EIS 155 ABO3 1133 Wilpinjong Coal Mine, Mudgee - Amazon S3

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EIS 155ABO3 1133Wilpinjong Coal Mine, Mudgee

pIINSW DEPT PRIMARt INAUSIRIESABO31 133UIG WIndustry &InvestmentI.: IJOINT STRATEGIC ENVIRONMENTALCOMPLIANCE AND PERFORMANCEREVIEW ON THE MANAGEMENT OFDUSTON COAL MINESIndustry & Investment NSW Audit.IIISeptember 2010WILPINJONG COAL MINE, MUDGEEEnvironment Sustainability Unit, Industry & InvestmentNSW.111C,)-0101Prepared by: Scott BrooksControl Copy Document No: 1Date: 9-1 0th SeptemberPage! of 11

Audit Report - Wilpinjong Coal MineIndustry & Investment NSWTABLE OF CONTENTSPAGEENVIRONMENTAL AUDITPurpose.ObjectiveScope.Audit Criteria, Evidence and FindingsAuditTeam .Audit Timetable .Participants in Attendance.Audit Procedure tions.APPENDIX 1 - AUDIT CHECKLISTAPPENDIX 2— PLAN OF THE MINE SITEAPPENDIX 3— PHOTOSAPPENDIX 4— AUDIT RESPONSE FROM MINEPrepared by: Scott BrooksControl Copy Document No: 1Date: 910th SeptemberPage 2 of 123334455699910

Audit Report - Wilpinjong Coal MineIndustry & Investment NSWENVIRONMENTAL AUDITPURPOSEAn Industry & Investment NSW (I&I NSW) Compliance Audit was undertaken atWilpinjong Coal mine operated by Wilpinjong Coal Pty Ltd (a Peabody company)located at Mudgee. The site was audited as part of a joint Department of Planning(D0P), Industry and Investment NSW (I & I NSW) and Department of Environment,Climate Change and Water (DECCW) environmental performance review on themanagement of dust from coal mines to improve environmental performance. Theaudit of Wilpinjong Coal mine was conducted with DECCW auditing against theirEnvironment Protection Licence and I & I NSW auditing the requirements of theMining Lease including the Mining Operational Plan and Annual EnvironmentalManagement Report relating to dust.The audit inspection was undertaken on 9-1 0th September 2010. The procedures andprocesses for conducting the Compliance Audits were consistent with details in theCompliance Audit Handbook, which can be accessed on the DECCW website nsing/cahandbookO6 13 .pdf.This Audit is a controlled document for distribution of the audit agencies and themine owner/operator.This report has been prepared to present the findings of the audit carried out and noresponsibility is accepted for its use in any other context, or for any other purpose.IIOBJECTIVEThe objectives of the audits were:to determine whether the enterprise is complying with Mining Lease andMining Operations Plan Requirements in relation to the audit scope andcriteria;to outline a time frame for follow-up action to address any noncompliances identified during the audit.SCOPEThe area covered by the audit was ML 1573 and covered in the Mining OperationsPlan dated October 2008 to January 2012. The subject area is also covered by theWilpinjong Coal mine Annual Environmental Management Report dated February2010.Prepared by: Scott BrooksControl Copy Document No: 1Date: 910th SeptemberPage 3 of 12

Audit Report - Wilpinjong Coal MineIndustry & Investment NSWThe scope of the audit is limited to the examination of the activitiesundertaken at the Wilpinjong Coal mine in relation to themanagement of dust:Timing, scheduling and sequencing of rehabilitationVegetative cover and quality in completed areasLandform shape in compliance with the MOPTopsoil managementSpontaneous combustion managementGeneral compliance with dust controlling commitments identified in theMOPThe temporal scope adopted for assessment of compliance is generally from thecommencement of the most recently completed AEMR period or a shorter time wherethe auditing item can be adequately assessed.AUDIT CRITERIA, EVIDENCE AND FINDINGSAudit criteria (the requirements against which the auditor compares collected auditevidence) are:Mining Lease Conditions,Most recent Mining Operations Plan and EDG03 MREMP Guidelines Vs3,Annual Environmental Management ReportIndustry accepted best practice standards at Wilpinjong Coal mine, in relationto the management of dust and air quality generally.Audit criteria may include any Management Plan referenced in the MOP.Audit evidence was collected during discussions with site personnel,examination of documentation provided by the mine and/or contained inI&I NSW files, together with observations made during the audit inspection.Assessment of compliance is based on information supplied by the mine,a review of records and documentation relating to the site.Prepared by: Scott BrooksControl Copy Document No: 1Date: 910th SeptemberPage 4 of 12

Audit Report - Wilpinjong Coal MineIndustiy & Investment NSWAUDIT TEAMIThe audit team consisted of Scott Brooks from the Maitland office of I&I NSW,Environmental Sustainability Unit.IAUDIT TIMETABLEIIThe Audit was announced with around 24 hours given prior to the commencement ofthe Audit. The Audit for Wilpinjong Coal mine was conducted on the 9th and 10thSeptember 2010. At the Audit it was advised that the mine would receive a draft ofthe Audit findings within 3 weeks of the audit with the final Audit report and Auditssummary completed prior to December 2010.Timetable for the Audit of Wilpinjong Coal mineTime9:00am - 10:30am10:30am - 12:30pm12:30am- 1:00pm1:00pm - 4:00pm9:00am - 12:30pm12:30pm— 1:00pm1:00pm —2:00pmThursday 91h September 2010Signing in and relevant staff,introductions and outlining of the AuditscopeSite inspection of the mine.LunchCompletion of ChecklistsFriday 101h September 2010Completion of Checklists and siteinspection to confirm findingsLunchJoint agency and mine close out meetingPARTICIPANTS IN ATTENDANCE:The following staff from Wilpinjong Coal mine were either in attendance at theopening and closing meeting or assisted through the course of the Audit.Shaun Cleary, Keiren Bennetts, Jason McWhirter, Amanda MacAlpine(Thiess), Sean Mumford (Thiess). The close out meeting was also attended by KeithDownham and Peter Schmidt.Agency attendees at the Audit were;I&INSWScott BrooksIIDECCWWinston WickremeratneSheridan LedgerPrepared by: Scott BrooksControl Copy Document No: 1IDate: 9-1 0th SeptemberPage 5 of 12

Audit Report - Wilpinjong Coal MineIndustry & Investment NSWFollowing introductions, the purpose and scope of the Audit was described by theLead Auditor from each of the 2 agencies. The Audit procedure was discussed,including reference to the identification of compliances, non-compliances andobservations as defined below.The lead Auditors confirmed the Audit would be restricted to the areas of the mine tobe audited and the scope was generally associated with activities that can potentiallycreate or lead to dust or a general degradation of air quality.AUDIT PROCEDUREThe relevance and implications of each of the aspects/activities identified in the AuditChecklist were discussed with mining personnel at the opening meeting and again asthe Checklist was filled out. Each of the questions/actions identified on the Checklistwere verified by observation, interview and/or documentation to determinecompliance with statutory approval, agreed MOP operating procedure and industrybest practice. Following the completion of the Checklists a field inspection wascarried out to confirm the findings in the Checklists. Following the field visit anyadditional information required was confirmed and a close out meeting was held toprovide mine management with an outline of the preliminary findings.Compliances, observations and non-compliances were recorded for each of thequestion/audit actions on the Audit Checklist.Appendix 1 summarises the results of the audit with respect to each of the elementsaudited.The following system was used to categorise findings:Prepared by: Scott BrooksControl Copy Document No: 1Date: 910th SeptemberPage 6 of 12

Audit Report - Wilpinjong Coal MineIndustry & Investment NSWDefinition of Audit OutcomesCompliance (C): adequacy of design and appropriateness of implementationwith current Departmental Approvals or Conditions, or compliance withcommitments made by the Company.Observation (0): a finding which is not likely to significantly affect theenvironment but which could lead to process improvement, further research orreference to pest available practice.INon-compliance: an inadequacy in the design and/or implementation againstcurrent Departmental Approvals or Condition. There are 4 subcategories ofnon-compliance;Category 1 (NC red) - a total absence of planning orimplementation of a required operations element which presents animmediate environmental risk or an isolated lapse in control in theimplementation of an operations element which will lead to asignificant environmental risk. A Red non-compliance would have acertain or likely chance of high environmental impact or a certainchance of moderate environmental impact.Category 2 (NC orange) - an isolated lapse or absence of controlin the implementation of an operations element which may not be ofsignificant environment risk. An Orange non-compliance would havea less likely chance of a high level of environmental impact, a likelychance of moderate environmental impact or a certain chance of lowenvironmental impact.Category 3 (NC yellow) - an isolated lapse or absence of controlthat would not have an immediate effect on the environment and in thelong term the effect can be reversed. A Yellow non-compliance wouldhave a less likely chance of a moderate environmental impact or alikely or less likely chance of low environmental impact.Category 4 (NC blue) - a non-compliance related to anadministrative, reporting or monitoring matter.Prepared by: Scott BrooksControl Copy Document No: IDate: 910th SeptemberPage 7 of 12

Audit Report - Wilpinjong Coal MineIndustry & Investment NSWRisk Assessment of Non-compliancesThe significance of any non-compliances identified during the audit process arecategorised. Following risk assessment for non-compliances, an escalating responserelative to the seriousness of the non-compliance is determined to ensure the noncompliance is addressed by the enterprise.The risk assessment of non-compliances involves assessment of the non-complianceagainst two criteria; the likelihood of environmental harm occurring and the level ofenvironmental impact as a result of the non-compliance. After these assessments havebeen made, information is transferred into the risk analysis matrix below.Likelihood of Environmental Harm OccurringCertainCLELikelyLess LikelyHighCode RedCode RedCode OrangeModerateCode RedCode OrangeCode YellowLowCodeOrangeCode YellowCode YellowoWEwThe assessment of the likelihood of environmental harm occurring and the level ofenvironmental impact allows for the risk assessment of the non-compliance via acolour coding system. A red risk assessment for non-compliance denotes that the noncompliance is of considerable environmental significance and therefore must be dealtwith as a matter of priority. An orange risk assessment for non-compliance is still asignificant risk of harm to the environment however can be given a lower priority thana red risk assessment. A yellow risk assessment for non-compliance indicates that thenon-compliance could receive a lower priority but must be addressed.There are also a number of licence conditions that do not have a direct environmentalsignificance, but are still important to the integrity of the regulatory system. Theseconditions relate to administrative, monitoring and reporting requirements. Noncompliance of these conditions is given a blue colour code.The colour code is used as the basis for deciding on the priority of remedial actionrequired by the licensee and the timeframe within which the non-compliance needs tobe addressed. This information is presented in the action program alongside thetarget/action date for the non-compliance to be addressed.While the risk assessment of non-compliances is used to prioritise actions to be taken,I&I NSW considers all non-compliances are important and licensees must ensure thatall non-compliances are addressed as soon as possible.Prepared by: Scott BrooksControl Copy Document No: IDate: 910th SeptemberPage 8 of 12

Audit Report - Wilpinjong Coal MineIndustry & hivestment NSWExplanation of the ChecklistThe purpose of this Audit, from an I&I NSW perspective, is to ensure compliancewith Mining Lease, Mining Operations Plan and AEIVIR requirements. The first stepin this process is to determine what is required within these documents. To do this therequirement needs to first be asked, and then as a second step, determine if therequirement has been implemented on the mine. Where a mine does not have arequirement for a particular activity or aspect, then the answer will be No. This isneither a compliance nor non-compliance.As an example it is asked if the MOP has a requirement for dust suppression on thecoal stockpiles. If this issue is silent in the MOP then the answer is No and theanswer to the next question is N/A as there is no requirement to implement this actionas it is not identified in the MOP. Whether this issue should be covered in the MOPor not is a matter to be considered as a part of the MOP acceptance process and isoutside the scope of the Audit.AUDIT FINDINGSThe I&I NSW Audit Team identified 66 aspects, as part of the Audit Checklist, toaudit at Wilpinjong Coal Mine.The Audit findings were as follows;29 Compliances were identified and documented in the Checklists.6 Non-Compliances were identified and are discussed in more detail below.14 Observations were made arising from auditing of aspect questions. TheseObservations are summarised on the checklists and discussed in more detail below;ICOMPLIANCESICompliances identified of the activity/aspect are either acknowledgement that thedocumentation requested exists, or was found satisfactory from a dust or air qualityperspective.IIIINon-Compliances identified consisted of yellow and blue non-compliances. Therecording of non-compliances and corrective actions taken by the mine are to bepresented in the next Annual Environmental Management Report.N/C Yellow1.Mining Sequence not compliant with the MOPMining in not identified to be occurring south of the suspended Pit 2 workings inthe current MOP period. The inspection found that 2 pits had been recentlyconstructed. One was east of the coal pad and the second was further east ofPrepared by: Scott BrooksControl Copy Document No: 1IDate: 910th SeptemberPage 9 of 12

Industry & Investment NSWAudit Report - Wilpinjong Coal Minethis. Both pits had been mined for coal. The purpose of the Mining OperationsPlan is to identify in both time and space where mining is to occur on the minesite. Opening up extra pits will increase the cumulative affect of the mine on theenvironment and this would not have been taken into account in the assessmentof the MOP. Negotiations to amend the MOP need to be commenced with I&INSW.Behind MOP commitment for rehabilitated areaThe area of completed rehabilitation is behind the area outlined in the MOP.There were 4 N/C's relating to an insufficient area of rehabilitation.Only around 60% of the area identified to be rehabilitated in the MOP in 2009has been completed. Given the area of disturbance equals or exceeds the areaoutlined in the MOP, the larger than planned area of bare ground could lead tothe production of more dust. The rate of rehabilitation needs to be sped up tomatch the MOP.Spontaneous CombustionSpontaneous combustion is occurring in at least 2 locations on the mine. TheMOP refers to a Spontaneous Combustion Management Plan. In this plan itdescribes that inert soil is to be placed over affected areas. An area on the soundbund was affected by spontaneous combustion and was not treated with inertsoil. All spontaneous combustion areas should be managed as required in theManagement Plan.OBSERVATIONSObservations in this Audit are presented in 2 categories:Checklist ObservationsGeneral/field Observations.Checklist Observations.Where an item is considered compliant with an Activity/Aspect on the Checklist, butwarrants comment, an Observation is recorded.GenerallField Observations.Where an Activity/Aspect is observed but will have no effect on the likelihood of dustor poor air quality, a General Observation is recorded. Further if something relevantto the Audit is observed outside the area to be audited, a General Observation isrecorded.Checklist Observations1.Access tracksCondition 20 of the Mining Lease requires access tracks to be constructed toDepartment of Planning requirements. These standards could not be found sotrack standards outlined in the Thiess document "Design and Construction ofPrepared by: Scott BrooksControl Copy Document No: 1Date: 9-1 0th SeptemberPage 10 of 12

IIIIIIIIIIIAudit Report - Wilpinjong Coal MineIndustry & Investment NSWMine Roads was taken as the required standard. This document was verycomprehensive. The tracks were found to be constructed to a satisfactorystandard but they did require maintenance. A number of drains were eithereroded or blocked with sediment.2.Topsoil stockpile recording.There were 2 observations regarding topsoil recording. Both the MOP andAE1\'IR contained a section outlining topsoil storage records. The MOPidentified the topsoil volumes planned to be stripped in the MOP period only. Itdid not show quantities of topsoil carried into the MOP period or topsoil plannedto be used for rehabilitation. The AEMR only showed the quantities of topsoilused. The purpose of both documents is to allow a topsoil budget to be created inthe MOP and the AEMR report against this budget to ensure the use of topsoil ismonitored to prevent a shortfall at the end of mining.Mapped areas of Spontaneous Combustion.As the site contains 2 areas of spontaneous combustion in the overburdenstockpiles, a plan is needed to locate these areas, so their size and location can bemonitored. The only known areas are well monitored and it is acknowledgedthat an infra red site survey is planned to be completed shortly on locating theknown and any unknown areas. This survey needs to be started shortly.General ObservationsGOAThe site was very wet for the duration of the Audit. This prevented anydust from being created and most of the equipment was idle due to wetconditions. This made it very difficult to asses management practices to reducethe risk of dust.The site had a very large area of disturbance relative to the size of themine. More care is needed to ensure the disturbance footprint is kept to aminimum. Once land is disturbed, and not planned to be re disturbed in theforeseeable future, it should be sown with grass to remove the risk of erosionproducing sediment and dust.APPENDICIESAppendix 1Audit Checklist-Appendix 2A plan showing the state of the mine in recent time of the Audit. Marked on this plancan be found the location of the photographs taken.IAppendix 3Photos taken during the Audit with captions.IPrepared by: Scott BrooksControl Copy Document No: 1IDate: 9-1 01h SeptemberPage 11 of 12

Audit Report - Wilpinjong Coal MineIndustry & Investment NSWAppendix 4Audit response from mine.Prepared by: Scott BrooksControl Copy Document No: 1Date: 910th SeptemberPage 12 of 12

APPENDIX 1AUDIT CHECKLIST

ANN.,; I n d u s t ry &NWInvestmentElement:Activity/AspectMining OperationsPlanEnvironmental Audit Checklist WILPINJONGAudit Date: 910TH SeptemberMining Lease Conditions2010Auditor: I&I NSW Team,Scott BrooksAudit Reference:C omment/Question/Audit ActionSourceVerificationML 1573unlessmarkedotherwiseIs a current Mining Operations YesC27Contents of MOP27bAEMR requirements28DustPlan with text and stampedplans available for review.YesAre Areas of disturbanceidentified in the MOP.Has an AEMR has beenYessubmitted for review within thelast 12 months of this Audit.Does the mining lease have any Noconditions particularly relatingto the control of dust.Strategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-2010Mine Representative:ResultCCFile No. 09/129 1Lead Auditor: Scott BrooksPage lof 13 pages

Mining dit ActionIf so have precautions beentaken to abate dust nuisance.Provide examples ofprecautions taken.Have there been dustcomplaints received by themine in the last 12 months. Ifso how many.DustDustAccess tracksC20Access tracksC20ExplorationC15ConmTlent/ VerificationN/AN/AN/AHave access tracks beenTrack were audited against Thiessdesigned in accordance withDesign and Construction of Minespecifications provided by DoP. Roads, as no DoP document wasavailableDoes the mine have evidenceYes, but they require maintenancethat the access tracks have been due to poor drainageconstructed in accordance withDoP.Has any exploration occurred Nooutside the mining footprintwithin the mining lease in thelast 2 years.Strategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-2010Mine Representative:Mine Name:Wilpinjong MineResultC0File No. 09/1291Lead Auditor: Scott BrooksPage 2of 13 pages

4iWb- -NWInvestmentElement:Activity/AspectAreas of disturbanceMining sequenceEnvironmental Audit Checklist WILPINJONGMining Operations PlanAudit Date: 9101h September2010.Please note that theAuditor: I&I NSW Team,Scott BrooksMOP includes allMOP Dated October 2008 listed ManagementJanuary2012PlansAudit Reference:Comment!Question/Audit ActionSourceVerificationMOP Are the areas of disturbance of This will need to be checked fromMOPCthe latest mining progress planthe mine within the areas ofYes, mining was within the identifieddisturbance identified in theextraction area.MOP.Is the mining sequenceNo. Pit 2 Box cut south being 2 N/Cidentified in the MOPpits not on the MOPconsistent with the progress ofmining as at the date of theaudit.Strategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-20 10ResultMine Representative:File No. 09/1291Lead Auditor: Scott BrooksPage 3of 13 pages

Mining isposalMOPTailings DisposalMOPCoal waste disposalSurface infrastructureMOPRehabilitated areas.MOPRehabilitated areasMOPQuestionlAudit ActionComment/VerificationIs the tailings/waste disposalYeslocation identified in the MOPconsistent with the progress ofmining as at the date of theaudit.Are there any provisions in the NoMOP for the management ofdust on tailings dams and if sohave they been applied.Does the MOP require theNoprompt burial of coarse rejectand if so what measures (dust)are being implemented forhandling and disposal.Are the surface infrastructure Yesitems identified in the MOPconsistent with the progress ofthe mining operation as at thedate of the audit.Are the rehabilitated areasNo. The area rehabilitated wasindicated in the MOP consistent significantly (around 40%) behindwith the most recent AEMRthe MOP requirements.ReportIf not, are the total areasNoidentified in the 2 documents asrehabilitated in the last 2 yearsconsistent.Strategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-20 10Mine Representative:Mine Name:Wilpinjong MineResultCCN/CN/CFile No. 09/129 1Lead Auditor: Scott BrooksPage 4of 13 pages

Mining OperationsPlanSourceActivity/AspectRehabilitated areasMOPRehabilitated areasMOPLandformMOPLandformMOPLandformMOPOverland conveyorsMOPQuestion/Audit ActionComment/VerificationNoAre the rehabilitated areasindicated in the MOP consistentwith the rehabilitation in thefield as at the date of the audit.If not are the total areasNorehabilitated consistent with theMOP commitment. ie have theareas identified to rehabilitatemoved.Are the rehabilitated landforms Slopes not shown in either document(slope and drainage) indicatedin the MOP consistent with themost recent AEMR report.Are the rehabilitated landforms(slope and drainage) indicatedin the MOP consistent with therehabilitation in the field as atthe date of the audit.If not are the landform areasconsistent with the MOPcommitment. ie have the steepareas identified moved.Does the MOP include dustsuppression requirements on thecoal conveyors on mine site.Slopes should be a maximum of 1:6(10.2) degrees.The 2 areas checked were 7 and 8degrees.Mine Representative:N/CN/CCN/ANoStrategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-2010Mine Name:Wilpinjong MineResultFile No. 09/129 1Lead Auditor: Scott BrooksPage 5of 13 pages

Mining OperationsPlanActivity/AspectSourceOverland conveyorsMOPROM and productstockpilesMOPROM and MOPBlastingMOPAir PollutionMOPQuestionlAudit ActionComment/VerificationIf applicable have these dustN/Asuppression systems operatedwithin the last 7 day or can bemade operational at the time ofthe audit.Does the MOP include dustNosuppression requirements on theROM and product stockpiles.If applicable have these dustN/Asuppression systems operatedwithin the last 7 day or can bemade operational at the time ofthe audit.Does the MOP include dust or Nofume mitigation measures forblasting.Have these measures beenN/Aimplemented in recent blasts.View blast record of the lastweek.In the blast records is fumeYes, All blasts are recorded on video Crecorded.Where fume is recorded are the Yes, Anomalies on blast are recorded Cprobable causes recorded forand actions were described at audit.future management decisions.Does the MOP contain anyMOP refers to Air Qualitygeneral requirements to prevent Management Plan.air pollution or contain it withinthe mine site.Strategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-2010Mine Name:Wilpinjong MineResultMine Representative:File No. 09/1291Lead Auditor: Scott BrooksPage 6of 13 pages

Mining OperationsPlanActivity/AspectSourceAir ireMOPBushfireMOPBushfireMOPQuestionlAudit ActionComment/VerificationYesCThe Spoil Corn Management Plancovers a number of treatmentsincluding covering affected areas,track rolling and compacting areas,extinguishing fires with water, etc.No, Spontaneous combustion wasHave these measures beenimplemented in the most recent observed in the sound bund. Thiscould be covered with soil.AEMR period,What measures are used toThe workings are very shallow andselectively handle and dispose easy to clean up. All overburdenof coal partings/rib coal.material is covered with 2m of inertoverburden.Are areas of spontaneousNo, but incident reports arecompleted on the 2 affected areascombustion mapped and how(report dated 12-7-20 10 sighted) andoften are these updated.mine is to be flown with thermalimagery cameras.Does the MOP containYesmeasures to prevent bushfireHave these measures beenYesimplemented in full on the minesite.Does the MOP containYesmeasures to manage theoutbreak of bushfire onceburning on the mine site.No, there have been no fires on site.IHave these measures beenCHave these requirements beenimplemented recently.What are the measures tomanage spontaneouscombustion.Strategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-20 10Mine Name:Wilpinjong MineResultMine Representative:N/CC0CCCFile No. 09/129 1Lead Auditor: Scott BrooksPage 7of 13 pages

Mining OperationsPlanActivity/AspectSourceBushfireTopsoil ManagementMOPTopsoil managementMOPTopsoil managementMOPTopsoil managementMOPTopsoil managementTopsoil managementComment/Verificationimplemented on the mine siteHas there been a planned fire in Development Consent does not allowvegetative material on the mine fires on site.site in the last 2 years.BushfireTopsoil managementQuestionlAudit ActionWould this fire be considered N/Abest practice for themanagement of vegetation bythe audit team.Does the MOP containYesmeasures to manage thestripping, stockpiling andspreading of topsoil.Have these measures beenYesimplemented in the most recentAEMR period.Have the topsoil stockpiles been Yesrevegetated.In what time frame is aNot stated in MOP but 6 monthsstockpile sown after placement stated in AQMPof disturbance.What is the maximum height of 2mthe topsoil stockpiles.Does the vegetative cover onNo. two stockpiles inspected.the topsoil stockpiles containweed content greater than 50%of the cover.topsoil stockpiles have aYes, for all except a recently sowntnimurn 70% vegetativearea.Strategic Environmental Compliance and Performance Audit, Mine Wilpinjong.Date: 9-9-2010Mine Name:Wilpinjong MineResultMine Representative:CCCCCCFile No. 09/1291Lead Auditor: Scott BrooksPage 8of 13 pages

Mining OperationsPlanActivity/AspectSourceTopsoil managementComment/Verificationcover.Are records of topsoil storedTopsoil budget is provided in MOPMOPGuidelines and used on site recorded in the but only includes the total topsoilMOP.planned to be stripped.Erosion and sedimentcontrolErosion and tionQuestion/Audit ActionMOPMOPAre the soil and waterstructures regularly inspected.If so are the fmdings andactions recorded.Does the MOP containrequirements to manage thedrill pads and explorationaccess roads.Have these measures beenimplemented on explorationsites within the last AEMRperiod.Have practices occurred on drillpads and exploration accessroads to minimise theproduction of dust.Mine Representative:0Yes, fortnightlyCYes, Document dated 8th Septembersighted.No.CN/AThere where no exploration dril

JOINT STRATEGIC ENVIRONMENTAL I COMPLIANCE AND PERFORMANCE REVIEW ON THE MANAGEMENT OF I DUSTON COAL MINES I Industry & Investment NSW Audit. September 2010 WILPINJONG COAL MINE, MUDGEE Environment Sustainability Unit, Industry & Investment NSW. 111 Prepared by: Scott Brooks C,) - Control Copy Document No: 1 01 01 Date: 9-1 0th September