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ENVIRONMENTAL ASSESSMENT REPORT

Fingal Tier Coal Project

Off Valley Rd, Fingal Valley

Hardrock Coal Mining Pty Ltd The Board of the Environment Protection Authority 28 August 2012

Environmental Assessment Report – Fingal Tier Coal Project

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Environmental Assessment Report

Proponent Hardrock Coal Mining Pty Ltd

Proposal Fingal Tier Coal Project

Location Off Valley Rd, Fingal Valley

NELMS no. 8651

DA number 003-12

Folder EN-EM-EV-112333_2

Doc Id.

Class of Assessment

A189498

2B

Assessment process milestones

29/08/2011 Notice of Intent submitted

25/10/2011 DPEMP Guidelines issued

23/12/2011 Permit application submitted to Council

10/01/2012 Application received by Board

21/01/2012 Start of public consultation period

19/02/2012 End of public consultation period

30/07/2012 Supplementary information submitted to Board

Acronyms

AMD Acid and Metalliferous Drainage

Board Board of the Environment Protection Authority

DPEMP Development Proposal and Environmental Management Plan

DPIPWE Department of Primary Industries, Parks, Water and Environment

EIA Environmental impact assessment

EMPC Act Environmental Management and Pollution Control Act 1994

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)

HCM Hardrock Coal Mining Pty Ltd

LUPA Act Land Use Planning and Approvals Act 1993

MSDS Material Safety Data Sheet

SD Sustainable development

WTE Wedge Tailed Eagle


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Report summary

This report provides an environmental assessment of Hardrock Coal Mining‟s proposed underground coal mine in Tasmania‟s Fingal Valley.

The proposal involves development of a new underground coal mine and associated infrastructure off Valley Rd in the Fingal Valley. The forecast extraction rate will be up to one million tonnes per annum (1M tpa). Above ground infrastructure will be located on the site of a former 1950‟s coal mine.

This report has been prepared based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP) and DPEMP Supplement. The advice of relevant Government Agencies and the public has also been sought and considered as part of this assessment.

On 28 February 2012, the proponent was asked to provide supplementary information to address public, government agency (including DPIPWE) and Council comments on the DPEMP. The submission of supplementary information was completed on 30 July 2012.

Background to the proposal and details of the assessment process are presented in Section 1 of this report. Section 2 describes the context of this assessment. Details of the proposal are contained in Section 3. Section 4 reviews the need for the proposal and considers the project, site and design alternatives. Section 5 summarises the public and Agency consultation process and the key issues raised in that process. The detailed evaluation of key issues is contained in Section 6. Section 7 identifies other environmental issues and the report conclusions are contained in Section 8.

Appendix 1 contains a tabular evaluation of other environmental issues referred to in Section 7. Appendix 2 contains a summary of issues raised in the consultation process. Appendix 3 contains environmental permit conditions for the proposal. Attachment 2 of the permit conditions contains the table of commitments from the DPEMP.


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Table of Contents

1 Approvals process .................................................................................... 4

2 SD objectives and EIA principles .............................................................. 5

3 The proposal ............................................................................................ 6

4 Need for proposal and alternatives ......................................................... 11

5 Public and agency consultation .............................................................. 12

6 Evaluation of key issues ......................................................................... 13

6.1 Interburden (waste) rock ................................................................................................. 13 6.2 Water .............................................................................................................................. 20 6.3 Geotechnical investigations ............................................................................................ 29 6.4 Noise and sensitive wildlife ............................................................................................. 32

7 Other environmental issues .................................................................... 34

8 Report Conclusion .................................................................................. 35

9 References ............................................................................................. 36

10 Summary of appendices ...................................................................... 37

Appendix 1 Assessment of other environmental issues ....................................................... 38 Appendix 2 Summary of issues raised by public and agency submissions .......................... 51 Appendix 3 Permit Conditions - Environmental .................................................................... 58


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1 Approvals process

An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Break O‟Day Council on 23 December 2011.

The proposal is defined as a „level 2 activity‟ under Schedule 2 Subsection 5(c) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being the extraction of any minerals and producing 1 000 tonnes or more of minerals per year. Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The application was received by the Board on 10 January 2012.

The Board required that additional information to support the proposal be provided in the form of a Development Proposal and Environmental Management Plan (DPEMP) prepared in accordance with guidelines jointly issued by the Board and Break O‟Day Council. The draft guidelines were considered by a number of government agencies/bodies with an interest in the proposal for 21 days. Final guidelines were issued to the proponent on 25 October 2011.

A number of drafts of the DPEMP were submitted to the EPA for comment prior to its formal submission. A draft DPEMP was submitted to Council with the permit application. The DPEMP was released for public inspection for a 28-day period commencing on 21 January 2012. Advertisements were placed in The Saturday Examiner and on the EPA web site. The DPEMP was also referred at this time to relevant government agencies for comment. Two public submissions were received.

On 28 February 2012, the Deputy General Manager (EPA Division) acting under delegation from the Board requested that the proponent prepare a DPEMP Supplement to address public, government agency (including DPIPWE) and Council comments on the DPEMP. Hardrock Coal Mining submitted three draft versions of a DPEMP Supplement between April and July 2012.


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2 SD objectives and EIA principles

The proposal must be considered by the Board in the context of the sustainable development objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) established by the EMPC Act. The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to protect the environment of Tasmania, and to further the RMPS and EMPCS objectives.

The Board must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment Principles defined in Section 74 of the EMPC Act.


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3 The proposal

The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 2 of the DPEMP.

Table 1: Summary of key proposal characteristics

Activity

Underground extraction and sizing of up to 1M tonnes per annum of coal.

Location and planning context

Location Off Valley Rd, Fingal-as shown in Figure 1

Land zoning Natural Resources Zone (Break O’Day Planning Scheme 1996)

Land tenure Crown Land (Forestry Tasmania) PID 2542073

Mining lease Pending (revised application expected 2013)

Lease area Forecast at 1016 ha.

Bond Pending (no mining lease granted)

Existing site

Land Use Forestry

Topography Development site is located on the undulating plateaus of the Fingal Tier land system, just below the high stony crests. Landscape is steep and often heavily scoured.

Geology In the Fingal region, flat-lying marine sediments of Permian age (correlates of the Upper Marine sequence of the Lower Parmeener Supergroup) are conformably overlain by Triassic coal measures, up to 400m thick, of the Upper Parmeener Supergroup. Minor Jurassic dolerite also intrudes the coal measures. [DPEMP Part 3.2.2, p40]

Soils The development site is located on the undulating plateaus of the Fingal Tier land system, just below the high stony crests. It is characterised by open forest on Jurassic dolerite, with deep (1m) soils. Soils are stony and gradational with a stony clay loam surface over a yellow-brown, light clay. Davies (1988) notes that these soils are not particularly susceptible to erosion. [DPEMP Part 3.2.3, p41]

Hydrology Cardiff Creek (class 3 stream) is the main stream through the site. It has a catchment of harvested forest and informal reserved forest which includes Smudgy Gully. It ultimately drains to the Break O‟Day River at the Killymoon Bridge. Three other „drainage lines‟ pass through the site and are identified as Western, Eastern and Central drainage lines respectively. The Western drainage line is a tributary of Cardiff Creek and a class 4 stream. Eastern and Central drainage lines appear to have substantial flow only during major rainfall events. Preliminary groundwater model highlights likely presence of perched aquifer in dolerite talus; dolerite bedrock aquifer; coal seam aquifer and fractured rock aquifer. Mining is predicted to disturb the latter two aquifers, leading to mine inflow of groundwater.


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Fauna Threatened fauna that have been recorded, or are predicted to occur within 5 km of the site according to the Natural Values Atlas Report and the EPBC Act Protected Matters Search Tool include:

Wedge-tailed eagle (Aquila audax)

Swift parrot (Lathamus discolor)

Tasmanian masked owl (Tyto novaehollandiae)

Grey goshawk (Accipiter novaehollandiae)

White-bellied sea-eagle (Haliaeetus leucogaster)

Eastern barred bandicoot (Perameles gunnii)

Green and gold frog (Litoria reniformis)

Swan galaxias (Galaxias fontanus)

[for full listing see DPEMP, Part 3.2.7 pp49-50]

An additional special values assessment by Forestry Tasmania confirmed the presence of suitable habitat on the proposed development site for the endangered Tasmanian masked owl. This assessment also provided further information about WTE nesting locations and habitat range.

Flora No threatened species were recorded during a botanical field survey and threatened species identified within 5 km of the study area through the Natural Values Atlas were considered unlikely to occur within the study area as there was determined to be little suitable habitat. A threatened community was identified and mapped during the field survey. E. amygdalina on sandstone (DAS) is listed as Threatened under the Nature Conservation Act 2002 and was recorded near the proposed mine portal. Less than 1 ha of this vegetation is expected to be removed during mine‟s construction activities. [DPEMP, Part 3, p48].

Local region

Climate Rainfall approximately 612 mm per annum. Temperature 12.1°C in July to a high of 23.4°C in January. Mean minimum temperatures range from low of 0.5°C in July to high of 10.3°C in January.

Surrounding land and uses

Forestry (tree harvesting and quarrying) and agriculture.

Species of conservation significance

Wedge tailed eagle; Tasmanian masked owl; Grey goshawk; White-bellied sea eagle; Tasmanian devil; Eastern barred bandicoot; Green and gold frog; Australian grayling; Swan galaxias

Proposed infrastructure

Major equipment Continuous miners and underground crusher

Overground belt coal conveyor

Coal hoppers

40 t truck-trailer units

Package sewage treatment plant

Office and amenities buildings

Workshop and facilities

Water storage tanks (with filtration and UV sterilisation)

Other infrastructure

Up to three water improvement ponds/ basins (plus a ~900kL retention basin)

New electricity transmission lines (including substation and transformer)

Inputs

Water Intent is to abstract water from Cardiff Creek for potable and utility use. A number of tanks will be provided to settle suspended solids and store water. Groundwater inflow to


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mine may be used to supplement supply from Cardiff Creek (utility use only). Estimate 2.5-5ML initial water demand per annum, increasing to 10ML per annum at coal extraction rate of 1M tpa.

Energy Electricity (for most major plant and equipment including continuous miners and conveyor): 7 500 MWhr pa

Diesel (for mobile plant, trucks): approx. 19TJ pa (approx. 500 kL pa)

Wastes and emissions

Liquid Stormwater runoff from hardstand areas (eg. coal load out) and access roads will be directed to water improvement ponds (includes ~900kL retention dam). Mine water (groundwater) will be pumped to the surface and directed to water improvement ponds/ basins. Discharge of water from retention basin to Cardiff Creek (or Break O‟Day River) is forecast, depending on acceptable water quality and flow in receiving water body.

Stormwater from proposed waste rock (interburden) dump (near Forestry Tasmania‟s Abrahams quarry) will be directed to a 300kL sediment basin. Periodic discharge to existing road culvert or natural drainage channel is forecast.

Package wastewater plant expected to treat up to 18kL per day. Treated water intended for dosing to sediment/ retention basins [DPEMP Supp, Appendix 11 Part 6]

Atmospheric Coal dust and dust from gravelled access tracks, Valley Rd and mine ventilation system.

Solid General refuse

Construction and industrial waste (eg. packaging materials, waste oils and lubricants)

Interburden/ waste rock- Net Acid Generation and Net Acid Producing Potential will be determined

Grease from interceptor traps, silt from water improvement ponds

Contracts will be established with suitably qualified and approved waste transporters/ handlers to manage solid wastes that arise from mining operations.

Safety and Environmental Management Plan will include provisions for management of waste materials (particularly during mine development).

Subject to favourable AMD results, a waste rock dump (WRD) will be constructed to store and manage interburden arising from initial mine development. The WRD will be created at or near a former Forestry Tasmania clay borrow pit on the intended mining lease, about 5km south east of the intended coal mine.

Noise From overground belt conveyor, hopper loading, coal load out by truck and trailer, waste rock transfer to Abrahams Pit, utility vehicles moving to and from the site. Workshop activities, deliveries of diesel and other materials.

Greenhouse gases

Estimate release of approx. 3 600 tpa CO2-e (emissions from electricity use 2 300 tpa and diesel consumption 1 300 tpa)

Commissioning and operations

Operating hours Five days per week commencing 23:00hrs Sunday to 23:00hrs Friday

Three shifts of 8.5hrs per day

Project timetable Mine life forecast at about 15 years.


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Figure 1: Proposed location of underground coal mine (DPEMP Drawing C2-04)


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Figure 2: Site plan (DPEMP Drawing C3-01)


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4 Need for proposal and alternatives

The project is a proposed underground coal mine and associated infrastructure with an extraction rate of up to one million tonnes per annum (1M tpa). The intent is to export all coal to Asia, primarily for energy generation in fluidised bed combustion power plants. To this end Hardrock Coal Mining (HCM) has partnered with a number of Asian energy generators which are required to improve their performance and reduce carbon emissions from their power stations.

HCM predicts the saleable coal resource at 447 million tonnes in-situ, according to the requirements of the Joint Ore Reserves Committee (JORC) code. It is on this basis that project feasibility has been assessed and investment procured.

Previous exploration activity has established that coal is of sufficient quality (ie will meet customer requirements) to negate the need for additional onsite processing (eg. coal washing). As shown in Figure 2, onsite activities will be limited to underground coal extraction, transfer of coal, first by shuttle car and conveyor to the surface, then by truck to a new rail spur adjacent to the Valley Rd and Esk Highway intersection.

Site alternatives

HCM has determined that for the mine to be viable the development site must be located in the immediate vicinity of the coal resource. HCM‟s geological assessment has established that the most viable coal seam for immediate extraction is located in the former mine operation known as Valley 2 Mine. While the Fingal Valley has vast underground coal resources, HCM considers that the disused Valley 2 mine is the most accessible and viable project site.

A key determinant for the proposed underground mine is its close proximity to existing road and rail infrastructure. The development site is located approximately 500m from the junction with Valley Rd, an important access road that services the forestry industry and managed by Forestry Tasmania. Access to the development site is about five kilometres from the Valley Rd-Esk Highway intersection and around six kilometres east of the Fingal township boundary.

HCM considers as critical the existing rail infrastructure at Fingal, since rail transport is the most effective and efficient way to move extracted coal to a dedicated terminal at TasPort‟s Bell Bay Port.

Design alternatives

HCM has selected underground bord-and-pillar extraction as the mining method, as it deems this the most economical way of extracting coal located in the initial mining area. HCM considers as unviable open cut mining, since the target coal seam runs horizontally from an outcrop in the Fingal Tier and is overlain by a dolerite cap greater than 300m in thickness once it extends to the Tier‟s plateau. Underground mining generally reduces the extent of environment impacts largely due to a reduced need for vegetation clearance, overburden removal with aboveground storage and less intensive final decommissioning and rehabilitation.

Consequences of mining not proceeding

HCM forecasts that the underground coal mine is likely to yield significant socio-economic benefits for the north east region and the State for a period of up to 15 years. By year three, when the mine is expected to be fully operational, substantial gains are predicted in local employment (78 FTE jobs) and population (300). Regional household income is expected to increase by about 1.4%.1 HCM considers these as very positive socio-economic indicators, likely to offset the negative socio-economic effects of a forestry sector in decline.

1 DPEMP Section 4.11.3, p.90


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5 Public and agency consultation

A summary of the public representations and government agency/body submissions is contained in Appendix 2 of this report. The proponent‟s response to those issues is contained in the DPEMP Supplement.

Two representations were received, though one was subsequently withdrawn. The main issues raised in the remaining representation included:

Deficient design of the Botanical Survey and Fauna Assessment, particularly with respect to fauna assessment.

That a desktop study [Strata report, Appendix 10] indicated potential for and instability in the area proposed for mining.

That potential impacts to groundwater had not been clearly identified and discussed.

The DPEMP was referred to a number of government agencies/bodies with an interest in the proposal. Responses were received from the following:

Department of Infrastructure, Energy and Resources (Mineral Resources Tasmania; Roads & Traffic Division).

Department of Economic Development, Tourism and the Arts (DEDTA, Secretary).

Forestry Tasmania.

The following Divisions/Areas of the Department of Primary Industries, Parks, Water and Environment also provided advice about the DPEMP:

Policy Conservation & Assessment Branch (Resource Management & Conservation)

Aboriginal Heritage Tasmania

Noise Specialist EPA Division

Scientific Officer (Water) EPA Division

Regulatory Officer (Mining & Extractives Unit) EPA Division

Air Modelling Specialist EPA Division

The DPEMP Supplement prepared by the proponent provides a response to each of the relevant environmental issues raised by the public and government agencies/bodies.


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6 Evaluation of key issues

The key environmental issues relevant to the proposal that were identified for detailed evaluation in this report were:

Interburden quantity and characteristics (eg. potential for acid and metalliferous drainage)

Land stability and siting of major infrastructure

Water quality impacts and sizing of water improvement system

Effects of noise on sensitive fauna (eg. wedge tailed eagle)

These issues are discussed individually in the following Sections. The table of commitments from the DPEMP is included in Appendix 3 of this report.

6.1 Interburden (waste) rock

Description

During initial mine development to access the desired coal seam and thereafter ongoing coal extraction, the intended bord and pillar mining method will encounter interburden that is likely to require resizing, removal and managed storage. HCM estimates that up to 24,000m3 of interburden (waste rock) is likely to be extracted during development of the mine drives (seam access), with a further 800,000 tonnes expected over the 15 year operating life of the mine.2

Due to limited storage capacity in the immediate area of the proposed mine, interburden arising from developing access to the coal seam is intended for storage in a new waste rock dump (WRD).3 HCM intends to develop the WRD about five kilometres south east of Valley adit No. 2 in former Forestry Tasmania (FT) clay borrow pit, adjacent an active FT quarry known as „Abrahams Pit‟. HCM intends to retain the remaining interburden underground in voids and spaces created by coal extraction.

Interburden has the potential to cause acidic and metalliferous drainage (AMD), depending on its composition, how it is accessed or disturbed and its proximity to and interaction with water (including groundwater). AMD can have substantial negative and persistent environmental, economic and social consequences, largely due to degradation of ground and surface waters. Serious and material environmental harm can occur in instances where AMD is acute, ongoing and/ or mitigation measures are inadequate or poorly implemented.

At the time of writing HCM had analysed material from two drill holes only for AMD potential, namely VR004 and VR006. The locations of both drill holes relative to the initial mine drive are illustrated in Figure 3. Briefly, a total of 27 samples representing core material from VR004 and VR006 were obtained and submitted for Net Acid Generation (NAG) and Net Acid Producing Potential (NAPP) testing. Samples were categorised as waste rock above, below or within the target and neighbouring coal seams. Assays showed that interburden in the region of the desired coal seam had low NAPP at <0 kg/T H2SO4 (all samples) and median NAGpH ~7.4 Minor potentially acid forming-low capacity (PAF-LC) material was detected but associated with coal seam measures (refer below). Such results suggest a low potential for AMD.

2 DPEMP Supplement July 2012

3 Subject to favourable AMD results.

4 Full NAPP and NAG results are illustrated in DPEMP Supplement V3, Appendix 6 Acid and Metalliferous

Drainage Assessment July 2012, Tables 6 & 7 Figures 4 & 6, p16-20.


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Figure 3: Intended drives relative to AMD sampling locations


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HCM reports that 52 samples of coal derived from its present drill program have been analysed for sulphur content. Assays showed the target F seam was associated with an average sulphur content of 0.3%.5 Historical coal seam data collected by Tasmania‟s Department of Mines during the 1980‟s also indicates that coal and potential waste rock at the proposed adit portal and area of early mine development have relatively low sulphur content. HCM states that a significant proportion of total sulphur in the carbonaceous material (coal) is organic sulphur, which is not expected to generate acid when naturally oxidised.

HCM‟s preliminary sampling and testing program of water presently draining from the adit of the Valley No.2 mine shows only slightly elevated iron and manganese with all other analysed parameters being within acceptable limits for drinking, irrigation or freshwater aquatic ecosystems. This observation again suggests that the prospect for AMD during mine development and ongoing operation is low.

While HCM‟s limited drill program did not confirm the identity of PAF material, the visual observation of pyrite in some coal samples points to the possibility that some PAF-LC material may be encountered at the site (albeit a low risk).

Considered together, NAPP and NAGpH results, acid base accounting, historical coal seam sulphur data, water quality results from Valley No. 2 adit and anecdotal evidence about AMD from Cornwall Coal personnel suggest that interburden (and coal measures) is likely to exhibit low AMD potential and as a consequence represent little risk to the environment.

Management measures

While the risk of AMD at the proposed coal mine is considered low, HCM has developed an AMD Contingency Management Plan (DPEMP Supplement Appendix 13) at the Director EPA‟s suggestion. This plan outlines a range of precautionary AMD management measures that will be adopted to control and minimise potential AMD impacts in the unlikely event that significant quantities of non-saleable PAF-LC, or PAF material is encountered during mine development and operative phases.

Briefly, the intended control measures for potential AMD fall into the following categories:

1. Material characterisation

2. Minimise disturbance of suspect PAF-LC and PAF materials

3. Selective handling procedures

4. Passive treatment processes

5. Active Treatment processes.

The suite of intended AMD management measures is illustrated in a flow diagram in the AMD Contingency Management Plan (Figure 7, p29). In the first instance, all non-acid forming (NAF) and acid consuming (AC) material recovered during mine development will be relocated and stored in a new waste rock dump adjoining a Forestry Tasmania quarry known as „Abrahams Pit‟. This former clay borrow pit is situated about five kilometres south east of the proposed mine and can readily accommodate HCM‟s estimate of 24,000m3 waste rock. The waste rock dump‟s design criteria, construction methods, ongoing sediment control and rehabilitation (including monitoring) are outlined and discussed in the Waste Rock Management Plan (DPEMP Supplement Appendix 12). HCM commits to managing waste rock from the mine‟s initial development in accordance with this Plan and the AMD Contingency Management Plan [Commitment 9].

5 95% confidence limit 0.39%


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Interburden material suspected as being PAF-LC6 will be blended with NAF / AC material at a location a few hundred metres north west of Valley No. 2 adit as depicted in Figure 8 of the AMD Contingency Management Plan.7 HCM has identified acid consuming sandstone and mudstone during its drill program. At this location, any blended stockpiles will be made into stable landforms, covered with suitable NAF material, topsoil, revegetated and monitored. All leachate from this area will be collected and directed to the site‟s water treatment system.

Material suspected as PAF will initially report to temporary underground storage at a location near Valley No. 2 adit (AMD Contingency Management Plan Figure 8). This facility will cater for at least 5,000m3 PAF material and be constructed in an area comprising NAF or AC rock type. Other construction criteria are detailed in AMD Contingency Management Plan Part 5.2.2 (pp33-34). If necessary, HCM proposes additional temporary storage for up to 30,000m3 PAF material will be provided aboveground, again near Valley 2 adit.

HCM states that PAF material will ultimately be encapsulated within an appropriately designed facility, located and constructed in accordance with best practice environmental management guidelines and in consultation with EPA. HCM will review the most appropriate location for the PAF encapsulation facility, using a risk assessment framework and taking into account contemporary, relevant information. If required, the PAF encapsulation area and/or PAF-LC blending and disposal area will likely be co-located at the above ground holding area (refer AMD Contingency Management Plan Figure 8).

A range of control measures to protect water quality will also be adopted, including the use of surface drains lined with limestone, pH / alkalinity monitoring and installation of an active dosing unit at the water treatment system, with the option to recirculate surface water through the dosing system should the need arise. These indicative control measures are illustrated in the AMD Contingency Management Plan Figure 9 and will also be employed to manage runoff at the proposed waste rock dump.

Sampling and AMD characterisation of important rock types is to occur every 80m of road header advancement (or about every fortnight) throughout the forecast six month adit construction period or when new or visibly different geological units are encountered (throughout mine development and operative phases).8

As outlined previously, the estimated remaining 700K tonnes waste rock likely to be encountered over the mine‟s expected 15 year operating life is intended for underground storage.

Public and agency comment

With reference to the DPEMP, the EPA Division, Mineral Resources Tasmania (MRT) and Forestry Tasmania (FT) highlighted that:

1. Though the potential for AMD is expected to be low this situation must be verified by mine water analysis and acid base accounting.

2. HCMs assertion about the likelihood of minimal waste interburden rock and coal of sufficient quality to negate the need for any further onsite processing (eg. washing) was premature, given insufficient drilling in order to characterise interburden and properly understand the quantity.

3. Interburden should be properly characterised and quantified during resource drilling so that waste management strategies can be finalised and assessed. .

4. Interburden material would need to be tested and declared free of Phytophthora cimmamomi before FT considers accepting it for storage in spent FT quarries or pits.

6 Eg. sighting of new or visibly different geological units

7 Provided kinetic modelling indicates this is a suitable treatment method.

8 AMD Contingency Management Plan Section 5.2.1, p32.


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Considering each of these issues in turn:

1. HCM included and discussed results of AMD tests (eg. NAPP, NAGpH, acid base accounting) on material abstracted from two of its drill cores in the DPEMP Supplement. Results of additional coal sulphur assays and HCM‟s preliminary water quality monitoring program were also included and discussed in the DPEMP Supplement.

2. The DPEMP Supplement V3 included more detail (including assumptions) about how interburden volume had been determined, describing several scenarios including worst case. A revised estimate for waste rock volume was provided. The characteristics of waste rock (and coal) were further elucidated in the DPEMP Supplement by inclusion of several reports, namely:

AMD Assessment

AMD Contingency Management Plan

Waste Rock Management Plan

3. The DPEMP Supplement included an AMD Contingency Management Plan to address this issue.

4. FT confirmed in the DPEMP Supplement that HCM had consulted with it during development of the Waste Rock Management Plan. FT confirmed that it is agreeable to interburden material being placed in a former FT clay pit adjoining „Abrahams Pit‟, provided that:

The material meets EPA guidelines for storage

The material is suitable for rehabilitation purposes

It will not cause future environmental issues on State forest or to other adjoining neighbours

EPA confirms with FT that AMD assessment of interburden material meets required environmental standards for the proposed use on State forest

Evaluation

HCM has formed a view that the AMD risk posed by waste rock (or interburden) is low. This view is based on HCM‟s assessment of:

Historical coal seam (low) sulphur analyses

Anecdotal evidence from mine personnel at neighbouring Duncan Colliery

Its own, limited testing of material from two drill cores for AMD parameters

Its own, preliminary water quality monitoring of drainage from Valley No. 2 adit

It is noted that the results of sulphur analyses of F seam coal are not dissimilar from those obtained by MRT (formerly Dept of Mines) and that the sulphur content of ~0.3-0.4% is considered low. It is also acknowledged that a significant proportion of total sulphur in this coal fraction is organic sulphur that will not generate acid under natural oxidation processes.

While historical observations indicate that AMD is not (has never been) a critical issue at the neighbouring Duncan Colliery, this anecdotal information can not be relied on as evidence that the risk of AMD at the intended mine site will also be low. However, the observations do provide important and relevant context and ultimately help corroborate the other AMD findings. In addition, the geological genesis (namely deposition in a fresh water rather than a marine environment) and climatic conditions in this part of north-east Tasmania are not typically associated with a high degree of AMD risk.

While HCM‟s AMD testing program was limited, the results correlate to a large degree with those obtained through the other avenues of AMD inquiry outlined above. There is no obvious conflict or


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disparity between the results of several lines of AMD inquiry and taken together, the evidence suggests a low risk of AMD at the intended mining location.

Even with an assessment of low AMD risk, the fact remains that PAF material may be encountered during initial mine development and then day-to-day operations; a prospect acknowledged by HCM. Consequently the Director EPA suggested that HCM develop a strategy to deal with unanticipated discovery of material (waste rock and coal) likely to cause AMD. The resulting AMD Contingency Management Plan contains a suite of precautionary measures that if properly applied should reduce / limit AMD risk to an acceptable level in the event PAF material is discovered, with the exception of HCM‟s proposal to create a temporary aboveground holding facility for suspect PAF material. To bring suspect PAF material to the surface is to immediately create conditions conducive to formation of AMD and is a scenario that can not be condoned unless appropriate management measures are in place. This can be given effect through a condition that prohibits PAF material being removed from underground unless the Director has approved specific management arrangements for the material.

Aside from this aspect of HCM‟s intended AMD contingency strategy, the remaining mitigation measures are proportionate to the AMD risk level posed by the mined material, technically proven and can be readily escalated if required. The Division‟s Scientific Officer (Water) reviewed HCM‟s AMD Contingency Management Plan and was satisfied that the Plan‟s management hierarchy is sound and contains a flexible, effective mix of precautionary measures which if properly implemented should limit AMD risk to an acceptable level. AMD mitigation and management measures will be specified by condition.

With reference to the issues outlined at Public and agency comment, with one exception, HCM has dealt adequately with these by providing a number of management plans which outline how waste rock (and coal measures) has been characterised, quantified and its intended storage/ disposal avenues depending on AMD risk profile.

The exception concerns the degree of certainty associated with HCM‟s estimate of waste rock volume. HCM has forecast that drive development will yield about 24,000m3 waste rock, most of which it expects will be NAF or AC and able to be stored aboveground. However, this volume is possibly an under-estimate, since HCM‟s calculations only consider the potential waste rock from drive development and presume that there will be extractable coal for most of the distance of the development drive. There are also no provisions for waste rock that will be derived from initial mining of the coal resource. This presumption may be optimistic given the variable nature of coal in this region (variable thicknesses, splits in seams, faulted areas), evident from previous exploration (MRT regional drilling and geophysics) and nearby mine development (Duncan Colliery). This scenario is likely to render sections of mine development unsuitable for commercial coal extraction, as large volumes of waste rock may need to be removed to develop the mine to a point where viable coal sections are encountered. To date HCM has not accumulated sufficient evidence (via rigorous mine planning and exploration) from which it can make confident statements about waste rock volumes or coal resource to be won.

In brief, HCM may encounter greater volumes of waste rock than presently calculated and that volume may exceed the design capacity (48,000m3) of the proposed waste rock dump. As such, HCM will need to develop a suitable contingency strategy (ie identify and develop additional secure and safe aboveground storage) to manage waste rock volumes substantially in excess of 48,000m3.

Conclusions

As previously discussed, while the evidence suggests a low likelihood of encountering significant deposits or amounts of PAF material during construction and operational stages, contingency must be made for this scenario. A range of requirements (via permit conditions) is proposed to ensure that the state of knowledge about the AMD potential of geological material (waste rock in particular) is continually improved as development progresses, The recommended permit


19

conditions aim to address each area of uncertainty and ensure that PAF material, if encountered, is properly contained and managed.

The management hierarchy that must be adopted to control and limit the risk of AMD is summarised in condition OP1. Briefly, routine observations and laboratory analyses will be conducted throughout construction and operational stages to determine each rock type‟s AMD potential (AMD classification). Where PAF-LC and PAF material is confirmed, disturbance of these areas must be minimised. The remaining controls comprise selective handling and disposal practices, passive treatment processes (such as limestone lined drainage channels) and finally active treatment processes (eg. chemical dosing at water treatment system). Specific AMD sampling, testing and reporting protocols are specified in a Table of Monitoring (Attachment 4) linked to condition M2. Briefly, during roadway construction rock types must be sampled, tested and classified with regard to AMD potential every 80m of road header advancement (or every two weeks) and when new or visibly different geological units are encountered. For ongoing mining operations, rock types must be sampled, tested and classified with regard to AMD potential whenever new or visibly different geological units are encountered.

To limit the risk of AMD posed by PAF material, all suspect PAF material must wherever practicable be retained underground and managed to prevent AMD. Managed includes all appropriate measures to encapsulate PAF material to minimise ingress of oxygen and provision of leachate collection and treatment. If PAF material is intercepted during the early stages of roadway development then retaining this material underground may not be readily achievable. In this case Condition CN3 requires the person responsible for the activity to prepare alternative management arrangements and submit to the Director for approval. Appropriate alternative management arrangements may include limited blending of PAF-LC material with NAF and AC material on an impervious surface with provision for leachate collection and treatment.

Material determined by laboratory analysis to be NAF or AC has low AMD risk and as such can be placed in a suitable „waste rock dump‟ (WRD). The location and minimum design volume of the intended WRD are specified in condition CN2. As noted there is a possibility that the preliminary waste rock volume may be under-estimated. Consequently condition CN2 also requires the preparation of a waste rock contingency management plan should it become apparent during roadway construction that a quantity of waste rock over and above the design volume of the WRD will be encountered. The Table of Monitoring referred to above (permit Attachment 4 linked to condition M2) also specifies the indicators of AMD that must be monitored for at the point where the WRD sediment basin discharges.

A vital aspect of limiting the prospect of AMD from waste rock is to ensure a robust (auditable) tracking procedure or protocol is in place. This requirement is reflected in condition CN4.

Once the mine roadway has been constructed and commercial quantities of coal reached, further quantities of PAF material are not likely to be encountered.9 In the event that PAF material is intercepted during commercial coal extraction however, sufficient underground space should be available to encapsulate this material and restrict conditions for AMD developing.

The combined evidence threads suggest that risk of AMD posed by the intended underground coal mine is low. Provided that the person responsible for the activity complies with the proposed conditions, any residual AMD risk is considered to be minimal.

9 Coal has been shown to possess very low AMD potential.


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6.2 Water

Description

The intended mining site, as defined by the location of key assets in drawing C3-01 (DPEMP Appendix 7), lies on a steep northerly facing slope within a catchment area known locally as „Smudgy Gully‟. This catchment extends approximately 800m to the top of the Tier to the south and south west and consists of many drainage and creek lines that are steep and often heavily scoured. One Class 3 stream10 and three main drainage lines dominate the intended mining site, namely Cardiff Creek and what HCM denotes as the western, central and eastern drainage lines respectively. The relationships between these watercourses are illustrated in Drawing H1-01 (DPEMP Appendix 7). This drawing shows how Cardiff Creek ultimately intercepts all three drainage lines as it passes through the area where most major mining assets will be situated.

Stormwater Uncontrolled stormwater flows from major mine asset locations including Valley No.2 adit area, coal loading hardstand, laydown area, haul road and roofs have the potential to cause environmental nuisance or harm by concentrated transfer of sediment (including coal fines), hydrocarbon and other pollutant load to Cardiff Creek and the three nominated drainage lines. Uncontrolled stormwater flows from these locations are also likely to exacerbate scouring of watercourses and riparian zones, especially during periods of very high rainfall.

Groundwater The intended coal mine has the potential to adversely affect groundwater resources in a number of ways, including:

Inducing AMD by exposing (if present) acid-forming minerals, a consequence of mine dewatering

Depressing water table and aquifer depressurisation. Mine dewatering can lower groundwater levels, which may adversely affect other groundwater users, groundwater dependant ecosystems and surface water base flows

Contamination (eg. hydrocarbons) during coal extraction and dewatering activities

Infiltration by contaminated surface water from aboveground mining assets such as intended bulk diesel storage tank, hardstands, haul road and conveyor

Potable water HCM intends to abstract water from Cardiff Creek and the western drainage line to provide the mine site‟s potable water. Uncontrolled water abstraction may compromise environmental flows and lead to degradation of established aquatic ecosystems.

Domestic wastewater HCM intends to install a package treatment plant able to treat a peak black and grey water load of 120 equivalent persons per day to cater for an anticipated workforce of 50-100. The intent is to treat domestic wastewater to secondary grade conforming to the specifications defined in AS/NZS 1546.1:2008 On-site domestic wastewater treatment units – Septic tanks and AS/NZS 1547:2012 On-site domestic waste water management. Treated domestic wastewater will be dosed to the water improvement system. Discharge from the package treatment plant is likely to represent about 8% of the average monthly inflow to basin one.

Discharge of treated domestic wastewater that fails to conform to the nominated standard may compromise the treatment capability of the water improvement ponds, in turn affecting the ability of this system to meet its own discharge requirements.

10 Class 3: Watercourses carrying running water most of the year between the points where their catchment is 50 and 100 ha (Tasmanian Forest Practices Code 2000).


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Baseline water monitoring: Surface water HCM has compiled about an eight month set of baseline water quality data for a suite of parameters negotiated with the EPA Division‟s Water Specialist. The proposed activity‟s Water Management Plan (DPEMP Supplement Appendix 11) Table 8 outlines the suite of monitoring parameters and monthly results while Figure 10 illustrates the monitoring locations. Briefly, the results indicate that:

Surface waters at the site are slightly alkaline, with Cardiff Creek exhibiting greatest flow rates

Water quality within Cardiff Creek and both the western and central drainage lines appeared to be of „good quality‟, meeting HCM‟s adopted water quality guideline trigger levels.11

In contrast, surface water at monitoring location „Valley M‟ on the eastern drainage line near Valley No. 2 adit was characterised by:

Slightly more acidic conditions (though still in the normal range)

Elevated conductivity levels (typically 2 to 3 times above adopted guideline trigger levels)

Elevated TDS and TSS concentrations, relative to other sampling locations (though still within adopted guideline trigger levels)

Iron and manganese levels in excess of guideline trigger values, though with minimal potential to adversely impact aquatic ecosystems.

Baseline groundwater information There have been no site-specific studies concerning contemporary groundwater systems, quality or flows at the proposed mine site. Some preliminary inferences about these groundwater aspects are reported in GHD‟s Stage 2 Hydrogeological Review (DPEMP Supplement Appendix 7).

A bore within about 2 km of the site has been used to gain an understanding of the Protected Environmental Values (PEVs) likely to apply in this locality. Based on the chemistry of water discharging from Valley No. 2 adit (where EC < 1,000 μS/cm), HCM postulates that groundwater in this area accords with segment A of the PEV-the segment associated with the highest level of beneficial uses.12 Anecdotal evidence from former Duncan Colliery workers indicates coal seam groundwater has relatively low salinity and is near neutral. No details on dissolved metal content were available.

HCM uses monitoring results for water discharging from the Valley No. 2 adit and two Cardiff Creek monitoring sites to provide some initial indicators about groundwater chemistry. With specific reference to water draining from Valley No. 2 adit, HCM‟s key initial inference about groundwater quality is that relatively low sulphate levels indicate that there is not a significant amount of pyrite oxidisation within the mine adit, consistent with the low sulphide content identified in concurrent AMD testing. HCM intends to develop and install facilities for direct groundwater sampling and testing of discrete aquifers (groundwater sampling bores) during its program of resource delineation drilling.

Numerical groundwater flow modelling for initial mine development, using both a calibrated model and a stochastic distribution model, indicated similar steady-state inflows with a 90th percentile inflow rate of 1.5 L/s (DPEMP Supplement Appendix 7, p41). HCM expects that most of this water could be utilised for underground operations (eg. dust and fines suppression) or allowed to dissipate naturally underground. On occasions where surplus groundwater arises, HCM intends to pump groundwater to the mine‟s water improvement ponds after initial settling of fines and dust in underground sumps. HCM notes that most underground water is likely to accompany coal exported to the surface.

11

Water Management Plan Part 5, p31. 12

State Policy on Water Quality Management 1997, Table 1.


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Stage 2 Hydrogeological Review’s conceptual groundwater model describes the possible local aquifer types, configuration, flow and impacts of underground mining on the groundwater system. HCM‟s assessment is that while the intended mining activity will intercept groundwater, high or unmanageable inflows are not expected (refer above), the bulk can be used during underground operations and conventional techniques to limit fracturing and manage ingress of groundwater (eg. grouting) will be applied. In addition, HCM states that the use of electric mining equipment (notably continuous miners) is likely to limit the extent of groundwater contamination.

Water balance and sizing of water improvement ponds HCM has developed a conceptual water balance for the proposed mining activity (DPEMP Supplement Appendix 11) and determined that:

About 2.5-5ML potable water per annum would be required, abstracted from Cardiff Creek and the western drainage line and stored in multiple aboveground tanks

Based on the previous 112 years of rainfall data and assuming the series of water improvement ponds provide 1ML of storage capacity, a net water discharge to the receiving environment is expected (est. average monthly discharge about 0.5ML)

On most occasions there is likely to be a net surplus of groundwater after underground operational uses

HCM‟s Water Management Plan (DPEMP Supplement Appendix 11) details how the water improvement system has been designed to manage expected monthly inflows from major mine asset locations including Valley No.2 adit area, coal loading hardstand, laydown area, haul road and roofs. Ability to capture and effectively remove sediments was the primary design criterion. Modelling indicated that sediment removal and other treatment requirements were favoured by employing a series of basins rather than a single basin. The preferred design outcome was a treatment system of about 1ML comprising three interconnected ponds with overflow to a ~900kL retention basin. HCM intends to use water from the retention basin for utility purposes, such as dust suppression (above and below ground) and other underground operations. The retention basin‟s spillway leads to the eastern drainage line and then to Cardiff Creek. HCM has nominated this location as the permitted discharge point for the mining activity.13 Ponds will be designed and constructed with reference to appropriate standards and guidelines (eg.DPIPWE‟s ACDC Offsets Guidelines).

Water quality monitoring HCM has proposed a water quality monitoring program for surface waters and groundwater. It has also nominated the point where the retention dam discharges to the eastern drainage line (and then Cardiff Creek) as the monitoring location. The proposed monitoring locations, parameters, sampling frequencies and trigger guideline values are described and discussed in the Water Management Plan Part 5, pp29-42.

The primary potential pollutant to the water improvement system is sediment of varying sizes, whether coal derived or from other sources (eg. disturbed soils). Other pollutants are likely to include hydrocarbons from operation of machinery and organic/inorganic materials contained in discharge from the proposed domestic package treatment plant.

In summary, HCM intends to channel all potentially contaminated waters associated with the mining activity to the water improvement system. HCM states that the water improvement system is designed to effectively treat potentially contaminated water from previously identified input locations to an acceptable standard for discharge to the eastern drainage line and then Cardiff Creek.

13

Denoted as „SPILL‟ in Water Management Plan, Table 11 & Figure 11, pp41-42.


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Management measures

Stormwater HCM intends to install a number of culverts at existing creek and drainage line crossings to manage stormwater flow through the proposed mine site. The aim is to divert as much stormwater as possible around the proposed major mine assets and working areas to limit the volume of stormwater requiring treatment. HCM will mitigate the potential for erosion and undue impact on aquatic habitat from culvert construction and water diversion by ensuring culverts are designed to relevant standards, including the environmental design requirements in the Tasmanian Wetlands & Waterways Works Manual 2003.

A new culvert will be installed at Cardiff Creek between Valley Rd and the coal load out area, where the creek presently bisects the access road. A new bypass culvert at the point where the central drainage line meets the light vehicle top road will direct both normal flow and any peak overland flow directly to Cardiff Creek, just above the new Cardiff Creek culvert. This diversion may exacerbate stream erosion and scouring at and around the point where the culvert discharges to Cardiff Creek, especially during periods of elevated rainfall. HCM intends to limit the prospect of undue erosion or scouring at this juncture by constructing an energy dissipating spill zone between the end of the culvert and the base of the creek, ensuring that the sides of the creek are protected from scouring during high flow discharges of the culvert. The proposed spill zone is likely to be constructed of nominal 150mm rock retained with wire gabions such that the flow is spread and dispersed over a nominal 3m wide dispersion zone as it enters the creek. Cardiff Creek generally has a broad sandstone base capable of receiving very large flows from the entire catchment. In particular the section of Cardiff Creek between the culvert discharge and access road crossing culvert is a well formed sandstone base, strewn with large boulders.

On the eastern drainage line a new throughput culvert will be established to drain runoff from the minor catchment above through to the original drainage gully below the working area of the proposed mine. The relationships between the intended culverts, watercourses and major mine assets are illustrated in drawings C3-01 and H1-01 (DPEMP Appendix 7).

Groundwater The preliminary hydrogeological model identifies the presence of a shallow perched aquifer in dolerite talus in the intended mining area. HCM notes this aquifer‟s location above new mine drives means that it should not be disturbed by proposed underground mining. The hydrogeological model also identifies a dolerite aquifer, which HCM believes should not be unduly affected by bord and pillar coal extraction provided that significant overhead fracturing can be avoided. In the event that pillars are robbed to the extent that roof collapse occurs, fracturing could extend up into a highly permeable zone above the coal seam to cause significant inflows. In such instances, or where underground mining intercepts open fault faults, HCM will manage elevated inflows largely by pumping to the surface sediment basins. According to HCM, any inflows are expected to be localised and associated with coal seams rather than strata. HCM‟s Mine Engineer states that „…the situation of the mine, in that it is super elevated above the surrounding topography, means that there are no deep aquifers or extensive alluviums that contain significant bodies of water nor a recharge mechanism.‟ and „…for there to be a significant problem there needs to be a recharge mechanism and geostatic head.‟ („Notes to DPEMP Supplement, August 2012‟14).

As indicated at Description, HCM views surplus groundwater as a valuable source of utility water. If it is not able to be immediately used underground then HCM will pump surplus groundwater to the aboveground water improvement system after initial settling in underground sumps.

14

„Notes to DPEMP Supplement‟ includes additional information from HCM, as requested by Division during preparation of this report.


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HCM commits to developing a number of groundwater monitoring bores by conversion of exploration holes to suit this purpose. HCM intends to monitor permeability, water levels, flow and chemistry and use the results to refine its preliminary hydrogeological model [Commitments 6 & 7]. HCM will use the refined model as a predictive mining tool to help avoid and limit undue impacts on groundwater. HCM‟s intended groundwater monitoring program is outlined in Stage 2 Hydrogeological Review Part 8.2 and „Notes to DPEMP Supplement August 2012‟.

Potable water HCM commits to draw water from Cardiff Creek and (if required) the western drainage line when flow and quality in the natural system are favourable. HCM expects that Cardiff Creek and the western drainage line will provide a sustainable yield of water suitable for potable and domestic use. If necessary HCM will augment supply with water collected from the roofs of buildings or import by water tanker.

Surface waters Aside from installing culverts to control stormwater flow, HCM‟s primary measure to mitigate undue impacts to surface water is to develop a series of three ponds (linked to a retention basin) to treat water from hardstand areas and underground mine to a suitable standard for occasional discharge to Cardiff Creek. This discharge location is the only discharge point to surface waters15 and will be associated with a monitoring regime specified by permit (in the event a permit is granted). HCM expects the retention basin to discharge infrequently and that discharge can be matched to suit adequate flow and quality conditions in Cardiff Creek to minimise undue impacts.

Provision of appropriate bunding at fuel storage and equipment refuelling and servicing areas will limit the risk of surface and ground water contamination by hydrocarbons in particular.

Another measure that HCM aims to adopt to avoid exacerbating sediment load to the water improvement system will be to, as far as practicable, take advantage of historical mine workings such as access tracks and other previously disturbed (cleared) land. For example, the coal load out area will be developed on a cleared terrace immediately below an old finger dump and historical access tracks will for the most part be upgraded (including minor realignment) to a standard suitable for larger, heavier vehicular access. Office and workshop locations respectively have also been selected to limit vegetation clearance. These configurations are evident in the site plan, drawing C3-01 (DPEMP Appendix 7).

Aside from the above measures, HCM also commits to implementing its Wastewater Management Plan, which as previously discussed outlines HCM‟s intended water quality monitoring program for surface and ground waters [Commitments 5 & 20].


With reference to the DPEMP, one representor was concerned that HCM had not clearly identified and discussed possible impacts to groundwater. This representor also suggested that HCM be required to conduct regular testing of water emanating from the development area.

HCM responded to the first point by conducting further hydrogeological field studies to produce the report Stage 2 Hydrogeological Review (DPEMP Supplement Appendix 7). As to the second point, HCM continued to collect and test water samples from a number of monitoring locations for a suite of parameters negotiated with the EPA Division. It presented and discussed results of this additional study plus details about its intended (surface and ground) water monitoring program in the reports Water Management Plan (dated 14 June 2012) and Stage 2 Hydrogeological Review (dated May 2012).

With reference to the DPEMP, the EPA Division and Mineral Resources Tasmania (MRT) highlighted that:

15

Other than a new discharge point to Cardiff Creek created by redirecting the central drainage line.


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1. The land identified for irrigation (drawings C3-01, C3-02 & C3-03) of wastewater from the package treatment plant did not appear to be appropriate with respect to soil type, slope and area. HCM should review and revise its irrigation plan with due regard to expected treatment performance of the package treatment plant and the need to protect water quality of ground and surface waters.

2. First wash diversion from the proposed coal loading area was not supported. Coal handling is not expected to cease during rainfall events. HCM should review this aspect of its intended water management strategy and if necessary include a revised measure to treat stormwater flow from the coal loading area in the DPEMP Supplement.

3. A Water Management Plan should be completed and incorporated into the DPEMP Supplement so that the proposed activity can be properly assessed based on the results and associated management measures.

4. Groundwater chemistry and AMD assessment (geochemistry) must be done and included in the DPEMP Supplement for assessment.

Taking each of these points in turn:

1. HCM revised its water management strategy such that treated wastewater from the package treatment plant is directed to the mine‟s series of water improvement ponds rather than being irrigated as originally proposed.

2. HCM revised its water management strategy such that all „first flush‟ water from the coal loading area reports to the mine‟s series of water improvement ponds.

3. HCM produced a Water Management Plan (DPEMP Supplement Appendix 11) for the proposed mining activity.

4. HCM produced Stage 2 Hydrogeological Review (DPEMP Supplement Appendix 7) and AMD Contingency Management (DPEMP Supplement Appendix 13) reports for the proposed mining activity.

Evaluation

Stormwater HCM will need to limit stormwater flow from the „Smudgy Gully‟ catchment through its intended mine site. Storm events or otherwise high rainfall episodes in the steep terrain of the Tier have the potential to cause serious damage to major mine assets if not suitably managed. HCM‟s proposal to use two strategically placed culverts to divert a relatively small fraction of typical overland flow away from the intended mine workings is fit for purpose and a valid way to restrict the volume of stormwater requiring treatment. Culverts are not expected to unreasonably interfere with or compromise the environmental or aesthetic values of the central and eastern drainage lines or Cardiff Creek respectively. HCM‟s proposed measures to limit high flows at the juncture of the new central drainage culvert and Cardiff Creek should minimise undue stream erosion or scouring at and around this point.16 Provided that HCM designs and constructs culverts with due respect to relevant guidelines and standards (eg. Tasmanian Wetlands & Waterways Works Manual 2003) then undue or unforeseen environmental consequences to the nominated waterways should be avoided.

Groundwater As indicated in the previous section, there have been no site-specific studies concerning contemporary groundwater systems, quality or flows at the proposed mine site. To counter this, HCM has developed a conceptual hydrogeological model using its own field observations and tests plus anecdotal evidence about conditions at the neighbouring Duncan Colliery.

16

Refer previous section, p20.


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A review of HCM‟s Stage 2 Hydrogeological Review yields the following observations:17

Hydraulic conductivity numbers presented for each rock type are similar to those already published for similar studies in the local area

Predicted inflow of 1 to 1.2L/s may not be a true representative value when major recharge events occur from East Coast low pressure systems (though is likely to be an appropriate estimate for the majority of the time)

The 27 runs of the stochastic modelling indicates a sensitivity analysis has been completed on the groundwater numerical modelling and the model appears to be robust

The four main potential hydrogeological hazards are addressed in an appropriate manner in Part 8.1 (p42). This is also supported by the results of packer testing

Overall, the report‟s methodology is sound and the modelling undertaken „acceptable with the current available information.‟

The review contained little information about groundwater quality and recommended that background groundwater quality conditions be determined before development starts. Additional monitoring and installation of piezometers as per Part 8.2 (pp43-44) is also supported.

It would have been preferable for HCM to build its own groundwater chemistry data set. However there is a need to balance time and financial spend necessary to achieve this with the likely degree of risk posed to groundwater quality by underground mining. To compile information about groundwater chemistry HCM has used the results for selected surface water quality parameters to infer what groundwater conditions might be like. The review of HCM‟s Stage 2 Hydrogeological Review noted the proposed mine and related groundwater system are likely to „have a direct connection to down gradient surface waters.‟ In this sense HCM‟s approach, to use selected surface water results as groundwater surrogates, appears valid. Anecdotal evidence about groundwater behaviour and quality has also been drawn from the adjacent Duncan Colliery. This information in general corroborates what HCM has determined from its own, albeit limited field work.

HCM has limited its inferences about groundwater chemistry to only key parameters, including sulphate level, conductivity, hardness and sodium absorption ratio (SAR). Such measures are useful indicators of potential AMD conditions underground (sulphate level), allow a PEV category to be nominated (conductivity) and the potential for scaling (hardness) and soil damage (SAR) respectively to be estimated. HCM‟s preliminary assessment that groundwater is likely to be of a standard suitable for the highest level of beneficial uses (including immediate use in underground mining operations) is considered fair. Given this scenario, HCM will need to adopt a very precautionary approach to mine development and ongoing operations.

HCM‟s preliminary groundwater analysis is sufficient to guide risk management planning at this stage of mine development, but more information about local hydrogeology must be obtained to refine the conceptual hydrogeological model and provide a useful predictive mining tool. As such, the range of (mine) management18 and monitoring measures listed in Part 8.2 (pp43-44) of the Stage 2 Hydrogeological Review, some of which are incorporated in DPEMP Commitments 6 and 7, is supported. When implemented, these measures will provide real time data about groundwater flows (including inflow rates), water levels and strata permeability. This information is vital to maintain a high degree of mine safety and environmental competence. Implementation of the proposed groundwater quality monitoring program should also allow HCM to make timely and informed decisions that limit mining impacts to groundwater quality.

17

Waste Management Officer Andrew Ezzy, 16/07/2012 18

Eg. low water level alarms to provide early warning of rapid dewatering associated with intersection of permeable faults or other potential inflow sources.


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Potable water HCM estimates that the Cardiff Creek catchment may yield a total water volume of up to 63ML. Even if this estimate is associated with a moderate (up to 15%) degree of uncertainty, HCM‟s forecast abstraction of 2.5-5ML pa from Cardiff Creek and the western drainage line represents only a small fraction of the catchment yield and is unlikely to unduly affect the natural functions of these water courses. HCM‟s intent to provide sufficient capacity to allow water take off only in times of suitable flow and quality is supported.

HCM‟s intent to install a small package water treatment unit comprising storage tank, dual cartridge filtration, UV disinfection and pressure supply pump to ensure abstracted water is suitable for potable use is also supported. HCM should install this treatment system in accordance with Break O‟ Day Council‟s specifications.

Sizing and treatment capacity of water improvement ponds The analysis of HCM‟s Stage 2 Hydrogeological Review indicated that the estimated groundwater inflow of 1-1.2 L/s was likely to be „appropriate‟ for typical meteorological conditions. The design of the water improvement ponds also considered the catchment size and slope, rainfall intensity and its susceptibility for soil loss during construction, as well as the expected coal dust on site from aboveground coal handling and from underground workings. While design calculations suggest a single basin of 0.5ML should provide sufficient capacity to remove most of the coarse sediment, it is noted that the preferred design includes two more basins (0.25ML each) to remove finer particles and to allow draw down for utility purposes. The methodology used to design the water improvement system [as per HCM‟s Water Management Plan] is sound and incorporates a reasonable level of engineering redundancy.

Consequently, the „concept‟ calculations done to verify sediment removal efficiency of the series of three basins as presented in the Water Management Plan Part 3.2.4 is accepted. While a full analysis of removal efficiency must be done at the detailed design stage, three interlinked sediment basins (0.25ML, 0.5ML, 0.25ML) is considered adequate to accept and treat the forecast volume of (sediment laden) wastewater to a standard suitable for periodic discharge to Cardiff Creek. At least two of the input streams, namely the treated domestic wastewater and surplus groundwater, should be associated with low pollutant load (low treatment demand). Flow from the coal loading area will pass through swales and culverts to capture and remove some of the initial sediment load from this area. The initial basin should settle and remove most coarse sediments, including coal dust and debris, from all input streams. The remaining basins should provide the extended detention period necessary to remove any remaining, finer particles such as suspended clays. It is noted that chemical dosing may be required to settle the finest particles. Regular de-silting of basin one (which will receive and remove the greatest sediment load) is supported. The treatment demand due to other pollutants, such as hydrocarbons, nutrients and other organic and inorganic (eg. metals) substances is expected to be low and catered for by the series of interlinked basins.

Domestic wastewater HCM has sized the domestic wastewater package treatment plant to allow for a 20% upward movement in employee number. This treatment buffer is adequate and should cater for a moderate increase in workforce over at least the initial years of the mine. The domestic wastewater package treatment plant is targeting Class B discharge quality as prescribed in Environmental Guidelines for use of recycled water in Tasmania 2002. Class B standard is considered acceptable and achievable. It is noted that the plant will be monitored and serviced at intervals required by the manufacturer. Passage of domestic wastewater treated to this standard through the proposed water improvement system is likely to allow further, albeit moderate, reductions to parameters such as BOD, nutrients and microbes.

Monitoring program As previously indicated, HCM has assembled about an eight month set of surface water quality data. The monitoring parameters and locations were developed in consultation with the EPA Division‟s Water Specialist and Scientific Officer (Water). HCM‟s background water monitoring has


28

allowed it to gauge how realistic its adopted guideline trigger values are and inform monitoring program design for the operational stage of the mine. HCM‟s adopted guideline trigger levels are considered to remain valid.19 HCM‟s proposed surface water monitoring programs outlined in its Water Management Plan Part 5.3 [encapsulated in Commitment 5] and Waste Rock Management Plan Parts 7 & 8 [Commitment 22], plus the groundwater monitoring framework outlined in Stage 2 Hydrogeological Review Part 8.2 is supported. The location identified as „SPILL‟ (Water Management Plan, Table 11 & Figure 11, pp41-42) is considered appropriate as the permitted discharge point for the proposed mining activity (should a permit be granted). HCM intends to provide the EPA with water quality results and discussion on at least an annual basis.

All monitoring requirements (sampling locations, parameters, frequencies, target discharge values) will be specified by environmental condition.

Conclusions

The strategic diversion to Cardiff Creek and the eastern drainage line of a proportion of stormwater flow through the intended mine site should help limit (unnecessary) sediment/ pollutant load to the site‟s water treatment system. Installation of a structure in the central drainage line-Cardiff Creek spill zone to dissipate energy from high culvert flows should limit scouring of the riparian zone. The requirement for adequate perimeter drains (culverts) is specified in standard condition E1. Similarly, standard condition E2 stipulates minimum obligations with regard to limiting degradation of receiving waters by stormwater runoff from the site. Provided that culverts are designed and installed according to relevant guidelines and standards then undue environmental impacts are unlikely.

Sediments are likely to represent the greatest, most consistent input to the water treatment system. Runoff from hardstand areas, formed tracks and the like will be directed to a series of three interlinked sediment basins and a retention basin which together should provide sufficient detention periods to remove sediments to acceptable levels. Minimum design and maintenance criteria for the activity‟s water treatment system are stipulated in condition E3.

Surface water monitoring over a period of about eight months has determined baseline/background quality and flow conditions at several key locations at the proposed mine site. This has enabled the selection of appropriate guideline trigger values and nomination of appropriate discharge limits. The Table of Monitoring (permit Attachment 4 linked to condition M2) specifies the suite of monitoring parameters plus sampling, testing and reporting protocols for surface waters, discharge points and groundwater. Discharge limits have been set for the point where the retention basin discharges to Cardiff Creek, as reflected in condition E5 (permit Attachment 6).

Preliminary results suggest that groundwater quality is suitable for most beneficial uses. Relatively low sulphate levels from Valley No. 2 adit suggest there is not a significant amount of pyrite oxidisation within the mine adit, consistent with the low sulphide content identified in concurrent AMD testing. Given that specific groundwater studies have not been conducted in the intended mine area, the expected high quality of groundwater and that underground mining is likely to intercept groundwater at some point, the person responsible for the activity will be required to collate quality and flow data on an ongoing basis to guide underground mine development and limit groundwater impacts. Groundwater monitoring bore design, installation and use criteria are specified in condition M3. Data should be used to refine the Stage 1 hydrogeological model to provide a useful predictive mining tool, as HCM commits to doing (commitment 6).

Provided that the above conditions are fully and properly implemented the risk of unduly degrading surface and ground waters is considered low.

19

To allow 95% protection of aquatic ecosystems (based on the requirement to protect species inhabiting a slight to moderately disturbed aquatic ecosystem).


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6.3 Geotechnical investigations

Description

HCM intends to mine coal and site major infrastructure assets such as water improvement ponds in an area known for its dynamic geology. Given the inherent geological instability of the intended mining area, HCM was required to conduct geotechnical investigation sufficient to demonstrate that above and in-ground infrastructure could be developed in nominated lease locations with a high degree of confidence. The intended mining area is not included in the existing coverage of MRT‟s landslide database.20

In the Fingal Tier the down slope movement of active Quaternary talus deposits manifests most notably as landslips. According to HCM‟s Geotechnical Assessment (DPEMP Appendix 2, p 8):

„Incision and erosion of drainage lines also contribute to movement as may infiltration and percolation of groundwater associated with a superficial aquifer in the talus deposits. The weathering products of the Triassic units may also show dispersive qualities and be prone to rill, sheet and tunnel erosion. This will increase instability risk in these soils, particularly where they are on slopes or proximal to drainage lines.‟

Initial geotechnical reconnaissance of the areas nominated for aboveground infrastructure such as coal load out pad and hoppers, coal conveyor, water storage tanks and workshop revealed clear evidence of geological instability (DPEMP Appendix 2, p 12-13):

„…the entire site showed evidence of recent active landscape movement, primarily as rock falls from higher areas associated with the talus, but also as incision and runout in drainage lines. The area around the [intended] office is possibly a former debris slide, with some morphological features of a landslide evident.‟

In addition, the Geotechnical Assessment notes (p 12) evidence of historical land instability with „…signs of debris slide and topples observed on high, steep talus slopes immediately to the west of the site associated with Spion Kop.‟

Mining assets should ideally be located on land that is geologically stable, where the inherent risk of down slope movement or landslide has been determined as low. Siting assets on areas of uncertain stability or where land instability is a more than likely prospect may lead to premature failure of these assets. In the case of HCM‟s intended series of three mine water improvement ponds, the ramifications of premature failure are likely to be relatively serious, both to the down slope environment and ongoing operation of mining itself. While simultaneous collapse of all ponds in a series of three is considered remote, the consequences of a single pond failing are likely to include:

At least short term physical damage to the surrounding natural environment

Pollutants (including sediments) entering nearby waterways (eg. Cardiff Creek), potentially in a concentrated burst

A suspension of mining

Disruption and degradation to amenity of down stream neighbours and water users

Given that water improvement ponds are integral to day to day mining, a significant rupture to even a single pond is likely to prompt an official review of the remaining pond‟s integrity, with the spectre of major remedial action or even pond relocation. In this respect, pond failure due to landslide has the potential to severely affect HCM‟s authority and capacity to mine.

While HCM acknowledged that the Tier and more specifically the area it proposed to mine is a landscape prone to instability, it was of the view that its preliminary geotechnical reconnaissance indicated that sufficient land could be identified in the vicinity of Valley No. 2 adit to site mining assets with an acceptable level of (environmental, social and financial) risk. In essence, HCM

20

http://www.mrt.tas.gov.au/portal/page?_pageid=35,840238&_dad=portal&_schema=PORTAL


30

contends that it will be able to formulate and implement an appropriate engineering solution to address any risks posed to infrastructure by land instability.

Management measures

HCM‟s preliminary geotechnical work is in essence a qualitative landslide risk assessment (LRA) for each of the zones nominated by HCM for development or siting of particular mining assets. Associated with each qualitative LRA is a list of risk mitigation strategies and residual risk assessment. In the case of the water improvement ponds for example, the LRA suggests that ponds should be located „…down slope on slopes of approximately 5°...provided that dams are suitably lined to prevent shallow water recharging of talus materials.‟ (DPEMP Appendix 2, p 28). Other risk mitigation options recommended via the LRA process include minimising earthworks, installing drainage above ponds and implementing an ongoing slope stability monitoring program. In all hazard situations, applying the proposed risk mitigation measures lead to an overall „low‟ residual risk rating in the case of the preferred water improvement system site.

The nominated zones for other site infrastructure, including water storage tanks, load out pad and coal hoppers, office and workshop were similarly treated. A site wide slope stability (qualitative) risk assessment was also conducted. Results are outlined respectively in Tables 1-5 of the Geotechnical Assessment. Table 6 (DPEMP Appendix 2, p 30) summarises for each asset location the key mitigation measures to minimise slope stability risk.

In terms of specific commitments to manage geotechnical risk, HCM commits to conduct and complete further geotechnical investigations prior to detailed engineering of site infrastructure [Commitment 1].


With reference to the DPEMP, the EPA Division and MRT highlighted that the land stability report (ie geotechnical study) was limited to a desk top review and considered insufficient to include in a DPEMP for a proposal of this nature. Both the EPA Division and MRT requested HCM to conduct a thorough onsite investigation by a suitably qualified expert in slope stability assessments of this scale. It was also requested that HCM submit the geotechnical report for peer-review before including it in the DPEMP [Supplement].

In response HCM commissioned Strata Geosciences, the firm responsible for the initial geotechnical study, to conduct some additional field investigations to more rigorously characterise and evaluate land stability risk. This additional study produced the qualitative LRA alluded to above at Management Measures.

Evaluation

Strata Geoscience‟s Geotechnical Assessment (DPEMP Appendix 2) constitutes a „reconnaissance‟ geotechnical study only, suitable to inform „…concept stage infrastructure design‟ as GHD states in its peer review of Strata Geoscience‟s geotechnical report. GHD‟s peer review, while generally supportive of how Strata conducted its initial study, serves to highlight the preliminary and highly qualified nature of initial geotechnical investigations. In addition, the peer review was in itself limited given that appropriately qualified GHD staff did not visit the intended mine site to „…independently assess the influence of topography or geology at the site.‟ (DPEMP Supplement Appendix 10, Part 2).

GHD‟s peer review contains the following critical observation about Strata‟s Geotechnical Assessment:

„Strata has developed an „initial‟ geotechnical model for the location of the mine site surface infrastructure. We deliberately use the term “initial” as we believe that there is much more to be done to get the model to a stage where the project team would have the confidence required to make important decisions on the location and detailed design of the surface works.‟


31

GHD‟s peer review also notes that for a mining activity of this scale, „…geotechnical investigations are often completed in a two stage approach, the initial investigation to inform site selection for the proposed infrastructure components and sometimes their concept design (suitable for development applications) and a furthermore targeted investigation to inform detailed design and construction.‟ (DPEMP Supplement Appendix 10, Parts 4 & 7). A substantial portion of the additional geotechnical studies recommended in both Strata‟s study and GHD‟s peer review does not constitute „detailed design‟ investigation, but represents the minimum investigation level necessary to demonstrate that mining assets can be developed on nominated footprints with a high degree of confidence (ie low risk of failure). The breadth of recommended additional geotechnical studies amplifies how preliminary the present land stability risk analysis has been (refer DPEMP Supplement Appendix 10, Parts 7 & 8).

While additional geotechnical investigations are likely to identify land with suitably acceptable landslip risk for most of the nominated mining assets, a similar outcome regarding the siting of the water improvement ponds is less certain. Site topography already constrains where ponds can be situated so a significant departure from the present location may not be (financially) realistic. HCM should be required to conduct extra geotechnical studies prior to the start of mine development (where „mine development‟ means development of drives). Mining should not occur until the Director has approved a wastewater management design appropriately informed by additional geotechnical investigations.

Conclusions

There remains an unacceptable level of uncertainty concerning landslip risk associated with siting of the water treatment system. The most appropriate design and location for this system must be informed by additional geotechnical investigation. Therefore, condition G8 requires the development of a water treatment infrastructure plan for the Director‟s consideration and approval. The plan must include geotechnical evidence that informs and supports the nominated design and safe siting of the water treatment system. This plan must be submitted to and approved by the Director prior to roadway development.


32

6.4 Noise and sensitive wildlife

Description

Potential habitat for several threatened fauna species, including wedge tailed eagle (WTE), masked owl and the Tasmanian devil was identified within a five kilometre radius of the intended mining activity. A Special Values Assessment (DPEMP Appendix 6) conducted by Forestry Tasmania confirmed the presence of a number of WTE nests that may be affected by HCM‟s drilling program and works to establish the above ground mining assets in particular. The Special Values Assessment also determined that:

Habitat suitable for the masked owl, eastern barred bandicoot, Tasmanian devil and quolls was present, though instances of these species were not recorded

Habitat suitable for the swift parrot and swan galaxias was not present

The Special Values Assessment includes drawing RO1-01 which illustrates the spatial relationships between HCM‟s intended drilling program, mine adit and area of major aboveground assets and mapped WTE nests. It shows eight WTE nests. The 1,000m buffer zones around four of these encircle several of HCM‟s intended drilling locations. No proposed drill sites lie within a 500m WTE nest exclusion zone. This Assessment also includes a range of recommended management actions to limit undue impacts on sensitive fauna such as the WTE. HCM commits to implementing these management actions during its drill program and mine development and operation. In doing so, HCM believes that its intended exploration, construction and mining operations will not unduly compromise the natural behaviours of sensitive fauna.

The use and operation of earthmoving machinery and other noisy (eg. drill rigs) equipment at and around the intended mine site has the potential to disturb the natural foraging and breeding behaviour of fauna species like the WTE and masked owl, to the detriment of such species.

Management measures

HCM proposed to adopt the mix of mitigation and management measures outlined in the DPEMP Section 4.7.2 to limit the potential for disruption to natural behaviours (eg. foraging and breeding) of sensitive fauna such as the WTE. For example, the point at which the overland coal conveyor projects over the coal hoppers will be designed with a high degree of noise mitigation in mind [Commitment 8]. These measures will effectively be encapsulated in a Special Values Management Plan that HCM will prepare to guide how it develops the mine site with least impact to WTE and other identified sensitive fauna [Commitment 12]. HCM also commits to establishing a forest lease agreement with FT in order to preserve all vegetation that acts to limit line of sight and noise disturbance to known WTE breeding sites in close proximity to the intended mine site [Commitment 11].


The Policy and Conservation Branch (PCAB) of DPIPWE‟s Resource Management and Conservation Division submitted that:

1. The Botanical Survey and Fauna Habitat Assessment (Assessment) was deficient due to design limitations. HCM must justify/ clarify why it considers the assessment to be a representative effort.

2. The Assessment highlights the potential for several fauna species to be present in area likely to be disturbed by mining activities but does not provide enough detail relating to actual survey methodologies adopted and area of land covered/ sampled. Specific information should be provided that addresses actual impacts to fauna and whether mitigation options are relevant /applicable for each species affected.

3. Further explanation of the results from the habitat assessment is required. The supporting report (Appendix 2) does not describe how fauna habitat was assessed nor defines the


33

criteria for the assessment.

4. It is recommended that vegetation clearance or other construction activities involving acoustic disturbance within 500m or within 1000m line of sight be avoided during WTE breeding season-unless an activity status check by a suitably qualified expert at the appropriate time confirms that the nest is not in use during that season.

5. It is recommended that drill site operations be conducted outside of the WTE breeding season (July-Feb) to minimise any impacts to nest #1112. This should be complemented by the above monitoring program.

6. It is recommended that HCM takes measures to avoid disturbing devil breeding (eg. conducting a pre-clearance survey by a suitably qualified expert prior to disturbing a potential den).

7. A pre-clearance search of mature hollow bearing trees be done by a suitably qualified expert. The survey should include a check of mature trees for hollows that may provide potential nests for masked owls and grey goshawks.

HCM responded to PCAB‟s points as follows:

Comments relating to survey methodology (1-3) HCM dealt with by liaising direct with PCAB. The outcome of this negotiation was expressed in PCAB‟s letter to HCM dated 2 April 2012 (DPEMP Supplement Appendix 4), where PCAB indicated it was satisfied with HCM‟s further efforts to clarify its survey approach.

As to PCAB‟s remaining points (4-7), HCM agreed to undertake a nest activity survey of three WTE nests identified near the intended mining site to guide its activities during mine development. HCM also reported that MRT had endorsed its exploration drilling program after considering FT‟s Special Values Assessment. HCM also agreed to undertake a pre-clearance survey of possible devil and masked owl habitat prior to any disturbance (removal) of vegetation in these areas.

Evaluation

HCM readily accepts and acknowledges that its exploration, construction and day to day mining operations have the potential to disturb the natural behaviours of sensitive fauna, especially those species identified through the Botanical Survey and Fauna Habitat Assessment (DPEMP Appendix 2) and Special Values Assessment (DPEMP Appendix 6). As noted at Management measures above, HCM has agreed to prepare a Special Values Management Plan to guide how its intended mining activity should proceed with least undue impact to sensitive fauna [Commitment 12]. This approach is supported. HCM‟s undertaking to negotiate a Forest Lease with FT to expand the present informal reserve in and around the intended mine site as a means to offset any habitat loss caused by the mining activity [Commitment 11] is also considered worthwhile. This arrangement is expressed in FT‟s letter to HCM dated 15 June 2012 (DPEMP Supplement Appendix 9).

As noted at Public and agency comment above, HCM has also agreed to conduct a number of surveys (eg. WTE nest activity) and provide the results to the Director prior to major on-ground works. Such studies are considered critical to informing how mine development best proceeds with least undue impact to sensitive fauna. These requirements will be specified by environmental condition.

Conclusions

Given that habitat suitable for several threatened species (eg. Tasmanian Devil) has been identified at the intended mine site, appropriate pre-clearance surveys must be conducted. This requirement is reflected in condition FF3. Similarly, to limit acoustic disturbance of WTEs, vegetation removal or other construction activities within 500m or 1,000m line of sight of WTE nests must be avoided during WTE breeding season, unless an activity status check at the appropriate time indicates that the nest is not in use during that season (condition FF2).


34

7 Other environmental issues

In addition to the key issues, the following environmental issues are considered relevant to the proposal and have been evaluated in Appendix 1.

Issue 1: Air emissions

Issue 2: Noise

Issue 3: Solid wastes

Issue 4: Biodiversity & conservation

Issue 5: Weed management

Issue 6: Heritage (European)

Issue 7: Heritage (Aboriginal)

Issue 8: Visual aspects

Issue 9: Traffic

Issue 10: Dangerous substances

Issue 11: Climate change & sustainability

Issue 12: Mine closure & rehabilitation


36

9 References

CBM Sustainability Group Pty Ltd (Dec 2011), Fingal Tier Coal Project DPEMP

CBM Sustainability Group Pty Ltd (July 2012), Fingal Tier Coal Project DPEMP Supplement


37

10 Summary of appendices

Appendix 1 Assessment of other environmental issues

Appendix 2 Summary of issues raised by public and agency submissions

Appendix 3 Permit Conditions - Environmental, includes DPEMP Commitments at Attachment 2

Appendix 1


38

Appendix 1 Assessment of other environmental issues

21

Rail spur will be subject of separate development application and assessment.

Issue 1

Air emissions

Description of potential impacts

There may be one primary stationary source of air emissions; two diesel gen sets at max 1MW generating capacity each installed to power mine ventilation system, underground machines and aboveground services. HCM‟s preference is to have „Stage 1‟ electricity supply in place before roadway development starts, which will obviate the need for gen sets.

Primary source of day to day emissions to air will be vehicular, namely diesel fuelled construction machinery and truck and trailers that will transport a) waste rock and b) coal from site to a) waste rock dump and b) proposed rail spur respectively.

21 Use of service and utility vehicles underground will also be a source of

emissions to air. All major underground mining equipment (continuous miners, shuttle cars, conveyors) will be electric and not a source of direct emissions to air.

Vehicular movements have the potential to create and spread dust and will also emit combustion products of diesel to air. If installed, then the gen set will emit combustion products of diesel to air on the limited occasions it is used.

Aside from vehicular generated dust, coal dust may emanate from underground processes and during hopper loading and discharge.

During construction activities temporary stockpiles of topsoil and subsoils may be formed. These are likely to be a dust source especially during prolonged dry conditions.

Uncontrolled emissions to air from mining activities have the potential to degrade overall air quality to the detriment of human health and health of local fauna and flora.

Management measures proposed in DPEMP

HCM indicates that it will minimise diesel consumption (and thereby air pollutants from this fuel type) primarily by using electric mining equipment wherever practicable [Commitment 2]. HCM also commits to using service and utility vehicles and truck and trailers that are „fuel efficient‟ and which will be „kept in optimal running order.‟ HCM states that indirect air emissions associated with provision of onsite electricity should be relatively low in a national context given hydro generation‟s low CO2 emission factor. HCM expects emissions from gen set (if installed) to be low due to limited periods of gen set use.

HCM will control coal dust underground by:

Adjusting moisture content of extracted coal to slightly above „dust extinction moisture level‟. According to HCM this is conventional and effective method to suppress fugitive coal dust during movement of coal to surface, loading and transport to proposed rail spur [Commitment 3]

Capturing and settling dust in sumps as necessary

Balancing ventilation air quantities and velocities to limit dust movement

Fitting ventilation shafts with filters if deemed necessary

HCM intends to control dust arising from heavy vehicle movement (on gravel sections of Valley Rd and unsealed mine tracks) with a water cart. HCM also intends to instigate a regular program of road maintenance to limit road degradation and airborne dust from traffic.

HCM states that established dry sclerophyll forest at intended mine site and around Valley Rd is also likely to mitigate spread of dust arising from day to day mine operation.

Appendix 1


39


EPA Division requested that HCM include a commitment to have a water cart available at all times to limit prospect of dust during movement of mining vehicles/ machinery on unsealed roads. HCM agreed to this request. EPA Division also requested more detail about HCM‟s proposed measures to suppress dust underground, particularly from ventilation system. HCM included more information about this in DPEMP Supplement.

Evaluation

Use of underground mining equipment is likely to be most intensive day to day activity at intended mine site. Use of electric continuous miners, shuttle cars, conveyors and other electric operated equipment to extract and move coal [Commitment 2] is supported. Use of electric operated machinery will help limit degradation of local air quality.

HCM‟s undertaking to use fuel efficient service and utility vehicles and maintain these in optimal working order is supported. Provided that HCM implements this undertaking the impact of diesel combustion products on local flora and fauna and near (human) neighbours is not likely to be measurable or present long term concerns. If installed, then gen set will only operate for a short period prior to verifying mains connection. As such, impacts associated with this source of air emissions are again not likely to present ongoing concerns or unduly degrade local air quality.

HCM‟s intended mitigation measures to control coal dust underground are fit for purpose and provided properly implemented will achieve desired outcome. It is noted that coal is likely to contain moderate water content at point of extraction which should act as an inherent dust retardant.

HCM‟s proposed control methods to limit generation and spread of vehicular/ machinery derived dust are considered satisfactory and should be effective provided implemented as stated. Intended mine‟s location in reasonably dense dry sclerophyll forest is likely to afford some resistance to widespread distribution of dust created by construction and day to day mining activities. Given that HCM has not nominated any control measures to avoid or limit dust from any temporary soil stockpiles, this requirement will be specified by environmental condition.

Conclusion

HCM should comply with standard conditions A1 (covering of vehicles), A2 (dust from traffic areas) and A3 (control of dust on The Land) in addition to Commitments 2 and 3.

Appendix 1


40

Issue 2

Noise


Noise associated with exploration, construction and day to day mining operations has the potential to cause nuisance to near neighbours.

22


Nearest noise sensitive neighbours occur about 4km away from the intended mining activity. Nearest neighbours in the Fingal township are about 5km distant from the intended mine site.

To limit undue noise impacts on sensitive neighbours, HCM intends to implement the mitigation measures outlined in DPEMP Part 4.5.4. Primarily, HCM intends to take advantage of the natural terrain by placing mine assets such as overland coal conveyor and coal hoppers in „depressions‟ or by using other existing landform features that will shield neighbours from mining operations. For example, the existing fingerdump provides a significant topographic barrier to the south and west of the coal loading area. HCM believes that upgrades to the surface of selected sections of Valley Rd and diligent maintenance will significantly mitigate undue noise associated with vehicle movement.

Aside from undertaking to ensure that the point at which the conveyor projects over the coal hoppers is designed with a high degree of noise suppression in mind [Commitment 8], there are no other specific commitments for noise mitigation.


None.

Evaluation

The nearest noise sensitive neighbours lie well outside the standard recommended attenuation distances associated with a mining activity. Furthermore, operations likely to produce most noise in terms of sound pressure levels and duration-namely loading of hoppers, trucks and then truck movements-will be located in an area well shielded by both a fingerdump and naturally sloping, vegetated terrain. The other significant noise source, continuous miners, will be located underground and consequently not present a concern to aboveground neighbours.

Mine development phase (eg. establishing drives, upgrading access tracks, clearing vegetation to place mine assets) is likely to be associated with the most concentrated period of noise, aside from the ultimate day to day loading and transport of coal. Mine development phase will largely involve vegetation clearing, earthmoving, transport and construction operations over a period of at least 12months. Activities will largely be confined to either well screened terraces (eg. coal load out area) or gullies within about a 500m radius of the mine site‟s nominal centre. Construction and filling of waste rock dump adjacent Abrahams Pit is expected to occur over about six months. This site is well removed from sensitive neighbours (over five kilometres) and surrounded by eucalypt forest. While mine development is likely to be associated with a significant level of noise, the intended mine site‟s isolation from neighbours and favourable topographic screening should serve to negate instances of nuisance noise.

Mine operational noise (eg. from conveying, loading and transporting coal) is likely to be dominated by coal loading and transport. As indicated above, favourable topographic shielding and considerable distance from neighbours is likely to negate instances of nuisance noise from this unit operation. Intended improvements to road surface of Valley Rd are also likely to mitigate transmission of noise caused by wheel vibration and rolling contact.

On balance, intended mine‟s remoteness, favourable (ie noise shielding) topography and lack of aboveground coal processing assets suggest explicit noise conditions are not necessary. Recourse via s53 of EMPCA (offence causing nuisance) is considered appropriate in this instance.

Conclusion

No specific noise conditions are considered necessary. HCM should comply with Commitment 8.

22

Potential affects of noise on behaviour of sensitive fauna discussed in this report Part 6.4.

Appendix 1


41

Issue 3

Solid wastes23


Solid wastes are expected in the form of general refuse, construction and industrial waste (eg. packaging materials, waste oils and lubricants), grease from interceptor traps and silt from water improvement ponds.

These materials may contaminate land, surface and ground waters in the proximity of the intended mine if not properly managed.


HCM intends to establish contracts with appropriate provider(s) of waste management services to deal with containment and disposal of solid waste materials. This undertaking is embodied in Commitment 10.


None.

Evaluation

HCM‟s commitment to employ the services of suitable waste management provider(s) is an acceptable way to minimise the likelihood that solid wastes contaminate land, surface and ground waters in the immediate surrounds of the intended mine site.

Conclusion

No specific conditions to manage waste (other than waste rock) are considered necessary. HCM should comply with Commitment 10.

23

Excludes interburden (waste rock).

Appendix 1


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Issue 4

Biodiversity & nature conservation24


Vegetation type is dry sclerophyll forest dominated by E.amygdalina. Much of intended mining area disturbed by previous mining activity. Survey noted presence of several introduced species including Cirsium vulgare (spear thistle), Hypochoeris radicata (rough catsear), Agrostis capillaris (bentgrass) and Anagallis arvensis (common pimpernel).

HCM‟s field survey did not record any instances of threatened flora species. Survey authors GHD also concluded that the study area did not contain habitat likely to support threatened species identified within 5km of the intended mine site by Natural Values Atlas.

HCM estimates that an area less than 5ha (includes transmission line easement) is likely to be cleared to allow installation of major site infrastructure. Less than 1ha of this is forecast to be threatened community E.amygdalina on sandstone. At proposed waste rock dump site, less than 1ha forecast for clearing. HCM expects that mine development and day to day operations will not compromise any floral biodiversity values.

Large scale or indiscriminate removal of vegetation has the potential to unduly affect floral populations, especially threatened species.


To limit vegetation removal and associated impacts, HCM intends to develop as much aboveground mining infrastructure as possible on previously disturbed land. Eg. upgrade existing access tracks, locate coal hoppers on minimally vegetated terrace near old fingerdump. HCM also intends to negotiate a Forest Lease with FT (refer this report Part 6.4) to offset forecast habitat loss and provide better „line of sight‟ protection for WTE nesting sites [Commitment 11].

Of relevance to biodiversity & nature conservation is fire frequency and intensity. HCM commits to developing a Fire Management Plan in consultation with FT and Tasmania Fire Service [Commitment 17].


PCAB provided feedback, refer Appendix 2.

Evaluation

Original Botanical Survey and Fauna Habitat Assessment (August 2011) and follow up botanical field survey (March 2012) did not identify any threatened floral species. One threatened community (E.amygdalina on sandstone) was identified. HCM‟s intent to build and locate major aboveground mining assets on previously disturbed land to the greatest extent possible, thereby minimising loss of habitat and unreasonable impacts to flora (and fauna) species is supported. HCM‟s intent to create a new Forest Lease with FT to offset forecast habitat loss is also considered worthwhile.

PCAB‟s assessment (of HCM‟s flora and fauna surveys) that works associated with the intended mining activity are „unlikely‟ to affect threatened flora or fauna species is noted.

Overall, intended mining activity poses little risk of serious or material harm to floral biodiversity and conservation values provided that HCM implements stated management measures and commitments.

Conclusion

HCM should comply with non-standard conditions FF1 (vehicle washdown), FF2 (WTE and vegetation clearance) and FF3 (pre-clearance surveys) in addition to Commitments 11 & 17.

24

Flora only. Fauna dealt with in this report Part 6.4.

Appendix 1


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Issue 5

Weed management


As indicated at Issue 4 above, botanical field surveys identified several introduced plant species within the intended mining area. No declared weed species were identified by either original (August 2011) or follow up (March 2012) survey. Similarly, no evidence of Phytophthora cinnamomi was detected.

During mine construction, increased vehicle traffic to/ from site increases the risk of introducing or spreading weeds and diseases such as P. cinnamomi to site vegetation.


HCM intends to instigate following mitigation measures during construction to minimise possibility of introducing new weeds or P. cinnamomi to site:

Wash down all vehicles and machinery prior to site entry, in accordance with NRM South‟s field hygiene manual 2010

Monitor/ survey for weeds and P. cinnamomi during mine development and construction

In the event P. cinnamomi is detected on site, manage impacts as per DPIPWE‟s Interim Phytophthora cinnamomi Management Guidelines 2005

HCM also undertakes to incorporate ongoing weed and disease mitigation measures (consistent with NRM South‟s field hygiene manual 2010 and DPIPWE‟s Interim Phytophthora cinnamomi Management Guidelines 2005 respectively) into its Site Environmental Management Plan [Commitment 19].


None.

Evaluation

It is noted that botanical field surveys did not identify any declared weeds species or evidence of P. cinnamomi. HCM‟s proposed mitigation measures are considered appropriate to limit introduction and/ or spread of weeds and diseases at intended mine site.

Conclusion

As previously indicated, HCM should comply with non-standard condition FF1 (vehicle washdown), which mirrors Commitment 19.

Appendix 1


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Issue 6

Heritage (European)


HCM‟s Stage 1 Heritage Report identified that properties Cullenswood [PID 6408349] and Killymoon [PID 6413156] fall within exploration lease area and a small section of Killymoon falls in initial mining area. HCM does not intend to mine outside the area shown in Stage 1 Heritage Report„s Figure 1 and this activity will occur well below surface with little or no impact aboveground. All aboveground works will be contained in mine development footprint located about five kilometres west of Killymoon property boundary.

No sites on the Tasmanian Heritage Places Inventory or the Register of the National Estate were located within close proximity of the intended mine site.

Stage 1 Heritage Report identified several features of interest within the study area, considered examples of mid-20th century coal mining heritage and possessing a degree of historical value. This included remnant mining machinery, vehicle bodies, other remnant materials and refuse.

Mining activity has the potential to damage or degrade items of heritage value if poorly planned and executed.


HCM commits to prepare a heritage management plan to manage relocation of portable remnant mining equipment to areas that are not designated for disturbance [Commitment 13]. The Plan will also guide how to conduct construction activities to limit undue impacts to non-portable mining heritage items such as adits, finger dumps and track cuttings.

Subject to agreement by relevant parties (eg. Heritage Tasmania, Council), HCM wishes to move all the site‟s portable mining equipment to an off-site location where it can be publicly displayed (eg. local interpretation centre).


None.

Evaluation

HCM‟s intended mining activity will not unduly affect the heritage values of either Killymoon or Cullenswood properties. HCM‟s commitment to produce a heritage management plan as outlined above is supported.

Conclusion

HCM should comply with non-standard condition G7 (prepare heritage management plan), which mirrors Commitment 13.

Appendix 1


45

Issue 7

Heritage (Aboriginal)


Aboriginal field survey at intended mine site identified two single artefact sites („scatters‟) and an area to south of development considered as having potential to hold archaeological deposits. Survey concluded that intended mining area likely to have low archaeological significance. At time of writing, cultural significance of site still being assessed.


If necessary, HCM will seek a permit under Section 14 of the Aboriginal Relics Act 1975 concerning suitable approach to preserve isolated scatterings identified in field survey.

Other measures include preserving area south of conveyor line and developing an Aboriginal Heritage Management Plan (Commitment 14). This plan will identify scale and scope of future investigation works and/or salvage as well as strategies to deal with any unanticipated identification of Aboriginal relics.


None.

Evaluation

Preparation of an Aboriginal Heritage Management Plan (Commitment 14) in consultation with AHT is supported. HCM should also apply for a permit under Section 14 of the Aboriginal Relics Act 1975 where mining works are likely to affect known areas of archaeological value.

Conclusion

No specific conditions concerning Aboriginal heritage are considered necessary. HCM should comply with Commitment 14.

Appendix 1


46

Issue 8

Visual aspects


HCM considered magnitude of visual impacts of any elevated mining assets when viewed from Esk Highway. Visual impact is limited to aboveground infrastructure, including administration and workshop buildings, aboveground conveyor, coal hoppers and power lines. HCM states that none of this infrastructure will be constructed higher than existing vegetation canopy. HCM expects that no aboveground mining assets will be visible from Esk Highway.

Mining assets such as conveyors, hoppers and stockpiles have potential to degrade visual amenity in the absence of suitable management controls.


Site variance in topography will allow HCM to locate key aboveground infrastructure in dips, hollows and terraces and effectively screen these from Esk Highway.

HCM will colour external surfaces of aboveground infrastructure in tones similar to surrounding vegetation and natural features to further limit any undue visual affects of aboveground mining assets [Commitment 15].


None.

Evaluation

Provided that HCM locates its aboveground mining assets as intended (as illustrated in DPEMP drawing C3-01 Site Plan) and colours assets to blend with surrounding vegetation types, then assets are unlikely to be visible from Esk Highway.

Conclusion

No specific conditions are recommended for visual affects. HCM should comply with Commitment 15.

Appendix 1


47

25

Excludes affects of traffic noise on sensitive receptors (refer this report Part 6.4 and Issue 2.

Issue 9

Traffic25


HCM‟s Traffic Impact Assessment (TIA) (DPEMP Appendix 1) shows that intended mining activity will substantially increase traffic flow along Valley Rd between Esk Highway and juncture of Valley Rd with mine access track. TIA determined that this section of Valley Rd would require significant upgrade, including new signage and dedicated maintenance program, in order to cater for projected increase in traffic intensity. Construction and filling of waste rock dump will also be a period of significant heavy vehicle movement along Valley Rd to Abrahams Pit (about five kilometres further into the Tier).

Significant increase to heavy vehicle movement on Valley Rd during mine construction and day to day operation will:

Degrade road surface and decrease time needed between maintenance and/or reconstruction works

Increase likelihood of both single vehicle and opposing vehicle accidents on Valley Rd and intersections with Esk Highway, mine access track

Create dust and noise that may cause environmental nuisance and disturb natural behaviours of local wildlife. Dust may also impede natural growth (photosynthesis and respiration) of local flora, especially those plants at verge and thereabouts


HCM intends to develop a Traffic Management Plan to guide traffic behaviour at mine site and along Valley Rd [Commitment 18]. HCM has also agreed to upgrade Valley Rd to 6.2m wide (excluding table drains) sealed pavement between Esk Hwy intersection and mine access road. This agreement is expressed in 15 June 2012 FT letter (DPEMP Supplement Appendix 9). HCM indicates sealing of this section of Valley Rd will alleviate need for ongoing dust suppression and should also reduce likelihood of undue noise and vibration from surface contact with wheels.


None.

Evaluation

FT is custodian of Valley Rd and as such is responsible for negotiating suitable conditions of use with HCM, including any works to upgrade/ improve section between Esk Highway and mine access track particularly. Preliminary outcomes of HCM‟s negotiation with FT as expressed in FT letter dated 15 June 2012 (DPEMP Supplement Appendix 9) are noted and supported. It is noted that DIER will negotiate an acceptable speed limit over Valley Rd between Esk Highway and mine access track with HCM during detailed engineering phase of development.

Sealing and widening Valley Rd between Esk Highway and mine access track should negate need for dust suppression on this section, decrease prospect of undue noise from rolling contact and improve ability to brake safely. HCM‟s undertaking to produce a Traffic Management Plan [Commitment 18] is considered worthwhile.

Conclusion

No specific conditions are considered necessary for traffic management. HCM should comply with Commitment 18.

Appendix 1


48

Issue 10

Dangerous substances


HCM indicates that it will transport fuel (diesel) for construction machinery to the intended mine site as necessary by fuel tanker. HCM expects maximum volume of fuel onsite during construction will be 2,000L and that fuelling of construction machinery will be done through hand held nozzle. Machinery will be fuelled at area designated as „lay down area‟ in drawing C3-01 Site Plan. HCM estimates that max likely loss of diesel during a fuelling event (construction phase) about ten litres.

For day to day operations, HCM intends to install a permanent diesel fuel tank of about 5,000 L at a location adjacent to workshop building (DPEMP Appendix 7 drawing A3-02). Tank will be contained within a suitably sized and impermeable bund.

HCM will store small quantities of oils, lubricants and other consumables in workshop for machinery servicing requirements.

HCM states that no explosives or blasting equipment will be required to develop and operate the coal mine.

Potential for fuel spills and leaks exists. Uncontrolled loss of dangerous substances such as hydrocarbons can infiltrate, contaminate and damage surface and ground water and soil ecosystems.


HCM intends to have appropriate (eg. hydrocarbon) mobile spill kits onsite for duration of construction. Company also commits to produce-prior to construction-a Safety and Environmental Management Plan (SEMP) that will specify procedures for fuelling of machinery and service vehicles and how best to manage events involving loss of dangerous substances such as liquid hydrocarbons [Commitment 16].

As indicated, bulk diesel tank will be contained within an impervious bund in a secure storage area adjacent

to workshop. Self-bunded „trans‟ tank of 5,000L will be matched to concrete refuelling slab, graded to a triple interceptor pit. A permanent spill kit and appropriate fire fighting equipment will also be stored in

close proximity to this location.

Small (<20L per container) quantities of oils, lubricants and other consumables will be stored in a locked, vented cabinet in workshop area and in accordance with MSDS requirements.

HCM intends to have available at water improvement ponds hydrocarbon skimming booms or similar to help remove any fuels or oils that may spill and wash/ be pumped into the ponds.


None.

Evaluation

HCM‟s proposed management measures to limit potential for site contamination by dangerous substances are fit for purpose provided implemented properly. Measures will be specified by environmental condition.

Preparation of a SEMP prior to any construction activity is supported and will be specified by condition.

Very localised hydrocarbon contamination of soils could occur if max spill event described by HCM occurs during machinery fuelling (construction phase). Acute and/ or long term environmental harm is unlikely provided that fuelling is supervised and spill kits promptly deployed.

Conclusion

HCM should comply with standard conditions for dangerous substances H1 and H2.

Appendix 1


49

26

Diesel usage and therefore associated GHG emissions expected to be moderately higher due to truck movement of waste rock to waste rock dump and machinery involved in building and filling waste rock dump. This consumption and associated emission was not calculated and included in DPEMP or Supplement.

Issue 11

Climate change & sustainability


HCM states that primary emission sources of greenhouse gases during operation of intended mine will be electricity and diesel usage respectively. HCM estimates total electricity usage at about 7,500 MWh/yr and diesel at about 500kL/yr. Associated GHG emissions are estimated at around 3,600 t CO2-e/yr.

26 HCM

considers GHG emission footprint of its intended mine to be relatively minor in national context.

Uncontrolled emissions of GHGs may contribute to global climate change.


Refer Issue 1.


None.

Evaluation

Refer Issue 1. HCM has not made any specific management commitments about climate change and sustainability.

Conclusion

No specific conditions for climate change and sustainability are proposed.

Appendix 1


50

Issue 12

Mine closure & rehabilitation


DPEMP Part 6 (pp 100-104) outlines HCM‟s intended mine closure and rehabilitation methodology in general terms.

Unchecked or abandoned mining activities have potential to impart legacy issues for immediate and surrounding environment, primarily persistent contamination of surface and ground waters.


As indicated above, HCM‟s broad mine closure and rehabilitation approach is detailed in DPEMP Part 6 (pp 100-104). Proposed management methods are primarily oriented at preventing or limiting ongoing contamination of surface and ground waters in addition to creating safe site conditions (eg. removal of mining infrastructure, closing mine adits). HCM commits to produce a SEMP that will consider mine closure in general terms. HCM commits to produce a more targeted and comprehensive Mine Closure Plan within two years of mine commencement [Commitment 21] (should Council grant a permit).


MRT requested that HCM produce a „mine closure plan‟ within two years of mine initiation. HCM has agreed to his request (Commitment 21).

Evaluation

HCM‟s broad approach for mine closure and rehabilitation as detailed in DPEMP Part 6 (pp 100-104) is considered satisfactory. Closure and rehabilitation requirements will be specified by condition. HCM‟s commitment to produce a „mine closure plan‟ within two years of intended coal mine commencing (in the event that Council grants a permit) is supported. This arrangement will also be specified by condition.

Conclusion

HCM should comply with standard conditions DC1 (notification of cessation), DC2 (topsoil stockpiles), DC3 (temporary suspension of activity), DC4 (mine closure plan) and DC5 (decommissioning and rehabilitation plan) in addition to Commitment 21.

Appendix 2


51

Appendix 2 Summary of issues raised by public and agency submissions

Hardrock Coal Mining / Fingal Tier Coal Project A. Relevant Public Submissions Submission No. Chapter Issue Comment Further

Info req?

Environmental

1 Appendix 2 Adequacy of flora & fauna assessment

Representation 1 critical of the deficient design of the Botanical Survey and Fauna Assessment, particularly with respect to fauna assessment.

Y

2 Clearing of E. amygdalina

Representation 1 indicated that Hardrock Coal Mining (HCM) would need to prepare a Forest Practices Plan concerning intended clearing of threatened E. amygdalina forest.

N

3.2.10; Appendix 10

Land stability Representation 1 noted that Strata report (Appendix 10) indicated potential for and instability in the area proposed for mining.

Y

4.4 Groundwater Representation 1 indicated that HCM had not clearly identified and discussed possible impacts to groundwater.

Y

3.2.4 Water management

Representation 1 suggested that HCM should conduct regular testing of water emanating from the development area.

N

4.1 Greenhouse gas emissions

Representation 1 suggested that the proposed activity would in fact be a significant greenhouse gas emitter, contrary to the position stated in the DPEMP

N

2 4.2 Coal dust Representation 2 suggested that coal dust may degrade air quality around Fingal. N

Planning

1 4.9 Compatibility

with planning

Codes

Representation 1 suggests that the location of the proposed activity conflicts with the intent of sections of both the Biodiversity and Wetlands and Waterways Codes respectively.

Y

General

2 2 Nature of the mine

Representation 2 queried whether proposed mining would be confined to underground. N

Exploration lease

Representation 2 queried why „the lease‟ extends into Fingal and therefore raised the possibility of future open cut mining on the valley floor.

N

Appendix 1 Traffic safety Representation 2 queried the forecast traffic frequency/ volume on Valley Road and highlighted that there had been two fatalities on or near the Esk Highway-Valley Road intersection in recent years (events not mentioned in the Traffic Impact Assessment). Fog and frost were also raised as conditions likely to affect road safety.

Y

Appendix 2


52

B. Referral Agency Comments Agency Chapt

er Section/

page Additional information required

Environmental

DPIPWE – Heritage Tasmania

4 4.8.4/ 82 Commitment 13 - producing a Heritage Management Plan – is commended. HCM should engage an

archaeologist familiar with the Tasmanian Heritage Council‟s Practice Note 2: Managing Archaeological Significance [http://www.heritage.tas.gov.au_practice_notes.html]. This will ensure appropriate recording of features prior to their removal from the site.

4.8.4/ 83 Heritage Management Plan should include a discussion about unanticipated discoveries. The methodology outlined in Heritage Tasmania‟s Predevelopment Assessment Guidelines should be followed. Guidelines available at http://www.heritage.tas.gov.au/guidelines.html

DPIPWE – Resource Management and Conservation

3 3.2.6- Policy and Conservation Assessment Branch (PCAB) considers the Botanical Survey and Fauna Habitat Assessment (Assessment) to be deficient due to design limitations (single event during winter comprising two days only). HCM must justify/ clarify why it considers the assessment to be a representative effort.

The Assessment highlights the potential for several fauna species to be present in area likely to be disturbed by mining activities but does not provide enough detail relating to actual survey methodologies adopted and area of land covered/ sampled.

27 Specific information should be provided that addresses actual impacts to fauna and

whether mitigation options are relevant/applicable for each species affected.

Furthermore, in the event that any major infrastructure such as water improvement ponds and/ or catchment dam needs to be re-sited for geotechnical reasons (see DIER - MRT comments below), then additional survey work to determine the natural values of and recommended management measures for the area of relocation is likely to be required. Again, this work will need to be conducted and reviewed prior to issue of any final approvals of the proposed activity.

3.2.7/ 48

Further explanation of the results from the habitat assessment is required. The supporting report (Appendix 2) does not describe how fauna habitat was assessed nor defines the criteria for the assessment. Include these pieces of information in the DPEMP Supplement.

Appendix 6 It is recommended that vegetation clearance or other construction activities involving acoustic disturbance within 500m or within 1000m line of sight be avoided during WTE breeding season-unless an activity status check by a suitably qualified expert at the appropriate time confirms that the nest is not in use during that season.

Attach. 5

It is recommended that drill site operations be conducted outside of the WTE breeding season (July-Feb) to minimise any impacts to nest #1112. This should be complemented by the above monitoring program.

27 HCM should note that the standard and quality of the report should meet DPIPWE’s Guidelines for Natural Values Assessments (July

2009) [http://www.dpiw.tas.gov.au/inter.nsf/WebPages/SSKA-7UM4AN?open].

http://www.heritage.tas.gov.au/guidelines.html

Appendix 2


53

Appendix 2 It is recommended that HCM takes measures to avoid disturbing devil breeding (eg. conducting a pre-clearance survey by a suitably qualified expert) prior to disturbing a potential den.

PCAB requires that a pre-clearance search of mature hollow bearing trees be conducted by a suitably qualified expert. The survey should include a check of mature trees for hollows that may provide potential nests for masked owls and grey goshawks.

4 4.7.1/ 76 Any clearance of the threatened Eucalyptus amygdalina forest and woodland on sandstone (DAS) should be avoided wherever practicable.

Development of the Fire Management Plan outlined in the Exec Summary states that the plan will be reviewed by the Tasmanian Fire Service (TFS) and the Tasmanian Parks and Wildlife Service (TPWS). This contradicts Chapter 4 where it is stated that only the TFS will be consulted. Clarify in the DPEMP Supplement which parties will be involved in the review process. PCAB recommends that Forestry Tasmania participate in the review given it is the primary manager of the surrounding land.

DPIPWE – EPA Division

P15 The mine air ventilation system is also expected to be a source of dust emissions. HCM should discuss in the DPEMP Supplement the likelihood of dust emissions via this route and how it intends to limit these.

P15/16 While the potential for AMD is expected to be low this must be verified by mine water analysis and Acid Base Accounting. Salinity is more likely to be an issue and can be determined by leach testing. Provide and discuss these analyses in the DPEMP Supplement.

P16 Location of the intended coal stockpile must be provided, along with an estimate of dimensions and intended management measures. HCM should also clarify whether it intends to include development of the coal stockpile with its application for a new coal loading facility and rail spur.

P22 HCM should identify Forestry Tasmania as a key stakeholder.

P29 HCM must confirm the route of transmission lines to the proposed mine site and area of vegetation to be cleared. Provide a drawing of the intended power easement (including transmission infrastructure). Note that HCM will need to conduct an assessment of natural values associated with the forest marked for clearing to establish the power easement.

P31 The land identified for irrigation [drawings C3-01, C3-02 & C3-03) of wastewater from the package treatment plant does not appear to be appropriate with respect to soil type, slope and area. HCM should review and revise its irrigation plan with due regard to expected treatment performance of the package treatment plant and the need to protect water quality of ground and surface waters.

P32 Ongoing dust suppression along Valley Rd will be required as per Traffic Impact Assessment recommendation. HCM should note that a water tanker will need to be available on demand and not just limited to the summer months.

Appendices 5 & 10

Limited to desk top reviews. Reports recommend more detailed work be undertaken (Commitments 1 and 6). These additional investigations must be conducted now and results discussed via the DPEMP Supplement, particularly with respect to how the results affect the present siting of major infrastructure such as water improvement ponds and catchment dam. See also comments at DIER – Mineral Resources Tasmania. Note that a conceptual water balance is required.

Appendix 2


54

Appendix 7 H3-04 EPA Division is not supportive of first wash diversion from the proposed coal loading area. Coal handling is not expected to cease during rainfall events. Coal fines will be contained within larger coal lumps and flushed depending on rainfall intensity, duration etc. HCM should review this aspect of its intended water management strategy and if necessary include a revised measure to treat stormwater flow from the coal loading area in the DPEMP Supplement.

DEDTA

4 4.11/87-90 DEDTA highlighted that mining and mineral processing identified as priority areas in Tas Government‟s Economic Development Plan. DEDTA indicated that if revenues stated in DPEMP were realised then mine represents a significant project for NE Tasmania with substantial positive financial flow on effects for State more widely. DEDTA expressed its strong support for the mine.

DIER – Mineral Resources Tasmania (MRT)

2 2.1.1/24-27 MRT notes that the mining plan is outlined as a “strategy” and is not a specific plan. A general description of the bord and pillar mining method is provided. This section lacks the detail that is normally informed by resource definition drilling.

2.1.5/30 Within the Waste section it is stated that “there will be minimal waste interburden rock, and the coal is of sufficient quality that all extracted material is transported off-site without any processing or washing onsite.” This statement cannot yet be made as there has been no characterisation of interburden and not enough drilling has been done to properly understand the quantity of interburden or the quality of the coal. HCM must characterise the nature of the interburden and in the DPEMP Supplement discuss what the results mean in terms of measures to manage this material. A revised estimate of the quantity of interburden must also be provided.

2.1.8/31 Estimated mine production is based upon incomplete exploration results and a conceptual mine plan. Refine/ validate mine production figures by continuing and completing intended drill program (and associated exploration study) to prove the coal resource.

3 (and related Appendix 10)

3.2.10/55-57

The first two paragraphs of the Land Stability section refer to a Desktop Review of Land Stability [DPEMP Appendix 10]. The desktop review is insufficient for inclusion in a DPEMP for a proposal of this nature. A thorough onsite investigation is required to be undertaken by a suitable qualified expert in slope stability assessments of this scale. The geotechnical report must investigate potential hazards and demonstrate that [the proponent] HCM understands these and that the risks can be satisfactorily managed. It is contemporary practice for geotechnical reports to include a resume outlining the qualifications and relevant experience of the practitioner(s) involved. The proponent should have the geotechnical report peer-reviewed before inclusion into the DPEMP Supplement and subsequent submission to MRT and EPA for their consideration. Any geotechnical investigation must adequately identify and assess all potential risks. HCM must use the results of further geotechnical investigations to confirm the intended locations of key infrastructure, such as water improvement ponds and/ or catchment dam. In the event that further geotechnical studies show that key infrastructure must be relocated due to stability concerns, then HCM must submit

Appendix 2


55

appropriate details and drawings to indicate the revised locations. Additional assessment of natural values of the proposed activity‟s site may be required in the case where major infrastructure is relocated as a consequence of further geotechnical studies.

28

3.2.10/57 Commitment 1 – completion of a comprehensive geotechnical investigation including stability assessment. This study should be completed and incorporated into the DPEMP Supplement so that the proposed activity can be properly assessed based on the results and associated management measures.

4 4.3.4/69 Commitment 5 – development of a Water Management Plan. This must be completed and incorporated into the DPEMP Supplement so that the proposed activity can be properly assessed based on the results and associated management measures. The Water Management Plan underpins the site water balance, conditions for wastewater irrigation and subsequent engineering designs (water improvement ponds, culverts, catchment dam, pump sizing for dewatering…).

4.4.4/71 Commitment 6 – further hydrogeological assessments. This work must be completed and incorporated into the DPEMP Supplement so that the proposed activity can be properly assessed based on the results and associated management measures.

4.6.4/75 Commitment 9 – interburden should be properly characterised and quantified during resource drilling so that waste management strategies can be finalised and assessed in the DPEMP Supplement.

4.7.2/82 Commitment 12 – development of a Special Values Management Plan for threatened fauna species. This plan must be completed and incorporated into the DPEMP Supplement so that the proposed activity can be properly assessed.

4.14.4/95 Commitment 19 – development of a traffic management plan. This plan must be completed and incorporated into the DPEMP Supplement so that the proposed activity can be properly assessed. Also refer to comments under DIER – Roads and Traffic Division and Forestry Tasmania.

5 5.2.2 & 5.2.3/100-101

Groundwater chemistry and AMD assessment (geochemistry) needs to be done and included in the DPEMP Supplement for assessment. This relates to Commitment 22.

6 6.4/107 Commitment 23 – development of Mine Closure Plan; has open-ended timing. This commitment should be within the first 2 years of commencement. HCM must provide a preliminary Mine Closure Plan in the DPEMP Supplement. The plan must outline the intended program for decommission of site activities and assets and include cost estimates for these. Costing information must be included for decommission of major infrastructure, whether these assets are dismantled and relocated or modified and retained onsite.

Appendix 9 General comment – the contents of Appendix 9 – mining Scoping Study by GHD – identifies and confirms MRTs concerns in relation to the high level of uncertainty with respect to resource definition, high level of assumptions required to develop a mine plan and the large amount of further work required in these areas.

28 If infrastructure is relocated to areas that have not been previously surveyed, then further natural values assessment will be

necessary.

Appendix 2


56

Forestry Tasmania

4 4.13/ 92 Commitment 17 - Forestry Tasmania (FT) manages fire on State Forest, as per the Forestry Act 1920. HCM must include FT in any proposed fire mitigation works in the surrounding State Forest vegetation or during the preparation of a Fire Management Plan for non structural areas. The Tasmanian Fire Service must be consulted for structural fire mitigation within the lease area.

4.3.4/ 69- 70

FT notes that HCM will need to establish a license agreement with FT during the assessment process conducted by the Assessments Committee for Dam Construction for any dams constructed on State Forest. Offsets will need to be established for loss of production forest and reserved areas, as per FT‟s dams on State Forest policy.

4.6.4/ 75 Commitment 9 - FT confirms initial discussions have occurred with HCM concerning storage/ disposal of waste rock within FT quarries in the Valley Rd area. FT notes that it will only consider waste rock/ burden for storage/ disposal in this manner if the material is shown to be free of Phytophthora cinnamomi. HCM should note that the EPA Division will need to sight evidence of any agreement between FT and HCM concerning storage/ disposal of waste rock/ burden in FT managed quarries or borrow pits. This will need to occur prior to issue of any final approval of the proposed activity.

4.7.1/ 76 FT confirms it‟s held preliminary discussions with HCM concerning potential license agreements for sections of State Forest for use as visual screening. No formal agreement has been reached. FT notes that the map referred to in drawing EN2-04 does not reflect the present land management practices on State Forest in this area (see comments below at EN2-04 and EN2-05).

Appendix 1 TIA FT does not support the proposed GHD Traffic Management Plan. Valley Rd is classed as a public road and therefore must provide safe access for all road users, not rely on radio communication. Refer also MRT comment above.

FT will require the Valley Rd surface to be sealed to a pavement width of 6.2m (excluding shoulder width) to cater for the safe passage of the forecast volume of heavy traffic and other road users.

6 6.3/ 102 FT requests that HCM confirm in the DPEMP Supplement that mine entrances will be capped during rehabilitation.

Appendix 7 Drawing EN2-04

Map does not reflect present land management practices on State Forest. Amend drawing and include adjusted map in DPEMP Supplement.

Appendix 7 Drawing EN2-05

Map does not reflect present land management practices on State Forest. Amend drawing and include adjusted map in DPEMP Supplement.

DIER – Roads & Traffic Division

Appendix 1 TIA The TIA indicates likely on-site employee numbers of between 40 – 50 staff and notes that most would travel to / from south of the site. This could potentially generate an increase in the number of right turning traffic from Esk Main Road into Valley Road. The TIA however does not provide any information on turning movements at the Esk Main Road / Valley Road junction. Review and include these details in the DPEMP Supplement.

Appendix 2


57

Roads & Traffic Division (R&TD) requires clarification about projected turn volumes at the Esk Main Road / Valley Road junction, particularly whether or not haulage vehicles (HVs) being used to transport coal from the mine to the stockpile will be solely for this purpose and when not in operation will be parked at the mine site and HV drivers commute via light vehicle at start /end of shifts. Alternatively, will HVs be using the junction at start / end of shifts due to them being garaged elsewhere outside operating times? Please clarify.

Austroads Guide to Road Design Part 4A suggests that a BAR basic right turn facility should be provided as a minimum treatment. However until HCM can clarify/ confirm that traffic using the Esk Main Road / Valley Road junction will be limited to mostly light vehicles and occasional HV use, R&TD cannot make an assessment on whether provision of such a facility may or may not be required. Please elaborate about this in the DPEMP Supplement.

R&TD will require the Valley Road junction to be sealed nominally 20m back along Valley Road from the edge of Esk Main Road traffic lanes to mitigate the tracking of loose gravel onto Esk Main Road.

R&TD does not support use of isolated regulatory 50km/h speed control in the vicinity of the mine access as mentioned in the TIA. However provision of 40km/h regulatory speed signs for vehicles exceeding 10t may be considered over the full length of the haulage route along Valley Road. HCM should note that provision of this and any permanent warning signs (i.e. trucks turning) will require DIER approval under the Traffic Act 1925.

R&TD notes that provisions to transport the stockpiled coal to the Fingal rail line are being explored separately to this assessment. This will require assessment by DIER to ensure that the design does not adversely impact on traffic safety and operation on the Esk main Road.

Appendix 3


58

Appendix 3 Permit Conditions - Environmental

Download - Off Valley Rd, Fingal Valley Hardrock Coal Mining Pty Ltd Coal Mining EAR.pdf · Off Valley Rd, Fingal Valley Hardrock Coal Mining Pty Ltd ... The draft guidelines were considered

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