project approval compliance audit report

153 Pages·2013·7.18 MB·English

by  Daniel Sullivan

ULAN COAL MINE
PROJECT APPROVAL
COMPLIANCE AUDIT REPORT
for
Ulan Coal Mine Limited
September 2013
ULAN COAL MINE

PROJECT APPROVAL
COMPLIANCE AUDIT REPORT

Prepared by:

HANSEN BAILEY
6/127-129 John Street
SINGLETON NSW 2330

September 2013

for:

Ulan Coal Mine Limited
Private Mail Bag 3006
MUDGEE NSW 2850
Project Approval Compliance Audit Report
Ulan Coal Mine 11 September 2013
for Ulan Coal Mine Limited Page i

EXECUTIVE SUMMARY

Hansen Bailey has been commissioned by Ulan Coal Mines Limited (UCML) to conduct an
environmental compliance audit against Project Approval PA 08_0184 and other relevant
supporting documentation for the period from January 2011 to June 2013.
This assessment was conducted by Dianne Munro (RABQSA International Certified Auditor
107622) and Daniel Sullivan (RABQSA International Certified Auditor P113202) from Hansen
Bailey Environmental Consultants Pty Ltd (Hansen Bailey). Experts in the fields of Noise
(Mark Bridges from Bridges Acoustics), Ecology (Dr David Robertson from Cumberland
Ecology), Groundwater (James Tomlin from AGE Consultants) and Surface Water (Greg
Roads from WRM Environment) also formed part of the audit team.
The site component of the audit was conducted by Dianne Munro and Daniel Sullivan over 4
days from 18 – 21 June 2013. The audit consisted of a detailed desktop review of
documentation, interviews with key Ulan Coal Mines staff and a field inspection of the
surface facilities, mining and rehabilitation areas. The audit was conducted generally
consistent with ‘ISO 14010 - Guidelines and General Principles for Environmental Auditing,
and ISO 14011 - Procedures for Environmental Auditing’.
The field inspection revealed that housekeeping in and around the workshop and storage
areas was excellent. The newly constructed Ulan West surface facilities were also visited
and the area was viewed to be well set up and being maintained in a tidy state with
appropriate sediment and erosion control and water management facilities in place.
Mining and rehabilitation was observed to have been progressed consistent with the
commitments made in the Environmental Assessment and Mining Operations Plan.
Rehabilitation across the site was observed to be of a high standard. Of particular note the
results of a recent trial to germinate Acacia ausfeldii from seed and root had proven to be
successful with over 30 individual saplings confirmed to have germinated in the trial plot.
Dust suppression measures were visible around the workshop areas and along the main
haul roads with water carts observed to be operating during the inspection with control
sprays also in operation on the ROM hopper.
No non compliances against the relevant criteria for air quality, noise or blasting occurred at
private receivers over the audit period. Three minor exceedances occurred as a result of
surface water discharges during the audit period. These were with regard to exceedances of
the criteria for EC and pH. These incidents were self-reported to the Environmental
Protection Authority as required under Environmental Protection Licence 394.
Community concerns are being well managed and are being recorded within Ulan’s
Environment and Community Database. Upon review of the database it is evident that the
number of complaints received during the audit period peaked in 2011 and early 2012 while
the Ulan West box cut was being constructed. Following completion of the box cut in June

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2012 the incidence of reported community concerns dropped off significantly. It is evident
from the correspondence observed that UCML is continuing to work with any residual
complainants to address their concerns. Actions taken to date include additional attended
monitoring at the properties in question, amendments to site noise Trigger Action Response
Plans and the installation of noise amelioration at one of the properties.
This audit identified some minor non-compliances against conditions of Project Approval
PA 08_0184 and other licences and approvals. Non-compliances to be addressed are
summarised in Section 5 and detailed in Appendix D and Appendix E of this report.
This audit has identified that non-compliances were largely administrative in nature. Of note
is that Ulan Coal Mines need to ensure that the revised environmental management plans
and strategies are approved by DP&I and implemented onsite.
Various other recommendations have also been made and are summarised in Section 6.
This audit has concluded that a good standard of environmental management is being
applied to the operation of Ulan. Of particular note the standard of completed rehabilitation,
water management and air and noise emissions management are commendable.

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TABLE OF CONTENTS
EXECUTIVE SUMMARY ........................................................................................................ i
LIMITATIONS OF REPORT ................................................................................................. iv
1 INTRODUCTION ........................................................................................................... 1
1.1 BACKGROUND .......................................................................................................................... 1
1.2 PRE-AUDIT CONSULTATION ................................................................................................... 2
1.3 DOCUMENTS REFERENCED IN AUDIT .................................................................................. 3
1.4 SITE DESCRIPTION .................................................................................................................. 3
1.5 REQUIREMENT FOR AUDIT ..................................................................................................... 4
1.6 REPORT STRUCTURE .............................................................................................................. 4
2 PA 08_0184 SUPPORTING DOCUMENTATION .......................................................... 6
2.1 EA ............................................................................................................................................... 6
2.2 MODIFICATION 1 ....................................................................................................................... 6
2.3 MODIFICATION 2 ....................................................................................................................... 7
2.4 COURT CASE 1 (NOVEMBER 2011) ........................................................................................ 7
2.5 COURT CASE 2 (MARCH 2012) ............................................................................................... 8
3 MANAGEMENT PLANS, PROGRAMS AND STRATEGIES ......................................... 9
4 ENVIRONMENTAL MANAGEMENT & MITIGATION EFFECTIVENESS .................... 11
4.1.1 Site Inspection.................................................................................................11
4.1.2 Complaints ......................................................................................................12
4.1.3 Incidents..........................................................................................................13
4.1.4 Monitoring .......................................................................................................14
4.1.5 Noise Management .........................................................................................14
4.1.6 Biodiversity Management ................................................................................15
4.1.7 Water Management .........................................................................................16
4.1.8 Tailings Management ......................................................................................19
5 SUMMARY OF NON-COMPLIANCES ........................................................................ 20
5.1 PROJECT APPROVAL ............................................................................................................. 20
5.2 OTHER LICENCES AND APPROVALS ................................................................................... 22
6 RECOMMENDATIONS ................................................................................................ 23

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LIST OF TABLES
Table 1 Audit Requirements ............................................................................ 4
Table 2 Audit Recommendations ................................................................... 23

LIST OF APPENDICES
Appendix A Regulatory Correspondence
Appendix B Opening Meeting Agenda & Audit Itinerary
Appendix C Audited Documentation
Appendix D Table A – Development Consent Compliance Table
Appendix E Table B – Other Licences and Approvals Compliance Table
Appendix F Plates from Site Inspection

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LIMITATIONS OF REPORT

In preparing this environmental compliance audit report, Hansen Bailey has assessed all
activities appropriate and necessary to evaluate the environmental status of the site and
operations on it. Hansen Bailey has addressed all technical matters which might reasonably
be considered to be relevant to such an assessment conducted to standards which apply in
New South Wales. Based on observations of the site, interviews with appropriate staff and a
review of available documentation, it is Hansen Bailey’s opinion that the potential critical
environmental issues associated with the site and operations are those discussed in this
report. However, Hansen Bailey auditors can only advise on the basis of the information
available to them and therefore cannot dismiss absolutely the possibility that parts of the site,
or adjacent properties, may give rise to additional issues.
The conclusions presented in this report are professional opinions based solely upon Hansen
Bailey’s visual observations of the site and the immediate site vicinity, and upon Hansen
Bailey’s interpretations of the documentation reviewed, interviews and conversations with
personnel knowledgeable about the site and other available information, as referenced in this
report. These conclusions are intended exclusively for the purposes stated herein, at the site
listed, and for the project indicated.
Opinions presented in this report apply to the site’s conditions and features as they existed at
the time of Hansen Bailey’s site visit between 18 – 21 June 2013, and those reasonably
foreseeable. They necessarily cannot apply to conditions and features which Hansen Bailey
is unaware of and has not had the opportunity to evaluate.
This report does not, and does not purport to, give legal advice on the actual or potential
environmental liabilities of any individual or organisation, or to draw conclusions as to
whether any particular circumstances constitute a breach of relevant legislation.

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ULAN COAL MINE
PROJECT APPROVAL COMPLIANCE AUDIT REPORT
for
Ulan Coal Mines Limited

1 INTRODUCTION
1.1 BACKGROUND
Hansen Bailey has been commissioned by Ulan Coal Mines Limited (UCML) to conduct an
environmental compliance audit against Project Approval PA 08_0184 which was most
recently modified in May 2012 for Ulan Coal Mine (Ulan). The original supporting
documentation of PA 08_0184 is the Ulan Coal Continued Operations Environmental
Assessment (EA) (Umwelt Australia Pty Ltd 2009) (Ulan EA). Two modifications have been
granted to PA 08_0184 and following the ‘Final Orders’ being made by the Land and
Environment Court in proceedings No. 10998 of 2010, further conditions of the approval have
been modified. The key components of each of the above modifications to PA 08_0184 are
described in detail in Section 2.
The auditing period that this report applies to is from January 2011 to June 2013. This
assessment was conducted by Dianne Munro (RABQSA International Certified Auditor
107622) and Daniel Sullivan (RABQSA International Certified Auditor P113202) from Hansen
Bailey Environmental Consultants Pty Ltd (Hansen Bailey). Assistance in preparing the audit
report was provided by Amy Porter from Hansen Bailey.
Experts in the fields of Noise (Mark Bridges from Bridges Acoustics), Ecology (David
Robertson from Cumberland Ecology), Groundwater (James Tomlin from AGE Consultants)
and Surface Water (Greg Roads from WRM Environment) also formed part of the audit team.
The findings from the expert’s reviews against the relevant conditions of PA 08_0184 are
included as part of this report.
The auditing team was approved by DP&I on 13 June 2013 (see Appendix A for
correspondence).
The audit consisted of a detailed desktop review of documentation and interviews with key
UCML staff including:
• Environment and Community Manager (ECM);
• Environment and Community Coordinator (ECC);
• Environment and Community Officer (ECO); and
• Community Land and Property Coordinator (CPLC).

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The site component of the audit was conducted by Dianne Munro and Daniel Sullivan over 4
days from 18 – 21 June 2013. Field inspections of the open cut and underground mining
areas, workshops, Coal Handling and Preparation Plant (CHPP), water management
systems and rehabilitation areas were undertaken in accordance with ISO 14010 -
Guidelines and General Principles for Environmental Auditing, and ISO 14011 - Procedures
for Environmental Auditing. An acoustics noise expert, Mark Bridges was also present for
the site component of the audit over 19 – 20 June 2013.
The weather conditions during the week of the audit were dry and on average consisted of
south westerly winds at up to 5.7 m/s and daytime temperatures ranging from -2.4 to 15.9
degrees (as per the UCML weather station). The site received rainfall during the week
preceding the Audit with approximately 34.7 mm of rainfall recorded at the onsite
meteorological station. These conditions were consistent with those experienced during the
site inspection at Ulan.
Each of an Opening and Closing Meeting was held at site with Senior Management and
Environmental staff from Ulan in attendance. An itinerary for the site component of the audit
(inclusive of attendees) is included in Appendix B.
1.2 PRE-AUDIT CONSULTATION
As required by Schedule 5 (condition 8b) of PA 08_0184 Hansen Bailey consulted with
relevant regulatory agencies prior to the audit to understand any additional requirements that
they might have for the audit. Agencies consulted with included:
• Department of Planning & Infrastructure (DP&I);
• Division of Resources & Energy (DRE);
• Office of Environment & Heritage (OEH);
• NSW Office of Water (NOW); and
• Mid-Western Regional Council (MWRC).
A summary of the comments of each are provided below.
DP&I requested that the audit, in addition to compliance with documentation under the
Environmental Planning & Assessment Act 1979 (EP&A Act), focus on the areas of water
management, biodiversity offsetting and noise management (cumulative).
NOW requested that the audit review the site’s current estimates of water taken from
different water sources (Goulburn River catchment, groundwater and captured from rainfall)
and provide a summary of the water licences held by Ulan. NOW also requested that the
audit report provide a statement on the compliance status with relevant licences and
approvals (including the Project Approval) and the sites status of compliance with licencing
requirements under Section 60 of the Water Management Act 2000 (WM Act).
EPA also requested that the audit consider recently reported water related incidents.

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No additional requirements were received from OEH or MWRC with regard to the audit.
1.3 DOCUMENTS REFERENCED IN AUDIT
Appendix C provides a list of all information reviewed as part of this audit.
As required by Schedule 2 Condition 8 of PA 08_0184 all existing development consents for
the site (apart from DA 113-12-98) have been surrendered. DA 113-12-98 is required to be
retained by UCML until mining is completed at Ulan No. 3 (specifically following the
completion of longwalls 26, West 2 and West 3. DA 113-12-98 was not audited as part of
this audit.
1.4 SITE DESCRIPTION
Ulan is a combined open cut and underground mine operated by Xstrata Coal NSW (XCN)
and owned as a joint venture between Xstrata Coal Pty Ltd (90%) and Mitsubishi
Development (10%). Ulan is situated approximately 1.5 km from Ulan Village and 38 km
north east of Mudgee, within the MWRC in Central West NSW.
Ulan has a long history of coal operations, with mining in the area undertaken since the
1920’s. Ulan’s No. 1 underground mine commenced in 1942 followed by its No.2
underground mine in 1957 and in the 1981 - open cut operations, surface facilities and the
augmentation of the No.2 underground mine. In November 2010, UCML was granted
PA 08_0184 which consolidated UCML’s multiple project approvals into a single,
contemporary project approval. It also allowed for the development of the Ulan No.3 and
Ulan West underground mines and recommencement of open cut mining.
Ulan has approval to extract up to 20 Million tonnes per annum (Mtpa) of Run of Mine (ROM)
coal. Mining operations are undertaken using longwall extraction equipment, continuous
miners, shuttle cars, breaker feeders, dragline, excavators and truck and shovels. Product
coal is transported to the Newcastle Port by rail via the Sandy Hollow-Gulgong Railway Line
and Main Northern Railway Line, for sale to the export market.
In the November 2010 – December 2011 and January 2012 – December 2012 reporting
periods, Ulan produced approximately 4.3 Mt and 6.0 Mt of ROM coal respectively. Ulan had
approximately 635 full time employees during the 2012 reporting period.
During the audit period operations undertaken have included mining in the open cut,
secondary extraction in longwall panels 26 and 27 at Ulan No 3 and panels C, E and F in the
North 1 Mining Area. The Ulan West box cut and surface facilities were also constructed and
first workings commenced in the Ulan West mining area.

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