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Independent Environmental Audit 2019 Independent Environmental Audit 2019 Bulli Seam Operations 20 December 2019 Project No: 0513868 The business of sustainability Document details Document title Independent Environmental Audit 2019 Document subtitle Bulli Seam Operations Project No. 0518993 Date 20 December 2019 Version 2.0 Author Nicole Whittaker, Heather McKay Client Name Illawarra Metallurgical Coal Document history ERM approval to issue Version Revision Author Reviewed by Name Date Comments Draft 1.0 Nicole Oliver Moore Oliver Moore 8/11/2019 Whittaker / Heather McKay Final 2.0 Nicole Oliver Moore Oliver Moore 20/12/2019 Whittaker / Heather McKay www.erm.com Version: 2.0 Project No.: 0518993 Client: Illawarra Metallurgical Coal 20 December 2019 Signature Page 20 December 2019 Independent Environmental Audit 2019 Bulli Seam Operations Heather McKay Oliver Moore Lead Auditor Partner in Charge Environmental Resources Management Australia Pty Ltd Level 15, 309 Kent St Sydney NSW 2000 © Copyright 2019 by ERM Worldwide Group Ltd and / or its affiliates (“ERM”). All rights reserved. No part of this work may be reproduced or transmitted in any form, or by any means, without the prior written permission of ERM www.erm.com Version: 2.0 Project No.: 0518993 Client: Illawarra Metallurgical Coal 20 December 2019 INDEPENDENT ENVIRONMENTAL AUDIT 2019 CONTENTS Bulli Seam Operations CONTENTS EXECUTIVE SUMMARY ......................................................................................................................... I 1. INTRODUCTION .......................................................................................................................... 1 1.1 Overview of Operations and Approvals ......................................................................................... 1 1.1.1 Description of primary processes undertaken during the audit period .......................... 2 1.2 Audit Objectives ............................................................................................................................. 3 1.3 Audit Scope ................................................................................................................................... 3 1.4 Audit Criteria .................................................................................................................................. 4 1.5 Limitations of this report ................................................................................................................. 4 2. AUDIT METHODOLOGY ............................................................................................................. 5 2.1 Methodology and Process ............................................................................................................. 5 2.2 Agency and Community Consultation ............................................................................................ 6 2.3 Classification of Audit Findings ...................................................................................................... 9 3. AUDIT FINDINGS ....................................................................................................................... 10 3.1 Previous audit follow up ............................................................................................................... 10 3.2 Complaints summary ................................................................................................................... 16 3.3 Incident Summary ........................................................................................................................ 16 3.4 Environmental monitoring performance ....................................................................................... 16 3.4.1 Noise ........................................................................................................................... 16 3.4.2 Air Quality ................................................................................................................... 16 3.4.3 Water Management .................................................................................................... 16 3.5 Management Plan Adequacy ....................................................................................................... 17 3.6 Environmental Protection Licence ............................................................................................... 17 3.7 Consolidated Coal Leases ........................................................................................................... 17 3.8 Compliance with regulatory instruments ...................................................................................... 17 4. CONCLUSION ............................................................................................................................ 30 APPENDIX A CONDITIONS OF APPROVAL, ENVIRONMENTAL PROTECTION LICENCE AND MINING LEASE COMPLIANCE TABLES APPENDIX B DEPARTMENTAL CORRESPONDENCE List of Tables Table E.1 Summary of Audit Findings ..................................................................................................... i Table 2.1 Agency and Stakeholder Consultation Summary ................................................................... 7 Table 3.1 Summary of 2017 Audit Findings .......................................................................................... 11 Table 3.2 Summary of Plan Implementation Review Findings ............................................................. 15 Table 3.3 Summary of 2019 Audit Findings .......................................................................................... 18 Table 3.4 Summary of 2019 Audit Findings – Management Plans....................................................... 27 Table 4.1 Summary of Audit Findings ................................................................................................... 30 www.erm.com Version: 2.0 Project No.: 0518993 Client: Illawarra Metallurgical Coal 20 December 2019 INDEPENDENT ENVIRONMENTAL AUDIT 2019 EXECUTIVE SUMMARY Bulli Seam Operations EXECUTIVE SUMMARY Environmental Resources Management Australia Pty Ltd (ERM) was commissioned to perform an Independent Environmental Audit (IEA) of the Bulli Seam Operations (‘BSO’) located 25km north-west of Wollongong, NSW on behalf of South32’s Illawarra Metallurgical Coal (herein referred to as ‘Illawarra Coal’). The primary purpose of the audit was to satisfy the Department of Planning, Industry and Environment (DPIE) Ministers’ Conditions of Approval (CoA) Project Approval number PA 08_0150, which requires completion of an independent audit every three years from the date of the approval. This audit was also undertaken to meet the requirements of Condition 18 of EPBC 2010/5350. The audit period assessed in this IEA is 4 February 2017 through 24 October 2019 (the date the site visit was completed as part of the audit). The audit included a review of: DPIE, Ministers Conditions of Approval PA 08_0150 (Modification 2) issued 28 October 2016; Environmental Protection Licence (EPL) 2504; Consolidated Coal Leases 724 and 767 with reference to Mining leases 1383, 1433, 1473, 1574, 1678 and 1698; Coal leases 388 and 381 and Mining purposes leases 200 and 201; EPBC Approvals 2010/5350 and 2010/5722; and Implementation of Management Plans developed as part of the Ministers Conditions of Approval. Illawarra Coal has established the control systems generally required for the stage of development. All staff interviewed demonstrated an understanding of requirements and a commitment to the application of the requisite management systems and plans. A qualitative risk assessment was also completed on the findings, consistent with AS/NZS 4360:2004 Risk management and HB 436:2004 Risk Management Guidelines Companion to AS/NZS 4360:2004 and as described in the Department of Planning & Environment publication “Independent Audit Guidelines” issued October 2015. The number of non-conformances with the statutory conditions and implementation of the management plans is summarised in Table E1 below. Table E.1 Summary of Audit Findings Review Non-compliances Administrative Observations Observations (NC) non-compliance (Obs NC) (Obs C) (ANC) Statutory 12 11 1 3 Instruments Implementation - 3 - 2 of Plans An action table addressing all findings of the audit has been developed by Illawarra Coal and will be issued separately to this report. www.erm.com Version: 2.0 Project No.: 0518993 Client: Illawarra Metallurgical Coal 20 December 2019 Page i INDEPENDENT ENVIRONMENTAL AUDIT 2019 INTRODUCTION Bulli Seam Operations 1. INTRODUCTION Environmental Resources Management Australia Pty Ltd (ERM) was commissioned to perform an Independent Environmental Audit (IEA) of the Bulli Seam Operations (BSO). The mine is located 25 km north-west of Wollongong, New South Wales (NSW), on behalf of South32’s Illawarra Metallurgical Coal (herein referred to as ‘Illawarra Coal'). The primary purpose of the audit was to satisfy the Department of Planning, Industry and Environment (DPIE)1 Ministers’ Conditions of Approval (CoA) Project Approval number PA 08_0150 (Modification 2), which requires completion of an independent audit every three years from the date of the approval. This audit was also undertaken to meet the requirements of Condition 18 of EPBC 2010/5350. The audit period assessed in this IEA is 4 February 2017 through to 24 October 2019 (the date the site visit was completed as part of the audit). The audit must: a) be conducted by a suitably qualified, experienced and independent team of experts
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