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for managing impacts on fauna.

Fauna management is described in the ROMP through control of feral animals, preventing access and monitoring procedures.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for reducing the visual impacts of the project.


Nil C



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3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for landscaping the site to minimise visual impacts.

Section 7.5 of the ROMP provides measures for minimising visual impacts via landscaping (including the tree screen on Thomas Mitchell Drive).

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for protecting areas outside the disturbance areas conserving and reusing topsoil.

Section 6.4 of the ROMP provides instruction for topsoil translocation including preparation of site and transfer of topsoil.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for collecting and propagating seeds for rehabilitation works.

Section 6.5 of the ROMP provides instruction for planting including collecting and propagating seeds.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for salvaging and reusing material from the site for habitat enhancement.

Section 6.6 of the ROMP provides for transfer of structural components.

Nil C



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3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for controlling weeds and feral pests.

The ROMP provides adequately provides measures for controlling weeds and pests.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for controlling access.

Section 6.7.1 of the ROMP provides Drayton Coal’s methods for controlling access to the Southern Offset Area. Controlling access to the Northern Offset Area is not included.

It is recommended that the ROMP is revised to include access management processes for the Northern Offset Area.

NC

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for bushfire management.

Section 7.2 of the ROMP references the Bushfire Management Plan.

Nil C

3 39(d) The Rehabilitation and Offset Management Plan must include a detailed description of what measures would be implemented over the next 3 years to rehabilitate the site and implement the Offset Strategy and Thomas Mitchell Drive tree screens, including the procedures to be implemented for managing any potential conflicts between the rehabilitation of the mine and Aboriginal cultural heritage.

Section 7.7 of the ROMP provides for managing potential conflicts between rehabilitation and Aboriginal cultural heritage. Conflict is not expected.

Nil C



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3 39(e) The Rehabilitation and Offset Management Plan must include detailed performance and completion criteria for the rehabilitation of the site and implementation of the Offset Strategy and Thomas Mitchell Drive tree screens.

Refer to Condition 39(f), Schedule 3 of PA 06_0202.

Nil C

3 39(f) The Rehabilitation and Offset Management Plan must include a detailed description of how the performance of the rehabilitation of the site and implementation of the Offset Strategy and Thomas Mitchell Drive tree screens would be monitored over time to achieve the relevant objectives and completion criteria.

The ROMP provides key performance indicators for the offset areas and the Thomas Mitchell Drive tree screen. Monitoring procedures are provided for the offset areas only.

It is recommended that the ROMP is revised to include monitoring procedures for the Thomas Mitchell Drive tree screen.

NC

3 39(g) The Rehabilitation and Offset Management Plan must include a description of the potential risks to successful rehabilitation and/or revegetation, and a description of the contingency measures that would be implemented to mitigate these risks.

Section 10.2 of the ROMP provides potential risks. Section 10.2.1 provides contingency measures.

Nil C

3 39(h) The Rehabilitation and Offset Management Plan must include details of who is responsible for monitoring, reviewing and implementing the plan.

Section 10.3 of the ROMP provides roles and responsibilities.

Nil C

3 39A Within 6 months of the modification approval (06_0202 MOD 2) the Proponent shall review and update the Rehabilitation and Offset Management Plan referred to in Condition 39 with consideration of the Muswellbrook Shire Council Mining Rehabilitation Policy, in consultation with Council, DRE and to the satisfaction of the Director General.

Drayton Coal complied with this requirement. Nil C



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3 40(a) The Final Void Management Plan must justify the planned final location and future use of the final voids

The FVMP describes the location of the final voids and lists potential future use. It does not include a justification of the locations and the future use of the final voids.

It is recommended that the FVMP is revised to include:

a justification of the locations and the future use of the final voids

design criteria and specifications justification(s) for the assessment of

potential creek/void interactions measures to minimise any potential

adverse impacts associated with the final voids and to manage and monitor the potential impacts of the final voids over time.

NC

3 40(b) The Final Void Management Plan must incorporate design criteria and specifications for the final voids based on verified groundwater modelling predictions and a re-assessment of post-mining groundwater equilibration.

The FVMP provides an indication of final water levels but does not provide the verified groundwater modelling predictions to justify these levels. Construction of a bund at the crest has significant potential to contribute to geotechnical and tunnel erosion failure of the highwall(s). Design criteria and specifications have not been provided for critical aspects:

slope erosion rates soil/spoil spontaneous combustion soil surface cover wave erosion salinity etc.


NC

3 40(c) The Final Void Management Plan must assess the potential interactions between creeks on the site and the final voids.

Section 5.6.3 of the FVMP states that the creeks will not be impacted but provides no science to justify these statements. It simply refers to the 2007 EA.


NC



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3 40(d) The Final Void Management Plan must describe what actions and measures would be implemented to minimise any potential adverse impacts associated with the final voids.

The FVMP does not adequately address measures to minimise any potential adverse impacts associated with the final voids and to manage and monitor the potential impacts of the final voids over time.


NC

3 40(d) The Final Void Management Plan must describe what actions and measures would be implemented to manage and monitor the potential impacts of the final voids over time.



NC

3 41(a) The Mine Closure Plan must define the objectives and criteria for mine closure.

The MCP provides objectives for mine closure but does not provide adequate criteria.

It is recommended that the Mine Closure Plan is revised to include: mine closure criteria investigation results for post mine options measures that would be implemented to

minimise of manage the on-going environmental effects.

NC

3 41(b) The Mine Closure Plan must investigate options for the future use of the site, including the final voids.

The MCP nominates various possible post mine land-uses but does not investigate options.


NC

3 41(c) The Mine Closure Plan must investigate ways to minimise the adverse socio-economic effects associated with mine closure, including reduction in local employment levels.

The MCP provides a brief investigation of ways to minimise adverse socio-economic effects associated with mine closure

Nil C

3 41(d) The Mine Closure Plan must describe the measures that would be implemented to minimise or manage the ongoing environmental effects of the project.

The MCP discusses monitoring of environmental effects but does not describe the measures that would be implemented to minimise or manage the on-going environmental effects.


NC

3 41(e) The Mine Closure Plan must describe how the performance of these measures would be monitored over time.

The MCP indicates that the existing environmental monitoring program will be continues during and post closure.

Nil C



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3 41A By 31 December 2012, the Proponent shall review the Rehabilitation and Offset Management Plan, Final Void Management Plan and Mine Closure Plan in consultation with Council and DRE and to the satisfaction of the Director General. This review must take Council’s Mining Rehabilitation Policy into account.

This requirement is not triggered until after the audit period.

Nil N/A

3 42 Within 3 months of the approval of the Landscape Management Plan, the Applicant shall lodge a conservation and biodiversity bond with either DRE or the Department to ensure that the Offset Strategy is implemented in accordance with the performance and completion criteria of the Landscape Management Plan.


Nil N/A

3 42(a) The sum of the conservation and biodiversity bond shall be determined by calculating the full cost of implementing the Offset Strategy.


Nil N/A

3 42(b) The sum of the conservation and biodiversity bond shall be determined by employing a suitably qualified quantity surveyor to verify the calculated costs.


Nil N/A

3 43 The Proponent shall prepare and implement an Aboriginal Heritage Plan to the satisfaction of the Director-General.

Drayton Coal has prepared and implemented the ACHMP (Document 24).

Nil C

3 43(a) The Aboriginal Heritage Plan must be prepared in consultation with OEH and relevant Aboriginal communities.


Nil N/A



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3 43(b) The Aboriginal Heritage Plan must be submitted to the Director-General for approval within 6 months of this approval or prior to the disturbance of any Aboriginal object or site, whichever is the soonest.


Nil N/A

3 43(c) The Aboriginal Heritage Plan must include a detailed salvage program and management plan for all Aboriginal sites within the project disturbance area.

Sections 4.6 and 4.7 of the ACHMP provide the salvage and management programs for Aboriginal sites.

Nil C

3 43(c) The Aboriginal Heritage Plan must include a detailed description of the measures that would be implemented to protect Aboriginal sites outside the project disturbance area.

Section 4.6.4 of the ACHMP provides processes for management of sites to be conserved within Drayton Mine Extension project area – which includes sites outside disturbance areas.

Nil C

3 43(c) The Aboriginal Heritage Plan must include a description of the measures that would be implemented if any new Aboriginal objects or skeletal remains are discovered during the project.

Section 4.7.7 of the ACHMP provides discovery protocols.

Nil C

3 43(c) The Aboriginal Heritage Plan must include a protocol for the ongoing consultation and involvement of the Aboriginal communities in the conservation and management of Aboriginal cultural heritage on the site.

Section 4.7.8 of the ACHMP provides the Aboriginal consultation protocol.

Nil C

3 44(a) The Proponent shall keep accurate records of the amount of coal transported from the site each year.

Drayton Coal provides a six monthly coal haulage report (Document 25) to DPI in accordance with the consent.

Nil C

3 44(a) The Proponent shall keep accurate records of the number of coal haulage train movements generated by the project (on a daily basis).


Nil C



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3 44(a) The Proponent shall keep accurate records of the date and time of each train movement generated by the project.

Drayton Coal maintains records of the dates and times of each train movement (Document 50).

Nil C

3 44(b) The Proponent shall include these records in the AEMR.

The AEMR records do not include the times of each train.

It is recommended that future AEMRs provide the times of all train movements associated with Drayton Coal.

NC

3 44A By 31 June 2012, the Proponent shall contribute $50,000 to Council towards the Council’s costs for a Route and Upgrade Assessment of Thomas Mitchell Drive.

Drayton Coal paid MSC $50,000 on 26 June 2012 (Document 26).

Nil C

3 45(a) The Proponent shall ensure that all external lighting associated with the development complies with Australian Standard AS4282 (INT) 1997 – Control of Obtrusive Effects of Outdoor Lighting, to the satisfaction of the Director-General.

The site inspection found that the only lighting directly visible to the public was some of the lighting associated with the ROM pad and the rail loop. Furthermore, the lighting associated with the rail loop is consistent with street lighting. All observed fixed lighting was pointed downwards with shielding preventing shine above the horizontal.

Nil C

3 45(b) The Proponent shall implement all reasonable and feasible measures to mitigate visual and off-site lighting impacts of the project, to the satisfaction of the Director-General.


Nil C

3 45(c) The Proponent shall minimise the visual impacts of the development to the satisfaction of the Director-General.

The site inspection found that the mine is essentially only publicly visible from Thomas Mitchell Drive (North Pit and associated emplacements). Some screening has been planted but a creek bed and a rocky outcrop prevents vegetative screening. Rehabilitation on the emplacements had commenced. Refer to Section 7.2.

Nil C



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3 46 The Proponent shall prepare and implement a Greenhouse and Energy Efficiency Plan for the project to the satisfaction of the Director-General.

Drayton Coal has prepared and implemented the GEEP (Document 27).

Nil C

3 46(a) The Greenhouse and Energy Efficiency Plan must be prepared generally in accordance with the Guidelines for Energy Savings Action Plans (DEUS 2005, or its latest version).

Preparation of the GEEP was undertaken prior to the audit period.

Nil N/A

3 46(b) The Greenhouse and Energy Efficiency Plan must be submitted to the Director-General for approval within 6 months of the date of this approval.


Nil N/A

3 46(c) The Greenhouse and Energy Efficiency Plan must include a program to monitor greenhouse gas emissions and energy use generated by the Project.

Sections 4.7.1 to 4.7.3 of the GEEP provide guidance on Drayton Coal’s greenhouse gas, energy and performance monitoring.

Nil C

3 46(d) The Greenhouse and Energy Efficiency Plan must include a framework for investigating and implementing measures to reduce greenhouse gas emissions and energy use associated with the project.

Section 4.7.4 of the GEEP provides performance improvement measures and gives timeframes. Refer to Section 6.7.


3 46(e) The Greenhouse and Energy Efficiency Plan must describe how the performance of these measures would be monitored over time.

The GEEP provides an action table for the performance measures (which include monitoring). Refer to Section 6.7.




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3 47(a) The Proponent shall monitor the amount of waste generated by the project, to the satisfaction of the Director-General.

Drayton Coal receives monthly waste reports from their waste contractor (Document 28). Waste records are provided in the AEMRs. Waste objectives and initiatives are provided in the AEMRs however it is suggested that future reports provide an analysis of performance against previous reporting periods where possible.

Nil C

3 47(b) The Proponent shall investigate ways to minimise waste generated by the project, to the satisfaction of the Director-General.


Nil C

3 47(c) The Proponent shall implement reasonable and feasible measures to minimise waste generated by the project, to the satisfaction of the Director-General.


Nil C

3 47(d) The Proponent shall ensure irrigation of treated wastewater is undertaken in accordance with OEH’s Environmental Guideline for the Utilisation of Treated Effluent, to the satisfaction of the Director-General.

Drayton Coal’s sewerage treatment area was assessed during the site inspection (refer to Section 7.2). The Environmental Guideline Use of Effluent by Irrigation (DECCW) was reviewed. The guideline applies the following environmental performance objectives to the use of effluent by irrigation: protection of surface waters protection of groundwater protection of lands protection of plant and animal health prevention of public health risks resource use community amenity.

The sewerage treatment area appeared to be compliant with all objectives.

Nil C



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3 47(d) The Proponent shall report on waste management and minimisation in the AEMR, to the satisfaction of the Director-General.


Nil C

4 1(a) Within 3 months of this approval, the Proponent shall notify the landowners of the land listed in Table 1 that they have the right to request an independent review of the impacts of the project in accordance with condition 3 of Schedule 4 if they believe the project is exceeding the relevant impact assessment criteria in this approval.


Nil N/A

4 2 If the results of the monitoring required in Schedule 3 identify that the impacts of the project are greater than the relevant impact assessment criteria in Schedule 3, except where a negotiated agreement has been entered into in relation to that impact, then the Proponent shall notify the Director-General and the affected landowners and/or existing or future tenants (including tenants of mine owned properties) accordingly, and provide quarterly monitoring results to each of these parties until the results show that the project is complying with the criteria in Schedule 3.

It was reported that monitoring results indicate that environmental performance is generally in accordance with the assessment criteria in Schedule 3.

Nil N/A

4 3 If a landowner considers the project to be exceeding the impact assessment criteria in Schedule 3 then he/she may ask the Director-General in writing for an independent review of the impacts of the project on his/her land.

There were three requests to DPI for an independent review of Drayton Coal’s environmental impact: De Boer residence on 22 November 2010

for noise and blasting and again in mid-2011for dust (Document 29).

Doherty residence in mid-December 2011 for noise and blasting (Document 30).

Nil N/A



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4 3(a) If the Director-General is satisfied that an independent review is warranted, the Proponent shall within 3 months of the Director-General’s decision consult with the landowner to determine his/her concerns.

Refer to Condition 3, Schedule 4 of PA 06_0202. It was reported that in all occurrences, the DPI were satisfied that an independent review was warranted. It was reported that Drayton Coal consulted with the affected residents within 3 months.

Nil C

4 3(b) If the Director-General is satisfied that an independent review is warranted, the Proponent shall within 3 months of the Director-General’s decision commission a suitably qualified, experienced and independent person, whose appointment has been approved by the Director-General, to conduct monitoring on the land to determine whether the project is complying with the relevant impact assessment criteria in Schedule 3; and identify the source(s) and scale of any impact on the land, and the project’s contribution to this impact.

Refer to Condition 3, Schedule 4 of PA 06_0202. Drayton Coal commissioned three separate independent reviews (Documents 31-33) in response to the three requests. Suitably qualified, experienced and independent consultancy, SLR, was commissioned in all cases. Commissioning SLR for the first review (de Boer residence) was not undertaken within three months. It was reported that SLR was commissioned for the other reviews within the three month limit.


4 3(c) If the Director-General is satisfied that an independent review is warranted, the Proponent shall within 3 months of the Director-General’s decision give the Director-General and landowner a copy of the independent review.



NC

4 4 If the independent review determines that the project is complying with the relevant criteria in schedule 3, then the Proponent may discontinue the independent review with the approval of the Director-General.

All three independent reviews reported Drayton Coal to be within respective approval and consent limits.

Nil N/A



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4 5(a) If the independent review determines that the relevant criteria in schedule 3 are being exceeded, but that more than one mine is responsible for this non-compliance, then together with the relevant mine/s, the Proponent shall implement all reasonable and feasible mitigation measures, in consultation with the landowner and appointed independent person, and conduct further monitoring until there is compliance with the relevant criteria.


Nil N/A

4 5(b) If the independent review determines that the relevant criteria in schedule 3 are being exceeded, but that more than one mine is responsible for this non-compliance, then together with the relevant mine/s, the Proponent shall conduct further monitoring to determine whether these measures ensure compliance.


Nil N/A

4 5 If the additional monitoring referred to above subsequently determines that the project is complying with the relevant criteria in Schedule 3, or the Proponent and landowner enter into a negotiated agreement to allow these exceedences, then the Proponent may discontinue the independent review with the approval of the Director-General.


Nil N/A



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4 6(a) If the independent review determines that the relevant criteria in Schedule 3 are being exceeded, but that more than one mine is responsible for this non-compliance, then the Proponent shall, together with the relevant mine/s take all reasonable and feasible measures, in consultation with the landowner, to ensure that the relevant criteria are complied with.


Nil N/A

4 6(b) If the independent review determines that the relevant criteria in Schedule 3 are being exceeded, but that more than one mine is responsible for this non-compliance, then the Proponent shall, together with the relevant mine/s conduct further monitoring to determine whether these measures ensure compliance.


Nil N/A

4 6(c) If the independent review determines that the relevant criteria in Schedule 3 are being exceeded, but that more than one mine is responsible for this non-compliance, then the Proponent shall, together with the relevant mine/s secure a written agreement with the landowner and other relevant mines to allow exceedences of the criteria in Schedule 3.


Nil N/A

4 6 If the additional monitoring referred to above subsequently determines that the noise generated by the project combined with the noise generated by other mines is complying with the relevant criteria in Schedule 3, then the Proponent may discontinue the independent review with the approval of the Director-General.


Nil N/A



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4 7 If the landowner disputes the results of the independent review, either the Proponent or the landowner may refer the matter to the Director-General for resolution.

It was reported that Drayton Coal did not formally dispute the reports.

4 7 If the matter cannot be resolved within 21 days, the Director-General shall refer the matter to an Independent Dispute Resolution Process (see Appendix 10).


Nil N/A

4 8(a) Within 3 months of receiving a -rom a landowner with acquisition rights, the proponent shall make a binding written offer to the landowner based on the current market value of the landowners interest in the property at the date of this written request, as if the property was unaffected by the project, having regard to the existing and permissible use of the land in accordance with the applicable planning instruments at the date of the written request.

It was reported that Drayton Coal did not receive any written requests from landowners with acquisition rights.

Nil N/A



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4 8(a) Within 3 months of receiving a written request from a landowner with acquisition rights, the proponent shall make a binding written offer to the landowner based on the current market value of the landowners interest in the property at the date of this written request, as if the property was unaffected by the project, having regard to presence of improvements on the property and/or any approved building or structure which has been physically commenced at the date of the landowners written request, and is due to be completed subsequent to that date, but excluding any improvements that have resulted from the implementation of any additional mitigation measures required under conditions 5 and 6 of Schedule 3.

Refer to previous requirement. Nil N/A

4 8(b) Within 3 months of receiving a written request from a landowner with acquisition rights, the proponent shall make a binding written offer to the landowner based on the reasonable costs associated with relocating within the Muswellbrook local government area, or to any other local government area determined by the Director General.


Nil N/A

4 8(b) Within 3 months of receiving a written request from a landowner with acquisition rights, the proponent shall make a binding written offer to the landowner based on the reasonable costs associated with obtaining legal advice and expert advice for determining the acquisition price of the land and the terms upon which it is to be acquired.


Nil N/A



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4 8 Within 3 months of receiving a written request from a landowner with acquisition rights, the proponent shall make a binding written offer to the landowner based on reasonable compensation for any disturbance caused by the land acquisition process.


Nil N/A

4 8 However if at the end of this period, the proponent and landowner cannot agree on the acquisition price of the land and/or the terms on which the land is to be acquired, then either party may refer the matter to the Director General for resolution.


Nil N/A

4 8 Upon receiving such a request, the Director-General shall request the President of the NSW Division of the Australian Property Institute to appoint a qualified independent valuer or Fellow of the Institute, to consider submissions from both parties, and determine a fair and reasonable acquisition price for the land, and/or terms upon which the land is to be acquired.


Nil N/A

4 8 Within 14 days of receiving the independent valuer’s report, the Proponent shall make a binding written offer to the landowner to purchase the land at a price not less than the independent valuer’s determination.


Nil N/A

4 8 If the landowner refuses to accept this offer within 6 months of the Proponent’s offer, the Proponent's obligations to acquire the land shall cease, unless otherwise agreed by the Director-General.


Nil N/A



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4 9 The Proponent shall bear the costs of any valuation or survey assessment requested by the independent valuer, or the Director-General, and the costs of determination referred above.


Nil N/A

4 10 If the Proponent and landowner agree that only part of the land shall be acquired, then the Proponent shall pay all reasonable costs associated with obtaining Council approval for any plan of subdivision (where permissible), and registration of the plan at the Office of the Registrar-General.


Nil N/A

5 1 The Proponent shall prepare and implement an Environmental Management Strategy for the project to the satisfaction of the Director-General.

Drayton Coal has prepared and implemented the EMS (Document 34).

Nil C

5 1 The Environmental Management Strategy must be submitted to the Director-General within 6 months of this approval.


Nil N/A

5 1(a) The Environmental Management Strategy must provide the strategic framework for environmental management of the project.


Nil N/A

5 1(b) The Environmental Management Strategy must identify the statutory approvals that apply to the project.

Section 5.6.2 of the EMS identifies the statutory requirements that apply to Drayton Coal.

Nil C

5 1(c) The Environmental Management Strategy must describe in general how the environmental performance of the project would be monitored and managed.

Section 5.6.3 of the EMS provides a general description of how Drayton Coal’s environmental performance is monitored and managed.

Nil C



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5 1(d) The Environmental Management Strategy must 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

Section 5.6.5 of the EMS provides a general description of Drayton Coal’s community and regulatory consultation processes.

Nil C

5 1(d) The Environmental Management Strategy must describe the procedures that would be implemented to receive, handle, respond to and record complaints.

Section 5.6.6 of the EMS provides a general overview of the Drayton Coal’s complaint handling process.

Nil C

5 1(d) The Environmental Management Strategy must describe the procedures that would be implemented to resolve any disputes that may arise during the course of the project.

Section 5.6.8 of the EMS provides a general description of Drayton Coal’s dispute resolution process.

Nil C

5 1(d) The Environmental Management Strategy must describe the procedures that would be implemented to respond to any non-compliance.

Section 5.6.7 of the EMS provides Drayton Coal’s protocol for reporting and responding to exceedences of approval limits. Section 5.6.9 of the EMS provides Drayton Coal’s non-compliance repsonse processes.

Nil C

5 1(d) The Environmental Management Strategy must describe the procedures that would be implemented to manage cumulative impacts.

Section 5.6.10 of the EMS provides a general description of Drayton Coal’s processes for managing cumulative effects.

Nil C

5 1(d) The Environmental Management Strategy must describe the procedures that would be implemented to respond to emergencies.

Section 5.6.11 of the EMS provides an overview of the Drayton Coal’s environmental emergency response processes.

Nil C

5 1(e) The Environmental Management Strategy must describe the role, responsibility, authority, and accountability of all the key personnel involved in environmental management of the project.

The comprehensive Environmental Accountability Matrix 2010 is appended to the EMS. An organisational chart with attached position descriptions detailing roles and responsibilities for Drayton Coal is also appended.

Nil C



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5 2 The Proponent shall prepare and implement an Environmental Monitoring Program for the project to the satisfaction of the Director-General. This program must be submitted to the Director-General within 6 months of this approval, and consolidate the various monitoring requirements in Schedule 3 of this approval into a single document, and be submitted to the Director-General concurrently with the submission of the relevant monitoring programs/plans.

Drayton Coal has prepared and implemented an Environmental Monitoring Program (Document 35). Submission of the Environmental Monitoring Program was triggered prior to the audit period.

Nil C

5 3 Within 24 hours of detecting an exceedence of the limits/performance criteria in this approval or the occurrence of an incident that causes (or may cause) harm to the environment, the Proponent shall notify the Department and other relevant agencies of the exceedence/incident.

It was reported that Drayton Coal encountered four reportable incidents during the audit period. It was reported that Drayton Coal reported the incidents to the DPI and EPA within 24 hours.

Nil C

5 4 Within 6 days of notifying the Department and other relevant agencies of an exceedence/incident, the Proponent shall provide the Department and these agencies with a written report that describes the date, time, and nature of the exceedence/incident.

It was reported that Drayton Coal encountered four reportable incidents during the audit period. In all four occasions, incident reports were provided to DPI and EPA within the required timeframes (Documents 51-55). All reports identified the timeframes, nature of the incident, the suspected cause, actions taken and proposed improvement measures.

Nil C

5 4 Within 6 days of notifying the Department and other relevant agencies of an exceedence/incident, the Proponent shall provide the Department and these agencies with a written report that identifies the cause (or likely cause) of the exceedence/incident.


Nil C



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5 4 Within 6 days of notifying the Department and other relevant agencies of an exceedence/incident, the Proponent shall provide the Department and these agencies with a written report that describes what action has been taken to date.


Nil C

5 4 Within 6 days of notifying the Department and other relevant agencies of an exceedence/incident, the Proponent shall provide the Department and these agencies with a written report that describes the proposed measures to address the exceedence/incident.


Nil C

5 5 Within 12 months of this approval, and annually thereafter, the Proponent shall submit an AEMR to the Director-General and relevant agencies.

There have been three AEMRs required during the audit period: 2009 Drayton Annual Environment

Management Report (Document 36). 2010 Drayton Annual Environment

Management Report (Document 37). 2011 Drayton Annual Environment

Management Report (Document 38). Submission letters were sighted by the Audit Team.

Nil C



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5 5(a) The AEMR must identify the standards and performance measures that apply to the project.

All three AEMRs completed and submitted during the audit period follow a consistent template. All three AEMRs provide performance results for all environmental aspects associated with Drayton Coal however none of the reports adequately provide performance targets (statutory or initiative) for most of the aspects (air quality parameters are included). None of the AEMRs provide the approval or EPL limits.

Refer to Condition 5(f), Schedule 5

NC

5 5(b) The AEMR must describe the works carried out in the last 12 months.

All three AEMRs completed and submitted during the audit period describe the works carried out in the last 12 months.

Nil C

5 5(c) The AEMR must describe the works that will be carried out in the next 12 months.

All three AEMRs completed and submitted during the audit period describe the environmental management works to be completed in the next reporting period. There is some discussion of future mining works for the next period but this is not consistently applied to all elements of the mining works sections. It is appreciated that it is difficult to apply estimates for mining works for the next period as actual works often fluctuates.

Nil C

5 5(d) The AEMR must include a summary of the complaints received during the past year, and compare this to the complaints received in previous years.

All three AEMRs completed and submitted during the audit period include a summary of the complaints received during the past year. None of the AEMRs provide a comparison to the complaints received in the previous reporting period.

It is recommended that future AEMRs provide a comparison to the complaints received in the previous reporting period. It is also suggested that the type and nature of the complaints are also compared to allow for trending and focus for improvement initiatives.

NC



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5 5(e) The AEMR must include a summary of the monitoring results for the project during the past year.

All three AEMRs completed and submitted during the audit period include a summary of the monitoring results for the project during the past year.

Nil C

5 5(f) The AEMR must include an analysis of these monitoring results against the relevant: limits/criteria in this approval; monitoring results from previous years;

and predictions in the EA.

Refer to Condition 5(a), Schedule 5. None of the three AEMRs completed and submitted during the audit period adequately include an analysis against: limits/criteria in this approval monitoring results from previous years predictions in the EA.

It is recommended that future AEMRs adequately include analysis against: limits/criteria in this approval monitoring results from previous years predictions in the EA.

NC

5 5(g) The AEMR must identify any trends in the monitoring results over the life of the project.

None of the three AEMRs completed and submitted during the audit period adequately identify any trends in the monitoring results over the life of the project.

It is recommended that future AEMRs include trending analysis for all monitoring results.

NC

5 5(h) The AEMR must identify and discuss any non-compliance during the previous year.

Of the three AEMRs completed and submitted during the audit period, only the 2011 report identified non-compliance. The 2011 report did not adequately discuss the non-compliances.

It is recommended that future AEMRs improve the discussion on identified non-compliances.

NC

5 5(i) The AEMR must describe what actions were, or are being, taken to ensure compliance.

Refer to Condition 5(h), Schedule 5 of PA 06_0202.

Refer to Condition 5(h), Schedule 5. NC

5 6 Within 2 years of this approval, and every 3 years thereafter, unless the Director-General directs otherwise, the Proponent shall commission and pay the full cost of an Independent Environmental Audit of the project.

An independent audit (Document 15) was undertaken by AECOM on 20-21 October 2009 with the report provided in November 2009. This audit was undertaken on 29-31 October 2012. The dates for this audit were approved by DPI on 2 October 2012 (Document 39).

Nil C



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5 6(a) The Independent Environmental Audit must be conducted by a suitably qualified, experienced and independent team of experts whose appointment has been endorsed by the Director-General.

Refer to Section 2.2 and Appendix 6 for the audit team and their qualifications. DPI endorsed the audit team on 2 October 2012 (Document 39).

Nil C

5 6(b) The Independent Environmental Audit must assess the environmental performance of the project, and its effects on the surrounding environment.

Refer to Section 7. Nil C

5 6(c) The Independent Environmental Audit must assess assess whether the project is complying with the relevant standards, performance measures, and statutory requirements.


5 6(d) The Independent Environmental Audit must review the adequacy of any strategy/plan/program required under this approval.


5 6(e) The Independent Environmental Audit must, if necessary, recommend measures or actions to improve the environmental performance of the project, and/or any strategy/plan/program required under this approval.


5 7 Within 6 weeks of the completion of this audit, or as otherwise agreed by the Director-General, the Proponent shall submit a copy of the audit report to the Director-General, together with its response to any recommendations contained in the audit report.

This requirement has not been triggered for this current audit report.

Nil N/A



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5 8(a) Within 3 months of submitting the audit report to the Director-General, the Proponent shall review and if necessary revise the strategies/plans/programs required under this consent to the satisfaction of the Director-General.

It was reported that the environmental management plans required under the approval were reviewed in accordance with Drayton Coal’s internal document management practices. The previous audit report did not provide any recommendations to revise strategies, plans or programs.

Nil N/A

5 8(b) Within 3 months of submitting the audit report to the Director-General, the Proponent shall review and if necessary revise the Conservation and Biodiversity Conservation Bond to the satisfaction of the Director-General.

The previous audit report did not provide any recommendations to revise the Conservation and Biodiversity Conservation Bond.

Nil N/A

5 9 The Proponent shall operate a Community Consultative Committee (CCC) for the project to the satisfaction of the Director-General, in general accordance with the Guideline for Establishing and Operating Community Consultative Committees for Mining Projects.

Drayton Coal has operated a CCC since operations commenced in 1983.

Nil C

5 10(a) Within 3 months of the approval of any plan/strategy/program required under this approval (or any subsequent revision of these plans/strategies/programs), or the completion of the audits or AEMRs required under this approval, the Proponent shall provide a copy of the relevant document/s to the relevant agencies and CCC.

It was determined that Drayton Coal generally abide to the three month limit for submission of revised environmental management plans.

Nil C



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5 10(b) Within 3 months of the approval of any plan/strategy/program required under this approval (or any subsequent revision of these plans/strategies/programs), or the completion of the audits or AEMRs required under this approval, the Proponent shall put a copy of the relevant document/s on its website.

Relevant AEMRs are available on the Drayton Coal website. The previous audit report (November, 2009) has not been posted or is currently unavailable.

It is recommended that the November 2009 audit report is posted on the Drayton Coal website.

NC

5 11(a) During the development, the Proponent shall include a copy of this approval, as may be modified from time to time, on its website.

Drayton Coal provides the approval on their website at location: http://www.angloamerican.com.au/our-operations/thermal-coal/drayton/environment.aspx.

Nil C

5 11(b) During the development, the Proponent shall provide a full summary of monitoring results required under this approval on its website.

Drayton Coal provides the monitoring results on their website at location: http://www.angloamerican.com.au/our-operations/thermal-coal/drayton/environment.aspx.

Nil C

5 11(c) During the development, the Proponent shall update these results on a regular basis (at least every 3 months).

All monitoring data provided on their website is current and updated monthly.

Nil C

Appendix 2

DA 106-04-00 checklist

Appendix 2 DA 106-04-00 checklist


Table A2 Drayton Rail Loop and Antiene Rail Spur Compliance Audit (DA 106-04-00) – Approval Conditions Checklist Sc

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2 1 There is an obligation on the Applicant to prevent and minimise harm to the environment throughout the life of the project. This requires that all practicable measures are to be taken to prevent and minimise harm that may result from the construction, operation and, where relevant, decommissioning of the development.

It was reported that Drayton Coal manage the environmental impacts associated with the rail loop and spur as part of their overall management of the Drayton Mine. Refer to Condition 1, Schedule 2 of PA 06_0202.


C

2 1.1(a) The development is to be carried out generally in accordance with development application No. 106-04-00, and the EIS dated March 2000, prepared by Umwelt (Australia) Pty Limited and certified in accordance with Section 78A(8) of the Act, and all other relevant documentation provided to DUAP, including: Additional information requested by the

EPA and supplied by Umwelt (Australia Pty Limited) in a letter dated 15 June 2000; with the results of extended noise monitoring, in a letter dated 20 July 2000 and accompanying report titled "Response to EPA Submission of 5 July 2000".

Drayton Coal Pty Ltd Response to Summary of Submissions received from DUAP on 2 June 2000, prepared by Umwelt (Australia) Pty Ltd, August 2000.

as may be modified by the conditions set out herein.

Refer to Section 7.1. Nil C



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2 1.1(b) If, at any time, the Director-General is aware of environmental impacts from the proposal that pose serious environmental concerns due to the failure of environmental management measures in place to ameliorate the impacts, the Director-General may order the Applicant to cease the activities causing those impacts until those concerns have been addressed to the satisfaction of the Director-General.

It was reported that there have been no instances where the DPI have ordered a cessation of activities during the audit period.

Nil N/A

2 1.1(c) If any licence conditions are breached the applicant shall comply with any modification to the work as specified by the relevant agency. Note: This consent should be read in conjunction with the existing Muswellbrook Shire Council Drayton Mine Project consent issued on 25 September 1980.

Requests from DPI following license breaches during the audit period involved either reports to be supplied or maintenance on infrastructure to revamped/revisited. It was reported that all applicable requests were complied with. Refer to Condition 4(a), Schedule 2 of PA 06_0202.

Nil C

2 1.2(i) The approval for coal transport operations is for a period of 25 years from the date of this consent.

The mine is currently in operation. Nil N/A

2 1.2(ii) At least two weeks prior to the commencement of operation or within such period as agreed by the Director-General, the Applicant shall submit for the approval of the Director-General a compliance report detailing compliance with all the relevant conditions that apply prior to the commencement of operation.


Nil N/A

2 1.2(iii) Date of commencement of operation is to be notified in writing to the Director-General, and MSC, at least two weeks prior to commencement of operation.


Nil N/A



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2 1.3 In the event that the Applicant, MSC or a Government agency, other than the Department of Urban Affairs and Planning, cannot agree on the specification or requirements applicable under this consent, the matter shall be referred by either party to the Director-General or if not resolved, whose determination of the disagreement shall be final and binding on the parties.

It was reported that there has not been any instance during the audit period where this requirement was triggered.

Nil N/A

2 2.1(a)i The Environmental Coordinator(s) employed by Drayton mine shall be responsible for the preparation of the environmental management plans required by this consent (refer Condition 2.2).

The Environmental Coordinator is responsible for preparation of all statutory required environmental management plans. The position description (Document 40) for Drayton Coal’s Environmental Coordinator was reviewed – there was not a direct responsibility stating development of management plans however the Environmental Coordinator is required to “Developing and continually improving Environment and Community systems and processes.” It is recommended that the position description is amended to provide a clear responsibility associated with environmental management plans. It is appreciated that all environmental management plans required under this consent have been prepared.

Nil C



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2 2.1(a)ii The Environmental Coordinator(s) employed by Drayton mine shall be responsible for considering and advising on matters specified in the conditions of this consent and compliance with such matters.

It was reported that the Environmental Coordinator is responsible for this considering and advising on matters specified in the consent. The position description for Drayton Coal’s Environmental Coordinator states: “Monitoring, reporting and advising on environmental performance as required by the various environment licences and approvals.”

Nil C

2 2.1(a)iii The Environmental Coordinator(s) employed by Drayton mine shall be responsible for receiving and responding to complaints in accordance with Condition 9.2(a).

Drayton Coal’s complaint handling procedure, Environmental Enquiries Procedure (Document 41) states: “The Environment Officer shall be responsible for receiving, recording and addressing environmental enquiries. They shall also be responsible for ensuring all conditions relating to the handling of enquiries and reporting to relevant authorities is undertaken as detailed in the development consent.” The position description for Drayton Coal’s Environmental Coordinator does not include a role for responding to environmental complaints and it is recommended that this is rectified in the next revision of the position description.

Nil C



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2 2.1(a)iv The Environmental Coordinator(s) employed by Drayton mine shall have the authority and independence to require reasonable steps to be taken to avoid or minimise unintended or adverse environmental impacts and failing the effectiveness of such steps, to stop work immediately if an adverse impact on the environment is likely to occur.

It was reported by both the Environmental Coordinator and the SHE Manager that the Environmental Coordinator has the authority to enforce cease work orders on activities where he is concerned for adverse environmental impacts. The position description for Drayton Coal’s Environmental Coordinator does not include authorities or specifically, this authority to order work cessations if necessary.

It is recommended that the the Environmental Coordinator’s position description is revised to include the authority to cease work activities that may cause adverse environmental impact, or any other reasonable step to be taken to avoid or minimise unintended or adverse environmental impact.

NC

2 2.1(b) The Applicant shall notify the Director-General, DMR, EPA, DLWC, MSC, and the CCC (refer condition 9.1) of any changes to the name and/or contact details of the Environmental Coordinator(s).

There was no evidence that Drayton Coal formally notified DPI, DTIRIS, EPA, NOW, MSC, and the CCC of James Benson’s new appointment and supplied his contact details. It is appreciated that the respective parties of from the abovementioned agencies/committees were made aware in due course.

Nil C

2 2.1(b) Any new appointment of an environmental Coordinator(s) is to receive prior approval of the Director-General.

Drayton Coal sought approval for James Benson’s appointment on 19 January 2012 (Document 42) and was granted approval on 25 January 2012 (Document 43). It was reported that although James was employed prior to this time, he was not officially appointed to the Environmental Coordinator role until after DPI approval.

Nil C

2 2.2(a) The Applicant shall prepare an Environmental Management Strategy providing a strategic context for the environmental management plans [refer condition 2.2(d)].

It was reported that the EMS was prepared and implemented for the Drayton Mine under PA 06_0202 was amended to include the requirements for DA 106-04-00.

Nil C



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2 2.2(a) The Environmental Management Strategy shall be prepared in consultation with the relevant authorities and the Community Consultative Committee (refer condition 9.1) and to the satisfaction of the Director-General, prior to commencement of operations.


Nil N/A

2 2.2(a) The Strategy shall be provided to the Director-General no later than the time the first Environmental Management Plan under sub clause (d) below is submitted.


Nil N/A

2 2.2(b)i The Environmental Management Strategy shall include, but not be limited statutory and other obligations which the Applicant is required to fulfill during operation, including all approvals and consultations and agreements required from authorities and other stakeholders, and key legislation and policies.


Nil C

2 2.2(b)ii The Environmental Management Strategy shall include, but not be limited to definition of the role, responsibility, authority, accountability and reporting of personnel relevant to environmental management, including the Environmental Officer.

Refer to Condition 1(e), Schedule 5 of PA 06_0202.

Nil C



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2 2.2(b)iii The Environmental Management Strategy shall include, but not be limited to overall environmental management objectives and performance outcomes, during, operation and decommissioning of the rail loop and Antiene rail spur, for each of the key environmental elements for which management plans are required under this consent.

Section 5.6.3 of the EMS provides a table which details Drayton Coal’s environmental management objectives. Although the environmental objectives include aspects and actions pertinent to the rail loop and spur, there is no direct reference to either the loop or spur and furthermore, performance outcomes during operation and decommissioning of the loop and spur is not included. Section 5.6.4 includes the list of environmental management plans applicable to Drayton Coal and their relationship with applicable approvals and licenses. The consent is not referenced nor are the management plans applicable to the spur and loop (e.g. Joint Acquisition Management Plan, JAMP).

It is recommended that the EMS is revised to include a clearer reference to the consent. This would include: providing performance outcomes during

operation and decommissioning of the loop and spur


including the environmental management plans applicable to the loop and spur.

NC

2 2.2(b)iv The Environmental Management Strategy shall include, but not be limited to overall ecological and community objectives for the project, and a strategy for the restoration and management of the areas affected by operations, including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives.

The EMS does not adequately provide ecological and community objectives for the rail loop and spur. The EMS does not adequately provide a strategy for the restoration and management of the areas affected by the rail loop and spur, including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives.

It is recommended that the EMS is revised to include: ecological and community objectives for

the rail loop and spur provide a strategy for the restoration and

management of the areas affected by the rail loop and spur including elements such as wetlands and other habitat areas, creek lines and drainage channels, within the context of those objectives.

NC

2 2.2(b)v The Environmental Management Strategy shall include, but not be limited to identification of cumulative environmental impacts and procedures for dealing with these at each stage of the development.


Nil C



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2 2.2(b)vi The Environmental Management Strategy shall include, but not be limited to overall objectives and strategies to protect economic productivity within the area affected by the operations.

Although it is appreciated that it is unlikely that the rail loop and spur may adversely impact on the economic productivity within the area, the EMS does not adequately discuss this or account for this requirement.

It is recommended that the EMS is revised to include: overall objectives and strategies to

protect economic productivity within the area affected by the operations.

NC

2 2.2(b)vii The Environmental Management Strategy shall include steps to be taken to ensure that all approvals, plans, and procedures are being complied with.

Section 5.6.9 of the EMS states: “Environmental compliance at Drayton is monitored through ongoing monitoring processes, environmental audits, external certification audits, compliance audits and external audits or inspections conducted by regulatory authorities. Outcomes from these activities are recorded in a database along with proposed actions to correct the non compliance to achieve compliance again.”

Nil C

2 2.2(b)viii The Environmental Management Strategy shall include processes for complaint handling, investigation and resolution in relation to the environmental management of the project.


Nil C

2 2.2(b)ix The Environmental Management Strategy shall include documentation of the results of consultations undertaken in the development of the Environmental Management Strategy.

Appendix 1 of the EMS allows for regulatory correspondence. No correspondence is recorded. A provision for non-regulatory consultation (e.g. CCC) is not provided.

It is recommended that the EMS is revised to include: a provision for all facets of consultation

relating to the development of the EMS.

NC

2 2.2(b)x The Applicant shall make copies of the environmental management strategy available to MSC, EPA, DMR and the CCC within fourteen days of approval by the Director-General.


Nil N/A



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2 2.2(d) The Applicant shall prepare a Dust management plan for the Drayton rail loading facility.

Drayton Coal prepared a Dust Management Plan for the rail loading facility prior to the audit period. Drayton Coal has since consolidated this plan into the current AQMP to be submitted to DPI by 29 March 2013. Refer to Condition 25(a), Schedule 3 of PA 06_0202.

Nil C

2 2.2(d) The Applicant shall prepare a Noise management plan for the Drayton rail loading facility.

Drayton Coal prepared a Noise Management Plan for the rail loading facility prior to the audit period. Drayton Coal has since consolidated this plan into the current NMP to be submitted to DPI by 29 March 2013. Refer to Condition 8(a), Schedule 3 of PA 06_0202.

Nil C

2 2.2(d) The Applicant shall prepare a Water management plan for the Drayton rail loading facility.

Drayton Coal has prepared the Water Management Procedure – Rail (Document 44). It was reported that the plan will be consolidated with the WMP for the Drayton Mine and submitted for review to DPI by 29 March 2013.

Nil C

2 2.2(d) The Applicant shall prepare a Joint Acquisition Management Plan for the Drayton rail loading facility.

Drayton Coal has prepared a JAMP. Nil C



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2 2.2(e) The management plans are to be revised, and updated as necessary, at least every 5 years or as otherwise directed by the Director-General in consultation with the relevant government agencies. They will reflect changing environmental requirements or changes in technology/operational practices. Changes shall be made and approved in the same manner as the initial environmental management plan. The plans shall also be made publicly available at MSC within two weeks of approval of the relevant government authority.

It was reported that the NMP, AQMP and WMP will be sent to MSC for public exhibition after approval in 2013. It is important to note the abovementioned plans will be available on the Drayton Coal website after approval. The JAMP has not been updated since 2001. It was reported that Mt Arthur Coal (the second party in the agreement) has been reluctant to invest resources into the review as they have since been granted a separate approval for the rail spur which excludes the JAMP.

It is recommended that Drayton Coal formally inform DPI of the current situation regarding the JAMP and seek advice for this matter.

NC

2 2.2(e) The management plans are to reflect changing environmental requirements or changes in technology/operational practices.

It was reported that the recent revisions to the plans (refer to Condition 2.2(e), Schedule 2 of DA 106-04-00) reflected changes in technology and operational practices. Revisions are ongoing and won’t be completed until 2013.

Nil C

2 2.2(e) Changes shall be made and approved in the same manner as the initial environmental management plan.

The consolidated dust, noise and water plan will be revised and submitted for review after the audit period. The JAMP has not been reviewed in the audit period (refer to Condition 2.2(e), Schedule 2 of DA 106-04-00).

Nil N/A

2 2.2(e) The plans shall also be made publicly available at MSC within two weeks of approval of the relevant government authority.

The original exhibition of the approved plans was triggered prior to the audit period. The plans will be revised and approved after the audit period. It is important to note the abovementioned plans will be available on the Drayton Coal website after approval.

Nil N/A



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2 2.2(f) The Applicant shall make copies of the updated environmental management plans available to MSC, EPA, DMR and the CCC within fourteen days of approval by the Director-General.


Nil N/A

2 2.3 The Applicant shall maintain the existing fire protection works on site at Drayton rail loading facility, including the availability of trained personnel, water tankers and fire fighting equipment and annual hazard reduction measures with particular attention to boundaries of adjoining landholdings.

The emergency response centre was observed during the site inspection. Areas around the rail loop (within the Drayton Mine boundary) appeared to be well managed with no stockpiles of vegetative material available. It was reported that Drayton Coal maintain access tracks as fire trails. Drayton Coal has three large water carts and one smaller cart on sites which are configured to respond to fire emergencies. It was reported that fire management and response is drilled regularly.

Nil C

2 3.1(a) The Applicant shall prepare a site water management plan and monitoring system for the Drayton rail loading facility to include the revised coal transport operations in consultation with DLWC prior to commencement of operations, and to the satisfaction of the Director-General.


Nil N/A

2 3.1(a)i The site water management plan shall include but not be limited to details of the integration of the revised coal transport operations with the existing Drayton mine water management plan and monitoring system.

The Water Management Procedure – Rail discusses integration of the revised coal transport operations with the existing Drayton mine water management plan and monitoring system.

Nil C



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2 3.1(a)ii The site water management plan shall include but not be limited to management of the quality and quantity of surface and groundwater within the areas covered by the Site Water Management Plan, which shall include preparation of monitoring programs;

The Water Management Procedure – Rail discusses surface and groundwater monitoring although it essentially refers to the WMP. This is acceptable considering that surface and groundwater aspects are managed for the site as a whole and that the WMP and Water Management Procedure – Rail will be consolidated early next year.

Nil C

2 3.1(a)iii The site water management plan shall include but not be limited to management of stormwater and general surface runoff diversion to ensure separate effective management of clean and dirty water.

The Water Management Procedure – Rail discusses management of stormwater and general surface runoff diversion although it essentially refers to the WMP. This is acceptable considering that surface and groundwater aspects are managed for the site as a whole and that the WMP and Water Management Procedure – Rail will be consolidated early next year.

Nil C

2 3.1(a)iv The site water management plan shall include but not be limited to measures to prevent the quality of any surface waters being degraded due to the revised coal transport operations, below that identified in Table 2.5 of the EIS.

A review of the water quality monitoring data found Drayton Coal to be in general accordance with Table 2.5 of the EIS.

Nil C

2 3.1(a)v The site water management plan shall include but not be limited to contingency plans for managing adverse impacts of the development on surface or ground water quality and quantity below that identified in Table 2.5 of the EIS.

Section 4.14 of the Water Management Procedure – Rail discusses managing adverse impacts. The procedure instructs that although adverse impacts are unlikely, if they do occur, they are to be managed in accordance with Drayton Coal’s incident management processes.

Nil C



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2 3.1(a)vi The site water management plan shall include but not be limited to identification of any possible adverse effects on water supply sources of surrounding land holders as a result of the revised coal transport operations, and implementation of mitigation measures as necessary.

Section 4.15 of the Water Management Procedure – Rail discusses effects on potential neighbouring landholders. The procedure states that no additional impacts are expected.

Nil C

2 3.1(a)vii The site water management plan shall include but not be limited to a program for reporting on the effectiveness of the water management systems and performance against objectives contained in the this water management plan.

Section 4.16 of the Water Management Procedure – Rail discusses managing the water system against performance objectives. Although the procedure provides performance objectives (essentially target capacity of the rail loop dam), there are no reporting processes (internal or external/regulatory) provided.

It is recommended that the internal and/or external reporting of performance objectives is included in the 2013 consolidation of the WMP and Water Management Procedure – Rail.

NC

2 4.1 The applicant shall ensure that the waste management system, including the management of waste water, is maintained and applied to the proposed increase coal transport operations along the Drayton rail loop and Antiene rail spur as detailed in Section 5.2.5 of the EIS.

Waste management measures for the rail loop and spur are included within the Drayton Coal waste management program for the entire site. Refer to Condition 47(a), Schedule 3 of PA 06_0202.

Nil C

2 5.1(a) The Applicant shall, within 3 months of this consent, prepare a Dust Management Plan for the Drayton rail loading facility, detailing air quality safeguards and procedures for dealing with dust emissions to the satisfaction of the Director-General.

This requirement was triggered prior to the audit period. The Dust Management Plan for the rail loop has been consolidated into the AQMP for the project. Refer to Condition 25(a), Schedule 3 of PA 06_0202.

Nil N/A



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2 5.1(a) The Dust Management Plan shall be prepared in consultation with the owners of the Bayswater rail loading facilities with the aim of achieving a consistent approach in the preparation of the Dust Management Plans for the Drayton and Bayswater rail facilities respectively.


Nil N/A

2 5.1(a) The Dust Management Plan shall include, but not be limited to the identification of dust affected properties and the relevant dust limits consistent with the EIS.

The AQMP provides all relevant dust limits. Although the AQMP does not specifically identify dust affected properties, it does utilise a blanket approach for all residents to the north of the project (essentially the only affected landowners).

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to specifications of the procedures for the dust monitoring program for the purpose of undertaking independent dust investigations, including joint investigations with the owners of the Bayswater rail loading facility and rail loop where necessary.

The AQMP provides all procedures required under this obligation. The instructions relating to the JAMP could be strengthened.

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to outline the procedure to notify property owners and occupiers likely to be affected by dust from the operations.

Section 4.16 of the AQMP provides instruction for engaging with stakeholders (through complaint management).

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to the establishment of a protocol for handling dust complaints that include recording, reporting and acting on complaints.

Refer to previous requirement. Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to appropriate mechanisms for community consultation.

There are no mechanisms for community consultation provided in the AQMP.

It is recommended that Drayton Coal revise the AQMP to include appropriate mechanisms for community consultation.

NC



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2 5.1(a) The Dust Management Plan shall include, but not be limited to outlining mitigation measures to be employed to minimise dust emissions.

Section 4.9 of the AQMP provides mitigation measures.

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to equipment to be available and used to control dust generation.

Section 4.11 provides equipment availability and utilisation.

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to methods to determine when and how operations are to be modified to minimise the potential for dust emissions if the relevant criteria are exceeded.

Section 4.9 of the AQMP states: “Mining coordinators and superintendents assess visual emissions and modify or cease operations as necessary. “

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to identification of longer term strategies directed towards mitigating dust levels that exceed the relevant EPA dust amenity criteria.

The mitigation measures provided in Section 4.9 of the AQMP include long term strategies. There were no reported exceedences of any air quality limits during the audit period.

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to details of locations for dust monitoring and deposition gauges (including existing Drayton monitoring locations if proposed to be used.) at residential areas and frequency of monitoring, as agreed with the EPA.

The AQMP includes dust monitoring locations.

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to a program to continue baseline monitoring undertaken prior to development consent.

The AQMP includes baseline monitoring and commits to continued comparison with the data.

Nil C

2 5.1(a) The Dust Management Plan shall include, but not be limited to details of the integration of this plan with the Drayton mine dust management plan, and this plan’s inter-relationship with the Bayswater rail facilities dust management plan.

The AQMP refers to the JAMP however the instructions relating to the JAMP could be strengthened.

Nil C



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2 5.1(b)a The Applicant shall undertake monitoring at locations described in the Dust Management Plan (Condition 5.1(a)).

Monitoring is being undertaken as per the requirement.

Nil C

2 5.1(b)ii The Applicant shall use existing relevant Drayton dust deposition and total suspended particulate (TSP) monitoring gauges for the Drayton Rail Loop and Antiene Rail Spur operations, including sites for monitoring impacts of dust at the nearest non-mined owned residences, and any additional locations as may be determined by the Dust Management Plan referred to in Condition 5.1(a).

Monitoring is being undertaken as per the requirement.

Nil C

2 5.1(b)iii The Applicant shall provide all results and analysis of air quality monitoring in the AEMR including a determination of the annual dust deposition rate in gm/m2/month, which shall be plotted in the AEMR.

The three relevant AEMRs for the audit period were reviewed. Air quality monitoring data is provided in all three AEMRs.

Nil C

2 5.1(c) Monitoring of dust deposition and the concentration of PM10 particulate matter in ambient air must be carried out at locations agreed to in consultation with the EPA. The sampling method, units of measure, interval and frequency of monitoring will be as set out in the "Approved Methods for Sampling and Analysis of Air Pollutants in NSW", or its latest version.

Locations of dust deposition and the concentration of PM10 particulate matter monitoring devices were undertaken prior to the audit period.

Nil N/A



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2 5.1(d)i In the event that a landowner or occupier considers that dust from the project at their dwelling or over more than 25% of their vacant land is in excess of the relevant EPA dust amenity criteria, and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request consult with the landowner or occupants affected to determine their concerns.


Nil C

2 5.1(d)ii In the event that a landowner or occupier considers that dust from the project at their dwelling or over more than 25% of their vacant land is in excess of the relevant EPA dust amenity criteria, and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request make arrangements for and bear the cost of, in consultation with the owner of the Bayswater rail loading facility and rail loop, appropriate independent dust investigations in accordance with the Dust Management Plan, and to the satisfaction of the Director-General, to quantify the impact and determine the source of the effect.


Nil C



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2 5.1(d)iii In the event that a landowner or occupier considers that dust from the project at their dwelling or over more than 25% of their vacant land is in excess of the relevant EPA dust amenity criteria, and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request modify the operation in accordance with the Dust Management Plan if exceedences are demonstrated to result from the operation. This shall include: Introduction of additional controls, either

of dust generation from individual sources on the site or on site operations or modify operations, to ensure that the dust criteria are achieved; and/or,

Enter into an agreement with the landowner, or provide such forms of benefit or amelioration as may be agreed between the parties as providing acceptable amelioration/benefit for the dust levels experienced. The agreement may also be made in consultation with the owner of the Bayswater rail loading facility and rail loop and

Conduct follow up investigations to the satisfaction of the Director-General, where necessary.


Nil N/A

2 5.1(e) If the independent dust investigations in sub-clause above confirm that dust limits are in excess of the relevant EPA dust amenity criteria, the Applicant shall at the written request of the owner acquire the relevant property. Acquisition shall be in accordance with the procedures set out in Condition 10.1, 10.2 and 10.3.


Nil N/A



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2 5.1(f) Further independent investigations shall cease if the Director-General is satisfied that the relevant consent limits or relevant EPA dust amenity criteria are not being exceeded and are unlikely to be exceeded in the future.


Nil N/A

2 5.2 Activities occurring at the premises must be carried out in a manner that will minimize emissions of dust from the premises.

Refer to Section 7.2. Refer to Section 7.2. C

2 5.3.1(a) For three years from the date of this consent, the applicant shall cooperate with the relevant mining operators to limit the cumulative noise contributions from the operation of Drayton rail loop and Antiene rail spur such that these noise levels in conjunction with the total cumulative noise emissions from the operations of the Drayton coal mine, Bayswater rail loading facility and rail loop, Bayswater mine, Antiene rail spur, and proposed Mount Arthur North project if approved, do not exceed the dB(A) Leq(9 hour/4

hour/11 hour) noise limits in Table 1 at any non-mine owned dwellings (refer also condition 10.1).


Nil N/A

2 5.3.1(a) The applicant shall also ensure that the noise levels from the Drayton rail loop and Antiene rail spur alone shall not exceed the dB(A) Leq(15 minute) noise limits also shown in Table 1 for the first three years from the date of this consent.


Nil N/A



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2 5.3.1(b) After three years from the date of this consent, the applicant shall cooperate with the relevant mining operators to limit the cumulative noise contributions from the Drayton rail loop and Antiene rail spur such that these noise levels in conjunction with the total cumulative noise contributions from the operations of the Drayton coal mine, Bayswater rail loading facility and rail loop, Bayswater mine and the Antiene rail spur, and proposed Mount Arthur North project if approved, do not exceed the dB(A) Leq(9 hour/4

hour/11 hour) noise limits in Table 2 at any non-mine owned dwellings (refer also condition 10.1).



2 5.3.1(b) The applicant shall also ensure that the noise levels from the Drayton rail loop and Antiene rail spur alone do not exceed the dB(A) Leq(15

minute) noise limits also shown in Table 2 after three years from the date of this consent.





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2 5.3.1(c) Notwithstanding condition 5.3.1 (b) above, the Director-General may otherwise agree to a request from the applicant to maintain the noise criteria of Table 1, provided that the Director-General is satisfied that the applicant can justify that it cannot achieve the noise criteria in Table 2 by: Providing full detail of whatever means

are required to achieve the noise levels in Table 2, and a quantitative analysis of the cost effectiveness of such means to the satisfaction of the EPA.

Following the analysis at (i) above, the applicant is required to determine, to the satisfaction of the EPA, the best alternative mitigation measures that might not achieve the levels in Table 2, but are considered reasonable and feasible and will be put in place by the applicant.

It was reported that Drayton Coal did not make any requests regarding amending noise limits to DPI during the audit period.

Nil N/A

2 5.3.1(d) Notwithstanding sub clauses (a), (b) and (c) above, the area of noise affectation for the cumulative operation of the Drayton rail loop, Antiene rail spur, Drayton coal mine, Bayswater rail loading facility and rail loop, Bayswater mine, Antiene rail spur, and proposed Mount Arthur North project if approved, is defined by demonstrated exceedence of noise levels at any non-mine owned dwellings of the dB(A) Leq(9 hour/4 hour/11

hour) noise limits shown in Table 3 below. The area of noise affectation for the Drayton rail loop and Antiene spur is defined by demonstrated exceedence of noise levels at any non-mine owned dwellings of the dB(A) Leq(15 minute) noise limits also shown in Table 3 below.

This requirement was not triggered during the audit period.

Nil N/A



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2 5.3.1(e)i In the event that a landowner or occupier considers that noise from the project at their dwelling is in excess of: the noise levels depicted in Table 1 within

the first three years from the date of this consent; or

the noise levels depicted in Table 2 after the first three years from the date of this consent (or as agreed by the Director-General); or

the noise levels depicted in Table 3; or that a landowner considers that the noise

levels depicted in Table 3 is being exceeded over more than 25% of their vacant land,

and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request consult with the landowner or occupants affected to determine their concerns.


Nil C



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2 5.3.1(e)ii In the event that a landowner or occupier considers that noise from the project at their dwelling is in excess of: the noise levels depicted in Table 1 within





and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request make arrangements for and bear the costs of, in consultation with the owner’s of Bayswater rail loading facility and rail loop, appropriate independent noise investigations in accordance with the noise management plan, and to the satisfaction of the Director-General, to quantify the impact and determine the source of the effect and contribution of the Drayton rail loop and Antiene rail spur.


Nil C



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2 5.3.1(e)iii In the event that a landowner or occupier considers that noise from the project at their dwelling is in excess of: the noise levels depicted in Table 1 within





and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request modify the coal transportation activity in accordance with a noise reduction plan prepared as part of the noise management plan, if exceedences are demonstrated to result from the coal transportation activity.

It was reported that Drayton Coal did not receive any written requests to modify coal transportation activities.

Nil N/A



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2 5.3.1(e)iv In the event that a landowner or occupier considers that noise from the project at their dwelling is in excess of: the noise levels depicted in Table 1 within





and the Director-General is satisfied that an investigation is required, the Applicant shall upon the receipt of a written request conduct follow up investigations to the satisfaction of the Director-General, where necessary.


Nil C

2 5.3.1(f) If the independent noise investigations in sub-clause (e) above confirm that noise limits in Table 3 are being exceeded, the Applicant shall at the written request of the owner acquire the relevant property. Acquisition shall be in accordance with the procedures set out in Condition 10.2 and 10.3.


Nil C

2 5.3.1(g) If continued complaints and noise investigations confirm that noise limits in Table 1 and/or 2 are being exceeded, but are less than the noise levels in Table 3, the Applicant shall continue to negotiate with the owner of the Bayswater rail loading facility and rail loop and the landowner until an acceptable resolution is reached.


Nil C



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2 5.3.1(h) Further independent investigations shall cease if the Director-General is satisfied that the relevant consent limits are not being exceeded and are unlikely to be exceeded in the future.


Nil C

2 5.3.2 The Applicant shall within three months of the date of this consent, prepare a Noise Management Plan for the Drayton rail loading facility and Antiene rail spur, to the satisfaction of the Director-General.


Nil N/A

2 5.3.2(a) The Noise Management Plan shall be prepared in consultation with the owner of Bayswater rail loading facility with the aim of achieving a consistent approach in the preparation of the Drayton rail loading facility noise management plan.


Nil N/A

2 5.3.2(a) The Noise Management Plan shall include details of the conduct of noise investigations at three monthly intervals (unless otherwise agreed by the Director-General) to evaluate, assess and report the both the Leq(15 minute)

(project alone) and Leq(9 hour/4 hour/11 hour) (cumulative) noise emission levels due to normal coal transport operations under adverse weather conditions.

Although the NMP does not strictly specify the obligations from this requirement, the noise monitoring (the combination of the Barn Owl real-time monitoring plus supplementary attended monitoring) provided should suffice. It is important to note that the DPI has approved this methodology. A section detailing how the requirements of the consent are satisfied should be included.

Nil C

2 5.3.2(a) The Noise Management Plan shall include details of the proposed methodologies including establishing the Drayton rail loop and Antiene rail spur operating configuration; determining survey intervals; weather conditions and seasonal variations; selecting variations, locations, periods and times of measurements.

As stated in the previous finding, whilst the NMP does not explicitly state each requirement, the provided methodology does suffice.

Nil C



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2 5.3.2(a) The Noise Management Plan shall outline the design of any noise monitoring and noise modelling or other studies including the means for determining the noise levels emitted by the operations.

Sections 5.2.1 and 5.2.2 provide Drayton Coal’s and independent noise monitoring processes respectively.

Nil C

2 5.3.2(a) The Noise Management Plan shall particularly focus on the management of night time noise (10.00pm – 7.00am) for each year of operation.

The NMP requires monitoring over a 12 month period to be taken at various times, including the night (10.00pm – 7.00am) timeframe.

Nil C

2 5.3.2(a) The Noise Management Plan shall identify noise affected properties and the relevant noise limits consistent with the EIS, the additional noise information requested by the EPA and supplied by Umwelt (Australia Pty Limited) in a letter dated 15 June 2000; with results of extended noise monitoring and in a letter dated 20 July 2000 and accompanying report titled “Response to EPA Submission of 5 July 2000; and the Drayton Coal Pty Ltd Response to Summary of Submissions received from DUAP on 2 June 2000, prepared by Umwelt (Australia) Pty Ltd, August 2000.

The noise assessment criteria provided in the NMP reflects the project approval, which in turn reflects the criteria provided in all relevant environmental assessments.

Nil C

2 5.3.2(a) The Noise Management Plan shall specify the procedures for a noise monitoring program for the purpose of undertaking independent noise investigations, in consultation with the owners of Bayswater mine, as necessary.

Refer to Condition 5.3.2(a), Schedule 2 of DA 106-04-00.

Nil C

2 5.3.2(a) The Noise Management Plan shall outline the procedure to notify property owners and occupiers likely to be affected by noise from the operations.

Section 5.6 of the NMP provides communication and stakeholder engagement processes.

Nil C



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2 5.3.2(a) The Noise Management Plan shall establish a protocol for handling noise complaints that include recording, reporting and acting on complaints.


Nil C

2 5.3.2(a) The Noise Management Plan shall record appropriate mechanisms for community consultation.


Nil C

2 5.3.2(a) The Noise Management Plan shall outline mitigation measures to be employed on the site to limit noise emissions.

Section 5.4 of the NMP provides mitigation measures.

Nil C

2 5.3.2(a) The Noise Management Plan shall identify longer term strategies directed towards mitigating noise levels that exceed the noise criteria in Table 2 under adverse meteorological conditions.

Section 5.8 of the NMP provides further commitments and measures to be implemented.

Nil C

2 5.3.2(a) The Noise Management Plan shall outline measures to be used to reduce the impact of intermittent, low frequency and tonal noise (including any truck reversing alarms).

Section 5.8 of the NMP states: “Alternative reversing beepers including Broadband (Quacker) Reverse Alarms have been implemented on all trucks, light vehicles and all other plant to further reduce noise emissions from these units across site.”

Nil C

2 5.3.2(a) The Noise Management Plan shall specify measures to be taken to document any higher level of impacts or patterns of temperature inversions, and detail actions to quantify and ameliorate enhanced impacts if they lead to exceedence of the relevant noise criteria.

The NMP describes the actions required to quantify and ameliorate enhanced impacts if they lead to exceedence The NMP specifies measures to document impacts.

Nil C



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2 5.3.2(a) The Noise Management Plan shall survey and investigate noise reduction measures, if required, from plant and equipment annually, subject to noise monitoring results and/or complaints received, and report in the AEMR at the conclusion of the first 12 months of operations and set targets for noise reduction taking into consideration valid noise complaints in the previous year. The Report shall also include remedial measures to achieve compliance with the specified noise goals.


Nil N/A

2 5.3.2(a) The Noise Management Plan shall include details of the integration of this plan with the existing Drayton mine Noise Management Plan, and its inter-relationship with the Bayswater rail facility noise management plan.

The latest NMP is a consolidation of the approval and consent noise management plans. The NMP refers to the JAMP however more information could be included (refer to Section 6.1).

Nil C

2 5.3.2(b) Prior to the commencement of operations the applicant shall ensure cladding is added to the northern side of the Drayton Coal Handling Facility, extending from ground level to the top of the conical section of both loading bins, with an internal facing of absorbing material and vibration isolated from the existing structure as described in the EIS.


Nil N/A

2 5.3.2(c)i The Applicant shall also make copies of the Plans available to the EPA, MSC and CCC within fourteen days of approval, or as otherwise agreed to be the Director-General.


Nil N/A

2 5.3.2(c)ii The Applicant shall also include a summary of noise monitoring results in the AEMR.

The three relevant AEMRs for the audit period were reviewed. Noise monitoring data is provided in all three AEMRs. Refer to Section 7.4.4.

Refer to Section 7.4.4. C



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2 5.3.3(a) The levels of noise emitted from the premises must be monitored for 72 hrs every 3 months unless otherwise agreed by the Director-General at locations agreed to in consultation with the EPA.

Monitoring is undertaken 24 hours per day by the Barn Owl. Independent monitoring is undertaken in accordance with the EPL.

Nil C

2 5.3.3(a) The monitoring must determine the LAeq,9hour,

LAeq,15min, LA10,15min, LA90, 15min, and LA1,1min and include an assessment of the impact of operational noise on adjoining residents.

Noise monitoring satisfies this requirement. Nil C

2 5.3.3(b) Noise monitoring at the specified locations must be undertaken during daytime (7.00am-6.00pm), evening (6.00pm-10.00pm) and night time (10.00pm-7.00am).


Nil C

2 5.4 The Applicant shall screen or direct all on-site lighting away from residences and roadways, or manage such lighting to the satisfaction of MSC.

The site inspection did not identify any external fixed lighting that was directed towards residents. Most of the lighting within the rail loop is attached to the rail loader which is screened from residents through vegetation and topography. Lights located along the rail loop that are not screened and fixed in a downward position and are shielded from shining above the horizontal. It was reported that no complaints about lighting was received from MSC during the audit period.

Nil C

2 6.1(a) Coal transported along the Drayton Rail Loop is limited to seven (7) million tonnes per annum.

Coal haulage reports (Document 25) indicate that the amount of coal transported along the Drayton Rail Loop was within limits during the audit period.

Nil C



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2 6.1(b) Coal transported along the Antiene Rail Spur is limited to twenty (20) million tonnes per annum.

It was reported that Mt Arthur Coal’s equivalent consent for the joint venture has since been suspended and their new consent allows for a greater amount of coal transport along the spur. Coal haulage reports indicate that the coal transport along the spur was within limits during the audit period.

Nil C

2 6.1(c) The peak number of train movements along the Drayton Rail Loop are limited to 12 per day.

Coal haulage reports (Document 25) indicate that the number of train movements along the Drayton Rail Loop was within limits during the audit period.

Nil C

2 6.1(d) The peak number of train movements along the Antiene Rail Spur are limited to 30 per day.

Coal haulage reports (Document 25) indicate that the number of train movements along the Antiene Rail Spur was within limits during the audit period.

Nil C

2 6.1(e) The maximum annual rate of coal haulage shall be calculated from the date of commencement of this consent. The Applicant shall submit a statement every six (6) months regarding the number of daily train movements, quantities and destination of product hauled on the Drayton rail loop and Antiene rail spur in that period to the Director-General unless otherwise agreed by the Director-General, commencing from the date of commencement of this consent.

Drayton Coal has submitted six monthly coal haulage reports during the audit period (Document 25).

Nil C



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2 6.1(f) To ensure residents access on the northern side of Antiene Road is not restricted, the Applicant shall consult with RAC to ensure amendment of the RAC signal procedures manual is undertaken so that the signal located to the west of the level crossing near the junction of the Antiene rail spur and the Main Northern Railway (signal 60) is the priority signal for access to the Main Northern Railway as discussed in section 4.3.2.2 of the EIS.

It was reported that this requirement is being complied with. Australian Rail and Track Corporation (ARTC) is responsible for signalling on the rail spur and the junction with the main line.

Nil C

2 6.2 No coal shall be hauled on public roads except under emergency or special situations and only with the prior written permission of the Director-General, RTA and MSC.


Nil C

2 7(a) In addition to the requirements contained elsewhere in this consent, the Director-General may, at any time in consultation with the relevant government authorities and Applicant, require the monitoring programs in Conditions 3 and 5 to be revised/updated to reflect changing environmental requirements or changes in technology/operational practices. Changes shall be made and approved in the same manner as the initial monitoring programs.

It was reported that Drayton Coal did not seek an amendment to any monitoring programs associated with the rail loop and spur.

Nil N/A

2 7(a) All monitoring programs shall also be made publicly available at MSC within two weeks of approval of the relevant government authority.


Nil N/A



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2 7(b) All sampling strategies and protocols undertaken as part of any monitoring program shall include a quality assurance/quality control plan and shall require approval from the relevant regulatory agencies to ensure the effectiveness and quality of the monitoring program.

The Environmental Monitoring Program does not include a quality assurance/quality control plan. The Environmental Monitoring Program is approved by DPI (prior to the audit period).

It is recommended that the Environmental Monitoring Program is revised to include a quality assurance/quality control plan which is suitable for all monitoring undertaken on site.

NC

2 7(b) Only laboratories with a nationally recognised relevant accreditation shall be used for laboratory analysis.

Laboratory certificates were sighted. All certificates were NATA accredited.

Nil C

2 7.1(a) Every three years from the date of this consent until completion of coal transportation in the DA area, or as otherwise directed by the Director-General, the Applicant shall conduct an environmental audit of the Drayton Rail loop operation and Antiene rail spur operation in accordance with ISO 14010 - Guidelines and General Principles for Environmental Auditing, and ISO 14011 - Procedures for Environmental Auditing (or the current versions), and in accordance with any specifications required by the Director-General.

The previous audit (Document 15) consolidated the DA 106-04-00 with PA 06_0202. Refer to Condition 8, Schedule 5 of PA 06_0202.

Nil C



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2 7.1(a) The audit shall be co-ordinated as far as possible with the audit for the Bayswater rail loading facility and rail loop as directed by the Director-General. Copies of the report shall be submitted by the Applicant to the Director-General, MSC, EPA, DMR, and CCC within two weeks of the report’s completion for comment.

The previous audit (Document 15) consolidated the DA 106-04-00 with PA 06_0202. As the report is consolidated with the approval, which has a longer timeframe for delivery, the audit report is required within 6 weeks. The audit report was submitted to DPI on 29/1/10 It was reported that it was not possible to coordinate this audit with Mt Arthur Coal’s auditing requirements. This audit was coordinated with Drayton Coal’s compliance audit for the PA 06_0202.

Nil C

2 7.1(b)i The audit shall assess compliance with the requirements of this consent, licences and approvals.

Refer to Section 7. Refer to Section 7. C

2 7.1(b)ii The audit shall assess the development against the predictions made in the EIS.


2 7.1(b)iii The audit shall review the effectiveness of the environmental management of the coal transportation operations, including any mitigation works.


2 7.1(b)iv The audit shall be carried out at the Applicant’s expense.

The audit team will invoice Drayton Coal upon completion of the audit report. Drayton Coal has raised a purchase order for the audit (Document 45).

Nil C

2 7.1(b)v The audit shall be conducted by a duly qualified independent person or team approved by the Director-General in consultation with MSC.

Refer to Section 2.2 and Appendix 6 for the audit team and their qualifications. DPI endorsed the audit team on 2 October 2012 (Document 39).

Nil C



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2 7.1(c) The Director-General may, after considering any submission made by the relevant government agencies, MSC and CCC on the report, notify the Applicant of any requirements with regard to any recommendations in the report. The Applicant shall comply with those reasonable requirements within such time as the Director-General may require.


Nil C

2 7.2 The applicant shall utilise the existing meteorological station at Drayton mine or establish an alternative meteorological station at a relevant location, in accordance with the requirements of AS 2922 1987 "Ambient Air Guide for Siting of Sampling Units" or updated version. The meteorological station must be capable of recording wind direction and speed, temperature and sigma theta and be operated in accordance with the requirements of AS 2923-1987 "Ambient Air Guide Horizontal Wind for Air Quality Application", or subsequent relevant standards.


Nil C

2 8.1(a) The Applicant shall, throughout the life of the rail loading facility and rail loop and for a period of at least three years after the completion of operations in the DA area, prepare and submit an Annual Environmental Management Report (AEMR), which may be incorporated into the existing Drayton AEMR to the satisfaction of the Director-General.

Drayton Coal’s AEMRs include the requirements for the consent. Refer to Condition 5, Schedule 5 of PA 06_0202.

Nil C



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2 8.1(a) The AEMR shall include a review of the performance of coal transportation against the Environmental Management Strategy, the conditions of this consent, and other licences and approvals relating to the coal transport operations.

All three applicable AEMRs (during the audit period) provided coal haulage performance against limits from the approval/consent.

Nil C

2 8.1(a)i To enable ready comparison with the predictions of the EIS, diagrams and tables, the report shall include, but not be limited to an annual compliance review of the performance of the project against conditions of this consent and statutory approvals.



NC

2 8.1(a)ii To enable ready comparison with the predictions of the EIS, diagrams and tables, the report shall include, but not be limited to a review of the effectiveness of the environmental management of the coal transport operations in terms of EPA, DMR, and MSC requirements.

All three applicable AEMRs (during the audit period) provided performance data with respect to their EPL limits.

Nil C

2 8.1(a)iii To enable ready comparison with the predictions of the EIS, diagrams and tables, the report shall include, but not be limited to results of all environmental monitoring required under this consent or other approvals, including interpretations and discussion by a suitably qualified person.

All three applicable AEMRs (during the audit period) provided monitoring data verified by specialists where applicable.

Nil C

2 8.1(a)iv To enable ready comparison with the predictions of the EIS, diagrams and tables, the report shall include, but not be limited to identify trends in monitoring results over the life of coal transport operations.



NC



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2 8.1(a)v To enable ready comparison with the predictions of the EIS, diagrams and tables, the report shall include, but not be limited to a listing of any variations obtained to approvals applicable to the subject area during the previous year.

All three applicable AEMRs (during the audit period) provided the changes to the approval conditions that resulted from the two modifications.

Nil C

2 8.1(a)vi To enable ready comparison with the predictions of the EIS, diagrams and tables, the report shall include, but not be limited to environmental management targets and strategies for the next year, taking into account identified trends in monitoring results.



NC

2 8.1(b)i In preparing the AEMR, the Applicant shall respond to any request made by the Director-General for any additional requirements.


Nil C

2 8.1(b)ii In preparing the AEMR, the Applicant shall comply with any requirements of the Director-General or other relevant government agencies.


Nil C

2 8.1(b)iii In preparing the AEMR, the Applicant shall ensure that the first report is completed and submitted within twelve months of this consent; or at a date determined by the Director-General in consultation with the DMR and the EPA; or in the next Drayton mine AEMR after the date of this consent.

It was reported that this requirement was not triggered within the audit period.

Nil N/A

2 9.1(i)(a) The Applicant shall, at its own expense provide to the existing Drayton Community Consultative Committee (CCC), or its equivalent, regular information on the progress of coal transport operations and monitoring results.

CCC minutes were reviewed. Drayton Coal regularly report on progress of coal transport operations and monitoring results.

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2 9.1(i)(b) The Applicant shall, at its own expense promptly provide to the Committee such other information as the Chair of the Committee may reasonably request concerning the environmental performance of the coal transport operations.

It was reported that Drayton Coal make every effort to adequately respond to requests from the CCC.

Nil C

2 9.1(i)(c) The Applicant shall, at its own expense provide access for site inspections by the Committee.

It was reported that Drayton Coal has facilitated open days and site inspections for members of the CCC.

Nil C

2 9.1(ii) The Applicant shall co-ordinate with Bayswater mine joint meetings of the Drayton and Bayswater CCCs or their equivalents, on a basis to be agreed by the two CCCs, to discuss the management of the joint user rail facility.

CCC meetings have been facilitated by Drayton Coal since the mine’s commencement in 1983. CCC meetings have been consolidated with Mt Arthur joint venture was instigated.

Nil C

2 9.2(a)i The environmental coordinator employed by Drayton mine (refer condition 2.1) shall be responsible for recording complaints with respect to coal transport operations along the Drayton rail loop and Antiene rail spur in accordance with the existing Drayton mine complaints handling procedures, or its equivalent, including use of the dedicated and publicly advertised telephone line, 24 hours per day 7 days per week, entering complaints or comments in an up to date log book, or other suitable data base, and ensuring that a response is provided to the complainant within 24 hours.

Drayton Coal maintains a 24/7 community hotline. All received complaints are facilitated by the Environmental Coordinator. The Environmental Coordinator will refer to Mt Arthur Coal where appropriate and follow-up with the complainant irrespective of the source mine.

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2 9.2(a)ii The environmental coordinator employed by Drayton mine (refer condition 2.1) shall be responsible for providing a report of complaints received with respect to the Drayton coal transportation operations every six months throughout the life of the project to the Director-General, MSC, EPA, DMR, and CCC, or as otherwise agreed by the Director-General. A summary of this report shall be included in the AEMR (condition 8.1(a)).

The Environmental Coordinator consolidates complaint reports with the six monthly coal haulage reports (Document 25).

Nil C

2 9.2(a)iii The environmental coordinator employed by Drayton mine (refer condition 2.1) shall be responsible consult with the environmental officer employed by the Bayswater mine to coordinate a response to any complaints received regarding the operation of the joint user rail facility.

Refer to Condition 9.2(a)i, Schedule 2 of DA 106-04-00.

Nil C

2 10.1(a) In the event that the cumulative impact of noise or dust contributed by the operation of the Drayton rail loading facility, rail loop and Antiene rail spur and other nearby mining/industrial activities, including the Bayswater rail loop, Bayswater mine, Drayton mine, and Mount Arthur North Project if approved, at dwellings, or vacant land (as described in Condition 6.3.1(e)), in the vicinity of the operation, is in excess of the noise or dust criteria contained in these conditions of consent, the Applicant shall negotiate with the other mining companies appropriate arrangements to reasonably contribute to the management of the identified cumulative impacts to the satisfaction of the Director-General.

It was reported that this requirement was not triggered within the audit period.

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2 10.1(b) If it is identified from subclause (a) above that an industrial operator, other than a mining company, is the cause of an exceedence, the applicant shall provide a report to the Director-General the reasons for the cumulative criteria exceedences with demonstration that the applicant’s activities are not the sole cause of the exceedences.

Refer to Condition 10.1(a), Schedule 2 of DA 106-04-00.

Nil N/A

2 10.1(c) If agreement on appropriate contributions towards mitigation measures/ acquisition cannot be reached from negotiations undertaken in accordance with subclause (a), then the Director-General may appoint an independent panel to resolve the matter. The membership of the independent panel shall be as determined by the Director-General. The independent panel shall determine the responsibilities of each of the mining companies. The decision of the independent panel shall be final and binding on all parties. The responsibilities of the mining companies and the landowner as described in Condition 10.2 and 10.3 will apply.


Nil N/A

2 10.1(d) Prior to the appointment of the independent panel, the applicant shall provide the Director-General a report detailing the applicant’s reasons for being unable to get agreement with the other parties, and the reasons for the cumulative criteria exceedences with demonstration that the applicant’s activities are not the sole cause of the exceedences.


Nil N/A

2 10.2(a) The Applicant shall negotiate and purchase a property, as identified in conditions 5.1, 5.3 and/or 10.1, within six (6) months of a written request from the affected land owner.


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2 10.2(b)i In respect of a request to purchase land arising under this condition, the Applicant shall pay the owner the acquisition price which shall take into account and provide payment for a sum not less than the current market value of the owner's interest in the land at the date of this consent, as if the land was unaffected by coal transport operations along the Drayton rail loop and Antiene rail spur the subject of this DA, having regard to: the existing use and permissible use of

the land in accordance with the applicable planning instruments at the date of the written request; and

the presence of improvements on the land and/or any Council approved building or structure which although substantially commenced at the date of request is completed subsequent to that date.


Nil N/A

2 10.2(b)ii In respect of a request to purchase land arising under this condition, the Applicant shall pay the owner the acquisition price which shall take into account and provide payment for the owner's reasonable compensation for disturbance allowance and relocation costs within the Muswellbrook or Singleton Local Government Area, or within such other location as may be determined by the Director-General in exceptional circumstances.


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2 10.2(b)iii In respect of a request to purchase land arising under this condition, the Applicant shall pay the owner the acquisition price which shall take into account and provide payment for the owner's reasonable costs for obtaining legal advice and expert witnesses for the purposes of determining the acquisition price of the land and the terms upon which it is to be acquired.


Nil N/A

2 10.2(c) Notwithstanding any other condition of this consent, the landowner and the Applicant may, upon request of the landowner, acquire any property affected by the project during the course of this consent on terms agreed to between the Applicant and the landowner.


Nil N/A

2 10.2(d)i In the event that the Applicant and any owner referred to in this condition cannot agree within the time limit upon the acquisition price of the land and/or the terms upon which it is to be acquired, then either party may refer the matter to the Director-General, who shall request the President of the Australian Institute of Valuers and Land Economists to appoint a qualified independent valuer or Fellow of the Institute, who shall determine, after consideration of any submissions from the owners, a fair and reasonable acquisition price for the land as described in sub-clause (c) and/or terms upon which it is to be acquired.


Nil N/A



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2 10.2(d)ii In the event that the Applicant and any owner referred to in this condition cannot agree within the time limit upon the acquisition price of the land and/or the terms upon which it is to be acquired, then: in the event of a dispute regarding outstanding matters that cannot be resolved, the independent valuer shall refer the matter to the Director-General, recommending the appointment of a qualified panel. The Director-General, if satisfied that there is need for a qualified panel, shall arrange for the constitution of the panel. The panel shall consist of: the appointed independent valuer, the Director-General or nominee, and the President of the Law Society of NSW

or nominee.


Nil N/A

2 10.2(e) The Applicant shall bear the costs of any valuation or survey assessment requested by the independent valuer, panel, or the Director-General and the costs of determination referred to in sub clauses (c) and (d).


Nil N/A

2 10.2(f) Upon receipt of a determination pursuant to sub-clauses (c) and (d), the Applicant shall, within 14 days, offer in writing to acquire the relevant land at a price not less than the determination. Should the Applicant's offer to acquire not be accepted by the owner within six (6) months of the date of such offer, the Applicant's obligations to purchase the property shall cease, unless otherwise agreed by the Director-General.


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2 10.2(g) In the event that only part of the land is to be transferred to the Applicant, the Applicant shall pay all reasonable costs associated with obtaining Council approval to any plan of subdivision and registration of the plan at the Office of the Registrar-General.


Nil N/A

2 10.2(h) The provisions of this condition do not apply to a land owner who is the holder of an authority under the Mining Act, 1992.


Nil N/A

2 10.3 The Applicant shall prior to commencement of the increased operations of the Drayton rail loop and Antiene rail spur, prepare a Joint Acquisition Management Plan with the owner of Bayswater rail loading facility and rail loop, to the satisfaction of the Director-General.


Nil N/A

2 10.3 The plan shall provide details of a joint approach to be adopted by the Applicant and the owner of the Bayswater rail loading facility and rail loop in regard to meeting the acquisition procedure requirements outlined in condition 10.2 of this consent relating to the cumulative impacts of the Drayton rail loop and Antiene rail spur, Drayton coal mine Bayswater rail loading facility and rail loop, Bayswater mine and the Mount Arthur North project if approved, should acquisition be required.

The JAMP (Document 46) satisfies this requirement.

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2 11.1(a) The Applicant shall ensure that all statutory requirements including but not restricted to those set down by the Local Government Act 1993, Protection of the Environment Administration Act 1991, Protection of the Environment Operations Act 1997, and all other relevant legislation, Regulations, Australian Standards, Codes, Guidelines and Notices, Conditions, Directions, Notices and Requirements issued pursuant to statutory powers by the MSC, EPA, DLWC, DMR, and RAC, are fully met.

Drayton Coal’s compliance with applicable licenses, legislation, approvals and consents has been assessed throughout this audit. Refer to Section 8.

Refer to Section 8. N/A

Appendix 3

Audit documents

Appendix 3

Audit documents


Table A2 Audit documents

Document No. Document

1 Mine Extension Environmental Assessment (Hansen Bailey, November 2007)

2 Project Approval Modification Environmental Assessment (Hansen Bailey, July 2009)

3 East Pit Tailings Emplacement & Explosive Storage Facility Environmental Assessment (Hansen Bailey, July 2011)

4 Letter from Pam Simpson, Drayton Coal to Ben Harrison, DPI (22 February 2011)

5 Letter from Julia Pope, DPI to Peter Forbes, Drayton Coal (9 May 2011)

6 Letter from Julia Pope, DPI to Peter Forbes, Drayton Coal (16 May 2011)

7 Letter from Scott Brooks, DPI to Pam Simpson, Drayton Coal (27 May 2011)

8 Letter from Julia Pope, DPI to Pam Simpson, Drayton Coal (13 July 2011)

9 Letter from Julia Pope, DPI to Pam Simpson, Drayton Coal (22 September 2011)

10 Email from Julia Pope, DPI to Peter Forbes, Drayton Coal (7 December 2011)

11 Drayton Coal – Coal Production Statistics – Fiscal Period Oct-2012 (8/11/12)

12 Construction Certificate No. 141/2010 – Mine Building, Thomas Mitchell Drive Muswellbrook

13 Memo from Brooke Lavis, Anglo American (14/5/12) – Horder Air Conditioner

14 Copy Tax Invoice for an air conditioner (11/5/12)

15 Drayton Mine Independent Environmental Audit, AECOM, 16 November 2009

16 Drayton Management System Standard Noise Management Plan (DRAFT 2012)

17 Email from James Benson, Drayton Coal to Scott Brooks, DPI (31 October 2012)

18 Letters from Brooke Lavis, Anglo American, to residents (12 in total) - Thomas Mitchell Drive – Road Closure on 23rd of October 2012 at 3pm due to blasting operations

19 Drayton Management System Standard Blast Management and Monitoring Plan

20 Drayton Management System Standard Spontaneous Combustion Management Plan

21 Drayton Management System Standard Air Quality Management and Monitoring Plan

22 Drayton Management System Standard Water Management Plan

23 Drayton Management System Standard Landscape Management Plan

24 Drayton Management System Standard Aboriginal Cultural Heritage Management Plan

25 Letters from Pam Williams or James Benson, Drayton Coal to DPI (audit period) – Coal Haulages and Enquires Reports

26 Email from Sally Pfeffer, Anglo American to James Benson, Drayton Coal (27 June 2012)

27 Drayton Management System Standard Greenhouse and Energy Efficiency Plan

28 Remondis Drayton Monthly Total Waste Management Report October 2012

29 Letter from G.H.J and P.H. De Boer, Muswellbrook to Letter from David Kitto, DPI (22/10/12)

30 Letter from David Kitto, DPI to Peter Forbes, Drayton Coal (23/12/11)

31 Drayton Mine Independent Review Noise and Blasting Report Number 630.10166_R1 7 October 2011 – SLR Global Environmental Solutions

32 Drayton Mine Air Quality Independent Review Report Number 630.10166_R2 7 October 2011 – SLR Global Environmental Solutions

33 Drayton Mine Independent Review Doherty Residence Noise and Blasting Report Number 630.10166-R3 23 March 2012 – SLR Global Environmental Solutions

34 Drayton Management System Standard Environmental Management Strategy

35 Drayton Management System Standard Environmental Monitoring Program

36 2009 Drayton Annual Environment Management Report



Appendix 3

Audit documents

Page 3.2 2172813A/PR_0665 PARSONS BRINCKERHOFF

Document No. Document

39 Letter from Scott Brooks, DPI to James Benson, Drayton Coal (2/10/2012)

40 Position Description – Environmental Coordinator (James Benson)

41 Anglo American System Standard - Environmental Enquiries Procedure

42 Letter from Peter Forbes, Drayton Coal to the Director General, DPI (19/1/12)

43 Letter from Howard Reed, DPI to Peter Forbes, Drayton Coal (25/1/12)

44 Anglo American System Standard - Water Management Procedure – Rail

45 Service Order K77509 (10/10/12)

46 Drayton Coal Pty Limited and Coal Operations Australia Limited Joint Acquisition Plan

47 Email from James Benson, Drayton Coal to Jeremy Arnott, Parsons Brinckerhoff (18/12/12)

48 Letter from James Benson, Drayton Coal to Craig Walker, RMS (19/10/12)

49 Email from Craig Walker, RMS to James Benson, Drayton Coal (29/10/12)

50 Drayton Trains (Excel Spreadsheet)

51 Water Discharge Event – October 2010

52 Blast Incident Report – Report on Shot ES27-B32-B42-BK15 Through Seam (11/5/11)

53 Letter from Pam Simpson, Drayton Coal to Julia Pope, DPI (16/6/11)

54 Letter from James Benson, Drayton Coal to Regional Manager, EPA (1/6/12)

55 Letter from James Benson, Drayton Coal to Julia Pope, DPI (1/6/12)

Appendix 4

Site photographs

Appendix 4

Site photographs


Photograph 1 –. Drayton Coal Mine (Southern Pit). It was reported that dust generation from the dragline is indicative

of normal operation.

Photograph 2 –The Antiene Rail Spur

Photograph 3 – Indicative general waste bin from site. This particular bin was located in the heavy vehicle workshop.

Note the amount of recyclable material.

Appendix 3

Site photographs

Page 4.2 DRAYTON COAL COMPLIANCE AUDIT (FINAL) PARSONS BRINCKERHOFF

Photograph 4 – Access Road Dam. Note water appeared to clean and free from obvious contamination.

Photograph 5 – Soil with apparent hydrocarbon contamination being deposited inside the bund wall of the bulk diesel

tank. Note dried material in top left of wall which indicates habitual practice

Photograph 6 – Waste batteries not being stored in a bunded/contained area (light vehicle workshop).

Appendix 4

Site photographs


Photograph 7 – Bioremediation area.

Photograph 8 – Savoy Dam. Note water appeared clean and free from obvious contamination although weed

management requires review.

Photograph 9 – The Drayton Coal rail loop. Note the lights are pointed down and shielded.

Appendix 3

Site photographs

Page 4.4 DRAYTON COAL COMPLIANCE AUDIT (FINAL) PARSONS BRINCKERHOFF

Photograph 10 – Fencing and signage at the northern offset area

Photograph 11 – Uncontained hydrocarbon leak from a water pump. Note that hydrocarbons have incurred into the

southern offset area.

Photograph 12 – Incursion of hydrocarbon contamination into the southern offset area. Note that the pump is situated on the access track which forms the border of the offset area. Note there is no fencing or signage indicating the offset area. It is important to note that this photograph was taken approximately 24 hours after the previous photograph was

taken. The pump has since been replaced but the spill has not been cleaned up.

Appendix 4

Site photographs


Photograph 13 – TEOM.

Photograph 14 – HVAS.

Appendix 5

Agency consultation log

Appendix 5

Agency consultation log


Table A5 Agency consultation log

Date Method Agency Contact Content

31 October 2012

Meeting DPI Scott Brooks Drayton Coal’s overall performance during the audit was discussed where it made apparent that although the audit identified a number of minor concerns (refer to Section 7.2), no major issues requiring the immediate attention of the DPI were found.

Drayton Coal had submitted a number of environmental management plans to the DPI for review on 31 October 2012 (the last day of the site audit and the day of the meeting with DPI). It was discussed that the audit would assess the adequacy of these plans as opposed to their respective existing pre-revision plans. This would allow Drayton Coal to revise these plans in accordance with the findings of this audit and resubmit the plans at a later date. DPI subsequently approved an extension of the submission date to 29 March 2012.

The intended approach of the audit was discussed with DPI and no issues were raised.

22 November 2012

Telephone DTIRIS Greg Summerhayes

Audit process reviewed progression of mining within approval boundary.

22 November 2012

Telephone DPI Scott Brooks The purpose of this conversation was to discuss the replacement of Dr Martin Predavec with Derek Low as the approved reviewer for the audit report. It was discussed that Martin was no longer available to provide a review of the audit in a suitable timeframe and that Derek appropriately qualified to undertake the quality review. DPI approved the replacement.

Appendix 6

Audit team curriculum vitae

PARSONS BRINCKERHOFF 28/03/2011 : M

JEREMY ARNOTT Environmental Scientist

Years of experience 8.5 (>1.5 with PB, 7 with others)

Residence Australia

Languages English

Education Bachelor of Science (Professional) (Honours), University of Newcastle

Professional qualifications Certified Lead Environmental Auditor, RABQSA International (RABQSA No. 112595)

Key qualifications Jeremy has extensive experience in the development and implementation of environmental and integrated (environmental, OHS, quality, risk, corporate governance and human resources) management systems, as well as associated management plans and performance documentation. Jeremy has consulted to companies and organisations in a range of industries across Australia and the Pacific, namely the mining and resource sector, State and Commonwealth Government and to the rail industry. Jeremy is a RABQSA certified Lead Environmental Auditor. He has performed numerous environmental audits, the majority being Compliance Audits based on Development Approvals, Environmental Impact Statements, tender submissions and other contractual documentation.

Previous experience

Environmental management system development Environmental management system development (2010–2011), Canberra, ACT, Australia,

Commonwealth Department of Sustainability, Environment, Water, Population and Communities. Team member. Revision and quality control.

Environmental management system development (2010), Newcastle, NSW, Australia, Country Rail Infrastructure Authority. Team member. Revision and quality control.

Environmental management system development (2009), Canberra, ACT, Australia, Commonwealth Department of Human Services. Project manager. Developed environmental management system in accordance with ISO14001. Revised existing documentation; developed new procedures and forms; principal client liaison; managed development team.

Integrated management system development Development of the Renex Management System (2012-2013), Melbourne, Vic, Australia, Renex

Holdings (Dandenong). Technical Lead. The Renex Management System was an integrated management system comprising environmental, quality and occupational health and safety elements. Designed the system, constructed core elements, liaised with software developers and assisted with project management.

Integration of environmental and occupational health and safety management systems (2009, 2011), Sydney, NSW, Australia, Confidential Client. Project manager. Project involved revision of environmental management system and subsequent integration with the existing occupational health and safety management system. Revised existing documentation; developed new procedures and forms; principal client liaison; managed development team.

Development of the Sustainable Business Management System (2009–2010), Brisbane, Qld, Harmony Gold. Project coordinator. Project involved the development of a fully integrated, eight tier management system incorporating corporate governance, risk management, business growth, human resources, environmental, occupational health and safety, quality and social management systems. Managed development team and project resources; developed new procedures and forms; client liaison.

Gold Ridge Gold Mine Integrated Management System (2008), Honiara, Solomon Islands, Australian Solomons Gold. Project coordinator. Project involved development of an integrated management

Jeremy Arnott

PARSONS BRINCKERHOFF 28/03/2011 2

system incorporating environmental, community relations and occupational health and safety management systems. The integrated management system was developed in accordance with ISO14001, AS/NZS 4801 and the International Finance Corporation Performance Standards. Revised existing documentation; developed new procedures and forms; client liaison; managed development team.

Environmental management documentation development RAAF Williamtown Environmental Management System Services (2011), Stockton Bight, NSW,

Australia. Spotless Facility Services. Team member. Developed a Construction Environmental Management Plan template. Documentation development and review.

Environmental Management Plans (2010), Gold Ridge, Solomon Islands, Gold Ridge Mining Limited. Team member. Project involved the development of Cyanide, Waste, Waste Rock, Erosion and Sedimentation, Surface and Groundwater, Air Quality and Noise and Vibration Management Plans. Documentation development and review.

Community management documentation development Relocation Action Plan (2008–2010), Honiara, Solomon Islands, Gold Ridge Mining Limited/Australian

Solomons Gold. Project coordinator. Development of Relocation Action Plan (and subsequent revisions) for resettlement of local indigenous population from mining lease area. Plans were developed in accordance with the International Finance Corporation’s Performance Standards. Plan development; client liaison; project management.

Stakeholder Engagement Plan (2008), Honiara, Solomon Islands, Australian Solomons Gold. Team member. Development of plan for community consultation with local indigenous population within the mining lease and neighbouring areas. Plans were developed in accordance with the International Finance Corporation’s Performance Standards. Plan development; client liaison.

Occupational health and safety management system development Occupational health and safety management system development (2010–2011), Newcastle, NSW,

Australia, Samaritans Foundation. Project manager. Developed occupational health and safety management system in accordance with AS/NZS4801. Revised existing documentation; developed new procedures and forms; principal client liaison; managed development team.

Auditing Environmental performance audit (2012), Boggabri, NSW, Boggabri Coal, Idemitsu Resources.

Evaluated environmental performance of principal mining contractor against contractual documentation and industry leading practice. Project manager.

Independent environmental compliance audit (2012), Ravensworth, NSW, Australia, Ravensworth Operations Project, Xstrata. Evaluated compliance against project approval. Led audit, prepared report and client liaison.

Environmental performance audit (2012), Blackwater, Qld, Australia, Wesfarmers Curragh Mine. Evaluated current environmental performance against project approval obligations. Led audit, prepared report and client liaison.

Environmental obligations design report (2012), Newcastle, NSW, Australia, Upper Hunter Valley Alliance. Assessed rail design against environmental obligations from assessment documentation. Conducted audit and prepared report.

Environmental management system audit (2012), Mt Isa, Qld, Australia, Stanwell Pty Ltd. Audit leader. Assessed environmental management system implementation and performance. Conducted audit; reviewed report.

Environmental compliance audits (2011-2012), Perth, WA, Australia, Magellan Metals. Auditor. Quarterly assessment of compliance with internal environmental management and monitoring programs. Conducted audits and prepared reports.

Environmental compliance audit (2011), Adelaide, SA, Australia, SA Water. Principal Auditor. Assessment contractors’ compliance with construction environmental management plan. Conducted audits and prepared report.

Jeremy Arnott


Environmental management system audit (2011), Newcastle, NSW, Australia, Country Rail Infrastructure Authority. Audit leader. Assessed environmental management system implementation and performance. Conducted audit; reviewed report.

Occupational health and safety management system gap analysis (2010), Newcastle, NSW, Australia, Samaritans Foundation. Audit leader. Assessed occupational health and safety management system’s conformance to AS/NZS4801. Conducted audit; prepared report and action plan.

Environmental compliance audit (2010), Broke, NSW, Australia, Bulga Coal, Xstrata Coal. Audit leader. Assessed external lighting in accordance with development approval. Conducted audit; reviewed report; project management.

Environmental, quality and safety compliance audits (2010), Newcastle, NSW, Australia, EnergyAustralia. Audit leader. Assessed EnergyAustralia construction contractors’ compliance to tender submissions. Audits involved initial audit with six monthly follow-ups. Conducted audits (8 total) and prepared report.

Environmental management system gap analysis (2009), Canberra, ACT, Australia, Commonwealth Department of Human Services. Audit team member. Assessed environmental management system’s conformance to ISO14001. Conducted audit; prepared report and action plan.

Environmental management system gap analysis (2009), Sydney, NSW, Australia, Confidential Client. Assessed environmental management system’s conformance to ISO14001. Conducted audit; prepared report and action plan.

Environmental management system audit (2008), Broke, NSW, Australia, Bulga Coal, Xstrata Coal. Audit team member. Assessed environmental performance of the coal handling and processing plant. Conducted audit and prepared report.

Environmental management system audit (2008), Broke, NSW, Australia, Bulga Coal, Xstrata Coal. Audit team member. Assessed environmental performance of the workshop and area station. Conducted audit and prepared report.

Environmental management system audit (2008), Broke, NSW, Australia, Bulga Coal, Xstrata Coal. Audit team member. Assessed surface water management. Conducted audit and prepared report.

Environmental assessment Review of environmental factors for the Singleton Sewage Treatment Plant upgrade (2011), Singleton,

NSW, Australia. Project manager. Prepared and managed a REF for construction of an upgrade to a sewage treatment plant. Project management; report development and client liaison.

Site based environmental management Environmental inspections and monitoring (2011), Adelaide, SA, SA Water. Construction

Environmental Interface Officer. Project involved the client liaison with construction contractors, environmental inspections and monitoring, provision of advice, preparation of reports and auditing.

Training development Off-the-Shelf Environmental Training Modules (2008–2009), Newcastle, NSW, Australia, Graham A

Brown & Associates. Project manager. Development of 17 environmental training modules with associated supporting documentation. Completed product included over 800 slides of training material with over 2500 pages of supporting documentation. Module and supporting documentation development; project management.

Teaching experience Environmental Auditor Certification Workshop, Newcastle, 2011.

Environmental Auditor Certification Workshop, Newcastle, 2010.

Environmental Auditor Certification Workshop, Port Hedland, 2010.

Environmental Management Systems Workshop, Newcastle, 2010.

Integrated Management Systems Workshop, Newcastle, 2010.

Spill Control and Awareness Workshop, Melbourne, 2009.

Jeremy Arnott


Professional development Integrated Management Systems Workshop, Newcastle, 2009.

Environmental Auditor Certification Workshop, Newcastle, 2008.

Environmental Management Systems Workshop, Newcastle, 2008.

Publications Arnott J, Williams R, Pandolfo A & Donne S 2007, ‘Microporosity of heat-treated manganese

dioxide’ Journal of Power Sources, vol. 165, no. 2, pp. 581-590.

Arnott J & Donne S 2007 'Examining manganese dioxide - Graphite connectivity in alkaline electrolytes', Journal of the Electrochemical Society, vol. 154 pp. A776-A783.

Arnott J, Browning G, & Donne S 2006 'Study on manganese dioxide discharge using electrochemical impedance spectroscopy', Journal of the Electrochemical Society, vol. 153 pp. A1332-A1340.

Professional history 2011–present Parsons Brinckerhoff 2007–2011 Graham A Brown & Associates 2004–2007 University of Newcastle

PARSONS BRINCKERHOFF 1

HUGH MADDEN Principal Environmental Scientist Parsons Brinckerhoff Accredited Project Manager RABQSA International Accredited Principal Environmental Auditor

Years of experience 19 (12 with Parsons Brinckerhoff; 7 with others)

Residence Languages Australia English

Education Bachelor of Science, University of Wollongong

Professional affiliations RABQSA International, Accredited Principal Environmental Auditor (Certificate No. 14761) Association of Professional Engineers, Scientists and Managers, Australia

Key qualifications Hugh is a principal environmental scientist with 19 years experienced in a range of environmental assessment and management projects. He is typically involved in large and/or multi-discipline projects requiring environmental input and has extensive experience in managing and supervising projects. He also has substantial experience with program alliances. Hugh is an accredited principal environmental auditor (RABQSA International Certificate No. 14761) and has fulfilled a number of independent environmental management representative roles on infrastructure projects. He has previously been an airport environment officer appointed by the Commonwealth Department of Transport and Regional Services for the Sydney Basin Airports as well as working for the NSW Environment Protection Authority and its predecessor the NSW State Pollution Control Commission (1991-1993). In addition, Hugh was Parsons Brinckerhoff’s state health and safety coordinator for NSW. In this role his responsibilities were to ensure the implementation of Parsons Brinckerhoff Australia’s Business Procedure for OHS within NSW with direct reporting to the state operations executive and the national OHS manager.

Parsons Brinckerhoff experience

Environment manager roles Transmission Cable Alliance (2010–2011), Sydney, NSW, Australia, Ausgrid. Environment manager.

The Transmission Cable (TraCa) Alliance was established to undertake the planning and delivery/construction of 132kV transmission cable projects within Ausgrid’s network. Hugh was part of the original alliance management team. Key deliverables and responsibilities of the environment manager role included: member of the alliance management team; environment policy; alliance environmental management plan/EMS; environmental induction and training material; environmental resource planning; environmental impact assessments and approvals; construction environmental management plans; technical support to planning and construction teams; audits; environmental performance reporting; environmental cost estimates for Target Outturn Costs (TOCs) and program risk management.

Sewerfix Wet Weather Alliance (2007–2010), Sydney, NSW, Australia, Sydney Water. Environment manager. The SewerFix Wet Weather Alliance was established to undertake the planning and delivery of solutions to reduce the frequency of wet weather related overflows from the key Sydney Water sewerage systems so as to meet targets set in their Environmental Protection Licences. Hugh was part of the original alliance management team. Key deliverables and responsibilities of the environment manager role included: environment policy; environmental management system; environmental induction and training material; environmental resource planning; environmental impact assessments and approvals; delivery environmental management plans (CEMPs and SEMPs); technical/specialist support to planning and delivery teams; environmental auditing (EMS, CEMP, SEMPs, KPIs); environmental performance reporting (sustainability, KPIs, Sydney Water corporate

Hugh Madden


and Alliance Management Team requirements); environmental cost estimates for Target Out-turn Costs (TOCs) and program risk management.

Wet Weather Overflow Reduction Program 1 (2005–2007), Sydney, NSW, Australia, Alinta. Environment manager. Hugh was appointed as Alinta’s environment manager for the Wet Weather Overflow Reduction Program 1 (WWORP1). This program was established to reduce the frequency of wet weather overflows from sections of Sydney Water’s sewerage system. During the define/design phase of the program, Hugh was responsible for the project management/coordination and technical review as well as obtaining Sydney Water’s approval for approximately 30 individual Review of Environmental Factors (REFs) as well as assisting Sydney Water in obtaining legislative approvals from other regulatory authorities. During the delivery phase of the program, Hugh managed the preparation and approval process for the Construction Environmental Management Plan and approximately 30 individual site environmental management plans.

Environmental management representative roles Belmore Park Zone Sub-Station (2010–present), Sydney, NSW, Australia, Ausgrid. Independent

environmental representative. Hugh was appointed as the independent environmental representative for the Stage 1A of the Sydney City Grid Project which involves the construction of a new zone sub-station. The role and authority of the environmental representative is specified in the conditions of approval and broadly requires the ER to: oversee the implementation of all environmental management plans and monitoring programs required under this approval, and advise the Proponent upon the achievement of these plans/programs; consider and advise the Proponent on its compliance obligations against all matters specified in the conditions of approval and the Statement of Commitments, permits and licences and have the authority and independence to recommend to the Proponent reasonable steps to be taken to avoid or minimise unintended or adverse environmental impacts, and, failing the effectiveness of such steps, to recommend to the Proponent that relevant activities are to be ceased as soon as reasonably practicable if there is a significant risk that an adverse impact on the environment will be likely to occur.

City West Cable Tunnel (2007–2010), Sydney, NSW, Australia, Ausgrid. Independent environmental management representative (EMR.. Hugh was appointed as the independent environmental management representative for the construction of the City West Cable Tunnel (CWCT), which became operational in 2010. The role and authority of the EMR is specified in the approval conditions issued for the construction of the CWCT. Key responsibilities of the EMR included: advising the Director-General of the Department of Planning and Energy Australia on matters relating to the approval conditions and compliance with during construction; review and endorsement the Construction Environmental Management Plan and subsequent updates; monitor construction activities to ensure compliance with the CEMP; recommend stop work orders be issued if an unacceptable impact on the environment is occurring or is likely to occur; review of corrective and preventative actions identified during construction to ensure their implementation and attend Community Liaison Group (CLG) meetings.

North West Transitway (2004–2005), Sydney, NSW, Australia, Roads and Traffic Authority. Interim environmental management representative. Hugh’s role was that of Interim Environmental Management Representative for the demolition of acquired properties before the commencement of construction works associated with the North West Transitway project. This role involved the review of the Environmental Impact Assessment report and RTA tender specification relating to Environment Protection, review and approval of Construction Environmental Management Plans prepared by the demolition contractors as well as periodic site inspections and reporting on environmental management aspects of demolition works as they progressed.

Environmental audits Belmore Park Zone Sub-Station (2010–present), Sydney, NSW, Australia, Ausgrid. Independent

environmental representative. Hugh was appointed as the independent environmental representative (ER) for the Stage 1A of the Sydney City Grid Project which involves the construction of a new zone sub-station by the NSW Department of Planning. The responsibilities of this position involved a component of auditing during the pre-construction and construction phases. Pre-construction auditing focused on ensuring that the CEMP and associated management sub plans complied with the requirements of key documents (e.g. Minister’s Conditions of Approval, Environmental Assessment, Submissions Report and Statement of Commitments). Construction auditing focused on evaluating compliance of construction works against the requirements of the CEMP and associated management sub plans.

Hugh Madden


Annual Environmental Management Report Stage 2 Kerosene Vale Ash Repository (2010), Wallerawang, NSW, Australia, Delta Electricity. Lead and principal environmental auditor. Parsons Brinckerhoff was engaged to prepare the first annual environmental management report for the operation of the Stage 2 Kerosene Vale Ash Repository at Wallerawang. The annual report is a condition of the project approval issued by the Department of Planning and its purpose is to detail the environmental performance of the project against the Operational Environmental Management Plan and the conditions of the project approval. In preparing the annual environmental report, a compliance audit was undertaken against the requirements of the OEMP and the conditions of project approval in addition to the review of site operations and environmental data. Recommendations were also provided to Delta Electricity in relation to actions required to ensure ongoing compliance with the OEMP and conditions of approval. Hugh was the lead/principal auditor and project manager for this project.

City West Cable Tunnel (2007–2010), Sydney, NSW, Australia, Ausgrid. Independent environmental management representative. Hugh was appointed as the independent environmental management representative by the NSW Department of Planning. The responsibilities of this position involved a component of auditing during the pre-construction and construction phases. Pre-construction auditing focused on ensuring that the CEMP and associated management sub plans complied with the requirements of key documents (e.g. Minister’s Conditions of Approval, Environmental Assessment, Submissions Report and Statement of Commitments). Construction auditing focused on evaluating compliance of construction works against the requirements of the CEMP and associated management sub plans.

Hexachlorobenzene (HCB) Waste Repackaging Project (2008–2009), Sydney, NSW, Australia, Orica Australia Pty Ltd. Independent environmental auditor. In 2008 the NSW Department of Planning approved Hugh to undertake an independent environmental audit of the hexachlorobenzene (HCB) waste repackaging plant project as required by the project approval. The scope of the audit required that the audit: be carried out in accordance with ISO19011:2002 – Guidelines for Quality and/or Environmental Management Systems Auditing; assess compliance with the requirements of the project approval, other licences and approvals that apply to the project; assess the environmental performance of the project against the predictions made and conclusions drawn in the Part 3A Environmental Assessment; and review the effectiveness of the environmental management of the project, including any environmental impact mitigation works. To date two environmental audits have been completed (2008 and 2009).

Independent Environmental Audits Shell Cove Waste Relocation Works (2007), Shellharbour, NSW, Australia, Australand. Environmental auditor. Parsons Brinckerhoff was commissioned to perform independent environmental audits of the waste relocation works associated with Shell Cove Boatharbour/Marina development. The focus of the audits was that of compliance against the environmental management requirements/conditions detailed in the project EMP and site EMPs. A total of 6 audits were undertaken covering the various phases of the overall project. Hugh was the lead auditor and project manager.

Independent Environmental Audits of Shadforth Wetlands Project (2005–2006), Shellharbour, NSW, Australia, YSCO Geomatics. Environmental auditor. Parsons Brinckerhoff was commissioned to undertake environmental audits of the civil earthworks associated with the construction of wetlands as part of the Myimbarr Community Park project. The audits were conducted against the Environmental Management Plan developed for the site and Landcom’s Performance Improvement Review system. The results of the audits were forwarded to the Project Manager (YSCO Geomatics) and Site Superintendent and followed up in subsequent audits. A total of 5 audits were undertaken covering the various phases of the overall project

Environmental Audit Mt Piper Power Station (2005), Mt Piper, NSW, Australia, Delta Electricity. Environmental auditor. Parsons Brinckerhoff was commissioned to undertake an environmental audit of the ash placement operations at the Mt Piper power station to assess compliance with Development Consent conditions and associated documentation. Hugh was a member of the 2 person site audit team and involved in the pre and post audit meetings and site auditing.

Environmental Audit of Caltex Twin Service Centres, F3 Freeway (2004), Wyong, NSW, Australia, Australian Unity. Environmental auditor. Parsons Brinckerhoff was engaged by Australian Unity to undertake an environmental audit of the Caltex Service Centres servicing north and south bound F3 Freeway traffic. Hugh was responsible for undertaking the audit including report preparation and project management.

Hugh Madden


Environmental Audit of ABB Moorebank Facilities (2003), Sydney, NSW, Australia, ABB Australia Pty Limited. Environmental auditor. Parsons Brinckerhoff was commissioned to undertake an environmental audit of three ABB divisions that had recently relocated to the ABB Moorebank site. The purpose of the audit was to identify the environmental aspects and impacts of these divisions as part of the ongoing development and implementation of the ABB Environmental Management System (EMS) at Moorebank. Hugh was a member of the 2 person site audit team.

Environmental Audit ADI Facilities, Garden Island (2003), Sydney, NSW, Australia, Defence Maintenance Management. Environmental auditor. Parsons Brinckerhoff was commissioned by Defence Maintenance Management (DMM), on behalf of the Department of Defence (DoD) to undertake a comprehensive environmental audit of ADI’s facilities and operations at Garden Island. The principal objective of the audit was to assess the activities and facilities operated by ADI with respect to compliance with environmental legislative requirements; the adequacy of ADI’s environmental management plan being used to manage the environmental aspects of the site; and identify opportunities for continued improvement. This audit covered the ADI lease at Garden Island, in particular the Captain Cook graving dock, heavy workshops, Cruiser Wharf, stores as well as industrial support and administration facilities. Hugh was a member of the 2 person audit team and involved in the pre and post audit meetings, site auditing and preparation of the audit report.

Environmental Audit of Prospect Quarry Southern Employment Land (2001–2005), Sydney, NSW, Australia, Boral Resources. Environmental auditor. This project involved the environmental auditing of fill material placement works associated with the redevelopment of the quarry void for employment land within the Greystanes Estate. The purpose of the auditing was to ensure the fill material placed in the quarry void is compatible with the proposed industrial land use. Detailed audit reports were prepared as work packages were completed and subject to an independent review.

Regulatory roles Airport Environment Officer (2003–2005), Sydney, NSW, Australia, Commonwealth Department of

Transport and Regional Services. Airport environment officer (AEO). Responsibilities included ensuring airport environments were managed in accordance with the Airports (Environment Protection) Regulations 1997 made under the Airports Act 1996, conducting environmental audits of tenants at Sydney airports including Kingsford Smith (Mascot), Bankstown, Hoxton Park and Camden, liaising with Airport Corporations and major tenants, preparation of quarterly progress reports for DOTARS as well as being on call to attend incidents/ emergency that may result in pollution of the environment.

Environmental impact assessments and associated studies Transmission Cable Alliance (2010–2011), Sydney, NSW, Australia, Ausgrid. Environment manager.

The Transmission Cable (TraCa) Alliance was established to undertake the planning and delivery/construction of 132kV transmission cable projects within Ausgrid’s network. Hugh was responsible for the project management/coordination, review and obtaining Ausgrid approval for five individual Review of Environmental Factors (REFs) during the design phase of the program as well as obtaining additional legislative permits as required from other authorities.

Replacement of 11kV Switchgear at Epping Zone Substation Review of Environmental Factors (2010–11), Sydney, NSW, Australia, Ausgrid. Project manager. The existing 11kV switchgear at the Epping zone substation was approaching the end of its serviceable life and required replacement. PB was engaged to prepare the Review of Environmental Factors documentation associated with the construction, operation and maintenance of a new switch/control room building and replacement of 11kV switchgear. Hugh was the project manager for the REF.

Reverse Osmosis Plant and Waste Water Pipeline Review of Environmental Factors (2010), Wallerawang and Mount Piper Power Stations, NSW, Australia, Delta Electricity. Project manager. Parsons Brinckerhoff was engaged to prepare Review of Environmental Factors documentation for these two projects. The REFs were undertaken in parallel with the design process in order to provide input into the design phase (e.g. replacement of scour points with pump out points) and to ensure the project’s overall approval in a timely manner to facilitate construction and operation. A number of specialist studies were undertaken to support the REFs including noise impact assessments, traffic impact assessments, flora/fauna surveys and heritage surveys. Hugh was the project manager for the REF.

Initial Environmental Review RAAF Base Williamtown Stage 2 Redevelopment (2010), Williamtown, NSW, Australia, Department of Defence, Defence Support Group, Infrastructure Asset Development Branch. Project manager and joint author. Hugh was the project manager and joint author of the Initial

Hugh Madden


Environmental Review (IER), which is similar to a preliminary environmental impact assessment. The IER was prepared to inform Defence, and relevant stakeholders, of the potential environmental, social and heritage issues relating to the construction and operation of the project. The IER involved a desktop review and gap analysis of existing environmental information and to identify any further studies required during the planning phase of the project. In addition, an environmental risk assessment was undertaken to identify and priorities the environmental impacts likely to be associated with the project along with management and mitigation measures to address the identified impacts.

Sewwerfix Wet Weather Alliance (2007–2010), Sydney, NSW, Australia, Sydney Water. Environment manager. The SewerFix Wet Weather Alliance was established to undertake the planning and delivery of solutions to reduce the frequency of wet weather related overflows from the key Sydney Water sewerage systems so as to meet targets set in their Environmental Protection Licences. Hugh was responsible for the project management/coordination, review and obtaining Sydney Water’s approval for numerous Review of Environmental Factors (REFs) during the define and design phase of the program as well as assisting Sydney Water to obtain legislative approvals from other regulatory authorities.

Wet Weather Overflow Reduction Program 1 (2005–2007), Sydney, NSW, Australia, Alinta. Environment manager. This program was established to reduce the frequency of wet weather overflows from sections of Sydney Water’s sewerage system. Hugh was responsible for the project management/coordination, review and obtaining Sydney Water’s approval for approximately 30 individual Review of Environmental Factors (REFs) during the define and design phase of the program as well as assisting Sydney Water to obtain legislative approvals from other regulatory authorities.

Homebush Bay Remediation Project Environmental Impact Statement (2002), Sydney, NSW, Australia, Thiess Services. Environmental scientist. Responsible for the preparation of technical papers for the EIS relating to the extent of contamination at the Lednez Site (former Union Carbide site) as well as in Homebush Bay, human health and ecological risk assessment at the Lednez Site and review of remediation options.

Modeling of Contaminant Transport in Groundwater (2002–2003), Rhodes, NSW, Australia, Thiess Services. Project manager. Project management of specialist groundwater consultant undertaking the modeling of contaminant transport in groundwater based on post remediation scenarios at the Lednez Site (former Union Carbide site).

Technical Papers for Application to Change Development Consent Conditions (2002–2003), Rhodes, NSW, Australia, Thiess Services. Project manager. Parsons Brinckerhoff were engaged by Thiess Services to prepare a series of technical papers to support an application to change development consent conditions associated with the remediation of the former Allied Feeds site which adjoins the Lednez site (former Union Carbide site). The technical papers addressed modeling of contaminant transport in groundwater based on post remediation scenarios, traffic impact assessment and data quality reports for existing contaminated site investigations. Hugh was responsible for project management of the technical papers in addition to preparing the data quality reports.

Remediation projects Remediation of Former RTA Depot (2004–2005), Bourke, NSW, Australia, Roads and Traffic Authority

(2004-2005). Project manager. The objective of the remediation works was for the site to reach a status suitable for residential use (caretaker’s residence) and Gundabooka Aboriginal Community activities including plant nursery, storage area, workshops, office buildings and women’s shed. The project involved the removal of fuel related infrastructure, stabilisation and off site disposal of free tar, excavation of impacted soil/fill and subsequent bioremediation via landfarming and validation sampling of the depot site and landfarmed material. Hugh was PB’s project manager.

Underground Storage Tank Replacement Program (2004), Liverpool and Blacktown East, NSW, Australia, ExxonMobil. Project environmental supervisor. Parsons Brinckerhoff was engaged by ExxonMobil to assist with the management of the underground storage tank replacement program at two service station sites. Responsibilities included the preparation of project plans including Remediation Action Plan, Environmental Management Plan, Erosion Control Plan and Occupational Health and Safety Plan. In addition, Hugh was responsible for the on site supervision of civil works to ensure compliance with environmental management requirements as well as the preparation of site condition reports upon completion of works.

Contaminated land assessments Combined Phase 1 and 2 Environmental Site Assessment (2002–2003), Prospect Quarry, NSW,

Australia, Boral Resources. Project manager and technical lead. Responsibilities included the project

Hugh Madden


management and preparation of a combined Phase 1 and 2 Environmental Site Assessment (ESA) report associated with the redevelopment of a 12 hectare portion of the Quarry known as Widemere East within the Southern Employment Land (SEL). Other responsibilities included liaison with the redevelopment project manager and client representatives. The site assessment was undertaken prior to redevelopment works to ensure the land was suitable for the proposed industrial land use. This project was subject to an independent review.

Phase 1 and 2 Environmental Site Assessments (2004) of the Eastern Extension of the Eastern Creek Waste Management Centre, Sydney, NSW, Australia, Waste Service NSW. Project manager and technical lead. Responsibilities included the project management and preparation of Stage 1 and Stage 2 Environmental Site Assessment (ESA) reports associated with the construction of a new landfill cell at the Eastern Creek Waste Management Centre. The ESA reports covered soil, sediment, surface water, groundwater and landfill gas investigations. The purpose of the project was to establish the pre-existing condition of the site with respect to contamination issues prior to the construction of a new landfill waste cell and to assist lease negotiations between Waste Service NSW and Planning NSW. This project was subject to an independent review.

Phase 1 and 2 Environmental Site Assessments (2000–2001), Prospect Quarry, NSW, Australia, Boral Resources. Project manager and technical lead. Responsibilities included the project management and preparation of Stage 1 and Stage 2 Environmental Site Assessment (ESA) reports associated with the redevelopment of a 60 hectare portion of the Quarry designated as the Northern Employment Land (NEL). Other responsibilities included liaison with the redevelopment project manager, client representatives and earthworks contractor. The site assessments were undertaken prior to bulk earthworks to ensure the land was suitable for the proposed industrial land use. This project was subject to an independent review.

Previous experience

Remediation projects Treatment of Schedule X Chemical Waste (2000), Sydney, NSW, Australia, Sydney Olympic Co-

ordination Authority. Project site supervisor. Involvement in this project was that of night shift site supervisor for a period of six weeks. During this time soil contaminated by organochlorine compounds was treated using an Indirect Thermal Desorption (ITD) plant. Responsibilities were to ensure that all works, undertaken during the shift, complied with the NSW EPA licence conditions as well as the project OH&S plan, EMP and Inspection and Test Protocols.

Remediation of the Martin Street Residential Estate (1999–2000), Armidale, NSW, Australia, Commonwealth Department of Finance and Administration. Project site supervisor. The estate consisted of 39 individual residential lots and a public reserve. The remediation works involved the demolition of three residential dwellings, the excavation of contaminated soil from 16 lots and the vertical mixing of soil on 23 lots as well as the public reserve. Approximately 5,000m3 of soil contaminated by PAHs and arsenic was removed from the site, of which 420m3 was bioremediated prior to disposal. Over 800 samples were collected and analysed during the six month project. This project was subject to an independent review. Responsibilities included preparation of project plans/documents, induction of site personnel regarding site safety and environmental requirements, supervision of civil subcontractors during remediation works, sample collection associated with investigation, waste classification and validation phases of the project, liaison with client’s representative/site superintendent, preparation of works completed reports and site validation report.

Remediation of a former disposal area associated with a foundry (1998–1999), Sydney, NSW, Australia, The Crane Group. Project site supervisor. The project involved the excavation, stabilisation and off site disposal of approximately 5,000m3 of lead and nickel contaminated soil/foundry sands using a mobile stabilisation (pugmill) plant. Responsibilities included conducting stabilisation trials, submitting treatment proposals to NSW EPA for review and approval, preparing project Environmental Management, OH&S and Quality plans, induction of site personnel regarding OH&S and environmental requirements, supervision of site personnel and civil subcontractors, liaison with client’s representative and preparation of off site disposal requests for site superintendent’s approval.

Remediation of a former sheep dip site (1997), Canberra, ACT, Australia, Environment ACT. Project site supervisor. Project involved the demolition of three residential dwellings and the excavation and off site disposal of approximately 2,700m3 of soil contaminated by arsenic. Over 400 soil samples were collected and analysed during the two month project. This project was subjected to and passed an independent review. Responsibilities included OH&S inductions of site personnel, supervision of civil subcontractor during remediation works, monitoring of respirable and depositional dust, collection of delineation and validation samples, preparing works completed reports for the client and ACT

Hugh Madden


Government, attending weekly community meetings to discuss the progress and findings of the project and preparation of site validation report.

Remediation of a decommissioned pesticide manufacturing plant (1997), Sydney, NSW, Australia, Boral. Project environmental scientist. Project involved the decontamination and demolition of site buildings. Excavation and off site disposal of soil/waste contaminated by organochlorine and organophosphorus pesticides, arsenic and heavy metals as well as on site bioremediation of soil contaminated by TPHs. Over 2,000 samples were collected during the project. Responsibilities consisted of supervising the validation sampling of the remediated site and preparing the site validation reports as well as liaising with client and NSW EPA.

Environmental Management Plan for Mortlake Town/Manufactured Gas Plant Rehabilitation (1997), Sydney, NSW, Australia Australian Pacific Projects. Project environmental scientist. Preparation of the Environmental Management Plan for Stage 2 of the rehabilitation of the Australian Gas Light (AGL) Town/Manufactured Gas Plant.

Stabilisation and on site containment of arsenic contaminated soil at an industrial park (1995), Sydney, NSW, Australia, Confidential Client. Project environmental scientist. Project involved a desktop review of the site’s history to identify any potential contamination issues. Subsequent soil sampling identified arsenic contaminated soil of high leachability, which was identified as impacting site groundwater. Arsenic contaminated soil was delineated, stabilised and contained on site so as to prevent further contamination of site groundwater. Responsibilities included undertaking the desktop review, soil/groundwater investigations and stabilisation trials, preparation of reports and subsequent validation report. Other tasks included liaison with client and NSW EPA.

Remediation of a decommissioned tyre manufacturing plant (1995), Sydney, NSW, Australia, Goodyear. Project environmental scientist. Project involved the excavation and off site disposal of 4,500m3 of soil/waste contaminated mainly by zinc, copper, lead, cadmium, chromium, nickel, arsenic and PAHs of which 1,800m3 was stabilised prior to disposal. 3,000m3 of soil contaminated by TPHs and BTEX was bioremediated on site for future use during site redevelopment. Over 600 samples were collected and analysed during the six month project. This project was subject to independent review. Responsibilities included preparation of Remediation Action Plan, supervision of staff undertaking delineation and validation sampling, preparation of excavation plans, conducting stabilisation trials, liaison with client representative and NSW EPA, data assessment/interpretation and preparing the site validation report.

Remediation of a disused tannery (1994), Sydney, NSW, Australia, Sydney Water Corporation. Project environmental scientist. Project involved the demolition of 40 buildings and the excavation and off site disposal of approximately 20,000m3 of soil/waste contaminated mainly by arsenic and chromium. Other contaminants included TPHs, BTEX, PAHs, copper and lead. Over 3,000 soil samples were collected and analysed during the nine month project. Responsibilities included assisting with the preparation of the Remediation Action Plan, supervision of staff involved in delineation and validation sampling; preparation of excavation plans, liaison with analytical laboratories, data assessment/interpretation and preparing the site validation report.

Regulatory roles Environment Protection Officer (1992–1993), Wollongong, NSW, Australia, Environment Protection

Authority. Environment protection officer, Catchment Management Unit. Assisted with the writing of the South Coast Region case study for the 1993 NSW State of the Environment Report. Conducted site surveys for a study entitled "Urban Erosion: A Study of the Degree of Compliance with Best Management Practice in the South Coast Region". Assisted inspectorial staff with investigations. Carried out water quality surveys of Burrill and Tabourie Lakes. Involved in the development of a centralised water quality database and assisted in the development of a catchment-based inventory of municipal sewage treatment plants within the South Coast region.

Technical Officer (1991–1992), Wollongong, NSW, Australia, State Pollution Control Commission. Technical officer. Undertook a water quality survey of the Shoalhaven River. Presented an audio-visual report to the Shoalhaven River Water Quality Working Party, concerning the changes in dissolved oxygen levels from 1986 to 1991. Wrote a simplified user manual for the Yeo-Kal submersible Data Logger and engaged in general report writing.

Professional development High Performance Team Training, Changeangles, 2011.

Realising Your Leadership Potential, Development Dimensions International, 2008.

Hugh Madden


Sydney Water Incident Controller Training, Sydney Water, 2008.

Planning For Effective Public Participation, International Association for Public Participation (IAP2), 2007.

Environmental Performance Summit, Liquid Learning Group, 2007.

Various alliance training and workshops as part of pursuit/tendering phase for the SewerFix Wet Weather Alliance, Alchemie Pty Ltd, 2006/2007.

Work Clearance for Contractors, Australian Institute of Petroleum, 2004.

Senior First Aid Certificate, St John Ambulance Australia, 2003.

Environmental Management Systems – Accredited Lead Auditor Training Course, QSA International, 2002.

Work Clearance for Contractors, Australian Institute of Petroleum, 2002.

Accredited Course in OHS Consultation, WorkCover NSW 2002.

Work Control Procedures for Service Stations and Depots, Mobil, 2001.

Accredited Occupational Health and Safety Induction Training for Construction Work – General Course, WorkCover NSW, 2001.

8 Hour Refresher Course, US OHSA, 1996

40 Hour Hazardous Waste Site Health & Safety Training, US OHSA, 1995.

Professional history 2000–present Parsons Brinckerhoff 1993–2000 ADI Limited 1992–1993 Environment Protection Authority NSW 1991–1992 State Pollution Control Commission/Environment Protection Authority NSW

PARSONS BRINCKERHOFF 18/10/2011: M

JUSTINE FIRTH Environmental Scientist

Years of experience 4 (1.5 with Parsons Brinckerhoff, 2.5 with others)

Residence Languages Australia English

Education Bachelor of Science (Atmospheric Science), Macquarie University; Bachelor of Science (First Class Honours) (Chemistry), Macquarie University; Graduate Diploma Environmental Law, University of Sydney

Key qualifications Justine is an environmental scientist with 4 years’ experience working in air quality and has recently joined the Parsons Brinckerhoff team. During this time, she has worked on a number of air quality impacts assessments projects which include the modelling of power stations, odour studies and controversial mine projects in New South Wales. She has experience in air emissions modelling including TAPM, AUSPLUME, ISCST3 and CALPUFF for a range of projects which include the mining, agriculture and industrial sectors and also has experience with geographic information systems such as ArcGIS. Justine has been involved in working on an ACARP research project in the Hunter Valley during the course of her studies and is currently studying a Graduate Diploma in environmental law.

Parsons Brinckerhoff experience

Air quality impact assessment Moorebank Intermodal (2012), Moorebank, Department of Finance. Environmental Scientist. Air

quality impact assessment for a proposed intermodal in southwest Sydney. Air dispersion modelling has been completed for a range of pollutants to determine potential impacts of the project.

Ravensworth Audit (2012), Hunter Valley, New South Wales, Ravensworth operations. Environmental Scientist. Completion of an audit of the air quality management plan.

Future Gas Supply Area (2012), Queensland, Santos. Environmental Scientist. Air quality impact assessment for a proposed coal seam gas processing facility that would supply coal seam gas to Gladstone. Air dispersion modelling was completed to determine the worst case incremental and cumulative impacts for a range of pollutants.

Wallumbilla Gas Turbine Facility (2012), Wallumbilla, Queensland, Santos. Environmental Scientist. Air quality impact assessment for a proposed coal seam gas processing facility that would for part of the Wallumbilla Hub. Air dispersion modelling was completed to determine the worst case incremental and cumulative impacts for a range of pollutants.

Cloncurry Rail Loadout Facility (2012), Cloncurry, Queensland, MMG. Environmental Scientist. Air quality impact assessment for a proposed rail load out facility for zinc and lead concentrate. Air dispersion modelling was completed at the initial design level to determine worse case impacts for to determine the conditions set in the Environmental Management Plan.

North Sydney Freight Corridor (2012), Sydney, New South Wales, Transport for NSW. Environmental Scientist. Air quality impact assessment for three proposed upgrades to the North Sydney Freight Corridor and includes North Strathfield Rail Underpass, Epping to Thornleigh Third Track and Gosford Passing Loop. Each air quality impact assessment investigated the potential impacts of emissions from locomotives in sensitive receivers located along the rail corridor.

Marulan Approvals Assistance (2012), Marulan, New South Wales, Siemens Ltd Australia. Environmental Scientist. Review of approval requirements in relation to air quality and aviation safety for a proposed change to turbine technology used at the Marulan Gas Fired Turbine Facility.

Cawdor Farm Development (2012), Cawdor, New South Wales, Muscat Hydroponics. Environmental Scientist. Completion of an odour and dust air quality impact assessment for a proposed chicken broiler farm in western Sydney.

Wollondilly Shire Council Peer Review (2012), Tahmoor, New South Wales, Wollondilly Shire Council. Environmental Scientist. Peer review of odour impact assessment for potential impacts of duck broiler

Justine Beaney

PARSONS BRINCKERHOFF 18/10/2011: M 2

farm odour and turkey abattoir odour on proposed rezoning of land for residential purposes in Tahmoor, New South Wales.

Kerrawary Power Station (2011), Southern Highlands, New South Wales, Origin Energy Limited. Environmental Scientist. Air quality impact assessment for a proposed open cycle gas turbine peaking power station producing up to 1000 MW.

Kauffman Property Consultants (2011), Ballarat, Vic., Australia, Kauffman Property Consultants. Environmental scientist. This project was a buffer study that qualitatively assessed the potential air quality impacts of nearby industry on a proposed residential development in Ballarat, Victoria.

Solar Flair Project (2011), Kogan, Qld, Australia, Marubeni Corporation. Environmental scientist. An air quality assessment for the potential impacts of coal seam gas combustion used to supplement a utility scale solar power generation.

Paradise South Phosphate Project (2011), Mt Isa, Qld, Australia, Legend International Holdings. Environmental scientist. Air quality impacts assessment for dust, fluoride and heavy metals for a proposed phosphate mine located north of Mount Isa, Queensland.

West Dapto Upgrade (2011), Illawarra, NSW, Australia, Sydney Water. Environmental scientist. Dispersion modelling to assess the existing and potential future impacts of H2S at residences in the Illawarra region.

Previous experience

Air quality impact assessment – industry & mining Cameron Park Asphalt Plant (2011), Lower Hunter, NSW, Australia, Boral. Environmental scientist. Air

quality impact assessment for potential dust, odour and other gaseous pollutants impact on air quality for the proposed asphalt plant in Cameron Park.

Grants Road Quarry (2011), Sydney, NSW, Australia, Grants Road Quarry. Environmental scientist. Conducted dispersion modelling in assessing the potential air quality impacts of a sand quarry.

Mount Pleasant Project (2010–2011), Hunter Valley, NSW, Australia, EMGA Mitchell McLennan. Environmental scientist. Involved the assessment of the change potential dust impacts for proposed service corridor for the Mount Pleasant Project.

Maules Creek Mine (2010–2011), Hunter Valley, NSW, Australia, Hansen Bailey. Environmental scientist. Assessed potential dust impacts and greenhouse gas emissions for proposed mine.

Metropolitan Colliery (2010), Helensburgh, NSW, Australia, Metropolitan Colliery. Environmental scientist. The assessment of the potential change in dust impacts for proposed modifications to the underground vent shaft at Metropolitan Colliery.

Eastern Creek Waste Recycling Centre (2010), Sydney, NSW, Australia, Eastern Creek Waste Recycling Centre. Environmental scientist. Assisted in the assessment of odour and dust impacts from proposed changes to Eastern Creek Waste Recycling Centre.

Moorebank Recyclers (2010), Sydney, NSW, Australia, Moorebank Recyclers. Environmental scientist. Assessed potential change in dust impacts for proposed modifications to Moorebank Recyclers.

Bengalla Coal Mine Modification (2009), Hunter Valley, NSW, Australia, Hansen Bailey. Environmental scientist. Assessed potential change in dust impacts and greenhouse gas emissions for proposed modifications to Bengalla Coal Mine.

Boggabri Coal Mine Continuation (2009–2010), Gunnedah Basin, NSW, Australia, Hansen Bailey. Environmental scientist. Assessment of the potential dust impacts and greenhouse gas emissions for proposed continuation of Boggabri Coal Mine.

Bloomfield Colliery (2009), Hunter Valley, NSW, Australia, Bloomfield Colliery. Business environment. Environmental scientist. Assessed potential change in dust impacts for proposed modifications to the Bloomfield Colliery.

Papua New Guinea Liquid Natural Gas Project (2007), Papua New Guinea. Papua New Guinea Liquid Natural Gas. Graduate environmental scientist. Assisted in modelling the potential air quality impacts of the proposed liquid natural gas pipeline in Papua New Guinea.

Justine Beaney


Camden Gas Project (2010), Camden, New South Wales. Atmospheric Scientist. Greenhouse gas assessment for natural gas supply in western Sydney.

Cement Australia (2010), Australia. Atmospheric Scientist. National Pollutant Inventory calculations for a several Cement Australia sites for the 2009/2010 reporting period.

Air quality impact assessment – roads and infrastructure Australian Rail Track Corporation (2009), Hunter Valley, NSW, Australia, Australian Rail Track

Corporation. Environmental scientist. Assisted in the qualitative assessment of the potential impacts of fugitive coal dust emissions from the Hunter Valley rail network.

Lane Cove Tunnel (2008), Sydney, NSW, Australia, Roads and Traffic Authority. Graduate environmental scientist. Assisted in a comparison study of monitoring data before and after the construction of the Lane Cove Tunnel.

Port Botany Expansion (2008) Sydney, NSW, Australia, City of Port Botany. Graduate environmental scientist. Assisted in the assessment of potential air quality impacts for the proposed expansion of Port Botany to allow for increased shipping flows.

Air quality impact assessment – odour impact Pascoe Planning (2009–2010), Camden area, NSW, Australia, Pascoe Planning. Environmental

scientist. Qualitative and quantitative assessments of potential odour impacts from chicken farms on various subdivision developments in the Camden area.

Air quality impact assessment – plume rise assessments Newcastle Gas Storage Facility (2011), Newcastle, NSW, Australia, AGL Energy Limited.

Environmental scientist. Plume rise assessment for several flares scenarios at the proposed Newcastle Gas Storage Facility.

Munmorah Rehabilitation (2010), Central coast, NSW, Australia, Delta Electricity. Environmental Scientist. Assisted with the plume rise assessment for the rehabilitation of Delta Electricity’s Munmorah Power Station.

Orica (2010), Botany, NSW, Australia, Orica. Environmental scientist. Assisted with the plume rise assessment for a number stacks located near Sydney Airport.

Bulla Energy Park (2009), SA, Australia, AGL. Environmental scientist. Assisted with plume rise assessment for the proposed Torrens Island Power Station.

Air quality management and review Mount Pleasant Project (2011), Hunter Valley, NSW, Australia, EMGA Mitchell McLennan.

Environmental scientist. Development of air quality management and monitoring plan for Mount Pleasant open cut coal mine.

Boggabri Coal/Tarrawonga Mine/Maules Creek Mine joint project (2011), Gunnedah Basin, NSW, Australia, Boggabri Coal/Tarrawonga Mine. Environmental scientist. Development of shared air quality monitoring plan for Boggabri Coal, Tarrawonga Mine and Maules Creek Mine.

Mount Thorley Warkworth (2010–2011), Hunter Valley, NSW, Australia, Coal & Allied. Project manager. Detailed metrological investigations of elevated particulate matter measurements recorded by the Mount Thorley Warkworth air quality monitoring network.

Hunter Valley Operations (2010–2011), Hunter Valley, NSW, Australia, Coal & Allied. Project manager. Detailed metrological investigations of elevated particulate matter measurements recorded by the Hunter Valley Operations air quality monitoring network.

Bulga Coal (2010), Hunter Valley, NSW, Australia, Bulga Coal. Environmental scientist. Detailed metrological investigations of elevated particulate matter measurements and long term trend analysis of data recorded by Bulga Coal air quality monitoring network.

Metropolitan Colliery (2010), Helensburgh, NSW, Australia, Metropolitan Colliery. Project manager. Detailed metrological investigations of elevated particulate matter measurements recorded by the Metropolitan Colliery air quality monitoring network.

Awards Honours Scholarship, Macquarie University, 2008–2009.

Justine Beaney


Professional development 5th International Conference on Advanced Vibrational Spectroscopy – Melbourne, 2009.

TAPM-CTM training, The Air Pollution Model – Chemical Transport Model, CSIRO (Commonwealth Scientific and Industrial Research Organisation), 2009.

19th International Clean Air & Environment Conference – Perth, 2009.

4th Australian Aerosol Workshop, AINSE and ANSTO, 2008.

Professional history 2011–present Parsons Brinckerhoff 2009–2011 PAEHolmes (formerly Holmes Air Sciences) 2007–2009 Holmes Air Sciences (casual)

DR BASIL BEAMISH MANAGING DIRECTOR – B3 MINING SERVICES PTY LTD

SENIOR LECTURER IN MINING ENGINEERING (DIRECTOR - SPONTANEOUS COMBUSTION TESTING LABORATORY)

QUALIFICATIONS Chartered Professional (Mining) Registered Professional Engineer of Queensland No.12621 PhD in Mining Engineering, University of Auckland, 1998 MSc in Mining Engineering, University of New South Wales, 1985

NSW Mines Rescue Certificate of Competency No. 2500, Southern Mines Rescue Brigade, 1980 BSc Hons, University of Tasmania, 1979

EMPLOYMENT 2007 - present Managing Director – B3 Mining Services Pty Ltd 2000 - present The University of Queensland, Director – Spontaneous Combustion Testing Laboratory 1998 - present The University of Queensland, Senior Lecturer in Mining Engineering 1991 - 93 James Cook University, Director – Coalseam Gas Research Institute 1987 - 98 The University of Auckland, Lecturer/Senior Lecturer 1980 - 87 Collinsville Coal Company Ltd, Mine Geologist/Geotechnical Engineer INDUSTRY AWARDS 2009 Recipient of the AusIMM Jim Torlach Health and Safety Award 1980 - 87 Member of North Queensland Mines Rescue Brigade (Vice-Captain of winning team Interdistrict Mines

Rescue Competition (1981 and 1982); Captain of winning team (1983) and runner-up team (1985) EK Healy Cup Mines Rescue Competition)

PROFESSIONAL SOCIETIES

Member Australasian Institute of Mining & Metallurgy Member Bowen Basin Geologists Group

SPECIALIST AREAS Spontaneous combustion of coal; Coalseam gas; Gas content measurement; In-seam drilling and drainage;

Frictional ignition; Coal properties SELECTED RELEVANT PUBLICATIONS

BEAMISH, B and Beamish, R, 2012. Testing and sampling requirements for input to spontaneous combustion risk assessment, in Proceedings of the Australian Mine Ventilation Conference, B Beamish and D Chalmers (eds), pp 15-21 (The Australasian Institute of Mining and Metallurgy: Melbourne). BEAMISH, B and Beamish, R, 2012. Benchmarking coal self-heating using a moist adiabatic oven test, in Proceedings of the 14th US/North American Mine Ventilation Symposium, F Calizaya and M G Nelson (eds), pp 423-427 (University of Utah, Department of Mining Engineering, Utah, USA). BEAMISH, B, Lin, Z and Beamish, R, 2012. Investigating the influence of reactive pyrite on coal self-heating, in Proceedings 12th Coal Operators’ Conference, N Aziz (ed), pp 295-300 (University of Wollongong and The Australasian Institute of Mining and Metallurgy). BEAMISH, B, McLellan, P, Turunc, U, Raab, M and Beamish, R, 2012. Quantifying spontaneous combustion inhibition of reactive coals, in Proceedings of the 14th US/North American Mine Ventilation Symposium, F Calizaya and M G Nelson (eds), pp 435-440 (University of Utah, Department of Mining Engineering, Utah, USA). BEAMISH, B and Beamish, R, 2011. Experience with using a moist coal adiabatic oven testing method for spontaneous combustion assessment, in Proceedings of the 11th Underground Coal Operators’ Conference, University of Wollongong and The AusIMM, Wollongong, February 2011, pp 380-384. Leal, M, BEAMISH, B and Claassen, C, 2011. Analysis of ethane emission trends from active goaf seals at Mandalong Mine, in Proceedings of the 11th Underground Coal Operators’ Conference, University of Wollongong and The AusIMM, Wollongong, February 2011, pp 375-379. BEAMISH, B and Beamish, R, 2010. Benchmarking moist coal adiabatic oven testing, in Proceedings of the 10th Underground Coal Operators’ Conference, University of Wollongong and The AusIMM, Wollongong, February 2010, pp 264-268. BEAMISH, B, Sutherland, T, Coull, M, Walker, D, Day, G, Shales, C, Craker, R, Rowland, J and Smith, J, 2010. Application of fault tree analysis to coal spontaneous combustion, in Proceedings of the 10th Underground Coal Operators’ Conference, University of Wollongong and The AusIMM, Wollongong, February 2010, pp 269-273.

Claassen, C and BEAMISH, B, 2010. Case study of ethane emissions at Mandalong Mine, in Proceedings of the 10th Underground Coal Operators’ Conference, University of Wollongong and The AusIMM, Wollongong, February 2010, pp 274-280. Cliff, D, BEAMISH, B and Cuddihy, P, 2009. Explosions, fires and spontaneous combustion, in Australasian Coal Mining Practice (eds: R J Kininmonth and E Y Baafi), pp 800-814 (The Australasian Institute of Mining and Metallurgy: Melbourne). BEAMISH, B and Hughes, R, 2009. Comparison of laboratory bulk coal spontaneous combustion testing and site experience – A case study from Spring Creek Mine, in Proceedings of the 9th Underground Coal Operators’ Conference, University of Wollongong and The AusIMM, Wollongong, February 2009, pp 287-295. BEAMISH, B B and Arisoy, A, 2008. Effect of intrinsic coal properties on self-heating rates, in Proceedings of the 12th US/North American Mine Ventilation Symposium, The Society of Mining, Metallurgy and Exploration Inc., Littleton USA, pp149-153. Arisoy, A, BEAMISH, B B and Cetegen, E, 2006. Modelling spontaneous combustion of coal, Turkish Journal of Engineering & Environmental Sciences, 30, 193-201.

BEAMISH, B B, 2005. Comparison of the R70 self-heating rate of New Zealand and Australian coals to Suggate rank parameter, International Journal of Coal Geology, 64, 139-144. BEAMISH, B B, Barakat, MA and St. George, J D, 2001. Spontaneous-combustion propensity of New Zealand coals under adiabatic conditions, in Geotechnical and Environmental Issues Related to Coal Mining, P. Lindsay and T.A. Moore (eds), Special Issue, International Journal of Coal Geology , 45(2-3), 217-224. BEAMISH, B B, Barakat, M A and St. George, J D, 2000. Adiabatic testing procedures for determining the self-heating propensity of coal and sample ageing effects, Thermochimica Acta, 362(1-2), 79-87. BEAMISH, B B and Crosdale, P J, 1998. Instantaneous outbursts in underground coal mines: an overview and association with coal type, in Coalbed Methane: From Coal-Mine Outbursts to a Gas Resource, R.M. Flores (ed), Special Issue, International Journal of Coal Geology, 35, 27-55. Crosdale, P J, BEAMISH, B B and Valix, M, 1998. Coalbed methane sorption related to coal composition, in Coalbed Methane: From Coal-Mine Outbursts to a Gas Resource, R.M. Flores (ed), Special Issue, International Journal of Coal Geology, 35, 147-158. Gamson, P D, BEAMISH, B B and Johnson, D P, 1996. Coal microstructure and secondary mineralisation: their effect on methane recovery, in Coalbed Methane and Coal Geology, R. Gayer and I. Harris Eds, Geological Society Special Publication, No. 97, 165-179. Gamson, P D, BEAMISH, B B and Johnson, D P, 1993. Coal microstructure and micropermeability and their effects on natural gas recovery, Fuel, 72, 87-99. BEAMISH, B B, 1990. Continuous gas monitoring for the assessment of outburst-proneness at a mining face, International Journal of Mining Geological Engineering, 8, 131-147.

CONSULTING PROJECTS

Consultancy projects to the coal industry on spontaneous combustion assessment, testing and management planning. Projects include: New South Wales Abel, Angus Place, Ashton, Beltana, Caroona, Chain Valley, Clarence, Dartbrook, Doyle’s Creek, Integra, Kayuga, Mandalong, Mandalong South, Metropolitan, Moolarben, Mount Arthur, Narrabri, Newstan, Saddler’s Creek, Tahmoor, Tasman, Ulan, Wambo, West Cliff, West Wallsend, Wilpinjong Queensland Alpha, Callide, Carborough, Clermont, Collinsville, Coppabella, Crinum, Dawson, Ensham, Grasstree, Inderi, Kestrel, Kogan Creek, Meandu, Meteor Downs South, Moranbah North, Moranbah South, New Acland, North Goonyella, Saraji East, Taroborah, Wards Well United States Bowie, San Juan, Skyline, West Elk New Zealand Huntly, Pike River, Spring Creek, other Solid Energy projects Other overseas countries Indonesia; Africa; and India. Spontaneous combustion assessment of: Clean coal technology products; Inhibiting (anti-oxidant) agents; and Australian metal concentrates.

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Curriculum Vitae Name: Michael Frankcombe

Qualifications: B. Env. Sc. Major – Land Resources and Management University of Wollongong, NSW Certified Professional in Erosion and Sediment Control (CPESC No. 1351) Envirocert International

Position: Principal Environmental Scientist Director

Summary of Experience:

Michael is a Principal Environmental Scientist with twenty three years practical environmental management experience in the civil construction, mining, urban, rural and tourism industries specialising in erosion and sediment control.

Michael is recognised nationally and internationally as a soil conservation specialist. He has presented more than twenty two papers on construction erosion and sediment control in Australia, New Zealand, the Philippines and the United States of America and has been an erosion and sediment control expert witness for the Environmental Defenders Office and the Queensland Environmental Protection Agency.

He is a Certified Professional in Erosion and Sediment Control (CPESC1351), registered as an RMS Soil Conservation Specialist Consultant and is President of the International Erosion Control Association (Australasian Chapter) and was previously Technical Vice President of IECA (parent body) in North America. He was also chair of the IECA Australasian CPESC committee and was the Region 10 representative for CPESC and the Certified Erosion, Sediment and Stormwater Inspector (CESSWI) programs for Envirocert International for six years.

Michael has trained more than one thousand people in construction site erosion and sediment control. He was one of the Soil Conservation Specialists on the Coopernook to Herons Creek Alliance Project which is a 33km long dual lane upgrading of the Pacific Highway between Coopernook and Herons Creek on the NSW mid-north coast. He was also the Soil Conservation Specialist on the Dinmore to Goodna Origin Alliance project which is a $1.95B upgrading of the Ipswich Motorway west of Brisbane.

Michael was co-author of the ‘Erosion and Sediment Guidelines for Local Government in Queensland’.

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Relevant projects: Land and Water Resource Management

• Soil Conservation Specialist for the Thornton Rail Overpass, Road and Maritime Services, Thornton, NSW.

• Soil Conservation Specialist for the MC(QCLNG)JV coal seam gas pipeline, MC(QCLNG)JV, Qld.

• Preparation of a stabilisation and rehabilitation plan for the Mountain Block Highwall. Liddell Coal, Liddell, NSW

• Preparation of a Mine Closure Plan, Rehabilitation and Offset Management Plan and Void Management Plan for the Bulga Coal Mine Complex, Bulga Coal, Bulga, NSW

• Re-design of the mine spoil dump landform to take into account soil stability characteristics, Bulga Coal, Bulga, NSW

• Peer review of Sunshine Coast Regional Council Erosion and Sediment Control Field Guide, Sunshine Coast Regional Council, Buderim, Qld

• Erosion and sediment control inspection of Dixons Road Construction Project Buderim, Sunshine Coast Regional Council, Buderim, Qld

• Soil Conservation Specialist for the Hunter Expressway Alliance, Hunter Ex Alliance, Newcastle, NSW

• Soil Conservation Specialist for the Coopernook to Herons Creek Road Alliance Project, C2HC Alliance, Johns River, NSW.

• Preparation of a wet weather shut down procedure for the Coopernook to Herons Creek Road Alliance Project, C2HC Alliance, Johns River, NSW.

• Development of soil and water management strategies for the Cardwell Range Upgrade for the Department of Main Roads, Townsville, Qld

• Preparation and implementation of an Erosion and Sediment Control Plan for the Surveyor Mine access/haul road on Conjuboy Station, Kagara Zinc Ltd, Mt Garnet, Qld

• Design of erosion and sediment control works for the Split Rock Road Project on Cape York, Department of Main Roads, Cairns, Qld

• Development of drainage, erosion and sediment design for the Byerstown Range Road Project on Cape York Peninsula, Department of Main Roads, Cairns, Qld

• Development of drainage, erosion and sediment design for the East Evelyn Range Road Project on the Atherton Tablelands, Department of Main Roads, Cairns, Qld

• Development of drainage, erosion and sediment design for the Cooktown Development Road Project on Cape York Peninsula, Department of Main Roads, Cairns, Qld

• Development of drainage, erosion and sediment design for the Herveys Range Road Project, Department of Main Roads, Townsville, Qld

• Development of drainage, erosion and sediment rehabilitation plan for the Mingela Range Road, Department of Main Roads, Queensland, Qld

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• Development of drainage, erosion and sediment design for the Three Sisters Road Project on Cape York Peninsula, Department of Main Roads, Cairns, Qld

• Developed soil and water management strategies for the proposed Kuranda Range Road Project in the Wet Tropics World Heritage Area, Department of Main Roads, Cairns, Qld

• Preparation of a Soil and Water Management Plan for the Laverack Blackhawke Helicopter Base, Department of Defense, Townsville, Qld

• Preparation and implementation of the Red Dome Mine Tailings Dam Seepage Management and Treatment System report, Kagara Zinc Ltd, Chillagoe, Qld

• Rehabilitation design of acid producing waste dumps at the Croydon Gold Mine, Union Mining, Croydon, Qld

• Preparation of a Soil and Water Management Plan for the Woodlawn Base Metal Mine, Denehurst Pty Ltd, Goulburn, NSW

• Preparation and implementation of grazing property Farm Plans in the Southern Highlands of NSW, Soil Conservation Service, Goulburn, NSW

• Vegetation Monitoring Kosciusko National Park, Soil Conservation Service, Cooma, NSW

• Preparation of a concept Erosion and Sediment Control Plan for a car based camping facility within the Illawarra State Recreation Area, National Parks and Wildlife Service, Wollongong, NSW

• Implementation and analysis of sediment, surface water, groundwater and biological monitoring of the derelict Horn Island Gold Mine, Department of Minerals and Energy, Horn Island, Qld

Environmental Management and Impact Assessment

• Preparation of a Mine Operations Plan for the Newstan Colliery, Centennial Newstan Ltd, Fassifern NSW

• Preparation and implementation of a Water Management Plan, Land Management Plan, Flora and Fauna Management Plan, Noise Management Plan, Archaeology and Cultural Heritage Management Plan, Erosion and Sediment Control Plan, Dust Management Plan, Fine Rejects Management Plan and Wetland Management Plan for the Newstan Colliery, Centennial Newstan Ltd, Fassifern NSW

• Managed the preparation of environmental studies and documentation to support obtaining environmental approval for the Balcooma open cut and underground base metal mine, Kagara Zinc Ltd, Mt Garnet, Qld

• Preparation of a Plan of Operations for the derelict Red Dome Gold Mine, Kagara Zinc Ltd, Chillagoe in Far North QLD

• Preparation of an Environmental Management Overview Strategy and Plan of Operations for the Balcooma, Surveyor, Dry River South and Mt Garnet base metal mines, Kagara Zinc Ltd, Mt Garnet QLD

• Development of the small metaliferous miner Environmental Management Overview Strategy, Plan of Operations and Environmental Audit proforma, Department of Minerals and Energy, Brisbane QLD

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• Preparation of an Environmental Management Plan for the Wapolu Gold Project, Union Mining, Milner Bay Province PNG

• Preparation of a Review of Environmental Factors for a titanium mineral sand bulk sample site, RZM Pty Ltd Garnpang Station adjacent to the Willandra Lakes World Heritage Area NSW

• Environmental Protection Licence applications for Cairns City Council’s sewage treatment plants, water treatment plants, municipal landfills, dog pounds and workshops. Cairns City Council, Cairns Qld

• Environmental Protection Licence applications for Herberton Shire Council’s sewage treatment plants, water treatment plants and gravel quarries. Herberton Shire Council, Herberton Qld

• Environmental Protection Licence applications for Hamilton Island Enterprises sewage treatment plants, waste transfer station, concrete batch plant, power station and bulk fuel storage. Hamilton Island Qld

• Co-author of the Wet Tropics World Heritage Area Road Maintenance Code of Practise, Department of Main Roads and Wet Tropics Management Authority, Cairns Qld

Environmental Policy and Strategy

• Preparation of a Northern Regional Strategic Environmental Plan, Department of Main Roads Townsville Qld

• Representative Queensland Government Erosion and Sediment Control Governance on Developments Working Party, Environmental Protection Agency Brisbane Qld

• Preparation of the Shoalwater Bay Training Area Strategic Environmental Plan, Department of Defence, Rockhampton Qld

• Designed and implemented field trials for the use of Eductor Dredge Mining Technology in Queensland, Department of Minerals and Energy, Brisbane Qld

• Developed stream protection guidelines for alluvial mining in the Palmer River Departmental and Official Purposes Reserve, Department of Minerals and Energy and Queensland Parks and Wildlife Service, Cairns Qld

• Preparation and review of draft Technical Environmental Guidelines for Mining in Queensland, Department of Minerals and Energy, Brisbane Qld

• Preparation and implementation of an ISO 14001 certified EMS for RZM titanium mineral sand mines Tomago NSW

• Preparation and implementation of an ISO 14001 based EMS for Kagara Zinc base metal mines, Mt Garnet, Qld

Environmental Audits

• Soil Conservation Specialist – undertake monthly erosion and sediment control inspection of the Cardwell Range Alliance road project in North Queensland. Cardwell, Qld

• Soil Conservation Specialist – review and certification of Erosion and Sediment

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Controls Plans and monthly compliance audits for the Macdow QC(LNG) pipeline. Gladstone, Qld

• Environmental Expert – Erosion and Sediment Control for the Environmental Evaluation of the Northern Networks Alliance Stage 2 water pipeline for the Department of Environment and Resource Management, Sunshine Coast, Qld

• Monthly erosion and sediment control audit, Dinmore to Goodna section of the Ipswich Motorway upgrade, Origin Alliance, Qld

• Co-auditor development consent compliance audit of Bulga Coal, Xstrata Coal NSW, Bulga, NSW

• Co-auditor development consent compliance audit of Hunter Enviro Mining, Abermain, NSW

• Weekly erosion and sediment control audits of the Coopernook to Herons Creek Road Alliance project, C2HC Alliance, Johns River, NSW

• Environmental approvals audit of Springvale Colliery, Centennial Coal, Lithgow NSW

• Monthly environmental compliance auditing of the Mt Garnet mine and processing plant, Surveyor Mine and Red Dome Gold Mine, Kagara Zinc Ltd, Mt Garnet, Qld

• Monthly environmental compliance auditing of RZM’s Plant 6, Plant 9, Plant 10 mineral sands mining operations and separator plant, RZM Pty Ltd, Tomago NSW

• Environmental audit of Hamilton Island Resort, Hamilton Island Enterprises, Hamilton Island, Qld

• Environmental audit of sewage treatment plants, water treatment plants, sewage pump stations, workshops, refuse tips, waste transfer station and dog pounds, Cairns City Council, Cairns, Qld

• Environmental audit of sewage treatment plants, water treatment plants, refuse tips, waste and extractive industries, Herberton Shire Council, Herberton, Qld

• Environmental compliance audit of Queensland Main Roads workshops, depots, laboratories and stockpiles sites Mt Isa, Cloncurry, Hughenden, Richmond, Bowen, Normanton, Burdekin, Townsville, Cardwell, Innisfail, Tully, Cairns, Mareeba, Lakeland Downs and Cooktown.

• Monthly environmental compliance audits of the Brinsmead to Kamerunga Road Project, Department of Main Roads, Cairns, Qld

• Monthly environmental compliance audits of the Edmonton Bypass Road Project, Department of Main Roads, Cairns Qld

• Environmental compliance audit of the Edmonton Cane Railway Deviation Project, Department of Main Roads, Cairns, Qld

• Environmental compliance audit of the Trevethan Creek to Green hills Road Project, Department of Main Roads, Cairns,Qld

• Monthly environmental compliance audits of the Cooktown Development Road Stage 1 Road Project, Department of Main Roads, Cairns,Qld

• Monthly environmental compliance audits of the Black Mountain Road Project,

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Department of Main Roads, Cairns, Qld

• Monthly environmental compliance audits of the Byerstown Range Road Project, Department of Main Roads, Cairns, Qld

• Monthly environmental compliance audits of the East Evelyn Range Upgrade Project, Department of Main Roads, Cairns Qld

• Environmental compliance audit of the Blue Water to Leichardt Creek Road Project, Department of Main Roads, Townsville, Qld

• Environmental compliance audit of the Hervey’s Range Road Project, Department of Main Roads, Townsville, Qld

• Six monthly environmental compliance audits of the Century Zinc Mine slurry pipeline, Department of Transport, Brisbane, Qld

• Environmental Protection Order compliance audit and expert witness report of the Red Peak Forest Estate Urban Development, Environmental Protection Agency, Cairns,Qld

Stabilisation and Rehabilitation Projects

• Preparation of a vegetative slope stabilisation guideline for the NSW Roads and Maritime Service, RMS, Sydney, NSW

• Preparation of a Fire and Land Management Trail Construction Guideline for Wyong Shire Council, Wyong, NSW

• Preparation of revegetation specifications for the Razorback Range Road Project, Sunshine Coast Regional Council, Buderim, Qld

• Remediation of a contaminated derelict antimony processing plant, RZM Pty Ltd, Clybucca, NSW

• Design, implementation and monitoring of the derelict Horn Island Gold Mine, Department of Minerals and Energy, Cairns, Qld

• Design, implementation and monitoring of the derelict Sunny Mount Tin and Gold Mine, Department of Minerals and Energy, Cairns, Qld

• Design, implementation and monitoring of the derelict Great Northern Mine Plant Site and Tailings Dam, Department of Minerals and Energy, Cairns, Qld

• Design, implementation and monitoring of soil conservation works on degraded grazing properties in the Warragamba Dam Catchment Area, Sydney Water, Sydney, NSW

• Design and construction of soil conservation works at the NSW Police Driver Training Centre, NSW Police Force, Goulburn, NSW

• Construction of road side soil conservation works on the Goulburn By-pass Road Project, Roads and Traffic Authority, Goulburn, NSW

• Design and construction of soil conservation works for the derelict Tarlo sand quarry, Department of Mineral Resources, Sydney, NSW

• Rehabilitation of the derelict Peelwood base metal mine, Department of Mineral Resources, Sydney, NSW

• Rehabilitation of the derelict Breadalbane base metal mine, Department of

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Mineral Resources, Sydney, NSW

• Rehabilitation of the derelict Gurrundah base metal mine, Department of Mineral Resources, Sydney, NSW

• Rehabilitation of the derelict quarry in the Kattang Nature Reserve, NSW National Parks and Wildlife Service, Port Macquarie, NSW

• Preparation of revegetation and landscaping specifications for the Coopernook to Herons Creek Alliance Project, C2HC Alliance, Johns River, NSW

• Preparation of revegetation specifications for road intersection and rail loop for the Mangoola Coal Mine, Xstrata Coal, Singleton, NSW

Community Consultation

• Participation on the Newstan Colliery Community Consultative Committee, Centennial Newstan Ltd, Fassifern, NSW

• Chair of the Mt Garnet Zinc Mine Community Consultative Committee, Kagara Zinc Ltd, Mt Garnet Qld

• Chair of the Cape Flattery Silica Mine Environmental Management Overview Strategy Consultative Working Party, Department of Minerals and Energy, Mareeba, Qld

• Undertook consultation with traditional owners on Horn Island in developing a decommissioning strategy for the derelict Horn Island Gold Mine, Department of Minerals and Energy, Horn Island, Qld

• Provision of technical advice and training to the Horn Island Gold Mine Rehabilitation Monitoring Committee, Department of Minerals and Energy, Brisbane, Qld

• Community liaison with the Old Mapoon Community Council during the Skardon River Kaolin Mine Environmental Impact Study Review, Department of Minerals and Energy, Weipa, Qld

• Technical representative for RZM on the Wemen Titanium Mineral Sands Project Community Consultative Committee, RZM Pty Ltd, Mildura, VIC

• Technical representative for Main Roads on the Black Mountain Road Project Community Consultative Committee, Department of Main Roads, Cooktown. Qld

• Founding member of the Mitchell River Watershed Management Group

• Member of the Wet Tropics Cassowary Advisory Group

Training

• Presentation and development of Day one of a four day erosion and sediment control course for Maroochy City Council, Maroochydore, QLD

• Prepared and presented a two day erosion and sediment control training course for Department of Minerals and Energy Field Officers, Department of Minerals and Energy, Emerald, Qld

• Prepared and presented a one day erosion and sediment control training course for Main Roads Designers and Engineers, Department of Main

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Roads,Cairns, Qld

• Prepared and presented a one day erosion and sediment control training course for Queensland Parks and Wildlife Service Rangers , Environmental Protection Agency, Cairns, Qld

• Prepared and presented a two day road side erosion and sediment control training course for Mareeba Shire Council personnel, Mareeba Shire Council,Mareeba, Qld

• Prepared and presented four one day erosion and sediment control training course for Cairns City Council personnel, Cairns City Council, Cairns, Qld

• Prepared and presented a one day urban erosion and sediment control training course for GHD engineers and designers, Gutteridge, Haskins and Davey, Cairns, Qld

• Prepared and presented environmental competency training for RZM personnel, RZM Pty Ltd, Tomago, NSW

• Developed and presented training on new Environmental Manuals for Main Roads personnel, Department of Main Roads, Brisbane, Qld

• Developed and presentation Wet Tropics World Heritage Area Maintenance Code of Practice Awareness Training to Main Roads and Local Government personnel across Far North Queensland, Department of Main Roads, Cairns, Qld

• Presentation and development of Day two of a five day erosion and sediment control course for Townsville City Council, Townsville City Council, Townsville, Qld

• Presentation and development of Day two of a five day erosion and sediment control course for Cairns City Council, Cairns City Council, Cairns, Qld

• Presentation and development of one day erosion and sediment control course for Lismore City Council, International Erosion Control Association, Lismore, NSW

• Presentation and development of one day erosion and sediment control course for Baulkham Hills City Council, International Erosion Control Association, Baulkham Hills, NSW

• Presentation and development of one day erosion and sediment control course for New Zealand Institute of Highway Technology, International Erosion Control Association, Palmerston North, NZ

• Presentation and development of one day erosion and sediment control course for the New Zealand Water and Waste Association, International Erosion Control Association, Auckland, NZ

• Prepared and presented erosion and sediment control training for the erosion and sediment control crews on the Coopernook to Herons Creek Alliance Project, C2HC, Johns River, NSW

• Prepared and presentation vegetation stabilisation and biodiversity seeding training for personnel on the Coopernook to Herons Creek Alliance Project, C2HC Alliance, Johns River, NSW

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Conference proceedings and publications

• Frankcombe, M.J., 2011 “The missing science of coal mining rehabilitation” In IECA Mining Rehabilitation Conference, Polkolbin

• Frankcombe, M.J., 2011 “Effective management of construction erosion and sediment control” In IQPC Environmental Compliance in Construction, Sydney

• Frankcombe, M.J.’ 2010 ‘A snapshot of construction revegetation – a practitioners perspective’ In Environmental Management in Transport Summit, Darling Harbour

• Frankcombe, M.J., 2009 “Getting it right the first – erosion and sediment control on the Coopernook to Herons Creek Road Project” In New Zealand Institute of Highway Technology and International Erosion Control Association, 3rd erosion control conference, Auckland

• Frankcombe, M.J.,2009 “The top ten reasons why mining revegetation programs fail” In IQPC Mining Rehabilitation Conference, Brisbane

• Frankcombe, M.J and Gardine, W., (2007) Erosion and Sediment Control Guideline for Local Government in Queensland – Local Government Association of Queensland, Brisbane

• Frankcombe, M.J., 2007 “Hydraulically and pneumatically applied mulches – are you getting what you paid for’ In New Zealand Institute of Highway Technology New Plymouth, Zealand November 2007

• Frankcombe, M.J., 2007 “Demonstrating construction site erosion and sediment control due diligence’ In New Zealand Institute of Highway Technology New Plymouth, Zealand November 2007

• Frankcombe, M.J., 2007 “Rolled erosion control products – application and limitation” International Geosynthetics Conference Brisbane October 2007

• Frankcombe, M.J., 2005 “Six years of erosion and sediment control in the road construction industry in Far North Queensland” In New Zealand Institute of Highway Technology Protecting the environment as an asset Palmerston North New Zealand September 2005

• Frankcombe, M.J., 2005 “Hydraulically and pneumatically applied mulches – are you getting what you paid for?” In New Zealand Institute of Highway Technology Protecting the environment as an asset Palmerston North New Zealand September 2005

• Frankcombe, M.J., 2005 “Introduction to construction site erosion and sediment control” In New Zealand Institute of Highway Technology Protecting the environment as an asset Palmerston North New Zealand September 2005

• Frankcombe, M.J., 2005 “Erosion and sediment control certification schemes – what have we got and where are we going?” In Queensland Environmental Protection Agency, Environment Institute of Australia and New Zealand and International Erosion Control Association Down to Earth Conference Cairns Australia September 2005

• Frankcombe, M.J., 2005 “The fundamentals of construction site erosion and sediment control – what is best practice” In Queensland Environmental Protection Agency, Environment Institute of Australia and New Zealand and International Erosion Control Association Down to Earth Conference Cairns

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Australia September 2005

• Frankcombe, M.J., 2005 “How to achieve effective erosion and sediment control in road construction – two Far North Queensland case studies” In Queensland Environmental Protection Agency, Environment Institute of Australia and New Zealand and International Erosion Control Association Down to Earth Conference Cairns Australia September 2005

• Frankcombe, M.J., 2003 “The Fundamentals of Erosion and Sediment Control”. In New Zealand Water and Waste Association 3rd South Pacific Storm Water Conference Auckland New Zealand May 2003

• Frankcombe, M.J., 2003 “The small things do matter: experience in erosion and sediment control in Far North Queensland”. In New Zealand Water and Waste Association 3rd South Pacific Storm Water Conference Auckland New Zealand May 2003

• Frankcombe, M.J. 2002 ‘Queensland Main Roads Fauna Overpass Research Project’ 3rd International Canopy Conference, Cairns June 2002

• Frankcombe, M.J and Oakley, K., (2002) Wet Tropics Maintenance Code of Practice Department of Main Roads – Cairns

• Frankcombe, M.J. 2002 ‘Byerstown Range Road Fauna Management Innovations’ 3rd International Canopy Conference, Cairns June 2002

• Frankcombe, M.J., 2002 “Turning hindsight into foresight – Lessons learned from the Byerstown Range Project in Far North Queensland”. In International Erosion Control Association – 32nd Annual Conference and Trade Exposition, Orlando Florida February 2002

• Frankcombe, M.J., 2001 “Getting it right the first time – Lessons learned from the Byerstown Range Project in Far North Queensland”. In International Erosion Control Association – 8th Annual Conference Gold Coast November 2001

• Frankcombe, M.J., 1999 Retrofitting Erosion and Sediment Controls – Lessons Learnt in the Construction Industry in North Queensland Australia. In International Erosion Control Association – 31st Annual Conference and Expo, Palm Springs USA 20 –23 February 1999

• Forde, K. and Frankcombe, M.J., (1999) Wet Tropics World Heritage Area Road Maintenance Code of Practice Main Roads - Cairns

• Frankcombe, M.J.,1998 The challenge of erosion and sediment control in Far North Queensland – A Road Construction Industry Perspective. In International Erosion Control Association – 5 the Annual Conference, Melbourne 18 – 22nd November 1998

• Frankcombe, M.J., 1998 Erosion and Sediment Control Best Practice in Far North Queensland – A Road Construction Industry Perspective. In Greening Australia – 1st Annual Conference, Brisbane 1998

• Frankcombe, M.J.,1993 Rehabilitation strategy for the derelict Horn Island Gold Mine. In Australian Mining Industry Council - 18th Annual Environmental Workshop, Burnie, 24 - 29th October 1993 pp 268 – 284

Referees: Available on request

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Professional history May 2010 – November 2011 Principal Environmental Consultant KMH Environmental June 2008 – April 2010 Principal Environmental Scientist Parsons Brinckerhoff October 2005 – June 2008 Senior Environmental Coordinator Centennial Coal Pty Ltd January 2005 – October 2005 Environment and Community Coordinator BHP Billiton - Douglas Project June 2003 – January 2005 Environmental Manager Kagara Zinc Ltd September 1997 – June 2003 Regional Environmental Advisor- Northern Queensland Department of Main Roads March 1996 – August 1997 Environmental Systems Manager RZM Pty Ltd October 1995 – March 1996 Senior Environmental Scientist Gutteridge, Haskins and Davey February 1991 – October 1995 Regional Environmental Officer Department of Minerals and Energy February 1989 – February 1991 Soil Conservationist (Goulburn North) NSW Soil Conservation Service

Independent Environmental Compliance Audit Report

Documents

Transcript of Independent Environmental Compliance Audit Report